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| Start date | Site | Identified by | Title | Description | |
|---|---|---|---|---|---|
| 05000313/FIN-2018003-03 | 30 September 2018 23:59:59 | Arkansas Nuclear | NRC identified | Failure to Provide Complete and Accurate Information in a License Amendment Request to Change Emergency Action Level Requirements | The inspectors identified a Severity Level IV non-cited violation because the licensee provided inaccurate information to the NRC in a license amendment request for an emergency action level scheme change. Specifically, the licensee provided information about the availability of the postaccident sampling system building radiation monitor and the Unit 1 level instrumentation that was material to the licensing decision, but not accurate. The NRC approved an emergency action level scheme change on November 9, 2012 (ADAMS Accession No. ML12269A455) to allow Arkansas Nuclear One to adopt the Nuclear Energy Institute (NEI) 99-01, Revision 5, scheme. Subsequently, the licensee identified that two of their current emergency action level thresholds could not be implemented in accordance with their emergency classification procedure: On May 26, 2017, Condition Report CR-ANO-2-2017-03161 documented that postaccident sampling system building radiation monitor 2RX-9840 should be removed from all regulatory commitments because the postaccident sampling system had been removed from service, and its building would not be monitored for radiological releases. Radiation monitor 2RX-9840 was being used as a means to evaluate emergency action levels AU1, AA1, AS1, and AG1. In addition, it was used in the loss/potential loss of containment (CNB6) for fission product emergency action levels. The condition report noted that requirements for the postaccident sampling system had been removed from Arkansas Nuclear One licenses in August 2000 and the licensee had abandoned the systems valves (March 2003, EC-ANO-1779), removed power from the postaccident sampling system ventilation system (January 2004), and made radiation monitor 2RX-9840 nonfunctional (May 2008, Condition Report CR-ANO-2-2008-01439 and Work Order 150817). On March 15, 2018, Condition Report CR-ANO-C-2018-01121 documented that the Unit 1 level instrumentation set point used in emergency action level CA1 was below the indicating range of the instrument. The emergency action level indicated that a loss of Unit 1s reactor vessel inventory was shown by an indicated level less than 368 feet, 0 inches. Therefore, the lowest level indicated on the instrument would be higher than the level used in making the emergency classification decision. The inspectors reviewed the licensees license amendment request, dated December 1, 2011 (ADAMS Accession No. ML113350317), Proposed Emergency Action Levels Using NEI 99-01, Revision 5, Scheme, and the licensees response to a request for additional information dated July 9, 2012, (ADAMS Accession No. ML12192A090) to determine whether the conditions identified in the corrective action program existed at the time the licensee requested the license amendment and whether the request correctly described the instruments. The inspectors identified: The December 1, 2011, submittal incorrectly indicated that radiation monitor 2RX-9840 was a viable means of classifying emergency action levels AU1, AA1, AS1, and AG1, as well as providing input for the evaluation of fission product barrier emergency action levels. In the response to NRCs request for additional information (RAI) dated July 9, 2012, the licensee provided additional details about the super particulate iodine noble gas (SPING) radiation monitors used in this application. Response to Question 3 associated with emergency action levels AA1, AS1, and AG1 stated: Each SPING is associated with a particular ventilation pathway and provides continuous monitoring of air discharged via the respective release pathway. The license reviewer concluded that all of the SPING monitors included in the license amendment request were operable and continuously monitoring the specified release pathways, thereby being capable of measuring the radiation levels described in the proposed emergency action levels. 17 The December 1, 2011, submittal indicated that loss of Unit 1 reactor vessel inventory for emergency action level CA1 was a vessel level less than 368 feet, 0 inches. This issue was NRC-identified because when the licensee identified the emergency action level errors, they took action to correct the errors, but failed to address the failure to ensure that technical information provided to the NRC in support of the license amendment request was complete and accurate in all material respects. Corrective Actions: To correct the Unit 1 reactor vessel level emergency action level threshold error, the licensee issued communications regarding correct application of the emergency action level on March 15, 2018, followed by implementation of a change to Procedure OP-1903.010, Emergency Action Level Classification, Revision 