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05000373/FIN-2012012-012012Q4LaSalleFailure to provide complete and accurate decommissioning status reportsDuring an NRC investigation completed on November 22, 2011, and a supplemental investigation completed on October 10, 2012, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below: 10 CFR 50.75(a) establishes requirements for indicating to the NRC how a licensee will provide reasonable assurance that funds will be available for the decommissioning process and states that for power reactor licensees, reasonable assurance consists of a series of steps as provided in paragraphs (b), (c), (e), and (f) of 10 CFR 50.75. 10 CFR 50.75(f)(2) states, in part, that power reactor licensees shall report at least every 2 years on the status of its decommissioning funding for each reactor or part of a reactor that it owns; and, that the information in this report must include, at a minimum, the amount of decommissioning funds estimated to be required pursuant to 10 CFR 50.75(b) and (c). 10 CFR 50.75(b)(1) states, in part, that for a holder of an operating license under 10 CFR Part 50, financial assurance for decommissioning shall be provided in an amount which may be more, but not less, than the amount stated in the table in paragraph (c)(1) adjusted using a rate at least equal to that stated in paragraph (c)(2). 10 CFR 50.75(c)(1) states the minimum amount required to demonstrate reasonable assurance of funds for decommissioning by reactor type and power level. 10 CFR 50.75(c)(2) requires, in part, that an adjustment factor be applied, which is based on escalation factors for labor and energy, and waste burial. 10 CFR 50.9(a) states, in part, that information provided to the Commission by a licensee shall be complete and accurate in all material respects. Contrary to the above, on March 31, 2005, March 31, 2006, March 31, 2007, and March 31,2009, Exelon Generation Company, LLC (Exelon) provided information on the status of its decommissioning funding that was not complete and accurate in all material respects, when it submitted the decommissioning funding status (DFS) reports pursuant to 10 CFR 50.75. Specifically, the March 31, 2005, March 31, 2007, March 31, 2006, and March 31, 2009, DFS reports stated that the decommissioning funds estimated to be required for each of the reactors, as listed in the report, were determined in accordance with 10 CFR 50.75(b) and the applicable formulas of 10 CFR 50.75(c). However, in multiple instances, the amount reported was a discounted value that was less than the minimum required amount specified by 10 CFR 50.75(b) and (c). This is a Severity Level IV violation.
05000454/FIN-2012012-012012Q4ByronFailure to provide complete and accurate decommissioning status reportsDuring an NRC investigation completed on November 22, 2011, and a supplemental investigation completed on October 10, 2012, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below: 10 CFR 50.75(a) establishes requirements for indicating to the NRC how a licensee will provide reasonable assurance that funds will be available for the decommissioning process and states that for power reactor licensees, reasonable assurance consists of a series of steps as provided in paragraphs (b), (c), (e), and (f) of 10 CFR 50.75. 10 CFR 50.75(f)(2) states, in part, that power reactor licensees shall report at least every 2 years on the status of its decommissioning funding for each reactor or part of a reactor that it owns; and, that the information in this report must include, at a minimum, the amount of decommissioning funds estimated to be required pursuant to 10 CFR 50.75(b) and (c). 10 CFR 50.75(b)(1) states, in part, that for a holder of an operating license under 10 CFR Part 50, financial assurance for decommissioning shall be provided in an amount which may be more, but not less, than the amount stated in the table in paragraph (c)(1) adjusted using a rate at least equal to that stated in paragraph (c)(2). 10 CFR 50.75(c)(1) states the minimum amount required to demonstrate reasonable assurance of funds for decommissioning by reactor type and power level. 10 CFR 50.75(c)(2) requires, in part, that an adjustment factor be applied, which is based on escalation factors for labor and energy, and waste burial. 10 CFR 50.9(a) states, in part, that information provided to the Commission by a licensee shall be complete and accurate in all material respects. Contrary to the above, on March 31, 2005, March 31, 2006, March 31, 2007, and March 31,2009, Exelon Generation Company, LLC (Exelon) provided information on the status of its decommissioning funding that was not complete and accurate in all material respects, when it submitted the decommissioning funding status (DFS) reports pursuant to 10 CFR 50.75. Specifically, the March 31, 2005, March 31, 2007, March 31, 2006, and March 31, 2009, DFS reports stated that the decommissioning funds estimated to be required for each of the reactors, as listed in the report, were determined in accordance with 10 CFR 50.75(b) and the applicable formulas of 10 CFR 50.75(c). However, in multiple instances, the amount reported was a discounted value that was less than the minimum required amount specified by 10 CFR 50.75(b) and (c). This is a Severity Level IV violation.
