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| Quarter | Site | Title | Description | |
|---|---|---|---|---|
| 05000293/FIN-2010002-04 | 2010Q1 | Pilgrim | Licensee-Identified Violation | Technical Specification (TS) 3.7.C.1 requires secondary containment to be operable in the Run, Startup and Hot Shutdown Modes, during movement of recently irradiated fuel assemblies in the Secondary Containment and during operations with a potential for draining the reactor vessel. Contrary to the above, on December 22, 2009, the A torus trough, which is required to be maintained at a water level above Reactor Building Close Cooling Water drain pipe openings, was found dry. Secondary Containment was declared inoperable, the torus trough water level was restored and TS 3.7.C.1 was exited. This event is documented in Entergy\'s Corrective Action Program as CR-PNP-2009-5295 and CR-PNP-2009-5309. The finding was determined to be of very low safety Significance (Green) because the finding only represented an impact to the radiological barrier function provided by secondary containment and the standby gas treatment system. |
| 05000293/FIN-2010003-01 | 2010Q2 | Pilgrim | Submerged Medium Voltage Cables | The inspectors identified a Green finding (FIN) for improper maintenance of underground non-safety related medium voltage electric cables. The inspectors identified that Entergy allowed non-safety related medium voltage cables to remain submerged in water for extended periods of time. Entergy entered this issue into their Corrective Action Program (CAP), and specified corrective actions to identify all underground medium voltage cables included under the Cable Reliability Program, and to identify which manholes should have dewatering capability. The inspectors determined that the finding was more than minor because it was associated with the Design Control attribute of the Initiating Events cornerstone, and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, continued submergence of the non-safety related power cables (from the start-up transformer to electrical buses A2 and A4) could lead to cable failure and cause an event that would affect plant stability. The inspectors performed a Phase 1 Significance Determination Process screening of the finding in accordance with NRC Inspection Manual Chapter 0609, Attachment 4, \"Phase 1 - Initial Screening and Characterization of Findings,\" and determined that the finding was of very low safety significance because the condition did not contribute to both the likelihood of a reactor trip and the unavailability of mitigating systems equipment. The inspectors determined that this finding had a cross-cutting aspect in the Problem Identification and Resolution cross-cutting area, Corrective Action Program component, because Entergy personnel did not thoroughly evaluate the problem when submerged cabling was initially identified (P.1(c)). |
| 05000293/FIN-2010003-02 | 2010Q2 | Pilgrim | Licensee-Identified Violation | Technical Specification (TS) 3.5.B.3, Reactor Building Closed Cooling Water (RBCCW) System, requires that two RBCCW subsystems shall be operable whenever irradiated fuel is in the reactor vessel, reactor coolant temperature is >212 F, and prior to startup from a cold shutdown. With one RBCCW subsystem inoperable, the required action is to restore the SUbsystem to operable within 72 hours or be in Cold Shutdown within an additional 24 hours. Contrary to the above, the \"A\" train of RBCCW was inoperable for an indeterminate amount of time that likely exceeded the 72 hours of TS allowed outage time. Upon discovery of the broken bolt on the seismic support, the \"A\" train of RBCCW was declared inoperable. An immediate corrective action was completed to install a new bolt on the seismic support and TS 3.5.B.3 was exited. The event is documented in Entergy\'s Corrective Action Program as CR-PNP-2010-0130. The finding was evaluated using IMC 0609, Significance Determination Process, and was determined to be of very low safety significance (Green) because the finding would not have resulted in the total loss of a safety function during a seismic event. |
| 05000293/FIN-2010004-01 | 2010Q3 | Pilgrim | Failure to Manage a Yellow Risk Condition for an Unplanned Half Scram | The inspectors identified a Green non-cited violation (NCV) of 10 CFR 50.65 paragraph (a)(4) for Entergy\'s failure to manage a Yellow risk condition for an unplanned half-scram. Specifically, Entergy performed an incorrect risk assessment and thereby did not recognize an increase in risk to a Yellow condition had occurred, and as a result Entergy did not specify any risk management actions. Entergy entered this issue into their corrective action program, specified corrective actions to upgrade this risk to Yellow, and implemented appropriate risk management actions This finding was determined to be more than minor because Entergy did not consider the increase in Initiating Event likelihood where the outcome of the overall elevated plant risk put the plant into a higher risk management category, and thereby required additional risk management actions. In addition, the finding affected the Human Performance attribute of the Initiating Events cornerstone\'s objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions. The inspectors performed an evaluation in accordance with IMC 0609, Significance Determination Process, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process, because the finding related to Entergy\'s assessment and management of risk. The finding was determined to be of very low safety significance (Green) because the Incremental Core Damage Probability Deficit for the medium trip risk for the duration of the activity was less than 1.0 E-6 per year (approximately 1.0 E-9 per year). The inspectors determined that this finding had a cross-cutting aspect in the Human Performance cross-cutting area, Decision Making component, because when faced with an unexpected plant condition, Entergy did not correctly implement its systematic process to make a risk-significant decision. |
