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05000334/FIN-2018003-012018Q3Beaver ValleyInadequate Verification of Full Low Head Safety Injection Suction PipingA self-revealed Green non-cited violation (NCV) of technical specification(TS)5.4.1, Procedures, was identified when FENOC failed to adequately implement procedure 1OM-52.4.R.2.A, Station Startup Mode 6 to Mode 1 Administrative and Local Actions, to verify that the low head safety injection (LHSI) suction pipes were full of water. Specifically, the non-destructive examination (NDE) inspector incorrectly determined that the suction pipes were full, which led to inoperability of one or more trains of LHSI for in excess of four hours on May 22, 2018,when the suction lines were found to be voided.
05000387/FIN-2018001-012018Q1SusquehannaLicensee-Identified ViolationThis violation of very low safety significant was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a Non-Cited Violation, consistent with Section 2.3.2 of the Enforcement Policy.Violation: Susquehanna Unit 1 TS section 5.4.1 requires that written procedures shall be implemented covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Susquehannas implementing instruction NDAP-QA-0503, General Housekeeping, Transient Material and Internal Cleanliness, Revision 45 implements aspects of the Regulatory Guide administrative procedures requirements. NDAP-QA-0503 section 6.1.5.h requires, in part, that transient equipment shall be located such that it will not impact safety related equipment during a seismic event. Locate all items at a distance greater than the height of the item from safety related equipment. Additionally, TS 3.5.1 Action Statement I directs immediate entry into Limiting Condition for Operation (LCO)3.0.3 if one core spray subsystem is inoperable with one low pressure coolant injection (LPCI) subsystem inoperable. LCO 3.0.3 requires action to be taken within 1 hour to place the unit in MODE 2 within 7 hours and MODE 3 within 13 hours.Contrary to the above, from December 1, 2017 to December 3, 2017, Susquehanna staged a 540 pound, ten foot long replacement pipe on 34 inch high stands within 34 inches of the safety related Unit 1, B Core Spray room cooler. Susquehanna concluded that the room cooler was inoperable because the pipe could have reasonably contacted and damaged the flexible conduit for the power cable to the room cooler during a seismic event. Additionally, from 7:48 a.m. on December 2, 2017 to 1:35 p.m. on December 3, 2017, maintenance was performed on the Unit 1, division 2 LPCI swing bus motor generator which rendered the division 2 LPCI system inoperable. During this time, Susquehanna did not perform the required actions of LCO 3.0.3 and remained in MODE 1.Significance/Severity Level: This violation is of very low safety significance (Green), since this finding did not represent a loss of system, a loss of function of at least a single train for greater than its TS allowed outage time, or a loss of a non-TS train. Corrective Action Reference(s): CR-2017-20227; CR-2018-01717; CR-2018-02250
05000278/FIN-2018001-012018Q1Peach BottomUntimely Corrective Actions to Address Primary Containment Isolation Valve Condition Adverse to QualityA Green self-revealing non-cited violation(NCV)of 10 Code of Federal Regulations(CFR)50, Appendix B, Criterion XVI, Corrective Action, was identified because Exelon did not implement prompt corrective actions to address a condition adverse to quality (CAQ) on primary containment isolation valve (PCIV) SV-3-7D-3671G.Specifically, drywellair sampling valve SV-3-7D-3671G failed to perform its PCIV function on February 1, 2018, by failing to stroke closed during its surveillance test as a result of untimely corrective actions.Exelon isolated the associated piping in accordance with technical specifications(TSs)
05000352/FIN-2018001-022018Q1LimerickEmergency Diesel Generator Combustion Air OverheatingA self-revealed Green NCV of LGS Unit 1 TS 6.8.1 and TS 3.8.1.1 was identified when Exelon failed to properly maintain an operating procedure to maintain a fail-safe design feature for the EDGs which led to the D12 EDG combustion air overheating and caused the EDG to be inoperable for greater than its TS allowed outage time.
05000353/FIN-2018001-012018Q1LimerickFailure of Emergency Diesel Generator Lube Oil Pipe Nipple FittingA self-revealed Green non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, and LGS Unit 2 technical specification (TS) 3.8.1.1 was identified when Exelon failed to correct a degraded lube oil pipe nipple fitting on the D22 emergency diesel generator (EDG) when maintenance was performed to address leakage which caused inoperability of the EDG for greater than its TS allowed outage time.
05000334/FIN-2017004-012017Q4Beaver ValleyInadequate Control of Entry into High Radiation AreasA self-revealing, very low safety significance NCV of Technical Specification (TS) 5.7.1 for failure to control a high radiation area (HRA) was identified. On November 8, 2017, during independent spent fuel storage installation (ISFSI) dry cask loading campaign activities, the failure of multiple barriers resulted in a worker gaining access to an HRA while signed onto an incorrect radiation work permit (RWP) and a subsequent dose rate alarm. Specifically, a worker signed on to an incorrect RWP during a break, and did not recognize that the surveyed work area dose rates were higher than the RWP setpoints. Additionally, radiation protection personnel controlling access to the HRA failed to ensure that the worker was on the correct RWP per plant procedure requirements for a subsequent entry into anHRA. This resulted in the worker entering an HRA under the incorrect RWP and receiving a dose rate alarm of 1,070 millirem per hour. Upon receiving a dose rate alarm, the worker backed away from the area and reported the issue to radiation protection personnel. FENOCs immediate corrective actions included putting the work in a safe condition, performing follow-up surveys, and verifying remaining personnel trip tickets to ensure all individuals were on the correct RWP. FENOC entered the issue into their corrective action program (CAP) as condition report (CR) 2017-11206.The failure to control access to an HRA is a performance deficiency that was within FENOCs ability to foresee and correct and should have been prevented. The performance deficiency is more than minor because it is associated with the Program and Process attribute (Procedures) of the Occupational Radiation Safety cornerstone and adversely affected the cornerstone objective of ensuring adequate protection of worker health and safety from exposure to radiation from radioactive material during routine reactor operation. Specifically, the failure of multiple barriers resulted in a worker gaining access to an HRA while signed on to an incorrect RWP and receiving a dose rate alarm. IMC 0612, Appendix E, Section 6, Health Physics, General Screening Criteria, states that a performance deficiency involving more than one barrier or the loss of a significant barrier would be classified as a more-than-minor performance deficiency. Using IMC 0609,Appendix C, Occupational Radiation Safety Significance Determination Process, the finding was determined to be of very low significance (Green) because: (1) it was not an as low as reasonably achievable (ALARA) finding, (2) there was no overexposure, (3) there was no substantial potential for an overexposure, and (4) the ability to assess dose was not compromised. The finding was a human performance cross-cutting aspect associated with avoiding complacency because FENOC failed to ensure individuals recognize and plan for the possibility of mistakes and ensure individuals implement the appropriate error reduction tools, even when expecting a successful outcome (H.12)
05000334/FIN-2017003-012017Q3Beaver ValleyOperability Determinations and Functionality AssessmentsInspection Scope The inspectors reviewed operability determinations for the following degraded or non- conforming conditions based on the risk significance of the associated components and systems: Unit 1 Anchor Darling double disk gate valves evaluation resulting from NRC Information Notice 2017- 03 on July 13, 2017 Unit 1 fire protection system functionality during a fire water header break on July 20, 2017 Impact on Unit 1 SSST 1A from nearby fire water header break on July 20, 2017 Unit 1 EDG exhaust piping not protected from tornado- generated missiles on July 25, 2017 Unit 1 degraded main steam valve room high energy line break door on July 26, 2017 Unit 2 inoperable DRPI impact on verifying operability of control rod F10 on August 25, 2017 Unit 1 EDG 1 -2 building exhaust damper missing louver on September 22, 2017 The inspectors evaluated the technical adequacy of the operability determinations to assess whether TS operability was properly justified and the subject SSC remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TS s and UFSAR to FENOCs evaluations to determine whether the SSCs were operable. The inspectors confirmed, where appropriate, compliance with bounding limitations associated with the evaluations. Where compensatory measures were required to maintain operability , the inspectors determined whether the measures in place would function as intended and were properly controlled by FENOC. 11 b. Findings 10 CFR 50, Appendix B, Criterion III, Design Control, requires, in part, that measures shall be established to assure that the applicable regulatory requirements and the design basis for SSCs are correctly translated into specifications, drawing, procedures, and instructions. Contrary to the above, FENOC failed to correctly translate the design basis for protection against tornado generated missiles into their specifications and procedures. Specifically, FENOC did not adequately protect Unit 1 EDG s exhausts from tornado generated missiles. FENOC documented the condition adverse to quality in their CAP under condition report 2017 -07550 and took immediate compensatory actions. The inspectors evaluated FENOCs immediate compensatory measures, which included verifying that procedures are in place and training is current for performing actions in response to a tornado. Because this violation was identified during the discretion period covered by Enforcement Guidance Memorandum 15- 002, Revision 1, Enforcement Discretion for Tornado Missile Protection Non- compliance (ML16355A286) and because FENOC has implemented compensatory measures, the NRC is exercising enforcement discretion and is not issuing enforcement action and is allowing continued reactor operation
05000334/FIN-2017002-012017Q2Beaver ValleyLicensee-Identified ViolationThe following violation of very low safety significance (Green) was identified by FENOC and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as a NCV . TS 3.7.8, "Service Water System", requires two service water trains to be operable. There is no associated action provided for both trains inoperable. LCO 3.0.3 states, in part, that when an LCO is not met and an associated action is not provided, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Act ion shall be initiated within one hour to place the unit, as applicable, in M ODE 3 within 7 hours. Contrary to the above, on August 20, 2015 and August 31, 2015 , FENOC had both trains of service water inoperable for greater than 7 hours while performing the service water full flow test and did not place Unit 2 in Mode 3. FE NOC entered this issue into the CAP as CR 2017- 04023. The inspectors evaluated this finding using IMC 0609.04, Initial Characterization of Findings . Because the finding represented a loss of function of a system, a detailed risk evaluation was performed. A Region I senior reactor analyst used the BVPS Unit 2 Standardized Plant Analysis Risk Model version 8.5 to perform the evaluation. A seismic initiating event frequency was obtained from the Risk Assessment of Operational Events Handbook Volume 2, External Events. A surrogate loss -of-offsite - power event was used applying the seismic initiating event frequency for BVPS with a train of service water being failed with no recovery assumed. The finding was determined to be of very low safety significance (Green) because the limited exposure time in this configuration resulted in a change in core damage frequency in the 1E -10/yr range. The dominant core damage sequence was a seismic event with failure of the EDG .
