Semantic search
Jump to navigation
Jump to search
| Quarter | Site | Title | Description | |
|---|---|---|---|---|
| 05000445/FIN-2018003-01 | 2018Q3 | Comanche Peak | Failure to Maintain the Ability to Withstand a Station Blackout | The inspectors identified a Green, non-cited violation of 10 CFR Part 50.63 for the licensees failure to maintain the ability to withstand and recover from a station blackout. Specifically, the licensees approved coping analysis for each unit required the availability of equipment on the non-blacked-out unit, and the licensee failed to maintain the required equipment available.The licensee entered this violation into their corrective action program as condition report CR-2017-011090. |
| 05000445/FIN-2018003-02 | 2018Q3 | Comanche Peak | Failure to Establish Adequate Procedural Guidance for Processing Technical Changes Performed by A Vendor on Installed Plant Equipment | The inspectors identified a Green, NCVof 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated with the licensees failure to establish an adequate procedure for controlling and processing vendor documents and vendor technical information. This resulted in the licensees failure to properly evaluate changes made by vendors to plant equipment. Specifically, the licensee allowed vendors to make physical changes to a component cooling water pump shaft and main steam isolation valve actuators without evaluating these changes. |
| 05000445/FIN-2018002-03 | 2018Q2 | Comanche Peak | Failure to Incorporate Design Information Into System Test Procedures | The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XI, Test Controls, for the licensees failure to ensure that the stations in-service testing program for main steam isolation valves (MSIVs) incorporated the requirements and acceptance limits contained in applicable design documents. Specifically, the licensees in-service procedures did not direct testing of the valves be performed at the minimum required pressure and this resulted in the licensees failure to identify two degraded MSIVs during in-service testing. The licensee entered this issue into the corrective action program as Condition Report CR-2018-003229. |
| 05000445/FIN-2018002-02 | 2018Q2 | Comanche Peak | Unacceptable Preconditioning of Main Steam Isolation Valves | The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XI, Test Controls, for the licensees unacceptable preconditioning of the Unit 1 main steam isolations valves (MSIV) prior to performing as-found in-service stroke time testing. Specifically, the licensee raised accumulator pressure prior to stroke time testing and this potentially masked an issue with MSIV 1-01. The licensee entered this issue into the corrective action program as Condition Report CR-2018-002405. |
| 05000445/FIN-2018002-01 | 2018Q2 | Comanche Peak | Failure to Identify and Correct a Condition Adverse to Quality | The inspectors identified a Green,non-cited violation of 10CFR 50, Appendix B, Criterion XVI, Corrective Action, associated with the licensees failure to identify and correct a condition adverse to quality associated with unacceptable main steam isolation valve (MSIV) stroke times. Specifically, during stroke time testing of MSIV 2-02 the valves stroke time was outside of the acceptance limit and the licensee failed to determine why the stroke time was out of specification and correct the issue prior to declaring the valve operable and placing it in service. The licensee entered this issue into the corrective action program as Condition Report CR-2018-002189. |
| 05000298/FIN-2018002-02 | 2018Q2 | Cooper | Failure to Maintain Adequate Work Instructions for Traversing In-Core Probe System Limit Switches | A self-revealed, Green non-cited violation of Technical Specification 5.4, Procedures, was identified when the licensee failed to maintain Procedure 14.2.14, TIP Chamber Shield Maintenance, with adequate instructions for reinstalling the traversing in-core probe system in-shield limit switches. As a result, the licensee experienced multiple failures of the shield limit switches resulting in inoperable primary containment isolation valves. |
| 05000298/FIN-2018002-01 | 2018Q2 | Cooper | Failure to Maintain Alarm Procedure for Service Water Booster Pump Ventilation Manual Actions | The inspectors identified a Green non-cited violation of Technical Specification 5.4, Procedures, when the licensee failed to maintain Procedure 2.3_R-1 with the bounding time restrictions for required manual ventilation actions identified in Engineering Evaluation NEDC 92-064, Transient Temperature Rise in SWBP Room After Loss of Cooling, Revision 3C2. As a result, the licensee relied on procedure guidance that contained an incorrect, less restrictive allowance of 13 hours for completion of manual actions rather than the bounding 5.8-hour allowance described in NEDC92-064. |
| 05000298/FIN-2018001-01 | 2018Q1 | Cooper | Licensee-Identified Violation | Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that for those systems, structures, and components to which this appendix applies, Design control measures shall provide for verifying or checking the adequacy of design.Contrary to the above, between September 2003, and December 19, 2017, the licensee failed to verify or check the adequacy of design of quality-related components associated with the Division 1 and 2 emergency diesel generator 125 Vdc control power circuits. Specifically, in 2003, the licensee modified the design of the control power circuit through Part Evaluation (PE) 4222806 and replaced 24 original light bulb lamp assemblies with a different style of light bulb and a carbon film dropping resistor (vs. the original wire-wound design). This change created an unrecognized vulnerability that left the affected portions of the circuit with dropping resistors that provided insufficient protection from shorting due to indication light bulb failures. As a result, on December 19, 2017, the licensee declared both emergency diesel generators inoperable due to the design vulnerability.Significance/Severity Level: The finding created a design vulnerability in the emergency diesel generator control power circuits, and resulted in the Division 1 and 2 emergency diesel generators being declared inoperable at the time of discovery. Although the emergency diesel generators were declared inoperable, subsequent licensee analysis determined that the system retained its function, and maintained a reasonable expectation of operability while the design deficiencies existed. Accordingly, the inspectors assessed the significance of this finding in accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings at Power, dated June 19, 2012, and determined this finding was of very low safety significance (Green) because it was a deficiency affecting the design or qualification of a mitigating structure, system, or component (SSC), but the SSC maintained its operability. Corrective Action Reference(s):Immediate corrective actions included compensatory measures to remove light bulbs from the vulnerable lamp assemblies in order to eliminate the shorting hazard. This issue was entered into the licensees corrective action program as Condition Report CR-CNS-2017-07513, and the licensee initiated a root cause evaluation |
| 05000445/FIN-2018001-05 | 2018Q1 | Comanche Peak | Failure to Correct a Significant Condition Adverse to Quality | The inspectors identified a Green,non-cited violation of 10CFR 50, Appendix B, Criterion XVI, Corrective Action, associated with the licensees failure to take corrective action for the identified cause of a significant condition adverse to quality. Specifically, a feedwater bypass control valve vibrated open resulting in a turbine trip and initiation of auxiliary feedwater. The licensee determined that the cause was an inadequate procedure for performing maintenance on the feedwater bypass control valves, but failed to correct the inadequate procedure after identifying it as the cause of a control valve failure and a turbine trip. This finding was entered into the licensees corrective action program as Condition Report CR-2018-000959. |
| 05000445/FIN-2018001-04 | 2018Q1 | Comanche Peak | Inadequate Maintenance Procedure for Feedwater Valves | The inspectors reviewed a self-revealed Green,non-cited violation of Technical Specification 5.4.1, Procedures, associated with the licensees failure to prescribe adequate procedures for performing maintenance on the feedwater bypass control valves. Specifically, the licensees procedure failed to specify the correct torque on the handwheel screw locknut, resulting in a loose locknut which led to a control valve failure and a turbine trip. This finding was entered into the licensees corrective action program as Condition Report CR-2017-009139. |
| 05000445/FIN-2018001-03 | 2018Q1 | Comanche Peak | Failure to Provide an Adequate Procedure | The inspectors identified a Green,non-cited violation of Technical Specification 5.4.1, Procedures, associated with the licensees failure to provide procedures appropriate to the circumstances. Specifically, station procedure INC-2085, Rework and Replacement of I&C Equipment, did not contain adequate instructions for wiring current to pressure (I/P) converters for safety related components which resulted in the steam generator atmospheric relief valve I/P converters being placed in a seismically unqualified configuration. This finding was entered into the licensees corrective action program as Condition Report CR-2017-011922. |
| 05000445/FIN-2018001-02 | 2018Q1 | Comanche Peak | Failure to Incorporate Design Information Into System Test Procedures | The inspectors identified a Green,non-cited violation of 10 CFR 50, Appendix B, Criterion XI, Test Control, for the licensees failure to ensure that station test procedures incorporated all requirements contained in applicable design documents. Specifically, the stations test procedures for the component cooling water system failed to test the safeguards loops supply and return train isolation valves for leakage. Excess leakage from these valves could prevent the performance of a safety function. This finding was entered into the licensees corrective action program as Condition Report CR-2017-012024. |
| 05000445/FIN-2018001-01 | 2018Q1 | Comanche Peak | Failure to Follow Commercial Grade Dedication Process | The inspectors identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated with the licensees failure to accomplish activities affecting quality in accordance with documented procedures. Specifically, the licensee upgraded the safety classification of Ashcroft series 200 diaphragms to safety related without following the requirements of station procedure ECE-6.02-03, Critical Characteristics Development. The licensee entered this issue into the corrective action program as Condition Reports CR-CR-2016-009733 and CR-2017-007811. |
| 05000445/FIN-2017003-02 | 2017Q3 | Comanche Peak | Programmatic Failures to Control Transient Combustible Material in Accordance with a Fire Protection Procedure | The inspectors identified 51 examples of a non- cited violation of Operating Licenses NPF -87 and NPF -89, License Condition 2.G, Fire Protection Program, for the failure to control transient combustibles in accordance with the station s Fire Protection Report . Specifically, Fire Protection Report, Revision 29, identifies areas that require strict control o f transient combustible materials such that they are not introduced into these areas without compensatory measures in place prior to introduction. Contrary to this, the licensee allowed storage of combustible materials in 51 areas without compensatory measures. This issue does not represent an immediate safety concern because the licensee removed the combustible materials when they were identified. The licensee entered this issue into its corrective action program as Condition Report CR -2017- 008728. The failure to control transient combustible material s in accordance with the approved Fire Protection Report is a performance deficiency. The performance deficiency was more than minor and therefore a finding because it was associated with the protection against the external factors attribute of the Mitigating System Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the introduction of transient combustible materials decreased the external event mitigation for fire prevention. Furthermore, the inspectors determined that this was a programmatic issue since multiple departments were responsible for t he inappropriate introduction of combustible materials into the exclusion areas . Using NRC Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, June 19, 2012, the inspectors determined that the finding pertained to a failure to adequately implement fire prevention and administrative controls for transient combustible materials. As a result, the inspectors were directed to Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, Sept ember 20, 2013 , and determined that the finding was of very low safety consequence (Green) because the fire prevention and administrative controls finding would not prevent the reactor from reaching and maintaining a safe shutdown condition because none of the examples impacted both trains of safe shutdown equipment . The finding has a human performance cross -cutting aspect associated with procedure adherence, in that station personnel failed to follow procedure requirements when introducing transient combustible materials into exclusion areas (H.8) |
