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	Quarter	Site	Title	Description
05000293/FIN-2018003-01	2018Q3	Pilgrim	Failure to Identify an Adverse Condition Associated with Elevated Standby Gas Treatment System Accumulator Leakage	The inspectors identified a Green non-cited violation (NCV) of Technical Specifications 3.7.B.1.c because Entergy exceeded the TS allowed outage time for the standby gas treatment system (SBGT) when the station did not identify an adverse condition associated with elevated air accumulator leakage in the system.
05000293/FIN-2018002-02	2018Q2	Pilgrim	Loss of Secondary Containment Integrity due to Simultaneously Opened Airlock Doors	A self-revealed Green finding was identified when personnel did not implement a procedure requiring the closure and verification of doors credited with specific design functions. Procedure 1.3.135, Control of Doors, requires station personnel to ensure closing and latching of doors. Failure to meet this requirement caused the loss of secondary containment integrity and unplanned entry into Technical Specification (TS) condition 3.7.C.1.
05000293/FIN-2018002-01	2018Q2	Pilgrim	Failure to Properly Implement the Fatigue Management Program Work Hour Controls for Covered Workers	The inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) 26.205(d). During the period December 2017 to April 2018, Entergy did not properly control the work hours of several workers who performed work covered under 10 CFR 26.4(a). Specifically, on eleven occasions, workers exceeded one of the following work hour limits: (1) 16 work hours in any 24-hour period; (2) 72 hours in any 7-day period; or (3) 54 hours per week average over a 6-week rolling time period.
05000293/FIN-2018002-03	2018Q2	Pilgrim	480V Bus B6 Auto Transfer Function Degraded Due to Time Delay Relay Failure	The inspectors identified a Severity Level IV NCV of TS 3.5.A.2 because a component of the low pressure coolant injection system was inoperable between May 12, 2015, and May 3, 2017, during which time, on occasions, core spray systems were also not operable. Specifically, a relay, used to transfer the power feed for the low pressure coolant injection valves to the backup source in the event of a degraded voltage condition, failed during testing. As a result, under certain conditions, the transfer would not have automatically occurred. This condition existed through the operating cycle, during which time the core spray pumps were also inoperable when removed from service for scheduled maintenance.
05000333/FIN-2018002-01	2018Q2	FitzPatrick	Licensee-Identified Violation	This violation of very low safety significance was identified by Exelon and has been entered into Exelons CAP and is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy Violation: 10 CFR 71.5 requires that licensees who transport licensed material comply with the applicable requirements of the Department of Transportation (49 CFR). 49 CFR 172.202(a)(1) and (a)(2) require that the shipping description on the shipping paper include the proper shipping name and identification number for the material. 49 CFR 172.302(a) requires that shipments in bulk packages be marked with the identification number. Contrary to the above, on July 12, 2016, the shipping description on the shipping paper for shipment JAF-2016-1613 from FitzPatrick to Tennessee did not include the proper shipping name and identification number for the material. Exelon identified the error during a subsequent review of the shipping paperwork. Significance/Severity Level: No examples of transportation issues are presented in IMC 0612, Appendix E (Examples of Minor Issues). IMC 0609, Appendix D, Section VII.C.e.1 lists examples of Green findings that include documentation deficiencies including failure to properly document compliance with 49 CFR requirements such as shipping papers. Corrective Action Reference: Exelon placed this issue into its CAP as CR-JAF-2016-02857. Corrective actions included providing a corrected shipping paper to the facility in Tennessee that had received the package.
05000293/FIN-2018002-04	2018Q2	Pilgrim	Licensee-Identified Violation	This violation of very low safety significance was identified by the licensee and has been entered into the licensees corrective action program and is being treated as a NCV, consistent with Section 2.3.2 of the Enforcement Policy. Violation: 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be prescribed by documented instructions appropriate to the circumstances and shall be accomplished in accordance with the instructions. Contrary to the above, from January 1994 to June 2017, Entergy modified site surveillance procedure 8.M.3-18, Standby Gas Treatment System Exhaust Fan Logic Test and Instrument Calibration, without prescribing adequate documented instructions for the condition caused by the testing. Specifically, Entergy failed to identify that the procedurally prescribed lineup of the standby gas treatment system resulted in secondary containment being inoperable due to the large opening introduced into the system. Significance/Severity: The inspectors evaluated this finding using Inspection Manual Chapter 0609.04, Initial Characterization of Findings, and Inspection Manual Chapter 0609, Appendix A, Exhibit 3, Barrier Integrity Screening Questions. The inspectors determined that the finding was of very low safety significance. Corrective Action Reference: CR-PNP-2017-11714 The disposition of this violation closes Licensee Event Reports 05000293/2017-013-00 and 05000293/2017-013-01.
05000293/FIN-2018002-05	2018Q2	Pilgrim	Licensee-Identified Violation	This violation of very low safety significance was identified by the licensee and has been entered into the licensees corrective action program and is being treated as a NCV, consistent with Section 2.3.2 of the Enforcement Policy. Violation: 10 CFR 50.72(b)(3)(v)(C) requires licensees to a notify the NRC within 8 hours any event or condition that at the time of discovery could have prevented the fulfillment of the safety function of structures or systems that are needed to control the release of radioactive material. Contrary to the above, Entergy did not make a required notification pursuant to 10 CFR 50.72(b)(3)(v)(C). Specifically, on June 20, 2017, secondary containment was declared inoperable due to simultaneous opening of both airlock doors, and Entergy did not make the required notification until June 22, 2017. Significance/Severity: This violation is being treated under the NRCs traditional enforcement process, for impeding the regulatory process, specifically Entergy did not make a required notification, as outlined in Inspection Manual Chapter 0612, Appendix B. The Reactor Oversight Processs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using traditional enforcement to adequately deter non-compliance. The severity of this violation was determined to be Severity Level IV, as outlined in Example 9 from Section 6.9.d. of the NRC Enforcement Policy. Corrective Action References: CR-PNP-2017-06380 and CR-PNP-2017-07015 The disposition of this finding closes Licensee Event Report 2017-011-00.
05000293/FIN-2018002-06	2018Q2	Pilgrim	Minor Violation	This violation of minor significance was identified by the licensee and has been entered into the licensees corrective action program and is being treated as a minor violation, consistent with the NRC Enforcement Policy. On June 22, 2015, Entergy submitted a licensee event report in accordance with 10 CFR 50.73 that contained information that was not complete or accurate in all material respects, contrary to the requirements in 10 CFR 50.9. Specifically, the licensee submitted Licensee Event Report 2015-004-00 to communicate the failure during testing of time delay Agastat relay 27A-B1X/TDDO intended to provide under-voltage protection for 480V emergency bus B6 by transferring power from bus B1 to bus B2. In the licensee event report, Entergy incorrectly documented that due to the failure, bus B6 would have continued to receive power from bus B1 with degraded voltage. Upon identifying the issue, on March 8, 2016, Entergy submitted a revised licensee event report with the correct information. Enforcement: 10 CFR 50.9 requires that information provided to the Commission by a licensee shall be complete and accurate in all material respects. Contrary to the above, on June 22, 2015, Entergy provided information to the Commission that was not complete and accurate in all material respects. In the licensee event report, the licensee documented that due to the failure, bus B6 would have continued to receive power from bus B1 with degraded voltage. However, bus B6 would actually have tripped from bus B1 and lost power completely. This information was material to the NRC because the NRC requires timely and accurate reporting of information related to events in order to evaluate the potential safety significance and required NRC response. Entergy identified the inaccuracy and entered the issue into its corrective action program (CR-PNP-2015-9762). On March 8, 2016, Entergy submitted a revision to the licensee event report (2015-004-01) that corrected the report. This failure to comply with 10 CFR 50.9 constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy. The disposition of this violation closes Licensee Event Report 05000293/2015-004-01.
