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	Quarter	Site	Title	Description
05000445/FIN-2018003-02	2018Q3	Comanche Peak	Failure to Establish Adequate Procedural Guidance for Processing Technical Changes Performed by A Vendor on Installed Plant Equipment	The inspectors identified a Green, NCVof 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated with the licensees failure to establish an adequate procedure for controlling and processing vendor documents and vendor technical information. This resulted in the licensees failure to properly evaluate changes made by vendors to plant equipment. Specifically, the licensee allowed vendors to make physical changes to a component cooling water pump shaft and main steam isolation valve actuators without evaluating these changes.
05000458/FIN-2018003-01	2018Q3	River Bend	Licensee-Identified Violation	This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy. Violation: Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that measures shall be established to assure that the design basis for those structures, systems, and components to which Appendix B applies is correctly translated into specifications, drawings, procedures, and instructions. The design basis for the control building air conditioning system, as specified in the updated safety analysis report, requires that the system be capable of performing its safety function in the event of a single failure in any component. Contrary to the above, the licensee failed to assure that the design basis was correctly translated into specifications for the control building air conditioning system. Specifically, while reviewing the control logic for the control building air conditioning system, the licensee discovered that the control logic was designed such that a single failure in a component in the control logic could have prevented the system from performing its specified safety function.
05000445/FIN-2018003-01	2018Q3	Comanche Peak	Failure to Maintain the Ability to Withstand a Station Blackout	The inspectors identified a Green, non-cited violation of 10 CFR Part 50.63 for the licensees failure to maintain the ability to withstand and recover from a station blackout. Specifically, the licensees approved coping analysis for each unit required the availability of equipment on the non-blacked-out unit, and the licensee failed to maintain the required equipment available.The licensee entered this violation into their corrective action program as condition report CR-2017-011090.
05000298/FIN-2017010-04	2017Q2	Cooper	Failure to Monitor No. 2 Diesel Generator under 50.65(a)(1) due to Inadequate Maintenance Rule Evaluation	Green. The team identified a non-cited violation of 10 CFR 50.65(a)(1)/(a)(2), for the licensees failure to perform an a(1) evaluation and establish a(1) goals when the No. 2 diesel generator a(2) preventive maintenance demonstration became invalid. Specifically, on April 28, 2017, the No. 2 diesel generator exceeded its performance criteria when it experienced a second maintenance rule functional failure, but the licensee failed to perform an associated a(1) evaluation. The licensee had failed to appropriately evaluate a February 4, 2017, failure associated with the No. 2 diesel generator jacket water heater failure in the Maintenance Rule Program and, as a result, the site failed to evaluate and monitor the equipment under 10 CFR 50.65(a)(1) as required. Corrective actions taken by the licensee to restore compliance included reevaluation of the February 4, 2017, functional failure and performance of an a(1) evaluation. The issue was entered into the licensees corrective action program as Condition Report CR-17-03930. The licensees failure to monitor the No. 2 diesel generator in accordance with the requirements of 10 CFR 50.65(a)(1), due to incorrectly evaluating one maintenance rule functional failure, in violation of 10 CFR 50.65(a)(1)/(a)(2), was a performance deficiency. The inspectors screened the performance deficiency using Inspection Manual Chapter 0612, Appendix B, Issue Screening, dated September 7, 2012, and determined that the issue was more than minor, and therefore a finding, because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, the inspectors determined that the finding had very low safety significance (Green) because it: was not a design deficiency; did not represent a loss of system and/or function; did not represent an actual loss of function; did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time; and did not result in the loss of a high safety-significant nontechnical specification train. The finding had a cross-cutting aspect in the area of problem identification and resolution associated with evaluation, because the licensee failed to ensure that the organization thoroughly evaluated 5 the No. 2 diesel generator issues to ensure that resolutions addressed causes and extent of conditions commensurate with their safety significance (P.2)
05000298/FIN-2017010-03	2017Q2	Cooper	Programmatic Failure to Identify and Correct Adverse Trends	Green. The team identified a Green non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, for the licensees programmatic failure to promptly identify adverse trends and enter them into the corrective action program. Often, when adverse trends were identified, they were addressed using informal processes. This was particularly the case for safety culture-related trends such as adverse trends in organizational behaviors. The licensee entered this violation into its corrective action program as Condition Report CR-CNS-2017-03938, and took action to formalize identification processes for potential adverse trends. The programmatic failure to promptly identify adverse trends as required by station procedures was a performance deficiency. This performance deficiency is more than minor because if left uncorrected, it has the potential to become a more significant safety concern. Specifically, failure to arrest an adverse trend, particularly in organizational behaviors, could lead to increased likelihood of a worker-induced initiating event or a failure to effectively mitigate an accident. Using Inspection Manual Chapter 0609, Appendix A, dated June 19, 2012, the inspectors determined that the finding had very low safety significance (Green) because it did not result in the loss of operability or functionality of any system or train. This finding has a trending cross-cutting aspect in the problem identification and resolution cross- cutting area because the organization failed to use available information in the aggregate to identify programmatic and common cause issues (P.4).
05000298/FIN-2017010-02	2017Q2	Cooper	Failure to Perform Timely Operability Determinations	Green. The team identified a Green non-cited violation of Technical Specification 5.4.1.a, for the licensees multiple failures to immediately evaluate operability of degraded or nonconforming conditions. The team identified multiple examples of these operability determinations not being performed within one shift, as required by procedure. Further, aggregate data indicated routine noncompliance with procedural requirements to document operability immediately and without delay. The licensee entered this violation into its corrective action program as Condition Report CR-CNS-2017-03937, and began evaluating actions to restore compliance. Multiple failures to perform immediate operability determinations timely as required by station procedures is a performance deficiency. This performance deficiency is more than minor because it was associated with the equipment performance attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of system s that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, dated June 19, 2012, the inspectors determined that the finding had very low safety significance (Green) because it did not result in the loss of operability or functionality of any system or train. This finding has a consistent process cross-cutting aspect in the human performance cross-cutting area because operators failed to use a consistent, systematic approach to make decisions regarding operability using the organizations well-defined decision making process (H.13)
05000298/FIN-2017010-01	2017Q2	Cooper	Failure to Assign Corrective Actions to Prevent Recurrence of High Pressure Coolant Injection Failure	Green. The team identified a non-cited violation of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to assign corrective actions to preclude repetition of a significant condition adverse to quality associated with the loss of the high pressure coolant injection system. Specifically, between July 28, 2016, and June 29, 2017, the licensee failed to assign or complete corrective actions to prevent recurrence to address the failure of a relay coil that resulted in a loss of safety function for the single train high pressure coolant injection system. Corrective actions to restore compliance included reevaluation of the corrective 3 actions assigned to the root cause of the condition and the creation of corrective actions to prevent recurrence for the condition. The licensee entered this deficiency into the corrective action program as Condition Report CR 17 03544. The licensees failure to assign corrective actions to preclude repetition of a significant condition adverse to quality, in violation of 10 CFR 50, Appendix B, Criterion XVI, was a performance deficiency. The performance deficiency was evaluated using Inspection Manual Chapter 0612, Appendix B, Issue Screening, dated September 7, 2012, and was associated with the Mitigating Systems cornerstone. The team determined that the performance deficiency was more than minor, and therefore a finding, because if left uncorrected, the performance deficiency would have the potential to lead to a more significant safety concern. Specifically, the licensees failure to assign corrective actions to preclude repetition of a significant condition adverse to quality could reasonably result in the condition recurring and creating more safety-significant equipment failures. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, the inspectors determined that the finding had very low safety significance (Green) because it: was not a design deficiency; did not represent a loss of system and/or function; did not represent an actual loss of function; did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time; and did not result in the loss of a high safety-significant non-technical specification train. The finding had a cross-cutting aspect in the area of problem identification and resolution associated with resolution, because the licensee failed to ensure that the organization took effective corrective actions to address issues in a timely manner commensurate with their safety significance (P.3).
05000298/FIN-2017010-05	2017Q2	Cooper	Failure to adopt appropriate procedures in accordance with 10 CFR Part 21	Severity Level IV. The team identified a violation of 10 CFR 21.21(a), for the licensees failure to adopt appropriate procedures to evaluate deviations and failures to comply to identify those associated with substantial safety hazards. Specifically, Procedure EN-LI-108, 10 CFR 21 Evaluations and Reporting, Revision 5C0, was inadequate to ensure that the correct reportability call was made for a manufacturing flaw discovered in a relay that had resulted in a loss of safety function for the high pressure coolant injection system on April 25, 2016. In particular, the procedure (1) led the licensee to incorrectly conclude that a substantial safety hazard could not be created, (2) allowed a limited extent of condition in performing the substantial safety hazard evaluation such that similarly dedicated parts were not included in the scope, and (3) included incorrect guidance in Attachment 9.3. Corrective actions to restore compliance included re-evaluation of the defect under Part 21 requirements and a procedure adequacy review of the EN-LI-108-01 procedure. The licensee entered this issue into the corrective action program as Condition Reports CR-17-03936 and CR-17-04143. The failure to adopt appropriate procedures to evaluate deviations and failures to comply to identify those associated with substantial safety hazards, in violation of 10 CFR 21.21(a), was a performance deficiency. The NRCs reactor oversight process considers the safety significance of findings by evaluating their potential safety consequences. Using Inspection Manual Chapter 0612, Appendix B, Issue Screening, dated September 7, 2012, the team determined that the performance deficiency was of minor safety significance under the reactor oversight process because it involved a failure to make a report; however the underlying equipment failure was previously evaluated as having very low safety significance. The traditional enforcement process separately considers the significance of willful violations, violations that impact the regulatory process, and violations that result in actual safety consequences. Traditional enforcement applied to this finding because it involved a violation that impacted the regulatory process. The team used the NRC Enforcement Policy, dated November 1, 2016, to determine the significance of the violation. The inspectors determined that the violation was similar to Examples 6.9.d.10 and 6.9.d.13 of the Enforcement Policy, because although the procedure resulted in an inadequate reportability review and the issue was not reported as a manufacturing flaw, the licensee had reported some aspects of the event under the requirements of 10 CFR 50.73. As a result, the team determined that the violation should be classified as a Severity Level IV violation. Cross-cutting aspects are not assigned to traditional enforcement violations.