| 05000446/FIN-2017003-01 | 2017Q3 | Comanche Peak | Failure to Promptly Correct a Condition Adverse to Quality | The inspectors identified a non- cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, associated with the licensees failure to take timely corrective actions for a condition adverse to quality. Specifically, the licensee failed to take corrective actions for a leak in the hydraulic snubbers for the Unit 2, loop 3 steam generator, resulting in the level in the hydraulic fluid reservoir going below the minimum level in the sight glass on multiple occasions. This issue does not represent an immediate safety concern because the licensee took action to refill the hydraulic fluid reservoir. The licensee entered this issue into its corrective action program as Condition Report CR -2017- 009071. The licensees failure to take timely and adequate corrective actions to correct a condition adverse to quality was a performance deficiency. The performance deficiency is more than minor , and therefore a finding, because it is associated with the protection against the external events performance attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences . Specifically, the failure to correct the leak resulted in the hydraulic fluid reservoir level dropping below the minimum sight glass level , and loss of reasonable assurance of adequate oil in the snubbers to support their operation. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, dated October 7, 2016, and Inspection Manual Chapter 0609, Appendix A , Significance Determination Process for Findings At -Power , Exhibit 4 , External Events Screening Questions, the inspectors determined the finding was of very low safety significance (Green) because: (1) the loss of the equipment by itself during the external initiating event it was intended to mitigate would not cause a plant trip or initiating event, would not de grade two or more train s of a multi -train system or function, and would not degrade one or more trains of a system that supports a risk significant system or function, and (2) the finding did not involve the total loss of any safety function that contributes to external event initiated core damage accident sequences. The finding has a human performance cross -cutting aspect associated with work management , in that, the licensee failed to ensure that the process of planning, controlling, and executing work 3 activities was implemented to ensure nuclear safety was the overriding priority (H.5 ) |
| 05000446/FIN-2017002-02 | 2017Q2 | Comanche Peak | Inadequate Operability Evaluation for Safety - related Pipe Supports | Green . The inspector s identified a non- cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, that occurred when the licensee failed on two occasions to perform an adequate operability determination associated with multiple safety -related pipe supports. Specifically, the operability determination of multiple carbon steel pipe support clamps exposed to boric acid and a bent sway strut pipe restraint lacked the engineering rigor necessary to provide a high degree of confidence to support the operability of the components. Subsequently, the inspector s concluded that the licensee established reasonable expectation for operability once engineering provided the control room with further analysis on the degraded conditions, and the new information was reviewed and accepted. This issue was entered into the licensees corrective action program as Condition Report CR -2017- 05418. The licensee's failure to perform adequate operability determinations per plant procedures was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the equipment performance attribute of the Mitigating System 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. Specifically, the licensee: (1) failed to perform the required corrosion evaluation for a comparison of material wastage against design dimensions of the pipe support clamps; (2) failed to perform a visual inspection of the material condition of the pipe support clamps as required by the work order; ( 3) used non- seismic design tolerances for the qualification of a seismically qualified strut in the immediate operability determination; and (4) failed to consider that the bent condition of the strut occurred after the previously accepted visual examinations on the same pipe support. All these issues could have resulted in safety -related components failing to perform their specified safety function during accident conditions. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, dated October 7, 2016, and Inspection Manual Chapter 0609, Appendix A, Significance Determination Process for Findings At -Power, Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined the finding was of very low safety significance (Green) because the finding: (1) it was not a design deficiency; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time; (4) and did not result in the loss of a high safety - significant non- technical specification train. This finding had a cross -cutting aspect in the area of problem identification and resolution associated with resolution because the licensee failed to adequately assess the degraded condition of the pipe supports in a complete and accurate manner to support a reasonable expectation of operability (P.1). |
| 05000445/FIN-2017002-06 | 2017Q2 | Comanche Peak | Unanalyzed Condition Involving Potential Moderate Energy Line Break | Inspection Scope On September 13, 2016, based on initial observations by NRC inspectors, the licensee determined that pressurized fire protection piping in the service water intake structure was not properly shielded for moderate energy line break protection of service water components which resulted in inoperability of one train of service water for both Unit 1 and Unit 2. During extent of condition walk downs conducted on October 6, 2016, October 10, 2016, November 17, 2016, December 5, 2016, and December 22, 2016, additional piping in the Unit 1 and Unit 2 safeguards and auxiliary buildings was found to not be shielded correctly as well, resulting in inoperability of one train of various safety related equipment for both units. The licensee determined the most likely cause of this event was that the methodology used to conduct the initial moderate energy line break walk downs was flawed and allowed some threats to be missed. The licensees corrective actions include shielding the affected piping, performing a 100 percent walk down of rooms containing moderate energy line break piping identified for shielding, and revising the systems interaction program maintenance procedure. These activities constituted completion of one event follow -up sample, as defined in Inspection Procedure 71153. b. Findings Introduction. The inspectors identified a non- cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, associated with the licensees failure to assure that applicable regulatory requirements and the design bases, as defined in 10 CFR 50.2 and as specified in the license application, for those structure, systems and components to which this appendix applies, were correctly translated into specifications, drawings, procedures, and instructions. Specifically, from initial construction through March 2017, the licensee failed to fully incorporate applicable design requirements for components needed to ensure the capability to shut down the reactor and maintain it in a safe shutdown condition following a moderate energy line break. Description. On September 13, 2016, inspectors performed walkdowns in the service water intake structure and identified a vertical run of unshielded, pressurized fire protection piping that appeared to pose a moderate energy line break threat to the service water pumps. Inspectors determined that in the event of a moderate energy line break crack along any portion of the unshielded piping, the resultant spray had the potential to impact the function of any one of the four service water pumps. However, only one train would have been affected during the event due to the physical configuration/separation relative to the source line and target pumps and/or associated motor control centers that support pump operation. Inspectors informed the licensee of their concern. Engineering personnel performed a subsequent walkdown of the intake structure and determined that the identified piping was not correctly shielded and operability of the service water pumps was in question. The licensee took immediate action to isolate and depressurize the fire protection line in question which addressed the operability concern. The licensee entered this issue into the station corrective action program as Condition Report CR -2016 -008147 for resolution. Part of the licensees actions was to perform extent of condition walkdowns for unshielded moderate energy piping in the safeguards building for Unit 1 and 2. During the extent of condition walk downs conducted on October 6, 2016, October 10, 2016, November 17, 2016, December 5, 2016, and December 22, 2016, additional piping in the Unit 1 and Unit 2 safeguards and auxiliary buildings was found to not be appropriately shielded against a moderate energy line break, resulting in the inoperability of various safety related equipment for both units. Unit 2 Train B 480 VAC motor control center 2EB2- 1 (Unit 2 Train B emergency core cooling, battery charger, containment spray, and containment isolation valve equipment) Unit 1 Train B 480V MCC 1EB4- 2, and Unit 1 Train B Distribution Panel 1ED2- 2 (Unit 1 Train B safety -related pumps, panels, sequencer, and transformers) Unit 1 Train B 480V MCC 1 EB4- 1 (Unit 1 Train B safety -related pumps, valves, fans, battery chargers, and transformers) Unit 2 Train B 480V MCC 2E134- 1 (Unit 2 Train B safety -related pumps, valves, fans, battery chargers, and transformer) Unit 1, Train B 480V MCC 1E84- 1 (Unit 1 Train B safety -related pumps, valves, fans, battery chargers, and transformers) In each of these instances the licensee took prompt action to isolate and depressurize the identified moderate energy piping pending modification. The licensee subsequently determined that the most probable cause of the issue was the use of a flawed methodology during the initial moderate energy piping walkdowns conducted in 1989. The licensee reported this issue to NRC in Event Report 52239, and Licensee Event Report 16 -002- 00. Analyses. The failure to incorporate applicable design requirements into specifications for moderate energy line break protection was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the design control attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, from initial construction through March 2017, the licensee failed to fully incorporate applicable design requirements for components needed to ensure the capability to shut down the reactor and maintain it in a safe shutdown condition following a moderate energy line break. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, dated July 1, 2012, and Inspection Manual Chapter 0609, Appendix A , Significance Determination Process for Findings At -Power , Exhibit 2, Mitigating Systems Screening Questions, dated October 7, 2016, the inspectors determined the finding required a detailed risk evaluation because the finding involved a deficiency affecting the design and qualification of a mitigating structure, system, or component, and resulted in a loss of operability, and represented an actual loss of function of at least a single train for longer than its allowed out age time. A senior reactor analysts from Region IV performed a detailed risk evaluation and determined that the bounding increase in core damage frequency for this issue was 5.1E -8/year for Unit 1 and 2.9E -10/year for Unit 2 , and was therefore of very low safety significance (Green). Additional information is included in the detailed risk evaluation in Attachment 3 of this report. The inspectors did not assign a cross -cutting aspect because the performance deficiency was not reflective of present performance. Enforcement. Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, states, in part, that, measures shall be established to assure that applicable regulatory requirements and the design bases, as defined in 10 CFR 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies, are correctly translated into specifications, drawings, procedures, and instructions. Contrary to the above, measures established by the licensee did not assure that applicable regulatory requirements and the design bases, as defined in 10 CFR 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies, were correctly translated into specifications, drawings, procedures, and instructions. Specifically, from initial construction through March 2017, the licensee failed to fully incorporate applicable design requirements for components needed to ensure the capability to shut down the reactor and maintain it in a safe shutdown condition following a moderate energy line break. This issue does not represent an immediate safety concern because when the lines were identified the licensee took prompt action to isolate and depressurize them, and the licensee has implemented plant modifications. Since this violation was of very low safety significance (Green) and has been entered into the corrective action program as Condition Report CR- 2016- 008147, this violation is being treated as a non -cited violation consistent with Section 2.3.2 of the NRC Enforcement Policy. (NCV 05000445/2017002 -05; 05000446/2017002- 05, Failure to Translate Design Requirements Into the As Built Facility) |