| 05000293/FIN-2010005-01 | 2010Q4 | Pilgrim | Failure to Manage a Yellow Risk Condition During HPCI Testing from the Alternate Shutdown Panel | The inspectors identified a Green non-cited violation (NCV) of 10 CFR 50.65 paragraph (a)(4) for Entergy\'s failure to correctly assess and manage a Yellow risk condition for planned testing of the High Pressure Coolant Injection (HPCI) system from the Alternate Shutdown Panel (ASP). Specifically, Entergy considered HPCI available by crediting multiple manual actions to restore the automatic function. However, these actions were not few or simple and would not have restored the HPCI automatic function in a timeframe consistent with guidance discussed in NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. In addition, HPCl\'s automatic function would not have been restored in a timeframe consistent with Pilgrim\'s Updated Final Safety Analysis Report (UFSAR), Section 6.4.1, which specifies 90 seconds for HPCI to reach its required design flow rate. Corrective actions included issuing a standing order to alert Operators of the specific requirements to maintain a system available during maintenance and testing. Corrective actions planned include revising Entergy\'s Risk Assessment Procedure to verify systems credited as available have clear and simple direction to restore automatic functional status during maintenance and testing. This finding was determined to be more than minor because Entergy\'s elevated plant risk would put the plant into a higher risk category and require additional risk management actions, namely protecting the Reactor Core Isolation Cooling system. In addition, the finding affected the Human Performance attribute of the Mitigating System\'s cornerstone objective to ensure the availability of systems to respond to initiating events and prevent undesirable consequences. The inspectors performed an evaluation in accordance with IMC 0609, Significance Determination Process, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process, because the finding related to Entergy\'s assessment and management of risk. The finding was determined to be of very low safety significance (Green) because the Incremental Core Damage Probability Deficit for the unavailability of HPCI for the duration of the activity was less than 1.0E-6 per year (approximately 2.6E-9 per year). The inspectors determined that this finding had a cross-cutting aspect in the Human Performance cross-cutting area, Work Control component, because Entergy did not correctly plan and coordinate work activities by incorporating appropriate risk insights (H.3(a)). (Section 1R13) |
| 05000293/FIN-2010005-02 | 2010Q4 | Pilgrim | Failure to Perform Required Quality Control Inspections | The inspectors identified an NCV of 10 CFR 50, Appendix B, Criterion X, Inspection, for the failure to ensure that Quality Control verification inspections were consistently included and correctly specified in quality-affecting procedures and work instructions for construction-like work activities as required by the Quality Assurance Program. Entergy initiated prompt fleet-wide corrective actions to ensure proper work order evaluation and proper inclusion of Quality Control verification inspections. This issue was entered into the corrective action program as condition reports (CR) CR-HQN 2009-01184 and CR-HQN-2010-0013. The failure to ensure that adequate Quality Control verification inspections were included in quality-affecting procedures and work instructions as required by the Quality Assurance Program was a performance deficiency. This issue was more than minor because, if left uncorrected, it could lead to a more significant safety concern; in that, the failure to check quality attributes could involve an actual impact to plant equipment. This issue affected the Design Control attribute of the Mitigating Systems cornerstone because missed or improper quality control inspections during plant modifications could impact the availability, reliability, and capability of systems needed to respond to initiating events. This performance deficiency was determined to be of very low safety significance (Green), since it was confirmed to involve a qualification deficiency that did not result in a loss of operability or functionality. The inspectors determined that this issue had a cross-cutting aspect in the Human Performance cross-cutting area, Decision-Making component, because the licensee did not have an effective systematic process for obtaining interdisciplinary reviews of proposed work instructions to determine whether Quality Control verification inspections were appropriate (H.1(a)). |
| 05000293/FIN-2010005-03 | 2010Q4 | Pilgrim | Failure to Implement the Experience and Qualification Requirements of the Quality Assurance Program | The inspectors identified an NCV of 10 CFR 50, Appendix B, Criterion II, Quality Assurance Program, for the failure to implement the experience and qualification requirements of the Quality Assurance Program. As a result, the licensee failed to ensure that an individual assigned to the position of Quality Assurance Manager met the qualification and experience requirements of ANSIIANS 3.1-1978 as required by the Quality Assurance Program. Specifically, the individual assigned to be the responsible person for the licensee\'s overall implementation of the Quality Assurance Program did not have at least one year of nuclear plant experience in the overall implementation of the Quality Assurance Program within the quality assurance organization prior to assuming those responsibilities. This issue was entered into the corrective action program as CRHQN- 2010-00386. The failure to ensure that an individual assigned to the position of Quality Assurance Manager met the qualification and experience requirements of ANSI/ANS 3.1-1978 as required by the Quality Assurance Program was a performance deficiency. This issue was more than minor because, if left uncorrected, it could create a more significant safety concern. The failure to have a fully qualified individual prOViding overall oversight to the Quality Assurance Program had the potential to affect all cornerstones, but the inspectors determined that this finding will be tracked under the Mitigating Systems cornerstone as the area most likely to be impacted. The issue was not suitable for quantitative assessment using existing NRC Significance Determination Process (SOP) guidance, so it was determined to be of very low safety significance (Green) using NRC Inspection Manual Chapter (IMC) 0609, Appendix M, Significance Determination Process Using Qualitative Criteria. The inspectors determined that there was no cross-cutting aspect associated with this finding because this issue was not indicative of current performance as it occurred more than three years ago. |
