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05000250/FIN-2013004-012013Q3Turkey PointInadequate Procedure to Vent 3B SGFP Results in AFW ActuationA self-revealing non-cited violation of Technical Specification 6.8.1, Procedures, was identified for the licensees failure to maintain an adequate procedure for venting the 3B steam generator feed pump (SGFP). Specifically, the licensee had failed to remove temporary instructions in Section 5.4 of procedure 3-NOP-074, Steam Generator Feedwater System, to jumper the contacts on the 3B SGFP breaker such that the breaker appeared open to the auxiliary feedwater (AFW) actuation logic, and as a result, AFW was inadvertently actuated and had to be secured by operators during a start of the 3B SGFP from the control room. The licensee entered the issue into the corrective action program as action request 1855704 and took corrective actions to revise 3-NOP-074 by removing the jumper installation steps from the procedure. The inspectors determined that the performance deficiency was more than minor because it was associated with the procedure quality attribute of the initiating events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during power operations. Specifically, the failure to remove the procedural instructions for installing a jumper in the 3B SGFP control circuit resulted in an inadvertent AFW actuation and required operators to take action to temporarily secure the ability of AFW to feed the steam generators. The inspectors determined the finding was of very low safety significance (Green) because the finding did not result in a reactor trip and a loss of mitigation equipment relied upon to transition the plant to a stable shutdown condition. The finding was associated with a cross-cutting aspect in the resources component of the human performance area because the licensee failed to ensure an accurate and up-to-date procedure was maintained for operation of the feedwater system (H.2(c)).
05000250/FIN-2013004-022013Q3Turkey PointFailure to Follow Procedure to Switch Running SGFPs Results in AFW ActuationA self-revealing non-cited violation of Technical Specification 6.8.1, Procedures, was identified for the licensees failure to implement Section 2.0 of procedure 3-NOP-074, Steam Generator Feedwater System, for starting the 3A steam generator feedwater pump (SGFP). Specifically, the licensee failed to implement 3-NOP-074 and ensure that a second condensate pump (CP) was running before starting a second SGFP which resulted in a loss of normal feedwater to the steam generators and an actuation of auxiliary feedwater (AFW). Operators took action to secure AFW flow to the steam generators to limit plant cool down and opened the reactor trip breakers to obtain additional reactivity shut down margin. Operators also took action to start the A standby steam generator feed pump (SBSGFP) to maintain level in the SGs and both trains of AFW were returned to operable standby status. The licensee entered the issue into their corrective program as action request 1856476. The inspectors determined that the performance deficiency was more than minor because it was associated with the human performance attribute of the initiating events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during power operations. Specifically, the failure to ensure that a second CP was running prior to starting 3A SGFP resulted in the trip of the running SGFP 3B and AFW actuation in response to the loss of normal feedwater supply. The inspectors determined the finding was of very low safety significance (Green) because the finding did not result in a reactor trip and a loss of mitigation equipment relied upon to transition the plant to a stable shutdown condition. The finding was associated with a cross-cutting aspect in the work practices component of the human performance area because the licensee failed to ensure proper supervisory oversight of work activities related to nuclear safety and prevent the loss of running SGFPs (H.4(c)).
05000250/FIN-2013004-032013Q3Turkey PointFailure to Provide Adequate Instructions during Maintenance on the Gland Seal Steam SystemA self-revealing finding was identified due to the licensees failure to provide adequate work instructions for throttling the Unit 3 gland seal steam bypass valve. As a result of the licensees inadequate work instructions, an operator opened the spill bypass valve on the gland seal steam system until system steam pressure dropped and allowed air in-leakage through the turbine gland seals. This resulted in a reactor trip and the main condenser was unavailable for reactor decay heat removal until vacuum could be restored. The licensee entered this issue into their corrective action program as action request 1847369 and revised the system operating procedure to address operation of the bypass line around the spillover control valve. The inspectors determined the performance deficiency was more than minor because it was associated with the configuration control attribute of the initiating events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during power operations. Specifically, the failure to provide adequate work instructions for the operation of the gland seal steam spillover bypass valve resulted in a reactor trip with the main condenser unavailable for reactor decay heat removal until vacuum could be restored. The inspectors screened the finding and determined that the finding was a transient initiator contributor which required a detailed risk analysis because the finding resulted in a reactor trip with a loss of condenser vacuum. A bounding analysis was performed by a regional Senior Reactor Analyst who concluded that the finding resulted in an increase in core damage frequency of less than 1E-6/year and, therefore, was a Green finding of very low safety significance. The finding was associated with a cross-cutting aspect in the work control component of the human performance area because the licensee did not adequately incorporate the need for planned contingencies, compensatory actions or abort criteria to ensure that throttling the gland seal steam spillover bypass valve would not result in a reactor trip and loss of the main condenser (H.3(a)).
05000250/FIN-2013004-042013Q3Turkey PointPower Operated Relief Valve Inoperable for Greater Than Allowed Outage Time Due to Lifted LeadsA self-revealing non-cited violation of the limiting condition for operation specified by Unit 4 Technical Specification (TS) 3.4.9.3, Overpressure Mitigating System, was identified due to the inoperability of a reactor coolant system (RCS) power-operated relief valve (PORV) for longer than the TS allowed outage time (AOT) of 24 hours. Specifically, the licensee failed to control the wiring configuration of the pressure comparator circuit for PORV PCV-4-456 and, as a result, the PORV would not have automatically responded to an overpressure event. The licensee corrected the wiring configuration error upon discovery and entered this issue into the corrective action program as action request 1868533. The inspectors determined the performance deficiency was more than minor because it was associated with the equipment performance attribute of the mitigating systems cornerstone and adversely impacted the objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to control the wiring configuration of PCV-4-456 resulted in the PORV being unable to automatically respond to an RCS overpressure event. The inspectors assessed the finding in the mitigating systems cornerstone and evaluated the significance using Manual Chapter 0609, Appendix G, Shutdown Operations Significance Determination Process. The inspectors determined that the finding required a detailed risk assessment because it was associated with a non-compliance with low temperature overpressure (LTOP) Technical Specifications. A Senior Reactor Analyst in NRC headquarters determined that the risk significance of the issue was very low (i.e., Green). The dominant accident sequence was an over-pressurization event caused by the pressurizer heaters, where the remaining PORV fails resulting in a through wall crack of the reactor coolant system. This finding was associated with a cross-cutting aspect in the work practices component of the human performance area because the licensee had not effectively communicated expectations regarding procedural compliance, and as a result, personnel did not implement procedural requirements to maintain plant configuration using wiring lift and land sheets; causing leads that affected the operability of PORV PCV-4-456 to not be re-landed (H.4(b)).
05000250/FIN-2013004-052013Q3Turkey PointSafety Injection Flow Path Not Isolated Due to Manual Valve Out of PositionThe inspectors identified a self-revealing non-cited violation of the limiting condition for operation specified by Unit 3 Technical Specification (TS) 3.4.9.3, Overpressure Mitigating Systems, which occurred as a result of the licensees failure to locally verify the closed position of manual valve 3-990 in accordance with OP-AA-100-1000, Conduct of Operations. The licensees failure to locally verify the closed position of manual valve 3-990 resulted in an unisolated high pressure safety injection flow path to the RCS for eight hours and 40 minutes which was greater than the TS 3.4.9.3 allowed outage time of four hours. Compliance with the TS was restored when the licensee isolated the flow path at the completion of in-service testing on February 28, 2013. Additionally, the licensee took corrective actions to fix the reach rod assembly and revised the procedures for verifying valve position and work order planning. The issue was entered into the licensees corrective action program as action request 1852222. The performance deficiency was more than minor because it was associated with the configuration control attribute of the initiating events cornerstone and adversely impacted the cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown operations. Specifically, the performance deficiency resulted in an open high pressure flow path to the reactor coolant system that degraded the overpressure mitigating systems ability to prevent a low temperature overpressure (LTOP) event. The inspectors assessed the finding using the initiating events cornerstone and evaluated the significance of the finding using Appendix G, Shutdown Operations Significance Determination Process, of Manual Chapter 0609. The inspectors determined that the finding required a detailed risk assessment because it was associated with a non-compliance with an LTOP technical specification. A Senior Reactor Analyst in NRC headquarters determined that the risk significance of the issue was very low (i.e., Green). The dominant accident sequence was an over-pressurization event caused by an inadvertent safety injection actuation, where the power-operated relief valves fail resulting in a through wall crack of the reactor coolant system. The finding was associated with a cross-cutting aspect in the resources component of the human performance area because the licensee failed to ensure that the work package contained adequate instructions for installation of roll pins instead of set screws in the reach rod assembly for valve 3-990 (H.2(c)).
