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05000315/FIN-2018010-012018Q3CookRecord Retention Requirements of the Boron Injection Tank and its Associated Support StructureThe inspectors identified an Unresolved Item concerning the Title 10 of the Code of Federal Regulations, Part 50, Appendix B, and ASME Code requirements for the BIT and its associated support structure calculation of record. Updated Final Safety Analysis Report (UFSAR) Section 2.9.2 delineated the BIT Seismic Classification as Class 1. The BIT was part of the Emergency Core Cooling System piping system, and is Seismic Class I. In addition, UFSAR Table 6.2-1 and UFSAR Table 6.2-3 delineated the BIT was designed in accordance with ASME Boiler and Pressure Vessel Code, Section III, Class C. Additionally, Subsection C under Section IIII Article N-2111, stated, in part, The requirements of Section VIII of the Code shall apply to the materials, design, fabrication, inspection and testing, and certification of Class C vessels.... The inspectors reviewed Drawing No. 113E275; 900 Gallon BIT; Revision 5 which contained the design specification for the BIT. Also the inspectors reviewed Struthers Wells Calculation No. 2-70-07-30717; Seismic Stress Calculations for BITs; 07/02/1970 which contained the BIT support structure qualification. The inspectors reviewed Calculation No. DC-D-12-MSC-8 Attachment A, page A.10-10 and page A.9-28; Revision 2 which contained the applied nozzle loads at the BIT inlet and outlet nozzles. Lastly, the inspectors reviewed Document No. 546 CRI 109890; Westinghouse Purchase Order for BIT; 06/22/1970 which contained design requirements for the BIT. During the review of aforementioned design basis documents the inspectors identified the following examples in which the licensee did not have a calculation of record to address the following ASME code requirements: ASME Section VIII, Division 1, Subsection A, General Requirements, Part UG-22 titled Loading states, in part, the loadings to be considered in designing a vessel shall include: Internal or external design pressure (as defined in Par. UG-21), Impact loads, including rapidly fluctuating pressures: Weight of the vessel and normal contents under operating or test conditions. (This includes additional pressure due to static head of liquids), Superimposed loads such as other vessels, operating equipment, insulation, corrosion-resistant or erosion-resistant linings and piping, Wind loads, and earthquake loads where required, Reactions of supporting lugs, rings, saddles or other types of supports (see Appendices D and G) and the effects of temperature gradients on maximum stress. The inspectors identified that the licensee did not have a calculation of record to address the applied loadings due to dead weight of the vessel, fluid weight inside of the vessel, design temperature of 300 degrees Fahrenheit and earthquakes (Operating Basis Earthquake and Safe Shutdown Earthquake) on the BIT vessel shell and head ASME Section VIII, Division 1, Subsection A, General Requirements, Part UG-54 titled Supports states, in part, All Vessels shall be supported and the supporting members shall be arranged and/or attached to the vessel in such a way as to provide for the maximum imposed loadings (see Par. UG-22).. The inspectors identified that the licensee did not have a calculation of record to address the applied loadings due to the superimposed piping loads at the BIT inlet and outlet nozzle to the BIT support structure as well as the applied loading due to the design temperature of 300 degrees Fahrenheit. Secondly, the inspectors identified that no calculation of record existed for the welded connection between the support legs and the baseplate. Thirdly, no calculation of record existed for the welded connection between the support legs and the BIT. Lastly, the self-weight and self-weight seismic excitation of the support structure was not considered in the applied stresses of the support structure calculation of record. In response to the inspectors concern, the licensee initiated AR 2018-7104, Lack in Documentation for BIT 1-TK-11, 07/12/2018. In addition, the licensee performed an operability review and reasonably determined the BIT remained operable. Near the end of the inspection period, the licensee provided the inspectors additional information relevant to the calculation record retention requirements as defined by the ASME Code and the DC COOK Quality Assurance Program Document which will require additional review to determine whether a violation exists. Therefore, this issue is considered an unresolved item pending completion of inspector review and evaluation and discussion with the Office of Nuclear Reactor Regulation and Office of the General Counsel.
