EA-97-382 - Arkansas Nuclear 1 & 2 (Entergy Operations, Inc.)
November 18, 1997
C. Randy Hutchinson, Vice President
Arkansas Nuclear One
Entergy Operations, Inc.
1448 S.R. 333
Russellville, Arkansas 72801-0967
SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT 50-313/97-14; 50-368/97-14)
Dear Mr. Hutchinson:
This is in reference to the predecisional enforcement conference held in the NRC's Arlington, Texas office on September 26, 1997. The conference was conducted to discuss three apparent violations of NRC requirements related to inspections of steam generator tubes at Arkansas Nuclear One, Units 1 and 2. The results of our inspection were discussed with your staff during a telephonic exit briefing conducted on August 8, 1997, and were documented in the subject NRC Inspection Report, which was issued September 12, 1997. After the September 26 conference, ANO provided further information and clarification during a telephone discussion held on October 2, 1997.
The three apparent violations described in the inspection report involved: (1) a failure to comply with 10 CFR Part 50 Appendix B Criterion IX in the use of data in bobbin coil sizing qualification criteria that did not conform to the requirements of the selected qualification method; (2) the failure to remove Unit 2 tubes from service which contained flaws that exceeded the plugging limit of the Technical Specifications; and (3) the lack of prompt corrective action in November 1995 prior to returning potentially defective sleeved tubes to service.
During the September 26 conference, Entergy expressed disagreement with the first apparent violation, contending that Entergy's sizing qualification for intergranular attack (IGA) met the provisions of appropriate industry qualification processes (EPRI Appendix "H"), and therefore Entergy was in compliance with 10 CFR Part 50 Appendix B. With regard to the second apparent violation, which involved Unit 2 steam generators, Entergy agreed that the violation occurred but contended that the violation warranted treatment as a non-cited violation. Entergy also disputed the third apparent violation, which is discussed below.
The NRC considered Entergy's arguments and has concluded that violations of NRC requirements occurred. The violations are cited in the enclosed Notice of Violation (Notice). Based on the discussions at the conference, we have modified the first violation to state that Entergy's inservice inspections of Unit 1 steam generators were not appropriately controlled and accomplished to identify tube defects that exceeded the technical specification plugging limit. The second violation involves Unit 2 steam generator tubes, with defects greater than the technical specification plugging limit, that were improperly considered operable.
Although these violations involve steam generators of different designs and different IGA flaw sizing methodologies, the violations are similar in that your methods for sizing IGA and tubing degradation in both Units 1 and 2 steam generators were shown to have been inadequate. The actual safety consequence of these violations is low because no significant leakage occurred as a result of tube leaks. These issues are of regulatory significance because of the programmatic nature of the problem; that is, you relied on methods which were incapable of detecting flaws greater than the plugging limit, and as a result, operated Units 1 and 2 with steam generators with tubes containing flaws that exceeded the technical specification plugging limit of 40 percent through wall (TW). Therefore, these two violations have been categorized in the aggregate in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600, as a Severity Level III problem.
In accordance with the Enforcement Policy, a base civil penalty in the amount of $55,000 is considered for a Severity Level III problem. Because your facility has been the subject of escalated enforcement actions within the last 2 years1, the NRC considered whether credit was warranted for Identification and Corrective Action in accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement Policy. Since Entergy identified both issues, the NRC has determined that Entergy is deserving of Identification credit. Further, the NRC has determined that Entergy is deserving of Corrective Action credit. Entergy's corrective actions for the first violation included declaring the steam generators inoperable, notifying the NRC, requesting (and being granted) a Notice of Enforcement Discretion from the NRC, administratively precluding IGA sizing, and investigating the cause of the problem. Entergy's corrective actions to the second violation included reviewing more "no detectable degradation" determinations to verify the quality of the 2R12 analyses, performing enhanced inservice inspections of indications, repairing the eggcrate cracks, enhancing training, and providing additional oversight of the inservice inspections.
Therefore, to encourage prompt identification and comprehensive correction of violations, I have been authorized not to propose a civil penalty in this case. However, significant violations in the future could result in a civil penalty.
The third violation cited in the enclosed notice involves Entergy's failure to take prompt corrective actions prior to returning to service potentially defective sleeved tubes exhibiting weld zone eddy current indications. At the conference, Entergy representatives expressed disagreement with this violation, contending that sufficient technical basis existed (including ultrasonic testing and visual testing) to justify use of the sleeves as-is. Further, Entergy representatives noted that, after re-inspection, only one of 28 indications was identified for repair based on new acceptance criteria and that all 28 indications met structural and leakage requirements. Notwithstanding Entergy's argument that the structural integrity of the sleeves was maintained, the NRC's position is that Entergy had an indication of a condition adverse to quality, and it took inadequate corrective actions. Specifically, your actions (in October 1995, during 2R11) were not adequate to evaluate defects that existed at the time, nor did you perform an operability assessment at the time. Therefore, in accordance with the its Enforcement Policy, the NRC has classified this violation at Severity Level IV.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response will be placed in the NRC Public Document Room (PDR).
Sincerely, Ellis W. Merschoff Regional Administrator
Dockets: 50-313 & 50-368
Licenses: DPR-51 & NPF-6
Executive Vice President
& Chief Operating Officer
Entergy Operations, Inc.
P.O. Box 31995
Jackson, Mississippi 39286-1995
Entergy Operations, Inc.