05000334/FIN-2017001-022017Q1Beaver ValleyOperability Determinations and Functionality Assessments10 CFR 50, Appendix B, Criterion III, Design Control, requires, in part, that measures shall be established to assure that the applicable regulatory requirements and the design basis for structures, systems, and components are correctly translated into specifications, drawing, procedures, and instructions. Contrary to the above, FENOC failed to correctly translate the design basis for protection against tornado-generated missiles into their specifications and procedures. Specifically, FENOC did not adequately protect Unit 1 and Unit 2s main steam safety and atmospheric dump valve exhausts from tornado-generated missiles. Additionally, FENOC did not adequately protect Unit 2s component cooling pumps and spent fuel from tornado-generated missiles by failing to include in their procedures actions for closing the tornado doors in the event of a tornado. The inspectors evaluated FENOCs immediate compensatory measures, which included verifying that procedures are in place and training is current for performing actions in response to a tornado. Because this violation was identified during the discretion period covered by Enforcement Guidance Memorandum 15-002, Revision 1, Enforcement Discretion for Tornado Missile Protection non-compliance (ML16355A286) and because FENOC has implemented compensatory measures, the NRC is exercising enforcement discretion, is not issuing enforcement action, and is allowing continued reactor operation.
05000334/FIN-2017001-012017Q1Beaver ValleyFailure to Follow the ASME OM Code for a Failed Relief Valve Set Pressure TestSeverity Level IV. The inspectors identified a Severity Level IV NCV of Title 10 of the Code of Federal Regulations (CFR) 50.55a(z), Alternatives to codes and standards requirements, for FENOCs failure to obtain prior authorization for implementing an alternative to the American Society of Mechanical Engineers Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code). Specifically, until prompted by the inspectors, FENOC did not submit to the NRC and receive an alternative to the ASME OM Code requirement to not test the residual heat removal (RHR) relief valve, RV-1RH-721, during a recent refueling outage for Unit 1 when the charging system letdown relief valve, RV-1CH-203, failed to lift within three percent of set-pressure. FENOCs immediate corrective actions included performing a prompt operability determination, submitting a relief request, and entering the issue into the corrective action program (CAP) as condition report (CR) 2017-03937. The inspectors determined that this violation impacted the ability of the NRC to perform its regulatory oversight function, and was therefore subject to traditional enforcement. Section 2.2.1.c of the Enforcement Policy states that failure to receive prior NRC approval for changes in licensed activities when required is an example of impacting the ability of the NRC to perform its regulatory oversight function. After considering the factors in Section 2.2.1.c of the Enforcement Policy, the inspectors determined that the performance deficiency was a Severity Level IV violation because the change implemented by FENOC would likely be approved by the NRC. Because this violation involves the traditional enforcement process and does not have an associated finding that is more than minor, the inspectors did not assign a cross-cutting aspect to this violation in accordance with IMC 0612, Appendix B.
05000334/FIN-2016004-012016Q4Beaver ValleyFailure to Follow Procedure Results in an Inoperable A River Water TrainA self-revealing NCV of Title 10 of the Code of Federal Regulations (CFR) 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified for FENOCs failure to assure that activities affecting quality were accomplished in accordance with procedures. Specifically, FENOC failed to follow NOP-OP-1001, Clearance/Tagging Program, and clearance 1W11-30-MNM-002 when removing the clearance for the A bay of the main intake structure. This resulted in disabling the automatic start capability of the standby C river water pump and made the A river water train inoperable and unavailable. FENOCs immediate corrective action was to rack the breaker for the A river water pump to the disconnect position, which cleared the annunciator and restored operability to the A train of river water. FENOC entered this issue into their corrective action program (CAP) as condition report (CR) 2016-14253. The performance deficiency is more-than-minor because it is 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, FENOC incorrectly racked the A river water pump breaker onto the 1AE 4160 volts alternating current (VAC) safety bus while the C river water pump was already racked onto the bus. This caused the A train of river water to be inoperable and unavailable because the automatic start capability of the C pump was disabled. The inspectors determined that this finding was of very low safety significance (Green) because it did not represent a loss of system and/or function, an actual loss of function of a single train for greater than its technical specification allowed outage time, or an actual loss of function of one non-technical specification train designated as high safety significance. This finding has a cross-cutting aspect in Human Performance, Avoid Complacency, because the operators did not plan for the possibility of mistakes and did not implement appropriate error-reduction tools (H.12).
05000334/FIN-2016004-022016Q4Beaver ValleyLicensee-Identified ViolationThe following licensee-identified violation of NRC requirements was determined to be of very low safety significance and meets the NRC Enforcement Policy criteria for being dispositioned as a NCV. Radioactive material shipment B-4655, was made from Beaver Valley on May 5, 2016, to ResinSolutions in Erwin, TN. During a self-assessment performed by the FENOC staff on November 3, 2016, it was identified that the scaling factors used to determine the hard-to-detect nuclides listed on the manifest (NRC Form 540) for shipment B-4655 were incorrect. The scaling factors used to manifest the shipment were not for the waste stream shipped. Recalculation of the isotopic values using the correct waste stream scaling factors resulted in different numeric values for multiple radionuclides in the shipment, but did not cause a change in the proper shipping name, packaging, or labeling. 10 CFR 71.5 requires, in part, that radioactive materials be transported with an accurate shipment manifest. Contrary to the above, on May 5, 2016, FENOC transported radioactive materials with a shipment manifest that incorrectly stated that the radiological activity of the package was higher than the actual activity. FENOC documented this issue in CR 2016-13071, and provided a corrected shipment manifest to the recipient of the material. In accordance with IMC 0609, Appendix D, "Public Radiation Safety Significance Determination Process," the finding was determined to be of very low safety significance (Green) because FENOC had an issue involving transportation of radioactive material, but it did not involve a radiation limit that was exceeded, a breach of package during transport, a certificate of compliance issue, a low level burial ground nonconformance, or a failure to make notifications or provide emergency information.
05000334/FIN-2016003-012016Q3Beaver ValleyFailure to Identify Conditions Adverse to Quality Leads to Inoperable Emergency Bus Degraded Voltage RelaysThe inspectors identified an NCV of Title 10 Code of Federal Regulations (CFR) 50, Appendix B, Criterion XVI, Corrective Action, for FENOCs failure to assure that a condition adverse to quality was promptly identified and corrected. Specifically, FENOC failed to promptly identify and correct a negative trend in setpoint drift and as found dropout voltage values in the AB 27N model 411T6375HF 4160 volts alternating current (VAC) and 480 VAC emergency bus degraded voltage relays. FENOCs immediate corrective actions included recalibrating or replacing the relays and entering the issue into their corrective action program (CAP) as condition report (CR) 2016-12018. The performance deficiency is more than minor because it is associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, FENOCs failure to promptly identify and address a negative trend in dropout voltage setpoint drift and as found values resulted in the reduced reliability of safety related bus degraded voltage relays (seven surveillance failures and inoperable degraded bus relays between 2011 and 2016). Inoperable emergency bus degraded voltage relays could lead to damage of safetyrelated equipment during a loss of offsite power. This finding is of very low safety significance (Green) because it does not represent a loss of system and/or function, an actual loss of function of a single train for greater than its technical specification allowed outage time, an actual loss of function of one non-technical specification trains designated as high safety significant, and did not involve a loss or degradation of equipment designed to mitigate a seismic, flooding, or severe weather initiating event. The finding has a crosscutting aspect in the area of Problem Identification and Resolution, Trending, because FENOC did not periodically analyze the results of the degraded voltage relay surveillances to provide early indication of a declining trend (P.4).