05000461/FIN-2012012-012012Q4ClintonFailure to provide complete and accurate decommissioning status reportsDuring an NRC investigation completed on November 22, 2011, and a supplemental investigation completed on October 10, 2012, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below: 10 CFR 50.75(a) establishes requirements for indicating to the NRC how a licensee will provide reasonable assurance that funds will be available for the decommissioning process and states that for power reactor licensees, reasonable assurance consists of a series of steps as provided in paragraphs (b), (c), (e), and (f) of 10 CFR 50.75. 10 CFR 50.75(f)(2) states, in part, that power reactor licensees shall report at least every 2 years on the status of its decommissioning funding for each reactor or part of a reactor that it owns; and, that the information in this report must include, at a minimum, the amount of decommissioning funds estimated to be required pursuant to 10 CFR 50.75(b) and (c). 10 CFR 50.75(b)(1) states, in part, that for a holder of an operating license under 10 CFR Part 50, financial assurance for decommissioning shall be provided in an amount which may be more, but not less, than the amount stated in the table in paragraph (c)(1) adjusted using a rate at least equal to that stated in paragraph (c)(2). 10 CFR 50.75(c)(1) states the minimum amount required to demonstrate reasonable assurance of funds for decommissioning by reactor type and power level. 10 CFR 50.75(c)(2) requires, in part, that an adjustment factor be applied, which is based on escalation factors for labor and energy, and waste burial. 10 CFR 50.9(a) states, in part, that information provided to the Commission by a licensee shall be complete and accurate in all material respects. Contrary to the above, on March 31, 2005, March 31, 2006, March 31, 2007, and March 31,2009, Exelon Generation Company, LLC (Exelon) provided information on the status of its decommissioning funding that was not complete and accurate in all material respects, when it submitted the decommissioning funding status (DFS) reports pursuant to 10 CFR 50.75. Specifically, the March 31, 2005, March 31, 2007, March 31, 2006, and March 31, 2009, DFS reports stated that the decommissioning funds estimated to be required for each of the reactors, as listed in the report, were determined in accordance with 10 CFR 50.75(b) and the applicable formulas of 10 CFR 50.75(c). However, in multiple instances, the amount reported was a discounted value that was less than the minimum required amount specified by 10 CFR 50.75(b) and (c). This is a Severity Level IV violation.
05000010/FIN-2012012-012012Q4DresdenFailure to provide complete and accurate decommissioning status reportsDuring an NRC investigation completed on November 22, 2011, and a supplemental investigation completed on October 10, 2012, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below: 10 CFR 50.75(a) establishes requirements for indicating to the NRC how a licensee will provide reasonable assurance that funds will be available for the decommissioning process and states that for power reactor licensees, reasonable assurance consists of a series of steps as provided in paragraphs (b), (c), (e), and (f) of 10 CFR 50.75. 10 CFR 50.75(f)(2) states, in part, that power reactor licensees shall report at least every 2 years on the status of its decommissioning funding for each reactor or part of a reactor that it owns; and, that the information in this report must include, at a minimum, the amount of decommissioning funds estimated to be required pursuant to 10 CFR 50.75(b) and (c). 10 CFR 50.75(b)(1) states, in part, that for a holder of an operating license under 10 CFR Part 50, financial assurance for decommissioning shall be provided in an amount which may be more, but not less, than the amount stated in the table in paragraph (c)(1) adjusted using a rate at least equal to that stated in paragraph (c)(2). 10 CFR 50.75(c)(1) states the minimum amount required to demonstrate reasonable assurance of funds for decommissioning by reactor type and power level. 10 CFR 50.75(c)(2) requires, in part, that an adjustment factor be applied, which is based on escalation factors for labor and energy, and waste burial. 10 CFR 50.9(a) states, in part, that information provided to the Commission by a licensee shall be complete and accurate in all material respects. Contrary to the above, on March 31, 2005, March 31, 2006, March 31, 2007, and March 31,2009, Exelon Generation Company, LLC (Exelon) provided information on the status of its decommissioning funding that was not complete and accurate in all material respects, when it submitted the decommissioning funding status (DFS) reports pursuant to 10 CFR 50.75. Specifically, the March 31, 2005, March 31, 2007, March 31, 2006, and March 31, 2009, DFS reports stated that the decommissioning funds estimated to be required for each of the reactors, as listed in the report, were determined in accordance with 10 CFR 50.75(b) and the applicable formulas of 10 CFR 50.75(c). However, in multiple instances, the amount reported was a discounted value that was less than the minimum required amount specified by 10 CFR 50.75(b) and (c). This is a Severity Level IV violation.