| 05000293/FIN-2010005-04 | 2010Q4 | Pilgrim | Licensee-Identified Violation | Procedure, EN-QV-111, \'Training and Certification of InspectionNerification and Examination Personnel, Section 4.0 (4)(i), requires that the Entergy corporate ANSI Level III inspector shall perform periodic (annual) surveillances of quality control inspection activities to ensure that the program is being adequately implemented and maintained. Contrary to the above, no surveillances of quality control inspection activities were performed for any Entergy site during calendar year 2008. The issue was not suitable for quantitative significance determination, so it was assessed using IMC 0609, Appendix M, and was evaluated using the qualitative criteria listed in Table 4.1. This finding was determined to be of very low safety significance because other quality assurance program functions remained unaffected by this performance deficiency, so defense-in-depth continued to exist. This issue was entered into the licensee\'s CAP as CR-HQN-2009-00111. |
| 05000293/FIN-2011002-01 | 2011Q1 | Pilgrim | Application of TS 3.3.8.1 When Control Rod Position Indication is Lost | An unresolved item (URl) was identified because additional information regarding the operability of control rods after control rod position indication was lost at PNPS is required to determine whether a performance deficiency exists, Control rod position indication was restored shortly after it was lost. The inspectors will review additional information when it is submitted by Entergy to determine if TS 3.3.8.1, Control Rod Operability, should have been entered when control rod position indication was lost. On January 20,2011, at 5:19 p.m., PNPS lost control rod position indication for all control rods. Instrumentation and control (l&C) technicians began troubleshooting the Rod Position Indication System (RPIS) and identified that the power supply feeding RPIS was inoperable. Operators determined that TS surveillance 4.3.8.1.5, Control Rod Operability, had been completed successfully just prior to losing RPIS and therefore they concluded that they had 24 hours from the surveillance completion before they would consider the surveillance not met. The inspector\\\'s review of Pilgrim\\\'s TS Bases identified the following statement: The OPERABILITY of an individual control rod is based on a combination of factors, primarily the scram insertion times, the associated control rod scram accumulator status, the control rod coupling integrity, and the ability to determine control rod position. When control rods are determined to be inoperable, TS 3.3.8.1, Control Rod Operability, requires the control rod to be fully inserted into the core within 3 hours. In addition, the associated Control Rod Drive for each control rod is required to be disarmed within 4 hours. l&C technicians repaired the power supply. RPIS was restored at 9:53 p.m., and control room personnel observed that there had been no change in control rod position. Condition Report (CR) CR-PNP-2O11-0272 was written to address the power supply failure and CR-PNP-2011-0511 was subsequently written to address Entergy\\\'s interpretation and administration of TS 3.3.8.1. URI 05000293/2011002-01, Application of TS 3.3.B.1 when Control Rod Position Indication is Lost. |
| 05000293/FIN-2011002-02 | 2011Q1 | Pilgrim | Inadequate Corrective Actions for RCIC Torus Suction Valve | A self-revealing Green NCV of 10 CFR 50, Appendix B, Criterion XVl, Corrective Action, was identified for Entergy\'s failure to correct a condition adverse to quality. Entergy did not correct a Reactor Core lsolation Cooling (RCIC) torus suction valve which had failed to close during testing on October 4,2010. On January 5,2011, the same valve again failed to close during testing. Pilgrim\'s corrective actions included cleaning and replacing circuit breaker contacts and revising maintenance procedures to perform periodic resistance checks on motor control center circuit breaker cubicle secondary disconnects. Entergy has entered this issue into the corrective action program (CR-PNP-201 0-3486 and CR-PNP-2011-0046). The inspectors determined that the finding was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems Cornerstone, and adversely affected the cornerstone\'s objective to ensure the reliability and availability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the RCIC torus suction valve failure to close affected the reliability of the RCIC system, and the RCIC system was made unavailable during system troubleshooting and repairs in January 2011. The inspectors determined the significance of the finding using IMC 0609.04, Phase 1 - Initial Screening and Characterization of Findings. The finding was determined to be of very low safety significance (Green) because the finding did not involve a design or qualification deficiency resulting in a loss of operability or functionality, did not result in a loss of system safety function of a single train for greater than its Technical Specification outage time, and did not screen as potentially risk significant due to external initiating events. The capability of RCIC to perform its function was not lost since the torus suction valve would have been able to be cycled open in the event RCIC needed to be aligned to the torus. This finding had a cross-cutting aspect in the Problem ldentification and Resolution cross-cutting area, Corrective Action Program component, because Entergy did not thoroughly evaluate the problem with the RCIC torus suction valve such that the resolution in October 2010 addressed the causes and corrected the problem. |
