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| Quarter | Site | Title | Description | |
|---|---|---|---|---|
| 05000445/FIN-2013008-04 | 2013Q4 | Comanche Peak | Licensee-Identified Violation | Title 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires that measures shall be established to ensure that conditions adverse to quality are promptly identified and corrected. Contrary to this requirement, the licensee failed to promptly identify and correct the continued unreliability of its service water vacuum breakers. The licensee initially identified and documented this violation in CR-2011-007644 and CR-2011-08500. This violation was of very low safety significance because it did not result in the loss of operability or functionality of any system or train. |
| 05000445/FIN-2013008-03 | 2013Q4 | Comanche Peak | Components of Indeterminate Quality Installed in Safety-Related Applications | The team identified a Green non-cited violation of 10 CFR 50, Appendix B, Criterion III, Design Control, for the licensees failure to control deviations from quality standards. After identifying that maintenance personnel had failed to ensure that subcomponents of 480-volt switchgear were properly identified and controlled during refurbishment, the licensee failed to document or evaluate where subcomponents of an indeterminate pedigree had been installed in safety-related applications. The licensee took immediate action to confirm the operability of the installed trip units and to determine the scope of the problem. The failure to control deviations from quality standards as required by 10 CFR 50, Appendix B, Criterion III was a performance deficiency. This performance deficiency was more than minor because it affected the design control attribute of the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of components that respond to initiating events. Using Inspection Manual Chapter 0609, Appendix A, the team determined that the finding was of very low safety significance because it did not result in the loss of operability or functionality of a safety-related system or train. The finding had a cross-cutting aspect in the corrective action program component of the problem identification and resolution cross-cutting area because the licensee had failed to implement a corrective action program with a low threshold for identifying issues to ensure that an issue potentially affecting nuclear safety was promptly identified and fully evaluated. |
| 05000445/FIN-2013008-02 | 2013Q4 | Comanche Peak | Failure to Provide Adequate Acceptance Criteria | The team identified a Green non-cited violation of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to provide adequate acceptance criteria for bearing oil level in its residual heat removal pump motors. The team identified two examples of this violation, one of which resulted in pump bearing oil being lowout- of-specification. After identification of this performance deficiency, operations management issued an Operations Shift Order to ensure equipment operators appropriately verified bearing oil levels. The failure to provide adequate acceptance criteria for an activity affecting quality was a performance deficiency. The performance deficiency was more than minor because it adversely affected the human performance attribute of the mitigating systems cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events. Using Inspection Manual Chapter 0609, Appendix A, the team determined that the finding was of very low safety significance because it did not result in the loss of operability or functionality of a safety-related system or train. The finding had a cross-cutting aspect in the corrective action program component of the problem identification and resolution crosscutting area because the licensee had failed to implement a corrective action program with a low threshold for identifying issues to ensure that an issue potentially affecting nuclear safety was promptly identified and fully evaluated. |
| 05000445/FIN-2013008-05 | 2013Q4 | Comanche Peak | Licensee-Identified Violation | Title 10 CFR 50, Appendix B, Criterion VII, Identification and Control of Materials, Parts, and Components, requires that measures shall be established for the identification and control of materials, parts, and components. Contrary to this requirement, the licensee failed to establish measures to identify and control safety-related Amptector trip units. The licensee identified and documented this violation in CR-2009-001000. This violation was of very low safety significance because it did not result in the loss of operability or functionality of any system or train. |
| 05000445/FIN-2013008-01 | 2013Q4 | Comanche Peak | Failure to Perform Cause Evaluations for Maintenance Preventable Functional Failures | The team identified a Green finding for a failure to follow procedures that required the licensee to perform cause evaluations for maintenance preventable functional failures (MPFFs). Two MPFFs were not evaluated for their causes because a condition report was not generated to perform the evaluation. After identification of this performance deficiency, the licensee generated condition reports to evaluate the two MPFFs for causes. The licensees failure to ensure that cause evaluations were performed for MPFFs as required by procedure was a performance deficiency. This constituted a programmatic weakness in the licensees maintenance rule program and corrective action program and resulted in MPFFs not being prioritized and evaluated appropriately for corrective action, which could result in recurring failures. The affected systems crossed the Initiating Events, Mitigating Systems, and Emergency Preparedness cornerstones, but because the performance deficiency was associated with a programmatic weakness of the maintenance rule program, the inspectors determined that the Mitigating Systems cornerstone was the most affected. The finding was more than minor because it adversely affected the equipment performance attribute of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At Power, the finding was determined to be of very low safety significance (Green) because the finding was not a deficiency affecting the design or qualification of a mitigating SSC, and did not represent a loss of system or function. The finding has a human performance cross-cutting aspect associated with work practices in that licensee supervision failed to define expectations regarding compliance with the maintenance rule and corrective action program procedures. |
| 05000397/FIN-2013008-01 | 2013Q3 | Columbia | Programmatic Failure to Promptly Evaluate Safety Impact of Degraded Conditions | The team identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instruction, Procedures and Drawings. This violation involved multiple examples of the licensees failure to follow station operability and functionality evaluation procedures, resulting in untimely and poorly documented operability and functionality determinations. The licensee documented the associated performance deficiency in its corrective action program as CR 289705 and took immediate actions to ensure operators understood and followed the timeliness requirements of PPM 1.3.66. The failure to follow station operability procedures, which resulted in operability determinations not being timely performed, was a performance deficiency. This performance deficiency was more than minor because if left uncorrected, the continued failure to perform timely operability and functionality evaluations would have the potential to lead to a more significant safety concern. This finding was associated with the mitigating systems cornerstone. Using Inspection Manual Chapter 0609 Appendix A, Exhibit 2, the team determined the finding was of very low safety significance (Green) because the performance deficiency did not result in the loss of functionality of any structure, system, or component. The inspectors determined that this finding had a cross-cutting aspect in the work practices component of the human performance crosscutting area because the licensee failed to define and effectively communicate expectations regarding compliance with PPM 1.3.66. |
| 05000397/FIN-2013008-05 | 2013Q3 | Columbia | Failure to Implement Procedure for Age Management of Electrolytic Capacitors | The team identified a green non-cited violation of Technical Specification 5.4.1.a, Procedures, for the licensees failure to implement its procedure for age management of electrolytic capacitors. The licensee had established the procedure in December 2011, to determine the age of electrolytic capacitors installed in critical applications and to identify or establish preventative maintenance tasks to monitor aging capacitors and to provide for their periodic replacement. As of July 2013, system engineers had not determined the age of electrolytic capacitors in their systems, identified existing preventative maintenance tasks that would include replacing the electrolytic capacitors, or established preventative maintenance tasks if none existed. The licensee entered the performance deficiency into its corrective action program as CR 288912. The licensees failure to fully implement the requirements of its age management of electrolytic capacitors procedure was a performance deficiency. The performance deficiency was more than minor, because if left uncorrected, the failure to establish preventative maintenance schedules for critical electrolytic capacitors per procedure would have the potential to lead to a more significant safety concern. Specifically, the failure to manage age-related degradation of electrolytic capacitors could cause equipment containing electrolytic capacitors to fail, resulting in a plant transients or safety-related equipment being inoperable or unavailable. Using Inspection Manual Chapter 0609, Appendix A, Exhibit 2, the team determined the finding was of very low safety significance (Green) because there was no loss of operability or functionality as a result of the performance deficiency. The inspectors determined the finding had a crosscutting aspect in the corrective action program component of the problem identification and resolution cross-cutting area because the licensee failed to take appropriate corrective action to ensure that an issue potentially impacting nuclear safety was addressed in a timely manner, commensurate with its safety significance and complexity. |
| 05000397/FIN-2013008-04 | 2013Q3 | Columbia | Failure to Control Inadequate Surveillance Procedure | The team identified a Green non-cited violation of Technical Specification 5.4.1.a for the licensees failure to follow its procedure-control procedure. Following discovery of an inadequate surveillance procedure for a high-pressure core spray instrument, the licensee failed to deactivate the procedure in accordance with its procedure-control procedure to prevent its use. This inadequate procedure was later implemented in the performance of a technical specification surveillance. The licensee entered this performance deficiency in its corrective action program as CR 288647. On July 9, 2013, the licensee placed the surveillance procedure on hold in accordance with the current Revision of its procedure-control procedure. The failure to deactivate an inadequate technical specification surveillance procedure in accordance with the licensees procedure-control procedure was a performance deficiency. The performance deficiency was more than minor because it affected the procedure quality attribute of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, Exhibit 2, the team determined the finding was of very low safety significance (Green) because there was no loss of operability or functionality as a result of the performance deficiency. The inspectors determined that this finding had a crosscutting aspect in the corrective action program component of the problem identification and resolution cross-cutting area because the licensee failed to take appropriate corrective action to ensure that an issue potentially impacting nuclear safety was addressed in a timely manner, commensurate with its safety significance and complexity. |
