ML110060549

Component Cooling Water

ML110060549
Person / Time
Site:	Saint Lucie
Issue date:	02/11/2011
From:	NRC/NRR/DIRS/IOEB
To:
Mark King, NRR, 301-415-1150
Shared Package
ML110130036	List: ML110060549 ML110400155
References
Download: ML110060549 (78)

Text

CCW FINDING and Component Cooling Water FINDING SEARCH RESULTS (December 6, 2004 to December 6, 2010)

Finding search results identified two greater-than-green findings related to CCW - including:

One Yellow Finding moderate to substantial safety risk) and One White Finding (low to moderate safety risk) related to Component Cooling Water (CCW) systems.

Mitigating Systems 12/03/2009 ST. LUCIE Yellow

• SCWE: N

• HP: Y *PIR: N Docket/Status: 05000335 (C)

Open: 2009006 Discussed: 2010009 (PIM) Failure to Identify and Correct a Condition Adverse to Quality The team identified an AV of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to implement adequate corrective actions associated with the CCW air intrusion event that occurred in October, 2008. The corrective actions were inadequate in that the licensee failed to identify and correct the cause of air intrusion. The issue was entered in the licensees corrective action program as CR 2009-25209 to address the ineffective corrective actions for the air intrusion event. Licensee corrective actions included isolating the CCW system from the containment IA compressors. The finding was determined to be more than minor because it affected the availability, reliability and capability of a safety system to perform its intended safety function. Specifically, without knowing the leak path from the containment IA compressors to the CCW system, the licensee could not ensure that adequate cooling would be available or maintained to essential equipment used to mitigate design bases accidents. The finding was assessed for significance in accordance with NRC Manual Chapter 0609, using the Phase I and Phase II SDP worksheets for mitigating systems. It was determined that a Phase III analysis was required since this finding represented a loss of safety system function for multiple trains which was not addressed by the Phase II pre-solved tables/worksheets. Based on the Phase III SDP, the finding was preliminarily determined to be greater than Green. This finding was determined to have a cross-cutting aspect in the area of Human Performance, Decision Making, specifically H.1(a). IR # 05000335, 389/2009006 dated January 19, 2009.

The Regulatory Conference was held on February 19, 2010. After considering the information developed during the inspection and information provided by FPL during and after the conference, the NRC has concluded that the finding involving the failure to identify and correct the source of the air in-leakage into the CCW system is characterized as Yellow, i.e., a finding of substantial significance with regard to safety, which will require additional NRC inspections.

The NRC also determined that the Unit 1 CCW system met the design requirements at the time of licensing and at the time of the October 2008 air intrusion event. Therefore, this issue does not represent a performance deficiency, and accordingly, a violation of 10 CFR 50, Appendix B, Criterion Ill did not occur. Accordingly, Apparent Violation 05000335, 389/2009006-05, Failure to Translate Design Basis Specifications to Prevent Single Failure of CCW is considered closed and deleted from the record. IR 05000335, 389/2010007 dated April 19, 2010.

Mitigating Systems 07/09/2009 PRAIRIE ISLAND White

• SCWE: N

• HP: Y *PIR: N Docket/Status:, 05000306 (C)

Open: 2009010 Discussed: 2009013, 2010009, 2010012 (PIM) Failure to Ensure Design Measures Were Appropriately Established for The Unit 2 Component Cooling Water System An inspector identified apparent violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, was identified due to the licensees failure to establish design control measures to ensure that the design basis for the Unit 2 CCW system was correctly translated into specifications, drawings, procedures, and instructions. Specifically, the licensee failed to ensure that the safety related function of the CCW system was maintained following initiating events (such as high energy line break, seismic or tornado events) in the turbine building. This issue has been preliminarily determined to be of low to moderate safety significance (White). This issue was entered into the licensees corrective action program as corrective action document 1145695. Upon identifying this issue, the licensee immediately declared the Unit 2 CCW system inoperable and entered Technical Specification 3.0.3. The Technical Specification was exited following the closure of several system isolation valves approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> later. The closure of the isolation valves prevented the Unit 2 CCW system from being vulnerable to failure following events in the turbine building. This finding was determined to be more than minor because it impacted the design control and external events aspects of the Mitigating Systems Cornerstone. The finding also impacted the Mitigating Systems Cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The initiating events in the turbine building could cause the CCW piping to fail. Loss of CCW inventory affects both trains of CCW based on the piping arrangement. The loss of both trains of CCW required a phase 3 significance determination.

The results of the phase 3 assessment showed a delta core damage frequency of 3.2E-6, White. The cause of this finding was related to the cross cutting element of Human Performance, Decision Making because the licensee failed to make safety significant and risk significant decisions using a systematic process to ensure that safety was maintained (H.1(a)).

Since both the Unit 1 and Unit 2 cross-cutting aspects are from the same performance deficiency and are separated based on the risk determination, the aspect of H.1(a) counts as one cross-cutting aspect in this report (Section 4OA5.1). Final determination letter issued with report number 2009-013 on September 3, 2009.

Finding search results for the term: CCW or Component Cooling Water.

All the items below are identified as Green (or very low safety significance) or were severity level four (SL-IV) violations (traditional violations that were not colorized).

ROP PIM Reports - Event Dates: 12/06/2004 - 12/06/2010 - Generated on 12/6/10 By Types, Cornerstones, Event Dates, Sites Key Word Search on CCW, Cross Cutting Areas:

• SCWE = Safety Conscious Work Environment

• HP = Human Performance

• PIR = Problem Identification and Resolution Finding Initiating Events 06/30/2010 SURRY Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status: 05000280 (C)

Open: 2010003 (PIM) Inadequate Rigging Practices Result in Damage to Safety Related Equipment A self-revealing Green Finding was identified for failure to adequately rig a 300 pound motor in the auxiliary building in accordance with the manufacturers recommendations on May 11, 2010.

As a result, the motor slipped from its rigging and dropped approximately 15 feet onto the A component cooling water (CCW) pump motor below, damaging the motors cabling and electrical junction box. The CCW pump was declared inoperable (CR 380834), the damage was repaired, and the CCW pump restored to an operable status on May 15, 2010. Inspectors determined that the failure to implement adequate rigging practices in accordance with vendor recommendations as required by procedure MA-AA-101, Revision 5, Fleet Lifting and Material Handling constituted a performance deficiency and a finding which was reasonably within the licensees ability to foresee and correct and which should have been prevented. The finding is similar to MC 0612, Appendix E example 4.f, and is more than minor because it resulted in damage to and inoperability of a risk significant component. The finding is associated with the human performance attribute of the initiating events cornerstone and adversely affected the cornerstone objective to limit the likelihood of those events which upset plant stability and challenge critical safety functions during shutdown as well as power operations because a loss of the component cooling water system would have resulted in a unit transient. The finding, evaluated per Attachment 4 of MC-0609, Phase 1 - Initial Screening and Characterization of Findings, was determined to be of very low safety significance (Green) because it did not contribute to both the likelihood of a plant transient and the loss of accident mitigation equipment. This finding has a cross-cutting aspect in the area of human performance, decision making because the licensee did not make safety/risk significant decisions using a systematic process, especially when faced with uncertain decisions, to ensure safety is maintained (H.1(a)). Specifically, the rigging team made safety/risk significant decisions within lifting/rigging procedures that did not include a systematic process for evaluating each lift, especially loads

<5000 lbs in the vicinity of risk significant equipment.

Initiating Events 09/30/2010 ROBINSON Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status:, 05000261 (C)

Open: 2010004 (PIM) Failure to have adequate work and post maintenance testing instructions for the volume control tank comparator module A self revealing Green finding was identified for a failure to have adequate work orders to properly configure and post maintenance test the volume control tank (VCT) level comparator module. The licensees procedure ADM-NGGC-0104, Work Implementation and Completion, required that work orders contain all work activities necessary to perform all related work activities including Post Maintenance Testing (PMT). The licensees work orders for installing a jumper on the VCT level comparator module and for post maintenance testing failed to contain adequate instructions to properly configure (place jumper in correct location) and post maintenance test the volume control tank level comparator module. This resulted in the failure of the charging pump suction to automatically transfer from the volume control tank to the refueling water storage tank (RWST) when the auto transfer VCT low level setpoint was reached. The licensees identified corrective actions included repairing the subject VCT level module, reviewing the adequacy of other replacement NUS modules that have non-safety control functions and revising the site specific PMT procedures to provide more specific guidance for ensuring that the control loop circuit is adequately tested. The failure to have adequate work order instructions to properly configure and post maintenance test the volume control tank level comparator module is a performance deficiency. This finding is greater than minor because the failure to auto transfer from the VCT to the RWST could cause a failure of the charging pump, resulting in the loss of seal injection which is a precursor to a seal LOCA.

Using IMC 0609, Significance Determination Process, (SDP) Phase 1 Worksheet, the inspectors concluded that a Phase 2 evaluation was required since the finding could have likely affected other mitigation systems resulting in a total loss of their safety function. This issue was evaluated using IMC 0609, Appendix A (SDP Phase 2) as being potentially greater than green with loss of component cooling water (LOCCW) and loss of service water (LOSW) as the dominant sequences. A phase 3 SDP risk evaluation was performed by a regional senior reactor analyst in accordance with the guidance in IMC 0609 Appendix A utilizing the NRCs Robinson Standardized Plant Analysis Risk (SPAR) model. The VCT level comparator module performance deficiency resulted in a core damage frequency increase of less than 1E-6, Green.

The risk was mitigated by the availability of the letdown and normal makeup charging pump suction sources, which would be available under certain conditions reducing the likelihood of an autoswap demand. Another factor which mitigated the risk is that the fire shutdown procedures for most fire areas specify use of a manual RWST supply valve. The performance deficiency is characterized as Green, a finding of very low safety significance. This issue has a cross-cutting aspect in the resources component of the human performance area because the licensee did not provide complete, accurate, and up-to-date work packages for the configuration and testing of the VCT comparator module (H.2.(c)) (Section 1R19)

Initiating Events 09/30/2010 ROBINSON Green

• SCWE:

N

• HP:

N

• PIR:

N Docket/Status:, 05000261 (C)

Open: 2010004 (PIM) Failure to design and implement a simulator model that demonstrated reference plant response A self-revealing Green NCV of 10 CFR 55.46(c), Simulation Facilities, was identified for a plant referenced simulator used for administration of operating tests not correctly modeling the reference plant. A loss of electrical power that resulted in a loss of component cooling water (CCW) to the reactor coolant pump seals was not properly modeled in the simulator. When power to safety-related 480 volt bus E-2 was transferred to the emergency diesel generator in the reference-plant, FCV-626, thermal barrier heat exchanger outlet isolation flow control valve, closed. The simulator modeled FCV-626 to respond to CCW flow through the valve and did not model the effect of a loss of power to the valve operator and associated control circuit.

Consequently, with a loss of power to bus E-2, the simulator model allowed this valve to remain open. The licensee documented the issue in Significant Adverse Condition Investigation Report, 390095. As corrective action the licensee changed the simulator modeling to match the plant configuration. The inspectors determined that the failure of the simulator to accurately demonstrate reference plant response was a performance deficiency. This finding was more than minor because it affected the human performance attribute of the initiating events cornerstone in that the unexpected closure of FCV-626 raises the likelihood of human error in response to a loss and subsequent re-energization of the E-2 Bus. This could challenge reactor coolant pump seal cooling and result in reactor coolant pump seal failure. The finding was evaluated using the Operator Requalification Human Performance SDP (MC 0609, Appendix I) because it was a requalification training issue related to simulator fidelity. The finding was of very low safety significance (Green) because the discrepancy did not have an impact on operator actions resulting in a total loss of RCP seal cooling and subsequent increase in reactor coolant system (RCS) leakage. There is not a cross-cutting aspect associated with the finding because the performance deficiency involving the simulator modeling occurred over 3 years ago and does not reflect current licensee performance (Section 1R11.2).

Miscellaneous 09/30/2010 ST. LUCIE N/A

• SCWE:

N

• HP:

N

• PIR:

N Docket/Status: 05000335 (C)

Open: 2010009 (PIM) 95002 Supplemental Inspection Results The NRC staff performed this supplemental inspection in accordance with IP 95002, Inspection for One Degraded Cornerstone or any Three White Inputs in a Strategic Performance Area, to assess the licensees evaluation associated with air intrusion into Unit 1 component cooling water (CCW) system in 2008 and 2009. The NRC staff previously characterized this issue as having Yellow safety significance, as documented in NRC IR 05000335/2010007 and 05000389/2010007. The inspectors determined that the St. Lucie staff performed a comprehensive evaluation of the subject Yellow finding associated with the CCW system air intrusion event. The St. Lucie staffs evaluation identified root causes of the issue to be: (1) decision making by the organization was insufficient due to inadequate knowledge and skills related to risk significant decisions, conservative assumptions and timely communication between departments, (2) the organization missed several opportunities to promptly identify, fully analyze and resolve in a timely manner the air intrusion event, (3) inadequate fleet/site procedures resulted in the failure to recognize the condition and significance of the event in a timely manner, (4) management did not effectively implement policies and procedures, which resulted in a reluctance to challenge issues and recognize the significance of the 2008 event and a repeat of the event in 2009, (5) less than adequate design of containment air compressor system resulted in recurrent air intrusion events, and (6) less than adequate maintenance resulted in a similar 2009 air intrusion event. The inspectors determined that the root cause evaluations for the CCW system air intrusion events were thorough and broad in scope. The evaluation appropriately determined the root and contributing causes, addressed the extent of condition and extent of cause, determined if safety culture contributed to the issue, and established and scheduled corrective actions that were sufficient to address the causes and prevent recurrence of the air intrusion event. The inspection team performed an independent extent of condition and extent of cause review and a focused review utilizing a safety culture expert as it related to the root cause evaluations. Overall, the team concluded that the licensees root cause evaluation and corrective actions, completed and planned, were sufficient to prevent recurrence. The root cause evaluation appropriately considered safety culture. The team did not identify any concerns associated with the safety conscious work environment at St.

Lucie. As a result of the NRC conclusion that the licensee appropriately addressed the above issues, the Yellow finding associated with air intrusion into Unit 1 CCW system will be considered in assessing plant performance for a total of four quarters in accordance with the guidance in IMC 0305, Operating Reactor Assessment Program.

NonCited Violation Initiating Events 02/17/2006 SALEM Green

• SCWE:

N

• HP:

N

• PIR:

Y Docket/Status: 05000272 (C), 05000311 (C)

Open: 2006006 (PIM) INADEQUATE PROCEDURE FOR LOSS OF COMPONENT COOLING WATER The team identified a finding of very low safety significance involving a non-cited violation of Technical Specification 6.8.1, Procedures, for an inadequate procedure to respond to a loss of component cooling water (CCW) event. The procedure was inadequate because it required operators to trip the reactor and immediately enter the emergency operating procedures (EOPs), but relied on an alarm response procedure to accomplish time critical and risk significant actions. The team identified that the execution of the alarm response procedure could be delayed during EOP implementation. As a consequence of relying on a lower tier procedure, the delayed actions significantly decreased margin with respect to reactor coolant pump (RCP) seal temperatures approaching operating limits during this postulated event. This finding was more than minor because it was similar to Example 3.k in NRC Inspection Manual Chapter (IMC) 0612 Appendix E, Examples of Minor Issues. Specifically, PSEGs human reliability analysis associated with a loss of CCW event, assumed operators could complete required risk significant, time critical actions in less than one minute, when in fact, the actions could have nominally taken 14 minutes. As a result of this procedure deficiency, there was a significant reduction in the time margin assumed in PSEG's analysis to perform risk significant manual actions (i.e., isolate letdown flow and transfer charging pump suction). This finding affected the Initiating Events Cornerstone objective to limit the likelihood of events that challenge critical safety functions, because it was associated with the cornerstone's attribute for procedure quality. The finding was of very low safety significance because it screened to Green in Phase 1 of the significance determination process (SDP) documented in IMC 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations.

Specifically, while the finding directly affected the likelihood of an RCP seal failure because PSEG's previous procedures had little margin for operator error or delay, it appeared that operators could have isolated letdown prior to reaching excessive RCP seal temperatures.

Additionally, there was no affect on mitigating systems. A contributing cause of this finding was related to the cross-cutting area of problem identification and resolution.

Initiating Events 03/31/2007 INDIAN POINT Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status:, 05000247 (C)

Open: 2007002 (PIM) FAILURE TO INCORPORATE DESIGN BASIS INFORMATION INTO PROCEDURES TO ASSURE ADEQUATE COOLING WATER FLOW TO THE RCP THERMAL BARRIERS The inspectors identified a Green, non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion III, Design Control, in that, Entergy did not appropriately incorporate design requirements into an operating procedure used to establish adequate component cooling water (CCW) flow to the reactor coolant pump (RCP) thermal barriers. Specifically, the flow specification in the CCW operating procedure did not incorporate the calculated design flow requirements to bound allowable CCW temperature limits. Entergy entered this issue into their corrective action program and will be evaluating the flow requirements specified in procedure 2-SOP-4.1.2, Component Cooling Water System Operation, to ensure that they bound the allowed plant operating limits. The inspectors determined that this finding was more than minor because it was associated with the Equipment Performance attribute of the Initiating Events cornerstone; and, it affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, Entergy did not incorporate design flow requirements necessary to assure adequate cooling water flow to the RCP thermal barriers into the plant operating procedures which establish the required flow. On a loss of seal injection, the procedure did not ensure that the heat removal capability was adequate to prevent a rise in seal temperature which would require the RCP to be stopped with a subsequent reactor trip. The inspectors evaluated the significance of this finding using Phase 1 of IMC 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations. This finding was determined to be of very low safety significance because it would not result in exceeding the Technical Specification limit for identified reactor coolant system leakage and would not have likely affected other mitigating systems resulting in a loss of their safety function. The inspectors found that the procedurally established nominal flow band would have assured adequate cooling of the RCP thermal barriers for the highest CCW supply temperature recorded over the previous year. The inspectors determined that this finding had a cross-cutting aspect in the area of human performance because the operating procedure used to set the flow rate of cooling water to the RCP thermal barriers was not adequate to make certain that sufficient cooling water was available to assure the components could perform their design function.

(H.2(c))

Initiating Events 03/31/2007 INDIAN POINT Green

• SCWE:

N

• HP:

N

• PIR:

N Docket/Status:, 05000247 (C)

Open: 2007002 (PIM) FAILURE TO ESTABLISH TESTING TO ASSURE ADEQUATE COOLING WATER FLOW TO THE RCP THERMAL BARRIERS The inspectors identified a Green, NCV of 10 CFR 50 Appendix B, Criterion XI, Test Control, in that, Entergy did not establish appropriate testing to assure adequate component cooling water (CCW) flow to the reactor coolant pump thermal barriers. Specifically no preventive maintenance activities or functional checks were conducted for the individual flow meters. It was determined that the rotameters on 21 and 23 RCP were not indicating correctly and that actual CCW flow to the thermal barrier heat exchangers was less that the design requirements for CCW temperature. Entergy entered this issue into their corrective action program (CR-IP2-2007-00783 and 00955), adjusted individual cooling water flow within the nominal band using ultrasonic flow meters, wrote work orders to replace the faulty flow meters, and is conducting an evaluation to determine the appropriate test requirements for the flow indicators. These inspectors determined that this finding was more than minor because it was associated with the Equipment Performance attribute of the Initiating Events cornerstone; and, it affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, Entergys test program did not assure that all testing required to demonstrate that the RCP thermal barriers will perform satisfactorily in service because no testing was performed to ensure the accuracy of the individual flow meters used to establish the required cooling water flow. Consequently, it was identified that two individual flow indicators did not read correctly and the CCW flow to two RCPs was not sufficient to assure adequate cooling in the event that seal water was lost based on the flow requirements established in design calculations. On a loss of seal injection, the cooling water flow would not ensure that the heat removal capability was adequate to prevent a rise in seal temperature which would require the RCP to be stopped with a subsequent reactor trip. The inspectors evaluated the significance of this finding using Phase 1 of IMC 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations. This finding was determined to be of very low safety significance because it would not result in exceeding the Technical Specification limit for identified reactor coolant system leakage and would not have likely affected other mitigating systems resulting in a loss of their safety function.

Initiating Events 12/31/2007 OCONEE Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status:, 05000287 (C)

Open: 2007005 (PIM) Inadequate Loss of Unit 3 SFP Cooling Procedure A self-revealing non-cited violation (NCV) of Technical Specification (TS) 5.4.1 was identified for failure to establish and implement an adequate procedure for loss of the Unit 3 spent fuel pool (SFP) cooling and/or level. More specifically, Abnormal Procedure AP/3/A/1700/035, Loss of SFP Cooling and/or Level, did not reflect the dependency that Unit 3 SFP cooling has on condenser circulating water (CCW) booster pump flow. If it had, the unexpected Unit 3 SFP temperature increase on December 1, 2007, could have been mitigated in a more timely manner and the SFP temperature increase limited to a lower value. The licensees failure to adequately establish and implement the procedure for loss of spent fuel pool cooling was a performance deficiency. The finding was considered to be more than minor because it affected the initiating events cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions. The finding was not suitable for SDP evaluation, but was reviewed by NRC management and was determined to be of very low safety significance, because the rate of SFP heatup was low (10 degrees F in four hours), the operators demonstrated the ability to restore CCW booster pump flow within a relatively short time period with respect to the heatup rate, and the Unit 1 and 2 recirculating cooling water (RCW) system was available to be lined up to supply cooling to the Unit 3 SFP cooling heat exchangers per existing plant procedures if needed. This finding was entered into the licensees corrective action program. It has a cross-cutting aspect of complete, accurate, and up-to-date procedures (H.2.c), as described in the resources component of the human performance cross-cutting area (Section 1R20b.(1)).

Initiating Events 02/08/2008 INDIAN POINT 3 Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status:, 05000286 (C)

Open: 2008007 (PIM) Inadequate Procedure Guidance to Diagnose and Align RCP Seal Cooling The team identified a Green non-cited violation of technical specification 5.4.1.d for failure to provide adequate procedure directions in 3-AOP-SSD-1, Control Room Inaccessibility Safe Shutdown Control, Rev. 6, for operators to properly determine if a loss of cooling to the reactor coolant pump (RCP) seal had occurred due to spurious closure of motor operated valves in the component cooling water (CCW) system. This finding was more than minor because it affected the procedure quality attribute of the Initiating Events cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, establishing adequate guidance to diagnose and align RCP seal cooling functions is important to limit the likelihood of an RCP seal loss of coolant accident. The team assessed this finding in accordance with NRC IMC 0609, Appendix F, Fire Protection Significance Determination Process. This finding screened to very low safety significance (Green) in Phase 1 of the SDP because it was assigned a low degradation rating.

The team determined that this finding has a cross-cutting aspect in the area of human performance because Entergy did not provide adequate procedure guidance to diagnose and align RCP seal cooling functions adequately to preclude seal leakage rates in excess of Appendix R Safe-Shutdown evaluation for a control building fire scenario (H.2(c))

Initiating Events 03/31/2009 KEWANUEE Green

• SCWE:

N

• HP:

N

• PIR:

Y Docket/Status: 05000305 (C)

Open: 2009002 (PIM) Inappropriate Application Of A Dedicated Operator During A Component Cooling Water Surveillance A finding of very low safety significance (Green) and associated Non-Cited Violation of 10 CFR 50.65(a)(4) was identified by the inspectors for the failure to properly assess risk that resulted from risk significant maintenance being performed on the component cooling water (CCW) system, when the licensee inappropriately applied criteria for the use of a dedicated operator to meet availability requirements. As part of its corrective actions, the licensee stopped work that required the use of a dedicated operator pending further evaluation. The issue was more than minor because the licensees risk assessment for March 11, 2009, failed to consider the CCW unavailable during maintenance. Specifically, the failure to account for the unavailability of CCW resulted in an inadequate daily risk assessment and could affect the unavailability time of this system in related performance and maintenance rule indicators. The inspectors evaluated the finding using the Significance Determination Process in accordance with Inspection Manual Chapter 0609, Significance Determination Process, Attachment K, Maintenance Risk Assessment and Risk Management Significance Determination Process, dated May 19, 2005, and determined the issue screened as having very low safety significance (Green), because the incremental conditional core damage probability was less than 1E 6 due to the test condition lasting only four hours. The inspectors determined that the finding had a cross cutting aspect in the corrective action program component of problem identification and resolution, because the licensee failed to thoroughly evaluate a prior problem such that the resolution addressed the causes and extent of conditions necessary to preclude this event (P.1(c)).