05000285/FIN-2013008-382013Q2Fort CalhounDeficient Evaluation for Known Degraded Conditions - AFW Pumps Discharge Check Valve Leakage and Potential Overpressure of AFW Pump Suction PipingThe team identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, associated with the licensees failure to properly evaluate a known degraded condition regarding the auxiliary feedwater pump discharge check valve leakage and potential over-pressurization of the pumps suction piping. Specifically, from October 10, 2012, to March 15, 2013, the licensee failed to properly evaluate concerns regarding the auxiliary feedwater pump discharge check valves which resulted in the failure to implement adequate corrective actions to verify leak tightness of the check valves and prevent potential over pressurization of the pumps suction piping. This issue has been entered into the corrective action program as Condition Reports CR 2013-04806 and CR 2013-05018. This performance deficiency is more than minor, and therefore a finding, because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affected the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, the finding is determined to have very low safety significance (Green) because it: (1) was not a deficiency affecting the design or qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time; (4) did not represent an actual loss of function of one or more nontechnical specification trains of equipment designated as high safety-significance in accordance with the licensees maintenance rule program; and (5) did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding or severe weather event. This finding has a cross-cutting aspect in the area of human performance associated with the decision-making component because the licensee failed to use conservative assumptions in decision-making and adopt a requirement to demonstrate that the proposed action is safe in order to proceed rather than a requirement to demonstrate it is unsafe in order to disapprove the action
05000285/FIN-2013008-242013Q2Fort CalhounFailure to Effectively Monitor the Performance of Penetration SealsThe team identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to promptly identify and correct conditions adverse to quality. Specifically, between July 2012 and March 2013, the team identified 6 instances where the licensee failed to identify a deficiency or a condition adverse to quality and to enter them into the corrective action program. As a result, conditions adverse to quality may not be corrected in a timely manner commensurate with the safety significance. This issue has been entered into the corrective action program as Condition Report CR 2013-07959. This performance deficiency is more than minor, and therefore a finding, because if left uncorrected it has the potential to lead to a more significant safety concern. Specifically, the failure to identify conditions adverse to quality and enter them into the corrective action program, has the potential to lead to a failure to correct conditions adverse to quality in a timely manner commensurate with the safety significance. This finding was associated with the Mitigating Systems Cornerstone. The team determined that the finding could be evaluated using the significance determination process in accordance with IMC 0609, Significance Determination Process, and conducted a Phase 1 characterization and initial screening. Using Phase 1, Table 3, SDP Appendix Router, the team answered yes to the following question: Does the finding pertain to operations, and event, or a degraded condition while the plant was shutdown? As a result, the team used IMC 0609 Appendix G, Shutdown Operations Significance Determination Process. Using Appendix G, the finding is determined to have very low safety significance (Green) since it did not need a quantitative assessment. This finding has a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action program component because the licensee did not implement a corrective action program with a low threshold for identifying issues and did not identify issues completely, accurately, and in a timely manner commensurate with their safety significance
05000285/FIN-2013008-252013Q2Fort CalhounDeficient Evaluation for Known Degraded Conditions: SAFETY-RELATED Air Operated Valve Elastomers Not Qualified for Helb/Loca TemeraturesThe team identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, associated with the licensee\'s failure to properly evaluate a known degraded condition regarding safety-related air operated valve elastomers that were not qualified for high energy line break or loss of coolant accident temperatures. Specifically, from January 11 through January 18, 2013, due to a an improper application of the single failure criteria, the licensee failed to properly evaluate and correct a known degraded condition associated with safety-related air operated valve elastomers that were not qualified for high energy line break or loss of coolant accident temperatures. This issue has been entered into the corrective action program as Condition Reports CR 2013-01396 and CR 2013-02611. This performance deficiency is more than minor, and therefore a finding, because if left uncorrected, the failure to correct the degraded condition had the potential to lead to a more significant safety concern. Specifically, the affected air operated valves would have been in a condition where they would not have been qualified to perform their intended safety function. This issue was associated with the Mitigating Systems Cornerstone. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, the finding is determined to have very low safety significance (Green) because it: (1) was not a deficiency affecting the design or qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time; (4) did not represent an actual loss of function of one or more nontechnical specification trains of equipment designated as high safety-significance in accordance with the licensees maintenance rule program; and (5) did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding or severe weather event. This finding has a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action program component because the licensee failed to thoroughly evaluate problems such that the resolutions address the causes
05000285/FIN-2013008-262013Q2Fort CalhounFailure to Properly Inspect, Maintain, and Test Emergency Feedwater Tank EquipmentThe team identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, associated with the licensees failure to ensure proper inspection, maintenance, and testing of equipment associated with emergency feedwater tank FW-19. Specifically, from initial construction until February 27, 2013, the licensee failed to ensure proper inspection, maintenance, and testing was performed on the emergency feedwater storage tanks sight glass ball check isolation valves, to prevent draining of the tank following failure of the sight glass. The licensee performed an analysis and concluded that operators have adequate time to respond to such a loss of tank FW-19 inventory. This issue has been entered into the corrective action program as Condition Reports CRs 2012-15687, CR 2013-03974, and CR 2013-06170. This performance deficiency is more than minor, and therefore a finding, because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone, and affected the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, the finding is determined to have very low safety significance (Green) because it: (1) was not a deficiency affecting the design or qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time; (4) did not represent an actual loss of function of one or more nontechnical specification trains of equipment designated as high safety-significance in accordance with the licensees maintenance rule program; and (5) did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding or severe weather event. This finding has a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action program component because the licensee failed to thoroughly evaluate problems such that the resolutions address the causes
05000285/FIN-2013008-282013Q2Fort CalhounFailure to Perform an Evaluation for a Change to Component Cooling Water MAKE-UPThe team identified a Severity Level IV non-cited violation of 10 CFR Part 50.59, with an associated Green finding, because the licensee failed to perform an evaluation for a design change that may have required NRC review and approval. Specifically, from June 2008, the licensee did not evaluate a change that would permanently substitute manual actions for an automatic action to add water and nitrogen gas to the component cooling water surge tank, which is an updated safety analysis report described design function for the component cooling water system. The licensee entered this condition into their corrective action program and planned to perform an evaluation to determine if prior NRC review and approval is needed for this design change. This issue has been entered into the corrective action program as Condition Report CR 2013-04417. The team determined that it was reasonable for the licensee to be able to foresee and prevent the occurrence of this deficiency. The team evaluated this performance deficiency as both a traditional enforcement violation, and a reactor oversight process finding. The violation of 10 CFR Part 50.59 was more than minor because it involved a change to an updated safety analysis report design function in that there was a reasonable likelihood that the change would require NRC review and approval. This finding is associated with the Mitigating Systems Cornerstone. The team used the NRC Enforcement Manual and Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, to evaluate this issue. The finding is determined to have very low safety significance (Green) because it was a design deficiency confirmed not to result in the loss of operability or functionality. The violation of 10 CFR 50.59 impacted the ability of the NRC to perform its regulatory oversight function and was determined to be Severity Level IV because the resulting changes were evaluated by the significance determination process as having very low safety significance, in accordance with the NRC Enforcement Policy. The NRC concluded that the finding did not reflect current licensee performance
05000285/FIN-2013008-312013Q2Fort CalhounMultiple Examples of Operability Determinations That Lacked Adequate Technical JustificationThe team identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, involving multiple examples of the licensees failure to perform an adequate operability determination as required by Procedure NOD-QP-31, Operability Determination Process. In each example, the team identified that the operability determination lacked adequate technical justification for why the structure, system, or component was operable with the degraded or nonconforming condition. Specifically, on January 24, 2012, June 6, 2012, December 27, 2012, January 22, 2013, and February 5, 2013, the operability determinations for Condition Reports CR 2012-00580, CR 2012-04973, CR 2012-20806, CR 2013-00907, and CR 2013-02260 were not performed in accordance with Procedure NOD-QP-31, Revision 49-53, Step 4.1.3 J. This issue has been entered into the corrective action program as Condition Reports CR 2013-08343, CR 2013-05596, CR 2013-08590, CR 2013-04163, and CR 2013-05353. This performance deficiency is more than minor, and therefore a finding, because it is associated with the equipment performance attribute of the Mitigating Systems Cornerstone, and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Since the finding involving inadequate operability determinations occurred while in a shutdown condition, the team used Manual Chapter 0609, Appendix G, Shutdown Operations Significance Determination Process, and determined the finding to have very low safety significance (Green) because the finding did not increase the likelihood of a loss of reactor coolant system inventory, the finding did not degrade the licensees ability to terminate a leak path or add reactor coolant system inventory when needed, and the finding did not degrade the licensees ability to recover decay heat removal once it was lost. This finding has a cross-cutting aspect in the area of problem identification and resolution associated with corrective action program component. Specifically, the team identified that the licensee failed provide an adequate technical discussion such that a reasonable expectation of operability was demonstrated for several degraded or nonconforming conditions
05000285/FIN-2013008-322013Q2Fort CalhounMultiple Examples of Inadequate RISK-BASED Operability DeterminationsThe team identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, involving multiple examples of the licensees use of probability or probabilistic risk assessment when performing operability determinations. The use of probability or probabilistic risk assessment when determining operability is contrary to Procedure NOD-QP-31, Operability Determination Process, Revision 49-53. Specifically, on January 26, 2012 and twice on February 21, 2013, the operability determinations performed for Condition Reports CR 2012-00626, CR 2013-03839, and CR 2013-03842 used probability and/or probabilistic risk assessment to justify the operability of structures, systems, and components. This issue has been entered into the corrective action program as Condition Reports CR 2013-05590, CR 2013-05466, and CR 2013-05597. This performance deficiency is more than minor, and therefore a finding, because it is associated with the equipment performance attribute of the Mitigating Systems Cornerstone, and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Since the finding involved inadequate operability determinations that occurred while in a shutdown condition and involved plant equipment needed during shutdown conditions, the team used Manual Chapter 0609, Appendix G, Shutdown Operations Significance Determination Process, and determined the finding to have very low safety significance (Green) because the finding did not increase the likelihood of a loss of reactor coolant system inventory, the finding did not degrade the licensees ability to terminate a leak path or add reactor coolant system inventory when needed, and the finding did not degrade the licensees ability to recover decay heat removal once it was lost. This finding has a cross-cutting aspect in the area of human performance associated with the decision-making component because the licensee failed to use conservative assumptions in decision making when performing operability determinations. Specifically, the licensee proposed that a degraded/nonconforming condition was safe by relying on a non-conservative assumption that an event such as a tornado generated missile or external flooding at the site were not likely to occur
