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05000244/FIN-2017001-012017Q1GinnaLicensee-Identified ViolationThe following violation of very low safety significance (Green) was identified by Exelon and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as a non- cited violation (NC V). Ginna TS Table 3.3.1- 1 requires the function of under frequency Bus 11A and 11B be tested to be greater than or equal to 57.5 hertz in accordance with surveillance requirement 3.3.1.10. Surveillance requirement 3.3.1.10 requires this testing to be completed in accordance with the Surveillance Frequency Control Program. The Surveillance Frequency Control Program requires the function of under frequency Bus 11A and 11B be tested every 24 months. Contrary to the above, on February 6, 2017, Ginna engineering personnel determined that the Bus 11A under frequency function had not been tested within the interval specified frequency ; the function had last been tested on May 1, 2014 . Upon identification, Exelon conducted a risk evaluation and completed the surveillance requirement at the next available opportunity i n accordance with surveillance requirement 3.0.3 for a missed surveillance. Exelon entered this issue into the CAP as AR 03970849 and completed the testing on March 11, 2017. Additional evaluation was required to demonstrate operability since the acceptance criteria of greater than or equal to 57.5 Hz was not met. The inspectors determined the finding was of very low safety significance (Green) in accordance with IMC 0609, Appendix A, The SDP for Findings at Power, Exhibit 1, Initiating Events Screening Questions, issued June 19, 2012, because the transient initiator did not cause a reactor trip and the loss of mitigating equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition.
05000244/FIN-2016003-012016Q3GinnaFailure to Perform Drills Required by the Site Emergency PlanThe inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50.54(q)(2) for Exelons failure to maintain an emergency plan that meets the requirements in Appendix E, Content of Emergency Plans, to Part 50 and the planning standards of 50.47(b). Specifically, Exelon did not perform a drive-in augmentation drill during the required 3-year cycle nor did they perform a health physics drill semi-annually as required by Ginnas Emergency Plan Implementing Procedure EP-AA-122-100, Drill and Exercise Planning and Scheduling. Immediate corrective actions included entering this issue into their corrective action program (CAP). This finding is more than minor because it is associated with the emergency response organization (ERO) readiness attribute of the Emergency Preparedness cornerstone and adversely affected the cornerstone objective to ensure that Exelon is capable of maintaining adequate measures to protect the health and safety of the public in the event of a radiological emergency. In accordance with IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, Attachment 2, Failure to Comply Significance Logic, the inspectors determined that the performance deficiency affected planning standard 10 CFR 50.47(b)(14). The inspectors concluded that this performance deficiency matched an example on Table 5.14-1 Significance Examples 50.47(b)(14), for a Degraded Planning Standard Function. Specifically, two drills had not been conducted during a 2year (calendar) period in accordance with the emergency plan, thus constituting a degraded planning standard function which corresponds to a very low safety significance (Green) finding. The cause of the finding has a cross-cutting aspect in the area of Human Performance, Procedure Adherence, because Exelon did not schedule or plan for a drive-in augmentation drill or health physics drills in accordance with procedure EP-AA-122-100. (H.8)
05000317/FIN-2016002-012016Q2Calvert CliffsScaffolding Impairs Fire Sprinkler Systems in Safety Related Fire AreasThe inspectors identified a Green, NCV of CCNPP Renewed Facility Operating License for Units One and Two, paragraph 2.E for Exelons failure to maintain in effect all provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report (UFSAR). Specifically, Exelon installed scaffolding in safety related areas not in accordance with approved procedures and, therefore, impaired fire sprinkler systems that were required by the approved fire protection program without establishing approved contingency measures. The inspectors determined that Exelons impairment of fire sprinkler systems by installing scaffolding with dimensions exceeding those approved in Exelon procedure MA-AA-716-025 was a performance deficiency that was within Exelons ability to foresee and prevent. The performance deficiency led to the violation of CCNPP Renewed Facility