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Quarter | Site | Title | Description | |
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05000313/FIN-2018003-06 | 2018Q3 | Arkansas Nuclear | Reactor Power Transient Caused by the Turbine Bypass Valve Failing Open | The inspectors reviewed a self-revealed Green finding and associated non-cited violation of Arkansas Nuclear One, Unit 1, Technical Specifications 5.4.1.a, for the licensees failure to properly preplan maintenance that can affect the performance of safety-related equipment. Specifically, the licensee failed to properly pre-plan maintenance for the replacement of air supply tubing for turbine bypass valve CV-6687, which resulted in the failure of the air tubing, causing valve CV-6687 to fail open, which led to a manual reactor trip and a subsequent loss of the main condenser. |
05000313/FIN-2018003-05 | 2018Q3 | Arkansas Nuclear | Failure to Maintain Main Feedwater Pump B Discharge Pressure in Band Caused a Reactor Trip | The inspectors reviewed a self-revealed, Green finding and associated non-cited violation of Arkansas Nuclear One, Unit 1, Technical Specifications 5.4.1.a, for the licensees failure to implement Procedure OP-1102.002, Plant Startup, Revision 106. Specifically, control room operators failed to maintain main feedwater pump discharge pressure in the required band to control flow to the steam generators during a plant startup. As a result, the only operating main feedwater pump tripped on high discharge pressure, causing an automatic reactor trip. |
05000313/FIN-2018003-04 | 2018Q3 | Arkansas Nuclear | Failure to Verify Safety-Related 4160 V Breaker Operability Following Maintenance Activities | The inspectors reviewed a self-revealed Green finding and associated non-cited violation of Arkansas Nuclear One, Unit 1, Technical Specification 5.4.1.a, for the licensees failure to properly preplan maintenance that can affect the performance of safety-related equipment. Specifically, the licensee failed to perform post-maintenance testing to demonstrate component operability for the train A safety-related 4160 V switchgear A-303 breaker that provides power to the swing service water pump B (P-4B) after the breaker was racked in. The breaker subsequently failed to close when attempting to start the pump. |
05000313/FIN-2018003-03 | 2018Q3 | Arkansas Nuclear | Failure to Provide Complete and Accurate Information in a License Amendment Request to Change Emergency Action Level Requirements | The inspectors identified a Severity Level IV non-cited violation because the licensee provided inaccurate information to the NRC in a license amendment request for an emergency action level scheme change. Specifically, the licensee provided information about the availability of the postaccident sampling system building radiation monitor and the Unit 1 level instrumentation that was material to the licensing decision, but not accurate. The NRC approved an emergency action level scheme change on November 9, 2012 (ADAMS Accession No. ML12269A455) to allow Arkansas Nuclear One to adopt the Nuclear Energy Institute (NEI) 99-01, Revision 5, scheme. Subsequently, the licensee identified that two of their current emergency action level thresholds could not be implemented in accordance with their emergency classification procedure: On May 26, 2017, Condition Report CR-ANO-2-2017-03161 documented that postaccident sampling system building radiation monitor 2RX-9840 should be removed from all regulatory commitments because the postaccident sampling system had been removed from service, and its building would not be monitored for radiological releases. Radiation monitor 2RX-9840 was being used as a means to evaluate emergency action levels AU1, AA1, AS1, and AG1. In addition, it was used in the loss/potential loss of containment (CNB6) for fission product emergency action levels. The condition report noted that requirements for the postaccident sampling system had been removed from Arkansas Nuclear One licenses in August 2000 and the licensee had abandoned the systems valves (March 2003, EC-ANO-1779), removed power from the postaccident sampling system ventilation system (January 2004), and made radiation monitor 2RX-9840 nonfunctional (May 2008, Condition Report CR-ANO-2-2008-01439 and Work Order 150817). On March 15, 2018, Condition Report CR-ANO-C-2018-01121 documented that the Unit 1 level instrumentation set point used in emergency action level CA1 was below the indicating range of the instrument. The emergency action level indicated that a loss of Unit 1s reactor vessel inventory was shown by an indicated level less than 368 feet, 0 inches. Therefore, the lowest level indicated on the instrument would be higher than the level used in making the emergency classification decision. The inspectors reviewed the licensees license amendment request, dated December 1, 2011 (ADAMS Accession No. ML113350317), Proposed Emergency Action Levels Using NEI 99-01, Revision 5, Scheme, and the licensees response to a request for additional information dated July 9, 2012, (ADAMS Accession No. ML12192A090) to determine whether the conditions identified in the corrective action program existed at the time the licensee requested the license amendment and whether the request correctly described the instruments. The inspectors identified: The December 1, 2011, submittal incorrectly indicated that radiation monitor 2RX-9840 was a viable means of classifying emergency action levels AU1, AA1, AS1, and AG1, as well as providing input for the evaluation of fission product barrier emergency action levels. In the response to NRCs request for additional information (RAI) dated July 9, 2012, the licensee provided additional details about the super particulate iodine noble gas (SPING) radiation monitors used in this application. Response to Question 3 associated with emergency action levels AA1, AS1, and AG1 stated: Each SPING is associated with a particular ventilation pathway and provides continuous monitoring of air discharged via the respective release pathway. The license reviewer concluded that all of the SPING monitors included in the license amendment request were operable and continuously monitoring the specified release pathways, thereby being capable of measuring the radiation levels described in the proposed emergency action levels. 