Initiating Events 12/31/2009 KEWAUNEE Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status: 05000305 (C)

Open: 2009005 (PIM) Inadequate Work Instructions Lead to Component Cooling Water Relief Valve Lift And Surge Tank Level Drop A finding of very low safety significance and associated Non-Cited Violation of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," was self-revealed for the failure to have adequate work instructions in place during the isolation of component cooling water (CCW) flow in the reactor coolant pump vaults. Specifically, the inadequate valve isolation sequence and the speed at which the outlet valves were closed caused CCW system relief valves to lift and rapidly drain the component cooling water surge tank while the CCW system was supporting the residual heat removal system for decay heat removal. In response to the issue, the licensee implemented compensatory corrective actions to modify the tagout and hang tags on the appropriate CCW isolation valves. The inspectors determined that the finding was more than minor because it was associated with the Initiating Events Cornerstone attribute of configuration control and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The inspectors determined that the finding could be evaluated in accordance with Inspection Manual Chapter 0609, Appendix G, "Shutdown Operations Significance Determination Process." The inspectors used Checklist 3 contained in Attachment 1 and determined that the finding required a Phase 2 analysis since the finding increased the likelihood that a loss of decay heat removal would occur. The Region III senior reactor analyst performed the assessment using Appendix G, Attachment 2, "Phase 2 Significance Determination Process Template for PWR [Pressurized Water Reactor] During Shutdown," and determined that this issue is best characterized as a finding of very low safety significance (Green). This finding has a cross-cutting aspect in the area of human performance, resources component, because the licensee did not maintain long-term plant safety by maintenance of design margins. Specifically, the work instruction did not adequately account for the low design margin that existed between the system operating pressure and the relief valve setpoints when both CCW pumps were running (H.2(a)).

Initiating Events 03/31/2010 FARLEY Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status: 05000348 (C)

Open: 2010002 (PIM) Failure to control combustible material in a no intervening combustible allowed area of the plant An NRC-identified NCV of License Condition 2.C.(4) was identified for the failure to control combustible material in the Unit 1 Component Cooling Water (CCW) Pump area as required by the licensees administrative controls program. Workers left combustible material in the area of the 1A CCW pump motor, which is identified as a 10 CFR 50, Appendix R,Section III.G.2.b area. Twenty feet of cable separation exists in the area, but because no fire barrier exists, no intervening combustibles or fire hazards are allowed. Work Order (WO) 1082262401 was generated by licensee personnel to clean the sight-glasses on the inboard and outboard motor bearings of the 1A CCW pump. Part of the preparation and planning process includes a transient fire load analysis, which is included in the maintenance work instructions. In the case of this WO, the instructions utilized the fire load analysis data for the Unit 1 CCW heat exchanger area instead of the CCW pump area, and was included in the written instructions.

The inspectors determined these inadequate work instructions contributed to the performance deficiency. The licensee entered their failure to control combustible material into their CAP for resolution (CR 2009114934) for resolution. The licensees immediate corrective action was removal of the material from the location. The finding was more than minor because it adversely affected protection against the external factors attribute of the Initiating Events (IE) cornerstone, to limit the likelihood of those events upsetting plant stability and challenging critical safety functions during shutdown, as well as power operations. Specifically, this finding affected plant safety-related equipment required for the safe shutdown of the plant in the event of a plant fire. This finding was assessed using the Phase 1 screening worksheets of Appendix 4 and Appendix F of MC 0609. The inspectors determined the presence of combustible materials was a low degradation finding against the fire protection program, because the identified material had a low likelihood of causing a fire from an existing source of heat or electrical energy. The inspectors determined the finding was of very low safety significance (Green) because of the low degradation rating. This finding was assigned a cross-cutting aspect in the resources component of the Human Performance area because complete, accurate and up-to-date design documentation, procedures, work packages, and correct labeling of components were not provided (H.2(c)) (Section 1R05).

Initiating Events 03/31/2010 FARLEY Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status: 05000348 (C)

Open: 2010002 (PIM) Failure to maintain control of combustible material A self-revealing NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, was identified for the licensees failure to maintain combustible material a distance of 35 feet or greater from the hot work area as required by station procedure FNP-0-AP-38, Use of Open Flame. Unit 1 entered a Notification of Unusual Event (NOUE) emergency action level on December 12, 2009, when a fire occurred in the CCW heat exchanger/pump room. The fire occurred below and to one side of the scaffold near the service water (SW) supply to the 1A CCW heat exchanger isolation valve Q1P16V003A. The cause of the fire was combustible material left in the work area by licensee personnel performing lead abatement on piping supports for a plant modification. Welding personnel had later entered the area, performed welding/grinding activities, then placed work-related material in a concentrated area under the work area. The licensee entered this performance deficiency into their CAP (CR 2009114825) for resolution. The finding was more than minor because it adversely affected the protection against the external factors attribute of the IE cornerstone to limit the likelihood of those events upsetting plant stability and challenge critical safety functions during shutdown, as well as power operations. Specifically, this finding resulted in upsetting plant stability and potentially affected plant safety-related equipment. This finding was assessed using the Phase 1 screening worksheets of Appendix 4 and Appendix F of MC 0609 SDP, and determined a Phase 2 analysis was required. Fire Damage State (FDS) 0 was assigned to the actual fire and any postulated fires due to the performance deficiency. FDS 0 indicated that no functions failed as a consequence of these fires. In the actual fire there was no functional damage to any target.

Also, the peak heat release had happened and passed when the fire was extinguished.

Consistent with Inspection Manual Chapter 0609, Appendix F, a maximum heat release rate of 200 KW was selected for the postulated transient combustible fires. No targets were observed in the zone of influence where the combustible material was located. Under step 2.2 of Appendix F performance deficiencies associated with FDS 0 fires were not analyzed in the Fire Protection SDP as a risk contributor. Therefore, the finding was determined to be of very low safety significance (Green). A contributing cause of the finding is the failure of supervisory personnel to ensure the area was free of combustible material as required by FNP-0-AP-38 and the actual open flame permit. Therefore, this finding was assigned a cross-cutting contributing cause related to the Human Performance work-practices component, and its aspect of the licensee ensures supervisory and management oversight of work activities, including contractors, such that nuclear safety is supported (H.4(c)) (Section 4OA3).

Mitigating Systems 12/31/2004 OCONEE Green

• SCWE:

N

• HP:

N

• PIR:

N Docket/Status: 05000269 (C), 05000270 (C), 05000287 (C)

Open: 2004005 (PIM) Incorrect Wiring of the SSF Submersible Pump Motor Leads A self-revealing non-cited violation of 10 CFR 50, Appendix B, Criterion XI, Test Control, was identified for the failure to establish and perform adequate testing to ensure that the standby shutdown facility (SSF) submersible pump would operate correctly to provide SSF equipment with a makeup source of water to the Unit 2 condenser circulating water (CCW) header when called upon. Specifically, the licensee's test program had failed to reveal that the pump's power leads had been reversed since November 19, 1992, despite the performance of twelve surveillances between November 19, 1992, and February 3, 2004. Failure to maintain the SSF submersible pump in a ready to operate condition was considered to be more than minor, in that, its incorrectly wired motor leads directly affected the cornerstone objective to ensure equipment reliability of a mitigating system (i.e., the SSF). A Phase 3 risk analysis determined that this issue was of very low risk significance. This was based primarily on the availability of an alternate source of water inventory to fill the Unit 2 CCW header (i.e.,via reverse, gravity supplied CCW flow from Lake Keowee through the unit's condensate coolers) (Section 4OA5.8).

Mitigating Systems 12/31/2004 SAN ONOFRE Green

• SCWE:

N

• HP:

N

• PIR:

Y Docket/Status:, 05000362 (C)

Open: 2004005 (PIM) Missing Taper Pins in Component Cooling Water System Butterfly Valves A self-revealing, noncited violation of 10CFR 50, Appendix B, Criterion XVI, was identified for the licensees failure to determine the cause of missing taper pins in component cooling water (CCW) 28 inch Fisher butterfly valves and to take appropriate corrective actions to prevent recurrence. The finding was more than minor because it affected the equipment performance attribute of the mitigating systems cornerstone, and if left uncorrected, could result in a more significant safety concern. Missing taper pins increase the potential to render the CCW system inoperable due to cross train leakage because the 50 gpm leak caused by a missing taper pin exceeds the operability leak rate limit of 18 gpm. Based on the results of the Significance Determination Process, Phase 1 evaluation, the finding was determined to have very low safety significance (Green) because it did not result in an actual loss of safety function of the CCW system. This finding also had crosscutting aspects associated with problem identification and resolution, because the condition was not properly corrected when previously identified.

Mitigating Systems 09/30/2005 KEWANUEE SL-IV

• SCWE:

N

• HP:

N

• PIR:

N Docket/Status: 05000305 (C)

Open: 2005012 (PIM) Failure to Report in a Timely Manner an Unanalyzed Condition Involving a Potential Runout Concern With the CCW Pumps The inspectors identified a Non-Cited Violation (NCV) when the licensee failed to make a written report, within 60 days, to the NRC in accordance with 10 CFR 50.73(a)(2)(ii)(B), when an unanalyzed condition that significantly degraded plant safety was identified. Specifically, the licensee did not recognize the significance of a previously identified condition involving a potential runout issue with the component cooling water (CCW) pumps, and did not report this condition until the inspectors identified the requirement. The concern related to the CCW pump capability to provide required flow under certain conditions. Specifically, during a loss of power, and with specific system configurations, the loss of power could lead to a CCW pump runout condition. The primary cause of this finding was related to the cross-cutting area of human performance. Because this issue affects the NRC's ability to perform its regulatory function, it was evaluated using the traditional enforcement process. The inspectors determined that this violation is of very low safety significance and because the licensee entered the issue into their corrective action program (CAP026528), this violation is being treated as an NCV consistent with Section VI.A.1 of the NRC Enforcement Policy. The licensee has taken actions to revise plant procedures to address this issue.

Mitigating Systems 12/16/2005 POINT BEACH Green

• SCWE:

N

• HP:

N

• PIR:

N Docket/Status: 05000266 (C), 05000301 (C)

Open: 2005018 (PIM) Failure to Apply Adequate Design Controls During Replacement of Service Water (SW)

Valves SW-360 and SW-322 A self-revealed finding of very low safety significance was identified by the inspectors associated with a violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control." During replacement of the Service Water outlet valves for the Component Cooling Water (CCW) heat exchangers, the licensee failed to evaluate design differences between the original valves and the replacement valves. These differences led to the eventual failure of the stems in both valves. The issue was more than minor because it affected the mitigating system cornerstone attribute of "Design Control." The finding screened as having very low significance (Green) using IMC 0609, Appendix A, "Significance Determination of Reactor Inspection Findings for the At-Power Situations," because the inspectors answered "no" to all five questions under the Mitigating Systems Cornerstone column of the Phase 1 worksheet. While the design deficiency led to failure of the valves, the failures occurred during a plant shutdown; therefore, the valves would not have been required to function as designed.

Mitigating Systems 12/31/2005 OCONEE Green

• SCWE:

N

• HP:

N

• PIR:

N Docket/Status: 05000269 (C), 05000270 (C), 05000287 (C)

Open: 2005005 (PIM) Inadequate Procedures for Testing the SSF Diesel Generator With the CCW Supply Secured A Green self-revealing non-cited violation was identified for failure to have adequate procedures for testing the Standby Shutdown Facility (SSF) diesel generator as required by Technical Specification (TS) 5.4.1. The licensee's existing test procedures did not establish the appropriate plant conditions with the Unit 2 condenser cooling water (CCW) system shut down such that the water supply to the SSF auxiliary service water (ASW) and station ASW heated above 90 degrees F rendering both unavailable for all three units. The licensee entered this finding into their corrective action program under Problem Investigation Process report (PIP) O-05-7479. This finding was considered to be of more than minor significance because it affected the Mitigating Systems Cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, as the elevated temperature of the SSF ASW and station ASW supply resulted in the unavailability of these systems. This issue was determined to be of very low safety significance based on the screening criteria found in MC 0609, Appendix A, Phase 1 SDP worksheet. More specifically, the total additional unavailability of the SSF (one day) as result of overheating the supply did not exceed the TS allowed outage time (Section 1R12).

Mitigating Systems 03/31/2006 SALEM Green

• SCWE:

N

• HP:

N

• PIR:

Y Docket/Status: 05000272 (C), 05000311 (C)

Open: 2006007 (PIM) FAILURE TO COMPLY WITH STATION COLD SHUTDOWN REPAIR PROCEDURES The team identified a non-cited violation (NCV) for failure to maintain equipment required for cold shutdown (CSD) repairs in the designated location. Specifically, procedure SC.MD-AB.ZZ-0001, Installation of Temporary 4KV Power Cables to CCW and RHR Motors, states that All equipment required to install jumpers, cooling fans and make cable terminations are located in the Salem Safe Shutdown Equipment Storage Area. Salem Safe Shutdown Equipment Storage Area is located in the Northwest area of the Hope Creek Unit 2 reactor building. An inventory of the designated area in response to inspector inquiries revealed that a significant number of CSD repair materials was found missing. The licensee generated a notification and restocked the missing repair materials. The finding is more than minor because it is associated with the Mitigating Systems cornerstones attribute objective to ensure the availability of the post-fire cold shutdown system that responds to initiating events to prevent undesirable consequences.

Under Manual Chapter 0609 Appendix F, Fire Protection, the finding was evaluated as representing a medium degradation. However, because the equipment involved only effects Cold Shutdown, the finding was determined to be of very low safety significance in accordance with the Fire Protection Significance Determination Process. The performance deficiency had a problem identification and resolution cross-cutting aspect because there was a previous case where cold shutdown repair equipment were found missing and where the corrective actions were ineffective to prevent recurrence.

Mitigating Systems 03/31/2006 TMI Green

• SCWE:

N

• HP:

N

• PIR:

N Docket/Status: 05000289 (C)

Open: 2006007 (PIM) Inservice Testing Reference Values Not Reestablished as Required by ASME Code Following Maintenance to Decay Heat, NSCCW, and Emergency Feedwater Pumps The team identified an NCV of 10 CFR 50.55a.(f)(4)(ii) "Codes and Standards," which requires, in part, that testing of safety-related pumps meet the requirements of the American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) Code requirements following maintenance on the "A" Decay Heat Removal (DH) pump. Specifically, AmerGen did not establish new vibration reference values or reconfirm the previous values following maintenance that can affect the reference values. This finding has been entered into the licensees corrective action program as IRs 467551, 467056, 472106 and 471745. The planned corrective actions include an evaluation of the "A" DH pump reference values and a review of the methodology and process used to perform reference value evaluations. This finding is more than minor because it is similar to IMC 0612, Appendix E example 2C and the same issue affected a number of pumps tested that include 2B emergency feedwater pump and the1C NSCCW pump.

This issue affected the Mitigating System cornerstone. The issue had very low safety significance (Green) because the "A" DH pump remained operable, there was no loss of safety function, and it was not related to a seismic, flooding, or fire initiating event.

Mitigating Systems 12/31/2006 MILLSTONE Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status:, 05000336 (C)

Open: 2006005 (PIM) FAILURE TO IMPLEMENT SURVEILLANCE PROCEDURES RESULTED IN A TEMPORARY LOSS OF SPENT FUEL POOL COOLING A Green self-revealing non-cited violation (NCV) of Technical Specification (TS) 6.8.1, Procedures, was identified because Operations did not adequately implement procedures while performing a surveillance to manually cycle the C reactor building component cooling (RBCCW) outlet valve. This resulted in a temporary loss of RBCCW flow to the shutdown cooling heat exchanger which was aligned for cooling the spent fuel pool (SFP). This issue has been entered into Dominions corrective action program (CR-06-10565). Corrective actions for this issue included temporarily removing individuals from shift until interviewed by the Supervisor of Nuclear Shift Operations, and an action to create and implement required reading for all operators identifying this event with emphasis on diligence, not rushing, and following proper place keeping and peer-checking during performance of any procedural guidance. This finding is more than minor because it is associated with the Human Performance attribute of the Spent Fuel Pool Cooling system function under the Barrier Integrity cornerstone and affected the cornerstones objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents and events. The inspectors determined the NCV to be of very low safety significance based on NRC management review.

Specifically, the finding only represented a degradation to the spent fuel pool in that spent fuel pool cooling was lost for four minutes and spent fuel pool temperature did not significantly increase, and SFP cooling was promptly restored. This finding is related to the cross-cutting area of Human Performance, Work Practice component, in that Dominions work practice techniques (placekeeping) were not effective in assuring procedural steps were implemented which resulted in a temporary loss of SFP cooling with the core off-loaded H.4(a).

Mitigating Systems 04/17/2007 KEWANUEE Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status: 05000305 (C)

Open: 2007006 (PIM) Non-Conservative Assumption Used for "B" Component Cooling Water Pump Room Heat Gain Calculation The inspectors identified a finding having very low significance and an associated NCV of 10 CFR Part 50, Appendix B, Criterion III. Specifically, the licensee failed to account for component cooling water (CCW) piping temperatures as high as 176°F in the CCW B pump room and the impact upon the temperature in the CCW B pump room. As a result, the licensee used the non-conservative results in an operability evaluation for the auxiliary building fan coil unit (FCU). Upon discovery, the licensee placed this issue into their corrective action program, performed an immediate operability evaluation, and planned to perform a more thorough evaluation. This finding has a cross-cutting aspect in the area of human performance associated with decision making because the licensee did not use conservative assumptions.

Specifically, the licensee failed to account for higher CCW piping temperatures because the licensee did not model the CCW room properly and did not use the maximum expected temperature under accident conditions when revising calculation C11156 (H.1.b). The issue was more than minor because the error because, if left uncorrected, the finding would become a more safety significant concern. The use of a non-conservative value as a basis for operability could allow FCU performance to degrade to unacceptable levels without being detected and corrected. The issue was of very low safety significance because the issue was a design issue confirmed to not result in a loss of operability.

Mitigating Systems 06/26/2007 SAN ONOFRE Green

• SCWE:

N

• HP:

N

• PIR:

Y Docket/Status:, 05000361 (C), 05000362 (C)

Open: 2007003 (PIM) Failure to Promptly Identify and Correct Gas Accumulation in the Units 2 and 3 Component Cooling Water Systems The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the failure to promptly identify and correct the formation of gas pockets in the piping of the Units 2 and 3 component cooling water systems from March 8 to December 15, 2006. This deficiency resulted in the Unit 3 Train B component cooling water system being inoperable for approximately eight days from December 8 to 15, 2007. This issue was entered into the licensees corrective action program as Action Requests 061001379 and 070500468.

This finding was determined to be more than minor because if left uncorrected it would become a more significant safety concern in that the operability of the Units 2 and 3 CCW systems would continue to be challenged by the accumulation of gas. The inspectors evaluated the issue using the Manual Chapter 0609, Appendix A, "Significance Determination of Reactor Inspection Findings for At-Power Situations," Phase 1 screening worksheet. The inspectors determined that a Phase 2 significance determination was required because both the mitigating systems and containment barriers cornerstones were affected. The inspectors performed a Phase 2 significance determination using the Risk-Informed Inspection Notebook for San Onofre Nuclear Generating Stations, Units 2 and 3, Revision 2.1. The finding was potentially greater than Green using these worksheets. The inspectors requested that a Region IV Senior Reactor Analyst perform a Phase 3 significance determination to provide a better estimation of overall risk significance. Based on the results of the Phase 3 analysis, the finding is determined to have very low safety significance (Green). The cause of the finding has a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action program because the licensee failed to thoroughly evaluate the formation of gas in the Units 2 and 3 CCW systems to ensure that the cause and extent of condition were addressed in a timely manner.

Mitigating Systems 07/25/2007 FORT CALHOUN Green

• SCWE:

N

• HP:

N

• PIR:

N Docket/Status: 05000285 (C)

Open: 2007007 (PIM) Failure to Meet Single Failure Criteria Configuration for Component Isolation Valves The team identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," for the failure to meet the single valve failure requirements for the component cooling water surge tank. The component cooling water surge tank water and nitrogen supply lines were credited with only a single check valve for meeting single failure criteria requirements.

Based on engineering review, this configuration was not considered acceptable. Manual Isolation Valves AC-1179 and NG-290 have now been administratively changed in accordance with the Safety Analysis for Operability from the normally open position to the normally closed position to meet the single failure criteria requirements for the component cooling water Surge Tank AC-2. Upstream Check Valves AC-391 and NG-113 were previously credited with meeting the single failure criteria. This issue was entered into the corrective action program as Condition Report 2007-2622. The failure to comply with ANSI 51.1, "Nuclear Safety Criteria for the Design of Pressurized Water Powerplants," with respect to single failure criteria (double isolation) for the demineralized water and Nitrogen makeup lines to the Component Cooling Water (CCW) surge tank is a performance deficiency. This finding is more than minor because it affected the mitigating system cornerstone objective (design control attribute) to ensure the reliability and capability of the equipment needed to mitigate initiating events. Using the Phase 1 worksheet in Manual Chapter 0609, "Significance Determination Process," this finding is determined to be of every low safety significance because there was no actual loss of a safety function.

Mitigating Systems 09/28/2007 ST. LUCIE Green

• SCWE:

N

• HP:

N

• PIR:

Y Docket/Status: 05000335 (C), 05000389 (C)

Open: 2007006 (PIM) Inadequate Corrective Action Associated with Degraded Performance of the CCW Heat Exchanger Temperature Control Valve (2-TCV 14-4A)

The team identified a violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, for inadequate corrective actions associated with the degraded performance of the Component Cooling Water (CCW) heat exchanger temperature control valve (2-TCV-14-4A). The finding was more than minor because it affected the equipment performance attribute associated with the mitigating systems cornerstone as related to the reliability, availability and capability of the ICW system. The finding was of very low significance (Green) because there was no loss of system safety function. Analysis performed by the licensee during the inspection determined that at the failed valve position the ICW system was capable of removing the design base accident heat load. This finding has a cross cutting aspect in the area of Problem Identification and Resolution, specifically Corrective Action Program, because the licensee failed to take appropriate corrective actions to address safety issues and adverse trends in a timely manner, commensurate with their safety significance (MC 0305 aspect P.1(d)). The licensee entered this deficiency into their corrective action program (Section 1R21.2.7).

Mitigating Systems 09/30/2007 POINT BEACH Green

• SCWE:

N

• HP:

N

• PIR:

Y Docket/Status: 05000266 (C), 05000301 (C)

Open: 2007004 (PIM) Failure to Correct Previous Indication of Degraded Oil in Component Cooling Water Pump The inspectors identified an NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the failure to implement prompt corrective actions for the degraded oil conditions initially identified with safety-related Component Cooling Water (CCW) Pump 1P-11B in March 2007. Following an additional oil sample with anomalous results in July 2007, the licensee declared the pump inoperable and performed troubleshooting and repair of CCW Pump 1P-11B.

