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05000269/FIN-2010004-012010Q3OconeeFailure to Install Fiber Reinforced Polymer on Unit 1 Auxiliary Building Wall as required by ProcedureAn NRC-identified Non-Cited Violation (NCV) of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, was identified for the licensees failure to install Fiber Reinforced Polymer (FRP) on the Unit 1 Auxiliary Building wall in accordance with the installation procedure. The licensee had not identified and repaired all wall defects greater than 0.75 inches deep as required by Procedure TN/1/A/102145/01C, FRP Installation. The issue was entered into the licensees corrective action program as PIP O-10-7414. The inspectors determined that the licensees failure to follow the approved procedure for FRP installation was a performance deficiency. The performance deficiency was more than minor because it was associated with the external events attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective in that continued failure to identify wall defects could result in the FRP failing to provide the required reinforcing for protection against the differential pressures generated by on-site tornados. The inspectors determined the finding to be of very low safety significance (Green) because the licensees structural analysis determined that the overall structural integrity of the wall would not be affected. This finding had a cross-cutting aspect of taking corrective actions to address safety issues and adverse trends in a timely manner commensurate with their safety significance and complexity in the Corrective Action Program component of the Problem Identification and Resolution area in that corrective actions for a previously identified adverse trend of not following procedures were ineffective. (P.1(d)) (Section 1R18)
05000269/FIN-2010004-032010Q3OconeeEQ Components Not Installed in the As-Qualified ConfigurationAn NRC-identified non-cited violation of 10 CFR 50.49(l) was identified when the licensee did not follow the requirements for replacing components within EPAs when existing components qualified under the Division of Operating Reactors, Guidelines for Evaluating Environmental Qualification of Class 1E Electrical Equipment in Operating Reactors (DOR Guidelines), dated November 1979, were combined with replacement components qualified to current standards. The outboard Viking EPA terminal box and associated terminal blocks, not qualified under current standards, were left in 86 EPAs that had been upgraded and made available for use in safety-related or environmentallyqualified applications. The failure to replace or to justify reasons to the contrary for not replacing the Viking EPA outboard terminal box and terminal blocks was a performance deficiency. The performance deficiency was more than minor because if left uncorrected, the licensee could have used the non 10 CFR 50.49 qualified terminal blocks as an electrical pathway for environmentally qualified or safety related loads. The inspectors completed a Phase 1 screening and determined that the finding was of very low safety significance (Green) because the finding did not result in the actual loss of function of the equipment receiving signals or power supplied through the modified EPAs. The finding directly involved the cross-cutting area of Human Performance under the Proper Maintenance Practices aspect of the Resources component in that the terminal boxes and associated terminal blocks which were not qualified under current standards were left in EPAs that had been upgraded and made available for use in safety-related or environmentally-qualified applications. (H.2.a)
05000269/FIN-2010004-042010Q3OconeeUnqualified Electrical Penetration AssembliesA NRC-identified non-cited violation was identified for the licensees failure to comply with 10 CFR 50.49(f) in that Rosemount transmitters, Limitorque valve actuators, and electrical penetration assemblies (EPAs), each an item of electric equipment important to safety, were found installed in a configuration other than the tested configuration and the licensee did not establish the qualification of the installed configuration. The failure to comply with the requirements of 10 CFR 50.49(f) was a performance deficiency. The performance deficiency was more than minor in that if left uncorrected it could have adversely affected indication required by operators to diagnose and respond to an event or resulted in unexpected equipment response. The inspectors determined that a Phase 2 evaluation was required for the Rosemount transmitters with plastic shipping plugs installed because of a potential loss of safety function of the Low Pressure Injection system. The inspectors performed a Phase 2 and concluded that the finding was of very low safety significance (Green) because the ability to achieve hot shutdown was not affected. The other three conditions screened as Green in Phase 1 because the finding did not result in the actual loss of function of the transmitters with improperly torqued covers, the Limitorque actuators, or EPAs. The finding involved the cross-cutting area of Human Performance under the Procedures aspect of the Resources component in that the licensee failed to develop complete and accurate procedures and work packages for the installation and periodic maintenance of Rosemount transmitters. (H.2.c) (Section 4OA2.2)
05000269/FIN-2010004-052010Q3OconeeLicensee-Identified ViolationTS 3.3.14, Emergency Feedwater Pump Initiation Circuitry, required for one or more required Loss of Main Feedwater pump (LOMF) initiation circuits inoperable, that the affected EFW pumps be declared inoperable. Additionally, TS 3.7.5 required, in part, that three EFW pumps shall be operable. Contrary to the above, on October 21, 2009, the licensee identified sixteen instances over the last three years, distributed among all three units, where conditions for declaring the EFW pumps inoperable were met due to a lack of understanding of the effect of the circuitry on operability during unit startup following refueling outages. As a result, the appropriate TS Action Statement of TS 3.7.5, which required the licensee to initiate action to restore one EFW pump to operable status immediately, was not entered as required. The inspectors verified the licensee corrected the procedural inadequacies. This finding is of very low safety significance (Green) because the finding did not represent an actual loss of system safety function. The licensee entered the finding into their CAP as PIP O-09-6670.
