Semantic search

Jump to navigation Jump to search
 TitleQuarterDescription
05000298/FIN-2009005-09Failure to Follow Radiation Work Permit Requirements in Two Instances2009Q4The inspectors reviewed a self-revealing, noncited violation of Technical Specifications 5.4.1 involving two examples of a failure to follow Radiation Work Permit requirements. In the first example, workers were not monitored with telemetry and constant coverage by a radiation protection technician was not provided as required by the radiation work permit. In the second example, a worker was not monitored with telemetry as required by the special work permit. As a result, the licensee conducted a stand-down to reinforce expectations for compliance with radiation work permits, instituted management challenges at the access control point, and began conducting an apparent cause evaluation. This was entered into the licensees corrective action program as Condition Report CR-CNS-2009-08197 and CR-CNS-2009-08623. The inspectors determined that the failure to meet radiation and special work permit requirements was a performance deficiency. The finding is more than minor because it involved multiple failures of radiation protection measures which, if left uncorrected, could become a more significant safety concern. Using the Occupational Radiation Safety Significance Determination Process, the inspectors determined this finding had very low safety significance because the finding involved an ALARA planning and work controls and the licensees average collective dose is less than 240 person-rem per unit. The finding had a crosscutting aspect in the area of human performance associated with work practices because of the lack of self and peer checking to ensure work activities were performed safely (H.4(a)
05000298/FIN-2009005-10Failure to Correct Diesel Generator 2 Oil Leakage2009Q4A self-revealing noncited violation of 10 CFR 50 Appendix B, Criterion XVI, Corrective Action, occurred for the licensees failure to assure that a condition adverse to quality was corrected. Specifically, the licensee identified oil leakage on Diesel Generator 2 mechanical overspeed governor drive flange as a condition adverse to quality on June 23, 2009, and failed to correct the condition of oil leakage as demonstrated by a September 9, 2009, failure of the Diesel Generator 2 due to loose fasteners at this location. The licensee entered this issue in their corrective action program as CR-CNS-2009-06716. The finding is more than minor because it is associated with the equipment performance attribute of the mitigating systems cornerstone, and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events. Using the screening worksheet in Manual Chapter 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings, the inspectors determined that the finding has very low safety significance because it was not a design or qualification deficiency and did not result in the loss of any system safety function. This finding has a crosscutting aspect in the corrective action program component of the Problem Identification and Resolution area because the licensees periodic trends and assessments did not identify programmatic and common cause problems, in that the licensees periodic trends and assessments did not recognize the significance of precursor events related to fasteners loosening and prompt action to prevent further problems on the emergency diesel generators (P.1(b)
05000298/FIN-2009005-11Failure to Preclude Repetition of Loss of Shutdown Cooling2009Q4A self-revealing noncited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, was identified for the licensees failure to preclude repetition of a significant condition adverse to quality, namely the loss of shutdown cooling caused by drawing a vacuum in the reactor pressure vessel. Specifically, corrective actions taken after a March 17, 1994, loss of shutdown cooling event were inadequate to prevent a similar event from occurring on November 7, 2009. The licensee entered this issue in their corrective action program as CR-CNS-2009-09486. The finding is more than minor because it affected the procedure quality attribute of the mitigating systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). The inspectors determined that Manual Chapter 0609, Appendix G was applicable due to the fact that at the time of the performance deficiency was discovered, the plant was in a forced outage with residual heat removal system in service. Using Checklist 8 in Attachment 1, Shutdown Operations Significance Determination Process Phase 1 Operational Checklists For Both PWRs and BWRs, the inspectors determined that although the residual heat removal mitigation capability on the checklist was not met, the criteria for requiring a phase 2 or phase 3 analysis were not satisfied. The inspectors determined that no cross cutting aspects were appropriate for this finding due to the fact that the performance deficiency occurred in 1994 and is not reflective of current performanc
05000298/FIN-2009005-12Failure to Follow Procedure For Control of Material2009Q4A self-revealing finding was identified for the licensees failure to follow Administrative Procedure 0.47, Control of In-Process Material, Specifically, a maintenance technician violated the procedure by obtaining a spare o-ring from an uncontrolled toolbox and that o-ring was then installed in the Main Turbine Control Valve 3 hydraulic fitting. The o-ring was the wrong size and caused a hydraulic leak that required taking the turbine off line and shutting down the reactor from 70 percent power. The licensee entered this issue in their corrective action program as CR-CNS-2009-09606. The finding is more than minor because it adversely affected the configuration control attribute of the initiating events cornerstone, and adversely affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations, in that this finding resulted in a condition that prompted a plant shutdown from 70 percent power. In accordance with Manual Chapter 0609, Attachment 4, the inspectors used the Phase 1 Initial Screening and Characterization worksheet to determine that the finding has very low safety significance because it did not result in the loss of any system safety function. The cause of this finding is related to human performance cross cutting component of work practices because the involved maintenance personnel proceeded in the face of uncertainty when obtaining replacement o-rings (H.4(a)
05000298/FIN-2009005-13Procedure Noncompliance Causes Fire in Heater Bay2009Q4A self-revealing noncited violation of Technical Specification 5.4.1.d, Fire Protection Program Implementation, was identified for the licensees failure to follow Administrative Procedure 0.39, Hot Work. Specifically, contractors under the licensees control failed to consider weld pre-heating as an activity requiring hot work controls, and as such did not take the appropriate precautions for a pre-heating activity. As a result, a degraded pre-heating blanket failed in service, started a fire in the heater bay and resulted in declaration of a Notice of Unusual Event. The licensee entered this issue in their corrective action program as CR-CNS-2009-08061. The performance deficiency associated with this finding involved the licensees failure to follow the requirements of Administrative Procedure 0.39, Hot Work. Specifically, contractors performing work in the turbine building heater bay failed to consider weld pre-heating as an activity requiring hot work controls and did not take the appropriate precautions for the pre-heating activity. The finding is more than minor because it affected the external events aspect of the initiating events cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The inspectors determined that Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, could not be applied to shutdown plant conditions. Because the plant was shutdown at the time this performance deficiency occurred, the inspectors used Manual Chapter 0609, Appendix G, Shutdown Operations Significance Determination Process. Using Checklist 7 in Attachment 1, Shutdown Operations Significance Determination Process Phase 1 Operational Checklists For Both PWRs and BWRs, the inspectors determined that the finding had very low safety significance because every item on the checklist was met. This finding has a crosscutting aspect in the area of human performance associated with work practices because the licensee personnel failed to maintain adequate supervisory control over contractors performing welding in the turbine building heater bay (H.4(c)
05000298/FIN-2009005-14Licensee-Identified Violation2009Q410 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, requires, that activities affecting quality shall be accomplished in accordance with procedures that are appropriate for the circumstances. Contrary to this requirement, on October 4, 2009, the licensed operators failed to follow the guidance of Section 7.3 of Administrative Procedure 0.40, Work Control Program, Revision 68. Specifically, the licensed operators performed Surveillance Procedure 6.1RPS.313, RPS Channel Test Switch Functional Test (Div 1), instead of the scheduled Surveillance Procedure 6.2RPS.313, RPS Channel Test Switch Functional Test (Div 2). This performance deficiency was discovered by licensed operators during closeout of the work order and was documented in CR-CNS-2009-07618. This event demonstrated failure to effectively use error prevention tools. Specifically, the licensees two minute drill card specifically challenges workers to ensure they are working on the right division. Despite continued emphasis on human error prevention, the entire watchteam agreed to perform a surveillance test on the wrong division. The inspectors determined that this issue was of very low safety significance because no loss of system safety function resulted from the performance deficiency
05000298/FIN-2009005-15Licensee-Identified Violation2009Q410 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, requires, that activities affecting quality shall be accomplished in accordance with procedures that are appropriate for the circumstances. Contrary to this requirement, during preparation for refueling outage 25, the plant staff failed to follow the guidance of Section 5 of Administrative Procedure 0.50.5, Outage Shutdown Safety, Revision 12. Specifically, the licensed operators failed to manage the risks associated with an operation with the potential to drain the reactor vessel. This performance deficiency was discovered on September 27, 2009, while shut down in Mode 4, by a control room operator who noted reactor vessel water level lowering and was documented in CR-CNS-2009-07191. Reactor vessel water level control was lost for five minutes when an inadvertent drain path was established lowering vessel level four inches prior to restoring a positive rising level. The inspectors determined that this issue was of very low safety significance because no loss of system safety function resulted from the performance deficiency
05000298/FIN-2009005-16Licensee-Identified Violation2009Q410 CFR Part 50.72(b)(3)(v)(B) requires that any condition resulting in a loss of the residual heat removal safety function be reported to the NRC as soon as practical and in all cases within eight hours of the occurrence. Contrary to this requirement, on November 7, 2009, a human performance error resulted in an automatic isolation of the shutdown cooling system and a loss of the residual heat removal safety function and this loss of safety function was not reported as required. The licensee discovered this missed report during management review of the event on November 9, 2009 and identified the performance deficiency in CR-CNS-2009-09537. The inspectors determined that this issue is consistent with the examples of a SLIV violation in Supplement I, paragraph D.4 of the Enforcement Policy
