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05000530/FIN-2018002-03Palo Verde2018Q2Failure to Assess the Operability of a Degraded or Nonconforming Structure, System, or ComponentThe inspectors identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to evaluate conditions adverse to quality for impacts on the operability of the essential spray ponds.
05000352/FIN-2017003-02Limerick2017Q3Licensee-Identified ViolationLGS Unit 1 Renewed Facility Operating License, NPF- 39, and LGS Unit 2 Renewed Facility Operating License, NPF- 85, License Condition 2.C.(3) requires , in part, that Exelon Generation Company shall implement and maintain all provisions of the approved Fire Protection Program as described in the UFSAR. LGS Unit 1 and Unit 2 UFSAR Chapter 9A requires compliance with Branch Technical Position, Chemical Engineering Branch 9.5- 1, guideline C.5.b(1), to limit fire damage so that one train of systems necessary to achieve and maintain cold shutdown conditions from either the control room or emergency control station can be repaired within 72 hours. Contrary to the above, from July 2014 to December 2016, an unanalyzed condition existed in which an abnormal ESW system alignment placed two Fire Areas in noncompliance with the FSSD analysis described in the UFSAR. Specifically, in July 2014, ESW to RHRSW flow return valve, HV -011 -015A was de- energized and tagged closed following ESW system testing. With on ly one RHRSW return path available to the A ESW loop, a postulated fire in Fire Area 12 or Fire Area 18 could cause a single spurious valve operation of either spray pond bypass valves HV -012- 031A or HV -012 -031C, when the ESW system is aligned in the spray pond winter bypass mode. This condition would result in no return flow path for the A loop of ESW, which would in turn result in loss of cooling water to EDGs aligned to the A ESW cooling loop. The affected EDGs would be inoperable until the ESW system could be realigned to provide cooling water flow. This condition coupled with a loss of offsite power assumed in FSSD analysis would result in a loss of power to SRVs needed to transition both LGS units from hot shutdown conditions to cold shutdown conditions. Following the depletion of station batteries after 4 hours, until offsite power is assumed to be restored after 72 hours, direct current power would be lost to SRVs that are necessary to reduce plant pressure low enough to place the shutdown cooling system into service and establish cold shutdown plant temperatures. The failure to have a cold shutdown repair that could be implemented within 72 hours in accordance with the FSSD analysis described in the UFSAR, was a performance deficiency. 24 The performance deficiency was more than minor because it was associated with the protection against external factors (fire) attribute of the mitigating systems cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors determined that the finding was of very low safety significance (Green ), based on IMC 0609, Appendix F, Fire Protection Significance Determination Process , Attachment 1, Part 1: Fire Protection Significance Determination Process Phase 1 Worksheet, dated September 2013. The finding screened to Green based upon task 1.3.1 screening question A, since the inspectors determined that for conditions evaluated by Appendix F the reactors were able to reach and maintain hot shutdown. Specifically, LGS Units 1 and 2 would have been able to achieve and maintain hot shutdown during the period the unanalyzed condition existed. This would have been accomplished by using HPCI and SRVs for pressure and level control. Both units would have been capable of maintaining hot shutdown conditions with postulated fire damage until offsite power could be restored. Because this issue was of very low safety significance (Green) and Exelon entered the issue into the corrective action program as IR 3955705, this finding is being treated as a licensee identified NCV , consistent with Section 2.3.2.a of the Enforcement Policy.
05000529/FIN-2016001-03Palo Verde2016Q1Licensee-Identified ViolationTechnical Specification 5.4.1, Procedures, requires that procedures be established, implemented, and maintained covering the applicable procedures in Regulatory Guide 1.33. Regulatory Guide 1.33, Appendix A, Section 9 requires, in part, that maintenance that can affect the performance of safety-related equipment be properly preplanned and performed in accordance with written procedures. Contrary to the above, prior to October 1, 2015, licensee work management personnel failed to perform an activity affecting quality in accordance with written procedures. Specifically, the licensee did not conduct an adequate review of technical specification LCO implications of a planned Unit 2 essential spray pond outage in accordance with procedure 51DP-9OM08, Look Ahead Process. Work planners did not recognize that the removal of two spray pond piping spool pieces was an activity required to restore spray pond system operability and therefore did not establish a tracking mechanism to ensure that the spool pieces were removed before the Unit 2 essential spray pond A was declared operable. Consequently, the Unit 2 essential spray pond A would not have been able to provide cooling to the essential cooling water heat exchanger following a seismic event. The inspectors evaluated the significance of the issue under the Significance Determination Process, as defined in Inspection Manual Chapter 0609.04, Initial Characterization of Findings, and 0609 Appendix A, The Significance Determination Process (SDP) for Findings at-Power, dated June 19, 2012. Inspectors concluded the finding was of very low safety significance (Green) because all questions in Exhibit 2 could be answered no. The licensee entered the issue into the corrective action program as CR 15-08352. The licensee now plans and controls the removal and re-installation of spray pond spool pieces using the stations temporary modification process.
