Semantic search
Jump to navigation
Jump to search
| Quarter | Site | Title | Description | |
|---|---|---|---|---|
| 05000445/FIN-2015001-01 | 2015Q1 | Comanche Peak | Failure to Evaluate Operability When Breeching Hazard Barriers | The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated with the licensees failure to perform adequate operability assessments when disabling hazard barriers during maintenance activities. Specifically, during maintenance activities in the main steam/main feed penetration area, the licensee disabled the high energy line break/environmental qualification door and failed to evaluate operability of the safety-related equipment protected by this door. This issue does not represent an immediate safety concern because, at the time of identification, the doors were shut. The licensee entered the finding into corrective action program as Condition Report CR-2015-001111. The failure to properly assess and document the basis for operability when creating a degraded or nonconforming condition during a maintenance activity, breaching a high energy line break/environmental qualification barrier, was a performance deficiency. The performance deficiency was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensees opening the high energy line break/environmental qualification door resulted in a condition where structures, systems, and components necessary to mitigate the effects of a high energy line break may not have functioned as required. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, dated June 19, 2012, the finding was determined to require a detailed risk evaluation because it was a deficiency affecting the design and qualification of a mitigating structure, system, or component that resulted in a loss of operability or functionality and represented a loss of system and/or function. A senior reactor analyst performed a detailed risk evaluation and determined that the finding was of very low safety significance (Green). The inspectors determined that this finding does not have a crosscutting aspect because the most significant contributor of this finding occurred in 2011 and does not reflect current licensee performance. |
| 05000446/FIN-2015001-02 | 2015Q1 | Comanche Peak | Failure to Have an Adequate Procedure for Vendor Information | The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated with the licensees failure to have an adequate procedure for controlling and processing vendor documents and vendor technical manual updates. This resulted in the licensees failure to properly implement new torque requirements for the turbine driven auxiliary feedwater pump trunnion bolts, and their subsequent backing out. The licensee performed an operability determination for the loose trunnion bolts that established a reasonable expectation for operability. The licensee entered the finding into the corrective action program as Condition Report CR-2014-009518. The failure to have an adequate procedure for controlling and processing vendor documents and vendor technical manual updates was a performance deficiency. The performance deficiency was more than minor because it was associated with the procedure quality attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the inadequate procedure allowed a lower torque value to be used on the trunnion bolts for the Unit 2 turbine driven auxiliary feedwater pump which resulted in a condition where the trunnion bolts were loose. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, dated June 19, 2012, the finding was determined to be of very low safety significance (Green) because the finding: (1) was not a deficiency affecting the design and qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality, (2) did not represent a loss of system and/or function, (3) did not represent an actual loss of function of at least a single train for longer than its allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time, and (4) does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant for greater than 24 hours in accordance with the licensees maintenance rule program. The inspectors determined that this finding does not have a cross-cutting aspect because the most significant contributor of this finding occurred more than three years ago and does not reflect current licensee performance. |
| 05000445/FIN-2015001-03 | 2015Q1 | Comanche Peak | Failure to Follow Work Planning Procedure | The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated with the licensees failure to follow the requirements of Procedure STI-606.03, Work Planning, when developing work instructions for replacing concrete expansion anchors. Specifically, when developing Work Order 4851077 to replace Hilti Kwik-Bolt II expansion anchors with Hilti Kwik-Bolt 3 anchors on Manhole MH-E2B, planners failed to follow the requirements of Procedure STI-606.03. This failure resulted in the wrong anchors being installed in the facility. The licensee performed an operability determination for the affected anchors that established a reasonable expectation for operability. The licensee entered the finding into the corrective action program as Condition Report CR-2015-001579. The licensees failure to follow the requirements of Procedure STI-606.03, Work Planning, when developing work instructions was a performance deficiency. The performance deficiency was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to follow procedure resulted in incorrect material being installed in the plant which resulted in a condition where a structure necessary to mitigate the effects of a tornado may not have functioned as required. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, dated June 19, 2012, the finding was determined to be of very low safety significance (Green) because the finding was a deficiency affecting the design and qualification of a mitigating structure, and did not result in a loss of operability or functionality. The finding has a human performance cross-cutting aspect associated with work management because the licensee failed to implement a process of planning activities such that nuclear safety is the overriding priority (H.5). |
| 05000445/FIN-2015001-04 | 2015Q1 | Comanche Peak | Failure to Follow Procedure Damages a Centrifugal Charging Pump | The inspectors identified a non-cited violation of 10 Part CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to follow procedure during the performance of a surveillance test. Specifically, the licensee failed to ensure applicable prerequisites were met for performing the Unit 1 train A integrated surveillance test procedure by not ensuring component cooling water was properly aligned for operation. This resulted in the overheating and damage to a centrifugal charging pump. The licensee entered the finding into the corrective action program as Condition Report CR-2015-003150. The licensees failure to follow the requirements of Procedure STA-201, Procedure Use and Adherence, to verify all applicable prerequisites were met prior to performing Procedure OPT-430A, Train A Integrated Test Sequence, was a performance deficiency. The performance deficiency was more than minor because it was associated with the human performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, operations personnels failure to ensure that component cooling water was properly aligned to the minimum flow line resulted in damage to a centrifugal charging pump. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, dated June 19, 2012, and Appendix G, Shutdown Operations Significance Determination Process, Attachment 1 Exhibit 3, Mitigating Systems Screening Questions, dated May 9, 2014, the finding was determined to be of very low safety significance (Green) because the finding did not represent a loss of safety function of a single required train, did not degrade level indication, and did not involve external events or fire protection. The finding has a human performance cross-cutting aspect associated with avoiding complacency because the licensee failed to plan for latent issues and inherent risk in performing a major test (H.12). |
| 05000446/FIN-2015001-07 | 2015Q1 | Comanche Peak | Inadequate Centrifugal Charging Pump Lubricating Oil Pump Installation Procedure | The inspectors reviewed a self-revealing finding of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings for failure to provide documented instructions of a type appropriate to the circumstances when performing maintenance on the centrifugal charging pump 2-02. As a result, the lubricating oil pump was not correctly installed and decoupled causing the charging pump to become inoperable. The licensee repaired the pump and revised the maintenance procedure. The licensee entered the finding into the corrective action program as Condition Report CR-2014-008651. The licensees failure to prescribe documented instructions of a type appropriate to the circumstances when performing maintenance on a charging pump was a performance deficiency. The performance deficiency was more than minor because it was associated with the procedure quality 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. The performance deficiency resulted in an inoperable centrifugal charging pump. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, dated June 19, 2012, the finding was determined to require a detailed risk evaluation because the finding represented an actual loss of function of a single centrifugal charging pump train for greater than its technical specification allowed outage time. A senior reactor analyst performed a detailed risk evaluation and determined that the finding was of very low safety significance (Green). The finding has a human performance cross-cutting aspect associated with training because the licensee failed to ensure the mechanics were adequately trained to understand the procedure and work requirements (H.9). |
| 05000445/FIN-2015001-05 | 2015Q1 | Comanche Peak | Failure to Provide an Accurate Shipping Manifest | The inspectors identified a non-cited violation of 10 CFR 71.5, pursuant to 49 CFR 172.203(d)(3), and 10 CFR 20.2006(b) for the licensees failure to ship radioactive waste with accurate manifests. Specifically, two radioactive waste shipments departed the site with inaccurate activity information on the manifest shipping papers. After determining that the shipment manifests and the amount of radwaste in the containers were incorrect, the licensee faxed corrected copies of the shipment manifests to the processor, suspended resin shipments, and conducted an apparent cause evaluation. The licensee entered the finding into the corrective action program as Condition Report CR-2015-000124. The failure to ship radioactive material with an accurate shipping manifest in accordance with 49 CFR 172.203(d) and 10 CFR 20.2006 was a performance deficiency. The performance deficiency was more than minor because it was associated with the program and process (transportation program) attribute of the Public Radiation Safety cornerstone and adversely affected the cornerstone objective. Specifically, incorrect information on shipment documentation could result in incorrect Department of Transportation shipping characterizations or incorrect waste classifications in accordance with 10 CFR 61. Using Inspection Manual Chapter 0609, Appendix D, Public Radiation Safety Significance Determination Process, dated February 12, 2008, the finding was determined to be of very low safety significance (Green) because: (1) radiation limits were not exceeded, (2) there was no breach of a package during transit, (3) it did not involve a certificate of compliance issue, (4) it was not a low level burial ground nonconformance, and (5) it did not involve a failure to make notifications or provide emergency information. The finding has a human performance cross-cutting aspect associated with avoid complacency because the licensee did not recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Specifically, the licensees procedure for conducting waste and material characterization did not include precautions related to not accounting for the decay of short lived isotopes or guidance on when it was appropriate to override a default software option to omit decay correction for material sample results (H.12). |