The licensee entered the issue into their corrective action program and took immediate corrective actions. The licensee continued to evaluate the causes and corrective actions to address this finding at the end of the inspection period. The finding is greater than minor because it could reasonably be viewed as a precursor to a significant event. Specifically, the failure to promptly correct the cause of the oil degradation in a timely manner in March 2007 could have resulted in the failure of the CCW pump. Additionally, the finding is associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective to ensure the reliability and capability of systems that respond to initiating events to prevent undesirable consequences. The finding is of very low safety significance (Green) because there was no design deficiency, no actual loss of safety function, no single train loss of safety function for greater than the TS allowed outage time, and no risk due to external events. Additionally, the inspectors determined that the primary cause of the finding is related to the cross-cutting area of problem identification and resolution. Specifically, under the component of corrective action program, the licensee failed to take appropriate corrective actions to address safety issues and adverse trends in a timely manner, commensurate with their safety significance and complexity Mitigating Systems 10/11/2007 SAN ONOFRE Green

• SCWE:

N

• HP:

N

• PIR:

N Docket/Status:, 05000361 (C), 05000362 (C)

Open: 2007013 (PIM) Inadequate Evaluation Results in CCW Pump Runout A self-revealing, Green noncited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, was identified when Unit 2 experienced a loss of instrument air due to the failure of a soldered joint. Specifically, the loss of instrument air resulted in component cooling water (CCW) Pump 024 being in a run out condition for approximately 75 minutes due to a previous system modification. The licensee entered this issue in their corrective action program as Action Requests AR 070700051 and 070600872. This finding was greater than minor because it was associated with the mitigating systems cornerstone attribute of design control and affected the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The finding did not affect the initiating events cornerstone functions of the component cooling water system because the condition would only have existed given a loss of instrument air initiator had already occurred. In accordance with NRC Inspection Manual Chapter 0609, Appendix A, Phase 1 Worksheet, Significance Determination Process (SDP) Phase 1 Screening Worksheet for the Initiating Events, Mitigating Systems, and Barriers Cornerstones, this finding was determined to be of very low safety significance because the finding was a design deficiency confirmed not to result in a loss of operability per Part 9900, Technical Guidance, Operability Determination Process for Operability and Functional Assessment.

Mitigating Systems 12/31/2007 DAVIS BESSE Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status: 05000346 (C)

Open: 2007005 (PIM) REDUCED FLOW THROUGH COMPONENT COOLING WATER 1 HEAT EXCHANGER BECAUSE OF IMPROPER VALVE OPENING LIMIT STOP A self-revealing NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, was identified for failing to include appropriate quantitative or qualitative acceptance criteria for assuring the proper setting of the travel stops on valve SW-36 [Component Cooling Water Heat Exchanger 1 Service Water Outlet Valve] after valve operator maintenance. This resulted in a valve opening setting that, in the event of a safety feature system actuation, would limit service water flow to less than flows analyzed in the approved flow balance calculation for flow to the component cooling water heat exchanger 1. The licensee entered the deficiency into their corrective action program and adjusted the travel stops to provide for the proper service water flow. This finding is greater than minor because the finding was associated with the configuration control attribute of the Mitigating Systems Cornerstone and did affect the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Also, the finding was more than minor, using example 1a of IMC 0612 Appendix E, September 20, 2007, in that testing determined CCW heat exchanger flows to be degraded subsequent to stop setting adjustment and declaring the heat exchanger operable. The finding was evaluated using the SDP and was determined to be a finding of very low safety significance because there was no actual loss of a safety system function. The finding was associated with the cross-cutting area of human performance in that the resources and specifically work packages were not adequate to ensure that work performed restored the component cooling water system to the analyzed condition (H.2(c)) after completion of maintenance activities.

Mitigating Systems 12/31/2007 FORT CALHOUN Green

• SCWE:

N

• HP:

N

• PIR:

N Docket/Status: 05000285 (C)

Open: 2007005 (PIM) Inadequate Design Control of Component Cooling Water Bypass Valve Green. A non-cited violation of Criterion III, Design Control, was identified for not translating calculation results on controlling the position of HCV-497, Component Cooling Heat Exchangers AC-1A-D CCW Bypass Line Isolation Valve, into procedures to maintain the component cooling water system operational. The failure to control HCV-497 position had the potential of not meeting design basis requirements to mitigate an accident during warm river water temperatures. The licensees failure to translate calculation results into procedures constitutes a performance deficiency and finding. This finding is greater than minor because it could be reasonably viewed as a precursor to a significant event (i.e., the ability of the component cooling water system to mitigate an accident during periods of warm river temperatures). Additionally, the finding affected the availability and reliability of mitigating system equipment. This finding was evaluated using the significance determination process and was determined to be a finding of very low safety significance because the finding was: (1) not a qualification deficiency confirmed to result in a loss of function, (2) did not result in a loss of safety system function, (3) did not represent an actual loss of safety function of a single train, (4) did not represent an actual loss of safety function of risk significant equipment for greater than 24-hours, and (5) did not screen as risk significant due to external events. This condition has been entered into the licensees corrective action program as Condition Report 2007-2864.

Mitigating Systems 03/30/2008 FARLEY Green

• SCWE:

N

• HP:

N

• PIR:

N Docket/Status: 05000348 (C)

Open: 2008002 (PIM) Failure of CCW 4160 Circuit Breaker to Operate When Demanded Due to Ineffective Corrective Actions A self-revealing Green NCV of 10 CFR 50 Appendix B, Criterion XVI was identified for inadequate corrective actions which resulted in the 1C CCW Pumps circuit breaker failing to operate when required. The combination of inadequate tolerances, manipulation of the breaker foot pedal, and the interlock plunger being bound in the interlock bar resulted in the circuit breaker experiencing a trip free operation during its demanded closing operation. During the time the 1C CCW Pump was inoperable, the 1A CCW Pump would not have restarted during LOSP or SI conditions due to a latent failure of its circuit breaker. Thus, a loss of safety function existed for approximately seven hours and fifteen minutes. Because the latent failure of the 1A CCW pump was not a trendable or foreseeable failure, no performance deficiency was identified. The NRC reviewed both breaker failures for a common performance deficiency and none was identified. This finding has been entered into the licensees CAP as CR 2007108601.

The licensees failure to ensure the interlock plunger was correctly aligned to allow proper operation of the 4160 volt 1C CCW pump circuit breaker is a performance deficiency. This finding is more than minor because it affected the equipment reliability attribute of the Mitigating Systems cornerstone. The cornerstone objective of ensuring the availability, reliability, and capability of systems responding to initiating events to prevent undesirable consequences was not met. The NRC performed a Phase 3 Significance Determination of the performance deficiency and concluded the finding was of very low safety significance.

Mitigating Systems 03/30/2008 FARLEY Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status: 05000348 (C)

Open: 2008002 (PIM) Failure to Prevent the Installation of a Nonconforming Breaker into the Cubicle for the 1C CCW Pump The NRC identified a Green NCV of 10 CFR 50 Appendix B, Criterion XV for failing to properly control nonconforming components resulting in the installation of a 4160 volt breaker for the Unit 1 1C CCW pump with a stop bolt gap dimension not meeting vendor and station maintenance acceptance criteria. This finding has been entered into the licensees CAP as CRs 2007108654 and 2008101720. Failure to control components not conforming to requirements in order to prevent their inadvertent use or installation in safety-related applications is a performance deficiency. The NRC determined this finding was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective. Specifically, installation of a breaker not meeting vendor or station acceptance criteria challenged the reliability of the 1C CCW pump. Because the finding did not result in a loss of operability or safety function and the finding did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event, the NRC concluded the finding was of very low safety significance (Green). A human performance cross-cutting aspect was identified regarding effectively communicating expectations for procedural compliance and personnel following procedures (H4(b)).

Mitigating Systems 03/30/2008 FARLEY Green

• SCWE:

N

• HP:

N

• PIR:

N Docket/Status:, 05000364 (C)

Open: 2008002 (PIM) Installation of a Maintenance Jumper for the 2C CCW Pump Cell Switch The NRC identified a Green NCV of 10 CFR 50 Appendix B, Criterion III for failing to implement measures to verify design adequacy resulting in the installation of a maintenance jumper on the cell switch for the Unit 2 2C Component Cooling Water (CCW) pump. This resulted in a condition unknown to the licensee at the time of installation, allowing simultaneous start of both the 2C and 2B CCW pumps in response to a loss of offsite power (LOSP) or safety injection (SI) sequencer signal. This finding has been entered into the licensees CAP as Condition Report (CR) 2007112315. Failure to verify design adequacy for safety-related components is a performance deficiency. This finding is more than minor because inadequate design evaluations challenged the operability of the A train of CCW. Subsequently, the A CCW train was shown to be operable following additional engineering evaluations. The finding affects the design control attribute of the Mitigating Systems cornerstone. The cornerstone objective of ensuring the availability, reliability, and capability of systems responding to initiating events to prevent undesirable consequences was not met. The Phase 1 screening performed by the NRC concluded the finding is of very low safety significance Mitigating Systems 12/30/2008 SALEM Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status:, 05000311 (C)

Open: 2008005 (PIM) INADEQUATE DESIGN CONTROL FOR NO. 22 COMPONENT COOLING WATER HEAT EXCHANGER SERVICE WATER OUTLET TEMPERATURE CONTROL VALVE The inspectors identified a self-revealing NCV of 10 CFR 50, Appendix B, Criterion III, Design Control, because the No. 22 component cooling water heat exchanger (CCWHX) service water (SW) outlet temperature control valve (22SW127) did not stroke open when the 22 CCWHX was placed in service following a high flow flush on November 18, 2008. Specifically, PSEG did not ensure that the design basis was correctly translated into valve set-up instructions for the 22SW127 valve. PSEGs corrective actions included mechanical adjustment to the valves stroke, revising the valves set-up instructions, and an extent of condition review. The finding was more than minor because it was associated with the design control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the improper valve set-up instructions caused the 22SW127 to operate not as expected resulting in an unexpected rise in component cooling water (CCW) system temperatures after the 22CCWHX was placed in service on November 18, 2008. As a result operators declared the 22CCWHX inoperable and documented the condition in the corrective action program. In accordance with NRC IMC 0609 the inspectors determined the finding was of very low safety significance (Green) because it was a design deficiency that was confirmed not to result in a loss of CCW train operability. The finding has a cross-cutting aspect in the area of human performance, resources, because PSEG did not ensure that adequate resources were available to maintain complete, accurate and up-to-date design documentation, procedures, and work packages H.2(c). Specifically, PSEG did not maintain the 22SW127 ICD card and valve set-up work order up-to-date in accordance with the valves design basis documentation.

Mitigating Systems 03/31/2009 POINT BEACH Green

• SCWE:

N

• HP:

N

• PIR:

Y Docket/Status: 05000266 (C)

Open: 2009002 (PIM) Failure To Recognize Unit 1 Component Cooling Water Pump Was Inoperable On January 1, 2009 The inspectors identified a finding of very low safety significance and associated Non-Cited Violation of Technical Specification (TS) 3.7.7, Component Cooling Water (CCW) System, for the failure to recognize that the Unit 1 1P-11B CCW pump was inoperable. Consequently, the licensee failed to take actions in accordance with TS for an inoperable CCW pump. Specifically, on January 1, 2009, auxiliary operators added a full reservoir (bubbler) of oil to the inboard bearing for the second time in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, due to an oil leak. This abnormal condition was not appropriately characterized by the licensee until after two more oil additions, when a condition report was written to document the oil addition on January 5, 2009. The licensee performed an apparent cause evaluation and implemented corrective actions to address the deficiencies and lessons learned from this finding. The finding was determined to be more than minor in accordance with Inspection Manual Chapter 0612, Appendix B, Issue Screening, dated December 4, 2008, because the finding was associated with the Mitigating Systems Cornerstone attribute of equipment performance and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the CCW pump was degraded with an inboard bearing oil leak and may not have been able to fulfill the 30-day mission time of the pump. The inspectors determined the finding could be evaluated using the Significance Determination Process in accordance with Inspection Manual Chapter 0609, Significance Determination Process, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings, Table 4a for the Mitigating Systems Cornerstone, dated January 10, 2008. The inspectors determined that the finding required a Phase 2 analysis since the finding represented an actual loss of a single train for greater than its TS allowed outage time.

The inspectors and senior reactor analyst determined through Phase 2 analysis that this issue is best characterized as a finding of very low safety significance (Green). The inspectors also determined that this finding has a cross-cutting aspect in the area of problem identification and resolution, corrective action program component, because personnel did not use a low threshold for identifying issues. Specifically, licensee personnel failed on three occasions to enter the oil additions into the corrective action program which would have required a Senior Reactor Operator to screen the condition for operability P.1(a).

Mitigating Systems 03/31/2009 POINT BEACH Green

• SCWE:

N

• HP:

N

• PIR:

Y Docket/Status: 05000266 (C)

Open: 2009002 (PIM) Failure To Promptly Correct Component Cooling Water Pump Oil Leak On January 27, 2009 The inspectors identified a finding of very low safety significance and associated Non-Cited Violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, for the failure to promptly correct a condition adverse to quality associated with an inboard oil leak on the Unit 1 1P11-B component cooling water (CCW) pump identified on January 27, 2009. Consequently, the CCW pump operated in a degraded condition until the pump was taken out-of-service to address inboard bearing oil leaks on January 31 and February 1, 2009. Specifically, on January 27, 2009, a condition report was written documenting an inboard bearing leak; however, the immediate operability screening was incorrect and the licensees screening process failed to ensure prompt corrective actions were taken to address this condition adverse to quality. The licensee performed an apparent cause evaluation and implemented corrective actions to address the deficiencies and lessons learned from this finding. The finding was determined to be more than minor in accordance with Inspection Manual Chapter 0612, Appendix B, Issue Screening, dated December 4, 2008, because the finding was associated with the Mitigating Systems Cornerstone attribute of equipment performance and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the CCW pump was degraded with an inboard bearing oil leak and may not have been able to fulfill the 30-day mission time of the pump. The inspectors determined the finding could be evaluated using the Significance Determination Process in accordance with Inspection Manual Chapter 0609, Significance Determination Process, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings, Table 4a for the Mitigating Systems Cornerstone, dated January 10, 2008. The inspectors determined that the finding required a Phase 2 analysis since the finding represented an actual loss of a single train for greater than its Technical Specification allowed outage time. The inspectors and senior reactor analyst determined through Phase 2 analysis that this issue is best characterized as a finding of very low safety significance (Green).

The inspectors also determined that this finding has a cross-cutting aspect in the area of problem identification and resolution, corrective action program component, because personnel did not thoroughly evaluate the identified problem while classifying, prioritizing and evaluating for operability and reportability of this condition adverse to quality. Specifically, licensee personnel did not thoroughly evaluate the condition adverse to quality associated with the 1P-11B CCW pump on January 27, 2009, such that the prompt corrective actions were appropriately prioritized and evaluated P.1(c).

Mitigating Systems 04/09/2009 SOUTH TEXAS PROJECT Green

• SCWE:

N

• HP:

N

• PIR:

N Docket/Status: 05000498 (C), 05000499 (C)

Open: 2009002 (PIM) Inadequate Surveillance Test for Component Cooling Water The inspectors identified a noncited violation of 10 CFR Part 50, Appendix B, Criteria V, Instructions, Procedures, and Drawings, for the inadequate surveillance Procedure 0PSP05-CC-0001, FCI CCW Surge Tank Compartment Level Switch Calibration, Revision 7. On October 14, 2008, during the 18-month surveillance test, Unit 2 component cooling water Train A was determined to be inoperable due to the failure of system valves to actuate to their designated positions. Troubleshooting determined that a loose wire was the reason for the inoperability. The wire was restored and the train returned to operable status on October 16, 2008. From January 22 through October 16, 2008, the Train A component cooling water low-low level switch was inoperable. Since this procedure is applicable to all trains of both units, the licensee verified that all other trains low-low level switches on both units were either surveillance tested after the last calibration procedure or were functionally checked using a temporary procedure to ensure operability. The finding was more than minor because it was similar to several examples in Inspection Manual Chapter 0612, Appendix E, where the system was returned to service without being fully operable, and it affected the Mitigating Systems cornerstone attribute of procedure quality and the objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.

Using the Significance Determination Process Phase 1 worksheets from Inspection Manual Chapter 0609, the finding was determined to have very low safety significance because it did not result in the actual loss of safety function of one or more trains and it did not screen as risk significant due to seismic, flooding, fire, or severe weather. This issue had no crosscutting aspects because the last revision to the procedure was too long ago (2005) to be indicative of current performance.

Mitigating Systems 06/30/2009 POINT BEACH Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status:, 05000301 (C)

Open: 2009003 (PIM) Inadequate Work Instructions And Procedures For 2P-11B Component Cooling Water Pump Maintenance A finding of very low safety significance (Green) and associated Non-Cited Violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was self revealed for the failure to have adequate work instructions and procedures in place for the March 2009 repair of the 2P 11B component cooling water (CCW) pump. Specifically, the work instructions did not contain sufficient guidance to ensure the proper installation, alignment, and adequacy of material conditions for reuse, of critical pump components. As a result, the CCW pump was returned to service, while still in a degraded state, and required an additional entry into a technical specification action condition 2 weeks later for unplanned corrective maintenance to replace components and repair an oil leak. In response to the issues, the licensee overhauled the pump and performed an apparent cause evaluation, which identified additional long term corrective actions. The finding was determined to be more than minor because the finding was associated with the Mitigating Systems Cornerstone attribute of equipment performance and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the CCW pump was degraded with an oil leak from the inboard bearing motor side oil seal and may not have been able to fulfill the 30-day mission time of the pump.

The inspectors determined that the finding was of very low safety significance (Green) because the finding did not involve a design or qualification deficiency, did not represent an actual loss of safety function, or represent a single train loss of safety function for greater than the Technical Specification-allowed outage time, and was not potentially risk-significant for external events.

The inspectors also determined that this finding has a cross-cutting aspect in the area of human performance, resources, because the level of training provided to the station personnel limited their ability to identify technical procedural deficiencies encountered during pump maintenance (H.2(b)).

Mitigating Systems 07/09/2009 PRAIRIE ISLAND Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status: 05000282 (C)

Open: 2009010 (PIM) Failure to Ensure Design Measures Were Appropriately Established for the unit 1 Component Cooling Water System.

An inspector identified Non Cited Violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, was identified due to the licensees failure to establish design control measures to ensure that the design basis for the Unit 1 component cooling water system (CCW) was correctly translated into specifications, drawings, procedures, and instructions. Specifically, the licensee failed to ensure that the safety related function of the CCW system was maintained following a tornado/high winds induced failure of the CCW system piping to the 122 spent fuel pool heat exchanger. Corrective actions for this issue included providing procedural guidance to isolate the Unit 1 CCW system from the 122 spent fuel pool heat exchanger following the receipt of a tornado watch and evaluating the need for additional tornado missile protection for the CCW system piping to the 122 spent fuel pool heat exchanger. This finding was determined to be more than minor because it impacted the design control and external events aspects of the Mitigating Systems Cornerstone. The finding also impacted the Mitigating Systems Cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. This finding was determined to be of very low safety significance due to the very low probability of the Prairie Island Nuclear Generating Plant experiencing a high wind condition that could generate a missile large enough to fail the Unit 1 CCW system piping to the 122 spent fuel pool heat exchanger. The cause of this finding was related to the cross cutting element of Human Performance, Decision Making because the licensee failed to make safety significant and risk significant decisions using a systematic process to ensure that safety was maintained (H.1(a)) (Section 4OA5.1).

Mitigating Systems 09/30/2009 PILGRAM Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status: 05000293 (C)

Open: 2009004 (PIM) Failure to Evaluate for Operability of the B RBCCW/SSW Heat Exchanger The inspectors identified a non-cited violation of very low safety significance (Green) of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, because Entergy did not assess operability of the B RBCCW/SSW Heat Exchanger (HX) when the HX failed a differential pressure (dP) surveillance. Specifically, operators conducted backwashing of a degraded HX as directed by Entergy procedure 2.2.32, Rev. 80, Attachment 7, Salt Service Water System, prior to assessing operability. In addition, Entergy Procedure 8.5.3.14, Revision 27, SSW Flow Rate Operability Test, specifically directs backwashing HXs as a corrective action prior to assessing operability when the HXs fail to meet the dP acceptance criteria.

Entergy entered this issue into their corrective action program, and actions will include evaluation for revision of applicable procedures to incorporate dP graphs to evaluate for operability. The performance deficiency is that Entergy did not assess operability of degraded HXs when the HX dP exceeded predetermined values specified in the procedure. The finding is more than minor because it affects the Mitigating Systems Cornerstone objective to ensure the capability of systems that respond to initiating events to prevent undesirable consequences (i.e.,

core damage). The issue adversely affects the procedure quality attribute of the cornerstone in the area of testing procedures in that the procedure directs taking corrective actions for a degraded HX prior to assessing operability of the HX. The inspectors evaluated this finding using IMC 0609.04, Phase 1 - Initial Screening and Characterization of Findings. This finding was of very low safety significance (Green) because it was not a design or qualification deficiency, did not represent a loss of system safety function, did not represent an actual loss of a single train system for greater than the TS allowed outage time, and was not made risk-significant because of external events. The inspectors determined that this finding had a cross-cutting aspect in the area of Human Performance, Resources, because Entergy did not provide an adequate procedure. Specifically, site procedures directed operators to take corrective actions prior to assessing operability of a degraded HX (H.2.c of IMC 0305).

Mitigating Systems 09/30/2009 VOGTLE Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status:, 05000425 (C)

Open: 2009004 (PIM) Human performance error renders 2BEDG inoperable A self-revealing non-cited violation (NCV) was identified for a human performance error associated with inadvertently racking out the 2B emergency diesel generator (EDG) output breaker. The system operator racked out the incorrect breaker while performing lockout 2-DT-09-1217-00289 on the Auxiliary Component Cooling Water (ACCW) system. As a result, the 2B EDG was temporarily rendered inoperable. Licensee immediately restored the 2B EDG to operable status by returning the output breaker to the connect position. The licensee entered the issue into their corrective action program. This issue is more than minor because it is associated with a cornerstone attribute and adversely affected the objective of the Mitigating Systems cornerstone. Specifically, the performance deficiency is a human performance error which affected the availability, reliability, and capability of the B train emergency core cooling system to respond to a loss of coolant accident during a loss of off-site power. The finding was determined to be of very low safety significance (Green) because the event did not represent an actual loss of safety function of a single train for greater than its Technical Specification (TS) allowed outage time. The inspectors determined that the cause of this finding was related to the Work Practices component of the Human Performance cross-cutting area due to less-than-adequate human error prevention techniques H.4(a). Specifically, peer checking techniques were less than adequate.

Mitigating Systems 12/03/2009 ST. LUCIE Green

• SCWE:

N

• HP:

N

• PIR:

N Docket/Status: 05000335 (C)

Open: 2009006 (PIM) Failure to Meet the ASME Boiler and Pressure Vessel Code,Section VIII, Division 1 Requirements for the Overpressure Protection for the CCW Surge Tank.

The team identified a non-cited violation of 10 CFR 50, Appendix B, Criterion III, Design Control, for failure to translate the design basis as specified in the license application into specifications, drawings, procedures, and instructions. The licensee did not ensure that the component cooling water (CCW) surge tank design included adequate overpressure protection for all procedurally allowed configurations as required by the applicable ASME Boiler and Pressure Vessel Code,Section VIII, Division 1. The code requires that no intervening stop valves be between the vessel and its protective device or devices or between the protective devices and the point of discharge. The team concluded that stop valve V6466 was an intervening stop valve for the CCW surge tank vent path to the chemical drain tank (CDT). The issue was entered in the licensees corrective action program as condition report (CR) 2009-23473. Immediate licensee corrective actions included verification that the valve was in its open position and the implementation of administrative controls to maintain the valve opens. This finding is associated with the Mitigating Systems Cornerstone attribute of Design Control, i.e. initial design, was determined to be more than minor because it impacted the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The team determined that if left uncorrected, this design deficiency had the potential to impact the operability of safety-related systems and, thus, become a more significant safety concern in that a closed intervening valve had the potential for over pressurizing the CCW surge tank. The team assessed this finding for significance in accordance with NRC Manual Chapter 0609, Appendix A, Attachment 1, Significance Determination Process (SDP) for Reactor Inspection Findings for At-Power Situations, and determined that it was of very low safety significance (Green), in that no actual loss of safety system function was identified. The team reviewed the finding for cross-cutting aspects and concluded that this finding did not have an associated cross-cutting aspect because the design of the CCW surge tank relief was established in an original plant design, and therefore, was not representative of current licensee performance [Section 1R21.2.2].

