EA-96-274 - Arkansas Nuclear 1 & 2 (Entergy Operations, Inc.)

September 6, 1996

EA 96-274

J. W. Yelverton, Vice President Operations
Arkansas Nuclear One
Entergy Operations, Inc.
1448 S.R. 333
Russellville, Arkansas 72801-0967

SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY - $50,000 (NRC Inspection Report No. 50-313/96-21; 50-368/96-21)

Dear Mr. Yelverton:

This is in reference to the matters discussed at a predecisional enforcement conference conducted on August 26, 1996, at the NRC's Arlington, Texas office. The conference was conducted to discuss apparent violations related to a May 19, 1996 event at Arkansas Nuclear One, Unit 1, during which a main steam safety valve (MSSV) failed to reseat following a reactor trip, resulting in one of two steam generators boiling dry and the declaration of an unusual event. The apparent violations were described in the referenced inspection report, issued on August 12, 1996. The results of an Augmented Inspection Team (AIT) follow-up to this event were described in a previous inspection report, 50-313/96-19; 50-368/96-19, issued on June 12, 1996. A conference summary, including the materials Entergy Operations, Inc., made available at the conference, was sent to you and to the NRC's Public Document Room on September 4, 1996.

Based on the information developed during the inspection and the information that you provided during the conference, the NRC has determined that violations of NRC requirements occurred. These violations are cited in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty. The circumstances surrounding them were described in detail in the subject inspection reports. Briefly, the violations involve a failure to assure that maintenance procedures were adequate to assure proper reassembly of MSSV components following testing, and a failure on the part of the mechanics involved in this activity to assure that the results intended by the procedures were attained, i.e., the proper installation of cotter pins through slots in the MSSV release nuts. I do want to note that in addition to the apparent violations specifically discussed at the conference, Violation B includes the failure of the mechanics to stop work when they recognized that they could not obtain full engagement of the cotter pins through the release nut slots on some of the MSSVs.

These violations resulted in one MSSV failing to reseat after a reactor trip on May 19, 1996, causing one of two steam generators to boil dry and removing it, albeit temporarily, as a source of cooling for the reactor. As documented in the inspection reports, operating personnel at ANO Unit 1 responded well to this event and the challenges created by it. Nonetheless, the failure of this MSSV to reseat substantially complicated the recovery from this event.

Furthermore, it was determined subsequent to this event that the cotter pins on at least two additional MSSVs were not fully engaged, and that the performance of the involved maintenance procedures prior to this event did not provide assurance that the cotter pins would be properly engaged. Thus, there was a potential, prior to the discovery and correction of this problem, for this same failure mechanism to have affected both steam generators, which would have presented a more difficult challenge to plant operators.

Entergy's presentation at the conference indicated that the primary root cause of the MSSV malfunction on May 19 was a failure to adhere to procedural requirements, but noted that a number of dimensional variations in the manufacture of the MSSV components created competing requirements in performing the procedure. Entergy's corrective actions in response to this event included, but were not limited to, inspecting all 16 MSSVs at ANO Unit 1, modifying the release nut slots to assure adequate room for proper engagement, modifying the procedures to eliminate the competing requirements and to include a caution statement, discussing this event with all maintenance personnel and other site personnel, communicating with the industry on this event, and ultimately removing manual lift levers and associated release nuts from the Unit 1 MSSVs when it was determined that they were not required. In addition, the mechanical supervisor and craft personnel voluntarily discussed this event with their peers at other Entergy plants.

As discussed during the conference, this event was preventable in two respects. The most significant opportunity to have prevented this event rested with the mechanics who were performing the MSSV reassembly following testing. They should have documented the fact that full engagement of the cotter pins could not be attained in all cases when the exact specifications in the procedure were followed, and stopped work pending resolution of this problem. The other opportunity to have prevented this event involves Entergy's review of a report of a similar failure mechanism at the Crystal River plant which had resulted in a MSSV not fully closing. Based on the discussions during the conference, the NRC agrees with Entergy that it is not clear that a timely review of this report would have resulted in the discovery of the problem that caused the May 19 event at ANO. Notwithstanding that consideration, the NRC expects licensees to perform timely reviews of important industry communications and that did not occur in this case.

The NRC has classified these violations 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 civil penalty is considered for a Severity Level III problem, with a base value of $50,000. Because your facility has been the subject of escalated enforcement action within the last 2 years,¹ 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. The NRC has determined that credit for identification is not warranted because the violations were discovered as the result of the May 19 event and because there were missed opportunities to discover this problem earlier and prevent the event from occurring. As discussed above, the most significant missed opportunity was the failure of the mechanics themselves to identify problems in performing the procedure. The NRC has determined that credit for corrective actions is warranted, based on Entergy's prompt actions in ferreting out the root cause of the event, and subsequent actions to address all of the hardware and human performance problems revealed by this event.

Therefore, to emphasize the importance of proper maintenance on safety-related components, including the need to identify problems encountered during the performance of such maintenance, I have been authorized, after consultation with the Director, Office of Enforcement, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) in the base amount of $50,000 for the Severity Level III problem described above and in the Notice.

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. After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC 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). To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction.

