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| Quarter | Site | Title | Description | |
|---|---|---|---|---|
| 05000397/FIN-2013005-01 | 2013Q4 | Columbia | Failure to Translate Internal Flooding Design into Station Procedures | The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to translate the design of water resistant doors used to protect emergency core cooling rooms from internal flooding into procedures used to control those doors. The licensee entered this finding into their corrective action program as Action Request AR 298068. The performance deficiency was more than minor because it affected the procedure quality attribute of the mitigating systems cornerstone objective and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. This finding is of very low safety significance (Green) because: (1) the finding was not a deficiency affecting the design or qualification of a mitigating system; (2) the finding did not represent a loss of system and/or function; (3) the finding did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and (4) the finding does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hours. This finding had a cross-cutting aspect in the area of human performance associated with the decision making component because the licensee failed to verify the validity of the underlying assumptions used in the stations flooding analysis and failed to identify possible unintended consequences when making changes to the barrier impairment procedure. |
| 05000397/FIN-2013005-02 | 2013Q4 | Columbia | Non-Conservative Error in Control Room Boundary Breach Specification | The inspectors identified a non-cited violation of 10 CFR Part 50 Appendix B, Criterion III, Design Control, for the licensees failure to translate the results of calculation NE-02-02-01, Control Room Boundary Leakage Limitation into allowed breach specifications for the control room ventilation boundary. This finding was entered into the licensees corrective action program as Action Request AR 298914. This performance deficiency was more than minor because it affected the design control attribute of the Barrier Integrity Cornerstone objective of providing reasonable assurance physical design barriers to protect the public from radionuclide releases caused by accidents or events. This finding is of very low safety significance (Green) because the finding only represents a degradation of the radiological barrier function provided for by the control room. The finding did not have a cross-cutting aspect because the performance deficiency occurred in early 2010 using a different process than currently exists and was therefore not reflective of current performance. |
| 05000397/FIN-2013005-03 | 2013Q4 | Columbia | Licensee-Identified Violation | Technical Specification 5.4.1.a, requires, in part, that written procedures be established, implemented, and maintained as described in Regulatory Guide 1.33, Revision 2, Appendix A, dated February 1978. Regulatory Guide 1.33, Paragraph 9.a states that maintenance that can affect the performance of safety-related equipment should b properly preplanned and performed in accordance with written procedures, documente instructions, or drawings appropriate to the circumstances. Contrary to the above, th licensee failed to preplan written procedures appropriate to the circumstances a required by Technical Specification 5.4.1.a. Specifically, on April 25, 2011 and January 4, 2010, the licensee planned Work Orders 01182801 and 01179746 to adjust the impeller lift for standby service water pumps 1A and 1B but failed to specify the appropriate impeller lift for the pump. Consequently, the licensee set the impeller lift higher than specified in the pump design during performance of Work Orders 01182801 and 01179746, resulting in degraded performance of the pump. The licensee identified this violation and entered it into their corrective action program as Action Requests AR 219553 and AR 292521. This finding was determined to be of very low safety significance because the finding is a design or qualification deficiency that did not affect operability or functionality. |
| 05000397/FIN-2013005-04 | 2013Q4 | Columbia | Licensee-Identified Violation | Title 10 CFR 71.5(a) requires that each licensee who transports material outside the site of usage, as specified in the NRC license...shall comply with the applicable requirements of the Department of Transportation regulations in 49 CFR... Title 49 CFR 172.203(d)(3) states, in part, the description for a shipment of a Class (radioactive) material must include the activity contained in each package of the shipment. Contrary to the above, on August 29, 2011, in the shipping manifest for Radioactive Waste Shipment 11-106, the licensee did not include the correct activity for the radioactive mechanical filters shipped, in that the original manifest stated an activit of 8.09 Curies, but the licensee later determined the activity was 31.54 Curies. The licensee identified this violation and entered it into their corrective action program as Action Request AR 248151. This finding was determined to be of very low safety significance (Green) because the finding did not involve the radioactive effluent release program or the radiological environmental monitoring program, but the finding did involve the transportation of radioactive material. The finding was not (1) in excess of radiation limits, (2) a breach of package during transit, (3) a certificate of compliance issue, (4) a low-level burial ground noncompliance, or (5) a failure to make notifications or provide emergency information. |
| 05000483/FIN-2013003-01 | 2013Q2 | Callaway | Failure to Monitor and Maintain Emergency Core Cooling System Room Coolers | The inspectors identified a non-cited violation of 10 CFR 50.65, involving the licensees failure to monitor performance of structures, systems, or components in a manner sufficient to provide reasonable assurance that these structures, systems, or components are capable of fulfilling their intended functions. Specifically, the licensee failed to adequately monitor the cooling water flow through the safety related room coolers that periodically became blocked by silting, to ensure they maintained their capability to remove the heat from the rooms. This issue was entered into the licensees corrective action program as Callaway Action Request 201301108. Corrective actions included a requirement to monitor the flow rates monthly and determine the appropriate monitoring and flushing requirements based on the results. The failure to monitor performance of structures, systems, or components in a manner sufficient to provide reasonable assurance that these structures, systems, or components are capable of fulfilling their intended functions was a performance deficiency. This performance deficiency was more than minor because it adversely affected 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. Using Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the finding was determined to be of very low safety significance (Green) because all of the questions received a negative response. This finding has a cross-cutting aspect in the area of problem identification and resolution associated with the operating experience component because the licensee failed to systematically collect, evaluate, and communicate relevant internal operating experience about silting of room coolers to internal stakeholders. |
| 05000483/FIN-2013003-02 | 2013Q2 | Callaway | Failure to Appropriately Pre-plan and Perform Maintenance on the Unit Auxiliary Transformer | The inspectors reviewed a self-revealing non-cited violation of Technical Specifications 5.4.1 and Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), involving the failure to appropriately pre-plan and perform maintenance on equipment that can affect the performance of safety-related equipment. Specifically, the licensee failed to properly pre-plan and perform maintenance on the unit auxiliary transformer that contributed to a fire. During Refueling Outage 19, the unit auxiliary transformer was providing power to non-safety house loads and train B battery chargers when it experienced a phase to phase short and fire in the surge capacitor. The fire and loss of power affected the performance of safety-related batteries and battery chargers, and led to manual actuations of the reactor protection system. This issue was entered into the licensee\'s corrective action program as Callaway Action Request 201302877. Corrective actions included installing new surge protectors on the unit auxiliary transformer, revising station procedures for connecting and disconnecting the surge protectors, and ordering new surge capacitors for the startup transformer. The failure to appropriately pre-plan and perform maintenance on equipment that can affect the performance of safety-related equipment was a performance deficiency. The performance deficiency was more than minor because it adversely affected the protection against external factors 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 as well as power operations. Specifically, the fault and fire led to a loss of power to mitigating systems while the reactor was shutdown. Using Inspection Manual Chapter 0609, Appendix G, Attachment 1, Checklist 4, PWR Refueling Operation: RCS level > 23\'OR PWR Shutdown Operation with Time to Boil > 2 hours And Inventory in the Pressurizer, the finding was determined to be of very low safety significance (Green) because the licensee maintained adequate event mitigation capabilities, the event did not result in a change in reactor coolant system inventory or temperature, and it did not require a quantitative risk assessment. This finding has a cross-cutting aspect in the human performance area associated with the resources component because the licensee failed to ensure that the equipment and maintenance procedures were adequate to assure nuclear safety. |
| 05000483/FIN-2013003-03 | 2013Q2 | Callaway | Failure to Appropriately Pre-plan and Perform Maintenance on Safeguards Transformer B | The inspectors reviewed a self-revealing non-cited violation of Technical Specification 5.4.1 and Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), involving the failure to appropriately pre-plan and perform maintenance on equipment that can affect the performance of safety-related equipment. Specifically, the licensee directed contractors to perform work on safeguards transformer B with work instructions, training, and supervisory oversight that was not appropriate for the individuals performing the work. This issue was entered into the licensees corrective action program as Callaway Action Request 201302280. Corrective actions included a revision to the work instructions to be more specific on grounding locations and a refocus and retraining of grounding electrical systems. Planned corrective actions include establishing a process for identifying high risk outage activities similar to the process used for online maintenance. The failure to appropriately pre-plan and perform maintenance on equipment that can affect the performance of safety-related equipment was a performance deficiency. This performance deficiency was more than minor because it adversely affected the procedure quality 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 as well as power operations. Using Inspection Manual Chapter 0609, Appendix A, Exhibit 1, Initiating Events Screening Questions, the 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 relied upon to transition the plant from the onset of the trip to a stable shutdown condition. This finding has a cross-cutting aspect in the human performance area associated with the work practices component because the primary cause for the performance deficiency was that the licensee failed to ensure supervisory and management oversight of work activities, including contractors, such that nuclear safety is supported. |