05000456/FIN-2012012-012012Q4BraidwoodFailure to provide complete and accurate decommissioning status reportsDuring an NRC investigation completed on November 22, 2011, and a supplemental investigation completed on October 10, 2012, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below: 10 CFR 50.75(a) establishes requirements for indicating to the NRC how a licensee will provide reasonable assurance that funds will be available for the decommissioning process and states that for power reactor licensees, reasonable assurance consists of a series of steps as provided in paragraphs (b), (c), (e), and (f) of 10 CFR 50.75. 10 CFR 50.75(f)(2) states, in part, that power reactor licensees shall report at least every 2 years on the status of its decommissioning funding for each reactor or part of a reactor that it owns; and, that the information in this report must include, at a minimum, the amount of decommissioning funds estimated to be required pursuant to 10 CFR 50.75(b) and (c). 10 CFR 50.75(b)(1) states, in part, that for a holder of an operating license under 10 CFR Part 50, financial assurance for decommissioning shall be provided in an amount which may be more, but not less, than the amount stated in the table in paragraph (c)(1) adjusted using a rate at least equal to that stated in paragraph (c)(2). 10 CFR 50.75(c)(1) states the minimum amount required to demonstrate reasonable assurance of funds for decommissioning by reactor type and power level. 10 CFR 50.75(c)(2) requires, in part, that an adjustment factor be applied, which is based on escalation factors for labor and energy, and waste burial. 10 CFR 50.9(a) states, in part, that information provided to the Commission by a licensee shall be complete and accurate in all material respects. Contrary to the above, on March 31, 2005, March 31, 2006, March 31, 2007, and March 31,2009, Exelon Generation Company, LLC (Exelon) provided information on the status of its decommissioning funding that was not complete and accurate in all material respects, when it submitted the decommissioning funding status (DFS) reports pursuant to 10 CFR 50.75. Specifically, the March 31, 2005, March 31, 2007, March 31, 2006, and March 31, 2009, DFS reports stated that the decommissioning funds estimated to be required for each of the reactors, as listed in the report, were determined in accordance with 10 CFR 50.75(b) and the applicable formulas of 10 CFR 50.75(c). However, in multiple instances, the amount reported was a discounted value that was less than the minimum required amount specified by 10 CFR 50.75(b) and (c). This is a Severity Level IV violation.
05000254/FIN-2012012-012012Q4Quad CitiesFailure to provide complete and accurate decommissioning status reportsDuring an NRC investigation completed on November 22, 2011, and a supplemental investigation completed on October 10, 2012, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below: 10 CFR 50.75(a) establishes requirements for indicating to the NRC how a licensee will provide reasonable assurance that funds will be available for the decommissioning process and states that for power reactor licensees, reasonable assurance consists of a series of steps as provided in paragraphs (b), (c), (e), and (f) of 10 CFR 50.75. 10 CFR 50.75(f)(2) states, in part, that power reactor licensees shall report at least every 2 years on the status of its decommissioning funding for each reactor or part of a reactor that it owns; and, that the information in this report must include, at a minimum, the amount of decommissioning funds estimated to be required pursuant to 10 CFR 50.75(b) and (c). 10 CFR 50.75(b)(1) states, in part, that for a holder of an operating license under 10 CFR Part 50, financial assurance for decommissioning shall be provided in an amount which may be more, but not less, than the amount stated in the table in paragraph (c)(1) adjusted using a rate at least equal to that stated in paragraph (c)(2). 10 CFR 50.75(c)(1) states the minimum amount required to demonstrate reasonable assurance of funds for decommissioning by reactor type and power level. 10 CFR 50.75(c)(2) requires, in part, that an adjustment factor be applied, which is based on escalation factors for labor and energy, and waste burial. 10 CFR 50.9(a) states, in part, that information provided to the Commission by a licensee shall be complete and accurate in all material respects. Contrary to the above, on March 31, 2005, March 31, 2006, March 31, 2007, and March 31,2009, Exelon Generation Company, LLC (Exelon) provided information on the status of its decommissioning funding that was not complete and accurate in all material respects, when it submitted the decommissioning funding status (DFS) reports pursuant to 10 CFR 50.75. Specifically, the March 31, 2005, March 31, 2007, March 31, 2006, and March 31, 2009, DFS reports stated that the decommissioning funds estimated to be required for each of the reactors, as listed in the report, were determined in accordance with 10 CFR 50.75(b) and the applicable formulas of 10 CFR 50.75(c). However, in multiple instances, the amount reported was a discounted value that was less than the minimum required amount specified by 10 CFR 50.75(b) and (c). This is a Severity Level IV violation.
