ANO: First Killing A Employee Yellow Finding, Now A flooding Yellow Finding

Right, the design bases flood would have distroyed all the cooling systems...

The repeated theme here across many plants…some seminal event happens usually a yellow or red finding, a broken RHR injections valve ignored for years, a dropped stator, a hole in the head, historic flooding and safety electrical problems like Fort Calhoun…then the NRC comes in with more intensive inspections finding many other hanging around not addressed safety issues for decades and not related violations finding at the plant.  Talking about the power of the gods, it is as if the NRC has a special secret process where some secret rule breaking is tolerated by the NRC. It might be against the rules, but everyone knows some violations are acceptable to the NRC and maintain secret from the public.

 

ARKANSAS NUCLEAR ONE- NRC INSPECTION REPORT - PRELIMINARY YELLOW FINDING - September 09, 2014

I am not that far off with picking on Entergy. These guys are the most dishonest fleet operators in the USA.

This is the intolerable theme with many sentinel issues in the US industry. The sentinel issue shows up, like TVA with the broken RHR injection…then in the intensified public scrutiny and NRC inspections they find a gaggle of non-related violations hanging around for decades that the NRC ignored. You have no idea how damaging this is to the safety culture of a nuclear when the NRC telegraphs they won’t act on well known violations in which all the plant staff knows. So this flooding issues comes out of the delayed NRC response to negligently dropping the 600 ton stator at the site, killing one and injuring eight.

Again, this flooding yellow violation was hanging around for decades and subsequent to Fort Calhoun and Fukushima…

You know, how much do we really know about any plant in the USA…

Why was the Killing of one employee a yellow finding based on nuclear risk, a year to see the light, and then another yellow finding about flooding? It sounds like absolutely no forward motion in a year at ANO-Entergy. Even if it was a yellow finding today, why wasn’t it bumped up to a red finding or shutdown, as for deterrence for not immediately correcting their attitude from the stator drop accident? I asked at Entergy-Palisades to be returned to the yellow oversight regime.

I got another swing at the Palisades RCP issue a few days ago. It was basically a speech about there is absolutely no deterrence with the ROP. I brought up many recent industry events that I thought are all connected to an ineffective regulator. Even from one event to another similar event at the same plant. I spent a lot of time getting transcribed, risked getting thrown out of this 2.206 for drawing outside the lines. Even the NRC has issues with me staying on subject. I tried explained waht the meaning of Fort Calhoun was to the all these NRC employees.

I’ll throw a link on the transcription of my speech…the NRC should be ashamed of themselves. I am sure you would wonder what I really knew, when I was on the phone to the NRC.

And by the way, I called the Cooper senior inspector today… Once the senior resident figured out what I was asking, he threw me to the NRC PR spokesman.

Again, you should read my 2011 2.206 excepts I submitted recently here…it is as relevant today as it was in 201, predicting the future at Palisades and all the rest of the plants in the USA…

ARKANSAS NUCLEAR ONE- NRC INSPECTION REPORT PRELIMINARY YELLOW FINDING -September 09, 2014 

Submitted by NUCBIZ on September 11, 2014 - 18:20

By Bob Meyer

This report is a shot over the bow of the nuclear industry for each plant to review flood walkdowns and review plant specific flood analysis. Based on my experience, some of the conditions that resulted in NRC violations exist at other plants. The NRC concuded that all long-term core makeup and cooling could have failed during an external flood.

Read this very important, detailed NRC inspection report and compare it to the conditions at your plant. Here is the redacted report.

Apparent Violation. The inspectors identified a finding of preliminary substantial safety significance (Yellow) for the failure to design, construct, and maintain the Units 1 and 2 auxiliary and emergency diesel fuel storage buildings in accordance with the safety analysis reports' description of internal and external flood barriers so that they could protect safety-related equipment from flooding. Two apparent violations were associated with this finding:

• Contrary to 10 CFR Part 50, Appendix B, Criterion Ill, "Design Control," the licensee failed to assure that regulatory requirements and the design basis were correctly translated into specifications, drawings, procedures, and instructions, and that design changes were subjected to design control measures commensurate with those applied to the original design.

