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| Quarter | Site | Title | Description | |
|---|---|---|---|---|
| 05000382/FIN-2010005-08 | 2010Q4 | Waterford | Licensee-Identified Violation | Procedure, EN-QV-111, Training and Certification of Inspection/Verification and Examination Personnel, Section 4.0 (4)(i), requires that the Entergy corporate ANSI Level III inspector shall perform periodic (annual) surveillances of quality control inspection activities to ensure that the program is being adequately implemented and maintained. Contrary to the above, no surveillances of quality control inspection activities were performed for any Entergy site during calendar year 2008. The issue was not suitable for quantitative significance determination, so it was assessed using IMC 0609, Appendix M, so it was evaluated using the qualitative criteria listed in Table 4.1. This finding was determined to be of very low safety significance because other quality assurance program functions remained unaffected by this performance deficiency, so defense-in-depth continued to exist. This issue was entered into the licensee\'s corrective action program as CR-HQN-2009-00111. |
| 05000247/FIN-2010005-01 | 2010Q4 | Indian Point | Inadequate Compensatory Measures for Out of Service Plant Vent Process Radiation Monitor | The inspectors identified a Green NCV of 10 CFR 50.54, Conditions of Licenses, paragraph (q), because Entergy staff did not implement adequate compensatory measures when the R-27 plant vent process radiation monitor, which is used for emergency action level (EAL) classification, was taken out of service. Specifically, between October 25, 2010 and November 24, 2010, the R-27 monitor was out of service for repair following preventive maintenance with inadequate compensatory measures regarding the impact on EAL classification capability. Entergy personnel implemented shortterm corrective actions by providing adequate compensatory instructions for the operating crews. The issue was entered into Entergy\'s CAP as CRlP-2010-06721 which includes longer-term corrective actions regarding emergency preparedness procedure changes. This finding is more than minor because it affected the Emergency Response Organization attribute of the Emergency Preparedness (EP) cornerstone to ensure that the Entergy personnel are capable of implementing adequate measures to protect the public health and safety in the event of a radiological emergency. Specifically, Entergy personnel did not provide adequate compensatory measures for when the R-27 plant vent monitors were taken out of service. In accordance with IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, the inspectors determined the finding to be of very low safety significance (Green). Using IMC 0609, Appendix B, Section 4.9 and Sheet 1, Failure to Comply, the inspectors determined that the failure to comply with an aspect of the Emergency Plan related to event classification (10 CFR 50.47(b)(4)) was a risk-significant planning standard (RSPS) problem; but it was not a RSPS functional failure of the Indian Point Energy Center (IPEC) event classification process. This finding has a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action program attribute of taking appropriate corrective actions to address safety issues in a timely manner. Specifically, Entergy staff did not take appropriate emergency planning compensatory corrective actions when the R-27 plant vent radiation monitor was taken out of service. |
| 05000247/FIN-2010005-10 | 2010Q4 | Indian Point | Licensee-Identified Violation | O CFR 50.47(b)(4), requires that a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the licensee. 10 CFR 50.54(q), states in part, that licensees shall follow and maintain in effect emergency plans which meet the standards in 0.47(b). Contrary to the above, on October 2Q,2010, during an extent of condition review of industry operating experience, Entergy personnel identified that the R-54 radiation monitor\'s (monitor is for liquid effluent from the the value of 2.5e-1uCi/cc required to declare an Alert using emergency action level (EAL) Table 5.1. Entergy personnel documented this issue in the CAP as CR-IP2-20\'10-06417 and provided timely guidance to the control room operators to ensure proper classification of an event. In addition, Entergy personnel performed an apparent cause evaluation which included an extent of condition of the issue. The EAL chart and associated emergency plan procedures were revised to reflect the EAL changes. The inspectors determined that this finding is of very low safety significance because it did not result in a significant degradation of the risk significant planning standard function. |
| 05000247/FIN-2010005-11 | 2010Q4 | Indian Point | Licensee-Identified Violation | 10 CFR 50, Appendix B, Criterion ll, Quality Assurance Program, requires, in part, that the licensee establish a quality assurance program which complies with Appendix B. This program shall be documented by written policies, procedures, or instructions and shall be carried out throughout plant life in accordance with those policies, procedures, or instructions. Procedure EN-QV-111, Training and Certification of Inspection/Verification and Examination Personnel, Section 4.0 (4)(i), requires that the Entergy corporate ANSI Level lll inspector shall perform periodic (annual) surveillances of quality control inspection activities to ensure that the program is being adequately implemented and maintained. Contrary to the above, no surveillances of quality control inspection activities were performed for any Entergy site during calendar year 2008. The issue was not suitable for quantitative significance determination, so it was assessed using IMC 0609, Appendix M, and evaluated using the qualitative criteria listed in Table 4.1. This finding was determined to be of very low safety significance because other quality assurance program functions remained unaffected by this performance deficiency, so defense-in-depth continued to exist. This issue was entered into the Entergy\'s CAP as CR-HQN-2009-00111. |
| 05000271/FIN-2010005-01 | 2010Q4 | Vermont Yankee | Failure to Perform Required Quality Control Inspections | The inspectors identified a non-cited violation (NCV) of 10 CFR 50, Appendix B . Criterion X, lnspection, for the failure to ensure that Quality Control verification inspections were consistently included and correctly specified in quality-affecting procedures and work instructions for construction-like work activities as required by the Quality Assurance Program. Entergy initiated prompt fleet-wide corrective actions to ensure proper work order evaluation and proper inclusion of Quality Control verification inspections. This issue was entered into the corrective action program as condition reports (CR) CR-HQN 2009-01184 and CR-HQN-2O10-0013. The failure to ensure that adequate Quality Control verification inspections were included in quality-affecting procedures and work instructions as required by the Quality Assurance Program was a performance deficiency. This issue was more than minor because, if left uncorrected, it could lead to a more significant safety concern; in that, the failure to check quality attributes could involve an actual impact to plant equipment. This issue affected the Design Control attribute of the Mitigating Systems cornerstone because missed or improper quality control inspections during plant modifications could impact the availability, reliability, and capability of systems needed to respond to initiating events. This performance deficiency was determined to be of very low safety significance (Green), since it was confirmed to involve a qualification deficiency that did not result in a loss of operability or functionality. The inspectors determined that this issue had a cross-cutting aspect in the Human Performance cross-cutting area, Decision-Making component, because the licensee did not have an effective systematic process for obtaining interdisciplinary reviews of proposed work instructions to determine whether Quality Control verification inspections were appropriate H.1(a)1. |
| 05000271/FIN-2010005-02 | 2010Q4 | Vermont Yankee | Failure to Implement the Experience and Qualification Requirements of the Quality Assurance Program | The inspectors identified an NCV of 10 CFR 50, Appendix B, Criterion ll, Quality Assurance Program, for the failure to implement the experience and qualification requiiements of the Quality Assurance Program. As a result, the licensee failed to ensure that two individuals assigned to the position of Quality Assurance Manager met the qualification and experience requirements of ANSI/ANS 3.1-1978 as required by the Quality Assurance Program. Specifically, the individual assigned to be the responsible person for the licensee\'s overall implementation of the Quality Assurance Program did not have at least one year of nuclear plant experience in the overall implementation of the Quality Assurance Program within the quality assurance organization prior to assuming those responsibilities. This issue was entered into the corrective action program as CR-HQN-201 0-00386. The failure to ensure that an individual assigned to the position of Quality Assurance Manager met the qualification and experience requirements of ANSI/ANS 3.1-1978 as required by the Quality Assurance Program was a performance deficiency. This issue was more than minor because, if left uncorrected, it could create a more significant safety concern. The failure to have a fully qualified individual providing overall oversight to the Quality Assurance Program had the potential to affect all cornerstones, but the inspectors determined that this finding will be tracked under the Mitigating Systems cornerstone as the area most likely to be impacted. The issue was not suitable for quantitative assessment using existing NRC Significance Determination Process (SDP) guidance, so it was determined to be of very low safety significance (Green) using NRC Inspection Manual Chapter (lMC) 0609, Appendix M, Significance Determination Process Using Qualitative Criteria. The inspectors determined that there was no crosscutting aspect associated with this finding because this issue was not indicative of current performance as it occurred more than three years ago. ( |
| 05000271/FIN-2010005-03 | 2010Q4 | Vermont Yankee | Licensee-Identified Violation | Procedure, EN-QV-1 1 1, Training and Certification of InspectionA/erification and Examination Personnel, Section 4.0 (4)(i), requires that the Entergy corporate ANSI Level lll inspector shall perform periodic (annual) surveillances of quality control inspection activities to ensure that the program is being adequately implemented and maintained. Contrary to the above, no surveillances of quality control inspection activities were performed for any Entergy site during calendar year 2008. The issue was not suitable for quantitative significance determination, so it was assessed using IMC 0609, Appendix M, and was evaluated using the qualitative criteria listed in Table 4.1. This finding was determined to be of very low safety significance because other quality assurance program functions remained unaffected by this performance deficiency, so defense-in-depth continued to exist. This issue was entered into the licensee\'s CAP as CR-HQN-2009-001 1 1. |