05000334/FIN-2016002-012016Q2Beaver ValleyProcedure Change Results in Failure to Maintain the Design Basis for the Service Water SystemThe inspectors identified an NCV of Title 10 of the Code of Federal Regulations (CFR) 50, Appendix B, Criterion III, Design Control, for FENOCs failure to assure that the regulatory requirements and design basis for the Unit 2 service water system were correctly translated into procedures. Specifically, FENOC implemented a procedure revision in 2002 that inappropriately removed the step to declare the Unit 2 service water system inoperable while the non-seismic standby service water system is aligned to it. FENOCs immediate corrective actions included issuing instructions that prohibit planned testing of or swapping to the standby service water system and revising procedure 2OST-30.1A. FENOC entered the issue into their CAP as condition report (CR) 2016-01710. The performance deficiency is more-than-minor because it is associated with the Design Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, FENOCs revision to 2OST-30.1A in 2002 resulted in reduced reliability of the service water system while connected to the standby service water system for over ten hours on February 1, 2016, and nine hours on April 3, 2014. This finding was of very low safety significance (Green) because it did not represent a loss of system and/or function, an actual loss of function of a single train for greater than its technical specification allowed outage time, an actual loss of function of one non-technical specification trains designated as high safety significant, and did not involve a loss or degradation of equipment designed to mitigate a seismic, flooding, or severe weather initiating event. This finding does not have a cross-cutting aspect because it is not representative of current performance. The inadequate review of revision 17 to 2OST-30.1A was an isolated instance that occurred over 14 years ago. Furthermore, the most recent NRC inspection of Changes, Tests, or Experiments and Permanent Plant Modifications, performed in 2013, and the Component Design Basis Inspection, performed in 2014 did not document any findings related to procedure changes. (Section 1R15)
05000334/FIN-2016002-032016Q2Beaver ValleyFailure to Appropriately Utilize Multiple and Diverse Indications Results in Plant TransientA self-revealing finding of NOP-OP-1002, Conduct of Operations, was identified for FENOCs failure to adequately implement operator fundamentals. Specifically, operators did not appropriately utilize multiple and diverse indications when making the decision to isolate electro-hydraulic control (EHC) to a Unit 1 main turbine governor valve. This resulted in an unanticipated reactor power reduction of 2.7 percent. FENOCs immediate corrective actions included re-opening the governor valve, verifying proper system response, and entering this issue into their corrective action program (CAP) as CR 2015-08263. The performance deficiency is more-than-minor because if left uncorrected, the performance deficiency had the potential to lead to a more significant safety concern. Additionally, example 4.b from IMC 0612 Appendix E details that a performance deficiency is more-than minor if it causes a reactor trip or other transient. This finding was determined to be of very low safety significance (Green) since it did not cause both a reactor trip and the loss of mitigation equipment relied upon to transition the plant to a stable shutdown condition. This finding has a cross-cutting aspect in Human Performance, Challenge the Unknown, because individuals did not consult the system expert when confronted with an unexpected condition (H.11).
05000412/FIN-2016002-022016Q2Beaver ValleyInadequate Compensatory Measures to Ensure the Effectiveness of an EALThe inspectors identified an NCV of 10 CFR 50.54(q)(2) for FENOCs failure to follow and maintain the effectiveness of an emergency plan that meets the planning standards of 10 CFR 50.47(b)(4). Specifically, following the failure of the area radiation monitor (ARM) for the Unit 2 primary auxiliary building 773 elevation on April 23, 2016, FENOC did not establish adequate compensatory measures to ensure the effectiveness of the emergency action level (EAL) for loss of control of radioactive material, RU2. FENOCs immediate corrective actions included establishing appropriate compensatory measures for RU2, communicating the standards of EAL compensatory measures to radiation protection technicians verbally and via narrative logs, and entering this issue into their CAP as CR 2016-05975. The performance deficiency is more-than-minor because it is associated with the Facilities and Equipment attribute of the Emergency Preparedness cornerstone, and adversely affected the cornerstone objective to ensure that FENOC is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, FENOCs failure to establish adequate compensatory measures for an out-of-service ARM could have resulted in exceeding a NOUE EAL threshold for a loss of control of radioactive material without the condition being recognized until further degradation in the level of plant safety occurs. This finding was determined to be of very low safety significance (Green) since it was example of an ineffective EAL, such that a notification of unusual event (NOUE) would not be declared or would be declared in a degraded manner. This finding has a cross-cutting aspect in Human Performance, Documentation, because FENOC did not ensure that plant activities are governed by comprehensive procedures (H.7).
05000334/FIN-2016001-012016Q1Beaver ValleyFailure to Properly Evaluate Control Room Envelope Test ResultsThe inspectors identified an NCV of Title 10 of the Code of Federal Regulations (CFR), Part 50, Appendix B, Criterion XI, Test Control, for FENOCs failure to properly evaluate the test results of the Control Room Envelope (CRE) unfiltered air in-leakage test performed in December 2015. Specifically, the test results exceeded the acceptance criteria specified in the test procedure and required further engineering evaluation to determine if the control room emergency ventilation system (CREVS) could meet its specified safety function. The inspectors identified that the engineering evaluation of the test results did not account for all of the in-leakage and resulted in a reasonable doubt of operability of CREVS. FENOCs immediate corrective action was to re-evaluate the December 2015 calculation and verify that CREVS remained operable with the increased in-leakage. FENOC entered the issue into their corrective action program, condition report (CR) 2016-03836. The performance deficiency is more-than-minor because it is associated with the human performance attribute of the Barrier Integrity cornerstone, and adversely affected the cornerstone objective of providing reasonable assurance that physical design barriers protect from radionuclide releases caused by accidents or events. Specifically, FENOCs evaluation did not account for in-leakage from the non-tested portions of the control room radiological barrier, and therefore, did not provide reasonable assurance that the control room dose would not exceed five rem during an uncontrolled release of radioactivity. Additionally, this issue is similar to example 3j and 3k of IMC 0612 Appendix E, Examples of Minor Issues, in that FENOCs December 2015 engineering evaluation failed to adequately account for CRE in-leakage and resulted in a reasonable doubt of the operability of CREVS. The inspectors determined that this finding was of very low safety significance (Green) because it only represented a degradation of the radiological barrier function provided for the control room. This finding has a cross-cutting aspect in the area of Human Performance, Conservative Bias, because FENOC did not take a conservative approach to decision making, particularly when the in-leakage information was incomplete (H.14).
05000289/FIN-2015004-012015Q4Three Mile IslandFailure to Trend Vibration Data for Safety Related River Water PumpThe inspectors identified a finding of very low safety significance involving an NCV of 10 Code of Federal Regulations (CFR) 50, Appendix B Criterion XVI, Corrective Action Program, because Exelon did not identify and correct a condition adverse to quality on the B nuclear river water pump (NR-P-1B). Specifically, Exelon did not properly evaluate an adverse vibration trend on NR-P-1B, which resulted in exceeding its in-service test (IST) required action level and declared inoperable on October 10, 2015. Exelon entered the condition into their corrective action program (CAP) as issue report 2568763 and emergently replaced the pump, engaged the vendor for short and long term design and material changes to correct the vibration, and created process and peer check corrective actions to ensure all vibration data is reviewed timely and trends are addressed commensurate with their safety significance. The performance deficiency is more than minor because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the elevated vibrations reduced the reliability and capability of NR-P-1B to perform its safety function. The inspectors evaluated the finding using IMC 0609, Attachment 4, Initial Characterization of Findings, and Appendix A, The Significance Determination Process for Findings At-Power, Exhibit 2, and determined this finding to be of very low safety significance (Green) because the degraded condition was not a design deficiency that affected system operability; did not represent an actual loss of function of a system; did not represent an actual loss of function of a single train or two separate trains for greater than its technical specification (TS) allowed outage time and did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety significant. The finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Evaluation, because the station did not thoroughly evaluate the elevated vibration data such that the issue was addressed before NR-P-1B became inoperable (P.2).
05000334/FIN-2015004-012015Q4Beaver ValleyInadequate Maintenance Rule Monitoring of the Auxiliary Feedwater SystemThe inspectors identified an NCV of Title 10 of the Code of Federal Regulations (CFR) 50.65, Requirements for monitoring the effectiveness of maintenance at nuclear power plants, for FENOCs failure to monitor the performance of the Unit 1 auxiliary feedwater (AFW) system against licensee-established goals. Specifically, FENOC did not identify and properly account for a maintenance preventable functional failure (MPFF) of the turbine driven auxiliary feedwater (TDAFW) pump, which demonstrated that performance of the Unit 1 AFW system was not being effectively controlled through appropriate preventive maintenance. FENOCs immediate corrective actions included entering this issue into their corrective action program, re-evaluating and classifying the TDAFW pump failure as a MPFF, performing a 10 CFR 50.65 (a)(1) evaluation of the Unit 1 AFW system, and placing the system in (a)(1) status. The performance deficiency was determined to be more-than-minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone, and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Additionally, example 7.d from IMC 0612 Appendix E details that a performance deficiency is more than minor if equipment performance problems were such that effective control of performance through appropriate preventive maintenance under (a)(2) could not be demonstrated. This finding was determined to be of very low safety significance (Green) since it was not a deficiency affecting the design or qualification of a mitigating structure, system, or component (SSC), it did not represent the loss of a system and/or function, it did not represent an actual loss of function of at least a single train or two separate safety systems out-of-service for greater than its technical specifications allowed outage time, and it did not represent an actual loss of a non-technical specification equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hours. This finding has a cross-cutting aspect in Human Performance, Avoid Complacency, because FENOC failed to consider the extent of condition and their causes following the failure of the Unit 1 TDAFW pump on January 6, 2014 (H.12).