Operating License, paragraph 2.E, because Exelon failed to maintain in effect all provisions of the approved fire protection program. Exelons immediate corrective actions included stationing continuous fire watches and removal of the scaffolding deck boards which were impairing the fire sprinkler systems. Exelon entered these issues in to their corrective action program (CAP) as issue reports (IR): 02642463, 02642549, 02642844, 02644495, 02647104, 02647454, and 02647455. The inspectors reviewed IMC 0612, Appendix B, Issue Screening, and determined the issue is more than minor because it adversely affected the protection against external factors attribute of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, Exelon installed scaffolding that exceeded the allowed dimensions in MA-AA-716-025 and impaired the function of fire sprinkler systems in areas containing safety related equipment. The inspectors evaluated the finding using IMC 0609, Attachment 4, Initial Characterization of Findings, issued on June 19, 2012, and IMC 0609, Appendix F, The Fire Protection SDP Worksheet issued on September 20, 2013 and determined the finding to be of very low safety significance (Green) because, in all cases of impairment, the fire sprinkler systems were still capable of protecting their intended targets or were still capable to suppress fires such that no additional equipment important to safety would have been affected. The inspectors determined that the finding had a cross-cutting aspect in the area of Human Performance, Procedure Adherence, because Exelon failed to properly implement procedure MA-AA-716-025, Scaffold Installation, Modification, and Removal Request Process, Revision 11, which limits scaffolding dimensions and locations when installing scaffolding in safety related areas. (H.8)
05000318/FIN-2016002-032016Q2Calvert CliffsFailure to Implement Engineering Change Procedures Results in Plant TripThe inspectors documented a self-revealing, Green finding for Exelons failure to implement procedures for engineering changes. Specifically, Exelon failed to address the full scope and critical parameters associated with a modification to a steam generator feed pump (SGFP). As a result, the 22 SGFP turbine pedestal studs were improperly torqued, resulting in the SGFP shifting, becoming misaligned, and eventually resulting in the failure of the turbine to pump coupling. This resulted in the unexpected tripping of the 22 SGFP on December 1, 2015, and operators inserting a manual reactor trip as required by procedure. The inspectors determined that Exelons failure to properly implement procedures CNG-CM-1.01-1003, Design Inputs and Change Impact Screen, Revision 00601, Attachment 12; CNG-CM-1.01-2000, Scoping and Identification of Critical Components, Revision 00201; and CNG-FES-007, Preparation of Design Inputs and Change Impact Screen, Revision 00010 was a performance deficiency that was a performance deficiency that was within Exelons ability to foresee and prevent. Exelons corrective actions included, replacing the failed coupling, verifying the torque on the 21 SGFP using a HYTORCTM, and developing an adverse condition monitoring plan for Unit 1s SGFPs. Exelon conducted a root cause evaluation (RCE) and developed corrective actions to preclude repetition (CAPR) including implementation of Exelon procedure HU-AA-1212, Technical Task Risk/Rigor Assessment, Pre-Job Brief, Independent Third Party Review, and Post-Job Review, Revision 007 and conducting critical parameters and rigor training for engineering personnel including the expectations for three pass reviews and verification of assumptions. The inspectors reviewed IMC 0612, Appendix B, Issue Screening, and IMC 0612, Appendix E, Examples of Minor Issues and determined the issue is more than minor because it was associated with the Design Control Attribute of the Initiating Events Cornerstone and adversely impacted the associated cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the performance deficiency resulted in a reactor trip from full power on December 1, 2015. The inspectors evaluated the finding using IMC 0609, Attachment 4, Initial Characterization of Findings, issued on June 19, 2012, and IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 1, Initiating Events Screening Questions, issued on June 19, 2012 and determined the finding to be of very low safety significance (Green) because the finding did not cause a reactor trip and the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. The inspectors determined that the finding had a cross-cutting aspect in the area of Human Performance, Documentation, because Exelon failed to develop and maintain complete and accurate engineering change packages (ECP), work orders (WO), and maintenance procedures.(H.7)