| 05000286/FIN-2010005-03 | 2010Q4 | Indian Point | Failure of the Offsite Notification Procedure to Meet the Requirements of the Site Emergency Plan | An NRC-identified Green NCV of 10 CFR 50.54, Conditions of Licenses, paragraph (q), was identified because the Entergy emergency plan implementing procedure (EPIP) for notification of offsite officials did not meet the requirements of the IPEC Emergency Plan. This EPIP had contained a deficiency in the backup process for offsite notification since July 2006. Entergy personnel responded by documenting the deficiency in CR-lP2-2010-07563 and by initiating a procedure change to align the backup process with the Emergency Plan commitments. This finding is more than minor because it affected the Emergency Response Organization attribute of the EP cornerstone to ensure that the Entergy personnel are capable of implementing adequate measures to protect the public health and safety in the event of a radiological emergency. Entergy procedures allowed for a back-up notification process that did not comply with the requirements of the site emergency plan: the Emergency Plan requires that the Shift Manager or his designee notify the offsite authorities of an emergency declaration, while Form EP-4 directed the delegation of this responsibility to an offsite authority itself. In accordance with Inspection Manual Chapter (lMC) 0609, Appendix B, Emergency Preparedness Significance Determination Process, the inspectors determined the finding to be of very low safety significance (Green). Using IMC 0609, Appendix B, Section 4.5 and Sheet 1, Failure to Comply, the inspectors determined that the failure to comply with an aspect of the Emergency Plan related to event notification (10 CFR 50.47(b)(5)) was a Risk Significant Planning Standard (RSPS) problem. lt was not a RSPS functional failure of the IPEC event notification process, because the deficiency in the IPEC EPIP was in the backup method for offsite notification, and despite the procedural flaw offsite notifications were made in a timely and accurate manner on November 7,201Q. The inspectors determined there was no cross-cutting aspect associated with this finding because the performance deficiency did not reflect Entergy\\\'s current performance. Specifically, the performance deficiency, associated with a procedure change made in July 2006, occurred more than three years ago and was outside the current assessment period. |
| 05000286/FIN-2010005-04 | 2010Q4 | Indian Point | Licensee-Identified Violation | 10 CFR 50, Appendix B, Criterion ll, Quality Assurance Program, requires, in part, that the licensee establish a quality assurance program which complies with Appendix B. This program shall be documented by written policies, procedures, or instructions and shall be carried out throughout plant life in accordance with those policies, procedures, or instructions. Procedure, EN-QV-111, Training and Certification of Inspection/Verification and Examination Personnel, Section 4.0 (4)(i), requires that the Entergy corporate ANSI Level lll inspector shall perform periodic (annual) surveillances of quality control inspection activities to ensure that the program is being adequately implemented and maintained. Contrary to the above, no surveillances of quality control inspection activities were performed for any Entergy site during calendar year 2008. The issue was not suitable for quantitative significance determination, so it was assessed using IMC 0609, Appendix M, and was evaluated using the qualitative criteria listed in Table 4.1 . This finding was determined to be of very low safety significance because other quality assurance program functions remained unaffected by this performance deficiency, so defense-in-depth continued to exist. This issue was entered into the licensee\'s corrective action program as CR-HQN-2009-00111. |
| 05000293/FIN-2010005-04 | 2010Q4 | Pilgrim | Licensee-Identified Violation | Procedure, EN-QV-111, \'Training and Certification of InspectionNerification and Examination Personnel, Section 4.0 (4)(i), requires that the Entergy corporate ANSI Level III inspector shall perform periodic (annual) surveillances of quality control inspection activities to ensure that the program is being adequately implemented and maintained. Contrary to the above, no surveillances of quality control inspection activities were performed for any Entergy site during calendar year 2008. The issue was not suitable for quantitative significance determination, so it was assessed using IMC 0609, Appendix M, and was evaluated using the qualitative criteria listed in Table 4.1. This finding was determined to be of very low safety significance because other quality assurance program functions remained unaffected by this performance deficiency, so defense-in-depth continued to exist. This issue was entered into the licensee\'s CAP as CR-HQN-2009-00111. |
| 05000333/FIN-2010005-02 | 2010Q4 | FitzPatrick | Failure to Maintain Equipment Status Control for a Manually Operated Normally Locked Open Residual Heat Removal Injection Valve | A self-revealing NCV of very low safety significance of TS 5.4, Procedures, was identified because Entergy personnel did not implement AP-12.06, Equipment Status Control, as required. Specifically, Entergy personneldid not maintain status control and properly document the position of the residual heat removal (RHR) to reactor water recirculation loop B isolation valve (10RHR-818) as closed nor did operators restore the valve to its normal locked open position upon completion of a leak surveillance test. Entergy personnel entered this issue into their corrective action program (CAP), (CR-JAF-2010-06656) and promptly restored the valve to its required locked open position. This finding is more than minor because it is associated with the configuration control attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, the operators did not maintain configuration control of the RHR isolation valve and restore the valve to a locked open position when the B RHR subsystem was credited for maintaining acceptable shutdown risk. The inspectors determined the significance of the finding using IMC 0609, Appendix G, Shutdown Operations Significance Determination Process. The issue was determined to screen as very low safety significance (Green) because the B RHR train could be considered available with respect to Appendix G, Section 4.0, and Attachment 3, Section 2,2.3. Specifically, the inspectors determined that operators had more than twice the time available (with a shortest time to boil of 5.8 hours) than would have been required to identify and take action to restore/open the RHR isolation valve in the event of a loss of shutdown cooling or RCS inventory. This finding had a cross-cutting aspect in the Human Performance cross-cutting area, Work Practices component, because Entergy personnel did not define and effectively com m unicate expectations regard ing procedural compliance, and personnel did not follow procedures. |
| 05000333/FIN-2010005-03 | 2010Q4 | FitzPatrick | Licensee-Identified Violation | TS 5.4 requires, in part, that the applicable procedures recommended in Regulatory Guide 1.33, Appendix A, November 1972,be established, implemented, and maintained, Regulatory Guide 1.33, Section D, Procedure for Startup, Operation, and Shutdown of Safety-Related BWR Systems, specifies, in part, that instructions for draining should be prepared, as appropriate, for the shutdown cooling, fuel storage pool cooling, and condensate systems. Entergy staff identified that, contrary to the above, they had not complied with TS 5.4.1 on October 3, 2010, when Entergy personnel did not adequately implement procedure OP-30A, Attachment 2, Checklist for Draining, step F.4.1. Specifically, upon performing additional reviews as a result of finding the B RHR valve mispositioned, Entergy staff identified that the B RHR auto control bypass and A and B CS auto actuation bypass switches had been in bypass when step F.4.1 was performed, which through verifying compliance with various technical specifications, required the verification that two low pressure emergency core cooling systems be operable prior to installing the spent fuel pool gates. However, with the three switches placed in bypass, only one emergency core cooling system, A RHR, was operable. Entergy personnel documented this condition in CR-JAF-2010-06659. The inspectors determined the significance of this finding using IMC 0609, Appendix G, Shutdown Operations Significance Determination Process. The issue was determined to screen as very low safety significance (Green) because the B RHR and A and B CS subsystems could be considered available with respect to Appendix G, Section 4.0, and Attachment 3, Section 2.2.3. Specifically, the inspectors determined that operators had more than twice the time available than would have been required to identify and take action to restore an additional injection source given an inadvertent RCS inventory loss. |
| 05000333/FIN-2010005-04 | 2010Q4 | FitzPatrick | Licensee-Identified Violation | 10 CFR 50, Appendix B, Criterion ll, Quality Assurance Program, requires, in part, that the licensee establish a quality assurance program which complies with Appendix B. This program shall be documented by written policies, procedures, or instructions and shall be carried out throughout plant life in accordance with those policies, procedures, or instructions. Procedure EN-QV-1Il, Training and Certification of Inspection/Verification and Examination Personnel, Section 4.0141(i), requires that the Entergy corporate ANSI Level lll inspector shall perform periodic (annual) surveillances of quality control inspection activities to ensure that the program is being adequately implemented and maintained. Contrary to the above, no surveillances of quality control inspection activities were performed for any Entergy site during calendar year 2008. The issue was not suitable for quantitative significance determination, so it was assessed using IMC 0609, Appendix M, and evaluated using the qualitative criteria listed in Table 4.1. This finding was determined to be of very low safety significance because other quality assurance program functions remained unaffected by this performance deficiency, so defense-in-depth continued to exist. This issue was entered into Entergy\'s CAP as CR-HQN-2009-00111. |
| 05000382/FIN-2010005-04 | 2010Q4 | Waterford | Failure to Conduct Timely Corrective Actions to Replace Degraded Diodes in Safety Related Inverters | A self-revealing non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, occurred because the licensee did not promptly correct a significant condition adverse to quality that affected static uninterruptible power supply inverters used to power vital and safety related loads. Specifically, the licensee did not conduct timely corrective actions following identification of degraded diodes in static uninterruptible power supply A and B inverters, respectively. As a result, this led to another failure of a static uninterruptible power supply inverter. The licensee entered this issue into their corrective action program for resolution as CR-WF3-2011-0217. The immediate corrective actions following the additional failure included installation of newly tested diodes from a different batch, new fuses and a new silicon controlled rectifier. The planned corrective actions included implementation of an increased condition based testing preventive maintenance frequency and a maintenance activity to perform preinstallation testing on all new diodes and rectifiers. This finding is greater than minor because it is associated with the equipment performance attribute of the Mitigating System cornerstone and affects the cornerstone objective to ensure the availability and reliability of static uninterruptible power supply inverters that respond to initiating events to prevent undesirable consequences in that these inverters supply power to vital and safety related loads. The inspectors evaluated the significance of this finding using Phase 1 of the IMC 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations given the importance of the system and the fact that this condition affects static uninterruptible power supplies A and B. The inspectors determined that the finding was of very low safety significance (Green) because it is not a design or qualification deficiency, did not represent a loss of a safety function of a system or a single train greater than its Technical Specification completion time, and did not screen as potentially risk significant due to external events. This finding has a crosscutting aspect in the decision-making component of human performance because the licensee did not make safety-significant or risk-significant decisions using a systematic process, especially when faced with uncertain or unexpected plant conditions, to ensure safety is maintained. |
