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05000387/FIN-2010004-012010Q3SusquehannaProcedural Inadequacies Result in Reactor Scram and Loss of Normal Heat SinkA self-revealing preliminary White finding regarding procedure NDAP-QA-0008, Procedure Writer\\\'s Guide, Revision 8, was identified following a July 16, 2010, flooding event in the Unit 1 condenser bay which resulted in a manual reactor scram and loss of the normal heat sink. There were three instances of inadequate procedures identified. The first instance involved maintenance procedure MT-043-001 which provided inadequate instructions regarding installation of the condenser waterbox gaskets and led to the event. In addition, two other off-normal procedures were inadequate in that they complicated operator response to the event. Specifically, operators used a diagram in off-normal procedure ON-100-003, Chemistry Anomaly, to identify and isolate the leak which was incorrect, delayed leak isolation, and resulted in a manual reactor scram in anticipation of a loss of the normal heat sink. Finally, ON-142-001, Circulating Water (CW) Leak, did not contain specific instructions to isolate a condenser waterbox leak which contributed to operators using ON-100-003 which was not intended to be used to isolate the condenser box during flooding conditions. PPL corrected the diagram error, dewatered and repaired affected equipment, and entered this issue into their CAP (1282128). This finding was determined to be more than minor as it affected the Initiating Events cornerstone attribute of Procedure Quality and its objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during power operation. The finding was evaluated using Phases 1, 2, and 3 of the Significance Determination Process. The conclusion of the Phase 3 analysis was an estimated change in core damage frequency (CDF) of 1.1 E-6/yr (White) and an estimated change in large early release frequency (LERF) of 2.6E-7/yr (White). The finding is related to the cross-cutting area of Problem Identification and Resolution, Corrective Acton Program, in that PPL did not thoroughly evaluate problems such that the resolutions address the causes and extent of condition, as necessary. Specifically, PPL did not appropriately evaluate and correct a known issue in an off-normal procedure or adequately evaluate previous CW system waterbox manway gasket leaks to ensure that future occurrences could be prevented.
05000244/FIN-2010010-012010Q3GinnaDeliberately Providing Inappropriate Assistance During General Employee TrainingThe actions of the Bartlett supervisors violated Ginna Technical Specifications Section 5.4.1, which caused Constellation to be in violation of its license conditions and NRC requirements. This section states, in part, that written procedures shall be established, implemented and maintained to cover the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Constellation Nuclear Generation Fleet Administrative Procedure, CNG-TR-1.01-1010, General Employee Training, Revision 00100, Section 5.1, states, in part, that all personnel who are to become eligible, or who are to requalify for Unescorted Access Authorization to nuclear power plants, must satisfy specified requirements, including that all personnel are required to requalify annually by completing GET-PAT (Plant Access Training) and GET-FFD (Fitness for Duty) training modules. Section 3.3, states, in part, that a passing grade on a GET exam shall be equal to or greater than 80%. Section 4.6, states, in part, that no person, at any time, shall copy, share or otherwise compromise the integrity of any exam. Contrary to the above, in August 2009, Constellation identified that Bartlett supervisors were compromising the integrity of GET exams. Specifically, the Bartlett supervisors were providing assistance to contract Bartlett employees taking the exams in order to help them pass. Although Constellation was unaware that the Bartlett supervisors were compromising the integrity of GET exams, Constellation is responsible for the actions of its employees, including contracted employees. Because you are responsible for the actions of your employees, and because the violation involved deliberate misconduct, the violation was evaluated under the NRC\\\'s traditional enforcement process as set forth in Section 2.2.4 of the NRC Enforcement Policy.. Absent willfulness, this violation would be categorized as minor; however, due to the willfulness of this violation, the NRC has categorized it at Severity Level IV in accordance with the NRC Enforcement Policy. Because this violation was of very low safety significance and was entered into Ginna\\\'s corrective action program, this violation is being treated as a non-cited violation (NCV), consistent with Section 2.3.2 of the NRC Enforcement Policy (NCV 05000244/201001001, Deliberately Providing Inappropriate Assistance During General Employee Training).