05000333/FIN-2017004-01	2017Q4	FitzPatrick	Inadequate Design Control for Battery Sizing Calculation	The inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion III, Design Control, because Exelon did not verify the adequacy of the low pressure coolant injection (LPCI) motor operated valve (MOV) independent power supply (IPS) with respect to the 419 volt direct current (VDC) battery sizing calculation. Specifically, non-conservative design inputs were used for the safety-related battery sizing calculation which reduced the battery capacity margin. On November 22, 2017, Exelon performed an operability determination for the identified issue and determined that the batteries had sufficient capacity. This issue was entered into the corrective action program (CAP) as issue report (IR) 4079452. The performance deficiency was determined to be 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, based on the quantity and magnitude of the errors, there was reasonable doubt that the LPCI MOV batteries would have adequate capacity under all design conditions. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, the finding was of very low safety significance (Green) because it was a design deficiency confirmed not to result in a loss of operability. This finding does not have a cross-cutting aspect because the calculation was last revised in 2003 so the finding is not indicative of current performance.
05000333/FIN-2017004-02	2017Q4	FitzPatrick	Human Error Resulting in Unplanned HPCI Isolation	A self-revealing NCV of very low safety significance (Green) of Technical Specification (TS) 5.4, Procedures, was identified for a procedural error which resulted in the inadvertent isolation of the high pressure coolant injection (HPCI) system. Specifically, on April 4, 2017, an instrumentation and controls (I&C) technician did not correctly perform procedure ISP-175B1, Reactor and Containment Cooling Instrument Functional Test/Calibration, which caused the HPCI system to isolate. Exelons immediate response to the event included stopping the surveillance test, and developing and implementing a plan to restore the HPCI system to an operable status. The HPCI system was subsequently restored to service approximately five hours after the inadvertent isolation. Additional corrective actions included increased observations of peer checks and validation of I&C activities. This issue was entered into the CAP as IR 03993791. This performance defficiency is more than minor because it is associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to correctly implement procedure ISP-175B1 caused an isolation of the HPCI system and rendered it unavailable to respond to an initiating event. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, the inspectors determined that this finding required a detailed risk evaluation since the HPCI isolation resulted in a loss of safety function. Using the Standardized Plant Assessment Risk Model (SPAR), the Region I senior reactor analyst (SRA) determined this finding was of low safety significance (Green). The inspectors determined that this finding had a cross-cutting aspect in the area of Human Performance, Avoid Complacency, because the I&C technician did not correctly implement error reduction tools and verify that the direct current voltage source was installed on the correct trip unit prior to performing the surveillance procedure. (H.12)
05000333/FIN-2017004-03	2017Q4	FitzPatrick	Licensee-Identified Violation	The following violation of very low safety significance (Green) was identified by Exelon and is a violation of NRC requirements, which meets the criteria of the NRC Enforcement Policy for being dispositioned as a NCV. 10 CFR 50.65(a)(4) states, in part, that before performing maintenance activities (including but not limited to surveillance, post-maintenance testing, and corrective and preventive maintenance), the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities. The scope of the assessment may be limited to structures, systems, and components that a risk-informed evaluation process has shown to be significant to public health and safety. Contrary to the above, on March 28, 2011, and April 16, 2015, before performing maintenance activities on the electric bay unit coolers, as discussed in Section 4OA2.4, Exelon did not assess and manage the increase in risk that resulted from the maintenance activities. This issue was documented in Condition Report JAF-2016-0838. In accordance with IMC 0609.04, Initial Characterization of Findings, and IMC 0609 Appendix K, Flowchart 2, Assessment of RMAs. The inspectors determined that the violation was of very low safety significance (Green) because the incremental core damage probability was less than 1E-5, with three risk management actions taken during the maintenance activities.
05000244/FIN-2017004-01	2017Q4	Ginna	Inadequate Component Monitoring Relating to Online Risk Management and Assessment	The inspectors identified a finding because Exelon personnel did not follow Procedure WC-AA-101-1006, On-Line Risk Management and Assessment, Revision 2 to sufficiently monitor components such that the latest information was used to evaluate plant risk. Specifically, on December 27, 2017, Exelon failed to sufficiently monitor the diesel driven air compressor, commensurate with its operating history, such that a failure would be assessed and updated in the current plant risk assessment. Exelon entered this issue into the corrective action program (CAP) for resolution as action request (AR) 0487519. Corrective actions included declaring the diesel driven air compressor non-functional, transitioned to Yellow online plant risk, and completed restoration of the C Instrument Air Compressor.This finding is more than minor because it is associated with the configuration control attribute of the Initiating Events cornerstone and adversely affected the associated cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Additionally, this issue is similar to Example 7.f of IMC 0612, Appendix E, Examples of Minor Issues, issued August 11, 2009, because the overall elevated plant risk placed the plant into a higher licensee-established risk category. The inspectors evaluated this finding using IMC 0609, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process, to determine the significance of the finding. The inspectors used Flowchart 2, Assessment of (risk management actions) RMAs, to analyze the finding and calculated the incremental large early release probability using PARAGON, Exelons risk assessment tool, and found the increase in incremental large early release probability was less than 1E-7. The inspectors determined that if this condition existed for the full duration of the maintenance period, the large early release probability would have been 2.22E-7. Because the increase in incremental large early release probability, was less than 1E-7, this finding was determined to be of very low safety significance (Green). This finding has a cross-cutting aspect in the area of Human Performance, Avoid Complacency, because Exelon did not recognize and plan for the possibility of mistakes, latent issues and inherent risk, even while expecting successful outcomes. Specifically, Exelon did not ensure a component used to manage and assess risk was monitored at a frequency commensurate with its past performance. (H.12)
05000220/FIN-2017001-02	2017Q1	Nine Mile Point	Failure to Identify and Correct a Non- Conforming Condition in Safety-Related UPSs	Green. The inspectors documented a self-revealing Green NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions, for the failure to identify and correct a non-conformance (an inadequate capacitor) in safety-related uninterruptable power supplies (UPSs) 162 and 172. Between 2008 and 2017, this non-conformance led to multiple component failures, loss of vital power supplies, plant transients, and in one case, loss of the emergency condenser safety function. Specifically, in 2003, during a preventative maintenance activity, NMPNS installed a commercially dedicated capacitor (part number C-805) that was not rated for the normal service temperature for the application. This resulted in chronic overheating, reduction of service life, and in seven cases failures (internal shorts of C-805) which resulted in the loss of the associated safety-related UPS. Upon identification, Exelon entered each failure into the CAP conducted an apparent cause evaluation (ACE) following the 2016 and 2017 failures, and developed corrective actions to replace the underrated capacitors. The performance deficiency was determined to be more than minor because it affected the equipment performance attribute of the Initiating Events Cornerstone and adversely affected the cornerstone objective of limiting the likelihood of events that upset plant stability and challenge the critical safety functions during shutdown as well as power operations. Specifically, the underrated capacitors failure resulted in the loss of a vital alternating current (AC) bus, a support system and in one case the unplanned loss of a safety function required to bring and maintain the plant in safe shutdown. In accordance with IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, a detailed risk assessment was required. Using the NMPNS Unit 1 Standardized Plant Analysis Risk (SPAR) Model Version: 8.21, model date January 28, 2010, a Region I senior reactor analyst ran a zero maintenance condition assessment with basic events for emergency condenser (EC) motor operated valve (MOV) 39-09R and EC MOV 39-10R, normally closed condensate return isolation valves, failed for a duration of one hour. The results were a CDP of 1.37E-08. The dominant risk sequences involved loss of feedwater and loss of offsite power. As a result, the finding is of very low safety significance (Green). The performance deficiency for this finding occurred in 2008. Because the performance deficiency occurred greater than 3 years ago and is not indicative of current performance based upon the corrective actions taken following the 2016 failure, there is no cross-cutting aspect assigned to this finding.
