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05000293/FIN-2014005-012014Q4PilgrimModification to the Spent Fuel Pool Cask Area without Prior NRC ApprovalSeverity Level lV. The inspectors identified a Severity Level lV NCV of Title 10 of the Cod of Federal Regulations (10 CFR) 50.59 in that Entergy did not obtain a license amendment prior to implementing a change to the plant that required a change to technical specification (TS). Specifically, Entergy removed the energy absorbing pad described in TS 4.3.4.b, Design Features, and Updated Final Safety Analysis Report (UFSAR) section 10.3.6, Consequences of a Dropped Fuel Cask, without receiving prior NRC approval. Entergy submitted a License Amendment Request (LAR) supplement to the NRC on September 11, 2014, to remove the energy absorbing pad language from TS, and performed an extent of condition review on previous engineering changes and prohibited placing a cask in the spent fuel pool (SFP) until receiving NRC approval for a change to TS 4.3.4.b. The inspectors determined that Entergy did not perform an adequate 10 CFR 50.59 evaluation and obtain a license amendment prior to removing the SFP energy absorbing pad. The inspectors determined this was a performance deficiency that was within Entergys ability to foresee and correct and should have been prevented. Because the issue had the potential to affect the NRCs ability to perform its regulatory function, the inspectors evaluated this performance deficiency in accordance with the traditional enforcement process. Using the Enforcement Manual, the inspectors determined that the violation was a Severity Level IV (a 10 CFR 50.59 violation that resulted in conditions that required NRC approval before implementation) violation. Because this violation involves the traditional enforcement process and does not have an underlying technical violation that would be considered more-than-minor, inspectors did not assign a cross-cutting aspect to this violation in accordance with IMC 0612, Appendix B.
05000354/FIN-2013003-012013Q3Hope CreekInadequate Preventive Maintenance Replacement Schedule for Agastat Control RelaysA self-revealing Green NCV of Technical Specifications (TS) 6.8.1, Procedures, was identified because PSEG failed to establish an appropriate preventive maintenance (PM) schedule for Tyco/Agastat General Purpose (GP) control relays. Specifically, the evaluation PSEG performed to revise the relay replacement periodicity from 22 years to 40 years neither adequately addressed available relay references nor all applicable failure mechanisms. As a result, high pressure coolant injection (HPCI) failed to respond to logic system actuation signals during surveillance testing on April 8, 2013. PSEGs immediate corrective actions included replacing failed relays and placing the issues in the corrective action program (CAP). Additionally, PSEG plans to revise the replacement frequency and to replace other Tyco/Agastat GP control relays of high safety significance, as identified in their extent of condition review. This finding was more than minor because it was associated with the equipment performance attribute of the mitigating systems cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure of a control relay caused the HPCI system to fail to automatically actuate during testing, and the HPCI system was unexpectedly declared inoperable. The inspectors evaluated the finding in accordance with IMC 0609, Significance Determination Process, issued June 2, 2011, and determined the finding is of very low safety significance (Green) following a detailed risk evaluation. No cross-cutting aspect was assigned to this finding because PSEG decisions made with regard to evaluating the PM replacement periodicity were made more than 3 years ago and a PM Ownership Committee has since been created to review PM change evaluations; therefore, this performance deficiency is not reflective of current plant performance.