• Contrary to 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," the licensee failed to prescribe documented instructions for activities affecting quality and accomplish activities affecting quality in accordance with drawings.

The inspectors determined that the finding was more than minor because it was associated with the protection against external factors attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the performance deficiency resulted in the vulnerability to flooding of safety-related equipment necessary to maintain core cooling in the auxiliary and emergency diesel fuel storage buildings.

The following were the dominant considerations in reaching a preliminary risk determination conclusion:

• With respect to the auxiliary and emergency diesel fuel storage buildings, there were more than 100 unknown ingress pathways for a flooding event, therefore if an external flood above grade level were to occur, the buildings would flood.

• The unexpected rate of flooding would likely be beyond the licensee's capability to prevent or mitigate as equipment and connections associated with alternative mitigating strategies, could be submerged.

• All reactor core cooling and makeup could fail due to significant flooding of the auxiliary and emergency diesel fuel storage buildings.

• The change in core damage frequency was quantitatively bounded below 2 x 10-3 and qualitatively determined to likely be less than 1 x 10-4 . The bounding and qualitative results are based on the frequency of the probable maximum flood event and a loss of all equipment needed for core cooling and makeup.

This finding was preliminarily determined to be of substantial safety significance (Yellow) for Unit 1 and Unit 2, as determined by a Significance and Enforcement Review Panel.

This finding had a cross-cutting aspect in the area of human performance related to maintaining design margins. Specifically, the licensee did not design, construct, and/or maintain over 100 flood barriers to ensure design margins were sustained [H.6].

Unit 1, Safety Analysis Report, Amendment 26, Section 5.1.6, "Flooding," defined the design basis for external flooding and stated, in part, that the seismic class 1 structures are designed for the maximum probable flood level at elevation 361 feet above mean sea level (MSL). All seismic class 1 systems and equipment are either located on floors above elevation 361 feet MSL or protected. Sections 5.3.2 and 5.3.5.2 identified the auxiliary and emergency diesel fuel storage buildings as seismic class 1 structures.

Unit 2, Safety Analysis Report, Amendment 25, Section 3.4.4, "Flood Protection," defined the design basis for external flooding and stated, in part, that seismic category 1 structures were designed for the probable maximum flood . All category 1 systems and equipment were either located on floors above elevation 369 feet MSL, or are protected. Table 3.2-2, "Seismic Categories of Systems, Components, and Structures," identified the auxiliary and emergency diesel fuel storage buildings as seismic class 1 structures.

At the end of the inspection period, the following deficient flood protection features had been identified:

1. Unsealed Conduits

Over 100 unsealed conduits that penetrated flood barriers for the Unit 1 and Unit 2 auxiliary and emergency diesel fuel storage buildings between 335 feet MSL and 361 feet MSL.

2. Degraded Seals

The March 31, 2013, stator drop event revealed degraded hatch seals that allowed fire water in the turbine building to leak into the Unit 1 auxiliary building. During extent of condition reviews, the licensee identified 13 degraded hatches for Unit 1 and Unit 2 at 354 feet MSL (site grade elevation). The licensee determined that some hatch seals were degraded from age and some hatch seals were rolled out of place upon installation. From its extent of condition review, the licensee also identified that the building expansion joint between the auxiliary building and containment buildings was significantly degraded and could be subjected to external floodwater by backflooding through un-isolable floor drains.

The inspectors determined that the degraded hatch seals failed to protect safety-related systems from flooding, and that the licensee failed to establish instructions that prescribed how to adequately inspect, replace, and test the seals. The licensee corrected the hatch seal deficiencies by establishing adequate instructions, replacing the seals, and smoke testing the hatches or seal welding the hatches shut. The licensee implemented compensatory measures to plug the floor drains upon notification of a flood to prevent external floodwater from impacting the auxiliary building to containment building expansion joint.