05000313/FIN-2016008-03	2016Q4	Arkansas Nuclear	Failure to Monitor Startup Transformers 1, 2, and 3 Voltage Regulator/Tap Changer Function	Green. The team identified a Green finding for the failure to meet the surveillance standards of IEEE 308-1971, Criteria for Class 1E Electric Systems for Nuclear Power Generating Stations, Section 5.2.3, Preferred Power Supply. Specifically, from 2001 to December 2, 2016, the licensee failed to monitor the operation of the voltage regulator/load tap changer functions on startup transformers 1, 2, and 3. In response to this issue, the licensee provided reasonable assurance that the voltage regulator/load tap changer was operating properly based on review of plant computer voltage plot data following an Arkansas Nuclear One, Unit 1 trip that occurred on December 14, 2015. This finding was entered into the licensees corrective action program as Condition Reports CR-ANO-C-2016-4777, CR-ANO-C-2016-4879, and CR-ANO-C-2016-5015. The team determined that the failure to monitor startup transformers 1, 2, and 3 voltage regulator/load tap changers to the extent that they are shown to be ready to perform their intended function, in accordance with IEEE Standard 308-1971, was a performance deficiency. The finding was determined to be more than minor because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of mitigating systems to respond to initiating events to prevent undesirable consequences. Specifically, the failure to monitor the adequacy of the voltage supplied from startup transformers 1, 2, and 3 voltage regulator/load tap changer did not ensure that offsite power would be available to perform its necessary functions to provide power to the safety-related mitigation equipment. In accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, Exhibit 2, Mitigating Systems Screening Questions, the issue screened as having very low safety significance (Green) because it was a design or qualification deficiency that did not represent a loss of operability or functionality; did not represent an actual loss of safety function of the system or train; did not result in the loss of one or more trains of non-technical specification equipment; and did not screen as potentially risk-significant due to seismic, flooding, or severe weather. This finding did not have a cross-cutting aspect because the performance deficiency did not reflect current licensee performance.
05000313/FIN-2016008-02	2016Q4	Arkansas Nuclear	Failure to Incorporate NRC Safety Guide 9 Criteria into Surveillance Procedures	Green. The team identified Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, which states, A test program shall be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. Additionally, Test results shall be documented and evaluated to assure that test requirements have been satisfied. Specifically, as of December 2, 2016, Units 1 and 2 emergency diesel generator surveillance procedures failed to incorporate the applicable voltage and frequency limits of NRC Safety Guide 9, and did not consistently document or evaluate results to assure test requirements have been satisfied. In response to this issue, the licensee provided the team test results which demonstrated that an immediate safety concern was not present. This finding was entered into the licensees corrective action program as Condition Reports CR-ANO-1-2016-4785 and CR-ANO-2-2016-4257. The team determined that the failure to incorporate the acceptance limits of NRC Safety Guide 9 into surveillance test procedures for emergency diesel generators and assure that test requirements have been satisfied in accordance with 10 CFR Part 50, Appendix B, Criterion XI, Test Control, was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the procedure quality attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of mitigating systems to respond to initiating events to prevent undesirable consequences, and would have the potential to lead to a more significant safety concern. Specifically, the failure to incorporate appropriate acceptance criteria in test procedures and assure that the criteria have been satisfied had the potential to lead to a worse condition, if left uncorrected. In accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, Exhibit 2, Mitigating Systems Screening Questions, the issue screened as having very low safety significance (Green) because it was a design or qualification deficiency that did not represent a loss of operability or functionality; did not represent an actual loss of safety function of the system or train; did not result in the loss of one or more trains of non-technical specification equipment; and did not screen as potentially risk-significant due to seismic, flooding, or severe weather. This finding did not have a cross-cutting aspect because the performance deficiency did not reflect current licensee performance.
05000313/FIN-2016008-04	2016Q4	Arkansas Nuclear	Failure to Perform an Adequate Emergency Feedwater Pump Suction Transfer Design Calculation or Testing (EA 2017-017)	Green. The team identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, which states, in part that, design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program. Specifically, prior to December 22, 2016, the licensee failed to verify the adequacy of the emergency feedwater suction transfer procedure by determining if the qualified condensate storage tank will be completely empty of water, possibly causing an air ingestion failure of the Unit 1 emergency feedwater pumps, prior to transferring to the credited safety-related alternate suction source. In response to this issue, the licensee resolved the immediate safety concern by revising the emergency feedwater pump operating procedure, removing the steps that were the cause of the concern. This finding was entered into the licensees corrective action program as Condition Reports CR-ANO-1-2016-5166, CR-ANO-1-2016-5725, and CR-ANO-1-2017-0040. The team determined that the failure to verify the adequacy of the design of the Unit 1 emergency feedwater suction from the qualified condensate storage tank to alternate sources of water by performance of design review, by use of calculational methods, or by performance of a suitable testing program in accordance with 10 CFR Part 50, Appendix B, Criterion III, Design Control, was a performance deficiency. This finding was more than minor because it was associated with the design control attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the reliability, availability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to have adequate measures in place to ensure an acceptable design analysis or a suitable test program would verify that the process of transferring emergency feedwater suction from the qualified storage tank to the alternate sources ensures the capability of the Unit 1 emergency feedwater system to perform its safety function. In accordance with Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, dated June 19, 2012, the team determined this finding affected the secondary short term heat removal function of the Mitigating Systems Cornerstone. In accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, Exhibit 2, Mitigating Systems Screening Questions, the finding represented a loss of the emergency feedwater system and function. Therefore, a detailed risk evaluation was necessary. The senior reactor analyst determined that the change in core damage frequency of this finding was 7 x 10-7 per year, therefore the significance was of very low safety significance (Green). This finding did not have a cross-cutting aspect because the performance deficiency did not reflect current licensee performance.
05000313/FIN-2016008-05	2016Q4	Arkansas Nuclear	Failure to Ensure Safety Systems Would Survive Sustained Degraded Voltage Conditions	Green. The team identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, which states, in part, design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program. Specifically, from December 17, 1979, to December 2, 2016, the licensee did not verify that the design of the protective devices for the loads required at the beginning of a loss-of-coolant accident were adequate to prevent tripping these devices under degraded voltage conditions, which would render the affected loads non-functional. In response to this issue, the licensee performed a preliminary analysis to determine that the protective overload devices would not cause safety equipment to fail at degraded voltages allowed by technical specifications. This finding was entered into the licensees corrective action program as Condition Reports CR-ANO-C-2016-5027 and CR-ANO-C-2016-5191. The team determined that the failure to ensure that safety-related electrical components would not fail during the allowable time duration of a degraded voltage condition (in accordance with NRC Multi-Plant Action B-23, Position 1.C) was a performance deficiency. The finding was determined to be more than minor because it was associated with the design control attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of mitigating systems to respond to initiating events to prevent undesirable consequences. Specifically, the failure to ensure that the protective devices for the loads required at the beginning of a Loss of Control Accident would not fail under degraded voltage conditions did not ensure that these loads would be available to perform their mitigating functions. In accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, Exhibit 2, Mitigating Systems Screening Questions, the issue screened as having very low safety significance (Green) because it was a design or qualification deficiency that did not represent a loss of operability or functionality; did not represent an actual loss of safety function of the system or train; did not result in the loss of one or more trains of non-technical specification equipment; and did not screen as potentially risk-significant due to seismic, flooding, or severe weather. The team determined that this finding did not have a cross-cutting aspect because the most significant contributor did not reflect current licensee performance.
05000313/FIN-2016008-06	2016Q4	Arkansas Nuclear	Readiness to Cope with External Flooding	Green. The team identified three examples of a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, which states, in part that, activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances. Specifically, prior to December 2, 2016, Unit 1 Operating Procedure OP 1203.025, Natural Emergencies, Revision 60 and Unit 2 Operating Procedure OP 2203.008 Natural Emergencies, Revision 42 failed to ensure all actions required to establish external flood protection, as specified by flood protection design basis engineering report CALC-ANOC-CS-00003, Revision 00 were implemented. This issue was entered into the licensees corrective action program as Condition Report CR-ANO-2-2016-4265. The licensees failure to prescribe procedures appropriate to the circumstances for combating emergencies or other significant acts of nature such as flooding was a performance deficiency. The performance deficiency was more than minor because it was associated with the procedure quality attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of mitigating systems to respond to initiating events to prevent undesirable consequences, and would have the potential to lead to a more significant safety concern. In accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, Exhibit 2, Mitigating Systems Screening Questions, the issue screened as having very low safety significance (Green) because it does not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding, or severe weather initiating event. This finding had a cross-cutting aspect in the area of problem identification and resolution associated with identification because the licensee failed to identify issues, completely, accurately, and in a timely manner in accordance with the corrective action program. Specifically, the licensee failed to identify these deficiencies during a review of these same procedures as part of actions to close significant performance deficiencies as documented in Arkansas Nuclear One Area Action Plan FP-6 (P.1).