| 05000397/FIN-2013008-03 | 2013Q3 | Columbia | Failure to Identify and Correct Environmental Qualification Deficiency | The team identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to promptly identify and correct a condition adverse to quality. Following discovery of non-environmentally qualified flow transmitters installed in the train A and C residual heat removal subsystems, licensee personnel failed to document the nonconforming condition in a condition report and failed to promptly restore the flow transmitters to an environmentally qualified state. No immediate actions were required to restore compliancethe licensee had replaced the nonconforming transmitters under Work Orders 01156960 and 01150424 on August 31, 2012, and September 12, 2012, respectively. The licensee entered this performance deficiency into its corrective action program as CR 289720. The licensees failure to initiate a condition report for a non-conforming condition involving non-environmentally qualified flow transmitters installed in the train A and C residual heat removal subsystems was a performance deficiency. The performance deficiency was more than minor because it affected the design control attribute of the Mitigating Systems Cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609 Appendix A, Exhibit 2, the team determined the finding was of very low safety significance (Green) because the finding was a design deficiency that did not result in the loss of functionality. The inspectors determined that this finding had a cross-cutting aspect in the decision-making component of the human performance cross-cutting area because the licensee failed to demonstrate that nuclear safety was an overriding priority by using conservative assumptions when making decisions about non-conforming conditions. |
| 05000397/FIN-2013008-02 | 2013Q3 | Columbia | Failure to Classify Condition Reports in Accordance with Procedures | The team identified a Green finding involving six examples of the licensees failure to follow its corrective action program procedures. This resulted in condition reports not being appropriately prioritized in accordance with procedure SWP-CAP-06, Condition Review Group (CRG), Revisions 18-20. The licensee entered this issue into its corrective action program as CR 289722. The licensees condition review groups failure to properly classify condition reports in accordance with SWP-CAP-06, Condition Review Group (CRG), Revisions 18-20, was a performance deficiency. The performance deficiency was more than minor, because if left uncorrected, the failure to properly prioritize condition reports would have the potential to lead to a more significant safety concern because safety-significant conditions may not be promptly evaluated and addressed. This finding was associated with the mitigating systems cornerstone. Using Inspection Manual Chapter 0609 Appendix A, Exhibit 2, the team determined the finding was of very low safety significance (Green) because the performance deficiency did not result in the loss of functionality of any structure, system, or component. The team determined that this finding had a cross-cutting aspect in the decision-making component of the human performance cross-cutting area because the licensee failed to demonstrate that nuclear safety was an overriding priority by formally defining the authority and roles for decisions affecting nuclear safety and implementing those roles and authorities as designed when prioritizing condition reports. |
| 05000397/FIN-2013008-07 | 2013Q3 | Columbia | Licensee-Identified Violation | Title 10 CFR, Part 50, Appendix B, Criterion III, Design Control, requires in part that measures shall be established to assure that applicable regulatory requirements and the design basis, as defined in 50.2 and as specified in the license application, for those structures, systems, and components to which the appendix applies are correctly translated into specifications, drawings, procedures, and instructions. These measures shall include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled. Contrary to this requirement, the licensee failed to establish measures that included provisions to assure that deviations from appropriate quality standards were controlled. Specifically, prior to April 24, 2012, the licensee failed to implement measures to control the seismic design qualification for diesel mixed air temperature indicating switch DMA-TIS-22B. The licensee self-identified this violation and entered it into the corrective action program as CR 262245. The performance deficiency was more than minor because it affected the design control attribute of the mitigating systems cornerstone objective. A senior reactor analyst performed a detailed risk evaluation for this finding. The finding was of very low safety significance (Green) because the bounding change to the core damage frequency was 1.5 x 10-7/year. This finding did not have a significant impact to the large early release frequency. |
| 05000397/FIN-2013008-08 | 2013Q3 | Columbia | Licensee-Identified Violation | Title 10 CFR, Part 50, Appendix B, Criterion III, Design Control, requires in part that measures shall be established to assure that applicable regulatory requirements and the design basis, as defined in 50.2 and as specified in the license application, for those structures, systems, and components to which the appendix applies are correctly translated into specifications, drawings, procedures, and instructions. These measures shall include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled. Contrary to this requirement, the licensee failed to establish measures that included provisions to assure that deviations from appropriate quality standards were controlled. Specifically, prior to September 12, 2012, the licensee failed to implement measures to control the environmental qualification requirements for residual heat removal flow transmitters RHR-FT-15A and RHR-FT-15C. The licensee self-identified this violation and entered it into the corrective action program as CR 289724. The performance deficiency was more than minor because it affected the design control attribute of the mitigating systems cornerstone objective. The finding was determined to be of very low safety significance because it did not represent an actual loss of a safety function. |
| 05000397/FIN-2013008-06 | 2013Q3 | Columbia | Inadequate Evaluation of Nonconforming Condition Resulting in Potential Missed Report | The team identified an unresolved item involving a potential failure to submit a required licensee event report following discovery of a non-seismically qualified temperature switch in the diesel mixed air system. If this switch would have been unable to perform its safety function following a seismic event, its installation would have represented a condition prohibited by the plants technical specifications. On April 24, 2012, the licensee initiated CR 262245 documenting that the then-installed diesel mixed air temperature indicating switch DMA-TIS-22B was not seismically qualified. DMA-TIS-22B controls a heater that supports the train B emergency diesel generator; the switch is required to be Seismic Category I. Equipment qualification report QID 342003-01 listed the seismically qualified switch as model T26S-18; the licensee discovered that the installed switch was non-seismic model T22. The licensee was unable to determine when the nonseismic switch had been installed. On April 25, 2012, the licensee replaced the nonqualified switch with the correct, seismically qualified component under work order 01183010. To determine if the installation of the nonseismic switch represented a condition prohibited by technical specifications and therefore required a Licensee Event Report to be submitted to the NRC, the licensee initiated Seismic Qualification Task W01939-001. This engineering evaluation qualitatively compared the two switches and concluded that Model T22 switch was as seismically qualified as the Model T26S-18 switch. Based on the results of the engineering evaluation, the licensee concluded that the issue described in CR 262245 did not require a report to the NRC. The team determined that the engineering evaluation performed under W01939-001 did not meet the seismic qualification requirements specified in the Columbia Generating Station Final Safety Analysis Report (FSAR). Specifically, the FSAR, Section 3.10.1.2.2.4, provides for Mandatory Dynamic Testing in certain circumstances: When potential failure of Class 1E equipment cannot be evaluated structurally (e.g., opening or closing of electrical circuits), then vibration tests are required to demonstrate seismic adequacy. No analytical procedures are considered acceptable in these instances. The team determined that because diesel mixed air temperature indicating Switch DMA-TIS-22B has a required function involving the opening or closing of electrical circuits, the FSAR, Section 3.10.1.2.2.4, precludes qualitative analysis of the non-qualified switch to determine that the nonseismic switch was as seismically qualified ; vibration tests were required to demonstrate that the switch met Seismic Class I criteria. If the Model T22 switch cannot be demonstrated by acceptable methods to have met Seismic Class I requirements while installed, the licensees determination that the train B emergency diesel generator remained operable with the nonqualified switch is invalid. If the emergency diesel generator was inoperable while the nonseismic switch was installed, a licensee event report would have been required for a condition prohibited by technical specifications in accordance with 10 CFR 50.73(a)(2)(i)(B). This report would have been required by June 23, 2012, sixty days after the April 24, 2012, discovery of the nonconforming condition. At the conclusion of the inspection, the licensee planned to perform vibration testing of a model T22 switch. Following completion of that testing, additional review will be required to determine if this issue constituted a violation of NRC requirements. This issue is identified as URI 05000397/2013008-06, Inadequate Evaluation of Nonconforming Condition Resulting in Potential Missed Report. |
| 05000361/FIN-2012009-02 | 2013Q2 | San Onofre | Failure to Verify Adequacy of Thermal-Hydraulic and Flow-Induced Vibration Design for the Unit 3 Replacement Steam Generators | The inspectors identified an apparent violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the failure to verify the adequacy of the thermal-hydraulic and flow-induced vibration design of the Unit 3 replacement steam generators, which resulted in significant and unexpected steam generator tube wear after 11 months of operation and an associated apparent violation of Technical Specification 5.5.2.11, Steam Generator Program, loss of tube integrity on Unit 3 Steam Generator 3E0- 88. The licensee initiated Nuclear Notification NN 202447265 to address this issue in the corrective action program. Southern California Edison revised the thermal-hydraulic code of record and ensured that the code was in accordance with ASME guidance. Subsequently, on June 7, 2013, Southern California Edison announced that Units 2 and 3 would be permanently shut down. This finding is more than minor because it is associated with the equipment performance attribute of the Initiating Events Cornerstone and adversely affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the failure to verify the adequacy of the thermal-hydraulic and flow-induced vibration design resulted in excessive and rapid tube wear due to fluid elastic instability, which challenged the structural integrity of the tubes to perform their pressure boundary function. The inspectors used NRC Inspection Manual Chapter 0609, Attachment 4 and Appendix A, to evaluate the significance of this finding. In accordance with Exhibit 1 of Inspection Manual Chapter 0609, Appendix A, the inspectors determined that this finding required evaluation in accordance with Inspection Manual Chapter 0609, Appendix J, because the finding involved a degraded steam generator tube condition where one tube could not sustain three times the differential pressure across a tube during normal full power, steady-state operation. In accordance with Inspection Manual Chapter 0609, Appendix J, this finding required a detailed risk analysis, since it involved two or more tubes that could not sustain three times the normal differential pressure and one or more steam generators that violated accident-induced leakage performance criterion. A Phase 3 analysis was completed using the San Onofre SPAR model, Revision 8.22, assuming average test and maintenance, and a truncation limit of 1.0E-11. Based on the best available information, the performance deficiency was preliminarily characterized as a finding of low to moderate safety significance (White). The final significance of this finding is to be determined. No cross-cutting aspect was assigned because this performance deficiency occurred in the 2005 to 2008 timeframe. Substantial management and personnel changes have occurred, including taking actions to address a chilled work environment and other safety culture issues. The NRC determined that the performance behavior that existed at that time is not indicative of current performance |