05000220/FIN-2017001-01	2017Q1	Nine Mile Point	Deficient Design Control of Outboard MSIV Pilot Valve Instrument Air Supply	Green. The inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion III, Design Control, for Exelons failure to correctly translate the design basis into the NMPNS Unit 1 instrument air system to ensure the Unit 1 outboard main steam isolation valves (MSIVs) were capable of performing their design function. Specifically, the NMPNS Unit 1 Updated Final Safety Analysis Report (UFSAR) states, Reliable operation of instrument air end users and in-line components is dependent on the filtration and removal of particulates greater than 40 microns. Additional filtration for various components exists where the 40 micron limit is not satisfactory. The MSIV pilot valves at Unit 1 have a tighter clearance than the 40 micron limit. However, contrary to the UFSAR, NMPNS did not install additional filtration upstream of the pilot valves. As a result, during a surveillance test conducted on December 10, 2016, foreign material in the instrument air system potentially contributed to the failure of an outboard MSIV. Exelons immediate corrective actions included entering this issue into its corrective action program (CAP) as issue report (IR) 03959732, performing an air purge of the instrument air system to remove foreign material from the system, and replacing the current style pilot valves with new style valves with larger clearances during the spring 2017 refueling outage. The performance deficiency was determined to be more than minor because it was associated with the design control attribute of the Barrier Integrity Cornerstone and adversely affected the cornerstone objective of providing reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents for events. Specifically, Exelon failed to install additional filtration in the instrument air system upstream of the outboard MSIV pilot valve in accordance with the Unit 1 UFSAR even though the internal clearance of the pilot valve was significantly less than the 40 micron particulate limit. Additionally, example 3.j from IMC 0612, Appendix E, Examples of Minor Issues, provides a similar scenario to this issue. Example 3.j details that a performance deficiency is more than minor if the error results in a condition where there is a reasonable doubt of the operability of a system or component. This performance deficiency is more than minor because without the additional filtration defined in the UFSAR there 4 existed a reasonable doubt of operability for the Unit 1 outboard MSIVs. The finding was evaluated in accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 3 of IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, and determined to be of very low safety significance (Green). The finding has a cross-cutting aspect in the area of Human Performance, Documentation, because Exelon failed to create and maintain complete, accurate, and up-to-date documentation pertaining to instrument air sampling for high particulate. Specifically, Exelon failed to develop and implement a surveillance testing program for the instrument air system that would alert personnel that particulate greater than 5 microns could jeopardize the operability of the outboard MSIVs. (H.7)
05000244/FIN-2017001-01	2017Q1	Ginna	Licensee-Identified Violation	The following violation of very low safety significance (Green) was identified by Exelon and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as a non- cited violation (NC V). Ginna TS Table 3.3.1- 1 requires the function of under frequency Bus 11A and 11B be tested to be greater than or equal to 57.5 hertz in accordance with surveillance requirement 3.3.1.10. Surveillance requirement 3.3.1.10 requires this testing to be completed in accordance with the Surveillance Frequency Control Program. The Surveillance Frequency Control Program requires the function of under frequency Bus 11A and 11B be tested every 24 months. Contrary to the above, on February 6, 2017, Ginna engineering personnel determined that the Bus 11A under frequency function had not been tested within the interval specified frequency ; the function had last been tested on May 1, 2014 . Upon identification, Exelon conducted a risk evaluation and completed the surveillance requirement at the next available opportunity i n accordance with surveillance requirement 3.0.3 for a missed surveillance. Exelon entered this issue into the CAP as AR 03970849 and completed the testing on March 11, 2017. Additional evaluation was required to demonstrate operability since the acceptance criteria of greater than or equal to 57.5 Hz was not met. The inspectors determined the finding was of very low safety significance (Green) in accordance with IMC 0609, Appendix A, The SDP for Findings at Power, Exhibit 1, Initiating Events Screening Questions, issued June 19, 2012, because the transient initiator did not cause a reactor trip and the loss of mitigating equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition.
05000317/FIN-2016004-01	2016Q4	Calvert Cliffs	Inadequate Inspection of Caulking, Seals, and Expansion Barriers in the Auxiliary Building	Green. The inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR), Appendix B, Criterion XVI, Corrective Action, for Exelons failure to identify conditions adverse to quality at CCNPP. Specifically, several safety related auxiliary building caulking, seals, expansion joints, and penetration barriers were found by the inspectors or revealed themselves by water intrusion events to be degraded. The inspectors determined that Exelons failure to identify degradation of several auxiliary building caulking, seals, and expansion joints was a performance deficiency that was reasonably within its ability to foresee and correct and should have been prevented. Exelons immediate corrective actions included performing operability determinations on degraded barriers, and repair of the degraded barriers. Exelon entered these issues into its corrective action program (CAP) as action request (AR) 02715188, AR 02715199, AR 02716543, AR 02725901, and AR 02564655. The inspectors reviewed IMC 0612, Appendix B, Issue Screening, issued on May 6, 2016, and determined the issue is more than minor because it adversely affected the Human Performance attribute, of the Auxiliary Building Area, of the Barrier integrity cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. The inspectors also reviewed IMC 0612, Appendix E, Examples of Minor Issues, and found it was sufficiently similar to Example 3.k, in that significant programmatic deficiencies were identified that could have led to worse outcomes. Specifically, several inspection programs designed to identify degraded barriers, caulking, seals, and expansion joints in safety related auxiliary building barriers, had not been performed, or had been performed inadequately. In accordance with IMC 0609, Attachment 4, Initial Characterization of Findings, issued on October 7, 2016, and IMC 0609, Appendix A, The Significance Determination Process for Findings at Power issued on June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) since, the only safety related degradation represented by the finding is of the radiological barrier function provided for the auxiliary building. The inspectors determined that the cause of the finding has a cross-cutting aspect in the area of Human Performance, Procedure Adherence, because Exelon did not complete the baseline inspection required by AMBD-0026 within the 10 years preceding entry of Units 1 and 2 into their respective periods of extended operation as specified in CNG-CM-6.01. Additionally, inspections conducted under AMBD-0052, and 0-013-49-O-18M were inadequate in that they failed to identify degradation of the barriers as described above. (H.8)
05000244/FIN-2016003-01	2016Q3	Ginna	Failure to Perform Drills Required by the Site Emergency Plan	The inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50.54(q)(2) for Exelons failure to maintain an emergency plan that meets the requirements in Appendix E, Content of Emergency Plans, to Part 50 and the planning standards of 50.47(b). Specifically, Exelon did not perform a drive-in augmentation drill during the required 3-year cycle nor did they perform a health physics drill semi-annually as required by Ginnas Emergency Plan Implementing Procedure EP-AA-122-100, Drill and Exercise Planning and Scheduling. Immediate corrective actions included entering this issue into their corrective action program (CAP). This finding is more than minor because it is associated with the emergency response organization (ERO) readiness attribute of the Emergency Preparedness cornerstone and adversely affected the cornerstone objective to ensure that Exelon is capable of maintaining adequate measures to protect the health and safety of the public in the event of a radiological emergency. In accordance with IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, Attachment 2, Failure to Comply Significance Logic, the inspectors determined that the performance deficiency affected planning standard 10 CFR 50.47(b)(14). The inspectors concluded that this performance deficiency matched an example on Table 5.14-1 Significance Examples 50.47(b)(14), for a Degraded Planning Standard Function. Specifically, two drills had not been conducted during a 2year (calendar) period in accordance with the emergency plan, thus constituting a degraded planning standard function which corresponds to a very low safety significance (Green) finding. The cause of the finding has a cross-cutting aspect in the area of Human Performance, Procedure Adherence, because Exelon did not schedule or plan for a drive-in augmentation drill or health physics drills in accordance with procedure EP-AA-122-100. (H.8)