| 05000382/FIN-2010005-07 | 2010Q4 | Waterford | Licensee-Identified Violation | Technical Specification 6.8.1.a requires that the licensee shall establish, implement, and maintain the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2. Contrary to the above, the licensee identified three occasions where they failed to comply with this technical specification. First, a work instruction governing maintenance on a safety-related emergency feedwater pump contained incorrect guidance. Second, a step in EN-OP-104 to verify operability of all equipment required for a scheduled mode shift was signed as complete, when all required equipment was not operable. Third, the licensee failed to follow EN-LI-102 and properly recognize the reportability of an event. This failure to comply with the technical specification is violation of NRC requirements. This finding was more than minor because it is associated with the equipment performance attribute of the Mitigating System cornerstone and affects the cornerstone objective to ensure the availability and reliability of systems that respond to initiating events to prevent undesirable consequences and since it is similar to Inspection Manual Chapter 0612, Appendix E, example 2g. The violation was evaluated as having very low safety significance (Green) because it did not represent a loss of a system safety function or the loss of a single train for greater than its allowed outage time. This condition was documented in Condition Report CR-WF3- 2010-5923 and CR-WF3-2008-2744. |
| 05000313/FIN-2010005-01 | 2010Q4 | Arkansas Nuclear | Exceeded Technical Specification Allowed Outage Time for Electrical Power Systems Due to Loss of Non-Technical Specification Supported System | The inspectors identified a noncited violation of Technical Specifications 3.8.4, DC Sources - Operating, Technical Specification 3.8.7, Inverters Operating, and Technical Specification 3.8.9, Distribution Systems Operating, due to the failure to enter the appropriate technical specification or complete the associated required action prior to the appropriate completion time when the associated emergency chillers were out of service. Specifically, the licensee did not enter the appropriate technical specification for an inoperable system, subsystem, train or component when the all necessary attendant nontechnical specification support equipment that are required for the system, subsystem, train, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s). The issue was entered into the licensee\\\'s corrective action program as Condition Reports CR- ANO-1-2010-3075 and CR-ANO-1-2011-0204. The inspectors determined that not entering the appropriate technical specification when the emergency switchgear chillers or applicable room cooling unit were not available to provide the technical specification support function for technical specific emergency switchgear equipment was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the design control attribute of the Mitigating Systems Cornerstone, and affected the associated cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences and is therefore a finding. Specifically, CALC-93-R-1040-01, ANO-1 AB Limiting Component Qualification Temperatures, Revision 3 identifies the temperature limits for each applicable room at 120 degrees F except for Room 110 which is 150 degrees F. Licensee Event Report No. 50-313/77-19 described the permanent solution to maintain room temperatures by the installation of two independent chilled water systems (VCH4s and applicable room coolers) to maintain those rooms and associated enclosed equipment (i.e., 480V motor control centers, inverters, battery chargers, instrument AC panels, etc.) below the rated continuous operating temperatures following a loss of coolant accident concurrent with a loss of offsite power, which was accepted by the NRC in a Safety Evaluation Report dated October 10, 1979. Failure to enter Technical Specifications 3.8.4, DC Sources - Operating, Technical Specification 3.8.7, Inverters Operating, and Technical Specification 3.8.9, Distribution Systems Operating, due to the loss of the non-technical specification chilled water cooling support system or complete the associated required action prior to the appropriate completion time when the associated emergency chillers were out of service was a violation of technical specifications. Using Inspection Manual Chapter 0609.04, Phase 1 - Initial Screening and Characterization of Findings, the finding was determined to require a Phase 2 analysis because removing a VCH-4 chiller from service did result in an actual loss of safety function of a single train for greater than its technical specification allowed outage time. The resident inspectors received support from the regional senior reactor analyst and determined that the finding to be of very low safety significance (Green). Specifically, although the function was lost by the designated support equipment (emergency switchgear chillers), representing the technical specification violation, the licensee had an evaluation that credited compensatory measures and specific environmental conditions that assured the overall functionality of the applicable switchgear train was not lost. The inspectors reviewed the engineering change EC-25691, Prepare EC markup to CALC-92-E-0103-01 to determine maximum outside ambient temperatures and compensatory measures to allow one chiller train to cool DC/BATT/SWGR areas during maintenance, and determined that it supported the conclusion that the compensatory measures in place assured the overall functionality of the applicable switchgear train was not lost, however, the compensatory measures sufficed for the function, but did not satisfy the technical specification switchgear operability requirements. The finding was determined to have a crosscutting aspect in the area of human performance, associated with decision making, in that the licensee did not use conservative assumptions in decision making and adopt a requirement to demonstrate that the proposed action is safe in order proceed rather than a requirement that it is unsafe in order to disapprove the action. Specifically, the licensee approved an engineering change that relied on the use of compensatory actions and non-safety related equipment to support the operability of technical specification equipment when the safety related support equipment was not available or functional and implemented a procedure change that resulted in not entering the appropriate technical specification when applicable non technical specification safety related equipment was out of service. |
| 05000382/FIN-2010005-09 | 2010Q4 | Waterford | Licensee-Identified Violation | Title 10 CFR 50.120(b)(2), states in part that training programs must be derived from a systems approach to training as defined in 10 CFR 55.4. Systems approach to training includes five elements, one of which is evaluation of trainee mastery of objectives. Written examinations are utilized by the licensee to evaluate Auxiliary Operator mastery of objectives. Contrary to the above, the licensee failed to properly implement the evaluation element of their systems approach to training. Specifically, an exam compromise was discovered during Cycle 1 of the 2009 Auxiliary Operator Requalification Cycle. This compromise invalidated subsequent auxiliary operator requalification exams during the cycle due to some commonality between weekly exams. The issue was placed into the licensees corrective action program as Condition Report CR-WF3-2009-1077. The licensee conducted a root cause evaluation which identified unclear guidance regarding acceptable forms of information sharing during a requalification exam cycle. Upon discovery of the exam compromise, the licensee reexamined all affected Auxiliary Operators with newly written exams to validate the requalification exam cycle. Extent of conditions determined the exam issue was isolated to the non-licensed operator program and was not evident within other accredited programs. The violation was determined to be of very low safety significance because all Auxiliary Operators were administered a valid exam during the requalification cycle and the extent of conditions was limited to the non-licensed operator community. |
| 05000382/FIN-2010005-06 | 2010Q4 | Waterford | Licensee-Identified Violation | Title 10 CFR 50.47(b)(4) requires, in part, that a standard classification and emergency action level scheme is in use by the licensee. Contrary to the above, on October 13, 2010, the licensee identified they had not maintained in effect a standard classification and emergency action level scheme. Specifically, the licensee identified seven examples of failures to implement emergency action level AA1-1 for airborne and liquid effluent releases in 2009 and 2010. In each example, the 200-times discharge permit specific alarm setpoint value could not be read on the associated process radiation monitor because the value was above the monitors operating range. This finding was more than minor because it impacted the Emergency Preparedness Cornerstone objective attribute of emergency response organization performance and was evaluated as having very low safety significance (Green) because it was a failure to comply with NRC requirements, was associated with a risk-significant planning standard, and was not a functional failure or degraded function of the planning standard. This condition was documented in Condition Reports CR-WF3-2010-6184 and CR-WF3-2010-6387. |