| 05000445/FIN-2015001-06 | 2015Q1 | Comanche Peak | Failure to Follow Procedure for Addressing Significant Conditions Adverse to Quality | The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for two examples of a failure to follow procedure for evaluating and correcting significant conditions adverse to quality. The licensee reduced the screening level of two significant conditions adverse to quality and therefore, failed to perform a root cause evaluation and identify corrective actions to preclude repetition. The licensee entered the finding into the corrective action program as Condition Reports CR-2015-002021 and CR-2015-003442. The licensees failure to follow the requirements of Procedure STA-422, Processing Condition Reports, was a performance deficiency. Specifically, the licensee failed to appropriately screen condition reports, perform root cause analyses, and identify corrective actions to preclude repetition for two significant conditions adverse to quality. The performance deficiency was more than minor because if left uncorrected, it could lead to a more significant safety issue. Specifically, for significant conditions to adverse to quality, the failure to use the appropriate screening criteria for condition report levels could result in failing to determine the cause and take corrective actions to preclude repetition. Because these failures were associated with unplanned reactor trips, this finding affected the Initiating Events cornerstone. Using Inspection Manual Chapter 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 1, Initiating Events Screening Questions, dated June 19, 2012, the finding was determined to be of very low safety significance (Green) because the finding did not cause a reactor trip and a loss of mitigation equipment. The finding has a human performance cross-cutting aspect associated with consistent processes because the licensee failed to use a consistent, systematic approach to make decisions to downgrade condition reports (H.13). |
| 05000446/FIN-2014005-01 | 2014Q4 | Comanche Peak | Failure to Follow Procedure for Boundary Valve Leakage Testing | The inspectors reviewed a self-revealing non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the failure to follow instructions when performing surveillance testing of the reactor coolant loop cold leg injection boundary valves. The test procedure had a prerequisite for the plant to be in mode 4 or 5. The licensee performed the test in mode 3 which isolated the residual heat removal system flow to loops 3 and 4 and aligned the loop 3 safety injection accumulator to the test line. As a result, both trains of residual heat removal and one safety injection accumulator were inoperable. The licensee revised the procedure for the plant conditions and re-performed the test. The licensee entered the finding into the corrective action program as Condition Report CR-2014-005254. The licensees failure to follow procedure for performing surveillance testing of the reactor coolant loop cold leg injection boundary valves was a performance deficiency. Specifically, personnel failed to ensure prerequisites were met in accordance with the procedure. The finding was more than minor because it was associated with the human performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability and reliability of systems that respond to initiating events to prevent undesirable consequences. The performance deficiency resulted in both trains of the residual heat removal system and one safety injection accumulator being inoperable. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the finding wa determined to require a detailed risk evaluation because the finding represented a loss o function for the residual heat removal system. A senior reactor analyst performed a bounding detailed risk evaluation and determined the finding to be of very low safety significance (Green). The finding has a human performance cross-cutting aspect associated with challenging the unknown because the licensee failed to stop when faced with uncertain conditions and evaluate risks before proceeding (H.11). |
| 05000498/FIN-2014005-01 | 2014Q4 | South Texas | Failure to Identify a Condition Adverse to Quality on Train A Emergency Diesel Generator | The inspectors documented a self-revealing non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to promptly identify and correct a condition adverse to quality following an unexpected alarm on the train A emergency diesel generator. Specifically, after receiving the, E-5 Starting Air System Malfunction alarm, the licensee did not identify the correct cause of the alarm or take the necessary action to ensure the operability and reliability of the emergency diesel generator. As a result, the train A emergency diesel generator was degraded for 20 days, and was later rendered inoperable and non-functional for approximately 26 hours when operators removed the only air start subsystem that remained unaffected from service. This issue was entered into the corrective action program as Condition Report 14-18639, and the cause was corrected. Failure to identify the cause for the starting air system alarm and recognize that this degraded the starting function was a performance deficiency. This performance deficiency is more than minor because it affected the equipment performance 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. Specifically, the failure to correctly identify and correct the cause of the E-5 Starting Air System Malfunction alarm resulted in the train A emergency diesel generator being degraded and later inoperable. Using NRC Inspection Manual 0609, Appendix A, The Significance Determination Process for Findings At-Power, the finding was determined to be of very low safety significance (Green) because it did not: 1) affect the design or qualification of a mitigating structure, system, or component; 2) represent a loss of system and/or function; 3) represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and 4) represent an actual loss of function of one or more non-technical specification trains of equipment designated as having high safety-significance. This finding has a cross-cutting aspect in the area of problem identification and resolution associated with Evaluation because the licensee failed to thoroughly evaluate the issue to ensure that resolutions address the causes and extent of conditions commensurate with the safety significance. Specifically, the licensees failure to fully evaluate the cause of the starting air system alarm, and as a result, failed to recognize and correct the out-of-position valve before it rendered the system inoperable (P.2). |
| 05000446/FIN-2014005-02 | 2014Q4 | Comanche Peak | Failure to Follow the Troubleshooting Activities Procedure in a Plant Transient | The inspectors reviewed a self-revealing finding for the licensees failure to follow the troubleshooting activities procedure while working on the condensate system alarm and control circuit. The troubleshooting activities caused the condensate low pressure heater bypass valve to open resulting in a plant transient. Operators responded to the event by manually initiating a turbine runback and then stabilized the plant. The workers had conducted additional troubleshooting activities without the awareness of operations and an evaluation by engineering, which did not meet the requirements of the troubleshooting procedure. The licensee entered the finding into the corrective action program as Condition Report CR-2014-001268. The failure to follow the troubleshooting activities procedure was a performance deficiency. The performance deficiency was more than minor because was associated with the human performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during power operations. Specifically, performing the additional troubleshooting steps without the required evaluation and notification resulted in a plant transient. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Appendix A, Exhibit 1, Initiating Events Screening Questions, the finding was determined to be of very low safety significance (Green) because the finding did not cause a reactor trip or the loss of mitigation equipment. The finding has a human performance cross-cutting aspect associated with documentation because the licensee failed to ensure that work packages were complete and thorough and that plant activities were governed by high-quality procedures (H.7). |
| 05000498/FIN-2014005-02 | 2014Q4 | South Texas | Failure to Update the UFSAR for the Ultrasonic Feedwater Flow Measurement System | The inspectors identified a non-cited violation of 10 CFR 50.71(e), Maintenance of Records, Making Reports, for the failure to update the Updated Final Safety Analysis Report with information on the installation and use of the ultrasonic feedwater flow measurement system to control reactor power and calibrate nuclear instruments, which was installed in both units by the end of 1999. This violation was entered into the corrective action program as Condition Report 15-420. The failure to update the Updated Final Safety Analysis Report, as required by 10 CFR 50.71(e), with a description of the ultrasonic feedwater flow measurement system was a performance deficiency. The inspectors determined that this performance deficiency was not more than minor. However, because it had the potential to impact the NRCs ability to perform its regulatory oversight function, the inspectors assessed more the significance of the violation using traditional enforcement. Using the NRC Enforcement Policy to evaluate the significance, the violation was determined to be a Severity Level IV violation in accordance with Section 6.1.d.3, since the lack of information in the Updated Final Safety Analysis Report was not used to make an unacceptable change to the facility or procedures. Cross-cutting aspects are not assigned to traditional enforcement violations. |
