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05000482/FIN-2018003-022018Q3Wolf CreekFailure to Submit a Licensee Event Report for a Condition Prohibited by Technical SpecificationsThe inspectors identified a Severity Level IV non-cited violation of 10 CFR 50.73(a)(2)(i)(B), because the licensee did not provide a written licensee event report (LER) to the NRC within 60 days. Specifically, the licensee did not provide a written LER to the NRC within 60 days of identifying a condition prohibited by the plants Technical Specifications associated with inoperability of control room emergency ventilation system train B for longer than its Technical Specification allowed outage time. As a result, the NRCs ability to regulate was impacted.
05000482/FIN-2018003-012018Q3Wolf CreekFailure to Correct Degraded Performance of a Safety-Related Tornado DamperThe inspectors identified a Green non-cited violation of 10 CFR Part 50, Criterion XVI, Corrective Action, for the licensees failure to promptly correct a condition adverse to quality associated with a safety-related tornado damper. Specifically, damper GTD0002 failed tests in 2012 and 2015, and following maintenance on the damper in 2017, again failed its next as-found test on February 8, 2018. As a result, this safety-related tornado dampers ability to close during a design basis tornado event was adversely impacted.
05000336/FIN-2018003-012018Q3MillstoneFailure to Assure that Safety-Related Service Water Piping Conformed to the Procurement DocumentsThe inspectors identified a Green finding and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion VII, Control of Purchased Material, Equipment, and Services, when the licensee failed to identify that a replacement service water pipe spool (JGD-1-25) was not in conformance with the American National Standards Institute (ANSI) B31.1 code, a condition of the purchase order, and was installed in the plant.
05000244/FIN-2018002-012018Q2GinnaIncorrect Scaling Factors in Reactor Vessel Level Monitoring System Instrumentation Uncertainty CalculationThe inspectors identified a Green non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion III, Design Control, when Exelon failed to ensure that adequate design control measures existed to verify the adequacy of the Reactor Vessel Level Monitoring System (RVLMS) uncertainty calculation. Specifically, Exelon failed to identify errors in the RVLMS uncertainty calculation which resulted in a reasonable doubt of operability for the system after a temporary modification was implemented.
05000352/FIN-2018002-022018Q2LimerickUnit 1 Core Spray Pump Failed to Start Resulting in Condition Prohibited by Technical SpecificationsThe inspectors identified a Severity Level IV NCV of Unit 1 Technical Specification 3.5.1 because one core spray subsystem was inoperable from July 17, 2017, until October 5, 2017. Specifically, the Unit 1 C core spray pump did not start upon demand during testing and was declared inoperable because the pumps associated circuit breaker closing charging springs were not charged.
05000352/FIN-2018002-012018Q2LimerickFailure to Conduct Adequate Radiation Surveys and Evaluate Potential Radiological HazardsA self-revealing Green finding and associated NCV of 10 CFR 20.1501, Surveys and Monitoring: General, was identified when Exelon failed to perform adequate loose surface contamination surveys of the Unit 1 RWCU isolation valve room prior to authorizing work to hang shadow shielding near the HV-051-1F017A valve, and also during the conduct of the work itself. Exelon also did not identify very high levels of loose surface contamination on overhead piping and structures which surrounded the work area. This failure resulted in unplanned internal radiation exposures to three personnel, including an RPT who was assigned to monitor the radiological aspects of the work.
05000353/FIN-2018001-012018Q1LimerickFailure of Emergency Diesel Generator Lube Oil Pipe Nipple FittingA self-revealed Green non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, and LGS Unit 2 technical specification (TS) 3.8.1.1 was identified when Exelon failed to correct a degraded lube oil pipe nipple fitting on the D22 emergency diesel generator (EDG) when maintenance was performed to address leakage which caused inoperability of the EDG for greater than its TS allowed outage time.
05000352/FIN-2018001-022018Q1LimerickEmergency Diesel Generator Combustion Air OverheatingA self-revealed Green NCV of LGS Unit 1 TS 6.8.1 and TS 3.8.1.1 was identified when Exelon failed to properly maintain an operating procedure to maintain a fail-safe design feature for the EDGs which led to the D12 EDG combustion air overheating and caused the EDG to be inoperable for greater than its TS allowed outage time.
05000317/FIN-2018001-012018Q1Calvert CliffsFailure to Conduct Adequate Radiation Surveys and Evaluate Potential Radiological HazardsAself-revealed Green non-cited violation(NCV)of Title 10 Code of Federal Regulations(10 CFR) 20.1501, Surveys and Monitoring: General, was identified when Exelon failed to perform adequate surveys of the 11 reactor coolant pump bay area following the aggregation of 25 high dose-rate in-core detectors in one area of the flooded refueling cavity, which is adjacent to the pump bay. Surveys were not performed as required after radiological conditions changed and radiological hazard mitigation measures, such as locking and controlling access in accordance with Exelon procedures, were not implemented, resulting in accessible dose-rates of up to 2,000 millirem per hour(mrem/hr)in the pump bay
05000317/FIN-2017004-012017Q4Calvert CliffsInadequate Assessment of Fire Brigade Performance During an Announced Fire DrillAn NRC-identified Green non-cited violation (NCV) of Calvert Cliffs Nuclear Power Plant Renewed Facility Operating License DPR-53, DRP-69, Condition E, was identified for Exelons failure to adequately assess the performance of the fire brigade during an announced fire drill. Specifically, Exelon failed to properly assess the command and control performance of the fire brigade leader (FBL) which resulted in the fire drill being improperly evaluated as having met the assessment criteria. The inspectors determined that Exelons failure to properly assess fire brigade performance in accordance with OP-AA-201-003, Fire Drill Performance, Revision 16, was a performance deficiency. Exelon has entered this issue into their corrective action program (CAP) as action request (AR) 04094397The inspectors reviewed IMC 0612, Appendix B, Issue Screening, issued on September 7, 2012, and determined the issue is more than minor because it was associated with the protection against external events (fire) attribute of the Mitigating Systems cornerstone and adversely affected its objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, failure to properly evaluate the performance of the fire brigade and correct identified deficiencies adversely affects the fire brigades ability to protect against the effects of a fire. In accordance with IMC 0609, Attachment 4, Initial Characterization of Findings, issued on October 7, 2016, and IMC 0609, Appendix A, The Significance Determination Process for Findings at Power issued on June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) since it involved fire brigade training requirements, the fire brigade demonstrated the ability to meet the required times for fire extinguishment for the fire drill scenario, and the finding did not significantly affect the fire brigades ability to respond to a fire. The inspectors determined that the finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Self-Assessment, because Exelon did not conduct a self-critical and objective assessment of the fire brigades performance. Specifically, Exelon failed to conduct a self-critical and objective assessment of the FBLs performance during the fire drill described above.
05000423/FIN-2017004-012017Q4MillstoneFailure to Maintain RCS Pressure during Solid Plant CooldownA self-revealed NCV of very low safety significance (Green) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified wherein, on October 13, 2017, Dominion failed to accomplish an activity affecting quality, Plant Cooldown, in accordance with approved procedures. Specifically, during solid plant cooldown, over the course of 18 seconds, reactor coolant system (RCS) pressure increased from 350 psia to 472 psia, which exceeded the limit of 435 psia established by Attachment 1, RCS Cooldown Curves, of operating procedure OP 3208, Plant Cooldown, Revision 028. Dominion operations staff took prompt actions to restore RCS pressure within limits and completed a required engineering evaluation to determine the effect of the out of limit condition on the structural integrity of the RCS. Dominion entered this issue into the corrective action program (CAP) as condition report (CR) 1080842 and completed a root cause evaluation of the event. This finding was determined to be more than minor because it adversely affected the configuration control attribute of the Barrier Integrity cornerstone objective to provide reasonable assurance that physical design barriers (RCS) protect the public from radionuclide releases caused by accidents or events. The inspectors evaluated the finding using IMC 0609, Appendix G, Attachment 1, Shutdown Operations Significance Determination Process Phase 1 Initial Screening and Characterization of Findings, and determined the finding to be of very low safety significance (Green). The finding had a cross-cutting aspect in the area of Human Performance related to Work Management because the licensee did not implement an adequate process of planning, controlling, and executing work activities such that nuclear safety was the overriding priority. Specifically, Dominion failed to recognize the increased risk of isolating instrument air during solid plant operations. (H.5)
05000353/FIN-2017004-012017Q4LimerickUnplanned HPCI Inoperability Due to Isolating All Suction Sources During Post-Maintenance Te s t i n gThe inspectors identified a self-revealing Green non-cited violation (NCV) of 10 Code of Federal Regulations (CFR) 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for Exelons failure to adequately establish post-maintenance testing instructions for a relay replacement for the Unit 2 high pressure coolant injection (HPCI) system. Specifically, implementing the instructions caused a loss of all suction sources and unplanned inoperability of the Unit 2 HPCI system. Exelon initiated a condition report (issue report (IR) 4036417) and conducted a technical human performance (THU) workshop with the maintenance planning department to increase awareness of THU tools and added THU behavior discussion topics to weekly maintenance planning department all hands meetings.This finding is more than minor because it adversely affected the configuration control attribute of the mitigating systems cornerstone to ensure the availability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, HPCI was made inoperable when it was planned to remain operable. Using IMC 0609, Appendix A, Exhibit 2, the inspectors determined that this finding required a detailed risk assessment because it represented a loss of the single train systems function. The Regional Senior Reactor Analyst performed a detailed risk evaluation using the Limerick Generating Station (LGS) Unit 2 Standardized Plant Analysis Risk Model. The issue was modeled with a HPCI failure to start due to the suction valves being closed. The change in core damage frequency per year was determined to be in the low E-9 range due to the very short duration that both suction sources were isolated. Therefore the issue was determined to be of very low safety significance (Green). The inspectors determined that this finding has a cross-cutting aspect in the area of Human Performance, Work Management, because the work process did not ensure individuals were aware of plant status and the changes in the plan of work were not effectively implemented. (H.5)