17 The December 1, 2011, submittal indicated that loss of Unit 1 reactor vessel inventory for emergency action level CA1 was a vessel level less than 368 feet, 0 inches. This issue was NRC-identified because when the licensee identified the emergency action level errors, they took action to correct the errors, but failed to address the failure to ensure that technical information provided to the NRC in support of the license amendment request was complete and accurate in all material respects. Corrective Actions: To correct the Unit 1 reactor vessel level emergency action level threshold error, the licensee issued communications regarding correct application of the emergency action level on March 15, 2018, followed by implementation of a change to Procedure OP-1903.010, Emergency Action Level Classification, Revision 56, dated June 26, 2018, with the corrected level. The use of radiation monitor 2RX-9840 is being removed from the emergency action levels as part of an emergency action level scheme change submitted to the NRC on March 29, 2018 (ADAMS Accession No. ML18088B412 and ML18094A155). In the interim, the licensee issued communications to emergency director-qualified staff members to ensure they are aware of the error, how to address it if implementing emergency action levels, and to inform them of the corrective actions in progress. Additionally, the licensee issued Condition Report CR-ANO-C-2018-03597, dated September 13, 2018, for the incomplete and inaccurate emergency action level submission examples to address the completeness and accuracy issues identified by the inspectors. |
05000313/FIN-2018003-02 | 2018Q3 | Arkansas Nuclear | Failure to Implement Welding Standard Guidance and Examination Procedures | The inspectors reviewed a self-revealed Green finding and associated non-cited violation of Arkansas Nuclear One, Unit 1, Technical Specification 5.4.1.a, for the licensees failure to properly preplan maintenance that can affect the performance of safety-related equipment. Specifically, the licensee failed to implement welding standard guidance and examination procedure guidance during the installation of the high pressure injection system drain line containing drain valves MU-1066A and MU-1066B. The drain line weld developed a crack that caused a leak shortly after plant startup that was determined to have been caused by grinding during the welding process, which was not permitted by the welding standard. |
05000313/FIN-2018003-01 | 2018Q3 | Arkansas Nuclear | Failure to Translate the Design Requirements into Instructions for Refueling Emergency Diesel Generators | The inspectors identified a Green finding and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to translate current design into instructions for Unit 1 and Unit 2 diesel fuel oil transfer system. Specifically, the licensee failed to translate the current diesel fuel oil transfer system design into instructions to refuel Unit 1 and Unit 2 safety-related fuel bunkers, T-57 and 2T-57, if the non-safety bulk diesel fuel oil tank T-25 was unavailable following a design basis event (e.g., tornado, external flooding, or earthquake) for which it was not designed to withstand. |
05000313/FIN-2018002-01 | 2018Q2 | Arkansas Nuclear | Failure to Implement Procedural Guidance to Close Spent Fuel Pool Cooler Outlet Crosstie Valve | The inspectors reviewed a self-revealed, Green finding and associated non-cited violation of Arkansas Nuclear One (ANO) Unit 1 Technical Specification (TS) 5.4.1.a for the licensees failure to implement Procedure OP-1102.015, Filling and Draining the Fuel Transfer Canal, Revision 44. Specifically, operators failed to close spent fuel pool cooler outlet valve SF-9 while lining up to fill the fuel transfer canal (FTC) from the borated water storage tank (BWST). As a result, the licensee drained approximately 2600 gallons from the SFP to the FTC. |
05000313/FIN-2018001-03 | 2018Q1 | Arkansas Nuclear | Licensee-Identified Violation | Title10CFR20.1501(a) requires that each licensee make or cause to be made surveys that may be necessary for the licensee to comply with the regulations in 10 CFR Part 20, and that are reasonable under the circumstances to evaluate the magnitude and extent of radiation levels, concentrations, or quantities of radioactive materials, and the potential radiological hazards that could be present.Contrary to the above, on August 7, 2017, the licensee failed to make necessary surveys of the Unit 2, 2T-15 tank room, that were reasonable to evaluate the magnitude and extent of radiation levels that could be present. Consequently, workers were allowed access to an area with dose rates up to 1000 millirem per hour at 30 cm without a proper briefing or oversight 17 Significance: Using NRC Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, the inspectors determined the finding to be of very low safety significance (Green) because: (1) it was not associated with as low as is reasonably achievable (ALARA) planning or work controls; (2) there was no overexposure; (3) there was no substantial potential for an overexposure; and (4) the ability to assess dose was not compromised.Corrective Action Reference(s): CR-ANO-2-2017-04634 and CR-ANO-2-2017-0533 |