05000317/FIN-2016002-022016Q2Calvert CliffsFailure to Report Conditions as Required by 10 CFR 50.73The inspectors identified a Severity Level IV, NCV of 10 CFR 50.73(a)(2) for Exelons failure to report within 60 days of discovery, a condition that could have prevented the fulfillment of the safety function of the service water (SRW) system needed to mitigate the consequences of an accident. Additionally, Exelon failed to report within 60 days of discovery, a single condition that caused two trains of the SRW system, a system designed to mitigate the consequences of an accident, to become inoperable. Exelon entered the issue into their CAP as IR 02688409 and on July 20, 2016, submitted LER 05000317/2016-004-00, High Energy Line Break Barrier Breached Due to Human Performance Error Causing Both Service Water Trains to be Inoperable. The inspectors determined that Exelons failure to report a single condition that caused the inoperability of two trains of SRW and may have prevented SRW from fulfilling its design functions to mitigate the consequences of an accident within 60 days of discovering the condition was a violation of 10 CFR 50.73(a)(2), and could have impacted the regulatory process. The inspectors reviewed IMC 0612, Appendix B, Issue Screening, and the NRC Enforcement Policy, revised February 4, 2015, and determined the violation is of SL-IV because it is most similar to example 6.9.d.9 of the NRC Enforcement Policy, A licensee fails to make a report required by 10 CFR 50.72 or 10 CFR 50.73, which is a SL-IV violation. The inspectors determined that the violation did not have a cross-cutting aspect because it involved the traditional enforcement process only.
05000244/FIN-2016002-012016Q2GinnaIncorrect Emergency Action Level TableExelon identified that they had inadvertently made a change to the Ginna Emergency Plan. The NRC determined that this error is a preliminary White finding under the Reactor Oversight Process and a violation of Title 10 of the Code of Federal Regulations (10 CFR) 50.54 (q)(2), Emergency Plans, because Exelon did not maintain the effectiveness of Ginnas Emergency Plan such that it met the requirements of Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, and the planning standards of 10 CFR 50.47(b). Specifically, Exelon implemented a revision to the emergency action level (EAL) table for the fission product barrier matrix that was incorrect with respect to the EAL threshold associated with potential loss of containment barrier. This could have resulted in an untimely declaration of a General Emergency or a failure to declare a Site Area Emergency during an actual event. Using IMC 0612, Appendix B, Issue Screening, the performance deficiency was determined to be more than minor because it impacted the procedure quality attribute of the Emergency Preparedness cornerstone and adversely affected the associated cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, Exelons EAL table was revised without adequate technical reviews resulting in a discrepancy between the EAL table and the EAL technical basis. The EAL wording of Table F-1 containment barrier potential loss, block C.6 did not meet the minimum required operable equipment in all situations and could have resulted in a delayed General Emergency declaration or a failure to declare a Site Area Emergency. The inspectors utilized IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process (SDP), to determine the significance of the performance deficiency. The performance deficiency is associated with the emergency classification system planning standard and is considered a risk-significant planning standard function. The inspectors were directed by the SDP to compare the performance deficiency with the examples in Section 5.4, 10 CFR 50.47 (b)(4), Emergency Classification System, to evaluate the significance of this performance deficiency. In accordance with Section 5.4, when an EAL has been rendered ineffective such that any General Emergency declaration would not be declared, but due to other EALs, an appropriate declaration would be made in a degraded manner or any Site Area Emergency would not be declared for a particular off-normal event, a degradation of risk-significant planning standard function (b)(4) is determined; and the finding is White. The finding has a cross-cutting aspect in the area of Human Performance, Change Management, because Exelon did not use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority. Specifically, Exelon did not maintain a clear focus on nuclear safety when implementing changes to the EALs resulting in a significant unintended consequence, the potential to make an untimely emergency declaration.