| 05000293/FIN-2011002-03 | 2011Q1 | Pilgrim | Need For Clarification on Condensate Storage Tank Suction Piping ASME Classification | An unresolved item (URI) was identified because additional information is needed to determine if a performance deficiency exists regarding a discrepancy between various piping and instrumentation drawings (P&IDs) for the condensate and demineralized water storage/transfer systems, and the associated in-service inspection (ISI) drawings for the High Pressure Coolant Injection (HPCI) and Reactor Core Isolation Cooling (RCIC) piping and their related ASME Code safety classification. During this review the inspector noted a lack of clear description in assignment of piping safety classification shown on plant drawings for the aforementioned systems. The inspector observed that symbol convention used on the drawings was not reconciled with the requirements presented in the piping specification (M300, Rev 107, Section 3.0, ltem 1.0, Classification of Piping Components), and the P&lD legend. Entergy initiated CR PNP-2011-0127, which identified the need for a definition of the safety classification of the HPCI and RCIC suction piping from the condensate storage tanks to the first isolation valve within the auxiliary building. Appropriate code safety classification is necessary to ensure accurate in-service inspection requirements. Entergy\\\'s actions with regard to the resolution of the HPCI and RCIC piping safety classification (and boundary class changes) as shown on the referenced drawings remain to be reviewed and assessed to ascertain conformance with the applicable ASME Code (Section Xl) and NRC regulatory requirements. While the discrepancy may be related to a drawing error, it is possible that the subject piping is ASME Class 2 (or other), and should have been subject to ASME Code Class 2 (or other) design and testing requirements. URI 05000293/2011002-03, Need For Clarification on Condensate Storage Tank Suction Piping ASME Classification. |
| 05000293/FIN-2011003-01 | 2011Q3 | Pilgrim | Transient Combustible Loading in SLC Room in Excess of the Fire Hazards Analysis Limit | The inspectors identified a Green NCV of License Condition 3.F of the Pilgri facitity Operating License (DPR-35) for the failure to evaluate transient combustible fir loading in the Standby Liquid Control (SLC) room. Specifically, Entergy did not evaluat the acceptability of transient combustibles that had been moved into the SLC room whic were in excess of the allowed combustible loading discussed in the Fire Hazards Analysis Entergy immediately walked down the area, established compensatory measures, an completed a transient combustibles evaluation. Entergy has since removed the transien combustibles from the area The inspectors determined that the failure to evaluate the transient combustibles was mor than minor based on a similar example described in Inspection Manual Chapter 0612 \\\"Power Reactor Inspection Reports,\\\" Appendix E, \\\"Examples of Minor lssues,\\\" Section 4k Specifically, the fire loading exceeded the Fire Hazard Analysis assumption and was no evaluated for acceptability. The finding is also associated with the Protection Agains External Events attribute of the Mitigating Systems cornerstone and could have adversel affected the cornerstones objective to ensure the availability of systems that respond t events to prevent undesirable consequences (i.e,, core damage). Specifically, a fire in th SLC room could affect the availability of the SLC system to respond to an event. IMC 0609 \\\"significance Determination Process,\\\" Appendix F, \\\"Fire Protection Significanc Det,ermination Process,\\\" was used to evaluate the significance of the finding. The safet significance of the finding was determined to be very low because the degradation facto was low; that is, the transient combustible evaluation process subsequently identified nearl the same level of fire protection effectiveness and reliability for the SLC room as it woul have if the degradation had not been present This finding had a cross-cutting aspect in the Human Performance cross-cutting area Work Control component; in that, Entergy did not coordinate work activities to ensure th interdepartmental coordination necessary to assure plant and human performance Specifically, the refueling organization did not notify fire protection engineering to ensure a evaluation of the\\\'transient combustible loading was completed for the SLC room (H.3(b)) (Section 1R05) |
| 05000293/FIN-2011003-02 | 2011Q3 | Pilgrim | Submerged Medium Voltage Cables | The inspectors identified a Green finding (FlN) for the improper maintenance o underground non-safety related medium voltage electric cables. The inspectors identifie that Entergy allowed non-safety related medium voltage cables to remain submerged i water for extended periods of time. Entergy entered this issue into their corrective actio program, specified corrective actions to increase the dewatering frequency of the affecte manhole, and then installed an automatic dewatering pump The inspectors determined that the finding was more than minor because it was associate with the Design Control attribute of the Initiating Events cornerstone and affected th cornerstone objective of limiting the likelihood of those events that upset plant stability an challenge critical safety functions during shutdown as well as power operations Specifically, continued submergence of the non-safety related power cables (from the startup transformer to electrical buses A2 and 44) could lead to cable failure and cause a event that would affect plant stability. The inspectors performed a Phase 1 Significanc Determination Process screening of the finding in accordance with NRC Inspection Manua Chapter 0609, Attachment 4, \\\"Phase 1 - Initial Screening and Characterization of Findings,\\\ and determined that the finding was of very low safety significance because the conditio did not contribute to both the likelihood of a reactor trip and the unavailability of mitigatin systems equipment The inspectors determined this finding had a cross-cutting aspect in the Proble ldentification and Resolution cross-cutting area, Corrective Action Program component because Entergy personnel did not implement corrective actions in a timely manner t ensure that underground cables were not submerged, commensurate with the safet significance and complexity of the degraded condition (P.1(d)). (Section 1R06) |
| 05000293/FIN-2011003-03 | 2011Q3 | Pilgrim | lnadequate Risk Assessment for Planned Maintenance and Testing on RCIC, SLC and ATS Systems | The inspectors identified a Green NCV of 10 CFR 50.65 paragraph (aX4) fo Entergy\'s failure to conduct an adequate risk assessment for planned Analog Trip Syste (ATS |