05000263/FIN-2018012-012018Q3MonticelloInboard Main Steam Isolation Valve Closure Time Test Acceptance Criteria Did Not Account for the Design Basis Accident Containment Back Pressure and Pneumatic Supply Operating PressureThe inspectors identified a Green finding and an associated NCV of Title 10 of the Code of Federal Regulations(CFR), Part 50, Appendix B, Criterion XI, Test Control, for the failure to assure that applicable requirements and acceptance limits contained in the inboard main steam isolation valve (MSIV) design documents were incorporated into their test procedure. Specifically, the inboard MSIV closure time acceptance criteria contained in Functional Test Procedure 0255-07-IA-2, Main Steam Isolation Valve Functional Checks Test, did not account for the elevated containment pressure and the expected lower pneumatic supply pressure expected during design basis accidents.
05000263/FIN-2018012-022018Q3MonticelloFailure to Implement Adequate Freeze Protection Monitoring for Condensate Storage Tank Instrumentation Piping in Response to Industry Operating ExperienceThe inspectors identified a Green finding and an associated NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to establish measures to ensure conditions adverse to quality are promptly identified and corrected. Specifically, the licensee failed to identify that monitoring of the CST instrument line heat tracing performed every 30 days was inadequate to assure the safety-related CST level instrumentation remained operable during extreme cold weather conditions
05000263/FIN-2018012-032018Q3MonticelloLicensee-Identified ViolationThis violation of very-low safety significance was identified by the licensee and has been entered into the licensee CAP. Therefore, this finding being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.Enforcement:Violation: Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that measures be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions. Updated Final Safety Analysis Report, Appendix I,Evaluation of High Energy Line Breaks Outside Containment,Table I.5-2, Table of System Effects,Revision 36P, listed the Division II emergency power system as available during HELBs outside containment. Contrary to the above, on July 29, 1974, the licensee failed to assure that applicable regulatory requirements and the design basis were correctly translated into specifications, drawings, procedures, and instructions. Specifically,the Division II emergency power system would not be available during a HELB outside containment.Procedure B.09.07-05, Operations Manual Section 4.16 kV Station Auxiliary, Revision 53,had actions that required entry into the lower 4kV area to permit repowering Division II emergency power systems but this area would be inaccessible during the event. Significance: The performance deficiency was determined to be more-than-minor because it was associated with the Mitigating Systems cornerstone attribute of Design Control and affected the cornerstone objective of ensuring the availability, reliability, and capability of mitigating systems to respond to initiating events to prevent undesirable consequences.Specifically, the performance deficiency resulted in a condition were the Division II emergency power system would not be available during HELBs outside containment. The inspectors assessed the significance of the finding using the SDP in accordance with IMC 0609, 11 Appendix A, The Significance Determination Process for Findings At-Power, using Exhibit 2, Mitigating System Screening Questions,and concluded the violation was of very-low safety or security significance (Green)because the licensee reasonably demonstrated an alternate strategy was available to timely reach and maintain cold shutdown conditions. Corrective Action References: CAP501000011837, CAP 50100001593
05000282/FIN-2018011-012018Q2Prairie IslandFailure to Justify Load Combinations Used in Main Steam Piping Stress AnalysisInspectors identified a Green finding and associated Non-Cited Violation of Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to correctly translate provisions from specified quality standards for load combinations into piping analysis. Specifically, in the analysis for the Class I main steam piping, the licensee combined the seismic Operating Basis Earthquake and safety relief valve operating loads by Square Root of Sum of Squares. Prairie Island Updated Safety Analysis Report and the Engineering Manual for piping system stress analysis do not permit the Square Root of Sum of Squares method for combining these loads.