56, dated June 26, 2018, with the corrected level. The use of radiation monitor 2RX-9840 is being removed from the emergency action levels as part of an emergency action level scheme change submitted to the NRC on March 29, 2018 (ADAMS Accession No. ML18088B412 and ML18094A155). In the interim, the licensee issued communications to emergency director-qualified staff members to ensure they are aware of the error, how to address it if implementing emergency action levels, and to inform them of the corrective actions in progress. Additionally, the licensee issued Condition Report CR-ANO-C-2018-03597, dated September 13, 2018, for the incomplete and inaccurate emergency action level submission examples to address the completeness and accuracy issues identified by the inspectors. |
| 05000368/FIN-2016009-04 | 30 June 2016 23:59:59 | Arkansas Nuclear | NRC identified | Failure to Adequately Establish Ignition Frequencies for the Risk-Informed Fire Protection Program | The team identified two examples of a Severity Level IV non-cited violation of License Condition 2.C(3)(b), Fire Protection, for the licensees failure to properly implement their risk-informed fire protection program and accurately capture component ignition frequencies in their fire probabilistic risk assessment. Specifically, the component ignition frequencies for air compressors and ventilation equipment were found to be lower than expected because the licensee misapplied the guidance in NUREG/CR-6850. The licensee entered this issue into their corrective action program as Condition Reports CR ANO-C-2016-2600, CR-ANO-C-2016-2528, and CR-ANO-2-2016-02356, with the intent to perform an extent of condition relating to other potential components that are misclassified in the fire ignition frequency analysis, correct the fire Ignition frequency report and the associated Fire Probabilistic Risk Assessment model calculations to incorporate the correct ignition frequency and the appropriate scenarios. The licensees failure to adequately implement the prescribed guidance in NUREG/CR-6850 to estimate the ignition frequencies for their risk-informed fire protection program was a performance deficiency. The performance deficiency was minor because the answer to all the IMC 0612, Appendix B, more than minor questions was No. The team determined that this issue was a traditional enforcement violation because it impacted the regulatory process when the only NRC-approved framework for conversion to NFPA 805 was not fully followed. The NRC determined that this violation was associated with a minor performance deficiency. The team determined that this violation was a Severity Level IV in the traditional enforcement process when comparing it to the violation examples in Section 6.1, Reactor Operations, of the NRC Enforcement Policy, specifically noting it was similar to Example 6.1.d.4 for failing to adequately assess the baseline risk of plant operations associated with implementation of a risk-informed program (NFPA 805) such that the program was implemented inappropriately. The finding did not have a cross-cutting aspect because traditional enforcement violations are not assessed for cross-cutting aspects. |
| 05000368/FIN-2015001-02 | 31 March 2015 23:59:59 | Arkansas Nuclear | NRC identified | Failure to Accurately Report Unplanned Scrams per 7000 Critical Hours Performance Indicator | The inspectors identified a non-cited violation of 10 CFR 50.9, Completeness and Accuracy of Information, for the licensees failure to provide information to the NRC that was complete and accurate in all material respects. Specifically, the Unit 2 unplanned scrams per 7000 critical hours performance indicator data submitted to the NRC for the second and third quarters of 2014 was inaccurate. The performance indicator data submitted did not include a Unit 2 plant scram that occurred on April 27, 2014. When the second quarter and third quarter 2014 data was corrected and submitted to the NRC on March 4, 2015, the unplanned scrams per 7000 critical hours performance indicator transitioned from Green to White. The issue was entered into the licensees corrective action program as Condition Report CR-ANO-2-2015-00362. The licensee failed to provided information to the NRC that was complete and accurate in all material respects, as required by 10 CFR 50.9. The NRCs significance determination process (SDP) is not designed to assess the significance of violations that impact or impede the regulatory process. Therefore, the issue of two quarterly submittals of discrepant unplanned scrams performance indicator data was assessed using the traditional enforcement process in accordance with the Enforcement Policy. The inspectors determined the violation to be at Severity Level IV, because the licensee submitted inaccurate performance indicator data to the NRC that would have caused the performance indicator to change from Green to White (Enforcement Policy example 6.9.d.11). Traditional enforcement violations are not assigned a cross-cutting aspect. |
