August 8, 2005 Jeffrey S. Forbes Vice President Operations Arkansas Nuclear One Entergy Operations, Inc. 1448 S.R. 333 Russellville, AR 72801-0967 SUBJECT: ARKANSAS NUCLEAR ONE, UNITS 1 AND 2 - NRC SAFETY SYSTEM DESIGN AND PERFORMANCE CAPABILITY INSPECTION REPORT 0500313/2005008; 0500368/2005008 Dear Mr. Forbes: On June 24, 2005, the Nuclear Regulatory Commission (NRC) completed an inspection at your Arkansas Nuclear One, Units 1 and 2, facility. The enclosed Safety System Design and Performance Capability inspection report documents the findings, which were discussed with you and other members of your staff at the conclusion of the inspection. This inspection examined activities conducted under your license as they relate to safety and compliance with the Commission’s rules and regulations and with the conditions of your license. The team reviewed selected procedures and records, observed activities and interviewed personnel. The report documents four findings that were evaluated under the risk significance determination process as having very low safety significance (Green). The NRC has also determined that violations were associated with three of these findings. The violations are being treated as noncited violations because they are of very low safety significance and because they have been entered into your corrective action program consistent with Section VI.A of the Enforcement Policy. If you contest the violations or the significance of these noncited violations, you should provide a response within 30 days of the date of the inspection report, with the basis for your denial, to the U.S. Nuclear Regulator Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the Arkansas Nuclear One facility. Entergy Operations, Inc. -2- In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRC’s document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). Sincerely, /RA/ J. Clark, P.E., Chief Engineering Branch - 1 Division of Reactor Safety Dockets: 50-313; 50-368 Licenses: DPR-51; NPF-6 Enclosure: NRC Inspection Report 05000313/2005008 and 05000368/2005008 w/Attachments: 1. Supplemental Information 2. Information Exempt From Public Disclosure In Accordance With 10 CFR 2.390 cc w/enclosure and Attachment 1: Senior Vice President & Chief Operating Officer Entergy Operations, Inc. P.O. Box 31995 Jackson, MS 39286-1995 Vice President Operations Support Entergy Operations, Inc. P.O. Box 31995 Jackson, MS 39286-1995 Manager, Washington Nuclear Operations ABB Combustion Engineering Nuclear Power 12300 Twinbrook Parkway, Suite 330 Rockville, MD 20852 County Judge of Pope County Pope County Courthouse 100 West Main Street Russellville, AR 72801 Entergy Operations, Inc. -3- Winston & Strawn LLP 1700 K Street, N.W. Washington, DC 20006-3817 Bernard Bevill Radiation Control Team Leader Division of Radiation Control and Emergency Management Arkansas Department of Health 4815 West Markham Street, Mail Slot 30 Little Rock, AR 72205-3867 James Mallay Director, Regulatory Affairs Framatome ANP 3815 Old Forest Road Lynchburg, VA 24501 Entergy Operations, Inc. -4- Electronic distribution by RIV: Regional Administrator (BSM1) DRP Director (ATH) DRS Director (DDC) DRS Deputy Director (KMK) Senior Resident Inspector (RWD) Branch Chief, DRP/E (DNG) Senior Project Engineer, DRP/E (VGG) Team Leader, DRP/TSS (RLN1) RITS Coordinator (KEG) DRS STA (DAP) J. Dixon-Herrity, OEDO RIV Coordinator (JLD) RidsNrrDipmIipb ANO Site Secretary (VLH) SISP Review Completed: ______ ADAMS: : Yes G No Initials: __JIT____ Publicly Available 4 Non-Publicly Available 4 Sensitive Non-Sensitive SRI/EB1 SRI/EB1 RI/EB1 RI:DRS/EB1 C:EB1 C:PBE C:EB1 JTapia/lmb CPaulk JAdams BHenderson JClark DGraves JClark /RA/ /RA/ /RA/ /RA/ /RA/ /RA/ /RA/ 08/04/05 08/04/05 08/04/05 08/04/05 08/06/05 08/06/05 08/08/05 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket Nos.: 50-313, 50-368 License Nos.: DPR-51, NPF-6 Licensee: Entergy Operations, Inc. Facility: Arkansas Nuclear One, Units 1 and 2 Location: Junction of Hwy. 64W and Hwy. 333 South Russellville, Arkansas Dates: June 6-24, 2005 Team Leader: J. I. Tapia, P.E., Senior Reactor Inspector, Engineering Branch - 1 Inspectors: J. Adams, Reactor Inspector, Engineering Branch - 1 B. Henderson, Reactor Inspector, Engineering Branch - 1 C. Paulk, Senior Reactor Inspector, Engineering Branch - 1 Accompanying