05000352/FIN-2017003-022017Q3LimerickLicensee-Identified ViolationLGS Unit 1 Renewed Facility Operating License, NPF- 39, and LGS Unit 2 Renewed Facility Operating License, NPF- 85, License Condition 2.C.(3) requires , in part, that Exelon Generation Company shall implement and maintain all provisions of the approved Fire Protection Program as described in the UFSAR. LGS Unit 1 and Unit 2 UFSAR Chapter 9A requires compliance with Branch Technical Position, Chemical Engineering Branch 9.5- 1, guideline C.5.b(1), to limit fire damage so that one train of systems necessary to achieve and maintain cold shutdown conditions from either the control room or emergency control station can be repaired within 72 hours. Contrary to the above, from July 2014 to December 2016, an unanalyzed condition existed in which an abnormal ESW system alignment placed two Fire Areas in noncompliance with the FSSD analysis described in the UFSAR. Specifically, in July 2014, ESW to RHRSW flow return valve, HV -011 -015A was de- energized and tagged closed following ESW system testing. With on ly one RHRSW return path available to the A ESW loop, a postulated fire in Fire Area 12 or Fire Area 18 could cause a single spurious valve operation of either spray pond bypass valves HV -012- 031A or HV -012 -031C, when the ESW system is aligned in the spray pond winter bypass mode. This condition would result in no return flow path for the A loop of ESW, which would in turn result in loss of cooling water to EDGs aligned to the A ESW cooling loop. The affected EDGs would be inoperable until the ESW system could be realigned to provide cooling water flow. This condition coupled with a loss of offsite power assumed in FSSD analysis would result in a loss of power to SRVs needed to transition both LGS units from hot shutdown conditions to cold shutdown conditions. Following the depletion of station batteries after 4 hours, until offsite power is assumed to be restored after 72 hours, direct current power would be lost to SRVs that are necessary to reduce plant pressure low enough to place the shutdown cooling system into service and establish cold shutdown plant temperatures. The failure to have a cold shutdown repair that could be implemented within 72 hours in accordance with the FSSD analysis described in the UFSAR, was a performance deficiency. 24 The performance deficiency was more than minor because it was associated with the protection against external factors (fire) 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. The inspectors determined that the finding was of very low safety significance (Green ), based on IMC 0609, Appendix F, Fire Protection Significance Determination Process , Attachment 1, Part 1: Fire Protection Significance Determination Process Phase 1 Worksheet, dated September 2013. The finding screened to Green based upon task 1.3.1 screening question A, since the inspectors determined that for conditions evaluated by Appendix F the reactors were able to reach and maintain hot shutdown. Specifically, LGS Units 1 and 2 would have been able to achieve and maintain hot shutdown during the period the unanalyzed condition existed. This would have been accomplished by using HPCI and SRVs for pressure and level control. Both units would have been capable of maintaining hot shutdown conditions with postulated fire damage until offsite power could be restored. Because this issue was of very low safety significance (Green) and Exelon entered the issue into the corrective action program as IR 3955705, this finding is being treated as a licensee identified NCV , consistent with Section 2.3.2.a of the Enforcement Policy.
05000353/FIN-2017003-012017Q3LimerickOperational Condition Mode Change from Startup to Run was Made with RCIC InoperableThe inspectors identified a Green NCV of Unit 2 technical specification (TS) 3.0.4, when Exelon changed the operating condition of Unit 2 from mode 2 (startup) to mode 1 (run) with reactor core isolation cooling ( RCIC ) inoperable for surveillance testing. Specifically, the TS 3.7.3 limiting condition for operation (LCO) for RCIC was not met, a mode change from startup to run was made, and none of the allowances, TS 3.0.4.a, TS 3.0.4.b, or TS 3.0.4.c, were met to allow the mode change in that condition. Exelon entered this issue into the corrective action program with issue report (IR) 4057128. The inspectors determined that the change in operating condition of LGS Unit 2 from startup to run with RCIC inoperable was reasonably within Exelons ability to foresee and correct and should have been prevented and therefore was a performance deficiency. This finding is more than minor because it adversely affected the configuration control attribute of the mitigating systems cornerstone to ensure the availability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, RCIC was inoperable during the time it was required to be operable, i.e. the mode change from startup to run. Additionally, this finding was similar to example 2.g of IMC 0612, Appendix E, in that a mode change was made without all required equipment being operable. Using IMC 0609, Appendix A, Exhibit 2, the inspectors determined that this finding was of very low safety significance (Green). Specifically, the finding did not represent a loss of function and did not represent the loss of a single train for greater than technical specification allowed outage times or greater than 24 hours. The inspectors determined that this finding has a cross - cutting aspect in the area of Human Performance, Documentation, because with respect to TS 3/4.7.3 Exelon did not create and maintain complete and accurate documentation of the correct usage of TS 3.0.4 that was more fully explained in the applicable safety evaluation. (H.7)
05000336/FIN-2017003-012017Q3MillstoneInadequate Procedure Results in Inadvertent Lowering of Spent Fuel Pool LevelA self-revealing NCV of very low safe ty significance (Green) of Technical Specification (TS) 6.8, Procedures, was identified because Dominion did not adequately establish Operating Procedure (OP) 2305, Spent Fuel Pool Cooling and Purification System. Specifically, from initial issuance until June 20, 2017, the procedure did not direct operators to verify the primary demineralizer bypass valve was closed while lining up to fill the spent fuel pool from the coolant waste receiver tanks, resulting in an unexpected loss of spent fuel pool inventory. Dominion has documented this condition within their corrective action program (CAP) as condition report (CR) 1064323, revised procedure OP 2305, and performed an apparent cause evaluation. The inspectors determined that the finding was more than minor because it was associated with the procedure quality attribute of the Barrier Integrity cornerstone and adversely affected its objective to provide reasonable assurance that physical design barriers, such as fuel cladding, protect the public from radionuclide releases caused by accidents or events. Specifically, spent fuel pool level was inadvertently lowered when operators aligned the system in accordance with OP 2305, which resulted in a reduced net positive suction head for the spent fuel pool cooling pumps as indicated by control room alarm. The finding screened to be of very low safety significance (Green) because it did not result in a loss of spent fuel pool water inventory below the minimum analyzed level limit and did not cause the spent fuel pool temperature to exceed the maximum analyzed temperature limit. This finding has a cross-cutting aspect in the Human Performance cross-cutting area, Avoid Complacency because Dominion did not recognize and plan for the possibility of a latent deficiency in procedure OP 2305 when used while the primary demineralizers were bypassed. (H.12)
05000352/FIN-2017002-032017Q2LimerickLicensee-Identified ViolationLER 05000352/2017-003-00 Condition Prohibited by Technical Specifications Due to an Inoperable Rod Position Indication System. TS 3.1.3.7 requires, in part, with one or more control rod position indicators inoperable, within 1 hour, determine the position of the control rod by using an alternate method, or otherwise, be in at least hot shutdown within the next 12 hours. Contrary to the above, on March 16, 2017, a power supply for the Unit 1 rod position indication system rendered position indication for 83 control rods inoperable for approximately 19.5 hours until the power supply was replaced. Exelon incorrectly used the full core display to verify control rod position for 81 of the 83 rods. The power supply failure rendered the full core display incapable of updating in response to a rod position change and was, therefore, not a valid means to determine rod position. Exelon initiated condition report IR 3988302 to document the TS violation. The inspectors evaluated the significance of this finding using IMC 0609 Appendix A, Significance Determination Process for Findings at Power, Exhibit 2, Mitigating Systems Screening Questions. The inspectors determined that this finding was of very low safety significance (Green) because the issue did not affect a single reactor protection system trip signal or the function of the other redundant trips or diverse methods of reactor shutdown, did not involve addition of positive reactivity, and did not result in mismanagement of reactivity by operators. Because this issue was of very low safety significance (Green) and Exelon entered the issue into the corrective action program (IR 3988302), this finding is being treated as a non-cited violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy.
05000352/FIN-2017003-002017Q2LimerickLicensee-Identified ViolationLER 05000352/2017- 003 -00 Condition Prohibited by Technical Specifications Due to an Inoperable Rod Position Indication System . TS 3.1.3.7 requires, in part, with one or more control rod position indicators inoperable, within 1 hour, determine the position of the control rod by using an alternate method, or otherwise, be in at least hot shutdown within the next 12 hours. Contrary to the above, on March 16, 2017, a power supply for the Unit 1 rod position indication system rendered position indication for 83 control rods inoperable for approximately 19.5 hours until the power supply was replaced. Exelon incorrectly used the full core display to verify control rod position for 81 of the 83 rods. The power supply failure rendered the full core display incapable of updating in response to a rod position change and was, therefore, not a valid means to determine rod position. Exelon initiated condition report IR 3988302 to document the TS violation. The inspectors evaluated the significance of this findi ng using IMC 0609 Appendix A , Significance Determination Process for Findings at Power, Exhibit 2, Mitigating Systems Screening Questions. The inspectors determined that this finding was of very low safety significance (Green) because the issue did not affect a single reactor protection system trip signal or the function of the ot her redundant trips or diverse methods of reactor shutdown, did not involve addition of positive reactivity, and did not result in mismanagement of reactivity by operators. Because this issue was of very low safety significance (Green) and Exelon entered the issue into the corrective action program (IR 3988302), this finding is being treated as a non- cited violation, consistent with Section 2.3.2 .a of the NRC Enforcement Policy.