05000528/FIN-2015002-01Palo Verde2015Q2Failure to Verify the Design of the Essential Spray Pond System Crosstie ValvesThe inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, involving the failure to maintain adequate design control measures associated with the ultimate heat sink. Specifically, the essential spray pond crosstie valves did not meet design requirements established in Regulatory Guide 1.117, "Tornado Design Classification," as described in the Updated Final Safety Analysis Report. Consequently, if the crosstie valves were damaged by a tornado, the licensee would not have enough available water inventory to meet the mission time of the essential spray pond system. The licensee has added steps to their emergency operating procedure to instruct operators to open the crosstie valves to achieve and maintain long-term cooling subsequent to a design-basis tornado event, and is evaluating potential plant modifications. The licensee has entered this issue into the corrective action program as Palo Verde Action Request 4633058. The failure to verify the design of the essential spray pond system in accordance with Regulatory Guide 1.117 was a performance deficiency. This performance deficiency was more-than-minor and is a finding because it affected the protection against external factors attribute of the Mitigating Systems Cornerstone objective of ensuring the capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, if the crosstie valves were damaged by a tornado, the licensee would not have enough available water inventory to meet the mission time for one train of the essential spray pond system during accident conditions. The inspectors performed the initial significance determination for the performance deficiency using NRC Inspection Manual 0609, Appendix A, Exhibit 2, "Mitigating System Screening Questions," dated July 1, 2012. The finding required a detailed risk evaluation because it involved the potential loss of a safety system, in that after at least 13 days of spray pond operation, operators were required to open the spray pond cross-connect valve to enable one train of the ultimate heat sink to use both trains of spray pond inventory. A Region IV senior reactor analyst performed a detailed risk evaluation. The design basis accident mission time was 30 days. However, the probabilistic risk assessment mission time was only 24 hours. Since the spray ponds could still perform the probabilistic risk assessment function for the probabilistic risk assessment mission time, this finding was of very low safety significance (Green). The change to the core damage frequency was much less than 1E-7/year. The finding did not contribute to the large early release frequency. Because the most likely cause of the finding does not reflect current licensee performance, no cross-cutting aspect is assigned to this finding.
05000528/FIN-2014005-01Palo Verde2014Q4Failure to Verify the Adequacy of the Design of the Diesel Fuel Oil CoolerThe inspectors reviewed a self-revealing Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to adequately review the suitability of materials of the diesel fuel oil cooler. Specifically, the Unit 2 A diesel generator fuel oil cooler design allowed for the interface of two dissimilar metals which promoted galvanic corrosion. This corrosion ultimately affected the structural integrity of the cooler and rendered the A Essential Spray Pond inoperable. In response to this, the licensee has replaced all six of the fuel oil cooler covers and initiated a design change to remove the fuel oil cooler from service. The licensee has entered the issue into the corrective action program as Condition Report Disposition Request 4543394. The failure to verify the adequacy of the design of the diesel fuel oil cooler was a performance deficiency. The performance deficiency is more than minor because it affected the equipment performance attribute of the Mitigating Systems cornerstone to ensure the availability, reliability, capability of systems that respond to initiating events to prevent undesirable consequences. Specifically the Unit 2 A diesel fuel oil cooler design allowed for the interface of two dissimilar metals which promoted galvanic corrosion. The corrosion ultimately affected the structural integrity of the cooler and rendered the Unit 2 A spray pond inoperable. In accordance with NRC Inspection Manual 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions. The finding screened to a detailed risk evaluation because it involved a potential loss of one train of safety related equipment for longer than the outage time allowed by technical specifications. By performing a detailed risk evaluation, a Region IV senior reactor analyst determined that the associated change to the core damage frequency was 1.5E- 7/year (Green). The dominant core damage sequences included loss of offsite power events that lead to station blackout conditions. The gas turbine generators and the auxiliary feedwater system helped to minimize the risk. This finding has no cross-cutting aspect because it is not indicative of current performance.