05000317/FIN-2016003-01	2016Q3	Calvert Cliffs	Deficient Design Control of Air Pressure Available for Unit 1 Component Cooling Water Air Operated Valves	The inspectors identified a Green non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion III, Design Control, for Exelons failure to establish measures to assure that the design basis was correctly translated into specifications affecting safety related functions of air operated valves (AOV). Specifically, when implementing a design change, Exelon failed to verify the air pressure supplied to AOVs in the component cooling (CC) water system was adequate to ensure that the valves would have performed their safety function to close during certain specific accident conditions. The inspectors determined that Exelons failure to verify ECP-15-000213 ensured that air pressure supplied to safety related Unit 1 CC heat exchanger (HX) outlet AOVs was sufficient to support their safety function of closing during a design basis accident (DBA) was a performance deficiency that was reasonably within its ability to foresee and correct and should have been prevented. Exelons immediate corrective actions included conducting an engineering evaluation that demonstrated the operability of the CC system in the degraded condition and increasing the air pressure supplied to the CC HX outlet valves to ensure the valves are capable of fully closing during a DBA. Exelon entered this issue into its corrective action program (CAP) as action request (AR) 02680281. The inspectors reviewed IMC 0612, Appendix B, Issue Screening, and determined the issue is more than minor because it adversely affected the design control attribute of the Barrier Integrity cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. The inspectors also reviewed IMC 0612, Appendix E, Examples of Minor Issues, and found it was sufficiently similar to Example 3.j, in that the design analysis deficiency resulted in a condition where reasonable doubt existed regarding the operability of the Unit 1 CC HX outlet valves. In accordance with IMC 0609, Attachment 4, Initial Characterization of Findings, issued on June 19, 2012, and IMC 0609, Appendix A, The Significance Determination Process for Findings at Power, issued on June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) since, the finding did not involve an actual open pathway in the physical integrity of reactor containment. The inspectors determined that the cause of the finding has a cross-cutting aspect in the area of Human Performance, Documentation, because Exelons AOV program, as implemented by ER-AA-410, Air Operated Valve Implementing Program, Revision 2, did not require that complete, accurate, and up-to-date documentation on the CC HX outlet valves design be maintained. (H.7)
05000220/FIN-2016003-01	2016Q3	Nine Mile Point	Licensee-Identified Violation	10 CFR 50.54q(2) requires, in part, that the license holder shall follow and maintain the effectiveness of an emergency plan that meets the requirements in appendix E and, for nuclear power reactor licensees, the planning standards of 50.47(b). 10 CFR 50.47(b)(14) requires, in part, periodic exercises be conducted to evaluate major portions of emergency response capabilities and develop and maintain key skills. Exelon procedure EP-AA-122-100, Drills and Exercise Planning and Scheduling, Revision 6, implements this planning standard and requires health physics drills be performed every 6 months. Contrary to the above, from December 28, 2015 to July 15, 2016 Exelon failed to appropriately implement its approved emergency plan by not meeting planning standard 10 CFR 50.47(b)(14). Specifically, Exelon failed to conduct and document the performance of a required health physics drill for the second half of 2015 as required by step 4.4 of Exelon procedure EP-AA-122-100. This performance deficiency was determined to be more than minor because it impacted the Emergency Preparedness cornerstone objective of ERO readiness to ensure that Exelon is capable of implementing adequate measures to protect the health and safety of the public and its workers in the event of a radiological emergency. The finding was evaluated using IMC 0609 Appendix B, Emergency Preparedness Significance Determination Process. The finding was determined to affect planning standard 10 CFR 50.47(b)(14) and matched an example of a degraded planning standard function. Therefore, the finding was determined to be of very low safety significance (Green). Exelon has entered this issue into its CAP as IR 02686128.
05000244/FIN-2016002-01	2016Q2	Ginna	Incorrect Emergency Action Level Table	Exelon identified that they had inadvertently made a change to the Ginna Emergency Plan. The NRC determined that this error is a preliminary White finding under the Reactor Oversight Process and a violation of Title 10 of the Code of Federal Regulations (10 CFR) 50.54 (q)(2), Emergency Plans, because Exelon did not maintain the effectiveness of Ginnas Emergency Plan such that it met the requirements of Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, and the planning standards of 10 CFR 50.47(b). Specifically, Exelon implemented a revision to the emergency action level (EAL) table for the fission product barrier matrix that was incorrect with respect to the EAL threshold associated with potential loss of containment barrier. This could have resulted in an untimely declaration of a General Emergency or a failure to declare a Site Area Emergency during an actual event. Using IMC 0612, Appendix B, Issue Screening, the performance deficiency was determined to be more than minor because it impacted the procedure quality attribute of the Emergency Preparedness cornerstone and adversely affected the associated cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, Exelons EAL table was revised without adequate technical reviews resulting in a discrepancy between the EAL table and the EAL technical basis. The EAL wording of Table F-1 containment barrier potential loss, block C.6 did not meet the minimum required operable equipment in all situations and could have resulted in a delayed General Emergency declaration or a failure to declare a Site Area Emergency. The inspectors utilized IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process (SDP), to determine the significance of the performance deficiency. The performance deficiency is associated with the emergency classification system planning standard and is considered a risk-significant planning standard function. The inspectors were directed by the SDP to compare the performance deficiency with the examples in Section 5.4, 10 CFR 50.47 (b)(4), Emergency Classification System, to evaluate the significance of this performance deficiency. In accordance with Section 5.4, when an EAL has been rendered ineffective such that any General Emergency declaration would not be declared, but due to other EALs, an appropriate declaration would be made in a degraded manner or any Site Area Emergency would not be declared for a particular off-normal event, a degradation of risk-significant planning standard function (b)(4) is determined; and the finding is White. The finding has a cross-cutting aspect in the area of Human Performance, Change Management, because Exelon did not use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority. Specifically, Exelon did not maintain a clear focus on nuclear safety when implementing changes to the EALs resulting in a significant unintended consequence, the potential to make an untimely emergency declaration.
05000317/FIN-2016002-01	2016Q2	Calvert Cliffs	Scaffolding Impairs Fire Sprinkler Systems in Safety Related Fire Areas	The inspectors identified a Green, NCV of CCNPP Renewed Facility Operating License for Units One and Two, paragraph 2.E for Exelons failure to maintain in effect all provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report (UFSAR). Specifically, Exelon installed scaffolding in safety related areas not in accordance with approved procedures and, therefore, impaired fire sprinkler systems that were required by the approved fire protection program without establishing approved contingency measures. The inspectors determined that Exelons impairment of fire sprinkler systems by installing scaffolding with dimensions exceeding those approved in Exelon procedure MA-AA-716-025 was a performance deficiency that was within Exelons ability to foresee and prevent. The performance deficiency led to the violation of CCNPP Renewed Facility Operating License, paragraph 2.E, because Exelon failed to maintain in effect all provisions of the approved fire protection program. Exelons immediate corrective actions included stationing continuous fire watches and removal of the scaffolding deck boards which were impairing the fire sprinkler systems. Exelon entered these issues in to their corrective action program (CAP) as issue reports (IR): 02642463, 02642549, 02642844, 02644495, 02647104, 02647454, and 02647455. The inspectors reviewed IMC 0612, Appendix B, Issue Screening, and determined the issue is more than minor because it adversely 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. Specifically, Exelon installed scaffolding that exceeded the allowed dimensions in MA-AA-716-025 and impaired the function of fire sprinkler systems in areas containing safety related equipment. The inspectors evaluated the finding using IMC 0609, Attachment 4, Initial Characterization of Findings, issued on June 19, 2012, and IMC 0609, Appendix F, The Fire Protection SDP Worksheet issued on September 20, 2013 and determined the finding to be of very low safety significance (Green) because, in all cases of impairment, the fire sprinkler systems were still capable of protecting their intended targets or were still capable to suppress fires such that no additional equipment important to safety would have been affected. The inspectors determined that the finding had a cross-cutting aspect in the area of Human Performance, Procedure Adherence, because Exelon failed to properly implement procedure MA-AA-716-025, Scaffold Installation, Modification, and Removal Request Process, Revision 11, which limits scaffolding dimensions and locations when installing scaffolding in safety related areas. (H.8)