05000313/FIN-2016008-01	2016Q4	Arkansas Nuclear	Failure to Verify the Adequacy of Motor Operated Valve Thermal Overload Devices	Green. The team identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, which states, in part, design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program. Specifically, prior to December 2, 2016, the licensee failed to use appropriate assumptions in thermal overload device calculations and failed to establish a suitable periodic test program for safety-related Unit 1 motor operated valve thermal overload device trip setpoints, as discussed in Regulatory Guide 1.106, Regulatory Position C.2. In response to this issue, the licensee demonstrated reasonable assurance of operability by using the results of the 18-month high pressure injection system valve testing which required multiple stroking of block valves to obtain various flows without tripping the thermal overload devices. This finding was entered into the licensees corrective action program as Condition Reports CR-ANO-C-2016-5017 and CR-ANO-1-2016-5130. The team determined that the failure to meet the intent of Regulatory Guide 1.106, Regulatory Position C.2 was a performance deficiency. The finding was determined to be more than minor because it was associated with the Mitigating Systems Cornerstone attribute of equipment performance and affected the cornerstone objective of ensuring the availability, reliability, and capability of mitigating systems to respond to initiating events to prevent undesirable consequences. Specifically, the failure to verify the adequacy of the design and perform suitable testing for thermal overload device setpoint drift did not ensure that the safety-related motor operated valves would be available to throttle the associated system flows during a design basis accident. In accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, Exhibit 2, Mitigating Systems Screening Questions, the issue screened as having very low safety significance (Green) because it was a design or qualification deficiency that did not represent a loss of operability or functionality; did not represent an actual loss of safety function of the system or train; did not result in the loss of one or more trains of non-technical specification equipment; and did not screen as potentially risk-significant due to seismic, flooding, or severe weather. This finding had a cross-cutting aspect in the area of problem identification and resolution associated with evaluations because the licensee failed to thoroughly evaluate issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance. Specifically, the licensee failed to thoroughly evaluate Condition Report CR-ANO-1-2016-0778 which documented NRC inspector concerns associated with design and testing of motor operated valve thermal overload devices (P.2).
05000285/FIN-2015009-02	2015Q4	Fort Calhoun	Failure to Revise Procedures and Perform Additional Training	The team evaluated a self-revealing NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions, which states, in part, that Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies... are promptly identified and corrected. Specifically, prior to September 30, 2015, the licensee failed to revise procedures, and perform additional operator training, to prevent the inadvertent opening of steam bypass and steam dump valves during plant startup, and any subsequent plant impacts. In response to this issue, the licensee initiated a condition report to document these corrective actions. This finding was entered into the licensees corrective action program as Condition Report CR-FCS-2015-13718. The team determined that the failure to take timely corrective actions to revise procedures and complete additional training to correct a condition adverse to quality, was a performance deficiency. This finding was more than minor because it was associated with the initiating events cornerstone objective of configuration control to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the licensee failed to take recommended corrective actions to revise procedures and perform additional operator training to ensure proper alignment of the steam dump and bypass valves controller during startup. In accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, Exhibit 1, Initiating Events Screening Questions, the team determined that the finding was determined to have very low safety significance (Green) since the transient did not result in a reactor trip or loss of mitigation equipment. The finding has a problem identification and resolution cross-cutting aspect in the area of Operating Experience, because the licensee failed to systematically and effectively collect, evaluate, and implement relevant internal operating experience in a timely manner (P.5).
05000416/FIN-2015008-03	2015Q4	Grand Gulf	Failure to Declare Secondary Containment Inoperable Based on Failed Surveillance Testing	The team identified a non-cited violation of Technical Specification 3.6.4.1 Condition A, for the failure to declare secondary containment inoperable. Specifically, on August 1, 2015, the licensee failed to declare secondary containment inoperable after it failed to achieve the necessary vacuum to pass Surveillance Requirement 3.6.4.1.4. The licensee entered this issue into their corrective action program as Condition Report CR-GGN-2015-05826. The failure to declare secondary containment inoperable due to failed surveillance test and enter the appropriate action statements as required by the licensees technical specifications is a performance deficiency. This deficiency is more than minor, and therefore a finding, because it is associated with the Structures, Systems, Components, and Barrier Performance attribute of the Barrier Integrity cornerstone. Specifically, the failure to declare secondary containment inoperable and take actions as required in Technical Specification Limiting Condition for Operation 3.6.4.1, Condition A, within four hours, adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, and Inspection Manual Chapter 0609, Appendix A, Exhibit 3, Barrier Integrity Screening Questions, dated July 1, 2012, the team determined that the finding is of very low safety significance (Green) because it only represented a degradation of the radiological barrier function provided for the auxiliary building secondary containment. The team determined that this finding has a cross-cutting aspect associated with avoid complacency, in that individuals did not recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Although the surveillance test was documented as Technical Specification Acceptance Criteria Unacceptable because it did not meet the criteria defined in test procedure 06-OP-1T48-R- 0002, Standby Gas Treatment A Logic and Vacuum Test, Revision 115, the licensee did not identify it as a failed surveillance test that affected secondary containment operability.
05000416/FIN-2015004-03	2015Q4	Grand Gulf	Failure to Make a Required Eight-Hour Report for Loss of Safety Function	The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.72(b)(3)(v)(C), for the licensees failure to make a required eight-hour report to the NRC for a condition that could have prevented fulfillment of the safety function of structures or systems that are needed to control the release of radioactive material. Specifically, on October 14, 2015, the licensee failed to make the required eight-hour report following two primary containment isolation valves, 1P11F130 and 1P11F131, in the same flow path being declared inoperable. On October 15, 2015 at 9:07 pm, the licensee made a late Event Notification, EN 51473. The licensee entered this issue into their corrective action program as Condition Report CR-GGN-2015-6043. The failure to make an eight-hour report, as required by 10 CFR 50.72(b)(3)(v)(C), for a condition that could have prevented fulfillment of a safety function was a performance deficiency. This performance deficiency was screened using Inspection Manual Chapter 0612 and was determined to be a minor violation in the Reactor Oversight Process. However, due to the performance deficiency affecting the NRCs ability to perform its regulatory oversight function, this performance deficiency was evaluated for traditional enforcement in accordance with the NRC Enforcement Policy. This performance deficiency was determined to be a Severity Level IV violation in accordance with Section 6.9.d.9 of the NRC Enforcement Policy, dated February 4, 2015. No cross-cutting aspect was assigned to this violation because no Reactor Oversight Process finding existed.
05000416/FIN-2015008-04	2015Q4	Grand Gulf	Failure to Make Required Event Notification	The team identified two examples of a Severity Level (SL) IV non-cited violation of 10 CFR 50.72(b)(3)(v)(C), for the failure to make an eight-hour report to the NRC for a condition that prevented the fulfillment of the safety function needed to control the release of radioactive material. Specifically, on August 1, 2015, and again on October 1, 2015, after failed secondary containment surveillance tests, the licensee failed to make an eight-hour report to the NRC for the loss of secondary containment barrier safety function needed to control the release of radioactive material. The licensee entered this issue into their corrective action program as Condition Report CR-GGN-2015-05826. The failure to report a condition that could have prevented the fulfillment of a systems safety function as required by 10 CFR 50.72(b)(3)(v)(C) is a performance deficiency. This performance deficiency was screened using Inspection Manual Chapter 0612 and was determined to be minor in the Reactor Oversight Process. However, due to the performance deficiency affecting the NRCs ability to perform its regulatory oversight function, this performance deficiency was evaluated for traditional enforcement in accordance with the NRC Enforcement Policy. This performance deficiency was determined to be a Severity Level IV violation in accordance with Section 6.9.d.9 of the NRC Enforcement Policy, dated February 4, 2015. No cross-cutting aspect was assigned to this violation because no Reactor Oversight Process finding exists.
05000416/FIN-2015004-06	2015Q4	Grand Gulf	Licensee-Identified Violation	Title 10 CFR 50.54(hh)(1)(iv) and (vi) require, in part, that licensees implement onsite actions necessary to enhance the capability of the facility to mitigate the consequences of an aircraft impact; and procedures for dispersal of equipment and personnel. Regulatory Guide 1.214, "Response Strategies for Potential Aircraft Threats," Section 7.1, states that to meet the dispersal requirement, licensee should include security personnel for accomplishing post-impact meditative actions in aircraft threat procedures. It further states, to include suitable locations to which those resources can be repositioned to increase survivability. Contrary to the above, on October 21, 2015, during the Grand Gulf Nuclear Station's biennial NRC evaluated exercise, the licensee failed to implement onsite actions necessary to enhance the capability of the facility to mitigate the consequences of an aircraft impact and did not have procedures for the dispersal of equipment and personnel. Specifically, during an emergency preparedness exercise observed by NRC, the licensee had not established an adequate process to use upon receiving potential aircraft threat warnings (simulated) from the NRC, to decide when or if to disperse or reposition security personnel to increase survivability. This finding was entered in the licensee's corrective action program as Condition Report CR-GGN-2015-06195. The finding is more than minor because if left uncorrected, it would have the potential to lead to a more significant security or safety concern; this failure could potentially and adversely affect survivability of security response personnel in the flight path of a potential aircraft threat as well as the capability to take appropriate actions to ensure adequate security resources when mitigating the consequences of an aircraft impact. The significance of the finding was assessed using NRC IMC 0609, Appendix E, Part I, Baseline Security Significance Determination Process, and it was determined to be of very low security significance (Green).