05000397/FIN-2014004-01Columbia2014Q3Failure to Comply with Ultimate Heat Sink Technical Specification Level RequirementsThe inspectors identified a non-cited violation of Technical Specification 3.7.1, Standby Service Water System and Ultimate Heat Sink, for the licensees failure to take the required actions for an inoperable ultimate heat sink. Specifically, the licensee failed to take action, as required by the plants technical specifications, when the water level in an individual ultimate heat sink spray pond was less than 432 feet 9 inches mean sea level. Following discovery of this issue, the licensee issued a night order and revised procedures to specify that both standby service water spray ponds had to be greater than 432 feet 9 inches MSL to meet the plants technical specification surveillance requirements. The licensee entered this issue into their corrective action program as AR 312706. The performance deficiency was more than minor because it affected the equipment performance 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. The inspectors performed the initial significance determination for the performance deficiency using NRC Inspection Manual 0609, Appendix A, Exhibit 2 Mitigating System Screening Questions, dated July 1, 2012. The finding required a detailed risk evaluation because it involved the potential loss of one train of a risk-significant system for longer than the technical specification allowed outage time. Therefore, a Region IV senior reactor analyst performed a detailed risk evaluation that determined that the finding was of very low safety significance (Green). The finding did not contribute to the large early release frequency. This finding had a cross-cutting aspect in the area of problem identification and resolution, selfassessments, because a 2013 self-assessment was not critical and thorough when reviewing the use of average spray pond level to meet technical specification inventory requirements.
05000528/FIN-2014004-01Palo Verde2014Q3Failure to Translate Design Basis Requirements for Establishing Operability of Spray Pond SystemThe inspectors identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the failure to correctly translate the mission time of the essential spray pond system into a procedure used to determine operability. In response to the inspectors concerns, the licensee re-evaluated essential spray pond operability determinations that had used the erroneous 26-day mission time and concluded that acceptable margin was available to ensure the system would remain operable for the 30-day mission time. The licensee entered this issue into the corrective action program as Palo Verde Action Request 4550539. The failure to ensure that design basis information associated with the mission time of the essential spray pond system was correctly translated into a procedure used to determine operability was a performance deficiency. This performance deficiency was more than minor because if left uncorrected, it had the potential to lead to a more significant safety concern. Specifically, the failure to use the correct mission time when determining operability could establish nonconservative results that could lead to the essential spray pond system not being able to meet its design safety function. The inspectors performed an initial screening of the finding in accordance with NRC Manual Chapter IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, dated July 1, 2012, this finding is of very low safety significance (Green) because it: (1) was not a deficiency affecting the design or qualification of a mitigating system; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of a single train for greater than its 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 in accordance with the licensees maintenance rule program for greater than 24 hours. This finding has a cross-cutting aspect in the area of human performance because the licensee failed to create and maintain complete, accurate, and up-to-date documentation. Specifically, after initially recognizing the adverse condition, the licensee did not document a standing order or temporary procedure change to prevent operability evaluations from using the incorrect essential spray pond mission time.