05000334/FIN-2015003-012015Q3Beaver ValleyFailure to Correct a Low Oil Level in the Condensate Pump MotorA self-revealing finding was identified for FENOCs failure to correct a low oil level in the lower motor bearing of the Unit 1 A condensate pump in accordance with NOP-LP- 2001, Corrective Action Program. Specifically, FENOC incorrectly cancelled the work order to add oil to the A condensate pump motor and installed a placard on the oil level sight glass with incorrect minimum and maximum oil levels. This led to the motor bearing failure, which caused the pump to trip on overcurrent, and required the operators to insert a manual reactor trip. FENOC entered the issue into their correct action program, condition report (CR) 2015-05256. The performance deficiency was more-than-minor because it was associated with the human performance attribute of the Initiating Events cornerstone, and adversely affected the cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, NOP-LP-2001, section 4.2.3, states that condition report/correct action owners should ensure that actions are developed to resolve the primary cause identified in the condition report. Instead of correcting the low oil level in the motor, FENOC cancelled the work order to add oil. This subsequently caused the operators to trip the plant when the condensate pump motor bearing overheated and the motor tripped on overcurrent. The inspectors determined that this finding was of very low safety significance (Green) because it did not cause a reactor trip and the loss of mitigation equipment. This finding has a crosscutting aspect in the area of Human Performance, Consistent Process, because FENOC did not seek input from the appropriate work group (engineering) prior to cancelling the work order to add oil to the condensate pump motor (H.13)
05000334/FIN-2015002-012015Q2Beaver ValleyFailure to Utilize Respiratory Protection as Specified by the Radiation Work PermiThe inspectors identified a self-revealing NCV of Technical Specification 5.4.1, Procedures, for FENOCs failure to utilize respiratory protection, as required by the applicable radiation work permit (RWP), for entry into the 722-foot elevation of the solid radioactive waste building on March 12, 2014. This resulted in the unplanned internal exposure of one worker. Immediate corrective actions included reestablishing RWP controls of the area and entering this issue into their corrective action program as condition report 2015-06636. The inspectors determined that the performance deficiency is more than minor because it affected the Program and Process attribute of the Occupational Radiation Safety cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. The inspectors evaluated the finding using NRC Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, and determined the finding to be of very low safety significance (Green) because it was not related to as low as (is) reasonably achievable (ALARA), did not result in an overexposure or a substantial potential for overexposure, and did not compromise the licensee's ability to assess dose. The finding has a cross-cutting aspect of Human Performance, Conservative Bias, in that individuals did not use decision making-practices that emphasized prudent choices over those that are simply allowable. Specifically, a radiation protection technician did not use conservative decision making practices and make prudent choices when entering an area with unknown radiological conditions. Examples of non-conservative decision making included: failure to wear respiratory protection when entering into unknown radiological conditions, the failure to complete and evaluate an air sample prior to entry, and not taking into account the adverse radiological conditions of the adjoining area above (735 foot elevation). (H.14)
05000412/FIN-2015002-022015Q2Beaver ValleyFailure to Perform Maintenance in accordance with Licensee Maintenance ProcessA self-revealing finding was identified for FENOCs failure to perform maintenance on the Unit 2 feedwater heater drain system in accordance with FENOCs maintenance process, NOP-WM-4006, Conduct of Maintenance. Specifically, FENOC did not adjust the A first point feedwater heater normal and high level control valve (LCV) controllers to their specified setpoints. As a result, the A heater and separator drain pumps tripped and this led to an unplanned power reduction from 100 percent to 60 percent reactor power on April 12, 2015. FENOCs corrective action included adjusting the setpoints of the LCV controllers to their specified setpoints and entering the issue into their corrective action program as condition report 2015-05088. The performance deficiency was more-than-minor because it was associated with the Configuration Control attribute of the Initiating Events cornerstone, and adversely affected the cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Additionally, the performance deficiency was similar to example 4.b in IMC 0612 Appendix E, in that failing to follow procedure caused a reactor transient. This finding was determined to be of very low safety significance (Green) because it did not cause a reactor trip and the loss of mitigation equipment. This finding has a cross-cutting aspect in the area of Human Performance, Training, because FENOC failed to ensure knowledge transfer to maintain a knowledgeable, technically competent workforce and instill nuclear safety values. Specifically, FENOC did not ensure that knowledge was adequate to perform maintenance on the A first point feedwater heater LCVs (H.9).
05000334/FIN-2014005-012014Q4Beaver ValleyFailure to Adequately Implement Risk Management ActionsThe inspectors identified an NCV of 10 CFR 50.65(a)(4), Requirements for monitoring the effectiveness of maintenance at nuclear power plants, for FENOCs failure to implement adequate risk management actions (RMAs) associated with maintenance on the alternate intake structure A bay. Specifically, FENOC did not establish a contingency plan for the maintenance activity as required by FENOCs risk management procedure. FENOC entered the issue into their corrective action program as CR 2015-00267. The performance deficiency is more than minor because it is associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected its objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, FENOCs failure to implement a contingency plan resulted in an increase in the duration of an elevated risk condition and unavailability of equipment relied upon to mitigate the consequences of a loss of the main intake structure. The finding was determined to be of very low safety significance (Green) because the incremental core damage probability (ICDP) for the event was less than 1.0 E-6. The inspectors determined that this finding had a cross-cutting aspect in the Human Performance, Work Management, because the FENOC work process failed to adequately manage the risk commensurate to the work (H.5).
05000334/FIN-2014005-022014Q4Beaver ValleyFailure to Properly Ship Category 2 Radioactive MaterialThe inspectors identified an NCV of 10 CFR 71.5, Transportation of licensed material, and 49 CFR 172, Subpart I, Safety and Security Plans. Specifically, FENOC personnel shipped a category 2 radioactive material of concern (RAM-QC) on public highways to a waste processor without adhering to a transportation security plan. FENOCs corrective actions included revising procedure NOP-OP-5201, Shipment of Radioactive Material Waste, to reflect the appropriate Department of Transportation requirements for shipment of Category 2 radioactive material. FENOC entered the issue into their corrective action program as CR 2014-17260. The issue is more than minor because it is associated with the Program and Process attribute of the Public Radiation Safety cornerstone and adversely affected its objective to ensure the safe transport of radioactive material on public highways in accordance with regulations. The finding was determined to be of very low safety significance (Green) because FENOC had an issue involving transportation of radioactive material, but it did not involve: (1) a radiation limit that was exceeded; (2) a breach of package during transport; (3) a certificate of compliance issue; (4) a low level burial ground nonconformance; or (5) a failure to make notifications or provide emergency information. The inspectors determined that the finding did not have a cross-cutting aspect because the issue was not reflective of current plant performance. Specifically, FENOC implemented changes to the radioactive waste shipment procedure that addressed applicable requirements and implemented a formal process for reviewing pending regulatory changes for impacts to FENOC operations and support activities.
05000412/FIN-2014004-012014Q3Beaver ValleyInadequate Plant Startup Procedure Led to Manual Reactor TripA self-revealing NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings was identified for FENOCs failure to have an adequate plant startup procedure. Specifically, 2OM-52.4A, Raising Power from 5% to Full Load Operation, did not adequately address plant startup with one condensate pump in operation. This led to an inability to adequately control steam generator (SG) level when the second condensate pump was started which required the operators to trip the reactor. FENOC is in the process of implementing corrective actions to revise procedure 2OM-52.4A and to address the human performance errors associated with this event. Additionally, FENOC entered the issue into their corrective action program as condition report (CR) 2014-09256. The finding is more than minor because it is associated with the procedure quality and human performance attributes of the Initiating Events cornerstone and affected the cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the inadequate procedure led to SG level fluctuations that could not be adequately controlled when the second condensate pump was started, and required the operators to trip the reactor. The inspectors determined that this finding is of very low safety significance (Green), because while it did result in a reactor trip, it did not cause a loss of mitigation equipment relied upon to transition the plant from the onset of a trip to a stable shutdown condition. The finding has a cross-cutting aspect in Human Performance, Challenge the Unknown, because FENOC operators did not stop when faced with uncertain conditions. Specifically, the adequacy of the procedure was not sufficiently questioned when the plant was not in the normal start up configuration of two running condensate pumps nor later when the condensate pump discharge header pressure low alarm occurred.