| 05000483/FIN-2013003-04 | 2013Q2 | Callaway | Failure to Correctly Screen Repetitive Equipment Failures | The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, for the licensees failure to perform activities affecting quality in accordance with procedures. Specifically, the licensee failed to recognize the significance of repetitive refrigerant leaks on the safety-related Class 1E electrical equipment air conditioning units units and assign the appropriate significance level in accordance with APA-ZZ-00500, Corrective Action Program, Revision 57. This issue was entered into the licensees corrective action program as Callaway Action Request 201304985. Further corrective actions are being evaluated, including enhancements to Callaways corrective action procedure for raising significance of repetitive issues and evaluating new enhancements for the corrective action programs screening process. The failure to perform activities affecting quality in accordance with procedures was a performance deficiency. This performance deficiency was more than minor because it adversely affected the equipment performance attribute of the Mitigating Systems Cornerstone objective of ensuring the reliability of systems that respond to initiating events. Specifically, the licensee failed to recognize the significance of repetitive refrigerant leaks on the safety related Class 1E electrical equipment air conditioning units and assign the appropriate significance level during issue screening, and therefore failed to perform a cause analysis and correct the cause. The finding required a detailed risk evaluation because it involved the potential failure of safety related equipment for longer than the technical specification allowed outage time. A senior reactor analyst determined that the change to the core damage frequency was much less than E-7/yr (Green). In each case, the affected chiller, while incapable of meeting the 30-day design basis mission time, could have still functioned properly and supported the inverters during the probabilistic risk assessment 24-hour mission time. Therefore, there was no quantifiable increase in the core damage frequency or the large early release frequency. This finding has a cross-cutting aspect in the area of problem identification and resolution with a problem evaluation component, because the licensee failed to fully evaluate the collective body of data regarding the Class 1E air conditioning units such that the resolutions address the causes and extent of condition, including proper classification. Specifically the licensee failed to thoroughly evaluate the repetitive failures all facets of this issue, including properly classifying the refrigerant leaks. |
| 05000498/FIN-2013002-01 | 2013Q1 | South Texas | Failure to Initiate a Condition Report for Spent Fuel Pool Cooling LOW Flow Alarms | The inspectors identified a Green finding for the failure to follow Procedure 0PGP03-ZX-0002, Condition Reporting Process, Revision 43, step 4.2.1, which required initiation of a condition report for an abnormal or unexpected condition on a structure, system, or component. On October 11, 2012, the inspectors toured the Unit 1 control room and observed operators starting the spent fuel pool cooling pumps. Shortly after starting the pumps, a low flow annunciator alarm was received. The operators dismissed the alarm as expected. However, the inspectors questioned the response to the alarm and determined that there was no documented explanation for the alarm to be expected. The inspectors reviewed several years of historical pump starts and determined that the alarms were not consistent between the trains, and the licensee failed to evaluate the inconsistency. The inspectors concluded this condition warranted the initiation of a condition report. During troubleshooting, the licensee concluded that they had installed the incorrect type of pulsation dampener (snubber) in the flow line which caused the low flow annunciator alarm. The licensees corrective actions included replacing the snubber, updating procedures, and training of maintenance and operations personnel about the condition. This finding was more than minor because it affected the Barrier Integrity Cornerstone attribute of Structures, Systems, and Components Performance (area of instrumentation to maintain functionality of the spent fuel pool cooling system), and it affected the cornerstone objective to provide reasonable assurance that physical design barriers (fuel cladding) protect the public from radionuclide releases caused by accidents or events. Specifically, if left uncorrected it would have the potential to become a more significant safety concern because it could have resulted in unreliable instrumentation, or alarms, that are used to ensure adequate cooling to the spent fuel pool. The inspectors performed the significance determination using NRC Inspection Manual Chapter 0609 because the finding affected the Barrier Integrity Cornerstone while the plant was at power. Attachment 0609.04, Initial Characterization of Findings, dated June 19, 2012, evaluates the finding using Appendix A. Using Appendix A, Exhibit 3, Barrier Integrity Screening Questions, the finding was determined to be of very low safety significance because the finding did not: (1) result in the spent fuel pool temperature exceeding the maximum analyzed temperature limit; (2) result from fuel handling errors that caused fuel cladding damage; (3) result in a loss of inventory below the minimum analyzed level limit; and (4) affect the spent fuel pool neutron absorber, fuel pattern loading, or soluble boron concentration. In addition, the NRC determined the finding had a human performance cross-cutting aspect associated with decision making because the licensee did not use conservative assumptions when dismissing the low flow alarm instead of having it evaluated to ensure that it was safe to proceed |
| 05000498/FIN-2013002-02 | 2013Q1 | South Texas | Use of NON-CONSERVATIVE Values in Reportability Evaluation | The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criteron V, Instructions, Procedures, and Drawings, for the failure to follow Procedure 0PGP04-ZA-0002, Condition Report Engineering Evaluation, Revision 18. On February 25, 2013, cavitation damage was discovered during a scheduled inspection of train C essential cooling water return throttle valve to the component cooling water heat exchange valve 2-EW-0101. A reportability review was performed by civil and mechanical design engineering personnel using Procedure 0PGP04-ZA-0002. Step 3.0 of this procedure stated that the engineering supervisor and the preparer are responsible for ensuring that the evaluation is technically and administratively correct. The inspectors determined that the evaluation was not technically correct because nonconservative values were used for carbon steel, and there was no discussion on aluminum bronze. The licensee entered this issue into the corrective action program as Condition Report 13-3170. Corrective actions included revising the original evaluation, generating a lessons learned for the engineering department, and creating an action item to evaluate revising the procedure to more clearly define roles and responsibilities for cross discipline evaluations. This finding was more than minor because it affected the Mitigating Systems Cornerstone attribute of Human Performance and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, using non-conservative values in a reportability evaluation which resulted in significant calculational errors requiring the evaluation be revised. The inspectors performed the significance determination using NRC Inspection Manual Chapter 0609 because the finding affected the Mitigating Systems Cornerstone while the plant was at power. Attachment 0609.04, Initial Characterization of Findings, dated June 19, 2012, evaluates the finding using Appendix A. Using Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the finding was determined to be of very low safety significance because it was not a design or qualification issue confirmed not to result in a loss of operability or functionality; did not represent an actual loss of safety function of the system or train; and did not result in the loss of one or more trains of nontechnical specification equipment. In addition, the NRC determined the finding had a human performance cross-cutting aspect, associated with work practices, because error prevention techniques such as self and peer checking were not performed commensurate with risk of the assigned task |
| 05000361/FIN-2012005-01 | 2012Q4 | San Onofre | Failure to Provide Complete and Accurate Information Regarding Auxiliary Feedwater System Operability | The inspectors identified a Severity Level IV non-cited violation of 10 CFR 50.9, Completeness and Accuracy of Information, for the failure of the licensee to provide complete and accurate information in all material respects in operability and reportability review supporting documents. Specifically, on September 29, 2011, the licensee did not provide information that was complete and accurate in all material respects, in that Evaluation Report FAI/11-0655, Evaluation of Potential Cooling of the SONGS Steam Line for the AFW Turbine, used inaccurate information to inappropriately determine that the turbine-driven auxiliary feedwater pump was operable, the condition was not reportable per the requirements of 10 CFR 50.73, and the compensatory measures implemented on May 5, 2011, could be removed. The compensatory measures were improperly removed on October 27, 2011. This violation has been entered into the licensees corrective action program as Nuclear Notification NN 202280026. The failure of the licensee to provide complete and accurate information related to the operability of the AFW system was a performance deficiency. The significance determination process is not suited to assess the significance of a violation of 10 CFR 50.9 because it affected the ability of the NRC to perform its regulatory oversight function and, as such, it was assessed using traditional enforcement. This violation was determined to be a Severity Level IV violation based on NRC Enforcement Policy examples provided in Section 6.9. No crosscutting aspect was assigned because the performance deficiency was assessed using traditional enforcement |
