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| Quarter | Site | Title | Description | |
|---|---|---|---|---|
| 05000390/FIN-2013011-01 | 2013Q4 | Watts Bar | Failure to Implement Monitoring Plan for Permanent Flood Mode Structures | The NRC identified a finding for the licensees failure to incorporate fleet inspection monitoring requirements for permanent flood mode structures into the Watts Bar external flood protection program procedure. Specifically, Watts Bar procedure 0-TI-444, External Flood Protection Program, Revision 0, failed to detail the procedures and processes used to track, trend, and maintain key program data related to periodic inspections for permanent flood mode structures. The licensee generated Problem Evaluation Reports (PERs) 824744 and 823305 to address this issue and other observations regarding the Watts Bar flood monitoring plan. The performance deficiency was more than minor because if left uncorrected it would lead to a more significant safety concern. Specifically, the absence of a site-level monitoring plan in 0-TI- 444 to track periodic inspection results of permanent flood mode structures would degrade the licensees ability to detect and correct declining external flood hazard barrier conditions or performance to ensure Watts Bar remained capable of withstanding a probable maximum flood elevation as intended by the external flood protection program. The inspectors concluded the finding was associated with the mitigating systems cornerstone and determined the finding was of very low safety significance (green) because the finding had not resulted in an actual physical degradation of equipment or function specifically designed to mitigate a seismic, flooding, or severe weather initiating event. The inspectors concluded the cause of the finding was related to the complete, accurate, and up-to-date procedures cross-cutting aspect in the Resources component of the Human Performance area. Specifically, the licensees implementation of the fleet external flood protection program had not ensured that site procedures and other resources were available to provide complete, accurate, and up-to-date documentation and procedures regarding the treatment of passive flood barriers. |
| 05000390/FIN-2012009-03 | 2013Q1 | Watts Bar | Failure to Maintain an Adequate Abnormal Condition Procedure to Implement the Flood Mitigation Strategy | The inspectors identified an AV of Technical Specification 5.7.1, Procedures, for the licensees inability to demonstrate that the required Stage I and Stage II activities could be performed within 27 hours as required by AOI-7.1, Maximum Probable Flood. The licensees failure to adequately demonstrate the ability to realign plant systems into their flood mode configuration using AOI-7.1, Maximum Probable Flood, within the time frame required by TRM 3.7.2 and Watts Bar UFSAR Section 2.4, which could directly lead to the inability to remove decay heat from the reactor core resulting in core damage, was a performance deficiency. This performance deficiency was considered more than minor because it was associated with the Protection Against External Factors attribute of the Reactor Safety/ Mitigating Systems Cornerstone and adversely affected the cornerstone objective of ensuring availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the inability to realign plant systems into their flood mode configuration within the required time frame could directly lead to the inability to remove decay heat. The combination of the seismic and rainfall event frequencies and types of rainfall events which would lead to flooding above site grade and the inability to realign plant systems into their flood mode configuration within the 27-hour required time frame could directly lead to the inability to remove decay heat from the reactor core resulting in core damage which has an impact of substantial safety significance. The NRC concluded that the significance of the finding is preliminarily substantial safety significance (Yellow). The cause of the finding had a cross-cutting component of Resources in the area of Human Performance with an aspect of ensuring that personnel, equipment, procedures, and other resources were available and adequate to assure nuclear safety. Specifically, inadequacies in those procedures, equipment, and personnel training necessary to realign plant systems within the required time frame to cope with all anticipated external flooding events. |
| 05000335/FIN-2012008-01 | 2012Q4 | Saint Lucie | Inadequate Procedure for Severe Weather Mitigation | The team identified a non-cited violation of Technical Specification 6.8, Procedures and Programs, for an inadequate technical specification required procedure to combat a loss of feedwater or feedwater system failure. Abnormal operating procedure 1-AOP-09.02, Auxiliary Feedwater, Attachment 5, Supplying Unit 1 AFW Pumps from the Unit 2 CST, could not be performed as written with respect to ensuring the availability of the Auxiliary Feedwater (AFW) pumps. The licensee promptly issued a standing night order to ensure that the AFW pumps would remain available and initiated action requests 1816711 and 1826000. The licensee has subsequently modified the procedure to rectify the issue. The licensees failure to provide an adequate procedure to mitigate a design basis event was a performance deficiency. The performance deficiency affected the Mitigating Systems Cornerstone objective to ensure the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, procedure 1-AOP-09.02, secured all suction sources to the AFW pumps