| 05000382/FIN-2010005-05 | 2010Q4 | Waterford | Failure to Implement the Experience and Qualification Requirements of the Quality Assurance Program | Inspectors identified a non-cited violation of 10 CFR 50, Appendix B, Criterion II, Quality Assurance Program, for the failure to implement the experience and qualification requirements of the Quality Assurance Program. As a result, the licensee failed to ensure that two individuals assigned to the position of Quality Assurance Manager met the qualification and experience requirements of ANSI/ANS 3.1-1978 as required by the Quality Assurance Program. Specifically, the individual assigned to be the responsible person for the licensees overall implementation of the Quality Assurance Program did not have at least 1 year of nuclear plant experience in the overall implementation of the Quality Assurance Program within the quality assurance organization prior to assuming those responsibilities. This issue was entered into the licensees corrective action program as Condition Report CR-HQN-2010-00386. Failure to ensure that an individual assigned to the position Quality Assurance Manager met the qualification and experience requirements of ANSI/ANS 3.1-1978 as required by the Quality Assurance Program was a performance deficiency. This performance deficiency was determined to be more than minor because, if left uncorrected, it could create a more significant safety concern. Failure to have a fully qualified individual providing overall oversight to the Quality Assurance Program had the potential to affect all cornerstones, but this finding will be tracked under the Mitigating Systems cornerstone as the area most likely to be impacted. The issue was not suitable for quantitative assessment using existing Significance Determination Process guidance, so it was determined to be of very low safety significance using Inspection Manual Chapter 0609, Appendix M, Significance Determination Process Using Qualitative Criteria. The inspectors determined that there was no cross-cutting aspect associated with this finding because this issue was not indicative of current performance because the violation occurred more than 3 years ago. |
| 05000416/FIN-2010005-08 | 2010Q4 | Grand Gulf | Licensee-Identified Violation | With one or more fire door(s) being inoperable and with at least one side of the inoperable fire door(s) having verified continuous fire monitoring and alarm capability, Condition 2.C.41 of Grand Gulf Nuclear Power Stations Facility Operating License requires the establishment of an hourly fire watch patrol in accordance with the station fire protection program. Contrary to the above, on September 19, 2010, several inoperable fire doors were not inspected by an hourly fire watch patrol for a period of approximately 10 hours. This issue was documented in the licensees corrective action program in condition report CR GGN-2010-06824. This finding is of very low safety significance because at least one side of each inoperable fire door had verified continuous fire monitoring and alarm capability. |
| 05000416/FIN-2010005-09 | 2010Q4 | Grand Gulf | Licensee-Identified Violation | Procedure, EN-QV-111, Training and Certification of Inspection/Verification and Examination Personnel, Section 4.0 (4)(i), requires that the Entergy corporate ANSI Level III inspector shall perform periodic (annual) surveillances of quality control inspection activities to ensure that the program is being adequately implemented and maintained. Contrary to the above, no surveillances of quality control inspection activities were performed for any Entergy site during calendar year 2008. The issue was not suitable for quantitative significance determination, so it was assessed using IMC 0609, Appendix M, so it was evaluated using the qualitative criteria listed in Table 4.1. This finding was determined to be of very low safety significance because other quality assurance program functions remained unaffected by this performance deficiency, so defense-in-depth continued to exist. This issue was entered into the licensee\'s corrective action program as CR-HQN-2009-00111. |
| 05000416/FIN-2010005-07 | 2010Q4 | Grand Gulf | Licensee-Identified Violation | Title 10 CFR 50.47(b)(4) requires, in part, that a standard classification and emergency action level scheme is in use by the licensee. Contrary to the above, on October 21, 2010, the licensee identified they had not maintained in effect a standard classification and emergency action level scheme. Specifically, the licensee identified 394 examples of failures to implement emergency action level AA1-1 for airborne and liquid effluent releases from October 1, 2008, to October 21, 2010. In each example, the 400-times discharge permit-specific alarm setpoint value could not be read on the associated process radiation monitor because the value was above the monitors operating range. This finding was more than minor because it impacted the Emergency Preparedness Cornerstone objective attribute of emergency response organization performance and was evaluated as having very low safety significance (Green) because it was a failure to comply with NRC requirements, was associated with a risk-significant planning standard, and was not a functional failure or degraded function of the planning standard. This condition was documented in Condition Report CR-GGN-2010-07456. Because the finding was determined to be of very low safety significance and was entered into the corrective action program, this violation is being treated as a Green noncited violation consistent with the NRC Enforcement Policy. |
| 05000458/FIN-2010005-06 | 2010Q4 | River Bend | Licensee-Identified Violation | Procedure, EN-QV-111, Training and Certification of Inspection/Verification and Examination Personnel, Section 4.0 (4)(i), requires that the Entergy corporate ANSI Level III inspector shall perform periodic (annual) surveillances of quality control inspection activities to ensure that the program is being adequately implemented and maintained. Contrary to the above, no surveillances of quality control inspection activities were performed for any Entergy site during calendar year 2008. The issue was not suitable for quantitative significance determination, so it was assessed using Inspection Manual Chapter 0609, Appendix M, so it was evaluated using the qualitative criteria listed in Table 4.1. This finding was determined to be of very low safety significance because other quality assurance program functions remained unaffected by this performance deficiency, so defense-in-depth continued to exist. This issue was entered into the licensee\'s corrective action program as Condition Report CR-HQN-2009-00111. |
| 05000458/FIN-2010005-07 | 2010Q4 | River Bend | Licensee-Identified Violation | Title 10 CFR Part 50, Appendix B, Criterion X, Inspection, requires, in part, that: Examinations, measurements, or tests of material... shall be performed for each work operation where necessary to assure quality . . . If mandatory inspection verification inspections, which require witnessing or inspecting by the licensees designated representative and beyond which work shall not proceed without the consent of the designated representative are required, the hold points shall be indicated in appropriate documents. Contrary to the above, between July 31, 2008 and November 30, 2009, mandatory inspection verification inspections, which require witnessing or inspecting by the licensees designated representative and beyond which work shall not proceed without the consent of the designated representative were required, but the required hold points were not indicated in appropriate documents. Specifically, the hold points were replaced with notification points, which provided general work activity oversight controls but did not clearly indicate discrete work steps where craft personnel were not to proceed until the required witnessing had occurred. . The issue was not suitable for quantitative significance determination, so it was assessed using Inspection Manual Chapter 0609, Appendix M, so it was evaluated using the qualitative criteria listed in Table 4.1. This finding was determined to be of very low safety significance because other quality assurance program functions remained unaffected by this performance deficiency, so defense-in-depth continued to exist. This issue was entered into the licensees corrective action program as Condition Report CR-RBS-2009-06123. |
| 05000313/FIN-2010005-08 | 2010Q4 | Arkansas Nuclear | Licensee-Identified Violation | Procedure EN-QV-111, Training and Certification of Inspection/Verification and Examination Personnel, Section 4.0 (4)(i), requires that the Entergy corporate ANSI Level III inspector shall perform periodic (annual) surveillances of quality control inspection activities to ensure that the program is being adequately implemented and maintained. Contrary to the above, no surveillances of quality control inspection activities were performed for any Entergy site during calendar year 2008. The issue was not suitable for quantitative significance determination, so it was assessed using Inspection Manual Chapter 0609, Appendix M, so it was evaluated using the qualitative criteria listed in Table 4.1. This finding was determined to be of very low safety significance because other quality assurance program functions remained unaffected by this performance deficiency, so defense-in-depth continued to exist. This issue was entered into the licensee\'s corrective action program as Condition Report CR-HQN-2009-00111. |
| 05000313/FIN-2010005-05 | 2010Q4 | Arkansas Nuclear | Failure to Use Human Performance Tools Results in Two Turbine Building Roof Fires | The inspectors documented a self-revealing finding for contract roofers failing to use human performance tools, per Procedure EN-HU-102, Human Performance Tools, Revision 5, while performing hot work activities on Arkansas Nuclear Ones turbine building roof which resulted in two fires. Specifically, contractors committed human performance errors during activities by not performing self- and peer-checks, or demonstrating a questioning attitude which resulted in a fire on September 17 and again on November 18, 2010. These issues were entered into the corrective action program as Condition Reports CR-ANO-1-2010-3231, CR-ANO-C-2010-2428, and CR-ANO-C-2010-2978. The failure to use human performance error prevention tools as specified in Procedure EN-HU-102, Human Performance Tools, Revision 5, was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the protection against external activities attribute of the Initiating Events Cornerstone, and affected the cornerstone objective to limit the likelihood of those events that upset plant stability during power operations, and therefore a finding. Using Inspection Manual Chapter 0609.04, Phase 1 Initial Screening and Characterization of Findings, 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 mitigation equipment or function would not be available. The finding was determined to have a crosscutting aspect in the area of human performance, associated with work practices, in that the licensee failed to ensure supervisory and management oversight of work activities, including contractors, such that nuclear safety is supported. Specifically, the licensee failed to provide adequate oversight of the roofing contractor to prevent fires. |