| 05000397/FIN-2012004-02 | 2012Q3 | Columbia | Failure to Develop Preventive Maintenance Schedule for Safety-Related 480V Starter Coils | The inspectors reviewed a self-revealing non-cited violation of Technical Specification 5.4.1.a, Procedures, for the licensees failure to implement preventive maintenance schedules for safety-related 480V starter coils. On June 16, 2012, fuel pool cooling pump FPC-P-1A unexpectedly stopped. Subsequent review determined that the loss of fuel pool cooling pump FPC-P-1A was due to no existing preventive maintenance requirement to replace safety-related critical starter coils that are either continuously energized or have a high duty cycle. As corrective action, the licensee implemented a preventive maintenance task to replace high duty cycle starter coils every 15 years and low duty cycle starter coils every 25 years. This issue was entered into the licensees corrective action program as Action Request 265422. The finding was more than minor because it affected the structures, systems, and components performance attribute of the Barrier Integrity Cornerstone objective to provide reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and containment) protect the public from radionuclide releases caused by accidents or events. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, the inspectors determined this finding to be of very low safety significance (Green) because the finding did not adversely affect decay heat removal capabilities from the spent fuel pool causing the pool temperature to exceed the maximum analyzed temperature limit specified in the site-specific licensing basis. The inspectors determined that this finding had a cross-cutting aspect in the area of problem identification and resolution associated with the operating experience component because the licensee failed to thoroughly evaluate and implement changes to the preventive maintenance schedule for 480V switchgear in response to industry operating experience. |
| 05000445/FIN-2012003-03 | 2012Q3 | Comanche Peak | Failure to Adequately Evaluate Fish Intrusion Operating Experience and Initiate Corrective Action | The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, for the failure of the licensee to identify and correct a condition adverse to quality. Specifically, the licensee failed to adequately evaluate industry operating experience related to fish intrusion into cooling water systems, which resulted in the failure to take appropriate corrective actions. Subsequently, shad from the safe shutdown impoundment entered the service water system and lowered cooling water flow to safety-related components when the fish were caught in the component strainers. The licensee entered the finding into the corrective action program as Condition Report CR-2012-006133. The licensees failure to identify a condition adverse to quality through an inadequate evaluation of industry operating experience related to fish intrusion into cooling water systems was a performance deficiency. The finding was more than minor because it was associated with the protection against external events attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the fish intrusion resulted in the clogging of strainers and the lowering of service water flow to safety-related pumps. Using NRC Manual Chapter 0609, Significance Determination Process, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, the finding was determined to be of very low safety significance because it was not a design or qualification deficiency, was not a loss of system safety function, was not an actual loss of 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. The finding did not have a cross-cutting aspect because the performance deficiency was not representative of current plant performance. |
| 05000397/FIN-2012004-03 | 2012Q3 | Columbia | Failure to Maintain Adequate Procedural Guidance for Critical Switchgear Ventilation Systems | The inspectors identified a non-cited violation of Technical Specification 5.4.1.a, Procedures, for the licensees failure to maintain adequate procedures associated with critical switchgear ventilation systems. Specifically, licensee Procedure ABN-HVAC, HVAC Trouble, Revision 10, incorrectly directs entry into Technical Specification 3.7.1, Standby Service Water (SW) System and Ultimate Heat Sink (UHS), Condition B, for periods when critical switch gear fans were out of service. As corrective action, the licensee changed the procedures to reflect the correct technical specification action statements that should be entered when critical switchgear ventilation systems are taken out of service. This issue was entered into the licensees corrective action program as Action Request AR 268099. This performance deficiency was more than minor because it adversely affected the procedural quality attribute of the Mitigating Systems Cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, the inspectors determined this finding to be of very low safety significance (Green) because it was not a deficiency or qualification deficiency, did not represent a loss of system and/or function, did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time or two separate safety systems out of service for greater than its technical specification allowed outage time, and the finding did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hours. The inspectors did not assign a cross-cutting aspect to this finding because the inadequate procedural guidance for critical switchgear ventilation systems was made in 2009 and is not reflective of current performance. |
| 05000397/FIN-2012004-04 | 2012Q3 | Columbia | Failure to Provide Adequate Work Instructions | The inspectors reviewed a self-revealing Green non-cited violation of 10 CFR Part 50 Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to provide work instructions appropriate for performing maintenance on the standby gas treatment system. Specifically, the licensee failed to provide work instructions that would have precluded a trip of the in-service reactor building ventilation system during calibration of the standby gas treatment system. The licensee updated similar work orders to provide provisions to swap to redundant trains to preclude future trips of running equipment. The licensee entered this issue into the corrective action program as Action Request AR 267373. This performance deficiency was more than minor because it 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. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, the inspectors determined the finding to be of very low safety significance (Green) because the finding only represented a degradation of the radiological barrier function provided for by the standby gas treatment system. The inspectors determined the finding had a cross-cutting aspect in the area of human performance associated with the work control component in that the licensee failed to appropriately coordinate work activities to address the operational impact to the reactor building ventilation system when calibrating the standby gas treatment control flow transmitter. |
| 05000397/FIN-2012004-05 | 2012Q3 | Columbia | Failure to Maintain Dose ALARA due to Poor Job Execution | The inspector reviewed a self-revealing finding for failure to maintain doses as low as is reasonably achievable (ALARA) due to poor job execution. The licensee estimated that ALARA Task 11748210101 attached to Radiation Work Permit 30002666, R20 TG Cond-HX-9 Replacement and Repairs Inside Condenser, would accrue 10.387 person-rem. However, the actual dose accrued was 19.447 person-rem. The primary reasons for exceeding the estimated dose was identified as a lack of experience and poor job execution that led to increased man hours. This was documented in the licensees corrective action program as Action Request 00245959. This finding is greater than minor because it is associated with the Occupational Radiation Safety Cornerstone, exposure control attribute, and affected the cornerstone objective in that it caused increased collective radiation dose for occupational workers. The inspector determined this finding to be of very low safety significance because although the finding involved ALARA planning and work controls, the licensees latest three-year rolling average collective dose was less than 240 person-rem. Additionally, this finding had a cross-cutting aspect in the human performance area, associated with the work practices component, because the licensee failed to ensure supervisory and management oversight of work activities, including contractors, such that nuclear safety is supported. |
| 05000397/FIN-2012004-06 | 2012Q3 | Columbia | Failure to Maintain Dose ALARA due to Inadequate Job Planning | The inspector reviewed a self-revealing finding, with two examples, for failure to maintain doses as low as is reasonably achievable (ALARA) due to inadequate job planning. In the first example, the licensee estimated that Radiation Work Permit 30002636, R20 DW CRA-M/FN Maintenance and Repairs LHR, would accrue 10.549 person-rem (as revised), but actually accrued 22.657 person-rem. In the second example, the licensee originally estimated that ALARA Task 11824040102 attached to Radiation Work Permit 30002684, R20 RF Wetwork Invessel, SFP, and Equipment Pool HR, would accrue 3.557 person-rem, but the actual dose accrued was 11.683 person-rem. The primary reason for exceeding the estimated dose was identified as inadequate job planning. This was documented in the licensees corrective action program as Action Requests 00238694 and 00239554, respectively. This finding is greater than minor because it is associated with the Occupational Radiation Safety Cornerstone, exposure control attribute, and affected the cornerstone objective in that it caused increased collective radiation dose for occupational workers. The inspector determined this finding to be of very low safety significance because although the finding involved ALARA planning and work controls, the licensees latest three-year rolling average collective dose was less than 240 person-rem. This finding had a cross-cutting aspect in the human performance area, associated with the work control component, because the licensee failed to incorporate job site conditions, including plant structures, systems, and components, human-system interface, radiological safety, and planned contingencies and compensatory actions to be consistent with nuclear safety. |
| 05000397/FIN-2012004-07 | 2012Q3 | Columbia | Failure to Identify a Performance Weakness During a Drill | A non-cited violation of 10 CFR 50.47(b)(14) was identified for the licensees failure to identify a deficiency occurring during a drill to ensure correction. Specifically, the licensee did not identify a failure to provide accurate information in the notification of an Alert. Corrective actions for the inaccurate notification were not implemented because the deficiency was not identified. The failure to identify a deficiency during a drill is a performance deficiency within the licensees control. The licensee has entered this issue into their corrective action program as Action Request 00269740. This finding is more than minor because failures to identify and correct deficiencies affect the Emergency Response Organization Performance Cornerstone attribute. The finding was evaluated using the Emergency Preparedness Significance Determination Process and was identified as having very low safety significance because it was a failure to comply with NRC requirements and was not a loss of the planning standard function. The planning standard function was not lost because the failure to identify weak performance occurred in a limited-scope drill. The finding was assigned a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action program Low Threshold component because the licensee failed to completely and accurately recognize a performance deficiency. |