| 05000298/FIN-2013009-01 | 2013Q1 | Cooper | Failure to Maintain Seismic Qualification of Standby Liquid Control System | The team identified a Green violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to assure that design basis requirements associated with the standby liquid control (SLC) system test tank were correctly translated into procedures. As a result, the licensee failed to maintain the tank empty as required to meet seismic design requirements. The violation is cited because the licensee failed to restore compliance in a reasonable time following documentation of the issue as a non-cited violation in NRC Inspection Report 05000298/2012002, issued May 10, 2012 (ML12131A674). The licensee entered these issues into its corrective action program for resolution as Condition Report CR-CNS-2013-01962, CR-CNS-2013-02027, and CR-CNS-2013-02328. The failure to maintain design control of the standby liquid control system was a performance deficiency. This performance deficiency was of more than minor safety significance because it was associated with the design control attribute of the mitigating systems cornerstone and it adversely affected cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensees failure to implement procedures to ensure the SLC test tank remained in a seismically qualified condition resulted in an inability to provide reasonable assurance of operability following a seismic event. Using Inspection Manual Chapter 0609, Appendix A, Exhibit 2, the team determined that the finding was of very low safety significance (Green) because it was a design deficiency that did not result in the loss of functionality. This finding had a cross-cutting aspect in the area of human performance associated with the decision-making component because the licensee failed to adopt a requirement to demonstrate that a proposed action was safe in order to proceed rather than a requirement to demonstrate it was unsafe in order to disapprove the action. |
| 05000298/FIN-2013009-02 | 2013Q1 | Cooper | Failure to Notify the NRC within Eight Hours of a Nonemergency Event | The team identified a Severity Level IV non-cited violation of 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors, for the licensees failure to make a required report to the NRC. After the licensee determined that the standby liquid control test tank could not meet Seismic Class I requirements unless empty, the team discovered that the tank was full. The licensee immediately drained the tank and implemented a compensatory action to maintain it empty. However, the licensee failed to recognize that because the compensatory measure was required to provide a reasonable assurance of operability, the as-found condition of the SLC systemwith the test tank fullrendered both trains of the system inoperable. Because this could have prevented the fulfillment of the SLC systems safety function, the licensee was required to report the condition to the NRC within eight hours of discovery. After identification, the licensee entered this issue into its corrective action program and made a late report to the NRC, restoring compliance with the regulation. The failure to make a required report to the NRC within the required time was a performance deficiency. The team determined that traditional enforcement applied to this violation because the violation impeded the regulatory process. Specifically, the NRC relies on the licensee to identify and report conditions or events meeting the criteria specified in regulations in order to perform its regulatory oversight function. Assessing the violation in accordance with Enforcement Policy, the team determined it to be of Severity Level IV because it involved the licensees failure to make a report required by 10 CFR 50.72 (Enforcement Policy example 6.9.d.9). Because this was a traditional enforcement violation with no associated finding, no cross-cutting aspect is assigned to this violation. |
| 05000313/FIN-2013010-01 | 2013Q1 | Arkansas Nuclear | Failure to Provide Maintenance Instructions for Installation of Fluorescent Light Fixtures | Inspectors identified a violation of Technical Specification 5.4.1.a, which requires that the licensee establish, implement, and maintain the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Paragraph 9.a of Appendix A requires, in part, that maintenance that can affect the performance of safety-related equipment be properly preplanned and performed in accordance with documented instructions. Contrary to the above, prior to March 2013, the licensee did not preplan and perform maintenance that could affect the performance of safety-related equipment in accordance with documented instructions. Specifically, the licensee failed to establish instructions to ensure that fluorescent light fixtures in both Unit 1 emergency diesel generator rooms were returned to their analyzed design configuration after maintenance was performed. The licensee documented the issue in Condition Reports CR-ANO-C-2013-0631 and CR-ANO-C-2013-0632. Inspectors concluded that the licensees failure to have work instructions to control the design configuration of fluorescent light fixtures, in the Unit 1 emergency diesel generator rooms, was a performance deficiency. The finding is more than minor because it is associated with the Mitigating System Cornerstone attribute of procedure quality and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Using Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, and Appendix A, The Significance Determination Process for Findings at Power, the finding was screened against the mitigating systems cornerstone and determined to be of very low safety significance (Green) because the finding did not: (1) result in an actual loss of operability or functionality, (2) represent a loss of system and/or function, (3) represent an actual loss of function of a single train for greater than its technical specification allowed outage time, (4) represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safetysignificant for greater than 24 hours and (5) involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding or severe weather event. This finding did not have a cross-cutting aspect associated with it because the most significant contributor was not indicative of current performance. Specifically, the licensee had never established instructions to ensure that the fluorescent light fixtures were returned to their analyzed design configuration after maintenance was performed. |
| 05000498/FIN-2012007-02 | 2012Q4 | South Texas | Licensee-Identified Violation | The following violation of NRC requirements was identified by the licensee. The team determined that the violation was of very low safety significance (Green) and that it met the criteria of the NRC Enforcement Policy for being dispositioned as a non-cited violation: Criterion V of 10 CFR Part 50, Appendix B requires that activities affecting quality shall be prescribed by procedures and accomplished in accordance with those procedures. Procedure OPGP03-ZX-002, Condition Reporting Process, Revision 44, provides criteria for classifying conditions identified in condition reports. While performing quality audits between 2010 and 2012, the licensee identified multiple examples of documented deficiencies associated with procedures or activities affecting quality that had been misclassified as conditions not adverse to quality. These misclassifications were contrary to the requirements of OPGP03-ZX-002; they therefore represented violations of 10 CFR 50, Appendix 8, Criterion V. The performance deficiency associated with this violation is of greater than minor safety significance because if left uncorrected, it would have the potential to lead to a more significant safety concern. Using qualitative engineering judgment and regulatory oversight experience in accordance with Inspection Manual Chapter 0609, Appendix M, the team determined the finding to be of very low safety significance (Green). The licensee identified this violation and documented it in its corrective action program as CR 12-27789. |
| 05000382/FIN-2012008-02 | 2012Q3 | Waterford | Failure to Take Corrective Action Associated with Emergency Feedwater Pump AB | The team identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the failure to take timely corrective action for a condition adverse to quality. Specifically, from May 2011, through August 2012, the licensee failed to restore a degraded condition, which included a corrective action to perform a new design analysis for the emergency feedwater pump AB after the removal of heat trace circuit 1-8C, despite having a reasonable amount of time to complete it. Currently, plant operators are required once per shift to perform temperature verifications of the heat trace to ensure condensation does not form in the steam supply pipe to the turbine driven pump and to maintain emergency feedwater pump AB in an operable but degraded status until the design analysis is complete. This finding was entered into the licensees corrective action program as Condition Report CR-WF3-2012-03754. The team determined that the failure to complete the corrective action of performing a new design analysis to determine if emergency feedwater pump AB - 6 - Enclosure 2 required a design modification based on the analysis in a timely manner was a performance deficiency. The performance deficiency was more than minor because it affected the equipment performance attribute of the Mitigating Systems Cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, failure to implement this corrective action could result in reduced reliability of the emergency feedwater pump AB. In accordance with NRC Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, the issue was determined to affect the Mitigating Systems Cornerstone. In accordance with NRC Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings at Power, the issue was determined to have very low safety significance (Green) because it affected the design or qualification of mitigating systems, structures, and components; however, the systems, structures, and components maintained operability. This finding had a cross-cutting aspect in the human performance area, resources component, in that the licensee failed to minimize a longstanding equipment issue adequately to assure nuclear safety |