| 05000293/FIN-2011003-04 | 2011Q3 | Pilgrim | Failure to Enter Technical Specifications for CHREAFS | The inspectors identified a Green NCV of Technical Specification (TS) 3\'7.8.2\'f StanOOV Gas Treatment System and Control Room High Efficiency Air Filtration Syste (CRHEAFS),\" for Entergy\'s failure to enter and perform the actions prescribed in TS afte the Control Room Envelope (CRE) was breached during work on a vital area door into th CRE. Entergy has since repaired the vital area door and restored the CRE. This finding was more than minor because it was associated with the Human Performanc attribute of the Barrier Integrity cornerstone (maintain the radiological barrier function of th control room) and adversely affected the cornerstone objective to provide reasonabl assurance that physical design barriers protect the public from radionuclide release caused by accidents or events. Specifically, the inoperable CRE could affect the operator\' ability to occupy the control room under adverse radiological, chemical, or smoke condition while responding to an event. IMC 0609, \"Significance Determination Process,\" Attachmen 0609.04, \"Phase 1- Initial Screening and Characterization of Findings,\" was used t evaluate the impact of the finding on loss of operability or functionality of the CRE an CHREAFS, and it was determined that further evaluation was required since the finding ha the potential to impact the control room envelope due to the effects of smoke and toxic gas As a result of this screening, a Phase 3 evaluation was conducted by a Senior Reacto Analyst (SRA). The SRA conducted a qualitative evaluation and determined the risk impac on control room habitability, due to this finding, from smoke and toxic gas to be lo (Green). Specifically, the Pilgrim Station Individual Plant Examination for External Event (IPEEE), sections 5.3.3 and 5.3.4, identified that the overall risk from on-site and off-sit chemical release was low The inspectors determined that this issue had a cross-cutting aspect in the Work Contro component of the Human Performance cross-cutting area. Specifically, Entergy did no plan and coordinate work activities affecting the CRE such that interdepartmenta coordination assured plant and human performance. In this case, Operations was no made aware that Maintenance would be working on the control room vital door (H.3(b)) (Section 1R15) |
| 05000293/FIN-2011003-05 | 2011Q3 | Pilgrim | Failure to Enter Technical Specifications after Loss of Control Rod Indication | The inspectors identified a Green NCV of Technical Specification (TS) 3.3.B. Control Rod Operability,\\\" for Entergy\\\'s failure to enter and perform the actions prescribe in Technical Specifications after losing control rod position indication. Entergy has sinc restored control rod position indication by repairing a failed power supply, Condition repor CR-PNP-2011-0272 was written to address the power supply failure and condition repor CR-PNP-201 1-051 1 was subsequently written to address Entergy\\\'s administration of TSs The inspectors determined that the issue was more than minor because the finding wa associated with the Equipment Performance attribute of the Mitigating Systems cornerston and adversely affected the cornerstone\\\'s objective to ensure the reliability of systems tha respond to events to prevent undesirable consequences (i.e., core damage). Specifically the locations of the control rods were indeterminate which could substantially impac operator\\\'s abilities to implement Emergency Operating Procedures, IMC 0609 \\\"Signi1cance Determination Process,\\\" Attachment 0609.04, \\\"Phase 1-lnitial Screening an Characterization of Findings,\\\" was used to evaluate the significance of the finding Attachment 0609.04, Table 4a, was used to evaluate the impact of the finding on loss o operability or functionality. The inspectors determined that the function of the control rod to add negative reactivity to the core during an event was not affected (SCRAM time an control rod worth were not affected). In addition, alternate means were available t operators to determine control rod position and once the power supply was restored, th control rods were determined to have remained in their original positions. Also, since th finding is not potentially risk significant due to a seismic, flooding or severe weathe initiating event, the finding was determined to be of very low safety significance (Green) The inspectors determined that this issue had a cross-cutting aspect in the Decision Makin component of the Human Performance cross-cutting area. Specifically, Entergy did not us conservative assumptions in decision making and adopt a requirement to demonstrate tha the proposed action is safe in order to proceed rather than a requirement to demonstrat that it is unsafe in order to disprove the action. ln this case, Entergy did not take th conservative approach to enter Technical Specifications when faced with a degrade condition affecting control rod operability (H.1(b)). (Section 1R15) |
| 05000293/FIN-2011004-01 | 2011Q3 | Pilgrim | Failure to Verify the Adequacy of the Design for the \'C\' Salt Service Water Pump | The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion III, Design Control, because Entergy\'s design control measures did not ensure two-over-one seismic protection of the \'C\' Salt Service Water (SSW) Pump. Specifically, Entergy did not ensure that a Class I to Class II interface would not result in a failure of a Class I component (\'C\' SSW Pump). Corrective actions included installing a temporary modification (Le., water shield), to protect the pump motor from potential spray effects of a Class II piping failure and performing an extent of condition review. The inspectors performed a review of Inspection Manual Chapter (IMC) 0612, Appendix E, Examples of Minor Issues, and did not find a similar more than minor example. The finding was determined to be more than minor because it was associated with the Protection Against External Events (Le., seismic) attribute of the Mitigating Systems Cornerstone, and adversely affected the cornerstone\'s objective to ensure the reliability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the \'C\' SSW pump motor was vulnerable to water spray from a failed Class II pipe during a seismic event which could have rendered the pump inoperable. The inspectors used IMC 0609.04, Phase 1 - Initial Screening and Characterization of Findings, and determined that further evaluation was required since the finding was potentially risk significant due to a seismic initiating event. As a result of this screening, a Phase 3 evaluation was conducted by a regional Senior Reactor Analyst (SRA). The condition was assessed as Green, with a change in core damage frequency (CDF) calculated to be 1.29E-8. Since the finding was assessed to have a CDF of less than 1E-7, large early release frequency was not required to be assessed. The finding does not have a cross-cutting aspect since the failure to verify the adequacy of design with respect to ensuring two-over-one seismic protection for the \'C\' SSW pump is not indicative of current licensee performance. In addition, current Entergy design procedures require rigorous Class II-over-I criteria for all new modifications. |