| 05000397/FIN-2012004-08 | 2012Q3 | Columbia | Failure to Establish Conservative Electronic Dosimeter Alarm Set-points | A non-cited violation of Technical Specification 5.4.1a was identified for the failure to follow station procedures and establish conservative electronic dosimeter set-points prior to entering the radiologically controlled area during emergency preparedness exercises and drills. On August 28, 2012, during the emergency preparedness exercise, the licensee used an exercise radiation work permit that established electronic dosimeter set-points of 5 millirem dose and 50 millirem per hour dose rate. As part of the exercise scenario, the inspectors observed Operations Support Center personnel demonstrate the ability to raise electronic dosimeter alarm set-points to 200 millirem dose and 1000 millirem/hour. However, prior to entering the plants actual radiologically-controlled area the licensee failed to re-establish conservative electronic dosimeter set-point values for the entry in accordance with Station Procedure GEN-RPP-02, ALARA Planning and Radiation Work Permits, Revision 29, and Radiation Work Permit 30002943. The inspectors also identified eight additional occurrences of non-conservative dosimeter set-points when entering the radiologically controlled area during previous exercises and drills. The licensee entered this issue into the corrective action program as Action Request AR 269790. The finding was more than minor because it was associated with the program and process attribute of the Occupational Radiation Safety Cornerstone and adversely affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material, and if left uncorrected, it would potentially result in unplanned radiation exposure. The inspectors evaluated the finding using Inspection Manual Chapter 0609 Appendix C, Occupational Radiation Safety Significance Determination Process, dated August 19, 2008. The inspectors determined that the finding was of very low safety significance because it did not: (1) involve ALARA planning and work controls; (2) result in an overexposure; (3) involve a substantial potential for overexposure; and (4) compromise the licensees ability to assess dose. In addition, the finding had human performance cross-cutting aspects associated with work control because interdepartmental communication, coordination, and cooperation was necessary to assure plant and human performance. |
| 05000397/FIN-2012004-01 | 2012Q3 | Columbia | Failure to Enter Applicable LCO for Offsite Power | The inspectors identified a non-cited violation of Technical Specification 3.8.1, AC Sources Operating, for the licensees failure to enter and take required actions contained in Technical Specification 3.8.1, Condition A, when removing startup transformer feeder breakers from service for planned maintenance activities. Upon identification the licensee issued Night Order 1411 which documented that if the startup transformer is unable to supply all safety-related busses then the startup transformer offsite power source should be considered inoperable. The licensee entered this issue into the corrective action program as Action Request AR 271413. This performance deficiency was more than minor because it affected the configuration control attribute of the Mitigating Systems Cornerstone objective of ensuring the availability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, the inspectors determined the performance deficiency was of very low safety significance (Green) because the finding did not represent a loss of safety function, did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time, and did not represent an actual loss of function of one or more non-technical specification equipment for greater than 24 hours. The inspectors determined that this finding had a cross-cutting aspect in the area of human performance associated with the resources component because the licensee failed to ensure that work packages were complete, accurate, and up-to-date. Specifically, the licensee failed to specify the potential technical specification surveillance requirement impacts when authorizing maintenance on startup transformer feeder breakers. |
| 05000397/FIN-2012004-09 | 2012Q3 | Columbia | Failure to Follow Radiation Work Permit Requirements to Inform Workers about Radiological Conditions | A non-cited violation of Technical Specification 5.4.1.a was identified for the failure to follow radiation work permit requirements to brief workers on the radiological conditions in the work area and to provide workers current radiological survey information. On August 28, 2012, during the biennial graded emergency preparedness exercise, mock repair teams entered the radiologically controlled area without being briefed on the actual radiological conditions and without being provided with current radiological survey information. The licensee entered this issue into their corrective action program as Action Request AR 269791. The finding was more than minor because it was associated with the Occupational Radiation Safety Cornerstone exposure control attribute of program and process and it affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material because it could have increased worker exposure while in the radiologically-controlled area. The inspectors evaluated the finding using Inspection Manual Chapter 0609 Appendix C, Occupational Radiation Safety Significance Determination Process, dated August 19, 2008. The inspectors determined that the finding was of very low safety significance because it did not: (1) involve ALARA planning and work controls; (2) result in an overexposure; (3) involve a substantial potential for overexposure; and (4) compromise the licensees ability to assess dose. In addition, the finding had human performance cross-cutting aspects associated with resources because the licensee did not ensure that complete, accurate, and up-to-date documentation (radiological surveys) were adequate to ensure radiological safety. |
| 05000397/FIN-2012004-10 | 2012Q3 | Columbia | Licensee-Identified Violation | Technical Specification 5.4.1.a, Procedures, requires, in part, that written procedures be established, implemented, and maintained as recommended in Regulatory Guide 1.33, Revision 2, Appendix A, dated February 1978. Paragraph 9.a of Regulatory Guide 1.33, Appendix A, requires that maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. Contrary to the above, on July 3, 2012, Work Order 01196946-02 was not appropriate to the circumstances because it did not include seismic design considerations and did not provide reference elevations for workers performing excavation near service water valve SW-V-933A. Consequently, the licensee on July 3, 2012, over-excavated near SW-V-933A when performing buried piping inspections. This finding was identified by the licensee and entered in the licensees corrective action program as Action Requests AR 266400 and 266405. This finding was determined to be of very low safety significance because it was a design or qualification deficiency confirmed not to result in a loss of operability. |
| 05000445/FIN-2012003-01 | 2012Q3 | Comanche Peak | Failure to Analyze Tornado Missile Strike on Turbine Driven Auxiliary Feedwater Exhaust Pipe | The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, for the failure to translate tornado missile protection design requirements to a pipe stress analysis procedure. This resulted in the licensees failure to analyze the effects of a tornado missile strike on the turbine driven auxiliary feedwater pumps steam exhaust piping. The licensee preliminarily determined that the auxiliary feedwater system would be able to perform its safety function given a tornado missile strike. The licensee entered the finding into the corrective action program as Condition Report CR-2012-006134. The licensees failure to analyze the effects of a tornado missile strike on the turbine driven auxiliary feedwater pump steam exhaust pipes was a performance deficiency. The finding was more than minor because it was associated with the protection against external events attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to ensure the reliability of the auxiliary feedwater system in response to a tornado missile hazard. Using NRC Manual Chapter 0609, Significance Determination Process, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, the finding was determined to be of very low safety significance because it was a qualification deficiency confirmed not to result in loss of operability or functionality. The finding did not have a cross-cutting aspect because the performance deficiency was not representative of current plant performance. |
| 05000445/FIN-2012003-02 | 2012Q3 | Comanche Peak | Failure to Revise Turbine Driven Auxiliary Feedwater Pump Acceptance Criteria | The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XI, for the failure to incorporate acceptance limits from applicable design documents into test procedures. Specifically, the licensee revised the Unit 1 and Unit 2 requirement for the turbine driven auxiliary feedwater pump discharge pressure for a power uprate, but failed to incorporate the change into the pump surveillance procedures. As a result, the acceptance criteria were incorrect and nonconservative. The pumps were able to meet the revised acceptance criteria and perform their safety function. The licensee entered the finding into the corrective action program as Condition Report CR-2012-006135. The licensees failure to update the turbine driven auxiliary feedwater surveillance procedure acceptance criteria following an accident analysis revision was a performance deficiency. The finding was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern, in that, if the turbine driven auxiliary feedwater pump performance degraded below the accident analysis assumptions, the surveillance would not detect the inoperability and corrective actions would not be taken. Using NRC Manual Chapter 0609, Significance Determination Process, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, the finding was determined to be of very low safety significance in the mitigating systems cornerstone because it was not a design or qualification deficiency, was not a loss of system safety function, was not an actual loss of 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. The finding did not have a cross-cutting aspect because the performance deficiency was not representative of current plant performance. |
| 05000445/FIN-2012003-04 | 2012Q3 | Comanche Peak | Failure to Take Corrective Actions for Safety Chiller Trips | The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, for the failure to identify and correct a condition adverse to quality. Specifically, safety chiller 2-06 tripped twice, but the licensee failed to develop corrective actions or provide any justification for not taking corrective actions. The licensee entered the finding into the corrective action program as Condition Report CR-2012-006136. The licensees failure to identify and correct a condition adverse to quality related to two safety chiller trips was a performance deficiency. The finding was 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 of systems that respond to initiating events to prevent undesirable consequences. Specifically, the safety chillers are unavailable while they are tripped. Using NRC Manual Chapter 0609, Significance Determination Process, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, the finding was determined to be of very low safety significance because it was not a design or qualification deficiency, was not a loss of system safety function, was not an actual loss of 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. The finding has a problem identification and resolution cross-cutting aspect associated with the corrective action program because the licensee failed to thoroughly evaluate the problem such that the resolution addresses the cause. |