Sincerely, L. J. Callan Regional Administrator

Docket Nos.: 50-313; 50-368
License Nos.: DPR-51; NPF-6

Enclosure: Notice of Violation and
Proposed Imposition of Civil Penalty

cc w/Enclosure:
Executive Vice President
& Chief Operating Officer
Entergy Operations, Inc.
P.O. Box 31995
Jackson, Mississippi 39286-1995

Vice President
Operations Support
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

Bernard Bevill, Acting Director
Division of Radiation Control and
Emergency Management
Arkansas Department of Health
4815 West Markham Street, Slot 30
Little Rock, Arkansas 72205-3867

Manager
Rockville Nuclear Licensing
Framatone Technologies
1700 Rockville Pike, Suite 525
Rockville, Maryland 20852

 

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NOTICE OF VIOLATION
AND
PROPOSED IMPOSITION OF CIVIL PENALTY Entergy Operations, Inc. Docket Nos. 50-313; 50-368 Arkansas Nuclear One, Unit 1 License Nos. DPR-51; NPF-6 EA 96-274

During an NRC inspection conducted July 12 to August 2, 1996, violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the Nuclear Regulatory Commission proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act), 42 U.S.C. 2282, and 10 CFR 2.205. The particular violations and associated civil penalty are set forth below:

A. Unit 1 Technical Specification 6.8.1.a states, in part, that written procedures shall be established, implemented and maintained covering the applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, November, 1972.

 

Paragraph I.1 of Regulatory Guide 1.33 states, in part, that maintenance which can affect the performance of safety-related equipment should be performed in accordance with written procedures appropriate to the circumstances.

Procedure 1306.017, "Unit 1 Main Steam Safety Valve Test," revision 11 for the testing and restoration of the Unit 1 Main Steam Safety Valves, Step 8.2.22 requires, in part, that the bottom of the release nut should clear the top of the lever by 1/16 to 1/8 inches and that a new stainless steel cotter pin be inserted through the release nut slots and spindle.

Contrary to the above, as of May 19, 1996, Procedure 1306.017 was not appropriate to the circumstances for Valves PSV-2684, -2685 and -2695, in that the cotter pin could not be installed through the release nut slots and spindle if the bottom of the release nut cleared the top of the lever by 1/16 to 1/8 inches.

B. Unit 1 Technical Specification 6.8.1.a states, in part, that written procedures shall be established, implemented and maintained covering the applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, November, 1972.

Paragraph I.1 of Regulatory Guide 1.33 states, in part, that maintenance which can affect the performance of safety-related equipment should be performed in accordance with written procedures appropriate to the circumstances.

Procedure 1000.006, "Procedure Control," Step 6.5.1 of requires, in part, that procedures shall be performed exactly as written. Step 6.5.4 requires, in part, that if problems occur during procedure performance due to unexpected results, the user shall stop work.

Procedure 1306.017, "Unit 1 Main Steam Safety Valve Test," revision 11, for the testing and restoration of the Unit 1 Main Steam Safety Valves, Step 8.2.22, requires, in part, to insert a new stainless steel cotter pin through the release nut slots and that a second person verifier shall verify that the cotter pin has been installed properly.

Contrary to the above, as of May 19, 1996, for Valves PSV-2684, -2685, and -2695, Procedure 1000.006 had not been performed exactly as written in that the cotter pins were found not inserted through the release nut slots and the second person verifier had not verified that the cotter pins were properly installed. In addition, Procedure 1000.006 had been performed on Valves PSV-2684, PSV-2685, and PSV-2695 with unexpected results and the users did not stop work.

These violations represent a Severity Level III problem (Supplement I).
Civil Penalty - $50,000

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 Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, within 30 days of the date of this Notice of Violation and Proposed Imposition of Civil Penalty (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each alleged violation: (1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, and if denied, the reasons why, (3) the corrective steps that have been taken and the results achieved, (4) the corrective steps that will be taken to avoid further violations, and (5) the date when full compliance will be achieved. 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. Consideration may be given to extending the response time for good cause shown. Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

Within the same time as provided for the response required above under 10 CFR 2.201, the Licensee may pay the civil penalty by letter addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, with a check, draft, money order, or electronic transfer payable to the Treasurer of the United States in the amount of the civil penalty proposed above, or the cumulative amount of the civil penalties if more than one civil penalty is proposed, or may protest imposition of the civil penalty in whole or in part, by a written answer addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission. Should the Licensee fail to answer within the time specified, an order imposing the civil penalty will be issued. Should the Licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty, in whole or in part, such answer should be clearly marked as an "Answer to a Notice of Violation" and may: (1) deny the violation(s) listed in this Notice, in whole or in part, (2) demonstrate extenuating circumstances, (3) show error in this Notice, or (4) show other reasons why the penalty should not be imposed. In addition to protesting the civil penalty in whole or in part, such answer may request remission or mitigation of the penalty.

In requesting mitigation of the proposed penalty, the factors addressed in Section VI.B.2 of the Enforcement Policy should be addressed. Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate parts of the 10 CFR 2.201 reply by specific reference (e.g., citing page and paragraph numbers) to avoid repetition. The attention of the Licensee is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalty.

Upon failure to pay any civil penalty due which subsequently has been determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282c.

The response noted above (Reply to Notice of Violation, letter with payment of civil penalty, and Answer to a Notice of Violation) should be addressed to: James Lieberman, Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, One White Flint North, 11555 Rockville Pike, Rockville, MD 20852-2738, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, 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.

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. However, if you find it necessary to include such information, you should clearly indicate the specific information that you desire not to be placed in the PDR, and provide the legal basis to support your request for withholding the information from the public.

Dated at Arlington, Texas,
this 6th day of September 1996

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1. For example, on July 17, 1995, a Notice of Violation was issued for a Severity Level III problem involving a number of violations associated with the movement of the Unit 1 core support assembly.