Mitigating Systems 12/31/2009 FARLEY Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status: 05000348 (C), 05000364 (C)

Open: 2009005 (PIM) Failure to Implement Maintenance Inspections of Safety-Related Switchgear A self-revealing NCV of TS 5.4.1, Procedures, was identified for failure to implement preventative maintenance inspections on the 1-2L 600 volt load center as specified by FNP EMP-1322.10, Maintenance and Cleaning of Westinghouse Switchgear. Failure to perform the specified inspections on the 1-2L 600 volt load center allowed bus fastener torque to degrade so bus bar damage occurred rendering said vlc inoperable. Licensee entered issue into CAP (CR 2008103720) & completed corrective actions to restore operability& schedule specified maintenance inspections on the vlc. failure to implement preventative maintenance inspections on said vlc specified by FNP-0-EMP-1322.10 was a performance deficiency. This finding was greater than minor because it adversely affected the equipment performance attribute of the MS cornerstone objective to ensure the availability, reliability and capability of systems responding to initiating events to prevent undesirable consequences (i.e., core damage). MS cornerstone column of Phase 1 screening wksheet of SDP used to assess finding. Was determined to require a Phase 3 analysis because finding represented actual LOSF of a single train for greater than its allowed TS outage time. Inspector determined the finding was of very low safety significance (Green). The dominant accident sequence was a failure of ATrain SW thru loss of the 4KV F Bus, failure of the BTrain thru a failure of that trains pump cooling sub-system and inability of the 600 VAC Load Center 1/2L to provide power due to the performance deficiency, leading to total loss of S W to the unit. AFW provided secondary side cooling but, without SW both RCP seal cooling sources, CCW thermal barrier cooling & HHSI/Charging seal injection, failed. A seal LCA happened w/o ability to makeup to the RCS and core damage ensued. This finding is associated with a cross-cutting aspect in the work control component of the human performance area (H.3(b)).

Mitigating Systems 03/31/2010 VOGTLE Green

• SCWE:

N

• HP:

N

• PIR:

Y Docket/Status:, 05000425 (C)

Open: 2010002 (PIM) Ineffective corrective action renders Unit 2 CCW pump #4 inoperable A self-revealing non-cited violation (NCV) for failure to meet the requirements of 10 CFR 50, Appendix B, Criterion XVI was identified. Specifically, for ineffective corrective maintenance performed on the Unit 2 Component Cooling Water (CCW) Pump #4. The corrective maintenance actions performed on CCW pump #4 in October 2009 to repair damage due to contact between the throttle bushing and the shaft sleeve on the inboard mechanical seal were ineffective, and consequently, the same damage to the inboard mechanical seal occurred in January 2010 when the pump was again operated. As a result, the Unit 2 CCW pump #4 was rendered inoperable for the second time in three months due to the same mechanical seal issue. This issue was greater than minor because it was associated with a cornerstone attribute and adversely affected the objective of the Mitigating Systems cornerstone. Specifically, the performance deficiency was an equipment performance issue which affected the availability, reliability, and capability of the B train emergency core cooling system (ECCS) to respond to a loss of coolant accident (LOCA). The finding was determined to be of very low safety significance (Green) because the event did not represent in an actual loss of safety function of a single train for greater than its Technical Specification allowed outage time. The inspectors determined that the cause of this finding was related to the Corrective Action Program component of the Problem Identification and Resolution cross-cutting area due to less-than-adequate problem evaluation P.1(c). Specifically, the corrective maintenance actions used to resolve the mechanical seal issue on CCW pump #4 were less than adequate (Section 1R12).

Mitigating Systems 04/07/2010 INDIAN POINT Green

• SCWE:

N

• HP:

N

• PIR:

N Docket/Status:, 05000247 (C)

Open: 2010006 (PIM) Fire Scenario resulting in loss of cooling water to charging pumps The team identified a Green, Non-Cited Violation of 10 CFR 50, Appendix R, III.G.3, in that Entergy failed to provide one train of reactor coolant system makeup free of fire damage for the control room, cable spread room, electrical switchgear room, and cable tunnel fire zones for postulated fire scenarios. Specifically, Entergy failed to assure that one charging pump would remain free of fire damage for alternate shutdown fire scenarios that could produce a spurious trip of a component cooling water (CCW) pump. Entergy initiated condition report CR-IP2-2010-00751 for long term resolution and promptly initiated hourly fire watches in all affected fire areas except for the cable tunnel as an interim compensatory measure. The cable tunnel was evaluated as not requiring an hourly fire watch and being sufficiently protected with installed fire detection and automatic fire suppression in addition to administrative controls that limit personnel access. This finding is more than minor because it is associated with the External Factors attribute (fire) of the Mitigating Systems Cornerstone and adversely affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the availability of the charging system was not ensured for postulated fires in alternative shutdown areas. The team used Phase 1, 2 and 3 risk assessment tools of IMC 0609, Appendix F, Fire Protection SDP, to determine that this finding was of very low safety significance (Green), with an estimated total core damage frequency in the low to mid E-7/year. A cross-cutting aspect was not identified (Section 1R05.01.2).

Mitigating Systems 09/30/2010 ST. LUCIE Green

• SCWE:

N

• HP:

N

• PIR:

N Docket/Status: 05000335 (C), 05000389 (C)

Open: 2010004 (PIM) Inadequate Procedure for Restoration of Non-Essential CCW Flow Following SIAS An NRC-identified NCV of very low safety significance involving Technical Specification 6.8.1, for failure of the licensee to provide adequate procedures for restoration of non-essential component cooling water (CCW) following a Safety Injection Actuation Signal (SIAS).

Specifically, emergency operating procedure, 1-EOP-99, Appendix A, Sampling Steam Generators and Appendix J, Restoration of CCW and CBO to the RCPs, Rev. 38, did not address the potential adverse impact on essential cooling flow required to mitigate a LOCA when the non-essential CCW was restored. This issue was entered into the CAP as CR 2009-22623 The finding was more than minor in accordance with IMC 0612, Appendix B, Issue Screening, because it was associated with the procedure quality attribute of the mitigating systems cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and operability of the control room air conditioning system to perform its intended safety function during a design basis event. The inspectors determined that the finding was of very low safety significance because it did not result in an actual loss of operability to the component. This finding was reviewed for cross-cutting aspects and none were identified.

Barrier Integrity 12/31/2006 FORT CALHOUN Green

• SCWE:

N

• HP:

N

• PIR:

Y Docket/Status: 05000285 (C)

Open: 2006005 (PIM) Failure to Determine Operability of Component Cooling Water Valves to Containment Cooling Units The inspectors identified a noncited violation of Technical Specification 2.4. The violation was identified as a result of the licensees failure to identify corrective actions two years ago that caused the Licensee to incorrectly determine the operability of component cooling water (CCW) inlet and outlet valves that supply CCW to the containment air cooling and containment air cooling and filtering units. On two occasions, June 29, 2006 and July 18, 2006, the licensee initially determined that air or nitrogen leaks associated with the CCW valves did not affect the operability of the valves. This incorrect operability determination was based on the valves failing-as-is and not being subject to flow-induced hydrodynamic operation. Because the valves are subject to flow-induced hydrodynamic operation caused the violation of technical specification. The finding was more than minor since it affected the Containment Configuration Control attribute of the Barrier Integrity cornerstone. Using Significance Determination Process, Manual Chapter 0609, the phase one analysis directs the use of Appendix H since the finding involves the actual reduction in defense-in-depth for the atmospheric pressure control. Manual Chapter 0609 Appendix H characterized the finding as having very low safety significance because it was determined to have no impact on core damage frequency or large early release frequency. The finding also has a crosscutting aspect in the problem identification and resolution area because the licensee failed to take appropriate corrective actions to address the safety issue in a timely manner. This issue was entered into the licensees corrective action program.

Occupational Radiation Safety 09/30/2007 HARRIS Green

• SCWE:

N

• HP:

N

• PIR:

Y Docket/Status: 05000400 (C)

Open: 2007004 (PIM) Failure to maintain an acceptable program for periodic CCW Process Radiation Monitor calibrations in accordance with 10 CFR 20.1101 An NRC-identified non-cited violation (NCV) of 10 CFR 20.1101 was identified for failure to maintain an acceptable program for process radiation monitor calibrations in accordance with 10 CFR 20.1501(b). Specifically, the licensee failed to maintain a program for periodic calibrations required to assure acceptable operability for process radiation monitoring equipment REM-01CC-3501ASA and REM-01CC-3501BSB used to monitor the component cooling water (CCW) system for potential contamination. The issue is greater than minor because the failure to periodically calibrate the CCW process radiation monitors could impair the licensees ability to accurately identify, trend and take appropriate action regarding any potential inadvertent contamination of a non-radioactive system. This finding is associated with the Occupational Radiation Safety Cornerstone and adversely affects the cornerstone objective attribute to properly maintain and calibrate radiation monitoring instrumentation to support radioactive material control monitoring activities for the potential release of contaminated materials into non-contaminated areas or equipment. This finding was evaluated using the Occupational Radiation Safety Significance Determination Process (SDP) and was determined to be of very low safety significance based on operation of the CCW as a closed system and lack of identified radioactive contamination associated with system operation. The cause of this finding is related to the cross-cutting element of Problem Identification and Resolution (P.1.c) (Section 2OS3).

1) Search results for the term Component Cooling Water ROP PIM Reports - Event Dates: 12/06/2004 - 12/06/2010 - Generated on 12/6/10 By Types, Cornerstones, Event Dates, Sites Key Word Search on component cooling water, Significance: All Cross Cutting Areas:

SCWE = Safety Conscious Work Environment HP = Human Performance PIR = Problem Identification and Resolution Finding Initiating Events 09/30/2005 GRAND GULF Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status: 05000416 (C)

Open: 2005004 (PIM) Improper Maintenance Results in Partial Loss of Component cooling water A Green self-revealing finding was reviewed involving the failure of a newly installed corrosion monitor probe that resulted in a leak in the component cooling water system. Licensee personnel used an inadequate procedure to install the probe and therefore failed to verify the pressure retaining capability of the probe prior to installation. The licensee entered this performance deficiency in their corrective action program for resolution. This finding is more than minor since it affected the design control attribute of the initiating events cornerstone and directly affected the cornerstone objective of limiting events that challenge plant stability. Based on the results of a Significance Determination Process Phase 1 evaluation, the finding is of very low safety significance (Green) since it did not contribute to the likelihood of a loss of coolant accident, did not contribute to a loss of mitigation equipment, and did not increase the likelihood of a fire or internal/external flood. The finding also had crosscutting aspects associated with human performance.

Initiating Events 06/23/2007 ANO Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status:, 05000368 (C)

Open: 2007003 (PIM) Complete Loss of Component cooling water Flow During maintenance Operations A self-revealing finding was identified when Unit 2 experienced a complete loss of component cooling water flow due to the loss of the Train B component cooling water Pump 2P-33B on February 21, 2007. Specifically, the loss of component cooling water occurred when an operator was attempting to pressurize an out-of-service heat exchanger to support maintenance activities. This issue was entered into the licensee's corrective action program as Condition Report ANO-2-2007-0313. The finding was determined to be more than minor because it affected the equipment performance attribute of the initiating events and mitigating systems cornerstones. Using the Manual Chapter 0609, Significance Determination Process, Phase 1 Worksheet, the inspectors concluded that a Phase 2 evaluation was required. The inspectors performed a Phase 2 analysis using Appendix A, "Technical Basis For At Power Significance Determination Process," of Manual Chapter 0609, "Significance Determination Process," and the Phase 2 Worksheets for Arkansas Nuclear One. The inspectors assumed that the duration of the component cooling water system unavailability was very short, approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Additionally, the inspectors assumed that only the power conversion system was affected and all other mitigating systems were available. Based on the results of the Phase 2 analysis, the finding was determined to have very low safety significance. The finding had crosscutting aspects in the area of human performance associated with resources (H.2(b)) because the training of personnel and procedural guidance available was inadequate.

Mitigating Systems 03/10/2005 WAT TS BAR Green

• SCWE:

N

• HP:

N

• PIR:

N Docket/Status:, 05000382 (C)

Open: 2005008 (PIM) Degraded performance could be masked and appropriate corrective actions not identified or implemented.

A finding with two examples of very low safety significance was identified for weaknesses in the maintenance rule program in regards to the component cooling water pumps, the reactor protection system and the reactor trip breakers. Specifically, the team found that the licensee did not monitor the performance or condition of structures, systems, or components in a manner sufficient to provide reasonable assurance that equipment reliability and degraded performance would not be masked and appropriate corrective actions would not be identified or implemented.

This finding is more than minor because it affects the Mitigating Systems Cornerstone attributes of equipment reliability, in that, degraded performance could be masked and appropriate corrective actions not identified or implemented. This finding was of very low safety significance because no performance criteria were exceeded and there was no actual loss-of-safety function. Licensee personnel initiated Condition Report CR-WF3-2005-00322 to address this finding (Section 1R21.4b2).

Mitigating Systems 04/02/2005 INDIAN POINT Green

• SCWE:

N

• HP:

N

• PIR:

N Docket/Status:, 05000247 (C)

Open: 2005002 (PIM) FAILURE TO PERIODICALLY VERIFY THE CAPABILITY OF CITY WATER BACKUP COOLING SAFETY FUNCTION The inspectors identified a Green finding associated with a loss of city water to the primary auxiliary building on January 26, 2005. Specifically, Entergy failed to periodically verify the capability of a backup cooling water supply for the charging pumps, safety injection pumps and the residual heat removal pumps. The finding is greater than minor since it affected the Mitigating Systems cornerstone objective of availability of backup cooling to safety pumps in response to a loss of all component cooling water and/or loss of service water event. This finding impacted the procedural quality attribute since no periodic verification existed since 2003 to verify the availability of backup cooling water source, city water. In accordance with IMC 0609, Appendix A, "Significance Determination of Reactor Inspection Findings for At-Power Situations," the Region I Senior Reactor Analyst (SRA) performed a Phase 3 analysis and determined that this finding was of very low risk significance (Green). No violations of NRC requirements were identified.

Mitigating Systems 05/02/2005 SALEM Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status: 05000272 (C)

Open: 2005007 (PIM) COMPONENT COOLING WATER CONFIGURATION CONTROL DEFICIENCY The team identified a finding of very low safety significance because PSEG did not properly follow its procedural guideline for conducting an apparent cause evaluation (ACE) in response to a component cooling water configuration control problem that caused the 11 residual heat removal heat exchanger to be inoperable. This finding is more than minor because it is associated with the Mitigating Systems cornerstone's configuration control attribute and affected the cornerstone's objective to ensure the availability and reliability of systems that respond to initiating events. This finding was of very low safety significance (Green) based on a Phase 1 SDP, because it was not a design deficiency, did not result in an actual loss of safety function, and did not screen as potentially risk significant due to external initiating events (seismic, flooding, or severe weather). The performance deficiency had a human performance cross cutting aspect. The individuals performing the ACE did not follow the site procedural guidelines for the conduct of the ACE.

Mitigating Systems 05/10/2006 WOLF CREEK Green

• SCWE:

N

• HP:

N

• PIR:

Y Docket/Status: 05000482 (C)

Open: 2006010 (PIM) Inadequate procedure for long-standing component cooling water pump problems The team identified a finding for the failure to establish appropriate procedures for the operation of the component cooling water pump. Specifically, the licensee did not establish procedures to include appropriate acceptance criteria for component cooling water pump axial shaft movement that has existed for approximately 18 years. The licensees procedure did not contain any vendor acceptance criteria to ensure axial shaft movement did not result in a failure of the pump during a postulated accident. The licensee did not evaluate the long-term impact from wear to the bearing fit surfaces, wear particles in oil samples, or long-term cyclic fatigue to adjacent piping and other components. This issue had crosscutting aspects associated with problem evaluation. The failure to establish a procedure with appropriate acceptance criteria was considered a performance deficiency. The finding was more than minor because it affected the mitigating systems cornerstone attribute of procedure quality and affected the cornerstone objective of ensuring availability, reliability and capability of systems to respond to events. The finding was of very low safety significance because, despite the fact that the condition was not properly evaluated, the affected equipment remained operable consistent with Generic Letter 91-18, Revision 1.

Mitigating Systems 09/25/2010 DIABO CANYON Green

• SCWE:

N

• HP:

N

• PIR:

Y Docket/Status:, 05000323 (C)

Open: 2010004 (PIM) Inadequate Risk Management During a Planned Auxiliary Saltwater Pump Outage The inspectors identified a finding after Pacific Gas and Electric failed to adequately manage risk during planned maintenance activity as required by Procedure AD7.DC6, On-line Maintenance Risk Management. On April 5, 2010, work control personnel requested that plant operators simultaneously remove Auxiliary Saltwater Pump 2-2 and Component cooling water Heat Exchanger 2-2 from service for two scheduled maintenance activities. Plant operators identified that the combination of the auxiliary saltwater pump and component cooling water heat exchanger out of service at the same time would result in an elevated maintenance risk (Yellow). Procedure AD7.DC6, On-line Maintenance Risk Management, Section 2.1, required that the licensee manage plant risk during on-line maintenance by minimizing the number of risk significant equipment simultaneously removed from service. The inspectors concluded that these two maintenance activities could have been performed in series rather than in parallel without affecting the duration either component was unavailable for maintenance. The licensee entered the performance deficiency into the corrective action program as Notification 50309451.

The inspectors determined that the performance deficiency is more than minor because the performance deficiency affected the Mitigating Systems Cornerstone attribute of human performance and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Also, the finding is similar to Example 7.e in Inspection Manual Chapter 0612, Appendix E, Examples of Minor Issues, because the work scope unnecessarily placed the plant into a higher licensee-established risk category and required additional risk management actions. The inspectors concluded that the finding is of very low safety significance (Green) based on an actual incremental core damage probability deficit of less than 1x10-6 and an evaluation using Flowchart 1 of Appendix K of Inspection Manual Chapter 0609, Maintenance Risk Assessment and Risk Management Significance Determination Process. This finding had a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program component because the licensee failed to implement adequate corrective actions to prevent unnecessarily entering elevated plant risk for the planned maintenance P.1(d).

Mitigating Systems 11/05/2010 PRAIRE ISLAND Green

• SCWE:

N

• HP:

N

• PIR:

Y Docket/Status:, 05000306 (C)

Open: 2010012 (PIM) INADEQUATE 50.59 EVALUATION FOR NEW MANUAL OPERATOR ACTIONS.

A Severity Level IV NCV of 10 CFR 50.59(d)(1), Changes, Tests, and Experiments, was identified by the inspector for the licensees failure to provide an evaluation that adequately documented why implementing new manual operator actions during periods of adverse weather, which isolated portions of the component cooling water system susceptible to hazards associated with tornado-generated missiles, did not present a more than minimal increase in the likelihood of occurrence of a malfunction of a structure, system or component (SSC) important to safety previously evaluated in the updated safety analysis report (USAR). The licensee initiated CAP 1257118, 50.59 Screening Not Sufficient - 122 Spent Fuel Pool Heat Exchanger Component Cooling Loss, and, at the end of the inspection, was in the process of correcting the deficiency. The violation was determined to be more than minor because the inspector could not reasonably determine that the changes would not have ultimately required prior NRC approval. Violations of 10 CFR 50.59 are dispositioned using Traditional Enforcement process instead of the SDP because they are considered to be violations that could potentially impede or impact the regulatory process. However, if possible, the underlying technical issue is evaluated under the SDP to determine the severity of the violation. In this case, the inspector determined that the finding could be evaluated using the SDP in accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings, Tables 3b and 4a, for the Mitigating Systems Cornerstone. The inspector answered Yes to Question 5 under the Mitigating Systems Cornerstone column of the Phase 1 worksheet because the inspector concluded that the finding screened as potentially risk significant due to a severe weather initiating event. Based upon Phase 3 SDP evaluation performed by a NRC Region III Senior Risk Analyst (SRA), the inspector concluded that the issue was of very low safety significance (Green). The inspectors concluded that this finding was cross cutting in the Problem Identification and Resolution area, corrective action component, because the licensee failed to thoroughly evaluate problems such that the resolutions address causes and extent of conditions as necessary P.1(c).

Miscellaneous 01/14/2005 ST. LUCIE N/A

• SCWE:

N

• HP:

N

• PIR:

N Docket/Status: 05000335 (C), 05000389 (C)

Open: 2004011 (PIM) Special Inspection's Findings and Observations Related with Breaker Failures After two safety-related 4160 volt circuit breakers failed to close, the licensee developed and performed sufficient tests to verify the ability of the remaining safety-related 4160 volt circuit breakers to operate. While the initial operability tests ensured that a breaker would cycle once, the licensee did not take into consideration breakers that must operate multiple times in performing various design functions. As a result, for any breaker cycled after passing an initial voltage verification test, but before operability was confirmed by a smooth operation check of the spring charging motor limit switch bracket, the licensee did not have reasonable assurance that the breaker would perform its safety function until a second successful voltage verification test was completed. The licensee's root cause evaluation was sufficient to identify the cause of the breaker failures associated with the 1A and 1C Component cooling water Pump Breakers.

However, it did not examine the following potential programmatic or organizational causes of the breaker failures: inadequate receipt inspection for the 1A Component cooling water Pump Breaker evidenced by the failure to identify the bent limit switch bracket; failure to refurbish the 1C Component cooling water Pump Breaker within the time frame identified in the maintenance program, or to identify the technical basis for extending the refurbishment cycle by 25%; and failure of the preventive maintenance procedure to identify the degraded performance of the 1C Component cooling water Pump Breaker. The licensee did not fully implement industry related operating experience in two areas; post-refurbishment receipt inspection of the Westinghouse DHP 4160 volt breakers and effects of hardened grease on 4160 volt breaker operation.

NonCited Violation Initiating Events 10/26/2005 CALVERT CLIFFS Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status: 05000317 (C)

Open: 2005005 (PIM) Failure To Establish Adequate Clearance Order Boundaries The inspectors identified a non-cited violation of Technical Specification 5.4.1.a. "..., written procedures shall be established, implemented,.." because plant procedural requirements were not implemented while establishing boundaries to perform maintenance activities. Specifically, on October 26, 2005, while hanging a clearance to support the replacement of 1-SV-3828, 11 shutdown cooling (SDC) outlet control valve (CV) solenoid valve, component cooling water flow to the Unit 1 containment components was reduced which adversely impacted the reactor coolant pumps due to the increased temperatures associated with the upper and lower guide bearings as well as the lower reactor coolant pump (RCP) seal. A misunderstanding as to how this clearance interacted with a previously established clearance lead to this event. The licensee restored component cooling water flow and corrected the sequencing of these clearances and maintenance activities to ensure plant stability was maintained. The licensee documented this occurrence in their corrective action program. This finding is greater than minor because it was associated with the Initiating Events Cornerstone configuration control attribute and affected the cornerstone's objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. This finding was determined to be of very low safety significance (Green), because it did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available. The inspectors identified that a contributing cause of this finding was related to the cross-cutting area of human performance. Specifically, the licensed operators did not follow plant procedures and determine if boundaries specified in the clearance order were adequate for the maintenance activity based on the actual plant conditions that existed at the time the clearance was to be implemented (Section 1R04).

