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05000293/FIN-2013005-012013Q4PilgrimFailure to Provide Adequate Justification to Extend the 12-Month Review Frequency of the Emergency Preparedness ProgramThe inspectors identified an NCV of Title 10 of the Code of Federal Regulations (10 CFR) Part 50.54(t)(1), Conditions of Licenses, for failure to provide adequate justification to extend the review of the emergency preparedness program elements. Specifically, Entergy did not base its justification on an adequate assessment against a set of performance indicators. The failure to provide justification based on an adequate assessment against performance indicators to exceed the 12-month interval to perform a review of its emergency preparedness program elements is a performance deficiency within Entergys ability to foresee and correct. The finding is more than minor because it affected the emergency response organization (ERO) readiness, facilities and equipment, procedure quality, and ERO performance attributes of the emergency preparedness cornerstone. This finding is of very low safety significance (Green) because it was a failure to comply with NRC requirements and was not associated with the planning standards of 10 CFR 50.47(b), Emergency Plans. Entergy entered this issue into its CAP as CR-PNP-2013-07463. This finding was assigned a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program component, because Entergy did not thoroughly evaluate the issue identified in 2009 and did not implement corrective actions to address the issue.
05000293/FIN-2013005-022013Q4PilgrimFailure to Perform Plant Level Maintenance Rule MonitoringThe inspectors identified a finding (FIN) associated with Entergy Nuclear Operations, Inc. (Entergy) procedure EN-DC-204, Maintenance Rule Scoping and Basis, because Entergy did not perform plant level monitoring in accordance with the criteria set forth therein. Specifically, the plant level performance criteria of Unplanned Scrams and Unplanned Power Changes were not monitored as Maintenance Rule performance criteria. Entergy entered this issue into its corrective action program (CAP) as condition report (CR)-PNP-2013-8114. The performance deficiency was more than minor because if left uncorrected it would have the potential to lead to a more significant safety concern, and because it is associated with the equipment performance attribute of the Initiating Events cornerstone and the associated cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, failure to monitor the plant against the required performance criteria and subsequent failure to evaluate for functional failures can result in the inability to identify systems that are not effectively being maintained and can contribute to events that upset plant stability and contribute to a significant event. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) because the finding was not a design or qualification deficiency, did not represent an actual loss of system safety function, did not represent an actual loss of safety function of a single train or two separate safety systems for greater than the technical specification allowed outage time, and did not represent an actual loss of safety function of one or more non-technical specification trains of equipment designated as risk significant in accordance with Entergys maintenance rule program. The finding has a cross-cutting aspect in the area of Human Performance, Resources component, because Entergy did not ensure that procedures are available and adequate to assure nuclear safety. Specifically, Entergy did not ensure that Maintenance Rule Bases Documents were updated to include all monitoring criteria requirements set forth in EN-DC-204.
05000334/FIN-2013004-012013Q3Beaver ValleyLicensee-Identified ViolationThe Beaver Valley Power Station Unit 2 Technical Specification limiting condition for operation (LCO) 3.5.2 requires two trains of emergency core cooling system (ECCS) to be operable in Modes 1, 2, and 3. Contrary to the above, on June 17, 2013 to June 24, 2013, FENOC failed to have two trains of ECCS operable in Mode 1 which existed for greater than the allowed restoration and shutdown completion times of the LCO due to inadequate procedures that resulted in gas voids in the 21C high head safety injection pump (HHSI) suction piping while the 21A HHSI pump was inoperable due to planned maintenance. FENOC corrective actions include increased void monitoring frequency and updating fill and vent procedures for the HHSI system (CR 2013-09725). In accordance with IMC 0609 Attachment 4, Initial Characterization of Findings, and Exhibit 2 of IMC 0609 Appendix A, The Significance Determination Process for Findings at Power, the inspectors identified that the finding screened as potentially risk-significant due to representing an actual loss of function of a single train for greater than its technical specification allowed outage time. Therefore, a detailed analysis was conducted utilizing the Beaver Valley Unit 2 SPAR model, version 8.23 run by SAPHIRE version 8.0.9. The 21C is a spare pump that can be manually aligned to either train. As a result the analysis considered cases in which it was in the standby configuration and also when it would be required to be manually realigned and started. The first case had a fault exposure time of 204 hours and was assumed to have the pump fail to start if called upon. The second condition had an exposure time of 185 hours and was assumed to fail if realigned. The increase in risk from these conditions resulted in a change in core damage frequency of less than 1E-7. The dominant sequence was a loss of containment air along with failures of reactor coolant pump seals, the ability to provide high pressure injection and the failure of secondary side heat removal. Because an increase in core damage frequency was less than 1E-7, further evaluation of external event and large early release risk was not required and the results calculated were determined to be of very low safety significance (Green).
05000334/FIN-2013004-022013Q3Beaver ValleyLicensee-Identified ViolationTechnical Specification 5.4.1, Procedures, requires that written procedures shall be implemented covering the Fire Protection Plan. The FENOC Fire Protection Plan includes 1/2-ADM-1904, Control of Ignition Sources (Hot Work) and Fire Watches, which requires fire watch patrols be completed every seventy-five minutes. Contrary to the above, between June 4, 2013 and August 21, 2013, FENOC identified fire watch patrols were not completed in accordance with the Fire Protection Plan procedure 1/2-ADM- on fifteen patrols. FENOC entered this issue into the corrective action program as CR-2013-08322. The inspectors determined that the finding was of very low safety significance (Green) in accordance with Attachment 4, Initial Characterization of Findings and IMC 0609, Appendix F, Fire Protection Significance Determination Phase 1 Screening, because the reactors were able to reach and maintain safe shutdown conditions.
05000334/FIN-2013004-032013Q3Beaver ValleyLicensee-Identified Violation10 CFR 50.54 Conditions of Licenses, paragraph (q), requires, in part, that licensees maintain an emergency plan that meets the planning standards in 10 CFR 50.47(b) Emergency Plans. 10 CFR 50.47(b)(4) requires use of a standard emergency classification and action level scheme. Contrary to the above, on March 20, 2013, FENOC identified that existing instrumentation was inadequate to assess and determine if abnormal radiological conditions existed such that the Emergency Action Level (EAL) declaration process would not declare an Alert or a Site Area Emergency in an accurate and timely manner. Specifically, the maximum readable values for the containment elevated release radiation monitor low-range channel (RM-1VS-110 Channel 5) and for the cooling tower vent radiation monitor mid-range channel (RM-1GW-109 Channel 7) were less than the EAL threshold values specified for an Alert and Site Area Emergency, respectively, in FENOCs EAL scheme. FENOC entered this issue into their corrective action program as CR-2013-04092. The inspectors determined this finding to be of very low safety significance (Green) in accordance with IMC 0609, Attachment 4, Initial Characterization of Findings, and Section 5.4 of IMC 0609 Appendix B, Emergency Preparedness SDP because the finding was an example of an ineffective EAL, such that an Alert would not be declared and an example of an ineffective EAL, such that a Site Area Emergency would be declared in a degraded manner.