| 05000313/FIN-2010005-07 | 2010Q4 | Arkansas Nuclear | Failure to Perform Face-to-Face Supervisory Assessments Less than 4 Hours Before Individuals Began Performing Work Activities Under a Waiver | The inspectors identified a noncited violation of 10 CFR 26.207(a)(3), Waivers and Exceptions, associated with the failure of supervisory personnel to appropriately perform face-to-face fatigue assessments. Specifically, supervisory personnel were performing one face-to-face fatigue assessment prior to the first shift worked under a waiver issued for multiple days, and not performing additional assessments for consecutive shifts worked under the same waivers when there was a break of at least 10 hours provided between the successive work periods covered by these waivers. The failure to perform face-to-face supervisory assessments less than 4 hours before individuals began performing work activities under a waiver was a performance deficiency. The licensee entered this issue in their corrective action program as Condition Report CR-ANO-C-2010-2396. The failure to perform face-to-face supervisory assessments less than 4 hours before individuals began performing work activities under a waiver was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the access authorization attribute of the Security Cornerstone, and affected the associated cornerstone objective to provide assurance that the licensees security system and material control and accounting program use a defense in-depth approach and can protect against (1) the design basis threat of radiological sabotage from external and internal threats and (2) the theft or loss of radiological materials, and is therefore a finding. Using Inspection Manual Chapter 0609, Appendix E, Baseline Security Significance Determination Process for Power Reactors, Figures 5 and 6, the finding was determined to have very low safety significance because the calculated point total did not exceed the threshold value for a Green noncited violation. The cumulative total for this finding was zero points, which was calculated by factoring the one impact area (vital areas) against Tier III Element 08.02.08, Security Force Work Hours, of the Access Authorization attribute, which resulted in a total of zero points within this attribute. The finding was determined to have a crosscutting aspect in the area of human performance associated with decision making (H.1(b)) in that the licensee failed to use conservative assumptions in decision making and adopt a requirement to demonstrate that the proposed action is safe in order to proceed rather than a requirement to show it is unsafe in order to disapprove the action. Specifically, the licensee had defined the work period to be 6 weeks without giving appropriate thought about potential consequences of this decision relative to potential fatigue aspects while continuing to work under a waiver. |
| 05000313/FIN-2010005-03 | 2010Q4 | Arkansas Nuclear | Failure to Perform Required Quality Control Inspections | Inspectors identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion X, Inspection, for the failure to ensure that quality control verification inspections were consistently included and correctly specified in quality-affecting procedures and work instructions for construction-like work activities as required by the quality assurance program. The licensee performed extensive reviews, and inspectors performed independent reviews of the licensees conclusions as well as independent sampling, to confirm that improper or missed inspections did not actually affect the operability of plant equipment. Entergy initiated prompt fleet-wide corrective actions to ensure proper work order evaluation and proper inclusion of quality control verification inspections. This issue was entered into the corrective action program under Condition Reports CR-HQN-2009-01184 and CR-HQN-2010-0013. The failure to ensure that adequate quality control verification inspections were included in quality-affecting procedures and work instructions as required by the quality assurance program was a performance deficiency. This programmatic deficiency was more than minor because, if left uncorrected, it could lead to a more significant safety concern in that the failure to check quality attributes could involve an actual impact to plant equipment. This issue affected the design control attribute of the Mitigating Systems Cornerstone because missed or improper quality control inspections during plant modifications could impact the availability, reliability, and capability of systems needed to respond to initiating events. This performance deficiency was determined to have very low safety significance in Phase 1 of the Significance Determination Process, since it was confirmed to involve a qualification deficiency that did not result in a loss of operability or functionality. The inspectors determined that this performance deficiency involved a crosscutting aspect related to the human performance in decision-making because the licensee did not have an effective systematic process for obtaining interdisciplinary reviews of proposed work instructions to determine whether quality control verification inspections were appropriate. |
| 05000313/FIN-2010005-04 | 2010Q4 | Arkansas Nuclear | Failure to Implement the Experience and Qualification Requirements of the Quality Assurance Program | The inspectors identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion II, Quality Assurance Program, for the failure to implement the experience and qualification requirements of the quality assurance program. As a result, the licensee failed to ensure that an individual assigned to the position of quality assurance manager met the qualification and experience requirements of ANSI/ANS 3.1-1978 as required by the quality assurance program. Specifically, the individual assigned to be the responsible person for the licensees overall implementation of the quality assurance program did not have at least 1 year of nuclear plant experience in the overall implementation of the quality assurance program within the quality assurance organization prior to assuming those responsibilities. This issue was entered into the corrective action program as Condition Report CR-HQN-2010-00386. Failure to ensure that an individual assigned to the position as quality assurance manager met the qualification and experience requirements of ANSI/ANS 3.1-1978 as required by the quality assurance program was a performance deficiency. This performance deficiency was determined to be more than minor because, if left uncorrected, it could create a more significant safety concern. Failure to have a fully qualified individual providing overall oversight to the quality assurance program had the potential to affect all cornerstones, but this finding will be tracked under the Mitigating Systems Cornerstone as the area most likely to be impacted. The issue was not suitable for quantitative assessment using existing Significance Determination Process guidance, so it was determined to be of very low safety significance using Inspection Manual Chapter 0609, Appendix M, Significance Determination Process Using Qualitative Criteria. The inspectors determined that there was no crosscutting aspect associated with this finding because this issue was not indicative of current performance because the violation occurred more than 3 years ago. |
| 05000313/FIN-2010005-06 | 2010Q4 | Arkansas Nuclear | Failure to Verify the Adequacy of the Unit 2 Refueling Water Tank and the Condensate Storage Tank Transfer Setpoints | The inspectors identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, which states, in part, that design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified methods of calculation, or by the performance of a suitable testing program. Contrary to the above, the licensee failed to assure that design control measures were provided for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculation methods, or by the performance of a suitable testing program. Specifically, since 1998, the licensee failed to verify the adequacy of the Unit 2 refueling water tank and the condensate storage tank transfer setpoints to prevent potential air entrainment due to vortexing in safety-related pump suction piping. This finding was entered into the licensees corrective action program as Condition Report ANO-C-2007-1469. The inspectors determined that the failure to verify the adequacy of the Unit 2 refueling water tank and the condensate storage tank transfer setpoints was a performance deficiency. The finding was more than minor because it was associated with the design control attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609.04, Phase 1 Initial Screening and Characterization of Findings, the inspectors determined that the finding was of very low safety significance (Green) because it was a design or qualification deficiency confirmed not to result in loss of operability or functionality. Specifically, the licensee performed subsequent analysis which demonstrated that vortexing in the refueling water and condensate storage tanks would not impact safety-related pump operation during a design basis event. This finding did not have a crosscutting aspect because the most significant contributor did not reflect current licensee performance. |
| 05000247/FIN-2010005-07 | 2010Q4 | Indian Point | Failure to Staff the Site TSC and OSC Within 60 Minutes of an Alert Emergency Declaration | A Green self-revealing NCV of 10 CFR 50.54, Conditions of Licenses, paragraph (q), was identified because Entergy staff did not adequately implement the requirements of the IPEC Emergency Plan. On the evening of November 7, 2010, the Unit 2 operators declared an Alert emergency at 1849 hours. The technical support center (TSC) was staffed and declared operational at 2008 hours, and the operations support center (OSC) was staffed and declared operational at 2015 hours. Both of these activation times exceeded the 60-minute staffing requirement in the IPEC Emergency Plan. This issue was entered into Entergy\'s CAP as CR-IP2-2010-6813, CR-IP2-2010- 6831, and CR-IP2-2010-6871. This finding is more than minor because it affected the Emergency Response Organization (ERO) attribute of the EP cornerstone to ensure that Entergy personnel are capable of implementing adequate measures to protect the public health and safety in the event of a radiological emergency. Entergy personnel did not meet the requirements of the IPEC Emergency Plan in that the TSC and OSC were not staffed nor declared operational within 60 minutes of the Alert emergency declaration on November 7,2010. In accordance with IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, the inspectors determined the finding to be of very low safety significance (Green). Using IMC 0609, Appendix B, Section 4.2 and Sheet 2, Actual Event lmplementation Problem, the inspectors determined that the failure to comply with an aspect of the Emergency Plan related to ERO augmentation (10 CFR 50.47 (b) (2) was a non-risk-significant planning standard problem which occurred during an Alert emergency and is therefore of very low safety significance (Green).This finding has a cross-cutting aspect in the area of human performance associated with the work practices attribute of defining and effectively communicating expectations regard ing proced u ral com pliance and personnel following proced ures. Specifically, Entergy staff did not comply with ERO expectations and procedures regarding prompt reporting to an assigned emergency response facility during an actual event. |
| 05000313/FIN-2010005-02 | 2010Q4 | Arkansas Nuclear | Failure to Submit for Approval a Decrease in Effectiveness of Emergency Plan | The inspectors identified a noncited violation of 10 CFR 50.54(q) for the failure to apply for and receive approval by the NRC prior to implementing a change that decreased the effectiveness of the Arkansas Nuclear One Emergency Plan. Specifically, the licensee changed the default Protective Action Recommendation from a 2-mile radius and 5 miles downwind for General Emergency conditions to a 5-miles radius and 10 miles downwind which was determined to be a change that decreased the effectiveness of the approved emergency plan and was implemented without application to and approval by the Commission. Because the violation was entered into the licensees corrective action program as Condition Report CR-ANO-C-2010-02502, it is being treated as a noncited Severity Level IV violation consistent with Section 2.3.2 of the Enforcement Policy. The failure to submit, for approval, a change to the Arkansas Nuclear One Emergency Plan that decreases emergency plan effectiveness is a performance deficiency. The finding is more than minor because the change made has the potential to unnecessarily increase the risk to the public. Because this issue has the potential for impacting the NRCs ability to perform its regulatory function, traditional enforcement is applicable in accordance with NRC Inspection Manual Chapter 0612, Appendix B, Issue Screening. The finding was determined to be a Severity Level IV violation in accordance with Section 6.6.d.1 of the Enforcement Policy because it involved the licensees ability to meet or implement any regulatory requirement not related to assessment or notification such that the effectiveness of the emergency plan decreases. This violation of NRC requirements occurred on March 13, 2003, no crosscutting aspect is assigned to this finding because it is not indicative of current performance. |