3. Ventilation Penetration

...during construction, the ductwork blind flange was not fabricated and procedural instructions to isolate this flooding pathway were never developed.

The inspectors determined that the licensee failed to stage the blind flange and translate the design for flange installation into Procedure OP-1203.025, "Natural Emergencies," Revision 37.

4. Floor Drains

During extent of condition reviews for the degraded hatches, the licensee identified that floor drains at 354 feet MSL from the turbine building and old radwaste building sump were routed to the Unit 1 auxiliary building and the lines did not contain isolation valves in case of flooding. The inspector determined that the licensee failed to translate the design requirement to have isolation capability into specifications and drawings for the floor drain system . The licensee corrected the condition by installing a blind flange on the old radwaste building sump drain line and implemented compensatory measures to plug the drain line from the turbine building upon notification of a flood.

5. Auxiliary Building Extension

During extent of condition reviews for the degraded hatches, the licensee identified that some Unit 2 auxiliary building extension pipe penetrations between 335 feet MSL and 354 feet MSL were not sealed between the turbine building and auxiliary building extension. Unit 2 Drawing A-2002, "Architectural Schematic, Fire and Flood Protection Plans and Sections," Revision 10, referenced which walls, ceilings, and floors are flood barriers that required seals. Unit 2 Drawing Series A-2600, "Fire Barrier Penetration Seal Details," Revision 5, showed seal installation details that met flood barrier requirements.

The inspectors determined that the licensee failed to install seals for pipe penetrations that could be subjected to floodwater. The licensee designed the auxiliary building extension to be watertight in order to protect the auxiliary building because the buildings were connected by a non-watertight door below the design flood elevation. The unsealed pipe penetrations combined with the non-watertight door could lead to flooding of the Unit 2 auxiliary building. The licensee corrected the condition by modifying the non-watertight door connecting the auxiliary building and the extension, so that if the Unit 2 auxiliary building extension flooded, the Unit 2 auxiliary building would not flood.

6. Non-Watertight Door and Hatch

During extent of condition reviews for the degraded hatches, the licensee identified non-watertight Unit 1 Hatch 522 and Unit 2 Door 253 that could be subjected to floodwater at 358 feet MSL. The licensee found that the door and hatch in the area between the Unit 1 and Unit 2 auxiliary building and containments could be subject to external floodwater because the area was below the design flood level, and the area floor drains were connected to Lake Dardanelle without backwater (check) valves. The inspectors determined that the licensee failed to translate design requirements into specifications and drawings for the Hatch 522 and Door 253. The licensee implemented compensatory measures to plug the floor drains upon notification of a flood.

7. Abandoned Equipment

During a flooding walkdown, the inspectors identified unsealed abandoned pipes that penetrated the Unit 1 auxiliary building flood barrier at 354 feet MSL. The inspectors discovered two pipes that penetrated the auxiliary building from the turbine building that were open on both ends. The licensee cut the pipes as part of a modification to abandon the waste solidification system. However, the design change failed to protect the Unit 1 auxiliary building from floodwater, a design requirement. The licensee corrected the condition by installing a blind flange and a pipe cap to seal the pipes.

8. Decay Heat Vault Drain Valves

The March 31, 2013, stator drop event revealed an open decay heat vault drain valve that allowed fire water internal to the auxiliary building to leak into Unit 1 decay heat vault B at 317 feet MSL. Unit 1, Safety Analysis Report, Amendment 26, Section 5.3.2, "Auxiliary Building," stated, in part, that the floor area at elevation 317 feet containing engineered safeguards equipment was partitioned into separate rooms to provide protection in the event of flooding due to a pipe rupture. In addition, the auxiliary building, which contains the decay heat removal vaults, is classified as seismic category 1 and is a safety-related structure; thereby the decay heat removal vaults are also safety-related. Each decay heat vault room contains a decay heat removal pump (low head safety injection) that is needed for accident mitigation.