| 05000445/FIN-2017002-05 | 2017Q2 | Comanche Peak | Failure to Translate Design Requirements Into the As Built Facility | Green. The inspectors identified a non- cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, associated with the licensees failure to assure that applicable regulatory requirements and the design bases, as defined in 10 CFR 50.2 and as specified in the license application, for those structure, systems and components to which this appendix applies, were correctly translated into specifications, drawings, procedures, and instructions. Specifically, from initial construction through March 2017, the licensee failed to fully incorporate applicable moderate energy line break design requirements for fire protection piping located in the vicinity of the station service water pumps, the latter which are needed to ensure the capability to shut down the reactor and maintain it in a safe shutdown condition following a moderate energy line break. This issue does not represent an immediate safety concern because when the lines were identified the licensee took prompt action to isolate and depressurize them, and the licensee has implemented plant modifications. The licensee entered this issue into the corrective action program as Condition Report CR -2016- 008147. The failure to incorporate applicable design requirements into specifications for moderate energy line break protection was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the design control attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, from initial construction through March 2017, the licensee failed to fully incorporate applicable design requirements for components needed to ensure the capability to shut down the reactor and maintain it in a safe shutdown condition following a moderate energy line break. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, dated July 1, 2012, and Inspection Manual Chapter 0609, Appendix A, Significance Determination Process for Findings At -Power , Exhibit 2, Mitigating Systems Screening Questions, dated 5 October 7, 2016, the inspectors determined the finding required a detailed risk evaluation because the finding involved a deficiency affecting the design and qualification of a mitigating structure, system, or component, and resulted in a loss of operability, and represented an actual loss of function of at least a single train for longer than its allowed outage time. A senior reactor analysts from Region IV performed a detailed risk evaluation and determined that the bounding increase in core damage frequency for this issue was 5.1E -8/year for Unit 1 and 2.9E -10/year for Unit 2, and was therefore of very low safety significance (Green ). The inspectors did not assign a cross -cutting aspect because the performance deficiency was not reflective of present performance |
| 05000445/FIN-2017002-04 | 2017Q2 | Comanche Peak | Failure to Adequately Assess Risk and Implement Risk Management Actions for Proposed Maintenane | Green. The inspectors identified a non- cited violation of 10 CFR 50.65(a)(4), Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, for the licensees failure to adequately assess risk and implement required risk management actions for a planned maintenance activity. Specifically, the licensee failed to evaluate the risk and implement required risk management actions associated with disabling a hazard barrier and breeching the control room envelope when blocking open door E -40A. This issue did not represent an immediate safety concern because, at the time of identification, the licensee stopped the activity and secured the door. The licensee entered this issue into the corrective action program for resolution as Condition Report CR- 2017- 006019. The failure to adequately assess the risk and implement required risk management actions for proposed maintenance activities was a performance deficiency. This performance deficiency was more than minor, and therefore a finding, because it was associated with the configuration control attribute o f the Barrier Integrity Cornerstone and affected the associated objective to ensure physical design barriers protect the public from radionuclide releases caused by accidents or events. Using Inspection Manual Chapter 0609, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process, dated May 19, 2005, Flowchart 2, Assessment of Risk Management Actions, the inspectors determined the need to calculate the risk deficit to determine the significance of this issue. A senior reactor analyst determined the finding to have very low safety significance (Green) based on combining the effects of the degradation of the radiological barrier and tornado missile barrier functions. The analyst performed a qualitative review of the screening criteria in Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At -Power, for the degradation of the radiological barrier function for the control room and considered the short exposure time (2.9E -5 years) and the Comanche Peak specific high winds frequency (3.0E -4/year) for the tornado missile barrier function of the control room to determine that the incremental core damage probability deficit and the incremental large early release probability deficit were less than 1E -6 and 1E -7, respectively. The finding has a human performance cross -cutting aspect associated with procedure adherence, in that operations personnel failed to follow procedures when allowing door E -40A to be opened |
| 05000445/FIN-2017002-03 | 2017Q2 | Comanche Peak | Relays not Environmentally Qualified | Green. The inspectors identified a non- cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, associated with the licensees failure to assure that design changes were subject to design control measures commensurate with those applied to the original design. Specifically, the licensee changed internal components for safety -related, steam generator atmospheric relief valve booster relays but failed to verify that these new components could withstand the environment created during a high energy line break. This issue does not represent an immediate safety concern because the licensee performed an operability determination which established a reasonable expectation for operability, and implemented corrective actions to replace the relays with qualified relays. The licensee 4 entered this issue into the corrective action program for resolution as Condition Report CR- 2017- 006236. The failure to ensure that changes to the facility were subject to design control measures commensurate with those applied to the original design was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affected the associated objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, dated October 7, 2016, and Inspection Manual Chapter 0609, Appendix A, Significance Determination Process for Findings At -Power, Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined the finding was of very low safety significance (Green) because the finding: (1) was not a deficiency affecting the design and qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality, (2) did not represent a loss of system and/or function, (3) did not represent an actual loss of function of at least a single train for longer than its allowed outage time, or two separate safety systems out -of-service for longer than their technical specification allowed outage time, and (4) does not represent an actual loss of function of one or more non- technical specification trains of equipment designated as high safety -significant for greater than 24 hours in accordance with the licensees maintenance rule program. The inspectors did not assign a cross -cutting aspect because the performance deficiency was not reflective of present performance |
| 05000445/FIN-2017002-01 | 2017Q2 | Comanche Peak | Failure to Control Transient Combustible Material in Accordance with a Fire Protection Procedure | Green. The inspectors identified a non- cited violation of Operating Licenses NPF -87 and NP F-89, License Condition 2.G, Fire Protection Program, for the failure to control transient combustibles in accordance with the station s fire protection report. Specifically, Fire Protection Report, Revision 29, Section 5.3.8, Fire Area EO Control Room, includes Deviation 3c -1, Control Room Missile Door, which requires, in part, that since the control room missile door in the west wall is not a 3 -hour rated fire door, the area of the turbine deck within 100 feet of the door is to be void of combustibles. Contrary to this, the licensee allowed storage of combustible materials in this area without required compensatory measures. This issue does not represent an immediate safety concern because the licensee removed the combustible materials upon identification. The licensee entered this issue into corrective action program as Condition Report CR -2017 -5564. The failure to control transient combustible material in accordance with the approved fire protection report is a performance deficiency. The performance deficiency was more than minor and therefore a finding because it was associated with the protection against external factors attribute of the Mitigating System Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the introduction of transient combustible materials decreased the external event mitigation for fire prevention. Using NRC Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, June 19, 2012, the inspectors determined that the finding pertained to a failure to adequately implement fire prevention and administrative controls for transient combustible materials. As a result, the inspectors were directed to Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, September 20, 2013. The inspectors evaluated the finding through Appendix F, Attachment 1, Fir e Protection Significance Determination Process Worksheet, September 20, 2013, and determined that the finding was of very low safety consequence (Green) because the Fire Prevention and Administrative Controls finding would not prevent the reactor from re aching and maintaining a safe shutdown condition. The finding has a problem identification and resolution cross -cutting aspect associated with resolution, in that, the licensee failed to take effective corrective actions to address issues in a timely manner. 3 Specifically, the licensee had previously identified this issue in Condition Report CR- 2014010224 but had failed to take corrective actions to address it (P.3) |
| 05000483/FIN-2017002-01 | 2017Q2 | Callaway | Failure to Follow Motor Control Center Procedure | Green . The inspectors reviewed a self -revealed, non- cited violation of Technical Specification 5.4.1.a, Procedures, for the licensees failure to follow Procedure MPE-ZZ-QS001, Cleaning and Inspection of Motor Control Centers, Revision 34. On May 2, 2017, the licensee failed to ensure contactors operated freely per step 7.6.8 during reassembly of motor control center NG08F for the essential service water cooling tower by pass valve EFHV0066. As a result, one train of the essential service water system was rendered inoperable for a total of 57 hours, of which 17 hours was unplanned, and the issue was only discovered when valve EFHV0066 failed to operate during a periodic surveillance test on May 3, 2017. As immediate corrective actions, the licensee replaced the starter assembly under Job 17001973, completed testing including electrically cycling valve EFHV0066, and restored the system to operable status on May 4, 2017. The licensee entered this issue into the corrective action program under Condition Report 201702418. The failure to follow Procedure MPE-ZZ-QS001 was a performance deficiency. This performance deficiency was more than minor, and therefore a finding, because it adversely affected the configuration control attribute of the Mitigating Systems Cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, one train of the essential service water system was rendered inoperable for a total of 57 hours, of which 17 hours was unplanned, and the issue was only discovered when valve EFHV0066 failed to operate during a periodic surveillance test on May 3, 2017. Using Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, and Appendix A, The Significance Determination Process (SDP) for Findings At -Power, Exhibit 2, Mitigating Systems Screening Questions, dated June 19, 2012, the inspectors determined the finding was of very low safety significance (Green) because (1) the finding was not a deficiency affecting the design or qualification of a mitigating system; (2) the finding did not represent a loss of system and/or function; (3) the finding did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and (4) the finding does not represent an actual loss of function of one or more non- technical specification trains of equipment designated as high safety -significant in accordance with the licensees maintenance rule program for greater than 24 hours. Specifically, the total duration of 3 inoperability was approximately 57 hours which is less than the allowed completion time of 72 hours for this system. The finding had a cross-cutting aspect in the area of human performance associated with challenge the unknown because the licensee failed to stop when faced with uncertain conditions. Specifically, the maintenance technician encountered resistance when manually operating the contactors, signed off the step as complete, and later rationalized the decision with the supervisor aft er completing the work (H.11 ). |