05000269/FIN-2010004-062010Q3OconeeLicensee-Identified ViolationTS 3.10.1, Standby Shutdown Facility, requires the Reactor Coolant Makeup subsystemto be operable in Modes 1, 2 and 3 or to restore operability within seven (7)days. Contrary to the above, between July 2, 2010, and July 16, 2010, the licenseeremoved four structural support members on the exterior of the Unit 2 WestPenetration Room brick wall which adversely impacted the ability of the wall towithstand a seismic event. The result of a wall failure caused by a seismic eventwould have damaged cables associated with the Standby Shutdown Facility ReactorCoolant Makeup sub-system which were routed along the interior surface of the wall.The condition was identified on July 14, 2010, and the support members reinstalledby July 16, 2010. The inspectors verified that the licensee took prompt actions torestore the structural integrity of the Unit 2 West Penetration Room brick wall. Thelicensee entered the finding into their CAP as PIP O-10-5561.
05000269/FIN-2010004-072010Q3OconeeLicensee-Identified ViolationTechnical Specification 5.4.1.a required that procedures defined in RG 1.33 shall be established and implemented. RG 1.33, Appendix A, stated in part that written procedures covering procedure adherence shall be developed and implemented.NSD 303 details the Environmental Qualification (EQ) process and required the licensee verify or create new environmental qualification maintenance manual sections for newly installed EQ equipment. Engineering Directives Manual 601,Engineering Change Manual, Appendix K.1, Equipment Qualification Sub-Screen on Environmental Qualification (EQ), required that any modification to EQ equipment meet the requirements of NSD 303. Contrary to the above, during the period from2002 to 2009, the licensee failed to follow the EQ process outlined in NSD 303, in that the licensee failed to assess the potential impact on the environmental qualification aspects of the Viking and D.G. OBrien electrical penetration assemblies being modified and the equipment they serviced under postulated accident conditions to ensure the equipment was not adversely affected and the appropriate EQ documentation was created or updated. The finding was entered into the licensees corrective action program as PIP O-10-1383.
05000269/FIN-2010004-082010Q3OconeeLicensee-Identified ViolationEDM 601, Engineering Change Manual, Appendix K.1, Equipment Qualification Sub- Screen on Environmental Qualification (EQ), required that any modification to EQ equipment meet the requirements of NSD 303. NSD 303 required the licensee to verify or create new EQMM sections for newly installed EQ equipment. Contrary to the above, during the period from 2002 to 2009, the licensee failed to follow NSD 303 in that the licensee did not assess the potential EQ impact on the modified Viking and D.G. OBrien EPAs and the equipment they serviced under postulated accident conditions to ensure the equipment was not adversely affected and the appropriate EQ documentation was created or updated. The finding was entered into the licensees corrective action program as PIP O-10-1383.
05000269/FIN-2010004-022010Q3OconeePotential inoperability of condenser off gas radiation monitorsAn Unresolved Item (URI) was identified when water was observed in the 1-RIA-40 and 2-RIA-40 rotameters. The rotameters were downstream of the detectors indicating that the monitors had been affected by the presence of condensed water. Units 1 and 2 were operating at or near 100% RTP and the mechanical vacuum pumps were not in operation. At full power, the N-16 detectors near the main steam lines were used to determine primary-to-secondary leakage. However, these detectors cannot be relied on when the reactor was at low power or shutdown due to the absence of significant N-16 production. The condenser off-gas monitoring system served to detect primary-to-secondary leakage during operation at low power and when the unit was shut down. The inspectors identified that the condenser off-gas monitors for both Units 1 and 2 had water in the rotameters downstream and approximately three feet above the elevation of the noble gas monitor chamber and detector. Gas Bubbles were passing through the water and it was believed that the monitors detection chamber was also partially filled with water due to their location below the rotameters. The monitor had a horizontally oriented, fixed volume gas measuring chamber with a beta sensitive detector mounted at the end of the chamber. The fixed volume allowed quantification of noble gas entrained in the effluent stream in the event of primary to secondary side leakage. The presence of water in the chamber would reduce the sensitivity to any radioactive noble gases that may be present. Also water would shield the detector from beta particles further reducing the monitors sensitivity. The response due to noble gases adsorbed into the water should be dampened due to the time lag between changes in the gas concentration and the time it takes for the water to reach the new equilibrium. The licensee was performing an analysis on the operability of the detectors and the impact on the ability of the monitor to provide timely detection and quantification of a primary to secondary leak at shutdown and low power conditions. This issue is identified as URI 05000269, 270/2010004-02: Potential Inoperability of Condenser Off-Gas Radiation Monitors.
05000277/FIN-2003013-012003Q4Peach BottomFailure to Adequately Maintain the E2 Emergency Diesel GeneratorA self-revealing finding was identified for the failure to adequately maintain the E2 emergency diesel generator (EDG) between July 1992 and September 2003. This finding involved two apparent violations. An apparent violation of Technical Specifications was identified for the failure to maintain the maintenance procedure for installation of EDG adapter gaskets. The procedure did not incorporate certain vendor recommendations intended to provide proper sealing of the gaskets, leading to relaxation over several years that allowed combustion gases to enter the jacket coolant system. An apparent violation of 10 CFR 50 Appendix B, Criterion XVI, Corrective Actions was identified because Exelon did not correct a condition adverse to quality following two instances of low jacket water pressure observed on the E2 emergency diesel generator (EDG) in March and April 2003. Subsequently, the EDG failed due to a low jacket water pressure condition. This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and adversely affects the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events. The finding was assessed using a Phase 3 evaluation. The finding is of low to moderate safety significance (WHITE) at Unit 2 based on delta core damage frequency ( CDF) and delta large early release frequency ( LERF). The finding is of very low safety significance (GREEN) at Unit 3 based on CDF and LERF. The difference between the two units is attributable to differences in electrical bus loads. (Section 2.2)