05000298/FIN-2009005-17Licensee-Identified Violation2009Q4Technical Specification Limiting Condition for Operation 3.10.4 requires, in part, that to allow withdrawal of a single control rod with the reactor in Mode 4, all other control rods in a five by five array centered on the control rod being withdrawn are disarmed. Condition B.2.2 requires when a limiting condition for operation is not met with the affected control rod not insertable to immediately initiate actions to satisfy the requirements of this limiting condition for operation. Contrary to the above, on November 1, 2009, the licensee discovered that the control rods in the five by five array around a withdrawn control rod were not disarmed for over two hours without immediately taking the actions required by technical specification action statement B.2.2. This was documented in the licensees corrective action program by CR-CNS-2009-9138. Because the plant was shutdown at the time this performance deficiency occurred, the inspectors used Manual Chapter 0609, Appendix G, Shutdown Operations Significance Determination Process. Using Checklist 7 in Attachment 1, Shutdown Operations Significance Determination Process Phase 1 Operational Checklists For Both PWRs and BWRs, the inspectors determined that the finding had very low safety significance because it did not require quantitative assessment for a phase 2 or 3 analysis
05000298/FIN-2009007-01Failure to Follow Procedure Results in Inadequate Operability Determinations of Degraded Agastat Timer Relays2009Q2The team identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to follow the requirements of Procedure ENN OP 104, Operability Determinations. Specifically, between 2005 and 2009 operations personnel failed to perform adequate operability determinations of degraded and potentially degraded conditions associated with essential Agastat time delay relays with internal foreign material contamination that either needed an immediate operability determination or needed more information to reasonable assurance of operability. This included a potential degraded condition of the installed essential Relay 27X15-1G that the inspection team noted had a trend similar to relays that had previously failed with internal foreign material contamination. The licensee documented this condition with CR-CNS-2009-02844 and replaced the potentially degraded relay ten days later. This finding is more than minor because it affected the reliability objective of the equipment performance attribute of the Mitigating Systems Cornerstone to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). 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. The cause of this finding is related to the problem identification and resolution crosscutting aspect associated with the corrective action program because licensee personnel failed to thoroughly evaluate conditions adverse to quality and perform meaningful operability determinations (P.1(c))
05000298/FIN-2009007-02Licensee-Identified Violation2009Q2Title 10 CFR 20.1501 requires the licensee to adequately survey and evaluate the magnitude and extent of radiation levels. Contrary to the above, on December 30, 2008, a radiation protection technician discovered radiation dose rates of 500 millirem per hour at one foot near the spent fuel storage pool gates. This constituted a high radiation area as defined by licensee Technical Specification 5.7.1. The high radiation area was not originally identified during initial surveys taken on December 10, 2008. The high radiation area was caused by control rod blades on hangers on the northwest wall of the spent fuel pool in close proximity to the gates for the fuel transfer channel. The issue was more than minor because it was associated with the Program/Process attribute of the Occupational Radiation Safety Cornerstone and affected the cornerstone objective to ensure adequate protection of worker health and safety from exposure to radiation. The issue represents a finding of very low safety significance because it did not involve as low as is reasonably achievable planning or work controls, there was no overexposure, nor did a substantial potential for an overexposure exist given the radiological conditions in the area and the workers response to the electronic dosimeter alarm. The licensee\'s ability to assess worker dose was not compromised
05000298/FIN-2009010-01Adequacy of aging management for the torus2009Q4The team reviewed the results of the Section XI, Subsection IWE inspections to assess the effects of aging. The applicant began performing the Section XI, Subsection IWE-required 100 percent wetted area torus inspection in 2001. Because the torus had a continuously wetted surface with evidence of pitting, the applicant categorized their torus as Category E-C. The team evaluated the torus inspection results from 2001, 2005 and 2008. The torus acts as the containment liner and contains the suppression pool water and components. It is made of carbon steel, with thicknesses of the torus wall ranging from 0.616 inches in the general shell to 1.1875 inches at the ring girder joints and at the penetrations. Because carbon steel is susceptible to corrosion, it is coated with a zincbased paint. The zinc acts as a sacrificial anode, which is consumed over time. The torus has historically collected sludge and corrosion products, resulting in murky water and solid deposits that appear to exceed what is typical for boiling water reactors of that vintage. The applicant does not have a cleanup system to help maintain the water chemistry in the suppression pool. The coating applied to the inside of the torus is the original un-top-coated zinc-based paint, which has worn and been locally damaged. In areas where the coating is degraded or missing, the containment liner has experienced corrosion. Below the waterline in the suppression pool, there is significant pitting corrosion. The torus coating repairs performed following the installation of the tee quenchers had begun to degrade. The team reviewed inspection results that indicated 2091 pits have been identified in the wetted surface of the suppression pool containment liner. This is an active problem, as hundreds of new pits were identified at each inspection. The team reviewed inspection videos from the last torus inspection and noted areas with exposed metal and significant general corrosion, including catwalk bracing, tee quencher piping and supports, ring girders, downcomer bracing, and near penetration regions on the shell. Corrosion on structures and supports undergoing generalized corrosion contributed to the increasing volume of sludge being removed, indicating the problem is getting worse with time. The applicant has documented in a 2001 inspection that the torus coating system was in fair to poor condition. The team noted that the applicant has not scheduled any actions to correct this condition. The applicants evaluations show that the pitting corrosion does not have a significant affect on the torus structurally. The applicant performed a stress evaluation in accordance with the American Society of Mechanical Engineers, Section III, Subsection NE. From this evaluation, the applicant identified a minimum wall thickness of 0.153 inches. The team reviewed design calculations that established acceptance criteria for identified pits and provided coating repair criteria. All pits evaluated by the applicant remained well within the structural integrity acceptance criteria. The applicant coated all pits that measured greater than 0,030 inches near penetrations and 0.050 inches near ring girders. Although no pitting on the general shell required repair, the torus general shell had dense pitting at localized areas without coating that ranged from one to two mils deep with occasional depths of 40 to 50 mils. The applicant was taking the following actions to manage the corrosion: Visually inspect 100 percent of the wetted surface of the torus once each period as specified in their 10-year inservice inspection plan to identify pitting locations and measure pit depth. Pits that exceed a threshold (values vary by location) were covered with an epoxy coating that cures underwater to arrest corrosion. Pits that do not exceed the threshold were monitored for growth at the next inspection. All pits that were identified were recorded on a pit map. The applicant has considered coating repairs or replacement, but has not scheduled any action Based on the above, the team needed additional information to determine whether the applicant would effectively manage the effects of aging in the wetwell. The inspectors had the following observations and concerns: The expected life of the original coating was not documented in the final safety analysis report or other documents reviewed by the inspectors. A review of general information on this type of coating seems to indicate that the coating used at Cooper Nuclear Station should not be expected to have a 40-year service life. In addition, the inspection reports provided to the applicant discuss that un-top-coated zinc coatings have on average an expected life of 15 years. Based on the current degree of coating failure, it does not appear that the existing coating is suitable for another 20 years or service. Depletion of the zinc has reduced the ability to provide corrosion protection to the exposed steel substrate and localized coating failures have exposed areas of bare steel. If the zinc remained available in sufficient quantities, localized bare metal surrounded by intact coating should not be exhibiting active corrosion as it has been. The applicant has not been managing the coating failures by making coating repairs to areas that have had localized coating failures, whether above or below the waterline. This has apparently resulted in localized galvanic corrosion with high corrosion rates (pitting), instead of very low and predictable general corrosion rates. It has also contributed to the amount of sludge and corrosion products collecting in the suppression pool. Instead, the applicant has been allowing corrosion and applying an epoxy coating intended to arrest the pitting. The applicant was attempting to manage the pitting corrosion in the context of structural integrity without correcting the causes. The available data indicate that the condition worsened over time, so this method of aging management is not being successful. Pitting corrosion rates are typically much higher and less predictable than general corrosion rates, and a through-wall pit would impact containment integrity without necessarily impacting structural integrity. The inspectors concluded that while the applicant met their obligations under the ASME Code, so this is not a current safety concern. However, the ASME Code does not address consideration of plant life extension or determination of when a coating should be replaced. Because additional information is needed to determine whether the applicant had established a program to manage the effects of aging for the wetwell during the period of extended operation, this issue will be tracked as an unresolved item: URI 05000298/2009010-01, Adequacy of aging management for the torus.