05000416/FIN-2015004-05	2015Q4	Grand Gulf	Licensee-Identified Violation	Technical Specification 3.6.1.3, Surveillance Requirement 3.6.1.3.9, requires, verification of combined leakage rate of 1 gallon per minute times the total number of primary containment isolation valves through hydrostatically tested lines that penetrate the primary containment is not exceeded when these isolation valves are tested at greater than or equal to 1.1 times peak containment pressure. Contrary to the above, since June 6, 2012, the licensee failed to verify combined leakage rate of 1 gallon per minute times the total number of primary containment isolation valves through hydrostatically tested lines that penetrate the primary containment is not exceeded when these isolation valves are tested at greater than or equal to 1.1 times peak containment pressure. Specifically, the post-extended power uprate peak containment pressure analyzed increased to 14.8 psig, resulting in a new required test pressure of 16.28 psig. The licensee did not test primary containment isolation valves 1P11F130 and 1P11F131 using the new higher pressure. The licensee subsequently declared the valves inoperable and tested the two valves using the new peak containment pressure. The valves passed the surveillance test and were declared operable at 11:01 am on October 15, 2015. This finding was entered in the licensee's corrective action program as Condition Report CR-GGN-2015-05072. The finding is more than minor because it was associated with the barrier performance attribute of the Barrier Integrity Cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers (containment) protect the public from radionuclide releases caused by accidents or events. Specifically, the licensee never performed Technical Specification Surveillance Requirement 3.6.1.3.9, and therefore did not have presumption of operability to provide the reasonable assurance that containment would protect the public from radionuclide releases caused by accidents or events. The significance of the finding was assessed using Inspection Manual Chapter 0609, Appendix A, Exhibit 3, Barrier Integrity Screening Questions, and it was determined to be of very low safety significance (Green).
05000416/FIN-2015004-04	2015Q4	Grand Gulf	Failure to Establish Adequate Maintenance Instructions to Perform Work Activities on the Division III Diesel Generator Overspeed Trip Limit Switch	The inspectors reviewed a self-revealing non-cited violation of Technical Specification 5.4.1.a, for the failure to establish adequate maintenance instructions to perform work activities on the division III diesel generator overspeed trip limit switch. Specifically, work orders did not contain adequate instructions to check the overspeed trip switches alignment in accordance with vendor recommendations. As a result, the division III diesel generator was rendered inoperable and unavailable. On July 15, 2015, the licensee appropriately set the limit switch to overspeed actuating arm engagement, and returned the diesel generator to operable. The licensee entered this issue into their corrective action program as Condition Report CR-GGN-2015-3985. The failure to establish adequate work instructions to verify the overspeed switch was properly set and adjusted was a performance deficiency. This performance deficiency is more than minor, and therefore a finding, because it is associated with the equipment performance attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, work orders to check the overspeed trip switches alignment did not contain adequate instructions to successfully perform the maintenance. The division III diesel generator was declared inoperable when the diesel spuriously tripped during the monthly surveillance run on July 13, 2015. The inspectors performed the initial significance determination for the division III emergency diesel generator failure. The inspectors used the NRC Inspection Manual 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions. The finding required a detailed risk evaluation because it involved a performance deficiency that represented a loss of the high pressure core spray system following a postulated loss of offsite power because of the failure of the division III diesel generator. The Region IV senior reactor analyst performed a detailed risk evaluation in accordance with NRC Inspection Manual 0609, Appendix A, Section 6.0, Detailed Risk Evaluation. The detailed risk evaluation result is a finding of very low safety significance (Green). The calculated change in core damage frequency of 5.0 x 10-7 was dominated by an unrecovered station blackout beyond battery depletion. The analyst determined that the bounding risk of a large, early release of radiation was 9.6 x 10 . For the details of the analysis, see Attachment 3. Work orders were developed to address operating experience provided from the diesel generator vendor to the industry in December 2011. The inspectors determined that the cause of the deficiency occurred in 2011, and therefore, determined the finding did not have a cross-cutting aspect since it is not indicative of current licensee performance.
05000416/FIN-2015004-01	2015Q4	Grand Gulf	Failure to Have Appropriate Instructions for Preventative Maintenance on the Division I Diesel Generator Simulated Run	The inspectors reviewed a self-revealing non-cited violation of Technical Specification 5.4.1.a, for the failure to establish adequate instructions to perform a simulated surveillance on the division I diesel generator. Specifically, the simulated surveillance run instructions verified the trip high vibration (E-23H) valve was open, but it did not close the (E-23H) valve following the run to ensure the high vibration trip was bypassed. As a result, the division I diesel generator spuriously tripped on high vibrations during the November 21, 2015, run and was rendered inoperable and unavailable. On November 22, 2015, the licensee closed the trip high vibration (E-23H) valve and successfully ran the division I diesel generator to return it to operable status. The licensee entered this issue into their corrective action program as Condition Report CR-GGN-2015-6831. The failure to establish adequate preventative maintenance instructions to perform a division I diesel generator simulated run and return the valve lineup to the required position was a performance deficiency. This performance deficiency is more than minor, and therefore a finding, because it is associated with the equipment performance attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, following the division I diesel generator simulated run, the preventative maintenance instruction did not require the licensee to close the trip high vibration (E-23H) valve, and therefore the high vibration trip capability remained for a duration of approximately 16 hours. As a result, during the November 21, 2015 run, the diesel generator spuriously tripped on an invalid high vibration signal and was rendered inoperable and unavailable. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, and Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined that the finding is of very low safety significance (Green) because it: (1) was not a deficiency affecting the design or qualification of a mitigating structure, system, or component, and did not result in a loss of functionality; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time; and (4) did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety significant in accordance with the licensees maintenance rule program. The inspectors determined that the finding has a design margin cross-cutting aspect within the human performance area because the licensee failed to ensure margins are carefully guarded and changed only through a systematic and rigorous process. Specifically, the licensee failed to fully implement their design change process such that all effected station documents and procedures were identified and revised after removing the high vibration trip for the division I and division II diesel generators (H.6).
05000285/FIN-2015009-01	2015Q4	Fort Calhoun	Failure to Take Adequate Corrective Action to Preclude Repetition of a Significant Condition Adverse to Quality Associated with Emergency Diesel Generator Room Water Intrusions	The team identified an NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions, for the licensees failure to take corrective actions to prevent repetition of a significant condition adverse to quality. Specifically, since February 2009, the licensee failed to take corrective actions to prevent repetitive water intrusions from the Auxiliary Building HVAC room (Room 82) into the number one Emergency Diesel Generator room (Room 63). The inspectors determined that the licensees failure to implement corrective actions to preclude repetitive water intrusions into Room 63 was a performance deficiency. The performance deficiency was more than minor because it was associated with the protection against external factors attribute of the mitigating systems cornerstone. Specifically, water intrusion events from Room 82 into Room 63 could challenge the reliability of the emergency diesel generator when relied upon during a loss of offsite power. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, Exhibit 2, Mitigating Systems Screening Question, inspectors determined that the finding was of very low safety significance (Green). The finding has a problem identification and resolution cross-cutting aspect within the area of Resolution, because the licensee did not take effective corrective actions to address issues in a timely manner commensurate with their safety significance (P.3).
05000416/FIN-2015008-01	2015Q4	Grand Gulf	Failure to Enter a Condition Adverse to Quality into the Corrective Action Program	The team identified a non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, for the failure to identify and correct a condition adverse to quality by entering it into the corrective action program for resolution. Specifically, the licensee failed to identify and correct the potential for safety-related Standby Service Water fans to rotate backwards under certain design conditions, which could affect their ability to perform their safety function when needed. The licensee entered this condition into the corrective action program as CR-GGN-2015-02509. The failure to enter a condition adverse to quality into the corrective action program as required by station procedure EN-LI-102, Corrective Action Program, Revision 24, is a performance deficiency. This performance deficiency is more than minor, and therefore a finding, because it is associated with the design control attribute of the Mitigating Systems cornerstone and adversely affects the cornerstone objective to ensure the reliability and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, not evaluating an identified nonconformance resulted in the failure to ensure the capability of safety-related Structures, Systems, and Components to respond reliably during anticipated events. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, and Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, dated July 1, 2012, the team determined that the finding is of very low safety significance (Green) because it: (1) was not a deficiency affecting the design or qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time; and (4) did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety significant in accordance with the licensees maintenance rule program. The team determined that this finding has a crosscutting aspect associated with problem identification, specifically, individuals failed to ensure that the issue was reported and documented in the corrective action program at a low threshold.
05000416/FIN-2015008-02	2015Q4	Grand Gulf	Failure to Promptly Initiate Condition Reports	The team identified five examples of a non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, for the failure to promptly identify and correct conditions adverse to quality. Specifically, on October 8, 2015, the team identified five conditions adverse to quality where the licensee failed to initiate a condition report in a prompt/timely manner. The five conditions adverse to quality were associated with: (1) the short circuit analysis for the 480V motor control center breakers; (2) emergency diesel generators minimum and maximum frequency; (3) emergency diesel generators fuel consumption rate; (4) Division 3 Emergency Diesel Generator load shedding test; and (5) 120V AC power system calculations. The licensee entered this issue into their corrective action program as Condition Report CR-GGN-2015-05550. The failure to promptly identify conditions adverse to quality and enter them into the corrective action program by initiating a condition report in a prompt/timely manner as required by Section 5.2(3) of EN-LI-102, Corrective Action Program, Revision 24, is a performance deficiency. This performance deficiency is more than minor, and therefore a finding, because the five examples are associated with the design control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, and Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the team determined that the finding is of very low safety significance (Green) because it: (1) was not a deficiency affecting the design or qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time; and (4) did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program. The team determined that this finding has a cross-cutting aspect associated with training, in that the organization did not provide training or ensure knowledge transfer to maintain a knowledgeable, technically competent workforce and instill nuclear safety values. Specifically, when the NRC identified the five conditions adverse to quality to licensee personnel, the licensee personnel did not recognize these conditions required prompt/timely initiation of a condition report.