05000528/FIN-2013009-03Palo Verde2014Q1Failure to Establish Adequate Procedures for an Alternate Source of Spray Pond InventoryThe team identified a Green, non-cited violation of Technical Specification 5.4.1, which states, in part, Written procedures shall be established, implemented, and maintained covering the following activities: Part a. The applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Section 6 of Regulatory Guide 1.33, Appendix A, requires procedures for combating emergencies and other significant events. Specifically, prior to January 24, 2014, emergency procedures to provide make-up water to the essential spray pond beyond its 26-day water inventory did not provide sufficient details and contained inaccuracies for supplying the essential spray ponds with water from the regional aquifer via a well. In response to this issue, the licensee confirmed that there had never been an event at the site for which the procedure would have been utilized. This finding was entered into the licensees corrective action program as Palo Verde Action Requests (PVARs) 4496901, 4497291, 4498167, and 4499085. The team determined that the failure to establish adequate procedures for an alternate source of spray pond inventory was a performance deficiency. This performance deficiency was more than minor because it adversely affected the Mitigating Systems Cornerstone attribute of Procedure Quality and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the continuous capability of the ultimate heat sink to perform its safety function beyond the 26-day inventory of the essential spray ponds was not ensured. In accordance with Inspection Manual Chapter 0609, Appendix A, 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 did not represent a loss of operability or functionality; did not represent an actual loss of safety function of the system or train; did not result in the loss of one or more trains of nontechnical specification equipment; and did not screen as potentially risk-significant due to seismic, flooding, or severe weather. The team determined that this finding did not have a cross-cutting aspect because the most significant contributor did not reflect current licensee performance
05000528/FIN-2013009-01Palo Verde2014Q1Failure to Translate Design Basis Requirements for Establishing Operability of the Spray Pond SystemThe team identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, which states, in part, Measures shall be established to assure that applicable regulatory requirements and the design basis, are correctly translated into specifications, drawings, procedures, and instructions. These measures shall include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled. Specifically, prior to February 7, 2014, the licensee used Engineering Calculation 13-NS-C088, Mission Times for EW, SP, SI, AF, and DG systems, for establishing a 26-day mission time of the spray pond system instead of a 30-day availability time as required by Regulatory Guide 1.27, Ultimate Heat Sink For Nuclear Power Plants, and approved in their safety evaluation report. Consequently, spray pond system operability determinations performed per Procedure 40DP-9OP26, Operations PVAR Processing and Operability Determination/ Functional Assessment, used the incorrect mission time. In response to this issue, the licensee performed a review of the operability determinations in question using 30 days for the mission time and confirmed that the spray pond system remained operable and maintained an adequate safety margin. This finding was entered into the licensees corrective action program as Palo Verde Action Request (PVAR) 4500910. The team determined that the failure to ensure that design basis information associated with the mission time of the spray pond system was correctly translated into a procedure used to determine operability was a performance deficiency. This performance deficiency was more than minor because it adversely affected the Mitigating Systems Cornerstone attribute of Equipment Performance and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to use the correct mission time when determining operability was a significant deficiency of design control in that operability determination evaluations could establish nonconservative results that could lead to the spray pond system not being able to meet its design safety function. 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 did not represent a loss of operability or functionality; did not represent an actual loss of safety function of the system or train; did not result in the loss of one or more trains of non-technical specification equipment; and did not screen as potentially risk-significant due to seismic, flooding, or severe weather. This finding had a cross-cutting aspect in the area of human performance because the licensee implemented an engineering study with inaccurate information establishing the incorrect mission time used in operability d.eterminations for the spray pond system.
05000528/FIN-2013005-04Palo Verde2013Q4Licensee-Identified ViolationTitle 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and be accomplished in accordance with these instructions, procedures, or drawings. Contrary to the above, on August 29, 2013, operations personnel failed to accomplish an activity affecting quality in accordance with procedures. Specifically, the operations personnel did not have a technical basis for declaring the essential spray pond system operable when it was not in a seismic configuration analyzed in the current licensing basis. Removal of a spray pond piping spool piece during planned maintenance on Unit 3 emergency diesel generator A resulted in the inoperable spray pond train. The inspectors evaluated the significance of the issue under the Significance Determination Process, as defined in Inspection Manual Chapter 0609.04, Initial Characterization of Findings, and 0609 Appendix A, The Significance Determination Process (SDP) for Findings at-Power. Inspectors concluded the finding was of very low safety significance (Green) because all questions in Exhibit 2 could be answered no. The licensee entered the issue into the corrective action program as PVAR 4450413.
05000352/FIN-2013007-01Limerick2013Q2Inadequate Fire Brigade TransportationThe NRC identified a Green, Non-Cited Violation (NCV) of License Condition 2.C.(3) of the Limerick Generating Station operating license, in that Exelon did not provide adequate procedural guidance for transporting the fire brigade and equipment to the spray pond pump house. Specifically, the existing fire procedure had incorrect guidance which would have needlessly delayed the fire brigade response. In response to this issue, Exelon initiated IR 1511763 and took prompt action to revise the affected procedures. The finding was more than minor because it negatively affected the protection against external factors (fire) attribute of the mitigating systems cornerstone as related to the objective of ensuring the reliability and availability of the Essential Service Water pumps and Residual Heat Removal Service Water pumps. The finding was determined to be of very low safety significance (Green) in accordance with Section D of Exhibit 2 in Appendix A of IMC 0609, The Significance Determination Process for Findings at Power, because the fire brigades response time was mitigated by other defense-in-depth elements such as: area combustible loading limits were not exceeded, installed fire detection systems were functional, and alternate means of safe shutdown were not impacted. The finding did not have a cross-cutting aspect because it was not indicative of current performance.
