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.