05000416/FIN-2015004-02	2015Q4	Grand Gulf	Failure to Timely Enter Technical Specification Surveillance Requirement 3.0.1	The inspectors identified a non-cited violation of Technical Specification Surveillance Requirement 3.0.1, for the failure to follow requirements when a surveillance was not performed within the specified frequency and declare the Limiting Condition for Operation not met or follow the provisions in Surveillance Requirement 3.0.3. Specifically, the licensee did not follow Technical Specification Surveillance Requirement 3.0.1, when they discovered that Surveillance Requirement 3.8.1.9 was not performed within its specified frequency and either declare Technical Specification Limiting Condition for Operation 3.8.1 not met, or perform the required actions to determine whether compliance with the requirement to declare the Limiting Condition for Operation not met may be delayed. The licensee failed to enter Technical Specification Surveillance Requirement 3.0.1, until September 29, 2015, after discussions with the NRC. On September 29, 2015, the licensee adequately performed the actions required in Technical Surveillance Requirement 3.0.3. The licensee entered this issue into their corrective action program as Condition Report CR-GGN-2015-5602. The failure to timely enter and perform the actions as required per Technical Specification Surveillance Requirement 3.0.1 was a performance deficiency. This performance deficiency is more than minor, and therefore a finding, because it is associated with the equipment performance attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to perform technical specification surveillance requirements, and associated actions, did not ensure that the diesel generator could appropriately respond to initiating events. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, and Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined that the finding is of very low safety significance (Green) because it: (1) was not a deficiency affecting the design or qualification of a mitigating structure, system, or component, and did not result in a loss of functionality; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time; and (4) did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety significant in accordance with the licensees maintenance rule program. The inspectors determined that the finding has a conservative bias cross-cutting aspect within the human performance area because the licensee failed to use decision makingpractices that emphasize prudent choices over those that are simply allowable. Specifically, operations personnel failed to enter Technical Specification Surveillance Requirement 3.0.1 because the operability determination alone justified operability without doing a detailed risk evaluation (H.14).
05000445/FIN-2015008-03	2015Q3	Comanche Peak	Inadequate Procedure for Surveillance on Safety-Related Service Water Systems	The team identified a non-cited violation of Technical Specification (TS) 5.4.1, Procedures, for an inadequate procedure for performing surveillances on the station service water (SSW) systems in units 1 and 2. Specifically, Procedures OPT-207 A and B, Service Water System, were modified in September 2010 so that failure of any SSW vacuum breaker to OPEN was considered a degraded condition and not an inoperable condition of the associated SSW System train. However, per DBD-ME-233, Station Service Water, Revision 33, Active Valves, vacuum breakers are required by ASME (Code Section) III on the inlet and outlet piping to the diesel generator jacket water coolers to mitigate the effects of water hammer due to water column separation and subsequent rejoining following a pump trip. This issue does not represent an immediate safety concern because the licensee confirmed that all of the vacuum breakers in service had passed their most recent surveillance test. The licensee entered this issue into the corrective action program for resolution as Condition Report CR-2015-010800. The finding is more than minor because it is associated with the procedure quality attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the licensee did not ensure the guidance incorporated into quality related procedures was accurate and consistent with the design basis analysis for the systems and this conflict resulted in inadequate operability determinations associated with the SSW System. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, dated June 19, 2012, the team determined that the finding is of very low safety significance (Green) because (1) the finding was not a deficiency affecting the design or qualification of a mitigating system; (2) the finding did not represent a loss of system and/or function; (3) the finding did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and (4) the finding does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hours. This finding has a human performance cross cutting aspect associated with design margins because the licensee failed to operate and maintain the SSW system equipment within design margins. Rather than ensure that margins are carefully guarded and changed only through a systematic and rigorous process, the licensee failed to re-evaluate SSW system operability with failed vacuum breaker valves even when additional test information indicated previous assumptions were incorrect (H.6).
05000445/FIN-2015008-02	2015Q3	Comanche Peak	Failure to Properly Assess and Document the Basis for Operability associated with the Turbine Driven Auxiliary Feedwater Pumps Steam Exhaust Piping not being Evaluated for Tornado Generated Missile Impacts	The team identified a non-cited violation of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated the licensees failure to perform adequate operability assessments when a degraded or nonconforming condition was identified associated with the turbine driven auxiliary feedwater pumps steam exhaust piping not being evaluated for tornado generated missile impacts. Specifically, operators used probabilistic assumptions and failed to adequately assess and document the basis for operability when a degraded or nonconforming condition was identified associated with the turbine driven auxiliary feedwater pumps steam exhaust piping not being evaluated for tornado generated missile impacts. This issue does not represent an immediate safety concern because the licensee performed a subsequent operability evaluation, which established a reasonable expectation of operability. The licensee entered this issue into the corrective action program for resolution as Condition Report CR-2015-007919. The licensees failure to properly assess and document the basis for operability when a degraded or nonconforming condition associated with the turbine driven auxiliary feedwater pumps steam exhaust piping not being evaluated for tornado generated missile impacts was identified, was a performance deficiency. The performance deficiency was more than minor because it was associated with the protection against external events factors attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to evaluate a design nonconformance on the turbine driven auxiliary feedwater pumps steam exhaust piping for lack of missile protection. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, dated June 19, 2012, the team determined that the finding is of very low safety significance (Green) because (1) the finding was not a deficiency affecting the design or qualification of a mitigating system; (2) the finding did not represent a loss of system and/or function; (3) the finding did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and (4) the finding does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hours. The finding has a human performance cross-cutting aspect associated with conservative bias because individuals failed to use decision-making practices that emphasize prudent choices over those that are simply allowable (H.14).
05000445/FIN-2015008-05	2015Q3	Comanche Peak	Failure to Perform Adequate Operability Assessments associated with Failures of Service Water System Vacuum Breaker during Surveillance Tests	The team identified an unresolved issue associated with the failures of the vacuum service water breakers that remained in service. During these failures, the licensee had documented the surveillance failures as degraded conditions and concluded that they did not have an impact on the operability of the service water system. The team reviewed the licensees operability assessments associated with surveillance tests where at least one of the service water system vacuum breakers failed to meet acceptance standards. During these failures, maintenance personnel mechanically agitated the vacuum breakers in order to get them to operate but did not replace the vacuum breakers until a future date. The inspectors noted that design basis calculations indicate that the larger of the two vacuum breakers (check valve) was required in order to protect the EDG jacket service water coolers and concluded that the licensee did not have appropriate justification to conclude that the service water system remained operable with a failed vacuum breaker if it was the larger breaker. During the inspection period the team was not able to determine which vacuum breakers were found in a degraded condition, therefore more information is required to determine if a non-compliance exists. Specifically, since September 2010, the licensee issued twenty six operability evaluations associated with failed surveillance test on vacuum breakers in the service water system where operators used incorrect information when assessing operability, which failed to establish a reasonable expectation of operability. This issue does not represent an immediate safety concern because at the time of discovery, there were no failed vacuum breakers in service. The licensee entered the finding into corrective action program as Condition Report CR-2015-008334. This issue will remain unresolved until the NRC is provided sufficient information regarding the particulars associated with the check valve/vacuum breaker failures in order to determine if a non-compliance exists. Specifically, the team requires information associated with the specific valve(s) that failed the length of time that the failed valve remained in service prior to replacement; whether the opposite train diesel generator was ever inoperable during the period the failed valve remained in service. (URI 05000445/2015008-05; 05000446/2015008-05, Failure to Perform Adequate Operability Assessments associated with Failures of Service Water System Vacuum Breaker during Surveillance Tests)
05000445/FIN-2015008-04	2015Q3	Comanche Peak	Failure to Maintain Adequate Controls for Design Calculations	The team identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, with two examples associated with the licensees failure to ensure that design changes were subject to design control measures commensurate with those applied to the original design and were approved by the designated responsible organization. Specifically: (1) The licensee instituted an engineering change package to modify the design and setpoints for the station service water (SSW) system vacuum breaker valves (CP1/2-SWVAVB-01/02/03/04) and did not consider the allowable tolerance for the setpoint for all design basis events and operating conditions. The licensee adequately addressed this issue by reperforming the calculation incorporating the setpoint allowable tolerance. (2) The licensee failed to account for system design leakage in design calculation DBD-CS-096, for the safe shutdown impoundment minimum level. The licensee evaluated the water loss from the impoundment due to evaporation, but failed to account for losses due to system design leakage. The licensee adequately addressed this issue by applying the design system leak rate for a 30-day mission time to the available water in the safe shutdown impoundment. The licensees failure to evaluate properly the effects of modifying the setpoint including allowable tolerances for all modes of operation and all sources of water loss from the safe shutdown impoundment was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the configuration control attribute of the Mitigating Systems Cornerstone, and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings AtPower, Exhibit 2, Mitigating Systems Screening Questions, dated June 19, 2012, the team determined that the finding is of very low safety significance (Green) because (1) the finding was not a deficiency affecting the design or qualification of a mitigating system; (2) the finding did not represent a loss of system and/or function; (3) the finding did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and (4) the finding does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hours. The inspectors determined that this finding does not have a cross-cutting aspect because the most significant contributor of this finding occurred more than three years ago and does not reflect current licensee performance.