05000318/FIN-2016002-03	2016Q2	Calvert Cliffs	Failure to Implement Engineering Change Procedures Results in Plant Trip	The inspectors documented a self-revealing, Green finding for Exelons failure to implement procedures for engineering changes. Specifically, Exelon failed to address the full scope and critical parameters associated with a modification to a steam generator feed pump (SGFP). As a result, the 22 SGFP turbine pedestal studs were improperly torqued, resulting in the SGFP shifting, becoming misaligned, and eventually resulting in the failure of the turbine to pump coupling. This resulted in the unexpected tripping of the 22 SGFP on December 1, 2015, and operators inserting a manual reactor trip as required by procedure. The inspectors determined that Exelons failure to properly implement procedures CNG-CM-1.01-1003, Design Inputs and Change Impact Screen, Revision 00601, Attachment 12; CNG-CM-1.01-2000, Scoping and Identification of Critical Components, Revision 00201; and CNG-FES-007, Preparation of Design Inputs and Change Impact Screen, Revision 00010 was a performance deficiency that was a performance deficiency that was within Exelons ability to foresee and prevent. Exelons corrective actions included, replacing the failed coupling, verifying the torque on the 21 SGFP using a HYTORCTM, and developing an adverse condition monitoring plan for Unit 1s SGFPs. Exelon conducted a root cause evaluation (RCE) and developed corrective actions to preclude repetition (CAPR) including implementation of Exelon procedure HU-AA-1212, Technical Task Risk/Rigor Assessment, Pre-Job Brief, Independent Third Party Review, and Post-Job Review, Revision 007 and conducting critical parameters and rigor training for engineering personnel including the expectations for three pass reviews and verification of assumptions. The inspectors reviewed IMC 0612, Appendix B, Issue Screening, and IMC 0612, Appendix E, Examples of Minor Issues and determined the issue is more than minor because it was associated with the Design Control Attribute of the Initiating Events Cornerstone and adversely impacted the associated cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the performance deficiency resulted in a reactor trip from full power on December 1, 2015. The inspectors evaluated the finding using IMC 0609, Attachment 4, Initial Characterization of Findings, issued on June 19, 2012, and IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 1, Initiating Events Screening Questions, issued on June 19, 2012 and determined the finding to be of very low safety significance (Green) because the finding did not cause a reactor trip and the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. The inspectors determined that the finding had a cross-cutting aspect in the area of Human Performance, Documentation, because Exelon failed to develop and maintain complete and accurate engineering change packages (ECP), work orders (WO), and maintenance procedures.(H.7)
05000317/FIN-2016002-02	2016Q2	Calvert Cliffs	Failure to Report Conditions as Required by 10 CFR 50.73	The inspectors identified a Severity Level IV, NCV of 10 CFR 50.73(a)(2) for Exelons failure to report within 60 days of discovery, a condition that could have prevented the fulfillment of the safety function of the service water (SRW) system needed to mitigate the consequences of an accident. Additionally, Exelon failed to report within 60 days of discovery, a single condition that caused two trains of the SRW system, a system designed to mitigate the consequences of an accident, to become inoperable. Exelon entered the issue into their CAP as IR 02688409 and on July 20, 2016, submitted LER 05000317/2016-004-00, High Energy Line Break Barrier Breached Due to Human Performance Error Causing Both Service Water Trains to be Inoperable. The inspectors determined that Exelons failure to report a single condition that caused the inoperability of two trains of SRW and may have prevented SRW from fulfilling its design functions to mitigate the consequences of an accident within 60 days of discovering the condition was a violation of 10 CFR 50.73(a)(2), and could have impacted the regulatory process. The inspectors reviewed IMC 0612, Appendix B, Issue Screening, and the NRC Enforcement Policy, revised February 4, 2015, and determined the violation is of SL-IV because it is most similar to example 6.9.d.9 of the NRC Enforcement Policy, A licensee fails to make a report required by 10 CFR 50.72 or 10 CFR 50.73, which is a SL-IV violation. The inspectors determined that the violation did not have a cross-cutting aspect because it involved the traditional enforcement process only.
05000410/FIN-2016001-01	2016Q1	Nine Mile Point	Inadequate Procedure Leading to Failure to Manage Elevated Risk during Preventive Maintenance	The inspectors identified a non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 50.65(a)(4), Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, when Exelon did not assess and manage the increase in risk for online maintenance activities. Specifically on February 12, 2016, Exelon did not assess and manage risk during Unit 2 planned testing associated with the A residual heat removal (RHR) system heat exchanger (HX). The inspectors identified that although the testing would render the A RHR minimum flow valve 2RHSMOV4A unavailable, this was not considered as part of the planned maintenance window, which resulted in an increase in risk during the unavailability of 2RHSMOV4A. When properly calculated, plant risk should have been indicated as Yellow for the day and not Green. Exelon generated issue report (IR) 02625546 to document the inspectors concern regarding the status of the availability associated with the A RHR minimum flow valve during test setup for the A RHR HX. Exelon corrective actions included evaluating the risk management activities to be implemented when the minimum flow valves are subject to maintenance or testing activities to ensure future work is properly screened. This finding is more than minor because it is associated with the configuration control attribute of the Mitigating Systems cornerstone and adversely affected the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, Exelons failure to plan for the unavailability of the A RHR minimum flow valve resulted in Unit 2 being placed in an unplanned elevated risk category (i.e., Yellow) without ensuring adequate compensatory measures were established and briefed to ensure maximum availability, reliability, and capability of the system. This issue is similar to Example 7.f of IMC 0612, Appendix E, Examples of Minor Issues, because the overall elevated plant risk placed the plant into a higher licensee-established risk category. The inspectors evaluated the finding using Phase 1, Initial Screening and Characterization worksheet in Attachment 4 and IMC 0609, Significance Determination Process. For findings within the Initiating Events, Mitigating Systems, and Barrier Integrity cornerstones, Attachment 4, Table 3, Paragraph 5.C, directs that if the finding affects the licensees assessment and management of risk associated with performing maintenance activities under all plant operating or shutdown conditions in accordance with Baseline Inspection Procedure 71111.13, Maintenance Risk Assessment and Emergent Work Control, the inspectors shall use IMC 0609, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process, to determine the significance of the finding. The inspectors used Flowchart 1, Assessment of Risk Deficit, to analyze the finding and calculated incremental core damage probability using Equipment Out Of Service (EOOS), Exelons risk assessment tool. The inspectors determined that had this condition existed for the full duration of the Technical Specification (TS) limiting condition for operation (LCO), the incremental conditional core damage probability would have been 3.46E-9. Because the incremental core damage probability deficit was less than 1E-6 and the incremental large early release probability was less than 1E-7, this finding was determined to be of very low safety significance (Green). This finding has a cross-cutting aspect in the area of Human Performance, Work Management, because Exelon did not properly implement a process of planning, controlling, and executing the work activity such that nuclear safety was the overriding priority. Specifically, Exelon did not ensure risk was properly assessed during the planning process in accordance with WC-AA-101-1006, On-Line Risk Management and Assessment, Revision 001, prior to testing the A RHR HX, which caused unavailability of the A RHR minimum flow valve during certain periods of the test.
05000317/FIN-2016001-01	2016Q1	Calvert Cliffs	Issue of concern Regarding Characterization and Acceptance of a Relevant Indication in Pressurizer to Nozzle Dissimilar Metal Weld	An unresolved item (URI) was identified by the inspectors relating to an issue of concern involving Exelons acceptance and characterization of the relevant indication in weld 4-SR-1006-1 during prior refuel outages. Additional information is required to determine whether a performance deficiency, which is more than minor, exists. Description. Based on a review of Exelon letter dated February 25, 2016, the inspectors preliminarily concluded the relevant indication in weld 4-SR-1006-1 was incorrectly accepted during prior refuel outages and was not in conformance with ASME Code Section XI, Article IWA-3000. Additional inspection, including review of Exelons root cause analysis of this issue, is warranted to determine whether a performance deficiency, which is more than minor, exists related to characterization and acceptance of a relevant indication in weld 4-SR-1006-1. (URI 05000317/2016001-01, Issue of Concern Regarding Characterization and Acceptance of a Relevant Indication in Pressurizer to Nozzle Dissimilar Metal Weld)
05000244/FIN-2016001-01	2016Q1	Ginna	Licensee-Identified Violation	Title 10 CFR 50.54(q)(2) requires that a holder of a nuclear power reactor operating license under this part shall follow and maintain the effectiveness of an emergency plan that meets the requirements in Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities. Section IV.B.1 of 10 CFR 50, Appendix E, requires, in part, that the means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification and participation of State and local agencies, the Commission, and other Federal agencies, and the emergency action levels that are to be used for determining when and what type of protective measures should be considered within and outside the site boundary to protect health and safety. Contrary to the above, prior to January 7, 2016, Exelon procedure EP-AA-110-203, GNP Dose Assessment, Revision 003, did not consider the possibility of two different flow rate values through the plant vent. The plant vent has the capability to flow through filters when new fuel assemblies are added to the SFP resulting in the potential for two different flow rates out the ventone with the filters in service (69074 cubic feet per minute) and one without the filters in service (50560 cubic feet per minute). Due to the error, during certain events, Exelon would have inappropriately determined the event contaminant release rate to be higher than actual, resulting in the early declaration of an emergency action level. Upon identification, Exelon entered this into its CAP as AR 02609057 and implemented dose assessment compensatory measures to be used in EP-AA-110-203, Attachment 7, Ventilation Systems Flow Rates, table data. The inspectors determined the finding was of very low safety significance (Green) in accordance with Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, issued September 22, 2015, because a deficient emergency classification process which would result in an overclassification, but would not result in unnecessary public protective measures should be considered Green.