| 05000397/FIN-2012003-04 | 2012Q2 | Columbia | Licensee-Identified Violation | Title 10 CFR, Part 50, Appendix B, Criterion III, Design Control, requires, in part, that measures be established to assure that the design basis for structures, systems, and components are correctly translated into specifications, procedures, and instructions. Contrary to the above, prior to April 10, 2012, the licensee failed to translate the correct flow coefficient for residual heat removal heat exchanger bypass valves RHR-V-48A and RHR-V-48B into Calculation 5.17.19 resulting in a calculated non-conservative pressure drop for the system. This non-conservative pressure drop was then translated into non-conservative acceptance criteria for Procedures OSP-RHR/IST-Q702, RHR Loop A Operability, Revision 0-33 and OSP-RHR/IST-Q703, RHR Loop B Operability Test, Revision 0-33. This finding was entered into the corrective action program as Action Request AR 261930. This finding was determined to be of very low safety significance because it represented a design or qualification deficiency confirmed not to result in a loss of operability. |
| 05000397/FIN-2012003-05 | 2012Q2 | Columbia | Licensee-Identified Violation | Technical Specification 5.4.1.a, Procedures, requires, in part, that written procedures be established, implemented, and maintained as recommended in Regulatory Guide 1.33, Revision 2, Appendix A, dated February 1978. Paragraph 6 of Regulatory Guide 1.33, Appendix A, requires specific procedures for combating emergencies or other significant events. Contrary to the above, prior to April 6, 2012, licensee Procedure PPM 5.2.1, Primary Containment Control, Revisions 0-19 were inadequate because Table 27 of the procedure provided direction to vent primary containment based on values that were not consistent with the Offsite Dose Calculation Manual offsite radioactivity release limits. This finding was entered into the corrective action program as Action Request AR 260848. This finding was determined to be of very low safety significance because the procedure, as written, created a degraded condition that had potentially important implication for the integrity of containment, but would not have an impact on large early release frequency. |
| 05000397/FIN-2012003-03 | 2012Q2 | Columbia | Failure to Properly Control High Energy Line Break Barriers | The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, for the failure of the licensee to control impairment of high energy line break barriers in accordance with Procedure PPM 1.3.57, Barrier Impairment, Revision 28. On May 6, 2012, the licensee performed Surveillance Procedure ISP-CIA-Q901, ADS Accumulator Backup Low Pressure Alarm Division 1 CFT/CC, Revision 7. A high energy line break barrier associated with instrument rack E-IR-67 was breached and left unattended during the surveillance. The licensee failed to meet requirements specified in Procedure PPM 1.3.57, Barrier Impairment, Revision 28, which required a barrier impairment permit for the high energy line break barrier that was breached. Additionally, the inspectors determined that the licensee failed to declare inoperable and unavailable, all equipment impacted by the breached high energy line break barrier on instrument rack E-IR-67. As interim corrective action, the licensee initiated Night Order 1379 directing a more complete review of Procedure PPM 1.3.57 prior to work authorization on components that serve as hazard barriers. This issue was entered into the licensees corrective action program as Action Request AR 263274. This performance deficiency was more than minor because it affected the configuration control attribute of the Mitigating Systems Cornerstone objective of ensuring the availability of systems that respond to initiating events. The inspectors performed an initial screening of the finding in accordance with IMC 0609.04, Phase 1 - Initial Screening and Characterization of Findings. The inspectors determined this finding to be of very low safety significance (Green) because it did not result in the loss of a system safety function, did not represent the loss of safety function of a single train for greater than its allowed outage time, did not result in the loss of safety function of any non-technical specification equipment, and did not screen as potentially risk significant due to seismic, flooding, or severe weather initiating events. The inspectors determined that this finding had a cross-cutting aspect in the area of human performance associated with the resources component because the licensee failed to update surveillance procedures associated with high energy line break barriers such that individuals responsible for maintaining those barriers were knowledgeable of the requirements in Procedure PPM 1.3.57 |
| 05000397/FIN-2012003-02 | 2012Q2 | Columbia | Failure to Establish Adequate Postmaintenance Tests for Replacement of Division 3 Safety Related Batteries | The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, for the failure of the licensee to perform a required postmaintenance test of the division 3 safety-related batteries prior to system restoration. On May 22, 2012, the licensee replaced the division 3 safety-related battery HPCS-B1-DG3 under Work Order 02000618. The resident inspectors reviewed the work orders associated with the replacement of battery HPCS-B1-DG3 and identified that the licensee failed to incorporate either a modified performance discharge test or a battery service test into their postmaintenance testing for battery HPCS-B1-DG3 and restored the equipment to operable without meeting Technical Specification Surveillance Requirement 3.8.4.3. Following identification, the licensee performed a battery service test and determined that the division 3 battery capacity was adequate to meet all operability requirements. The licensee initiated corrective action documents Action Requests AR 264204 and AR 264214 to address the failure to include all technical specification requirements into postmaintenance testing for battery HPCS-B1-DG3. This performance deficiency was more than minor because it affected the configuration control attribute of the Mitigating Systems Cornerstone objective of ensuring the reliability of systems that respond to initiating events. The inspectors performed an initial screening of the finding in accordance with IMC 0609.04, Phase 1 - Initial Screening and Characterization of Findings. The inspectors determined this finding to be of very low safety significance (Green) because the finding was a qualification deficiency confirmed not to result in loss of operability. The inspectors determined that this finding had a cross-cutting aspect in the area of human performance associated with the decision making component because the licensee failed to obtain an interdisciplinary review on the postmaintenance testing planned for battery HPCS-B1-DG3. Specifically, the shift manager failed to request input from system engineering and licensing on the decision to not perform a battery service test. |
| 05000397/FIN-2012003-01 | 2012Q2 | Columbia | Failure to Evaluate Operability Associated with Residual Heat Removal Pump B | The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, for the failure of the licensee to perform a required operability determination for a degraded condition associated with residual heat removal pump B. On March 25, 2012, the licensee performed Procedure OSP-RHR/IST-Q703, RHR Loop B Operability Test, Revision 34, and recorded a pump discharge pressure that exceeded the acceptance criteria by 0.03 psig. The operating crew determined that no immediate operability determination was required by Procedure PPM 1.3.66, Operability and Functionality Evaluation, Revision 20, since pump performance was stable and satisfactory. Subsequent review by the inspectors revealed that the assumption that pump performance was stable and satisfactory was not correct and an operability determination was required. Specifically, pump discharge pressure dropped below the technical specification surveillance requirement acceptance criteria at several points after the licensee had recorded their data and the pump had exhibited a declining trend in performance since its last surveillance. This issue was entered into the licensees corrective action program as Action Request AR 266371. This performance deficiency was more than minor because it affected the equipment performance attribute of the Mitigating Systems Cornerstone objective of ensuring the reliability of systems that respond to initiating events. The inspectors performed an initial screening of the finding in accordance with IMC 0609.04, Phase 1 - Initial Screening and Characterization of Findings. The inspectors determined this finding to be of very low safety significance (Green) because it did not result in the loss of a system safety function, did not represent the loss of safety function of a single train for greater than its allowed outage time, did not result in the loss of safety function of any non-technical specification equipment, and did not screen as potentially risk significant due to seismic, flooding, or severe weather initiating events. The inspectors determined that this finding had a cross-cutting aspect in the area of human performance associated with the decision making component because the licensee failed to use conservative assumptions when evaluating Action Request AR 260478 that documented low margin for residual heat removal pump B. Specifically, the shift manager failed to challenge the non-conservative assumption that pump flow was stable and satisfactory. |
| 05000498/FIN-2012002-02 | 2012Q1 | South Texas | Licensee-Identified Violation | Technical Specification 6.8.1.a requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures in Appendix A of Regulatory Guide 1.33, Revision 2. Regulatory Guide 1.33, Appendix A, Section 8(1) (dd) recommends procedures for surveillance tests. Procedure 0PSP03-MS-0001, Main Steam System Valve Operability Test, Revision 38, step 5.9.25 stated, PLACE SG PORV STATION BLACKOUT PWR PV-7441 in BYP position (EAB 10, Rm 015, ASP, ZLP-100). Contrary to the above, on January 31, 2012, during a surveillance test on steam generator 1D power operated relief valve, a non-licensed operator failed to review and implement the procedure step as written. The finding was of very low safety significance because it did not result in a loss of system safety function; it was not inoperable for longer than its technical specification allowed outage time; and it was not risk significant due to seismic, flooding, or severe weather initiating event. This item was entered into the corrective action program as Condition Report 12-5448. |
| 05000498/FIN-2012002-01 | 2012Q1 | South Texas | Licensee-Identified Violation | Technical Specification 3.4.1.4.2.b requires that, each valve or mechanical joint used to isolate unborated water sources shall be secured in the closed position. Contrary to the above since 2003, when the recycle holdup tanks were used to fill the reactor coolant system, boron recovery system valves BR-204 and BR-205 were closed but not secured (locked). The inspectors used Manual Chapter 0609, Appendix G, and determined that the finding was of very low safety significance because there was no reactivity change that warranted a quantitative risk analysis. This item was entered into the corrective action program as Condition Report 11-7747 |