05000387/FIN-2009004-052009Q3SusquehannaLicensee-Identified ViolationOn 25 August 2009, while performing pre-start checks to place Unit 2 RHR in suppression pool cooling, a field operator identified the ESW cooling water valves 211193 and 211194 to be unlocked and closed. These valves are required to be locked open to assure supply of cooling to a Unit 2 RHR room cooler and 2C RHR pump motor oil cooler. This was an identified violation of TS 5.4.1, and a violation of those procedures that must be implemented for operation of the unit and for the performance of maintenance as delineated in Regulatory Guide 1.33. Contrary to NDAP-QA-0302, System Status and Equipment Control, PPL did not use a proceduralized method to maintain status control of these valves and contrary to NDAP-QA-502, Work Control Process, these valves were not returned to the original design configuration following maintenance. PPL determined that the status control of these valves was most likely lost during the post-modification testing performed in late April 2009. Upon discovery, the valves were promptly aligned to provide cooling flow and the performance issue was captured in CR 1174837. Using a Phase III risk evaluation model, the region staff determined this finding to . be of very low safety significance (Green)
05000443/FIN-2009007-012009Q3SeabrookInadequate B EDG Design ChangeA self-revealing apparent violation of 10 CFR 50, Appendix B, Criterion III, Design Control was identified following a review of the identified causes for the failure of the B EDG jacket water cooling system on February 25, 2009. Specifically, NextEras failure to adequately control design changes implemented on the B EDG jacket water cooling system in January 2009 led to the failure of the gasket on flange JTR005 in the B EDG jacket water cooling system on February 25. The inspectors determined that this finding is more than minor because it is associated with the design control attribute of the Mitigating Systems Cornerstone and affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, design modification 08MSE11, intended to address flange JTR005 alignment and change the flange gasket design was inadequate and resulted in inoperability of the B EDG. In accordance with IMC 0609, Significance Determination Process, a Phase 3 risk analysis was performed and determined that the calculated delta CDF for the finding was 2.27E-6, which represents a low to moderate safety significance or White finding. The cause of the finding is related to the corrective action component of the cross-cutting area of problem identification and resolution because NextEra did not thoroughly evaluate problems in a timely manner such that resolutions address causes (P.1(c)). Specifically, NextEra did not adequately evaluate deficient conditions when addressing B EDG cooling water flange leaks, failed to adequately use readily available internal operating experience, and failed to adequately evaluate and correct the impact of engine vibrations on flange JTR005 integrity, contributing to a subsequent failure of the flange. (1R18
05000387/FIN-2009004-042009Q3SusquehannaFailure to Maintain Occupational Radiation Exposure As Low As Reasonably Achievable during the Unit 2 Refueling OutageA self-revealing, Green finding was identified that involved inadequate work planning relative to the in-vessel visual inspectionl inservice inspection (IWIIISI) of the reactor vessel that resulted in additional unplanned collective exposure contrary to aslow- as-is-reasonably-achievable (ALARA) controls. Specifically, the utilization of inexperienced workers to perform the various tasks involved in the IWI/ISI activity resulted in the additional collective exposure to perform this routine task. This finding was entered into PPL\'s Correction Action Program for resolution. This finding is more than minor because it resulted in unplanned, unintended collective exposure that was greater than 50 percent above the intended collective exposure and greater than 5 person-rem. Additionally, the performance deficiency adversely affected the radiation protection cornerstone objective. The inspectors assessed the finding in accordance with IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, and determined that the finding was of very low safety significance (Green) because the finding was due to ALARA work control planning and the 3-year rolling average collective exposure at Susquehanna was less than 240 person-rem (107 person-rem for 2005-2007). This finding was determined to have a cross-cutting aspect in the area of Human Performance, Resources, because PPL did not utilize sufficiently qualified personnel to assure occupational radiation safety requirements were met (H.2(b)). Specifically, PPL\'s use of inexperienced contract workers resulted in additional collective exposure that could have been avoided.