05000445/FIN-2015008-01	2015Q3	Comanche Peak	Failure to Evaluate the Lack of Missile Protection on the Turbine Driven Auxiliary Feedwater Pumps Steam Exhaust Piping	The team identified a cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to evaluate the lack of missile protection on the turbine driven auxiliary feedwater pumps steam exhaust piping. Specifically, since June 13, 2012, the licensee failed to verify the adequacy of design of the turbine driven auxiliary feedwater pumps steam exhaust piping to withstand impact from a tornado driven missile hazard, or to evaluate for exemption from missile protection requirements using an approved methodology. This issue does not represent an immediate safety concern because the licensee performed an operability evaluation, which established a reasonable expectation of operability. The licensee entered this issue into the corrective action program for resolution as Condition Report CR-2015-007869. The licensees failure to analyze the effects of a tornado missile strike on the turbine driven auxiliary feedwater pumps steam exhaust piping was a performance deficiency. The performance deficiency was more than minor because it was associated with the protection against external events factors attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to evaluate a design nonconformance on the turbine driven auxiliary feedwater pumps steam exhaust piping for lack of missile protection. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, dated June 19, 2012, the team determined that the finding is of very low safety significance (Green) because (1) the finding was not a deficiency affecting the design or qualification of a mitigating system; (2) the finding did not represent a loss of system and/or function; (3) the finding did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and (4) the finding does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hours. The finding has a human performance cross-cutting aspect associated with conservative bias because individuals failed to use decision-making practices that emphasize prudent choices over those that are simply allowable (H.14).
05000397/FIN-2015007-06	2015Q1	Columbia	Failure to Initiate Condition Report for Operating Experience that Impacts Molded Case Circuit Breakers	The team identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, for the licensees failure to initiate a condition report as required by the operating experience program. Specifically, the licensee failed to initiate a condition report for a nonconforming condition involving molded case circuit breakers. Following discovery of this issue, the licensee initiated Action Request AR 324184 documenting six General Electric molded case circuit breakers installed in the plant without the required preventative maintenance tasks. The licensee entered the failure to follow the requirements of operating experience procedure into their corrective action program as Action Request AR 324159. The licensees failure to initiate a condition report for a nonconforming condition was a performance deficiency. This performance deficiency is more than minor, and therefore a finding, because it is associated with the human performance attribute of the Mitigating Systems cornerstone and adversely affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The finding is of very low safety significance (Green) because the finding was not a deficiency affecting the design or qualification of a mitigating system; the finding did not represent a loss of system and/or function; the finding did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and the finding does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hours. This finding has a cross-cutting aspect in the area of problem identification and resolution, evaluation, in that the licensee failed to fully evaluate the operating experience to determine if the required preventative maintenance for molded case circuit breakers was complete (P.2).
05000397/FIN-2015007-05	2015Q1	Columbia	Failure to Translate Design Basis into Component Classification Evaluation Records	The team identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to translate the design basis into specifications. Specifically, the team identified five instances where the licensee failed to translate the design basis into specifications in the form of component classification evaluation records. Plant operators use these records to establish the current licensing basis of the facility when performing operability determinations. The licensee initiated Action Request ARs 323666, 324082, 324130, 324135 and 324144, to address the individual examples of inaccurate component classification records and AR 324160 to address process deficiencies related to the use of these records. The licensees failure to translate station design requirements into specifications was a performance deficiency. The performance deficiency is more than minor because it affects the design control attribute of the Mitigating Systems cornerstone and adversely affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, this performance deficiency resulted in inaccurate design basis documents being used by plant operators to make operability decisions. The finding is of very low safety significance (Green) because the finding was not a deficiency affecting the design or qualification of a mitigating system; the finding did not represent a loss of system and/or function; the finding did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and the finding does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hours. This finding has a cross-cutting aspect in the area of problem identification and resolution, resolution, in that the licensee failed to take timely action to address inadequate design records (P.3).
05000397/FIN-2015007-04	2015Q1	Columbia	Failure to Maintain Maintenance Procedures for Temperature Control Valve Electro-Hydraulic Operators	The team reviewed a self-revealing Green, non-cited violation of Technical Specification 5.4.1.a, Procedures, for the licensees failure to provide adequate work instructions for performing maintenance on service water temperature control valve electrohydraulic operators. Consequently, following maintenance on service water temperature control valve SW-TCV-15A, the valve operator uncoupled from the valve stem resulting in an unplanned trip of control room emergency chiller CCH-CR-1A. The licensee initiated Action Request AR 324188 to address the inadequate maintenance instructions for valve electrohydraulic operators. The licensees failure to maintain adequate work instructions for maintenance on electro hydraulic operators was a performance deficiency. The performance deficiency is more than minor, and therefore a finding, because it affects the equipment performance attribute of the Mitigating Systems cornerstone and adversely affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The team determined that the finding is of very low safety significance (Green) because; the finding was a deficiency affecting the design or qualification of a mitigating system that did no result in a loss of operability. The finding is of very low safety significance (Green) because the finding was not a deficiency affecting the design or qualification of a mitigating system that; the finding did not result inrepresent a loss of operability system and/or function; the finding did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and the finding does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hours. This finding did not have a cross-cutting aspect since the cause of procedural deficiency was due to an error during initial development and was therefore not reflective of current licensee performance.
05000397/FIN-2015007-03	2015Q1	Columbia	Failure to Identify and Evaluate the Operability of a Nonconforming Condition Involving Molded Case Circuit Breakers	The team identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, for the licensees failure to identify a nonconforming condition involving molded case circuit breakers. Consequently, operations staff failed to perform an operability determination in accordance with Procedure 1.3.66, Operability and Functionality Evaluation, for six molded case circuit breakers installed without the proper preventative maintenance. Following identification of this issue, the licensee performed a prompt operability determination for the six molded case circuit breakers on March 22, 2015. The licensee entered this issue into the corrective action program as Action Request AR 324146. The licensees failure to perform an operability determination in accordance with station procedures for a nonconforming condition involving molded case circuit breakers was a performance deficiency. This performance deficiency is more than minor, and therefore a finding, because it is associated with the human performance attribute of the Mitigating Systems cornerstone and adversely affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The finding is of very low safety significance (Green) because the finding was not a deficiency affecting the design or qualification of a mitigating system; the finding did not represent a loss of system and/or function; the finding did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and the finding does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hours. This finding has a cross-cutting aspect in the area of human performance, design margin, in that the licensee failed to recognize that the current licensing basis includes margins such as those provided for by a preventative maintenance program (H.6).
05000397/FIN-2015007-02	2015Q1	Columbia	Failure to Maintain Configuration Control of Ventilation Systems Needed for Station Blackout	The team identified a Green, non-cited violation of 10 CFR 50.63, Loss of All Alternating Current Power, for the licensees failure to maintain appropriate quality assurance requirements for components needed to cope with a station blackout event. Specifically, the licensee failed to maintain configuration control of the standby service water pump house A ventilation system such that the system would provide sufficient capability during a postulated station blackout. The licensee entered the issue in the corrective action program as Action Request AR 324106. On March 22, 2015, the licensee replaced filter POA-FL-1A so that the system could supply the airflow assumed in Calculation ME-02-92-65. The licensees failure to maintain the configuration of the pump house outside air system used to cope with a station blackout in accordance with 10 CFR 50.63 was a performance deficiency. The performance deficiency is more than minor, and therefore a finding, because it is associated with the configuration control attribute of the Mitigating Systems cornerstone and adversely affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The finding is of very low safety significance (Green) because the finding was not a deficiency affecting the design or qualification of a mitigating system; the finding did not represent a loss of system and/or function; the finding did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and the finding does not represent an actual loss of function of one or more nontechnical specification trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hours. The finding does not have a cross-cutting aspect since the configuration control error is associated with initial implementation of the station blackout rule and therefore not reflective of current licensee performance.
05000397/FIN-2015007-01	2015Q1	Columbia	Failure to Initiate Condition Report for a degraded Condition Outside the Scope of Maintenance Work Order	The team identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to initiate a condition report in accordance with SWP-CAP-01, Corrective Action Program, Revision 22. Specifically, on October 23, 2013, the licensee failed to initiate a condition report to document that the motor operator for valve SW-V-75A had a missing plug and insufficient grease in the limit switch compartment of the valve operator. The licensee initiated Action Request AR 323201 to enter this issue into the corrective action program, following the teams identification of this issue. The licensees failure to initiate a condition report upon discovery of an unexpected degraded or nonconforming condition was a performance deficiency. The performance deficiency is more than minor, and therefore a finding, because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affects the associated objectives to ensure availability, reliability, and capability of systems that responds to initiating events to prevent undesirable consequences. Specifically, the licensees failure to initiate a condition report could have left the condition uncorrected and prevented the valve from meeting its intended safety function. In addition, failure to initiate a condition report for a degraded valve operator could have prevented additional adverse conditions from being identified, because the licensee had not performed an extent of condition review. The finding was of very low safety significance (Green) because although it affected the qualification of one or more mitigating systems, structures, or components (SSCs), these SSCs maintained their functionality. The finding has a cross-cutting aspect in the area of human performance consistent process, in that maintenance personnel did not use an established process for decision making in failing to document an unanticipated degraded condition in the corrective action program (H.13).