| 05000333/FIN-2010005-01 | 2010Q4 | FitzPatrick | Inadequate Procedure for Refueling Water Level Control Resulted in Overflowing of Reactor Cavity Water in the Reactor Building | A self-revealing NCV of very low safety significance of technical specification (TS) 5.4, Procedures, was identified because Entergy procedure OP-30A Refueling Water Level Control, did not provide adequate guidance to operators for filling the reactor cavity which resulted in the reactor building (RB) floor drains overflowing and water intrusion from higher to lower levels in the RB. Entergy personnel entered this issue into their corrective action program (CAP), (CR-JAF-2010-05406 and CR-JAF-2010-05407) and performed several actions to ensure proper water level control prior to the next drain down of the reactor cavity. These actions included revising OP-30A to provide sufficient detail, ensuring additional detail would be included in pre-job briefings to include potential drain paths from the reactor cavity and spent fuel pool, and installing a dedicated camera to monitor reactor cavity water level. This finding is more than minor because it is associated with the procedure quality attribute of the Initiating Events cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown. Specifically, water spray throughout areas of the RB created a potential for water entering motors, valve operators, motor control centers, circuit breakers, and electricaljunction boxes, such that electrical components could have been compromised, which increased the likelihood of an event that would upset plant stability and challenge a critical safety function. The inspectors determined the significance of the finding using IMC 0609, Appendix G, Shutdown Operations Significance Determination Process, Phase 1. The finding was determined to be of very low safety significance because Entergy personnel maintained an adequate mitigation capability and there was there neither an inadvertent loss of two feet of RCS inventory nor an inadvertent reactor coolant system pressurization. The inspectors determined this finding had a cross-cutting aspect in the area of human performance within the resources component because the procedure used for filling the reactor cavity was not sufficiently complete to assure nuclear safety. |
| 05000416/FIN-2010005-01 | 2010Q4 | Grand Gulf | Inadequate Operability Evaluation Following a Spurious Actuation of the Standby Service Water Pump House Ventilation Fan | The inspectors identified a noncited violation of 10 CFR 50 Appendix B, Criterion V, involving a failure to follow procedures, which resulted in an inadequate operability evaluation. On December 5, 2010, a spurious actuation of the standby service water pump house ventilation system occurred, resulting in the pump house temperatures dropping below the design limit. In their operability evaluation, the licensee failed to consider the impact of the actual freezing conditions occurring at the site at that time, and operations did not secure the fan after the spurious actuation until questioned by the inspectors. The licensee subsequently revised the operability evaluation to properly account for environmental conditions in the pump house. The licensee entered this issue into their corrective action program as Condition Report CR-GGN-2011-00151. This performance deficiency is more than minor because it is associated with the mitigating systems cornerstone attribute of equipment performance as it adversely affected the cornerstone objective to ensure the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. Using the Phase 1 Worksheet in attachment 4 of Manual Chapter 0609, Significance Determination Process, the inspectors determined that this finding was of very-low safety significance (Green) because in Table 4a of the Phase 1 Screening Worksheet, all of the questions for the Mitigating Cornerstone were answered in the negative. This finding has a crosscutting aspect in the area of problem identification and resolution associated with the corrective actions component because the licensee did not thoroughly evaluate problems such that the resolutions address causes and extent of condition. |
| 05000416/FIN-2010005-02 | 2010Q4 | Grand Gulf | Untimely Corrective Actions in Response to Deficiencies in the RCIC Flow Control System | The inspectors reviewed a self-revealing noncited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Actions, associated with the licensees failure to take timely corrective actions to correct a condition adverse to quality associated with degradation of the Reactor Core Isolation Cooling (RCIC) flow control system, which ultimately resulted in the RCIC turbine governor failing its surveillance test. On September 23, 2010, the licensee replaced the electric governor-magnetic pickup, correcting the condition adverse to quality. The licensee entered this issue into the corrective action program as Condition Report CR-GGN-2010-06850. This performance deficiency is more than minor because it is associated with the mitigating systems cornerstone attribute of equipment performance as it adversely affected the cornerstone objective to ensure the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors determined that this finding affected the mitigating systems cornerstone because the deficiency degraded an operating margin associated with the short term heat removal capability of the RCIC system. Using the Phase 1 Screening Worksheet in attachment 4 of Inspection Manual 0609, Significance Determination Process, the inspectors determined that the finding had very-low safety significance (Green) because in Table 4a of the Phase 1 Screening Worksheet, all of the questions for the Mitigating Cornerstone were answered in the negative. This finding has a cross-cutting aspect in the resources component of the Human Performance area because the licensee did not maintain long-term plant safety by maintaining design margins. |
| 05000416/FIN-2010005-03 | 2010Q4 | Grand Gulf | Failure to Have Guidelines for the Choice of Protective Actions During an Emergency Consistent with Federal Guidance | A cited violation of 10 CFR 50.47(b)(10) was identified for failure to develop and have in place guidelines for the choice of protective actions during an emergency that were consistent with federal guidance. Federal guidance for the choice of protective actions during an emergency is described in EPA-400-R-92-001 and states, in part, that evacuation is seldom justified when doses are less than protective action guides. The licensees automatic process that extended existing protective action recommendations with changes in wind direction without considering radiation dose was identified as a performance deficiency. This finding is more than minor because it affects the Emergency Preparedness Cornerstone objective of implementing adequate measures to protect the health and safety of the public during a radiological emergency, and is associated with the cornerstone attributes of emergency response organization performance and procedure quality. This finding was determined to be of very low safety significance because it was a failure to comply with NRC requirements, was associated with risk significant planning standard 10 CFR 50.47(b)(10), and was not a risk significant planning standard functional failure or a planning standard degraded function. The finding was not a functional failure or degraded planning standard function because appropriate protective action recommendations for the public would have been made for all areas where protective action guides were exceeded. This finding is a cited violation of 10 CFR 50.47(b)(10) because the licensee failed to restore compliance with NRC requirements in a timely manner. The finding is related to the corrective action element of the problem identification and resolution crosscutting aspect because the licensee failed to take corrective actions to address the safety issue in a timely manner. |
| 05000416/FIN-2010005-04 | 2010Q4 | Grand Gulf | Inadequate Reactor Shutdown Procedure Causes Power and Level Oscillations | The inspectors identified a noncited violation of 10 CFR 50 Appendix B, Criterion V, for an inadequate shutdown procedure resulting in power and level oscillations in the reactor. The revised procedure failed to require the plant to be placed in startup feedwater level control during low power operations. The performance deficiency was self-revealing; however the inspectors added significant value by identifying inadequate condition report classification, causal evaluation, and corrective actions. As corrective action, the licensee planned to revise the procedure to ensure the plant is placed in startup feedwater control during low power operations. The licensee entered this issue into the corrective action program as Condition Report CR-GGN-2010-05140. The finding is more than minor because it was associated with the initiating events cornerstone attribute of procedure quality and affected the associated cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. Using the Phase 1 Screening Worksheet in attachment 4 of Inspection Manual 0609, Significance Determination Process, the inspectors determined that the finding had very-low safety significance (Green) because in Table 4a of the Phase 1 Screening Worksheet, the finding was a transient initiator that did not contribute to both the likelihood of a reactor trip and to the likelihood that mitigation equipment or functions would not be available. This finding has a crosscutting aspect in the area of human performance associated with the decision-making component, because station management failed to use conservative assumptions to demonstrate that the change to the shutdown operating procedure was safe prior to proceeding. |