05000244/FIN-2016001-012016Q1GinnaLicensee-Identified ViolationTitle 10 CFR 50.54(q)(2) requires that a holder of a nuclear power reactor operating license under this part shall follow and maintain the effectiveness of an emergency plan that meets the requirements in Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities. Section IV.B.1 of 10 CFR 50, Appendix E, requires, in part, that the means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification and participation of State and local agencies, the Commission, and other Federal agencies, and the emergency action levels that are to be used for determining when and what type of protective measures should be considered within and outside the site boundary to protect health and safety. Contrary to the above, prior to January 7, 2016, Exelon procedure EP-AA-110-203, GNP Dose Assessment, Revision 003, did not consider the possibility of two different flow rate values through the plant vent. The plant vent has the capability to flow through filters when new fuel assemblies are added to the SFP resulting in the potential for two different flow rates out the ventone with the filters in service (69074 cubic feet per minute) and one without the filters in service (50560 cubic feet per minute). Due to the error, during certain events, Exelon would have inappropriately determined the event contaminant release rate to be higher than actual, resulting in the early declaration of an emergency action level. Upon identification, Exelon entered this into its CAP as AR 02609057 and implemented dose assessment compensatory measures to be used in EP-AA-110-203, Attachment 7, Ventilation Systems Flow Rates, table data. The inspectors determined the finding was of very low safety significance (Green) in accordance with Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, issued September 22, 2015, because a deficient emergency classification process which would result in an overclassification, but would not result in unnecessary public protective measures should be considered Green.
05000277/FIN-2015008-012015Q2Peach BottomFailure to Initiate IRs for Out-of-Calibration SPVsThe inspectors identified a finding of very low safety significance (Green) because PBAPS did not initiate issue reports (IR) to identify out-of-tolerance conditions for a number of single point vulnerability (SPV) instruments. An SPV instrument is any instrument for which a single failure could initiate a plant transient or cause a plant scram. Specifically, during routine preventative maintenance (PM) calibrations, certain SPV instruments as-found data was found outside expected tolerance bands, with many being significantly outside of their bands. In most cases, IRs were not written to document these adverse conditions contrary to station guidance. The finding is determined to be more than minor because it affected the reliability of the initiating cornerstones attribute of equipment performance and affected its objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during power operations. Specifically, by not identifying and trending out-of calibration SPVs in a timely manner, a resulting transient from the loss of a single feed pump or a single reactor recirculation pump is more likely to occur. The inspectors conducted a Phase 1 screening in accordance with NRC Inspection Manual Chapter (IMC) Attachment 0609.04, Phase 1 Initial Screening and Characterization of Findings, and determined that the finding was of very low safety significance (Green) because the finding did not cause a reactor trip and the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition (e.g. loss of condenser, loss of feed water.) A loss of a single feed pump or a single recirculation pump typically results in a power reduction but not a reactor scram. The inspectors determined that the finding had a cross-cutting aspect in the area of Problem Identification and Resolution, Identification. In the case of the finding, PBAPS did not ensure that degraded conditions, namely, out of tolerance SPV instruments, were promptly reported and documented in the corrective action program at a low threshold.