05000410/FIN-2016001-02	2016Q1	Nine Mile Point	50.65(a)(4) Risk Evaluation Not Properly Performed Prior to Residual Heat Removal Heat Exchanger Testing	The inspectors identified a Green non-cited (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 50.65(a)(4), Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, for Exelons failure to take risk management actions (RMAs) as required by procedure OP-AA-108-117, Protected Equipment Program, Revision 004, during a Unit 2, Division III, emergency switchgear electrical maintenance window on January 27, 2016. Specifically contrary to procedure OP-AA-108-117, during planned maintenance, Exelon failed to post the unit coolers in the A and B RHR pump and HX rooms, the C RHR pump room, and their associated breakers as protected equipment although their inoperability would have resulted in both trains of the standby gas treatment system (SBGT) being inoperable which would require entry into Technical Specification (TS) Limiting Condition for Operation (LCO) 3.0.3 and a short term shutdown action statement. Upon identification, Exelon generated IR 02617915 to document this issue. Corrective actions included creating an action item to evaluate Attachment 3 of N2-OP-52 and to determine the relevance of the TS LCO 3.0.3 entry requirement. The inspectors determined the performance deficiency to be more than minor because it was associated with the structure, system, and component (SSC) and barrier performance attribute of the Barrier Integrity cornerstone and adversely affected the associated cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, contrary to OP-AA-108-117, Exelon personnel failed to include the unit coolers for the Unit 2 RHR pump and HX rooms and their associated breakers, whose unavailability would have resulted in the inoperability of both trains of SBGT and necessitated entry into LCO 3.0.3. Additionally, Examples 7.e, 7.f, and 7.g from IMC 0612, Appendix E, Examples of Minor Issues, provided similar scenarios to this issue. Example 7.e details that a performance deficiency is more than minor if a failure to include accurate TS requirements in a risk assessment and if done properly, would have required RMAs, or additional RMAs under applicable plant procedures. The inspectors evaluated the finding using Phase 1, Initial Screening and Characterization worksheet in Attachment 4 to IMC 0609, Significance Determination Process. For findings within the Initiating Events, Mitigating Systems, and Barrier Integrity cornerstones, Attachment 4, Table 3, Paragraph 5.C, directs that if the finding affects the licensees assessment and management of risk associated with performing maintenance activities under all plant operating or shutdown conditions in accordance with Baseline Inspection Procedure 71111.13, Maintenance Risk Assessment and Emergent Work Control, the inspectors shall use IMC 0609, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process, to determine the significance of the finding. The inspectors used Flowchart 2, Assessment of RMAs, to analyze the finding and calculated incremental core damage probability using EOOS, Exelons risk assessment tool, and found the result to be less than 1E-6. The inspectors determined that had this condition existed for the full duration of the TS LCO, the incremental core damage probability would have been 6.8E-7. Because the incremental core damage probability deficit was less than 1E-6 and the incremental large early release probability was less than 1E-7, this finding was determined to be of very low safety significance (Green). This finding has a cross-cutting aspect in the area of Human Performance, Procedure Adherence, because Exelon failed to follow processes, procedures and work instructions. Specifically, Exelon failed to follow procedure OP-AA-108-117, which led to the failure to protect the unit coolers for the RHR pump rooms, HX rooms, and associated breakers which could have led to a TS LCO 3.0.3 entry.
05000410/FIN-2016001-04	2016Q1	Nine Mile Point	Licensee-Identified Violation	Eight-hour reports. If not reported under paragraphs (a), (b)(1), or (b)(2) of this section, the licensee shall notify the NRC as soon as practical and in all cases within eight hours of the occurrence of any of the following: (v) Any event or condition that at the time of discovery could have prevented the fulfillment of the safety function of structures or systems that are needed to: (C) Control the release of radioactive material. Contrary to the above, from April 2, 2014, until October 5, 2015, Exelon failed to submit an EN to the NRC within 8 hours upon discovery on a condition which could have prevented the safety function of a SSC needed to control the release of radioactivity on April 2, 2014, at 11:20 a.m. Specifically, secondary containment being declared inoperable due to both airlock doors being open at the same time in Mode 5 with an OPDRV in progress. The inspectors reviewed the violation using IMC 0612 Appendix B, Issue Screening, and the NRC Enforcement Policy. This violation impacted the regulatory process so traditional enforcement applies. Comparing this violation to the examples in the NRC Enforcement Policy Chapter 6, the violation matches Severity Level IV Example 6.9.d.9, a licensee fails to make a report required by 10 CFR 50.72 or 10 CFR 50.73. The NRC did not rely upon the information to make any regulatory decisions and the error did not result in increased scope or effort of NRC inspections. Compliance was restored when Exelon submitted LER 05000410/2014-007-01, Secondary Containment Inoperable due to Simultaneous Opening of Airlock Doors, to correct the public record and inform the NRC. Exelon staff entered the issue into its CAP.
05000220/FIN-2016001-03	2016Q1	Nine Mile Point	Inadequate Tagout Resulting in Reactor Building Closed-Loop Cooling Drain Down Event	A self-revealing Green non-cited violation (NCV) of Technical Specification (TS) 6.4.1, Procedures, was identified when a Unit 1 Exelon operator did not maintain proper configuration control of a plant system during a system tagout for planned maintenance. Specifically, on January 25, 2016, a Unit 1 non-licensed operator manipulated a reactor building closed-loop cooling (RBCLC) system drain valve out of sequence while performing a tagout for the #13 shutdown cooling (SDC) HX for planned maintenance. This resulted in unintentional draining of the operating RBCLC system, annunciation of multiple alarms in the main control room, and operators entering abnormal operating procedures to recover the RBCLC system. As part of corrective actions, proper configuration was promptly restored and the operator involved in the event was given a remediation plan for requalification and placed on an operations excellence plan. This finding is more than minor because it is associated with the configuration control attribute of the Mitigating Systems cornerstone and adversely affected the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences; and if left uncorrected, the event had potential to lead to a more significant safety concern. Specifically, the failure to quickly isolate the drain down of the RBCLC system would have required a manual reactor scram, a manual trip of all five reactor recirculation pumps (RRPs), a manual isolation of the reactor water cleanup system, a loss of cooling to the spent fuel pool (SFP) cooling system, instrument air compressors, and the control room emergency ventilation system. The inspectors evaluated the finding using IMC 0609.04, Initial Characterization of Findings, and Exhibit 1 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power. The inspectors determined that this finding was of very low safety significance (Green) because the performance deficiency did not result in the loss of a support system, RBCLC, or affect mitigation equipment. This finding has a cross-cutting aspect in the area of Human Performance, Procedure Adherence, because the non-licensed operator failed to follow Exelons procedures and the instructions he received at the pre job brief stop when manipulating the drain valve. Specifically, the non-licensed operator rationalized, without being the designated performer of the tagout, that it was acceptable to perform a valve manipulation out of sequence with the tagout plan.
05000410/FIN-2016001-05	2016Q1	Nine Mile Point	Licensee-Identified Violation	The holder of an operating license under this part shall submit a Licensee Event Report (LER) for any event of the type described in this paragraph within 60 days after the discovery of the event. (v) Any event or condition that could have prevented the fulfillment of the safety function of structures or systems that are needed to: (C) Control the release of radioactive material. Contrary to the above from June 2, 2014, until October 5, 2015, Exelon failed to submit an LER notification to the NRC within 60 days after discovery of a condition which could have prevented the safety function of a SSC needed to control the release of radioactivity on April 2, 2014 at 11:20 a.m. Specifically, secondary containment being declared inoperable due to both airlock doors being open at the same time in Mode 5 with an OPDRV in progress. The inspectors reviewed the violation using IMC 0612, Appendix B and the NRC Enforcement Policy. This violation impacted the regulatory process so traditional enforcement applies. Comparing this violation to the examples in the NRC Enforcement Policy Chapter 6, the violation matches Severity Level IV Example 6.9.d.9, a licensee fails to make a report required by 10 CFR 50.72 or 10 CFR 50.73. The NRC did not rely upon the information to make any regulatory decisions, and the error did not result in increased scope or effort of NRC inspections. Compliance was restored when Exelon submitted LER 05000410/2014-007-01 to correct the public record and inform the NRC. Exelon staff entered the issue into its CAP.