05000528/FIN-2013002-06Palo Verde2013Q1Licensee-Identified ViolationTitle 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and be accomplished in accordance with these instructions, procedures, or drawings. Contrary to the above, prior to November 8, 2012, the licensee failed to prescribe heat exchanger visual inspection procedures of a type appropriate to the circumstances. Specifically, on November 8, 2012, during a scheduled occupational safety area walkdown, the licensee identified through-wall leakage on the outside of a Unit 3 spray pond system drain line on the train A essential cooling water heat exchanger. The licensee declared the Unit 3 train A spray pond system inoperable and began actions to make immediate repairs. The licensees subsequent apparent cause investigation determined that pre-existing coating defects were likely present and the corrosion process had begun prior to the most recent visual inspection. The investigation also concluded that procedures for visual inspection of heat exchangers were inadequate in that they did not explicitly mentioned the need to inspect nozzles as potential areas subject to localized corrosion. Therefore, the pre-existing flaw in the Unit 3 drain nozzle had gone undetected during previous visual inspections. The licensee revised their heat exchanger visual inspection procedure to identify small heat exchanger nozzles as an area requiring additional emphasis and requiring documentation of nozzle inspection results. The inspectors concluded that the finding is of very low safety-significance (Green) because the as-found nozzle wall flaw would not have prevented the spray pond system from performing its safety function and the issue has been entered into the licensees corrective action program as PVAR 4285944.
05000397/FIN-2013002-05Columbia2013Q1Licensee-Identified ViolationTechnical Specification 5.4.1.a, Procedures, requires, in part, that written procedures be established, implemented, and maintained as recommended in Regulatory Guide 1.33, Revision 2, Appendix A, dated February 1978. Paragraph 8 of Regulatory Guide 1.33, Appendix A, requires specific procedures for surveillance tests. Contrary to the above, prior to February 14, 2013, Procedure OSP-SW-Q101, SW Spray Pond Average Sediment Depth Measurement, Revisions 0-8, were inadequate because the tool specified for use during the surveillance was inadequate for measuring the sediment in the service water basin. This finding was entered into the corrective action program as Action Request AR 278932. This finding was determined to be of very low safety significance because the procedure did not result in a loss of operability for the standby service water system.
05000528/FIN-2009005-01Palo Verde2009Q4Failure to Establish Adequate Procedures to Control Potential Tornado Borne Missile Hazards Near the Essential Spray PondsThe inspectors identified a cited violation of 10 CFR Part 50, Appendix B, Criterion V, \"Instructions, Procedures, and Drawings,\" for the failure of engineering personnel to establish adequate procedures to ensure evaluation and approval of transient missile hazards that have an effect on the operability of the essential spray ponds. Specifically, since January 15, 1997, civil engineering personnel failed to develop an adequate procedure to verify missile density criteria are not exceeded to ensure operability of the essential spray ponds during severe weather. Due to the licensees failure to restore compliance from the previous NCV 05000528/2008004-04 within a reasonable time, this violation is being cited in a Notice of Violation consistent with Section VI.A of the NRC Enforcement Policy. This issue was entered into the licensee\'s corrective action program as CRDR 3397839. The finding is more than minor because it is associated with the external factors attribute of the Mitigating Systems Cornerstone and affects the cornerstone objective of ensuring the reliability of systems that respond to initiating events to prevent undesirable consequences. Using Manual Chapter 0609.04, \"Phase 1 Initial Screening and Characterization of Findings,\" the finding was determined to have very low safety significance because the finding did not result in a loss of system safety function, an actual loss of safety function of a single train for greater than its technical specification allowed outage time, or screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. This finding has a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program because appropriate corrective actions were not taken to address safety issues and adverse trends in a timely manner, commensurate with their safety significance and complexity (P.1(d)) (Section 1R15)