05000298/FIN-2010002-01Repeat Failure to Follow Procedure for Initiating Condition Reports2010Q1The inspectors identified a noncited violation of 10 CFR 50 Appendix B, Criterion V, Instructions, Procedures and Drawings, regarding the licensees failure to follow the requirements of Administrative Procedure 0.5, Conduct of the Condition Reporting Process. Specifically, plant engineers performing an extent of condition review for errors in the internal flooding analysis failed to initiate condition reports for additional degraded or nonconforming conditions as they were identified. The licensee entered this issue in their corrective action program as CR-CNS-2010-01596. The inspectors determined that Manual Chapter 0612, Appendix E, Examples of Minor Issues provided no sufficiently similar examples, and that the finding is more than minor because it is 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. Using the Manual Chapter 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings, the inspectors determined that the finding has very low safety significance because all of the items in the Table 4a mitigating systems cornerstone checklist were answered in the negative. The finding has a crosscutting aspect in the area of problem identification and resolution because the licensee failed to take appropriate corrective actions to address previously identified examples of employees not initiating condition reports during extent of condition reviews (P.1(d)
05000298/FIN-2010002-02Inadequate Service Water Pump Room Loss of Heat Calculation2010Q1The inspectors identified a noncited violation of 10 CFR, Part 50, Appendix B, Criterion III, Design Control, for the licensees use of an incorrect post-accident service water flow rate in the design basis calculation of record. Calculation NEDC 91-232 determined the minimum service water pump room temperature following a loss of offsite power. The minimum service water flow during accident conditions is used to derive the heat input into the room by the service water pump motors. The calculation incorrectly assumed a value for the post-accident service water flow rate that was less conservative than the value defined in the updated final safety analysis report. In response to the inspectors concerns, the licensee initiated Condition Report CR-CNS-2009-10389 and revised the affected calculation. The inspectors determined that this performance deficiency was sufficiently similar to the not-minor-if description of Example 3.a, 3.l, 3.j and 3.k of Manual Chapter 0612, Appendix E, Examples of Minor Issues due to the fact the effected calculation had to be re-performed to demonstrate the operability of the service water system. As such, the inspectors determined that the finding was more than minor because it was associated with the design control attribute of the mitigating systems cornerstone, and adversely affected the cornerstone objective to ensure the availability, reliability and capability of systems that respond to mitigating events to prevent undesirable consequences. The inspectors determined that this performance deficiency was dissimilar from any other examples in Manual Chapter 0612, Appendix E. Using the Manual Chapter 0609 Exhibit 1, Initial Screening and Characterization of Findings, the issue screened as having very low safety significance because it was a design deficiency confirmed not to result in loss of operability in accordance with NRC Manual Chapter Part 9900, Technical Guidance, Operability Determination Process for Operability and Functional Assessment. The inspectors determined that no cross cutting aspect was applicable to this performance deficiency because the calculation error is not reflective of current performanc
05000298/FIN-2010003-01Failure to Document Design of Service Water Discharge Piping in Plant Drawings2010Q2The inspectors identified a non-cited violation of 10 CFR 50 App B Criterion III, Design Control, in which the licensee failed to maintain accurate design drawings of the service water system discharge piping. Specifically, Drawing BR 2120, Yard Circ. & Service Water Piping Plan & Sections, Revision 14 incorrectly identified the as-built configuration of the service water system discharge piping, and was used as a design input to numerous essential calculations. The licensee completed an operability evaluation that demonstrated that the service water was operable despite the condition. The licensee entered this issue in their corrective action program as Condition Report CR-CNS-2010-03689 The finding was more than minor because it affected 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 (i.e., core damage). This finding was characterized under the significance determination process as having very low safety significance because all of the screening questions in the Manual Chapter 0609, Attachment 4, Initial Screening and Characterization of Findings Phase 1 screening table were answered in the negative. The inspectors determined that no cross cutting aspect was applicable to this finding due to the age of the performance deficiency and the lack of recent identification opportunities.
05000298/FIN-2010003-02Failure to Place the Essential 4160 Volt Alternating Current System Agastat Relays in (a)(1)2010Q2The inspectors identified a noncited violation of 10 CFR 50.65(a)(2), requirements for monitoring the effectiveness of maintenance at nuclear power plants, for failure to demonstrate that the performance of the essential 4160 volt alternating current power system was effectively controlled through appropriate preventive maintenance. As a result, the licensee did not establish goals or monitor the performance of the essential power system Agastat relays per 10 CFR 50.65 (a)(1) to ensure appropriate corrective actions were initiated when a revised evaluation of a Agastat time delay relay failure incorrectly changed the initial functional failure determination. Incorrectly changing this maintenance preventable functional failure resulted in the affected function, EE-PF03A, not reaching the licensees maintenance rule (a)(1) threshold. The licensee entered this issue in their corrective action program as Condition Report CR-CNS-2008-07910 This finding is more than minor because it affected the reliability objective of the Equipment Performance attribute under the Mitigating Systems Cornerstone. The inspectors determined that this performance deficiency was an additional, but separate consequence of the degraded performance of the essential 4160 volt alternating current system Agastat relays. Following the guidance of Appendix B to MC0612 and Appendix D to IP 71111.12, the inspectors determined that this finding occurred as a consequence of actual problems with the Agastat relays, and that those actual problems were not attributable to this finding. This finding therefore cannot be processed through the significance determination process, and is considered to be Green by NRC staff review. The finding has a crosscutting aspect in the area of human performance associated with decision-making because the licensee did not use conservative assumptions in the functional failure evaluation of a Agastat relay failure (H.1(b))
05000298/FIN-2010003-03Work Preparation Activities Cause Unplanned Increase in Reactor Power2010Q2A self-revealing noncited violation of 10 CFR 50.54.j was identified when the licensee failed to ensure that mechanisms which may affect reactivity are manipulated only with the knowledge and consent of a licensed operator at the controls. Specifically, a work planner caused a feedwater heater trip by touching a pressure regulating valve without the knowledge of the control room. This action resulted in a feedwater transient. A subsequent reactivity increase occurred due to the change in feedwater temperature causing the reactor to exceed the licensed thermal power limit of 2419 MWt until reactor operators reduced power. The licensee immediately reduced power using the recirculation pumps. The licensee entered this issue in their corrective action program as CR-CNS-2010-03091 The finding was more than minor because the performance deficiency could be reasonably viewed as a precursor to a significant event in that a reactor power transient was initiated without the knowledge of the control room. This finding was characterized under the significance determination process as having very low safety significance because while the finding degraded the transient initiator contributor function of the initiating events cornerstone, it did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions will not be available. The inspectors determined that this finding has a crosscutting aspect in the area of human performance associated with the work practices component because the work planner proceeded in the face of unexpected circumstances by exceeding the scope of the job when he found the leak was greater than expected (H.4(a))
05000298/FIN-2010003-04Failure to Perform Required Maintenance Causes Unplanned Down Power2010Q2A self-revealing finding was identified for the licensees failure to implement the preventive maintenance requirements of the vendor manual for the plant traveling water screens. Specifically, Vendor Manual 140, Traveling Water Screen, Revision 35, contained daily and weekly routine maintenance requirements to open the channel-flushing valve to clear any accumulated debris from the screens. Despite the fact that the licensee incorporated this vendor manual into their preventive maintenance system, this maintenance requirement was overlooked. The failure to perform this maintenance task led to the trip of the A1 and A2 traveling water screens on May 1, 2010, and required an emergent power reduction. The licensee entered this issue in their corrective action program as Condition Report CR-CNS-2010-03195, and implemented daily checks of the traveling water screens and daily flushing of the screen debris troughs The finding was more than minor because it affected the equipment performance attribute of the initiating events cornerstone, and adversely affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. This finding was characterized under the significance determination process as having very low safety significance because it did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation functions would be unavailable. The inspectors determined that no crosscutting aspect was applicable to this finding because the performance deficiency was not reflective of current performance (Section 4OA5).
05000298/FIN-2010004-01Failure to Adequately Monitor the Performance of the Screen Wash System2010Q3The inspectors identified that the licensee failed to correctly determine that a plant power reduction caused by a clogged screen wash system for the circulating water system was a maintenance preventable functional failure that exceeded the plant level performance criteria. As a direct consequence, the licensee failed to assess this Maintenance Rule Program function per 10 CFR 50.65(a)(1) as required by station procedures. This issue was determined to involve a noncited violation of 10 CFR 50.65(a)(2) requirements for monitoring the effectiveness of maintenance at nuclear power plants. The licensee entered this issue in their corrective action program as CR-CNS-2010-05631. This finding is more than minor because failure to monitor the effectiveness of the screen wash system function CW-F01 affects the protection against external factors attribute of the initiating events cornerstone, since this system was intended to limit the likelihood of events that upset plant stability. The inspectors determined that this performance deficiency was an additional, but separate consequence of the obstructed screen wash system. The inspectors determined that this finding occurred as a separate consequence of the licensees functional failure assessment process, and that the system performance problem was not directly attributable to this finding. Therefore, this finding cannot be processed through the significance determination process, and was determined to be green using the guidance of Appendix B to Manual Chapter 0612 and Appendix D to Inspection Procedure 71111.12. The finding has a crosscutting aspect in the area of human performance associated with decision-making because the licensee did not use conservative assumptions in the functional failure evaluation of an obstructed screen wash system (H.1(b))
05000298/FIN-2010004-02Failure to Follow Procedure Results in Repeat Equipment Failure2010Q3A self-revealing finding was identified for the licensees failure to follow the guidance of Administrative Procedure 0.5.EVAL, Preparation of Condition Reports, Revision 21. Specifically, corrective actions to fix the Reactor Recirculation Motor Generator field breaker failure from 2009 failed to meet the measurable and reasonable criteria when the actions did not prevent a repeat failure of the same breaker and resulted in a fire in the breaker. The licensee entered this issue in their corrective action program as CR-CNS-2009-04115. The finding is more than minor because it adversely affected the protection against external factors (Fire), attribute of the initiating events cornerstone, and adversely affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Using Manual Chapter 0609, Significance Determination Process, Phase 1 Worksheet (Initial Screening and Characterization of Findings) the finding was determined to have very low safety significance since it did not contribute to the likelihood of a primary or secondary system loss-of-coolant accident, did not contribute to a loss of mitigation equipment, and did not increase the likelihood of a fire or internal/external flood. This finding has a crosscutting aspect in the corrective action program component of the problem identification and resolution area due to licensee corrective actions that failed to implement a resolution of field breaker failures.
