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05000341/FIN-2015301-012015Q3FermiInadequate Examination Security on a Simulator ResetTitle 10, Code of Federal Regulations (CFR), Part 55.49, Integrity of examinations and tests, states, in part, that a licensee shall not engage in any activity that compromises the integrity of any application, test, or examination required by this part. The integrity of a test or examination is considered compromised if any activity, regardless of intent, affected, or, but for detection, would have affected the equitable and consistent administration of the test or examination. Contrary to this, the licensee failed to clean a marked-up hard card prior to a job performance measure (JPM) during administration of the operating tests. To correct this issue, the licensee initiated corrective action CARD number 15-26003. Additionally, a replacement JPM was administered to the applicant affected by the compromised JPM. The failure of the licensees staff to ensure that previously used examination materials were not available for an applicant during the initial examination administration was a performance deficiency. The performance deficiency was evaluated through the traditional enforcement process because it impacted the ability of the NRC to perform its regulatory oversight function. This resulted in assignment of a Severity Level IV noncited violation because it involved a non-willful compromise of examination integrity and is consistent with Section 6.4.d of the NRC Enforcement Policy.
05000440/FIN-2012008-022012Q2PerryFailure to Ensure Design Spray Density is AchievedThe inspectors identified a finding of very low safety significance (Green) and associated Non-Cited Violation of License Condition 2.C(6) for the failure to ensure design spray density was achieved for the Unit 1 Division 2 cable chase area. Specifically, the placement of spray nozzles for cable trays did not ensure that the design spray density specified by design calculations would be achieved. The licensee entered the issue into their corrective action program and planned to evaluate their calculation and the actual water density required. The inspectors determined that the finding was more than minor because the failure to ensure that the design spray density would be achieved resulted in the potential that a fire involving cable trays would not be suppressed. The finding was of very low safety significance due to a combination of low ignition frequencies for the area and only one train of equipment would be affected. The inspectors did not identify a cross-cutting aspect associated with this finding because the finding was an original design issue and not representative of current performance.
05000440/FIN-2012008-032012Q2PerryFailure to Ensure Sprinkler Piping Could Be DrainedThe inspectors identified a finding of very low safety significance (Green) and associated Non-Cited Violation of License Condition 2.C(6) for the failure to ensure that sprinkler piping could be drained. Specifically, the licensee failed to install sprinkler piping in accordance with the standard for sprinkler systems which required that all sprinkler pipe and fittings shall be so installed that the system may be drained. The licensee entered the issue into their corrective action program and planned to further assess existing conditions of the piping and determine what changes are needed to ensure piping is drained after a system actuation. The finding was determined to be more than minor because some corrosion of internal sprinkler piping was observed which could result in blockage of individual sprinkler heads or spray nozzles thereby reducing the effectiveness of the sprinkler system. This finding was of very low safety significance because the inspectors concluded that significantly less than 10 percent of the spray nozzles and sprinkler heads would be affected. This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Operating Experience, because the licensee did not evaluate relevant external operating experience. Specifically, the licensee had reviewed operating experience relating to blockage of pre-action sprinkler systems, but did not sufficiently evaluate the operating experience to recognize that it applied to the Perry Nuclear Power Plant.
05000440/FIN-2012008-042012Q2PerryFailure to Install Sequential Timing Device for Fire PumpsThe inspectors identified a finding of very low safety significance (Green) and associated Non-Cited Violation of License Condition 2.C(6) for the failure to install a sequential timing device for the diesel driven fire pump. Specifically, the standard for fire pumps required that controllers for multiple pump units, such as those at the Perry Nuclear Power Plant, incorporate a sequential timing device to prevent any one pump starting simultaneously with any other pump. The licensee entered the issue into their corrective action program and initiated a modification to install a time delay for the pump. The inspectors determined that the finding was more than minor because the failure to install a sequential timing device for the diesel driven fire pump could result in both fire pumps starting simultaneously and a significant water hammer which could damage fire protection piping or equipment. The finding was of very low safety significance due to a combination of low ignition frequencies for the affected areas and only one train of equipment would be affected for fires in those areas. This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Self and Independent Assessments, because the licensee did not conduct a self-assessment of sufficient depth. Specifically, a self-assessment reviewed an Unresolved Item (URI) relating to this issue for another plant, but failed to identify that the Perry Nuclear Power Plant had the same configuration and requirements as described in the URI.
05000440/FIN-2012008-052012Q2PerryFailure to Provide Full Area DetectionThe inspectors identified a finding of very low safety significance (Green) and associated Non-Cited Violation of License Condition 2.C(6) for the failure to provide detection throughout Fire Area 1CC-4a. Specifically, Fire Area 1CC-4a was described by the USAR as having an early warning detection system. However, the corridor area of Fire Area 1CC-4a lacked detection. The licensee entered the issue into their corrective action program and planned to evaluate a change to their detection system. The inspectors determined that the finding was more than minor because the lack of detection in the corridor area of Fire Area 1CC-4a could result in delayed detection of a fire which, if unmitigated, could affect safety-related cables above the corridor area. The finding was of very low safety significance because the portion of Fire Area 1CC-4a which contained safety-related cables did have smoke detectors and a sprinkler/spray system. This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Self-Assessments, because the licensee did not conduct a self-assessment of sufficient depth. Specifically, a self-assessment reviewed Fire Area 1CC-4a, but did not assess the design of systems in terms of the licensing basis.
05000440/FIN-2012008-012012Q2PerryFailure to Implement Transient Combustible ProgramThe inspectors identified a finding of very low safety significance and associated NCV of Technical Specifications Section 5.4.1.a for the failure to control transient combustible materials in accordance with fire protection program requirements. Specifically, the licensee failed to remove transient combustibles from the plant after they were no longer required to support a work activity. Upon discovery the licensee entered the issue into their corrective action program and removed the transient combustibles from the area. The inspectors determined that this finding was more than minor because the transient combustible materials were stored below safety-related Division 1 cables in cable trays and formed a credible fire scenario. This finding was of very low safety significance because the materials would not result in ignition of a fire from existing sources of heat or electrical energy. The finding did not have a cross-cutting aspect because it was isolated and not reflective of current performance.
05000237/FIN-2012008-042012Q1DresdenUnit 2 East and West LPCI Corner Rooms Internal Flooding Event IssueThe inspectors reviewed Engineering Change (EC) 386469, Repair of Flood Seals for Unit 2 West LPCI Corner Room Penetration No. 5 and No. 10 on Flood Seal Drawing FL-37 and East LPCI Corner Room Penetration No. 9 on Flood Seal Drawing FL-41 , Revision 3. Section 4.1.4.1 of this EC stated the function of the flood seal penetrations No. 5, 9 and 10 was to prevent water from leaking from the Torus basement into the Reactor Building corner rooms where the LPCI and Core Spray pumps are located. The LPCI and Core Spray pumps are safety-related. The purpose of this EC was to repair the aforementioned existing flood seal penetrations. The repair to the existing flood seal penetrations was classified per the EC as non-safety-related. In Revision 1 of this EC, the classification of the modification was changed from safety-related to non-safety-related. The licensee made this classification change to the EC because they concluded that the flood seal penetrations do not perform a safety-related or accident mitigation function as described by their current license basis. Also, the licensee described the flood seal penetration as being conservatively classified as safety-related because the licensee had not assigned a classification to the flood seal penetrations. During a walkdown of the flood seal penetrations, the inspectors identified non-safety-related fire protection and service water piping in close proximity to the non-safety-related flood seal penetrations. The inspectors noted that the non-safety-related piping was not designed and licensed to withstand a Class 1 earthquake event and failure of the piping could result in an internal flood in the torus basement which could generate a flood height that could reach and bypass flood seal penetrations No. 5, 9 and 10. During this inspection, the licensee was unable to locate an evaluation of whether or not the non-safety-related piping could withstand a Class 1 earthquake event or an evaluation to determine the flood height generated by a failure of the non-safety-related piping that would flood the torus basement when subjected to a Class 1 earthquake event and determine whether the flood could reach and bypass the flood seal penetration. In response to this concern, the licensee initiated Condition Report (CR) 01338733, Mod/50.59: Addl Info Needed for Non-Seismic Piping, dated March 8, 2012. The inspectors also discussed this issue with staff in the Office of Nuclear Reactor Regulation (NRR). After the exit, the licensee provided the inspectors additional information on IPEEE relevant to the design basis and licensing basis of the flood seals for the Unit 2 East and West corner rooms, which will require additional NRC review. Therefore, this issue is considered unresolved pending additional inspector review of the information provided by the licensee and consultation with NRR to determine the design and licensing basis requirements of the flood seals at Dresden.