05000353/FIN-2017002-012017Q2LimerickInadequate Design Control of the Drywell Unit Cooler Condensate Flow Rate Monitoring SystemGreen . A self -revealing Green NCV of 10 Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion III, Design Control, occurred when Exelon failed to verify or check the adequacy of design of a new Unit 2 drywell unit cooler condensate flow rate monitoring system. Specifically, the design did not identify that the low conductivity of the drain fluid affected the ability of the flow elements to accurately detect drain flow. In addition to this, LGS staff did not assure adequate post modification acceptance test ing in accordance with CC- AA- 107- 1001, Post Modification A cceptance Testing. This inadequately designed and tested modification also resulted in a violation of technical specification (TS) 3.4.3.1, Leakage Detection Systems , because the system was inoperable and unavailable to perform its function following t he Unit 2 April 2015 refueling outage, and the TS 3.4.3.1 action statement was not met until the system was decl ared inoperable on December10, 2015. In response to this issue, Exelon initiated a condition report, IR 2598308, performed an apparent cause investigation, and replaced the Rosemount drywell unit cooler condensate flow rate monitoring system with a modified ver sion of the previously used system. The inspectors determined that the failure to verify the adequacy of the newly installed Rosemount dr ywell unit cooler condensate flow rate monitoring was within Exelons ability to foresee and correct and should have been prevented and therefore w as a performance deficiency . This issue is more than minor because it adversely affected the design control attribute of the barrier integrity cornerstone to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the Unit 2 drywell unit cooler condensate flow rate monitoring system was inoperable and unavailable to perform its function as part of the reactor coolant leakage detection system following the Unit 2 April 2015 refueling outage . This issue was evaluated in accordance with IMC 0609, Appendix A, "Significance Determination Process for Findings At-Power, using Exhibit 3, Barrier Integrity Screening Questions, Section B, Reactor Containment . The finding was determined to be of very low safety significance (Green) because the finding did not represent an actual open pathway in the physical integrity of the reactor containment and did not involve an actual reduction in function of hydrogen ig niters in the reactor containment. The inspectors determined that this finding has a cross -cutting aspect in the area of Human Performance, Conservative Bias , because LGS staff ma de inappropriate decisions based on informal vendor input and a successful implementation of the modification at another facility . (H.1 4)
05000219/FIN-2017002-012017Q2Oyster CreekInadequate Assessment of Degraded Fuel Oil Filter Impact to Emergency Diesel Generator OperabilityThe inspectors identified a finding associated with Exelon procedure OP-AA-108-115, Operability Determinations, because Exelon did not adequately assess the No. 2 emergency diesel generator operability with a degraded fuel oil filter. Specifically, Exelon did not adequately assess the capability of the emergency diesel generator to perform its function during its credited duration time of 72 hours. Exelon entered this issue into the corrective action program for resolution as issue report (IR) 3999576 and IR 3990799 and subsequently replaced the fuel oil filter. The finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone objective to ensure the reliability and capability of systems that respond to initiating events to prevent undesirable consequences. This issue was also similar to Example 3j of IMC 0612, Appendix E, Examples of Minor Issues, because the condition resulted in reasonable doubt of the operability of the No. 2 emergency diesel generator and additional analysis was necessary to verify operability. The inspectors evaluated the finding using Exhibit 2, Mitigating System Screening Questions, in Appendix A to IMC 0609, Significance Determination Process. The inspectors determined that this finding was a deficiency affecting the design or qualification of a mitigating structure, system, or component (SSC), where the SSC maintained its operability or functionality. Therefore, inspectors determined the finding to be of very low safety significance (Green). The finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Evaluation, because Exelon did not thoroughly evaluate the issue associated with the degraded fuel oil filter and its impact to the No. 2 emergency diesel generator operability (P.2).
05000336/FIN-2017002-012017Q2MillstonePotential Untimely Corrective Action for Anchor Darling Double Disc Gate ValvesThe inspectors identified that Dominion has not implemented corrective actions to address potential substantial safety hazards associated with several safety significant valves at Millstone Unit 2 that was reported in a 10 CFR Part 21 notification letter dated February 25, 2013. Specifically, after establishing a corrective action plan, to date Dominion has not implemented actions to either evaluate or inspect susceptible valves. However, inspectors need to compare actions taken to Dominions CAP requirements and review industry recommendations to address the Part 21 letter to determine if this represents a performance deficiency or violation of NRC requirements. As a result, the NRC has opened an unresolved item (URI) related to this issue of concern. Description. In 2012, Browns Ferry Nuclear Plant Unit 1 experienced a failure of an isolation valve due to a failure of the valve stem to wedge anti-rotation wedge pin as noted in a 10 CFR Part 21 Notification Letter dated January 4, 2013. Subsequent analysis by Flowserve, owner of Anchor/Darling, determined the cause was a manufacturing defect, wherein the wedge pin installation torque was insufficient to meet the design needs of the valve. Flowserve further concluded that other valves of this type, Anchor Darling double disc gate valves in motor operated valve (MOV) applications with Limitorque or Rotork actuators, could be susceptible to similar failures. As documented in the associated 10 CFR Part 21 Notification Letter from Flowserve dated February 25, 2013, Millstone was susceptible to a potential substantial safety hazard due to this potential failure mechanism. Dominion captured this condition in CR504097 and determined that the following Millstone Unit 2 valves were susceptible: CS-4.1A, Containment Spray Header Isolation CS-4.1B, Containment Spray Header Isolation CS-13.1A, RWST Outlet Isolation CS-13.1B, RWST Outlet Isolation CS-16.1A, Containment Sump Outlet Header Isolation CS-16.1B, Containment Sump Outlet Header Isolation The Dominion fleet MOV Program owner accepted the action (CA284339) to establish a corrective action plan on November 21, 2014, approximately 21 months after 10 CFR Part 21 notification by Flowserve. The corrective action plan for the susceptible valves included valve performance monitoring consistent with current MOV program requirements as well as stem position monitoring during travel every cycle which would indicate potential degradation of the wedge pin. Ultimate resolution for each location incorporates valve disassembly, intrusive inspection, and re-torque of the stem/wedge connection to mitigate the notified potential substantial safety hazard. To date, Dominion has not performed stem position monitoring, contrary to their corrective action plan, thereby limiting their capacity to identify wedge pin degradation without assessment of the change. Furthermore, due to the invasive nature of the ultimate resolution as well as the safety functions of the susceptible locations, final corrective actions for each valve must be performed with the unit offline. Dominion initially established ultimate resolution at each location in spring of either 2016 or 2017 without alignment to an outage schedule or cycle plan. On February 16, 2016, because the 2016 valves would be worked during a refueling outage, the facilities safety review committee met, extending due dates until June 1, 2017. Immediately preceding the spring 2017 refueling outage, Dominion realigned ultimate resolution for the susceptible valves to the fall 2018 and spring 2020 refuel outages due to failure to receive parts required to complete contingency maintenance. Ultimately, from February 25, 2013, through the present, the inspectors identified that Dominion delayed implementation of corrective actions for multiple potential substantial safety hazards that was communicated in a 10 CFR Part 21 notification letter. However, inspectors need to compare actions taken to Dominions CAP requirements and review industry recommendations to address the Part 21 letter to determine if this represents a performance deficiency or violation of NRC requirements. (URI 05000336/2017002-01, Potential Untimely Corrective Action for Anchor Darling Double Disc Gate Valves)
05000352/FIN-2017002-022017Q2LimerickFollow -Up of Events and Notices of Enforcement DiscretionInspection Scope On March 20, 2016, Limerick Unit 1 was performing a planned shutdown to support a refueling outage. The drywell leak inspection team identified a 0.5 gallons per minute reactor coolant system (RCS) pressure boundary leak on the shutdown cooling equalizing line. The apparent cause evaluation determined that the 34 inch A RHR shutdown cooling return check valve equalizing line developed a crack at the toe of the weld due to high cyclic fatigue induced by vibration from the reactor recirculation system. This check valve was previously replaced in 2006, and the equalizing line came pre - fabricated to the valve body. The affected section of the piping was replaced with a new socket weld with a 2x1 overlay to improve the pipe stability and minimize stresses. The Unit 1 B RHR shutdown cooling return check valve equalizing line weld was also reworked using the 2x1 weld method during the Unit 1 refueling out age in April 2016. The similar Unit 2 welds on the equalizing lines were examined and reinforced during the May 2017 refueling outage. The LER and associated evaluations and follow -up actions were reviewed for accuracy, the appropriateness of corrective actions, violations of requirements, and potential generic issues. This LER is closed. b. Findings Description. On March 20, 2016, Limerick Unit 1 was performing a planned shutdown to support a refueling outage. The drywell leak inspection team identified a 0.5 gallons per minute RCS pressure boundary leak on the shutdown cooling equalizing line. Additionally, Exelon determined that this leakage constituted a violation of the Unit 1, TS 3.4.3.2. Operational Leakage that requires the RCS leakage to be limited to no pressure boundary leakage. The condition was reported in event notification 51809 as required by 10 CFR 50.72(b)(3)(ii)(A ) because it represented a degradation of a principal safety barrier. Exelon evaluated the flaw and determined the cause of the RCS pressure boundary leakage was that the 34 inch A RHR shutdown cooling return check valve equalizing line developed a crack at the toe of the weld due to high cyclic fatigue induced by vibration from the reactor recirculation system. The inspectors reviewed the LER and Exelons apparent cause evaluation of the event. The inspectors reviewed the event information and leakage data over the previous cycle and concluded that reactor pressure boundary leakage reasonably began on an unknown date that was more than 36 hours before March 20, 2016. However, the inspectors determined that the existence of R CS pressure boundary leakage was not within Exelons ability to foresee and correct and therefore was not a performance deficiency. In particular, the RHR shutdown cooling return check valve was replaced on the recommended periodicity, and the equalizing line that developed the crack came pre- fabricated to the valve body when replaced in 2006. For information, the inspectors screened the significance of the condition using IMC 0609, Appendix A, The Significance Determination Process For Findings At -Power , and determined that the condition represented very low safety significance (Green) because it would not result in exceeding the RCS leak rate for a small LOCA and would not have likely affected other systems used to mitigate a LOCA. 19 Enforcement. TS 3.4.3.2 requires, in part, that RCS operational leakage shall be limited to no pressure boundary leakage. If pressure boundary leakage exists, the TS 3.4.3.2 limiting condition for operation action statement requires Unit 1 to be in at least hot shutdown within 12 hours and in cold shutdown within the next 24 hours. Contrary to the above, for a period that began on an unknown date that was very likely more than 36 hours before March 20, 2016, and ending on March 20, 2016, RCS pressure boundary leakage existed, and Exelon did not place Unit 1 in at least hot shutdown within 12 hours and in cold shutdown within the next 24 hours. This issue is considered within the traditional enforcement process because there was no performance deficiency associated with the violation of NRC requirements. Inspection Manual Chapter 0612, Power Reactor Inspection Reports, Section 03.22 states, in part, that traditional enforcement is used to disposition violations receiving enforcement discretion or violations without a performance deficiency. The NRC Enforcement Policy, Section 2.2.1 states, in part, that, whenever possible, the NRC uses risk information in assessing the safety significance of violations. Accordingly, after considering that the condition represented very low safety significance, the inspectors concluded that the violation would be best characterized as Severity Level IV under the traditional enforcement process. However, the NRC is exercising enforcement discretion (EA- 17- 076) in accordance with Section 3.10 of the NRC Enforcement Policy which states that the NRC may exercise discretion for violations of NRC requirements by reactor licensees for which there are no associated performance deficiencies. In reaching this decision, the NRC determined that the issue was not within the licensees ability to foresee and correct; the licensees actions did not contribute to the degraded condition; and the actions taken were reasonable to identify and address the condition. Furthermore, because the licensees actions did not contribute to this violation, it will not be considered in the assessment process or the NRCs Action Matrix.