| 05000416/FIN-2010005-05 | 2010Q4 | Grand Gulf | Failure to Perform Required Quality Control Inspections | Inspectors identified a noncited violation of 10 CFR 50, Appendix B, Criterion X, Inspection, for the failure to ensure that Quality Control verification inspections were consistently included and correctly specified in quality-affecting procedures and work instructions for construction-like work activities as required by the Quality Assurance Program. The licensee performed extensive reviews, and inspectors performed independent reviews of the licensees conclusions as well as independent sampling, to confirm that improper or missed inspections did not actually affect the operability of plant equipment. Entergy initiated prompt fleet-wide corrective actions to ensure proper work order evaluation and proper inclusion of Quality Control verification inspections. This issue was entered into the corrective action program under Condition Reports CR-HQN 2009-01184 and CR-HQN-2010-0013. The failure to ensure that adequate Quality Control verification inspections were included in quality-affecting procedures and work instructions as required by the Quality Assurance Program was a performance deficiency. This programmatic deficiency was more than minor because, if left uncorrected, it could lead to a more significant safety concern in that the failure to check quality attributes could involve an actual impact to plant equipment. This issue affected the Design Control attribute of the Mitigating Systems cornerstone because missed or improper quality control inspections during plant modifications could impact the availability, reliability, and capability of systems needed to respond to initiating events. This performance deficiency was determined to have very low safety significance in Phase 1 of Manual Chapter 0609, Significance Determination Process, since it was confirmed to involve a qualification deficiency that did not result in a loss of operability or functionality. The inspectors determined that this performance deficiency involved a cross-cutting aspect related to the human performance in decision-making (H.1a), because the licensee did not have an effective systematic process for obtaining interdisciplinary reviews of proposed work instructions to determine whether Quality Control verification inspections were appropriate. |
| 05000416/FIN-2010005-06 | 2010Q4 | Grand Gulf | Failure to Implement the Experience and Qualification Requirements of the Quality Assurance Program | Inspectors identified a noncited violation of 10 CFR 50, Appendix B, Criterion II, Quality Assurance Program, for the failure to implement the experience and qualification requirements of the Quality Assurance Program. As a result, the licensee failed to ensure that an individual assigned to the position of Quality Assurance Manager met the qualification and experience requirements of ANSI/ANS 3.1-1978 as required by the Quality Assurance Program. Specifically, the individual assigned to be the responsible person for the licensees overall implementation of the Quality Assurance Program did not have at least 1 year of nuclear plant experience in the overall implementation of the Quality Assurance Program within the quality assurance organization prior to assuming those responsibilities. This issue was entered into the corrective action program as Condition Report CR-HQN-2010-00386. Failure to ensure that an individual assigned to the position Quality Assurance Manager met the qualification and experience requirements of ANSI/ANS 3.1-1978 as required by the Quality Assurance Program was a performance deficiency. This performance deficiency was determined to be more than minor because, if left uncorrected, it could create a more significant safety concern. Failure to have a fully qualified individual providing overall oversight to the Quality Assurance Program had the potential to affect all cornerstones, but this finding will be tracked under the Mitigating Systems cornerstone as the area most likely to be impacted. The issue was not suitable for quantitative assessment using existing Significance Determination Process guidance, so it was determined to be of very low safety significance using IMC 0609, Appendix M, Significance Determination Process Using Qualitative Criteria. The inspectors determined that there was no crosscutting aspect associated with this finding because this issue was not indicative of current performance because the violation occurred more than 3 years ago. |
| 05000286/FIN-2010005-01 | 2010Q4 | Indian Point | Repeated Control Room Air Conditioner Gasket Failures | An NRO-identified NCV of very low safety significance of 10 CFR 50, Appendix B, Criterion XVl, Corrective Actions, was identified because Entergy personnel did not take prompt action to correct a condition adverse to quality regarding the safety-related control room air conditioning units. Specifically, Entergy personnel documented bulging and leaking control room air conditioning (CCR A/C) condenser gaskets in multiple condition reports between June and November 2010, but did not correct the condition as evidenced by the repeated nature of the gasket issues. As a result, the CCR A/C units incurred periods of unavailability while the gaskets were repaired. Entergy personnel entered this issue into the corrective action program (CAP) as CR- |
| 05000286/FIN-2010005-02 | 2010Q4 | Indian Point | Failure to lmplement the Experience and Qualification Requirements of the Quality Assurance Program | The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion ll, Quality Assurance Program (QAP), because Entergy personnel did not implement the qualification and experience requirements of the QAP to ensure that an individual assigned to the position of quality assurance manager (OAM) met the qualification and experience requirements of ANSI/ANS 3.1-1978. Specifically, the individual assigned as the responsible person for the Entergy\'s overall implementation of the QAP did not have at least one year of nuclear plant experience in the overall implementation of the QAP within the quality assurance organization prior to assuming those responsibilities. This issue was entered into Entergy\'s CAP as CR-HQN-2010-00386. This finding is more than minor because if left uncorrected, it could lead to a more significant safety concern. Specifically, the failure to have a fully qualified individual providing overall oversight to the QAP had the potential to affect all cornerstones. However, this finding will be tracked under the Mitigating Systems cornerstone as the area most likely to be impacted. The finding was not suitable for quantitative assessment using existing Significance Determination Process guidance. Using IMC 0609, Appendix M, Significance Determination Process Using Qualitative Criteria, NRC management determined the finding to be of very low safety significance (Green) because other quality assurance program functions remained unaffected by this performance deficiency, so defense-in-depth continued to exist. The inspectors determined there was no cross-cutting aspect associated with this finding because the performance deficiency did not reflect Entergy\'s current performance. Specifically, the performance deficiency occurred more than three years ago and was outside the current assessment period. |
| 05000247/FIN-2010005-02 | 2010Q4 | Indian Point | Inadequate Work Planning Control Relative to Regenerative Heat Exchanger Permanent Shielding Modification That Resulted in Additional Unplanned Collective Exposure | A Green self-revealing finding was identified because Entergy personnel did not adequately plan and control work activities related to a regenerative heat exchanger permanent shielding modification in accordance with radiation work permit (RWP) 20102537 , 2R19 Permanent Regen Hx Shielding. Specifically, Entergy personnel did not perform walkdowns to support modification package planning and provided limited field supervision which resulted in significant unplanned collective exposure (17.189 person-rem compared to a revised work activity estimate of 8.000 person-rem). This issue was entered into Entergy\'s CAP as CR-IP2-2010-02817. The finding is more than minor because it is associated with the program and process attribute of the Occupational Radiation Safety cornerstone and affected the cornerstone objective of ensuring the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine reactor operations. Additionally, this finding is similar to the more than minor example 6.j provided in IMC 0612, Power Reactor Inspection Reports, Appendix E, Examples of Minor lssues, because it involves an actual collective exposure greater than 5 person-rem and exceeded the planned, intended dose by more than 50%. Using IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, the finding was determined to have very low safety significance (Green) because the finding involved an as low as reasonably achievable (ALARA) planning issue and the 3-year rolling average collective dose history was less than 135 person-rem (52.261 person-rem average annual exposure for 2Q07-2Q09). The finding has a cross-cutting aspect in the area of human performance associated with the work control attribute because Entergy\'s planned work activities did not adequately ncorporate the job site interferences and their resolution in accordance with radiological safety |
| 05000247/FIN-2010005-03 | 2010Q4 | Indian Point | Inadequate Work Coordination Relative to Reactor Cavity Liner Repair That Resulted in Additional Unplanned Collective Exposure | A Green self-revealing finding was identified because Entergy personneldid not adequately plan and control work activities related to reactor cavity liner repair in accordance with RWP 20102530, 2R19 Cavity Liner Repair. Specifically, outage schedule delay and inadequate work coordination resulted in the use of back-up workers to perform the reactor cavity sealant removalwork, and also resulted in reactor head shielding removal and cancellation of additional shielding that was specified in the ALARA plan, which resulted in significant unplanned collective exposure (7.058 person-rem compared to a revised work activity estimate of 3.635 person-rem). This issue was entered into Entergy\'s CAP as CR-lP2-2010-02817. This finding is more than minor because it is associated with the program and process attribute of the Occupational Radiation Safety cornerstone and affected the cornerstone objective of ensuring the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine reactor operations. lt is also similar to the more than minor example 6.j provided in IMC 0612, Power Reactor Inspection Reports, Appendix E, Examples of Minor lssues, because it involves an actual collective exposure greater than 5 person-rem and exceeded the planned, intended dose by more than 50%. Using IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, the finding was determined to have very low safety significance (Green) because the finding involved an as low as reasonably achievable (ALARA) planning issue and the 3-year rolling average collective dose history was less than 135 person-rem (52.261 person-rem average annua exposure for 2007 -2009). The finding has a cross-cutting aspect in the area of human performance associated with the work coordination attribute because Entergy personnel did not coordinate and implement work activities as planned, which resulted in significant dose overrun. |
| 05000247/FIN-2010005-04 | 2010Q4 | Indian Point | Failure to Perform Required Quality Control lnspections | The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion X, lnspection, because Entergy personnel did not ensure that quality control verification inspections were consistently included and correctly specified in quality-affecting procedures and work instructions for construction-like work activities as required by the quality assurance program (OAP). Entergy personnel performed extensive reviews and initiated prompt fleet-wide corrective actions to ensure proper work order evaluation and proper inclusion of quality control verification inspections. This issue was entered into Entergy\'s corrective action program (CAP) as CR-HQN-2009-01184 and CR-HQN-2010-0013. This finding is more than minor because it is a programmatic deficiency that if lef uncorrected, could lead to a more significant safety concern in that the failure to check quality attributes could involve an actual impact to plant equipment. This finding is associated with the design control attribute of the Mitigating Systems cornerstone because missed quality control inspections during plant modifications could impact the availability, reliability, and capability of systems needed to respond to initiating events. Using IMC 0609.04, Phase 1 - Initial Screening and Characterization of Findings, the finding was determined to have very low safety significance (Green) because the finding is a qualification deficiency confirmed not to result in a loss of operability or functionality. Specifically, inspectors verified by sampling that work documents provided objectiv quality evidence that work activities that had missed quality control verifications were properly performed. The finding has a cross-cutting aspect in the area of human performance associated with the decision-making attribute because Entergy personnel did not have an effective systematic process for obtaining interdisciplinary reviews of proposed work instructions to determine whether Quality Controlverification inspections were appropriate. |