| 05000445/FIN-2014004-03 | 2014Q3 | Comanche Peak | Maintenance of a Standard Action Level Scheme for Main Steam Line Monitors | The inspectors identified a non-cited violation of 10 CFR 50.54(q)(2) for the failure to follow and maintain the effectiveness of an emergency plan that meets the requirements of planning standard 50.47(b)(4), which requires that a standard emergency classification and action level scheme is in use by the licensee. Specifically, several main steam line monitors were out of service for extended periods of time without apparent contingency actions in place in order to be able to declare an emergency. The licensee entered the finding into the corrective action program as Condition Report CR-2014-005874. The failure to maintain a standard emergency classification and action level scheme for the initiating condition requiring the main steam line monitors was a performance deficiency. The performance deficiency was more than minor because it affected the licensees ability to implement adequate measures to protect the health and safety of the public. Using Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, and Table 5.4-1, Significance Examples 50.47(b)(4), the finding was determined to be of very low safety significance (Green) because it was a failure to comply with NRC requirements and was not a degraded risk significant planning standard function. The planning standard function was not degraded because of other emergency action levels; an appropriate declaration could be made in an accurate and timely manner. This finding has a problem identification and resolution cross-cutting aspect associated with evaluation because the licensee failed to thoroughly evaluate the extent of condition of the inoperable monitors on the emergency plan and scheme for declaring emergencies (P.2). |
| 05000445/FIN-2014004-04 | 2014Q3 | Comanche Peak | Failure to Install an Insulated Bushing on a Generator Current Transformer Circuit Results in an Automatic Reactor Trip | The inspectors reviewed a self-revealing finding for the licensees failure to follow an electrical installation specification and install an insulated bushing on the end of a flexible conduit. As a result, a generator current transformer conductor shorted to ground causing a generator trip and ultimately an automatic reactor trip. The licensee repaired the conductor and returned the unit to service. The licensee entered the finding into the corrective action program as Condition Report CR-2014-000579. The failure to follow an electrical installation specification and install an insulated bushing on the end of a flexible conduit was a performance deficiency. The performance deficiency was more than minor because it was associated with the human performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective 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, Attachment 04, Initial Characterization of Findings, and Appendix A, Exhibit 1, Initiating Event Screening Questions, the finding was determined to be of very low safety significance (Green) because although the finding caused a reactor trip, it did not involve the loss of mitigation equipment. The inspectors determined that the finding was not representative of current licensee performance and no cross-cutting aspect was assigned. |
| 05000445/FIN-2014004-01 | 2014Q3 | Comanche Peak | Failure to Establish Goals and Monitor the Performance of the Uninterruptible Power Supply Air Conditioning System | The inspectors identified a non-cited violation of 10 CFR 50.65(a)(1) for the failure to establish performance goals and perform monitoring to ensure the uninterruptible power supply air conditioning unit X-01 was capable of performing its intended function. Specifically, the licensee failed to include unavailability hours that caused the equipment to exceed the performance criteria. The licensee planned to establish goals for the system. The licensee entered the finding into the corrective action program as Condition Report CR-2014-010188. The failure to establish goals and monitor the performance of the uninterruptible power supply air conditioning system was a performance deficiency. The performance deficiency 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 and reliability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Appendix A, Exhibit 2, Mitigating System Screening Questions, the finding was determined to be of very low safety significance (Green) because the finding did not represent an actual loss of safety function of a system and did not represent an actual loss of a technical specification train for greater than its allowed outage time. The finding has a human performance cross-cutting aspect associated with procedure adherence because the engineer failed to use human error reduction techniques when following procedure (H.8). |
| 05000445/FIN-2014004-02 | 2014Q3 | Comanche Peak | Inadequate Acceptance Criteria for Inservice Testing of Auxiliary Feedwater Discharge Check Valves | The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, for the failure to incorporate adequate acceptance limits in a written procedure to demonstrate components will perform satisfactorily. The licensee used acceptance criteria for inservice testing that did not demonstrate successful performance of the test. Specifically, the licensee failed to use appropriate acceptance limits which would have identified a failed check valve when testing auxiliary feedwater discharge check valves. The licensee revised the inadequate test procedure. The licensee entered the finding into the corrective action program as Condition Report CR-2014-010082. The licensees failure to incorporate adequate acceptance limits in a written procedure to demonstrate components perform satisfactorily was a performance deficiency. The finding was more than minor because it was associated with the procedure quality 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. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the finding was determined to be of very low safety significance (Green) because although the finding was a deficiency affecting the design or qualification of a mitigating system, the system maintained its operability and functionality. The inspectors determined that the finding was not representative of current licensee performance and no cross-cutting aspect was assigned. |
| 05000445/FIN-2014003-05 | 2014Q2 | Comanche Peak | Failure to Follow Procedure for Brazing Copper Tubing | The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the failure to follow procedure for brazing copper joints. Specifically, personnel failed to follow procedure and exercise sufficient care to assure the copper tubing was not overheated during a brazing activity. As a result, personnel overheated copper joints and caused the inoperability of an uninterruptible power supply air conditioning unit when the component developed a leak The licensee repaired the leak to the uninterruptible power supply air conditioning unit. The licensee entered the finding into the corrective action program as Condition Repor CR-2013-002298. The failure to follow procedure for brazing copper tubing was a performance deficiency. The performance deficiency was more than minor because it was associated with the human performance attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability and reliability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Appendix A, Exhibit 2, Mitigating System Screening Questions, the finding was determined to be of very low safety significance (Green) because the finding did not represent an actual loss of at least a single train of equipment for greater than its technical specification allowed outage time. The inspectors determined that the finding was not representative of current license performance and no cross-cutting aspect was assigned. |
| 05000445/FIN-2014003-06 | 2014Q2 | Comanche Peak | Failure to Correct Fire Protection Violations in a Timely Manner | The inspectors identified a 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 inspectors identified two examples where the licensee failed to implement corrective actions and restore compliance in a timely manner for two non-cited violations associated with the fire protection program. The licensee implemented compensator measures that included: hourly fire watches, changes to the safe shutdown procedures, and administrative changes to the fire protection program. The licensee entered the finding into the corrective action program as Condition Report CR-2014-007713. The failure to implement corrective actions and restore compliance in a timely manner for two violations associated with the fire protection program was a performance deficiency. The 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. Specifically, the potential loss of the credited charging pump or spurious opening of a power-operated relief valve adversely affected the availability, reliability, and capability of the systems required to achieve and maintain safe shutdown in the event of a fire. The inspectors evaluated the finding using Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, because it affected the ability to reach and maintain safe-shutdown conditions in case of a fire. A senior reactor analyst performed a Phase 3 evaluation to determine the risk significance of this finding. The senior reactor analyst determined this finding was of very low safety significance (Green). The finding has a human performance cross-cutting aspect associated with work management because the licensee failed to include the identification and management of risk commensurate to the work performed (H.5). |
| 05000445/FIN-2014003-09 | 2014Q2 | Comanche Peak | Licensee-Identified Violation | Noncompliance with Pressure and Temperature Limits Report During Vacuum Fill Technical Specification 3.4.3 RCS Pressure and Temperature (P/T) Limits, limitin condition for operation requires that, RCS pressure, RCS temperature, and RCS heatu and cooldown rates shall be maintained within the limits specified in the PTLR. If th limiting condition for operation cannot be met, Required Action C.1 requires, in part, tha the licensee immediately initiate action to restore parameters to within limits. Contrary t the above, from 1996 until April 8, 2014, the licensee failed to immediately initiate actio to restore parameters to within limits of the pressure and temperature limits report whe operating outside the limits. Specifically, the licensee failed to maintain the parameters within the limits of the pressure and temperature limits report during a reactor coolant system vacuum evolution. The finding was more than minor because it was associate with the human performance attribute of the Barrier Integrity Cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that the reactor coolant system protect the public from radionuclide released caused by accidents or events. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Appendix G, Attachment 1, Shutdown Operations Significance Determination Process Phase 1 Initial Screening and Characterization of Findings, Exhibit 4, Barrier Integrity Screen Questions, the finding was determined to be of very low safety significance (Green) because the finding did not challenge the reactor coolant system barrier. The violation was entered into the licensees corrective action program as Condition Report CR-2014-000960. This is the enforcement aspect of the licensee event report discussed in Section 4OA3.2. |