05000285/FIN-2013008-332013Q2Fort CalhounInadequate Operability Determination Due to Failure to Establish Component Cooling Water System Leakage CriteriaThe team identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, involving the licensees failure to follow procedures when evaluating the impact of component cooling water system leakage on the containment air coolers. Specifically, on October 6, 2010, and December 29, 2010, the operability determinations for Condition Reports CR 2010-04955 and CR 2010-06905 were not performed in accordance with Procedure NOD-QP-31, Operability Determination Process, Revision 43-44, Step 4.1.3 J, and consequently, failed to evaluate the impact of component cooling water system leakage on containment air coolers operability. This issue has been entered into the corrective action program as Condition Report CR 2013-05630. This performance deficiency is more than minor, and therefore a finding, because it is associated with the equipment performance attribute of the Mitigating Systems Cornerstone, and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, the finding is determined to have very low safety significance (Green) because it: (1) was not a deficiency affecting the design or qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time; (4) did not represent an actual loss of function of one or more nontechnical specification trains of equipment designated as high safety-significance in accordance with the licensees maintenance rule program; and (5) did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding or severe weather event. This finding has a cross-cutting aspect in the area of problem identification and resolution associated with corrective action program component. Specifically, the team identified that the licensee failed provide an adequate technical discussion such that a reasonable expectation of operability was demonstrated for containment air coolers with known leakage in the component cooling water system
05000285/FIN-2013008-342013Q2Fort CalhounFailure to Follow ASME Code Requirements When Establishing New Pump Reference Values as Corrective ActionsThe team identified a non-cited violation of 10 CFR 50.55a, Codes and Standards, for the failure of the licensee to follow the ASME Code when establishing new reference curves as corrective action to address the performance of component cooling water pump AC-3A within the low required action range of the in-service testing program. Specifically, on July 29, 2011, the licensee failed to follow ASME Code, Subsection ISTB 6200(c), in that, the new reference curves were established without performing an analysis which included verification of the pumps operational readiness at a pump level and a system level, without determining the cause of the change in pump performance, and without an evaluation of all trends indicated by available data. The team confirmed that while the pump was inoperable from an in-service testing perspective during this period, required surveillance testing showed that pump flows and differential pressures were still sufficient to meet the assumptions used in the Fort Calhoun Station safety analysis. This issue has been entered into the corrective action program as Condition Report CR 2013-04010. This performance deficiency is more than minor, and therefore a finding, because it is associated with the human performance attribute of the Mitigating Systems Cornerstone, and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Since this finding was discovered during plant shutdown and involved plant equipment needed during shutdown conditions, the team used Manual Chapter 0609, Appendix G, Shutdown Operations Significance Determination Process, and determined the finding to have very low safety significance (Green) because the finding did not increase the likelihood of a loss of reactor coolant system inventory, the finding did not degrade the licensees ability to terminate a leak path or add reactor coolant system inventory when needed, and the finding did not degrade the licensees ability to recover decay heat removal once it was lost. This finding has a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action program component because the licensee failed to fully evaluate the degraded performance of component cooling water pump AC-3A to ensure that resolutions correctly addressed causes of the degraded performance and the cumulative impact on system operational readiness
05000285/FIN-2013008-352013Q2Fort CalhounFailure to Correct Condition Adverse to Quality Associated with Corrective Action Program Procedures and the Operability ProcessThe team identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions, for the failure to implement corrective actions to address inadequate procedures involving the degraded/nonconforming condition evaluation and operability determination process. Specifically, prior to March 1, 2013, the licensee failed to correct the procedural inadequacies associated with Procedure FCSG-24-3, Condition Report Screening, Revision 3, as identified in the root cause analysis for Condition Report CR 2012-09494. This issue has been entered into the corrective action program as Condition Report CR 2013-04380. This performance deficiency is more than minor, and therefore a finding, because if left uncorrected, inadequate corrective action program procedures could become a more significant safety concern. This finding is associated with the Mitigating Systems Cornerstone. Since the finding was discovered while in a shutdown condition, the team used Manual Chapter 0609, Appendix G, Shutdown Operations Significance Determination Process, and determined the finding to have very low safety significance (Green) because the finding did not increase the likelihood of a loss of reactor coolant system inventory, the finding did not degrade the licensees ability to terminate a leak path or add reactor coolant system inventory when needed, and the finding did not degrade the licensees ability to recover decay heat removal once it was lost. This finding has a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action program component because the licensee failed to implement a corrective action program with a sufficiently low threshold. Specifically, although the licensee identified significant flaws in Fort Calhoun Station procedures while performing the root cause analysis for Condition Report CR 2012-09494, the licensee failed to initiate the appropriate corrective action documents to drive the necessary procedure changes
05000285/FIN-2013008-362013Q2Fort CalhounDeficient Evaluation of NRC Bulletin 88-04, Strong Pump Weak Pump Due to Failure to Consider the Effect of AFW Pumps Discharge Check Valves LeakageThe team identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, associated with the licensees failure to properly evaluate NRC Bulletin 88-04, Potential Safety-Related Pump Loss, regarding the auxiliary feedwater pumps. Specifically, from November 28, 2010, through February 2013, the licensee failed to properly evaluate NRC Bulletin 88-04, for strong pump, weak pump, interaction regarding auxiliary feedwater pumps FW-6 and FW-10. The evaluation failed to consider pump-to-pump interaction that may result due to pump discharge check valve leakage. In addition, the licensee failed to re-evaluate the condition after surveillance testing performed on November 28, 2010, and September 1, 2012, identified leakage past both pump discharge check valves. This issue has been entered into the corrective action program as Condition Reports CR 2013-04680 and CR 2013-04806. This performance deficiency is more than minor, and therefore a finding, because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone, and affected the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, the finding is determined to have very low safety significance (Green) because it: (1) was not a deficiency affecting the design or qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time; (4) did not represent an actual loss of function of one or more nontechnical specification trains of equipment designated as high safety-significance in accordance with the licensees maintenance rule program; and (5) did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding or severe weather event. This finding has a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action program component because the licensee failed to thoroughly evaluate problems such that appropriate corrective actions were promptly implemented
05000285/FIN-2013008-372013Q2Fort CalhounImproper Storage of the RAW Water to Auxiliary Feedwater Emergency Tank Fill HoseThe team identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated with the licensees failure to properly store the raw water to emergency feedwater storage tank fill hose. Specifically, from July 1996 to February 27, 2013, the licensee failed to provide adequate instructions or procedures to ensure proper storage and temperature qualification of the auxiliary feedwater emergency fill hose. This issue has been entered into the corrective action program as Condition Report CR 2013-52276. This performance deficiency is more than minor, and therefore a finding, because it was associated with the design control attribute of the Mitigating Systems Cornerstone, and affected the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, the finding is determined to have very low safety significance (Green) because it: (1) was not a deficiency affecting the design or qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time; (4) did not represent an actual loss of function of one or more nontechnical specification trains of equipment designated as high safety-significance in accordance with the licensees maintenance rule program; and (5) did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding or severe weather event. This finding has a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action program component because the licensee failed to thoroughly evaluate problems such that the resolutions address the causes
05000285/FIN-2013008-192013Q2Fort CalhounFailure to Initiate Condition Reports in Accordance with the Corrective Action Program ProceduresThe team identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to initiate condition reports when problems or conditions adverse to quality were identified in accordance with Procedure FCSG-24-1, Condition Report Initiation, Revision 3. Specifically, between July 2012 and March 2013, the team identified 11 instances where licensee staff failed to initiate a condition report after identifying a deficiency or a condition adverse to quality. In some instances, licensee personnel had to be prompted by the team to initiate a condition report. As a result, the corrective actions taken to address the conditions could have been potentially untimely. This issue has been entered into the corrective action program as Condition Report CR 2013-06991. This performance deficiency is more than minor, and therefore a finding, because if left uncorrected it has the potential to lead to a more significant safety concern. Specifically, if the licensee does not enter conditions adverse to quality into the corrective action program, the conditions adverse to quality may not be evaluated and corrected in a timely manner. This finding is associated with Mitigating Systems Cornerstone. The team determined that the finding could be evaluated using the significance determination process in accordance with IMC 0609, Significance Determination Process, and conducted a Phase 1 characterization and initial screening. Using Phase 1, Table 3, SDP Appendix Router, the team answered yes to the following question: Does the finding pertain to operations, and event, or a degraded condition while the plant was shutdown? As a result, the team used IMC 0609 Appendix G, Shutdown Operations Significance Determination Process. Using Appendix G, the finding is determined to have very low safety significance (Green) since it did not need a quantitative assessment. This finding has a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action program component because the licensee did not implement a corrective action program with a low threshold for identifying issues