Initiating Events 03/31/2006 CALVERT CLIFFS Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status: 05000317 (C)

Open: 2006002 (PIM) Failure to establish adequate physical boundaries for RCP maintenance Green. A self-revealing non-cited violation of Technical Specification 5.4.1 occurred when requirements contained in plant procedure NO-1-112, Safety Tagging, were not adequately implemented prior to maintenance on the 12A reactor coolant pump. Specifically, on February 22, 2006, while in Mode 5, a component cooling water system containment isolation valve was stroked open while performing a surveillance test which resulted in a level decrease of about 20 inches in the component cooling water head tank. T he cause of the event was due to an incomplete tagout boundary which had been established for the 12A reactor coolant pump seal replacement maintenance activity. The licensee documented this performance deficiency in their corrective action program for resolution. The inspectors determined that a contributing cause of this finding was related to the cross-cutting area of human performance in that licensed operators did not establish adequate tagout boundaries. This finding was more than minor because it was associated with the Initiating Event Cornerstone attribute of configuration control and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown operations. The event did not involve an actual loss of shutdown cooling (SDC). As a result, this finding was determined to be of very low safety significance (Green) in accordance with a risk assessment performed using the NRC Inspection Manual Chapter (IMC)0609, "Significance Determination Process,"

Appendix G, "Shutdown Operations" (Section 1R20).

Initiating Events 07/07/2007 WOLF CREEK Green

• SCWE:

N

• HP:

N

• PIR:

Y Docket/Status: 05000482 (C)

Open: 2007003 (PIM) Failure to Identify Cause of Component cooling water Valve Closures The inspectors identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Conditions Adverse to Quality, involving Wolf Creeks failure to identify and correct the cause of the reactor coolant pump (RCP) thermal barrier component cooling water heat exchanger outlet valves stroking closed on high flow. Specifically, between 2001 and 2007, Wolf Creek experienced repeated cases of the RCP thermal barrier component cooling water heat exchanger outlet valves stroking closed when two component cooling water pumps are started during train swaps. Wolf Creek evaluated the issue after inspector questioning but did not review the impact of the valves stroking closed during design basis events or accidents and the operators ability to open them given the valves circuit breakers opening. Wolf Creek has further condition reports open on this finding. The failure to identify and correct the condition adverse to quality of ensuring RCP seal cooling as described in the Updated Safety Analysis Report is a performance deficiency. The finding is more than minor because it is associated with the equipment performance attribute for the Initiating Events Cornerstone; and, it affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The finding is determined to be of very low safety significance because the finding would not result in exceeding the Technical Specification limit for identified reactor coolant system leakage and would not have affected other mitigation systems resulting in a total loss of their safety function.

The cause of the finding has problem identification and resolution crosscutting aspects in the area of corrective action because Wolf Creek did not thoroughly evaluate the issue such that the resolution addressed the extent of conditions given multiple opportunities documented in the corrective action program (P.1(c)).

Initiating Events 12/31/2008 PRAIRE ISLAND Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status: 05000282 (C), 05000306 (C)

Open: 2008005 (PIM) OPERATOR MANIPULATES INCORRECT COMPONENT DUE TO FAILURE TO FOLLOW PROCEDURES One self-revealed finding of very low safety significance and an associated NCV of Technical Specification (TS) 5.4.1 was identified on October 13, 2008, due to an operators failure to follow procedures during refueling activities. The failure to follow procedures resulted in a loss of seal injection flow to the 11 reactor coolant pump due to the manipulation of a Unit 1 seal injection valve rather than a Unit 2 seal injection valve. Corrective actions for this issue included communicating this event to all Operations personnel, resetting the operations departments event free clock and providing additional training of the use of human performance tools. The inspectors determined that this finding was more than minor because if left uncorrected, a continued failure to follow procedures could lead to the incorrect operation of additional plant equipment and become a more significant safety concern. The inspectors determined that this issue was of very low safety significance because the finding would not result in leakage that exceeded any TS limit and because the finding would not have affected other mitigation equipment. Specifically, the reactor coolant pumps were designed to be able to operate without seal injection flow for several hours as long as the component cooling water supply to the thermal barrier heat exchanger remained within allowable ranges. The inspectors concluded that this finding was cross cutting in the Human Performance, Decision Making area because the operator failed to use the systematic process for implementing procedures when deciding which valve needed to be manipulated.

Initiating Events 12/16/2009 WOLF CREEK Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status: 05000482 (C)

Open: 2009005 (PIM) Failure to Obtain Vendor Data Necessary for Plant Modification On December 16, 2009, inspectors identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, involving failure to obtain vendor design data for a modification.

In August 2009, a component cooling water modification was made to the reactor coolant pump thermal barrier heat exchangers flow rates as a corrective action to VIO 05000482/2009002 07 (EA-09-110). A flow rate above the previous design value was justified by an internal memo of a vendor opinion from a telephone conversation in 1992. The inspectors found this to be contrary to Procedure AP 05-005, for obtaining data from vendors. The notice of violation will remain open until full compliance has been restored. Wolf Creek consulted with Westinghouse, confirmed the acceptability of the increased flow rate, and requested a formal calculation. This issue is captured in Condition Report 22824. The inspectors determined that this finding was more than minor because this issue aligned with Inspection Manual Chapter 0612, Appendix E, example 2.f, in that the modification relied on verbal statements to raise the allowable flow through the heat exchanger. This is a significant deficiency in the modification package. The inspectors determined this finding was associated with the design control attribute of the Initiating Events Cornerstone and affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions. The inspectors evaluated the significance of this finding using Phase 1 of Inspection Manual Chapter 0609.04 and determined that the finding was of very low safety significance because assuming worst case degradation, the finding would not result in exceeding the technical specification limit for identified reactor coolant system leakage and would not have likely affected other mitigation systems resulting in a total loss of their safety function because seal injection was available.

This finding has a crosscutting aspect in the area of human performance associated with work practices in that management was unsuccessful in communicating expectations on procedure use and adherence in engineering H.4(b).

Initiating Events 12/31/2009 WATERFORD Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status:, 05000382 (C)

Open: 2009005 (PIM) Reactor Coolant Pump Vapor Seal Leakage A self-revealing Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, was identified for the licensees failure to promptly correct a condition adverse to quality. Specifically, the licensee did not promptly correct reactor coolant pump vapor seal leakage that resulted in boric acid accumulation on the component cooling water heat exchanger and cover areas of three reactor coolant pumps. Corrective actions for this condition were implemented during refuel outage 15, but these corrective actions failed to correct the condition and the vapor seal leakage continued through operating cycle 16. This resulted in some additional boric acid corrosion and degradation to reactor coolant pump covers and carbon steel component cooling water flanges. The licensee implemented a design modification to correct the condition and documented the condition in CR-WF3-2009-5501. The licensees failure to promptly correct a condition adverse to quality is more than minor because it is associated with the equipment performance attribute of the initiating events cornerstone and affects the cornerstone objective to limit the likelihood of those events that upset plant stability. The finding has very low safety significance because, although the finding contributes to the likelihood of a reactor trip, mitigation equipment was still available. This finding had a crosscutting aspect in area of human performance associated with work control in that the licensee did not effectively plan for the resources necessary to implement the post maintenance testing associated with the corrective actions implemented during refuel outage 15, and therefore failed to discover that those corrective actions were inadequate to correct the condition[H.3(a)].

Initiating Events 03/31/2010 WATERFORD Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status:, 05000382 (C)

Open: 2010002 (PIM) Failure to Control Transient Combustibles (Section 1R05)

The inspectors identified five examples of a green noncited violation of Waterford Steam Electric Station, Unit 3s license condition 2.C.9 for the failure to perform a transient combustible evaluation prior to introducing transient combustibles into procedurally controlled vital plant areas. Specifically, procedures limit the amount of transient combustibles that may be introduced into the control room ventilation equipment room, the component cooling water Train B heat exchanger room, and the main steam isolation valve Train B roof area. Any amounts greater than the preset procedural limits require a transient combustible evaluation to be performed. In all five cases, this evaluation was not performed prior to introduction of the transient combustibles. This violation has been entered into the licensees corrective action program as condition reports CR-WF3-2010-0482, CR-WF3-2010-0598, and CR-WF3-2009-4035. The performance deficiencies associated with this violation were the failure to comply with Waterford Steam Electric Station, Unit 3s license condition 2.C.9. Specifically, the procedural requirements to perform a transient combustible evaluation prior to introducing the transient combustibles into designated fire zones were not performed. Since several of the previously described fire zones fail to meet 10 CFR50, Appendix R train separation requirements, use of Inspection Manual Chapter 0612, Appendix E to screen for minor examples is not appropriate. This condition is greater than minor because, if left uncorrected, it would become a more significant safety concern, since continued introduction of unevaluated transient combustible loading into controlled areas could significantly reduce the ability to achieve a safe shutdown condition, in the event of a fire in that controlled area. The inspectors evaluated the finding using Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, to assess the safety significance. Since the severity of the observed deficiencies was assigned a low degradation rating, it was determined to be of very low risk significance. This finding had a crosscutting aspect in the area of human performance associated with the work practices component in that the licensee failed to utilize appropriate human error prevention techniques by (1) discussing transient combustible controls and expectations during pre-job briefs and (2) effectively utilizing human performance barriers, such as posted door signs H.4(a).

Mitigating Systems 12/31/2004 POINT BEACH Green

• SCWE:

N

• HP:

N

• PIR:

N Docket/Status: 05000266 (C), 05000301 (C)

Open: 2004012 (PIM) 10 CFR 50, Appendix B, Criterion XI, "Test Control." Failure to Have Adequate Test Procedures for the Testing of Safety-Related Switches A Green finding associated with a Non-Cited Violation of 10 CFR Part 50, Appendix B, Criterion XI, "Test Control," was identified by the inspectors for the failure to establish and perform testing required to demonstrate that components will perform satisfactorily in service with written test procedures which incorporate applicable requirements and acceptance limits. The licensee performed post-maintenance testing of a component cooling water pump control switch, a safety-related component, without the use of a written test procedure which incorporated the applicable requirements and acceptance limits for testing to demonstrate the component would perform satisfactorily in service. The licensee's extent of condition identified the potential for at least 11 additional activities for which safety-related components did not have the appropriate test procedures established. At the end of the inspection period, the licensee developed actions to correct the identified deficiencies and to ensure licensee personnel were aware of the requirements to use procedures for the testing of safety-related components. This issue was more than minor because if left uncorrected the finding could become a more significant safety concern. In addition, the finding affected the mitigating systems cornerstone attribute of procedure quality, specifically maintenance and testing (pre-event) procedures, and the cornerstone objective to ensure the reliability of systems that respond to initiating events to prevent undesirable consequences. In accordance with the Significance Determination Process, this finding was determined to be a Non-Cited Violation of very low safety significance because the finding was not a design or qualification deficiency that was confirmed to result in a loss of function per Generic Letter 91-18.

Mitigating Systems 02/10/2005 SAN ONOFRE Green

• SCWE:

N

• HP:

N

• PIR:

Y Docket/Status:, 05000361 (C)

Open: 2005002 (PIM) Failure to prevent recurrence of missing taper pins from Fisher butterfly valves A self-revealing non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, was identified for the licensee's failure to prevent recurrence of the significant condition adverse to quality of missing taper pins from safety-related Fisher butterfly valves. This deficiency, which affected the operability of the component cooling water system, had been identified six times since 1993.

The finding was more than minor because it is associated with the equipment performance attribute of the mitigating systems cornerstone and it affected the cornerstone objective by challenging the availability and capability of the containment spray system. In addition, if left uncorrected, the finding could become a more significant safety concern in that the loss of taper pins would continue to challenge the availability and capability of mitigating systems. Based on the results of the Significance Determination Process Phase 1 evaluation, the finding was determined to have very low safety significance (Green), because it did not result in an actual loss of safety function of the containment spray system. This finding also had crosscutting aspects associated with problem identification and resolution, because the extent of the condition was not properly evaluated.

Mitigating Systems 03/10/2005 WATERFORD Green

• SCWE:

N

• HP:

N

• PIR:

N Docket/Status:, 05000382 (C)

Open: 2005008 (PIM) Failure to maintain design control over Seismic Category 1 structure.

A noncited violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," was identified for failure to perform a complete and adequate design of a Seismic Category 1 structure. Specifically, the licensee failed to perform a complete analysis of the component cooling water surge tank baffle plate. The surge tank was designed and constructed with a baffle plate internal to the tank, providing two independent trains of component cooling water.

The analysis performed on the tank did not include an analysis of the baffle plate welds to ensure adequate performance for all applicable load scenarios. The licensee subsequently performed an analysis to demonstrate the adequacy of the baffle plate welds. This issue was entered into the corrective action program as Condition Report CR-WF3-2005-00313. The finding is greater than minor because it affects the Mitigating Systems Cornerstone objective, in that, not providing adequate design analyses for the baffle plate welds did not ensure that all load scenarios were included in the analysis. Failure of these baffle plate welds could have resulted in a loss of both trains of component cooling water surge tank. This finding is determined to be of very low safety significance because the licensee performed a calculation that demonstrated the adequacy of the welds, and there was no actual loss of a safety function.

Mitigating Systems 04/02/2005 PALISADES Green

• SCWE:

N

• HP:

N

• PIR:

Y Docket/Status: 05000255 (C)

Open: 2005004 (PIM) Failure to Implement Corrective Actions Which Impaired the Ability to Identify the Cause of CV-0823 and CV-0826 Failing to Open The inspectors identified a finding of very low safety significance (Green) regarding the failure to implement corrective actions in a timely manner to identify why the component cooling water heat exchanger service water outlet valves failed to open in February 2003 and March 2003.

Consequently, the cause was not identified and on January 16, 2005, CV-0826, "Component cooling water Heat Exchanger E-54B Service Water Outlet Valve," again failed to open when control room operators initially attempted to open the valve. The primary cause of this finding was related to the cross-cutting area of problem identification and resolution for failing to implement corrective actions. This finding was more than minor because it was related to the equipment performance attribute of the mitigating systems cornerstone and the cornerstone objective to ensure the reliability and capability of systems that respond to initiating events to prevent undesirable consequences was adversely impacted. Specifically, the reliability and capability of CV-0826 to automatically open on a recirculation actuation signal and provide the required flow to the component cooling water heat exchangers was not ensured when CV-0826 failed to open on January 16, 2005. The finding was of very low safety significance because the safety function was not lost. A non-cited violation of 10 CFR 50 Appendix B, Criterion XVI, "Corrective Action," was identified. As an interim corrective action, both CV-0823 and CV-0826 are being cycled on an increased frequency to verify the valves will stroke open. Other planned corrective actions included installing a larger spring in the valve actuators to increase the opening force to overcome high frictional forces and to evaluate and implement appropriate modifications for the valves.

Mitigating Systems 07/01/2005 INDIAN POINT Green

• SCWE:

N

• HP:

N

• PIR:

Y Docket/Status:, 05000247 (C)

Open: 2005003 (PIM) Inadequate post work test resulting in a safety related system exceeding its AOT The inspector identified a Green NCV of 10 CFR 50, App. B, Criterion XI "Test Control" involving an inadequate post work test following maintenance on auxiliary component cooling water discharge check valve 755A. This resulted in the failure to identify a condition which led to one train of the containment recirculation spray system being unavailable for greater than its technical specification (TS) allowed outage time. The finding is associated with the cross-cutting issue of problem identification and resolution in that the licensee's evaluation for CR IP2-2005-00252 failed to identify the deficiencies in the post maintenance test therefore no corrective actions were written to address this issue until prompted by the inspectors. This issue is greater than minor because the performance deficiency adversely affected the equipment performance attribute of the Mitigating Systems Cornerstone objective associated with ensuring the availability of systems that respond to initiating events to prevent undesirable consequences. A Phase 3 SDP analysis was used to assess the deficiency due to modeling limitations of the Phase 2 SDP tools. The Phase 3 evaluation, performed by a Region I Senior Reactor Analyst, confirmed that this issue was of very low safety significance.

Mitigating Systems 09/02/2005 FORT CALHOUN Green

• SCWE:

N

• HP:

N

• PIR:

N Docket/Status: 05000285 (C)

Open: 2005011 (PIM) Inadequate Analysis for Using Fire Water as a Backup for Raw Water The team identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion III (Design Control), for the failure to perform a complete and adequate analysis of the design conditions that exist for using fire water as a backup raw water source in Abnormal Operating Procedure AOP-18, "Loss of Raw Water." Specifically, the following technical errors in Calculation 203.19.05, "The Feasibility of Using Firewater for Cooling the Component cooling water System," Revision 4/26/88, were identified: the licensee failed to analyze river water temperatures at a maximum inlet temperature of 90°F as described in the Updated Safety Analysis Report and instead performed the analysis with a less conservative inlet temperature of 85°F; the supporting design documentation assumes the use of two of three Component cooling water Heat Exchangers A, C or D (which excludes heat exchanger "B") while Abnormal Operating Procedure AOP-18 allows the use of any two heat exchangers, and; Abnormal Operating Procedure AOP-18 includes steps to bring the reactor coolant temperature to 300°F, however, the design analysis only takes into account the reactor coolant temperature being held at a hot shutdown condition of 515°F. The failure to perform adequate design analyses to support required procedures was a performance deficiency. The issue had more than minor safety significance because it impacted the Mitigating Systems cornerstone objective of ensuring the availability, reliability, and capability of systems that mitigate plant accidents in that not providing an adequate analysis for the use of firewater could prevent proper cooling of the reactor coolant system. The finding was of very low safety significance because the procedure has never been required to be used. This issue has been entered into the licensee's corrective action program as Condition Report 200504328. (Section 1R21.1)

Mitigating Systems 09/02/2005 FORT CALHOUN Green

• SCWE:

N

• HP:

N

• PIR:

N Docket/Status: 05000285 (C)

Open: 2005011 (PIM) Inadequate Abnormal Operating Procedure for Loss of Raw Water The team identified a noncited violation of Fort Calhoun Technical Specification 5.8, "Procedures," for failure to properly develop and implement a technical specification required procedure. Technical Specification 5.8 states, in part, that written procedures shall be established, implemented and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2. Item 6g of Appendix A to Regulatory Guide 1.33 requires a procedure to combat a loss-of-service water (at Fort Calhoun service water is identified as the raw water system). Contrary to this, Fort Calhoun Abnormal Operating Procedure AOP-18, "Loss of Raw Water," was inadequate with respect to the connection of a back-up water source to the "A" component cooling water heat exchanger. The procedure requires that a fire water hose be connected to the raw water drain of the "A" component cooling water heat exchanger, however, the physical orientation of the connection and limited clearance with the adjacent wall would result in the fire water hose being kinked, which would restrict flow through this heat exchanger. This finding was a performance deficiency because the inadequate connection was not identified during verification of the adequacy of steps in Abnormal Operating Procedure AOP-18. The finding was greater than minor because it affected the Mitigating Systems cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events, in that, if left uncorrected could result in the plant not being able to sustain long-term decay heat removal under specific conditions. This finding was of very low safety significance because there has never been an instance when fire water has been called upon to provide cooling to the "A" component cooling water heat exchanger. This issue was entered into the licensee's corrective action program as Condition Report 200504153. (Section 1R21.5(1))

Mitigating Systems 09/30/2005 PRAIRE ISLAND Green

• SCWE:

N

• HP:

N

• PIR:

N Docket/Status:, 05000306 (C)

Open: 2005008 (PIM) INADEQUATE DESIGN CONTROL FOR THE 22 COMPONENT COOLING WATER HEAT EXCHANGER DIVIDER PLATE MODIFICATIONS A finding of very low safety significance was identified by the inspectors for a violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control." The licensee failed to implement appropriate configuration and design controls associated with modifications made to the number 22 component cooling water (CC) heat exchanger (HX) divider plate. Specifically, the licensee failed to verify input of a key input assumption, apply appropriate acceptance criteria, and update drawings with the replacement divider plate material installed. As corrective actions, the licensee revised related modifications and calculations, and intends to examine CC HX welds during the next internal HX inspection. This finding was more than minor because the number 22 CC HX divider plate was modified, returned to service, and operated outside design allowable limits due to excessive differential pressure. Sustained operation outside design allowable limits could have resulted in divider plate failure and loss of heat exchanger function.

The finding was of very low safety significance because it was a design issue which did not result in loss of function per Generic Letter 91-18.

Mitigating Systems 12/16/2005 POINT BEACH Green

• SCWE:

N

• HP:

N

• PIR:

N Docket/Status: 05000266 (C), 05000301 (C)

Open: 2005018 (PIM) Failure to Apply Adequate Design Controls During Replacement of Service Water (SW)

Valves SW-360 and SW-322 A self-revealed finding of very low safety significance was identified by the inspectors associated with a violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control." During replacement of the Service Water outlet valves for the Component cooling water (CCW) heat exchangers, the licensee failed to evaluate design differences between the original valves and the replacement valves. These differences led to the eventual failure of the stems in both valves. The issue was more than minor because it affected the mitigating system cornerstone attribute of "Design Control." The finding screened as having very low significance (Green) using IMC 0609, Appendix A, "Significance Determination of Reactor Inspection Findings for the At-Power Situations," because the inspectors answered "no" to all five questions under the Mitigating Systems Cornerstone column of the Phase 1 worksheet. While the design deficiency led to failure of the valves, the failures occurred during a plant shutdown; therefore, the valves would not have been required to function as designed.

Mitigating Systems 12/31/2005 SAN ONOFRE Green

• SCWE:

N

• HP:

N

• PIR:

N Docket/Status:, 05000361 (C), 05000362 (C)

Open: 2005005 (PIM) Failure to Implement Design Controls for Component cooling water Heat Exchanger Tube Plugging The inspectors identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," for the failure to implement appropriate design controls when plugging component cooling water heat exchanger tubes. Specifically, plugging heat exchanger tubes constitutes a design change. Criterion III requires the licensee to implement design control measures commensurate with those applied to the original design. The licensee entered the issue into their corrective action program as Action Request 051201123. The failure to implement appropriate design controls when plugging heat exchanger tubes was a performance deficiency. The issue was more than minor because, if left uncorrected, it could result in a more significant safety concern, in that the heat exchanger may not be able to meet licensing basis/design basis heat exchanger capabilities. The inspectors assessed the finding in accordance with the Manual Chapter 0609, "Significance Determination Process," Phase 1 worksheet and determined the finding was of very low safety significance. Specifically, this design deficiency was confirmed not to result in loss of operability in accordance with "Part 9900, Technical Guidance, Operability Determination Process for Operability and Functional Assessment."

Mitigating Systems 02/17/2006 SALEM Green

• SCWE:

N

• HP:

N

• PIR:

N Docket/Status: 05000272 (C)

Open: 2006006 (PIM) DEGRADED COMPONENT COOLING WATER VALVE IMPACT ON COMPONENT COOLING WATER HYDRAULIC ANALYSES The team identified a finding of very low safety significance (Green) involving a non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action. Specifically, the corrective actions for a degraded condition that impacted the existing design analysis for component cooling water flowrates to safety-related components under certain accident scenarios was inadequate. PSEG had failed to identify and evaluate the impact of a 700 gpm leak-by through a spent fuel pool heat exchanger valve which invalidated existing component cooling hydraulic model design analysis assumptions. The finding was more than minor because the condition affected the design control performance attribute of the mitigating system cornerstone objective to ensure the capability of systems that respond to initiating events. The team reviewed this finding using the Phase 1 SDP worksheet for mitigating systems and determined the finding was of very low safety significance (Green), because there was no loss of system safety function.