05000289/FIN-2015001-012015Q1Three Mile IslandLicensee-Identified ViolationLER 05000289/2014-001-00 describes an unanalyzed condition in which Exelon identified DC motor control circuits were unfused. Specifically, Exelon did not provide overcurrent protection for wiring associated with 250VDC full-voltage control circuits for four non-safety emergency bearing oil pumps in the turbine building to prevent wires from overheating due to fire-induced faults and excessive currents flowing through the cable. With enough current flowing through the cable, the potential exists that the overloaded motor control wiring could damage adjacent control circuit wiring for both instrument air compressors (IA-P-1A/B), which are needed to achieve and maintain post-fire safe shutdown for a fire in the cable spreading room. This condition could result in a loss of the associated safe shutdown components or a secondary fire in another fire area. The failure to protect safe shutdown cables from the effect of postulated fires was a performance deficiency. This performance deficiency was a violation of TMI Operating License Condition 2.C.(4), which requires, in part, post-fire safe shutdown cables remain free of the effects of fire-induced cable faults during postulated fires. Contrary to the above, Exelon identified they failed to meet this requirement and the condition existed since initial construction. The issue was more than minor because it was associated with the protection against external events (fire) attribute of the mitigating systems cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors determined that the finding was of very low safety significance (Green), based on IMC 0609, Appendix F, Fire Protection Significance Determination Process, Phase 2 screening criteria. The finding screened to Green based upon task number 2.3.5, and because no credible fire ignition source was determined to adversely affect the motor control circuits of concern as determined. Additionally, a fire area of concern (cable spreading area) is an alternate shutdown fire area protected by detection and an automatic suppression system. The cables in the other fire area of concern (turbine building) are Institute of Electrical and Electronics Engineers 383 (thermoset) construction with steel armor and tied to station ground which decreases the likelihood of inter-cable and intra-cable interactions. Because this finding is of very low safety significance and had been entered into Exelons corrective action program (IRs 1651702, 1658837, 1658842), this violation is being treated as a Green, licensee-identified NCV consistent with the NRCs Enforcement Policy.
05000277/FIN-2015001-012015Q1Peach BottomFailure to Scope Flood Detection Level Switches into the MRThe inspectors identified a non-cited violation (NCV) of very low safety significance (Green) of 10 CFR Part 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," because Exelon did not include certain flood indication functions into the scope of the maintenance rule (MR). Specifically, level switches used to indicate flood levels in the Unit 2 and Unit 3 emergency core cooling system (ECCS) rooms were not included in the scope of the MR as required by 10 CFR 50.65 (b)(2)(i) as non-safety related components that are used in plant emergency operating procedures (EOPs). PBAPS entered the issue into their corrective action program (CAP) as issue reports (IRs) 02433897 and 02437502 and scoped the level switches into the MR. The finding is determined to be more than minor because it is associated with the protection against external factors attribute of the Mitigating Systems cornerstone and affected the cornerstones objective to ensure the reliability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). In the case of this finding, monitoring of components that provide alarm indication to operators during a flood hazard were not incorporated into the MR. The inspectors also reviewed IMC 0612, Appendix E, Examples of Minor Issues, and determined the issue was similar to example 7.d; in that, flood detection was not within the scope of the MR and that one of the flood detectors had experienced performance problems during preventive maintenance (PM) testing . The inspectors conducted a Phase 1 screening in accordance with IMC 0609.04, Phase 1 Initial Screening and Characterization of Findings, and determined that the finding was of very low safety significance (Green), because the finding was not a design or qualification deficiency, did not represent an actual loss of system safety function, did not represent an actual loss of safety function of a single train for greater than its Technical Specification (TS) allowed outage time, and did not screen as risk significant due to external initiating events. The inspectors determined that the finding had a cross-cutting aspect in the area of Human Performance, Change Management because PBAPS did not use a systematic process for evaluating and implementing a change. Specifically, during PBAPSs MR database update and monitoring criteria development for new functions, PBAPS did not ensure that certain level switches that provide alarms for flooding used in plant EOPs were scoped into the MR despite identifying that it was required. (H.3)
05000247/FIN-2014005-062014Q4Indian PointLicensee-Identified ViolationOn February 24, 2014, Entergy personnel determined that a condition prohibited by Unit 2 TSs existed when a pinhole leak from a drain valve body was identified which resulted in an inoperable 23 SG. TS 3.4.4 requires during Mode 1 and 2 that four RCS loops be operable or be in Mode 3 within 6 hours. Contrary to the above, prior to February 24, Indian Point Unit 2 operated in Modes 1 and 2 with an inoperable SG when a pinhole leak from a valve body on the 23 SG existed in excess of 6 hours without entering Mode 3. Although attempts had been made to identify the source of a small secondary leak in containment during plant operation, the drain valve was not accessible with the reactor in operation and plant shutdown was required to complete the inspection on February 24, 2014. No performance deficiency was identified because it was not reasonable for Entergy to foresee and prevent the pinhole leak. The leak when found was documented in CR-IP2-2014-0975, and the valve was replaced. The violation was more than minor because it impacted the Equipment Performance attribute of the Initiating Events cornerstone. The issue screened to be of very low safety significance (Green) using IMC 0609, Appendix A when loss of coolant analysis assumptions and equipment performance were not affected by the degradation.