05000368/FIN-2018001-02 | 2018Q1 | Arkansas Nuclear | Failure to Preplan and Perform Service Water Pre-Screen Maintenance | The inspectors reviewed a self-revealed,non-cited violation and associated finding of Arkansas Nuclear One, Unit 2, Technical Specification 6.4.1.a, for the licensees failure to properly preplan maintenance that can affect the performance of safety-related equipment. Specifically, the licensee failed to properly preplan pre-screen cleaning maintenance, causing the trainB service water system to become inoperable |
05000313/FIN-2018001-01 | 2018Q1 | Arkansas Nuclear | Failure to Establish Adequate Criteria for Flood Seal Testing | The inspectors identified a Green finding and associated non-cited violation of Unit1 Technical Specification 5.4.1.a and Unit 2 Technical Specification 6.4.1.a for the licensees failure to establish the criteria for ensuring the necessary conditions existed for a successful test of hatch flood seals. Specifically, Procedure OP 1402.240, Inspection of Watertight Hatches, Revision 1, did not contain adequate guidance to ensure that the auxiliary building was at a lower pressure than the turbine building such that puffing smoke on the turbine building side would allow a seal leak to be detectable. |
05000313/FIN-2017003-01 | 2017Q3 | Arkansas Nuclear | Failure to Maintain Service Water Train Separation | The inspectors identified a non- cited violation of Technical Specification 5.4.1.a for the licensees failure to maintain train separation between safety -related service water trains when swapping the swing high pressure injection (HPI) pump between trains. Specifically, by following procedure OP 1104.002, Makeup and Purification System Operation, Revision 89, operators cross -tied service water trains, placing the system in an unanalyzed condition. This condition resulted in the train A electrical equipment room emergency chiller and train B reactor building emergency cooling coils being inoperable for a maximum of 25 minutes per occurrence. Additionally, it was determined that service water temperatures over the past 3 years did not result in an actual loss of function associated with these components if a design basis accident would have occurred. The immediate corrective actions were to assess past operability for not maintaining service water train separation and to revise Operating Procedure 1104.002 with adequate work instructions to maintain service water train separation. The licensee entered this deficiency into the corrective action program as Condition Report CR -ANO -1-2017- 02518. The licensees failure to maintain safety -related service water train separation when swapping the swing HPI pump between trains was a performance deficiency. The performance deficiency was more than minor because it was associated with the procedural quality attribute of the Mitigating Systems Cornerstone, and adversely affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events. Specifically, the licensees failure to maintain service water train separation placed the system in an unanalyzed condition and was subsequently determined to cause the train A electrical equipment room emergency chiller and train B reactor building emergency cooling coils to be inoperable for a maximum of 25 minutes per occurrence . Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Finding s At-Power, dated June 19, 2012, the inspectors determined that the finding had very low safety significance (Green) because it: was not a design deficiency; did not represent a loss of system and/or function; did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time; and did not result in the loss of a high safety -significant , non -technical specification train. Specifically, inspectors confirmed that service water temperatures were never high enough to result in an actual loss of function for either limiting component. The finding had 3 a cross -cutting aspect in the area of human performance associated with conservative bias because the licensee failed to determine whether the proposed action was safe to proceed, rather than unsafe in order to stop. Specifically, in December 2015 when this approach was revise d to declare only the non- protected service water train inoperable, the licensee did not ensure that the transition lineup was analyzed to be within safety analyses before adopting the revised steps. (H.14) |
05000368/FIN-2017002-02 | 2017Q2 | Arkansas Nuclear | Failure to Install Set Screw Leads to Breaker Failure | Green . The inspectors documented a Green self -revealing finding and associated non- cited violation of Unit 2 Technical Specification 6.4.1.a, for failure to properly pre-plan and perform maintenance on the Unit 2 containment spray pump B breaker in accordance with written procedures. Specifically, the licensee failed to install a cam shaft set screw during the breakers last overhaul. The cam eventually became displaced on the shaft, and the breaker failed to close. To correct the issue, the licensee replaced the breaker and installed a cam shaft set screw in the failed breaker. The licensee also inspected all other similar breakers to verify the cams were properly secured. The licensee entered the issue in to their corrective action program as Condition Report CR -ANO -2-2017- 03168. The failure to install a cam shaft set screw during the overhaul of the Unit 2 containment spray pump B breaker is a performance deficiency. The performance deficiency is 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 reliability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the performance deficiency resulted in the failure of a Unit 2 containment spray pump breaker. Using 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 not a design or qualification deficiency; did not represent a loss of system; did not result in the actual loss of function of a train of technical specification equipment for greater than its allowed outage time; and did not screen as potentially risk significant due to seismic, flooding, or severe weather events. The inspectors determined this finding did not have a cross -cutting aspect because the most significant contributor did not reflect current licensee performance. Specifically, the error occurred during the breakers last overhaul, which occurred in 2011 |