05000331/FIN-2012007-012012Q1Duane ArnoldFlammable Gas Bottles Installed in the Reactor BuildingThe inspectors identified a finding of very low safety significance and associated NCV of Title 10, Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion III, Design Control, for the failure to check the adequacy of design for flammable gas bottles installed in the reactor building and their impact on safety-related cables and safety-related equipment. Specifically, the licensee failed to evaluate how a failure of the flammable gas bottles and the resulting fire or explosion at the installed locations could impact nearby safety-related structures, systems, or components. The licensee entered this issue into their corrective action program to review the placement of the flammable gas bottles. The inspectors determined that the finding was more than minor because the finding was associated with the Initiating Events cornerstone attribute of Protection against External Factors (Fire) and affected the cornerstones objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The finding was of very low safety significance due to the low fire initiating frequency and the availability of remaining mitigating systems. This finding did not have a cross-cutting aspect because the finding was not representative of current performance.
05000341/FIN-2012007-032012Q1FermiFailure to Identify EDG\\\'s Neutral Grounding Resistor Exceeded its Design ValuesThe inspectors identified a finding of very low safety significance and an associated NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to identify and correct a condition adverse to quality. Specifically, the licensee failed to identify and evaluate that the installed Neutral Grounding Resistors (NGRs) for emergency diesel generators (EDGs) exceeded the maximum design value specified in the design basis calculation. The field measurement data obtained by the licensee in support of the 4.16kV cable replacement modification, in November 2011, exceeded the design value of 4.225 ohms specified in calculation DC-5373. The licensee entered this issue into their corrective action program to revise the design calculation to incorporate using the measured or the resistors maximum tolerance value. The inspectors determined that the finding was more than minor because the finding was associated with the Mitigating Systems cornerstones attribute of Equipment Performance and affected the cornerstones objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the licensee failed to assure that the measured NRG for EDG-11 and EDG-13, which exceeded the maximum design value specified in the design basis calculation would perform their design function during overvoltage and fault conditions. The finding was of very low safety significance because it did not result in a loss of operability. No cross-cutting aspects were associated with this finding.
05000237/FIN-2012008-022012Q1DresdenFailure to Conduct Adequate Post Installation and Maintenance Inspections on Standby Liquid Control System ComponentsThe inspectors identified a finding of very low safety significance (Green) and associated NCV of 10 CFR Part 50, Appendix B, Criterion X, Inspection, for the licensees failure to perform adequate post-installation and post-maintenance inspections on standby liquid control (SBLC) heat tracing and pumps. Specifically, the licensee failed to verify that heat tracing on the SBLC system components was properly installed and later failed to verify that thermal insulation was properly replaced following maintenance on the SBLC pumps, which led to thermal degradation of the explosive material in the squib valves. The licensee entered this issue into their corrective action program and replaced the 3B squib valve. The inspectors determined that the finding was more than minor because the finding was associated with the Mitigating Systems cornerstone attribute of equipment performance and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). The finding was of very low safety significance based on a Phase III Significance Determination Process Analysis. This finding had a cross-cutting aspect in the area of problem identification and resolution, operating experience because the licensee did not properly implement vendor operating experience.
05000237/FIN-2012008-012012Q1DresdenFlammable Hydrogen Gas Bottles Installed in the Reactor BuildingThe inspectors identified a finding of very low safety significance (Green) and associated NCV of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to check the adequacy of design for flammable hydrogen gas bottles installed in the reactor building and their impact on safety-related structures, systems, and components (SSCs). Specifically, the licensee failed to evaluate how a failure of the flammable hydrogen gas bottles and the resulting fire or explosion at the installed locations could impact nearby safety-related SSCs. The licensee entered this issue into their corrective action program to review the placement of the flammable hydrogen gas bottles. The inspectors determined that the finding was more than minor because the finding was associated with the Initiating Events cornerstone attribute of Protection against External Factors (Fire) and affected the cornerstones objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown, as well as power operations. The finding was of very low safety significance due to the low fire initiating frequency and the availability of remaining mitigating systems. This finding had a cross-cutting aspect in the area of problem identification and resolution, operating experience because the licensee did not properly evaluate relevant operating experience identified during the preparation of a focused area self assessment.
05000237/FIN-2012008-032012Q1DresdenFailure to Provide Complete and Accurate Information to the NRCThe inspectors identified a Severity Level IV, Non-Cited Violation of 10 CFR 50.9(a), Completeness and Accuracy of Information, for the licensees failure to provide complete and accurate information to the NRC during a 2011 Triennial Fire Protection Inspection. Specifically, between July 7 and October 17, 2011, the licensee failed to inform the NRC that bottles containing 100 percent hydrogen were located in the plant in response to inspectors questions regarding flammable gas bottles. The licensee entered this issue into their corrective action program to document the incomplete response provided. The inspectors determined that the performance deficiency was more than minor because it impacted the regulatory process. Specifically, had the NRC known during the 2011 Triennial Fire Protection Inspection that the hydrogen bottles contained 100 percent hydrogen the inspectors would likely have documented a finding associated with the hydrogen bottles. The issue was a Severity Level IV Non-Cited Violation because the inspectors documented a finding of very low safety significance associated with the flammable hydrogen bottles once they determined that bottles containing 100 percent hydrogen were located in the plant.
05000341/FIN-2012007-022012Q1FermiInadequate Safety Evaluation for the Online Noble Chemical Metal ProcessThe inspectors identified a Severity Level IV, Non-Cited Violation (NCV) of 10 CFR 50.59(d)(1), Changes, Tests, and Experiments, and an associated (Green) finding for the licensees failure to provide an adequate written safety evaluation to demonstrate that application of the On-Line NobleChemTM(OLNC) process did not require a license amendment. Specifically, the licensee had not provided an evaluation to demonstrate that application of the OLNC process did not increase the likelihood for hydrogen induced detonation and piping failures for six areas of the balance of plant (BOP) piping susceptible to hydrogen accumulation. The licensee entered the issue into its corrective action program as CARD 12-20812 and intended to revise safety evaluation No.10-0286 to provide an adequate written basis for the OLNC process prior to the next scheduled application of OLNC materials. The finding was determined to be more than minor because the inspectors could not reasonably determine if the application of the OLNC process would not have required NRC prior approval (e.g., a license amendment). The finding was also determined to be more than minor because the finding was associated with the Initiating Events Cornerstone attribute of Equipment Performance and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions. Absent NRC identification, the licensee would have continued to introduce OLNC materials into the reactor feed system without confirming that the OLNC process did not increase the likelihood for hydrogen induced detonation and piping failures in the BOP piping segments that would upset plant stability and challenge safety systems. The finding was of very low safety significance because the finding did not contribute to both the likelihood of a reactor trip AND the likelihood that mitigation equipment or functions will not be available. This finding has a cross-cutting aspect in the Decision Making component of the Human Performance cross-cutting area because the licensee did not use conservative assumptions to ensure the proposed action was safe. Specifically, the licensees failure to provide a written safety evaluation, which demonstrated that application of the OLNC process did not increase the likelihood for hydrogen induced detonation and piping failures was the result of a non-conservative assumption that the OLNC process was safe.
05000341/FIN-2012007-012012Q1FermiInadequate Safety Evaluation for the Online Noble Chemical Metal ProcessThe inspectors identified a Severity Level IV, Non-Cited Violation (NCV) of 10 CFR 50.59(d)(1), Changes, Tests, and Experiments, and an associated (Green) finding for the licensees failure to provide an adequate written safety evaluation to demonstrate that application of the On-Line NobleChemTM(OLNC) process did not require a license amendment. Specifically, the licensee had not provided an evaluation to demonstrate that application of the OLNC process did not increase the likelihood for hydrogen induced detonation and piping failures for six areas of the balance of plant (BOP) piping susceptible to hydrogen accumulation. The licensee entered the issue into its corrective action program as CARD 12-20812 and intended to revise safety evaluation No.10-0286 to provide an adequate written basis for the OLNC process prior to the next scheduled application of OLNC materials. The finding was determined to be more than minor because the inspectors could not reasonably determine if the application of the OLNC process would not have required NRC prior approval (e.g., a license amendment). The finding was also determined to be more than minor because the finding was associated with the Initiating Events Cornerstone attribute of Equipment Performance and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions. Absent NRC identification, the licensee would have continued to introduce OLNC materials into the reactor feed system without confirming that the OLNC process did not increase the likelihood for hydrogen induced detonation and piping failures in the BOP piping segments that would upset plant stability and challenge safety systems. The finding was of very low safety significance because the finding did not contribute to both the likelihood of a reactor trip AND the likelihood that mitigation equipment or functions will not be available. This finding has a cross-cutting aspect in the Decision Making component of the Human Performance cross-cutting area because the licensee did not use conservative assumptions to ensure the proposed action was safe. Specifically, the licensees failure to provide a written safety evaluation, which demonstrated that application of the OLNC process did not increase the likelihood for hydrogen induced detonation and piping failures, was the result of a non-conservative assumption that the OLNC process was safe.