C. Baron, P.E., Contractor, Beckman & Associates, Inc. Personnel: Approved by: J. Clark, P.E., Chief Engineering Branch - 1 Division of Reactor Safety -1- Enclosure SUMMARY OF FINDINGS IR 05000313/2005008, 05000368/2005008;6/6-24/2005; Arkansas Nuclear One, Units 1 and 2; Safety System Design and Performance Capability; Permanent Plant Modifications; Evaluations of Changes, Tests, or Experiments. The report covered a 2-week period of inspection on site by a team of four region-based engineering inspectors and one consultant. Four Green findings of very low safety significance were identified during this inspection. Three of the findings were classified as noncited violations. The findings were evaluated using the significance determination process. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, “Significance Determination Process” (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC’s program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, “Reactor Oversight Process,” Revision 3, dated July 2000. A. Inspector-Identified and Self-Revealing Findings Cornerstone: Barrier Integrity • Green. The team identified a violation of 10 CFR Part 50, Appendix B, Criterion XVI (Corrective Action) for failing to properly evaluate the need to place the closing function of the containment sump Isolation Valve 2CV-5650-2 into the inservice testing program despite two opportunities to do so over an 11-year period. The finding is greater than minor because it had the potential to affect the Barrier Integrity cornerstone objective of ensuring that physical barriers protect the public from radionuclide releases, in that, failure of the valve to close could release radioactivity from containment following an accident. The violation was of very low safety significance because there was never an actual open pathway from the reactor containment building (Section R21). Cornerstone: Mitigating Systems • Green. The team identified a violation of 10 CFR Part 50, Appendix B, Criterion XVI (Corrective Action) for the failure to take prompt corrective actions to address a longstanding problem. In 1993, a design change incorporated an impermeable membrane fabric over the top of the emergency cooling pond dam/spillway. On May 19, 2002, Condition Report CR-ANO-C-2002-00394 was written to document that the fabric was torn, missing in some areas and in need of replacement. At the time of this inspection, the licensee had not initiated actions to repair or replace the damaged and missing portions of the fabric and restore the required design. The failure to address this longstanding problem was a performance deficiency. The issue had more than minor safety significance because it impacted the -2- Enclosure Mitigating Systems cornerstone objective of ensuring the availability of systems that mitigate plant accidents and could have affected the ability of a safety- related structure to perform its design basis function. The finding was of very low safety significance because the structure remained operable consistent with Generic Letter 91-18, “Information to Licensees Regarding NRC Inspection Manual Section on Resolution of Degraded and Nonconforming Conditions,” Revision 1, and because it did not represent an actual loss-of-safety function (Section R21). • Green. The team identified a violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," for failing to assure that a design change to the emergency cooling pond was incorporated into the design basis and the associated technical specification surveillance requirements. As a result, the licensee failed to recognize that the design change reduced the effective volume of the emergency cooling pond and that the surveillance acceptance criteria needed to be revised. This finding was more than minor because the emergency cooling pond capacity was degraded because of a reduced volume, which was not detected during the design change nor during subsequent surveillances. Arkansas Nuclear One engineering staff had to perform reanalyses and operability evaluations to address this finding and the minimum required emergency cooling pond level had to be increased to ensure operability. The finding was of very low safety significance because it did not represent an actual loss-of-safety function (Section R21). • Green. The team identified a finding, in that, the licensee had