Entergy Maliciously Contesting minor NRC Violations at ANO

Look at how much time is being eaten up over this non cited violation of the Fuel Oil piping by the mindlessly complex codes and regulation?  This is how bureaucratic war looks like to Entergy and the NRC. The interpretation of rules and codes as ruthless weapons? You see the excessive rules favors Entergy.

Entergy is sending the message to the NRC, you better be hyper vigilant on the rules and codes future violations...the bureaucracy that nobody can understand. So Entergy is trying to consume limited NRC resources on a non cited violation...the NRC is going to be excessively careful in the future concerning small violations. They are going to have to triple vitrify all the rules and codes. They are going to be buried in the excessive complex bureaucratic rules while not seeing the big violations.

They is how a war looks like between a shameless licensee and a neutered NRC...

0CAN091501

September 3, 2015

U.S. Nuclear Regulatory Commission

ATTN: Document Control Desk

11555 Rockville Pike

Rockville, MD 20852

SUBJECT: Response to Non-cited Violation in NRC Integrated Inspection

Report 05000313/2015002 and 05000368/2015002

Arkansas Nuclear One – Units 1 and 2

Docket Nos. 50-313 and 50-368

License Nos. DPR-51 and NPF-6

REFERENCE: NRC letter to Entergy, Arkansas Nuclear One – NRC Inspection Report 05000313/2015002 and 05000368/2015002, dated August 5, 2015

(0CNA081501) (ML15218A371)

 

Reference 1 provided the results of the Arkansas Nuclear One (ANO) integrated inspection for the second quarter of 2015. Per 10 CFR 50.4 and in accordance with the guidance in the

Enforcement Policy, Entergy Operations Inc. (Entergy) hereby contests one of the non-cited violations (NCVs) identified in the report.

A green NCV of 10 CFR Part 50, Appendix B, Criterion XI, “Test Control,” was identified in the report for failure to establish and maintain an adequate testing program for the fuel oil transfer piping for ANO, Units 1 (ANO-1) and 2 (ANO-2). Specifically, the licensee did not establish inservice inspection (ISI) requirements to detect degradation of the fuel oil piping, above ground and buried, between the fuel oil storage tanks and the emergency diesel generator (EDG) day tanks.

ANO-2 Conclusion

The ANO-2 ASME Section XI Inservice Inspection (ISI) program correctly excludes the diesel fuel oil piping based on the requirements of 10 CFR 50.55a and the ANO-2 licensing basis. There are no requirements of ASME Section XI or 10 CFR 50.55a that require plants that received a construction permit after January 1, 1971, to include piping in the Section XI boundaries not required by regulation or the licensing basis to be designed and constructed to ASME Section III, Class 1, 2, or 3 requirements. For ANO-2 Entergy’s implementation of Safety

Guide 26 (RG 1.26) and the classification of the fuel oil piping as ANSI B31.1 were described in the licensing basis and accepted by the NRC. Also, the position taken by the NRC in the subject NCV appears inconsistent with the regulatory guidance provided in NUREG 1482, Revision 2.