05000373/FIN-2010503-022011Q2LaSalleChanges to EAL Basis Decreased the Effectiveness of the Plan without Prior NRC ApprovalThe inspector identified a finding of very low safety significance involving a Severity Level IV NCV of 10 CFR 50.54(q) for failing to obtain prior approval for an emergency plan change which decreased the effectiveness of the plan. Specifically, the licensee modified the Emergency Action Level (EAL) Basis in EAL HU6, Revision 26, which indefinitely extended the start of the 15-minute emergency classification clock beyond a credible notification that a fire is occurring or indication of a valid fire detection system alarm. This change decreased the effectiveness of the emergency plan by reducing the capability to perform a risk significant planning function in a timely manner. The violation affected the NRCs ability to perform its regulatory function because it involved implementing a change that decreased the effectiveness of the emergency plan without NRC approval. Therefore, this issue was evaluated using Traditional Enforcement. The NRC determined that a Severity Level IV violation was appropriate due to the reduction of the capability to perform a risk significant planning standard function in a timely manner. The licensee entered this issue into its corrective action program and revised the EAL basis to restore compliance. The finding was more than minor using IMC 0612, because it is associated with the emergency preparedness cornerstone attribute of procedure quality for EAL and emergency plan changes, and it adversely affected the cornerstone objective of ensuring that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Therefore, the performance deficiency was a finding. Using IMC 0609, Appendix B, the inspector determined that the finding had a very low safety significance because the finding is a failure to comply with 10 CFR 50.54(q) involving the risk significant planning standard 50.47(b)(4), which, in this case, met the example of a Green finding because it involved one Unusual Event Classification (EAL HU6). Due to the age of this issue, it was not determined to be reflective of current licensee performance and therefore a cross-cutting aspect was not assigned to this finding.
05000237/FIN-2010502-022011Q2DresdenChanges to EAL Basis Decreased the Effectiveness of the Plan without Prior NRC ApprovalThe inspector identified a finding of very low safety significance involving a Severity Level IV NCV of 10 CFR 50.54(q) for failing to obtain prior approval for an emergency plan change which decreased the effectiveness of the plan. Specifically, the licensee modified the Emergency Action Level (EAL) Basis in EAL HU6, Revision 24, which indefinitely extended the start of the 15-minute emergency classification clock beyond a credible notification that a fire is occurring or indication of a valid fire detection system alarm. This change decreased the effectiveness of the emergency plan by reducing the capability to perform a risk significant planning function in a timely manner. The violation affected the NRCs ability to perform its regulatory function because it involved implementing a change that decreased the effectiveness of the emergency plan without NRC approval. Therefore, this issue was evaluated using Traditional Enforcement. The NRC determined that a Severity Level IV violation was appropriate due to the reduction of the capability to perform a risk significant planning standard function in a timely manner. The licensee entered this issue into its corrective action program and revised the EAL basis to restore compliance. The finding was more than minor using IMC 0612, because it is associated with the emergency preparedness cornerstone attribute of procedure quality for EAL and emergency plan changes, and it adversely affected the cornerstone objective of ensuring that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Therefore, the performance deficiency was a finding. Using IMC 0609, Appendix B, the inspector determined that the finding had a very low safety significance because the finding is a failure to comply with 10 CFR 50.54(q) involving the risk significant planning standard 50.47(b)(4), which, in this case, met the example of a Green finding because it involved one Unusual Event classification (EAL HU6).
05000461/FIN-2010502-022011Q2ClintonChanges to EAL Basis Decreased the Effectiveness of the Plan without Prior NRC ApprovalThe inspector identified a finding of very low safety significance involving a Severity Level IV NCV of 10 CFR 50.54(q) for failing to obtain prior approval for an emergency plan change which decreased the effectiveness of the plan. Specifically, the licensee modified the Emergency Action Level (EAL) Basis in EAL HU6, Revision 12, which indefinitely extended the start of the 15-minute emergency classification clock beyond a credible notification that a fire is occurring or indication of a valid fire detection system alarm. This change decreased the effectiveness of the emergency plan by reducing the capability to perform a risk significant planning function in a timely manner. The violation affected the NRCs ability to perform its regulatory function because it involved implementing a change that decreased the effectiveness of the emergency plan without NRC approval. Therefore, this issue was evaluated using Traditional Enforcement. The NRC determined that a Severity Level IV violation was appropriate due to the reduction of the capability to perform a risk significant planning standard function in a timely manner. The licensee entered this issue into its corrective action program and revised the EAL basis to restore compliance. The finding was more than minor using IMC 0612, because it is associated with the emergency preparedness cornerstone attribute of procedure quality for EAL and emergency plan changes, and it adversely affected the cornerstone objective of ensuring that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Therefore, the performance deficiency was a finding. Using IMC 0609, Appendix B, the inspector determined that the finding had a very low safety significance because the finding is a failure to comply with 10 CFR 50.54(q) involving the risk significant planning standard 50.47(b)(4), which, in this case, met the example of a Green finding because it involved one Unusual Event classification (EAL HU6). Due to the age of this issue, it was not determined to be reflective of current licensee performance and therefore a cross-cutting aspect was not assigned to this finding.
05000454/FIN-2010502-022011Q2ByronChanges to EAL Basis Decreased the Effectiveness of the Plan without Prior NRC ApprovalThe inspector identified a finding of very low safety significance involving a Severity Level IV NCV of 10 CFR 50.54(q) for failing to obtain prior approval for an emergency plan change which decreased the effectiveness of the plan. Specifically, the licensee modified the Emergency Action Level (EAL) Basis in EAL HU6, Revision 22, which indefinitely extended the start of the 15-minute emergency classification clock beyond a credible notification that a fire is occurring or indication of a valid fire detection system alarm. This change decreased the effectiveness of the emergency plan by reducing the capability to perform a risk significant planning function in a timely manner. The violation affected the NRCs ability to perform its regulatory function because it involved implementing a change that decreased the effectiveness of the emergency plan without NRC approval. Therefore, this issue was evaluated using Traditional Enforcement. The NRC determined that a Severity Level IV violation was appropriate due to the reduction of the capability to perform a risk significant planning standard function in a timely manner. The licensee entered this issue into its corrective action program and revised the EAL basis to restore compliance. The finding was more than minor using IMC 0612, because it is associated with the emergency preparedness cornerstone attribute of procedure quality for EAL and emergency plan changes, and it adversely affected the cornerstone objective of ensuring that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Therefore, the performance deficiency was a finding. Using IMC 0609, Appendix B, the inspector determined that the finding had a very low safety significance because the finding is a failure to comply with 10 CFR 50.54(q) involving the risk significant planning standard 50.47(b)(4), which, in this case, met the example of a Green finding because it involved one Unusual Event classification (EAL HU6). Due to the age of this issue, it was not determined to be reflective of current licensee performance and therefore a cross-cutting aspect was not assigned to this finding.