05000298/FIN-2010004-03Licensee-Identified Violation2010Q3Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, requires activities affecting quality shall be prescribed by instructions appropriate to the circumstances. Contrary to this on December 21, 2009 Operations found the high pressure coolant injection turbine was not operable due to inadequate work instructions to prevent the mixing of unfiltered and filtered oil. Introduction of unfiltered oil resulted in particulate in the electronic governor remote unit leading to corrosion and binding of the electronic governor remote unit rendering the high pressure coolant injection system inoperable. The licensee entered this issue in their corrective action program as CR-CNS-2009-10691. This finding is of very low safety significance as determined by a Manual Chapter 0612 significance determination process Phase 3 analysis.
05000298/FIN-2010005-01Failure to Implement Fire Protection Plan Requirements Related to Hot Work Activities2010Q4The inspectors identified two examples of a finding for the failure of contract personnel to properly implement the requirements of the station procedure for control of hot work activities, where one instance resulted in a fire. Specifically, between November 9 and December 4, 2010, two examples were identified where contractor personnel failed to properly implement the requirements of station Procedure 0.39, Hot Work, Revision 42, Step 5.17.3 which required that all combustible material within 35 feet of the hot work area was removed, protected or additional fire watches stationed. Consequently, on December 4, 2010, during torch cutting activities on the central alarm station upgrade project, combustible material that had been introduced into the area was ignited by the hot work. These issues were entered into the corrective action program as Condition Reports CR-CNS-2010-8364, and CR-CNS-2010-9015. The failure of contract personnel to follow the requirements of the stations control of hot work procedure was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the protection against external factors attribute and directly affected the Initiating Events Cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations, and is therefore a finding. Additionally, if left uncorrected, the practice of conducting hot work in a manner that results in unintended combustion of uncontrolled combustible material within the procedurally specified exclusion area would have the potential to lead to a more significant safety concern, in that, it could result in a fire in or near risk important equipment. Using NRC Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, Phase 1 worksheet, the finding was determined to have very low safety significance because the condition represented a low degradation of a fire prevention and administrative control. This finding had a crosscutting aspect in the area of human performance associated with decision making, in that, the licensee failed to use conservative assumptions in their decision making and adopt a requirement to demonstrate that the proposed action is safe in order to proceed rather than a requirement to demonstrate that it is unsafe in order to disapprove the action when allowing combustible material to be introduced into the procedurally specified exclusion area for hot work activities.
05000298/FIN-2010005-02Failure to Assess and Manage Risk for Electrical Switchyard Impacting Maintenance2010Q4The inspectors identified a noncited violation of 10 CFR 50.65(a)(4), Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, for the failure of operations and work control personnel to adequately assess and manage risk associated with a planned maintenance activity. Specifically, on December 7, 2010, operations and work control personnel failed to adequately assess maintenance activities involving the use of a crane in the plants electrical switchyard. Following the inspectors identification of this issue, the licensee adequately assessed and managed the increase in risk for the maintenance activities. The issue was entered into the licensees corrective action program as Condition Report CR-CNS-2010-9146. The failure to perform an adequate risk assessment for planned maintenance activities was a performance deficiency. As such, the finding was more minor because it affected the protection against external factors attribute of the Initiating Events Cornerstone. Additionally, if left uncorrected the practice of not properly evaluating crane activities in the stations switchyard would have the potential to lead to a more significant safety concern, in that, it could result in a more than minimal increase in risk associated with other risk important equipment that would not be identified nor result in appropriate actions being taken to mitigate this increase in risk. The inspectors determined that the licensee does not maintain a probabilistic risk analysis model that incorporates the electrical switchyard, and as such, an incremental core damage probability cannot be estimated for the plant conditions that existed at the time of the performance deficiency. For this reason, the inspectors determined that Manual Chapter 0609, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process, Flowchart 2, could not be used to determine the risk significance the finding. Using the qualitative review process of Manual Chapter 0609, Appendix M, Significance Determination Process Using Qualitative Criteria, the finding is determined to have very low safety significance because the finding did not result in any additional loss of defense in depth systems. This finding had a crosscutting aspect in the area of human performance associated with decision making, in that, the licensee failed to use conservative assumptions in their decision making and adopt a requirement to demonstrate that the proposed action is safe in order to proceed rather than a requirement to demonstrate that it is unsafe in order to disapprove the action.
05000298/FIN-2010005-03Failure to Adequately Assess and Manage Risk During Maintenance Activities2010Q4The inspectors documented a noncited violation of 10 CFR 50.65(a)(4), Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, associated with the licensees failure to perform an adequate risk assessment for the planned maintenance activities. Specifically, on August 24, 2010, operations and work control personnel failed to adequately assess and manage the increase in risk associated with the breaker switching sequence to support maintenance on the station startup service transformer. Following identification of the issue, the licensee adequately assessed and managed the increased risk associated with the maintenance activity. The issue was entered into the licensees corrective action program as Condition Report CR-CNS-2010-6100. The failure to perform an adequate risk assessment for planned maintenance activities was a performance deficiency. The performance deficiency was greater than minor because it was associated with the protection against external factors attribute and directly affected the Initiating Events Cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations, and is therefore a finding. Using NRC Manual Chapter 0609, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process, Flowchart 1, the finding was determined to have very low safety significance because the incremental core damage probability deficit and the incremental large early release probability deficit, used to evaluate the magnitude of the error in the licensees inadequate risk assessment, were less than 1E-6 and 1E-7, respectively. This finding had a crosscutting aspect in the area of problem identification and resolution associated with operating experience, in that, the licensee uses operating experience information, including vendor recommendations and internally generated lessons learned, to support plant safety. Specifically, the licensee implements and institutionalizes operating experience through changes to station processes and procedures.
05000298/FIN-2010005-04Failure to Have Guidelines for the Choice of Protective Actions During an Emergency Consistent with Federal Guidance2010Q4A cited violation of 10 CFR 50.47(b)(10) was identified for failure to develop and have in place guidelines for the choice of protective actions during an emergency that were consistent with federal guidance. Federal guidance for the choice of protective actions during an emergency is described in EPA-400-R-92-001 and states, in part, that evacuation is seldom justified when doses are less than protective action guides. The licensees automatic process that extended existing protective action recommendations with changes in wind direction without considering radiation dose was identified as a performance deficiency. This finding is more than minor because it affects the Emergency Preparedness Cornerstone objective of implementing adequate measures to protect the health and safety of the public during a radiological emergency, and is associated with the cornerstone attributes of emergency response organization performance and procedure quality. This finding was determined to be of very low safety significance because it was a failure to comply with NRC requirements, was associated with risk significant planning standard 10 CFR 50.47(b)(10), and was not a risk significant planning standard functional failure or a planning standard degraded function. This finding is a cited violation of 10 CFR 50.47(b)(10) because the licensee failed to restore compliance with NRC requirements in a timely manner. The finding is related to the corrective action element of the problem identification and resolution crosscutting aspect because the licensee failed to take corrective actions to address the safety issue in a timely manner.
05000298/FIN-2010005-05Diesel Generator Overspeed Governor Loose Bolting Issue2010Q4The inspectors identified an unresolved item associated with the loose bolting issue on the over speed governor of diesel generator two. Specifically, the issue concerns past operability of the diesel, adequacy of previous evaluations and corrective actions taken by the licensee, and procedure quality and use. On September 8, 2009, while performing a monthly surveillance run of diesel generator two, the overspeed governor trip mechanism was observed to be vibrating significantly. The licensee secured the diesel generator, and during subsequent inspection found that all eight nuts that that were used to retain the governor were loose (less than finger tight). The licensee determined that this event had been caused by gasket creep and thermal cycle effects, and had this been occurring over a very long period of time, approximately 30 years. The licensee took corrective actions based on these identified causes. Subsequently, on August 17, 2010, while performing bolt tightness checks the licensee discovered six of eight nuts that were used to retain the diesel generator two overspeed governor drive unit were loose (less than finger tight), and one bolt was at a reduced torque (48 ft-lbs). The licensee determined that the cause of this event was improper torque being applied to the nuts when they had been reassembled following the September 2009 issue along with thermal cycle effects. During review of the root cause report for the loose bolting issue found on diesel generator two in August 2010, the inspectors noted that this condition appeared to be a repeat occurrence of what had been found in September 2009, and as such, questioned the licensees determined cause for the 2010 issue. The inspectors also questioned key assumptions used by the licensee when evaluating this issue. Furthermore, the inspectors noted that the past operability evaluation that the licensee performed failed to consider all pertinent conditions that could have affected the equipments ability to perform its design basis function, specifically elevated vibrations associated with the asfound condition. As such, the inspectors determined that more inspection was necessary to resolve this issue. Accordingly, this issue is being considered an unresolved item pending further review. An unresolved item is an issue requiring further information to determine if it is acceptable, if it is a finding, or if it constitutes a violation of NRC requirements. As such, no analysis of this issue has occurred. Additional information was needed to determine whether a violation of regulatory requirements occurred. Pending further review of additional information provided by the licensee, this issue is being treated as an Unresolved Item 05000298/2010005-05, Diesel Generator Overspeed Governor Loose Bolting Issue.
