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05000482/FIN-2018010-012018Q3Wolf CreekFailure to Follow ProceduresThe team identified two examples of a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for failure to follow procedures.
05000482/FIN-2018010-022018Q3Wolf CreekFailure to Establish an Adequate Procedure for Operator Time Critical Actions ValidationThe team identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for failure to have an adequate Procedure. Procedure AI 21-016, Operator Time Critical Actions Validation, Revision 14, Attachment B Time Sensitive Action List, does not have unique identifiers for cross referencing the records to the procedure.
05000482/FIN-2018010-032018Q3Wolf CreekFailure to Correct Reoccurring Problems with Time Critical/Sensitive Action ActivitiesThe team identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to correct reoccurring problems with completing Time Critical/Time Sensitive Action issues.
05000482/FIN-2018010-042018Q3Wolf CreekFailure to Identify 125 VDC Equalizing Voltage Exceeded Design RequirementsThe team identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the failure to verify or check the adequacy of design calculation NK-E-001, 125 Volt Direct-Current (VDC) Class 1E Battery System Sizing, Voltage Drop and Short Circuit Studies, Revision 4. The licensee failed to recognize that the actual 125 VDC Class 1E bus voltages had exceeded the maximum design limit voltages for downstream equipment identified in the calculation, and they had not placed any limits on voltages which could exceed the design limit of 140 VDC on the Class 1E System components.
05000482/FIN-2018010-052018Q3Wolf CreekLicensee-Identified ViolationThis violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy. Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, states, in part, Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected.Contrary to the above, prior to 2015, the licensee failed to promptly identify and correct a repetitive deficiency or non-conformance. Specifically, the licensee had identified a leaking flange on the residual heat removal heat exchanger since 1997. Prior to 1997 a different data base had been used to record boric acid leakage, and the data was not available during the inspection.Over the years since plant startup, the licensee had been diligent in completing boric acid evaluations on the leaking residual heat removal heat exchanger flange, indicating minimal wastage of the flange closure studs and nuts that had been subjected to boric acid. Corrective actions included cleaning up the boric acid leakage, and checking or re-torqueing the closure nuts. These measures did not correct the problem of the leaking heat exchanger flange. In 2015 the licensee completed an in-depth engineering evaluation of the leaking flange, including discussions with the heat exchanger manufacturer. New corrective measures included changing the torque values on the closure studs and nuts. The licensee is still evaluating the results of the corrective actions taken to preclude further leakage.
05000483/FIN-2017007-012017Q3CallawayNot Verifying the Operation and Timing of the Engineered Safety Feature Transformer XNB01 Load Tap ChangerThe team identified a Green, cited violation of Technical Specification 5.4.1.a which requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, Appendix A, Section 9, Procedures for Performing Maintenance, requires, in part, that maintenance that can affect the performance of safety-related equipment should be properly pre-planned and performed in accordance with documented instructions appropriate to the circumstances. Specifically, from May 2014 through August 4, 2017, as a result of ineffective corrective action of Callaway Action Requests CAR-201402827 and CAR-201405312, the licensee failed to performed preventative maintenance procedures to verify the operation and timing of the engineered safety feature transformer XNB01 load tap changer. This violation was previously identified by the NRC and documented as NCV 05000483/2014007-01. In accordance with Section 2.3.2.a of the NRC Enforcement Policy, this finding is being cited because the licensee failed to restore compliance within a reasonable amount of time after the violation was initially identified. This finding was entered into the licensees corrective action program as Condition Report CR-201703992, VIO 05000458/2017007-01, Not Verifying the Operation and Timing of the Engineered Safety Feature Transformer XNB01 Load Tap Changer. The team determined that the failure to implement maintenance procedures to periodically verify transformer XNB01 load tap changer operation and time testing was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failures to perform, periodic verification of the operation and time testing of the load tap changer could result in adverse operation of the load tap changer during a design basis event. If the load tap changer did not operate correctly, the safety-related buses may not have adequate voltage to reset the degraded voltage relay, thus spuriously disconnecting from the offsite power source. In accordance with Inspection Manual Chapter 0609, Appendix A, Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, Exhibit 2, Mitigating Systems Screening Questions, the issue screened as having very low safety significance (Green) because it was a design or qualification deficiency that did not represent a loss of operability or functionality; did not represent an actual loss of safety function of the system or train; did not result in the loss of one or more trains of non-technical specification equipment; and did not screen as potentially risk-significant due to seismic, flooding, or severe weather. The finding had a cross-cutting aspect in the area of human performance, work management, because the licensee failed to plan, control, and execute work activities such that nuclear safety is the overriding priority. Specifically, the licensee did not plan and execute the testing of the transformer XNB01 load tap changer in a timely manner (H.5).