05000219/FIN-2012012-012012Q4Oyster CreekFailure to provide complete and accurate decommissioning status reportsDuring an NRC investigation completed on November 22, 2011, and a supplemental investigation completed on October 10, 2012, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below: 10 CFR 50.75(a) establishes requirements for indicating to the NRC how a licensee will provide reasonable assurance that funds will be available for the decommissioning process and states that for power reactor licensees, reasonable assurance consists of a series of steps as provided in paragraphs (b), (c), (e), and (f) of 10 CFR 50.75. 10 CFR 50.75(f)(2) states, in part, that power reactor licensees shall report at least every 2 years on the status of its decommissioning funding for each reactor or part of a reactor that it owns; and, that the information in this report must include, at a minimum, the amount of decommissioning funds estimated to be required pursuant to 10 CFR 50.75(b) and (c). 10 CFR 50.75(b)(1) states, in part, that for a holder of an operating license under 10 CFR Part 50, financial assurance for decommissioning shall be provided in an amount which may be more, but not less, than the amount stated in the table in paragraph (c)(1) adjusted using a rate at least equal to that stated in paragraph (c)(2). 10 CFR 50.75(c)(1) states the minimum amount required to demonstrate reasonable assurance of funds for decommissioning by reactor type and power level. 10 CFR 50.75(c)(2) requires, in part, that an adjustment factor be applied, which is based on escalation factors for labor and energy, and waste burial. 10 CFR 50.9(a) states, in part, that information provided to the Commission by a licensee shall be complete and accurate in all material respects. Contrary to the above, on March 31, 2005, March 31, 2006, March 31, 2007, and March 31,2009, Exelon Generation Company, LLC (Exelon) provided information on the status of its decommissioning funding that was not complete and accurate in all material respects, when it submitted the decommissioning funding status (DFS) reports pursuant to 10 CFR 50.75. Specifically, the March 31, 2005, March 31, 2007, March 31, 2006, and March 31, 2009, DFS reports stated that the decommissioning funds estimated to be required for each of the reactors, as listed in the report, were determined in accordance with 10 CFR 50.75(b) and the applicable formulas of 10 CFR 50.75(c). However, in multiple instances, the amount reported was a discounted value that was less than the minimum required amount specified by 10 CFR 50.75(b) and (c). This is a Severity Level IV violation.
05000272/FIN-2012012-012012Q4SalemFailure to provide complete and accurate decommissioning status reportsDuring an NRC investigation completed on November 22, 2011, and a supplemental investigation completed on October 10, 2012, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below: 10 CFR 50.75(a) establishes requirements for indicating to the NRC how a licensee will provide reasonable assurance that funds will be available for the decommissioning process and states that for power reactor licensees, reasonable assurance consists of a series of steps as provided in paragraphs (b), (c), (e), and (f) of 10 CFR 50.75. 10 CFR 50.75(f)(2) states, in part, that power reactor licensees shall report at least every 2 years on the status of its decommissioning funding for each reactor or part of a reactor that it owns; and, that the information in this report must include, at a minimum, the amount of decommissioning funds estimated to be required pursuant to 10 CFR 50.75(b) and (c). 10 CFR 50.75(b)(1) states, in part, that for a holder of an operating license under 10 CFR Part 50, financial assurance for decommissioning shall be provided in an amount which may be more, but not less, than the amount stated in the table in paragraph (c)(1) adjusted using a rate at least equal to that stated in paragraph (c)(2). 10 CFR 50.75(c)(1) states the minimum amount required to demonstrate reasonable assurance of funds for decommissioning by reactor type and power level. 10 CFR 50.75(c)(2) requires, in part, that an adjustment factor be applied, which is based on escalation factors for labor and energy, and waste burial. 10 CFR 50.9(a) states, in part, that information provided to the Commission by a licensee shall be complete and accurate in all material respects. Contrary to the above, on March 31, 2005, March 31, 2006, March 31, 2007, and March 31,2009, Exelon Generation Company, LLC (Exelon) provided information on the status of its decommissioning funding that was not complete and accurate in all material respects, when it submitted the decommissioning funding status (DFS) reports pursuant to 10 CFR 50.75. Specifically, the March 31, 2005, March 31, 2007, March 31, 2006, and March 31, 2009, DFS reports stated that the decommissioning funds estimated to be required for each of the reactors, as listed in the report, were determined in accordance with 10 CFR 50.75(b) and the applicable formulas of 10 CFR 50.75(c). However, in multiple instances, the amount reported was a discounted value that was less than the minimum required amount specified by 10 CFR 50.75(b) and (c). This is a Severity Level IV violation.