05000285/FIN-2013008-392013Q2Fort CalhounFailure to Properly Implement Applicable ASME OM Code RequirementsThe team identified two examples of a non-cited violation of 10 CFR 50.55a.(f)(4)(ii), Codes and Standards, associated with the licensees failure to properly implement applicable code requirements for in-service testing of safety-related pumps and check valves. Specifically, prior to March 11, 2013, the licensee failed to ensure that the testing of safety-related pumps and valves met the requirements of the American Society of Mechanical Engineers Operation and Maintenance Code. The applicable Code for the current in-service test program is the 1998 Edition through the 2000 Addenda. This issue has been entered into the corrective action program as Condition Reports CR 2013-04680, CR 2013-05018, CR 2013-05514, and CR 2013-05569. This performance deficiency is more than minor, and therefore a finding, because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone, and affected the associated cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, the finding is determined to have very low safety significance (Green) because it: (1) was not a deficiency affecting the design or qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time; (4) did not represent an actual loss of function of one or more nontechnical specification trains of equipment designated as high safety-significance in accordance with the licensees maintenance rule program; and (5) did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding or severe weather event. This finding has a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action program component because the licensee failed to thoroughly evaluate problems such that the resolutions addressed the causes
05000285/FIN-2013008-402013Q2Fort CalhounFailure to Obtain Prior NRC Approval for a Facility ChangeThe team identified a non-cited violation of 10 CFR 50.54(q)(2) for the licensees failure to maintain the effectiveness of an emergency plan. Specifically, since May 14, 2009, the licensee failed to maintain a proper value for low river level associated with the declaration of an emergency at the ALERT classification level. The licensee did not maintain a standard emergency action level scheme in accordance with the requirements of 10 CFR 50.47(b)(4), which states in part, that a standard emergency classification and action level scheme is in use by the nuclear facility licensee. The emergency action level scheme was not maintained because emergency action levels HU1 and HA1, Natural or destructive phenomena affecting the Protected Area, contained an inaccurate river level of 973 feet 9 inches. The river level was inaccurate because the basis document, Procedure EPIP-OSC-1, Emergency Classification, Revision 46, stated the emergency action level was based on the minimum elevation of the raw water pump suction. Based on available plant data, the minimum elevation of the raw water pump suction was above the Alert declaration point of 973 feet 9 inches. This issue has been entered into the corrective action program as Condition Reports CR2013-04198 and CR 2013-04169. This performance deficiency is more than minor, and therefore a finding, because it is associated with emergency response organization performance attribute of the Emergency Preparedness Cornerstone and 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, inaccurate emergency action levels degrade the licensees ability to implement adequate measures to protect public health and safety. The finding was evaluated using the Emergency Preparedness Significance Determination Process, and was determined to be of very low safety significance (Green) because the finding was not a lost or degraded risk significant planning function. The planning standard function was not degraded because the Notification of Unusual Event and Alert emergency classifications would have been declared although potentially in a delayed manner. This finding was not assigned a cross-cutting aspect because the performance deficiency is not reflective of current performance
05000285/FIN-2013008-412013Q2Fort CalhounInappropriate Modification of Turbine Driven Auxiliary Feedwater Pump Back Pressure Protection TripThe team identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, associated with an inappropriate modification of the auxiliary feedwater system. Specifically, from April 2011 through February 2013, measures established by the licensee did not assure that the modification to remove the turbine driven auxiliary feedwater pumps exhaust back pressure trip, properly considered and addressed the open configuration of the pumps exhaust piping to prevent blockage of the exhaust piping. This issue has been entered into the corrective action program as Condition Report CR 2013-05026, and an immediate operability determination was performed. This performance deficiency is more than minor, and therefore a finding, because if left uncorrected, the continued practice of modifying the facility without evaluating for adverse impacts had the potential to lead to a more significant safety concern. Specifically, unevaluated modifications to the facility could introduce adverse changes that result in systems not able to perform their intended safety function which would not be recognized. This finding was associated with the Mitigating Systems Cornerstone. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, the finding is determined to have very low safety significance (Green) because it: (1) was not a deficiency affecting the design or qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time; (4) did not represent an actual loss of function of one or more nontechnical specification trains of equipment designated as high safety-significance in accordance with the licensees maintenance rule program; and (5) did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding or severe weather event. This finding has a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action program component because the licensee failed to thoroughly evaluate problems such that the resolutions address the causes
05000285/FIN-2013008-422013Q2Fort CalhounFailure to Make Timely Event Notifications for Unanalyzed ConditionsThe team identified four examples of a non-cited violation of 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors, for the licensees failure to make required event notifications within 8 hours following discovery of an event requiring a report. Specifically, on April 12, 2012, February 7, 2013, February 25, 2013, and February 27, 2013, the licensee failed to notify the NRC within 8 hours of the occurrence an event or condition that resulted in the nuclear power plant being in an unanalyzed condition that significantly degraded plant safety. This issue has been entered into the corrective action program as Condition Report CR 2013-05070. The violation was evaluated using Section 2.2.4 of the NRC Enforcement Policy, because the failure to required event report may impact the ability of the NRC to perform its regulatory oversight function. As a result, this violation was evaluated using traditional enforcement. In accordance with Section 6.9 of the NRC Enforcement Policy, this violation was determined to be a Severity Level IV non-cited violation. The team determined that a cross-cutting aspect was not applicable to this performance deficiency because the failure to make a required report was strictly associated with a traditional enforcement violation
05000285/FIN-2013008-432013Q2Fort CalhounRepetitive Issues Involving Untimely Submittal of Required Licensee Event ReportsThe team identified nine examples of a non-cited violation of 10 CFR 50.73, Immediate Notification Requirements for Operating Nuclear Power Reactors, for the licensees failure to make required licensee event reports within 60 days following discovery of an event requiring a report. Specifically, on nine occurrences between May 9, 2011, and August 30, 2012, the licensee failed to submit a licensee event report for an event meeting the requirements for reporting specified in 10 CFR 50.73. This issue has been entered into the corrective action program as Condition Report CR 2012-03796. The violation was evaluated using Section 2.2.4 of the NRC Enforcement Policy, because the failure to submit a required licensee event report may impact the ability of the NRC to perform its regulatory oversight function. As a result, this violation was evaluated using traditional enforcement. In accordance with Section 6.9 of the NRC Enforcement Policy, this violation was determined to be a Severity Level IV non-cited violation. The team determined that a cross-cutting aspect was not applicable to this performance deficiency because the failure to make a required report was strictly associated with a traditional enforcement violation
05000285/FIN-2013008-202013Q2Fort CalhounFailure to Identify Conditions Adverse to QualityThe team identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to promptly identify and correct conditions adverse to quality. Specifically, between July 2012 and March 2013, the team identified 6 instances where the licensee failed to identify a deficiency or a condition adverse to quality and to enter them into the corrective action program. As a result, conditions adverse to quality may not be corrected in a timely manner commensurate with the safety significance. This issue has been entered into the corrective action program as Condition Report CR 2013-07959. This performance deficiency is more than minor, and therefore a finding, because if left uncorrected it has the potential to lead to a more significant safety concern. Specifically, the failure to identify conditions adverse to quality and enter them into the corrective action program, has the potential to lead to a failure to correct conditions adverse to quality in a timely manner commensurate with the safety significance. This finding was associated with the Mitigating Systems Cornerstone. The team determined that the finding could be evaluated using the significance determination process in accordance with IMC 0609, Significance Determination Process, and conducted a Phase 1 characterization and initial screening. Using Phase 1, Table 3, SDP Appendix Router, the team answered yes to the following question: Does the finding pertain to operations, and event, or a degraded condition while the plant was shutdown? As a result, the team used IMC 0609 Appendix G, Shutdown Operations Significance Determination Process. Using Appendix G, the finding is determined to have very low safety significance (Green) since it did not need a quantitative assessment. This finding has a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action program component because the licensee did not implement a corrective action program with a low threshold for identifying issues and did not identify issues completely, accurately, and in a timely manner commensurate with their safety significance
05000285/FIN-2013008-022013Q2Fort CalhounFrazil Ice Monitor Not OperationalThe team identified a finding for the licensee\'s failure to maintain their frazil ice detector operational. The detector was sampling a non-representative water temperature which would not have warned operators of the presence of conditions favorable for the formation of frazil ice on intake structure components. The licensee entered the issue into the corrective action program as Condition Report CR 2013-04310 and switched the points they monitored for potential frazil ice formation. This performance deficiency is more than minor, and therefore a finding, because it is associated with the configuration control attribute of the Mitigating Systems Cornerstone and affected the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix G, Shutdown Operations Significance Determination Process, Attachment 1, Checklist 4, PWR Refueling Operation: RCS level > 23\' OR PWR Shutdown Operation with Time to Boil > 2 hours And Inventory in the Pressurizer, the finding is determined to have very low safety significance (Green) because the finding did not increase the likelihood of a loss of reactor coolant system inventory; did not degrade the licensees ability to terminate a leak path or add reactor coolant system inventory; and did not degrade the licensees ability to recover decay heat removal, this finding did not require a Phase 2 or 3 analysis as stated in Checklist 4. This finding has a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action program component because the licensee did not take appropriate corrective actions to address a similar condition during the winter of 2011-2012 in a timely manner, commensurate with the safety significance and complexity
05000285/FIN-2013008-032013Q2Fort CalhounLack of SAFETY-RELATED Equipment for Design Basis LOW River LevelThe team identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, associated with the licensees failure to have safety-related equipment to ensure safe operations down to the design basis low river level. Specifically, from initial plant operations, the licensee failed to ensure that raw water cooling was provided down to the design basis low river level by ensuring the associated specifications and procedures supported raw water pump operation. This issue has been entered into the corrective action program as Condition Reports CR 2013-04169 and CR 2013-06436. This performance deficiency is more than minor, and therefore a finding, because it is associated with the configuration control attribute of the Mitigating Systems Cornerstone and affected the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, the finding is determined to have very low safety significance (Green) because it: (1) was not a deficiency affecting the design or qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time; (4) did not represent an actual loss of function of one or more nontechnical specification trains of equipment designated as high safety-significance in accordance with the licensees maintenance rule program; and (5) did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding or severe weather event. This finding has a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action program component because the licensee did not thoroughly evaluate problems such that the resolutions address causes and extent of conditions