| 05000382/FIN-2012008-03 | 2012Q3 | Waterford | Failure to Take Timely Corrective Action to Establish a Basis for Flood Control Measures | The team identified a cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control , for the failure to establish measures to assure that applicable regulatory requirements and the design basis as defined in 10 CFR 50.2 are correctly translated into procedures. Specifically, the licensee has not determined a basis for the level at which flood control measures are initiated, two years after receiving a non-cited violation for the same deficiency. As an interim compensatory measure for a previous violation of inadequate technical specifications, the licensee modified their flooding procedure to include an action to start shutting flood control doors at a river level of 24 feet instead of 27 feet. The licensee recognized the need to establish a basis for initiating these actions at 24 feet, and issued a corrective action to track completion. The licensee extended the due date several times and had not completed it by the arrival of the inspection team. The inspection team questioned why the licensee had not completed the calculation to justify their basis for their compensatory measures, noting that it had been over two years since the original violation was identified. The inspectors verified through walk-downs, procedure reviews, and historical data that the licensees use of 24 feet did not represent an immediate operability concern, and that the current river level was sufficiently low to allow time for the licensee to correct the deficiency. This finding was entered into the licensees corrective action program as condition report CR-WF3-2012-03752. The failure to complete the corrective action to establish a basis for flood control measures in a timely manner was a performance deficiency. The performance deficiency was more than minor because it was associated with the protection from external events 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. Specifically, the licensee failed to verify through calculations or analysis that the actions taken to secure flood doors could be completed in time to protect safety related equipment from flooding due to a levee failure. In accordance with NRC Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, the issue was determined to affect the Mitigating Systems Cornerstone. In accordance with NRC Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings at Power , the issue was determined to have very low safety significance (Green) because it did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding, or severe weather initiating event. Specifically, the inspectors confirmed that the licensee could reasonably ensure the flood control doors could perform their safety function. This finding had a cross-cutting aspect in the human performance area, resources component in that the licensee failed to maintain long term plant safety by maintenance of design margins and ensuring engineering backlogs low enough to support safety. |
| 05000382/FIN-2012008-04 | 2012Q3 | Waterford | Failue to Ensure Operator Knowledge of Equipment Status | The team identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for a failure to follow Procedure EN-OP-115, Conduct of Operations . Specifically, the licensee failed to ensure that control room operators knew the status of equipment at all times. While interviewing the person responsible for tracking plant deficiencies, the inspectors discovered that the licensee had two separate governing procedures. These two instructions had different definitions for categories of plant deficiencies and different databases for tracking them. The inspectors then interviewed the on-shift operators in the control room and reviewed both databases. The inspectors identified several issues, including lack of knowledge by the control room operators about which procedure to use, failure to track deficiencies in both databases, and inadequate classification of deficiencies. The inspectors determined that in March 2010, the licensee changed their process for tracking deficiencies to be consistent with their fleet reporting process. However, the licensee did not revise the procedure and did not train all affected personnel on the new process. As a result, control room operators did not have a complete and accurate knowledge of all plant deficiencies. This finding was entered into the licensees corrective action program as Condition Report CR-WF3-2012- 03732. The failure to ensure that operators were aware of the status of all plant equipment was a performance deficiency. The performance deficiency was more than minor because it was associated with the procedure quality attribute of the Initiating Events Cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the licensee failed to implement a procedure designed to ensure operators were aware of deficiencies in the instrumentation, controls, and operation of nuclear plant systems. In accordance with NRC Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, the issue was determined to affect the Initiating Events Cornerstone. In accordance with NRC Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings at Power, the issue was determined to have very low safety significance (Green) because it did not cause a reactor trip and did not cause the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. This finding had a cross-cutting aspect in the human performance area, work practices component, in that the licensee failed to define and effectively communicate expectations regarding procedural compliance, and personnel did not follow procedures |
| 05000382/FIN-2012008-05 | 2012Q3 | Waterford | Failure to Develop Effective Corrective Actions to Preclude Repetition | The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions, because the licensee failed to determine the cause of a significant condition adverse to quality and take - 4 - Enclosure 2 corrective actions to preclude repetition. Specifically, the licensee failed to assure that the cause of the condition was determined and corrective action taken to preclude repetition related to a contractors non-compliance with site procedural requirements. The corrective actions include developing additional training and provisions to provide additional contractor oversight. This finding was entered into the licensees corrective action program as Condition Reports CR-WF3-2012-03769 and CR-WF3-2012-03772. The failure to determine the cause of a significant condition adverse to quality and take corrective action to preclude repetition was a performance deficiency. The performance deficiency was more than minor because if left uncorrected, it could lead to more significant consequences; therefore, it is a finding. Specifically, failure to determine the cause of a significant condition adverse to quality and take corrective action to prevent recurrence can result in recurrence of the condition. In accordance with NRC Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, the issue was determined to affect the Initiating Events Cornerstone. In accordance with NRC Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings at Power, the issue was determined to have very low safety significance (Green) because the finding did not cause a reactor trip and the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. This finding had a cross-cutting aspect in the human performance, work practice component, in that the licensee failed to follow guidance in the root cause evaluation procedure when developing appropriate corrective actions to prevent repetition |
| 05000382/FIN-2012008-06 | 2012Q3 | Waterford | Licensee-Identified Violation | Title 10 of the Code of Federal Regulations Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, states, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings and shall be accomplished in accordance with these instructions, procedures, or drawings. Contrary to this requirement, on May 10 and May 12, 2011, the licensee failed to accomplish an activity affecting quality as prescribed by the documented procedure. Specifically, the licensee failed to perform operability reviews when heat trace circuit 1-8C fell below the operating instruction temperature on the steam supply piping to the emergency feedwater pump in accordance with Procedure EN-OP-104, Operability Determination Process. The team determined that this finding was of very low safety significance (Green) because it affected the design or qualification of a mitigating system structure component; however, the system structure component maintained its operability. The emergency feed water pump AB was declared inoperable on May 14, 2011; however, subsequent evaluation declared the pump operable but degraded. This was documented in the licensees corrective action program as Condition Reports CR-WF3-2011-03599 and CR-WF3-2011-03600. |
| 05000483/FIN-2012008-01 | 2012Q3 | Callaway | Failure to identify and correct the failure mode of an essential service water pump | The team reviewed a Green self-revealing non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to promptly identify and correct a condition adverse to quality. During troubleshooting, the licensee incorrectly identified a failed circuit card as the cause of an essential service water pump room fan damper failure. The licensee returned the damper to service and declared the associated pump operable without identifying the actual failurepinched wires introduced during previous maintenance. This resulted in a subsequent failure. The failure to identify that pinched wires had caused the damper failure and to correct the condition before replacing the circuit card and declaring the system operable was a performance deficiency. This performance deficiency was more than minor because it adversely affected the equipment performance attribute of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609.04, Phase 1 Initial Screening and Characterization of Findings, the team determined the finding to be of very low safety significance (Green) because it did not result in the loss of the safety function of any system or train and did not screen as potentially risk significant due to seismic, flooding, or severe weather initiating events. This finding had a cross-cutting aspect in the decision-making component of the human performance cross-cutting area because the licensee failed to conduct an effectiveness review of safety-significant decisions to verify the validity of the underlying assumptions or identify possible unintended consequences. |
| 05000483/FIN-2012008-02 | 2012Q3 | Callaway | Failure to provide adequate maintenance instructions | The team reviewed a non-cited violation of Technical Specification 5.4.1.a, Procedures, for the licensees failure to provide maintenance instructions appropriate for repair of the Train B emergency diesel generator supply fan. These inadequate instructions resulted in maintenance technicians routing and restraining electrical cables inappropriately during maintenance in July 2006. These cables later came loose and, in August 2011, caused a failure of the Train B emergency diesel generator supply fan to start on demand. The failure to provide maintenance procedures appropriate to the circumstance was a performance deficiency. This finding was more than minor because it affected the equipment performance attribute of the Mitigating Systems Cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609.04, Phase 1 Initial Screening and Characterization of Findings, the team determined that the finding was of very low safety significance (Green) because it did not result in the loss of the safety function of any system or train and did not screen as potentially risk significant due to seismic, flooding, or severe weather initiating events. The team determined that this performance deficiency was not indicative of current plant performance because it was the result of repair instructions written and implemented in 2006. Therefore, no cross-cutting aspect was assigned. |
| 05000483/FIN-2012008-03 | 2012Q3 | Callaway | Failure to initiate a corrective action document | The team identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure, upon discovery of an adverse condition, to initiate a Callaway Action Request, to notify the shift manager, and to review the condition for, operability, functionality, and reportability in accordance with APA-ZZ-00500, Corrective Action Program, revision 54. During planned testing of tornado dampers for the emergency diesel generator rooms, the as found breakaway torque for the dampers was high out-of-specification. The licensee failed to document this adverse condition in its corrective action program to evaluate it for significance and to determine whether the operability of the emergency diesel generator was adversely affected. The failure to satisfy the guidance in APA-ZZ-00500 upon identification of high out-of specification torque measurements on safety-related tornado dampers by initiating a Callaway Action Request, informing the shift manager, and evaluating the condition for operability, functionality, and reportability was a performance deficiency. This performance deficiency was more than minor because if left uncorrected, the licensees continued failure to conform to APA-ZZ-00500 upon discovery of an adverse condition impacting the EDG tornado protection system had the potential to lead to a more significant safety concern. Using Inspection Manual Chapter 0609.04, Phase 1 Initial Screening and Characterization of Findings, the team determined that the finding was of very low safety significance (Green) because it did not result in the loss of the safety function of any system or train and did not screen as potentially risk significant due to seismic, flooding, or severe weather initiating events. This finding had a cross-cutting aspect in the corrective action program component of the problem identification and resolution cross-cutting area because the licensee failed to completely, accurately, and in a timely manner identify and fully evaluate an issue potentially impacting nuclear safety. |