| 05000483/FIN-2017002-02 | 2017Q2 | Callaway | Failure to Analyze the Effect of Changes to Maintaining the Gaitronics System | Severity Level IV. The inspectors identified a Severity Level IV non- cited violation for the licensees failure to perform an analysis of a change to processes supporting the emergency preparedness program that demonstrated the change did not reduce the effectiveness of the emergency plan in accordance with the requirements of 10 CFR 50.54(q)(3). There were no immediate safety concerns associated with this violation because less than 10 percent of the public address speakers were determined to be degraded or non- functional. This issue has been placed in the licensees corrective action system as Condition Report 201702343. The failure to perform an analysis of the effect of changes in processes supporting emergency preparedness is a performance deficiency within the licensees ability to foresee and correct. The finding was more than minor because the finding was associated with the Facilities and Equipment Cornerstone attribute and adversely affected the Emergency Preparedness Cornerstone objective. The finding was assessed using traditional enforcement because the licensees failure to perform a required analysis impacted the regulatory process . The finding was evaluated using the NRCs Enforcement Policy, dated November 1, 2016, Section 6.6(d) , and was determined to be a Severity Level IV violation because the violation did not affect radiological assessment or offsite notification. Traditional enforcement violations are not assessed for cross -cutting aspects. |
| 05000483/FIN-2017001-01 | 2017Q1 | Callaway | Enforcement Action EA-17-050, Enforcement Discretion for Tornado-Generated Missile Protection Noncompliances | Appendix A to 10 CFR Part 50, General Design Criteria for Nuclear Power Plants, Criterion 2, Design Bases for Protection Against Natural Phenomena, states, in part, that structures, systems, and components important to safety shall be designed to withstand the effects of natural phenomena, such as tornadoes. Criterion 4, Environmental and Dynamic Effects Design Basis, states, in part, that structures, systems and components important to safety shall be appropriately protected against dynamic effects including missiles which may result from events and conditions outside the nuclear power unit. As part of their response to Regulatory Issue Summary 2015-06, Tornado Missile Protection, the licensee performed a review of protection against tornado-generated missiles required by the current licensing basis. During the review, on March 13, 2017, the licensee identified a portion of the diesel generator fuel oil system that could be susceptible to tornado missiles. The licensee identified a low-probability scenario where one or more tornado-generated missiles could impact the emergency fuel oil truck connection lines on the south wall of the diesel generator building. The two non-safety-related connection lines are each connected to the safety-related normal fuel oil transfer lines via a tee connection and a normally closed isolation valve. Direct impact by a tornado-generated missile parallel to either trains connection line could impart a load on the tee connection to the normal fuel oil line that had not been evaluated. Failure of the tee connection would result in the associated diesel generator being incapable of performing its safety function. Relevant Enforcement Discretion Policy On June 10, 2015, the NRC issued Enforcement Guidance Memorandum (EGM) 15-002, Enforcement Discretion for Tornado-Generated Missile Protection Noncompliance (Adams Accession Number ML15111A269). The EGM referenced a bounding generic risk analysis performed by the NRC staff that concluded that tornado missile vulnerabilities pose a low risk significance to operating nuclear plants. Because of this, the EGM described the conditions under which the NRC staff may exercise enforcement discretion for noncompliance with the current licensing basis for tornado-generated missile protection. Specifically, if the licensee could not meet the technical specification required actions within the required completion time, the EGM allows the staff to exercise enforcement discretion provided the licensee implements initial compensatory measures prior to the expiration of the time allowed by the limiting condition for operation. The compensatory actions should provide additional protection such that the likelihood of tornado missile effects are lessened. The EGM then requires the licensee to implement more comprehensive compensatory measures within 60 days of issue discovery. The compensatory measures must remain in place until permanent repairs are completed, or until the NRC dispositions the non-compliance in accordance with a method acceptable to the NRC such that discretion is no longer needed. In addition, the issue must be entered into the licensees corrective action program. Because EGM 15-002 listed Callaway as a Group A plant, enforcement discretion will expire on June 10, 2018. Because the EGM did not provide for enforcement discretion for any related underlying technical violations; any associated underlying technical violations will be assessed through the enforcement process. Licensee Actions The licensee declared both diesel generators inoperable, complied with the applicable technical specification action statements, initiated a condition report, invoked the enforcement discretion guidance, implemented prompt compensatory measures, and returned the systems, structures, and components to an operable status. The licensee instituted compensatory measures intended to reduce the likelihood of tornado missile effects. These included verifying that guidance was in place for severe weather procedures, abnormal and emergency operating procedures, and procedures dedicated to the Diverse and Flexible Coping Strategy (FLEX), that training on these procedures was current, and that a heightened level of awareness of the vulnerability was established. As an additional compensatory measure, the licensee placed concrete blocks adjacent to the piping penetrations to provide a greater level of protection from tornado generated missiles. NRC Actions The inspectors review addressed the material issues in the plant, and whether the measures were implemented in accordance with the guidance in EGM 15-002. The inspectors also evaluated whether the measures as implemented would function as intended and were properly controlled. The inspectors verified through inspection that the EGM 15-002 criteria were met in each case. Therefore, the staff determined that it was appropriate to exercise enforcement discretion and not take enforcement action for the required actions of Technical Specification 3.8.1, AC Sources Operating, provided the non-compliances are resolved by June 10, 2018 (EA-17-050). The inspectors did not fully review the underlying circumstances that resulted in the technical specification violations. As stated in EGM 15-002, violations of other requirements which may have contributed to the technical specification violations will be evaluated independently of EGM implementation. The inspectors will verify restoration of compliance and assess the underlying circumstances during future inspection activities. |
| 05000446/FIN-2017001-06 | 2017Q1 | Comanche Peak | Licensee-Identified Violation | Comanche Peak Unit 2, Operating License NPF-89, Condition 2.G, Fire Protection, requires, in part, that the licensee implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report through Amendment 87, and as approved in the Safety Evaluation Report and its supplements through Supplement 27. The stations approved fire protection program includes Fire Protection Report, Revision 29, Section 3.1 which requires, in part, that when fire detection equipment located inside of the containment building is inoperable then hourly monitoring of air temperature is performed as a compensatory measure. Contrary to the above, on November 22, 2016, licensee personnel identified that compensatory measures implemented for a failed detection system in the Unit 2 containment had not been implemented. The licensee had implemented a compensatory measure on December 3, 2015, to monitor containment temperature in the Unit 2 containment hourly due to a failed thermistor strip. On November 17, 2016, the licensee stopped monitoring temperature after restoring a different component to service. The licensee subsequently realized that the compensatory measure was still required and reinstated it on November 22, 2016. The violation is more than minor because it affected the protection against 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. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, the inspector determined that the violation is of very low safety significance (Green) because the finding did not affect the ability of either unit to achieve safe shutdown. The violation was entered into the licensees corrective action program as Condition Report CR-2016-009888. |
| 05000445/FIN-2017001-05 | 2017Q1 | Comanche Peak | Licensee-Identified Violation | Title 10 CFR 50.54(q)(2) requires, in part, that licensees shall follow and maintain the effectiveness of an emergency plan that meets the planning standards of 10 CFR 50.47(b). Title 10 CFR 50.47(b)(2) requires, in part, that timely augmentation of response capabilities be available. The licensees emergency plan provides for the ability to augment response capabilities by use of a system to callout additional personnel to fill their emergency response organization (ERO) staffing requirements for declared emergencies. Contrary to the above, from January 5, 2017 until January 17, 2017, the licensee failed to ensure timely augmentation of response capabilities was available. Specifically, on January 5, 2017, the licensees corporate security office removed 32 members of the ERO from the licensees callout system, including eight personnel assigned to minimum staffing positions. The licensee identified the issue when, following an inadvertent actuation of the callout system on January 16, 2017, they discovered that multiple personnel were not called. The licensee restored all required personnel to the callout system on January 17, 2017. The violation is more than minor because it affected the ERO readiness attribute of the Emergency Preparedness cornerstone and impacted the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, the inspector determined that the violation is of very low safety significance (Green) because the finding represented a failure to comply with planning standard (b)(2), and, using table 5.2-1, was screened as a Green finding because the deficiency did not cause more than one required ERO functional area to not be filled. The violation was entered into the licensees corrective action program as CR-2017-001524. |
| 05000445/FIN-2017001-04 | 2017Q1 | Comanche Peak | Failure to Promptly Correct a Condition Adverse to Quality | Green. The inspectors identified a non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, associated with the licensees failure to take timely corrective actions for a previously identified condition adverse to quality. Specifically, the licensee failed to verify the adequacy of the design of the Unit 1 120 VAC vital bus inverter 1PC1 with respect to use of alternate AC power to the inverter. The 120 VAC calculation did not properly account for low voltage when the buses are supplied from their alternate source. This issue does not represent an immediate safety concern because, following the inspectors identification, the licensee performed an operability evaluation which established a reasonable expectation of operability. The licensee implemented immediate corrective actions by entering the issues into the corrective action program for resolution and performed an operability determination for the identified degraded conditions. The licensee entered this issue into their corrective action program as CR-2017-001296. The licensees failure to take timely and adequate corrective actions to correct a condition adverse to quality was a performance deficiency. The performance deficiency is more than minor, and therefore a finding, because it is associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to correct the low voltage susceptibility resulted in delayed restoration of a bus following the failure of the swing inverter to sync. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, dated October 7, 2016, and Inspection Manual Chapter 0609, Appendix A, Significance Determination Process for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined the finding was of very low safety significance (Green) because the finding: (1) was not a deficiency affecting the design and qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality, (2) did not represent a loss of system and/or function, (3) did not represent an actual loss of function of at least a single train for longer than its allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time, and (4) does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant for greater than 24 hours in accordance with the licensees maintenance rule program. The finding has a human performance cross-cutting aspect associated with resources, in that, the licensee failed to ensure that resources were adequate to support nuclear safety (H.1). |