05000387/FIN-2009004-012009Q3SusquehannaFailure to Implement and Maintain the Fire Protection Program with Respect to the Use and Storage of Combustibles in the Control StructureThe inspectors identified a Green NCV of the Susquehanna, Unit 2 Operating License Condition 2.C.(3), Fire Protection for failure to administratively control combustible loading in an area on the 686\' elevation of the control structure. As a result, a normally locked storage area was discovered to contain numerous combustibles without designated detection, suppression, or a pre-fire plan. This issue was placed in PPL\'s corrective action program (CAP) and immediate corrective actions included the removal of some of the combustible materials and the assignment of hourly fire watches. The finding was more than minor because it was associated with the external factors attribute (fire) of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, PPL did not ensure that plant procedures controlled the use and storage of combustible materials and that a combustible loading analysis was maintained for a locked storage area fire zone in the control structure. The inspectors assessed this finding in accordance with IMC 0609, Appendix F, Fire Protection Significance Determination Process, and determined the finding to be of very low safety significance (Green) because the fire barrier between the safety-related equipment in the lower relay room and this storage area was being properly maintained and found in good physical condition. The finding was determined to have a crosscutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, because PPL did not implement a CAP with a low threshold for identifying issues (P.1(a)). Specifically, PPL had reasonable opportunities to identify the combustible loading issue on multiple occasions during access of the storage room
05000443/FIN-2009007-022009Q3SeabrookLicensee-Identified Violation10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires that measures be established to assure that conditions adverse to quality are promptly identified and corrected. In the case of significant conditions adverse to quality, the measure shall assure that the cause of the condition is determined and corrective action is taken to preclude repetition. The Florida Power and Light (FPL) Energy Quality Assurance Topical Report (QATR) was written pursuant to the above and states in Section A-6 that FPL implements a corrective action program to promptly identify and correct conditions adverse to quality. Procedure PI-AA-205 requires that significant conditions adverse to quality be resolved through corrective actions to prevent recurrence. Contrary to the above, NextEra Nuclear Oversight issued a finding on April 9, 2009, (QR 090-017) after determining that past corrective actions for B EDG turbocharger vibration issues were inadequate and have not been effective based on a past and recent history of increased vibration, bolt failures, bolt loosening, turbocharger related coolant piping weld failures, coolant system leaks and a failure in some instances to document these conditions in the condition reporting system. The failure to resolve long standing and increasing vibration and related issues for the B EDG constituted ineffective corrective action. The finding was more than minor because the ineffective action to resolve turbocharger vibrations impacted the availability and reliability of a mitigating system. Further, turbocharger vibration was causal to the B EDG failure on February 25, 2009 (reference Section 1R18 above). The finding had very low safety significance because it did not involve a loss of safety function or impact the safety function for a time greater than the allowed outage time in the technical specifications. While increased vibrations were causal to the February 25th B EDG failure, they were not the root cause since the cooling water system would have failed due the inadequate gasket design and irregular flange conditions. Further, the finding identified in QR 09-017 is separate from NRC Violation 20090701 since the inadequate design change resulting in the February 25 B EDG failure occurred during the discrete time period of January 29-31, 2009, whereas the corrective actions for the B EDG turbocharger vibrations have been ongoing for a longer period of time (reference 2001 CR 200107312). The inspectors determined that the Criterion XVI violation was licensee-identified. NextEra entered the issue into the corrective action program as CR 00194370.
05000387/FIN-2009004-032009Q3SusquehannaInadequate Corrective Actions Result in a Repeat Failure of Unit 1 HPCI Turbine Stop ValveThe inspectors identified a Green NCVof 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, in that PPL did not implement timely corrective actions to preclude repetition of a significant condition adverse to quality. Specifically, actions taken to address causes of the Unit 1 high pressure coolant injection (HPCI) stop valve failure to close in 2006 did not prevent the same HPCI stop valve from failing to close on August 18, 2009. In both cases, the stop valve failure to close rendered this single train HPCI system inoperable as it was unable to meet the 30 second injection response time as described in the design basis. Corrective maintenance was performed on the valve and the issue was entered into PPL\'s CAP. The finding is more than minor because it adversely affected the performance attribute of the Mitigating Systems cornerstone objective, to ensure the availability, reliability, and capability of equipment that respond to initiating events to prevent undesirable consequences. Specifically, a full closed stop valve indication resets the HPCI ramp generator via a lower limit switch. Without this reset, the governor is unprepared to restart the turbine from an idle state during a designed basis event. The inspectors assessed this finding in accordance with IMC 0609, Attachment 4, Phase 1 -Initial Screening and Characterization of Findings and determined the finding to be of very low safety significance because it did not result in an actual loss of safety function for greater than the Technical Specification allowed outage time. The finding was determined to have a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, because PPL did not take appropriate corrective actions to address safety issues in a timely manner, commensurate with their safety significance and complexity (P.1(d)). Specifically, PPL did not appropriately implement corrective actions following the 2006 failure of the HPCI stop valve.