Mitigating Systems 03/24/2006 BYRON Green

• SCWE:

N

• HP:

N

• PIR:

N Docket/Status: 05000454 (C), 05000455 (C)

Open: 2006006 (PIM) Failure to Translate Design Basis Into Procedures for Service Water Flow to the CC Heat Exchangers The inspectors identified a Non-Cited Violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, having very low safety significance for the licensees failure to correctly translate the design basis into procedures. Specifically, the licensee failed to update operator rounds to verify the revised design basis minimum value for essential service water flow to the component cooling water (CC) heat exchangers. In addition, because the operator rounds were not revised, the design basis minimum flow value was not bounded by the emergency operating procedure used for establishing initial cold leg recirculation in the event of a loss of coolant accident (LOCA). This issue was entered into the licensees corrective action program to revise the operator rounds. The issue was more than minor because it was associated with the Mitigating System cornerstone attribute of Design Control, and affected the cornerstone objective of ensuring the capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to have operator rounds verify the design basis minimum service water flow or to have the emergency operating procedures ensure the minimum flow prior to establishing initial cold leg recirculation in the event of a LOCA could potentially have allowed the service water flow to be less than the required value to maintain the design heat load during post LOCA conditions. This finding was of very low safety significance because it screened out as Green using the SDP Phase 1 worksheet. Even though the licensee did not control their bounding design basis service water flow procedurally, the flow to the CC heat exchangers has historically been well above the bounding design basis flow.

Mitigating Systems 03/31/2006 SEABROOK Green

• SCWE:

N

• HP:

N

• PIR:

Y Docket/Status: 05000443 (C)

Open: 2006002 (PIM) Failure to Identify and Correct Degraded Component cooling water Flow to Safety-Related Components The inspectors identified a non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action." In January 2006, the inspectors identified degraded component cooling water flow to the residual heat removal pump seal cooler and the enclosure air handling cooler.

Although the flows were determined to be below design basis values, additional engineering analysis demonstrated the degraded flow would not result in inoperability of the systems.

Seabrook completed immediate actions to adjust the component cooling water flow to the safety-related components. This finding was associated with the cross-cutting area of problem identification and resolution in that operators performing routine tours in the areas of the flow indicators and system engineers recording flows during quarterly walkdowns did not identify that the flow was degraded for eight months. The finding is more than minor because it affected the Mitigating System cornerstone objective to ensure the availability, reliability, and capability of systems that respond to an initiating event. The attribute of equipment performance was impacted by the degraded component cooling water flow. The finding is determined to be of very low safety significance (Green) since it did not result in loss of safety function of the equipment and it did not impact external initiating events.

Mitigating Systems 04/14/2006 CALLAWAY Green

• SCWE:

N

• HP:

N

• PIR:

Y Docket/Status: 05000483 (C)

Open: 2006011 (PIM) Failure to Recognize and Correct Inadequate Emergency Procedures The inspectors identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion XVI, for the failure to take adequate corrective action to prevent recurrence of a significant condition adverse to quality. Specifically, AmerenUE failed to correct the Emergency Operating Procedure deficiencies associated with Final Safety Analysis Report requirements following an April 15, 1998 notification of the same deficiencies at another standardized nuclear unit power plant system plant. At that time AmerenUE did not identify and correct similar deficiencies involving the component cooling water system support function for residual heat removal heat exchangers. The Emergency Operating Procedure deficiencies were discovered by plant personnel on March 27, 2006, during a simulator exercise involving the transition to the emergency core cooling system recirculation phase. Problem identification and resolution crosscutting aspects were identified for the failure to adequately identify and correct Emergency Operating Procedures deficiencies to ensure operation within the design basis. This issue was more than minor because it affected the Mitigating Systems cornerstone objective of equipment reliability. The failure to provide for component cooling water system flow through the residual heat removal heat exchangers for initial containment recirculation could result in a loss of the component cooling water system and thus become a much more significant safety concern.

AmerenUEs evaluation of the condition was considered for the time allowable to establish component cooling water flow before a loss of the component cooling water system would occur. AmerenUE provided an evaluation that demonstrated a loss of component cooling water would not occur based on the timing of operator actions. Because the timing did affect the probabilistic risk assessment for human reliability, a Phase 3 risk assessment was performed by an NRC senior reactor analyst. The analyst determined that the finding was of very low safety significance, Green. AmerenUE entered this issue into their corrective action program as Callaway Action Request 200602565.

Mitigating Systems 12/31/2006 ANO Green

• SCWE:

N

• HP:

N

• PIR:

N Docket/Status:, 05000368 (C)

Open: 2006005 (PIM) FAILURE TO PERFORM MODIFICATION RESULTED IN AN INOPERABLE REACTOR COOLANT PUMP OIL COLLECTION SYSTEM A self-revealing noncited violation of ANO Unit 2 License Condition 2.C.(3)(b), Fire Protection, was identified for failure of the licensee to maintain the lube oil collection system for reactor coolant Pumps C and D in an operable condition. Specifically, the licensee failed to perform a modification on the motor installed on reactor coolant Pump C which resulted in the oil collection tank and its associated overfill berm being filled with water from the component cooling water system. This issue was entered into the licensee's corrective action program as Condition Report ANO-2-2006-1407. The finding was determined to be more than minor because it affected the protection against external factors attribute of the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using the fire protection significance determination process, the finding is determined to have very low safety significance because the condition constituted a low degradation of fire prevention and administrative controls feature.

Mitigating Systems 12/31/2006 FORT CALHOUN Green

• SCWE:

N

• HP:

N

• PIR:

Y Docket/Status: 05000285 (C)

Open: 2006005 (PIM) Failure to Promptly Identify and Correct a Degraded Component cooling water Pump The inspectors identified a Green NCV for the licensees failure to promptly identify and correct a degraded component cooling water pump. The failure to recognize and fix this condition led to the pump being more likely to fail upon a valid demand to start. This finding was determined to be greater than minor because it affected the Availability/Reliability component of the Equipment Performance attribute under Mitigating Systems cornerstone. The inspectors evaluated this finding using Manual Chapter 0609, Appendix A, and determined that it was of very low safety significance (Green). This conclusion was reached because the finding wasnt a design or qualification deficiency, the finding did not represent a loss of safety function, was not an actual loss of safety function of a single train for greater than its Technical Specification Allowed Outage time, did not represent an actual loss of safety function for non-Technical Specification equipment, and was not potentially significant due to external events such as flooding, seismic occurrences, etc. This violation was entered into the licensees corrective action program as Condition Report (CR) 200603835. This finding has a crosscutting aspect in the area of problem identification and resolution because the licensee failed to identify and correct the condition despite numerous opportunities to do so.

Mitigating Systems 03/31/2007 SURRY Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status:, 05000281 (C)

Open: 2007002 (PIM) Inadequate Procedural Instructions Results in Inoperable Charging Pump Component cooling water System A self-revealing non-cited violation of Technical Specification 6.4.A, Unit Operating Procedures and Programs, was identified for failure to have adequate written procedures for normal startup of systems and components involving nuclear safety. Specifically, the licensee failed to have adequate procedural instructions to preclude the Unit 2 charging pump component cooling water system from becoming air bound when returning it to service. As a result all three Unit 2 charging pumps, also emergency core cooling system (ECCS) pumps, were declared inoperable due to lack of seal cooling. This violation was entered in the licensee corrective action program as CR000031 for resolution, which included performing an apparent cause analysis, and determining corrective actions. The finding is more than minor because a procedural error that results in a consequence, in this case the inoperability of three ECCS pumps, is more than of minor safety significance. The significance of the finding was determined to be of very low safety significance (Green) due to the short period of time the cooling water system was unavailable. The cause of the finding was directly related the complete documentation and component labeling aspect of the human performance cross-cutting area because procedural instructions for venting the component cooling water system were not adequate.

Mitigating Systems 06/12/2007 BRAIDWOOD Green

• SCWE:

N

• HP:

N

• PIR:

Y Docket/Status: 05000456 (C), 05000457 (C)

Open: 2007007 (PIM) INADEQUATE EXTENT OF CONDITION REVIEW WHICH FAILED TO IDENTIFY THAT IST TESTING WAS NOT PERFORMED FOR COMPONENT COOLING WATER SYSTEMS VALVES The inspectors identified a Non-Cited Violation of 10 CFR Part 50, Appendix B, Criterion XI, "Test Control," because the licensee failed to include several manual component cooling water system valves that were required to perform a safety function, in the inservice testing (IST) program and subsequently test the valves in accordance with IST program requirements. The finding was related to the cross-cutting area of Problem Identification and Resolution. A cross-cutting aspect in the corrective action program was identified because the licensee did not conduct an adequate extent of condition review, for a previously missed IST surveillance on several essential service water system valves. As a result, the licensee failed to identify that the component cooling water systems valves required inclusion in and testing by the IST program.

The licensee initiated an issue report to track the corrective actions for this finding.

Subsequently, the licensee placed the valves on the Plan-Of-The-Day Meeting Agenda to ensure testing, which was scheduled for June 30, 2007. The failure to account for these valves in the IST program was more than minor because the finding affected the mitigating systems cornerstone objective of ensuring the availability and reliability of the component cooling water and residual heat removal systems when required to respond to initiating events to prevent undesirable consequences. Specifically, the finding was associated with the mitigating systems attribute of equipment performance. The finding is of very low safety significance because the finding screened as Green during the Phase 1 Significance Determination Process.

Mitigating Systems 06/30/2007 CATAWABA Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status:, 05000414 (C)

Open: 2007003 (PIM) Inadequate Implementation of Risk Management Actions Associated With Planned Maintenance on the Unit 2 B Train KC Heat Exchanger Inspectors identified a non-cited violation (NCV) of 10 CFR 50.65(a)(4) for the licensees failure to effectively implement the risk mitigation actions contained in the approved Critical Evolution Plan associated with work on the Unit 2 B Train Component cooling water (KC) heat exchanger to manage and minimize the resulting increased plant risk. Specifically, during the cleaning of the Unit 2 B Train KC heat exchanger tubes, the offsite power supply was not protected and in fact, work was conducted within the switchyards protective fence. This issue has been entered into the licensees corrective action program as Problem Investigation Process report (PIP) C-07-2025. This finding was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences is maintained. The inspectors completed a Phase 1 screening of the finding using Appendix K of the Inspection Manual Chapter 0609, Maintenance Risk Assessment and Risk Significance Determination Process, and determined that the performance deficiency represented a finding of very low safety significance based on the resulting magnitude of the calculated Incremental Core Damage Probability associated with the work being performed in the switchyard in conjunction with the 2B KC heat exchanger tube cleaning being less than 1E-6. The finding directly involved the cross-cutting area of Human Performance under the Work Activity Coordination aspect of the Work Control component, in that the licensee failed to appropriately coordinate work activities to ensure the operational impact of the planned work was controlled and the increased risk minimized in accordance with the approved Critical Evolution Plan associated with the cleaning of the Unit 2 B train KC heat exchanger (H.3.b) (Section 1R13b.(1)).

Mitigating Systems 07/25/2007 FORT CALHOUN Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status: 05000285 (C)

Open: 2007007 (PIM) Inadequate Abnormal Operating Procedure for loss of Component cooling water The team identified a noncited violation of Fort Calhoun Technical Specification 5.8, Procedures, for an inadequate Technical Specification required procedure. Specifically, Abnormal Operating Procedure 11, "Loss of Component cooling water, could not be performed as written for establishing backup raw water to the containment fan coolers during post-accident conditions with a loss-of-component cooling water. The licensee has entered this finding into their corrective action program as Condition Report 2007-02268. The finding is greater than minor because it is associated with the barrier integrity cornerstone attribute for operating post event procedure quality. Using the significance determination process of Manual Chapter 0609, Appendix A, for the containment barrier cornerstone, the finding did not represent an actual open pathway in the physical integrity of reactor containment or involve an actual reduction of defense-in-depth for the atmospheric pressure control of the reactor containment. The finding had a cross-cutting aspect in the area of human performance resources because the licensee did not ensure that procedures to assure nuclear safety, in this case establishing backup raw water to the containment fan coolers during post-accident conditions with a loss-of-component cooling water, were complete, accurate and up-to-date.

Mitigating 10/15/2007 BRUNSWICK Green

• SCWE:

• HP:

• PIR:

Systems N

N Y

Docket/Status: 05000325 (C), 05000324 (C)

Open: 2007011 (PIM) Inadequate Corrective Action for Fisher Model 9100 Unbonded Butterfly Valve Failures The inspectors identified an NCV of 10 CFR 50 Appendix B, Criterion XVI, for failure to promptly identify and correct a condition adverse to quality related to foreign material in the service water system (SW) resulting from Fisher butterfly valve rubber lining failures. There had been a number of failures of Fisher butterfly valve rubber linings since 1985 including a Unit 1 failure in 2004 and a Unit 2 failure in 2005. The examples in 2004 and 2005 were examples where valve lining material was missing from Fisher valves and all the material was not accounted for and removed from the SW system. On August 16, 2007, the licensee detected reduced flow from the 1B Residual Heat Removal (RHR) room cooler and on August 18, 2007, identified foreign material in the inlet piping to the cooler. Additional rubber lining material was also found in the 1 A RHR room cooler. An additional example of Fisher valve foreign material in the SW system was noted in 2005 in the Unit 2 2B Turbine Building Component cooling water Heat Exchanger.

The licensee entered this issue into the corrective action program. The failure to maintain the SW system free of foreign material was considered a performance deficiency and a finding in the mitigating systems cornerstone. This finding is greater than minor because it affected the availability and reliability of the RHR room coolers which support the emergency core cooling equipment used to mitigate the consequences of an accident. Although related to degradation in the service water system, the finding is of very low safety significance because the licensee detected the change in SW flow and removed the material prior to the flow reduction reaching the minimum required flow for accident mitigation. There was no loss of safety function from either train of service water. This finding has an appropriate and timely corrective action aspect in the cross-cutting area of problem identification and resolution because the licensee failed to recognize the foreign material as a condition adverse to quality and implement timely corrective action to locate the source of and remove all the material from the SW system Mitigating Systems 12/31/2007 CALLAWAY Green

• SCWE:

N

• HP:

N

• PIR:

N Docket/Status: 05000483 (C)

Open: 2007005 (PIM) Failure to Establish Needed Test Conditions to Satisfy Technical Specification Surveillance Requirement 3.8.1.18 The inspectors identified a Green noncited violation of 10 CFR 50, Appendix B, Criterion XI, Test Control, after AmerenUE confirmed that the load shedding emergency load sequencing test could not demonstrate that component cooling water pump breakers would perform satisfactorily in service. On November 19, 2007, AmerenUE determined that quantitative data did not exist to support that component cooling water pump breakers would be capable of closing at Step 1 (5 seconds) of the load shedding emergency load sequence. Technical Specification Surveillance Requirement 3.8.1.18, testing of the emergency load sequencing, required the licensee to verify that load blocks are actuated within +/-10 percent of the specified start time. This finding, failure to correctly test 4 kV essential bus loading, is more than minor because it was associated with the reactor safety mitigating systems cornerstone attribute of equipment performance and affected the cornerstone objective to ensure availability and reliability of systems that respond to initiating events to prevent undesirable consequences.

Using the Manual Chapter 0609, Significance Determination Process, Phase 1 worksheet, this finding was determined to have very low safety significance because it was not a design or qualification deficiency, did not represent a loss of system safety function, did not represent a loss of safety function of a single train for greater than its Technical Specification allowed outage time and did not affect seismic, flooding, or severe weather initiating events. This finding was evaluated as not having a crosscutting aspect because it was not reflective of current licensee performance.

Mitigating Systems 04/07/2008 WATERFORD Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status:, 05000382 (C)

Open: 2008002 (PIM) ACCW pump failure due to inaccurate operator aid The inspectors identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, because the licensee failed to correct a condition adverse to quality (inadequate instructions that led to low fuel oil and the failure of auxiliary component cooling water pump bearing). Specifically, the licensee's corrective action for a previous event called for an operator aid (oil level label). However, the operator aid contained incorrect and confusing information. Consequently, another auxiliary component cooling water pump failed. The licensee entered this deficiency into their corrective action program as Condition Report CR WF3 2008-0350. The finding was more than minor because it was similar to nonminor violation example 4.f in Inspection Manual Chapter 0612, Appendix E, "Examples of Minor Issues," in that the problem affected auxiliary component cooling water Pump B operability. Using the Manual Chapter 0609, "Significance Determination Process," Phase 1 Screening Worksheet, the issue screened as having very low safety significance because it did not: (1) represent a loss of safety function; (2) represent an actual loss of a single train of equipment for more than its Technical Specification allowed outage time; or (3) screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. This finding had crosscutting aspects associated with Human Performance area, resources program component, because the licensee failed to have correct labeling on components H.2(c).

Mitigating Systems 06/03/2008 SAN ONOFRE Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status:, 05000361 (C)

Open: 2008003 (PIM) Failure to Properly Implement the Operability Determination Process.

The inspectors identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, for the failure of operations and engineering personnel to follow procedures and adequately evaluate degraded, nonconforming, and unanalyzed conditions to support operability decision-making. Specifically, on June 3, 2008, operations and engineering personnel failed to adequately evaluate the operability of the Unit 2 component cooling water system Train A when unexpected, rapid heat exchanger fouling occurred during low tide conditions. This finding was entered into the licensees corrective action program as Action Request 080600438. The finding is greater than minor because the degraded component cooling water heat exchanger is associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affects the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using the Manual Chapter 0609, Significance Determination Process, Phase 1 Worksheets, the finding is determined to have very low safety significance because the finding did not result in a loss of safety function of component cooling water Train A for greater than the Technical Specification allowed outage time. This finding has a crosscutting aspect in the area of human performance associated with decision-making because the licensee did not make safety-significant decisions using a systematic process when faced with uncertain and unexpected conditions H.1(a).

Mitigating Systems 06/03/2008 SAN ONOFRE Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status:, 05000362 (C)

Open: 2008003 (PIM) Component cooling water heat exchanger not operable due to Inadequate Maintenance Procedure.

The inspectors identified a noncited violation of Technical Specification 5.5.1.1 for the failure of maintenance personnel to have adequate procedures in place to ensure maintenance associated with a saltwater cooling isolation butterfly valve would not adversely impact the availability or operability of the component cooling water heat exchanger. Specifically, on January 8, 2008, inadequate procedures resulted in the failure to properly install butterfly Valve 2HCV6510. Additionally, the postmaintenance testing procedure was not adequate to verify the proper function of the valve prior to its return to service. This finding was entered into the licensees corrective action program as Action Request 0806000104. The finding is greater than minor because the degraded saltwater cooling valve is associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affects the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using the Manual Chapter 0609, Significance Determination Process, Phase 1 Worksheets, the finding is determined to have very low safety significance because the finding did not result in a loss of safety function of component cooling water Train A for greater than the Technical Specification allowed outage time. This finding has a crosscutting aspect in the area of human performance associated with resources because the licensee did not have complete, accurate, and up-to-date procedures

H.2(c).

Mitigating Systems 12/31/2008 CATAWBA Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status:, 05000414 (C)

Open: 2008005 (PIM) Inadequate Implementation of Risk Management Actions Associated With Planned Maintenance on the Unit 2 A Train KC Heat Exchanger The inspectors identified a non-cited violation (NCV) of 10 CFR 50.65(a)(4) for the licensees failure to provide sufficient details for equipment protection in the approved Critical Activity Plan.

In addition, the risk mitigation actions contained in the plan intended to manage and minimize the increased plant risk associated with work on the Unit 2 A Train of Component cooling water (KC). The finding was more than minor because the risk mitigation strategies in the Critical Activity Plan were not effectively implemented. In addition, the plan lacked specific guidance on what components were to be posted to provide adequate protection of the 2B train of KC. As a result, work activities were allowed to take place that could have adversely affected the remaining train of KC. This finding was determined to be of very low safety significance because the resulting magnitude of the calculated Incremental Core Damage Probability was less than 1E-5 and the licensees implementation of more than three Risk Management Actions.

The finding directly involved the cross-cutting area of Human Performance under the Work Activity Coordination aspect of the Work Control component H.3.b]. This issue has been entered into the licensees corrective action program as Problem Investigation Process report (PIP) C-08-6133 (Section 1R13.1).

Mitigating Systems 01/21/2009 SAN ONOFRE Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status:, 05000361 (C)

Open: 2009002 (PIM) Failure to Properly Implement the Operability Determination Process The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, for the failure of operations and engineering personnel to follow procedures and adequately evaluate degraded conditions to support operability decision-making. Specifically, operations and engineering personnel failed to adequately evaluate the operability of the Unit 2 component cooling water system Train B, when a tube leak was identified, and subsequently, when the tube exhibited a degrading trend. This finding was entered into the licensees corrective action program as Nuclear Notification 200289984. The finding is greater than minor because the degraded component cooling water heat exchanger is associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affects the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using the Manual Chapter 0609, Significance Determination Process, Phase 1 Worksheets, the finding is determined to have very low safety significance because the finding did not result in a loss of safety function of component cooling water Train B for greater than the technical specification allowed outage time. The finding has a crosscutting aspect in the area of human performance associated with decision-making because the licensee did not review past operability decisions to verify the validity of the underlying assumptions H.1(b) (Section 1R15).

Mitigating Systems 03/31/2009 CATAWABA Green

• SCWE:

N

• HP:

N

• PIR:

N Docket/Status: 05000413 (C), 05000414 (C)

Open: 2009002 (PIM) Failure to translate design requirements into a maintenance program to ensure Component cooling water system operability was maintained over the design life of the plant (Section 4OA3.1)

• Green: A self-revealing non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, "Design Control," was identified for the failure to translate the design basis for the Component cooling water (KC) heat exchanger Nuclear Service Water (RN) outlet control valve and the vendors construction drawings into maintenance procedures to ensure the valve would remain operable over the design lifetime of the component. More specifically, the valves actuator arm assembly was not scoped into the licensees maintenance procedures for replacement, despite the fact that the vendor drawing identified the assembly as a consumable. As a result, an initially undetected failure of the assembly rendered the 1A train of KC inoperable for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, which included three periods of time (in excess of the unit shutdown requirements in Technical Specification (TS) Limiting Condition for Operation (LCO) 3.0.3) in which the 1B train was also unavailable due to planned maintenance. The finding was determined to be more than minor because it is associated with the Mitigating Systems cornerstone of Design Control. It impacts the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events and prevent undesirable consequences. The failure to adequately maintain the valve actuator arm assembly resulted in a train of safety-related equipment being rendered inoperable, which was determined to be a safety system functional failure. Using the IMC 0609, "Significance Determination Process," Phase 1 Worksheet, the inspectors concluded that a Phase 2 evaluation was required because the finding resulted in a loss of safety function.

The inspectors performed a Phase 2 analysis using Appendix A, "Determining the Significance of Reactor Inspection Findings for At-Power Situations," of IMC 0609, "Significance Determination Process," and the Phase 2 Worksheets for Catawba Nuclear Station. The finding was determined to be of very low safety significance (Green) based upon the Phase 2 evaluation. This finding was reviewed for crosscutting aspects and none were identified. This issue has been entered into the licensees Corrective Action Program as Problem Investigation Process (PIP) report C-09-0546 (Section 4OA3.1).

Mitigating Systems 03/31/2009 INDIAN POINT Green

• SCWE:

N

• HP:

N

• PIR:

Y Docket/Status:, 05000247 (C)

Open: 2009002 (PIM) Inadequate Test Acceptance Criteria for Auxiliary Component Cooling Check Valves The inspectors identified a NCV of very low safety significance related to 10 CFR 50.55a, Codes and standards, because Entergys procedure, 2-PT-Q031A for an auxiliary component cooling water pump, did not contain appropriate acceptance criteria for positively determining that safety-related check valves performed their safety function when required in accordance with the American Society of Mechanical Engineers (ASME) OM Code. Specifically, the test used reverse rotation of a parallel pump to verify that the pumps discharge check valve was closed although previous site-specific experience demonstrated that the pump impeller would not rotate backwards when the check valve was stuck open. Entergy entered this issue into their corrective action program as CR-2009-1312. The inspectors determined that the performance deficiency was greater than minor because it was associated with the procedure quality attribute of the Mitigating System cornerstone and it adversely affected the cornerstones objective to ensure the reliability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the test criterion used in procedure 2-PT-Q013A did not ensure that valve 755A reliably performed its safety function when tested as demonstrated by testing performed in January 2005. The inspectors determined that the performance deficiency was of very low safety significance (Green) IMC 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings. Specifically, the inspectors determined that this finding was of very low safety significance because the finding did not result in a loss of safety function and did not screen as potentially risk-significant due to external events initiating events. The inspectors determined the finding had a cross-cutting aspect related to effective corrective actions in the corrective action program component of the problem identification and resolution area.