05000289/FIN-2012012-012012Q4Three Mile IslandFailure to provide complete and accurate decommissioning status reportsDuring an NRC investigation completed on November 22, 2011, and a supplemental investigation completed on October 10, 2012, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below: 10 CFR 50.75(a) establishes requirements for indicating to the NRC how a licensee will provide reasonable assurance that funds will be available for the decommissioning process and states that for power reactor licensees, reasonable assurance consists of a series of steps as provided in paragraphs (b), (c), (e), and (f) of 10 CFR 50.75. 10 CFR 50.75(f)(2) states, in part, that power reactor licensees shall report at least every 2 years on the status of its decommissioning funding for each reactor or part of a reactor that it owns; and, that the information in this report must include, at a minimum, the amount of decommissioning funds estimated to be required pursuant to 10 CFR 50.75(b) and (c). 10 CFR 50.75(b)(1) states, in part, that for a holder of an operating license under 10 CFR Part 50, financial assurance for decommissioning shall be provided in an amount which may be more, but not less, than the amount stated in the table in paragraph (c)(1) adjusted using a rate at least equal to that stated in paragraph (c)(2). 10 CFR 50.75(c)(1) states the minimum amount required to demonstrate reasonable assurance of funds for decommissioning by reactor type and power level. 10 CFR 50.75(c)(2) requires, in part, that an adjustment factor be applied, which is based on escalation factors for labor and energy, and waste burial. 10 CFR 50.9(a) states, in part, that information provided to the Commission by a licensee shall be complete and accurate in all material respects. Contrary to the above, on March 31, 2005, March 31, 2006, March 31, 2007, and March 31,2009, Exelon Generation Company, LLC (Exelon) provided information on the status of its decommissioning funding that was not complete and accurate in all material respects, when it submitted the decommissioning funding status (DFS) reports pursuant to 10 CFR 50.75. Specifically, the March 31, 2005, March 31, 2007, March 31, 2006, and March 31, 2009, DFS reports stated that the decommissioning funds estimated to be required for each of the reactors, as listed in the report, were determined in accordance with 10 CFR 50.75(b) and the applicable formulas of 10 CFR 50.75(c). However, in multiple instances, the amount reported was a discounted value that was less than the minimum required amount specified by 10 CFR 50.75(b) and (c). This is a Severity Level IV violation.
05000352/FIN-2012012-012012Q4LimerickFailure to provide complete and accurate decommissioning status reportsDuring an NRC investigation completed on November 22, 2011, and a supplemental investigation completed on October 10, 2012, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below: 10 CFR 50.75(a) establishes requirements for indicating to the NRC how a licensee will provide reasonable assurance that funds will be available for the decommissioning process and states that for power reactor licensees, reasonable assurance consists of a series of steps as provided in paragraphs (b), (c), (e), and (f) of 10 CFR 50.75. 10 CFR 50.75(f)(2) states, in part, that power reactor licensees shall report at least every 2 years on the status of its decommissioning funding for each reactor or part of a reactor that it owns; and, that the information in this report must include, at a minimum, the amount of decommissioning funds estimated to be required pursuant to 10 CFR 50.75(b) and (c). 10 CFR 50.75(b)(1) states, in part, that for a holder of an operating license under 10 CFR Part 50, financial assurance for decommissioning shall be provided in an amount which may be more, but not less, than the amount stated in the table in paragraph (c)(1) adjusted using a rate at least equal to that stated in paragraph (c)(2). 10 CFR 50.75(c)(1) states the minimum amount required to demonstrate reasonable assurance of funds for decommissioning by reactor type and power level. 10 CFR 50.75(c)(2) requires, in part, that an adjustment factor be applied, which is based on escalation factors for labor and energy, and waste burial. 10 CFR 50.9(a) states, in part, that information provided to the Commission by a licensee shall be complete and accurate in all material respects. Contrary to the above, on March 31, 2005, March 31, 2006, March 31, 2007, and March 31,2009, Exelon Generation Company, LLC (Exelon) provided information on the status of its decommissioning funding that was not complete and accurate in all material respects, when it submitted the decommissioning funding status (DFS) reports pursuant to 10 CFR 50.75. Specifically, the March 31, 2005, March 31, 2007, March 31, 2006, and March 31, 2009, DFS reports stated that the decommissioning funds estimated to be required for each of the reactors, as listed in the report, were determined in accordance with 10 CFR 50.75(b) and the applicable formulas of 10 CFR 50.75(c). However, in multiple instances, the amount reported was a discounted value that was less than the minimum required amount specified by 10 CFR 50.75(b) and (c). This is a Severity Level IV violation.