05000298/FIN-2010005-06Failure to Update Flood Protection for Safety Related Buildings2010Q4The team identified an unresolved item concerning external flood protection for plant areas considered vital to allow the reactor to achieve cold shutdown. Specifically, the issue concerns the ability of the licensee to protect the Cooper Nuclear Station reactor building and intake structure from external floods as stated in Updated Safety Analysis Report, Technical Specifications, and emergency procedures. The inspectors reviewed the historical information for hydrology in the Cooper Nuclear Station Updated Safety Analysis Report Section II-4, Hydrology. The inspectors noted that this information was used to establish the design basis floods levels and flood protection at Cooper Nuclear Station. By reviewing recent industry operating experience and the 2010 floods along the Missouri River, the inspectors identified that actual river flow rates yielded higher flood levels than previously evaluated in the Updated Safety Analysis Report. Additionally, the US Army Corps of Engineers published new data in January 2004 that river flows on the Missouri River created the potential for higher flood levels than previous published data. Because of the potential for increased flood levels, the inspectors questioned the licensees ability to protect nuclear plant structures from the design basis flood levels. Based on questions from the inspectors, the licensee entered the condition into the corrective action program. The inspectors determined that more inspection is necessary to resolve the issue. Since more information is necessary, the issue is considered an unresolved item pending further NRC Region IV review. The NRC Region IV review will determine: 1. If the licensees flood protection strategy will adequately protect to the flood levels stated in the Updated Safety Analysis Report, 2. If failure to meet these standards of flood protection is a performance deficiency in accordance with NRC Manual Chapter 0612, and 3. If a violation of NRC requirements is associated with the performance deficiency.
05000298/FIN-2010006-01Inadequate Post-Fire Safe Shutdown Procedures2010Q4An apparent violation of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," and Criterion XVI, "Corrective Action," with a preliminary white significance, was identified for failure to ensure that some steps contained in Emergency Procedures at Cooper Nuclear Station would work as written and the concurrent failure to assure that a condition adverse to quality was promptly identified and corrected, respectively. Specifically, steps in Emergency Procedure 5.4 POST-FIRE, "Post-Fire Operational Information," and Emergency Procedure 5.4 FIRE-SID, "Fire Induced Shutdown From Outside Control Room," intended to reposition motor operated valves from the motor starter cabinet, would not have worked as written because the steps were not appropriate for the configuration of three valve motor starters. This finding was entered into the licensee's corrective action program under Condition Reports CR-CNS-201 0-08193 and CR-CNS-2010-08242, however the licensee failed to adequately correct the procedure and the procedure remained unworkabie. The failure to verify that procedure steps needed to safely shutdown the plant in the event of a fire would actually reposition motor operated valves to the required positions and the simultaneous failure to address the previous finding that the same procedure steps would not work as written, was a performance deficiency. This finding was more than minor safety significance because it impacted the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to external events (such as fire) to prevent undesirable consequences. This finding affected both the procedure quality and protection against external factors (such as fires) attributes of this cornerstone objective. This finding was determined to have a preliminary lovv-to-moderate safety significance (White) during a Phase 3 evaluation using best available information. This problem, which has existed since 1997, involves risk factors that were not dependent on specific fire damage. The scenarios of concern involve larger fires in specific areas of the plant which trigger operators to implement fire response procedures to place the plant in a safe shutdown condition. Since some of those actions could not be completed using the procedures as written, this would challenge the operators' ability to establish adequate core cooling. This finding had a crosscutting aspect in the Corrective Action Program component, under the Problem Identification and Resolution area (P.1 (c) - Evaluation), because the licensee failed to properly evaluate the circuit operation or conduct verification tests to ensure that corrective actions for a previous violation would reliably position the three valves. Upon identification of this issue, both emergency procedures were revised to assure correct valve alignment by manually operating the valve locally. Therefore, this finding does not represent a current safety concern.
05000298/FIN-2010006-02Failure to Monitor the Performance of the Emergency Lights Against the Maintenance Rule Criteria2010Q4A noncited violation of 10 CFR 50.65(a)(2) was identified for the failure to monitor the performance of the emergency lighting system against the established performance criteria. The licensee included the emergency lighting system in the Maintenance Rule program and specified that the emergency light batteries must be capable of 8 hours of operation, as required by 10 CFR Part 50, Appendix R, Section iii.J. The team identified that the licensee did not perform tests that demonstrated the capability of the emergency lights to last for 8 hours; therefore, the licensee failed to monitor the performance of the emergency lights against the established performance criteria. This finding was entered into the licensee\\\'s corrective action program under Condition Reports CR-CNS-201 0-08014 and CR-CNS-2010-08250. The failure to monitor the performance of the emergency lighting system against the performance criteria stated in the Maintenance Rule program was a performance deficiency. The performance deficiency was more than minor because it was associated with the protection against external events (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. Specifically, the failure to ensure that emergency lights would last for 8 hours could adversely affect the ability of operators to perform all of the manual actions required to support safe shutdown in the event of a fire. The significance of this finding was evaluated using Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, because the performance deficiency affected fire protection defense-in-depth strategies involving post fire safe shutdown systems. The finding was assigned a low degradation rating since the finding minimally impacted the performance and reliability of the fire protection program element. Specifically, the team determined that the licensee\\\'s preventive maintenance strategy provided reasonable assurance that the emergency lights would last sufficiently long for the operators to perform the most time-critical manual actions required to support safe shutdown in the event of a fire. The team also noted that operators were required to obtain and carry flashlights. Therefore, the finding screened as having very low safety significance (Green). This finding had a crosscutting aspect in the area of Human Performance associated with Decision Making because the licensee failed to identify possible unintended consequences of the decision to change the maintenance program for the emergency lights. Specifically, the licensee failed to identify that deleting emergency light testing impacted Maintenance Rule performance monitoring.
05000298/FIN-2010007-01Failure to Translate Design and Operating Requirements into Procedures2010Q4The team identified three examples of a Green noncited violation of 10 CFR 50, Appendix B, Criterion XI, Test Control, for failure to ensure that design information was correctly translated into station test procedures. Specifically, as of August 12, 2010, the licensee failed to ensure that design information was correctly translated into station procedures involving capacity testing, service testing, and maintenance of safety-related station batteries. This finding was entered into the licensees corrective action program as Condition Reports CNS-2010-5445, CNS-2010-5564, CNS-2010-5674, and CNS-2010-5759. The failure to correctly translate design requirements into station procedures involving capacity testing, service testing, and maintenance of safety-related station batteries was a performance deficiency. This finding was more than minor because it was associated with the test control attribute of the mitigating systems cornerstone and impacted the cornerstone objective to ensure the availability, reliability, and capability of the affected system to respond to initiating events and prevent undesirable consequences. Using the Manual Chapter 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings, the issue screened as having very low safety significance (Green) because it was not a design or qualification deficiency and did not represent a loss of safety function. The licensee performed an evaluation and determined that the station batteries were capable of performing their safety functions. This finding had a crosscutting aspect in the area of human performance resources because the licensee did not provide complete, accurate and up-to-date design documentation to plant personnel.
05000298/FIN-2010007-02Failure to promptly Correct Conditions Adverse to Quality2010Q4The team identified three examples of a Green noncited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the failure to ensure conditions adverse to quality were promptly corrected. Specifically, as of August 12, 2010, the licensee failed to promptly correct conditions adverse to quality involving the installation and testing of safety-related station batteries and the design control process. This finding was entered into the licensees corrective action program as Condition Reports CNS-2010-05674, CNS-2010-05647, and CNS-2010-5950 The failure to promptly correct conditions adverse to quality was a performance deficiency. This finding was more than minor because it was associated with the corrective actions attribute of the mitigating systems cornerstone and if left uncorrected would have the potential to lead to more significant safety concerns. Using the Manual Chapter 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings, the issue screened as having very low safety significance (Green) because it was not a design or qualification deficiency and did not represent a loss of safety function. This finding had a crosscutting aspect in the human performance decisionmaking because the licensee failed to use conservative assumptions in decision-making to correct the underlying cause of the many conditions adverse to quality.