| 05000483/FIN-2012008-04 | 2012Q3 | Callaway | Failure to fully implement fluid leak management program | The team identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to fully implement the requirements of its fluid leak management procedure. The team identified two instances where the licensee had not hung a fluid leak management tag on an active fluid leak and several examples of fluid leak management tags not indicating whether individual leaks were monitored. Further, the team found no evidence that leakage indications were actively monitored and trended, as required by procedure both before and after repairs were made. The licensee had previously determined that the extent of condition of weaknesses in its boric acid corrosion control program included the fluid leak management program. However, corrective actions only addressed the boric acid corrosion control program. The licensees failure to implement the requirements of its fluid leak management procedure was a performance deficiency. The team determined that the performance deficiency was more than minor because if left uncorrected, it had the potential to become a more significant safety concern. Specifically, if the licensee continued to fail to implement its fluid leak management procedure, leaks that adversely affect safety related equipment could go unmonitored, resulting in equipment degradation. Using Inspection Manual Chapter 0609.04, Phase 1 Initial Screening and Characterization of Findings, the team determined the finding to be of very low safety significance (Green) because it did not result in the loss of the safety function of any system or train and did not screen as potentially risk significant due to seismic, flooding, or severe weather initiating events. The team determined that the finding had a cross-cutting aspect in the corrective action program component of the problem identification and resolution crosscutting area because the licensee failed to fully evaluate a problem such that the resolution addressed the causes and extent of condition. |
| 05000382/FIN-2012008-01 | 2012Q3 | Waterford | Failure to Promptly Determine the Operability of the Emergency Diesel Generators | The team identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for a failure to follow the Operability Determination Process. Specifically, the licensee failed to determine the operability of the emergency diesel generators immediately upon discovery without delay and in a controlled manner using the best information available in response to NRC Information Notice 2010-04. The licensee completed an evaluation of the information notice that indicated that Waterford 3 was vulnerable and susceptible to the issue, but the licensee failed to issue a condition report as required by their procedure. The failure to initiate a condition report resulted in the licensees failure to perform an operability determination of the emergency diesel generators as required by, EN-OP-104, Operability Determination Process, Revision 6. In the evaluation, the licensee considered the fact that they had an Action Request in their system to add routine thermography inspections within the voltage regulator cabinets to their preventative maintenance program as being adequate. The action request was not completed when the inspection team reviewed the issue. The inspectors questioned whether there was an operability concern for the emergency diesel generators. The licensee recognized their failure to perform an operability determination. They performed a prompt operability determination based on no observed degradation in performance and declared the emergency diesel generators operable. In addition, they plan to conduct the thermography inspections during the next scheduled emergency diesel generator surveillance. This finding was entered into the licensees corrective action program as Condition Report CR-WF3-2012-03761. The failure to promptly perform an operability determination of the emergency diesel generators in response to NRC Information Notice 2010-04 was a performance deficiency. The performance deficiency was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to promptly determine the operability of the diesel generators after obtaining information of a potential condition adverse to quality. In accordance with NRC Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, the issue was determined to affect the Mitigating Systems Cornerstone. In accordance with NRC Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings at Power, the issue was determined to have very low safety significance (Green) because it was not a deficiency affecting the design or qualification of the system, it did not represent a loss of system or function, and it was a Technical Specification system, but did not represent an actual loss of function of a single train for greater than it allowed outage time. Specifically, the licensee performed an operability determination in response to the inspectors questions and determined the emergency diesel generators were operable based on a review of surveillance data and maintenance records. This finding had a cross-cutting aspect in the problem identification and resolution area, operating experience component, in that the licensee failed to systematically collect, evaluate, and communicate to affected internal stakeholders in a timely manner relevant internal and external operating experience |
| 05000416/FIN-2011006-04 | 2011Q4 | Grand Gulf | Inadequate Corrective Action for a Leak on the Division II Emergency Diesel Generator Lube Oil Sump | The team identified a Green cited violation of 10 CFR 50 Appendix 8, Criterion XVI, Corrective Actions, for the failure to promptly identify and correct a leak on the Division II emergency diesel generator lube oil sump. Despite identification of the leak in 2004, ineffective attempts to repair the leak and previous identification by the NRC in 2009, the licensee disposition the leak as accept as-is without a full understanding of the lube oil sump leak and potential consequences. The licensee entered this condition into their corrective action program as condition report CR-GGN-2011-8880. The condition was discovered and documented by the licensee in 2004. This finding was initially determined by the NRC to be a minor violation in 2009. Paragraph F of Section 2.10 of the NRC Enforcement Manual states in part that where a licensee does not take corrective action for a minor violation, the matter should be considered more than minor and associated with a green inspection finding and disposition in a cited or noncited violation, as appropriate. This finding is now determined to be more than minor because if left uncorrected the failure to restore the lube oil sump for the Division II emergency diesel generator to design conditions would have the potential to lead to a more significant safety concern, specifically, the leak could worsen and potentially affect operability of the emergency diesel generator. Due to the licensee\'s failure to restore compliance within a reasonable time after the violation was identified, this violation is being cited as a Notice of Violation consistent with Section 2.3.2 of the Enforcement Policy. This finding affects the mitigating systems cornerstone. Using Manual Chapter 0609.04, Phase 1 - Initial Screening and Characterization of Findings, this finding was of very low safety significance because it did not create a loss of system safety function of a single train for greater than the technical specification allowed outage times, and did not affect seismic, flooding, or severe weather initiating events. This finding has a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action program component because the licensee failed to thoroughly evaluate this problem such that the resolutions addressed the causes. |
| 05000382/FIN-2011009-01 | 2011Q3 | Waterford | Failure To Use Effective Engineering Controls As Part Of PreJob Planning To Reduce Contamination and Subsequent Exposure | The inspectors identified an apparent White finding because the licensee failed to use effective engineering controls as part of pre-job planning to reduce contamination and subsequent exposure. The primary reason for the dose overage was the licensee\\\'s failure to prevent radioactive water from leaking into work areas and raising radiation dose rates. As corrective action, the licensee installed a trough system to collect and route the radioactive water away from the work area and to the reactor containment floor drain system. This issue was placed in the corrective action program as Condition Report CR-WF3-2011-05672. The failure to use effective engineering controls as part of pre-job planning to reduce contamination and subsequent exposure is a performance deficiency. The finding is more than minor because it was similar to (the more than minor) Example 6.i in Inspection Manual Chapter 0612, Appendix E, Example of Minor Issues, in that the actual collective dose exceeded 5 person-rem and exceeded the planned, intended dose by more than 50 percent. Additionally, the finding is associated with the program and process attribute of the Occupational Radiation Safety cornerstone and affected the cornerstone objective in that it increased collective radiation dose. The inspectors used Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, to analyze the significance of the finding. The finding was preliminarily determined to be White (low to moderate safety significance) because it involved ALARA planning or work controls; the average collective dose at the time the finding was identified was greater than 135 person-rem; and the actual dose associated with a work activity was greater than 25 person-rem. Alternately, there were greater than four occurrences in which the actual collective dose exceeded 5 person-rem and the estimated/planned dose by more than 50 percent. The finai significance of this finding is to be determined. The finding had a crosscutting aspect in the area of problem identification and resolution, associated with the operating experience component, because the iicensee did not institutionalize operating experience concerning the effects of reactor coolant pump leakage on work area dose rates. |
| 05000361/FIN-2011002-03 | 2011Q1 | San Onofre | Failure to Comply with Technical Specifications | The inspectors identified a noncited violation of Technical Specification 3.5.4, Refueling Water Storage Tank, for the failure of licensee personnel to comply with the technical specification. Specifically, the licensee did not enter the appropriate technical specification for an inoperable refueling water storage tank when it was potentially not capable of performing its specified safety function while aligned to the non-seismic spent fuel pool cooling and purification system for cleanup. On October 8, 2010, operations personnel placed administrative controls on system isolation valves to prevent the refueling water storage tank from being aligned to non-seismic systems. This issue was entered into the licensees corrective action program as Nuclear Notifications NN 201133936 and NN 201135761. The performance deficiency was determined to be more than minor and is therefore a finding because it is associated with the design control attribute of the Mitigating Systems Cornerstone and affects the associated cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using the NRC Inspection Manual 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings, the inspectors determined that a Phase 2 evaluation was required because the finding involved the potential loss of a safety function. A Phase 2 significance determination was performed using the pre-solved worksheet from the Risk Informed Inspection Notebook for the San Onofre Nuclear Generating Station, Revision 2.01a. Assuming both trains of high pressure injection were inoperable, the finding was Yellow, which warranted further review. Therefore, the analyst performed a bounding Phase 3 significance determination. Based on the licensees PRA calculation, consultation with licensee PRA personnel, and an understanding of the bounding and conservative assumptions incorporated in the analysis, the analyst determined that the licensees delta-CDF result of 7.6E-7/yr was clearly bounding, that the large early release frequency was negligible, and that the significance of the issue was very low. Since the apparent root cause determined the cause was due to weaknesses in the design change processes early in plant operations (between 1982 and 1995), and the licensees program has improved with respect to performing design changes, the inspectors determined that this finding was not reflective of current performance and therefore did not have a crosscutting aspect |