| 05000313/FIN-2012405-01 | 30 June 2012 23:59:59 | Arkansas Nuclear | NRC identified | Security | |
| 05000313/FIN-2012002-02 | 31 March 2012 23:59:59 | Arkansas Nuclear | NRC identified | Failure to Update the Safety Analysis Report with Adequate Details Relative to its Solid Radwaste Equipment, Processes, and Facilities | Inspectors identified a non-cited violation of 10 CFR 50.71(e), Maintenance of Records, because the licensee failed to update their Safety Analysis Report with adequate details and submittals that include the effects of changes made to the facility. Specifically, the licensee built numerous low level radwaste storage facilities on the owner controlled area for interim radwaste storage of dry and solidified radioactive waste and failed to update the Safety Analysis Report to adequately include these changes to equipment, processes, and facilities. This issue was entered in the licensees corrective action program as Condition Report CR-ANO-C-2012-00749. This issue was dispositioned using traditional enforcement because it had the potential for impacting the NRCs ability to perform its regulatory function. The performance deficiency is more than minor, thus characterized as a finding, because it has a material impact on licensed activities in that solid radwaste equipment and processes, as well as stored radwaste materials with a significant radioactive source term, have not been adequately described and maintained in all licensee records and reports. There was no cross-cutting aspect associated with this finding because it was dispositioned using traditional enforcement. This finding is characterized as a Severity Level IV non-cited violation in accordance with NRC Enforcement Policy, Section 6.1 and was treated as a non-cited violation consistent with Section 2.3.2.a of the NRC Enforcement Policy |
| 05000313/FIN-2010005-02 | 31 December 2010 23:59:59 | Arkansas Nuclear | NRC identified | Failure to Submit for Approval a Decrease in Effectiveness of Emergency Plan | The inspectors identified a noncited violation of 10 CFR 50.54(q) for the failure to apply for and receive approval by the NRC prior to implementing a change that decreased the effectiveness of the Arkansas Nuclear One Emergency Plan. Specifically, the licensee changed the default Protective Action Recommendation from a 2-mile radius and 5 miles downwind for General Emergency conditions to a 5-miles radius and 10 miles downwind which was determined to be a change that decreased the effectiveness of the approved emergency plan and was implemented without application to and approval by the Commission. Because the violation was entered into the licensees corrective action program as Condition Report CR-ANO-C-2010-02502, it is being treated as a noncited Severity Level IV violation consistent with Section 2.3.2 of the Enforcement Policy. The failure to submit, for approval, a change to the Arkansas Nuclear One Emergency Plan that decreases emergency plan effectiveness is a performance deficiency. The finding is more than minor because the change made has the potential to unnecessarily increase the risk to the public. Because this issue has the potential for impacting the NRCs ability to perform its regulatory function, traditional enforcement is applicable in accordance with NRC Inspection Manual Chapter 0612, Appendix B, Issue Screening. The finding was determined to be a Severity Level IV violation in accordance with Section 6.6.d.1 of the Enforcement Policy because it involved the licensees ability to meet or implement any regulatory requirement not related to assessment or notification such that the effectiveness of the emergency plan decreases. This violation of NRC requirements occurred on March 13, 2003, no crosscutting aspect is assigned to this finding because it is not indicative of current performance. |
| 05000313/FIN-2009005-05 | 31 December 2009 23:59:59 | Arkansas Nuclear | NRC identified | Failure to Report a Safety System Functional Failure | The inspectors identified a noncited violation of 10 CFR 50.73, Licensee Event Report System, associated with the licensees failure to submit a licensee event report within 60 days following discovery of an event meeting the reportability criteria as specified. Specifically, on September 22, 2009, the licensee completed their analysis of an issue associated with degradation of the latching mechanism of a station high energy line break door. The licensee determined that an unanalyzed condition may have existed for the period that the door was unlatched. The licensee reported the unanalyzed condition per 10 CFR 50.73. The licensee further determined that, due to this door latch issue, a main feedwater pipe critical crack high energy line break event would force the door open which would create a harsh environment in the adjoining emergency feedwater pump room, which would result in both trains of emergency feedwater being inoperable. The licensee determined that this was a safety system functional failure. Based on this, the inspectors determined that this condition was reportable per 10 CFR 50.73(a)(2)(v) since this resulted in a condition which affected both trains of a system described in the Safety Analysis Report that was needed to mitigate the consequences of an accident. Although the licensee submitted the licensee event report indicating that Unit 1 was in an unanalyzed condition, they failed to report the safety system functional failure aspect. The licensee entered this issue into their corrective action program as Condition Report CR-ANO-C-2009-2590 |