05000254/FIN-2010503-012011Q2Quad Cities(Traditional Enforcement) Changes to EAL Basis Decreased the Effectiveness of the Plan without Prior NRC ApprovalThe inspector identified a finding of very low safety significance involving a Severity Level IV NCV of 10 CFR 50.54(q) for failing to obtain prior approval for an emergency plan change which decreased the effectiveness of the plan. Specifically, the licensee modified the Emergency Action Level (EAL) Basis in EAL HU6, Revision 26, which indefinitely extended the start of the 15-minute emergency classification clock beyond a credible notification that a fire is occurring or indication of a valid fire detection system alarm. This change decreased the effectiveness of the emergency plan by reducing the capability to perform a risk significant planning function in a timely manner. The violation affected the NRCs ability to perform its regulatory function because it involved implementing a change that decreased the effectiveness of the emergency plan without NRC approval. Therefore, this issue was evaluated using Traditional Enforcement. The NRC determined that a Severity Level IV violation was appropriate due to the reduction of the capability to perform a risk significant planning standard function in a timely manner. The licensee entered this issue into its corrective action program and revised the EAL basis to restore compliance. The finding was more than minor using IMC 0612, because it is associated with the emergency preparedness cornerstone attribute of procedure quality for EAL and emergency plan changes, and it adversely affected the cornerstone objective of ensuring that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Therefore, the performance deficiency was a finding. Using IMC 0609, Appendix B, the inspector determined that the finding had a very low safety significance because the finding is a failure to comply with 10 CFR 50.54(q) involving the risk significant planning standard 50.47(b)(4), which, in this case, met the example of a Green finding because it involved one Unusual Event Classification
05000282/FIN-2011502-012011Q2Prairie IslandIncomplete and Inaccurate Emergency Action Level Change SubmittalThe NRC identified a Severity Level IV Non-Cited Violation of 10 CFR 50.9 for failing to provide complete and accurate information for prior approval of a new Emergency Action Level (EAL) scheme. The licensees submittal to the NRC, entitled, Revision to Emergency Action Levels, dated October 22, 2004, was not complete and accurate in all material respects. The submitted EAL scheme specified instrument threshold values for Alert classifications, EALs RA1.1 and RA1.2, which were beyond the indicated ranges of the effluent radiation monitors R-18, R-25, and R-31. The NRC accepted and approved the proposed EALs not realizing the information was incomplete and inaccurate. The inspectors determined that the licensees failure to provide complete and accurate information to the NRC, a violation of 10 CFR 50.9, was a performance deficiency and within the licensees ability to foresee and prevent. The deficiency was determined to be more than minor because it was associated with the Emergency Preparedness Cornerstone attribute of Procedure Quality. As a violation that potentially impedes or impacts the regulator process, it was dispositioned using the traditional enforcement process as described in NRC Inspection Manual Chapter 0612, Revision 04/30/10. Using Section 6.9 of the Enforcement Policy and after consultation with the Director of the Office of Enforcement, this issue was determined to be a Severity Level IV violation. Specifically, though the NRC would have questioned the issue with additional and correct information, the EAL ultimately would have been acceptable with an adjustment in the indicator range or EAL entry criteria value. In either case, it would not have resulted in substantial further inquiry. Additionally, the associated technical violation was determined to be of very low safety significance. As this was a traditional enforcement action, no cross cutting aspect was screened.
05000373/FIN-2010503-012011Q2LaSalle(Traditional Enforcement) Changes to EAL Basis Decreased the Effectiveness of the Plan without Prior NRC ApprovalThe inspector identified a finding of very low safety significance involving a Severity Level IV NCV of 10 CFR 50.54(q) for failing to obtain prior approval for an emergency plan change which decreased the effectiveness of the plan. Specifically, the licensee modified the Emergency Action Level (EAL) Basis in EAL HU6, Revision 26, which indefinitely extended the start of the 15-minute emergency classification clock beyond a credible notification that a fire is occurring or indication of a valid fire detection system alarm. This change decreased the effectiveness of the emergency plan by reducing the capability to perform a risk significant planning function in a timely manner. The violation affected the NRCs ability to perform its regulatory function because it involved implementing a change that decreased the effectiveness of the emergency plan without NRC approval. Therefore, this issue was evaluated using Traditional Enforcement. The NRC determined that a Severity Level IV violation was appropriate due to the reduction of the capability to perform a risk significant planning standard function in a timely manner. The licensee entered this issue into its corrective action program and revised the EAL basis to restore compliance. The finding was more than minor using IMC 0612, because it is associated with the emergency preparedness cornerstone attribute of procedure quality for EAL and emergency plan changes, and it adversely affected the cornerstone objective of ensuring that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Therefore, the performance deficiency was a finding. Using IMC 0609, Appendix B, the inspector determined that the finding had a very low safety significance because the finding is a failure to comply with 10 CFR 50.54(q) involving the risk significant planning standard 50.47(b)(4), which, in this case, met the example of a Green finding because it involved one Unusual Event Classification (EAL HU6). Due to the age of this issue, it was not determined to be reflective of current licensee performance and therefore a cross-cutting aspect was not assigned to this finding.
05000237/FIN-2010502-012011Q2Dresden(Traditional Enforcement) Changes to EAL Basis Decreased the Effectiveness of the Plan without Prior NRC ApprovalThe inspector identified a finding of very low safety significance involving a Severity Level IV NCV of 10 CFR 50.54(q) for failing to obtain prior approval for an emergency plan change which decreased the effectiveness of the plan. Specifically, the licensee modified the Emergency Action Level (EAL) Basis in EAL HU6, Revision 24, which indefinitely extended the start of the 15-minute emergency classification clock beyond a credible notification that a fire is occurring or indication of a valid fire detection system alarm. This change decreased the effectiveness of the emergency plan by reducing the capability to perform a risk significant planning function in a timely manner. The violation affected the NRCs ability to perform its regulatory function because it involved implementing a change that decreased the effectiveness of the emergency plan without NRC approval. Therefore, this issue was evaluated using Traditional Enforcement. The NRC determined that a Severity Level IV violation was appropriate due to the reduction of the capability to perform a risk significant planning standard function in a timely manner. The licensee entered this issue into its corrective action program and revised the EAL basis to restore compliance. The finding was more than minor using IMC 0612, because it is associated with the emergency preparedness cornerstone attribute of procedure quality for EAL and emergency plan changes, and it adversely affected the cornerstone objective of ensuring that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Therefore, the performance deficiency was a finding. Using IMC 0609, Appendix B, the inspector determined that the finding had a very low safety significance because the finding is a failure to comply with 10 CFR 50.54(q) involving the risk significant planning standard 50.47(b)(4), which, in this case, met the example of a Green finding because it involved one Unusual Event classification (EAL HU6).
05000461/FIN-2010502-012011Q2Clinton(Traditional Enforcement) Changes to EAL Basis Decreased the Effectiveness of the Plan without Prior NRC ApprovalThe inspector identified a finding of very low safety significance involving a Severity Level IV NCV of 10 CFR 50.54(q) for failing to obtain prior approval for an emergency plan change which decreased the effectiveness of the plan. Specifically, the licensee modified the Emergency Action Level (EAL) Basis in EAL HU6, Revision 12, which indefinitely extended the start of the 15-minute emergency classification clock beyond a credible notification that a fire is occurring or indication of a valid fire detection system alarm. This change decreased the effectiveness of the emergency plan by reducing the capability to perform a risk significant planning function in a timely manner. The violation affected the NRCs ability to perform its regulatory function because it involved implementing a change that decreased the effectiveness of the emergency plan without NRC approval. Therefore, this issue was evaluated using Traditional Enforcement. The NRC determined that a Severity Level IV violation was appropriate due to the reduction of the capability to perform a risk significant planning standard function in a timely manner. The licensee entered this issue into its corrective action program and revised the EAL basis to restore compliance. The finding was more than minor using IMC 0612, because it is associated with the emergency preparedness cornerstone attribute of procedure quality for EAL and emergency plan changes, and it adversely affected the cornerstone objective of ensuring that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Therefore, the performance deficiency was a finding. Using IMC 0609, Appendix B, the inspector determined that the finding had a very low safety significance because the finding is a failure to comply with 10 CFR 50.54(q) involving the risk significant planning standard 50.47(b)(4), which, in this case, met the example of a Green finding because it involved one Unusual Event classification (EAL HU6). Due to the age of this issue, it was not determined to be reflective of current licensee performance and therefore a cross-cutting aspect was not assigned to this finding.
05000454/FIN-2010502-012011Q2Byron(Traditional Enforcement) Changes to EAL Basis Decreased the Effectiveness of the Plan without Prior NRC ApprovalThe inspector identified a finding of very low safety significance involving a Severity Level IV NCV of 10 CFR 50.54(q) for failing to obtain prior approval for an emergency plan change which decreased the effectiveness of the plan. Specifically, the licensee modified the Emergency Action Level (EAL) Basis in EAL HU6, Revision 22, which indefinitely extended the start of the 15-minute emergency classification clock beyond a credible notification that a fire is occurring or indication of a valid fire detection system alarm. This change decreased the effectiveness of the emergency plan by reducing the capability to perform a risk significant planning function in a timely manner. The violation affected the NRCs ability to perform its regulatory function because it involved implementing a change that decreased the effectiveness of the emergency plan without NRC approval. Therefore, this issue was evaluated using Traditional Enforcement. The NRC determined that a Severity Level IV violation was appropriate due to the reduction of the capability to perform a risk significant planning standard function in a timely manner. The licensee entered this issue into its corrective action program and revised the EAL basis to restore compliance. The finding was more than minor using IMC 0612, because it is associated with the emergency preparedness cornerstone attribute of procedure quality for EAL and emergency plan changes, and it adversely affected the cornerstone objective of ensuring that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Therefore, the performance deficiency was a finding. Using IMC 0609, Appendix B, the inspector determined that the finding had a very low safety significance because the finding is a failure to comply with 10 CFR 50.54(q) involving the risk significant planning standard 50.47(b)(4), which, in this case, met the example of a Green finding because it involved one Unusual Event classification (EAL HU6). Due to the age of this issue, it was not determined to be reflective of current licensee performance and therefore a cross-cutting aspect was not assigned to this finding.