05000528/FIN-2009002-01Palo Verde2009Q1Failure to Correct Deficient Condition for the Essential Spray Pond Chemical Addition System Valves High Failure RateThe inspectors identified a finding for the failure of engineering and maintenance personnel to adequately implement timely corrective actions for deficiencies associated with the essential spray pond sodium hypochlorite chemical addition system. Specifically, between May 2006 and March 2009, corrective actions to replace degraded sodium hypochlorite valves with a more reliable chemical addition system were not taken resulting in the Unit 2 spray pond Train A chemistry pH level being out of specification high on two occasions. This issue was entered into the licensees corrective action program as Palo Verde Action Request 3277070.The finding is more than minor because it is associated with the equipment performance attribute of the mitigating systems cornerstone and affects the cornerstone objective of ensuring the reliability of systems that respond to initiating events to prevent undesirable consequences. Using Manual Chapter 0609.04, Phase 1 Initial Screening and Characterization of Findings, the finding was determined to have a very low safety significance because the finding did not result in a loss of system safety function, an actual loss of safety function of a single train for greater than its Technical Specification allowed outage time, or screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. This finding has a crosscutting aspect in the area of human performance associated with decision making because the licensee did not communicate bases for decisions to personnel with a need to know such that work is performed safely in a timely manne
05000528/FIN-2009002-02Palo Verde2009Q1Failure to Perform an Adequate Operability Determination for High Chlorine in the Essential Spray PondThe inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the failure of operations personnel to follow procedures to declare the essential spray pond inoperable. Specifically, on November 13, 2008, operations personnel failed to follow procedures to declare Unit 2 essential spray Pond A inoperable and perform a 10 CFR 50.59screening when a compensatory measure, such as acid addition, was required to restore operability of the spray pond. This resulted in the performance of a calculation and an evaporative test to verify operability of essential spray Pond A for the mission time without taking credit for compensatory measures. This issue was entered into the licensee\'s corrective action program as Palo Verde Action Request 3258988. The finding is more than minor because it is associated with the equipment performance attribute of the mitigating systems cornerstone and affects the cornerstone objective of ensuring the reliability of systems that respond to initiating events to prevent undesirable consequences. Using Manual Chapter 0609.04, Phase 1 Initial Screening and Characterization of Findings, the finding was determined to have a very low safety significance because the finding did not result in a loss of system safety function, an actual loss of safety function of a single train for greater than its technical specification allowed outage time, or screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. This finding has a crosscutting aspect in the area of human performance associated with decision-making because safety-significant decisions were not verified to validate underlying assumptions and identify unintended consequences
05000528/FIN-2008004-04Palo Verde2008Q3Failure to Provide an Adequate procedure to Control Essential Spray Pond Missile HazardsThe inspectors identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion V, \"Instructions, Procedures and Drawings,\" for the failure of engineering personnel to establish adequate procedures to ensure evaluation and approval of transient missile structure hazards that have an effect on the operability of the essential spray ponds. Specifically, since January 15, 1997, civil engineering personnel failed to develop an adequate procedure to verify missile density criteria are not exceeded to ensure operability of the essential spray ponds during severe weather. This resulted in approximately 40 transient missile hazards being placed around Unit 1 spray Pond A without an approval or evaluation to ensure continued operability of the essential spray ponds. The licensee determined the spray pond was operable following a walkdown and evaluation of the missile hazards. This issue was entered into the licensee\'s corrective action program as Condition Report/Disposition Request 3224028. The finding is greater than minor because it is associated with the external factors attribute of the mitigating systems cornerstone and affects the cornerstone objective of ensuring the reliability of systems that respond to initiating events to prevent undesirable consequences. Using Manual Chapter 0609.04, \"Phase 1 Initial Screening and Characterization of Findings,\" the finding was determined to have a very low safety significance because the finding did not result in a loss of system safety function, an actual loss of safety function of a single train for greater than its technical specification allowed outage time, or screen as potentially risk-significant due to a seismic, flooding, or severe weather initiating event. This finding has a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program because appropriate corrective actions were not taken to address safety issues and adverse trends in a timely manner, commensurate with their safety significance and complexity (P.1(d)) (Section 1R13).