05000336/FIN-2014003-032014Q2MillstoneFailure to Adequately Maintain EALsThe inspectors identified a Green NCV associated with emergency preparedness planning standard Title 10 of the Code of Federal Regulations (10 CFR) 50.47(b)(4) and the requirements of Sections IV.B and IV.C of Appendix E to 10 CFR 50. Specifically, Dominion did not maintain the Millstone Units 2 and 3 emergency action level (EAL) schemes for assessing a loss of forced flow cooling during refueling operations. Dominion entered this issue into the CAP and implemented temporary corrective actions which included procedure changes to direct operators to the shutdown safety assessment checklists to determine representative reactor coolant system (RCS) temperature increases in order to assess the initiating conditions (ICs) for this situation. The inspectors determined that the failure by Dominion to provide site specific criteria for operators to adequately implement the EALs for a loss of forced flow cooling during refueling was a performance deficiency that was reasonably within their ability to foresee and prevent. The finding is more than minor because it is associated with the Procedure Quality attribute of the Emergency Planning Cornerstone and affected the cornerstone objective to ensure that Dominion is capable of implementing 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, the inspectors determined that this finding is of very low safety significance (Green) because the performance deficiency was an issue where two EAL ICs had been rendered ineffective such that an Unusual Event and an Alert would not be declared, or declared in a degraded manner for a loss of forced flow cooling during refueling. The finding has a cross-cutting aspect in the area of Problem Identification and Resolution, in that Dominion did not implement a CAP with a low threshold for identifying issues. Dominions self-assessment for two previous NCVs regarding EAL deficiencies failed to identify the lack of specific criteria to assess the ICs for EALs EU1.2 and EA2.1 for a loss of forced cooling flow during refueling.
05000336/FIN-2014003-012014Q2MillstoneFailure to Maintain Adequate Procedure For RCS Drain/FillThe inspectors identified a Green NCV of TS 6.8.1, Procedures, for Dominions failure to maintain an adequate procedure for reactor filling and draining that incorporates guidance contained in NRC Generic Letter 88-17. Specifically, OP2301E, Draining the RCS, permitted operation in a reduced RCS inventory condition without ensuring redundant means of level indication contrary to the inventory control requirements of OU-M2-201, Shutdown Safety Assessment Checklist. The failure to maintain an adequate procedure for operating in reduced inventory conditions is a performance deficiency. The inspectors determined this performance deficiency is more than minor because it is associated with the Initiating Events cornerstone attribute of equipment performance and affects the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown operations. Specifically, inadequate procedural guidance increased the likelihood that operators could experience a loss of level indication during the reduced inventory condition. The inspectors evaluated the significance of the finding using IMC 0609 Appendix G, Shutdown Operations Significance Determination Process, Attachment 1, Shutdown Operations Significance Determination Process Phase 1 Initial Screening and Characterization of Findings, and the issue screened to a Phase 2 analysis. Using the guidance contained in IMC 0609, Appendix G, Attachment 2, Phase 2 Significance Determination Process Template for PWR During Shutdown, the inspectors worked with regional and headquarters senior reactor analysts to determine the issue screened to Green. The inspectors determined this issue had a cross-cutting aspect in the area of Human Performance, Avoid Complacency, where individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Specifically, the latent error of considering L-112 and LI-112 as independent level instruments even though a single failure impacted both instruments contributed to the issue.
05000336/FIN-2014003-022014Q2MillstoneFailure to Utilize Respiratory Protection as Specified in Work Control DocumentsA self-revealing Green NCV of Technical Specification (TS) 6.8.1; Regulatory Guide 1.33, Appendix A; Radiation Work Permits (RWP); and as low as reasonably achievable (ALARA) procedures was identified for Dominions failure to utilize respiratory protection, as required by the applicable RWP and associated ALARA evaluation for work on replacement of valve 2-SI-227 on April 20, 2014. This failure resulted in an unplanned intake of radioactive material for one worker. Dominion subsequently enforced the respiratory protection requirements to complete the work and entered this issue into their corrective action program (CAP) as condition report (CR) 546439. Failure to use respiratory protection during machining work as required by Dominion procedure was a performance deficiency that was reasonably within Dominions ability to foresee and correct. The inspectors determined that the performance deficiency was more than minor because it affected the Radiation Safety Occupational Radiation Safety Cornerstone attribute of Program and Process associated with exposure/contamination controls, because it resulted in the unintended internal exposure of a worker. A crosscutting aspect of Human Performance, Conservative Bias, was associated with the finding. Specifically, radiation protection staff did not adhere to the RWP requirements.
05000334/FIN-2014003-022014Q2Beaver ValleyRemoval of Missile Barrier Renders Containment InoperableThe inspectors identified a Green non-cited violation of TS limiting condition for operation (LCO) 3.6.1, Containment. Specifically, the inspectors determined that FENOC removed the missile barriers for the unit 1 and unit 2 containment equipment hatches while in a mode when containment was required to be operable. As a result FENOC did not have adequate tornado protection for containment and then did not take the actions directed by the LCO action statement when the LCO was not met. FENOC entered the issue into their corrective action program, CR 2014-11878, and placed the procedures to remove the missile barriers on administrative hold. The performance deficiency is more than minor because it adversely affected the configuration control attribute of the Barrier Integrity Cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. In accordance with IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 3, Barrier Integrity Screening Questions, this finding screens to Green, very low safety significance. This finding has a cross-cutting aspect in the area of conservative bias where individuals use decision making-practices that emphasize prudent choices over those that are simply allowable and that a proposed action is determined to be safe in order to proceed, rather than unsafe in order to stop. Specifically, FENOC did not adequately consider the containment operability implications of removing the missile barriers for the unit 1 and unit 2 containment equipment hatches while in a mode where containment is required to be operable. (H14)
05000412/FIN-2014003-012014Q2Beaver ValleyFailure to Follow Procedure Results in Inoperable SI AccumulatorA self-revealing NCV of technical specification (TS) 5.4.1 was identified because the unit 2 B safety injection (SI) accumulator was made inoperable when FENOC operators did not follow procedural requirements to align nitrogen to the accumulator. Specifically, the operators did not align the nitrogen header to the accumulator prior to opening the valve to repressurize the accumulator. The inspectors noted that this resulted in the accumulator pressure falling below the TS pressure limit which required FENOC to declare the accumulator inoperable. FENOCs corrective actions included immediately realigning the system, restoring accumulator pressure and entering the issue into their corrective action program, CR 2014-09260. The performance deficiency is more than minor because it is associated with the configuration control 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, FENOC did not have reasonable assurance that the nitrogen pressure in the B SI accumulator was sufficient to ensure injection into the core during an accident due to the misalignment of the nitrogen header. This finding is of very low safety significance (Green) because the performance deficiency was not a design or qualification deficiency, did not involve an actual loss of safety function, did not represent actual loss of a safety function of a single train for greater than its technical specification allowed outage time, and did not screen as potentially risk-significant due to a seismic, flooding, or severe weather initiating event. This finding has a cross-cutting aspect in the area of Human Performance, Avoid Complacency, because FENOC operators did not recognize the possibility of mistakes and did not implement appropriate error reduction tools while attempting to re-pressurize the B SI accumulator. (H.12)
05000334/FIN-2014003-032014Q2Beaver ValleyLicensee-Identified ViolationTechnical Specification 5.7.2, High Radiation Area, requires, in part, that locked doors be provided for each high radiation area in which the intensity of radiation exceeds 1000 millirem per hour. Contrary to the above, on April 26, 2014, for approximately 2.5 hours, the door to the Regenerative Heat Exchanger room was not locked. FENOCs immediate corrective action included placing chains and padlocks on this door and all similar style entrances to locked high radiation areas, entering this issue into their corrective action program (CR-2014-07646), and performing a root cause evaluation. The finding is of very low safety significance, Green, because it did not involve ALARA, there was no overexposure, there was no substantial potential for an overexposure, and the ability to assess dose was not compromised.
05000423/FIN-2014002-012014Q1MillstoneFailure to Evaluate Test Results Outside of Acceptance Criteria For A Service Water PumpThe inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50, Appendix B, Criterion XI, Test Control, because Dominion did not properly evaluate test results outside of the acceptance criteria for the Unit 3 A service water (SW) pump. Specifically, on February 23, when the A SW pump did not meet its acceptance criteria for running amps, Dominion did not fully evaluate pump operability under all conditions. Dominions immediate corrective actions included entering the issue into their corrective action program (CAP) and placing the pump in pull to lock status until the issue could be resolved. The inspectors determined that Dominions failure to properly evaluate test results outside of the acceptance criteria for the A SW pump in accordance with the requirements of 10 CFR 50, Appendix B, Criterion XI, to assure that test requirements have been satisfied was a performance deficiency that was within Dominions ability to foresee and correct, and should have been prevented. This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, without proper evaluation of the test results, Dominion kept a component in service that was later determined to be non-functional. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) because the performance deficiency was not a design or qualification deficiency, did not involve an actual loss of safety function, did not represent actual loss of a safety function of a single train for greater than its technical specification (TS) allowed outage time, and did not screen as potentially risk-significant due to a seismic, flooding, or severe weather initiating event, and did not represent an actual loss of function of a non-TS train of equipment designated as high safety significant. This finding has a cross-cutting aspect in the area of Human Performance, Design Margins, in that Dominion did not operate and maintain the pump within design margins, where margins are carefully guarded and changed only through a systematic and rigorous process.