05000336/FIN-2017001-032017Q1MillstoneLicensee-Identified ViolationAs discussed in Section 4OA2.2 of this report, the inspectors concluded that the ECCS minimum flow recirculation check valves should have been characterized as Category A valves, and should have been leak rate tested as per the IST Program. The associated LER is discussed in Section 4OA3.1. Title 10 CFR 50.55a, Codes and Standards, Section (f)(4), required in part, that throughout the service life of a pressurized water-cooled nuclear power facility, valves that are classified as Class 1, 2, or 3 must meet the IST requirements set forth in the ASME OM Code. Dominions Code of Record, ASME OM Code - 2001 Edition, Subsection ISTC-1300, Valve Categories, required that valves within the scope of Subsection ISTC-1300 shall be placed in one or more of the following categories, which included Category A (those valves for which seat leakage is limited 28 to a specific maximum amount in the closed position for fulfillment of their required function). The inspectors concluded that minimum flow recirculation check valve 2- CS-6A should have been a Category A valve, and leak rate tested, to assure fulfillment of its safety function (to mitigate the dose consequences of a postulated accident). Contrary to the above, since 1975, when the check valve 2-CS-6A was initially categorized, Dominion failed to appropriately categorize the subject valve and therefore did not meet the ASME OM Code requirements and 10 CFR 50.55a requirements. Specifically, failure to categorize the check valve as a Category A resulted in the valve not being subject to leak rate testing. This issue is more than minor because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors determined that the finding was of very low safety significance because it did not result in the loss of operability or functionality of a system or train, and the actual leakage through the check valve would not have resulted in a radiological dose in excess of regulatory requirements. Dominion entered the issue into the CAP as CR 582112 and CA 3013009. Because Dominion identified this issue of very low safety significance and it has been entered into their CAP, this finding is being treated as a licensee-identified NCV, consistent with Section 2.3.2.a of the NRC Enforcement Policy. This item was considered licensee-identified because it was identified by Dominion as a result of deliberate observation by licensee personnel, and was entered into their CAP.
05000423/FIN-2017001-022017Q1MillstoneChange of C Charging Pump Testing Requirements Contrary to ASME OMGreen. The inspectors identified a Green NCV of 10 CFR 50.55a(f) because Dominion did not perform all required inservice testing (IST) of the Unit 3 C charging pump, 3CHS*P3C, in accordance with the American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) Code. Specifically, from April 15, 2016, to the end of the inspection period, Dominion stopped the required Group A quarterly surveillances which could result in a condition where degradation of the charging pump would remain undetected by IST testing. Dominion entered this issue into their CAP as CR 1064337. 4 This finding was more than minor in accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated September 7, 2012, as it adversely affected the Equipment Performance attribute of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Eliminating quarterly IST surveillance tests could challenge the reliability of the C charging pump and allow degradation of the equipment remaining undetected. In accordance with IMC 0609, Significance Determination Process, Attachment 4, Initial Characterization of Findings, and IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, Section A, Mitigating Systems, Structures or Components and Functionality, the finding screened to be of very low safety significance (Green), when the deficiency affecting the design or qualification whereupon the component maintains operability or functionality question was answered yes. The C charging pump has not yet experienced any failures. This finding has a cross-cutting aspect in Human Performance, Change Management, in accordance with IMC 0310, Aspects within the Cross-Cutting Areas, where leaders use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority. Specifically, Dominion evaluated this change to the IST program without requesting relief from the ASME Code requirements. (H.3)
05000336/FIN-2017001-012017Q1MillstoneFailure to Maintain CST Temperature in Accordance with Procedural RequirementsGreen. The inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the failure to adequately implement Operating Procedure (OP) 2319B, Condensate Storage and Surge System. Specifically, Dominion failed to maintain the Millstone Unit 2 condensate storage tank (CST) temperature above procedural requirements. Dominion has documented this condition within their corrective action program (CAP) as condition report (CR) 1066291. The inspectors determined this finding was more than minor as it adversely affected the protection from external factors attribute of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The reliability of the mitigating systems heat removal function was challenged based upon the reasonable doubt of lost operability of the CST to provide a sufficient supply of water to the auxiliary feedwater (AFW) system. There was reasonable doubt of lost operability due to indications of CST water temperature below OP 2319B prescribed limitations, winter temperatures falling, and an inability to restore CST recirculation system in a timely manner. The finding was determined to be of very low safety significance (Green), when all screening questions were answered No as the conditions discussed in the Dominion engineering evaluation, approved on January 7, 2017, were capable of showing that no safety systems or functions were lost. This finding has a crosscutting aspect in the Problem Identification and Resolution, Resolution, in that Dominion did not take effective corrective actions or corrective maintenance to address CST recirculation pump degradation in a timely manner, prior to the onset of winter, commensurate with their safety significance such that operations could maintain CST water temperature above procedurally defined limitations. (P.3)
05000352/FIN-2017001-022017Q1LimerickFailure to Implement Human Performance Tools Results in Draining of Emergency Diesel Generator Jacket Water SystemGreen. The inspectors identified a Green self-revealing finding for the failure of Exelon personnel to follow procedures related to human performance tools which resulted in the inadvertent opening of a valve on the D13 emergency diesel generator (EDG). Specifically, Exelon personnel did not correctly identify and maintain a distance barrier from the diesel generator jacket water drain valve during a maintenance activity which resulted in the draining of the jacket water system and unplanned inoperability and unavailability of the D13 EDG. Exelon refilled the jacket water system, restored D13 EDG to an operable condition, and entered the issue into the corrective action program as IR 3986305. This finding is more than minor because it adversely affected the configuration control attribute of the mitigating systems cornerstone to ensure the availability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, the valve mispositioning caused the D13 EDG to be inoperable and unavailable. Using IMC 0609, Appendix A, Exhibit 2, the inspectors determined that this finding was of very low safety significance (Green). Specifically, the finding did not represent a loss of system or function and did not represent the loss of a single train for greater than technical specification allowed outage times or greater than 24 hours. The inspectors determined that this finding has a cross-cutting aspect in the area of Human Performance, Avoid Complacency, because Exelon personnel did not properly implement error reduction tools. (H.12)
05000353/FIN-2017001-012017Q1LimerickInadequate Work Instructions for Staging of Equipment and Routing of Temporary Power CablesGreen. The inspectors identified a Green NCV of 10 Code of Federal Regulations (CFR) 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for Exelons failure to establish instructions appropriate to the circumstances to properly stage equipment and route temporary power cables. Specifically, during cell replacement of the Class 1E 2A2 125/250 volts direct current (Vdc) safeguards battery, a portable battery charger was staged adjacent to operable 2A1 battery cells and not restrained to prevent potential tipping and shorting of exposed battery cell terminals and a non-safety related extension cord was routed in near contact with exposed safety related cables in an open cable tray. Exelon moved the portable battery charger, removed and rerouted extension cords, and entered the issues into the corrective action program as issue report (IR) 3980217; IR 3980203; and IR 3983203. This finding is more than minor because it adversely affected the configuration control attribute of the mitigating systems cornerstone to ensure the availability and reliability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, the portable battery charger was adjacent to the 2A1 battery rack and oriented such that it was susceptible to tipping over and causing electrical shorting, and a non-safety related temporary power cable connected to a non-safety related power source was routed in near contact with safety related cables in an open cable tray which introduced a potential to damage and disable safety related equipment. Using IMC 0609, Appendix A, Exhibit 2, the inspectors determined that this finding was of very low safety significance (Green). Specifically, the finding did not represent a loss of system or function and did not represent the loss of a single train for greater than technical specification allowed outage times or greater than 24 hours. The inspectors determined that this finding has a cross-cutting aspect in the area of Human Performance, Training, because Exelon did not provide sufficient training to maintain a knowledgeable workforce and instill nuclear safety values associated with the staging of material and equipment. (H.9)
05000244/FIN-2017001-012017Q1GinnaLicensee-Identified ViolationThe following violation of very low safety significance (Green) was identified by Exelon and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as a non- cited violation (NC V). Ginna TS Table 3.3.1- 1 requires the function of under frequency Bus 11A and 11B be tested to be greater than or equal to 57.5 hertz in accordance with surveillance requirement 3.3.1.10. Surveillance requirement 3.3.1.10 requires this testing to be completed in accordance with the Surveillance Frequency Control Program. The Surveillance Frequency Control Program requires the function of under frequency Bus 11A and 11B be tested every 24 months. Contrary to the above, on February 6, 2017, Ginna engineering personnel determined that the Bus 11A under frequency function had not been tested within the interval specified frequency ; the function had last been tested on May 1, 2014 . Upon identification, Exelon conducted a risk evaluation and completed the surveillance requirement at the next available opportunity i n accordance with surveillance requirement 3.0.3 for a missed surveillance. Exelon entered this issue into the CAP as AR 03970849 and completed the testing on March 11, 2017. Additional evaluation was required to demonstrate operability since the acceptance criteria of greater than or equal to 57.5 Hz was not met. The inspectors determined the finding was of very low safety significance (Green) in accordance with IMC 0609, Appendix A, The SDP for Findings at Power, Exhibit 1, Initiating Events Screening Questions, issued June 19, 2012, because the transient initiator did not cause a reactor trip and the loss of mitigating equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition.