05000298/FIN-2010007-03Inadequate Test Control2010Q4The team identified four examples of a Green noncited violation of Technical Specification 5.4.1.a, which states in part that, Written procedures shall be established, implemented, and maintained, covering the procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A.9.b, for the failure to establish adequate procedures. Specifically, as of August 12, 2010, the licensee failed to establish adequate procedures involving 4160 V breaker maintenance, safety-related check valve maintenance, and the operation of residual heat removal pumps. This finding was entered into the licensees corrective action program as Condition Reports CNS- 2010- 05611, CNS-2010-05635, CNS-2010-05556, CNS-2010-05586, CNS-2010-05590, and CNS-2010-05342. The failure to establish adequate procedures for 4160 V breaker maintenance, safety-related check valve maintenance, and the operation of residual heat removal pumps was a performance deficiency. This finding was more than minor because it was 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 the 4160 Vac systems, core spray system and the residual heat removal system to respond to events and prevent undesirable consequences. Using the Manual Chapter 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings, the issue screened as having very low safety significance (Green) because it was not a design or qualification deficiency and did not represent a loss of safety function. The licensee placed the 4160 V breaker procedures on administrative hold, performed an evaluation of the affected check valves which determined that they would be able to perform their required functions, and revised the procedures related to residual heat removal pump operations. This finding had a crosscutting aspect in the area of human performance resources because the licensee did not provide complete, accurate, and up-to-date design documentation to plant personnel.
05000298/FIN-2010007-04Inadequate Design Control2010Q4The team identified seven examples of a Green noncited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for failure to establish measures to ensure that applicable regulatory requirements and the design bases were correctly translated into specifications, drawings, procedures, and instructions. These measures shall include provisions to ensure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled. Specifically, as of August 12, 2010, the licensee failed to correctly translate regulatory requirements and design bases information into specifications, drawings, procedures, and instructions involving emergency diesel generator frequency, service water pump, electrical cables for the residual heat removal pumps, seismic supports, the emergency diesel generator air start system testing, tornado and high wind impact on the emergency diesel generator fuel oil storage facilities and safety-related Agast relay service life evaluations. This finding was entered into the licensees corrective action program as Condition Reports CNS-2010-05301, CNS-2010-5763, CNS-2010-05222, CNS-2010-05281, CNS-2010-5294, CNS-2010-5350, and CNS-2010-5438. The failure to correctly translate regulatory requirements and design bases information into specifications, drawings, procedures, and instructions for the emergency diesel generator frequency, service water pump, electrical cables for the residual heat removal pumps, emergency diesel generator room ventilation seismic supports, emergency diesel generator air start system testing, tornado and high wind impact on the emergency diesel generator fuel oil storage facilities and safety-related Agast relay service life evaluations was a performance deficiency. This finding was more than minor because it was associated with the design control attribute of the mitigating systems cornerstone and impacted the cornerstone objective to ensure the availability, reliability, and capability of the affected system to respond to events and prevent undesirable consequences. Using the Manual Chapter 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings, the issue screened as having very low safety significance (Green) because it was not a design or qualification deficiency and did not represent a loss of safety function. The licensee performed evaluations which determined that the affected components and systems were capable of meeting their design functions. The finding had a crosscutting aspect in the area of problem identification and resolution, associated with operating experience because the licensee failed to properly evaluate and apply various industry events associated with the above systems and incorporate the information into plant procedures and training.
05000298/FIN-2010007-05Ice Deflector Pontoon Barge Storage in Service Water Discharge Canal2010Q4The team identified a Green noncited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the failure to verify the adequacy of design for the service water system. Specifically, prior to August 10, 2010, the licensee did not have a calculation to support storage of an ice deflector pontoon barge in the service water discharge canal during design tornado or high wind conditions. This finding was entered into the licensees corrective action program under Condition Report CNS-2010-5763. The failure to establish appropriate design controls by having a calculation for storage of a pontoon barge in the safety-related service water discharge canal is a performance deficiency. The finding is more than minor because it is 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 the service water system to respond to events to prevent undesirable consequences. Using the Manual Chapter 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings, the issue screened as having very low safety significance (Green) because it was not a design or qualification deficiency and did not represent a loss of safety function. The licensee performed a calculation (NEDC 10-057) which demonstrated the current storage of the pontoon barge in the service water discharge was sufficient, such that it will not to adversely affect the service water system. The finding had a crosscutting aspect in the area of human performance decision making because the licensee failed to use conservative assumptions in decision making and adopt a requirement to demonstrate that the proposed action is safe in order to proceed rather than a requirement to demonstrate that it is unsafe in order to disapprove the action because the licensee failed conduct an effective review of safety-significant decisions associated with the ice deflector barge storage to verify the validity of the underlying assumptions, identify possible unintended consequences, and determine how to improve future decisions.
05000298/FIN-2010007-06Faulty General Electric Switches2010Q4The team identified a severity level IV noncited violation of 10 CFR Part 21, Notification of Failure to Comply or Existence of a Defect and its Evaluation, for the failure of the licensee to evaluate the deviations in 13 of 23 safety-related switches within 60 days. Specifically, prior to August 10, 2010, the licensee failed to submit a report as required by paragraph 21.21 (a)(1) of 10 CFR Part 21 when 13 of 23 General Electric control switches purchased to support a station modification to the safety-related 4160 kV switchgear were discovered to have a defect that was later determined to create a substantial safety hazard. The defective switches were discovered and documented on Condition Report CNS-2009-09985 dated November 25, 2009 and the evaluation was not completed until August 10, 2010. After the evaluation determined the defect did create a substantial safety hazard, the NRC was notified via an event notification on August 10, 2010. Using the Traditional Enforcement Policy and Manual, this was determined to be a Severity Level IV noncited violation. This finding was entered into the licensees corrective action program as Condition Report CNS-2010- 5629. The finding had a crosscutting aspect of problem identification and resolution, alternative process, because the licensee failed to ensure appropriate and timely resolution of identified problems.
05000298/FIN-2010007-07URI 05000298/2007011-07, Fuel Oil Storage Tank Required Submergence To Prevent Vortexing And Available Volume Are Marginal Without Accounting For Instrument Uncertainties2010Q4The team identified a Green noncited violation of CFR Part 50, Appendix B, Criterion III, Design Control, for the failure of the licensee to verify the adequacy of design for the diesel fuel oil transfer system. Specifically, the licensee failed to demonstrate an adequate supply of fuel oil was available in the tanks to support the safety function of the emergency diesel generators because the licensee failed to consider the potential for vortex formation in the two diesel fuel oil storage tanks and the two day tanks and net positive suction head of the associated pumps. This finding was entered into the licensees corrective action program under Condition Report CNS-2010-5763. The failure to establish appropriate design controls for the safety-related diesel fuel oil transfer pump net positive suction head calculation was a performance deficiency. The finding was more than minor because it was associated with the design control attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of the diesel fuel oil transfer system to respond to events and prevent undesirable consequences. Using the Manual Chapter 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings, the issue screened as having very low safety significance (Green) because it was not a design or qualification deficiency and did not represent a loss of safety function. The licensee performed an evaluation which determined that the system was capable of meeting its design function. This finding did not have a crosscutting aspect because the most significant contributor did not reflect current licensee performance.
05000298/FIN-2010007-08URI 05000298/2007011-08, High Pressure Coolant Pump Swap-Over from Emergency Condensate Storage Tank to Torus Vortex Calculation2010Q4The team identified a Green noncited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the failure of the licensee to verify the adequacy of design for the high pressure coolant injection system. Specifically, prior to December 2007, the licensee did not have vortex calculations for the high pressure coolant injection system during swap-over from the emergency condensate storage tank to the torus. The calculation was required to establish that the high pressure coolant injection pumps have adequate net positive suction head to operate in accordance with design. This finding was entered into the licensees corrective action program under Condition Report CNS-2010-5763. The failure to establish appropriate design controls for the safety-related high pressure coolant injection pump net positive suction head calculation was a performance deficiency. The finding was more than minor because it was associated with the design control attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of the high pressure coolant injection system to respond to events and prevent undesirable consequences. Using the Manual Chapter 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings, the issue screened as having very low safety significance (Green) because it was not a design or qualification deficiency and did not represent a loss of safety function. The licensee performed an evaluation which determined that the system was capable of meeting its design function. This finding did not have a crosscutting aspect because the most significant contributor did not reflect current licensee performance.
05000298/FIN-2010403-01Security2010Q4
05000298/FIN-2011002-01Failure to Properly Evaluate All Senior Operator License Holders during Annual Operating Test2011Q1The inspectors identified a noncited violation of 10 CFR Part 55.59 (a)(2)(ii), Requalification, for the failure of the licensee to ensure that three senior operator license holders were evaluated during the annual operating test to the appropriate level of their license. This issue was entered into the licensees corrective action program as Condition Report CR-CNS-2010-09350. The failure of the licensee to properly evaluate the three senior operators to the level of their license in the annual operating test was a performance deficiency. The performance deficiency is more than minor, and therefore a finding, because it adversely impacted the human performance attribute of the Mitigating Systems Cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Additionally, if left uncorrected, the performance deficiency could have become more significant in that allowing licensed operators to return to the control room without valid demonstration of appropriate knowledge on the biennial examinations could be a precursor to a significant event if undetected performance deficiencies develop. Using Manual Chapter 0609, Significance Determination Process, Phase 1 worksheets, and Appendix M, Significance Determination Process Using Qualitative Criteria, the finding was determined to have very low safety significance (Green) because, although the finding resulted in three senior operator license holders standing watch in the senior operator position without being properly evaluated during the annual operating test, there were no actual safety consequences. This finding has a crosscutting aspect in the area of human performance associated with the decision making component because the licensee failed to use conservative assumptions in decision making and adopt a requirement to demonstrate that the proposed action is safe in order to proceed rather than a requirement to demonstrate that it is unsafe in order to disapprove the action (H.1(b)) (Section 1R11).