05000387/FIN-2009004-022009Q3SusquehannaViolation of 10CFR55.3, Senior Reactor Operators Performing Licensed Duties While Not Qualified Due to Medical Examination IssuesPPL identified two examples of an apparent violation (AV), involving PPL Susquehanna, LLC (PPL) failing to ensure that individual license holders, on shift in the capacity of senior reactor operators (SROs), met the medical prerequisites required for holding a license prior to performing the duties of a licensed operator as required by 10 CFR 55.3. In one occasion in August 2009, an SRO failed a medical examination which identified a disqualifying condition, in that, the examination identified that the SRO\'s vision did not meet the health requirements stated in ANSI/ANS 3.4-1983; Section 5.4.5, Eyes. However, he performed the function of an SRO during three watches with a license that was not appropriately conditioned to require that corrective lenses be worn. In the second occasion, a different SRO performed licensed operator duties 52 times between April 1, 2009, and July 22, 2009, after the deadline for his biennial medical examination had passed. The medical examination may have identified an issue with the SRO\'s medical condition and general health that would have disqualified him from being authorized by a license. Upon discovery, PPL removed both individuals from watchstanding duties pending follow-up medical evaluations and, in the case involving the SRO whose failed medical examination resulted in a disqualifying condition, PPL requested a conditional NRC license to address the disqualifying medical condition. Both issues have been entered into PPL\'s corrective action program. Each example was evaluated independently using the traditional enforcement process because the failure to determine an operator\'s medical condition and general health has the potential to impact or impede the regulatory process. Specifically, medical certification and conditional licensing are used by the NRC to ensure health conditions will not adversely affect operator duties or performance. The finding was determined to have a cross-cutting aspect in the area of Problem Identification and Resolution, Operating Experience, because PPL did not systematically collect, evaluate, and communicate relevant external operating experience (P.2(a)). Specifically, PPL failed to evaluate NRC Information Notice 2004-20 for medical examination issue applicability in accordance with their operating experience review program as evidenced by the 2008 SL-IV NCV (NRC IR 50-387 & 50-388 2008302-01), for an initial licensed operator application submitted to the NRC with a disqualifying medical condition, as well as these two events in July and August of 2009.
05000317/FIN-2008502-012009Q1Calvert CliffsFailure to maintain emergency plans (Section 1EP4)Constellation identified an apparent violation associated with the failure to meet emergency preparedness planning standard 10 CFR 50.47(b)(4). For the period of August 31, 2005, until April 10, 2008, the emergency action level (EAL) tables fission product barrier matrix contained an inaccurate threshold associated with identifying the potential loss of the containment barrier. The error was not identified by Constellation prior to implementation of the revised EAL table. Constellation evaluated this condition and took prompt actions to correct the inaccurate EAL. The finding was more than minor because it was associated with the procedure quality (EAL changes) 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. This finding is associated with risk significant planning standard 10 CFR 50.47(b)(4) and 10 CFR 50 Appendix E, IV.B, Assessment Actions. The NRC determined that the finding is preliminarily White, a finding with low to moderate safety significance, that may require additional NRC inspection. Using Emergency Preparedness Significance Determination Process, Inspection Manual Chapter (IMC) 0609, Appendix B, Sheet 1, Failure to Comply, the finding was determined to be a risk significant planning standard (RSPS) problem and an RSPS degraded function (White). Additionally, IMC 0609, Appendix B contains an example of Loss of RSPS Function for 10 CFR 50.47 (b)(4); more than one Alert, or any Site Area Emergency would not be declared that should be declared, resulting in a White finding. There is no crosscutting aspect associated with this finding since it is not reflective of current licensee performance. (Section 1EP4)