05000282/FIN-2018011-022018Q2Prairie IslandPotential Failure to Protect Class I Structures, Systems,and Components from Tornado Generated Missiles

Inspectors identified a number of structure, systems,and components (SSCs) that lacked protection from tornado generated missiles. The following SSCs were identified: Division 1 and Division 2 Emergency Diesel Generators (D1/D2 EDGs)engine exhaust, fuel oil day tank vents, and main fuel oil storage tanks vents; and Diesel Driven Cooling Water Pumps (DDCWPs) main fuel storage tank vents, day tank vents, engine exhausts, and rooms ventilation intake and exhaust equipment. In various cases susceptible SSCs for redundant equipment (e.g. fuel tank vents) were right next to or within a few feet of each other such that a single missle could affect both trains of the system 

A review of the sites licensing bases, including the original FSAR, identified the D1/D2 EDGs and the DDCWPs as Class I, safety-related SSCs, which are required to be designed to withstand, without loss of capability, environmental phenomena including tornadoes and tornado generated missiles. Specifically, the current USAR Table 12.2-1, Classification Of Structures, Systems and Components, list both systems as Class I and has two notes of interest. Note 1 applies to the Diesel Generators and their associated (Main) Fuel Oil Storage Tank, which states, in part, The indicated Design Class I is applicable to D1/D2 Diesel Generators and associated(emphasis added) safety related components and systems. The second note is listed at the beginning of the Table, which states,in part,To determine detail design classifications and boundaries separating different design classes within the overall classification scheme listed here, refer to controlled drawings. A review of controlled drawings, including NF-39255-1, Flow Diagram Diesel Generators D1 & D2 Unit 1 & 2,Revision 85, and NF-39232, Flow Diagram Fuel & Diesel System Unit 1 & 2, Revision 86,showed the fuel oil vents for the main storage tanks, fuel oil vents for the day tanks,engine exhaust piping,mufflers, and silencers for the D1/D2 EDGs and DDCWPs were classified as safety-related Class I SSCs. A review of the current UFSAR identified the following sections of interest:The USAR Section 1.5.I, Overall Plant Requirements, Criterion 2 -Performance Standards, Answer, established in part The system and components designated Class I in Section 12, in conjunction with administrative controls and analysis, as applicable, are designed to withstand, without loss of capability to protect the public, the most severe environmental phenomena ever experienced at the site with appropriate margins included in the design for uncertainties in historical dataThe USAR Section 12.2.1.1.a, Classification of Structures and Components, defines Design Class I as Those structures and components including instruments and controls whose failure might cause or increase the severity of a loss-of-coolant accident or result in an uncontrolled release of substantial amounts of radioactivity, and those structures and components vital to safe shutdown and isolation of the reactor.The USAR Section 12.2.5.1.g.1, Protection for Class I Items, establishes, in part, that Class I items are protected against damage from: Missiles from different sources.These sources comprise: Tornado created missiles.The USAR Section 12.2.1.3.2.c., Tornado Loads, defines the design tornado driven missile as assumed equivalent to an airborne 4 x 12 x 120 plank travelling end-on at 300 mph, or a 4000 lbs automobile flying through the air at 50 mph and at not more than 25 feet above ground level.Based on the above, the inspectors were concerned the susceptible SSCs could lose the capability to perform their safety-related function if they were impacted by tornado generated missiles. For example, an impact to the fuel oil vents could crimp the vent path resulting in a vacuum inside the tanks that could collapse the tank and/or cause the associated fuel transfer pump to lose net positive suction head

The licensee provided a position paper proposing the susceptible SSCs identified by the inspectors were meeting their current licensing bases and no further actions were required. The inspectors disagreed, but decided to request support from the Office of Nuclear Reactor Regulation (NRR) to obtain clarification on the sites licensing bases related to tornado generated missiles. Planned Closure Action: The inspectors have requested NRR to provide clarification on the sites current licensing bases regarding tornado generated missiles required protection.Licensee Action: Licensee is considering doing a self-review of design and licensing basis of the fuel oil storage tank vent lines to understand and clarify design class of the lines