05000285/FIN-2013008-042013Q2Fort CalhounNON-CONSERVATIVE Value for Declaring an Alert on LOW River LevelThe team identified a non-cited violation of 10 CFR 50.54(q)(2) for the licensees failure to maintain the effectiveness of an emergency plan. Specifically, since May 14, 2009, the licensee failed to maintain a proper value for low river level associated with the declaration of an emergency at the ALERT classification level. The licensee did not maintain a standard emergency action level scheme in accordance with the requirements of 10 CFR 50.47(b)(4), which states in part, that a standard emergency classification and action level scheme is in use by the nuclear facility licensee. The emergency action level scheme was not maintained because emergency action levels HU1 and HA1, Natural or destructive phenomena affecting the Protected Area, contained an inaccurate river level of 973 feet 9 inches. The river level was inaccurate because the basis document, Procedure EPIP-OSC-1, Emergency Classification, Revision 46, stated the emergency action level was based on the minimum elevation of the raw water pump suction. Based on available plant data, the minimum elevation of the raw water pump suction was above the Alert declaration point of 973 feet 9 inches. This issue has been entered into the corrective action program as Condition Reports CR2013-04198 and CR 2013-04169. This performance deficiency is more than minor, and therefore a finding, because it is associated with emergency response organization performance attribute of the Emergency Preparedness Cornerstone and 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, inaccurate emergency action levels degrade the licensees ability to implement adequate measures to protect public health and safety. The finding was evaluated using the Emergency Preparedness Significance Determination Process, and was determined to be of very low safety significance (Green) because the finding was not a lost or degraded risk significant planning function. The planning standard function was not degraded because the Notification of Unusual Event and Alert emergency classifications would have been declared although potentially in a delayed manner. This finding was not assigned a cross-cutting aspect because the performance deficiency is not reflective of current performance
05000285/FIN-2013008-052013Q2Fort CalhounInadequate Procedure for Combating Loss of RAW WaterThe team identified a non-cited violation of Technical Specification 5.8.1, Procedures, for the licensee\'s failure to maintain an adequate procedure for the loss of raw water cooling. Specifically, since April 2011, the licensee failed to maintain Procedure AOP-18, Loss of Raw Water, to adequately align the component cooling water system for the feed and bleed mode. This issue has been entered into the corrective action program as Condition Report CR 2013-04417. This performance deficiency is more than minor, and therefore a finding, because it is associated with the procedure quality attribute of the Mitigating Systems Cornerstone and affected the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events - 4 - to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix G, Shutdown Operations Significance Determination Process, Attachment 1, Checklist 4, PWR Refueling Operation: RCS level > 23\' OR PWR Shutdown Operation with Time to Boil > 2 hours And Inventory in the Pressurizer, the finding is determined to have very low safety significance (Green) because the finding did not increase the likelihood of a loss of reactor coolant system inventory; did not degrade the licensees ability to terminate a leak path or add reactor coolant system inventory; and did not degrade the licensees ability to recover decay heat removal, this finding did not require a Phase 2 or 3 analysis as stated in Checklist 4. This finding has a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action program component because the licensee did not thoroughly evaluate problems such that the resolutions address causes and extent of conditions
05000285/FIN-2013008-062013Q2Fort CalhounFailure to Account for Worst Case Conditions in Fuel Oil Inventory CalculationThe team identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, associated with the licensees failure to account for design basis conditions in their fuel oil consumption calculation. Specifically, since June 2011, the licensee failed to translate the worst case design emergency diesel generator frequency that could impact the consumption of fuel oil into the applicable design documentation. To address the deficiency, this issue has been entered into the corrective action program as Condition Reports CR 2013-04311 and CR 2013-04470. This performance deficiency is more than minor, and therefore a finding, because it is associated with the configuration control attribute of the Mitigating Systems Cornerstone and affected the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, the finding is determined to have very low safety significance (Green) because it: (1) was not a deficiency affecting the design or qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time; (4) did not represent an actual loss of function of one or more nontechnical specification trains of equipment designated as high safety-significance in accordance with the licensees maintenance rule program; and (5) did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding or severe weather event. This finding has a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action program component because the licensee did not thoroughly evaluate problems such that the resolutions address causes and extent of conditions
05000285/FIN-2013008-082013Q2Fort CalhounSluice Gate Leakage Not Periodically VerifiedThe team identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, associated with the licensees failure to ensure that a critical parameter in the design calculation for intake cell level control (sluice gate leakage) was periodically measured to ensure the plant stayed within the parameters of the design calculation. Specifically, since April 2011, the licensee failed to assure that the assumed leakage of the sluice gates was translated into a procedure to periodically measure leakage against acceptance criteria to ensure the leakage was low enough to support the intake structure design calculation. This issue has been entered into the corrective action program as Condition Report CR 2013-04315. This performance deficiency is more than minor, and therefore a finding, because it is associated with the configuration control attribute of the Mitigating Systems Cornerstone and affected the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix G, Shutdown Operations Significance Determination Process, Attachment 1, Checklist 4, PWR Refueling Operation: RCS level > 23\' OR PWR Shutdown Operation with Time to Boil > 2 hours And Inventory in the Pressurizer, the finding is determined to have very low safety significance (Green) because the finding did not increase the likelihood of a loss of reactor coolant system inventory; did not degrade the licensees ability to terminate a leak path or add reactor coolant system inventory; and did not degrade the licensees ability to recover decay heat removal, this finding did not require a Phase 2 or 3 analysis as stated in Checklist 4. This finding has a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action program component because the licensee did not thoroughly evaluate problems such that the resolutions address causes and extent of conditions
05000285/FIN-2013008-102013Q2Fort CalhounFailure to Accurately Model RAW Water Flow Into the Intake StructureThe team identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, associated with the licensees failure to accurately model the traveling screens and trash racks in the flow calculation for cell level control. Specifically, since April 2011, the licensee failed to translate the actual plant configuration for flow of water into the intake structure during flooding into the applicable design calculation. This issue has been entered into the corrective action program as Condition Reports CRs 2013-04468 and CR 2013-04310. This performance deficiency is more than minor, and therefore a finding, because it is associated with the configuration control attribute of the Mitigating Systems Cornerstone and affected the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, the finding is determined to have very low safety significance (Green) because it: (1) was not a deficiency affecting the design or qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time; (4) did not represent an actual loss of function of one or more nontechnical specification trains of equipment designated as high safety-significance in accordance with the licensees maintenance rule program; and (5) did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding or severe weather event. The finding has a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action program component because the licensee did not thoroughly evaluate problems such that the resolutions address causes and extent of conditions
05000285/FIN-2013008-122013Q2Fort CalhounInadequate Root Cause for a Significant Condition Adverse to QualityThe team identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, associated with the licensees failure to promptly identify, correct, and prevent recurrence of a significant condition adverse to quality. Specifically, from November 2009 to present, measures established by the licensee failed to assure that the cause of an identified significant condition adverse to quality was corrected and corrective actions taken would preclude repetition involving the failure to identify nonconforming quality equipment before it is installed and relied upon to perform specified safety functions. Specifically, in this instance, the licensee failed to identify that a 480 Volt replacement breaker has a jumper installed inappropriately resulting in the failure of the breaker to trip during a faulted condition. This issue has been entered into the corrective action program as Condition Report CR 2013-04037. The performance deficiency is more than minor, and therefore a finding, because it is associated with the protection against external factors attribute of the Mitigating Systems Cornerstone, and affected the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Additionally, if left uncorrected, the licensees root cause analysis will not provide assurance that effective corrective actions are taken to preclude recurrence of a breaker trip failure. Using Inspection Manual Chapter 0609, Appendix G, Shutdown Operations Significance Determination Process, Attachment 1, Checklist 4, PWR Refueling Operation: RCS level > 23\' OR PWR Shutdown Operation with Time to Boil > 2 hours And Inventory in the Pressurizer, which contained the initial screening for pressurized water reactors that are shutdown with a time to boil of greater than 2 hours. Technical Specification 2.7, Electrical Systems, states that the reactor shall not be heated up or maintained at temperatures above 300 degrees Fahrenheit unless the electrical systems listed in that section (includes the 480 V busses) are operable. Because the plant was maintained below 300 degrees during the exposure period, the team determined that power availability technical specifications were being met as discussed in Checklist 4. Because the finding did not increase the likelihood of a loss of reactor coolant system inventory; did not degrade the licensees ability to terminate a leak path or add reactor coolant system inventory; and did not degrade the licensees ability to recover decay heat removal, this finding did not require a Phase 2 or 3 analysis as stated in Checklist 4. Therefore, the finding is determined to have very low safety significance (Green). This finding has a cross-cutting aspect in the area of accountability associated with the other safety culture components because the licensee failed to demonstrate a proper safety focus and reinforce safety principles among their peers. Specifically, the licensee focused on sending a message about the vendor rather than the licensees failures to establish accountability for the vendors products and services
05000285/FIN-2013008-132013Q2Fort CalhounFailure to Establish and Document Basis for Test Acceptance CriteriaThe team identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, associated with the licensees failure to assure that applicable design basis information, as defined in 10 CFR 50.2, for breaker testing was correctly translated into specifications, drawings, procedures, and instructions. Specifically, from July 2011, to the present the licensee failed to incorporate the basis for the acceptance limits of the digital low resistance ohmmeter values into specifications and procedures. Without a basis for the acceptance values the licensee cannot show that the breakers will perform satisfactorily in service, and incorrect acceptance values could allow high resistance connections to go unnoticed. This issue has been entered into the corrective action program as Condition Report CR 2013-04032. This performance deficiency is more than minor, and therefore a finding, because it is associated with the design control attribute of the Mitigating Systems Cornerstone, and affected the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix G, Shutdown Operations Significance Determination Process, Attachment 1, Checklist 4, PWR Refueling Operation: RCS level > 23\' OR PWR Shutdown Operation with Time to Boil > 2 hours And Inventory in the Pressurizer, the team determined that because this finding did not increase the likelihood of a loss of reactor coolant system inventory; did not degrade the licensees ability to terminate a leak path or add reactor coolant system inventory; and did not degrade the licensees ability to recover decay heat removal, this finding did not require a Phase 2 or 3 analysis as stated in Checklist 4. Therefore, the finding is determined to have very low safety significance (Green). This finding has a cross-cutting aspect in the area of human performance associated with the work practices component because licensee personnel failed to follow procedures. Specifically, Fort Calhoun Station personnel failed to follow the requirements specified in Procedure PED-GEI-7, Specification of Post-Modification Test Criteria