| 05000293/FIN-2011004-02 | 2011Q3 | Pilgrim | Failure to Identify a Primary Containment System Maintenance Rule Functional Failure and Thereby Establish Monitoring Requirements for the System | The inspectors identified a Green NCVof 10 CFR 50.65, paragraph (a)(1) and (a)(2), Requirements for Monitoring the Effectiveness of Maintenance of Nuclear Power Plants, because Entergy did not monitor the performance of the Primary Containment System (Drywell to Torus Vacuum Breaker Components) against license-established goals to provide reasonable assurance that these components are capable of fulfilling their intended functions. Specifically, Entergy did not identify a functional failure of the Drywell to Torus Vacuum Breaker Component portion of the Primary Containment System and thereby did not recognize that the system exceeded its unavailability performance criteria, requiring a Maintenance Rule (a)(1) evaluation. Entergy subsequently conducted an (a)(1) evaluation and concluded that the system should be classified as (a)(1), corrective actions specified, and system monitoring completed. The finding is more than minor because it is associated with the Barrier Performance attribute of the Barrier Integrity cornerstone, in that the issue affected the Primary Containment System reliability due to the failure to recognize the need to evaluate the system for goals, corrective actions, and monitoring. The inspectors determined the significance of the finding using IMC 0609-04, Phase 1 - Initial Screening and Characterization of Findings. The finding was determined to be of very low safety significance (Green) because the degraded condition had been corrected by the time of the failure to accurately evaluate the maintenance rule functional failure. As a result, this finding did not involve a design or qualification deficiency, did not result in a loss of system safety function, and did not screen as potentially risk significant due to external initiating events. The finding has a cross-cutting aspect in the Human Performance cross-cutting area, Decision Making component; in that, Entergy did not use conservative assumptions when evaluating the degraded Drywell to Torus Vacuum Breakers condition to correctly conclude that a functional failure had occurred. Specifically, Entergy did not consider that the function of these vacuum breakers would be required as soon as plant conditions exceeded 212F, and therefore, the procedural guidance for Technical Specification applicability not being exceeded was an incorrect basis for this decision |
| 05000293/FIN-2011004-03 | 2011Q3 | Pilgrim | Failure to Accurately Assess Risk of Maintenance on Standby Gas and Secondary Containment | The inspectors identified a Green NCV of 10 CFR 50.65(a)(4) because Entergy did not assess and manage risk during elective maintenance for both \'A\' and \'B\' trains of the StandBy Gas Treatment (SBGT) system. Specifically, Entergy did not consult qualitative guidance in their risk assessment process procedures before removing both trains of SBGT from service and, therefore, removing the Secondary Containment key safety function while online. Corrective actions planned include evaluating and revising risk assessment procedures, and communicating qualitative risk assessment guidance to Senior Reactor Operators and Work Week Managers. A review of NRC Inspection Manual Chapter (IMC) 0612, Appendix E, Minor Examples, identified that Section 7, Maintenance Rule, Example e, reflected a similar more than minor example. This finding was determined to be more than minor because Entergy\'s risk assessment failed to account for the loss or significant uncompensated impairment of a key operating safety function. In addition, the finding affected the Human Performance attribute of the Barrier Integrity cornerstone\'s objective to ensure that physical design barriers (containment) protect the public from radionuclide releases caused by accidents or events. The inspectors performed an evaluation in accordance with IMC 0609, Significance Determination Process, Attachment 4, Phase 1 -Initial Screening and Characterization of Findings, and determined that the finding was of very low safety significance (Green) because the finding only represented a degradation of the radiological barrier function provided for the SBGT system. The inspectors determined that this finding had a cross-cutting aspect in the Human Performance crosscutting area, Work Control component, because Entergy did not plan work activities by incorporating appropriate risk insights |