05000289/FIN-2014002-012014Q1Three Mile IslandFailure to Perform a 10 CFR 50.59 Evaluation for the BWST Seismic QualificationsThe inspectors identified a Severity Level IV (SL-IV), Non-Cited Violation of 10 CFR 50.59, Changes, Tests, and Experiments, and an associated finding of very low safety significance (Green) for Exelons failure to perform a 50.59 evaluation review to determine whether a license amendment was required to align the borated water storage tank (BWST) to non-seismic piping. Specifically, Exelon staffs 50.59 screening accepted the alignment of the seismically qualified BWST to a non-seismically qualified clean-up system. The inspectors determined the alignment would involve a change to the BWST that adversely affects its Updated Final Safety Analysis Report chapter 5.1.1, Classes of Structures and Systems for Seismic Design, described design function of being seismically qualified. Additionally, the inspectors determined that following the 50.59 review Exelon placed the line-up in service. The inspectors determined these two actions were performance deficiencies that were reasonably within Exelons ability to foresee and prevent. Furthermore, the 50.59 screening credited unapproved operator manual actions to ensure functionality of the BWST. Exelon documented this as issue report 1631468 and implemented interim corrective actions to isolate the BWST from the clean-up system until a permanent resolution is determined and implemented. The inspectors determined the 50.59 violation regarding the failure to perform an evaluation was more than minor because the inspectors could not reasonably determine that the alignment would not have ultimately required NRC prior approval, because the BWST alignment was not in accordance with the current licensing basis and the evaluation credited the use of unapproved operator manual actions. The inspectors also determined that the performance deficiency of accepting and aligning the adverse clean-up line-up, challenging the BWST seismic qualification, was more than minor because it adversely affected the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors evaluated the finding using IMC 0609, Attachment 4, Initial Characterization of Findings, and Appendix A, The Significance Determination Process for Findings At-Power, and determined that this finding required a detailed risk evaluation. The detailed evaluation was performed which determined that the performance deficiency was a finding of very low safety significance (Green). Additionally, In accordance with Section 6.1.d.2 of the NRC Enforcement Policy, the 50.59 violation is categorized as a Severity Level IV. This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Operating Experience, in that the station did not effectively evaluate and internalize relevant external operating experience (Information Notice (IN) 2012-01) regarding connections between safety-related seismic and non-seismic qualified piping and components.
05000423/FIN-2014002-022014Q1MillstoneNOED Granted by NRC for TDAFW Pump Repairs on January 26, 2014The NRC identified an unresolved item (URI) for Dominions request for enforcement discretion from TS 3.7.1.2(a) limiting condition of operation (LCO) action statement (C) on January 26, 2014, in accordance with IMC 0410, Notices of Enforcement Discretion. Following an overspeed trip of the Unit 3 TDAFW pump during a scheduled surveillance test, Dominions efforts to complete troubleshooting, repairs and retesting could not be completed in time to comply with TS 3.7.1.2(a) action (C), which allowed up to 72 hours to complete repairs before a plant shutdown was required. Dominion requested additional time to complete the repairs without having to shutdown Unit 3, and the NRC granted a NOED that extended the allowable outage time for an additional 48 hours. On January 23, 2014, the Unit 3 TDAFW pump failed a required surveillance test. During the starting sequence, the pump tripped on overspeed due to mechanical binding in the turbine governor linkage. Dominion entered TS LCO 3.7.1.2(a) action (C) which provided up to 72 hours to repair the failed pump before requiring Unit 3 to be shutdown to Mode 3. Troubleshooting efforts revealed that the mechanical linkage between the governor and the turbine control valve (3MSS*MCV5) was binding due to a degraded cam follower bearing and a mechanical link that had been installed incorrectly. Although repairs had been completed, it became apparent that the required post-maintenance tests, including a full flow test at full power, could not be completed prior to the expiration of the LCO on January 26, 2014. Dominion requested enforcement discretion from compliance with TS 3.7.1.2 for a period of 72 hours. The NRC reviewed the request in accordance with IMC 0410, NOED, and granted a one-time 48 hour extension to required action (C) of TS LCO 3.7.1.2(a). Dominion completed the post-maintenance testing and restored the TDAFW pump to an operable status within the additional time granted. The NOED specified a list of prerequisites and compensatory actions to mitigate risk that were required to be verified and completed prior to the 48 hour extension becoming effective. Closure of this URI will require review and verification of Dominions satisfactory completion of the specified requirements in the NOED in coordination with the Special Inspection Team that is inspecting Dominions performance during this event.
05000336/FIN-2013005-022013Q4MillstoneInadequate Alternative Shutdown ProcedureThe inspectors identified an NCV of Millstone Unit 2 Operating License Condition 2.C. (3) for failure to implement and maintain all aspects of the approved Fire Protection Program (FPP). Specifically, Dominion had not adequately implemented an alternative shutdown procedure, as required by 10 CFR 50, Appendix R, Section III.L.3 and the approved FPP. The procedure for a Unit 2 fire, which could lead to control room abandonment, did not ensure the electrical distribution system was correctly configured prior to re-energizing alternating current (AC) buses. As a result, an over-current condition could occur and trip the 4 kilovolt (kV) supply breaker complicating safe shutdown operations and delaying AC bus recovery. In response to this issue, Dominion promptly revised their fire safe shutdown operating procedure prior to the end of the inspection to correct this deficiency. This finding was more than minor because it was associated with the protection against external factors (e.g., fire) attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability and reliability of systems that respond to initiating events to prevent undesirable consequences. The inspectors evaluated the finding in accordance with IMC 0609, Appendix F, Fire Protection SDP. This finding affected the post-fire safe shutdown category and was determined to have a high degradation rating because the alternative shutdown procedure lacked adequate instructions to ensure correct equipment alignment. A Phase 3 SDP analysis determined that this finding was of very low safety significance (Green) because the best estimate of core damage frequency (? CDF) was in the mid E-7 per year range. This finding did not have a cross-cutting aspect because it was considered to not be indicative of current licensee performance.
05000423/FIN-2013005-032013Q4MillstoneInadequate Operability Determination for TDAFW Pump Overspeed TripThe inspectors identified a Green Finding (FIN) for the failure to follow Dominion Procedure OP-AA-102, Operability Determinations, and establish adequate compensatory measures to restore reliability to the Unit 3 Turbine Driven Auxiliary Feedwater (TDAFW) Pump following overspeed trips on November 4 and December 18, 2013. The inspectors determined that the performance deficiency was within Dominions ability to foresee and correct. Dominion entered this issue into their corrective action program (CAP) (CR531536, CR532536 and CR535411), established additional compensatory measures to address degraded pump reliability, and scheduled additional maintenance activities to more thoroughly investigate the cause of the overspeed trips. The inspectors determined the performance deficiency was more than minor because it affected the equipment performance attribute of the mitigating systems cornerstone to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Failure to adequately establish effective compensatory measures resulted in a decrease in the reliability of the auxiliary feedwater (AFW) system to mitigate events. The inspectors determined that, after further compensatory measures were established, the TDAFW pump maintained its operability, the AFW system maintained all safety functions, and the finding was of very low safety significance (Green). This finding has a cross-cutting aspect in the area of human performance, in that Dominion did not use conservative assumptions in decision making and did not adopt a requirement to demonstrate that the proposed action is safe in order to proceed rather than a requirement to demonstrate that it is unsafe in order to disapprove the action.
05000336/FIN-2013005-042013Q4MillstoneLicensee-Identified ViolationTS 6.8.1, Procedures, requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in RG 1.33. Contrary to this requirement, on May 15, 2013, Dominion failed to correctly implement procedure OP 3312A, Containment Personnel Air Lock Operation, 3CS*Hatch1, to ensure that the equalizing valve for the Unit 3 outer access door was maintained in a closed configuration while the inner access hatch was opened. As a result, a loss of containment integrity occurred when the plant was in mode 4. The operators entered TS 3.6.1.1 and verified the equalizing valve had been closed, thereby restoring containment integrity within one hour required as required by TS 3.6.1.1 and 3.6.1.3. The inspectors determined that the finding was of very low safety significance (Green) in accordance with IMC 0609, Appendix A, The Significance Determination Process for Findings at Power. Dominion entered this issue into their CAP as CR 515704 and subsequently reported the loss of safety function to the NRC in LER-2013-005-00 as required under 10 CFR 50.73(a)(2)(v)(C).
05000336/FIN-2013005-052013Q4MillstoneLicensee-Identified ViolationTS 3.6.6.2, Secondary Containment, requires secondary containment to be operable. If inoperable, secondary containment shall be restored to operable within 24 hours or the unit shall be in at least HOT STANDBY within 6 hours and in COLD SHUTDOWN within the following 30 hours. Contrary to this requirement, from 1:57 AM on November 17, 2012, when security performed its test of the Unit 3 roll-up door, until 12:51 PM on November 21, 2012, when the door was fully closed (4 days, 9 hours, 12 minutes), secondary containment was inoperable. Because Dominion did not recognize this condition as rendering secondary containment inoperable until January 28, 2013, they did not take action in accordance with their TS. The inspectors determined that the finding was of very low safety significance (Green) in accordance with IMC 0609, Appendix A, The Significance Determination Process for Findings at Power. Dominion entered the issue into their CAP as CR 507822 and reported the loss of safety function and condition prohibited by TS as required under 10 CFR 50.73(a)(2)(v)(C) and 10 CFR 50.73(a)(2)(i)(B).
