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05000250/FIN-2009003-012009Q2Turkey PointFailure to Implement Procedures for Conducting a Valve Alignment Causes Spill of Reactor Coolant And Contamination Of a Plant EmployeeA Self-revealing Non-cited Violation of Technical Specification (TS) 6.8.1 was identified for failure to follow procedures that assure that valves are maintained in the proper positions. As a result of mis-positioning of letdown system valves, a spill of reactor coolant from the Unit 3 letdown system occurred onto the auxiliary building roof and a security officer was contaminated. The licensee documented this in CR 2009-14469.The finding was more than minor because it affected the Human Performance attribute of Initiating Events cornerstone and if failure to implement valve position controls were left uncorrected it would have the potential to lead to a more significant safety concern. The inspectors evaluated the finding using NRC Inspection Manual 0609, Attachment0609.04, SDP Phase 1. Because the finding did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available, the finding was screened as Green. The cross-cutting element of Human Performance, Work Practices, Human Performance & Error Prevention (H.4(a)), was affected when the licensee did not properly document activities regarding the failure to position valves in accordance with a specified valve lineup
05000250/FIN-2009003-062009Q2Turkey PointInadequate Evaluation of Damaged Rod Control Extension Results in High Risk Condition and Condition YellowA Self-revealing Finding was identified when the licensee did not manage maintenance activities adequately to identify and repair a damaged rod control drive component on Unit 3 prior to setting the reactor vessel closure head on the reactor vessel flange. As a result, the subsequently filled reactor coolant system had to be drained again to 2 feet below the reactor vessel flange (a high risk activity) placing the unit in the licensees risk condition Yellow for repairs. The licensee documented this in condition report (CR) 2009-10284.The finding was more than minor because it affected the Human Performance attribute of Initiating Events cornerstone and the licensee=s risk assessment failed to anticipate that the maintenance activity could result in another plant draining evolution with its inherent risk of an initiating event of loss of inventory or shutdown cooling. With appropriate mitigating equipment available, the finding screened to be of very low safety significance (Green). The finding affected the cross cutting area of Human Performance, Work Practices, Supervisory & Management Oversight (H.4(c)) because the licensee did not appropriately provide oversight of work activities, including contractors, such that nuclear safety is supported
05000250/FIN-2009003-072009Q2Turkey PointFailure to Implement TS Requirements Regarding Structural Integrity of Code Class 2 Main Steam Isolation ComponentsThe inspectors identified a Non-cited violation of TS 3.4.10 requirements on Unit3 regarding required components, when plant operation continued although a structural flaw in Class 2 main steam isolation valve steam trap piping had been identified. As a result of using an incorrect drawing in assessing the leak, plant operation continued although a plant shutdown should have been initiated. The licensee documented this in CR 2009-15284.The finding was more than minor because it affected the RCS equipment and barrier performance attribute of the Barrier Integrity cornerstone and the un-isolable through wall leak challenged the integrity of the main steam system for isolating steam generator tube ruptures. Using Manual Chapter 0609, Attachment 0609.04, Phase 1 screening, this finding was determined to be of very low safety significance because all containment barrier characterization answers marked as No. The cross-cutting element of Human Performance, Decision Making, Conservative Assumptions & Safe Actions (H.1 (b)) was affected when the licensee did not use conservative assumptions in evaluating a Class 2component flaw and its TS implications, and did not demonstrate that continued operation with the crack was safe in order to proceed
05000250/FIN-2009003-022009Q2Turkey PointFailure to Implement TS Requirements Resulting From Loss of Configuration Control of the 3C Main Steam Isolation ValveA Self-Revealing Non-cited violation of TS 3.7.1.5 requirements was identified when the Unit 3 C main steam isolation valve (MSIV) failed to close on demand on May4, 2009. Licensee evaluation has found the root cause of the failure to be an inadequate post maintenance test after maintenance that resulted in the air throttle valve for the MSIV being left in the closed position. When identified, the licensee placed the throttle valve in the correct position and tested the valve stroke time satisfactorily. The licensee documented this in CR 2009-13568.The finding was more than minor because it affected the Configuration Control attribute of the Mitigating Systems cornerstone and the failure of the MSIV to close when demanded challenged the integrity of the main steam system for isolating steam system or generator tube ruptures. The inspectors evaluated the finding using NRC Inspection Manual 0609, Attachment 0609.04, SDP Phase 1 and SDP Phase 2. An initial SDP Phase 2 screening of the finding revealed a greater than green result for Large Early Release Probability (LERF) and Phase 3 was required. A Regional Senior Reactor Analyst performed a Phase 3 evaluation of the performance deficiency and classified the finding of very low safety significance (Green). The major assumption was predicated on the information in NUREG 1806, Technical Basis for Revision of the Pressurized Thermal Shock (PTS) Screening Limit in the PTS Rule (10CFR50.61), which indicated that the possibility of core damage was remote following an extreme cool down due to a Main Steam Line Break without isolation. The cross-cutting aspect of Human Performance, Work Practices, Human Performance & Error Prevention (H.4(a)) was affected when personnel did not practice error prevention techniques such as self and peer checking, and properly document activities
05000250/FIN-2009003-032009Q2Turkey PointFailrue to Maintain Lighting Impedes Compensatory Measure For Failed Fire DetectionThe inspectors identified a Green finding for failure to correct failed lighting in a Unit 4 electrical penetration room that prevented the hourly rover from adequately compensating for fire detection that was out of service. The inspectors determined that maintaining lighting in areas of degraded fire protection features is not a specific NRC requirement. The licensee documented this in CR 2009-17533.The finding was more than minor because it affected the External Event attribute of the Mitigating Systems cornerstone and failure to correct a problem that impacted the ability of fire watch personnel to adequately compensate for out of service fire detection equipment could reasonably be viewed as a precursor to a significant fire event. The inspectors evaluated this finding using NRC Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination. The finding was screened as Green because the assigned fire degradation rating was low. The finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, Appropriate & Timely Corrective Actions (P.1(d)) because the licensee did not document and correct a problem that was previously identified