| 05000293/FIN-2011005-01 | 2011Q4 | Pilgrim | Licensed Operators Stood Watch Without Being Medically Qualified | The inspectors identified an apparent violation (AV) of Title 10 of the Code of Federal Regulations (10 CFR) 55.53 and 10 CFR 55.21 related to Entergy\\\'s medical examinations of licensed operators. Specifically, at various times over a period of almost four years, ten operators did not meet certain medical requirements (for stamina and/or blood pressure) for performing NRC-licensed operator activities, and the operators continued to perform NRC-licensed activities. Additionally, Entergy did not perform complete medical testing of its licensed operators, in that five of those licensed operators had not been administered stamina tests for more than two years and therefore did not complete their NRC-required biennial medical exam. lmmediately after the NRC identified the issue, Entergy restricted operators from watch until they could pass the requirements of their medical testing. Entergy entered this issue into their corrective action program (CR-PNP-201 1 -04554). The inspectors determined that Entergy\\\'s failure to ensure that licensed operators met the license conditions associated with medical testing prior to performing license activities was a performance deficiency that was within Entergy\\\'s ability to foresee and correct and should have been prevented. The inspectors determined that Traditional Enforcement applies, as the issue had the potential to impact the NRC\\\'s ability to perform its regulatory function because the NRC relies upon the accurate certification by the licensee\\\'s medical examiner to ensure all licensed operators meet the medical conditions of their license. Specifically, ten operators had not taken the stamina test during their annual physical, but were certified by the medical examiner and licensee as being fit to safely perform their watch-standing duties. Additionally, five of those operators had not taken the stamina test during their biennial physical, but were certified by the medical examiner and licensee as being fit to safely perform their watch-standing duties. Lastly, an individual who had not passed their blood pressure examination, and required a license condition to take medication, was placed back on watch-standing duty without such a license condition. The performance deficiency was screened against the Reactor Oversight Process (ROP) per the guidance of lnspection Manual Chapter (lMC) 0612, Appendix B, lssue Screening. No associated ROP finding was identified and no cross-cutting aspect was assigned. These issues are being characterized as an apparent violation in accordance with the NRC\\\'s Enforcement Policy, and its final significance will be dispositioned in separate future correspondence. |
| 05000293/FIN-2011005-02 | 2011Q4 | Pilgrim | Entergy did not Provide Complete and Accurate Medical Information for Licensed Operator Renewal Applications | The inspectors identified an AV of 10 CFR 50.9, Completeness and Accuracy of Information, related to Entergy\\\'s medical examinations of licensed operators. Specifically, Entergy did not provide information to the NRC that was complete and accurate in all material respects, in that Entergy submitted two NRC licensed operator renewal applications which certified that the applicants met the medical requirements for license renewal when in fact they did not complete the required stamina tests. Entergy entered this issue into their corrective action program (CR-PNP-2011-04554). The inspectors determined that Entergy\\\'s failure to provide complete and accurate information to the NRC was a performance deficiency that was within Entergy\\\'s ability to foresee and correct and should have been prevented. The inspectors determined that Traditional Enforcement applies, as the issue had the potential to impact the NRC\\\'s ability to perform its regulatory function. Specifically, Entergy did not provide information to the NRC that was complete and accurate in all material respects, in that although Entergy had not administered complete medical examinations of licensed operators in accordance with American National Standards Institute/American Nuclear Society (ANSI/ANS)3.4-1983 (because it had not conducted stamina testing), it submitted two NRC Form-396s for renewal of operator licenses which certified that the applicants met the medical requirements of ANSI/ANS 3.4-1983, Subsequently, the NRC made a licensing decision based on this information that was not complete and accurate in all material respects. The performance deficiency was screened against the ROP per the guidance of IMC 0612, Appendix B, lssue Screening. No associated ROP finding was identified and no cross-cutting aspect was assigned. This issue constitutes an apparent violation in accordance with the NRC\\\'s Enforcement Policy, and its final significance will be dispositioned in separate future correspondence. |
| 05000293/FIN-2011005-03 | 2011Q4 | Pilgrim | Entergy did not Notify the NRC within 30 days of discovering changes in Medical Conditions | The inspectors identified an AV of 10 CFR 50.74, Notification of Change in Operator or Senior Operator Status. Specifically, Entergy did not notify the NRC within 30 days of discovering a change in medical condition for two licensed operators. Subsequently, Entergy submitted notifications for both operators on November 10, 2011 and entered the issue into their corrective action program (CR-PNP-2011-04554). The inspectors determined that Entergy\\\'s failure to notify the NRC within 30 days of discovering the change in medical condition for two licensed operators was a performance deficiency that was within Entergy\\\'s ability to foresee and correct and should have been prevented. The inspectors determined that Traditional Enforcement applies, as the issue had the potential to impact the NRC\\\'s ability to perform its regulatory function because if a licensed operator has a change in medical condition, the NRC may need to perform a review for consideration of a licensing action. Specifically, Entergy had not notified the NRC within 30 days of learning of a change in medical condition for two licensed operators for which a license condition was required. The performance deficiency was screened against the ROP per the guidance of IMC 0612, Appendix B, lssue Screening. No associated ROP finding was identified and no crosscutting aspect was assigned. This issue constitutes an apparent violation in accordance with the NRC\\\'s Enforcement Policy, and its final significance will be dispositioned in separate future correspondence. |