05000286/FIN-2014005-072014Q4Indian PointLicensee-Identified ViolationOn March 1, 2013, Entergy personnel tested Unit 3 main steam safety valves and determined main steam safety valve MS-46-3 had a lift setpoint outside of the +/-3 percent lift setting required by TS 3.7.1. Subsequently, MS-46-3 was declared inoperable and further testing found valve MS-48-3 also lifted out of the TS band. TS 3.7.1 requires the main steam safety valves be operable or reduce neutron flux trip setpoint to less than that listed in TS Table 3.7.1-1. Contrary to the above, as of March 1, 2013, main steam safety valves MS-46-3 and MS-48-3 had lift setpoints outside of the TS required band and flux trip setpoints were not reduced to those listed in TS Table 3.7.1-1. The affected valves were adjusted at the time of testing to within the required band, the condition was documented in the CAP as CR-IP3-2013- 0869 and CR-IP3-2013-0892, and an evaluation was initiated. Other valves similarly tested were satisfactory. No performance deficiency was identified because it was not reasonable for Entergy to foresee and prevent the change in main steam safety valve setpoint during plant operation. Corrective actions to prevent recurrence were documented in LER 05000286/2013-001-00. The violation was more than minor because it impacted the Equipment Performance attribute of the Mitigating Systems cornerstone. The issue screened to be of very low safety significance (Green) using IMC 0609, Appendix A because the overall pressure mitigating function was not affected by the degradation of the two valves of the twenty total.
05000247/FIN-2014005-052014Q4Indian PointLicensee-Identified ViolationAccording to 10 CFR 55.25, if an operator develops a permanent physical or mental condition that causes the operator to fail to meet the requirements of 10 CFR 55.21, the facility licensee shall notify the NRC within 30 days of learning of the diagnosis, in accordance with 10 CFR 50.74(c) which states that the regional administrator shall be notified if a licensed operator develops a permanent disability or illness. Contrary to these requirements, during the time frame of July through September 2014, the facility licensee identified four operators (in addition to the one mentioned above) that required medical restrictions and that the NRC needed to be notified. These four cases have been documented in CR-IP2-2014-04202, CR-IP3-2014-1961, and CRIP3- 2014-2156. In all four cases, the individual operators were untimely in notifying the facility licensee of the changes in their medical conditions or the licensee physician failed to recognize the need to report the condition to the NRC. This violation is subject to traditional enforcement because of the potential impact upon the regulatory process for issuing restrictions to operators licenses. This issue meets the criteria for a Severity Level IV violation because all of the operators met the criteria of ANSI/ANS-3.4-1983 but failed to report conditions requiring a license restriction.