05000336/FIN-2013005-012013Q4MillstoneImplementation of NEI 99-01 GuidanceA URI was identified because additional NRC review and evaluation was needed to determine whether Dominion adequately implemented the guidance of NUMARC NESP-007, Methodology for Development of EALs, to establish initiating conditions for two EALs applicable to Mode 6 operations. This is considered a URI because more information is needed, specifically the clarification and interpretation of existing guidance by the NRCs Office of Nuclear Security and Incident Response (NSIR), in order to determine if the issue constitutes a violation. During a review of both units EAL schemes, the NRC identified two EALs applicable in mode 6 during a loss of RHR flow when there was no direct RCS temperature indication (that was representative of core temperatures) available to determine if the initiating conditions had been met for an Unusual Event or an Alert. Upon discovery of this issue, the inspectors discussed it with staff from NSIR. The NSIR staff preliminarily indicated that this issue appeared to be an industry-wide generic issue in that there was a lack of specified instrumentation for assessing core temperature during refueling if there was a loss of RHR flow. Therefore, given the apparent lack of a specified standard to assess the initiating conditions for these EALs, the inspectors delayed pursuing enforcement action pertaining to Dominions adherence to 10 CFR 50.47(b)(4) and Sections IV.B and IV.C of Appendix E to 10 CFR Part 50. While assessing the adequacy of Dominions extent of condition review for two prior NCVs related to the operators ability to implement the EAL scheme, the inspectors identified two EALs applicable to both units during a loss of cooling flow while in Mode 6. During this condition, there was no direct indication available to determine if the initiating conditions had been met. Specifically, in Mode 6 during a loss of RHR flow there would also be a loss of core temperature indication because the only available instrumentation is in the RCS loops (With the vessel head removed, the core exit thermocouples are no longer available and there is no temperature indication for the refueling cavity). The initiating conditions for an Unusual Event ( Uncontrolled RCS temperature increase > 10F ) and an Alert ( Uncontrolled RCS temperature increase > 10F that results in RCS temperature > 200F ) cannot be assessed due to the loss of RHR flow through the core causing the instrumentation to become unrepresentative of actual core temperature. Upon discovery of this issue, the inspectors discussed it with NRC staff from NSIR. The NSIR staff preliminarily concluded that this issue appeared to be an industry-wide generic issue in that there was a lack of specified RCS core temperature indication during refueling if there is a loss of RHR flow. The inspectors will coordinate with NSIR to review the adequacy of Dominions implementation of the guidance in NEI 99-01. Pending review of this issue, this item is an Unresolved Item (URI 05000336/2013005- 01 and 05000423/2013005-01, Implementation of NEI 99-01 Guidance)
05000336/FIN-2013004-012013Q3MillstoneInadequate Corrective Actions to Restore Degraded Unit 3 Main Feedwater Isolation ValvesThe inspectors identified a cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, for Dominions continued failure to take timely and effective corrective actions for conditions adverse to quality involving the degradation of the closing capability of four Unit 3 main feedwater isolation valves. Dominion had deferred correcting this condition over a period of six years (three refueling outages) which the inspectors noted in NCV 05000423/2012010-01, a Green NCV of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action. Dominion has since deferred repairs from the April 2013 refueling outage until the October 2014 outage. The violation is cited because Dominion has failed to restore compliance or demonstrate objective evidence of plans to restore compliance at the first opportunity in a reasonable period of time following initial identification in 2007 and documentation in 2012 NRC inspection reports. Dominion entered the issue into their CAP as CR507299 and plans to modify the valves in the 2014 refueling outage. The inspectors determined this issue was more than minor because it is similar to the more than minor examples, 4.f and 4.g of IMC 0612, Appendix E, Examples of Minor Issues. Specifically, Dominion did not correct a condition adverse to quality in a timely manner and resulted in a situation that impacted the operability of the feedwater isolation valves. Additionally, the finding is more than minor because it is associated with the design control attribute of the Barrier Integrity cornerstone, and adversely affected the cornerstones objective of providing reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and containment) protect the public from radionuclide releases caused by accidents or events. The inspectors determined that the finding was of very low safety significance (Green) because the issue did not represent an actual open pathway in the physical integrity of the reactor containment. In the event of a ruptured feedwater line, the train A main feedwater regulating valves and bypass valves would remain capable of closing to isolate feedwater flow. This finding had a cross-cutting aspect in the Human Performance area, Resources component, because Dominion did not maintain long term plant safety by minimizing longstanding equipment issues and ensuring maintenance and engineering backlogs which are low enough to support safety. Specifically, Dominion deferred the feedwater isolation valve replacement project from 3RFO15 to 3RFO16 because the design change could not be issued to support online work on the project required prior to the outage. Additionally, there were a number of outstanding technical issues for the design change that were not resolved in time despite the condition existing since 2007.
05000336/FIN-2013004-022013Q3Millstone\"Inadequate Operability Determination for the Turbine Drive Auxiliary Feedwater (TDAFW) Pump\"The inspectors identified a finding (FIN) for Dominions failure to complete an adequate and timely operability determination as required by OP-AA-102, Operability Determination, to assess governor control oscillations following completion of maintenance on the turbine driven auxiliary feedwater (TDAFW) pump 3FWA*P2 on May 17, 2013. The inspectors determined that the failure to adequately evaluate pump operability was a performance deficiency that was within Dominions ability to foresee and correct. Dominion entered this issue into their corrective action program (CAP) as CR528526 and repaired the TDAFW pump governor on August 12, 2013, prior to return to power following the reactor shutdown on August 9, 2013. The inspectors determined the performance deficiency was more than minor because it affected the equipment performance attribute of the Mitigating Systems cornerstone to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Failure to adequately assess operability resulted in a decrease in the reliability of the auxiliary feedwater (AFW) system to mitigate events. In addition, the performance deficiency is similar to examples 1.a and 2.a of IMC 0612, Appendix E, Examples of Minor Issues. The inspectors determined that the finding was of very low safety significance (Green) because the performance deficiency did not represent a loss of system safety function or a loss of safety function of a single train for greater than its Technical Specification allowed outage time. This finding has a cross-cutting aspect in the area of Human Performance, in that Dominion uses conservative assumptions in decision making and adopts a requirement to demonstrate that the proposed action is safe in order to proceed rather than a requirement to demonstrate that it is unsafe in order to disapprove the action.
05000336/FIN-2013004-032013Q3MillstoneLicensee-Identified Violation10 CFR 50 Appendix B, Criterion V, Instructions, Procedures, and Drawings, states, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with those instructions, procedures, or drawings. Contrary to the above, on March 7, 2013, Dominion failed to maintain a HELB door closed during the TDAFW pump surveillance and rendered both trains of AFW inoperable for approximately 30 minutes. The inspectors determined that the finding was of very low safety significance (Green) in accordance with IMC 0609, Appendix A, The Significance Determination Process for Findings at Power. Dominion entered the issue into their CAP (CR507412).
05000336/FIN-2013004-042013Q3MillstoneLicensee-Identified ViolationTS 3.8.2.1 requires, in part, that when 480V Emergency Load Center 22E is inoperable, it must be restored to operable status within 8 hours or be in COLD SHUTDOWN within the next 36 hours. Contrary to the above, from initial construction until June 8, 2012, the bus 22E was inoperable due to a gap in the HELB barrier. This gap would allow high energy steam to enter the switchgear rooms, causing the electrical equipment inside to potentially fail. The inspectors determined that there was a performance deficiency in that Dominion did not recognize the inoperability of the 22E bus as a result of the historical gap and take the appropriate actions as required by TS. This finding is of very low safety significance as determined by a detailed risk assessment using SAPHIRE 8 and a modified main steam line break outside of containment event tree from the Millstone 2 SPAR model. Specifically, the risk analysis reviewed three possible main steam line break sources in the turbine building near the West 480V Switchgear Room. The assumed one year exposure period was broken down into a period of 66 days when alternate cooling was in effect for the West 480V Switchgear Room and two days when it was in effect for the East 480V Switchgear Room. The frequencies of the associated steam line breaks were determined from a recent EPRI steam line break technical report, given the assumed leak location and the estimated length of associated piping. With the gaps in the HELB barrier and assuming a steam line break, the West 480V switchgear was assumed to fail. When alternate cooling was used for the West 480V Switchgear Room, if the steam line was not isolated, both trains of DC switchgear were also assumed to fail due to high temperature/humidity. When the East Switchgear alternate cooling was used, it was assumed that failure of all safety-related 480V power would have occurred due to high temperature/humidity. Dominion sealed the gap upon discovery in June 2012 and has entered this issue into the CAP (CR478194).
