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EA-96-512 - Arkansas Nuclear 1 & 2 (Entergy Operations, Inc.)April 9, 1997 EA 96-512 C. Randy Hutchinson, Vice President
SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL
PENALTY - $50,000 (NRC Inspection Report 50-313;368/96-27)
Dear Mr. Hutchinson: This refers to the predecisional enforcement conference conducted in Arlington, Texas, on March 28, 1997 with Entergy Operations, Inc. (Entergy) representatives. The conference was conducted to discuss apparent violations of NRC requirements associated with an October 17, 1996 fire at Arkansas Nuclear One (ANO), Unit 1, as documented in NRC Inspection Report 50-313;368/96-27, issued February 3, 1997. The inspection was conducted October 22-29 and November 21-25, 1996, and was finalized in a telephonic exit meeting on December 11, 1996. The apparent violations described in the inspection report involved several inadequacies in NRC-required reactor coolant pump oil collection systems at ANO, and three examples of inadequate responses to plant conditions which indicated the potential for a fire (i.e., inadequate corrective action, as required by 10 CFR Part 50, Appendix B, Criterion XVI). At the conference, Entergy expressed disagreement with parts of the apparent fire protection violations, contending that the oil collection system for the reactor coolant pumps was not required to collect oil spray from lift oil piping leaks, nor to collect leakage from "remote" oil fill lines. Entergy did not explicitly disagree with the corrective action violations. However, Entergy's position was that plant personnel had responded reasonably to oil leaks and smoke in light of their lack of understanding of the "wicking" phenomenon which created the potential for oil-soaked insulation to ignite at a lower than expected temperature. The NRC considered Entergy's fire protection arguments but has concluded that 10 CFR Part 50, Appendix R, is clear with regard to these reactor coolant pump components being protected by oil collection systems. Based on our discussions during the conference, we have clarified the violation to include the failure to protect the fill connection on the Unit 1 B reactor coolant pump and to clarify that the flanged connections were not protected on the lower reservoir transmitters. We also deleted one of the apparent examples of an Appendix B, Criterion XVI violation. Specifically, we deleted the example involving oil found on the floor of the Unit 1 containment building by radiation protection personnel during the outage because, as discussed during the conference, the small amounts of oil involved did not represent a clear opportunity to determine the source of the leak and take corrective action. Therefore, based on the information developed during the inspection and the information that was 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 the violations were described in detail in the subject inspection report. The violations include: 1) a failure to maintain an adequate lube oil collection system for reactor coolant pumps, which created the potential for a fire when oil spray from a cracked weld accumulated in fibrous insulation; and 2) a failure in two instances to take prompt action to identify and correct conditions which resulted in a fire in the ANO Unit 1 containment building on October 17, 1996. These violations appear to have resulted from a lack of sensitivity to fire protection requirements related to reactor coolant pump lube oil collection systems and to plant conditions which indicated a potential for a containment fire to occur. The October 17, 1996 fire was quickly extinguished and did not affect the safety of the plant. Nonetheless, the NRC finds the fire protection inadequacies, coupled with the plant staff's inadequate response to indications of a fire, i.e., oil-soaked insulation which was reported to be smoking excessively during plant heat-up, unacceptable performance. Therefore, these violations have been classified in the aggregate as a Severity Level III problem, in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600. The NRC acknowledges that Entergy has taken or planned a number of corrective actions in response to these violations, all of which were discussed at the conference. In brief, these actions involve: 1) training and procedural revisions to heighten sensitivity to smoke, oil leaks, lube oil collection system requirements and the potential for reduced auto-ignition temperatures of oil-soaked insulation; and 2) plant modifications and administrative measures to address the various inadequacies in reactor coolant pump lube oil collection systems. In accordance with the Enforcement Policy, a civil penalty with a base value of $50,000 is considered for a Severity Level III problem. Because your facility has been the subject of escalated enforcement actions within the last 2 years,1 the NRC considered whether Entergy should be given credit for Identification and Corrective Action in accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement Policy. The violations were discovered only because the fire occurred. In that plant staff missed opportunities to take action to prevent the fire, the NRC has determined that Entergy should not be given credit for identification. The NRC has determined that Entergy should be given credit for its corrective actions, summarized above, which were prompt and comprehensive. Consideration of these factors results in the assessment of a base civil penalty. Therefore, to emphasize the importance of adherence to fire protection requirements in the design and operation of the facility, and the importance of reacting to plant conditions indicating a potential for a fire, 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 amount of $50,000. 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
Docket Nos. 50-313; 50-368 Enclosure: Notice of Violation and Proposed Imposition of Civil Penalty cc w/Enclosure: Executive Vice President Vice President Operations Support Manager, Washington Nuclear Operations County Judge of Pope County Winston & Strawn Bernard Bevill, Acting Director Manager
NOTICE OF VIOLATION
Entergy Operations, Inc. Docket Nos. 50-313; 50-368
Arkansas Nuclear One, Unit 1 License Nos. DPR-51; NPF-6
EA 96-512
During an NRC inspection completed December 11, 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. 10 CFR Part 50, Appendix R, Section III.O states in part: "The reactor coolant pump shall be equipped with an oil collection system if the containment is not inerted during normal operation. "Such collection systems shall be capable of collecting lube oil from all potential pressurized and unpressurized leakage sites in the reactor coolant pump lube oil systems. "Leakage points to be protected shall include lift pump and piping, overflow lines, lube oil cooler, oil fill and drain lines and plugs, flanged connections on oil lines, and lube oil reservoirs where such features exist on reactor coolant pumps." Contrary to the above, as of October 17, 1996, the licensee failed to protect the lift piping and the fill connection on the Unit 1 B Reactor Coolant Pump; the lift piping on the four Unit 2 Reactor Coolant Pumps; the flange connections on lower reservoir transmitters on the Unit 1 A, C, D, and all four Unit 2 Reactor Coolant Pumps; and the oil fill lines on all four Unit 1 and Unit 2 Reactor Coolant Pumps. (01013) B. 10 CFR Part 50, Appendix B Criteria XVI states: "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. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition. The identification of the significant condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to the appropriate levels of management." 1. Contrary to the above, on October 9, 1996, licensee personnel identified a crack in a weld on the Unit 1 B Reactor Coolant Pump lift oil piping, but did not identify and correct the fact that this oil leakage from this crack had resulted in oil accumulation in the fibrous insulation of Steam Generator B, a fire hazard. On October 17, 1996, during plant heat-up, this oil-soaked insulation ignited, causing a fire. (01023)2. Contrary to the above, on October 17, 1996, licensee personnel identified oil-soaked insulation which was smoking excessively during plant heat-up, but did not take prompt action to correct this condition. Later on the same day, this oil-soaked insulation ignited, causing a fire. (01033) These violations represent a Severity Level III problem (Supplement I). 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 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 responses 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 Arkansas Nuclear One facility. 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, 1. A $50,000 civil penalty was issued September 6, 1996, for violations related to improper maintenance on main steam safety valves.
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