05000285/FIN-2013008-152013Q2Fort CalhounFailure to Correct Conditions Adverse to Quality Involving Frequency Compatibility Issues in the 120VAC SystemThe team reviewed a self-revealing non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions, for the licensees failure to address frequency compatibility issues in the 120 Vac electrical distribution system. Specifically, between June 5, 2008, and February 22, 2013, the licensee failed to correct known frequency compatibility issues in the 120 Vac instrument system that resulted in voltage transients and damage to instrumentation supplied by the 120 Vac instrument inverters. This issue has been entered into the corrective action program as Condition Report CR 2013-03866. At the close of the inspection, the licensee was still completing causal analysis and identification of corrective actions necessary to address frequency compatibility issues in the 120 Vac electrical distribution system. This performance deficiency is more than minor, and therefore a finding, because it affected the equipment performance attribute of the Mitigating Systems Cornerstone and affected the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix G, Shutdown Operations Significance Determination Process, the finding is determined to have very low safety significance (Green) because the finding did not increase the likelihood of a loss of reactor coolant system inventory, the finding did not degrade the licensees ability to terminate a leak path or add reactor coolant system inventory when needed, and the finding did not degrade the licensees ability to recover decay heat removal once it was lost. This finding had a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action program component. Specifically, the team identified that the licensee failed to adequately evaluate repeated low voltage/ground alarm associated with the 120 Vac distribution system
05000285/FIN-2013008-162013Q2Fort CalhounFailure to Account for Additional Diesel Loading from NON-SAFETY LoadsThe team identified a non-cited violation of 10 CFR Part 50, Appendix B, Criteria III, Design Control, for the licensees failure to update calculations to account for non safety-related loads supplied by the emergency diesel generator through non-qualified isolation devices and the cumulative impact on diesel fuel oil consumption. Specifically, prior to April 1, 2013, Calculation EA-FC-92-072, Diesel Generator Transient Loading Analysis Using EDSA Design Base 3.0, Revision 6, failed to account for the additional diesel fuel oil consumption that would occur due to the loads that would be supplied from the emergency diesel generators through non-CQE isolation devices. The licensee modified Calculation EA-FC-92-072 to address the teams concerns. This issue has been entered into the corrective action program as Condition Report CR 2013-09817. The performance deficiency is more than minor, and therefore a finding, because it is 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. Because this performance deficiency affected the calculation used to determine the required diesel fuel oil inventory for an accident or a loss of offsite power occurring from at power conditions, the team used Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, and determined the finding to have very low safety significance (Green) because it: (1) was not a deficiency affecting the design or qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time; (4) did not represent an actual loss of function of one or more nontechnical specification trains of equipment designated as high safety-significance in accordance with the licensees maintenance rule program; and (5) did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding or severe weather event. This finding has a cross-cutting aspect in the area of problem identification and - 11 - resolution associated with the corrective action program component because the licensee failed to thoroughly evaluate the condition identified in Condition Report CR 2013-04594 to determine its impact to emergency diesel generator fuel oil consumption
05000285/FIN-2013008-172013Q2Fort CalhounFailure to Adequately Implement the Maintenance RuleThe team identified a non-cited violation of 10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, associated with the licensees failure to adequately monitor the performance of structures, systems, and components, against established goals in a manner sufficient to provide reasonable assurance that these structures, systems, and components are capable of fulfilling their intended functions. Specifically, from June 7, 2011, to the present, the licensee failed to monitor the performance of the 480 Vac busses in a manner sufficient to provide reasonable assurance that they are capable of fulfilling their intended safety functions. This issue has been entered into the corrective action program as Condition Report CR 2013-04352. This performance deficiency is more than minor, and therefore a finding, because it is associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affected the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix G, Shutdown Operations Significance Determination Process, Attachment 1, Checklist 4, PWR Refueling Operation: RCS level > 23\' OR PWR Shutdown Operation with Time to Boil > 2 hours And Inventory in the Pressurizer, which contained the initial screening for pressurized water reactors that are shutdown with a time to boil of greater than 2 hours. Technical Specification 2.7, Electrical Systems, stated that the reactor shall not be heated up or maintained at temperatures above 300 degrees Fahrenheit unless the electrical systems listed in that section (includes the 480 V busses) are operable. Because the plant was maintained below 300 degrees during the exposure period, the team determined that power availability Technical Specifications were being met as discussed in Checklist 4. Because the finding did not increase the likelihood of a loss of reactor coolant system inventory; did not degrade the licensees ability to terminate a leak path or add reactor coolant system inventory; and did not degrade the licensees ability to recover decay heat removal, this finding did not require a Phase 2 or 3 analysis as stated in Checklist 4. Therefore, the finding is determined to have very low safety significance (Green). This finding has a cross-cutting aspect in the area of human performance associated with the decision-making component because the licensee failed to use conservative assumptions in decision-making and adopt a requirement to demonstrate that the proposed action is safe in order to proceed rather than a requirement to demonstrate it is unsafe in order to disapprove the action
05000285/FIN-2013008-182013Q2Fort CalhounFailure to Establish Adequate Instructions for Restoring Temporary ModificationsThe team identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated with the licensees failure to establish adequate instructions for restoring temporary modifications. Specifically, from January 17, 2013, to the present, the licensees temporary modification control procedure did not include appropriate criteria for determining that control room and operations control center references reflect current plant configuration and were updated in a timely manner. The licensee initiated Condition Report CR 2013-04286, which stated that the licensees transition to a new procedure will help ensure that control room and operations control center documents were updated in a timely manner and that the licensee is determining whether any near-term action is necessary to address the issue until then. This performance deficiency is more than minor, and therefore a finding, because it is associated with the procedure quality attribute of the Mitigating Systems Cornerstone and affected the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Additionally, if left uncorrected, the procedure inadequacy could become a more significant issue because it could allow operators to continue to reference material that does not reflect current plant configuration. Using Inspection Manual Chapter 0609, Appendix G, Shutdown Operations Significance Determination Process, Attachment 1, Checklist 4, PWR Refueling Operation: RCS level > 23\' OR PWR Shutdown Operation with Time to Boil > 2 hours And Inventory in the Pressurizer, the team determined that because this finding did not increase the likelihood of a loss of reactor coolant system inventory; did not degrade the licensees ability to terminate a leak path or add reactor coolant system inventory; and did not degrade the licensees ability to recover decay heat removal, this finding did not require a Phase 2 or 3 analysis as stated in Checklist 4. Therefore, the finding is determined to have very low safety significance (Green). This finding has a cross-cutting aspect in the area of human performance associated with the work control component because the licensee failed to appropriately coordinate work activities by incorporating actions to address the need to keep personnel apprised of work status, the operational impact of work activities, and plant conditions that may affect work activities. Specifically, the licensee did not incorporate actions into the procedure that would address the impact of out-of-date control room references on operator performance
05000285/FIN-2013008-212013Q2Fort CalhounFailure to Ensure That Design Requirements Associated with the Containment Electrical Penetration Assemblies Were Correctly Translated Into Installed Plant EquipmentThe team identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, associated with the licensees failure to translate applicable regulatory requirements and the design basis into specifications, drawings, procedures, and instructions. Specifically, from initial construction to present, the licensee did not perform adequate analysis and/or post-accident condition functional testing of the teflon insulated and teflon sealed Conax electrical penetration assemblies to determine if they were suitable for expected post accident conditions. The licensee has decided to replace or cap all Teflon-insulated containment electrical penetration assemblies prior to returning to power operations. This issue has been entered into the corrective action program as Condition Report CR 2013-03571. This performance deficiency is more than minor, and therefore a finding, because it is associated with the design control attribute of the Barrier Integrity Cornerstone and affected the associated cornerstone objective to provide reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and containment) protect the public from radionuclide releases caused by accidents or events. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, the finding is determined to have very low safety significance (Green) because it did not represent an actual open pathway in the physical integrity of reactor containment, containment isolation system, and heat removal components. This finding has a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action program component because the licensee failed to implement a corrective action program with a low threshold for identifying issues and identify such issues completely, accurately, and in a timely manner commensurate with their safety significance
05000285/FIN-2012011-042012Q4Fort CalhounInadequate Design Basis DocumentationThe NRC identified a non-cited violation of 10 CFR 50 Appendix B, Criterion V, Procedures, for failing to follow a quality procedure. Specifically; PED-QP-13 Design Basis Document Control, requires FCS to update and maintain their Design Bases Documents. The license has failed to maintain these design documents. Some examples include PLDBD-51 Seismic Criteria where the configuration of the Steam Generator supports were not accurately described, and PLDBD-ME-10 Pipe Stress and Supports where the piping design code classification for Main Steam is incorrect. The licensee entered the issue into its corrective action program for evaluation and review. The performance deficiency is more than minor because if left uncorrected it would have the potential to lead to a more significant safety concern. The finding was determined to affect the Initiating Events, Mitigation Systems, and Barrier Cornerstones using Inspection Manual Chapter 0609.04, Initial Characterization of Findings. The finding was characterized as having very low safety significance (i.e., Green) using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) For Findings At-Power, because all logic questions for the applicable cornerstones were answered in the negative. The finding is assigned a cross-cutting aspect in the area of Human Performance, in the component of Resources because the licensee failed to ensure that personnel, equipment, procedures, and other resources, specifically those necessary for complete, accurate and up-to-date design documentation, were available and adequate to assure nuclear safety.