| 05000445/FIN-2014003-10 | 2014Q2 | Comanche Peak | Licensee-Identified Violation | Cable Routing Unanalyzed for Fire Safe Shutdown Barrier License Condition 2.G for Unit 2 requires, in part, that the licensee implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report through Amendment 87 and as approved in the Safety Evaluation Report and its supplements through Supplement 27. Section 9.5.1.3, Fire Hazard Analysis Evaluation, of the Final Safety Analysis Report references the Comanche Peak Nuclear Power Plant Fire Protection Report. Section II of the Fire Protection Report is the Fire Hazards Analysis Report. Section 4.5, Fire Protection Features for Fire Safe Shutdown, of the Fire Hazards Analysis Report specifies the allowable methods of ensuring that one of the redundant sets of systems necessary to achieve and maintain hot standby conditions is free of fire damage. Section 4.5.2.c, states, in part, that, enclosures of cables (if not one hour fire rated cables) and equipment and associated nonsafety circuits of components of redundant sets of systems in a fire barrier have a 1-hour rating. In addition, fire detectors and automatic fire suppressions systems adequate for hazards in the fire area are installed. Appendix A, CPNPP Fire Protection Program Separation Criteria Comparison Table, of the Fire Protection Report specifies that the separation method per Section 4.5 of the Fire Hazards Analysis Report utilized in fire area SB is method 2.c Contrary to the above, prior to June 19, 2014, the licensee failed to ensure that a associated nonsafety circuit in fire area SB was enclosed in a fire barrier having a 1-hou rating. Specifically, the licensee failed to ensure that cable EO223531, a cable in th control circuit for the train A containment recirculation sump isolation valve, wa enclosed in a fire barrier having a 1-hour fire rating. The licensee documented this issu in Condition Report CR-2014-004721. This violation was determined to be of very lo safety significance (Green) based on Inspection Manual Chapter 0609, Appendix F Attachment 1, Fire Protection Significance Determination Process Phase 1 Worksheet Question 1.4.4.A. This is the enforcement aspect of the licensee event report discusse in Section 4OA3.3. |
| 05000445/FIN-2014003-11 | 2014Q2 | Comanche Peak | Licensee-Identified Violation | Hot Short Prevention Cable Shield Conductor License Condition 2.G for Unit 2 requires, in part, that the licensee implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report through Amendment 87 and as approved in the Safety Evaluation Report and its supplements through Supplement 27. Section 13.3B.5, Quality Assurance Program, of the Final Safety Analysis Report describes the fire protection quality assurance program. The fire protection quality assurance program states that measures shall be established to ensure that conditions adverse to fire protection such as failures, malfunctions, deficiencies or deviations, defective components, uncontrolled combustible material and nonconformances are promptly identified, reported, and corrected. Contrary to the above, prior to June 19, 2014, the licensee failed to ensure that a condition adverse to fire protection was promptly corrected. Specifically, the licensee failed to properly connect the shield conductor for the hot short prevention cable that was installed as part of a modification to resolve a fire protection nonconformance. The licensee identified that the modification design connected the hot short prevention cable shield conductor to the plant ground instead of the dc negative potential. The licensee identified this issue in Condition Report CR-2014-005198. The senior reactor analyst determined this violation was of very low safety significance (Green) based on a bounding Phase 3 evaluation. |
| 05000445/FIN-2014003-01 | 2014Q2 | Comanche Peak | Failure to Follow 10 CFR 50.59 for a Change to the Spent Fuel Pool Configuration | The inspectors identified a non-cited violation of 10 CFR 50.59, Changes, Tests, and Experiments, for failure to conduct an adequate written evaluation and submit a license amendment for a change to the facility that required a technical specification amendment. Specifically, the licensee changed Procedure NUC-211, Surveillance of Region II Storage Limitations, Revision 1, to allow for storage of uprated fuel in Region II (high density racks) of the spent fuel pool using a methodology for fuel burnup penalties that had not been previously approved by the NRC and therefore, required an amendment to Technical Specification 3.7.17 Spent Fuel Assembly Storage prior to implementation. Subsequently, the licensee stopped all fuel movement in Region II of the spent fuel pool unless notifying the NRC prior to the movement. The licensee entered the finding into the corrective action program as Condition Report CR-2014-004693. The failure to perform an adequate 10 CFR 50.59 evaluation and obtain prior NRC approval for a change to the facility that involved a change to the technical specifications was a performance deficiency. The inspectors concluded that this issue involved traditional enforcement because it had the potential for impacting the NRCs ability to perform its regulatory function. This performance deficiency is more than minor because it was associated with the reactivity control attribute of the Barrier Integrity Cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Because the significance determination process does not directly address spent fuel pool criticality, a senior reactor analyst evaluated this issue using Inspection Manual Chapter 0609, Appendix M, Significance Determination Process Using Qualitative Criteria. Based on calculations provided by the licensee, the analyst determined that even with all uncertainties included in the calculations, the spent fuel pools would remain subcritical under all conditions, including a complete dilution of the borated water. The analyst qualitatively considered a completed dilution of the spent fuel pools to be a very low probability event. Therefore, the analyst concluded that this issue was of very low safety significance (Green). Because this issue was considered to be Green, it is treated as a Severity Level IV violation in traditional enforcement. The inspectors determined that the finding was not representative of current license performance and no cross-cutting aspect was assigned. |
| 05000446/FIN-2014003-02 | 2014Q2 | Comanche Peak | Failure to Provide Appropriate Instructions for Filling the Component Cooling Water System | The inspectors reviewed a self-revealing non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the failure to have documented instructions of a type appropriate to the circumstances when performing a activity affecting quality. Specifically, the licensee failed to have appropriate instructions for filling a Unit 2 component cooling water heat exchanger. As a result, component cooling water was inadvertently isolated to spent fuel pool heat exchanger X-02. The operators immediately stopped the filling activity and restored cooling water to the spent fuel pool heat exchanger. The licensee entered the finding into the corrective action procedure as Condition Report CR-2014-004111. The failure to have appropriate instructions for filling a Unit 2 component cooling water heat exchanger was a performance deficiency. The performance deficiency was more than mino because it was associated with the procedure quality attribute of the Barrier Integrit Cornerstone and adversely affected the cornerstone objective to provide reasonabl assurance that spent fuel pool design barriers protect the public from radionuclide releases caused by accidents or events. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Appendix A, Exhibit 3, Barrier Integrity Screening Questions, the finding was determined 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 finding has a human performance crosscutting aspect associated with work management because the licensee failed to ensure that the work process identified and managed the risk commensurate with the work (H.5). |
| 05000445/FIN-2014003-04 | 2014Q2 | Comanche Peak | Failure to Adequately Brief Workers on Radiological Conditions Prior to Entry into High Radiation Areas | The inspectors reviewed a self-revealing, non-cited violation of Technical Specification 5.7.1 resulting from the licensees failure to control high radiation areas with radiation levels of 100 millirem per hour or greater on three separate occasions. In each instance, the licensee failed to adequately inform the worker of current radiological dose rates prior to entry and the worker entered a posted high radiation area without proper knowledge of the radiological conditions (dose rates). Consequently, the workers received unanticipated high dose rate alarms on their electronic alarming dosimeters at 563 millirem per hour, 274 millirem per hour, and at 750 millirem per hour, respectively. As immediate corrective actions, the licensee performed follow-up surveys, coached the involved individuals, and reviewed the radiologically controlled area entry card requirements. The licensee entered the three issues into the corrective action program as Condition Reports CR-2013-004154, CR-2014-003464, and CR-2014-003997 The failure to provide workers with proper knowledge of high radiation area radiologica conditions prior to entry is a performance deficiency. The performance deficiency is mor than minor because it impacted the program and process attribute (exposure control) of the Occupational Radiation Safety Cornerstone and adversely affected the cornerston objective of ensuring adequate protection of worker health and safety from exposure t radiation. Specifically, worker entry into high radiation areas without knowledge of the radiological conditions placed them at increased risk for unnecessary radiation exposure. Using Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, the finding was determined to be of very low safety significance (Green) because: (1) it was not an as low as is reasonably achievable finding, (2) there was no overexposure, (3) there was no substantial potential for an overexposure, and (4) the ability to assess dose was not compromised. The finding has a human performance cross-cutting aspect associated with teamwork because the workers failed to demonstrate and execute a strong sense of communication and collaboration in connection with the operational activities involved in the finding to ensure nuclear safety was maintained (H.4). |
| 05000445/FIN-2014003-07 | 2014Q2 | Comanche Peak | Failure to Follow the Site Design Modification Procedures | The inspectors reviewed a self-revealing finding for the failure to follow the design modification process. The licensee implemented a design modification using incorrect technical information. The personnel who conducted the design modification walk-downs did not fully understand their responsibility and the licensees work organization did not ensure that anyone actually verified the physical details of the cable route. As a result, the design modification was inadequate and an incorrect cable was cut which caused a loss of all offsite power to the safety-related 6.9 kV busses on both units. The licensee suspended the modification activities, repaired the damaged offsite power cable, and restored offsite power to the safety-related 6.9 kV busses. The licensee entered the finding into the corrective action program as Condition Report CR-2013-012287. The failure to follow the electronic design change process procedure was a performance deficiency. The performance deficiency was more than minor because it was associated with the human performance attribute of the Initiating Events Cornerstone and adversely affected the cornerstone objective 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, Attachment 04, Initial Characterization of Findings, and Appendix A, Exhibit 1, Initiating Event Screening Questions, the finding was determined to be of very low safety significance (Green) because although the finding involved the complete loss of a support system that caused an initiating event, it did not involve the loss of affected mitigation equipment. The finding has a human performance cross-cutting aspect associated with field presence because the licensee failed to ensure proper oversight of contractors to ensure deviations from standards and expectations were promptly corrected (H.2). |