05000368/FIN-2017002-01 | 2017Q2 | Arkansas Nuclear | Failure to Follow Fire Protection Program Procedures | Green . The inspectors identified a finding and associated non -cited violation of License Conditions 2.C.( 3)(b), Fire Protection, for Arkansas Nuclear One Unit 2, associated with the failure to adequately implement the fire protection program. Specifically, the licensee failed to follow the requirements for control of flammable liquid lockers and compressed hydrogen gas cylinders. The licensee immediately removed the hydrogen cylinders and stored them in an approved location and began processing the flammable liquid lockers through the design change process. The licensee entered these issues into their corrective action program as Condition Reports CR -ANO -2-2017- 01525 and CR -ANO -C-2017 -01508 . The failure to properly control transient combustible material in accordance with the approved fire protection program was a performance deficiency. The finding was considered more than minor because storing unanalyzed flammable material could result in the potential to exceed combustible material limits , and is 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 power operations. Specifically, the failure to follow procedures resulted in conditions that increased the risk of fire which could upset plant stability and challenge critical safety functions. The inspectors evaluated the finding using Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, and assigned the finding to the Fire Prevention and Administrative Controls category; because it affected the licensees combustible materials control. The finding was determined to be Green, or very low safety significance, in accordance with Inspection Manual Chapter 0609, Appendix F, Question 1.3.1, because the reactor would have been able to reach and maintain safe shutdown since the postulated fires would not have affected both trains of safe shutdown equipment . This finding had a cross -cutting aspect associated with teamwork within the human performance area since multiple groups in the licensee staff were involved in the decisions that resulted in the improper introduction of the flammable liquids lockers and the improper storage of the hydrogen cylinders (H.4). |
05000313/FIN-2017008-02 | 2017Q2 | Arkansas Nuclear | Inadequate FLEX Procedures | Green. The team identified a finding with three examples for the licensee failing to assure that FLEX procedures were adequate for implementation of the strategies credited in the licensees Final Implementation Plan. This issue was entered into the licensees corrective action program as Condition Reports CR -ANO -C-2017- 00341, CR- ANO -C 2017- 00344, CR- ANO -1-2017 -00250, and CR -ANO -C-2017 00295. The failure to provide adequate procedures for responding to an extended loss of all AC power due to a flooding or high wind event was a performance deficiency. The performance deficiency was more than minor because it was associated with the protection against external factors attribute of the Mitigating Systems Cornerstone and adversely affected the Mitigating Systems Cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The significance of the finding was evaluated using NRC Inspection Manual Chapter 0609, Appendix O, Significance Determination Process for Mitigating Strategies and Spent Fuel Pool Instrumentation (Orders EA -12-049 and EA -12-051), dated October 7, 2016, and Appendix M , Significance Determination Process Using Qualitative Criteria, dated April 12, 2012. A bounding evaluation was performed using the exposure time, frequency of random failure of both emergency diesel generators , and tornado frequency or flood frequency . The licensees compliance date wit h the order was January 12, 2016, so an exposure time of one year was used. The random failure frequency of both units emergency diesel generators (3.15E -3/year) was selected since the emergency diesel generators are protected from damage during high wind and flood events. For the two examples impacted by flood events, t he flood frequency selected was for a flood exceeding the site grade elevation (8.47E -5/year). The change in core damage frequency for the se examples was determined to be 2.67E -7/year. For t he example which would only impact the licensee s response to a high wind event , the tornado frequency selected was for an F2 or greater tornado striking the site (5.31E -5/year). The change in core damage frequency for th is example was determined to be 1.67E -7/year. Therefore, the three examples of the finding were determined to of very low risk significance. The findi ng had a cross-cutti ng aspect in the Procedure Adherence co mponent of Human Performance becau se the lice nsee failed to adequately perform reviews required by the licensees procedure control program to confirm that : (1) instructions for implementing the strategies in the licensees Final Implementation Plan were complete and appropriate; and (2) reviews for affected procedures relat ed to other procedure revisions identified impacts on the implementing strategies and revised them appropriately (H.8). |