05000250/FIN-2009003-042009Q2Turkey PointFailure to Assure That Design Controls Were Maintained During Maintenance On The 3B Main Steam Isolation Valve (MSIV)The inspectors identified a Non-cited violation of 10 CFR50, Appendix B, Criterion III, Design Control when maintenance personnel failed to follow procedure during reassembly of 3B main steam isolation valve and did not maintain proper configuration of a safety-related component. The licensee documented this in CR 2009-11481.The finding was determined to be more than minor because it was associated with the Design Control attribute of the Mitigating Systems cornerstone, and it affected the cornerstone objective to ensure the reliability of systems that respond to initiating events to prevent undesirable consequences, such as the 3B MSIV. Using Manual Chapter 0609, Attachment 0609.04, Phase 1 screening, this issue was determined to be of very low safety significance because the design deficiency did not result in loss of operability. The cross-cutting element of Human Performance, Work Practices (H.4.(b)) was affected when the licensee did not effectively communicate expectations regarding procedural compliance and contractor personnel did not follow procedures
05000250/FIN-2009003-052009Q2Turkey PointFailure to Implement Design Controls When Modifying Safety Equipment During Painting ActivitiesA Self-revealing Non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion V was identified for failing to implement procedures that assure design control during an alteration to the 4C intake cooling water pump motor, a safety-related component. As a result, the running Unit 4 C intake cooling water pump experienced a high temperature condition and was stopped by operators. The pump may not have been able to complete its design function with the alteration that restricted the cooling air flow for the motor during painting activities. The licensee documented this in CRs 2009-15970 and2009-16336.The finding was more than minor because it affected the Human Performance attribute of the Mitigating Systems cornerstone and the licensee did not complete an engineering evaluation of the modification causing a high temperature condition on the motor to assure that the motor could perform its design functions. Also, NRC Inspection Manual Chapter 0612, Appendix E, Example 4.a was applicable (failure to perform an engineering evaluation with missed opportunities for licensee identification) and the finding was more than minor. The finding screened as Green using NRC Inspection Manual Chapter 0609, Attachment 0609.04, SDP Phase 1 screening because the finding did not result in a loss of function of a single train of TS equipment for greater than the allowed outage time of 14 days. The finding affected the cross-cutting area of Human Performance, Work Practices, Supervisory & Management Oversight (H.4(c)) because the licensee did not ensure supervisory oversight of work activities, including contractors, such that nuclear safety is supported
05000250/FIN-2009002-012009Q1Turkey PointLicensee-Identified ViolationTurkey Point Technical Specification 3.6.3 requires three operable emergency containment filtering units when Unit 3 is operated in Modes 1 thru 4. Further, with one filtering unit inoperable, restore the inoperable unit to operable status within 7 days or be in Hot Standby within 6 hours and Cold Shutdown within the following 30 hours. Contrary to the above, as of August 27, 2008, Unit 3 containment filtering unit 3B was inoperable in excess of 7 days because of an inadequate electrical design that had occurred years before and no action was taken to place the unit in the required configuration. The problem was discovered by the licensee during an engineering review in preparation for circuit modification and was corrected on August 28, 2008 by modifying the circuit to eliminate the design flaw. Because redundant filtering units were not affected, and the affected unit would be manually started if required, the issue was of very low safety significance (Green). The issue was documented in the licensee corrective action program as CR 2008-27014 and reported to the NRC in Licensee Event Report 05000250/2008-004-00
05000250/FIN-2009002-022009Q1Turkey PointLicensee-Identified ViolationTurkey Point Technical Specification 6.8.5 requires that administrative procedures be implemented to limit the working hours of personnel who perform safety related functions, and that any deviation from the guidelines be authorized by department managers or higher. The licensee implements these requirements with procedure QI 1- PTN-1 which states in paragraph 5.8.1 that to the extent practicable, personnel are not assigned to shift duties while in a fatigued condition that could significantly reduce their mental alertness or their decision making ability. Additionally, in paragraph 5.8.6, the procedure states that the circumstances of the extraordinary action shall be documented on an overtime deviation request form and that each deviation requires a separate deviation form. Contrary to the above, the licensee had identified multiple examples (listed below) where deviations from the working hour guidelines had occurred without documenting the circumstances of the extraordinary action on a separate deviation form. The issue was entered into the corrective actions program as CR 2008-31143. The licensee has planned and implemented actions noted in the following CRs to prevent exceeding the working hour limits on any routine basis: 1. (CR 2008-17179) Deviation request completed for meeting of up to 33 operations personnel held on May 14, 2008 for work authorization to exceed 24 hours in a 48 hour period or 72 hours in a 7 day period, but no authorization was written for the same individuals exceeding these limits in the subsequent shifts. 2. (CR 2008-17180) Deviation request completed for meeting of up to 35 operations personnel held on May 20, 2008 for work authorization to exceed 24 hours in a 48 hour period or 72 hours in a 7 day period, but no authorization was written for the same individuals exceeding these limits in the subsequent shifts. 3. (CR 2008-21249) Deviation request completed for two operations personnel on June 27, 2008 for work authorization to exceed 72 hours in a 7 day period, but no authorization was written for these individuals subsequently exceeding these limits on June 29 and June 30, 2008. 4. (CR 2008-15659, and 2008-14968) Deviation request completed after the fact for two operators assigned to exceed 24 hours in a 48 hour period or 72 hours in a 7 day period, on April 30, 2008 and no deviation request was completed for exceeding these limits on May 1, 2008