05000254/FIN-2010503-022011Q2Quad CitiesChanges to EAL Basis Decreased the Effectiveness of the Plan without Prior NRC Approval.The inspector identified a finding of very low safety significance involving a Severity Level IV NCV of 10 CFR 50.54(q) for failing to obtain prior approval for an emergency plan change which decreased the effectiveness of the plan. Specifically, the licensee modified the Emergency Action Level (EAL) Basis in EAL HU6, Revision 26, which indefinitely extended the start of the 15-minute emergency classification clock beyond a credible notification that a fire is occurring or indication of a valid fire detection system alarm. This change decreased the effectiveness of the emergency plan by reducing the capability to perform a risk significant planning function in a timely manner. The violation affected the NRCs ability to perform its regulatory function because it involved implementing a change that decreased the effectiveness of the emergency plan without NRC approval. Therefore, this issue was evaluated using Traditional Enforcement. The NRC determined that a Severity Level IV violation was appropriate due to the reduction of the capability to perform a risk significant planning standard function in a timely manner. The licensee entered this issue into its corrective action program and revised the EAL basis to restore compliance. The finding was more than minor using IMC 0612, because it is associated with the emergency preparedness cornerstone attribute of procedure quality for EAL and emergency plan changes, and it adversely affected the cornerstone objective of ensuring that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Therefore, the performance deficiency was a finding. Using IMC 0609, Appendix B, the inspector determined that the finding had a very low safety significance because the finding is a failure to comply with 10 CFR 50.54(q) involving the risk significant planning standard 50.47(b)(4), which, in this case, met the example of a Green finding because it involved one Unusual Event Classification
05000456/FIN-2010503-022011Q1BraidwoodChanges Made to EAL Basis that Decreased the EffectivenessA Green finding involving a Severity Level IV, Cited Violation of 10 CFR 50.54(q) was identified by the inspector for the licensees change to the emergency plan which decreased the effectiveness of the plan without NRC approval. Specifically, the licensee modified the Emergency Action Level (EAL) Basis in EAL HU6, Revision 21, to delay the 15-minute classification time by the dispatching of personnel, reporting the notification of a fire from the field, and extinguishing the fire. As a result, this change indefinitely extends the start of the 15-minute emergency classification clock beyond a credible notification that a fire is occurring or indication of a valid fire detection system alarm. This change decreased the effectiveness of the emergency plan by reducing the capability to perform a risk significant planning function in a timely manner. The violation affected the NRCs ability to perform its regulatory function because it involved implementing a change that decreased the effectiveness of the emergency plan without NRC Commission approval. Therefore, this issue was evaluated using Traditional Enforcement. The NRC determined that a Severity Level IV violation was appropriate due to the reduction of the capability to perform a risk significant planning standard function in a timely manner. The violation is cited because no corrective action had been taken to restore compliance since the issue was entered in the licensees corrective action program in December 2009. The performance deficiency was more than minor and of very low safety-significance using Manual Chapter (MC) 0612 and MC 0609, Appendix B, because it is associated with the emergency preparedness cornerstone attribute of procedure quality for EAL and emergency plan changes, and it adversely affected the cornerstone objective of ensuring that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Therefore, the performance deficiency was a finding. Using MC 0609, Appendix B, the inspector determined that the finding had a very low safety significance. The inspectors also determined that the finding had a cross-cutting aspect in the area of Human Performance, decision-making because the licensee did not recognize that the change made to the EAL basis document decreased the effectiveness of the emergency plan. (H.1.(b)) (Section 1EP4)
05000456/FIN-2010503-012011Q1Braidwood(Traditional Enforcement) Changes to EAL basis Decreases the Effectiveness of the Plan without Prior NRC Approval (Tradiional EnforcementA Green finding involving a Severity Level IV, Cited Violation of 10 CFR 50.54(q) was identified by the inspector for the licensees change to the emergency plan which decreased the effectiveness of the plan without NRC approval. Specifically, the licensee modified the Emergency Action Level (EAL) Basis in EAL HU6, Revision 21, to delay the 15-minute classification time by the dispatching of personnel, reporting the notification of a fire from the field, and extinguishing the fire. As a result, this change indefinitely extends the start of the 15-minute emergency classification clock beyond a credible notification that a fire is occurring or indication of a valid fire detection system alarm. This change decreased the effectiveness of the emergency plan by reducing the capability to perform a risk significant planning function in a timely manner. The violation affected the NRCs ability to perform its regulatory function because it involved implementing a change that decreased the effectiveness of the emergency plan without NRC Commission approval. Therefore, this issue was evaluated using Traditional Enforcement. The NRC determined that a Severity Level IV violation was appropriate due to the reduction of the capability to perform a risk significant planning standard function in a timely manner. The violation is cited because no corrective action had been taken to restore compliance since the issue was entered in the licensees corrective action program in December 2009. The performance deficiency was more than minor and of very low safety-significance using Manual Chapter (MC) 0612 and MC 0609, Appendix B, because it is associated with the emergency preparedness cornerstone attribute of procedure quality for EAL and emergency plan changes, and it adversely affected the cornerstone objective of ensuring that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Therefore, the performance deficiency was a finding. Using MC 0609, Appendix B, the inspector determined that the finding had a very low safety significance. The inspectors also determined that the finding had a cross-cutting aspect in the area of Human Performance, decision-making because the licensee did not recognize that the change made to the EAL basis document decreased the effectiveness of the emergency plan. (H.1.(b)) (Section 1EP4)
05000305/FIN-2010502-012010Q3Kewaunee(Traditional Enforcement) Changes to EAL Technical Bases Document Decreases the Effectiveness of the Plan without Prior NRC ApprovalThe inspector identified a Green finding and an associated Severity Level IV NCV of 10 CFR 50.54(q) associated with 10 CFR 50.47(b)(2) because the licensee failed to obtain prior NRC approval for a change made to its emergency plan that decreased the effectiveness of the plan. Specifically, the licensee changed wording in their EAL technical basis document for EAL SU5 and CU1, RCS Leakage. The new wording eliminates leakage from the charging and letdown systems from consideration as RCS Leakage and therefore, leakage from these systems that meet the EAL thresholds would not constitute an Unusual Event declaration, using the licensees revised wording. This change was made without prior NRC approval. The performance deficiency was more than minor and of very low safety-significance using MC 0612 and MC 0609, Appendix B, because it is associated with the emergency preparedness cornerstone attribute of procedure quality for EAL and emergency plan changes, and it adversely affected the cornerstone objective of ensuring that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Therefore, the performance deficiency was a finding. Using MC 0609, Appendix B, the inspectors determined that the finding had a very low safety significance. The inspectors also determined that the finding had a cross-cutting aspect in the area of Human Performance, decision-making because the licensee did not recognize that the change that was made to the EAL Technical Basis document decreased the effectiveness of the emergency plan.
