05000220/FIN-2016004-01
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Finding | |
|---|---|
| Title | Licensee-Identified Violation |
| Description | The following violation of very low safety significance (Green) was identified by Exelon and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as an NCV. Technical Specification 6.4.1 for Unit 1 and TS 5.4.1 for Unit 2 state that, Written procedures shall be established, implemented, and maintained covering the following activities: ... d. Fire Protection Program Implementation. Procedure OP-AA-201-003, Fire Drill Performance, implements portions of the Exelon fire protection program, and OP-AA-201-003 states fire drills shall be conducted quarterly for each shift fire brigade. Contrary to the above, Exelon failed to correctly implement its fire brigade training program procedure. Specifically, Exelon failed to conduct fire drills for brigade teams A, C, and D for the third quarter 2015 as required by OP-AA-201-003 because of scheduling conflicts caused by emergent and planned work and station activities. For fire brigade A, the brigade was initially scheduled to perform a third quarter fire drill on July 22, 2015. However, that drill as well as subsequent drills which were scheduled to be performed on August 25, 2015, and September 30, 2015, respectively, were cancelled to facilitate other work activities. For fire brigade C, the third quarter drill which was scheduled for September 8, 2015 was cancelled because of station work load. For fire brigade D, a third quarter drill that was scheduled for September 24, 2015, was also canceled because of other work activities. On October 2, 2015, Exelon documented the missed quarterly drills in the CAP as IR 02564520. During the fourth quarter, crews A, C, and D each conducted a make-up drill as well as a regular quarterly drill. However on October 31, 2015, crew C failed its make-up drill. Crew C was remediated and passed a repeat drill on November 10, 2015. The inspectors determined that the performance deficiency was more than minor in accordance with IMC 0612, Appendix B, Issue Screening, because if left uncorrected, it could lead to a more significant safety concern. The inspectors decision was informed by examples 3j and 3k in IMC 0612, Appendix E, Examples of Minor Issues. The examples refer to an issue not being minor if significant programmatic deficiencies were identified with the issue that could lead to worse errors if left uncorrected. Specifically, 60 percent of the NMPNS fire brigade teams had missed their quarterly fire drill requirement which is indicative of a programmatic issue and there is a reasonable concern as to the effectiveness of the fire brigade since the required training had not been completed and one crew subsequently failed its next drill. Based on IMC 0609, Attachment 4, Initial Characterization of Findings, findings that involve discrepancies with the fire brigade are directed to IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power. From IMC 0609 Appendix A Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined that a the final significance must be determined using IMC 0609, Appendix M, Significance Determination Process Using Qualitative Criteria. The finding was determined to have very low safety significance (Green) because a prior similar violations significance bounded this findings significance. The prior similar violation occurred at NMPNS, which was documented in inspection report 05000220/410/2009006-01 as an NCV. Because this violation was determined to be of very low safety significance and entered into the CAP in IR 02564520, it is being treated as an NCV, consistent with section 2.2.3 of the NRC Enforcement Policy. |
| Site: | Nine Mile Point  |
|---|---|
| Report | IR 05000220/2016004 Section 4OA7 |
| Date counted | Dec 31, 2016 (2016Q4) |
| Type: | NCV: Green |
| cornerstone | No Cornerstone |
| Identified by: | Licensee-identified |
| Inspection Procedure: | |
| Inspectors (proximate) | B Palagi C Hunt G Hansen J Neurauter K Stoedter R Ng R Ruiz R Zuffa T Ospino V Meghani W Schaup |
| Violation of: | Technical Specification |
| INPO aspect | |
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Finding - Nine Mile Point - IR 05000220/2016004 | ||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Nine Mile Point) @ 2016Q4
Self-Identified List (Nine Mile Point)
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