| 05000247/FIN-2010005-05 | 2010Q4 | Indian Point | Failure to lmplement the Experience and Qualification Requirements of the Quality Assurance Program | The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion ll, Quality Assurance Program (QAP), because Entergy personnel did not implement the qualification and |
| 05000247/FIN-2010005-06 | 2010Q4 | Indian Point | Inadequate Main Boiler Feed Pump Speed Controller Setting | A Green self-revealing finding was identified because Entergy\'s procedure 2-IC-PC-N-P-408A, Main Boiler Feed Pump (MBFP) Discharge Pressure Spee Control, did not provide adequate guidance to ensure proper settings for the MBFP speed controller settings at low power operations. Specifically, between May 5, 2006 and September 3, 2010, procedure 2-lC-PC-N-P-408A did not provide adequate guidance to ensure proper settings for the MBFP speed controller settings at low power operations, resulting in a slow MBFP response, which contributed to a reactor trip from 41 % power. Entergy personnel took immediate corrective actions to change the MBFP speed controller settings. This issue was entered into Entergy\'s corrective action program (CAP) as condition report (CR)-lP2-2010-05484. This finding is more than minor because it is associated with the design control attribute of the Initiating Events cornerstone and affects the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety function during power operations. Specifically, inadequate design control of the MBFP speed controller settings contributed to a reactor trip. Using IMC 0609.04, Phase 1 - Initial Screening and Characterization of Findings, the finding was determined to have very low safety significance (Green) because the finding did not contribute to the likelihood that mitigation equipment or functions would not be available. The inspectors determined there was no cross-cutting issue associated with the finding because the performance deficiency did not reflect Entergy\'s current performance. Specifically, the performance deficiency occuned more than three years ago and was outside the current assessment period. |
| 05000247/FIN-2010005-09 | 2010Q4 | Indian Point | Failure to Meet TS Oversight Requirement | A Green self-revealing NCV of Technical Specification (TS) 5.1, responsibility, was identified because on February 9, 2010, the control room supervisor (CRS) assigned as having the control room command function, left the control room without designating another senior reactor operator (SRO) qualified individual to assume the control room command function. The CRS promptly returned to the control room shortly after the issue was identified. This issue was entered into Entergy\'s CAP as CR-IP2-201 0-00708. he finding is more than minor because it could be reasonably viewed as a precursor to a significant event. Specifically, the absence of SRO oversight during licensed control room activities increases the likelihood of human performance errors contributing to an initiating event and reduces the effectiveness of event mitigation. The finding is associated with the human performance attribute of the Mitigating Systems cornerstone and affects the cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. The finding was not suitable for quantitative assessment using existing Significance Determination Process guidance. Using IMC 0609, Appendix M, Significance Determination Process Using Qualitative Criteria, NRC management determined the finding to be of very low safety significance (Green) because of the short period the CRS was absent from the control room, and because no initiating events occurred during that time. The finding has a cross-cutting aspect in the area of human performance associated with the work practices attribute because of the ineffective use of shift turnover practices, in that the CRS did not self check or communicate his decision to leave the control room to the rest of the control room staff. |
| 05000293/FIN-2010005-01 | 2010Q4 | Pilgrim | Failure to Manage a Yellow Risk Condition During HPCI Testing from the Alternate Shutdown Panel | The inspectors identified a Green non-cited violation (NCV) of 10 CFR 50.65 paragraph (a)(4) for Entergy\'s failure to correctly assess and manage a Yellow risk condition for planned testing of the High Pressure Coolant Injection (HPCI) system from the Alternate Shutdown Panel (ASP). Specifically, Entergy considered HPCI available by crediting multiple manual actions to restore the automatic function. However, these actions were not few or simple and would not have restored the HPCI automatic function in a timeframe consistent with guidance discussed in NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. In addition, HPCl\'s automatic function would not have been restored in a timeframe consistent with Pilgrim\'s Updated Final Safety Analysis Report (UFSAR), Section 6.4.1, which specifies 90 seconds for HPCI to reach its required design flow rate. Corrective actions included issuing a standing order to alert Operators of the specific requirements to maintain a system available during maintenance and testing. Corrective actions planned include revising Entergy\'s Risk Assessment Procedure to verify systems credited as available have clear and simple direction to restore automatic functional status during maintenance and testing. This finding was determined to be more than minor because Entergy\'s elevated plant risk would put the plant into a higher risk category and require additional risk management actions, namely protecting the Reactor Core Isolation Cooling system. In addition, the finding affected the Human Performance attribute of the Mitigating System\'s cornerstone objective to ensure the availability of systems to respond to initiating events and prevent undesirable consequences. The inspectors performed an evaluation in accordance with IMC 0609, Significance Determination Process, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process, because the finding related to Entergy\'s assessment and management of risk. The finding was determined to be of very low safety significance (Green) because the Incremental Core Damage Probability Deficit for the unavailability of HPCI for the duration of the activity was less than 1.0E-6 per year (approximately 2.6E-9 per year). The inspectors determined that this finding had a cross-cutting aspect in the Human Performance cross-cutting area, Work Control component, because Entergy did not correctly plan and coordinate work activities by incorporating appropriate risk insights (H.3(a)). (Section 1R13) |
| 05000293/FIN-2010005-02 | 2010Q4 | Pilgrim | Failure to Perform Required Quality Control Inspections | The inspectors identified an NCV of 10 CFR 50, Appendix B, Criterion X, Inspection, for the failure to ensure that Quality Control verification inspections were consistently included and correctly specified in quality-affecting procedures and work instructions for construction-like work activities as required by the Quality Assurance Program. Entergy initiated prompt fleet-wide corrective actions to ensure proper work order evaluation and proper inclusion of Quality Control verification inspections. This issue was entered into the corrective action program as condition reports (CR) CR-HQN 2009-01184 and CR-HQN-2010-0013. The failure to ensure that adequate Quality Control verification inspections were included in quality-affecting procedures and work instructions as required by the Quality Assurance Program was a performance deficiency. This issue was more than minor because, if left uncorrected, it could lead to a more significant safety concern; in that, the failure to check quality attributes could involve an actual impact to plant equipment. This issue affected the Design Control attribute of the Mitigating Systems cornerstone because missed or improper quality control inspections during plant modifications could impact the availability, reliability, and capability of systems needed to respond to initiating events. This performance deficiency was determined to be of very low safety significance (Green), since it was confirmed to involve a qualification deficiency that did not result in a loss of operability or functionality. The inspectors determined that this issue had a cross-cutting aspect in the Human Performance cross-cutting area, Decision-Making component, because the licensee did not have an effective systematic process for obtaining interdisciplinary reviews of proposed work instructions to determine whether Quality Control verification inspections were appropriate (H.1(a)). |
| 05000293/FIN-2010005-03 | 2010Q4 | Pilgrim | Failure to Implement the Experience and Qualification Requirements of the Quality Assurance Program | The inspectors identified an NCV of 10 CFR 50, Appendix B, Criterion II, Quality Assurance Program, for the failure to implement the experience and qualification requirements of the Quality Assurance Program. As a result, the licensee failed to ensure that an individual assigned to the position of Quality Assurance Manager met the qualification and experience requirements of ANSIIANS 3.1-1978 as required by the Quality Assurance Program. Specifically, the individual assigned to be the responsible person for the licensee\'s overall implementation of the Quality Assurance Program did not have at least one year of nuclear plant experience in the overall implementation of the Quality Assurance Program within the quality assurance organization prior to assuming those responsibilities. This issue was entered into the corrective action program as CRHQN- 2010-00386. The failure to ensure that an individual assigned to the position of Quality Assurance Manager met the qualification and experience requirements of ANSI/ANS 3.1-1978 as required by the Quality Assurance Program was a performance deficiency. This issue was more than minor because, if left uncorrected, it could create a more significant safety concern. The failure to have a fully qualified individual prOViding overall oversight to the Quality Assurance Program had the potential to affect all cornerstones, but the inspectors determined that this finding will be tracked under the Mitigating Systems cornerstone as the area most likely to be impacted. The issue was not suitable for quantitative assessment using existing NRC Significance Determination Process (SOP) guidance, so it was determined to be of very low safety significance (Green) using NRC Inspection Manual Chapter (IMC) 0609, Appendix M, Significance Determination Process Using Qualitative Criteria. The inspectors determined that there was no cross-cutting aspect associated with this finding because this issue was not indicative of current performance as it occurred more than three years ago. |