05000247/FIN-2014005-042014Q4Indian PointLicensee-Identified ViolationAccording to 10 CFR 55.21 and 33, licensed operators are required to have a physical examination every two years to ensure that their medical condition and general health will not adversely affect the performance of assigned operator job duties or cause operational errors endangering public health and safety. As a part of licensed operator medical evaluations, olfactory testing is required as specified in ANSI/ANS-3.4-1983, Medical Certification and Monitoring of Personnel Requiring Operator Licenses for Nuclear Power Plants. Olfactory testing in the standard states Nose. Ability to detect odor of products of combustion and of tracer and marker gases. License procedure, EN-NS-112, Medical Program, has the same wording. Contrary to this requirement, in CR-IP2-2014-04622, Entergy identified that they had not been testing operators for two tracer/marker gases used on site wintergreen in the carbon dioxide systems and mercaptan used in natural gas. This violation is subject to traditional enforcement because of the potential impact upon the regulatory process because the operators medical conditions are reviewed by the NRC when issuing or renewing operator licenses. This issue meets the criteria for a Severity Level IV violation because, upon subsequent olfactory testing, all operators were found to meet the health requirements for licensing.
05000247/FIN-2014005-022014Q4Indian PointIncomplete and Inaccurate Medical Information Provided by the Licensee Which Impacted an Operators License RenewalEntergy identified two AVs of NRC requirements related to Entergy not notifying the NRC within 30 days of a change in a licensed reactor operators (ROs) medical condition and to providing information to the NRC pertaining to renewing a RO license that was not complete and accurate in all material respects. Specifically, Entergy identified an AV of Title 10 of the Code of Federal Regulations (10 CFR) 50.74, Notification of Change in Operator or Senior Operator Status, for Entergys failure to notify the NRC within 30 days after learning, on October 25, 2012, that a Unit 3 RO had a permanent disability or illness (sleep apnea). Entergy also did not request an amended license with a condition to account for the medical issue, resulting in the RO performing licensed duties without a properly restricted license. Additionally, Entergy identified an AV of 10 CFR 50.9, Completeness and Accuracy of Information, pertaining to Entergys failure to provide information to the NRC in the ROs license renewal application in that it did not specify that the RO had a medical condition (sleep apnea) that required a restriction (for use of a continuous positive airway pressure (CPAP)). The NRC, in turn, issued a license renewal that did not contain the necessary restriction. Compliance was restored on July 7, 2014, when Entergy submitted a letter to the NRC with a Form 396 indicating the new restriction for the use of a CPAP machine. On August 14, 2014, the NRC issued a license amendment with the new restriction. These issues were entered into Entergys corrective action program (CAP) as condition report (CR)-IP3-2014-1416 and CR-IP2-2014- 4202. The inspectors determined that Entergys failure to report a change in a licensed operators permanent medical condition to the NRC and subsequently provide complete and accurate information to the NRC was a performance deficiency that was within their ability to foresee and correct and should have been prevented. The inspectors determined that traditional enforcement applies, as the issue impacted the NRCs ability to perform its regulatory function. The inspectors screened the issue using Section 6.4.c.4(b) of the NRC Enforcement Policy and preliminarily determined that these AVs meet the definition of a Severity Level III violation because Entergy failed to report a condition that would have required the addition of a license restriction within the required timeframe and, again, for the ROs license renewal. No associated Reactor Oversight Process finding was identified and no cross-cutting aspect was assigned. These issues constitute AVs in accordance with the NRCs Enforcement Policy, and the final significance will be dispositioned in future correspondence. Because the significance determination of this issue is not complete, it is identified as TBD.
05000247/FIN-2014005-032014Q4Indian PointLicensee-Identified Violation10 CFR 50, Appendix B, Criterion XII, Control of Measuring and Test Equipment, requires measures shall be established to assure that tools, gages, instruments, and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specified periods to maintain accuracy within necessary limits. Contrary to 10 CFR 50, Appendix B, Criterion XII, Indian Point did not properly implement their measuring and test equipment (M&TE) program resulting in the use of uncalibrated M&TE to perform maintenance, tests, and meet surveillance requirements on safety-related SSCs. Entergy identified deficiencies in their M&TE program during an Entergy Nuclear Oversight Quality Assurance audit of the Entergy Maintenance department. As a result of the Quality Assurance finding, a root cause analysis was conducted and corrective action plan developed. The corrective action plan CR-IP2-2014-03809 was reviewed by NRC inspectors as well as operability assessments conducted by Entergy operations personnel on safetyrelated SSCs worked on with out-of-tolerance M&TE. The issue screened to be of very low safety significance (Green) using IMC 0609, Appendix A, because the affected safety-related SSCs maintained their operability. No additional findings resulted from the NRC inspector review.