05000336/FIN-2016004-012016Q4MillstoneRoutine Failure to Perform Engineering Evaluation of Long Term ScaffoldingThe inspectors identified a Green NCV of Title 10 of the Code of FederalRegulations (10 CFR) Part 50, Appendix B, Criterion V, Instructions, Procedures, andDrawings, for the failure to adequately implement procedure MA-AA-105, Scaffolding,Revision 17. Specifically, Dominion routinely failed to perform engineering evaluations oflong term scaffolding installed in the plant for greater than 90 days. Dominion hasdocumented this condition within their corrective action program (CAP) as condition reportCR1049493.The inspectors determined that this finding was more than minor as it represents the routine failure to perform 10 CFR 50.59 engineering evaluations consistent with the requirements of procedures MA-AA-105 and CM-AA-400 which if left uncorrected, would have the potential to lead to a more significant safety concern as informed by IMC 0612, Appendix E,Examples of Minor Issues, example 4.a. The finding screened to be of very low safety significance (Green), when all screening questions were answered No as the conditions identified did not challenge safety system functions. This finding has a cross-cutting aspect in the Problem Identification and Resolution, cross-cutting area associated with Resolution,in that under CR1049057, Dominion did not take effective corrective action to resolve and correct the identified gaps in the tracking and assessment of scaffolding installed for greater than 90 days as directed by MA-AA-105 and CM-AA-400, resulting in three further failures to evaluate long term scaffolding identified by the inspectors in the Unit 2 A Safeguards Room. (P.3)
05000336/FIN-2016004-022016Q4MillstoneFailure to Maintain Licensed Operator Examination IntegrityThe inspectors identified an NCV of 10 CFR 55.49, Integrity of Examinations and Tests, for the failure of the licensee to ensure that the integrity of an operating test administered to licensed operators was maintained. During the annual operating exam, 19of the Unit 2 licensed operators received more than two of five job performance measures(JPMs) (>50 percent) for their operating tests that had been administered to other licensed operators in previous weeks of the same exam cycle. This failure resulted in a compromise of examination integrity because it exceeded the Dominion Nuclear Fleet Procedure TR-AA-730, "Licensed Operator Biennial and Annual Operating Requalification Exam Process,4 Revision 9, requirement to repeat less than or equal to 50 percent of the JPMs during the exam cycle. However, this compromise did not lead to an actual effect on the equitable and consistent administration of the examination. This issue was entered into Dominions CAP as CR1056308.The failure of Dominions training staff to maintain the integrity of examinations administered to licensed operations personnel was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because if left uncorrected, the performance deficiency could have become more significant in that allowing licensed operators to return to the control room without valid demonstration of appropriate knowledge on the biennial examinations could be a precursor to a more significant event. Using IMC 0609, Significance Determination Process, and the corresponding Appendix I, Licensed Operator Requalification Significance Determination Process, the finding was determined to have very low safety significance (Green) because although the finding resulted in a compromise of the integrity of operating test JPMs and compensatory actions were not immediately taken when the compromise should have been discovered in 2016, the equitable and consistent administration of the test was not actually impacted by this compromise. This finding has a cross-cutting aspect in the area of Human Performance associated with Field Presence, because the licensee failed to ensure that deviations from standards and expectations are corrected promptly such that the 50 percent maximum limit on repeated JPMs was not exceeded. Specifically, Dominion supervisory review and approval of the original examination plan and subsequent changes to that plan could have discovered the deviation from standards and expectations. (H.2)
05000423/FIN-2016004-032016Q4MillstoneUntimely Corrective Action for Vital InvertersThe inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVI,Corrective Action, for Dominions failure to take timely corrective actions to replacedegraded diodes in Unit 3 vital inverters INV-1 and INV-2 upon receipt of information that called their reliability into question. Specifically, following two inverter failures, Dominion had not taken any corrective actions to replace degraded diodes in the Unit 3 vital inverters from the receipt of the Exelon Power Labs report on September 20 until the susceptible diodes were inspected and replaced on November 17 and 22. Dominion entered this issue into their CAP as CR1041301. The inspectors found that Dominions failure to take timely corrective action to replace degraded vital inverter diodes was a performance deficiency within Dominions ability to foresee and correct. This performance deficiency was considered to be more than minor because it would affect the Mitigating Systems cornerstone equipment performance attribute objective to ensure the availability and reliability of vital 120V power. Specifically,manufacturing defects in the diodes caused these subcomponents to fail when they were expected to last the life of the inverter. The finding was evaluated in accordance with IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, and determined to be of very low safety significance (Green) because although the failure challenged the reliability of the inverters, it did not result in a loss of operability or functionality. This finding has a cross-cutting aspect in the Human Performance crosscutting area associated with Work Management, in that Dominion focused on managing the risk associated with voluntarily entering a 24 hour technical specifications (TS) limiting condition for operation (LCO) to replace the degraded diodes instead of the potential risk of another inverter failure. (H.5)
05000336/FIN-2016004-042016Q4MillstoneLicensee-Identified Violation10 CFR 50, Appendix B, Criterion XVI, Corrective Action, states in part that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected. Contrary to this, Dominion failed to identify 3SWP*MOV115A, the circulating water pump lube water valve, was part of a population of valves subject to dealloying and did not take appropriate corrective actions prior to valve failure. Dominion discovered this issue during a planned system walkdown and entered it into the CAP as CR1052697. The inspectors evaluated this finding using IMC 0609.04, Initial Characterization of Findings, and IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, and determined that the finding was of very low safety significance (Green) because the finding did not represent a loss of system or function, or an actual loss of a train for greater than its TS allowed outage time, or an actual loss of function of one or more non-TS trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hours.