| 05000445/FIN-2014003-08 | 2014Q2 | Comanche Peak | Failure to Follow Procedure to Provide Adequate Work Instructions | The inspectors reviewed a self-revealing finding for the failure to properly plan and review work activities to ensure equipment and personnel safety. Specifically, the licensee failed to ensure the work instructions met the requirements of Procedure STA-606, Control of Maintenance and Work Activities, Revision 32. As a result, during the implementation of a modification, personnel used an inadequate work instruction and cut the incorrect cable which caused a loss of all offsite power to the safety-related 6.9 kV busses on both units. The licensee suspended the modification activities, repaired the damaged offsite power cable, and restored offsite power to the safety-related 6.9 kV busses. The licensee entered the finding into the corrective action program as Condition Report CR-2013-012287. The failure to follow procedure and provide adequate work instructions was a performance deficiency. The performance deficiency was more than minor because it was associated with the procedure quality attribute of the Initiating Events Cornerstone and adversely 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, Attachment 04, Initial Characterization of Findings, and Appendix A, Exhibit 1, Initiating Event Screening Questions, the finding was determined to be of very low safety significance (Green) because although the finding involved the complete loss of a support system that caused an initiating event, it did not involve the loss of affected mitigation equipment. The finding has a human performance cross-cutting aspect associated with avoiding complacency because the licensee failed to ensure that work planning personnel planned for the possibility of mistakes and latent issues and did not implement appropriate error reduction tools (H.12). |
| 05000445/FIN-2014003-03 | 2014Q2 | Comanche Peak | Maintenance of a Standard Action Level Scheme for Main Steam Line Monitors | Introduction. The inspectors identified an unresolved item related to maintaining the effectiveness of the licensees emergency plan that meets planning standard 50.47(b)(4), which requires, in part, that a standard emergency classification and action level scheme is in use by the licensee. Specifically, several main steam line monitors were out of service for extended periods of time without apparent contingency actions in place to ensure the correct emergency action level would be implemented. Description. On November 20, 2013, the licensee initiated Condition Report CR-2013-011914 identifying that the main steam line radiation monitors had a trend of being out-of-service for significant time periods. Monitor 1-RE-2328 was out of service for 110 and 210 days on two separate occasions. Monitor 1-RE-2326 was out of service for 77 and 157 days on two separate occasions. Monitor 1-RE-2325 was out of service for 61 days. Four other monitors from the two units had been out of service, some more than once, for periods of five days or less. There are four online main steam line monitors for each unit. The licensee addressed the trend by trouble-shooting, repairing, and replacing detectors. The main steam line radiation monitors are important to emergency preparedness because they are inputs into the emergency action levels and define the initiating conditions related to abnormal radiation releases/radiation effluent emergency declarations. The inspectors determined that the licensee had taken appropriate action to initiate corrective action and repair. The licensee also tracked the out of service time of the monitors as operational focus items and in the station tactical equipment issues list. All eight main steam line monitors are currently in service with zero out of service days in 2014. However, there was no evidence that contingency actions were implemented to maintain the approved emergency action level scheme when the monitors were out of service. Title 10 CFR 50.54(q) requires licensees to maintain the effectiveness of an emergency plan that meets the requirements in the planning standards of 50.47(b). Title 10 CFR 50.47(b)(4) requires a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee. This issue was identified as an unresolved item because the NRC has not determined whether the licensee has adequately implemented planning standard 10 CFR 50.47(b)(4). Specifically, the NRC has not determined whether the emergency action level initiating condition was rendered ineffective, such that, any general emergency would not be declared for a particular off-normal event in an accurate and timely manner or in a degraded manner. The licensee has entered this issue into the corrective action program as Condition Report CR-2014-005874. This issue is identified as unresolved item URI 05000445/2014003-03; 05000446/2014003-03, Maintenance of a Standard Action Level Scheme for Main Steam Line Monitors. |
| 05000445/FIN-2014002-01 | 2014Q1 | Comanche Peak | Failure to Follow Procedure for Operation of the Containment Emergency Air Lock Doors | The inspectors reviewed a self-revealing non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the failure to follow procedure for performing surveillance testing of the containment emergency air locks. Specifically, licensee personnel failed to fully close the Unit 1 containment emergency airlock exterior door and equalizing valve after performance of a door seal leak surveillance test. As a result, the containment emergency air lock exterior door was inoperable. Upon discovery, the licensee properly closed the containment emergency airlock door. The licensee entered the finding into the corrective action program as Condition Report CR-2013-000264. The finding was more than minor because it was associated with the human performance attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that containment physical design barriers protect the public from radionuclide releases caused by accidents or events. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Appendix A, Exhibit 3, Barrier Integrity Screening Questions, the finding was determined to be of very low safety significance (Green) because the finding did not represent an actual open pathway in the physical integrity of reactor containment. The finding has a human performance cross-cutting aspect associated with resources, in that, the licensee failed to ensure that equipment and procedures were adequate to support nuclear safety (H.1). |
| 05000445/FIN-2013005-01 | 2013Q4 | Comanche Peak | Failure to Follow Instructions for Containment Sump Inspection Results in Debris Left in the Sump | The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the failure to follow instructions and maintain appropriate housekeeping and cleanliness controls when performing an inspection in the containment emergency sump. As a result, the four sections of tape that were attached to the wheels of the robot, used to perform the inspection, fell off and remained in the sump for an operating cycle. The licensee entered the finding into the corrective action program as Condition Report CR-2013-005097. The finding was more than minor because it was associated with the human performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee did not follow documented instructions and ensure no foreign material remained in the sump after the inspection. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, the finding was determined to be of very low safety significance (Green) because the finding was not a design or qualification deficiency; did not represent an actual loss of safety function of a system or train; and did not result in the loss of one or more trains of non-technical specification trains of equipment. The finding has a human performance cross-cutting aspect associated with resources, in that, the licensee failed to ensure the work instruction was adequate for the inspection activity. |
| 05000498/FIN-2013005-01 | 2013Q4 | South Texas | Failure to Include Appropriate Acceptance Criteria in a Quality Procedure | The inspectors identified a non-cited violation of Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for failure to include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. Specifically, the licensee did not include sufficient criteria to identify and evaluate new critical tasks created for operator performance on the simulator scenario portion of the biennial requalification examination to enable the evaluators to correctly assess licensed operator performance. The licensee has entered this issue into their corrective action program as Condition Report 2013-13857. The failure to include appropriate qualitative acceptance criteria in Procedure LOR-GL-002, to ensure evaluators can correctly identify and evaluate critical tasks based on operator performance was a performance deficiency. The performance deficiency was more than minor, therefore, a finding, because if left uncorrected, the performance deficiency would have the potential to lead to a more significant safety concern. Specifically, the failure to include the appropriate criteria to identify and evaluate critical tasks during biennial requalification examinations could result in operators returning to licensed operator duties without being properly remediated and retested on performance deficiencies. Using Manual Chapter 0609, Attachment 0609.04, Appendix I, Operator Requalification Human Performance Significance Determination Process, starting at block 9, the finding was determined to be of very low safety significance (Green) because the finding is associated with licensee administration of an annual requalification operating test. The finding had a cross-cutting aspect in the area of human performance associated with the decision-making component because the licensee failed to make safety-significant or risk-significant decisions using a systematic process (H.1(a)) (Section 1R11.3.b.1). |
| 05000445/FIN-2013005-02 | 2013Q4 | Comanche Peak | Cutting Incorrect Cable Results in an Inoperable Offsite Power Source | The inspectors reviewed a self-revealing finding for the failure of maintenance personnel to follow work instructions. Specifically, maintenance personnel failed to follow instructions and cut the wrong cable during a transformer modification. As a result, one offsite power source to both units was unavailable during the repair of the damaged cable. The licensee entered the finding into the corrective action program as Condition Report CR-2013-011124. The finding was more than minor because it was associated with the human performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At Power, the finding was determined to be of very low safety significance (Green) because the finding was not a design or qualification deficiency; did not represent an actual loss of safety function of a system or train; and did not result in the loss of one or more trains of non-technical specification trains of equipment. The finding has a human performance cross-cutting aspect associated with work practices in that the licensee personnel failed to use human performance error prevention techniques such as self and peer checking when cutting cables. |