05000336/FIN-2013004-052013Q3MillstoneLicensee-Identified Violation10 CFR 50 Appendix B, Criterion III, Design Control, states, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions. Contrary to this, from initial construction until November 16, 2012, Dominion failed to ensure that Unit 2 safety related equipment would perform their safety function during a 22 foot MSL design basis flood event concurrent with a 26.5 foot MSL standing wave in the intake structure. Specifically, the unsealed electrical conduits and other openings would have allowed water to bypass Dominions flood protection features and could have affected the functionality of the safety related AFW and HPSI pumps and the PORVs. Dominion entered the issue into their corrective action process as CR491792 and sealed the conduits. Dominion performed an analysis that modeled the postulated effects of the compromised flood barriers. The evaluation postulated the time based impact of the design basis Probable Maximum Hurricane (PMH) tidal surge, using data (including wave runup above the still water heights) from Table 2.5-1 of the UFSAR, with and without the concurrent +26.5 ft MSL water level in the intake structure. The calculation estimated the height of water in the turbine, control, and auxiliary buildings rooms containing equipment necessary to maintain safe hot shutdown using: physical plant layout (floor areas and elevations, internal access doors and postulated water flow paths); water flow estimates; relative height of the identified leakage points; and critical water levels where equipment could be compromised. The engineering calculations demonstrated no impact to equipment needed to perform during the design basis flood without the concurrent intake structure standing wave. However, there was a potential to affect the functionality of the auxiliary feedwater pumps, the PORVs and the high pressure injection system if the standing wave condition occurred, as assumed, for one hour concurrent with the design basis maximum storm surge. The inspectors and a Region I senior risk analyst (SRA) reviewed the associated engineering calculations and technical evaluation. The Region I SRAs conducted and peer reviewed a detailed risk evaluation which they discussed with Office if Nuclear Reactor Regulation, Division of Risk Assessment staff. The SRAs determined that the finding was of very low safety significance with an estimated increase in core damage frequency of less than one in one million reactor years (Green). This was based on available frequency information and on the possibility of some credit for core damage mitigation equipment due to conservative assumptions, as follows: Dominion included significant conservatisms in their calculation and evaluation, which tend to overestimate the chance of damage to mitigation equipment, such as: including wave runup above the assumed still water heights; the one hour duration of intake structure water level at + 26.5 ft MSL due to the postulated standing wave; the height at which equipment damage would occur; and the assumed size of the identified flood barrier breaches. Dominion took no credit for operator actions to protect the important equipment either prior to or during a predicted extreme weather event. Plant procedures for these types of weather conditions discuss pre-staging equipment (sand bags, portable pumps and generators) and personnel to respond to limit the impact of potential flooding on important equipment.
05000336/FIN-2013010-012013Q3MillstoneInadequate Alternative Shutdown ProcedureThe team identified an apparent violation of Millstone Unit 2 Operating License Condition 2.C. (3) for failure to implement and maintain all aspects of the approved Fire Protection Program (FPP). Specifically, Dominion had not adequately implemented an alternative shutdown procedure, as required by 10 CFR 50 Appendix R Section III.L.3 and the approved FPP. The procedure for a Unit 2 fire which could lead to control room abandonment did not ensure the electrical distribution system was correctly configured prior to re-energizing AC buses. As a result, an over-current condition could occur and trip the 4kV supply breaker complicating safe shutdown operations and delaying AC bus recovery. In response to this issue, Dominion promptly revised their fire safe shutdown operating procedure prior to the end of the inspection to correct this deficiency. This finding was more than minor because it was associated with the Protection Against External Factors (e.g., fire) attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability and reliability of systems that respond to initiating events to prevent undesirable consequences. The team performed a Phase 1 Significance Determination Process (SDP) screening in accordance with NRC Inspection Manual Chapter 0609, Appendix F, and Fire Protection Significance Determination Process. This finding affected the post-fire safe shutdown category, and was determined to have a high degradation rating because the alternative shutdown procedure lacked adequate instructions to ensure correct equipment alignment. Therefore, the team concluded that a more appropriate and accurate characterization of the risk significance of this issue would be obtained by performing a Phase 3 SDP analysis because the Phase 2 SDP analysis does not explicitly address alternative safe shutdown fire scenarios. The Phase 3 SDP analysis cannot be accurately calculated until additional cable routing and ignition source information is presented by Dominion and is necessary to develop the fire scenarios that would require the alternative shutdown procedure to be implemented. This finding did not have a cross-cutting aspect because it was a legacy issue and was considered to not be indicative of current licensee performance.
05000220/FIN-2013003-022013Q2Nine Mile PointInadequate Procedural Implementation for Battery Cell ReplacementThe inspectors identified an NCV at Unit 2 of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, because CENG did not assure that the replacement of cells in battery 2C were prescribed and performed by appropriate procedures which resulted in degraded accuracy of test results and potential degradation of safety-related battery cells. In response to this issue, CENG generated CR-2013-005235 and initiated actions to evaluate replacing the new cells. This finding is more than minor because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, the inspectors determined this finding is of very low safety significance (Green) because the performance deficiency was not a design or qualification deficiency, did not involve an actual loss of safety function, did not represent actual loss of a safety function of a single train for greater than its TS allowed outage time, and did not screen as potentially risk-significant due to a seismic, flooding, or severe weather initiating event. This finding has a cross-cutting aspect in the area of Human Performance, Decision-Making component, because CENG did not use conservative assumptions in decision making. Specifically, CENG did not monitor the cells in storage, question the adequacy of the discharged cells, charge the cells prior to installation, or fully evaluate the implications of the test and recharge results.
05000336/FIN-2013003-022013Q2MillstoneFailure to Establish Measures for the Identification and Control Design Interfacesand for Coordinating among Participating Design OrganizationsThe inspectors noted a self-revealing Green NCV of 10 CFR 50, Criterion III, Design Control, when Dominions did not adequately implement established measures for the identification and control of design interfaces and for coordinating among participating design organizations. Specifically, Dominion failed to properly require a temporary modification for a work activity that met the design requirements of CM-AA-TCC-204, Temporary Configuration Changes, when workers installed an air line jumper that caused an AOV to open and led to an uncontrolled loss of RCS inventory. Dominion entered the issue into their CAP as CR511856. The finding is more than minor because it is associated with the design control attribute of the Initiating Events cornerstone and affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown operations. Specifically, Dominion failed to properly implement a temporary modification which ultimately led to the uncontrolled loss of RCS inventory. The finding was of very low safety significance (Green) because the charging system had sufficient capacity to maintain pressurizer level, the leakage would not have caused the loss of the running residual heat removal (RHR) pump for a substantial period of time, and at least one steam generator (SG) remained available. The finding had a cross-cutting aspect in Human Performance, Work Practices, because Dominion failed to ensure supervisory and management oversight of work activities such that nuclear safety is supported. Specifically, the station did not maintain control of activities in accordance with plant procedures.
05000336/FIN-2013003-032013Q2MillstoneFailure to Make a 10 CFR 50.72(b)(3)(v) Report for a Major Loss of EmergencyAssessment Capability for Stack Radiation MonitorThe inspectors identified a Severity Level IV NCV of 10 CFR 50.72(b)(3)(xiii) for the failure to make the required initial notification to the NRC within eight hours of a major loss of monitoring capability. On April 16, Dominion declared the main station stack radiation monitor inoperable but did not report this to the NRC until the inspectors questioned the control room operators on April 18. Dominion evaluated the condition and made the required notification (NRC event report number 48941) on April 18, 2013, and entered the issue into their corrective action program (CAP) as CR512007. The inspectors determined that Dominion did not notify the NRC of a major loss of emergency assessment capabilities event in the time required by 10 CFR 50.72. The inspectors determined the finding was subject to traditional enforcement because Dominions failure to make a required report could potentially impact the NRCs regulatory function. This finding is similar to the one described in NRC Enforcement Policy, Section 6.9.d(9), A licensee fails to make a report required by 10 CFR 50.72 or 10 CFR 50.73, which corresponds to Severity Level IV. In accordance with guidance contained in IMC 0612, Power Reactor Inspection Reports , Section 07.03, cross-cutting aspects are not assigned to traditional enforcement violations.
05000220/FIN-2013003-032013Q2Nine Mile PointInadequate Design Control for Battery Sizing CalculationThe inspectors identified an NCV at Unit 2 of 10 CFR Part 50, Appendix B, Criterion III, Design Control, because CENG did not verify the adequacy of the design with respect to battery 2C. Specifically, by failing to size the battery to the most limiting time period, the sizing calculation significantly overstated the available design margin. CENGs corrective actions included generating condition report CR-2013-005117 and evaluating the condition for operability. This finding is more than minor because it was associated with the design control attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, the inspectors determined this finding is of very low safety significance (Green) because the performance deficiency was not a design or qualification deficiency, did not involve an actual loss of safety function, did not represent actual loss of a safety function of a single train for greater than its TS allowed outage time, and did not screen as potentially risk-significant due to a seismic, flooding, or severe weather initiating event. The inspectors did not assign a cross-cutting aspect because the finding was not indicative of current performance.
05000336/FIN-2013003-042013Q2MillstoneLicensee-Identified ViolationOn March 19, Dominion received laboratory results for the A train CREFS charcoal filter sample on Unit 3 that had been taken on March 13. The results indicated that the methyl iodide penetration for the charcoal sample was 4.46 percent, which exceeded the TS requirement of 2.5 percent. Dominion determined that the A CREFS had been inoperable from March 13 to March 21, which exceeded the seven day allowed outage time. Because Dominion could not recognize the inoperability of the A CREFS until after the charcoal test results were available they did not take actions contrary to the requirements of TS 3.7.7. Traditional enforcement applies in accordance with IMC 0612, Sections 0612-09 and 0612-13, and Enforcement Policy Section 2.2.4.d, because the inspectors did not identify an associated performance deficiency. The inspectors determined this to be a SLIV violation of TS 3.7.4 in accordance with Enforcement Policy Section 6.1.d. This condition is reportable under 10 CFR 50.73(a)(2)(i)(B) as a condition prohibited by TS and as a result Dominion submitted LER 05000423/2013-004-00 and entered the issue into their CAP as CR508567.