05000317/FIN-2016004-012016Q4Calvert CliffsInadequate Inspection of Caulking, Seals, and Expansion Barriers in the Auxiliary BuildingGreen. The inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR), Appendix B, Criterion XVI, Corrective Action, for Exelons failure to identify conditions adverse to quality at CCNPP. Specifically, several safety related auxiliary building caulking, seals, expansion joints, and penetration barriers were found by the inspectors or revealed themselves by water intrusion events to be degraded. The inspectors determined that Exelons failure to identify degradation of several auxiliary building caulking, seals, and expansion joints was a performance deficiency that was reasonably within its ability to foresee and correct and should have been prevented. Exelons immediate corrective actions included performing operability determinations on degraded barriers, and repair of the degraded barriers. Exelon entered these issues into its corrective action program (CAP) as action request (AR) 02715188, AR 02715199, AR 02716543, AR 02725901, and AR 02564655. The inspectors reviewed IMC 0612, Appendix B, Issue Screening, issued on May 6, 2016, and determined the issue is more than minor because it adversely affected the Human Performance attribute, of the Auxiliary Building Area, of the Barrier integrity cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. The inspectors also reviewed IMC 0612, Appendix E, Examples of Minor Issues, and found it was sufficiently similar to Example 3.k, in that significant programmatic deficiencies were identified that could have led to worse outcomes. Specifically, several inspection programs designed to identify degraded barriers, caulking, seals, and expansion joints in safety related auxiliary building barriers, had not been performed, or had been performed inadequately. In accordance with IMC 0609, Attachment 4, Initial Characterization of Findings, issued on October 7, 2016, and IMC 0609, Appendix A, The Significance Determination Process for Findings at Power issued on June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) since, the only safety related degradation represented by the finding is of the radiological barrier function provided for the auxiliary building. The inspectors determined that the cause of the finding has a cross-cutting aspect in the area of Human Performance, Procedure Adherence, because Exelon did not complete the baseline inspection required by AMBD-0026 within the 10 years preceding entry of Units 1 and 2 into their respective periods of extended operation as specified in CNG-CM-6.01. Additionally, inspections conducted under AMBD-0052, and 0-013-49-O-18M were inadequate in that they failed to identify degradation of the barriers as described above. (H.8)
05000423/FIN-2016003-022016Q3MillstoneFailure to Scope Safety Related Acoustic Valve Monitoring System into the Maintenance RuleThe inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50.65(b)(1), for Dominions failure to include the safety-related Unit 2 Pressurizer Safety Valve, Acoustic Valve Monitoring System (AVMS) SSC within the scope of the maintenance rule program. Specifically, Dominion removed the Millstone Unit 2 AVMS, which is required to remain functional during and following a design bases event to provide indication to operators in the control room of significant abnormal degradation of the reactor coolant pressure boundary and monitor for loss of coolant due to an open safety relief valve, from the scope of the maintenance rule monitoring program. Dominion has documented this condition in their CAP as CR1049493. The inspectors determined that the finding was more than minor because it was associated with the equipment performance attribute of the Initiating Events cornerstone and adversely affected the objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, Dominions removal of AVMS from maintenance rule performance and condition monitoring and the failures observed have resulted in the complete loss of availability and reliability of each channel of AVMS such that they cannot perform their intended function. The finding was determined to be of very low safety significance (Green) because the conditions associated with the most applicable design basis event are bound by the small break loss of coolant accident (LOCA) analysis and did not affect other systems used to mitigate a LOCA. This finding has a crosscutting aspect in the Human Performance cross-cutting area associated with Procedure Adherence, in that Millstone Maintenance Rule Expert Panel (MREP) members did not follow the Dominion maintenance rule program implementing procedure, ER-AA-MRL-100, which provides guidance for scoping systems into the maintenance rule. (H.8)
05000334/FIN-2016003-012016Q3Beaver ValleyFailure to Identify Conditions Adverse to Quality Leads to Inoperable Emergency Bus Degraded Voltage RelaysThe inspectors identified an NCV of Title 10 Code of Federal Regulations (CFR) 50, Appendix B, Criterion XVI, Corrective Action, for FENOCs failure to assure that a condition adverse to quality was promptly identified and corrected. Specifically, FENOC failed to promptly identify and correct a negative trend in setpoint drift and as found dropout voltage values in the AB 27N model 411T6375HF 4160 volts alternating current (VAC) and 480 VAC emergency bus degraded voltage relays. FENOCs immediate corrective actions included recalibrating or replacing the relays and entering the issue into their corrective action program (CAP) as condition report (CR) 2016-12018. The performance deficiency is more than minor because it is associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, FENOCs failure to promptly identify and address a negative trend in dropout voltage setpoint drift and as found values resulted in the reduced reliability of safety related bus degraded voltage relays (seven surveillance failures and inoperable degraded bus relays between 2011 and 2016). Inoperable emergency bus degraded voltage relays could lead to damage of safetyrelated equipment during a loss of offsite power. This finding is of very low safety significance (Green) because it does not represent a loss of system and/or function, an actual loss of function of a single train for greater than its technical specification allowed outage time, an actual loss of function of one non-technical specification trains designated as high safety significant, and did not involve a loss or degradation of equipment designed to mitigate a seismic, flooding, or severe weather initiating event. The finding has a crosscutting aspect in the area of Problem Identification and Resolution, Trending, because FENOC did not periodically analyze the results of the degraded voltage relay surveillances to provide early indication of a declining trend (P.4).
05000336/FIN-2016003-012016Q3MillstoneFailure to Review Standing OrdersThe inspectors identified a Green NCV of Technical Specification (TS) 6.8.1.a, for Dominions failure to implement procedures as required by Regulatory Guide 1.33, Revision 2, Appendix A.1, Administrative Procedures, during the performance of watch turnover. This resulted in multiple operators across multiple crews in both Unit 2 and 3 standing watch without performing a review of the applicable standing orders for up to 4 months from March to July 2016. Dominion entered the condition in their corrective action program (CAP) as condition report (CR)1042287. The inspectors determined that the finding was more than minor because if left uncorrected the performance deficiency could lead to a more significant event. Specifically, the operators did not review TS amendments, emergency action level classifications, emergency operating procedures, and plant computer issues impacting the plant prior to taking watch. Without reviewing the standing orders to understand the information contained within, operators could potentially take improper actions to control the plant during evolutions and abnormal conditions. The finding was determined to be of very low safety significance (Green) because it did not affect design or qualification of a mitigating structure, system, and component (SSC), did not represent a loss of system function, and did not involve external event mitigation systems. The inspectors determined that the finding has a cross-cutting aspect in the Human Performance cross-cutting area associated with Field Presence, where leaders are commonly seen in the work areas of the plant observing, coaching, and reinforcing standards and expectations. Specifically, Dominion leadership observations in the control room or management review of monthly standing order audits could have discovered the deviation from standards and expectations. (H.2)
05000244/FIN-2016003-012016Q3GinnaFailure to Perform Drills Required by the Site Emergency PlanThe inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50.54(q)(2) for Exelons failure to maintain an emergency plan that meets the requirements in Appendix E, Content of Emergency Plans, to Part 50 and the planning standards of 50.47(b). Specifically, Exelon did not perform a drive-in augmentation drill during the required 3-year cycle nor did they perform a health physics drill semi-annually as required by Ginnas Emergency Plan Implementing Procedure EP-AA-122-100, Drill and Exercise Planning and Scheduling. Immediate corrective actions included entering this issue into their corrective action program (CAP). This finding is more than minor because it is associated with the emergency response organization (ERO) readiness attribute of the Emergency Preparedness cornerstone and adversely affected the cornerstone objective to ensure that Exelon is capable of maintaining adequate measures to protect the health and safety of the public in the event of a radiological emergency. In accordance with IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, Attachment 2, Failure to Comply Significance Logic, the inspectors determined that the performance deficiency affected planning standard 10 CFR 50.47(b)(14). The inspectors concluded that this performance deficiency matched an example on Table 5.14-1 Significance Examples 50.47(b)(14), for a Degraded Planning Standard Function. Specifically, two drills had not been conducted during a 2year (calendar) period in accordance with the emergency plan, thus constituting a degraded planning standard function which corresponds to a very low safety significance (Green) finding. The cause of the finding has a cross-cutting aspect in the area of Human Performance, Procedure Adherence, because Exelon did not schedule or plan for a drive-in augmentation drill or health physics drills in accordance with procedure EP-AA-122-100. (H.8)
05000317/FIN-2016003-012016Q3Calvert CliffsDeficient Design Control of Air Pressure Available for Unit 1 Component Cooling Water Air Operated ValvesThe inspectors identified a Green non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion III, Design Control, for Exelons failure to establish measures to assure that the design basis was correctly translated into specifications affecting safety related functions of air operated valves (AOV). Specifically, when implementing a design change, Exelon failed to verify the air pressure supplied to AOVs in the component cooling (CC) water system was adequate to ensure that the valves would have performed their safety function to close during certain specific accident conditions. The inspectors determined that Exelons failure to verify ECP-15-000213 ensured that air pressure supplied to safety related Unit 1 CC heat exchanger (HX) outlet AOVs was sufficient to support their safety function of closing during a design basis accident (DBA) was a performance deficiency that was reasonably within its ability to foresee and correct and should have been prevented. Exelons immediate corrective actions included conducting an engineering evaluation that demonstrated the operability of the CC system in the degraded condition and increasing the air pressure supplied to the CC HX outlet valves to ensure the valves are capable of fully closing during a DBA. Exelon entered this issue into its corrective action program (CAP) as action request (AR) 02680281. The inspectors reviewed IMC 0612, Appendix B, Issue Screening, and determined the issue is more than minor because it adversely affected the design control attribute of the Barrier Integrity cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. The inspectors also reviewed IMC 0612, Appendix E, Examples of Minor Issues, and found it was sufficiently similar to Example 3.j, in that the design analysis deficiency resulted in a condition where reasonable doubt existed regarding the operability of the Unit 1 CC HX outlet valves. In accordance with IMC 0609, Attachment 4, Initial Characterization of Findings, issued on June 19, 2012, and IMC 0609, Appendix A, The Significance Determination Process for Findings at Power, issued on June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) since, the finding did not involve an actual open pathway in the physical integrity of reactor containment. The inspectors determined that the cause of the finding has a cross-cutting aspect in the area of Human Performance, Documentation, because Exelons AOV program, as implemented by ER-AA-410, Air Operated Valve Implementing Program, Revision 2, did not require that complete, accurate, and up-to-date documentation on the CC HX outlet valves design be maintained. (H.7)
05000336/FIN-2016002-012016Q2MillstoneSecondary Containment Inoperability Due to Inadequate ProceduresThe inspectors documented a self-revealing Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, because Dominion did not develop a Unit 3 supplementary leak collection and release system (SLCRS) damper procedure that was adequate to prevent the inoperability of the system. Specifically, deficiencies in procedure SP 3614I.3A, Supplementary Leak Collection and Release System Boundary Isolation Damper Test, as well as the SLCRS damper monitoring program and preventative maintenance strategy, led to both trains of the Unit 3 SLCRS failing their respective surveillance tests resulting in the inoperability of secondary containment. After the issue was identified, Dominion entered the condition into their corrective action program (CAP) as condition report (CR)1033408, declared the secondary containment inoperable until the plant entered a mode of technical specifications non-applicability, and conducted walkdowns and repairs to the system to restore it to compliance. This performance deficiency was considered to be more than minor because it adversely affected the system, structure, and component (SSC) and barrier performance attribute of the Barrier Integrity cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, inadequate maintenance of the SLCRS system led to a system differential pressure during operation that was not adequate to meet its design basis surveillance requirement and thus rendered the system inoperable. Additionally, the performance deficiency was similar to IMC 0612, Appendix E, minor example 2.a. The finding was evaluated in accordance with IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, and determined to be of very low safety significance (Green) since it only represented a degradation of the radiological barrier function provided for the auxiliary building. The finding is related to the cross-cutting aspect of Human Performance, Design Margins, because Dominion did not operate and maintain equipment within design margins. Specifically, Dominion did not appropriately monitor and maintain the SLCRS system in such a way that declining damper performance trends were identified and prevented prior to the inoperability of the system.