| 05000416/FIN-2011006-02 | 2011Q4 | Grand Gulf | Failure to Report a Condition Prohibited by Technical Specifications | The team identified a Severity Level IV noncited violation of 10 CFR 50.73, Licensee Event Report System, associated with the licensee\'s failure to submit a licensee event report within 60 days following discovery of an event meeting the reporting criteria as specified. Specifically, the licensee was not meeting the technical specification surveillance requirement for venting the reactor core cooling isolation system and subsequently the system was inoperable in excess of the allowed outage time which constituted a condition prohibited by technical specifications. The licensee entered this condition into their corrective action program as condition report CR-GGN- 2011-8890. This finding affects the mitigating systems cornerstone and is greater than minor because the NRC relies on licensees to identify and report conditions or events meeting the criteria specified in the regulations in order to perform its regulatory function. Because this issue affected the NRC\'s ability to perform its regulatory function, it was evaluated with the traditional enforcement process. Consistent with the guidance in Section 6.9 of the Enforcement Policy, this finding was determined to be a Severity Level IV noncited violation. This finding has no crosscutting aspect, as it is not indicative of current performance. |
| 05000416/FIN-2011006-06 | 2011Q4 | Grand Gulf | Licensee-Identified Violation | Title 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires that the licensee establish measures to promptly identify and correct conditions adverse to quality. Contrary to this requirement, the licensee failed to adequately correct a condition adverse to quality. Specifically, on February 4,2010 in response to non cited violation NCV 05000416/2009008-01, Inadequate Procedure Used to Vent the Reactor Core Isolation Cooling System. The licensee took ineffective action to address a failure to meet Technical Specification Surveillance Requirement 3.5.3.1 when changing the procedure for venting the discharge piping for the reactor core isolation cooling system, Procedure 06-0P-1 E51-M-0001, Reactor Core Isolation Cooling System Operability Verification. This change was inadequate in that it did not ensure the piping was full of water because it vented piping and then performed confirmatory ultrasonic testing. The issue was entered in to the corrective action program as condition report CR-GGN- 2011-07675, in which the licensee resolved this is by changing the procedure. finding is of very low safety significance (Green) because the system was always functional. |
| 05000416/FIN-2011006-05 | 2011Q4 | Grand Gulf | Licensee-Identified Violation | Title 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires that licensees promptly identify and correct conditions adverse to quality. Contrary to this requirement, the licensee failed to correct a condition adverse to quality. Specifically, on November 9, 2010, licensee was issued a noncited violation for the failure to properly assess the risk impact of maintenance on the switchyard batteries. The issue was entered in to the corrective action program as condition report CR-GGN-201 0-6668. On October 4, 2011, the licensee identified that the actions taken per condition report CR-GGN-201 0-6668 did not adequately address the noncited violation in that the corrective action was focused on the work being performed on the batteries versus appropriately evaluating the heavy work being performed in the switchyard. The licensee entered this issue into its corrective action program as condition report CR-GGN-2011-0767 4. The finding is of very low safety significance (Green) because it does not contribute to both the likelihood or a reactor trip and the likelihood that mitigation equipment or functions will not be available. |
| 05000416/FIN-2011006-04 | 2011Q4 | Grand Gulf | Inadequate Corrective Action for a Leak on the Division II Emergency Diesel Generator Lube Oil Sump | The team identified a Green cited violation of 10 CFR 50 Appendix 8, Criterion XVI, Corrective Actions, for the failure to promptly identify and correct a leak on the Division II emergency diesel generator lube oil sump. Despite identification of the leak in 2004, ineffective attempts to repair the leak and previous identification by the NRC in 2009, the licensee disposition the leak as accept as-is without a full understanding of the lube oil sump leak and potential consequences. The licensee entered this condition into their corrective action program as condition report CR-GGN-2011-8880. The condition was discovered and documented by the licensee in 2004. This finding was initially determined by the NRC to be a minor violation in 2009. Paragraph F of Section 2.10 of the NRC Enforcement Manual states in part that where a licensee does not take corrective action for a minor violation, the matter should be considered more than minor and associated with a green inspection finding and disposition in a cited or noncited violation, as appropriate. This finding is now determined to be more than minor because if left uncorrected the failure to restore the lube oil sump for the Division II emergency diesel generator to design conditions would have the potential to lead to a more significant safety concern, specifically, the leak could worsen and potentially affect operability of the emergency diesel generator. Due to the licensee\'s failure to restore compliance within a reasonable time after the violation was identified, this violation is being cited as a Notice of Violation consistent with Section 2.3.2 of the Enforcement Policy. This finding affects the mitigating systems cornerstone. Using Manual Chapter 0609.04, Phase 1 - Initial Screening and Characterization of Findings, this finding was of very low safety significance because it did not create a loss of system safety function of a single train for greater than the technical specification allowed outage times, and did not affect seismic, flooding, or severe weather initiating events. This finding has a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action program component because the licensee failed to thoroughly evaluate this problem such that the resolutions addressed the causes. |
| 05000416/FIN-2011006-03 | 2011Q4 | Grand Gulf | Failure to Document a Condition as a Significant Condition Adverse to Quality | The team identified a Green noncited violation of 10 CFR 50 Appendix 8, Criterion XVI, Corrective Actions, for the failure to identify and document a significant condition adverse to quality and report the condition to appropriate levels of management. As a result, a root cause analysis was not performed and more comprehensive actions to prevent recurrence were not considered for the condition. The licensee entered this condition into their corrective action program as condition report CR-GGN-2011- 07671, to address the problem. This finding is more than minor because it is associated with the protection against external factors attribute of the mitigating systems cornerstone and affects the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Manual Chapter 0609.04, Phase 1 - Initial Screening and Characterization of Findings, this finding was of very low safety significance (Green) because it did not create a loss of system safety function of a single train for greater than the technical specification allowed outage times, and did not affect seismic, flooding, or severe weather initiating events. This finding has a cross-cutting aspect in the area of human performance associated with the resources component because the licensee\'s procedures for significant conditions adverse to quality were not complete and accurate enough to prevent the condition. |
| 05000416/FIN-2011006-01 | 2011Q4 | Grand Gulf | Failure to Take Timely Corrective Actions for Reactor Core Isolation Cooling System Venting | The team identified a Green noncited violation of 10 50 Appendix Criterion XVI, Corrective Actions, for the failure to promptly identify and correct an inadequate venting procedure for the reactor core isolation cooling system. Corrective actions were not taken in a timely enough manner such that resolution was reached prior to time to demonstrate the licensee met their applicable technical specification surveillance requirement. The licensee entered this condition into their corrective action program as condition report CR-GGN-2011-07669 and subsequently altered their procedure, which performs the technical specification surveillance requirement to demonstrate that it meets the applicable requirements. This finding is more than minor because it affects the procedure quality attribute of the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Manual Chapter 0609.04, Phase 1 - Initial Screening and Characterization of Findings, this finding was of very low safety significance because it did not create a loss of system safety function of a single train for greater than the technical specification allowed outage times, and did not affect seismic, flooding, or severe weather initiating events. This finding has a cross-cutting aspect in the area of human performance associated with the decision making component. The licensee did not use conservative assumptions when deciding to pursue corrective action for venting of the reactor core isolation cooling system piping to demonstrate their action was safe in order to proceed rather than demonstrating it was unsafe to disapprove the action. |
| 05000498/FIN-2011004-01 | 2011Q3 | South Texas | Failure to Follow Standby Diesel Generator Maintenance Procedures | The inspectors reviewed a self-revealing noncited violation of Technical Specification 6.8.1.a, for the failure to follow maintenance work authorization number 416904. Specifically on January 27, 2011, mechanics incorrectly aligned the fuel oil delivery valve stop and spring on standby diesel generator 13 cylinder 1R. On July 17, 2011, the control room received an alarm for standby diesel generator 13 because the crankcase lubricating oil level was high out of band. After operability testing on July 15, 2011, fuel oil leaked through cylinder 1R into the crankcase because the spring broke creating foreign material that fouled the injector nozzle. The licensee corrected the error, replaced the spring, and restored operability of the diesel. The finding was more than minor because it affected the Mitigating Systems Cornerstone attribute of Human Performance, and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences because it caused the diesel to be inoperable. The inspectors used NRC Inspection Manual Chapter 0609, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings, dated January 10, 2008, to determine the significance of the finding because it affected the Mitigating Systems Cornerstone while the plant was at power. The finding was determined to be of very low safety significance because it was not a design or qualification deficiency; it did not represent a loss of a system safety function; it did not represent the loss of a single train for greater than technical specification allowed outage time; it did not represent a loss of one or more nontechnical specification risk-significant equipment for greater than 24 hours; and it did not screen as potentially risk significant due to seismic, flooding, or severe weather. In addition, this finding had human performance cross-cutting aspects associated with work practices because the licensee did not communicate human error prevention techniques, such as self and peer checking, commensurate with the risk, such that the work activity was performed safely |