05000317/FIN-2015004-03	2015Q4	Calvert Cliffs	Licensee-Identified Violation	10 CFR 55.25 states, in part, that if an operator develops a permanent physical or mental condition that causes the operator to fail to meet the requirements of 10 CFR 55.21, the facility licensee shall notify the Commission within 30 days of learning of the diagnosis, in accordance with 10 CFR 50.74(c) which states that the regional administrator shall be notified if a licensed operator develops a permanent disability or illness. Contrary to these requirements, as the result of Exelons medical examination audit completed August 8, 2014, Exelon identified four cases in which a change in licensed operator medical conditions were not communicated to the NRC within the required 30 days. The results of the medical examination audit were documented in IR 2423780 and subsequent notifications were made to the NRC. This violation is subject to traditional enforcement because of the potential impact upon the regulatory process for issuing restrictions to operators licenses. The inspectors determined that this issue meets the criteria for a Severity Level IV violation using example 6.4.d.1(a) from the NRC Enforcement Policy because no incorrect regulatory decision was made as the result of the failure of the licensee to report within 30 days. This is of very low safety significance because after NRC review of the subsequent notifications, no changes to license restrictions were required.
05000317/FIN-2015004-01	2015Q4	Calvert Cliffs	Failure to Implement Procedures for the Control of Hazard Barriers During Maintenance	The inspectors identified a Green NCV of Technical Specification (TS) 5.4.1.a for Exelons failure to implement procedures as required by Regulatory Guide (RG) 1.33, Appendix A, Section 1, Administrative Procedures, during replacement of the 11 service water (SRW) pump motor, resulting in the SRW pump room door, a high energy line break (HELB) barrier, being impaired. This rendered the safety-related equipment protected by the HELB barrier inoperable. The inspectors determined that the failure to properly implement Exelon procedures EN-1-135, Control of Barriers, Revision 00202, and CC-AA- 201, Plant Barrier Control Program, Revision 11, was a performance deficiency that was reasonably within Exelons ability to foresee and prevent. Upon identification, Exelon staff entered this issue into their corrective action program (CAP) as issue report (IR) 2586773. Exelons immediate corrective actions included halting of impairing hazard barriers without considering the degraded barriers effect on equipment operability. The inspectors reviewed IMC 0612, Appendix B, Issue Screening, and determined the performance deficiency was more than minor because it adversely 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. Specifically, Exelons actions in blocking open the HELB barrier resulted in a condition where structures, systems, and components (SSCs) necessary to mitigate the effects of a HELB may not have functioned as required; therefore, the reliability of these protected SSCs was adversely impacted. In accordance with IMC 0609, Attachment 4, Initial Characterization of Findings, issued on June 19, 2012, and IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, issued on June 19, 2012, the inspectors determined that a detailed risk evaluation was necessary to disposition the significance of this finding because the finding represented a loss of the SRW system. A regional Senior Reactor Analyst (SRA) performed a detailed risk evaluation using an exposure interval of 10 minutes as the maximum time the condition was allowed in the plant. Using these inputs yielded an initiating event frequency of 4E-9/year. From discussions with the inspectors, the analyst confirmed a list of affected equipment. The analyst bounded the scenario by assuming all mitigating equipment would be lost which gave a maximum change in core damage frequency of 4E-9/year. Since the bounded change in core damage frequency was less than 1E-6, the finding was determined to be of very low safety significance (Green). The inspectors determined that the finding had a cross-cutting aspect in the area of Human Performance, Work Management, because Exelon did not implement a process of planning, controlling, and executing work activities such that nuclear safety was the overriding priority. Specifically, Exelons process for planning and controlling maintenance did not identify the applicability of Exelon procedure CC-AA-201.
05000317/FIN-2015004-02	2015Q4	Calvert Cliffs	AFAS Channel Inoperable due to Valve Misposition	The inspectors documented a self-revealing Green NCV of TS 5.4.1.a for Exelons failure to implement procedures as required by RG 1.33, Appendix A, Section 8, Procedures for Control of Metering and Testing Equipment and for Surveillance Tests, Procedures, and Calibrations, during maintenance which resulted in a manual isolation valve (1HVFW-1804) being incorrectly placed in the closed position. This human performance error isolated the number 12 steam generator (SG) wide range level transmitter (1LT1124C) and subsequently rendered the auxiliary feedwater actuation system (AFAS) sensor channel ZF inoperable for 33 hours and 39 minutes, a condition prohibited by TS 3.3.4, Engineered Safety Features Actuation System (ESFAS) Instrumentation. The inspectors determined that the failure to properly implement procedure STP M-525AT-1 and place 1HVFW-1804 in its required position was a performance deficiency that was reasonably within Exelons ability to foresee and prevent. Upon identification, Exelon staff entered this issue into their CAP as condition report (CR)-2014-003320. Exelons immediate corrective action was to enter TS 3.3.4.A, to determine and correct the cause, and to retest the system for proper operation. The inspectors reviewed IMC 0612, Appendix B, Issue Screening, and determined the issue is more than minor because it adversely affected the configuration control 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. Specifically, Exelon operated with manual isolation valve, 1HVFW-1804 closed which resulted in the inoperability of the AFAS sensor channel ZF for approximately 33 hours and 39 minutes. In accordance with IMC 0609, Attachment 4, Initial Characterization of Findings, issued on June 19, 2012, and IMC 0609, Appendix A, The Significance Determination Process for Findings at Power, Exhibit 2, Mitigating Systems Screening Questions, issued on June 19, 2012, the inspectors determined that a detailed risk evaluation was necessary to disposition the significance of this finding because the finding represented an actual loss of function of at least a single train of AFAS for greater than its TS allowed outage time. A regional SRA performed a detailed risk evaluation. The finding was determined to be of very low safety significance (Green) because the redundant AFAS sensor was operable and functional to ensure actuation of the system if it had been required, therefore there was no loss of the system function. Additionally, the unit was in Mode 3 with very low decay heat levels during the time the ZF sensor channel was determined to be inoperable and plant procedures exist to manually start the AFW system if failure of automatic actuation were to occur. The inspectors determined that the finding has a cross-cutting aspect in the area of Human Performance, Challenge the Unknown, because Exelon did not stop when faced with an uncertain condition about the position of 1HVFW- 1804. Specifically, personnel conducting the second verification did not appropriately question the position of isolation valve 1HVFW-1804 because of the higher experience level of the personnel conducting the first verification.
05000317/FIN-2015004-04	2015Q4	Calvert Cliffs	Licensee-Identified Violation	10 CFR 55.21 and 10 CFR 55.33 state, in part, that licensed operators are required to have a physical examination every two years to ensure that their medical condition and general health will not adversely affect the performance of assigned operator job duties or cause operational errors endangering public health and safety. As part of licensed operator medical evaluations, screening questions to identify potentially disqualifying medical conditions are required as specified in ANSI/ANS-3.4-1983, Medical Certification and Monitoring of Personnel Requiring Operator Licenses for Nuclear Power Plants. Contrary to this requirement, as a result of Exelons medical examination audit completed August 8, 2014, Exelon identified nine (9) licensed operators who were given an incomplete health questionnaire during their biennial medical examination. The questionnaire failed to request information about seven (7) potentially disqualifying health conditions from ANSI/ANS-3.4-1983 during a biennial medical examination. The omission of these seven potentially disqualifying conditions from the questionnaire resulted in an incomplete medical examination. Exelon identified that the cause was an incorrect revision to the sites medical examination process procedure. The revision issue was corrected in a subsequent revision and the audit documented that the nine licensed operators all completed medical evaluations with the correct screening questions within the next 18 months. The results of the medical examination audit were documented in IR 2423783. This violation is subject to traditional enforcement because of the potential impact upon regulatory process because the operators medical conditions are reviewed by the NRC when issuing or renewing operator licenses. The inspectors determined that this issue meets the criteria for a Severity Level IV violation using example 6.4.d.1(c) from the NRC Enforcement Policy because the operators who potentially did not meet ANSI/ANS-3.4, Section 5, due to an incomplete medical examination, subsequently were found to meet the health requirements for licensing. This is of very low safety significance because no incorrect regulatory decision was made as a result of the incomplete medical questionnaire and because no changes to license restrictions were required.