05000336/FIN-2009002-022009Q1MillstoneContainment Penetration Not Fully Closed During Fuel MovementThe inspectors reviewed the LER and Dominions apparent cause evaluation of the event. The inspectors determined that the failure to completely close valve 3FWS*V861 was not within Dominions ability to foresee and correct and was not a performance deficiency. Valve 3FWS*V861 does not have position indication. The operator who closed the valve and the operator who performed the independent verification did not have an alternate means to verify that the valve was completely closed. Additionally, when the valve was identified to be leaking while filling the SG, it was only able to be completely closed when mechanical leverage was applied. A review of previous work orders (WOs) revealed that the valve was replaced like for like in 2007 due to seat leakage. A different packing was used which required more force to consolidate. Also, the packing gland was torqued per procedure when, previously, the packing was tightened using good mechanical practices. Because of these changes, more force would be required to operate the valve; however, there was no indication in the 2007 WO that the valve was difficult to operate. A review of the CRs associated with this valve did not indicate any previous problems in operating the valve. Because of these details, the inspectors concluded that the inability to fully close valve 3FWS*V861 could not have reasonably been avoided or detected by Dominions quality assurance program or other related control measures. The inspectors also performed a Phase1 SDP analysis and determined the violation to be of very low safety significance (Green). Dominions corrective actions included closing the valve, entering the issue into their corrective action process (CR 117527), changing the position verification procedure to specify physical verification versus visual, and plans to modify the valve during the next refueling outage to improve the stroking function. Therefore, in accordance with Section VII.B.6 of the Enforcement Policy, the NRC has chosen to exercise enforcement discretion and not issue a violation for this issue.
05000336/FIN-2009002-012009Q1MillstoneLicensee-Identified ViolationTS 3.0.4 states, in part, that entry into an operational mode shall not be made when the conditions for the Limiting Condition for Operation are not met and the associated action requires a shutdown if they are not met within a specified time interval. Contrary to this, from November 22, 2008 at 17:46 until November 24, 2008 at 03:46, Unit 3 did not meet the conditions for TS 3.7.1.2, AFW system due to an isolated steam trap, and transitioned from mode 3 to mode 1. Dominion restored the AFW system to operability and entered the issue into their corrective action process, CR120030. This finding is of very low safety significance because the finding does not involve a loss of system safety function or a loss of safety functions of a single train for greater than its TS allowed outage time
05000293/FIN-2008005-032008Q4PilgrimApplication of TS 4.0.3 When It Was Discovered That a Surveillance Had Never Been PerformedOn June 25, 2007, Entergy informed the Nuclear Regulatory Commission (NRC) staff that it had missed a Technical Specification (TS) surveillance requirement to perform time response testing of four Reactor Protection System (RPS) scram contactors. During their review, Entergy identified that the four RPS scram contactors had never been tested. Entergy evaluated the operability of the RPS system and determined that the system remained operable and that TS 4.0.3, Surveillance Requirement Applicability, would allow a delay period up to the limit of the specified surveillance frequency. The inspectors questioned Entergy regarding the applicability of TS 4.0.3 given that the time response test had never been performed on the RPS scram contactors, as compared to missing a surveillance test following satisfactory initial system baseline testing that originally showed system operability. As a result of this implementation of TS 4.0.3, Entergy failed to take action in accordance with TS 3.1, Reactor Protective System, which constituted a violation of NRC requirements. Entergy later modified the applicable surveillance procedures and successfully response time tested all RPS scram contactors. In Task Interface Agreement (TIA) 2008-004, the NRC staff disagreed with Entergy on its implementation of TS 4.0.3 and considered Entergy to have been in violation of TS 3.1, Reactor Protection System, as a result. Discretion is warranted because: (1) licensee current basis documents do not specifically clarify the distinction between a missed surveillance and one that has never been performed, (2) the licensee subsequently completed the surveillance testing satisfactorily, and (3) the issue was of very low safety significance, since when the correct testing was accomplished, it was completed satisfactorily indicating that the timing of the reactor scram function was not negatively impacted. Accordingly, the NRC staff is exercising enforcement discretion for the TS 3.1 violation in accordance with Section VII.B.6 of the NRC Enforcement Policy and no violation will be issued.