| 05000445/FIN-2017001-03 | 2017Q1 | Comanche Peak | Use of Non-Design Fouling Factor for Component Cooling Water Heat Exchanger in Station Service Water Tornado Missile Calculation | Green. The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, involving the failure to use the design fouling factor for the component cooling water heat exchanger in a design basis calculation evaluating a tornado missile strike of station service water system piping. The licensee implemented immediate corrective actions by entering the issues into the corrective action program for resolution and performed an operability determination for the identified degraded conditions. The licensee entered this issue into their corrective action program as Issue Report IR-2017-001465. The inspectors determined that the failure to use the design fouling factor for the component cooling water heat exchanger in the tornado missile analysis of the station service water system discharge piping was a performance deficiency. This finding was more-than-minor because it was associated with the design control 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. Specifically, the use of a non-conservative heat exchanger fouling factor in a design basis accident analysis resulted in a more restrictive temperature limit (i.e., less than the technical specification allowed value) of the safe shutdown impoundment. In accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, Exhibit 2, Mitigating Systems Screening Questions, the issue screened as having very low safety significance (Green) because it was a design or qualification deficiency that (1) did not represent a loss of operability or functionality; (2) did not represent an actual loss of safety function of the system or train; (3) did not result in the loss of one or more trains of non-technical specification equipment; and (4) did not screen as potentially risk-significant due to seismic, flooding, or severe weather. The inspectors determined that this finding did not have a cross-cutting aspect because the most significant contributor to the performance deficiency did not reflect current licensee performance. Specifically, the licensee performed the calculation in 1988, therefore, the performance deficiency occurred outside of the nominal three-year period for present performance. |
| 05000445/FIN-2017001-02 | 2017Q1 | Comanche Peak | Failure to Evaluate Heat Loads on Control Room Air Conditioning System | Green. The inspectors identified a non-cited violation of 10 CFR 50, Appendix B, Criterion III, Design Control, for the licensees failure to properly evaluate heat loads on the control room air conditioning system. Specifically, the licensee used a non-conservative assumption for the number of persons in the control room envelope when calculating the required capacity of the system. The licensee had assumed there would only be six personnel in the technical support center (which is included in the control room envelope) during a design basis event. However, the emergency plan nominally staffed the technical support center with 25 station personnel, and an additional five NRC personnel. The licensee implemented immediate corrective actions by entering the issues into the corrective action program for resolution and performed an operability determination for the identified degraded condition. The licensee entered this issue into their corrective action program as Condition Report CR-2017-000744. The failure to evaluate heat loads to determine the required system capacity was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the design control attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, dated October 7, 2016, and Inspection Manual Chapter 0609, Appendix A, Significance Determination Process for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined the finding was of very low safety significance (Green) because the finding: (1) was not a deficiency affecting the design and qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality, (2) did not represent a loss of system and/or function, (3) did not represent an actual loss of function of at least a single train for longer than its allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time, and (4) does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant for greater than 24 hours in accordance with the licensees maintenance rule program. The inspectors determined that no cross-cutting aspect was assigned because the performance deficiency was not reflective of present performance. |
| 05000445/FIN-2017001-01 | 2017Q1 | Comanche Peak | Failure to Maintain B.5.b Equipment in a State of Readiness to Support Mitigation Strategies | Green. The inspectors identified a non-cited violation of 10 CFR 50.54(hh)(2), Conditions of Licenses, involving the licensees failure to maintain available equipment needed to implement mitigating strategies to provide makeup to steam generators following loss of large areas of the plant due to explosions or fire. Specifically, the licensee failed to maintain available a portable alternate mitigation equipment pump related to the steam generator makeup strategy. As an immediate corrective action the licensee put temporary heaters in place for the alternate mitigation equipment pump to ensure the equipment was stored at temperatures greater than 32 degrees Fahrenheit pending further evaluation. The licensee entered this issue into their corrective action program as Condition Report CR-2016-010832. The failure to maintain all necessary equipment available to implement mitigating strategies as required by regulations and conditions of the operating license was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the design control attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix L, B.5.b Significance Determination Process, dated December 24, 2009, the inspectors determined the finding was of very low safety significance (Green) because it resulted in an unrecoverable unavailability of an individual mitigating strategy but did not result in multiple unavailable mitigating strategies, or loss of all on-site, self-powered, portable pumping capability. The inspectors did not assign a cross-cutting aspect because the performance deficiency was not reflective of present performance. |
| 05000445/FIN-2016004-01 | 2016Q4 | Comanche Peak | Failure to Evaluate Inservice Testing Results of Power Operated Relief Valve | Green. The inspectors identified a non-cited violation of 10 CFR 50, Appendix B, Criterion XI, Test Control, for the licensees failure to evaluate inservice testing results of a power operated relief valve (PORV). Specifically, the licensee restored a unit 1 PORV to service that did not meet its specified opening time, which resulted in the inoperability of the low temperature overpressure protection (LTOP) system. Following maintenance on PORV 1-PCV-455A during October 2014, the licensee performed stroke time testing on the valve, but failed to recognize that the valve exceeded its test acceptance criteria until it failed again in May 2016. The licensee entered this issue into the corrective action program as CR-2016-003920. The failure to evaluate test results to ensure they met test requirements is a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the Reactor Coolant System Equipment and Barrier Performance attribute of the Barrier Integrity cornerstone and affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, dated October 7, 2016, Inspection Manual Chapter 0609, Appendix G, Shutdown Operations Significance Determination Process, dated May 9, 2014, and Appendix G Attachment 1, Phase 1 Initial Screening and Characterization of Findings, Exhibit 4, Barrier Integrity Screening Questions, the inspectors determined the finding affected the Barrier Integrity cornerstone and required a detailed risk evaluation because the finding involved the unavailability of a PORV during LTOP operations. Using the assumption that the slow opening time prevents the PORV from fulfilling its LTOP system function, a senior reactor analyst performed a bounding qualitative assessment, using Inspection Manual Chapter 0609, Appendix G, Shutdown Operations Significance Determination Process. The influential assumptions used by the senior reactor analyst included an exposure time of approximately 9 hours and that the licensee maintained the availability of a single additional relief valve with capability sufficient to mitigate an LTOP event as described in the final safety analysis report. Using these assumptions, the senior reactor analyst determined that a bounding increase in core damage frequency for this issue was 1.45E-8 per year and was therefore, of very low safety significance (Green). The finding has a human performance cross-cutting aspect associated with work management, in that, the licensee failed to ensure that the work process includes the need for coordination with different groups or job activities (H.5). |
| 05000445/FIN-2016004-02 | 2016Q4 | Comanche Peak | Failure to Scope the Containment Ventilation System in the Maintenance Rule Program | Green. The inspectors identified a non-cited violation of 10 CFR 50.65(b)(2) associated with the licensees failure to scope the containment ventilation system into the maintenance rule program. Specifically, the containment ventilation system, a non-safety related system that is relied upon to mitigate accidents or transients and used in emergency operating procedures, was not included in the scope of the monitoring program specified in 10 CFR 50.65(a)(1). In response to this issue the licensee scoped the system in the plants maintenance rule monitoring program, and placed the equipment under 10 CFR 50.65(a)(1) monitoring requirements pending further review. The licensee entered this issue into the corrective action program as CR-2016-008491. The failure to monitor the performance and condition of a system that meets the maintenance rule scoping criteria of 10 CFR 50.65(b)(2) is the performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, dated July 1, 2012, and Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated October 7, 2016, Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined the finding affected the Mitigating Systems cornerstone and was of very low safety significance (Green), because the finding did not represent a loss of system function and the system was not designated as high safety-significant in accordance with the licensees maintenance rule program. The finding has a human performance cross-cutting aspect associated with avoiding complacency, in that, the licensee failed to ensure that individuals recognized and planned for the possibility of mistakes and latent issues when re-evaluating the basis for excluding the system (H.12). |
| 05000445/FIN-2016004-03 | 2016Q4 | Comanche Peak | Licensee-Identified Violation | Title 10 CFR 50.65(a)(2), requires, in part, that monitoring of system performance under 10 CFR 50.65(a)(1) is not required where it has been demonstrated that performance of the system is being effectively controlled through appropriate preventive maintenance. Contrary to the above, from June 2014 to May 2016, the licensee failed to demonstrate that performance of the 480 Volt AC system, a system not being monitored under 10 CFR 50.65(a)(1), was being effectively controlled by preventive maintenance. Specifically, the 480 Volt AC system exceeded the established performance criteria in June 2014, and the licensee failed to evaluate its performance. The licensee discovered in May 2016 through an engineering review that the system had exceeded its criteria in 2014 and should have been placed in (a)(1) monitoring status. The licensee evaluated the system performance and ensured appropriate corrective action had been taken. The violation is more than minor because it affected the equipment performance attribute of the Mitigating Systems cornerstone and impacted the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, the inspectors determined that the violation is of very low safety significance (Green) because the finding did not represent a loss of system or function, and did not represent a loss of function of a single train for greater than its technical specification allowed outage time. The violation was entered into the licensees corrective action program as CR-2016-009963. |