05000285/FIN-2012011-032012Q4Fort CalhounFailure to Ensure that Adequate Equipment was Available to Measure River Level Locally to be Able to Comply with an Abnormal Operating ProcedureThe inspectors identified a non-cited violation of 10 CFR 50, Appendix B, Criterion III, Design Control, for the licensees failure to ensure that adequate equipment was available to measure river level locally to comply with an abnormal operating procedure. Specifically, the length of the weighted tape measure used to measure river level locally was inadequate to ensure that the entire range of river levels needed for operation of the plant would be covered. The licensee entered the issue into its corrective action program for evaluation and review. The performance deficiency was determined to be more than minor because it is associated with the Mitigating Systems Cornerstone attribute of Equipment Performance and it adversely affects the associated cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The finding was screened as very low safety significance (Green) because the licensee maintained an adequate mitigation capability and it would not be characterized as a loss of control. The inspectors determined the finding had a cross-cutting aspect in the area of problem identification and resolution because the licensee falied to thoroughly evaluate problems such that resolutions address the causes and extent of condition specifically associated with deficiencies involving the Acts of Nature procedural guidance.
05000285/FIN-2012012-042012Q4Fort CalhounFailure to Adequately Implement the Maintenance Rule ProgramThe team identified a Green NCV of 10 CFR 50.65, Requirements for monitoring the effectiveness of maintenance at nuclear power plants which states, in part, that the licensee shall monitor the performance or condition of structures, systems, or components, against licensee-established goals, in a manner sufficient to provide reasonable assurance that these structures, systems, and components are capable of fulfilling their intended functions. These goals shall be established commensurate with safety and, where practical, take into account industry-wide operating experience. Specifically, from March of 2012 until October of 2012, the licensee allowed the maintenance rule program to deteriorate by not performing initial screenings in a timely fashion. In some cases, the initial screenings were being done months later and the actual evaluation of the equipment status was not being performed at all for a period of eight months. Consequently, several components, including electrical relays and electrical load centers, were not being evaluated in accordance with program requirements. Additionally, the licensee was not implementing the operating experience program as required by this regulation. The licensee discontinued performance of level 1 and level 2 operating experience evaluations by direction from the senior management in August of 2012 based on resource concerns. Several examples where operating experience was not properly evaluated included the containment spray pump low oil issues (ACA 2008-5695), vendor manual updates, and loose fasteners (both electrical and mechanical) from San Onofre Nuclear Generating Station Licensee Event Reports (LER) 3612007005, 3612007006, and 3612008006. This finding was entered into the licensees Corrective Action Program as CR 2012-17572. The team determined that the failure to adequately implement the maintenance rule was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because if left uncorrected it could lead to a more serious concern. Using Manual Chapter 0609, Attachment 4, Significance Determination Process router on Table 3, it sends the user to Appendix G for Shutdown Operations Significance Determination Process. Using Checklist 4 of Appendix G for the given plant conditions, the finding was determined to have very low safety significance (Green) because the finding did not 1) increase the likelihood of a loss of RCS inventory, or 2) degrade the licensees ability to terminate a leak path or add RCS inventory when needed, or 3) degrade the licensees ability to recover decay heat removal once it is lost. This finding was determined to have a cross-cutting aspect in the area of human performance associated with the decision-making component because the licensee did not use conservative assumptions in decision making and did not identify the possible unintended consequences of suspending maintenance rule program activities and the corresponding impact on the program.
05000285/FIN-2012011-052012Q4Fort CalhounFailure to Properly Scope All the Pertinent External Flood Protection Features into the Walkdown List in Accordance with Industry Guidance NEI 12-07The inspectors identified a finding of very low safety significance (Green) for the licensees failure to generate a complete inspection list, with all the external flood protection features credited in the current licensing basis documents for flooding events, to comply with NRC endorsed NEI 12-07, Guidelines for Performing Walkdowns of Plant Flood Protection Features. These walkdowns were being performed in response to a March 12, 2012, letter from the NRC to licensees, entitled, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident. Specifically, the scoping list did not include several active components, which are an essential part of Fort Calhouns design basis flood mitigation strategy. The licensee entered the issue into the corrective action program and revised the scoping list accordingly. The performance deficiency was determined to be more than minor because it is associated with the Mitigating Systems Cornerstone attribute of Protection Against External Factors (Flood Hazard) and it adversely affects the associated cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, in addition to not scoping the sluice gates into the Flooding Features Walkdown List, fourteen additional active components would not have been scoped into the walkdown list. This would have prevented the licensee from identifying that preventive maintenance tasks needed to be created, and some active components that are an essential part of the flood mitigating strategy would not have been inspected and tested. The finding was screened as very low safety significance (Green) because the finding did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding, or severe weather initiating event. The inspectors determined the finding had a cross-cutting aspect in the area of human performance because licensee personnel did not properly apply human error prevention techniques such as peer checking and proper documentation of activities.
05000285/FIN-2012012-012012Q4Fort CalhounHot Work Procedures Allowed a Roving Fire WatchThe inspectors identified a Green non-cited violation (NCV) of Technical Specification 5.8.1.c for the failure to maintain written procedures covering fire protection program implementation. Specifically, the licensee changed the hot work procedure to allow a roving fire watch in lieu of the continuous fire watch required by the fire protection program. The licensee entered this issue into their Corrective Action Program as Condition Report (CR) 2012-19945. The failure to maintain adequate written procedures covering fire protection program implementation was a performance deficiency. This finding was more than minor because it was associated with the procedure quality attribute of the Initiating Events cornerstone and it adversely affected the cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The inspectors evaluated the risk significance of this finding using Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, because the performance deficiency involved a failure to adequately implement fire prevention and administrative controls for hot work activities. A senior reactor analyst performed a limiting Phase 3 evaluation and determined this finding had very low risk significance (Green). The finding did not have a cross-cutting aspect since it was not indicative of present performance.