05000305/FIN-2010502-022010Q3KewauneeChanges Made to EAL Technical Bases that Decreased the EffectivenessThe inspector determined that changes made by the licensee to the EAL Technical Basis document decreased the effectiveness of the Emergency Plan and the change was implemented without prior NRC approval. The issue was determined to be a licensee performance deficiency that impacted the regulatory process and, in accordance with MC 0612 Power Reactor Inspection Reports, was evaluated using the NRCs traditional enforcement policy as well as the Reactor Oversight Process (ROP). Using the NRCs Enforcement Policy, this performance deficiency was considered for escalated enforcement. However, the NRC has classified this violation as a Severity Level IV, after determining that its actual and potential safety significance was very low based on the following considerations: (1) the issue was relatively isolated, in that the decrease in effectiveness resulted from a single mistake; (2) the impact of the issue was confined to two unusual event classifications, not any of the other higher event classifications; and (3) the revision was provided to the NRC for review after implementation, which reduced the impact to the regulatory process. Using MC 0612 Power Reactor Inspection Reports, Appendix B Issue Screening, the performance deficiency was determined to be more than minor and, therefore, a finding, because it is associated with the emergency preparedness cornerstone attribute of procedure quality for EAL and emergency plan changes, and it adversely affected the cornerstone objective of ensuring that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, the licensee made a change to its EAL Technical Basis Document, which was a DIE, because the change eliminated a pathway to get to an Unusual Event by excluding the Charging and Letdown System leakage from consideration as RCS leakage. And, this change was made without prior NRC approval The inspector determined the finding could be evaluated using the SDP in accordance with IMC 0609, Significance Determination Process, Appendix B, Emergency Preparedness Significance Determination Process. The finding is a failure to comply with 10 CFR 50.54(q) involving the risk significant planning standard 50.47(b)(4), which, in this case, is not considered degraded. This EAL Classification finding is GREEN because it involves two Unusual Event classifications (EAL CU1 and SU5). This finding has a cross-cutting aspect in the area of human performance, decision-making, because the licensee failed to use conservative assumptions when making decisions and did not demonstrate that nuclear safety was an overriding priority. Specifically, the licensee changed its EAL Technical Basis to remove consideration of leakage from the Charging and Letdown system as RCS leakage and eliminated a pathway to declare an Unusual Event for two EALs (CU1 and SU5). This change was screened through the licensees 50.54(q) process and was not identified as a DIE. However, after evaluation by the inspector, this change was determined to be a DIE of the emergency plan and it was not approved by the NRC before the change was implemented.
05000282/FIN-2010301-012010Q1Prairie IslandLicensee-Identified ViolationTitle 10 CFR 55.49, stated, in part, that station personnel shall not engage in any activity that compromises the integrity of any application, test, or examination required by this part. The integrity of a test or examination is considered compromised if any activity, regardless of intent, affected, or, but for detection, would have affected the equitable and consistent administration of the test or examination. This included activities related to the preparation and certification of license applications and all activities related to the preparation, administration, and grading of the tests and examinations required by this part. Contrary to the above, during the administration of the NRC written exam, a copy of the approved answer key with a photograph of a panel was improperly used to identify which panel lights were lit for one question. This was done in reply to a question asked by an applicant during the exam. Inadvertently, the copy of the photograph of the panel with associated question distractors also included a check mark indicating the correct answer, which immediately compromised the question. The violation was of very low safety significance because the error was discovered shortly after the copies were distributed to the applicants, the NRC was immediately informed, and the compromised question was deleted from the examination. Additionally, after deleting the compromised question, the NRC determined that because the examinations question distribution still supported a wide and adequate variety of plant knowledge items, the examination was still considered to be a valid examination. Immediate actions taken by the licensees training department included entering this condition into the corrective action program as AR 1223729. The licensees training personnel were again briefed concerning examination security requirements and the need to comply with examination security procedures was stressed.
05000255/FIN-2010502-012010Q1PalisadesInadequate Evaluation of Interface with State and Local GovernmentsThe inspectors identified a finding of very low safety significance and associated NCV of 10 CFR 50.54(t), Conditions of licenses, for the failure to complete an independent review of all program elements of the emergency preparedness program. The independent assessment did not evaluate and document the adequacy of the interfaces with State and local governments at an interval not to exceed 12 months for all groups. Specifically, Quality Assurances assessment failed to evaluate the adequacy of interface with one of the counties in 2008, and the interface with the State and two counties was not evaluated in 2009. The licensee entered the issue in their corrective action program as CR-PLP-2009-04915. The deficiency did not meet the criteria for traditional enforcement, therefore, was screened using the Emergency Preparedness (EP) SDP. The finding was determined to be more than minor because the finding adversely affected the EP cornerstone objective to ensure the licensee is capable of implementing adequate measures to protect the health and safety of the public in a radiological emergency. The failure to conduct the audit to evaluate the effectiveness of the EP program had the attribute associated with Offsite EP, specifically, the evaluation of the working relationship between the offsite and onsite emergency response organizations and programs. The inspector evaluated the finding using with IMC 0609, Appendix B, Sheet I, Failure to Comply flowchart. The audit program was noncompliant with a regulatory requirement not involving an EP planning standard or a risk significant planning standard; therefore, the finding was determined to be of very low safety significance (Green). The finding has a cross-cutting component in the Problem Identification and Resolution area with the component of Self and Independent Assessments. The licensee did not conduct the self-assessments in sufficient depth to evaluate the interfaces for all offsite governments
05000282/FIN-2010504-012010Q1Prairie IslandFailure to Maintain a Standard Emergency Action Level SchemeA licensee identified finding and associated Apparent Violation (AV) of 10 CFR 50.54(q) and 10 CFR 50.47(b)(4) was identified for the failure to follow and maintain in effect emergency plans which use a standard emergency classification and action level scheme. Specifically, the licensee\\\'s emergency plan Alert emergency action levels (EALs) RA1.1 and RA1.2 specified instrument threshold values that were beyond the indicated ranges of the effluent radiation monitors. The performance deficiency was determined to be more than minor because the deficiency, if left uncorrected, would have the potential to lead to a more significant safety concern. Specifically, in the event of a radiological emergency, the deficiency could lead to the failure to declare two Alert conditions in a timely manner. The finding was evaluated using the SDP in accordance with IMC 0609, \\\"Significance Determination Process,\\\" Appendix B. Using the \\\"Failure to Comply\\\" flowchart, the performance deficiency screened as a risk significant planning standard problem. The inspector determined the problem was a degraded function, rather than function failure, because even though the two Alerts (RA1.1 and RA1.2) would not be able to be declared due to the EAL threshold values being beyond the range of the associated instruments, an Alert could be declared, although in a delayed manner, using RA1.3 which is based on a sample results. The degraded risk significant planning standard function resulted in a preliminary White finding.
05000282/FIN-2010503-012010Q1Prairie IslandFailure to Maintain a Standard Emergency Action Level SchemeA licensee identified finding and associated Apparent Violation (AV) of 10 CFR 50.54(q) and 10 CFR 50.47(b)(4) was identified for the failure to follow and maintain in effect emergency plans which use a standard emergency classification and action level scheme. Specifically, the licensee\\\'s emergency plan Alert emergency action levels (EALs) RA1.1 and RA1.2 specified instrument threshold values that were beyond the indicated ranges of the effluent radiation monitors. The performance deficiency was determined to be more than minor because the deficiency, if left uncorrected, would have the potential to lead to a more significant safety concern. Specifically, in the event of a radiological emergency, the deficiency could lead to the failure to declare two Alert conditions in a timely manner. The finding was evaluated using the SDP in accordance with IMC 0609, \\\"Significance Determination Process,\\\" Appendix B. Using the \\\"Failure to Comply\\\" flowchart, the performance deficiency screened as a risk significant planning standard problem. The inspector determined the problem was a degraded function, rather than function failure, because even though the two Alerts (RA1.1 and RA1.2) would not be able to be declared due to the EAL threshold values being beyond the range of the associated instruments, an Alert could be declared, although in a delayed manner, using RA1.3 which is based on a sample results. The degraded risk significant planning standard function resulted in a preliminary White finding
05000346/FIN-2009503-032009Q4Davis BesseLicensee-Identified ViolationA violation of very low safety significance (Severity Level IV) was identified by the licensee and was a violation of NRC requirements which meets the criteria of Section VI of the NRC Enforcement Policy. A violation of 10 CFR 50.72 was identified for failure to provide timely notification to the NRC. On June 25, 2009, Davis-Besse failed to provide timely notification to the NRC of the after-the-fact Alert classification resulting from an explosion in the switchyard. The delayed notification was not a result of competing safety-related activities, plant stabilization activities, or equipment failures. The delayed notification was not a result of the licensees initial failure to classify the event. At 07:50 hours the licensee recognized that conditions warranted the classification of an Alert and they had missed the Alert declaration; however, the licensee did not notify the NRC of the missed Alert until 11:44 hours, a period exceeding one hour notification requirement. The finding was evaluated using the traditional enforcement process because the deficiency had the potential to impact the NRCs ability to perform its regulatory function. Since the emergency condition no longer existed at the time the report was required and the report was untimely versus not reported at all, the issue was characterized as a violation of very low safety significance (SL IV) and as a NCV. The licensee entered the issue into their corrective action program (CR 09-61112)
05000461/FIN-2009502-012009Q4ClintonImplementation of a Change which Decreased the Effectiveness of the Emergency PlanThe inspectors identified a NCV of 10 CFR 50.54(q) associated with 10 CFR 50.47(b)(2) because the licensee failed to obtain prior NRC approval for a change made to its emergency plan that decreased the effectiveness of the plan. Specifically, the licensee removed staffing and capabilities from the minimum on-shift emergency response staffing requirements from the Clinton Power Station Emergency Plan Annex, Section 2, Table B-1. The licensee entered this issue into their corrective action program and replaced staffing back on-shift as required by the 1998 emergency plan annex. This finding was more than minor and of very low safety-significance using IMC 0609, Appendix B, because the finding was associated with the Emergency Preparedness Cornerstone attribute of emergency response organization readiness for minimum on-shift emergency response staffing. Because the finding affected the NRCs ability to perform its regulatory function, the inspectors evaluated the significance using the traditional enforcement process. This finding was determined to be a Severity Level IV violation because the licensee failed to meet an emergency planning requirement not directly related to assessment and notification. The inspectors determined that this finding had a cross-cutting aspect in the area of Human Performance, decision making because the licensee did not initially recognize that the removal of minimum on-shift emergency response staffing decreased the effectiveness of the emergency plan (H.1.(b)).