05000483/FIN-2017007-022017Q3CallawaySafety Injection Piggyback Valve EJ-HV-8804A Valve Interlocks Not TestedThe team identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, which requires, in part, that a test program shall be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written procedures. Specifically, prior to August 3, 2017, the licensee failed to have a program to completely test the interlock circuit for safety injection pump and recirculation suction isolation valves, EJ-HV-8804A and EJ-HV-8804B. When the licensee personnel performed a review the interlock circuits for the valves, they identified that there had been gaps in the testing. In response to this issue, the licensee investigated all of the testing activities associated with the valve interlock circuits and identified that in 2010, a comprehensive test of the circuits had been performed as the result of a modification. The licensee has entered this issue into their corrective action program as Condition Report CR-201703962. The team determined that the failure to develop and implement testing programs for verifying that the circuits for the multiple interlocks associated with safety injection valve EJ-HV-8804A would perform as designed was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to establish a testing program to verify that the valve interlock circuits for valve EJ-HV-8804A were being tested. A failure of the interlocks and an operator error could result in an inadvertent release path to the environment. In accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, Exhibit 2, Mitigating Systems Screening Questions, the issue screened as having very low safety significance (Green) because it was a design or qualification deficiency that did not represent a loss of operability or functionality; did not represent an actual loss of safety function of the system or train; did not result in the loss of one or more trains of non-technical specification equipment; and did not screen as potentially risk-significant due to seismic, flooding, or severe weather. The team determined that this finding did not have a cross-cutting aspect because the most significant contributor did not reflect current licensee performance.
05000483/FIN-2017007-032017Q3CallawayInputs to Internal Flooding Calculations Not Translated into Procedures or InstructionsThe team identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, which requires, in part, that measures shall be established to assure that the design basis is correctly translated into procedures and instructions. Specifically, prior to on August 4, 2017, the licensee had design calculations that assumed operator actions to mitigate internal flooding of certain areas within specified time durations. These time requirements for the design basis flooding calculations had not been translated into any procedures or instructions. In response to this issue, the licensee performed a preliminary evaluation and determined that operator actions to support the design calculation could be performed within the time required. The licensee has entered this issue into their corrective action program as Condition Report CR-201703981. The team determined that the failure to translate operator time requirements for mitigating design basis flooding of critical areas into procedures or instructions was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to confirm that design basis inputs had been translated into procedures or instructions. In accordance with NRC Inspection Manual Chapter 0609, Appendix A, Exhibit 2, "Mitigating Systems Screening Questions," the issue screened as having very low safety significance (Green) because it was a design or qualification deficiency that did not represent a loss of operability or functionality; did not represent an actual loss of safety function of the system or train; and did not result in the loss of one or more trains of nontechnical specification equipment. The team determined that this finding did not have a cross-cutting aspect because the most significant contributor did not reflect current licensee performance.
05000483/FIN-2017007-042017Q3CallawayLicensee-Identified ViolationTechnical Specification 5.4.1.a requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Section 8 of Regulatory Guide 1.33, Revision 2, Appendix A, Procedures for Control of Measuring and Test Equipment and for Surveillance Tests, Procedures, and Calibrations, Part b, requires, in part, that specific procedures for surveillance tests, inspections, and calibrations, should be written (implementing procedures are required for each surveillance test, inspection, or calibration, listed in the technical specifications). Station Procedure EDP-ZZ-01114, Motor Operated Valve Program Guide, Revision 034, Section 3.6.3.b, requires, in part, that the motor-operated valve engineer document a signature analysis report within 60 days following a diagnostic test of motor operated valves. Contrary to the above, on July 17, 2016, the motor-operated valve engineer failed to generate a signature analysis report within 60 days following a recent diagnostic test of a motor-operated valve. Specifically, in May 2014, the NRC inspection team identified NCV 05000483/2014007-06, Failure to Review Motor Operated Valve (MOV) Data and Complete Analysis of the Data in a Timely Manner. This finding was entered into the licensee's corrective action program as Callaway Action Requests CARs 201402987 and 201402992. During Refueling Outage RF21 (spring of 2016), 33 motor operated valves had been tested and should have had a signature analysis report completed by the end of June 2016. On July 17, 2016, the licensee personnel recognized that they had not completed the signature analysis report for 31 of the 33 valves tested. The team evaluated the significance of the issue under the Significance Determination Process, as defined in Inspection Manual Chapter 0609.04, Initial Characterization of Findings, and 0609 Appendix A, The Significance Determination Process (SDP) for Findings at-Power, dated June 19, 2012. The team concluded the finding was of very low safety significance (Green) because all questions in Exhibit 2 could be answered no. The licensee entered this issue into their corrective action program as Condition Report CR-201606143.