05000313/FIN-2017008-01 | 2017Q2 | Arkansas Nuclear | Inadequate FLEX Power Supply Connections | Green. The team identified a finding for the fail ure to assure that FLEX power supply connections would be reliable following all required postulated beyond design basis external events . Specifically, the team identified that one installed cable configuration could potentially be damaged during high wind events preventing operation of the portable diesel generator required to operate plant equipment. This issue was entered into the licensees corrective action program as Condition Report CR- ANO -C-2017- 00316. The failure to adequately ins tall the electrical modification for connecting the portable diesel generator was a performance deficiency. The performance deficiency was more than minor because it was associated with the protection against external factors attribute of the Mitigating S ystems Cornerstone and adversely affected the Mitigating Systems Cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The significance of the find ing was evaluated using NRC Inspection Manual Chapter 0609, Appendix O, Significance Determination Process for Mitigating Strategies and Spent Fuel Pool Instrumentation (Orders EA -12- 049 and EA -12-051), dated October 7, 2016, and Appendix M , Significance Determination Process Using Qualitative Criteria, dated April 12, 2012. A bounding evaluation was performed using the exposure time, tornado frequency, and frequency of a random failure of both emergency diesel generators. The licensees compliance date with the order was January 12, 2016, so an exposure time of one year was used. The tornado frequency selected was for an F2 or greater tornado striking the site (5.31E -5/year). The random failure frequency of both units emergency diesel generators (3.15E -3/year) was selected since the emergency diesel generators are protected from damage during high wind events. This is a conservative bounding analysis because it assumes that any tornado would result in damage causing a loss of offsite p ower and damage the cables in terminal panel 2TB1011 on the roof. The change in core damage frequency for the finding was determined to be 1.67E -7/year. Therefore, the finding was determined to a very low risk significance . The findi ng had a cross-cutti ng aspect in the challenge to the unknown co mponent of Human Performance becau se the lice nsee failed to adequately address all potential damage scenarios when developing the modification design requirements for beyond design basis external events (H.11) |
05000313/FIN-2017002-04 | 2017Q2 | Arkansas Nuclear | Licensee-Identified Violation | Title 10 CFR 50.55a(g)4, Inservice Inspection Standards Requirement for Operating Plants, states in part, Throughout the service life of a pressurized water -cooled nuclear power facility, components that are classified as ASME Code Class 1, Class 2, and Class 3 must meet the requirements set forth in Section XI of the ASME Code. The ASME Section XI, Article IWA - 2610, requires that all welds and components subject to a surface or volumetric examination be included in the licensees inservice inspection program. This includes identifying system supports in the inservice inspection plan, per ASME Section XI, Article IWA -1310. Contrary to the above, prior to March 9, 2017, the licensee did not ensure that all welds and components subject to a surface or volumetric examination were included in the licensees inservice inspection. Specifically, the licensee did not apply the applicable inservice inspection requirements for surface or volumetric examination to all portions of the Unit 2 emergency feedwater system within the system ASME Code Class 3 boundary. The licensee identified that they failed to include the emergency feed pump supports in their inservice inspection program. The licensee entered this issue into their corrective action program as Condition Report CR- ANO -2-2016 -01023 and reasonably determined the emergency feedwater system remained operable. The licensee restored compliance by inspecting the supports, with no degradation identified, and entering the emergency feedwater pump supports into the ASME Section XI program. The finding was of very low safety significance (Green) because the finding did not 34 represent an actual loss of safety function of a system or train and did not result in the loss of a single train for greater than technical specification allowed outage time. This issue was entered into the licensees corrective action program as Condition Report CR- ANO -2-2016- 01023. |