| 05000498/FIN-2011004-02 | 2011Q3 | South Texas | Inadequate Corrective Actions from an Inadequate Extent of Condition Review | The inspectors identified a noncited violation of 10 CFR Part 50, Appendix B, Criteria XVI, Corrective Action, for the failure to assure that conditions adverse to quality were promptly identified and corrected. Specifically, the licensee did not promptly identify and correct improperly installed temperature switches. On October 28, 2010, the Unit 2 essential cooling water vent fan 21A failed because the control power fuse blew due to an unused uninsulated wire. The root cause investigation determined that the unused wire had been installed when the switch was replaced in February 2005. The extent of condition review identified that a total of 60 switches had been replaced, but only one additional switch was verified and it also had an unused uninsulated wire. After inspector questioning, the licensee inspected the 12 actuation switches and determined that only the Unit 2 essential cooling water vent fans for trains A and C were affected. The licensee's corrective actions included: performing an immediate and prompt operability, performing training with the maintenance personnel on the procedural requirements for unused wires, and scheduling the inspection of the 48 high/high temperature switches commensurate with risk significance. The inspectors identified a noncited violation of 10 CFR Part 50, Appendix B, Criteria XVI, Corrective Action, for the failure to assure that conditions adverse to quality were promptly identified and corrected. Specifically, the licensee did not promptly identify and correct improperly installed temperature switches. On October 28, 2010, the Unit 2 essential cooling water vent fan 21A failed because the control power fuse blew due to an unused uninsulated wire. The root cause investigation determined that the unused wire had been installed when the switch was replaced in February 2005. The extent of condition review identified that a total of 60 switches had been replaced, but only one additional switch was verified and it also had an unused uninsulated wire. After inspector questioning, the licensee inspected the 12 actuation switches and determined that only the Unit 2 essential cooling water vent fans for trains A and C were affected. The licensee's corrective actions included: performing an immediate and prompt operability, performing training with the maintenance personnel on the procedural requirements for unused wires, and scheduling the inspection of the 48 high/high temperature switches commensurate with risk significance. |
| 05000498/FIN-2011004-03 | 2011Q3 | South Texas | Untimely Corrective Action to Correct an Inadequate Procedure | The inspectors identified a noncited violation of 10 CFR Part 50, Appendix B, Criteria XVI, Corrective Action, for the failure to assure that conditions adverse to quality were promptly identified and corrected. Specifically, the inspectors determined that operations had no instructions for manual control of the 4160 Vac load tap changing transformers. Procedure 0POP02-AE-0002, Transformer Normal Breaker and Switch Lineup, was not revised providing these instructions. In December 2010, Unit 2 experienced a material issue with the load tap changer, which required operations to take manual control of the load tap changer without procedure guidance. Subsequently, the licensee issued an operation's standing order to allow for manual operations, but did not revise the procedure. In May 2011, the licensee experienced another material condition issue with the Unit 2 load tap changer that required operations to take manual control of the load tap changer, but since the procedure was never revised, operations found themselves operating the plant outside of procedures again. Corrective actions included revising Procedure 0POP02-AE-0002, to include manual operation of the load tap changer, and training all the operations personnel on the new procedure. This finding was more than minor because it was associated with the Mitigating Systems Cornerstone attributes of Design Control and Procedure Quality, and it affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The deficiency resulted in operations not having any guidance on how to control the Units 1 and 2 train B 4160 Vac transformer load tap changer to ensure that the bus remained within technical specification surveillance requirement voltage limits. The inspectors performed the significance determination using NRC Inspection Manual Chapter 0609, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings, dated January 10, 2008, because it affected the Mitigating Systems Cornerstone while the plant was at power. The finding was determined to be of very low safety significance because it was not a design or qualification deficiency; it did not represent a loss of safety system function; it did not represent the loss of a single train for greater than technical specification allowed outage time; it did not represent a loss of one or more non-technical specification risk-significant equipment for greater than 24 hours; and it did not screen as potentially risk significant due to seismic, flooding, or severe weather. In addition, this finding had human performance cross-cutting aspects associated with decision making, in that, the licensee failed to communicate decisions and the basis for decisions to personnel who have a need to know the information to perform work safely. |
| 05000498/FIN-2011004-04 | 2011Q3 | South Texas | Licensee-Identified Violation | Technical Specification 3.0.4 requires, in part, that when a limiting condition for operation is not met, entry into a mode shall only be made when the associated actions permit continued operation in the mode for an unlimited period of time, or after performance of a risk assessment and establishment of risk management actions. In addition, Technical Specification 3.4.6.2 requires, in part, that while the plant is operating in Modes 1 through 4, unidentified reactor coolant system leakage shall be limited to 1.0 gallons per minute, and identified leakage shall be limited to 10.0 gallons per minute, or reduce to within limits within 4 hours, or be in Mode 3 within 6 hours and Mode 5 within the next 30 hours. Contrary to the above, the licensee failed to meet the requirements of Technical Specification 3.0.4, because Unit 2 entered Mode 4 on November 8, 2010, and Mode 3 on November 9, 2010, with unidentified leakage at approximately 2.0 gallons per minute, without reducing the leakage to within limits or transitioning to Mode 5 within the required timeframe; nor did they perform the required risk assessment or implement any risk management actions prior to making the mode changes. This violation was processed through significance determination process using Manual Chapter 0609, Appendix A, because the licensee had secured from using residual heat removal system in Mode 3. The finding was determined to be of very low safety significance because, assuming the worst case degradation, the finding would not have resulted in exceeding the 10 gallons per minute technical specification limit for reactor coolant system for identified leakage. The licensee entered this issue into their corrective action program as Condition Report 10-24488. |
| 05000498/FIN-2011004-05 | 2011Q3 | South Texas | Licensee-Identified Violation | Technical Specification 6.8.1.a requires the licensee to implement the procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, dated February 1978. Regulatory Guide 1.33, Appendix A, Section 9, Procedures for Performing Maintenance, Part a states, in part, that maintenance that can affect the performance of safety-related equipment should be properly performed in accordance with written procedures. Procedure 0PMP02-NZ-0013, "Cable Terminations," specifies how the licensee is to terminate unused cables to prevent damage to equipment. Contrary to the above, from February 2005 to March 2011, the licensee failed to correctly terminate the replacement Static-O-Ring temperature switch for one of the Unit 2 ECW train A vent fans. The finding was determined to be of very low safety significance because only one train of ECW was inoperable for less than the technical specification allowed outage time. The licensee entered this issue into the corrective action program as as Condition Report 10-23446. |
| 05000498/FIN-2011003-01 | 2011Q2 | South Texas | Inadequate Fire Protection System Functionality Procedure Results in Failure to Establish Fire Watches | The inspectors identified a noncited violation of license condition 2.E, Fire Protection Program, because of an inadequate procedure that resulted in the licensee failing to establish compensatory fire watches in eight fire zones with degraded fire detection equipment. On March 2, 2011, the inspectors reviewed fire impairments to ensure adequate compensatory actions were being implemented. The inspectors identified that fire watches were not implemented in several areas where the fire detection system was degraded because Procedure 0PGP03-ZF-0018, Fire Protection System Functionality Requirements, Revision 14, did not require a fire watch until greater than 50 percent of the fire detection functionality within the fire zone was degraded. The inspectors determined that the licensee failed to correctly copy the licensing basis NUREG-0452 technical specification requirements into the procedure. The licensees corrective actions included: (1) posting an hourly fire watch; (2) changing the procedure to correctly reflect licensing basis requirements; and (3) providing training to fire safety and operations personnel. The finding was more than minor because it was associated with the Mitigating Systems Cornerstone attribute of procedure quality and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, because the lack of compensatory measures could result in a delayed response to a fire. The inspectors performed the significance determination using NRC Inspection Manual Chapter 0609, Appendix F, dated February 28, 2005, because the finding affected fire protection defense-in-depth strategies, as described in NRC Inspection Manual Chapter 0609.04, Table 3b, Phase 1 - Initial Screening and Characterization of Findings, dated January 10, 2008. The finding was assigned to the fixed fire protection systems category with a degradation rating of moderate because compensatory measures were not in place for unoccupied fire areas that had greater than 10 percent degradation of fire detection equipment. Because the finding was a programmatic weakness where multiple fire areas lacked compensatory measures and it had a moderate degradation rating, the finding required a Phase 3 analysis be performed by a senior reactor analyst. The senior reactor analyst determined that the finding was of very low safety significance because there were no identified dominant core damage sequences, and, therefore, there was no quantifiable change to the core damage frequency. The functional fire detectors helped to mitigate the risk. This finding did not have cross-cutting aspects because the licensee had not made changes to this procedural requirement within the last 3 years, and therefore, was not indicative of current licensee performance. |