05000498/FIN-2014010-02	2014Q4	South Texas	Licensee-Identified Violation
05000498/FIN-2014010-01	2014Q4	South Texas	Security
05000483/FIN-2014008-03	2014Q3	Callaway	Emergency Diesel Generator Operability Evaluations using 7 Day Mission Time	The team identified an unresolved item concerning the licensees operability evaluations associated with a 7-day mission time for the emergency diesel generators as written in Station Procedure APA-ZZ-00500 Appendix 1, Operability and Functionality Determinations, Revision 22, and the assumption in FSAR Section 3.1.2 crediting the loss of offsite power and restored in 7 days. The team noted that the design basis accidents in FSAR Chapter 15 were analyzed to 30 days and questioned whether operability determinations using an emergency diesel generator 7-day mission time was appropriate. The team reviewed CARs 201303303 and 201303613 and Station Procedure APA-ZZ-00500 Appendix 1, Operability and Functionality Determinations, Revision 22, concerning jacket water leaks on emergency diesel generators A and B. The team noted the station had used a 7-day mission time for the emergency diesel generators operability evaluations and declared both emergency diesel generators operable. Station Procedure APA-ZZ-00500 Appendix 1 stated in part that the emergency diesel generator mission time is 7 days (and that) this is consistent with the 7-day capacity of the emergency diesel generator fuel storage tanks. The team noted that Technical Specification Basis 3.8.3, Diesel Fuel, Lube Oil, and Starting Air and FSAR Section 9.5.4, Emergency Diesel Engine Fuel Oil Storage and Transfer System do require a 7-day capacity for the emergency diesel generator fuel storage tanks. This requirement, in conjunction with the ability to obtain replacement of fuel supplies within 7 days, supports the availability of the emergency diesel generators required to shut down the reactor and to maintain it in a safe condition for an anticipated operational occurrence or a postulated design basis accident with a loss of offsite power. The licensee stated the basis for the emergency diesel generator 7-day mission was contained in FSAR Section 3.1.2 Additional Single Failure Assumptions, and was part of the original FSAR submittal to the NRC, and not APA-ZZ-00500 Appendix 1. FSAR Section 3.1.2 states, in part, In designing for and analyzing for Design Basis Accidents (i.e., large break loss-ofcoolant accident, main steam line break, main feedwater line break, rod rejection, locked reactor coolant pump rotor or shaft break, fuel handling accident, or steam generator tube rupture), the following assumptions (a-f) are made in addition to postulating the initiating event. e. All offsite power is simultaneously lost and is restored within 7 days (except for the events postulated to occur during MODE 5, MODE 6, and/or during movement of irradiated fuel assemblies when the plant is MODE 5 or MODE 6 or with the core fully offloaded, such as a fuel handling accident, a loss of all offsite power is not required to be assumed in addition to a single failure.) The team reviewed Safety Evaluation Report (SER) and FSAR Section 15.0 Accident Analysis to determine if the stations basis of restoring offsite power in 7 days was appropriate when evaluating operability of emergency diesel generators for degraded nonconforming conditions. The SER did not document whether the NRC approved or disapproved the assumption of restoration of offsite power in 7 days during a design basis accident (FSAR Section 15). However, the team noted the following contained in FSAR Section 15: The basic principle applied in relating design requirements to each of the conditions is that the most probable occurrences should yield the least radiological risk to the public, and those extreme situations having the potential for the greatest risk to the public shall be those least likely to occur. Where applicable, reactor trip system and engineered safeguards functioning assumed to the extent allowed by considerations, such as the single failure criterion, in fulfilling this principle. This means that seismic Category I, Class IE (safety-related 4160 Vac Buses NB01 and NB02 and emergency diesel generators A and B), and IEEE qualified equipment, instrumentation, and components are used in the ultimate mitigation of the consequences of Conditions II (Faults of moderate frequency), III (Infrequent faults), and IV (Limiting faults- design basis accidents) events. The team determined that more inspection was necessary to resolve whether it was appropriate to evaluate emergency diesel generator operability using a 7-day mission time based on the restoration of offsite power as stated in FSAR Section 3.1.2, when no discussion of restoring offsite power was contained in the SER and FSAR Section 15. Since, further NRC clarification/interpretation of the existing guidance is necessary, the issue is considered an unresolved item pending further NRC review. (URI 05000483/2014008-03, Emergency Diesel Generator Operability Evaluations using a 7-Day Mission Time)
05000482/FIN-2014007-03	2014Q3	Wolf Creek	Failure to Include the Containment Coolers in a Test Program	The inspectors identified a violation of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, for the licensees failure to include the containment coolers in the heat exchanger inspection program that would demonstrate their leak tight integrity and capability to perform their safety function. During the period since the last problem and identification program inspection, the licensee had not implemented any means to assess the amount of corrosion in the tubing to support continued assurance of operability of containment coolers. Containment cooler operability earlier this year was the subject of NRC inspectors questions due to the lack of inspection and testing of the containment coolers. The containment coolers were subsequently hydrostatically tested to assure operability for a limited period of time. The licensee entered this finding in its corrective action program as CR-87668. The failure to include the containment coolers in the heat exchanger inspection program to demonstrate their leak tight integrity and capability to perform their safety function is a performance deficiency. The deficiency was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and it adversely affects the objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Therefore, the performance deficiency is a finding. The inspectors performed the significance determination using NRC Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, dated June 19, 2012, and Appendix A, The Significance Determination Process (SDP) For Findings At-Power, dated June 19, 2012. Using Appendix A, Exhibit 2, the inspectors determined that the finding was of very low safety significance (Green) because the finding was a design or qualification deficiency that was confirmed, not to result in loss of system operability or functionality. Any leaks that had occurring during this period were isolated or repaired such that the containment coolers were restored to operable status prior to exiting outages. In addition, the inspectors determined that the finding also had a potential to bypass the containment barrier, if containment pressure, in a loss of coolant accident, was greater than essential service water pressure in a containment cooler tube with a leak. Therefore, the inspectors evaluated the finding using NRC Inspection Manual Chapter 0609 Appendix H, Containment Integrity Significance Determination process dated May 6, 2004. It was determined that this is a Type B finding since there is no impact on delta core damage frequency. During Phase 1 screening, the finding does not screen out, because a pinhole leak can be considered a breach of a containment penetration. A Phase 2 assessment was performed assuming greater than a 30-day exposure. Essential service water (cooling water running through the containment cooler tubes) pressure was determined to be greater than the maximum containment pressure during a design basis accident. This would cause no leakage from containment to environment. Additionally, analysis shows any leakage would be less than 100 percent containment volume/day through a pinhole leak. Therefore, this resulted in a Green finding. This finding has a cross-cutting aspect of identification in the problem identification and resolution area, associated with individuals identifying issues completely in accordance with the corrective action program. Licensee staff failed to identify that the lack of non-destructive inspection for the containment coolers was an item that required corrective action program implementation (P.1).
05000482/FIN-2014007-02	2014Q3	Wolf Creek	Failure to Preclude Repetition of a Significant Condition Adverse to Quality to Prevent Reactor Coolant System Leak	The inspectors reviewed a self-revealing violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions, for failure to prevent repetition of a significant condition adverse to quality related to reactor coolant system boundary leakage on April 20, 2014. This violation is documented in CR-87667. The failure to prevent the recurrence of a significant condition adverse to quality was a performance deficiency. This performance deficiency was more than minor because it affected the reactor coolant system equipment and barrier performance attribute of the Barrier Integrity cornerstone objective. Specifically, the failure to prevent the recurrence of high cycle fatigue, induced socket weld cracking resulting in reactor coolant system barrier leakage. The inspectors assessed the significance of the issue using IMC 0609, Appendix G Attachment 1, Shutdown Operations Significance Determination Process Phase 1 Initial Screening and Characterization of Findings, dated May 9, 2014. The finding was of very low safety significance (Green) because the finding did not cause a low temperature over pressurization, did not increase the potential for a freeze seal failure, did not involve steam generator nozzles dams, did not cause a boron dilution event, or degrade the ability to isolate a leak path. The performance deficiency occurred in 2003, this finding is not indicative of current plant performance and does not have a cross-cutting aspect.
05000482/FIN-2014007-01	2014Q3	Wolf Creek	Failure to Perform Operability Determinations on Degraded Boundaries	The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to perform operability determinations on degraded boundaries with credited compensatory measures in accordance with Wolf Creek Procedure AP 26C-004, Operability Determination and Functionality Assessment. Specifically, operations staff were stationing boundary watches to shut blocked open doors credited for maintaining operability of safety related components in the event of a high-energy line break in the turbine building. There was no reasonable assurance that an operator would be able to close these doors during a high-energy line break event. This violation is documented in CR-87666. The failure to perform operability determinations on degraded high-energy line break boundaries is a performance deficiency. This performance deficiency is more than minor because it 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. Using NRC Inspection Manual 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, the finding was determined to be of very low safety significance because the finding is a deficiency in the qualification of the mitigating system and a licensee evaluation determined that affected system was maintained operable. The finding has a cross-cutting aspect in resources in the human performance cross-cutting area because the licensee failed to ensure that procedures were adequate to support nuclear safety. Specifically, Wolf Creek Procedure AP 10 104, Breech Authorization, Revision 30, led operators to believe that operability determinations were not required for degraded boundaries and that a boundary watch was an adequate compensatory measure for a high-energy line break, despite clear guidance to the contrary in Procedure AP 26C-004 (H.1).