05000313/FIN-2017002-03 | 2017Q2 | Arkansas Nuclear | Failure to Comply with ECCS Technical Speci fications | Green . The inspectors reviewed a Green self -revealing finding and associated non -cited violation of Unit 1 Technical Specification 3.5.2, Emergency Core Cooling System (ECCS) Operating, for the licensees failure to ensure the operability of the P36A high pressure injection pump after reinstalling its feeder breaker during a unit outage. A violation of Unit 1 Technical Specification 3.0.4 was also identified for making a mode change without meeting the requirements to do so. Following unit restart, the pump failed to start during routine equipment rotation, resulting in one train of emergency core cooling system being inoperable for long er than allowed by Unit 1 Technical Specifications. The licensee subsequently identified that the feeder breaker had not been fully racked into position. Inspectors also noted that the breaker had been racked in manually rather than using the normal electric racking tool, and no special precautions had been taken to ensure this infrequently -used method was successful. When the breaker was correctly racked in, the pump was satisfactorily tested. The licensee subsequently verified that all similar breakers were correctly racked into position. The licensee entered this issue into their corrective action program as Condition Report CR- ANO -1-2017- 01764. The inspectors determined that the failure to verify that the P36A high pressure injection pump was operable after racking its feeder breaker into the switchgear cubicle was a performance deficiency. The performance deficiency was more than minor because it was associated with the human 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. 4 The inspectors performed the initial significance determination for the performance deficiency using NRC Inspection Manual 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, dated June 19, 2012 , and concluded that it required a detailed risk evaluation because it involved the loss of a single train of mitigating equipment for longer than the technical specification allowed outage time. Therefore, a Region IV senior reactor analyst performed a bounding detailed risk evaluation. The estimate in the increase in core damage frequency is 4.4 E-8 per year, or of very low safety significance (Green). This finding had a cross-cutting aspect in the area of Human Performance, Avoid Complacency, because the licensee failed to ensure that individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Specifically, the licensee failed to verify that the pump was operable after its breaker was rein stalled, even though an infrequently-used method was employed (H.12). |
05000323/FIN-2016010-01 | 2016Q3 | Diablo Canyon | Failure to Establish Adequate Work Instructions for Installation of Namco Snap Lock Limit Switches | The inspectors identified a preliminary White finding associated with an apparent violation of Technical Specification 5.4.1.a, Procedures, for the licensees failure to develop adequate instructions for the installation, adjustment, and testing of NamcoTM Model EA170 snap lock limit switches. Specifically, the licensee failed to provide site-specific instructions for limiting the travel of these external limit switches when installed on safety-related motor operated valves. Consequently, the lever switch actuator for valve RHR-2-8700B, residual heat removal pump 2-2 suction from the refueling water storage tank, was installed such that the limit switch was operated repeatedly in an over-travel condition resulting in a sheared internal roll pin that ultimately caused the limit switch to fail. Following identification of this issue, the licensee replaced the limit switch for valve RHR-2-8700B and implemented actions to modify maintenance procedures for installing, calibrating, and testing motor-operated valve external limit switches. The licensee entered this issue into their corrective action program as Notification 50852345. The performance deficiency is more than minor, and therefore a finding, because it is associated with the procedure quality 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 (i.e., core damage). Specifically, maintenance procedure MP E-53.10R, Augmented Stem Lubrication for Limitorque Operated Valves, used to perform limit switch adjustments on the Unit 2 valve RHR-2-8700B, did not provide adequate acceptance criteria to prevent overtravel of the limit switch actuating lever. This resulted in a subsequent failure of the limit switch, preventing the open permissive signal for valve SI-2-8982B, residual heat removal pump 2-2 suction from the containment recirculation sump, used during the emergency core cooling system (ECCS) recirculation mode. The inspectors evaluated the finding using the Attachment 0609.04, "Initial Characterization of Findings," worksheet to Inspection Manual Chapter (IMC) 0609, Significance Determination Process, issued June 19, 2012. The attachment instructs the inspectors to utilize IMC 0609, Appendix A, Significance Determination Process (SDP) for Findings At-Power, issued June 19, 2012. In accordance with NRC Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined that the finding required a detailed risk evaluation because it represented an actual loss of function of the train B ECCS for greater than its technical specification allowed outage time. A senior reactor analyst performed a detailed risk evaluation in accordance with IMC 0609, Appendix A, Section 6.0, Detailed Risk Evaluation. The calculated increase in core damage frequency was dominated by small and medium loss of coolant accident initiators with failures of the opposite train of ECCS or related support systems. The analyst did not evaluate the large early release frequency because this performance deficiency would not have challenged the containment. The NRC preliminarily determined that the increase in core damage frequency for internal and external initiators was 7.6E-06/year, a finding of low to moderate risk significance (White). The inspector did not identify a cross-cutting aspect with this finding because it was not reflective of current performance. The inadequate procedure was developed in 2011 and did not reflect the licensees current performance related to procedure development. |