The licensee determined that the reach rod for the valve was loose, so that the position indication was inaccurate, and that the condition applied to both Unit 1 decay heat vaults' drain valves. The inspectors identified that valve position indicated that the valve was closed for approximately 36 degrees of valve rotation. Consequently, when the valve indicated closed, it could actually be open. As stated above, the Unit 1 Safety Analysis Report indicated that the decay heat vaults were designed to be watertight, and the auxiliary building was designated seismic category 1 (safety-related), which includes the decay heat vaults; however, the inspectors determined that the vault drain valves were classified as non-safety-related components.

The inspectors determined that the licensee failed to identify the loose reach rods during daily operation or surveillance testing, correct the inaccurate position indication, and properly classify the vault drain valves as safety-related. The licensee corrected the deficiencies by replacing the reach rods and ensuring the position indication was accurate. In addition, the licensee initiated Condition Report CR-ANO-C-2014-01477 to document the inspectors concerns with maintenance and classification of the vault drain valves.

9. Startup transformer 2 Buswork

The inspectors identified that startup transformer 2 buswork was installed at 360.5 feet MSL. The licensee credited offsite power for Unit 1 and Unit 2 through startup transformer 2 up to the design flood level of 361 feet MSL, as an alternating current power source for vital and non-vital loads. The licensee implemented compensatory actions to seal the buswork upon notification of a flood.

Due to the number and relatively large area of unsealed penetrations affecting both Unit 1 and Unit 2 auxiliary buildings at plant grade or below, an external flood could cause an inflow of approximately 2,000 gallons per minute and overwhelm the total sump pump capacity of 300 gallons per minute. For unsealed penetrations, the inspectors calculated the inflow by creating a matrix of the penetrations, with a static head of water at the penetration given a flood height of 354 feet , 1 inch MSL. The inspectors calculated the potential flow through those unsealed penetrations using the Bernoulli and Darcy Weisbach equations, with the penetration lengths, number of elbows and other restrictions, as indicated on plant drawings, being included in the calculations. The inspectors estimated the flow through hatches by calculating the flowrate through the hatches during the stator drop event based on water volume and time and applying that potential flowrate to the remainder of hatches and doors. The static head of water on the hatches during the stator drop could approximate a flood height of 354 feet, 1 inch MSL. The Unit 1 and Unit 2 emergency diesel fuel storage building had 14 unsealed conduits that penetrated the flood barrier, and the inflow could overwhelm the sump pump capacity of 15 gallons per minute. The inspectors determined that the auxiliary and emergency diesel fuel storage buildings could flood if water level exceeded site grade elevation.

The inspectors conclude d that, for Unit 1 and Unit 2, the licensee failed to protect safety-related systems below the design flood level from external floodwater, including equipment inside of vaults. Most importantly, all long-term core makeup and cooling could have failed during an external flood.

The emergency diesel fuel storage building could have flooded, submerging the Unit 1 and Unit 2 diesel fuel oil transfer pumps, which could have starved the emergency diesel generators of fuel. Unit 1 and Unit 2 spent fuel pool cooling could have been lost because both units' pumps are in the auxiliary building below flood elevation and are not flood protected. Unit 2 outside containment isolation valves were affected because breakers for the valves could be submerged, however the valves were accessible for manual operation and the inside containment isolation valves would be available. Unit 1 and Unit 2 containment spray systems could be submerged. Unit 1 and Unit 2 portable recovery equipment, connections, and other recovery strategies, such as gravity feeding tanks, could be unavailable due to submergence from flooding.

The NRC and licensee identified multiple floodwater paths into the auxiliary building after the licensee had performed flooding walkdowns, as directed by the March 12, 2012, 50.54(f) letter, concerning actions to be taken by licensees that resulted from the Fukushima Dai-ichi nuclear power plant event. The licensee failed to properly identify all flood protection features, as specified in NEI 12-07, "Guidelines for Performing Walkdowns of Plant Flood Protection Features," Revision 0.

Licensee Personnel

J. Browning, Site Vice President

D. James, Director, Regulatory and Performance Department

S. Pyle, Manager, Regulatory Assurance

NRC ADAMS: ML14253A122