05000482/FIN-2014007-04	2014Q3	Wolf Creek	Failure to Incorporate LERs in OE Program	The inspectors identified a finding for the licensees failure to follow the operating experience programs requirement to review external licensee event reports, and initiate a condition report for those potentially applicable to Wolf Creek. The licensee had discontinued reviewing external licensee event reports and writing condition reports, contrary to Procedure AP-20E-001, Industry Operating Experience Program, Revision 25. Instead, the program relied upon the receipt of a third partys report prior to initiating a condition report. The inspectors determined that the third party does not submit a report for every nuclear power plant licensee event report. During the inspection, the licensee conducted an extent of condition and entered the issue into its corrective action program as CR-87670. The licensees failure to follow the operating experience programs requirement was a performance deficiency. This performance deficiency is more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, the licensees failure to review external licensee event reports and initiate condition reports when potentially applicable to Wolf Creek, per Procedure AP-20E-001 was a programmatic deficiency that could cause unacceptable conditions to go undetected. In accordance with Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, dated June 19, 2012, and Inspection Manual Chapter 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, the team determined the finding was most appropriately associated with the Mitigating System Cornerstone, and was of very low safety significance (Green) because the finding did not represent an actual loss of function. This finding has a cross-cutting aspect of avoid complacency, because the licensee did not use error reduction tools to confirm that the third-party report contained all external licensee event reports (H.12).
05000483/FIN-2014008-01	2014Q3	Callaway	Failure to Follow Operability Procedure	The team identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated with the licensees failure to assess operability in accordance with Station Procedure APA-ZZ-00500 Appendix 1, Operability and Functionality Determinations, Revision 22. Specifically, the licensee failed to assess operability when taking safety-related electrical cabinets and switchgear out of their seismically qualified configuration during maintenance activities. The licensee entered this deficiency into their corrective action program for resolution as Callaway Action Request 201405359. The licensees failure to assess the basis for operability of a degraded or nonconforming condition was a performance deficiency. This performance deficiency was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the associated objectives to ensure availability, reliability, and capability of systems that responds to initiating events to prevent undesirable consequences. Specifically, the licensees failure to assess and document operability resulted in conditions of unknown operability for degraded or nonconforming conditions. The finding is of very low safety significance (Green) because although it affected the qualification of one or more mitigating systems, structures or components (SSCs), these SSCs maintained their functionality. The finding has a cross-cutting aspect in the area of human performance associated with how the organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. In this case, the licensees work control process failed to evaluate the activity in order to assure nuclear safety (H.5).
05000483/FIN-2014008-02	2014Q3	Callaway	Failure to Analyze for Tornado Missile Strike on Turbine Driven Auxiliary Feedwater Steam Exhaust Piping	The team identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, associated with the licensees failure to verify the adequacy of the design of the turbine-driven auxiliary feedwater pump exhaust stack to be able to withstand the effects of natural phenomena. Specifically, the licensee failed to verify that the exhaust stack of the turbine was protected from the effects of tornado-generated missiles. The licensee entered this deficiency into their corrective action program for resolution as Callaway Action Request 201405508. The licensees failure to verify the adequacy of the design was a performance deficiency. This performance deficiency was more than minor because it was associated with protection against external events attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to ensure the reliability of the turbine-driven auxiliary feedwater pump after a postulated tornado missile impact to the steam exhaust piping. The finding was of very low safety significance because it represented a qualification deficiency that did not result in the loss of operability or functionality. The finding had a cross-cutting aspect in the area of problem identification and resolution for the licensees failure to thoroughly evaluate issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance (P.2).
05000458/FIN-2014004-01	2014Q3	River Bend	Failure to Provide Positive Exposure Control Within A Locked High Radiation Area	The inspectors identified a non-cited violation of Technical Specification 5.7.2 because a radiation protection technician did not provide positive exposure control to workers entering an area with dose rates greater than 1,000 millirem/hour. Radiation protection representatives removed the workers radiological controlled area access privileges, counseled the workers, conducted a stand-down meeting, and performed an apparent cause evaluation. The failure to provide positive control to workers entering an area with dose rates greater than 1,000 millirem/hour is a performance deficiency. The significance of the performance deficiency was more than minor because it was associated with an Occupational Radiation Safety cornerstone attribute (exposure control) and adversely affected the associated cornerstone objective because it allowed workers to be exposed to higher-than-planned radiation dose rates. The violation had very low safety significance because: (1) it was not an as low as is reasonably achievable finding because a collective dose threshold was not challenged, (2) there was no overexposure, (3) there was no substantial potential for an overexposure, and (4) the ability to assess dose was not compromised. This violation has a cross-cutting aspect in the human performance area, associated with avoiding complacency, because the radiation protection technician did not recognize and plan for the possibility of mistakes by the operators in identifying the correct valve to tag, and the inherent risk of the operators entering an unsurveyed area (H.12).
05000458/FIN-2014004-02	2014Q3	River Bend	Licensee-Identified Violation	River Bend Station License Condition 2.C.10, Attachment 4, requires, in part, that the licensee implement and maintain in effect all provisions of the approved fire protection program as described in the Updated Safety Analysis Report, as amended, and as approved in the Station Safety Evaluation Report, dated May 1984, and Supplement 3. Station Safety Evaluation Report, Supplement 3, concluded that the fire protection program was acceptable because it was in conformance with the guidelines of Appendix R, Section III.G. Appendix R, Section III.G, Paragraph 1.a, states, "One train of systems necessary to achieve and maintain hot shutdown conditions from either the control room or emergency control station(s) is free from fire damage." Contrary to the above, on January 9, 2014, the licensee identified that non-safe shutdown cables that shared a common enclosure with safe shutdown cables were not electrically protected and, therefore, did not meet the requirements of Appendix R, Section III.G. Specifically, the licensee identified that the battery ammeter circuits routed from the DC motor control centers to the ammeters located in the Control Room were not fused. These cables were routed in trays and installed in panels with other safe shutdown cables. During a fire event in the Control Room, fire-induced failures could have damaged the ammeter circuit and could have resulted in damaging other safe shutdown cables that are in direct physical contact with these cables in different fire zones. This issue was entered in the licensees corrective action program as Condition Report CR-RBS-2013-04654. A senior reactor analyst performed a detailed risk evaluation and determined that the bounding change to the core damage frequency was approximately 6.5E-8/year. Since this value was less than 1E-7/year, quantification of the large early release frequency was not required. The finding was of very low safety significance (Green). The dominant core damage sequences involved a control room fire initiating event in Panel H13-P808-87B, loss of Division II and Division III emergency AC power sources, and a secondary fire which caused the loss of the Division I emergency AC train. The availability of the reactor core isolation cooling system as well as the station blackout diesel generator helped to minimize the risk. This violation is associated with LER 05000458/2014-001-00. Refer to Section 4OA3.2 of this inspection report for the review and closure of the licensee event report.
05000458/FIN-2014004-03	2014Q3	River Bend	Licensee-Identified Violation	Title 10 CFR 50.65(a)(1) requires, in part, that holders of an operating license shall monitor the performance or condition of systems, structures, and components within the scope of the rule against licensee-established goals in a manner sufficient to provide reasonable assurance that such systems, structures, and components are capable of fulfilling their intended safety functions. Title 10 CFR 50.65(a)(2) requires, in part, that monitoring specified in paragraph (a)(1) is not required where it has been demonstrated the performance or condition of a system, structure, and component is being effectively controlled through appropriate preventive maintenance, such that the system, structure, and component remains capable of performing its intended function. Contrary to the above, from May 13, 2013, to February 28, 2014, the licensee failed to demonstrate that the performance of the remote shutdown system was being effectively controlled through appropriate preventive maintenance. Specifically, station personnel failed to appropriately evaluate repetitive component failures of Gould J11 relays across system boundaries, resulting in the remote shutdown system exceeding the functional failure criteria without implementing appropriate preventive maintenance to improve system performance. The licensee entered this deficiency into the corrective action program as Condition Report CR-RBS-2014-01006. The finding was more than minor since violations of 10 CFR 50.65(a)(2) necessarily involve degraded system performance which, if left uncorrected, could become a more significant safety concern. This finding has very low safety significance (Green) because the finding did not lead to an actual loss of safety function of the system or cause a component to be inoperable, nor did it screen as potentially risk-significant due to a seismic, flooding, or severe weather initiating event.
05000458/FIN-2014004-05	2014Q3	River Bend	Licensee-Identified Violation	Title 10 CFR 20.1501(a) requires that each licensee make, or cause to be made, surveys that may be necessary for the licensee to comply with the regulations in 10 CFR Part 20 and that are reasonable under the circumstances to evaluate the extent of radiation levels, concentrations or quantities of radioactive materials, and the potential radiological hazards that could be present. Pursuant to 10 CFR 20.1003, a survey means an evaluation of the radiological conditions and potential hazards incident to the production, use, transfer, release, disposal, or presence of radioactive material or other sources of radiation. Title 10 CFR 20.1201(c) states, in part, the assigned deep-dose equivalent must be for the part of the body receiving the highest exposure. Contrary to this requirement, the licensee did not make or cause to be made surveys that were necessary for the licensee to comply with the regulations of 10 CFR 20.1201(c). Specifically, licensee representatives did not perform surveys to evaluate the radiation dose gradient in the reactor cavity, caused by placement of the reactor pressure vessel head, during work on March 15 and 16, 2013. The failure to provide dose gradient surveys was identified by the outage control center radiation protection representative while reviewing radiation survey records. Licensee personnel documented the failure to survey for radiation dose gradients in Condition Report CR-RBS-2013-02426 and performed an apparent cause evaluation. During follow-up actions, licensee personnel identified an example in which a worker received 104 millirem of unplanned radiation dose and reported it as an occupational exposure control effectiveness performance indicator occurrence. Using Inspection Manual Chapter 0609, Appendix C, "Occupational Radiation Safety Significance Determination Process," the inspectors determined the violation had very low safety significance because: (1) it was not an as low as is reasonably achievable (ALARA) finding, (2) there was no overexposure, (3) there was no substantial potential for an overexposure, and (4) the ability to assess dose was not compromised.

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