05000275/FIN-2016001-01 | 2016Q1 | Diablo Canyon | Failure to Verify Adequate Design Airflow for 480 volt AC Switchgear and 125 volt DC Inverter Rooms | The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the failure to verify the design adequacy of the safety-related ventilation system for the 480-volt AC switchgear and 125-volt DC inverter rooms. Specifically, the licensee failed to verify sufficient ventilation system airflow to ensure the temperature in rooms housing safety-related electrical equipment remained below 104 degrees Fahrenheit. The licensees corrective actions were documented in Notification 50840266. The failure to provide design control measures to verify the adequacy of the 480-volt AC switchgear and 125-volt DC inverter rooms ventilation system design was a performance deficiency. The performance deficiency was 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 reduction in airflow to the rooms impacts the reliability of the safety-related equipment ventilation system to maintain the temperatures in these rooms below design limits for the duration of all accident scenarios. Using NRC Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined the finding was of very low safety significance 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. The inspectors determined that this finding did not have a cross-cutting aspect because the most significant contributor of this finding occurred more than three years ago, and is therefore, not representative of current licensee performance. |
05000382/FIN-2015004-01 | 2015Q4 | Waterford | Failure to Properly Pre-Plan and Perform Maintenance on the Core Element Assembly Calculators | The inspectors reviewed a self-revealing, non-cited violation of Technical Specification 6.8.1.a, associated with the licensees failure to properly pre-plan and perform maintenance in accordance with EN-DC-153, Preventative Maintenance Component Classification. The licensee entered this condition into their corrective action program as condition report CR-WF3-2015-06438. The licensee restored compliance by properly classifying the components as High Critical in accordance with EN-DC-153, Revision 2, and by initiating development of appropriate preventative-maintenance for the control element assembly calculators (CEACs). In addition, the licensee initiated work to improve the reliability of the CEACs, including reviewing card refurbishments to ensure circuit card reliability is enhanced. The performance deficiency was more than minor because it is associated with the Equipment Performance 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, inappropriate preventative maintenance on the circuit cards associated with the CEACs ultimately resulted in a plant trip on October 3, 2015. The inspectors screened the finding in accordance with NRC Inspection Manual Chapter (IMC) 0609, Significance Determination Process. Using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, the inspectors determined that the finding was of very low significance (Green) because the finding did not cause a trip and the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. Because the performance deficiency occurred in 2008, the inspectors concluded that the finding does not reflect current licensee performance and therefore did not assign a cross-cutting aspect. |
05000382/FIN-2015003-01 | 2015Q3 | Waterford | Failure to Establish Design Control Measures for Safety-Related Emergency Feedwater System Valves | The inspectors reviewed a self-revealing non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, because the licensee failed to verify the adequacy of the design of the emergency feedwater system. As a result, on June 3, 2015, following a manual plant trip that occurred due to a loss of the main feedwater system, the emergency feedwater back-up flow control valves oscillated so severely that control room personnel removed the system from automatic operations and manually controlled flow to the steam generators. The licensee entered this condition into their corrective action program as condition report CR-WF3-2015-03565. Long term corrective actions are to develop a modification to the system for better flow control, and complete testing that would demonstrate the automatic function of these valves. The performance deficiency is more than minor because it is 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 failure to ensure that the safety-related emergency feedwater back-up flow control valves would perform as designed, impacted the systems ability to perform its safety function during the feedwater loss event on June 3, 2015. A bounding detailed risk evaluation determined that the finding was of very low safety significance (Green) and was not significant to the large early release frequency. The dominant sequences included losses of off-site power, failure of the backup essential feedwater valves in the closed direction, and random failures of the primary essential feedwater flow control valves in the closed direction. The primary essential feedwater flow control valves and the diversity of the emergency feedwater system helped to minimize the risk. The finding does not have a cross-cutting aspect because the most significant contributor to the performance deficiency of not identifying the design flaws or the need for a test occurred more than two years ago and did not reflect current licensee performance. |