05000244/FIN-2016001-012016Q1GinnaLicensee-Identified ViolationTitle 10 CFR 50.54(q)(2) requires that a holder of a nuclear power reactor operating license under this part shall follow and maintain the effectiveness of an emergency plan that meets the requirements in Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities. Section IV.B.1 of 10 CFR 50, Appendix E, requires, in part, that the means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification and participation of State and local agencies, the Commission, and other Federal agencies, and the emergency action levels that are to be used for determining when and what type of protective measures should be considered within and outside the site boundary to protect health and safety. Contrary to the above, prior to January 7, 2016, Exelon procedure EP-AA-110-203, GNP Dose Assessment, Revision 003, did not consider the possibility of two different flow rate values through the plant vent. The plant vent has the capability to flow through filters when new fuel assemblies are added to the SFP resulting in the potential for two different flow rates out the ventone with the filters in service (69074 cubic feet per minute) and one without the filters in service (50560 cubic feet per minute). Due to the error, during certain events, Exelon would have inappropriately determined the event contaminant release rate to be higher than actual, resulting in the early declaration of an emergency action level. Upon identification, Exelon entered this into its CAP as AR 02609057 and implemented dose assessment compensatory measures to be used in EP-AA-110-203, Attachment 7, Ventilation Systems Flow Rates, table data. The inspectors determined the finding was of very low safety significance (Green) in accordance with Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, issued September 22, 2015, because a deficient emergency classification process which would result in an overclassification, but would not result in unnecessary public protective measures should be considered Green.
05000317/FIN-2016001-012016Q1Calvert CliffsIssue of concern Regarding Characterization and Acceptance of a Relevant Indication in Pressurizer to Nozzle Dissimilar Metal WeldAn unresolved item (URI) was identified by the inspectors relating to an issue of concern involving Exelons acceptance and characterization of the relevant indication in weld 4-SR-1006-1 during prior refuel outages. Additional information is required to determine whether a performance deficiency, which is more than minor, exists. Description. Based on a review of Exelon letter dated February 25, 2016, the inspectors preliminarily concluded the relevant indication in weld 4-SR-1006-1 was incorrectly accepted during prior refuel outages and was not in conformance with ASME Code Section XI, Article IWA-3000. Additional inspection, including review of Exelons root cause analysis of this issue, is warranted to determine whether a performance deficiency, which is more than minor, exists related to characterization and acceptance of a relevant indication in weld 4-SR-1006-1. (URI 05000317/2016001-01, Issue of Concern Regarding Characterization and Acceptance of a Relevant Indication in Pressurizer to Nozzle Dissimilar Metal Weld)
05000317/FIN-2015004-022015Q4Calvert CliffsAFAS Channel Inoperable due to Valve MispositionThe inspectors documented a self-revealing Green NCV of TS 5.4.1.a for Exelons failure to implement procedures as required by RG 1.33, Appendix A, Section 8, Procedures for Control of Metering and Testing Equipment and for Surveillance Tests, Procedures, and Calibrations, during maintenance which resulted in a manual isolation valve (1HVFW-1804) being incorrectly placed in the closed position. This human performance error isolated the number 12 steam generator (SG) wide range level transmitter (1LT1124C) and subsequently rendered the auxiliary feedwater actuation system (AFAS) sensor channel ZF inoperable for 33 hours and 39 minutes, a condition prohibited by TS 3.3.4, Engineered Safety Features Actuation System (ESFAS) Instrumentation. The inspectors determined that the failure to properly implement procedure STP M-525AT-1 and place 1HVFW-1804 in its required position was a performance deficiency that was reasonably within Exelons ability to foresee and prevent. Upon identification, Exelon staff entered this issue into their CAP as condition report (CR)-2014-003320. Exelons immediate corrective action was to enter TS 3.3.4.A, to determine and correct the cause, and to retest the system for proper operation. The inspectors reviewed IMC 0612, Appendix B, Issue Screening, and determined the issue is more than minor because it adversely affected the configuration control attribute of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, Exelon operated with manual isolation valve, 1HVFW-1804 closed which resulted in the inoperability of the AFAS sensor channel ZF for approximately 33 hours and 39 minutes. In accordance with IMC 0609, Attachment 4, Initial Characterization of Findings, issued on June 19, 2012, and IMC 0609, Appendix A, The Significance Determination Process for Findings at Power, Exhibit 2, Mitigating Systems Screening Questions, issued on June 19, 2012, the inspectors determined that a detailed risk evaluation was necessary to disposition the significance of this finding because the finding represented an actual loss of function of at least a single train of AFAS for greater than its TS allowed outage time. A regional SRA performed a detailed risk evaluation. The finding was determined to be of very low safety significance (Green) because the redundant AFAS sensor was operable and functional to ensure actuation of the system if it had been required, therefore there was no loss of the system function. Additionally, the unit was in Mode 3 with very low decay heat levels during the time the ZF sensor channel was determined to be inoperable and plant procedures exist to manually start the AFW system if failure of automatic actuation were to occur. The inspectors determined that the finding has a cross-cutting aspect in the area of Human Performance, Challenge the Unknown, because Exelon did not stop when faced with an uncertain condition about the position of 1HVFW- 1804. Specifically, personnel conducting the second verification did not appropriately question the position of isolation valve 1HVFW-1804 because of the higher experience level of the personnel conducting the first verification.
05000317/FIN-2015004-042015Q4Calvert CliffsLicensee-Identified Violation10 CFR 55.21 and 10 CFR 55.33 state, in part, that licensed operators are required to have a physical examination every two years to ensure that their medical condition and general health will not adversely affect the performance of assigned operator job duties or cause operational errors endangering public health and safety. As part of licensed operator medical evaluations, screening questions to identify potentially disqualifying medical conditions are required as specified in ANSI/ANS-3.4-1983, Medical Certification and Monitoring of Personnel Requiring Operator Licenses for Nuclear Power Plants. Contrary to this requirement, as a result of Exelons medical examination audit completed August 8, 2014, Exelon identified nine (9) licensed operators who were given an incomplete health questionnaire during their biennial medical examination. The questionnaire failed to request information about seven (7) potentially disqualifying health conditions from ANSI/ANS-3.4-1983 during a biennial medical examination. The omission of these seven potentially disqualifying conditions from the questionnaire resulted in an incomplete medical examination. Exelon identified that the cause was an incorrect revision to the sites medical examination process procedure. The revision issue was corrected in a subsequent revision and the audit documented that the nine licensed operators all completed medical evaluations with the correct screening questions within the next 18 months. The results of the medical examination audit were documented in IR 2423783. This violation is subject to traditional enforcement because of the potential impact upon regulatory process because the operators medical conditions are reviewed by the NRC when issuing or renewing operator licenses. The inspectors determined that this issue meets the criteria for a Severity Level IV violation using example 6.4.d.1(c) from the NRC Enforcement Policy because the operators who potentially did not meet ANSI/ANS-3.4, Section 5, due to an incomplete medical examination, subsequently were found to meet the health requirements for licensing. This is of very low safety significance because no incorrect regulatory decision was made as a result of the incomplete medical questionnaire and because no changes to license restrictions were required.
05000317/FIN-2015004-032015Q4Calvert CliffsLicensee-Identified Violation10 CFR 55.25 states, in part, that if an operator develops a permanent physical or mental condition that causes the operator to fail to meet the requirements of 10 CFR 55.21, the facility licensee shall notify the Commission within 30 days of learning of the diagnosis, in accordance with 10 CFR 50.74(c) which states that the regional administrator shall be notified if a licensed operator develops a permanent disability or illness. Contrary to these requirements, as the result of Exelons medical examination audit completed August 8, 2014, Exelon identified four cases in which a change in licensed operator medical conditions were not communicated to the NRC within the required 30 days. The results of the medical examination audit were documented in IR 2423780 and subsequent notifications were made to the NRC. This violation is subject to traditional enforcement because of the potential impact upon the regulatory process for issuing restrictions to operators licenses. The inspectors determined that this issue meets the criteria for a Severity Level IV violation using example 6.4.d.1(a) from the NRC Enforcement Policy because no incorrect regulatory decision was made as the result of the failure of the licensee to report within 30 days. This is of very low safety significance because after NRC review of the subsequent notifications, no changes to license restrictions were required.
05000317/FIN-2015004-012015Q4Calvert CliffsFailure to Implement Procedures for the Control of Hazard Barriers During MaintenanceThe inspectors identified a Green NCV of Technical Specification (TS) 5.4.1.a for Exelons failure to implement procedures as required by Regulatory Guide (RG) 1.33, Appendix A, Section 1, Administrative Procedures, during replacement of the 11 service water (SRW) pump motor, resulting in the SRW pump room door, a high energy line break (HELB) barrier, being impaired. This rendered the safety-related equipment protected by the HELB barrier inoperable. The inspectors determined that the failure to properly implement Exelon procedures EN-1-135, Control of Barriers, Revision 00202, and CC-AA- 201, Plant Barrier Control Program, Revision 11, was a performance deficiency that was reasonably within Exelons ability to foresee and prevent. Upon identification, Exelon staff entered this issue into their corrective action program (CAP) as issue report (IR) 2586773. Exelons immediate corrective actions included halting of impairing hazard barriers without considering the degraded barriers effect on equipment operability. The inspectors reviewed IMC 0612, Appendix B, Issue Screening, and determined the performance deficiency was more than minor because it adversely affected the equipment performance attribute of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, Exelons actions in blocking open the HELB barrier resulted in a condition where structures, systems, and components (SSCs) necessary to mitigate the effects of a HELB may not have functioned as required; therefore, the reliability of these protected SSCs was adversely impacted. In accordance with IMC 0609, Attachment 4, Initial Characterization of Findings, issued on June 19, 2012, and IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, issued on June 19, 2012, the inspectors determined that a detailed risk evaluation was necessary to disposition the significance of this finding because the finding represented a loss of the SRW system. A regional Senior Reactor Analyst (SRA) performed a detailed risk evaluation using an exposure interval of 10 minutes as the maximum time the condition was allowed in the plant. Using these inputs yielded an initiating event frequency of 4E-9/year. From discussions with the inspectors, the analyst confirmed a list of affected equipment. The analyst bounded the scenario by assuming all mitigating equipment would be lost which gave a maximum change in core damage frequency of 4E-9/year. Since the bounded change in core damage frequency was less than 1E-6, the finding was determined to be of very low safety significance (Green). The inspectors determined that the finding had a cross-cutting aspect in the area of Human Performance, Work Management, because Exelon did not implement a process of planning, controlling, and executing work activities such that nuclear safety was the overriding priority. Specifically, Exelons process for planning and controlling maintenance did not identify the applicability of Exelon procedure CC-AA-201.