| 05000361/FIN-2011002-02 | 2011Q1 | San Onofre | Failure to Follow Procedures to Establish Compensatory Measures | The Inspectors identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion V, Instruction, Procedures, and Drawing, for the failure of operations personnel to follow the operability determination procedure and establish compensatory measures associated with an emergency diesel generator. Specifically, on February 23, 2011, operations personnel failed to establish temporary procedures as compensatory measures associated with an emergency diesel generator when an immersion heater was removed from service. On March 18, interim corrective actions were taken that included operator required reading (priority 2 reading) to ensure that on-shift licensed operators use conservative decision making regarding compensatory measures. Planned corrective actions will be part of a root cause evaluation. These issues have been entered into the licensees corrective action program as Nuclear Notifications NNs 201365616, 201348283 and 201378245. The performance deficiency was more than minor and is therefore a finding because it was associated with the Mitigating Systems Cornerstone attribute of procedure quality and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using the NRC Manual Chapter 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, the finding is determined to have very low safety significance because it did not result in the loss of safety function of any technical specification required equipment. The finding was determined to have a crosscutting aspect in the area of human performance associated with the decision-making component because the licensee failed to verify the validity of underlying assumptions for operability decision-making (H.1(b)) |
| 05000361/FIN-2011002-01 | 2011Q1 | San Onofre | Failure to Follow Station Procedures for Seasonal Readiness | The inspectors identified a finding for the failure of license personnel to follow procedure SO23-XX-29.1, Seasonal Readiness. Specifically, licensee personnel failed to implement, as seasonal weather conditions dictated, the appropriate preventative maintenance program for roof drains associated with the emergency diesel generator buildings. As a result of the recurring degraded and clogged roof drains, rainwater was allowed to accumulate on the roof which resulted in water intrusion into the Unit 2 building and over energized electrical equipment. A plastic tent was installed by maintenance personnel to protect the electrical equipment. Based on the inspectors concerns, licensee personnel completed a walk down of the other emergency diesel building to identify whether similar rainwater intrusion was occurring. Maintenance personnel corrected the condition by removing debris which had clogged the Unit 2 roof drains. This issue was entered into the licensees corrective action program as Nuclear Notifications NN 201393414 and NN 201174566. The performance deficiency was more than minor and is therefore a finding because it was associated with the protection against external events attribute of the Mitigating Systems cornerstone and affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using the NRC Manual Chapter 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, the finding was determined to have very low safety significance because it did not represent a loss of system safety function, nor actual loss of safety function of a single train, and it did not screen as potentially risk significant due to flooding or severe weather because the potentially degraded equipment was not specifically designed to mitigate flooding or severe weather nor would it contribute to external event initiated accident sequences. The finding was determined to have a crosscutting aspect in the area of human performance associated with the component of work control because the licensee did not plan and coordinate work activities consistent with nuclear safety. Specifically, the licensee did not plan or implement preventative maintenance for roof drains to support long-term equipment reliability by limiting reliance on manual actions, such as plastic tents to protect plant equipment during the rain events. Maintenance scheduling was more reactive than preventative (H.3(b))( |
| 05000482/FIN-2010006-08 | 2010Q3 | Wolf Creek | Notice of Unusual Event Due to Loss of Both Emergency Diesel Generators | The inspectors reviewed a self-revealing noncited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for failure to identify a degraded equipment condition in December 2006. As a result, the emergency diesel generator system experienced a failure on October 22, 2009, which caused the plant to make a notice of unusual event emergency declaration. Licensee personnel missed an opportunity to identify the condition because they did not thoroughly evaluate a surveillance failure and post-mortem testing data available in December 2006. The finding is more than minor because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone, and it 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, the issue is determined to have very low safety significance because the finding is not a design or qualification issue confirmed not to result in a loss of operability or functionality; did not represent an actual loss of safety function of the system or train; did not result in the loss of one or more trains of nontechnical specification equipment; and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. A crosscutting aspect was identified in the problem identification and resolution in that the licensee did not thoroughly evaluate problems such that the resolution addressed causes (P.1(c)) |
| 05000482/FIN-2010006-01 | 2010Q3 | Wolf Creek | Failure to Resolve Degraded Conditions in a Timely Manner | The inspectors identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to promptly correct degraded or nonconforming conditions in that the conditions were not corrected at the first available opportunity or appropriately justify a longer completion schedule. Some examples of affected degraded or nonconforming conditions included degraded atmospheric relief valve discharge line silencer, essential service water system water hammer events and internal corrosion, and 23 items on the Operability Evaluation Database that had not been corrected prior to the start of the last refuel outage. As corrective actions for this issue, the licensee implemented interim procedural guidance and initiated Condition Report 27071 to evaluate the adequacy of tracking methods used for degraded, nonconforming, or unanalyzed conditions. In addition, the licensee initiated a review of work requests, condition reports, and other items for degraded, nonconforming, or unanalyzed conditions and is assessing the justification for delayed implementation of these corrective actions. This issue was more than minor because it affected the equipment performance attribute of the Mitigating Systems Cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, the issue is determined to have very low safety significance because the finding is not a design or qualification issue confirmed not to result in a loss of operability or functionality; did not represent an actual loss of safety function of the system or train; did not result in the loss of one or more trains of nontechnical specification equipment; and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The inspectors determined that the finding has a crosscutting aspect in the area of human performance associated with the component of resources because the licensee failed to provide adequate procedures to assure timely resolution of degraded or nonconforming conditions (H.2(c)). |
| 05000482/FIN-2010006-02 | 2010Q3 | Wolf Creek | Unqualified Scaffolding Erected Near Safety-Related Equipment | The inspectors identified a noncited violation of Technical Specification 5.4.1.a for failure to properly implement Procedure AP 14A-003, Scaffold Construction and Use, Revision 17, when scaffolding was erected near operable safety-related equipment. On July 14, 15, and 28, the inspectors identified a total of four instances where the minimum separation distance between scaffolding and safety-related components was less than the minimum allowed by procedure and an approved engineering evaluation to justify the deviation was not performed. The licensee entered the issue into its corrective action program as Condition Reports 26752 and 27010, corrected each scaffolding deficiency, and performed comprehensive walkdowns of all scaffolding around safety-related structures, systems, and components. The deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. The finding was associated with the Mitigating Systems Cornerstone. Using Inspection Manual Chapter 0609, the issue is determined to have very low safety significance because the finding is not a design or qualification issue confirmed not to result in a loss of operability or functionality; did not represent an actual loss of safety function of the system or train; did not result in the loss of one or more trains of nontechnical specification equipment; and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The inspectors determined the finding has a crosscutting aspect in the area of problem identification and resolution associated with corrective action program because the licensee did not take appropriate corrective actions to address previously identified scaffolding construction issues in a timely manner (P.1(d)). |
| 05000482/FIN-2010006-03 | 2010Q3 | Wolf Creek | Failure to Adequately Monitor Control Room Deficiencies | The inspectors identified a finding for the failure to follow Procedure AI 22A-001, Operator Work Arounds/Burdens/Control Room Deficiencies, Revision 8, to adequately identify, document, and track control room deficiencies associated with instruments and controls to ensure proper prioritization and timely corrective actions. Specifically, inspectors observed that the licensee had approximately 52 WR (work request) buttons on the control boards indicating that work requests had been initiated to correct problems on instruments and controls. However, not all deficiencies were logged, and some of the deficiencies had existed for years without correction or justification. The licensee initiated Condition Report 27034 to document and evaluate this concern. The deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern, in that, the deficient condition could cause an operator to take an inappropriate action based on expected plant response or conversely cause an operator not to take action when action is required. The finding is associated with the Mitigating Systems Cornerstone. The senior reactor analyst determined that this finding was not appropriate to be evaluated using the significance determination process since this finding was associated with numerous equipment issues and associated human performance aspects that might impact equipment operation. Using Inspection Manual Chapter 0609, Appendix M, Significance Determination Process Using Qualitative Criteria, the finding is determined to have very low safety significance because there was no adverse impact to plant equipment. The inspectors determined that the cause of the finding has a crosscutting aspect in the area of problem identification and resolution associated with the component of corrective action program because the licensee did not identify issues completely, accurately, and in a timely manner commensurate with their safety significance (P.1(a)) |