| 05000445/FIN-2016004-04 | 2016Q4 | Comanche Peak | Licensee-Identified Violation | Title 10 CFR 50 Appendix B, Criterion V, requires, in part, that licensees shall perform activities affecting quality in accordance with instructions appropriate to the circumstances. Contrary to the above, on May 10, 2016, the licensee failed to perform safety chiller maintenance, a quality related activity, in accordance with the approved instructions. Specifically, licensee personnel failed to torque electrical connections on overload relays on the unit 1 train A safety chiller as required by the licensees work instructions. The inadequate torque was present until June 9, 2016, when the licensee performed thermography on the chiller electrical connections. The licensee discovered elevated temperatures, shut down the chiller, and replaced and torqued the affected components. The licensee determined that the chiller was inoperable from May 28, 2016, when it was required to be in service due to the unit entering Mode 4, until the chiller was restored on June 9. The violation is more than minor because it affected the equipment performance attribute of the Mitigating Systems cornerstone and impacted the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, the inspectors determined that the violation required a detailed risk evaluation (DRE) because the finding represented a loss of function of a single train for greater than its technical specification allowed outage time. A senior reactor analyst from Region IV performed the risk evaluation. The licensee provided an analysis demonstrating that the chiller would be able to perform its safety function for at least 24 hours. Based on that demonstration, the analyst was able to determine that the risk was of very low safety significance (Green). The violation was entered into the licensees corrective action program as CR-2016-005798. |
| 05000445/FIN-2016002-02 | 2016Q2 | Comanche Peak | Failure to Determine Dose Rates Prior to Allowing Entry into a High Radiation Area | The inspectors reviewed a self-revealed non-cited violation of Technical Specification 5.7.1.e associated with the licensee allowing a worker access into the 2-077-B penetration valve room, a high radiation area, without an adequate knowledge of the radiological conditions. Specifically, the licensee briefed the worker on the conditions with outdated radiation survey information even though the 2-077-B penetration valve room was subject to changing radiological conditions. As a result, an individual entered areas with general area dose rates of 210 mrem per hour rather than the briefed dose rates of less than 50 mrem per hour. This issue was entered into the licensees corrective action program as Condition Report CR-2015-010211. Corrective actions included performing follow-up radiation surveys and implementing improvements to the high radiation area access control program. The inspectors determined that allowing a worker access into a high radiation without an adequate knowledge of the radiological conditions was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it affected the program and process attribute of the Occupational Radiation Safety cornerstone and adversely affected the cornerstone objective of ensuring adequate protection of worker health and safety from exposure to radiation. Specifically, entry into a high radiation area without adequate knowledge of the radiological conditions placed the individual at risk for unnecessary exposure. The finding was assessed using Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, issued August 19, 2008, and was determined to be of very low safety significance (Green) because the performance deficiency was not an ALARA planning issue, there was not an overexposure nor substantial potential for an overexposure, and the licensees ability to assess dose was not compromised. The finding has a human performance cross-cutting aspect associated with work management, because the organization failed to implement a process of planning, controlling, and executing work activities such that nuclear safety was the overriding priority (H.5). |
| 05000446/FIN-2016002-01 | 2016Q2 | Comanche Peak | Failure to Correct Conditions Adverse to Quality | The inspectors identified a non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, associated with the licensees failure to correct a condition adverse to quality in safety-related equipment. Specifically, following an in-service testing failure of auxiliary feedwater check valve 2FW-091 in November 2012, the licensee performed an operability evaluation of the auxiliary feedwater system. However, the inspectors identified that the licensee failed to take corrective action to address the condition adverse to quality that resulted in the valve failing to seat properly. Consequently, the same valve failed a subsequent inservice test in November 2015. Following discovery of this issue, the licensee performed an operability determination that established a reasonable expectation of operability pending implementation of corrective actions. The licensee entered this issue into corrective action program as CR-2015-10961. The licensees failure to correct a condition adverse to quality was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to correct auxiliary feedwater check valve 2FW-0191 failure to seat in November 2012 resulting in an additional failure in November 2015. Using Inspection Manual Chapter (IMC) 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, inspectors determined that this finding was of very low safety significance (Green) because the finding (1) was not a deficiency affecting the design and qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality, (2) did not represent a loss of system and/or function, (3) did not represent an actual loss of function of at least a single train for longer than its allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time, and (4) did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant for greater than 24 hours in accordance with the licensees maintenance rule program. The finding has a problem identification and resolution cross-cutting aspect associated with evaluation, in that, the licensee failed to thoroughly evaluate issues to ensure that resolutions address extent of conditions. Specifically, the licensee failed to appropriately classify the issue of the check valve not seating and recognize this as a degraded condition (P.2). |
| 05000445/FIN-2016002-03 | 2016Q2 | Comanche Peak | Licensee-Identified Violation | Comanche Peak Unit 1, Operating License NPF-87, Condition 2.G, Fire Protection, requires, in part, that the licensee implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report through Amendment 78 and as approved in the Safety Evaluation Report and its supplements through Supplement 24. Comanche Peak Unit 2, Operating License NPF-89, Condition 2.G, Fire Protection, requires, in part, that the licensee implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report through Amendment 87 and as approved in the Safety Evaluation Report and its supplements through Supplement 27. The stations approved fire protection program includes Fire Protection Report, Revision 29, Section 5.3.8, Fire Area EO Control Room, includes Deviation 3c-1, Control Room Missile Door, which requires, in part, that since the control room missile door in the west wall is not a three hour rated fire door, the area of the turbine deck within 100 feet of the door is to be void of combustibles. Contrary to the above, on May 5, 2016, the licensee stored combustible materials within 100 feet of the control room missile door in the west wall. Specifically, licensee personnel identified that contractors had stored combustibles within the combustible free zone, and that no compensatory measures had been implemented for the deviation from the Fire Protection Report. The licensee implemented a periodic roving fire watch to compensate for the reduction in fire protection. The violation is more than minor because if left uncorrected, it could lead to a more significant safety concern. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, the inspector determined that the violation is of very low safety significance (Green) because the finding did not affect the ability of either unit to achieve safe shutdown. The violation was entered into the licensees corrective action program as CR-2016-004167. |
| 05000446/FIN-2016002-04 | 2016Q2 | Comanche Peak | Licensee-Identified Violation | Technical Specification 5.4.1.a states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, Appendix A, Section 9.a., identifies procedures for maintenance as required procedures. Work order 4831032 is a procedure established by the licensee for performing maintenance on diesel generator 2-02. The work order provided instructions for installation of the magnetic speed pickup sensor cable. Contrary to the above, from October 1996 through March 2, 2016, the licensee failed to install the unit 2 diesel generator 2-02 magnetic speed pickup sensor cable in accordance with the approved instructions. Specifically, the speed sensor cable conduit was not fully threaded onto the cable plug. This inadequate installation was present until 2016, when the conduit threaded connection was physically impacted at an undetermined time. The impact caused the conduit connection to break and the conduit to separate from the plug, leaving the cable leads exposed but intact. A licensee technician identified the broken connection during a system walk down on March 2, 2016. The licensee declared the diesel generator inoperable and restored the cable to its design configuration. The licensee analyzed the apparent thread engagement, and determined that, prior to the break in the conduit connection, the cable would have maintained its function in a seismic event, but after the break, the cable function could not be assured. The licensee determined that a failure of the cable would result in the diesel generator exceeding its allowed frequency, but would not result in a diesel generator failure to run. Because the time that the break occurred could not be determined, the diesel generator was assumed to be inoperable at the time of discovery. The violation is more than minor because it affected the configuration control attribute of the Mitigating Systems cornerstone and impacted the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, the inspector determined that the violation is of very low safety significance (Green) because the finding did not represent a loss of system or function, and did not represent a loss of function of a single train for greater than its technical specification allowed outage time. The violation was entered into the licensees corrective action program as CR-2016-001941. |
| 05000368/FIN-2016007-20 | 2016Q1 | Arkansas Nuclear | Licensee-Identified Violation | Title 10 CFR Part 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Section (a)(4), requires, in part, that before performing maintenance activities, the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities. Contrary to these requirements, on July 8, 2015, ANO identified that they failed to assess and manage the increase in risk that may result from the proposed maintenance activities. Specifically, ANO failed to assess and manage the risk associated with removing and cleaning the Unit 2 SW system pre-screens for maintenance. ANO documented this violation in the CAP as CR-ANO-2-2015-01865. Additionally, ANO added guidance to procedure COPD-024 to address this issue. The team determined that this issue was of very low safety significance (Green) after reviewing IMC 0609 Attachment 0609.04, and Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process, dated May 19, 2005. Specifically, the team determined the incremental core damage probability deficit was not greater than 1E-6. |
| 05000313/FIN-2016007-03 | 2016Q1 | Arkansas Nuclear | Inadequate Operating Experience Evaluations | The team identified a Green finding for the licensees failure to evaluate operating experience as required by procedure EN-OE-100-02, Operating Experience Evaluations. This procedure allowed taking no action for operating experience issues that were applicable to the station if multiple barriers existed to preclude failure. The team identified two examples where the licensee had not correctly verified the adequacy of credited barriers and as a result, represented a vulnerability to a similar event occurring at the station. The licensees corrective actions included re-performing the operating experience evaluations and documenting the issue in the corrective action program as condition reports CR-ANO-C-2016-00463 and CR-ANO-C-2016-00782. The failure to evaluate operating experience was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the protection against external factors attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the failure to take corrective action to address the large motor and respiratory protection operating experience could result in a similar adverse condition or event at the station. The finding was evaluated using Inspection Manual Chapter 0609, Significance Determination Process, Attachment 0609.04, Initial Characterization of Findings, and Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 1 Initiating Events Screening Questions, dated June 19, 2012. The team determined the finding was of very low safety significance (Green) because the finding would not result in exceeding the reactor coolant system leak rate for a small loss of coolant accident or affect systems used to mitigate a loss of coolant accident, did not cause a reactor trip and loss of mitigation equipment, did not involve the loss of a support system, did not involve a degraded steam generator tube condition, and did not impact the frequency of a fire or internal flooding event. This finding had a human performance cross-cutting aspect of Conservative Bias because the licensee failed to ensure that individuals used decision making-practices that emphasized prudent choices over those that were simply allowable. Specifically, individuals performing evaluations rationalized assumptions rather than verifying the actual conditions (H.14). |