05000336/FIN-2015004-032015Q4MillstoneLicensee-Identified Violation10 CFR Part 50.54(q), states that power reactor licensees shall follow and maintain in effect emergency plans which meet the standards in 10 CFR Part 50.47(b) and Appendix E to Part 50. 10 CFR Part 50.47(b)(4) requires, in part, that the nuclear facility licensee have a standard emergency classification and action level scheme in use, and state and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial off-site response measures. Appendix E, Section IV.C.2 states in part that, nuclear power reactor licensees shall establish and maintain the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and shall promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level. Contrary to the above, on November 4, Unit 3 control room operators received a fire alarm in the A EDG enclosure at 10:56 AM, but did not declare an Unusual Event for a fire in a safe shutdown area until 11:25 AM. The control room received a report from the EDG enclosure at approximately 10:55 AM that there were visible flames on the exhaust line of the A EDG and they entered Emergency Operating Procedure 3509, Fire Emergency, but the declaration was not made within the required 15 minutes. The control room operators received additional information that there was charring and scorching on the A EDG at 11:33 AM and appropriately upgraded the emergency declaration to an Alert (fire affecting a safe shutdown area and damage to the equipment indicated). The upgraded Alert declaration was made at 11:35 AM, within the required 15 minutes. The inspectors determined that the finding is of very low safety significance (Green) because it was related to the timeliness of an NOUE, in accordance with IMC 0609, Appendix B, "Emergency Preparedness Significance Determination Process, Attachment 1, "Failure to Implement (Actual Event) Significance Logic." Dominion entered the issue into the CAP as CR 1017078.
05000336/FIN-2015004-022015Q4MillstoneTurbine Driven Auxiliary Feedwater Pump Corrective Actions to Prevent RecurrenceThe inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, for Dominions failure to take corrective action to prevent repetition for a significant condition adverse to quality according to the definition in PI-AA-200, Corrective Action. Specifically, PI-AA-200 lists unplanned entry into a TS action that results in taking a unit off-line as an example of a significant condition adverse to quality. On July 26, 2014, Dominion performed a TS required shutdown of Unit 2 due to the inoperability of the turbine driven auxiliary feedwater (TDAFW) pump. Dominion cancelled the root cause evaluation (RCE) assigned to investigate the cause of the plant shutdown, stating that the direct cause of the shutdown was foreign material in the flow orifice in a recirculation line for the TDAFW pump. No corrective actions to prevent recurrence (CAPRs) were assigned after the direct cause was determined. Dominion entered this issue into their CAP as CR1019514. This performance deficiency was determined to be more than minor in accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated September 7, 2012, because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and adversely affected its objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, taking CAPRs will help to ensure the availability and reliability of the TDAFW pump. This finding was evaluated in accordance with IMC 0609, Significance Determination Process, Attachment 4, Initial Characterization of Findings, and IMC 0609, Appendix A, Exhibit 2, and screened as very low safety significance (Green) since it was not a qualification or design deficiency, did not represent a loss of system or function, and did not exceed its TS allowed outage time. The inspectors determined this issue had a cross cutting aspect in Human Performance, Consistent Process, where individuals use a consistent, systematic approach to make decisions. Specifically, Dominion inappropriately used the corrective action procedure to change the causal evaluation category without properly balancing the risk of the decision, and therefore did not develop CAPRs for a significant condition adverse to quality.
05000336/FIN-2015004-012015Q4MillstoneCharging Packing Lubrication Pump Inadequate Operating Procedure Acceptance CriteriaThe inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated with Dominions failure to include in the Unit 2 charging pump operating procedure appropriate acceptance criteria for determining operability of the Unit 2 charging pumps upon the loss of the associated charging flushing/lubrication pump. Specifically, Dominion implemented a procedure change which stated that the condition of the charging flushing/lubrication pumps does not affect charging pump operability or mission time without supporting technical information and contrary to guidance provided in the charging pump vendor technical manual, impacting an operability determination on December 13, 2015. Dominion has entered the concern associated with the charging pump operability acceptance criteria into their corrective action program (CAP) under condition report (CR)1021512. This finding was determined to be more than minor in accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated September 7, 2012, because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and adversely affected its objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Further, this finding was found to be consistent with more than minor examples 3.j and 3.k of IMC 0612, Appendix E, Examples of Minor Issues, dated August 11, 2009. This finding was evaluated in accordance with IMC 0609, Significance Determination Process, Attachment 4, Initial Characterization of Findings, and IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, Section A, Mitigating Systems, Structures or Components and Functionality, and screened as very low safety significance (Green) since it was not a qualification or design deficiency, did not represent a loss of system or function, and did not exceed its technical specification (TS) allowed outage time. Inspectors identified a cross-cutting aspect in Human Performance, Documentation, in that Dominion lacked technical documentation to support the operability assertion in the charging pump operating procedure to address contrary guidance provided in the charging pump vendor manual.
05000336/FIN-2015003-032015Q3MillstoneLicensee-Identified Violation10 CFR 50, Appendix B, Criterion VII, Control of Purchased Material, Equipment, and Services, requires, in part, that measures shall be established to assure that purchased services conform to the procurement documents. Contrary to Criterion VII, Design Change MP3-09-01030, Replacement of Actuators on 3FWS*CTV41 A/D (FWIVs), was supplied by Dominions vendor (Flowserve) and accepted by Dominion with an inadequate valve weak link analysis (valve backseat determined to be the weak link versus the steam coupling bolts). This was identified by Dominion during installation of MP3-09-01030 which required significant changes to the modification design prior to returning the FWIVs to service. This issue is more than minor because, if left uncorrected, the issue would have the potential to lead to a more significant safety concern. Specifically, not correcting the valve weak link analysis had the potential to lead to damage and/or failure of the FWIV stem coupling bolts rendering the valve inoperable. The inspectors evaluated this finding using IMC 0609.04, Initial Characterization of Findings, and IMC 0609, Appendix A, Exhibit 3, Barrier Integrity Screening Questions. The inspectors determined that the finding was of very low safety significance (Green) because the finding did not represent an actual open pathway in the physical integrity of reactor containment. Dominion documented the issue in CRs 564977 and 564801.
05000423/FIN-2015003-022015Q3MillstoneInadequate Procedural Direction to Mitigate a LOCA and Failure of an RSS Heat Exchanger TubeThe inspectors identified a Green NCV of Millstone Unit 3 TS 6.8.1, as specified by Regulatory Guide (RG) 1.33, associated with Dominions failure to implement adequate procedures to address a hypothetical large break loss of coolant accident (LBLOCA) inside containment with a failure of a recirculation spray system (RSS) heat exchanger tube resulting in a loss of coolant accident (LOCA) that bypasses the containment barrier. 4 Dominion did not provide adequate procedural direction or training to the operators for the control of the emergency core cooling systems (ECCS) during this hypothetical event in June of 2015. Dominion entered the issue into their corrective action program as condition report (CR) 1008205. The finding was more than minor in accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated September 7, 2012, as it represented a challenge to the procedure quality attribute of the Barrier Integrity cornerstone to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. The finding was screened to be of very low safety significance (Green) as the deficiency did not represent an actual open pathway in the physical integrity of reactor containment in accordance with IMC 0609, Significance Determination Process, Attachment 4, Initial Characterization of Findings, and IMC 0609, Appendix A, Exhibit 3, Barrier integrity Screening Questions, Section B, Reactor Containment. The inspectors identified a cross-cutting aspect in Problem Identification and Resolution, Evaluation, because the organization failed to evaluate the issue to ensure that resolution addressed causes and extent of conditions commensurate with their safety significance.
05000423/FIN-2015003-012015Q3MillstoneChange of Pump Reference Values Contrary to ASME OMThe inspectors identified a Green NCV of Millstone Unit 3 Technical Specification (TS) Surveillance Requirement 4.0.5 because Dominion did not implement the Inservice Testing (IST) Program in accordance with the American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) Code of Record, 2001 through 2003 incorporated addenda. On July 18, 2015, Dominion changed the reference values of the B control building air conditioning booster pump, 3SWP*P2B, prior to determining the cause of the condition which resulted in the pump performing in the Action Range (ISTB-6200(b)) in April 2015. This finding was more than minor in accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated September 7, 2012, as it represented a challenge to the equipment performance attribute of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The reliability of 3SWP*P2B was challenged based upon Dominions change in the pumps reference values contrary to the ASME OM code of record for Millstone Unit 3 which could result in the degradation of the equipment remaining undetected. The finding screened to be of very low safety significance (Green) because the safety function of 3SWP*P2B was not lost based on analysis of design basis flow requirements. The inspectors determined the finding has a cross-cutting aspect in Problem Identification and Resolution, Evaluation, in that the organization failed to evaluate the issue to ensure that resolution addressed causes and extent of conditions commensurate with their safety significance. Specifically, Dominions analysis of the April 2015 pump failures was not thorough enough to understand a new potential failure mode (impeller movement) and how it may impact system performance.
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