05000456/FIN-2009005-072009Q4BraidwoodChanges to EAL HU6 Potentially Decreased the Effectiveness of the Plans Without Prior NRC ApprovalThe inspectors reviewed changes implemented to the Braidwood Station Emergency Plan Annex EALs and EAL Basis. In Revision 21, the licensee changed the basis of EAL HU6, Fire not extinguished within15 minutes of detection within the protected area boundary, by adding two statements. The two changes added to the EAL basis stated that if the alarm could not be verified by redundant control room or nearby fire panel indications, notification from the field that a fire exists starts the 15-minute classification and fire extinguishment clocks. The second change stated the 15-minute period to extinguish the fire does not start until either the fire alarm is verified to be valid by additional control room or nearby fire panel instrumentation, or upon notification of a fire from the field. These statements conflict with the previous Braidwood Station Annex, Revision 20, basis statements and potentially decrease the effectiveness of the Plans. Description: Braidwood Station Radiological Emergency Plan Annex, Revision 20, EAL HU6 initiating condition stated, Fire not extinguished within 15 minutes of detection, or explosion, within the protected area boundary. The threshold values for HU6 were, in part: 1) Fire in any Table H2 area not extinguished within 15 minutes of Control Room notification or verification of a Control Room alarm, or 2) Fire outside any Table H2 area with the potential to damage safety systems in any Table H2 area not extinguished within 15 minutes of Control Room notification or verification of a Control Room alarm. Table H2, Vital Areas, were identified as containment, auxiliary building, fuel handling building, main steam tunnels, radioactive waste storage tanks, condensate storage tanks, and lake screen house. The basis defined fire as combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fires. Observation of flame is preferred but is not required if large quantities of smoke and heat are observed. The basis for Revision 20, EAL HU6 thresholds 1 and 2 stated, in part, the purpose of this threshold is to address the magnitude and extent of fires that may be potentially significant precursors to damage to safety systems. As used here, notification is visual observation and report by plant personnel or sensor alarm indication. The 15-minute period begins with a credible notification that a fire is occurring or indication of a valid fire detection system alarm. A verified alarm is assumed to be an indication of a fire unless personnel dispatched to the scene disprove the alarm within the 15-minute period. The report, however, shall not be required to verify the alarm. The intent of the 15-minute period is to size the fire and discriminate against small fires that are readily extinguished (e.g., smoldering waste paper basket, etc.). Revision 21 of the Braidwood Station Radiological Emergency Plan Annex, changed the threshold basis for EAL HU6 by adding the following two statements: 1) If the alarm cannot be verified by redundant control room or nearby fire panel indications, notification from the field that a fire exists starts the 15-minute classification and fire extinguishment clocks, and 2) The 15-minute period to extinguish the fire does not start until either the fire alarm is verified to be valid by utilization of additional control room or nearby fire panel instrumentation, or upon notification of a fire from the field. The two statements added to the basis in Revision 21 conflict with the Revision 20 threshold basis and initiating condition. The changed threshold basis in Revision 21 could add an indeterminate amount of time to declaring an actual emergency until a person responded to the area of the fire and made a notification to the control room of a fire in the event that redundant control room or nearby fire panel indications were not available. Pending further review and verification by the NRC to determine if the changes to EAL HU6 threshold basis potentially decreased the effectiveness of the Plans, this issue was considered an Unresolved Item. (URI 05000456/2009005-07; 05000457/2009005-07
05000341/FIN-2009010-012009Q4FermiFailure to Provide Complete Information to the NRC which Impacted Licensing Decisions.On August 13, 2009, during performance of a self-assessment, the licensee identified that two American National Standards Institute (ANSI) Standard requirements for physical examinations of licensed operators were no longer being administered by Fermi medical personnel. Specifically, olfactory and tactile testing were deleted by a procedure change that was implemented in May 1999. Because the issue affected the NRC=s ability to perform its regulatory function, it was evaluated using the traditional enforcement process. Although licensed operators were subsequently tested and found to have passed the olfactory and tactile tests, this failure had regulatory significance because the incomplete and inaccurate information was provided under a signed statement to the NRC and impacted numerous licensing decisions. This was preliminarily determined to be an apparent violation of 10 CFR 50.9, Completeness and Accuracy of Information. No cross cutting aspect was identified for the finding due to the age of the performance deficiency (e.g., 1999)
05000346/FIN-2009503-012009Q4Davis BesseFailure to Use Classification Scheme for an AlertA licensee identified finding and associated Apparent Violation (AV) of 10 CFR 50.54(q) and 10 CFR 50.47(b)(4) was identified for the failure to implement the emergency classification and action level scheme during an actual event to declare an Alert after an explosion in the switchyard. The operators failed to verify, assess, and classify the situation in conjunction with the Davis-Besse Emergency Plan Table of Emergency Action Level Conditions. Specifically, immediately following an electrical fault and catastrophic failure of a voltage transformer in the switchyard resulting in an explosion, fires, and damage to several switchyard components which affected plant operations, the operators failed to recognize the hazard to the stations operations met the emergency action level conditions for declaring an Alert. The station entered a Limiting Condition for Operation per Technical Specifications. The finding was screened to be more than minor because the failure to declare an Alert adversely affected the Reactor Safety - Emergency Preparedness Cornerstone objective to ensure the licensee is capable of implementing adequate measures to protect the health and safety of the public during a radiological emergency. The performance deficiency has the attribute of Emergency Response Organization Performance associated with Actual Event Response. The performance deficiency involving the failure to properly utilize the emergency classification and action level scheme during an actual Alert meets the criteria of the Emergency Preparedness SDP for a failure to implement a risk significant planning standard of event classification. The failure to classify was a result of the licensees errors in recognition, was not due to competing safety-related activities, and denied offsite authorities the opportunity to make decisions regarding protecting public health and safety. The finding was screened to be a failure to implement the risk significant planning standard associated with classification at the Alert level and was screened to be preliminarily White. Additionally, the cause of the deficiency had a cross-cutting component in the area of Human Performance. Specifically, the licensee failed to make safety-significant decisions using a systematic process and failed to obtain adequate reviews on the decisions (H.1(a))
05000282/FIN-2009012-012009Q3Prairie IslandFailure to Provide Complete Information to the NRC which Impacted a Licensing DecisionOn May 11, 2009, while reviewing an application to incorporate a medical restriction into an SROs operating license, an NRC inspector identified that Prairie Island Nuclear Generating Plant (PINGP) had provided incomplete and inaccurate information to the NRC when a license renewal was requested for the SRO in May 2007. The issue was considered to be of very low safety significance, but was considered to have important regulatory significance because the information was provided to the NRC under a signed statement and resulted in a licensing action that would not have been taken had complete and accurate information been provided to the NRC. This was an apparent violation of 10 CFR 50.9, Completeness and Accuracy of Information. Because the issue affected the NRC=s ability to perform its regulatory function, it was evaluated using the traditional enforcement process. The finding was determined to be of low safety significance because the licensed operator had taken medications as prescribed and had not made errors during any emergency condition prior to the license being amended. However, the regulatory significance was important because the incomplete and inaccurate information was provided under a signed statement to the NRC and impacted a licensing decision for the licensed operator. This was preliminarily determined to be an apparent violation of 10 CFR 50.9, Completeness and Accuracy of Information. No cross-cutting element for this finding was assigned. This appears to be a misunderstanding of NRC reporting requirements since they changed in January 2006 and is not reflective of current plant standards or processes in this area