| 05000498/FIN-2013005-02 | 2013Q4 | South Texas | Flawed Job Performance Measures | The inspectors identified a finding of very low safety significance for developing and administering an excessive number of flawed job performance measures during the 2012 and 2013 NRC annual operating tests, which resulted in invalidating several operators NRC annual operating tests. The inspectors reviewed all of the job performance measures that were developed and/or administered to the licensed operator staff for their annual operating tests. Greater than 20 percent of the job performance measures reviewed for both 2012 and 2013 were deemed to be flawed and inappropriate for an NRC-required operating test. This invalidated the operating tests for some of the licensed operators in both years. As part of their corrective action, Condition Report 2013-10673, the licensee retested the operators that were affected after the 2013 test, and analyzed the effect on site-wide human performance errors that the affected operators may have had after the 2012 operating testthere was no increase in human performance errors attributable to taking the flawed 2012 operating test. Using Inspection Procedure 71111.11, Appendix C, Annual Requalification Operating Test Quality, more than 20 percent of the annual operating test job performance measures developed in 2012 and 2013 were flawed; therefore, this was a performance deficiency. In accordance with Manual Chapter 0612, Power Reactor Inspection Reports, the performance deficiency was more than minor, therefore, a finding because it affected the Initiating Events Cornerstone attribute of Human Performance, and adversely affected the cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Using Manual Chapter 0609, Attachment 0609.04, Appendix I, Operator Requalification Human Performance Significance Determination Process, starting at block 6, the finding was determined to be of very low safety significance (Green) because: the finding involved operating test quality; less than 40 percent of the job performance measures were flawed; and less than 40 percent of the simulator scenarios were flawed. 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 in decision making when developing the flawed job performance measures that invalidated several operators annual operating tests (H.1(b)) (Section 1R11.3.b.2). |
| 05000445/FIN-2013005-04 | 2013Q4 | Comanche Peak | Licensee-Identified Violation | The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meet the criteria of the NRC Enforcement Policy for being dispositioned as a non-cited violation. Title 10 CFR 50, Appendix B, Criterion III, Design Control, requires, in part, that measures shall be established to assure that applicable design bases requirements are translated into procedures. Contrary to the above, from 1989 until March 1, 2012, the licensee failed to assure that applicable design bases requirements were translated into procedures. Specifically, the licensee failed to assure preventative measures were established to ensure the electromagnetic door devices for the battery room and cable spreading room would maintain their function. The finding was more than minor because it was associated with design control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the reliability and capability of systems that respond to initiating event to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) For Findings At-Power, the inspector determined that the violation is of very low safety significance (Green) because the finding did not result in a loss of operability or functionality of a structure, system, or component. The violation was entered into the licensees corrective action program as Condition Report CR-2012-0002186. This is the enforcement aspect of the licensee event report discussed in Section 4OA3.1. |
| 05000445/FIN-2013005-03 | 2013Q4 | Comanche Peak | Notice of Enforcement Discretion 13-4-004 for a Loss of Both Required Offsite Power Circuits | On December 4, 2013, the two required offsite circuits to both Units 1 and 2 safety-related 6.9 kV buses became inoperable during planned modification work to install an additional 138 kV transformer (XST1A). As a result of the event, the licensee declared an Unusual Event. The inspectors responded to the control room to access the operators performance, procedure usage, and proper emergency plan declaration. The inspectors performed a walkdown of the control boards to verify appropriate equipment response following the loss of offsite power. The inspectors discussed the event with licensee personnel and the control room staff. Power was lost to the 345 kV transformer (XST2), which at the time was providing power to the 6.9 kV safeguards buses for both Units 1 and 2, when the licensee inadvertently cut into an energized 6.9 kV cable for transformer XST2, rather than the de-energized cable for transformer XST1. At 1:41 pm, both units entered Technical Specification 3.8.1, AC Sources - Operating, Condition C, Required Action C.2, restore one required offsite circuit to operable status with a completion time of 24 hours. If the completion time of 24 hours is not met, then both units would be required to enter Condition G and be in Mode 3 in 6 hours and Mode 5 in 36 hours. The licensee requested a notice of enforcement discretion and an additional 14 hours to restore transformer XST1 or XST2, such that the completion time of Required Action C.2 would expire at 3:41 a.m. on December 6, 2013. A notice of enforcement discretion was granted by the NRC staff at 1:00 p.m. on December 5, 2013. Consistent with NRC policy, the NRC agreed not to enforce compliance with the specific technical specifications in this instance, but will further review the cause(s) that created the apparent need for enforcement discretion to determine if there is a performance deficiency, if the issue is more than minor, or if there is a violation of requirements. This issue will be tracked as an unresolved item (URI) 05000445/2013005-03; 05000446/2013005-03, Notice of Enforcement Discretion 13-4-004 for a Loss of Both Required Offsite Power Circuits. |
| 05000445/FIN-2013004-01 | 2013Q3 | Comanche Peak | Failure to Remove Cable Material from Inside Containment | The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the failure to follow instructions and remove cables from containment as part of a modification. As a result, portions of 12 cables totaling approximately 100 feet in length wrapped with tape on the ends remained in containment and could have been transported to the emergency sumps during an accident. The licensee entered the finding into the corrective action program as Condition Report CR-2013-009443. 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, reliability, and capability of the emergency sumps. Using NRC Manual Chapter 0609, Significance Determination Process, Appendix G, Shutdown Operations Significance Determination Process, Attachment 1, Checklist 2, the finding was determined to be of very low safety significance because the licensee maintained adequate mitigation capability for the current plant state and the finding was not characterized as a loss of control event. The finding has a human performance cross-cutting aspect associated with work practices in that the maintenance personnel did not involve supervision when they had questions concerning the removal of the cables and proceeded in the face of uncertainty. |
| 05000445/FIN-2013004-02 | 2013Q3 | Comanche Peak | Failure to Establish Goals and Monitor the Performance of the Auxiliary Feedwater System | The inspectors identified a non-cited violation of 10 CFR 50.65(a)(1) for the licensees failure to establish performance goals and perform monitoring to ensure the Unit 1 auxiliary feedwater system was capable of performing its intended function. The licensee entered the finding into the corrective action program as Condition Report CR-2013-010024. This 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 and reliability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, the finding was determined to be of very low safety significance (Green) because the finding was not a design or qualification deficiency; did not represent an actual loss of safety function of a system or train; and did not represent an actual loss of a technical specification train for greater than its allowed outage time. The finding had a human performance cross-cutting aspect associated with decision-making, in that, the licensee failed to demonstrate that nuclear safety is the overriding priority by not obtaining adequate interdisciplinary input when determining the auxiliary feedwater maintenance rule status. |
| 05000445/FIN-2013004-03 | 2013Q3 | Comanche Peak | Failure to Properly Install Auxiliary Condenser Tube Plugs Causes Steam Generator Chemistry Excursion and Unit Power Reduction | The inspectors reviewed a self-revealing finding for the licensees failure to ensure the heat exchanger tube plugging procedure was adequate. As a result, auxiliary condenser plugs were improperly inserted and caused a tube to leak. This caused high sodium levels in the steam generators and a Unit 2 power reduction from 100 percent to less than 50 percent power. The licensee entered the finding into the corrective action program as Condition Report CR-2012-011805. The inspectors reviewed a self-revealing finding for the licensees failure to ensure the heat exchanger tube plugging procedure was adequate. As a result, auxiliary condenser plugs were improperly inserted and caused a tube to leak. This caused high sodium levels in the steam generators and a Unit 2 power reduction from 100 percent to less than 50 percent power. The licensee entered the finding into the corrective action program as Condition Report CR-2012-011805. |
| 05000445/FIN-2013004-04 | 2013Q3 | Comanche Peak | Failure to Initiate a Condition Report for a Degraded Under Frequency Relay | The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the failure to follow procedures that require initiating a condition report for degradation to safety-related equipment. During a surveillance activity, maintenance personnel discovered that a reactor coolant pump under frequency relay was outside the as-found setpoint tolerance for pick-up frequency and failed to enter the condition into the corrective action program. As a result, the cause and effect of the degraded condition was not evaluated and the relay again drifted outside the setpoint tolerance. The licensee entered the finding into the corrective action program as Condition Report CR-2013-010078. The finding was more than minor because if the licensee continues to fail to document degraded safety-related equipment in the corrective action database, there is a potential that this could lead to a more significant safety concern, in that the cause of the degradation will not be evaluated and corrected. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, the finding was determined to be of very low safety significance (Green) because the finding was not a design or qualification deficiency; did not represent an actual loss of safety function of a system or train; and did not represent an actual loss of a technical specification train for greater than its allowed outage time. The finding has a human performance cross-cutting aspect associated with resources in that the licensee failed to provide adequate training to personnel performing maintenance. |