| 05000313/FIN-2009005-06 | 31 December 2009 23:59:59 | Arkansas Nuclear | NRC identified | Failure to Notify the NRC with 8 Hours of a Nonemergency | The inspectors identified a noncited violation of 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors, for the licensees failure to notify the NRC Operations Center within 8 hours following discovery of an event meeting the reportability criteria as specified. Specifically, on September 22, 2009, the licensee initiated a 10 CFR 50.72 (b)(3)(xiii) 8-hour nonemergency report at 12:46 p.m. CST to the NRC Operations Center based on an event time of 5:11 a.m. Operations staff notified the resident inspectors of the 8-hour event notification to the NRC Operations Center later that afternoon. The inspectors questioned whether the timing of the NRC notification met the requirements of the applicable regulation. The inspectors determined that the initial loss of power to the emergency offsite facility occurred at approximately 10:40 p.m. on September 21, 2009, the emergency offsite facility diesel generator K8 started but failed to supply power to the facility, and this was reported to the control room at 11:45 p.m. on September 21, 2009. Normal power was restored at 4:20 a.m. Due to the time that the emergency offsite facility was degraded, this was considered a major loss of assessment, communications, and response capability, and the licensee initiated a 10 CFR 50.72 (b)(3)(xiii) 8-hour nonemergency report, but not within the 8-hour reporting period of the discovery. The licensee entered this issue into their corrective action program as Condition Report CR-ANO-C-2008-2024. The failure to report an applicable nonemergency 8-hour event notification report within the required time frame was determined to be a performance deficiency. The finding was determined to be applicable to traditional enforcement because the NRCs ability to perform its regulatory function was potentially impacted by the licensees failure to make a required notification within the specified time frame. The finding was not suitable for evaluation using the significance determination process and was therefore evaluated in accordance with the NRCs Enforcement Policy. The finding was reviewed by NRC management and was determined to be of very low safety significance (Severity Level IV) consistent with the NRC Enforcement Policy. The cause of this finding was determined to have a crosscutting aspect in the area of human performance associated with resources (H.2(c)) in that the licensee failed to have complete and accurate procedures to properly evaluate problems when faced with unexpected condition |
| 05000313/FIN-2009007-02 | 30 September 2009 23:59:59 | Arkansas Nuclear | NRC identified | Failure to Provide Accurate Information in Response to Generic Letter 2007-01, Inaccessible or Underground Power Cables Failures that Disable Accident Mitigation Systems or Cause Plant Transients | The team identified a noncited violation of 10 CFR 50.9, Completeness and Accuracy of Information, which states in part that information required by statute or by the Commissions regulations, orders, or license conditions to be maintained by the applicant or the licensee shall be complete and accurate in all material respects. Contrary to the above, the licensees May 7, 2007, response to Generic Letter 2007-01, Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients, did not accurately describe the licensees programs, procedures, or practices for inspection, testing, and monitoring programs to detect the degradation of inaccessible or underground power cables that support emergency diesel generators, offsite power, essential service water, service water, component cooling water, and other systems that are in the scope of 10 CFR 50.65, The Maintenance Rule. The licensee asserted in their response to Generic Letter 2007-01, Question 2, that ANO inspection, testing, and monitoring practices presently include visual cable inspection during routine operations, periodic meggering of cables and connected equipment associated with maintenance activities, and periodic inspection of manholes for dewatering. In fact, there was no evidence that these manholes or cables had ever been periodically or routinely inspected for Unit-1, and none of the cables for either of the units were being routinely inspected as the licensee had asserted. The finding was more than minor because the information was material to the NRCs decision making processes. In accordance