05000293/FIN-2008005-022008Q4PilgrimProcedural Error Resulting in Unplanned RCIC IsolationA self-revealing Green non-cited violation (NCV) of TS 5.4.1, Procedures , was identified for a procedure which resulted in an inadvertent isolation of the Reactor Core Isolation Cooling (RCIC) system. Specifically, the procedure was previously revised and a step was inadvertently placed out-of-order. The procedure incorrectly instructed technicians to remove relay contact blockers, or boots , before clearing an isolation signal which resulted in the system isolation. Entergy entered this issue into their corrective action program. Corrective actions will include revising this procedure and reviewing other surveillance procedures that had been revised at the same time. This finding was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone. Isolating the RCIC system affected the cornerstone objective of ensuring the availability of systems that respond to initiating events to prevent undesirable consequences. The inspectors evaluated this finding using IMC 0609.04, Phase 1 Initial Screening and Characterization of Findings . This finding was of very low safety significance because it was not a design or qualification deficiency, did not represent a loss of system safety function, did not represent an actual loss of a single train system for greater than the Technical Specification allowed outage time, and was not made risk-significant because of external events. The inspectors determined that this finding had a cross-cutting aspect in the area of Human Performance, Resources, because Entergy did not ensure that the procedure was complete and accurate
05000293/FIN-2008005-012008Q4PilgrimFailure to Conduct a Risk Assessment for Emergent Maintenance on the High Pressure Coolant Injection SystemThe inspectors identified a Green non-cited violation (NCV) of 10 CFR 50.65(a)(4) for Entergys failure to conduct a risk assessment for emergent maintenance on the High Pressure Coolant Injection (HPCI) system injection valve. Specifically, the failure to conduct a risk assessment resulted in Entergy not recognizing an increase in risk to a Yellow condition, and therefore no risk management actions were taken. Entergy entered this issue into their corrective action program. Corrective actions will include revising attachments in Entergys Technical Specification requirements procedure to perform a risk review as a result of emergent maintenance activities. This finding was more than minor because Entergy failed to consider the unavailability of a risk significant system where the outcome of the risk assessment would have been a change in a risk management category. The inspectors conducted an evaluation in accordance with IMC 0609, Significance Determination Process, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process. The finding was determined to be of very low safety significance (Green) because the Incremental Core Damage Probability Deficit for the timeframe that HPCI was removed from service was significantly less than 1E-6. The inspectors determined that this finding had a cross-cutting aspect in the area of Human Performance, Decision Making, because Entergy did not use a systematic process to make a risk-significant decision when faced with an unexpected plant condition
05000277/FIN-2008405-012008Q1Peach BottomExtent of Condition and Corrective Action Program Usage for Operator Watch Standing Issues. (Section 4OA2.2)On September 10, 2007, representatives of WCBS-TV (New York City) contacted the NRC stating that they possessed videotapes of inattentive security officers at the Peach Bottom Atomic Power Station (PBAPS). Based upon this information, the NRC Region I Regional Administrator directed implementation of enhanced inspection oversight of security activities by the resident inspectors at PBAPS, and verbally informed Exelon management of the information received. Exelon commenced an internal investigation based upon this information. On September 19, 2007, WCBS-TV shared the videotapes with the NRC staff, which viewed the videos and determined that the situation warranted an Augmented Inspection. An Augmented Inspection Team (AIT) completed an inspection at PBAPS from September 21 through 28, 2007. The team concluded that Exelons prompt compensatory measures and corrective actions in response to the videotaped inattentive security officers at PBAPS were appropriate and ensured the stations ability to satisfy the Security Plan. However, the team determined that the security officer inattentiveness affected the defense-in-depth strategy, and that security force supervisors were not effective in ensuring unacceptable behavior was promptly identified and corrected. The AIT inspection results were published on November 5, 2007 in NRC Inspection Report 2007404 (ADAMS accession number ML073090061). On October 4, 2007, Exelon sent a letter to the NRC Region I Regional Administrator (ML072850708) which described their completed actions and initiatives to address the issues identified by the AIT. These initiatives included terminating the current security contract with their contractor and transitioning to a proprietary security force. Exelon also described plans to complete a root cause analysis of the security officer inattentiveness, identify corrective actions, and perform safety conscious work environment (SCWE) surveys of the Peach Bottom Security organization. On October 19, 2007, the NRC issued a Confirmatory Action Letter (CAL) to confirm Exelons commitments