| 05000445/FIN-2013004-06 | 2013Q3 | Comanche Peak | Licensee-Identified Violation | Title 10 CFR 50, Appendix B, Criterion III, Design Control, requires, in part, that design control measures shall assure that appropriate quality standards are specified and that deviations from such standards are controlled. Contrary to the above, from initial plant operation until October 2011, the licensee failed to control deviations from standards of material applications inside containment. Specifically, the licensee failed to identify and prevent the use of aluminum in multiple containment airlock valve bodies and pressure gauges in containment. The finding was more than minor because it was associated with the containment configuration control attribute of the Barrier Integrity cornerstone and adversely affected the associated 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 inspector determined that the violation is of very low safety significance (Green) because the finding did not represent an actual open pathway in the physical integrity of reactor containment. The violation was entered into the licensees corrective action program as Condition Report CR-2011-005686. The licensee subsequently removed the affected pressure gauges and replaced the hydraulic valves. This is the enforcement aspect of the licensee event report discussed in Section 4OA3. |
| 05000445/FIN-2013004-05 | 2013Q3 | Comanche Peak | Potential Motor-Operated Valve Single Spurious Operation Vulnerability | The inspectors identified an unresolved item associated with fire-induced single spurious operations. The inspectors were concerned that a single hot short could cause the spurious operation of motor-operated valves and bypass their torque/limit switch, resulting in damage to the pressure boundary. On February 28, 1992, the NRC issued Information Notice 92-18, Potential for Loss of Remote Shutdown Capability During a Control Room Fire, to alert licensees of conditions that could result in the loss of capability to maintain the reactor in a safe shutdown condition in the event that a control room fire forced operators to evacuate the control room (i.e., alternative shutdown scenarios). Information Notice 92-18 was primarily concerned with the loss of control of valves required for alternative shutdown. Specifically, the Information Notice was concerned with the potential for hot shorts to cause the spurious operation of these motor-operated valves and bypass their torque/limit switch, potentially damaging the valves before operators could transfer control to the remote shutdown panel. In this situation, the valves may not be able to be operated manually or from the remote shutdown panel. The licensee evaluated this issue in Engineering Report ER-ME-089, Resolution of NRC Information Notice 92-18, Potential Loss of Remote Shutdown Capability Following Control Room Fire, Revision 0, dated December 29, 1993. The licensee evaluated the population of motor-operated valves that were required to be operated manually or remotely from the remote shutdown panel for alternative shutdown scenarios. This population consisted of 86 motor-operated valves. The licensee made modifications as necessary to ensure that these valves could be operated manually or remotely from the remote shutdown panel for all alternative shutdown scenarios. In 2010, the licensee began their evaluation of multiple spurious operations in accordance with Nuclear Energy Institute Document NEI 00-01, Guidance for Post-Fire Safe-Shutdown Circuit Analysis, Revision 2. Appendix G to NEI 00-01 contained the generic list of multiple spurious operations scenarios applicable to pressurized water reactors. This appendix contained a scenario (MSO-55) that considered valve failure due to a spurious motor-operated valve operation in conjunction with a short that bypassed the torque/limit switch. This scenario was described as follows: General scenario is that fire damage to motor-operated valve circuitry causes spurious operation. If the same fire causes wire-to-wire short(s) such that the valve torque and limit switches are bypassed, then the valve motor may stall at the end of the valve cycle. This can cause excess current in the valve motor windings as well as valve mechanical damage. This mechanical damage may be sufficient to prevent manual operation of the valve. Scenario only applies to motor-operated valves. Note this generic issue may have already been addressed during disposition of the NRC Information Notice 92-18. This disposition should be reviewed in the context of multiple spurious operations and multiple hot shorts. The licensee formed a multiple spurious operations expert panel, which met in March 2010, to review the generic list of multiple spurious operations contained in NEI 00-01. The multiple spurious operations expert panel meeting results were documented in Engineering Report ER-ME-130, Summary of Expert Panel Activities Related to Postulation of Multiple Spurious Operations for the CPNPP Fire Safe Shutdown Analysis, Revision 0, dated April 2010. The licensee initially concluded that scenario MSO-55 was already addressed in the fire safe shutdown analysis. On August 17, 2010, the licensee convened a supplemental meeting of the multiple spurious operations expert panel. The expert panel reconsidered multiple spurious operations scenario MSO-55 and concluded that a nonconformance existed. Specifically, the expert panel concluded that the licensee had addressed the concerns raised in Information Notice 92-18 for alternative shutdown scenarios, but did not address the concerns for scenarios where operators did not need to evacuate the control room. The licensee subsequently evaluated the larger population of motor-operated valves that are used or must remain intact for post-fire safe shutdown. The licensee concluded that modifications were needed for 57 valves. Ten of the valves required a mechanical modification, while the remaining 47 valves required an electrical modification. The licensee entered this issue into their corrective action program as Condition Report CR-2010-007806 and implemented compensatory measures. The inspectors identified an issue of concern with the potential for single spurious operations to damage the pressure boundary. The inspectors determined that additional inspection is required to determine if a performance deficiency exists. This issue of concern is being treated as an unresolved item URI 05000445/2013004-06; 05000446/2013004-06, Potential Motor-Operated Valve Single Spurious Operation Vulnerability. |
| 05000445/FIN-2013003-01 | 2013Q2 | Comanche Peak | Inadequate Procedure for Testing the Main Steam Safety Valves | 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 have documented instructions of a type appropriate to the circumstances for testing the main steam safety valves. Specifically, the procedure for testing the main steam safety valves did not provide direction to declare the valves inoperable when applying pressure to the lifting device. As a result, the licensee failed to declare the main steam safety valves inoperable during testing. The licensee entered the finding in the corrective action program as Condition Report CR-2013-002947. The finding was more than minor because it was associated with the procedure quality attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the procedure did not provide guidance to declare a main steam safety valve inoperable with the test rig installed. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, the finding was determined to be of very low safety significance because the finding was not a design or qualification deficiency; did not represent an actual loss of safety function of a system or train; and did not result in the loss of one or more trains of non-technical specification trains of equipment. The inspectors determined that the finding was not representative of current licensee performance and no cross-cutting aspect was assigned. |
| 05000445/FIN-2013003-02 | 2013Q2 | Comanche Peak | Failure to Follow Procedure Results in Water Hammer | The inspectors identified a non-cited violation of Technical Specification 5.4.1.a for the failure to follow an auxiliary feedwater system operating procedure. As a result, a water hammer occurred on the condensate storage tank makeup reject line. The licensee entered the finding into the corrective action program as Condition Report CR-2012-012539. The finding was more than minor because it was associated with the human performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective, in that, it increased the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. Specifically, it resulted in a system water hammer. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, the finding was determined to be of very low safety significance because the finding did not cause a reactor trip and the loss of mitigation equipment. The finding had a human performance cross-cutting aspect associated with resources, in that, the licensee failed to ensure that personnel were adequately trained to perform the activity. |
| 05000445/FIN-2013003-03 | 2013Q2 | Comanche Peak | Failure to Properly Install an Air Regulator Causes Heater Drain Valve Closure and Reactor Trip | The inspectors reviewed a self-revealing finding for the licensees failure to appropriately plan and control work activities during the installation of an air regulator in the heater drain system. As a result, the fitting that connected the air regulator to an adjacent in-line air filter broke and caused a plant transient and an automatic reactor trip. The licensee entered the finding in the corrective action program as Condition Report CR-2012-012183. The finding was more than minor because it was associated with the equipment performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective in that it increased the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, the finding was determined to be of very low safety significance because the finding did not contribute to both the likelihood of a reactor trip and the likelihood that mitigating equipment would not be available. The finding had a human performance cross-cutting aspect associated with work control in that the licensee failed to appropriately plan the work activity. |
| 05000445/FIN-2013002-01 | 2013Q1 | Comanche Peak | Failed Condenser Support Causes Steam Generator Sodium Transient and Manual Reactor Trip | The inspectors reviewed a self-revealing finding for the failure to evaluate the effects of vibration on pipe supports in accordance with the design control program when removing the supported pipes. As a result, a pipe support failed due to fatigue and the falling support sheared circulating water tubes causing high sodium levels in the steam generators. The operators manually tripped the reactor as a result of high sodium levels in the steam generators. The licensee entered the finding in the corrective action program as Condition Report CR-2011-006118. The licensees failure to evaluate the effects of vibration on pipe supports in accordance with the design control program when removing the supported pipes was a performance deficiency. The finding was more than minor because it was associated with the design control attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective. It increased the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. Specifically, the performance deficiency resulted in a manual reactor trip. Using NRC Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, the finding was determined to be of very low safety significance because the finding did not contribute to both the cause of a reactor trip and affect mitigation equipment. The finding had a human performance cross-cutting aspect associated with decision-making, in that, licensee personnel failed to use conservative assumptions and adopt a requirement to demonstrate that the action was safe in order to proceed rather than a requirement to demonstrate that it was unsafe in order to disapprove the action. |