P.O. Box 31995
Jackson, Mississippi 39286
Manager, Washington Nuclear Operations
ABB Combustion Engineering Nuclear Power
12300 Twinbrook Parkway, Suite 330
Rockville, Maryland 20852
County Judge of Pope County
Pope County Courthouse
Russellville, Arkansas 72801
Winston & Strawn
1400 L Street, N.W.
Washington, D.C. 20005-3502
David D. Snellings, Jr., Director
Division of Radiation Control and
Arkansas Department of Health
4815 West Markham Street, Mail Slot 30
Little Rock, Arkansas 72205-3867
Rockville Nuclear Licensing
1700 Rockville Pike, Suite 525
Rockville, Maryland 20852
NOTICE OF VIOLATION
Entergy Operations, Inc. Dockets: 50-313; 50-368 Arkansas Nuclear One Licenses: DPR-51; NPF-6 EA 97-382
During an NRC inspection conducted on May 27 through August 8, 1997, violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:
A. Criterion IX of Appendix B to 10 CFR Part 50 states, in part, "Measures shall be established to assure that special processes, including. . . nondestructive testing, are controlled and accomplished. . . using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements."
Unit 1 Technical Specification 4.18.2a. states, in part, "Inservice inspection of steam generator tubing shall include nondestructive examination by eddy-current testing or other equivalent. . . ." Technical Specification 4.18.5b, through Amendment No. 134 to Facility Operating License No. DPR-51, states, in part, "The steam generator shall be determined operable after completing the corresponding actions (plug or sleeve all tubes exceeding the plugging limit and all tubes containing through-wall cracks) required by Table 4.18-2. . . ." Table 4.18-2 requires defective tubes to be plugged or sleeved. Technical Specification 4.18.5a defines a defect as an imperfection which exceeds the plugging limit, a defective tube as one containing a defect in its pressure boundary, and the plugging limit as equal to 40 percent of the nominal tube wall thickness.
Unit 2 Technical Specification 126.96.36.199 requires that each steam generator shall be demonstrated operable by performance of an augmented inservice inspection program. Technical Specification 188.8.131.52 states, in part, ". . . the inspected tubes shall be verified acceptable per the acceptance criteria of Specification 184.108.40.206. . . ." Technical Specification 220.127.116.11b. states, in part, "The steam generator shall be determined operable after completing the corresponding actions (plug or repair all tubes exceeding the plugging or repair limit and all tubes containing through-wall cracks) required by Table 4.4-2. . . ." Table 4.4-2 requires defective tubes to be plugged or sleeved. Technical Specification 18.104.22.168a. defines a defect as an imperfection which exceeds the plugging limit, a defective tube as one containing a defect, and the plugging limit as equal to 40 percent of the nominal parent tube wall thickness.
1. Contrary to the above, from October 25, 1996 (the date of return to power operations following outage 1R13) through April 9, 1997 (the date of approval of enforcement discretion), eddy current examinations of Unit 1 steam generator tubes performed during Unit 1 Refueling Outage 1R13 were not appropriately controlled and accomplished to identify tube defects in Unit 1 steam generator tubes that could have exceeded the technical specifications plugging limit. Specifically, the licensee inadequately controlled its eddy current testing and sizing technique used during Unit 1 Refueling Outage 1R13 to measure the depth of intergranular attack present in steam generator tubing at locations within the upper tube sheet. All tubes that were found by use of this technique to contain intergranular attack with a depth less than 40 percent of the nominal tube wall thickness were allowed to remain in service on return to power operations on October 25, 1996. Subsequent metallographic examination of three tubes exhibiting upper tube sheet intergranular attack, which were removed from Steam Generator B during the refueling outage, found actual flaw depths that exceeded the depths predicted by the sizing technique. This created the potential for flaws being left in service up to April 9, 1997 (i.e., the date of enforcement discretion approval) that exceeded the plugging limit of the Technical Specifications. (01013)2. Contrary to the above, from January through May 1997, adequate measures were not taken to assure that inservice inspections of Unit 2 steam generators tubes were controlled and accomplished to identify defects exceeding the plugging limit. Reevaluation, in May 1997, of data obtained during Unit 2 Outage 2F96-1 bobbin coil examination (performed before January 1997) identified 76 tubes in Steam Generator A and 122 tubes in Steam Generator B that had defects in excess of the plugging limit of the Technical Specifications. (01023)
These violations represent a Severity Level III problem (Supplement I) (50-313/9714-01).
B. Criterion XVI of Appendix B to 10 CFR Part 50 states, in part, "Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. . . ."
Contrary to the above, in November 1995, the licensee failed to take adequate corrective actions, during Refueling Outage 2R11, after identifying defects in welded sleeves in Unit 2 steam generators tubing, and prior to returning these potentially defective Unit 2 sleeved tubes to service. Although the licensee performed additional testing (ultrasonic and visual testing), these were inadequate to evaluate defects that existed at the time, and the licensee did not perform an operability assessment at that time. (02014)
This is a Severity Level IV violation (Supplement I) (50-368/9714-03).
Pursuant to the provisions of 10 CFR 2.201, Entergy Operations, Inc. (Licensee) is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violations, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.
Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.
Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.
Dated at Arlington, Texas
this 18th day of November 1997
1. A Severity Level III problem and a $50,000 civil penalty was issued on April 9, 1997, involving fire protection inadequacies and the plant staff's inadequate response to indications of a fire (EA 96-512).