| 05000482/FIN-2010006-04 | 2010Q3 | Wolf Creek | Failure to Update an Operability Evaluation | The inspectors identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, for the failure to implement Procedure AP 26C-004, Technical Specification Operability, Revision 20, to adequately evaluate the operability of a degraded essential service water system. Specifically, operations and engineering personnel failed to adequately evaluate the operability of the essential service water system when relevant new information was identified that challenged a previously performed operability determination and which challenged the reasonable expectation for operability. Condition Report 27288 was initiated to evaluate the failure to perform adequate operability determinations. The issue was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. The finding is associated with the Mitigating Systems Cornerstone. Using Inspection Manual Chapter 0609, the issue is determined to have very low safety significance because the finding is not a design or qualification issue confirmed not to result in a loss of operability or functionality; did not represent an actual loss of safety function of the system or train; did not result in the loss of one or more trains of nontechnical specification equipment; and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The inspectors determined that the cause of the finding has a crosscutting aspect in the area of human performance associated with resources because the licensee failed to provide complete, accurate, and up-to-date procedures for performing operability evaluations (H.2(c)) |
| 05000482/FIN-2010006-05 | 2010Q3 | Wolf Creek | Failure to Perform Adequate Evaluation for Significant Conditions | The inspectors identified a cited violation 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, because the licensee failed to perform an adequate evaluation to determine the cause of loss of offsite power induced water hammers and internal corrosion in the essential service water system and did not take corrective actions to preclude repetition of additional water hammer events and system leaks. Specifically, the licensee performed an apparent cause evaluation instead of a root cause evaluation as required, and the licensees evaluation did not consider metallurgical evaluations that were performed outside the corrective action program. The inspectors found that the licensee had not corrected a previous NCV 05000482/2009007-03, Failure to Correctly Screen ESW Piping Leaks for Significance, which resulted in the licensee failing to perform a root cause evaluation. Because the licensee failed to restore compliance within a reasonable time after NCV 05000482/2009007-03 was identified, this violation is being cited in a Notice of Violation in accordance with Section VI.A.1 of the NRCs Enforcement Policy. The licensees corrective action to this cited violation was to initiate Condition Reports 27212, 26466, and 27075, to evaluate and correct the identified conditions, to start a root cause evaluation and, separately, to evaluate the licensees failure to properly respond to NCV 05000482/2009007-03. The issue was more than minor because it is associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affects the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and is therefore a finding. Using Inspection Manual Chapter 0609, the issue is determined to have very low safety significance because the finding is not a design or qualification issue confirmed not to result in a loss of operability or functionality; did not represent an actual loss of safety function of the system or train; did not result in the loss of one or more trains of nontechnical specification equipment; and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The inspectors determined that the cause of the finding has a crosscutting aspect in the area of problem identification and resolution associated with the component of corrective action program because the licensee failed to thoroughly evaluate problems such that the resolutions address causes and extent of conditions (P.1(c)) |
| 05000482/FIN-2010006-07 | 2010Q3 | Wolf Creek | Failure to Determine if a Deficiency Existed in the Ultimate Heat Sink | The team identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the failure to follow the requirements of Procedure AP 26C-004, Technical Specification Operability, Revision 20. Specifically, Wolf Creek Generating Station failed to confirm if a deficiency existed with the ability of the ultimate heat sink to perform its safety function after delaying the 5-year scheduled dredging of the channel. The licensee initiated Condition Report 27080 and performed an operability determination to evaluate the deficiency. The issue was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone, and it 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, the issue is determined to have very low safety significance because the finding is not a design or qualification issue confirmed not to result in a loss of operability or functionality; did not represent an actual loss of safety function of the system or train; did not result in the loss of one or more trains of nontechnical specification equipment; and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. This finding has a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program component because licensee personnel failed to identify a potential deficiency in the ultimate heat sink in a timely manner (P.1(a)) |
| 05000482/FIN-2010006-09 | 2010Q3 | Wolf Creek | Failure to Translate Design Information into a Procedure | The inspectors identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the failure to translate criteria from the atmospheric relief valve accumulator leakage calculation into proceduralized leakage criteria. Specifically, engineering personnel did not translate the calculated design basis leakage criteria and the required minimum pressure to start the test into the procedure. The licensee entered this in to the corrective action program as Condition Report 26771, and the licensee was developing plans to revise the leakage criteria in the procedure. This issue was more than minor because it affected the design control attribute of the Mitigating Systems Cornerstone and affected the objective to ensure the reliability and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, the issue is determined to have very low safety significance because the finding is not a design or qualification issue confirmed not to result in a loss of operability or functionality; did not represent an actual loss of safety function of the system or train; did not result in the loss of one or more trains of nontechnical specification equipment; and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. This finding has a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program component because licensee personnel failed to take appropriate corrective actions to previously identified problems (P.1(d)) |
| 05000382/FIN-2009009-03 | 2009Q3 | Waterford | Failure to Have an Operating Procedure for Executing an Evolution Credited in the UFSAR and in a Request for a License Amendment | The team identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings pertaining to the emergency diesel generator fuel oil transfer pump. Criterion V states, in part, activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Specifically, the licensee did not have operating procedures for accomplishing the transfer of fuel oil from one storage tank to the opposite train feed tank (day tank) using the opposite train fuel oil transfer pump, as designated in the USAR Table 9.5-2, Failure Mode and Effects Analysis. Also, License Amendment Number 157 (TAC Number MA4940) was granted, in part, for having the capability to transfer fuel oil from one storage tank to the opposite train feed tank using the opposite transfer pump. The licensee specified this capability as part of the justification for having an insufficiently sized fuel oil storage tank. Moreover, the Safety Evaluation Report associated with License Amendment Number 157 specifically referred to this capability at Waterford 3, and specified that procedures were available for accomplishing the transfer of fuel oil. The licensee has entered this finding in their corrective action program as Condition Report CR-WF3-2009-04950, and performed an operability assessment for the issue. This finding is more than minor because it affected the mitigating systems cornerstone attribute of equipment performance to ensure the availability, reliability and capability of safety systems that respond to initiatinq events. Also, using Inspection Manual Chapter 0612, Power Reactor Inspection Reports, Appendix B, Section 1-3, Screen for More than Minor - ROP, question 2, the finding is more than minor because if left uncorrected, the performance deficiency would have the potential to lead to a more significant safety concern. Using Inspection Manual Chapter 0609, Significance Determination Process, Attachment 4, the finding was determined to have very low safety significance (Green) because the failure to have an operating procedure did not result in loss of function, did not represent an actual loss of a system safety function, did not result in exceeding a technical specification allowed outage time, and did not affect external event mitigation. This finding was reviewed for crosscutting aspects and none were identifie |
| 05000382/FIN-2009009-07 | 2009Q3 | Waterford | Failure to Verify or Check the Adequacy of Design Changes for the Emergency Diesel Generator Protective Relay IGCV-51V | The team identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control. The calculation EE2-14-3 Diesel Generator Overcurrent Protection, Revision 1, does not document sufficient design bases for the setting of the IGCV-51 overcurrent with voltage control relays for the emergency diesel generators. Specifically, the licensee failed to perform an adequate evaluation of new setpoint values identified in Engineering Report ER-W3-99-0174-00-00, which provided the bases for relay tap setpoint changes for emergency diesel generator overcurrent protection while the diesel was in test mode. The primary purpose of the IGCV-51V relays was to protect the emergency diesel generator against external faults and prevent the output breaker from closing foilowing a breaker trip associated with a fault. If the faulted bus had been isolated by the operation of the under-voltage relays instead of the IGCV-51 relays, the emergency diesel generator output breaker would be allowed to electrically reclose onto this faulted bus and potentially damage the emergency diesel generator and the associated switchgear. The issue has been entered into the licensee\'s corrective action program as Condition Report CR-WF3-2009-04780. The failure to have sufficient design bases for the emergency diesel generator overcurrent protection IGCV-51V relays without an adequate verification of the setpoint modification for the IGCV-51V relay, Voltage Controlled, Time-Overcurrent Relay, for emergency diesel generator overcurrent protection while the diesel was in test mode, was a performance deficiency. Specifically, failure to verify the adequacy of a design modification for the IGCV-51V relay could result in reduced reliability of the emergency diesel generators. The finding was determined to be greater than minor because it affected the mitigating systems cornerstone attribute of design control to ensure the availability, reliability, and capability of safety systems that respond to initiating events to prevent undesirable consequences. Using Manual Chapter 0609.04, the finding was determined to have a very low safety significance (Green) because the failure did not result in loss of operability or functionality and because the finding did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. This finding was reviewed for crosscutting aspects and none were identifie |