05000443/FIN-2012503-012012Q2SeabrookFailure of Exercise Critique to ldentify an RSPS Weakness as a DEP Pl Opportunity FailureThe NRC identified an apparent violation (AV) for the licensee exercise critique process not properly identifying a weakness associated with a risk significant planning standard (RSPS) that was determined to be a Drill/Exercise Performance (DEP) Performance Indicator (Pl) opportunity failure during a full-scale exercise. The AV is associated with emergency preparedness planning standards 10 CFR 50.47(bX14) and 10 CFR 50.47(bX5) and the requirements of Section lV.F.2.g of Appendix E to 10 CFR Part 50. This finding was entered into the licensee corrective action program. The failure of NextEra to identify the exercise weakness related to an incorrect protective action recommendation (PAR) notification during their exercise critique was a performance deficiency that was reasonably within NextEra ability to foresee and prevent. The finding is more than minor because it is associated with the emergency response organization attribute of the Emergency Preparedness Cornerstone and affected the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. This finding was determined to potentially have greater-than- Green safety significance because the licensee exercise critique process did not properly identify a weakness associated with a RSPS that was determined to be a DEP Pl opportunity failure during a biennial full-participation exercise. The finding is related to the cross-cutting area of Problem identification and Resolution, Corrective Action Program; in those NextEra personnel did not identify a RSPS issue completely, accurately, and in a timely manner commensurate with the safety significance. Specifically, during the biennial full-participation exercise evaluation Next Era failed to identify a weakness.
05000237/FIN-2011008-042011Q4DresdenSafe Shutdown Procedure ImplementationThe inspectors identified an Unresolved Item (URI) concerning safe shutdown procedure implementation. The fire protection safe shutdown procedures specified, as a precaution, that the procedures were to be followed only in the event that normal or emergency procedures were insufficient. The training provided to operators reinforced this procedural expectation. The inspectors were concerned that this precaution effectively established an entry condition, which could delay or preclude operators from entering safe shutdown procedures during a fire. The inspectors were concerned that operators may not perform necessary actions in sufficient time in the event of a severe fire. In response to the inspectors concerns, the licensee initiated AR 01258932, NRC FP Triennial 2011 NRC Question Regarding T-0, and AR 01272652. This issue is a URI pending further assessment of how operators would respond to ensure that 10 CFR Part 50, Appendix R, Section III.L performance goals are met in the event of a fire. The assessment will likely include development of fire scenarios which would challenge operator decision making abilities using existing procedures, and evaluation of how operators would respond under such scenarios either through table top review with the licensee or simulator demonstration.
05000237/FIN-2011008-072011Q4DresdenLicensee-Identified ViolationIn April 2011 the licensee determined that several paths existed, in addition to previously evaluated condensate storage tank (CST) to hotwell make-up valve path, which could cause gravity drain of the CST to the hotwell due to multiple spurious operations. As a result, the licensee determined that a review and circuit analysis of other CST and clean demineralizer paths needed to be performed. The licensee initiated a circuit analysis review, which was still in progress at the time of this inspection, to more fully address potential CST drain down scenarios. Based on the inspectors review, it was determined that the above non-compliance for an MSO (Scenario 2aj, Loss of CST Inventory to Hot Well, of NEI 00-01, Table G-1, BWR Generic MSO List) was a violation of 10 CFR Part 50, Appendix R, Section III.G. The inspectors determined that the licensees existing procedures already addressed the more significant potential drain down path event involving spurious opening of CST to hotwell make-up valves and that a drain down event would occur over a relatively long period of time, providing operators an opportunity to intervene. Therefore, inspectors assigned a low degradation to this finding and determined that it screened as having very low safety significance (Green). The licensee initiated ARs 01257847, FP Triennial: MSO Scenario Did Not Have IR, and 01257854, MSOPS 2aj: CST Drain Down, to add Scenario 2aj to the corrective action program.
05000237/FIN-2011008-062011Q4DresdenFailure to Obtain NRC Approval for Change Adverse to Safe ShutdownThe inspectors identified a Severity Level IV, NCV of License Conditions 2.E and 3.G, for Units 2 and 3, and an associated finding of very low safety significance (Green) for the failure to obtain NRC approval prior to making a change, which was adverse to safe shutdown. Specifically, the licensee made a change to Administrative Technical Requirements, which permitted a suppression system to be inoperable without compensatory measures, thereby degrading the ability to suppress a fire and challenging the ability to achieve and maintain safe shutdown in the event of a fire. The licensee entered the issue into their corrective action program and issued an operations standing order to require fire watches, regardless of whether there was operable detection when a suppression system was out of service. The inspectors determined that this finding was more than minor because the change permitted suppression systems to be inoperable without any compensatory action. This finding was of very low safety significance because the majority of issues identified by fire watches would involve combustible materials, which would not result in ignition of a fire from existing sources of heat or electrical energy. The inspectors did not identify a cross-cutting aspect associated with the finding because the finding was not representative of current performance.