| 05000313/FIN-2016007-04 | 2016Q1 | Arkansas Nuclear | Inadequate Control of Monitoring for Wall Loss in the Service Water System | The team identified a Green finding and an associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, because the licensee failed to implement the Microbiologically Influenced Corrosion Monitoring Program in a manner that would monitor for pipe wall loss in the service water system. Specifically, the team identified that the licensee had not maintained representative monitoring points and allowed an excessive time period between pipe wall thickness inspections. The licensees corrective actions included initiating an evaluation of the Microbiologically Influenced Corrosion Monitoring Program and documenting the issue in the corrective action program as condition reports CR-ANO-C-2016-00435, CR-ANO-C-2016-00524 and CR-ANO-C-2016-00546. The team did not identify a loss of structural integrity in any service water system pipe caused by these errors and therefore did not have an operability concern. The failure to implement the Microbiologically Influenced Corrosion Monitoring Program was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone objective and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to monitor service water system pipe locations for microbiologically influenced corrosion could result in a loss of pipe structural integrity (e.g., large pipe break) resulting in the loss of a service water train and adversely affecting safety-related equipment necessary for accident mitigation. The finding was evaluated using Inspection Manual Chapter 0609, Significance Determination Process, Attachment 0609.04, Initial Characterization of Findings, and Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2 Mitigating Systems Screening Questions, dated June 19, 2012. The team determined the finding was of very low safety significance (Green) because the finding was a deficiency affecting the design or qualification of a mitigating system, structure or component, but the system, structure or component maintained its operability. This finding had a human performance cross-cutting aspect of Conservative Bias because the licensee failed to ensure that individuals used decision-making practices that emphasized prudent choices over those that were simply allowed. Specifically, the program database contained errors related to non-conservative decisions regarding the impact of monitoring points following pipe replacement and limiting the maximum time between monitoring for wall loss (H.14). |
| 05000313/FIN-2016007-06 | 2016Q1 | Arkansas Nuclear | Failure to Correct Degraded Unit 2 Train B Emergency Diesel Generator Heat Exchangers Service Water Flow and Degraded Unit 1 Containment Coatings | The team identified two examples of a Green finding and an associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to correct conditions adverse to quality. Specifically, the licensee failed to correct long term degraded service water flow to the Unit 2 safety-related train B emergency diesel generator heat exchangers since 2008, and degraded Unit 1 reactor containment building coatings since 2009. The licensees corrective actions included performing an operability determination and determining that the service water system and the Unit 1 containment sump were operable and documenting the issue in the corrective action program as condition reports CR-ANO-C-2016-00946, and CR-ANO-1-2015-00200. The failure to correct conditions adverse to quality associated with Unit 2 service water flow to the B emergency diesel generator heat exchangers and the Unit 1 reactor containment building coatings was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to correct long term degraded: 1) service water flow beyond the action limit in accordance with procedure EN-DC-159, Component and System Monitoring, to the B emergency diesel generator heat exchangers, which challenged the capability of emergency diesel generator response to design basis events; and 2) containment coatings which challenged the Unit 1 emergency core cooling system capacity. The finding was evaluated using Inspector Manual Chapter 0609, Significance Determination Process, Attachment 0609.04, Initial Characterization of Findings, and Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, dated June 19, 2012. The team determined the finding was of very low safety significance (Green) because the finding was a deficiency affecting the design or qualification of mitigating system, structure or component, but the system, structure or component maintained operability. This finding had a human performance cross-cutting aspect of Design Margins because the licensee failed to place special attention on maintaining margins in safety related equipment. Specifically the licensee has repeatedly: 1) throttled service water flow away from the safety-related shutdown cooling heat exchangers, reducing the shutdown cooling design margins to maintain minimally acceptable flow to the emergency diesel generator heat exchangers since 2008; and 2) reduced the available containment sump margin rather than correct containment coating deficiencies (H.6). |
| 05000313/FIN-2016007-09 | 2016Q1 | Arkansas Nuclear | Emergency Feedwater Pump Casing Wall Loss Not Monitored | The team identified a Green finding and an associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, for the licensees failure to establish a test program for monitoring the Unit 1 emergency feedwater pumps casing wall thickness loss to demonstrate that the pumps would remain satisfactory for service. The scope of the Wall Thinning Aging Management Program included the emergency feedwater pumps casing. However, the team noted that the procedure did not include wall thickness measurements on the emergency feedwater pumps casings. The licensees corrective actions included performing an immediate operability determination and determining the pumps were operable, and documenting the issue in the corrective action program as condition report CR-ANO-1-2016-00606. The failure to establish a test program for monitoring the Unit 1 emergency feedwater pumps casing wall thickness loss was a performance deficiency. The performance deficiency was determined to be more than minor because, it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to monitor the Unit 1 emergency feedwater pumps casing wall thickness could result in a corrosion- or erosion-induced pump casing failure. The finding was evaluated using Inspection Manual Chapter 0609, Significance Determination Process, Attachment 0609.04, Initial Characterization of Findings, and Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2 Mitigating Systems Screening Questions, dated June 19, 2012. The team determined the finding was of very low safety significance (Green) because the finding was a deficiency affecting the design or qualification of a mitigating system, structure or component, but the system, structure or component maintained its operability. This finding had a human performance cross-cutting aspect of Work Management for failing to implement a process of planning, controlling, and executing work activities such that nuclear safety is an overriding priority. Specifically, the licensee entered the period of extended operation in May 2014 and had not established a surveillance procedure to monitor the corrosion induced wall loss of the pump casings as required by the approved aging management program (H.5). |
| 05000313/FIN-2016007-13 | 2016Q1 | Arkansas Nuclear | Failure to Update Probabilistic Risk Assessment Model in a Timely Manner Results in Failure to Submit Complete and Accurate Information | The team identified a Green finding for the licensees failure to update the Level 1 probabilistic risk assessment model as required by procedure EN-DC-151, Probabilistic Safety Assessment (PSA) Maintenance and Update, Revision 5. This finding also involved a Severity Level IV, non-cited violation of 10 CFR 50.9, Completeness and Accuracy of Information, because the licensee failed to submit complete and accurate model maintenance information in their license amendment request for the extension of the integrated leak rate testing for the Unit 1 reactor building. Procedure EN-DC-151 established requirements to ensure that ANOs models represent the as-built, as-operated plant in a manner sufficient to support the applications for which they are used, including performing periodic updates within four years of the previous update. The licensee had not updated the internal events model for Unit 1 since July 2009 and for Unit 2 since 2008. The licensees corrective actions included completing the model update for Unit 1 on April 15, 2016, for Unit 2 on February 29, 2016, and documenting the issue in the corrective action program as condition report CR-ANO-C-2016-01573. The failure to perform probabilistic risk assessment updates as required by procedure EN-DC-151 was a performance deficiency and therefore a finding. An NRC-identified violation of 10 CFR 50.9 was associated with this finding because it impacted the regulatory process in that inaccurate information was provided to the NRC that was material in making a licensing decision. Therefore, in accordance with Inspection Manual Chapter 0612, Appendix B, Issue Screening, this issue was evaluated using both the finding and traditional enforcement processes. This violation is associated with a finding that has been evaluated by the significance determination process and communicated with a significance determination process color reflective of the safety impact of the deficient licensee performance. The significance determination process, however, does not specifically consider the regulatory process impact. Thus, although related to a common regulatory concern, it is necessary to address the violation and finding using different processes to correctly reflect both the regulatory importance of the violation and the safety significance of the associated finding. The performance deficiency was determined to be more than minor because it was associated with the equipment performance and procedure quality attributes of the Mitigating Systems cornerstone objective and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the lack of a formal process to ensure that probabilistic risk assessment model updates were performed as scheduled impacted license amendment requests, performance indicator accuracy, and daily maintenance risk evaluations for planned and emergent maintenance activities since the internal events model was not reflective of current plant conditions. The finding was evaluated using Inspection Manual Chapter 0609, Significance Determination Process, Attachment 0609.04, Initial Characterization of Findings, and Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2 Mitigating Systems Screening Questions, dated June 19, 2012. The team determined the finding was of very low safety significance (Green) because it did not represent an actual loss of function of at least a single train for greater than its technical specification allowed outage time, and did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding, or severe weather initiating event. Consistent with Section 6.9 of the NRC Enforcement Policy, this violation was determined to be a Severity Level IV violation because inaccurate information was provided, but it would not have likely caused the NRC to reconsider its regulatory position or undertake substantial further inquiry. This finding had a human performance cross-cutting aspect of Resources because the licensee did not ensure that sufficient personnel resources were available to perform all probabilistic risk assessment duties, including model maintenance (H.1). |