| 05000445/FIN-2013002-02 | 2013Q1 | Comanche Peak | Failure to Have Instructions When Performing Activities | The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, for the failure to accomplish an activity affecting quality as prescribed by documented instructions. Specifically, radiation protection personnel installed cameras inside containment and did not have a work order to accomplish the activity because the work order had not been completed and approved. The licensee entered the finding in the corrective action program as Condition Report CR-2013-001723. The licensees failure to have documented instructions for installing cameras inside containment 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, not using instructions could cause a more significant event and cause the inoperability of safety-related equipment. Using NRC Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, the finding was determined to be of very low safety significance because the finding was not a design or qualification deficiency; did not represent an actual loss of safety function of a system or train; and did not result in the loss of one or more trains of non-technical specification trains of equipment. The finding had a human performance cross-cutting aspect associated with work practices, in that, the licensee did not effectively communicate the expectations regarding the use of the work order when installing cameras inside containment. |
| 05000445/FIN-2013002-03 | 2013Q1 | Comanche Peak | Failure to Correct Diesel Frequency Degradation | The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, for the failure to preclude repetition of a significant condition adverse to quality. Specifically, the Unit 2 train B diesel generator failed to maintain 60 hertz during an isochronous test on April 9, 2011, which was a repeat of a significant condition adverse to quality identified in 2010. As a result, the capability of the diesel generator to supply emergency power was degraded. The licensee entered the finding in the corrective action program as Condition Report CR-2011-007683. The licensees failure to preclude repetition of the Unit 2 train B diesel generator frequency degradation, a significant condition adverse to quality, 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 capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the isochronous diesel frequency degraded from the nominal 60 hertz, which would cause powered equipment to slow down. Using NRC Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, the finding was determined to be of very low safety significance because the finding was not a design or qualification deficiency; did not represent an actual loss of safety function of a system or train; and did not result in the loss of one or more trains of non-technical specification trains of equipment. Although the diesel frequency was degraded, the diesel and all of its powered equipment remained capable of performing their safety functions. The finding had a problem identification and resolution cross-cutting aspect associated with the corrective action program, in that, the licensee failed to thoroughly evaluate problems such that the resolutions address causes and extent of conditions, as necessary. |
| 05000445/FIN-2013002-04 | 2013Q1 | Comanche Peak | Failure to Identify Inadequate Auxiliary Feedwater Valve Maintenance | 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, the licensee failed to identify and correct an inadequate auxiliary feedwater test line isolation valve preventative maintenance document. As a result, the valve was difficult to operate and was not fully closed following pump testing, causing auxiliary feedwater flow to be diverted away from the steam generators during a plant shutdown. The licensee entered the finding in the corrective action program as Condition Report CR-2013-003095. The licensees failure to identify and correct the inadequate preventative maintenance document that led to an auxiliary feedwater flow diversion was a performance deficiency. The finding was more than minor because it was associated with the procedure quality attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the inadequate maintenance resulted in auxiliary feedwater flow diverted away from the steam generators during a plant shutdown. Using NRC Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, the finding was determined to be of very low safety significance because the finding was not a design or qualification deficiency; did not represent an actual loss of safety function of a system or train; and did not result in the loss of one or more trains of non-technical specification trains of equipment. The finding had a problem identification and resolution cross-cutting aspect associated with the corrective action program, in that, the licensee failed to have a low threshold for identifying issues. |
| 05000445/FIN-2013002-05 | 2013Q1 | Comanche Peak | Failure to Initiate a Condition Report for a Degraded Reactor Coolant Pump Motor Lower Oil Reservoir | The inspectors reviewed a self-revealing non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, for the failure to follow procedures that require initiating a condition report for degradation of equipment. During a maintenance activity, the licensee discovered that the reactor coolant pump motor lower oil reservoir level was low and failed to enter the condition into the corrective action program. As a result, the cause of the degraded condition was not evaluated. The licensee entered the finding in the corrective action program as Condition Report CR-2012-011607. The licensees failure to initiate a condition report for a degraded reactor coolant pump motor lower oil reservoir was a performance deficiency. The finding was more than minor because it was associated with the equipment performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective. It increased the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. Using NRC Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, the finding was determined to be of very low safety significance because the finding did not contribute to both the cause of a reactor trip and affect mitigation equipment. The finding had a problem identification and resolution cross-cutting aspect associated with the corrective action program, in that, the licensee did not ensure issues potentially impacting nuclear safety are fully evaluated. Specifically, the licensee did not trend and assess the issues associated with the leaking reactor coolant pump motor oil reservoir. |
| 05000445/FIN-2013002-06 | 2013Q1 | Comanche Peak | Failure to Install Grout Under Pipe Support Base Plates | The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, for the failure to install grout under pipe support base plates for a main steam line in accordance with drawings. As a result, the pipe supports ability to withstand a seismic event was degraded. The licensee entered the finding in the corrective action program as Condition Report CR-2012-008954. The licensees failure to install grout under pipe support base plates for a main steam system pipe in accordance with drawings was a performance deficiency. The finding was more than minor because it was associated with the protection against external factors attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the lack of grout under the pipe support base plates reduced the capability of the support to protect the piping from a seismic event. Using NRC Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, the finding was determined to be of very low safety significance because the finding did not result in the total loss of any safety function that contributes to external event initiated core damage accident sequences. Specifically, despite the degraded condition, the inspectors concluded that the main steam system was capable of performing its safety functions. Since the performance deficiency occurred prior to 1993, the inspectors concluded that the finding was not representative of current licensee performance and no cross-cutting aspect was assigned. |
| 05000445/FIN-2013002-07 | 2013Q1 | Comanche Peak | Licensee-Identified Violation | Title 10 CFR 55.53(e) requires, in part, that to maintain active license status, the licensee shall actively perform the functions of an operator or senior operator on a minimum of seven 8-hour or five 12-hour shifts per calendar quarter. Contrary to the above, on October 23, 2011, an operator stood watch as the Unit 2 control room supervisor, a senior operator position, and failed to stand five 12-hour proficiency watches the previous calendar quarter. The finding was more than minor because if left uncorrected the finding could have become more significant, in that, allowing licensed operators to stand watch in the control room without valid demonstration of appropriate knowledge and abilities by not maintaining conditions of their licenses could be a precursor to a significant event if undetected performance deficiencies develop. Using NRC Manual Chapter 0609, Significance Determination Process, Phase 1 worksheets, the inspectors were directed to use Appendix I, Licensed Operator Requalification Significance Determination Process, to process this violation. However, the inspectors determined that NRC Manual Chapter 0609, Appendix I, could not be used to process this finding. Based on direction from headquarters and regional management to use NRC Manual Chapter 0609, Appendix M, Significance Determination Process Using Qualitative Criteria, the non-cited violation was determined to have very low safety significance. The licensee entered this issue into their corrective action program as Condition Report CR-2011-012886. |
| 05000445/FIN-2012005-01 | 2012Q4 | Comanche Peak | Foreign Material in Diesel Generator Governor Causes Start Failure | The inspectors reviewed a self-revealing non-cited violation of Technical Specification 5.4.1.a for the failure of the licensee to follow procedure and properly replace diesel generator governor oil. As a result, foreign material was introduced into the governor and caused a diesel generator start failure. The licensee replaced the governor to correct the problem. The licensee entered the finding into the corrective action program as Condition Report CR-2012-006280. The licensees failure to follow procedure and properly replace the diesel generator governor oil was a performance deficiency which resulted in a diesel generator start failure. The finding was more than minor because it was associated with the human performance attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the reliability of systems that respond to initiating events to prevent undesirable consequences. Using NRC Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, the finding screened to a detailed risk evaluation because it represented an actual loss of function of a single train for greater than its technical specification allowed outage time. A senior reactor analyst evaluated the risk and determined that the risk was of very low safety significance. The finding has a human performance cross-cutting aspect associated with work control, in that, the job site conditions impacted the human performance of the work activity. |