05000298/FIN-2011002-02Failure to Assess and Manage Risk for Maintenance That Could Impact Initiating Events2011Q1The inspectors identified a cited violation of 10 CFR 50.65(a)(4), Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, for the failure of work control and operations personnel to adequately assess and manage the increase in risk associated with maintenance activities. Specifically, on February 17, 2011, work control and operations personnel failed to adequately assess and manage the increase in risk associated with maintenance activities involving the use of heavy equipment in or near the electrical switchyard and offsite power components. Due to the licensees failure to restore compliance from the previous NCV 050000298/2008005-02 and other subsequent violations within a reasonable time after the violations were identified, this violation is being cited in a Notice of Violation consistent with Section 2.3.2 of the NRC Enforcement Policy. This finding was entered into the licensees corrective action program as condition reports CR-CNS-2010-09146, CR-CNS-2008-08645 and CR-CNS-2009-03714. The performance deficiency associated with this finding involved the licensees failure to adequately assess and manage the risk of planned maintenance activities. This finding is greater than minor because it affected the protection against external factors attribute of the Initiating Events Cornerstone, and directly affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The inspectors determined that Manual Chapter 0609, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process, could not be used due to the licensees inability to quantify the increase in risk associated with the heavy equipment activity in the switchyard. The inspectors therefore used Manual Chapter 0609, Appendix M, Significance Determination Process Using Qualitative Criteria. The inspectors performed a bounding qualitative evaluation using the best available information and determined that the finding was of very low safety significance because another qualified source of offsite power (the emergency transformer) was unaffected by this performance deficiency and provided sufficient remaining defense in depth in the event of a loss of offsite power. This finding has a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program component because the licensee did not take appropriate corrective actions to address safety issues and adverse trends in a timely manner, commensurate with their safety significance and complexity (P.1(d))(Section 1R13).
05000298/FIN-2011002-03Failure to Adequately Implement Foreign Material Exclusion Controls2011Q1The inspectors identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated with the licensees failure to adequately implement Procedure 0.45, Foreign Material Exclusion Program, Revision 33. Specifically, between November 24, 2010, and March 24, 2011 multiple occasions were identified where licensee personnel failed to implement appropriate foreign material exclusion controls in areas designated as Zone 1 areas around safety related equipment (e.g., failure to appropriately log material into and out of the zone, or appropriately lanyard material in the zone) as required by station procedure. This issue was entered into the licensee\'s corrective action program as Condition Reports CR-CNS-2010-9173, CR-CNS-2010-9678, CR-CNS-2011-2775 and CR-CNS-2011-3214. The failure of station personnel to follow Procedure 0.45, Foreign Material Exclusion Program, when working in Zone 1 foreign material exclusion areas around safety related equipment/areas, was a performance deficiency. The performance deficiency was more than minor because it affected the human performance attribute of the Barrier Integrity Cornerstone, and directly affected the cornerstone objective of providing reasonable assurance that physical barriers protect the public from radionuclide releases caused by accidents or events, and is therefore a finding. Furthermore, station personnels continued failure to implement appropriate foreign material exclusion controls could result in the introduction of foreign material into critical areas, such as the spent fuel pool or the reactor cavity, which in turn could result in degradation and adverse impacts on materials and systems associated with these areas. Using Inspection Manual Chapter 0609, Significance Determination Process, Phase 1 Worksheets (at power issues), and Manual Chapter 0609, Appendix G, Shutdown Operations Significance Determination Process, Phase 1 guidance (shutdown issues), this finding was determined to have a very low safety significance because; the finding was only associated with the fuel barrier (at power), and did not result in an increase in the likelihood of a loss of reactor coolant system inventory, degrade the ability to add reactor coolant system inventory, or degrade the ability to recover decay heat removal (shutdown). This finding had a crosscutting aspect in the area of human performance associated with the work practices component, in that the licensee failed to define and effectively communicate expectations regarding procedural compliance and personnel follow procedures (H.4(b)) (Section 1R20).
05000298/FIN-2011002-04Repeat Failure to Follow Procedure for Initiating Condition Reports2011Q1The inspectors identified a noncited violation of 10 CFR 50 Appendix B, Criterion V, Instructions, Procedures and Drawings, regarding the licensees failure to follow the requirements of Administrative Procedure 0.5.CR, Condition Report Initiation, Review and Classification to enter conditions adverse to quality into the corrective action program. Specifically, between January 12, 2011, and February 24, 2011, the inspectors identified multiple instances where licensee personnel were aware of conditions adverse to quality, but failed to appropriately enter them into the corrective action program until being prompted by the inspectors. The licensee entered this issue in their corrective action program as CR-CNS-2011-1239. The performance deficiency associated with this finding involved the licensees failure to initiate condition reports as required by Administrative Procedure 0.5.CR, Condition Report Initiation, Review and Classification. The performance deficiency was more than minor because it affected the equipment performance attribute of the Mitigating Systems Cornerstone, and directly affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Although the examples mentioned above may be minor violations, the inspectors used Section 2.10.F of the NRC Enforcement Manual to determine that the performance deficiency was more than minor and is therefore a finding because the NRC has indication that the minor violation had occurred repeatedly. Using the Manual Chapter 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings, the inspectors determined that the finding has very low safety significance because all of the items in the Table 4a Mitigating Systems Cornerstone checklist were answered in the negative. The finding has a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program component, in that the licensee takes appropriate corrective actions to address safety issues and adverse trends in a timely manner. Specifically, the licensee failed to take appropriate corrective actions to address previously identified examples of employees not initiating condition reports in response to conditions adverse to quality (P.1(d)) (Section 4AO2).
05000298/FIN-2011002-05Failure to Notify the NRC within Eight Hours of a Nonemergency Event2011Q1The inspectors identified a Severity Level IV noncited violation of 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors, for the licensees failure to notify the NRC Operations Center within 8 hours following discovery of an event meeting the reportability criteria as specified. Specifically, on January 18, 2011, while the B train of residual heat removal was inoperable for scheduled maintenance the A train experienced a fault which rendered it inoperable for its low pressure coolant injection function. As a result, both trains of residual heat removal were incapable of performing their system specified safety function of residual heat removal. The licensees evaluation of this condition determined that it was not a reportable event because both core spray pumps were operable and the D residual heat removal pump was available therefore the overall function of decay heat removal was maintained. The inspectors questioned this rational, because the apparent intent of the reporting criteria as described in NUREG 1022, Event Reporting Guidelines 50.72 and 50.73, Revision 2, section 3.2.7, was to cover an event or condition where structures, components, or trains of a safety system could have failed to perform their intended safety function as described in the plant safety analysis. Consultation with the Office of Nuclear Reactor Regulation determined that this was the intent of the criteria. As such, the inspectors determined that the licensee had failed to make a non-emergency 8 hour report as required by 10 CFR 50.72(b)(3)(v). The licensee submitted the 8 hour report on January 21, 2011 and entered this issue into the corrective action program as Condition Report CR-CNS-2011-0618. The failure to make an applicable non-emergency 8-hour event notification report within the required time frame was determined to be a performance deficiency. The inspectors reviewed this issue in accordance with NRC Inspection Manual Chapter 0612 and the NRC Enforcement Manual. Through this review, the inspectors determined that traditional enforcement was applicable to this issue because the NRC\'s regulatory ability was affected. Specifically, the NRC relies on the licensees to identify and report conditions or events meeting the criteria specified in regulations in order to perform its regulatory function; and when this is not done, the regulatory function is impacted. The inspectors determined that this finding was not suitable for evaluation using the significance determination process, and as such, was evaluated in accordance with the NRC Enforcement Policy. The finding was reviewed by NRC management and because the violation was determined to be of very low safety significance, was not repetitive or willful, and was entered into the corrective action program, this violation is being treated as a Severity Level IV noncited violation consistent with the NRC Enforcement Policy. This finding had a crosscutting aspect in the area of human performance associated with the decision making component, in that, the licensee failed to use conservative assumptions in their decision making (H.1(b)) (Section 4OA3).