05000528/FIN-2008004-05Palo Verde2008Q3Failure to Perform an Operability Determination for High Chlorine in the Essential Spray PondThe inspectors identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion V, \"Instructions, Procedures, and Drawings,\" for the failure of operations and chemistry personnel to follow the corrective action program to ensure that potentially nonconforming conditions associated with the essential spray pond system were reviewed for operability. Specifically, between July 10, 2008, and July 11, 2008, operations and chemistry personnel failed to ensure all relevant information was reviewed for operability when the Unit 2 essential spray Pond A hypochlorite addition Valve 2-SPN-V494 was found open. This resulted in the essential spray pond chemistry pH and chlorine samples being delayed to the extent that the sample results were not reliable to assess operability. This issue was entered into the licensee\'s corrective action program as Condition Report/Disposition Request 3206115. The finding is greater than minor because it is associated with the equipment performance attribute of the mitigating systems cornerstone and affects the cornerstone objective of ensuring the reliability of systems that respond to initiating events to prevent undesirable consequences. Using Manual Chapter 0609.04, \"Phase 1 Initial Screening and Characterization of Findings,\" the finding was determined to have a very low safety significance because the finding did not result in a loss of system safety function, an actual loss of safety function of a single train for greater than its technical specification allowed outage time, or screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. This finding has a crosscutting aspect in the area of human performance associated with decision-making because safety-significant decisions were not verified to validate underlying assumptions and identify unintended consequences (H.1(b)) (Section 1R15).
05000397/FIN-2007005-02Columbia2007Q4Failure to Perform Adequate Structural Monitoring of Submerged StructuresThe inspectors identified an unresolved item for failure to perform adequate monitoring of the condition of three structures. The suppression chamber, the standby service water spray ponds, and condensate storage tank were within the scope of the maintenance rule, but the condition monitoring that was being done did not include the submerged portions of these structures, which is critical to the safety function. Until the submerged portions of these structures are examined, the inspectors cannot determine the safety significance, therefore, this issue is unresolved. Failure to perform adequate condition monitoring for safety-related structures within the scope of the maintenance rule and in accordance with licensee technical instructions is a performance deficiency and affects the Mitigating Systems Cornerstone. However, the inspector was unable to determine whether the performance deficiency involved degradation of the structures. In order to assess the significance of this issue, additional information is needed to determine whether degradation exists. The inspectors will review the results of the next inspection that includes the submerged portions of these structures. The suppression chamber, the standby service water spray ponds, and condensate storage tank are structures within the scope of the Maintenance Rule. These structures were all scheduled for periodic monitoring but the licensee\'s monitoring consisted of walkdowns of the above water portions of these structures, yielding little information concerning the actual condition of the structures\' ability to meet their intended safety function. Because the licensee performed some monitoring of these structures, this performance deficiency did not rise to the level of a violation of the Maintenance Rule. Until the submerged portions of these structures are examined, the inspectors cannot complete the inspection to determine the safety significance, therefore, this issue is considered an unresolved item (URI 05000397/2007005-02, Failure to perform adequate structural monitoring of submerged structures).
05000528/FIN-2006011-03Palo Verde2006Q310 CFR 50.59 Reviews not performed or Inadequate for multiple changes to spray pond chemistry control procedureA noncited violation of 10 CFR 50.59 was identified for making nine revisions to Procedure 74DP-9CY04, System Chemistry Specification, a procedure described in the Updated Final Safety Analysis Report between 1998 and 2004. Specifically, the licensee failed to perform evaluations for Revisions 3, 6, 8, 10, 12, 24, 28, 32, and 36 and performed inadequate evaluations for Revisions 10 and 36, to assess the potential impact of the changes on the safety-related components in the spray pond system. Each of these changes revised spray pond chemistry parameter limits which were subsequently determined to have contributed to heat exchanger fouling. Failure to adequately evaluate the impact of changes to the Chemistry Control Program was a performance deficiency. Because this violation had the potential to impact the NRC?s regulatory function, and because the associated significance was determined to be Green using Phase 3 of the significance determination process, this violation is being treated as a Severity Level IV violation. This issue was entered into the Corrective Action Program under CRDR 2902498. Because this violation was of very low safety significance and has been entered into the corrective action program, it is being treated as a noncited violation consistent with Section VI.A of the Enforcement Policy: NCV 05000528; 05000529; 05000530/2006011-03, 50.59 Reviews Not Performed or Inadequate for Multiple Changes to Spray Pond Chemistry Control Procedure.
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