05000237/FIN-2011008-032011Q4DresdenFailure to Ensure Operators Required for Safe Shutdown Were On-SiteThe inspectors identified a finding of very low safety significance (Green) and associated NCV of 10 CFR Part 50, Appendix R, Section III.L., for the licensees failure to ensure that operators required for safe shutdown were on-site at all times. Specifically, operators required for safe shutdown in the event of a fire traveled off-site for performing routine operator rounds. The licensee entered the issue into their corrective action program and planned to evaluate their safe shutdown procedure actions and operations shift crew composition. The inspectors determined that the finding was more than minor because the failure to ensure that operators required for safe shutdown were on-site at all times reduced the margin for time available to perform safe shutdown actions. The finding was of very low safety significance because it was feasible to perform the specified manual actions with available staff. This finding does not have a cross-cutting aspect because the finding is not representative of current performance.
05000237/FIN-2011008-022011Q4DresdenFailure to Identify Diesel Fire Pump Battery Terminal CorrosionThe inspectors identified a finding of very low safety significance (Green) and associated NCV of Technical Specifications for the licensees failure to implement the diesel fire pump battery surveillance procedure. Specifically, the licensee failed to identify corrosion on the diesel fire pump battery terminals, which was contrary to the surveillance procedure that implemented the fire protection program. The licensee entered the issue into their corrective action program and surface cleaned the terminals. The inspectors determined that the finding was more than minor because, if left uncorrected, the presence of corrosion in conjunction with identified voltage issues for two battery cells could affect the reliability of the diesel fire pump. This finding was of very low safety significance because the diesel fire pump had started as part of a recent routine surveillance. This finding has a cross-cutting aspect in the area of Human Performance because the maintenance personnel who performed the battery surveillance did not have sufficient training to recognize the presence of corrosion.
05000237/FIN-2011008-012011Q4DresdenFailure to Implement Transient Combustible ProgramThe inspectors identified a finding of very low safety significance and associated NCV of Technical Specifications Section 5.4.1.c for the failure to control transient combustible materials in accordance with fire protection program requirements. Specifically, the licensee failed to control the amount and location of transient combustibles in areas containing safety-related components. In addition, the licensee failed to identify the presence of transient combustibles through fire watches conducted as required by the fire protection program. The licensee removed the transient combustibles and planned on reviewing training related to the transient combustibles. The inspectors determined that this finding was more than minor because the transient combustible materials were stored near safety-related cables and components and formed credible fire scenarios. This finding was of very low safety significance because the materials would not result in ignition of a fire from existing sources of heat or electrical energy. This finding had a cross-cutting aspect in the area of Human Performance within the decision making component because the licensee did not properly communicate and reinforce expectations related to the fire protection program implementation concerning transient combustibles to personnel performing maintenance work and fire watches.
05000237/FIN-2011008-052011Q4DresdenFailure to Obtain NRC Approval for Change Adverse to Safe ShutdownThe inspectors identified a Severity Level IV, NCV of License Conditions 2.E and 3.G, for Units 2 and 3, and an associated finding of very low safety significance (Green) for the failure to obtain NRC approval prior to making a change, which was adverse to safe shutdown. Specifically, the licensee made a change to Administrative Technical Requirements, which permitted a suppression system to be inoperable without compensatory measures, thereby degrading the ability to suppress a fire and challenging the ability to achieve and maintain safe shutdown in the event of a fire. The licensee entered the issue into their corrective action program and issued an operations standing order to require fire watches, regardless of whether there was operable detection when a suppression system was out of service. The inspectors determined that this finding was more than minor because the change permitted suppression systems to be inoperable without any compensatory action. This finding was of very low safety significance because the majority of issues identified by fire watches would involve combustible materials, which would not result in ignition of a fire from existing sources of heat or electrical energy. The inspectors did not identify a cross-cutting aspect associated with the finding because the finding was not representative of current performance.
05000445/FIN-2011007-032011Q2Comanche PeakFailure to Ensure Emergency Lights in Safe Shutdown Areas had an 8-Hour CapacityThe team identified a noncited violation of License Condition 2.G for failure to implement and maintain in effect all provisions of the approved fire protection program. Specifically, the licensee failed to establish a maintenance and/or test program that demonstrated that emergency lighting had an 8-hour capacity in areas required for safe shutdown. When inspectors questioned the licensee\'s practice of replacing the emergency light batteries without ever testing to confirm that the replacement interval was appropriate to ensure an 8-hour capacity, the licensee conducted tests that showed that 22 percent of the batteries on a 3-year replacement interval failed in less than 8 hours. The licensee entered this issue into their corrective action program as Condition Report CR-2011-001821. The licensee created action items to CR-2011-001821 for additional testing on a broader sample of emergency lights to aid in determining the correct replacement interval to ensure operability, and shortened the 3-year replacement interval for lights which failed to meet operability requirements as a result of testing to a more conservative 2-year replacement interval which had no demonstrated testing failures. The failure to establish a maintenance and/or test program that demonstrated operability for 8-hour emergency lighting required for operator manual actions at safe shutdown equipment is a performance deficiency. The performance deficiency was more than minor because it is associated with the protection against external events (fire) attribute of the Mitigating Systems cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure of the emergency lights to last 8 hours could adversely affect the ability of operators to perform the manual actions required to support safe shutdown in the event of a fire. The significance of this finding was evaluated using Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, because the performance deficiency affected fire protection defense-In-depth strategies involving post-fire safe shutdown systems. Using Appendix F, Attachment 2, Degradation Rating Guidance Specific to Various Fire Protection Program Elements, the finding was assigned a low degradation rating because the finding minimally impacted the performance and reliability of the fire protection program element. The team also noted that operators were required to obtain and carry flashlights. Therefore, the finding screened as having very low safety significance (Green). This finding did not have a crosscutting aspect because it was not indicative of current licensee performance, in that the replacement program had been used for longer than 3 years.