Specifically, Entergy personnel did not implement effective corrective actions to resolve the testing inadequacy since 2005 and during subsequent quarterly testing.

Mitigating Systems 04/09/2009 SOUTH TEXAS PROJECT Green

• SCWE:

N

• HP:

N

• PIR:

Y Docket/Status:, 05000499 (C)

Open: 2009002 (PIM) Inadequate Reportability Misses an Inoperable Component cooling water Train The inspectors identified a noncited violation of Technical Specification 3.7.3 for an inadequate reportability review on the Train A component cooling water low-level actuation switch which failed during surveillance testing. On October 14, 2008, during the 18-month surveillance test, Unit 2 component cooling water Train A was determined to be inoperable due to the failure of system valves to actuate to their designated positions. The inspectors continued to ask questions related to the event and discovered that the last time the switch was manipulated was January 22, 2008, during a calibration procedure. After the inspectors questioned the reportability, engineering reviewed it and determined that the calibration procedure did not have a functional check of the switch internal contacts before restoration. Engineering concluded that, as a result of the switch not being functionally checked after the calibration, that the wire must have become disconnected during the restoration section of the procedure. Consequently, from January 22, 2008 through October 16, 2008, the Train A component cooling water low-low level switch was inoperable and therefore reportable. The licensee performed a root cause of the event itself and an apparent cause for operations inappropriately applying time of discovery for the initial reportability review under Condition Reports 08-15541 and 08-19420, respectively.

The finding was more than minor because, if left uncorrected, it would have the potential to lead to a more significant safety concern in that inadequate operability/reportability reviews could result in a degraded system being returned to service, and it affected the Mitigating Systems cornerstone attribute of human performance and the objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using the Significance Determination Process Phase 1 worksheets from Inspection Manual Chapter 0609, the finding was determined to have very low safety significance because it did not result in the actual loss of safety function of one or more trains and it did not screen as risk significant due to seismic, flooding, fire, or severe weather. In addition, this finding had Problem Identification and Resolution crosscutting aspects associated with the corrective action program P.1(c) because the licensee failed to thoroughly evaluate for operability and reportability conditions adverse to quality.

Mitigating 09/30/2009 PRAIRIE ISLAND Green

• SCWE:

• HP:

• PIR:

Systems N

Y N

Docket/Status: 05000282 (C)

Open: 2009004 (PIM) INADEQUATE WORK INSTRUCTION FOR WELD REPAIRS ON THE 11 COMPONENT COOLING HEAT EXCHANGER On September 16, 2009, the inspectors identified a finding of very low safety significance and a Non-Cited Violation of 10 CFR Part 50, Appendix B, Criterion V, for the licensees failure to have adequate work instructions associated with weld repairs on the 11 component cooling water heat exchanger. Specifically, the licensee failed to include the applicable American Society of Mechanical Engineers Code,Section XI, post weld acceptance criteria into Work Instruction 100611. As a corrective action, the licensee performed an inservice Code VT-2 visual examination to confirm that the heat exchanger was not leaking from the weld repair areas. The inspectors determined that this finding was more than minor because if left uncorrected, the failure to have adequate work instructions could become a more significant safety concern.

Specifically, the failure to include a pressure test and Code VT-2 visual examination could result in undetected heat exchanger leakage affecting the operability of an inservice component cooling water train. This finding was of very low safety significance because it was a design or qualification deficiency, confirmed to not result in loss of operability or functionality. The inspectors determined this finding had a cross-cutting aspect in the area of Human Performance, adequacy of procedures, because the licensee failed to ensure that the work instruction for the weld repair on the 11 component cooling water heat exchanger was complete and up to date with the applicable Code requirements.

Mitigating Systems 09/30/2009 WOLF CREEK Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status: 05000482 (C)

Open: 2009004 (PIM) Inability to perform manual actions for risk assessment The inspector identified a noncited violation of 10 CFR 50.65(a)(4) for failure to adequately assess and manage the increase in risk during fuse inspection of component cooling water valves supplying cooling loads inside containment. On March 18, 2009, component cooling water Valves EG HV-16 and EG HV-54 were out of service for fuse inspections to verify wiring for fire protection analyses. The inspectors observed that the evolution was not included in the weekly risk assessment and that operation and maintenance personnel did not have guidance or briefings for restoration of the valves. Review of the risk assessment revealed that the impact of de-energizing the valves in the closed position was neglected and that restoration actions credited by the risk analyst were unknown to the control room and craft workers. T he issue was entered into the corrective action program as Condition Report 15318. The failure to adequately assess and manage risk in accordance with AP 22C-003 and the preplanned risk assessment for the use of local actions to ensure component cooling water cooling to loads inside containment was a performance deficiency. The finding is more than minor because the licensee failed to effectively manage prescribed significant compensatory measures for maintenance activities that could increase the likelihood of initiating events. The finding was of very low safety significance because the magnitude of the calculated risk deficit was less than IE-6 even though risk management actions were not in place. The inspectors also determined that the finding has a human performance crosscutting aspect in the area associated with work control because the risk assessment procedure and clearance order procedure assumed local actions could be accomplished but there was no communication regarding this during the work planning stages H.3(b).

Mitigating Systems 10/15/2009 WOLF CREEK Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status: 05000482 (C)

Open: 2009005 (PIM) Unevaluated Scaffold Against Component cooling water Piping The inspectors identified a noncited violation of Technical Specification 5.4.1.a for failure to properly implement Procedure AP 14A-003, Scaffold Construction and Use, when scaffolding was erected against operable safety-related equipment. On October 15, 2009, the inspectors walked down containment and identified scaffolding in contact with component cooling water piping. The tag on the scaffold explicitly stated that it was not seismically qualified. At the time, both steam generators were inoperable and both trains of residual heat removal were required to be operable. The inspectors reviewed the bases for Technical Specification 3.4.7, RCS Loops - Mode 5, Loops Filled, which required an operable heat sink path from residual heat removal to component cooling water to essential service water. This issue was entered into the corrective action program as Condition Report 22464. The construction of an unqualified scaffold against operable component cooling water piping was a performance deficiency. The inspectors determined that this finding was more than minor because it is associated with the equipment performance attribute for the Mitigating Systems Cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, this issue relates to the availability and reliability examples of the equipment performance attribute because a latent failure mechanism was not evaluated. The inspectors evaluated the significance of this finding using Inspection Manual Chapter 0609, Appendix G, Attachment 1, Shutdown Operations Significance Determination Process Phase 1 Operational Checklists for Both PWRs and BWRs. The inspectors determined that Checklist 3 was applicable because the unit was in cold shutdown with the refueling cavity level less than 23 feet. Using Appendix G, Attachment 1, Checklist 3, Phase 2 analysis was not needed and the finding was of very low safety significance (Green) because the licensee was able to demonstrate that the seismically unqualified scaffolding would not have resulted in a loss of safety function. The inspectors determined the cause of the finding had a human performance aspect in the area of resources.

Specifically, Procedure AP 14A-003 was inadequate because it had conflicting guidance that allowed seismically unqualified scaffolds in Modes 5 and 6 H.2(c).

Mitigating Systems 10/25/2009 SAN ONOFRE Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status:, 05000361 (C)

Open: 2010002 (PIM) Failure to Perform an Adequate Postmaintenance Test A self-revealing Green noncited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified for failure of maintenance planning personnel to develop and specify an adequate postmaintenance test in the work instructions used to perform maintenance on the backup nitrogen regulator for the component cooling water surge tank. Specifically, on October, 25, 2009, Maintenance Order MO 800335873 did not specify postmaintenance testing instructions that would verify that nitrogen supply valve PCV 5403 would perform satisfactorily in service, following calibration, and properly control surge tank pressure during changes in surge tank levels. This issue was entered into the licensees corrective action program as Nuclear Notifications NNs 200766430 and 200887764. The finding is greater than minor because it is associated with the procedure quality attribute of the Mitigating Systems Cornerstone and affects the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Furthermore, the finding is similar to more than minor example 3.i in NRC Inspection Manual Chapter 0612, Appendix E, Examples of Minor Issues, in that, an extensive engineering evaluation was required to verify that the component cooling water system remained capable of performing its safety function during a design basis earthquake.

Using the Manual Chapter 0609, Appendix G, Shutdown Operations Significance Determination Process, Phase 1 guidance, the finding is determined to have very low safety significance because the finding did not result in an increase in the likelihood of a loss of reactor coolant system inventory, degrade the ability to add reactor coolant system inventory, or degrade the ability to recover decay heat removal. This finding has a crosscutting aspect in the area of human performance associated with work practices because maintenance planning personnel failed to follow procedures to develop adequate work instructions to perform maintenance on safety-related equipment H.4(b).

Mitigating Systems 12/31/2009 PRAIRIE ISLAND SL-IV

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status:, 05000306 (C)

Open: 2009005 (PIM) FAILURE TO PROVIDE COMPLETE AND ACCURATE INFORMATION FOR LER 05000306/2008-001-00 A NRC-identified issue and a NCV of 10 CFR 50.9 was identified when the inspectors discovered that Licensee Event Report (LER) 05000306/2008-001-00 was not complete and accurate in all material aspects. Specifically, the LER omitted information regarding when and how the licensee became aware that the Unit 2 component cooling water system was susceptible to failure following a postulated high energy line break in the turbine building. The omitted information was considered to be material to the NRC because it potentially affected the NRC's determination as to whether this issue would be characterized as an old design issue per Inspection Manual Chapter 0305. Subsequent to discovery of the deficiency, the licensee submitted Revision 1 to LER 05000306/2008-001 00, on January 19, 2009, which documented the originally omitted information. This issue was determined to be more than minor because it affected the NRCs ability to perform its regulatory function. As a result, this finding was evaluated with the traditional enforcement process. Using the information provided in IMC 0612, Appendix B, Issue Screening, this issue was determined to be a Severity Level IV NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy. This finding was determined to be cross cutting in the Human Performance, Work Control area, because the licensee failed to properly plan and coordinate work activities to address the impact of work on different job activities and the need for groups to communicate, coordinate, and cooperate with others during work activities (H.3(b)).

Mitigating Systems 01/25/2010 DIABLO CANYON SL-IV

• SCWE:

N

• HP:

N

• PIR:

Y Docket/Status:, 05000323 (C)

Open: 2009009 (PIM) Failure to Evaluate a Change to the Facility as Described in the Final Safety Report Update Associated with the Addition of Manual Actions in the Safety Analysis The inspection team identified a noncited violation of 10 CFR 50.59, which states that a licensee may make changes to the facility as described in the final safety analysis report without obtaining a license amendment if the change does not result in a departure from a method of evaluation described in the final safety analysis report used in establishing the design bases or in the safety analyses. This regulation further requires the licensee to include a written evaluation providing the basis for concluding that a license amendment is not required. On November 21, 2005, the licensee failed to provide a written evaluation concluding that a license amendment was not required for a change to the facility as described in the final safety analysis report. Specifically, the licensee identified a condition where large differential pressure across the residual heat removal suction containment sump valves could cause them to fail to open during certain small break loss of coolant accidents. On October 5, 2005, the licensee revised Emergency Operating Procedure E-1, Loss of Reactor or Secondary Coolant, to add an operator action to align component cooling water to the residual heat removal heat exchanger.

On June 16, 2009, the licensee again revised Emergency Operating Procedure E-1 to specify that operator action to align component cooling water within 30 minutes was a time critical operator action. The licensee did not evaluate either change to determine if prior NRC approval was required for the new manual actions. The licensee entered this issue into their corrective action program as Notification 50276288. The failure of the licensee to perform a 10 CFR 50.59 evaluation of a new manual action supporting the plants design basis was a performance deficiency within the licensees ability to foresee and correct. The inspectors evaluated this issue using the traditional enforcement process because the performance deficiency had the potential for impacting the NRCs ability to perform its regulatory function. The inspectors concluded that the issue was more than minor because of a reasonable likelihood that the change to the facility would require Commission review and approval prior to implementation.

The inspectors also evaluated the significance of this issue under the Significance Determination Process using Inspection Manual Chapter 0609.04, Phase 1 Initial Screening and Characterization of Findings. The inspectors concluded that the issue affected the Mitigating Systems Cornerstone and screened Green because the finding was a design or qualification deficiency confirmed not to result in loss of operability. The issue was classified as Severity Level IV because the violation of 10 CFR 50.59 involved conditions resulting in very low safety significance by the significance determination process. This finding had a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program component because the licensee did not thoroughly evaluate the change to the facility as described in the Final Safety Analysis Report Update to determine if prior NRC approval was required P.1(c).

Mitigating Systems 01/27/2010 SAN ONOFRE Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status:, 05000361 (C)

Open: 2010002 (PIM) Failure to Follow Operations Procedure to Monitor Component cooling water Surge Tank pressure A self-revealing noncited violation of Technical Specification 5.5.1.1 was identified for the failure of operations personnel to follow procedures for operating the component cooling water system.

Specifically, on January 27, 2010, operations personnel failed to follow the requirements of procedure SO123-2-17, Component cooling water System Operation, Revision 31, while performing a planned drain down of the component cooling water surge tanks. Operations personnel failed to maintain the surge tank pressure, in accordance with procedure SO23-2-17, such that, component cooling water surge tank pressure was permitted to go low out of the expected operating range. As a result of this low surge tank pressure, operators declared the component cooling water and shutdown cooling train A systems inoperable. This issue was entered into the licensees corrective action program as Nuclear Notification NN 200771367.

The finding is greater than minor because the continued failure to follow procedures when operating safety-related plant equipment, if left uncorrected, would have the potential to lead to a more significant safety concern. The finding is associated with the Mitigating Systems Cornerstone. Using the Manual Chapter 0609, Appendix G, Shutdown Operations Significance Determination Process, Phase 1 guidance, the finding is determined to have very low safety significance because the finding did not result in an increase in the likelihood of a loss of reactor coolant system inventory, degrade the ability to add reactor coolant system inventory, or degrade the ability to recover decay heat removal. This finding has a crosscutting aspect in the area of human performance associated with work practices because operations personnel failed to use proper human error prevention techniques and proceeded in the face of unexpected circumstances when operating the component cooling water system H.4(a).

Mitigating Systems 03/18/2010 SAN ONOFRE Green

• SCWE:

N

• HP:

N

• PIR:

N Docket/Status:, 05000361 (C)

Open: 2010003 (PIM) Failure to Assure Circuit Breakers Were Qualified for Installation A self-revealing noncited violation of 10 CFR Part 50, Appendix B, Criterion VII, Control of Purchased Material, Equipment, and Services, was identified for the failure of engineering personnel to assure that 4 kV vacuum circuit breakers supplied by NLI/Square D conformed to the procurement documents prior to installation in Unit 2 bus 2A06 train B. Specifically, on December 18, 2009, 4 kV bus 2A06 was restored to operable status following installation of 4 kV vacuum circuit breakers supplied by NLI/Square D that did not conform to the design requirements specified in the procurement documents. Engineering personnel failed to assure that 4 kV vacuum circuit breakers conformed to the requirements of Specification SO23-302-02A, 4kV Roll-in Replacement Circuit Breakers, Revision 1, and failed to identify that the vendor completed seismic qualification test deviated from the procurement specifications prior to installation in the plant. On March 18, 2010, an unexpected trip of component cooling water pump circuit breaker 2A0605 prompted an investigation that identified the design inadequacies.

Operations personnel declared the associated circuit breakers inoperable following identification of the design inadequacies. Immediate actions to eliminate the design inadequacies were completed to return 4 kV bus 2A06 to operable on March 25, 2010. Apparent Cause Evaluation ACE 200845084 was initiated to identify additional corrective actions. This issue was entered into the licensees corrective action program as Nuclear Notification NN 200842716. The performance deficiency is more than minor because it is associated with the design control attribute of the Mitigating Systems Cornerstone and affects the cornerstone objective to ensure the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences, and is therefore a finding. Using the Manual Chapter 0609, Appendix G, Shutdown Operations Significance Determination Process, Phase 1 guidance, the finding is determined to have very low safety significance because the finding did not result in an increase in the likelihood of a loss of reactor coolant system inventory, degrade the ability to add reactor coolant system inventory, or degrade the ability to recover decay heat removal.

Since the lack of questioning attitude that contributed to an overreliance on the specifications occurred in 2005, and Procurement Specification Training was conducted in 2008 to close an identified gap in specification review and implementation, the inspectors determined that this was not reflective of current performance and therefore did not have a crosscutting aspect associated with it.

Mitigating Systems 03/24/2010 CALLAWAY Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status: 05000483 (C)

Open: 2010002 (PIM) Failure to Follow Operability Determination Procedure The NRC identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, for failure to follow Procedure APA-ZZ-00500, Appendix 1, Operability and Functionality Determinations. The inspectors determined that the licensee failed to provide a reasonable expectation of operability for the degraded condition.

Specifically, the licensee failed to account for both auxiliary feedwater as an essential service water system load and fouling resistance in the component cooling water system heat exchanger. Long term corrective actions planned include a modification of the component cooling water heat exchangers divider plate during the upcoming April 2010 refueling outage.

The licensee placed this issue in their corrective action program as Callaway Action Request 201001152. This finding was determined to be greater than minor because it impacted the Mitigating Systems Cornerstone attribute of human performance and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Manual Chapter 0609.04, Phase 1 - Initial Screening and Characterization of Findings, this issue screened as very low safety significance because it was not a design or qualification deficiency that resulted in a loss of operability or functionality, did not create a loss of system safety function of a single train for greater than the technical specification allowed outage time and did not affect seismic, flooding, or severe weather initiating events. This finding has a crosscutting aspect in the area of human performance associated with the decision making component because the licensee failed to use conservative assumptions when performing operability evaluations H.1(b).

Mitigating Systems 03/24/2010 CALLAWAY Green

• SCWE:

N

• HP:

N

• PIR:

N Docket/Status: 05000483 (C)

Open: 2010002 (PIM) Failure to Ensure Suitable Replacement Parts Essential for the Operation of the Component cooling water System The NRC identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, after the licensee failed to adequately select suitable replacement gaskets essential to the operation of the component cooling water system heat exchangers. On October 19, 2008, Callaway engineering personnel identified that the component cooling water heat exchangers, due to corrosion and inadequate gasket sealing, had a small gap between the divider plate and channel head such that it allowed essential service water flow to bypass the heat exchanger which resulted in a reduced heat transfer capability. Corrective actions to address the identified gap in the component cooling water heat exchanger were scheduled to be implemented during the licensees next refueling outage. The licensee entered the issue in the corrective action program as Callaway Action Request 201001900. This finding was greater than minor because it was associated with the Mitigating Systems Cornerstone attribute of design control and affects the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Manual Chapter 0609.04, Phase 1 - Initial Screening and Characterization of Findings, this issue screened as very low safety significance because it was not a design or qualification deficiency that resulted in a loss of operability or functionality, did not create a loss of system safety function of a single train for greater than the technical specification allowed outage time and did not affect seismic, flooding, or severe weather initiating events. This finding was determined not to have a crosscutting aspect since it is a performance deficiency not reflective of current licensee performance.

Mitigating Systems 03/27/2010 DIABLO CANYON SL-IV

• SCWE:

N

• HP:

N

• PIR:

Y Docket/Status: 05000275 (C), 05000323 (C)

Open: 2010002 (PIM) Failure to Update the Final Safety Analysis Report with the Current Plant Design Bases The inspectors identified a noncited violation of 10 CFR 50.71 after Pacific Gas and Electric failed to update the Final Safety Analysis Report Update with the current design basis. The inspectors identified that the current Final Safety Analysis Report Update, Revision 18, Sections 3.1, 6.4, 6.5, and 9.4 did not capture the current design basis for the control room, component cooling water, and auxiliary feedwater systems. The failure of the licensee to provide current design basis information in the Final Safety Analysis Report Update had an adverse impact on the plant modification process, the licensees ability to assess operability for degraded plant systems, and the NRCs ability to ensure that regulatory requirements were met. The licensee entered this violation into the corrective action program as Notifications 50308588, 50306131, 5030799, and 50307476. The inspectors evaluated this violation using the traditional enforcement process because the issue affected the NRCs ability to perform its regulatory function. The inspectors concluded that the violation is more than minor because the incorrect Final Safety Analysis Report Update information had a potential impact on safety and licensed activities. The inspectors concluded the violation is Severity Level IV because the erroneous information was not used to make an unacceptable change to the facility or procedures that would have resulted in greater than very low safety significance under the Significance Determination Process. Because the violation included a performance deficiency, the inspectors also concluded the issue was a finding under the Reactor Oversight Process. The finding had a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program component because the licensee did not adequately evaluate the extent of condition of previous similar violations and take appropriate corrective actions

P.1(c).

Mitigating Systems 03/31/2010 BRAIDWOOD Green

• SCWE:

N

• HP:

N

• PIR:

Y Docket/Status:, 05000457 (C)

Open: 2010002 (PIM) FAILURE TO IDENTIFY A CONDITION ADVERSE TO QUALITY The NRC identified a finding of very low safety significance (Green) and an associated Non-Cited Violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to correct a Condition Adverse to Quality associated with the Unit 2A component cooling water heat exchanger. The licensees corrective actions included initiating a new work request to repair the degradation during the next refueling outage, and determining how the work requests could be closed despite being properly tied to the corrective action program. This performance deficiency was considered more than minor because it was similar to example 3(g) in Appendix E of Inspection Manual Chapter 0612, in that a Condition Adverse to Quality was not corrected and it recurred, such that the operability of a mitigating system component was potentially affected. Because there was no actual loss of operability or functionality of the 2A component cooling water heat exchanger, the issue screened out as having very low safety significance (Green). This finding is associated with the cross-cutting area component of corrective action program in the problem identification and resolution cross-cutting area.

Specifically, the licensee did not thoroughly evaluate why work requests to correct degradation of the 2A component cooling water heat exchanger were repeatedly cancelled with no actions taken and for unknown reasons (P.1(c)).

Mitigating Systems 03/31/2010 PRAIRIE ISLAND Green

• SCWE:

N

• HP:

N

• PIR:

Y Docket/Status: 05000282 (C)

Open: 2010002 (PIM) FAILURE TO HAVE ADEQUATE PROCEDURE FOR TESTING VALVE CC-5-2 A self-revealed finding of very low safety significance and a Non-Cited Violation of Technical Specification 5.4.1 were identified on January 27, 2010, when the licensee failed to establish an appropriate procedure for testing component cooling water pump return check valve CC-5-2. As a result, additional system inoperability and unavailability time were accumulated until the procedural inadequacies could be addressed and the procedure was performed successfully.

Corrective actions included revising the test procedures to incorporate an improved test method and re testing valve CC-5-2. The inspectors determined that this finding was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and impacted the cornerstone objective of ensuring the availability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to establish an appropriate test procedure resulted in an additional 34 hours3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br /> of system inoperability/unavailability. This finding was determined to be of very low safety significance because it was not a design deficiency, did not result in a loss of system safety function, was not an actual loss of safety function of one train of equipment for greater than the Technical Specification allowed outage time, and did not screen as a potentially significant seismic, flooding, or severe weather issue. The inspectors determined that this finding was cross-cutting in the Problem Identification and Resolution, Corrective Action area, because the licensee did not thoroughly evaluate a November 2009 problem with valve CC 5 2 such that the resolution addressed the cause and extent of the condition (P.1(c)).