| 05000313/FIN-2016007-16 | 2016Q1 | Arkansas Nuclear | Failure to Properly Calibrate Unit 1 Reactor Building Atmospheric Particulate Radiation Monitor RE-7460 | The team identified a Green finding and an associated non-cited violation of 10 CFR 20.1501(c) because the licensee failed to ensure that instruments and equipment used for quantitative radiation measurements were calibrated periodically for the radiation measured. Specifically, the licensee did not properly calibrate the Unit 1 Reactor Building Atmospheric Particulate Radiation Monitor RE-7460. The licenses corrective actions, included removing radiation monitor RE-7460 from service, instituting compensatory measures for assessing reactor coolant system leak detection in accordance with Technical Specification 3.4.15, RCS Leakage Detection Instrumentation, and documenting the issue in the corrective action program as condition reports CR-ANO-1-2016-00056 and CR-ANO-1-2016-01087. The failure to properly calibrate radiation monitor RE-7460 was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the plant instrumentation attribute of the Occupational Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure adequate protection of the worker health and safety from exposure to radiation from radioactive material. Specifically, the failure to properly calibrate radiation monitor RE-7460 adversely impacted its ability to be used to identify reactor coolant system leakage and the ability to assess radioactive airborne concentrations and dose rates. The finding was evaluated using the significance determination process in accordance with Inspection Manual Chapter 0609, Significance Determination Process, Attachment 0609.04, Initial Characterization of Findings, dated June 19, 2012, and Appendix C, Occupational Radiation Safety Significance Determination Process, dated August 19, 2008. The team determined that the finding was of very low safety significance (Green) because it was not an as-low-as-reasonably-achievable (ALARA) issue, there was no overexposure or substantial potential for an overexposure, and the ability to assess dose was not compromised. This finding had a human performance cross-cutting aspect of Documentation because the licensee failed to create and maintain complete, accurate and up-to-date documentation. Specifically, the licensee personnel failed to translate the vendor manual instruction to ensure the detector was installed against the hard stop so that it was in the correct position to make the calibration valid (H.7). |
| 05000313/FIN-2016007-01 | 2016Q1 | Arkansas Nuclear | Failure to Complete Extent of Condition Reviews for the Stator Drop Significant Condition Adverse to Quality Event | The team identified a Green finding and an associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, because the licensee failed to follow procedure EN-LI-102, Corrective Action Program, which required verification that the required action has been completed as intended. Specifically, for the extent of condition reviews for the stator drop event, two corrective actions were closed even though the actions were inadequate. The licensees corrective actions included re-performing the actions and documenting the failures in the corrective action program as condition reports CR-ANO-C-2016-00479 and CR-ANO-C-2016-00480. The failure to complete two of the extent of condition reviews associated with the stator drop event specified in the associated corrective action plan was a performance deficiency. The performance deficiency was determined to be more than minor because, it was associated with the design control attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the failure to complete actions related to identifying and correcting the extent of condition for a significant condition adverse to quality could potentially lead to an initiating event. The finding was evaluated using Inspection Manual Chapter 0609, Significance Determination Process, Attachment 0609.04, Initial Characterization of Findings, and Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 1 Initiating Events Screening Questions, dated June 19, 2012. The team determined the finding was of very low safety significance (Green) because the inadequate closure of corrective actions did not cause a reactor trip or the loss of mitigation equipment relied upon to transition the plant from the onset of a trip to a stable shutdown condition. This finding had a problem identification and resolution cross-cutting aspect of Resolution because the licensee did not take effective corrective actions to address issues in a timely manner commensurate with their safety significance. Specifically, the scope of the actions taken as part of the corrective actions did not resolve the issue as describe in the corrective action statement (P.3). |
| 05000368/FIN-2016007-07 | 2016Q1 | Arkansas Nuclear | Failure to Maintain Service Water Design Cooling to the Unit 2 High Pressure Safety Injection Pump Seal and Bearing Coolers | The team identified a Green finding and an associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to assure that the design basis service water cooling flow rates for the Unit 2 high pressure safety injection pump bearing and seal coolers were correctly translated into operating and surveillance procedures. Specifically, the pump surveillance and operating procedures were inadequate to monitor for, or correct degraded service water flow to the pump seal and bearing coolers. The procedures allowed for zero flow to the coolers, whereas the design drawing required 20 gallons per minute. The licensees corrective actions included performing an immediate operability determination and determining the pumps were operable based on the most recent surveillance flow tests, requesting a prompt operability determination, scheduling inspection of the seal and bearing coolers, and documenting the issue in the corrective action program as condition reports CR-ANO-2-2016-00672 and CR-ANO-2-2016-00674. The failure to correctly incorporate the design basis service water cooling flow for the Unit 2 high pressure safety injection pump coolers into the operating and surveillance procedures was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the design control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to incorporate the design basis service water cooling flow into the operating and surveillance procedures could result in the failure of the high pressure safety injection pumps during accident mitigation. The finding was evaluated Inspection Manual Chapter 0609, Significance Determination Process, Attachment 0609.04, Initial Characterization of Findings, and Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2 Mitigating Systems Screening Questions, dated June 19, 2012. The team determined the finding was of very low safety significance (Green) because the finding was a deficiency affecting the design or qualification of a mitigating system, structure or component, but the system, structure or component maintained its operability. The team did not identify a cross-cutting aspect for this issue because the cause of this performance deficiency was not reflective of current performance. |
| 05000368/FIN-2016007-10 | 2016Q1 | Arkansas Nuclear | Failure to Develop an Operability Decision-Making Issue for Degraded Condition on Safety Injection Tank | The team identified a Green finding for the licensees failure to create an operational decision making issue document per procedure EN-OP-111, Operability Decision Making Issue (ODMI) Process. Specifically, the licensee failed to evaluate the plant impact and operational challenges associated with not repairing safety injection tank check valve 2SI-13D bonnet leakage, which was identified prior to starting up from the fall 2016 outage. The leakage increased to the point where normal makeup capability was challenged. The licensees corrective actions included performing an unplanned shutdown to repair safety injection tank check valve 2SI-13D, and documenting the issue in the corrective action program as condition reports CR-ANO-2-2016-00546, CR-ANO-C-2016-0948, and CR-ANO-C-2016-01348. The failure to establish operational decision making issue guidance per procedure EN-OP-111 to address safety injection tank check valve 2SI-13D leakage was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the equipment reliability attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the leak became an operational challenge, in that, operators were filling the safety injection tank for the majority of the shift. The finding was evaluated using Inspection Manual Chapter 0609, Significance Determination Process, Attachment 0609.04, Initial Characterization of Findings, and Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2 Mitigating Systems Screening Questions, dated June 19, 2012. The team determined the finding was of very low safety significance (Green) because it did not represent an actual loss of function of at least a single train for greater than its technical specification allowed outage time, and did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding, or severe weather initiating event. This finding had a problem identification and resolution cross-cutting aspect of Self-Assessment because the licensee did not conduct self-critical and objective reviews of degraded plant issue to determine whether they should be addressed using the operational decision making issue process (P.6). |
| 05000313/FIN-2016007-11 | 2016Q1 | Arkansas Nuclear | Pressurizer Block Valve Not Installed in the Qualified Environmental Configuration | The team identified a Green finding and an associated non-cited violation of 10 CFR 50.49(f) for the licensees failure to ensure that Unit 1 pressurizer block valve CV-1000, was installed in the qualified configuration. Specifically, the safety-related motor operated block valve was installed with the limit switch compartment facing downward instead of up. The licensees corrective actions included performing a prompt operability determination and determining the valve was operable, evaluating the extent of condition, and documenting the issue in the corrective action program as condition report CR-ANO-C-2016-00884. The failure to ensure the pressurizer motor operated block valve CV-1000 was in the qualified configuration was a performance deficiency. The performance deficiency was determined to be more than minor because, it was associated with the design control and equipment performance attributes of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, valve CV-1000 not being installed in the qualified configuration increased the possibility of leaking grease or accumulating condensation in the limit switch compartment which could cause failure, electrical shorts or erratic operation. The finding was evaluated using Inspection Manual Chapter 0609, Significance Determination Process, Attachment 0609.04, Initial Characterization of Findings, and Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2 Mitigating Systems Screening Questions, dated June 19, 2012. The team determined the finding was of very low safety significance (Green) because the finding was a deficiency affecting the design or qualification of a mitigating system, structure or component, but the system, structure or component maintained its operability. This finding had a problem identification and resolution cross-cutting aspect of Operating Experience because the licensee failed to systematically and effectively collect, evaluate, and implement relevant internal and external operating experience in a timely manner (P.5). |
| 05000313/FIN-2016007-12 | 2016Q1 | Arkansas Nuclear | Failure to Perform Predictive Maintenance on Safety-Related Medium-Voltage Switchgear | The team identified a Green finding for the licensees failure to fully implement procedure EN-DC-310, Predictive Maintenance Program, Revision 7. Specifically, the licensee failed to perform predictive maintenance-related thermography on medium-voltage safety-related electrical switchgear. The team identified that the predictive maintenance equipment list appropriately included the medium-voltage switchgear as components in the predictive maintenance program. However, the monitoring was not being scheduled or performed. The licensees corrective actions included performing an operability determination and determining that there was no impact to the performance of the switchgear, creating tasks to perform thermography, and documenting the issue in the corrective action program as condition report CR-ANO-C-2016-00571. The failure to perform predictive maintenance on safety-related medium-voltage switchgear as required by procedure EN-DC-310 was a performance deficiency. The performance deficiency was determined to be more than minor because it was 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. Specifically, degradation of safety-related medium voltage switchgear could go unidentified for extended periods, reducing system reliability. The finding was evaluated using Inspection Manual Chapter 0609, Significance Determination Process, Attachment 0609.04, Initial Characterization of Findings, and Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2 Mitigating Systems Screening Questions, dated June 19, 2012. The team determined the finding was of very low safety significance (Green) because it did not represent an actual loss of function of at least a single train for greater than its technical specification allowed outage time, and did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding, or severe weather initiating event. This finding had a problem identification and resolution cross-cutting aspect of Identification because the licensee did not identify issues completely, accurately, and in a timely manner. Specifically, the licensee did not identify that their implementation of the Predictive Maintenance Program did not appropriately address safety-related medium-voltage switchgear as requiring periodic thermography inspections (P.1). |