with Inspection Manual Chapter 0612, Power Reactor Inspection Reports, the violation was subject to the traditional enforcement process because 10 CFR 50.9 violations impact the NRCs ability to perform its regulatory function. Using the Enforcement Policy, Supplement VII, Miscellaneous Matters, the inspectors characterized the violation as a Severity Level IV violation because it did not meet the Severity Level I, II or III criteria. NRC management reviewed the finding and determined that it was of very low safety significance. Because the violation was of very low safety significance and was entered into the licensees corrective action program as Condition Report CR-ANO-C-2009-1415, this violation is being treated as a noncited violation, consistent with the NRC Enforcement Policy, Section VI.A. The inspectors determined that the finding has a crosscutting aspect in the area of problem identification and resolution in that the licensee failed to implement operating experience directly communicated with a generic letter through changes to station processes, procedures, and equipment (P.2(b)) |
| 05000313/FIN-2007005-07 | 31 December 2007 23:59:59 | Arkansas Nuclear | NRC identified | Communication of an NRC Inspectors Presence by Security Personnel | The inspectors identified a Severity Level IV NCV of 10 CFR 50.70, Inspections, for the licensees failure to ensure that the arrival and presence of an NRC inspector is not communicated to persons at the facility. A security officer informed other security officers at the facility of the presence and expected arrival of an NRC resident inspector at their duty location. This issue was entered into the licensee\'s corrective action program as Condition Report ANO-2007-1508. The finding was determined to be applicable to traditional enforcement because the NRCs ability to perform its regulatory function was potentially impacted by the licensees notification of personnel whose activities are subject to unannounced inspection by NRC inspectors. The finding was not suitable for evaluation using the significance determination process, and was therefore evaluated in accordance with the Enforcement Policy. The finding was reviewed by NRC management and was determined to be of very low safety significance |
| 05000313/FIN-2003004-05 | 30 September 2003 23:59:59 | Arkansas Nuclear | NRC identified | Failure to Obtain a License Amendment for Upgrade of the Spent Fuel Area Crane | A noncited violation of 10 CFR 50.59 was identified by the inspectors when the licensee did not submit a license amendment request for a modification to the L-3 spent fuel area crane. The modification, which increased the maximum critical load rating to allow for a different type of spent fuel storage cask to be carried over the control rooms of both units, created the possibility for a malfunction of the L-3 crane that had a different result than previously evaluated. The licensee subsequently submitted a license amendment request for the modification on February 24, 2003 This issue involves traditional enforcement because it involves a violation of 10 CFR 50.59 and is more than minor because there was a reasonable likelihood that the change would require NRC review and approval prior to its implementation. The finding affects the initiating events cornerstone objective attributable to fuel handling equipment performance and has very low safety significance because, after identification of the problem, the licensee did not transfer spent fuel casks until the license amendment was approved. Consequently, the finding is categorized as a Severity Level IV noncited violation in accordance with the NRC Enforcement Policy. |
| 05000313/FIN-2003002-01 | 31 March 2003 23:59:59 | Arkansas Nuclear | NRC identified | Deletion of Containment Integrity Controls for Secondary System Containment Penetrations | Severity Level IV. The inspectors identified a noncited violation of 10 CFR 50.59 because the licensee failed to identify that changes made to the Units 1 and 2 Updated Safety Analysis Reports required a license amendment request. These changes removed containment isolation valve controls for secondary system containment penetrations. The licensee initiated corrective action on March 28, 2003, to prepare a license amendment request to obtain NRC approval of the changes to the Updated Safety Analysis Reports This is an item for traditional enforcement because it involves an issue not appropriate for evaluation using the SDP. It involves a violation of 10 CFR 50.59, an issue which impacts NRC oversight ability. The issue is more than minor because it involves a programmatic issue affecting containment controls for all secondary system penetrations. It was considered to be a noncited Severity Level IV violation. Management review determined it was greater than minor because the change should have received NRC review prior to implementation. Redundant containment barrier (system piping) existed and the licensee entered this issue into its corrective action program. |