| 05000382/FIN-2009009-06 | 2009Q3 | Waterford | Failure to Incorporate START-UP Transformer Protective Relay Design Bases Into Instructions, Procedures or Drawings | The team identified a finding for failure to translate design basis criteria into a design basis document for the start-up transformer \'3A\' 51 G relay to support the settings listed in Calculation EC-E90-012, Protective Relays Settings for Main Generator and Transformers, Revision 1. Without the design basis criteria for the 51 G relay, the setpoint values could not be established. Specifically, the team determined that the relay settings listed in Calculation EC-E90-012 had not been effectively implemented since the required current transformer ratio of 600/5, upon which the settings were based, was never installed. The issue has been entered into the licensee\'s corrective action program as Condition Report CR-WF3-2009-04813. This finding was more than minor because the failure to provide adequate relay setting coordination could result in an unnecessary separation of the safety buses from the electrical grid and an ensuing plant transient (initiating event). The team noted that this finding also applies to 51 G relay in the \'B\' train which could challenge the single failure criterion. The team determined this finding was of very low safety significance (Green) because the issue would not prevent the safety buses from being reenergized by the emergency diesel generators. Enforcement action does not apply because the performance deficiency did not involve a violation of a regulatory\' requirement. This finding was reviewed for crosscutting aspects and none were identifie |
| 05000382/FIN-2009009-04 | 2009Q3 | Waterford | Failure to Properly Analyze the Affect of Acceptable Reverse Flow Through the Emergency Feedwater Check Valves | The team identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control. Specifically, the licensee failed to analyze the effects of the acceptable back leakage of 25 gpm from the emergency feedwater pump discharge check valves on the integrity of the emergency feedwater pumps and the integrity of its suction piping. The acceptable back leakage could possibly cause the pump to reverse rotate, and provide a path for high pressure fluid to go through the pump and pressurize low pressure suction piping. The licensee has entered this item in their corrective action program as Condition Report CR-WF3-2009-04528 and performed an operability assessment for this issue. This finding is more than minor because it affected the mitigating systems cornerstone attribute of design control to ensure the availability, reliability, and capability of safety systems that respond to initiating events. This finding closely parallels Inspection Manual Chapter 0612, Appendix E, Example 3.j, Not Minor: If the engineering calculation error results in a condition where there is now a reasonable doubt on the operability of a system or component, or if significant programmatic deficiencies were identified with the issue that could lead to worse errors if uncorrected. This finding was determined to be of very low safety significance (Green) because this design issue did not result in loss of function, did not represent an actual loss of a system safety function, did not result in exceeding the Technical Specification allowed outage time, and did not affect external event mitigation. The inspectors determined that the finding has a crosscutting aspect in the area of Problem Identification and Resolution, Self and Independent Assessment. The licensee conducted a Waterford 3 Component Design Basis Assessment, on April 20-23, 2009, that included the emergency feedwater AB turbine-driven pump in the Scope of Components to be Reviewed During CDBI Assessment, and failed to identify the impact of reverse flow on the integrity of the pump and its suction piping (P.3.(a) |
| 05000528/FIN-2009008-04 | 2009Q3 | Palo Verde | Inadequate Corrective Actions for Vaults Containing SBO Cables | The team identified a noncited violation of very low safety significance for failure to effectively implement the corrective action requirements of Regulatory Guide 1.155, Station Blackout, Appendix A, Criterion 8, Corrective Action, which were adopted by the licensee in order to meet 10 CFR 50.63, Loss of All Alternating Current. Although the licensee started a vault monitoring program for water intrusion in vaults with electrical cables in 2003, the effort to prevent exposure of medium voltage cables to submerged conditions has been ineffective for certain vaults that contain the 15Kv station blackout generator output cables. Additionally, there are 27 splices in these cables which have contributed to cable test failures in previous meggar resistance tests that, in some cases, required splice replacement in order to pass resistance tests. The licensee entered this issue into their corrective action program as Palo Verde Action Requests 3350712, 3350713, 3350939, and 3352858. This finding is more than minor because it is associated with the design control and equipment performance attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The risk significance of this finding was determined using Inspection Manual Chapter 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings. The finding is of very low safety significance (Green) since the finding did not result in a loss of operability, a loss of system safety function, an actual loss of safety function of a single train for greater than its technical specification allowed outage time, or an actual loss of safety function for greater than 24 hours and the finding did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The finding was reviewed for crosscutting aspects and none were identified |
| 05000528/FIN-2009008-03 | 2009Q3 | Palo Verde | Failure to Incorporate Vendor Information for Reactor Trip Breakers | The team identified a Green noncited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, with programmatic implications for the licensee\'s failure to follow site procedures and incorporate updated vendor information for the reactor trip breakers. Specifically, the licensee failed to incorporate an updated revision of the maintenance program manual and at least two technical bulletins from the reactor trip breaker vendor. The licensee entered this issue into their corrective action program as Palo Verde Action Requests 3354252 and 3355082. This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The risk significance of this finding was determined using Inspection Manual Chapter 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings. The finding is of very low safety significance (Green) since the finding did not result in a loss of operability, a loss of system safety function, an actual loss of safety function of a single train for greater than its technical specification allowed outage time , or an actual loss of safety function for greater than 24 hours and the finding did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. This finding has a crosscutting aspect in the area of problem identification and resolution associated with operating experience since the licensee failed to implement changes to station processes, procedures, equipment, and training programs (P.2(a) |
| 05000416/FIN-2009004-03 | 2009Q3 | Grand Gulf | Licensee-Identified Violation | Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, states, in part, that activities affecting quality shall be prescribed by documented procedures and shall be accomplished in accordance with those procedures. Contrary to this, no documented procedures were in place to ensure the operability of safety related ventilation systems that provides cooling for the standby service water pumphouses. On January 15, 2009, it was determined by the engineering staff that the ventilation flow rates for the safety related standby service water pump rooms were significantly degraded to almost half of normal flow rate for cooling and higher than normal flow rate for recirculation flow that is required during colder weather. The site determined that on August 20, 2009, the reason for the degraded flow was due to the ventilation screens being severely clogged and several dampers being broken in the open direction. It was determined by system engineering that no procedures or preventive maintenance schedules were in place to inspect, clean and restore degraded conditions in the ventilation system for the standby service water pump houses. This issue was documented in the licensees corrective action program as condition reportCR-GGN-2009-00199. This finding is of very low safety significance because although the ventilation flow rates were degraded operability of the standby service water pumps were maintained such that they could perform their safety function for their required mission time. |
| 05000416/FIN-2009004-04 | 2009Q3 | Grand Gulf | Licensee-Identified Violation | Title of 10 CFR Part 50 Appendix B, Criterion V, Instructions, Procedures and Drawings, states, in part, that activities affecting quality shall be prescribed by documented instructions and shall be accomplished in accordance with those instructions. Section 5.4(2) of Procedure EN-OP-104, Operability Determinations, Revision 3, required operability evaluations to provide a technical basis for each item in the detailed problem statements per Step 5 of Attachment 9.5 of the procedure. Contrary to the above, on August 21, 2009 plant engineers failed to provide a technical basis for the operability determination they performed by not considering external events such as earthquakes, high winds and tornados when determining operability of the standby services ventilation system which was in a degraded condition. Operations accepted the initial operability provided by engineering but the subsequent shift manager required the design engineering to perform new evaluation taking into account external events. The new operability determination was performed and determined that the standby service water system remained operable. This issue was documented in the licensees corrective action program as condition report CR-GGN-2009-04302. This finding was of very low safety significance since it did not result in a loss of operability of the standby service water system. |
| 05000416/FIN-2009004-05 | 2009Q3 | Grand Gulf | Licensee-Identified Violation | Title 10 of CFR Part 50, Appendix B, Criterion V, _Instructions, Procedures and Drawings,_ states, in part, that activities affecting quality shall be prescribed by documented procedures and shall be accomplished in accordance with those procedures. On September 16, 2009, plant operations management failed to implement section 6.1.1 of Procedure 02-1-S-17, Control of Limiting Conditions for Operation. The procedure states that the shift supervisor will initiate limiting conditions for operation whenever plant conditions warrant. Contrary to this, a limiting condition for operation was not entered prior to removing the inspection hatches on the standby gas treatment system. The reason for not entering the limiting conditions for operation action statement was due to maintenance supervisor assuming that worked started on September 14, 2009, that required entry into the limiting conditions for operation action statement, which operations entered that day, was never exited by operations when work was completed on September 14, 2009. Therefore, when work was recommenced on September 16, 2009, the maintenance department personnel never informed the control room. The maintenance personnel also failed to follow Procedure EN-AD-102, Procedure Adherence and Level of Use, Revision 5, Step 5.2.5 (3) that requires personnel to verify all prerequisites are still satisfied after stopping work for greater than shift. This issue was documented in the licensees corrective action program as condition report CR-GGN-2009-04754. This finding is of very low safety significance because it did not represent a degradation of the radiological barrier function provided for the control room, it did not represent a degradation of the barrier function of the control room against smoke or a toxic atmosphere, it did not represent an open pathway in containment, and did not impact the hydrogen igniters in containment. |