05000298/FIN-2011002-06Licensee-Identified Violation2011Q110 CFR 50.65(a)(3) states, in part, that performance and condition monitoring activities and associated goals and preventive maintenance activities shall be evaluated at least every refueling cycle provided the interval between evaluations does not exceed 24 months. Contrary to the above, as of August 31, 2010, the licensee had not completed the (a)(3) assessment in the 24 months since the last assessment period ended August 2008. When a licensee self assessment determined on February 3, 2011 that they had failed to perform the assessment, Condition Report CR 2011-01003 was initiated to track completed the assessment and revise the controlling procedure to prevent recurrence of this condition. The inspectors determined that this issue was of very low safety significance and no degraded performance or condition of associated structure, system, and components functions within the scope of the maintenance rule, resulted from the performance deficiency.
05000298/FIN-2011003-01Failure to Assess Potential Adverse Effects on Internal Flooding Analysis2011Q2The inspectors identified two examples of a noncited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated with the failure of the licensee to ensure compliance with the requirements of station Procedure 3.3SAFE, Safety Assessment. Specifically, licensee personnel failed to identify the potential adverse impact to the station internal flooding analysis for the installation of a temporary chemical decontamination skid associated with the fuel pool cooling system, and meshing material installed around the handrails. The licensee performed an evaluation for the skid which demonstrated compliance, and removed the meshing material when it was identified. These issues were entered into the licensees corrective action program as Condition Reports CR-CNS-2011-2182, CR-CNS-2011-2232, CR-CNS-2011-2240, CR-CNS-2011-2242, CR-CNS-2011-2249, CR-CNS-2011-3551, CR-CNS-2011-5754, and CR-CNS-2011-5798. The failure to comply with the requirements of station Procedure 3.3SAFE and identify and evaluate the potential adverse impact to the stations internal flooding analysis of several configuration changes was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the design control attribute of the Mitigating Systems Cornerstone, and affected the associated cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and is therefore a finding. Using Manual Chapter 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, the finding was determined to have very low safety significance because the finding: (1) was not a design or qualification issue confirmed not to result in a loss of operability or functionality; (2) did not represent an actual loss of safety function of the system or train; (3) did not result in the loss of one or more trains of nontechnical specification equipment; and (4) did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The finding was determined to have a cross-cutting aspect in the area of human performance, associated with the decision making component, in that the licensee failed to use conservative assumptions in decision making. Specifically, the licensees qualitative analysis comparing the two hatches failed to take into account configuration differences associated with external structures around the hatch (H.1(b)) (Section 1R06).
05000298/FIN-2011003-02Failure to Follow Procedure Results in Inadequate Operability Determinations2011Q2The inspectors identified multiple examples of a noncited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, regarding the licensees failure to follow the requirements of EN-OP-104, Operability Determinations. Specifically, the inspectors identified examples in which operations failed to properly document the basis for operability when a degraded or nonconforming condition had been identified. The licensee entered these issues into their corrective action program with individual condition reports for each issue. Corrective actions resulted in revised operability reviews and corrective actions to processes and training to prevent similar operability determination problems. The performance deficiency is more than minor because the condition of performing inadequate operability determinations could become more significant if left uncorrected. Unrecognized degradation of essential equipment impacts the equipment performance attribute of the Mitigating Systems Cornerstone, and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Using Manual Chapter 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, the finding was determined to have very low safety significance because the finding: (1) was not a design or qualification issue confirmed not to result in a loss of operability or functionality; (2) did not represent an actual loss of safety function of the system or train; (3) did not result in the loss of one or more trains of nontechnical specification equipment; and (4) did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. This finding was determined to have a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action component, in that, the licensee failed to thoroughly evaluate problems such that the resolutions addressed causes and extent of conditions. Specifically, licensee personnel failed to thoroughly evaluate conditions adverse to quality and perform meaningful operability determinations (P.1(c))(Section 1R15).
05000298/FIN-2011003-03Failure to Follow Procedure Results in Personnel Contaminations2011Q2The inspectors reviewed a self-revealing, noncited violation of Technical Specification 5.4.1, resulting from workers who entered a posted contamination area without required protective clothing and were contaminated as a result. The condition was detected when contamination monitors alarmed during the workers attempt to process out of the radiologically controlled area. The workers were then decontaminated prior to exiting. The licensee entered the issue into the corrective action program as Condition Report CR-CNS-2011-03311. The corrective actions included communication of the issue throughout the department. The failure to follow radiation work permit requirements is a performance deficiency. The finding was more than minor because it was associated with the Occupational Radiation Safety Cornerstone attribute (exposure control) of program and process and affected the cornerstone objective, in that, working in an area outside the scope of the radiation work permit and not following protective clothing requirements resulted in personnel contaminations. Using the Occupational Radiation Safety Significance Determination Process, the inspectors determined the finding to have very low safety significance because: (1) it was not associated with 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. The finding was determined to have a cross-cutting aspect in the area of human performance, associated with the work control component, in that, the licensee failed to appropriately coordinate work activities by incorporating actions to address plant conditions that may affect work activities. Specifically, the radiation protection technician failed to verify current conditions prior to briefing workers on expected plant conditions that may affect work activities (H.3(b))(Section 1R20.1).
05000298/FIN-2011003-04Communication of an NRC Inspectors Presence by Station Personnel2011Q2The inspectors identified a Severity Level IV noncited violation of 10 CFR 50.70, Inspections, associated with the licensees failure to ensure that the arrival and presence of NRC inspectors was not communicated to persons at the facility. Specifically, a radiation protection technician manning the access point to the drywell informed other individuals entering the drywell to perform work of inspectors presence and location during an unannounced walkdown of the drywell to observe licensee work activities. This issue was entered into the licensees corrective action program as Condition Report CR-CNS-2011-4124. Licensee personnels action of announcing the presence and location of NRC inspectors during an unannounced walkdown inspection was a performance deficiency. The inspectors reviewed this issue in accordance with NRC Inspection Manual Chapter 0612 and the NRC Enforcement Manual. Through this review, the inspectors determined that traditional enforcement was applicable to this issue because the NRC\'s regulatory ability was affected. Specifically, the NRC relies on its ability to perform unannounced inspections to evaluate licensee performance, and communicating the presence and location of NRC inspectors affects their ability to perform these inspections, and as such the regulatory function is impacted. The inspectors determined that this finding was not suitable for evaluation using the significance determination process, and as such, was evaluated in accordance with the NRC Enforcement Policy. The finding was reviewed by NRC management and because the violation was determined to be of very low safety significance, was not repetitive or willful, and was entered into the corrective action program, this violation is being treated as a Severity Level IV noncited violation consistent with the NRC Enforcement Policy. The inspectors determined that there was no cross-cutting aspect associated with this finding because this issue was not indicative of current performance because the violation did not affect any of the safety culture components (Section 1R20.3).
05000298/FIN-2011003-05Failure to Follow Radiation Work Permit Requirements2011Q2The inspectors reviewed a self-revealing, noncited violation of Technical Specification 5.4.1, resulting from workers who failed to follow radiation work permit requirements and entered a high radiation area, after climbing from one scaffold to another. As corrective action, the licensee posted the area, searched for similar situations in the plant, and entered the issue into the corrective action program as Condition Reports CR-CNS-2011-0318 and -03217. The failure to follow radiation work permit requirements is a performance deficiency. The finding was more than minor because it was associated with the Occupational Radiation Safety Cornerstone attribute (exposure control) of program and process and affected the cornerstone objective, in that, working in an area outside the scope of the radiation work permit and not knowing the dose rates in the high radiation area had the potential to increase personnel dose. Using the Occupational Radiation Safety Significance Determination Process, the inspectors determined the finding to have very low safety significance because: (1) it was not associated with 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. The finding has a human performance cross-cutting aspect associated with work practices component because the individuals did not use peer or self-checking before climbing to the second scaffold (H.4(a))(Section 2RS01).
05000298/FIN-2011003-06Failure to Correctly Translate Design Requirements into Installed Plant Configuration2011Q2The inspectors documented a self revealing, noncited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, associated with the licensees failure to assure that the applicable design basis for structures, systems, and components were correctly translated into specifications, procedures, and instructions. Specifically, the licensee failed to correctly translate the design requirements for the service water zurn strainers reduction gear to motor shaft into the installed plant equipment. This resulted in instances where the strainer motor was not able to perform its function of strainer backwash, an essential function, due to a failure of the wiper arm motor-to-gear box coupling. This issue was entered into the licensees corrective action program as Condition Report CR-CNS-2010-2213. The licensees failure to ensure that design requirements were correctly translated into installed plant equipment was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone, and affected the associated cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and is therefore a finding. Using Manual Chapter 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, the inspectors determined that a Phase 2/3 assessment was required because this was a design or qualification deficiency that did result in a loss of operability or functionality. The inspectors received support from the regional senior reactor analyst to evaluate this issue. As a bounding analysis, the analyst assumed: (1) the only time this design deficiency would cause an issue would be when strainer backwash was required due to debris loading; (2) the licensee had procedures already in place for manual actions in the event of a coupling failure; (3) the licensee would implement these actions before the strainer became inoperable due to debris loading; and (4) these actions were not complex and could easily be implemented. Given these assumptions the analyst determined that the finding was of very low safety significance (Green). This finding did not have a cross-cutting aspect because the most significant contributor did not reflect current licensee performance (Section 4OA2).
Retrieved from "https://kanterella.com/Special:Ask"