Corrective Action Reference:501000012997
05000440/FIN-2017008-012017Q4PerryFailure to Address the Susceptibility of the Condensate Storage TankLow Level Instrument Lines to FreezeThe team identified a finding of very-low safety significance (Green) and an associated NCV of Title 10 of the Code of Federal Regulations(CFR),Part 50, Appendix B, Criterion III, Design Control, and 10 CFR 50.63, Loss of All Alternating Current Power, for the licensees failure to evaluate the capability to transfer the high pressure core spray (HPCS)and the reactor core isolation cooling (RCIC) pumps suction source from the condensate storage tank (CST)to the suppression pool during cold weather conditions. Specifically, (1) monitoring of the CST level instrument lines heat tracing was inadequate to detect a credible common mode failure before the instrument lines would freeze and be rendered inoperable during normal operation, (2)the licensee did not address the condensate (CST) level instrument lines susceptibility to freeze during a cold weather loss of off-site power (LOOP) event with or without a design basis transient or accident, and (3)the licensee incorrectly evaluated the capability to transfer the HPCS pump suction source from the CST to the suppression pool during a cold weather station blackout (SBO) event. The licensee captured the issues within their Corrective Action Program (CAP) as Condition Report(CR) CR-2017-08685, CR-2017-08930, and CR-2017-09006. Corrective actions implemented included: increased the CST level instrument line heat tracing circuit monitoring frequency, revised the affected procedures ensured HPCS and RCIC are adequately aligned to the suppression pool during LOOP design basis events, and ensured a timely transfer of the HPCS and RCIC pump suctions to the suppression pool during a SBO. The performance deficiency was determined to be more-than-minor because it was associated with the Mitigating Systems cornerstone attribute of design control and 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 of the HPCS and or RCIC pumps to automatically transfer their suction source from the CST to the suppression pool upon reaching a low CST water level condition could damage the pump(s) thus preventing them to be used to mitigate a transient or accident. A detailed risk evaluation was performed and determined that the finding was of very-low safety-significance (Green). The team did not identify a cross-cutting aspect associated with this finding because it was not confirmed to reflect current performance due to the age of the performance deficiency. Specifically, the CST instrument lines were designed and the SBO coping strategy during cold weather was established more than 3 years ago.
05000440/FIN-2017008-022017Q4PerryInadequate Evaluation of Emergency Closed Cooling System Pipe SupportThe team identified a finding of very-low safety significance (Green) and an associated NCV of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the failure to consider all stresses resulting from the emergency closed cooling system as built pipe support 1P42-H1080 connection details. Specifically, the evaluation for the pipe support did not address the impact of rigid connections at both ends of the W8 steel post and of the lateral load on W21 auxiliary steel beam. The licensee captured the issues in their CAP as CR-2017-08986 and CR-2017-09043, reasonably determined the support remained operable, and planned to revise the affected structural analyses.The performance deficiency was determined to be more-than-minor because it was associated with the Mitigating Systems cornerstone attribute of design control and 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 analyze actual pipe configuration and to evaluate the W21 beam did not ensure the emergency closed cooling system and its safety-related supported loads would remain available and capable of providing their accident mitigating function. The finding screened as of very-low safety significance (Green) because it did not result in the loss of operability or functionality of mitigating systems. The team determined that this finding had a cross-cutting aspect in the area of human performance because the licensee did not recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Specifically, the licensee did not recognize this latent issue when revising the structural evaluation in 2015.