05000382/FIN-2015003-02 | 2015Q3 | Waterford | Failure to Follow Procedures when Changing Materials Used for Feedwater Heater Level Control Valves | The inspectors reviewed a self-revealing finding of very low safety significance that occurred because the licensee did not follow procedural guidance when changing materials used for feedwater heater level control valves. As a result, a feedwater heater normal level control valve failed unexpectedly, causing a trip of feedwater pump A and ultimately resulted in a plant trip. The licensee entered this issue into their corrective action program for resolution as condition report CR-WF3-2015-03563. The immediate action taken to restore compliance was to replace the valve internals with those of appropriate materials. The performance deficiency was more than minor because it was associated with the Design Control attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. A detailed risk evaluation determined that the finding was of very low safety significance (Green). The bounding change to the core damage frequency was less than 4E-7/year, and the finding was not significant with respect to the large early release frequency. The dominant core damage sequences included transients with the common-cause failure of the essential chilled water system and the failure of the turbine driven emergency feedwater pump. This finding has a cross-cutting aspect in the Evaluation aspect of the Problem Identification and Resolution area because the licensee did not thoroughly evaluate the causes of several previous feedwater level control valve failures. |
05000382/FIN-2015002-02 | 2015Q2 | Waterford | Failure to Follow Instructions in Painting Procedure while Painting on Safety-Related Equipment | The inspectors reviewed a self-revealing non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to follow procedure PMC-002-007, Maintenance and Construction Painting, while performing work on emergency diesel generator A. Specifically, while conducting painting activities in the emergency diesel generator cubicle between June 2014 and October 2014, the licensee failed to ensure that painting activities would not have an adverse impact on the moving parts and surfaces of the emergency diesel generator. Consequently, emergency diesel generator A failed to operate properly during a surveillance test on March 2, 2015. Immediate corrective actions included replacing the cylinder 7R fuel injector and fuel injection pump. The licensee restored emergency diesel generator A to operable status on March 4, 2015. The licensee entered this issue into their corrective action program as CR-WF3-2015-02626. This finding was more than minor because it was associated with the human 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, the licensee conducted painting on and around the emergency diesel generator in such a manner that paint was inadvertently deposited and remained in a location which caused the cylinder 7R fuel metering rod to jam at the full-fuel position, which ultimately caused emergency diesel generator A to fail its surveillance test on March 2, 2015, and be declared inoperable. Using NRC Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined that this finding was of very low safety significance (Green) because it did not represent a design or qualification deficiency, did not represent a loss of safety function for a single train for greater than its technical specification allowed outage time, and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. This finding has a Field Presence cross-cutting aspect in the area of Human Performance in that the licensee failed to provide adequate supervisory and management oversight of work activities to ensure deviations from standards and expectations were corrected promptly. |
05000382/FIN-2015002-01 | 2015Q2 | Waterford | Failure to Identify and Secure Potential Tornado-Borne Missile Hazards | The inspectors identified a non-cited violation of Technical Specification 6.8.1.a and Regulatory Guide 1.33, Revision 2, Appendix A, for the licensees failure to follow procedure OP-901-521, Severe Weather and Flooding, Revision 313. Specifically, on April 24, 2015, the licensee failed to assess and control potential tornado-borne missile hazards on-site as required by the procedure. The licensee entered this condition into their corrective action program as condition report CR-WF3-2015-02556. The licensee restored compliance by securing the identified hazards. This finding was 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 of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, in the event of a tornado at the site, the loose items could have become missiles with the potential to initiate a loss of off-site power adversely impacting safety-related equipment and personnel. The inspectors performed the initial significance determination for the finding using NRC Inspection Manual Chapter 0609, Appendix A, Exhibit 4, External Event Screening Questions, dated June 12, 2012. The finding required a detailed evaluation because it had the potential to degrade at least one train of a system that supports a risk significant system or function. Therefore, a senior reactor analyst performed a bounding detailed risk evaluation. The analyst determined that the finding was of very low safety significance (Green). The bounding change to the core damage frequency was less than 1.1E-7/year. The finding was not significant with respect to the large early release frequency. The dominant core damage sequences included tornado induced losses of off-site power, and random and common cause diesel generator failures. The ability to recover the diesel generators helped to minimize the significance of the event. The finding has a Resolution cross-cutting aspect in the area of Problem Identification and Resolution, because the licensee did not take effective corrective actions to address issues in a timely manner commensurate with their safety significance. Specifically, the licensee did not take effective corrective actions to address the issue after the inspectors identified it during previous tornado watches in 2013 and 2014. |