05000247/FIN-2014005-012014Q4Indian PointLicensed Operator Requalification Remedial Exam Standard AdherenceThe inspectors identified a Green finding (FIN) because Entergy did not adhere to their procedural standards for generating remedial written exams. Entergy failed to follow the guidance as stated in their procedure EN-TQ-201-03, Systematic Approach to Training, Section 5.4, regarding remedial exam construction when an operator was retested on April 25, 2013. The inspectors determined that Entergys failure to adhere to their remedial examination standards in EN-TQ-201-03 was a performance deficiency. The inspectors determined that the finding was more than minor because it was associated with the human performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the finding affected the quality and level of difficulty of the remedial quiz which potentially impacted Entergys ability to appropriately evaluate the licensed operator. The inspectors determined that this issue had a cross-cutting aspect in Human Performance, Procedure Adherence, because Entergy did not follow their procedural standards for generating remedial written exams.
05000333/FIN-2014004-022014Q3FitzPatrickLicensee-Identified ViolationTS 3.3.5.2, Reactor Core Isolation Cooling System Instrumentation, requires that the RCIC system instrumentation for all four channels of low CST water level be operable while in Modes 1, 2, or 3 with reactor steam dome pressure greater than 150 psig. With one level switch inoperable, Condition D requires that the channel be placed in trip. When this condition is not met, Condition E requires that RCIC be declared inoperable. TS 3.5.3, RCIC System, further requires that RCIC be restored to operable status within 14 days or be in Mode 3. Contrary to TS 3.3.5.2, with one RCIC CST level switch, 13LS-76B, inoperable from September 17, 2013 until November 4, 2013, Entergy did not place the channel in trip or declare RCIC inoperable, or place the reactor in Mode 3 per TS 3.5.3. The cause of the inoperability was the failure to align the microswitch in accordance with vendor manual instructions when the switch was replaced in September. Entergy entered this issue into the CAP as CR-JAF-2013-5576. The inspectors determined that the finding was of very low safety significance (Green) in accordance with IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings at Power, because the finding was not a design or qualification deficiency, did not involve the actual loss of safety function, did not represent the actual loss of a safety function of a single train for greater than its TS allowed outage time, and did not screen to potentially risk significant due to a seismic, flooding, or severe weather initiating event.
05000333/FIN-2014004-012014Q3FitzPatrickFailure to Notify NRC Within 30 Days of Medical Changes for Licensed OperatorsThe inspectors identified a Severity Level (SL) IV NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50.74, Notification of Change in Operator or Senior Operator Status. Specifically, on three occasions, Entergy staff did not notify the NRC of a change in the medical status of a licensed operator within 30 days of learning of the diagnosis. These issues were entered into the corrective action program (CAP) as condition report (CR)-JAF-2014-02227 and CR-JAF-2014-02304. The inspectors determined that Entergys failure to notify the NRC of licensed operator medical status changes as described above within 30 days was a performance deficiency that was within Entergys ability to foresee and correct and should have been prevented. Because the issue had the potential to affect the NRCs ability to perform its regulatory function, the inspectors evaluated this performance deficiency in accordance with the traditional enforcement process. Using example 6.4.d.1(b) from the NRC Enforcement Policy, the inspectors determined that the violation was a Severity Level IV (more than minor concern that resulted in no or relatively inappreciable potential safety or security consequence) violation because Entergy staff did not communicate licensed operator permanent medical status changes within the 30 day reporting requirement for three licensed operators. In accordance with IMC 0612, Power Reactor Inspection Reports, traditional enforcement issues are not assigned cross-cutting aspects.
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