without ensuring that the motor driven auxiliary feedwater (MDAFW) pumps would not auto start if an auxiliary feedwater actuation signal was received. The performance deficiency was determined to have more than minor safety significance because if left uncorrected, the failure of the MDAFW pumps could lead to a more significant safety concern as a result of the plant not being able to sustain short-term decay heat removal under specific conditions. The procedure steps created a condition that could have resulted in the inoperability of both MDAFW pumps. In accordance with NRC Inspection Manuel Chapter 0609.04, Initial Screening and Characterization of Findings, the team determined that a detailed risk evaluation was required because the finding screened as potentially risk-significant due to a severe weather initiating event. A bounding Significance Determination Process Phase 3 analysis was performed by a regional senior risk analyst which determined the performance deficiency was a Green finding of very low safety significance. The inspectors determined that no cross cutting aspect was applicable to this performance deficiency because this finding was not indicative of current licensee performance. |
| 05000424/FIN-2012003-01 | 2012Q2 | Vogtle | Failure to Follow Procedures Renders Safety Related Battery Chargers Inoperable | The inspectors identified a self-revealing NCV of Technical Specification (TS) 5.4.1, for two instances of failure to properly implement approved maintenance procedures and work order instructions. Specifically, maintenance electricians inadvertently removed the 2BD1CB safety related battery charger from service while attempting to perform a routine quarterly battery surveillance on the 2DD1CB battery charger. When the 2BD1CA/2BD1CB Trouble alarm was received in the control room, the operators immediately contacted the electricians and the work was halted. Battery charger 2BD1CB was restored to service within 31 minutes. In the second instance, maintenance electricians inadvertently rendered both battery chargers for the 1CD1 safety-related battery inoperable during load-sharing adjustments on the 1CD1CB battery charger. The licensee restored the 1CD1CA battery charger to service within a few minutes. The licensee entered both of these issues into their corrective action program (CR 445343 & 457102 respectively). The inspectors concluded that this finding was more than minor because it impacted the Reactor Safety Mitigating Systems Cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences and affected the cornerstone attribute of equipment performance. Specifically, the unintentional opening of the AC input breakers to the 2BD1CB, 1CD1CA and 1CD1CB battery chargers resulted in the chargers being declared inoperable for several minutes. The inspectors used the Phase 1 Initial Screening and Characterization of Findings (IMC 0609.04 Exhibit 1) to characterize the finding. Since the inspectors answered No to all of the Table 4a Mitigating Systems Cornerstone questions, the inspectors concluded that the finding was of very low safety significance (Green). The inspectors determined that the cause of this finding was related to the Work Practices component of the Human Performance cross-cutting area due to less than adequate procedure use and self/peer checking. |
| 05000424/FIN-2012003-02 | 2012Q2 | Vogtle | Licensee-Identified Violation | TS limiting condition of operation (LCO) 3.5.4 Condition D requires that the RWST be returned to operable status with a completion time of 1 hour. If the RWST is not returned to operable status within 1 hour, TS LCO 3.5.4 Condition E requires that the unit be placed in Mode 3 within 6 hours and in Mode 5 within 36 hours. Contrary to the above, the licensee aligned the seismically qualified RWST to the non-seismically qualified SFPP system in Mode 1 for periods greater than one hour. The licensee inappropriately believed that manual operator compensatory actions could be used to maintain the RWST operable. Consequentially, no LCO required actions were taken. The licensee entered this condition in its corrective action program as CR 408441. This finding was assessed using IMC 0609, Phase 1 screening worksheet of Attachment 4 and was determined to be of very low safety significance (Green) because the finding represents a qualification deficiency confirmed not to result in the loss of functionality of the RWST. |
| 05000424/FIN-2012003-03 | 2012Q2 | Vogtle | Licensee-Identified Violation | 10 CFR 50 Appendix B, criterion V requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, and that these instructions, procedures, or drawings include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. Contrary to the above, maintenance procedure 27599-C Rev. 2.2, EDG Fuel Oil Filter and Strainer Maintenance provided inadequate guidance for draining the fuel oil filter prior to replacement. As a result, on May 25 maintenance personnel inadvertently rendered the 1B EDG inoperable by draining the fuel header while attempting to replace the east fuel filter. When contacted for assistance a few hours later, engineering and operations personnel recognized this degraded condition and the diesel was declared inoperable. The licensee documented this event in their corrective action program as CR 460607. This finding was assessed using IMC 0609, Phase 1 screening worksheet of Attachment 4 and was determined to be of very low safety significance (Green) because the finding did not represent the actual loss of safety function of a single train for greater than its TS allowed outage time. |