Mitigating Systems 03/31/2010 TURKEY POINT Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status:, 05000251 (C)

Open: 2010002 (PIM) Failure to implement design controls in a temporary modification.

The inspectors identified an NCV of 10 CFR 50, Appendix B, Criterion III, Design Control, for failing to maintain control of temporary equipment installed on unit 4 A residual heat removal pump piping when the permanent component cooling water flow indication to the pump seal failed high. Operators were using a controlotron as a compensatory measure to verify adequate cooling flow to the unit 4A residual heat removal pump seal and to assure operability of the unit 4A residual heat removal pump. If the controlotron had failed, the operators would not have received a component cooling water low flow alarm in the control room, lack of cooling flow to the pump would have gone undetected, and operability of the residual heat removal pump could have been affected. The inspectors identified the licensee failed to follow the temporary system alteration procedure to ensure design adequacy and to determine if the alteration required a 10 Code of Federal Regulations (CFR) 50.59 evaluation and NRC approval. The licensee documented this in the corrective action program as condition report 2010-479. The finding is more than minor because it affected the configuration control attribute of the Mitigating Systems Cornerstone in that it reduced the reliability of the 4A residual heat removal pump with the permanent flow indicator out of service while using an unevaluated controlotron to determine continued operability of the 4A residual heat removal pump. The inspectors screened the finding using NRC Inspection Manual Chapter 0609, Significance Determination of Reactor Inspection Findings for At Power Operations, Phase 1 screening. The finding was of very low safety significance because the design or qualification deficiency did not result in actual loss of operability or functionality of the pump. The cross cutting aspect of Human Performance, Work Practices (H.4(b)) was affected (1R18).

Mitigating Systems 05/31/2010 SAN ONOFRE Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status:, 05000362 (C)

Open: 2010003 (PIM) Unavailability Time for Component cooling water Incorrectly Counted The inspectors identified a noncited violation of 10 CFR 50.65(a)(1) and 50.65(a)(2) for the failure of engineering personnel to demonstrate that the performance or condition of the Unit 3 component cooling water system had been effectively controlled through the performance of appropriate preventive maintenance and did not monitor against licensee-established goals.

Specifically, as of May 31, 2010, engineering personnel failed to identify and properly account for at least 47 hours5.439815e-4 days <br />0.0131 hours <br />7.771164e-5 weeks <br />1.78835e-5 months <br /> of component cooling water heat exchanger unavailability when considering whether the performance of the Unit 3 component cooling water train A had been effectively controlled through maintenance. These 47 hours5.439815e-4 days <br />0.0131 hours <br />7.771164e-5 weeks <br />1.78835e-5 months <br /> of unavailability, when combined with other train unavailability over the previous 12 months, demonstrate that the performance or condition of this structure, system, or component was not being effectively controlled through the performance of appropriate preventive maintenance and, as a result, that goal setting and monitoring was required. Licensee personnel initiated a notification to evaluate how component cooling water train unavailability is counted. This issue was entered into the licensees corrective action program as Nuclear Notification NN 200961310. The performance deficiency is more than minor because it affected the equipment performance attribute of the Mitigating Systems Cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and is therefore a finding. Using Manual Chapter 0609, Significance Determination Process, Phase 1 Worksheets, the finding is determined to have very low safety significance because the finding:

(1) is not a design or qualification deficiency confirmed not to result in a loss of operability or functionality; (2) did not represent an actual loss of safety function of the system or train; (3) did not result in the loss of one or more trains of non-technical specification equipment; and (4) did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. This finding has a crosscutting aspect in the area of human performance associated with the component of decision making because the engineering personnel failed to demonstrate that nuclear safety was an overriding priority through the use of conservative assumptions in decision making and adopting a requirement to demonstrate that a proposed action is safe in order to proceed rather than a requirement to demonstrate that it is unsafe in order to disapprove the action H.1(b).

Mitigating Systems 06/10/2010 DIABLO CANYON Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status:, 05000323 (C)

Open: 2010007 (PIM) Non-Conservative Decision Making resulted in a Violation of Technical Specification On March 10, 2010, the inspectors identified a noncited violation of Technical Specification 3.7.7, "Vital Component cooling water System," after both Unit 2 component cooling water loops were inoperable longer than permitted during power operations. On March 9, 2010, Pacific Gas and Electric identified that the degraded voltage protection scheme was inadequate to ensure minimum required voltage would be available to operating engineered safety feature pumps during a degraded offsite power grid. The licensee concluded that operating pumps could trip and lock out on over current before the protection scheme would automatically transfer power to the emergency diesel generators. The licensee declared the 230kV offsite power systems inoperable and took compensatory actions to enable the automatic transfer of busses with operating engineered safety feature pumps directly to the diesel generators following a unit trip.

On March 10, 2010, the inspectors identified that operating component cooling water pump 2-3 was still aligned to automatically transfer to 230kV offsite power source following a unit trip. The licensee had previously removed component cooling water pump 2-2 from service for maintenance on March 7, 2010. Technical Specification 3.7.7, "Vital Component cooling water System," required a minimum of two operable component cooling water pumps to establish operability of a vital component cooling water loop. Contrary to Technical Specification 3.7.7, on March 10, 2010, the licensee operated Unit 2 without an operable vital component cooling water loop for greater than 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />. The licensee has entered this issue into their corrective action program as Notification 50304802. Either the failure of Pacific Gas and Electric to restore at least two operable component cooling water pumps or to have placed Unit 2 in Mode 3 within six hours, as required by plant Technical Specification 3.7.7, was a performance deficiency.

The performance deficiency is more than minor because it is associated with the Mitigating Systems Cornerstone attribute of equipment performance, of ensuring the availability, reliability, and capability of safety systems that respond to initiating events to prevent undesirable consequences (i.e., core damage), and it was within the licencee's ability to correct this problem. The inspectors used Inspection Manual Chapter 0609, Appendix A, "Determining the Significance of Reactor Inspection Findings for At-Power Situations," to analyze the finding because the violation represents the actual loss of safety function for greater than the technical specification allowed outage time. The finding was of very low safety significance (Green) based on a bounding qualitative evaluation using Inspection Manual Chapter 0609, Appendix M, "Significance Determination Process Using Qualitative Criteria," The inspectors based this conclusion on the low probability of an actual degraded grid condition coincidental with an accident or anticipated operational occurrence during the 14-hour exposure that the vital component cooling water loops were unavailable due to the performance deficiency. The inspectors concluded that this finding had a crosscutting aspect in the area of human performance associated with the decision-making component because the licensee did not use conservative assumptions in their decision to implement compensatory actions following the inoperability of the degraded voltage protection scheme H.1(b).

Mitigating Systems 06/10/2010 DIABLO CANYON SL-IV

• SCWE:

N

• HP:

N

• PIR:

N Docket/Status:, 05000323 (C)

Open: 2010007 (PIM) Failure to Update Text to Reflect Credited Design Class I Makeup Flowpath to Component cooling water Expansion Tank in the Final Safety Analysis Report Update The team identified a Severity Level IV noncited violation of 10 CFR 50.71, Maintenance of records, making of reports. Title 10 CFR 50.71, paragraph (e) states, Each person licensed to operate a nuclear power reactor shall update periodically the final safety analysis report originally submitted as part of the application for the license, to assure that the information included in the report contains the latest information developed. In the Final Safety Analysis Report Update Table 9.2-7, Component 5, it states, This 250 gpm, Design Class I, makeup water flowpath, described under Makeup Provisions in Subsection 2.3.3 (Section 9.2.2.3.3), can be started within 10 minutes. Final Safety Analysis Report Update, Section 9.2.2.3.3 states, All piping and valves in the makeup path from the condensate storage tank (including their cross-connections) and the firewater tank, through the makeup water transfer pumps up to and including the makeup valves on the component cooling water system lines, are Design Class I.

Text later in the section implied that the flow path from the firewater tank was not Design Class I. Review by the licensee staff revealed that the only Design Class I flow path to provide makeup to the component cooling water expansion tank is via the condensate storage tank.

This revealed that the text provided in Final Safety Analysis Report Update, Section 9.2.2.3.3 stating that both the condensate storage tank and firewater tank makeup paths are credited is incorrect. Contrary to above, since 1984 (Final Safety Analysis Report Update, Revision 0), the licensee did not update Final Safety Analysis Report Update, Section 9.2.2.3.3 to correct the error of including firewater as a possible makeup path to the component cooling water expansion tank. The licensee has entered this issue into their corrective action process as Notification 50301884. Failure to periodically update the Final Safety Analysis Report Update with a known error is a performance deficiency. Using Inspection Manual Chapter 0612, Appendix B, the team determined that this performance deficiency was to be evaluated using the traditional enforcement process because the performance deficiency had the potential for impacting the NRCs ability to perform its regulatory function. Using General Statement of Policy and Procedure for NRC Enforcement Actions, Supplement I, Reactor Operations, dated January 14, 2005, to evaluate the significances of this violation, the team concluded that the violation is more than minor because the incorrect Final Safety Analysis Report Update information had a potential impact on safety and licensed activities. Using Supplement I, Section D, Item 6, of the NRC Enforcement Policy, this performance deficiency will be treated as a Severity Level IV violation. Because this violation is of very low safety significance and was entered into the licensees corrective action program, this violation is being treated as a noncited violation, consistent with Section VI.A.1 of the NRC Enforcement Policy. The team reviewed the finding for crosscutting aspects and none were identified.

Mitigating Systems 09/25/2010 DIABLO CANYON Green

• SCWE:

N

• HP:

N

• PIR:

Y Docket/Status: 05000275 (C), 05000323 (C)

Open: 2010004 (PIM) Failure to Identify a Degraded Fire Barrier The inspectors identified a noncited violation of the Diablo Canyon Facility Operating License Condition (5), Fire Protection, after Pacific Gas and Electric failed to maintain the integrity of a fire door in the rated configuration. On August 19, 2010, the inspectors identified that Fire Door 223 was inoperable. Fire Door 223 was required to provide a 3-hour rated barrier between Fire Areas 5-A-4 and 5-B-4. A fire in either of these areas could have prevented operation of the auxiliary feedwater, auxiliary saltwater, or component cooling water pumps or steam generator level control from the remote shutdown panel. Equipment Control Guideline 18.7, Fire Rated Assemblies, required the licensee to either maintain Fire Door 223 operable or implement compensatory actions within one hour. The inspectors concluded the most significant contributor to the finding was that licensee personnel did not identify and enter the degraded fire door into the Corrective Action Program. The licensee entered the performance deficiency associated with this finding into the corrective action program as Notification 50336901 and completed repairs to the door on August 23, 2010. The inspectors concluded that the performance deficiency was more than minor because the degraded fire barrier affected the mitigating systems cornerstone external factors attribute objective to prevent undesirable consequences due to fire. The inspectors determined that the inoperable door was a fire confinement category finding and that the fire barrier was moderately degraded because the door would not perform the rated fire barrier function. The inspectors concluded the finding was of very low safety significance because the degraded barrier would have provided a minimum of 20 minutes fire endurance protection and ignition sources and combustible materials were positioned that had a fire spread to secondary combustibles, the degraded barrier would not have been subject to direct flame impingement. This finding has a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program component because the licensee did not implement a low threshold for identifying and entering issues into the Corrective Action Program P.1(a).

Mitigating Systems 09/30/2010 SOUTH TEXAS PROJECT Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status:, 05000499 (C)

Open: 2010004 (PIM) Failure to Repair Essential Cooling Water System Leak within the Technical Specification Allowed Outage Time The inspectors identified a Green noncited violation of Technical Specification 3.7.4 because the licensee had one independent loop of essential cooling water inoperable for longer than the allowed outage time of 7 days. Specifically, on October 27, 2009, the licensee failed to initiate actions to evaluate and repair a through-wall leak in the 30-inch essential cooling water return line from the Unit 2 train C component cooling water heat exchanger, as required by American Society of Mechanical Engineers Boiler and Pressure Vessel Code, and in accordance with guidance contained in NRC Generic Letter 90-05, Guidance for Performing Temporary Non-Code Repair of ASME Code Class 1, 2, and 3 Piping. The inspectors questioned the licensees reportability review and determined there was firm evidence that the through-wall leak caused the Unit 2 train C essential cooling water system to be inoperable for a period of 11 days instead of 8 days as initially concluded by the licensee. The licensees corrective actions were:

(1) the leak was repaired, (2) a revised licensee event report was submitted, (3) training was provided to personnel performing these evaluations, and (4) procedures were updated to require that these types of evaluations must be performed. The finding was more than minor because the through-wall leak could have challenged the structural integrity of the piping and it was associated with the Mitigating Systems Cornerstone attribute of configuration control and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors performed the initial significance determination using NRC Inspection Manual 0609, Attachment 0609.04, dated January 10, 2008, Phase 1-Initial Screening and Characterization of Findings, because it affected the Mitigating Systems Cornerstone while the plant was at power, and determined a Phase 2 was required because it involved an actual loss of safety function of a single train. A Region IV senior reactor analyst performed a Phase 2 significance determination and found that the finding was potentially greater than Green. The senior reactor analyst then performed a bounding Phase 3 significance determination and found the finding to be of very low safety significance. The dominant core damage sequences included: seismic initiated loss of offsite power, failure of the essential cooling water train C, failure of the train A and B standby diesel generators, failure to recover offsite power and a standby diesel generator in 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, and an event initiated reactor coolant pump seal loss-of-coolant accident. Remaining mitigation equipment that helped to limit the significance of the finding included the remaining functional essential cooling water trains and the turbine-driven auxiliary feedwater pump. In addition, this finding had human performance crosscutting aspects associated with resources in that the licensee did not ensure that training of personnel about the requirements for properly characterizing Class 3 piping leaks was adequate to assure nuclear safety H.2(b).

Mitigating Systems 11/05/2010 PRAIRIE ISLAND SL-IV

• SCWE:

N

• HP:

N

• PIR:

N Docket/Status:, 05000306 (C)

Open: 2010012 (PIM) INADEQUATE 50.59 EVALUATION FOR NEW MANUAL OPERATOR ACTIONS.

A Severity Level IV NCV of 10 CFR 50.59(d)(1), Changes, Tests, and Experiments, was identified by the inspector for the licensees failure to provide an evaluation that adequately documented why implementing new manual operator actions during periods of adverse weather, which isolated portions of the component cooling water system susceptible to hazards associated with tornado-generated missiles, did not present a more than minimal increase in the likelihood of occurrence of a malfunction of a structure, system or component (SSC) important to safety previously evaluated in the updated safety analysis report (USAR). The licensee initiated CAP 1257118, 50.59 Screening Not Sufficient - 122 Spent Fuel Pool Heat Exchanger Component Cooling Loss, and, at the end of the inspection, was in the process of correcting the deficiency. The violation was determined to be more than minor because the inspector could not reasonably determine that the changes would not have ultimately required prior NRC approval. Violations of 10 CFR 50.59 are dispositioned using Traditional Enforcement process instead of the SDP because they are considered to be violations that could potentially impede or impact the regulatory process. However, if possible, the underlying technical issue is evaluated under the SDP to determine the severity of the violation. In this case, the inspector determined that the finding could be evaluated using the SDP in accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings, Tables 3b and 4a, for the Mitigating Systems Cornerstone. The inspector answered Yes to Question 5 under the Mitigating Systems Cornerstone column of the Phase 1 worksheet because the inspector concluded that the finding screened as potentially risk significant due to a severe weather initiating event. In addition, the ROP finding of very low safety significance, Green, is dispostioned separately from the Traditional Enforcement violation and, therefore, the finding is being assigned a separate tracking number. Although there is an additional tracking number, the cross-cutting aspect is assigned only once. (FIN 05000306/2010012 02; Failure to Adequately Evaluate New Manual Operator Actions)

Barrier Integrity 05/03/2006 DIABLO CANYON Green

• SCWE:

N

• HP:

N

• PIR:

N Docket/Status:, 05000323 (C)

Open: 2006003 (PIM) Failure to follow welding procedures An NRC-identified, non-cited violation of Technical Specification 5.4.1 was identified because Pacific Gas and Electric Company (PG&E) failed to follow the procedure for ensuring that welding preheat temperatures were verified prior to welding. Specifically, during the replacement of Component cooling water Valves 279 and 280, which provide cooling to the reactor vessel support pads, PG&E failed to verify that the minimum welding preheat temperature of 50°F was met and could not demonstrate that the ambient temperature was greater than 50°F. PG&E entered the finding into their corrective action program as Action Request A0665588. The finding was greater than minor because it was associated with the human performance attribute of the Barrier Integrity Cornerstone and impacted the cornerstone objective of providing reasonable assurance that physical design barriers, in this case the reactor coolant system, protect the public from radio-nuclide releases caused by accidents or events. The finding was determined to be of very low safety significance based on management review of the plant conditions at the time the performance deficiency occurred (defueled) and the condition was evaluated prior to the plant entering Mode 5.

Barrier Integrity 06/21/2008 GRAND GULF Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status: 05000416 (C)

Open: 2008003 (PIM) Failure to Follow Procedures Causing a Loss of Decay Heat Removal to the Spent Fuel Pool.

The inspectors identified a Green noncited violation of Technical Specification 5.4.1(a) involving the failure of operators to follow a safety-related off normal event procedure resulting in a loss of decay heat removal to the spent fuel pool. The operators elected to remove cooling to the fuel pool cooling heat exchangers to minimize the temperature rise on the component cooling water system during a partial loss of the plant service water system. This action was not specified in the off-normal event procedure. The off-normal event procedure only permitted the isolation of component cooling water flow to the fuel pool cooling heat exchangers for degraded component cooling water flow or pressure. This resulted in the spent fuel pool losing decay heat removal for approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and 22 minutes. The licensee entered this issue in their corrective action program as Condition Report CR-GGN-2008-02147. The finding is more than minor since it affects the human performance attribute of the barrier integrity cornerstone and affects the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Using the Manual Chapter 0609, Significance Determination Process, Phase 1 Worksheet, inspectors determined that the finding has very low safety significance (Green) since it did not preclude operators from restoring spent fuel pool cooling to ensure the Fuel Barrier Cornerstone. The cause of this finding has a crosscutting aspect in the area of human performance associated with decision making in that operators did not use a systematic decision making process when faced with unexpected plant conditions H.1(a).

Public Radiation Safety 06/17/2010 SAN ONOFRE Green

• SCWE:

N

• HP:

N

• PIR:

Y Docket/Status:, 05000361 (C), 05000362 (C)

Open: 2010006 (PIM) Failure to establish component cooling water radiation monitoring procedures.

The inspectors identified a noncited violation of Technical Specification 5.5.1.1.a, Scope, involving the failure to establish procedures for component cooling water system alignments such that leakage of radionuclides to the environment would be monitored during all operational alignments of component cooling water. Specifically, radiation monitors could be aligned to only one train of component cooling water at a time and the licensees procedures had no provision for monitoring the second train when both trains were in-service. This finding was entered into the licensees corrective action program as Nuclear Notification 200871387, and actions were implemented to require periodic grab sampling of the train which was not being monitored. The inspectors determined that this finding was more than minor because this issue impacted the Public Radiation Protection Cornerstone and its objective to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain as a result of routine civilian nuclear reactor operation. Specifically, the radiation monitors for component cooling water were not sufficient to ensure adequate release measurements. The inspectors evaluated the significance of this finding using Phase 1 of Inspection Manual Chapter 0609.04 and determined that the finding screened to Inspection Manual Chapter 0609, Appendix D, Public Radiation Safety Significance Determination Process. The inspectors evaluated the significance of this finding using Inspection Manual Chapter 0609, Appendix D, and determined that the finding was of very low safety significance (Green) because dose did not exceed Appendix I criteria. This finding was determined to have a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program in that the plant operators did not have a low threshold for identifying deficiencies in procedures.

P.1(c)

Miscellaneous 07/31/2009 ANO SL-IV

• SCWE:

N

• HP:

N

• PIR:

Y Docket/Status: 05000313 (C), 05000368 (C)

Open: 2009007 (PIM) Failure to Provide Accurate Information in Response to Generic Letter 2007-01, Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients SL-IV. The team identified a noncited violation of 10 CFR 50.9, Completeness and Accuracy of Information, which states in part that information required by statute or by the Commission's regulations, orders, or license conditions to be maintained by the applicant or the licensee shall be complete and accurate in all material respects. Contrary to the above, the licensees May 7, 2007, response to Generic Letter 2007-01, Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients, did not accurately describe the licensees programs, procedures, or practices for inspection, testing, and monitoring programs to detect the degradation of inaccessible or underground power cables that support emergency diesel generators, offsite power, essential service water, service water, component cooling water, and other systems that are in the scope of 10 CFR 50.65, The Maintenance Rule. The licensee asserted in their response to Generic Letter 2007-01, Question 2, that ANO inspection, testing, and monitoring practices presently include visual cable inspection during routine operations, periodic meggering of cables and connected equipment associated with maintenance activities, and periodic inspection of manholes for dewatering. In fact, there was no evidence that these manholes or cables had ever been periodically or routinely inspected for Unit-1, and none of the cables for either of the units were being routinely inspected as the licensee had asserted. The finding was more than minor because the information was material to the NRCs decision making processes. In accordance with Inspection Manual Chapter 0612, Power Reactor Inspection Reports, the violation was subject to the traditional enforcement process because 10 CFR 50.9 violations impact the NRCs ability to perform its regulatory function. Using the Enforcement Policy, Supplement VII, Miscellaneous Matters, the inspectors characterized the violation as a Severity Level IV violation because it did not meet the Severity Level I, II or III criteria. NRC management reviewed the finding and determined that it was of very low safety significance. Because the violation was of very low safety significance and was entered into the licensees corrective action program as Condition Report CR ANO C-2009-1415, this violation is being treated as a noncited violation, consistent with the NRC Enforcement Policy,Section VI.A. The inspectors determined that the finding has a crosscutting aspect in the area of problem identification and resolution in that the licensee failed to implement operating experience directly communicated with a generic letter through changes to station processes, procedures, and equipment P.2(b).

Violation Initiating Events 03/31/2009 WOLF CREEK Green

• SCWE:

N

• HP:

Y

• PIR:

N Docket/Status: 05000482 (O)

Open: 2009002 Discussed: 2009005 (PIM) Failure to correct component cooling water valve closures The inspectors identified a cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, involving Wolf Creeks failure to correct the cause of the reactor coolant pump thermal barrier component cooling water heat exchanger outlet valves stroking closed on high flow. Specifically, between 2001 and 2009, Wolf Creek experienced repeated cases of the reactor coolant pump thermal barrier component cooling water heat exchanger outlet valves stroking closed during component cooling water pump swaps and during isolations of the radioactive waste evaporators. Wolf Creek reinitiated evaluation of the issue after the inspectors questions but did not review the impact on the operators ability to open the valves given the valves circuit breakers opening. Repeated throttle valve adjustments have not been successful in stopping the valve closures. This issue and the corrective actions are being tracked by the licensee in Condition Report 2007 002074 and have corrective action pending to modify valve circuitry but it has not been implemented. The failure to correct a condition adverse to quality of ensuring reactor coolant pump seal cooling as described in the Updated Safety Analysis Report is a performance deficiency. The finding is more than minor because it is associated with the equipment performance attribute for the Initiating Events Cornerstone; and, it affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations.

The finding was determined to be of very low safety significance because the finding would not result in exceeding the Technical Specification limit for identified reactor coolant system leakage and would not have affected other mitigation systems resulting in a total loss of the seal cooling safety function. This finding is being cited because the licensee failed to establish measures to assure this condition adverse to quality was promptly identified and corrected. This finding has a crosscutting aspect in the area of human performance associated with the decision making component because, even though numerous instances of valve closures occurred since the first noncited violation, Wolf Creek downgraded the condition report. Using nonconservative assumptions, the licensee consistently viewed this issue as not having a risk impact because seal injection was not simultaneously lost. H.1.b]