| 05000498/FIN-2011003-02 | 2011Q2 | South Texas | Inadequate Risk Assessment for Switchyard Activities | The inspectors reviewed a self-revealing noncited violation of 10 CFR 50.65(a)(4) for the failure to perform an adequate risk assessment to manage the increase in risk of performing activities in the switchyard. On September 26, 2010, the licensee removed 345 kVac circuit breaker Y530 from service for planned replacement. The replacement activities were performed by a contractor, however, the details of the work package were not provided to the licensee nor were they discussed. As a result of incorrect terminations, on September 30, 2010, when the work was completed and the contractors were performing testing, a false differential condition was sensed resulting in all the north bus breakers opening. This resulted in a loss of power to the standby transformer for Unit 1, de-energizing the train B engineered safety features bus. The loss of offsite power to the train B bus resulted in an engineered safety features actuation that started the train B standby diesel generator and actuated train B safety-related equipment. The licensees corrective actions included: (1) revising the switchyard management procedure to provide more detailed instructions for utilizing the switchyard coordinator in providing oversight and directing of switchyard activities; (2) specific instructions as to points of contact, details of switchyard work to be performed; and (3) specifying coping strategies and integrating the work control process with the management of switchyard activities. This finding was more than minor because it affected the Initiating Events Cornerstone attribute of protection against external factors and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. This deficiency directly resulted in loss of offsite power to the train B engineered safety features bus. The inspectors performed the significance determination using NRC Inspection Manual Chapter 0609.04, Phase 1 - Initial Screening and Characterization of Findings, dated January 10, 2008, because it affected the Initiating Events Cornerstone while the plant was at power. Because the finding affects the licensees assessment and management of risk the Phase 1 worksheet sent the inspectors to Attachment K, Maintenance Risk Assessment and Risk Management Significance Determination Process, dated May 19, 2005. This finding was determined to be of very low safety significance because it only impacted performance of risk managed actions not taken and the incremental core damage probability risk assessment increase of 6.3 E-13 was less than the 1 E-6 threshold. In addition, this finding had human performance cross-cutting aspects associated with work practices in that the licensee did not ensure supervisory and management oversight of work activities, including contractors, such that nuclear safety is supported. |
| 05000498/FIN-2011003-03 | 2011Q2 | South Texas | Licensee-Identified Violation | The licensee identified a Severity Level IV noncited violation of 10 CFR 50.9(a) for failure to provide information that was complete and accurate in all material respects regarding access authorization documentation required to be maintained by the licensee in accordance with 10 CFR 73.56(h)(1). Specifically, on March 7, 2007, the personal history questionnaire and criminal history self disclosure forms utilized by the South Texas Project reviewing official in making trustworthy and reliability determinations did not contain valid information regarding prior legal actions by an applicant. This information was material because it was used by the NRC in the performance of regulatory duties. The finding was more than minor because it impacted the NRCs ability to perform its regulatory function. Specifically, the licensee failed to ensure that personnel provide complete and accurate information to the NRC. This event is documented in the licensees corrective action program as Condition Report 10-2265. Because the violation involved the act of a low-level individual, it is being characterized as a Severity Level IV noncited violation. |
| 05000361/FIN-2010009-01 | 2011Q1 | San Onofre | Adequacy of Model Inputs Used in Restoration of Nuclear Concrete Containment Structures | The inspectors identified an unresolved item regarding the licensees engineering modeling inputs related to restoration of Unit 2 and 3 containment buildings. During the inspection, insufficient information was available to determine if newer industry standards are appropriate to apply in the licensee finite element modeling of concrete stresses. The inspectors also questioned if the alternate modeling was allowed by NRC approved codes. The licensee considered using the inputs from the newer industry standards as an analytical refinement and not a methodology change. The inspectors could not determine if the licensee properly applied the Title 10 CFR 50.59 process to conclude the new analysis did not involve a departure from approved methods of evaluation. To address the concern, a Technical Interface Agreement (TIA 2011-008) was initiated with the NRC Office of Nuclear Reactor Regulation. During performance of the inspection, the inspectors reviewed three related engineering calculations and the screening required by 10 CFR 50.59 associated with the SONGS Unit 3 containment restoration. The licensee performed calculations and evaluations of the structural integrity of the restored containment building. The calculations reviewed in conjunction with the inspection referenced models and equations from two contemporary reports; ACI 209R-92, Prediction of Creep, Shrinkage, and Temperature Effects in Concrete Structures, and ACI 224.2R-92, Cracking of Concrete Members in Direct Tension. These two ACI reports were not referenced in the licensees concrete construction code of record, which is ACI 318-71, Building Code Requirements for Reinforced Concrete, and BC-TOP-5, Prestressed Concrete Nuclear Reactor Containment Structures. These reports were also not referenced in the licensees final safety analysis report. The NRC determined the licensees 10 CFR 50.59 evaluation did not address the referenced models and equation inputs from ACI 209R-92 and ACI 224.2R-92. Upon further questioning by the NRC about the appropriate use of the inputs, engineering personnel concluded that inputs from these reports did not represent a change in methodology to the original approved evaluation, in part, because the inputs were needed to address cracking, as required per the original analysis and was considered a calculation refinement. Pending review of documentation to determine if inputs from these reports do represent a change in methodology as described in the 10 CFR 50.59 evaluation, this issue will remain an Unresolved Item (URI) and tracked as URI 05000362/2010009-01; Adequacy of Model Inputs Used in Restoration of Concrete Containment Structures. |
| 05000498/FIN-2010007-03 | 2011Q1 | South Texas | Transfer of Station Blackout Requirements from Current Licensing Basis into Final Safety Analysis Report | The team identified that Surveillance Test 32345357, 125 Volt Class 1E Battery Modified Performance Surveillance Test, discharge time was terminated at 03:25:59 for the 125 V DC batteries and that the licensee had never tested their batteries to the established station blackout design requirements (battery duty cycle) in the current licensing basis that specified a 4-hour duty cycle. The licensee argued that no testing requirements were violated, because they were licensed as an alternate alternating current plant, and as a result, did not have to perform a coping analysis as defined by Regulatory Guide 1.155, Station Blackout, and NUMARC 87-00, Guidelines and Technical Bases for NUMARC Initiatives Addressing Station Blackout at Light Water Reactors. The team reviewed all of the provided licensing and design basis documents that addressed station blackout battery capacity, but did not see any indication that the licensee was an approved alternate alternating current plant. Additionally, the licensee was unable to provide any documentation that showed that they were an alternate alternating current plant capable of starting in 10 minutes and did not require a coping analysis. After discussions, the licensee acknowledged that their Final Safety Analysis Report was not completely accurate on the subject of station blackout battery testing and was unclear on whether they were an alternate alternating current plant. To resolve this matter, the NRC is waiting on the licensee's submittal to NRR clarifying their current licensing basis. Upon completion, the NRC can complete the inspection and review of this unresolved item: URI 05000498;05000499/2010007-03, Transfer of Station Blackout Requirements from Current Licensing Basis into Final Safety Analysis Report. |
| 05000445/FIN-2010003-01 | 2010Q2 | Comanche Peak | Failure to Follow the Radiation Work Permit Requirements | Inspectors identified a noncited violation of Technical Specification 5.4.1.a for the failure of a rigger to follow radiation work permit requirements. Specifically, a rigger made an unauthorized entry into a high radiation area on a radiation work permit that did not grant access to that area. A radiation protection technician confirmed that the rigger was not briefed and not authorized to enter the high radiation area and had the rigger exit the area. The licensee entered the finding into the corrective action program as Condition Report CR-2010-003458 The failure to follow the instructions on a radiation work permit was a performance deficiency. The finding was more than minor because it was associated with the program and process attribute of the occupational radiation safety cornerstone and affected the cornerstone objective, in that, the failure to follow a radiation work permit instruction had the potential to increase personnel dose. Using NRC Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, the finding was determined to be of very low safety significance because: (1) it was not associated with as low as reasonably achievable (ALARA) planning or work controls, (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 has a human performance crosscutting aspect associated with work practices because the licensee failed to effectively communicate expectations regarding procedural compliance to the rigger. |
| 05000445/FIN-2010003-02 | 2010Q2 | Comanche Peak | Failure to Barricade and Post a High Radiation Area | The inspectors reviewed a self-revealing noncited violation of Technical Specification 5.7.1.a for the failure to maintain a high radiation area barricaded and conspicuously posted. A high radiation area in the Unit 1 containment was posted as a radiation area. Consequently, an individual received unexpected electronic dosimeter dose rate alarm while building scaffolding in the Unit 1 containment building because the worker entered a high radiation area without the knowledge that the dose rates measured 145 millirem per hour. Subsequently, a radiation protection technician barricaded the area with rope and posted it as a high radiation area. The licensee entered the finding into the corrective action program as Condition Report CR-2010-003382 The failure to barricade and post a high radiation area was a performance deficiency. The finding was more than minor because it was associated with the program and process attribute of the occupational radiation safety cornerstone and affected the cornerstone objective, in that, the failure to properly control a high radiation area had the potential to increase personnel dose. Using NRC Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, the finding was determined to be of very low safety significance because: (1) it was not associated with as low as reasonably achievable (ALARA) planning or work controls, (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 has a human performance crosscutting aspect associated with work control because the licensee did not appropriately plan work activities by incorporating job site conditions or radiological safety. |