05000237/FIN-2009301-012009Q1DresdenFailure to Provide Complete and Accurate Information to the NRC Associated with Verifying No Operating Test Item Duplication with the Audit TestThe inspectors identified a Severity Level IV Non-Cited Violation (NCV) of 10 CFR 55.40, Implementation, 10 CFR 50.9, Completeness and accuracy of information, and 10 CFR 55.49, Integrity of examinations and tests. For the Dresden Station March 2009 NRC Initial Operator License Examination, the inspectors identified that the examination author and the facility reviewer had initialed Step 2.b and Step 3.a.(3) of Form ES-201-2, Examination Outline Quality Checklist, on August 15, 2008, and August 19, 2008, respectively, and Step 1.c of Form ES-301-3 Operating Test Quality Checklist, on January 15, 2009, and January 20, 2009, respectively, which indicated that the operating test did not duplicate items from the applicants audit test, when, upon NRC review, it was determined that six of the 23 dynamic simulator scenario events, and one of the 15 Job Performance Measures (JPMs) for the Reactor Operator (RO) candidates were duplicated from the applicants audit test. The finding was determined to be more than minor, because the integrity of the NRC initial operator licensing examination could have been compromised if, but for detection by the NRC examiners, the NRC examination had been administered with the duplication of the operating test items from the applicants audit test. The finding was determined to be of very low safety significance because the duplication of operating test items was discovered by the NRC examiners prior to administration of the NRC examination, the duplicate test items were either removed from the audit test or the NRC exam changed to remove the duplication, and the facility implemented examination security requirements for the audit test similar to that which was required for the NRC examination. The inspectors concluded that this finding had a cross-cutting aspect in the area of Human Performance, Work Practices, because the licensee did not define and effectively communicate expectations regarding procedural compliance and for personnel to follow procedures (i.e., in the development of the NRC initial operator license examination) (H.4(b)). (Section 4OA5.2)
05000266/FIN-2009008-012009Q1Point BeachFailure to Notify the NRC of a Permanent Illness or Disability of a License OperatorPrior to becoming a licensed reactor operator (RO) in 1999, a non-licensed operator notified the stations medical staff that he began taking a prescribed medication for a potentially disqualifying medical condition in 1993. The NRC was not notified of the SROs potentially disqualifying medical condition until October 20, 2008. Title 10 CFR 50.74(c), Notification of Change in Operator or Senior Operator Status, requires the licensee to notify the NRC within 30 days of the licensee being informed of a permanent change in a licensed operators medical condition. The licensee should have notified the NRC of the operators potentially disqualifying medical condition when the operator applied for an NRC operating license in 1999. The time period between May 1999 and November 2008 exceeded the 30-day notification requirement. The licensee conducted a review of all licensed operator medical records to determine the extent of condition and initiated other compensatory measures to prevent recurrence of this condition. Because the issue affected the NRCs ability to perform its regulatory function it was evaluated using the traditional enforcement process. The finding was determined to be of low safety significance because the SRO was taking the medications as prescribed and had not made any operational errors during any emergency condition. The regulatory significance was important because plant staff failed to notify the NRC of a permanent disability or illness of an SRO within 30 days. This was preliminarily determined to be an apparent violation of 10 CFR 50.74(c). The cause of the apparent violation is related to the cross-cutting element of problem identification and resolution in the area of operating experience. P.2(b)(Section 1R11)
05000266/FIN-2009008-022009Q1Point BeachFailure to Provide Complete Information to the NRC Which Impacted a Licensing DecisionEvery six years an operators NRC operating license must be renewed. When the licensee submits the request for license renewal, the licensee must certify to the NRC that the operator is medically capable of performing license duties. This is done by completing an NRC Form 396, Certification of Medical Examination by Facility Licensee. When signed by senior station management, the NRC Form 396 certifies that an operator is able to perform operator duties. The form contains several standard license conditions that restrict operator activities to ensure their ability to 2 Enclosure perform license duties. In this SROs case, the licensee certified to the NRC in a letter dated January 23, 2008, that the operator was capable of performing license duties with no restrictions. The licensee provided incomplete and inaccurate information on the accompanying NRC Form 396 in that the licensee failed to inform the NRC that the SRO was taking medication for a potentially disqualifying medical condition so the NRC could properly restrict the SROs operating license to have a Must Take Medication as Prescribed to Maintain Qualifications license restriction. Because the issue affected the NRCs ability to perform its regulatory function, it was evaluated using the traditional enforcement process. The finding was determined to be of low safety significance because the SRO had taken medications as prescribed and had not made errors during any emergency condition prior to the license being amended. However, the regulatory significance was important because the incomplete and inaccurate information was provided under a signed statement to the NRC and impacted a licensing decision for the SRO. This was preliminarily determined to be an apparent violation of 10 CFR 50.9, Completeness and Accuracy of Information. The cause of the apparent violation is related to the cross-cutting element of problem identification and resolution in the area of operating experience. P.2(b)(Section 1R11)
05000305/FIN-2008503-012008Q3KewauneeFailure to Maintain a Standard EAL SchemeAn AV was identified by the inspector for failure to follow and maintain in effect emergency plans which use a standard emergency classification and action level scheme. Specifically, the licensee\\\'s emergency plan Alert emergency action levels (EALs) RA1.1 and RA1.2 specified instrument setpoints that were beyond the limits of the effluent radiation monitors capabilities. This finding was considered more than minor because the licensee is required to be capable to implement adequate measures to protect public health and safety in the event of a radiological emergency. Regulations require a standard emergency classification and action level scheme, the bases which included facility system and effluent parameters, in use by the licensee and State and local response plans call for reliance on information provided by the licensee for determination of minimum initial offsite response measures. As a result of having Alert EAL threshold values that were beyond the range of the associated effluent radiation monitors, Kewaunee personnel would not have been able to classify an emergency based upon an effluent radioactive material release in a timely manner. Emergency response actions directed by the State and local emergency response plans, which rely on information provided by the licensee, could have potentially been delayed. The cause of the finding is related to the human performance cross-cutting element of H.2(c) for ensuring that personnel, equipment, and procedures are available and adequate to assure nuclear safety. Specifically, those necessary for complete, accurate, and up-to-date design documentation, procedures, and work packages. (Section 1EP4
05000305/FIN-2003005-042003Q4KewauneeFailure to Provide Accurate Information to the NRC Concerning Eligibility Requirements for Operator License Application Per NRC Form 398.Severity Level IV. The inspector identified a Level IV Non-Cited Violation of 10 CFR 50.9, "Completeness and Accuracy of Information." The inspector identified that on or about August 13, 2002, a senior facility licensee representative submitted to the NRC, NRC Forms 398 for three individuals, each applying for an initial operator's license, that were not accurate in all material respects. The facility licensee provided inaccurate information by certifying on the NRC Form 398 that the initial operator license applicaitons for three individuals had appropriately met the minimum training requirements for reactivity manipulations on the refrenced facility simulator in accordance with 10 CFR 55.31(a)(5) and 10 CFR 55.46(c)(2).
05000305/FIN-2003005-022003Q4KewauneeFailure to Provide Accurate Information to the NRC Concerning Licensed Operator Medical Requirements Per NRC Form 396.Severity Level IV. The inspector identified a Level IV Non-Cited Violation of 10 CFR 50.9, "Completeness and Accuracy of Information." The inspector identified that the facility licensee, between January 2, 2000, thorugh August 26, 2002, submitted to the NRC, NRC Forms 396 for 13 individuals applying for an initial operator's license and 18 licensed operators applying for renewal of their operator licenses, that were not accurate in all material respects. Specifically, the NRC Forms 396 certified that each applicant and licensed operator met the medical requirements of ANSI/ANS 3.4-1983. In fact, all the applicants and licensed operators were not adequately examined for all medical tests as required to meet the minimum standards of ANSI/ANS 3.4-1983.
05000346/FIN-2001015-012001Q4Davis BesseSL Iv Violation of 10 CFR 50.7The NRC concluded that a security officer was discriminated against for engaging in protected activities within the scope of 10 CFR 50.7, "Employee Protection." A security supervisor subjected the officer to a fact-finding meeting on January 12, 2001, and placed a copy of the documentation from the meeting in the security officer's personnel file. The NRC determined that these actions were taken, at least in part, as a result of the security officer engaging in protected activity when he identified and documented in the condition report the potential security department training deficiency. The NRC issued a Notice of Violation by letter dated December 20, 2001, requiring a response by the licensee (VIO 50-346/01-15-01).
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