to assure that security officers remain attentive at all times while on duty (ML072920283). Exelon completed their root cause analysis in October 2007 and identified several causal factors related to the security officer inattentiveness issues and specific corrective actions to address the causal factors. One of the corrective actions was to perform a systematic SCWE assessment of all work groups at PBAPS (including the Security work group) based on an integrated review of information from the PBAPS Corrective Action Program (CAP), Employee Concerns Program (ECP), publicly available NRC allegation statistics, and SCWE surveys. The NRC conducted an AIT follow-up inspection from November 5 through 9, 2007, to review Exelons root cause analysis report and their planned corrective actions. The inspectors concluded the corrective actions were appropriate. With regard to the security officer inattentiveness issue, the AIT follow-up inspection identified a finding regarding Exelons failure to maintain the minimum required number of available security officer responders and an associated failure to implement an effective behavior observation program. The AIT follow-up inspection determined that the finding was related to SCWE because it involved security supervisors who did not encourage the free flow of information related to raising safety concerns, and who did not respond to security officer safety concerns in an open, honest, and non-defensive manner. The NRC determined the finding was of low to moderate safety significance (White). This was documented in a subsequent letter to Exelon dated February 12, 2008 (ML080440012). The AIT follow-up inspection results were issued in NRC Inspection Report 2007405 (ML073550590) dated December 21, 2007. Region I determined that Exelons actions to address the PBAPS inattentive security officer issues and their plans to transition to a proprietary security force warranted additional inspection and oversight beyond that specified in the Reactor Oversight Process (ROP) baseline inspection program. On November 28, 2007, the Regional Administrator recommended, through a Deviation Memorandum to the NRCs Executive Director for Operations (EDO), that PBAPS warranted additional inspection resources (ML073320344). One additional inspection activity was to conduct inspections of Exelons efforts to address SCWE issues, including a review of the results of SCWE surveys conducted at the site. The EDO approved this request on November 28, 2007. Consistent with the planned corrective actions from their root cause evaluation, Exelon arranged for a third party to conduct a survey of the SCWE at PBAPS. The survey was in the form of a series of questions provided to the staff in January 2008. The survey was completed and the results provided to Exelon in February 2008. A separate SCWE survey of the security organization was also conducted during November 2007. Exelon utilized the survey results to complete a self-assessment of the SCWE at PBAPS. In accordance with the NRC Action Matrix Deviation Memorandum, this inspection was conducted onsite from March 24 though 28, 2008, to review Exelons self-assessment of the PBAPS SCWE, including a review of the results of their SCWE survey. Other completed Deviation Memorandum activities included a security organization performance monitoring inspection (ML080720038) and a root cause corrective action evaluation (ML081090161).
05000277/FIN-2007405-012007Q4Peach BottomSecurityInattentive security officers and the staff determination that the licensee failed to effectively implement its behavior observation program
05000334/FIN-2006009-012006Q3Beaver ValleyFailure to Provide Adequate Corrective Actions to a PREVIOUSLY-IDENTIFIED Emergency Preparedness Exercise WeaknessThe inspector identified an apparent violation for the licensees failure to provide adequate corrective actions to a previously-identified emergency preparedness exercise weakness. 10 CFR 50, Appendix E, Section IV.F.2.g, requires that any emergency preparedness weakness or deficiency that is identified shall be corrected. An apparent violation of that requirement was identified involving the licensees failure to adequately correct a performance deficiency in the area of Protective Action Recommendation development identified by the NRC in the May 2004 evaluated exercise. Specifically, in the 2006 exercise, the licensee dose assessment team did not adequately consider plant-specific situational information to develop the best dose projection estimate achievable at the time, which was an apparent repeat of a problem exhibited in the 2004 exercise. The licensees 2006 performance regarding the development of a dose projection without a sound technical basis demonstrated that the licensee had implemented ineffective corrective actions for the 2004 inspection finding. This finding is greater than minor because it is associated with the Emergency Response Organization Performance attribute and affected the objective of the Emergency Preparedness Cornerstone to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. The Emergency Preparedness SDP, Section 5.3, Failure to Correct Drill or Exercise Weaknesses, was used to evaluate the significance of this finding. Because the licensees corrective actions were not adequate and the weakness involved a Risk Significant Planning Standard area that is not covered by performance indicators (i.e., 10 CFR 50.47(b)(9)), a loss of planning standard function was assessed, resulting in a White finding.