05000285/FIN-2012012-032012Q4Fort CalhounFailure to Properly Manage the Functionality of the River Sluice GatesThe team identified a finding exemplified by multiple violations for the failure to manage the functionality of the river sluice gates. Specifically, the licensees preventive maintenance program requirements were not appropriately implemented for a period of 6 months and as a result, the functionality of the river sluice gates was improperly maintained. The examples were: 1. A licensee identified violation of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, for the failure to perform preventive maintenance required to demonstrate the functionality of the river sluice gates. An NRC identified violation of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, for the failure to accomplish activities affecting quality in accordance with prescribed instructions when in September 2012, the licensee failed to test the C and D river sluice gates in accordance with station procedure SAO-12-001, to properly maintain functionality of the river sluice gates. 2. An NRC identified violation of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, for the failure to accomplish activities affecting quality in accordance with prescribed instructions when the licensee failed to test all six gates in October 2012, to maintain functionality of the river sluice gates in accordance with station procedure SAO-12-001. 3. An NRC identified violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Actions, for the licensees failure to properly identify and timely enter conditions adverse to quality into the Corrective Action Program following multiple failures of the river sluice gates. 4. An NRC identified violation of 10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, for the licensees failure to demonstrate effective control of performance of the circulating water system river sluice gates and failure to place the system in (a)(1) when system performance deteriorated. 5. An NRC identified violation of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, for the failure to accomplish activities affecting quality in accordance with prescribed instructions when the licensee failed to make the appropriate functionality assessment when the circulating water river sluice gates failed to close during the August 2012 monthly test. The licensee entered these issues into their Corrective Action Program under various CRs described in the body of this report. The team concluded that the failure to manage the functionality of the sluice gates was a performance deficiency that warranted further evaluation. Specifically, the licensees preventive maintenance program requirements were not appropriately implemented for a period of 6 months and as a result, the functionality of the sluice gates was improperly maintained. Using the guidance in IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, the inspectors determined this finding affected the Mitigating Systems cornerstone. The finding is greater than minor because it is associated with both of the Mitigating Systems Cornerstone attributes of Equipment Performance and Protection Against External Factors and, it adversely affects the associated cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The significance of this finding is bounded by the significance of a related Yellow finding regarding the ability to mitigate an external flooding event (Inspection Report 05000285/2010008). The inspectors determined the finding had a cross-cutting aspect in the area of problem identification and resolution because the licensee did not take appropriate corrective action to address safety issues and adverse trends in a timely manner, commensurate with their safety significance and complexity.
05000285/FIN-2012011-022012Q4Fort CalhounFailure to Follow Radiation Work Permit RequirementsInspectors reviewed a self-revealing Green noncited violation of Technical Specification 5.8.1.a for the failure to follow procedure requirements related to radiation work permit requirements. Specifically, workers unexpectedly created a high radiation area when working with tri nuke filter hosing while on a radiation work permit that did not allow access into a high radiation area. Both workers received alarms on their dosimeters. The licensee entered the issue into its corrective action program for evaluation and review. The failure to follow a procedure was a performance deficiency. The finding was more than minor because it negatively impacted the Occupational Radiation Safety cornerstones attribute of program and process, in that not following the requirements of the radiation work permit led to workers unplanned, unintended dose. Using NRC Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, the finding was determined to be of very low safety significance because: (1) it was not associated with as low as is reasonably achievable (ALARA) planning or work controls, (2) there was no overexposure, (3) there was no substantial potential for an overexposure, and (4) the ability to assess dose was not compromised. The finding has a problem identification and resolution crosscutting component associated with operating experience because the licensee didnt implement operating experience through changes to station procedures. Specifically, there was operating experience which could have prevented the issue if it had been discussed at the pre-job brief.
05000285/FIN-2012011-012012Q4Fort CalhounInadequate operability determination for containment internal structuresThe NRC identified a non-cited violation of Title 10 CFR Part 50, Appendix B, Criterion V, Procedures, for the failure to perform an adequate operability determination as required by FCS Procedure NOD-QP-31, Operability Determination Process. Specifically, the licensees operability determination for non-conforming containment internal structures failed to address that a section of the containment internal structures exceeded the allowable working stress criteria. The licensee entered this issue into its corrective action program for evaluation and review. Inspectors found that the failure to perform an adequate operability determination to specifically evaluate that the containment internal structures did not meet the design code of record was a performance deficiency. This violation is more than minor because it is associated with the design control attribute of the barrier integrity cornerstone and has the potential to adversely affect the cornerstone objective. The inspectors used Inspection Manual Chapter 0609, Appendix G Shutdown Operations Significance Determination Process , to determine that the issue screened as very low safety significance (green) because it did not require a quantitative assessment per Checklist 4. This violation was determined to have a crosscutting aspect in the area of human performance associated with decision making (H.1.b). Specifically, the licensee did not use conservative assumptions in decision making and did not adopt a requirement to demonstrate that the proposed action is safe in order to proceed rather than a requirement to demonstrate that it is unsafe in order to disapprove the action.
05000285/FIN-2012012-062012Q4Fort CalhounLicensee-Identified ViolationLER 05000285/2012-005-01 described a failure to monthly verify the automatic start features of the diesel fuel oil pumps. This was a violation of Technical Specification 3.7(1)e and Table 3-2, Item 12. The performance deficiency was more than minor because it was associated with the procedure quality attribute of the Mitigating Systems Cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. It was determined to be of very low safety significance since there was not an actual failure of the automatic start features of the diesel fuel oil pumps. This issue was entered into the CAP as CR 2012-01324. This violation is also discussed in Section 4OA3.1.
05000285/FIN-2012012-072012Q4Fort CalhounLicensee-Identified ViolationTitle 10 of the Code of Federal Regulations, Part 50.47(b)(16), requires, in part, that licensee emergency planners are properly trained. Contrary to the above, two licensee emergency planners were not trained in accordance with station training requirements as described in EPDM 12, Emergency Planning Staff Training and Qualification Program, Revision 3. Specifically, one emergency planner was 36 months overdue on five required reading packages and 30 months overdue on four required reading packages, and another emergency planner was 36 months overdue on a required offsite training course. The finding is more than minor because if left uncorrected it could have led to a more significant safety concern and it impacted the Emergency Response Organization Performance attribute. The finding could have led to a more significant safety concern because an untrained licensee emergency planner could have failed to recognize and correct risk-significant emergency preparedness issues. The finding was evaluated using the EP Significance Determination Process and determined to be of very low safety significance (Green) because it was a failure to comply with NRC requirements and was not a lost or degraded planning standard function. The planning standard function was not degraded because the licensee had a formal program for training emergency preparedness department staff, the identified emergency planners had completed some required training activities, and three other emergency planners were current in their training activities. The finding was entered into the licensees CAP as CR 2012-10400.
05000285/FIN-2012012-052012Q4Fort CalhounFailure to Perform Siren Maintenance as required by the Alert and Notification System Design ReportThe NRC identified deviations between the licensees annual preventative maintenance program for outdoor emergency warning sirens and the licensees commitments as described in their FEMA approved Alert and Notification System design report The inspectors determined that Section 4.2.2.2 of their FEMA approved, Design Report for the Outdoor Public Warning System, Revision 1, requires annual inspection and testing according to vendor instructions found in Attachment 6, Installation, Operation, and Service Manual, Federal Signal Corporation Model DCFCTB, dated October 2003. Service Manual Section 8.2.2, Annual Inspection, recommends annual performance of the pre-operational testing described in Sections 7.1 through 7.4. Inspectors determined that siren maintenance records did not contain sufficient detail to establish that the licensee conducted the tests described in sections 7.1, Rotation Current Sensor, Chopper Current Sensor, A/C Power Sensor, and Intrusion Sensor, Section 7.2, Battery Voltage Measurement, Section 7.3, Battery Charger Voltage Measurement, or Section 7.4, 2001TR Transformer-Rectifier Testing. Siren testing, maintenance, and repair is performed by Omaha Public Power Districts Corporate Telecommunications Department, located in Omaha, Nebraska, and is not performed by FCS. Licensee staff stated that some tests described in Service Manual Sections 7.1 through 7.4 were performed but lacked knowledge of specific siren maintenance procedures. The licensee appeared to lack a formal siren maintenance procedure or other documents to establish the scope of the preventative maintenance program for the Model DCFCTB outdoor warning siren. Additional information about the actual scope of the licensees siren maintenance program is required to determine compliance with NRC requirements. In addition, a determination is required from the FEMA whether the licensees deviations from the approved design report are acceptable.
05000285/FIN-2012004-042012Q3Fort CalhounFailure to Ensure Breaker Coordination of 480 VAC Electrical Power Distribution System Was MaintainedThe team identified a violation of 10 CFR 50 Appendix B Criteria III, Design Control. Specifically, the design modification package for the 480 VAC breaker replacements failed to ensure the breaker coordination for the 480 VAC electrical buses was maintained. As a result, feeder breaker 1B3A tripped unexpectedly during the fire event in the 1B4A switchgear. This performance deficiency also resulted in the loss of multiple buses on both trains of 480 VAC, including ECCS systems, from a single fault on a 480 VAC bus. This finding and its corrective actions will be managed by the NRCs Inspection Manual Chapter 0350 Oversight Panel. This finding is associated with Enforcement Action 12-121. The failure to ensure that the 480 VAC electrical power distribution system design requirements were maintained was a performance deficiency that was within OPPDs ability to foresee and prevent. The performance deficiency was reviewed using NRC Inspection Manual Chapter 0612, Appendix B, Issue Screening, and the issue was determined to be more than minor because it affected the Initiating Events Cornerstone attributes of protection against external events (i.e., fire) and design control. The issue adversely affected the associated cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The significance of this finding is bounded by the significance of the Red finding documented in Inspection Report 05000285/2012010. The licensee entered this issue into its corrective action program as CR 2011-6621. The performance deficiency had a cross-cutting aspect in the area of human performance associated with resources because OPPD failed to ensure that station procedures for engineering changes, plant modifications, inspections, installations, and maintenance contained sufficient details.
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