05000440/FIN-2017008-032017Q4PerryFailure to Verify the Capability to Manually Backwash the Emergency Service WaterStrainer during Loss of Offsite PowerThe team identified a finding of very-low safety significance (Green) and an associated NCV of 10 CFR Part 50, Appendix B, Criterion III, Design Control,for the failure to verify the capability to manually backwash the emergency service water (ESW) strainer during a LOOP. Specifically, the licensee credited the capability to manually backwash the ESW strainers during a LOOP. However, the associated differential pressure alarm setpoint did not ensure sufficient time to complete this activity because the alarms were set at the same value as the design differential pressure value assumed by the hydraulic calculations. The licensee captured the issue in their CAP as CR-2017-09033, reasonably determined ESW remained operable, and planned to revise the associated calculation and the alarm setpoint to ensure sufficient time to perform the required manual actions during a LOOP.The performance deficiency was determined to be more-than-minor because it was associated with the Mitigating Systems cornerstone attribute of protection against external factors and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the performance deficiency did not assure the ESW capability to supply the required minimum flow to its supported components. The finding screened as of very-low safety significance (Green) because it did not result in the loss of operability or functionality of mitigating systems. The team did not identify a cross-cutting aspect associated with this finding because it was not confirmed to reflect current performance due to the age of the performance deficiency. Specifically, the alarm set point was established more than 3 years ago.
05000266/FIN-2017007-012017Q3Point BeachFailure to Correct a Condition Adverse to Quality Associated with a Seismic Interaction of the Motor-Driven Auxiliary Feedwater PipingThe NRC identified a finding of very-low safety significance (Green) and an associated NCV of Title 10, Code of Federal Regulations (CFR), Part 50, Appendix B, Criterion XVI, Corrective Action, for the licensee failure to correct a Condition Adverse to Quality (CAQ) associated with a seismic piping interaction affecting the Motor Driven Auxiliary Feedwater (MDAFW) system. Specifically, the licensee identified a flange clearance to the Unit 1 MDAFW suction piping was nonconforming and captured it in the Corrective Action Program (CAP) as Action Request (AR) 01684524. However, the licensee closed the AR without correcting the CAQ. The licensee captured the inspectors concern in the CAP as AR 02212810 and performed an evaluation that reasonably concluded the MDAFW remained operable.The performance deficiency was determined to be more-than-minor because it was associated with the Mitigating Systems cornerstone attribute of protection against external factors and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The finding screened as of very-low safety significance (Green) because it did not result in the loss of operability or functionality of mitigating systems. Specifically, the licensee performed an operability determination which concluded the stresses resulting from the seismic interaction would reasonably be bounded by the applicable stress operability limits. The team did not identify a cross-cutting aspect associated with this finding because it was not confirmed to reflect current performance because the performance deficiency occurred more than 3 years ago. Specifically, the licensee closed AR 01684524 without correcting this CAQ on September 20, 2011.
05000266/FIN-2017002-022017Q3Point BeachFailure to Identify Non-Conforming Conditionsafter Receipt of Anchor Darling Double Disc Gate Valve Related Part 21 ReportThe inspectors identified a finding of very-low safety significance (Green), and an associated (NCV) of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action,for the licensees failure to identify a condition adverse to quality. Specifically, after receiving and reviewing the Flowserve 10 CFR Part 21 report, the licensee misunderstood the information provided and failed to identify 36 safety-related valves that were nonconforming. Of these 36 valves, 14 were identified as being susceptible to pin failure based on their torque setting, 6 of which had open or close safety functions. The licensee captured the inspectors concern in the CAP as AR 02212531, and AR 02212915. In addition, the licensee performed operability evaluations that concluded the affected valves remained operable.The performance deficiency was more-than-minor because it was associated with the equipment performance attribute of the Mitigating System and Initiating Event cornerstones, and adversely affected the cornerstone individual objectives. Using IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, the finding screened as of very-low safety significance (Green) by answering No to the questions contained in Exhibit 1, and in accordance with Exhibit 2, it did not result in the loss of operability or functionality of mitigating systems. The team did not identify a cross-cutting aspect associated with this finding because the most significant cause for the error was not reflective of current performance. Specifically, the Part 21 report and associated review by the licensee occurred in February 2013.
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