05000336/FIN-2000017-032001Q1MillstoneN/AThe weaknesses with respect to the prioritization and evaluation of problems and corrective action effectiveness, as reflected in NRC findings identified over the past year, represent a substantive cross-cutting issue. Most notable was the failure to promptly address anomalous indications in the governor for the Unit 2 turbine-driven auxiliary feedwater (TDAFW) pump in August 2000. Further, after the failure of the TDAFW pump, the evaluation of the problems with the governor was not thorough and did not address other contributors to the failure. Other examples included the failure to implement timely corrective actions to ensure correct voltage regulator settings for a Unit 2 emergency diesel generator, which resulted in a second identical occurrence one year later; and the failure to incorporate a corrective action to prevent recurrence of the inoperability of the Unit 2 C high pressure safety injection pump.
05000247/FIN-2000007-112000Q2Indian PointN/AIn the operations and engineering support areas, corrective actions to resolve known problems were untimely or incomplete. While the problems were of very low risk significance, some of these procedure and equipment problems caused unnecessary challenges to the operators and delays in achieving cold shutdown after the event. These problems included difficult procedural guidance for aligning pressurizer spray flow, non-functional steam generator leak monitoring (N-16) recorder, high pressure steam dump system deficiencies, and the lack of gas turbine Nos. 2 and 3 remote start capability (Section 4OA5).
05000220/FIN-2000003-012000Q2Nine Mile PointN/AThe licensee was effective at identifying and tracking problems. The team did not identify any issues that were not already being tracked by the licensee. However, the team identified seven examples, involving both units, where issues involving equipment failures documented in the Problem Identification process had work orders to conduct the repairs, but no Deviation/Event Reports (DERs) were written, as required by the DER procedure. The failure to initiate DERs is a violation of the Nine Mile Point, Units 1 and 2 Technical Specifications related to procedure implementation, and is being treated as a Non-Cited Violation. The violation was not assessed using the Significance Determination Process, as it did not impact one of the cornerstones; however, it provides substantive information relative to the cross cutting issue of problem identification and resolution. (Section 4OA2.1)
05000220/FIN-2000003-022000Q2Nine Mile PointN/ABased on the sample reviewed, the licensees resolution of problems was adequate. Items entered into the corrective action program were properly classified and prioritized for resolution. The evaluations and root cause analyses reviewed were of good depth and quality. Although the team found a few instances where the evaluation of some Deviation/Event Reports had not been completed within the specified time, the team did not identify any instance that represented a significant concern. The licensee was already aware of these delays and was taking action to correct the problem. (Section 4OA2.2)
05000220/FIN-2000003-032000Q2Nine Mile PointN/AThe prescribed corrective actions for the Deviation/Event Reports reviewed, appeared appropriate to correct the problems. The backlog of corrective actions was being managed well and the team did not identify any backlogged action that represented an adverse effect on plant risk. (Section 4OA2.3)
05000220/FIN-2000003-042000Q2Nine Mile PointN/AIssues identified in the Quality Assurance Audits and Self Assessment Reports reviewed had been properly entered into the Deviation/Event Report process. Some assessment findings resulted in recommendations and identification of issues not previously included in the DER process. Based upon a review of a sample of meeting minutes of the Station Oversight Review Committee and the Corrective Action Review Board (CARB), and observation of some CARB meetings, the team found that the committees provided good oversight of the Corrective Action Program. (Section 4OA2.4)
05000247/FIN-2000007-062000Q2Indian PointN/AThe control room operators did not enter significant plant items, such as event declaration and implementation of the emergency plan, in the control room logs, as required by Con Edison procedures. This procedure violation was a problem that was also noted for the August 31, 1999, loss of bus event. The failure to enter significant items into the control room logs was determined to be a non-cited violation. Although this issue does not affect any of the seven cornerstones (Attachment 1), it was considered important because prior corrective actions were not effective (Section 4OA2.3).
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