05000445/FIN-2011007-022011Q2Comanche PeakFailure to Identify and Mitigate or Correct Potential Single Spurious Fire Damage ScenarioThe team identified a noncited violation of License Condition 2.G for failure to implement and maintain in effect all provisions of the approved fire protection program. Specifically, the licensee failed to recognize that electrical cables for the pressurizer power-operated relief valves and associated block valves were installed in many of the same cable trays, leaving the plant susceptible to fire damage that could spuriously open the power-operated relief valve and prevent the ability to shut the block valve. This scenario could challenge operators by creating a loss of coolant during a plant fire. The licensee entered this issue into their corrective action program as Condition Reports CR-011-001319, CR-2011-001807, CR-2011-001808 and CR-2011-002430. As a compensatory measure, the licensee revised attachment 17 to Procedure ABN-901 , Fire Protection System Alarms or Malfunctions, Revision 9, to close the affected pressurizer block valves in the event of a fire in the Auxiliary or Safeguards buildings in order to mitigate potential circuit interactions that could spuriously open a poweroperated relief valve. Failure to identify and mitigate or correct an existing plant configuration that was susceptible to single spurious failures while performing expert panel reviews of fire damage scenarios that could prevent safely shutting down the plant in the event of a fire is a performance deficiency. This performance deficiency was more than minor because it is associated with the protection against external events (fire) attribute of the Mitigating Systems cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The team used Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, because the performance deficiency affected fire protection defense-in-depth strategies involving post-fire safe shutdown. Because the Phase 1 screening criteria were not met, the analysis continued to Phase 2. Because the finding did not screen as Green during the Phase 2 analysis, a senior reactor analyst performed a Phase 3 analysis. Using information from the Phase 2 worksheets and discussions with the licensee PRA staff, the senior reactor analyst\\\'s Phase 3 analysis calculated the total change in core damage frequency to be 3.2E-7/yr (Green), based on the proximity of fire sources available to damage these circuits. This finding had a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program component because the licensee did not identify the issues completely, accurately, and in a timely manner commensurate with their safety significance while conducting expert panel reviews of this and other scenarios in 2009.
05000445/FIN-2011007-012011Q2Comanche PeakFailure to Implement Effective Corrective Actions for a Condition Adverse to Fire ProtectionThe team identified a noncited violation of License Condition 2.G for the failure to implement and maintain in effect all provisions of the approved fire protection program. Specifically, the team identified two examples where the licensee failed to implement effective corrective actions to ensure that time-critical manual actions would be accomplished within analyzed times for alternative shutdown scenarios. The first example involved the failure to close a spuriously opened pressurizer power-operated relief valve within the time allowed by the postfire safe shutdown analysis. The second example involved the failure to restore station service water cooling before damage could occur to the credited emergency diesel generator in the event of a control room fire with a loss of offsite power. The licensee entered this issue into their corrective action program as Condition Reports CR-2011-001647, CR-2011-001742 and CR-2011- 001836. In response to this issue, the licensee re-ordered the procedure steps to isolate the power-operated relief valves and ensure the standby service water pump was running sooner. The licensee planned to perform a validation of the revised procedures. Failure to implement effective corrective actions to ensure that time-critical manual actions would be accomplished within analyzed times for alternative shutdown scenarios is a performance deficiency. This performance deficiency was more than minor because it was associated with the protection against external events (fire) attribute of the Mitigating Systems cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The significance of this finding could not be evaluated using Inspection Manual Chapter 0609, Appendix F. Fire Protection Significance Determination Process, because the performance deficiency involved a control room fire that led to control room abandonment. A senior reactor analyst performed a Phase 3 evaluation bounding analysis that concluded this finding had very low safety significance (Green) because the number of electrical cabinets in the control morn and cable spreading room that contained circuits that could have a fire that could affect the power-operated relief valves or station service water system was a small fraction of the total. This performance deficiency had a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program because the licensee did not take appropriate corrective actions to address safety issues in a timely manner, commensurate with their safety significance.
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