05000387/FIN-2015503-01	2015Q1	Susquehanna	Failure to Maintain a Standard EAL Scheme	The inspectors identified an apparent violation of Title 10 of the Code of Federal Regulations (10 CFR) 50.54(q)(2), which preliminarily has been determined to be of low to moderate safety significance (White). Specifically, 10 CFR 50.54(q)(2) requires a licensee to follow and maintain an emergency plan which meets the requirements of 10 CFR 50.47(b), and 10 CFR Part 50, Appendix E. Contrary to this requirement, as of June 20, 2012, PPL Susquehanna (PPL) failed to establish an effective Susquehanna Steam Electric Station (Susquehanna) Emergency Plan to ensure that a timely event declaration would be made for an unisolable primary system leak outside of primary containment. Specifically, PPLs interpretation of the 15-minute assessment and classification period degraded their ability to make timely Alert or Site Area Emergency declarations in certain cases. This potential delay in declaration of an Alert or Site Area Emergency could have impacted the ability of off-site response organizations to implement timely actions to protect the public during a radiological emergency. The inspectors determined the incorrect interpretation of the 15-minute assessment and declaration period was a performance deficiency that was within PPLs ability to foresee and correct and should have been prevented. Using IMC 0612, Appendix B, Issue Screening, the performance deficiency was determined to be more than minor because it was associated with the ERO performance attribute of the emergency preparedness (EP) Cornerstone and affected the cornerstone objective to ensure that the licensee was capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, the finding could impact the declaration timeliness of an emergency associated with a degraded fission product barrier. The inspectors utilized IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, to determine the significance of the finding. The finding is associated with the emergency classification planning standard and is considered a risk significant planning standard (RSPS) function. This finding impacts the following required RSPS function: 10 CFR 50.47(b)(4), Emergency Classification System. The inspectors utilized the SDP to compare the finding with the examples in Section 5.4, 10 CFR 50.47(b)(4), Emergency Classification System, to evaluate the significance of this finding. Using Table 5.4-1, Significance Examples 50.47(b)(4)," the inspectors determined that the finding matched an example of a degraded RSPS function, which would be assessed as White. Specifically, the example states that the finding would be assessed as White if the emergency action level (EAL) classification process is not capable of classifying a general emergency or a Site Area Emergency within 15-minutes or declaring the emergency promptly once the appropriate classification level is determined. The inspectors determined that the cross-cutting aspect that contributed most to the root cause is P.5, Operating Experience: The organization systematically and effectively collects, evaluates, and implements relevant internal and external operating experience in a timely manner. Specifically, PPL did not perform a thorough review of operating experience during and after implementing the new EP rule to ensure all Susquehanna EAL thresholds were being evaluated in accordance with the NRCs emergency declaration timeliness requirement in the regulation.
05000220/FIN-2014005-01	2014Q4	Nine Mile Point	Incomplete and Inaccurate Medical Information Provided by Exelon Which Impacted Issuance of Initial and Renewal Licenses	Exelon Generation Company, LLC (Exelon) identified two AVs: (1) An AV of Title 10 of the Code of Federal Regulations (10 CFR) 50.9, Completeness and Accuracy of Information; and (2) An AV of 10 CFR 50.74, Notification of Change in Operator or Senior Operator Status. Specifically, during an internal audit in July 2014, Exelon identified that between September 2002 and February 2012, NMPNS staff submitted certified copies of an NRC reactor operator and/or senior operator license applications for seven applicants that did not specify that the applicants required a restriction in order to maintain medical qualifications. The NRC issued the reactor operator and senior operator initial and renewed licenses for the seven applicants, but without the necessary medical restrictions (AV #1). From June 2002 through August 2014, Exelon had numerous additional opportunities to identify these potentially disqualifying medical conditions and that license conditions were required during the biennial licensed operator requalification program reviews and medical examinations. On September 25, 2014, a period that exceeded 30 days from when the conditions were identified, the facility notified the NRC of these medical conditions via a letter requesting amendment to the seven operators licenses to include the appropriate restrictions (AV #2). The NRC issued the license amendment with the new restrictions. The NRC inspectors also identified an additional example of both AVs which had not been reported by Exelon to the NRC in the September 25, 2014 letter. On November 5, 2014, Exelon requested termination of the license for that operator. This issue was entered into Exelons corrective action program (CAP) The inspectors determined that Exelons failure to provide complete and accurate information to the NRC in the reactor operator and senior operator license applications and to notify the NRC of a change in a reactor operator or senior operators status for a condition which was known by Exelon were performance deficiencies that were within their ability to foresee and correct and should have been prevented. The inspectors determined that traditional enforcement applies, as the issue affected the NRCs ability to perform its regulatory function. Namely, the NRC requires Exelon to ensure all licensed operators meet the medical conditions of their licenses. If, during the term of the individual operator license, an operator develops a permanent physical or mental disability that causes the operator to fail to meet the requirements of 10 CFR 55.21, Medical Examination, the licensee shall notify the NRC within 30 days of learning of the diagnosis, in accordance with 10 CFR 50.74(c). Additionally, the NRC issued reactor operator and senior operator licenses to the applicants based on information that was not complete and accurate in all material aspects. The performance deficiencies were screened against the Reactor Oversight Process per the guidance of IMC 0612, Appendix B, Issue Screening. No associated Reactor Oversight Process finding was identified and no cross-cutting aspect was assigned. These issues constitute AVs in accordance with the NRCs Enforcement Policy, and their final significance will be dispositioned in separate future correspondence. (Section 1R11)
05000317/FIN-2014404-02	2014Q4	Calvert Cliffs	Security
05000317/FIN-2014404-01	2014Q4	Calvert Cliffs	Security
05000272/FIN-2014404-01	2014Q2	Salem	Security
05000272/FIN-2014404-02	2014Q2	Salem	Security
05000317/FIN-2013403-01	2013Q2	Calvert Cliffs	Security
05000336/FIN-2012503-01	2012Q4	Millstone	Failure to Adequately lmplement Fuel Clad Barrier EALs	The NRC identified a non-cited violation (NCV) associated with emergency preparedness planning standard 10 CFR 50.47(b)(4), and the requirements of Sections lV.B and lV.C of Appendix E to 10 CFR Part 50. Specifically, Dominion did not maintain in effect the Millstone Units 2 and 3 emergency action level (EAL) schemes by not providing operations procedures for obtaining reactor coolant samples once a safety injection signal has occurred. These deficiencies adversely affected the ability of the licensee to properly classify events involving the loss of the fuel clad fission product barrier. The inspection team determined that the failure by Dominion to provide the proper operating procedures for operators to adequately implement their respective unit\\\'s EALs was a performance deficiency that was reasonably within their ability to foresee and prevent. The finding is more than minor because it is associated with the emergency response organization (ERO) attribute of the Emergency Preparedness Cornerstone and affected the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. The inspectors evaluated this finding using the Emergency Preparedness Significance Determination Process (Appendix B to IMC 0609) and determined the finding to be of very low safety significance (Green). Appendix B to IMC 0609, Section 5.4, and Table 5.4-1, were used to reach this determination. The inspector determined that this finding involved an example where an EAL has been rendered ineffective such that any Site Area Emergency would not be declared for a particular off-normal event, but because of other EALs, an appropriate declaration could be made in a degraded manner (e.9., delayed). The finding is related to the crosscutting area of Problem ldentification and Resolution, Corrective Action Program, in that Dominion personnel did not take appropriate corrective actions to address a Risk- Significant Planning Standard (RSPS) issue completely, accurately, and in a timely manner commensurate with the safety significance (P.1(d)). Specifically, Dominion did not place this issue into the corrective action program and take appropriate action until prompted by the NRC team\\\'s findings.
05000317/FIN-2012405-01	2012Q4	Calvert Cliffs	Security

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