| 05000293/FIN-2011005-04 | 2011Q4 | Pilgrim | Entergy Incorrectly Credited Operators Proficiency Watch-Standing Experience and the Operators subsequently stood watch | The inspectors identified a Severity Level lV NCV of 10 CFR 55.53 (e) and (f), Conditions of Licenses, because Entergy incorrectly credited two individuals for proficiency watch-standing experience and then these operators subsequently stood watch without meeting the minimum proficiency requirements necessary to maintain an active license. Entergy implemented immediate corrective action that included discontinuing the practice of crediting the emergency core cooling system (ECCS) and Extra Balance of Plant (BOP) positions for proficiency. Entergy entered this issue into their corrective action program (CR-PNP-201 1-04649). The inspectors determined that Entergy incorrectly credited two individuals for proficiency watch-standing experience and then these operators subsequently stood watch in the control room. This error constitutes a performance deficiency that was within Entergy\\\'s ability to foresee and correct and should have been prevented. The inspectors determined that Traditional Enforcement applies, as the issue had the potential to impact the NRC\\\'s ability to perform its regulatory function because if a licensed operator fails to meet the conditions of their license, the NRC may need to perform a review for consideration of a licensing action, and if the information regarding an individual\\\'s qualifications is not accurately presented, the NRC could potentially make an incorrect licensing decision based on the inaccurate information. Specifically, Entergy did not ensure that two reactor operator (RO) licensed individuals maintained their RO licenses in an active status in the 2nd quarter 2011, prior to standing RO watches in the 3rd quarter 201 1 which violated a license condition as specified in 10 CFR 55.53 (e) and (f). The performance deficiency was screened against the ROP per the guidance of IMC 0612, Appendix B, lssue Screening. No associated ROP finding was identified and no cross-cutting aspect was assigned. This issue is similar to violation example 6.4.c.1(c) in the NRC Enforcement Policy for a Severity Level lll violation because it involves noncompliance with a condition stated on an individual\\\'s license. However, since there were no adverse impacts to nuclear safety, the NRC has determined that this issue constitutes a Severity Level lV NCV in accordance with the NRC\\\'s Enforcement Policy. |
| 05000293/FIN-2011005-05 | 2011Q4 | Pilgrim | Written NRC Biennial Written Examinations did not meet Qualitative Standards | The inspectors identified a Green finding of 10 CFR 55.59, Requalification, based on a determination that greater than 20 percent of the biennial requalification written exam questions administered to licensed operators during weeks three and four of the 2010 examination cycle were unacceptable. Entergy entered this issue into the corrective action program (CR-PNP-201 1 -04561). The inspectors determined that the finding was more than minor because it was associated with the Human Performance attribute of the Mitigation Systems cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the finding affected the quality and level of difficulty of biennial written exams which potentially impacted Entergy\'s ability to appropriately evaluate licensed operators. The risk importance of this issue was evaluated using IMC 0609, Appendix l, Licensed Operator Requalification Significance Determination Process (SDP). Appendix I was entered using the number of written exam questions that did not meet the qualitative standard for the written exam questions. The qualitative standard used by the inspectors is defined in NUREG-1021, Rev. 9, ES- 602, Attachment 1, Guidelines for Developing Open-Reference Examinations, and Appendix B, Written Examination Guidelines. Since 28.6 percent of the questions reviewed did not meet the guidance, Block 16 of Appendix I applied, specifically, Were more than 20 percent of the written questions sampled by the inspectors unacceptable? Based on this screening criteria, the finding was characterized by the SDP as having very low safety significance (greater than 20 percent unacceptable), or Green. A review of the cross-cutting aspects was performed and no cross-cutting aspect was identified that would be considered a contributor to the cause of the finding. |
| 05000293/FIN-2011005-06 | 2011Q4 | Pilgrim | Licensee-Identified Violation | The following violation of very low safety significance (Green) was identified by Entergy and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as a non-cited violation (NCV), Technical specification 5.4,1, Procedures, requires that written procedures shall be established, implemented, and maintained including the emergency operating procedures (EOP) required to implement the requirements of NUREG-0737, Clarification of TMI Action Plan Requirements, and NUREG-0737, Supplement 1, as stated in Generic Letter 82-33, Order Confirming Licensee Commitments on Emergency Response Capability Schedules. Contrary to technical specification 5,4.1, portions of EOP-2, RPV Control, Failure to Scram, could not have been implemented from October 8, 2011 through November 6,2011. Specifically, injection of sodium pentaborate would not have been able to be performed because Pilgrim\'s warehouse did not resupply its inventory of the required 12 barrels of sodium pentaborate necessary to implement EOP-2. Pilgrim entered this issue into the corrective action program as CRPNP- 201 1-4887, and obtained the required inventory on November 6, 201 1. The inspectors determined that the finding was of very low safety significance (Green) in accordance with NRC Inspection Manual Chapter 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, Mitigating Systems Cornerstone, because the finding was not a design or qualification deficiency, did not represent a loss of system safety function, did not represent an actual loss of a single train for greater than its technical specification allowed outage time, and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. |
| 05000293/FIN-2011008-01 | 2011Q1 | Pilgrim | Failure to Follow Corrective Action Process for HPCI Diaphragm Degraded Condition | The NRC identified a finding of very low significance for Entergy\'s failure to follow their corrective action process in the identification, documentation, and evaluation of a degraded condition. Specifically, Entergy failed to recognize, fully document, and evaluate in their corrective action process that an installed diaphragm in the High Pressure Coolant Injection (HPCI) System exceeded its manufacturer-recommended service life. Entergy entered this issue in their corrective action process (CR-PNP-2011-0917) to evaluate and determine corrective actions to address this issue. The inspectors determined the finding was more than minor because it is similar to example 4(a) of NRC Inspection Manual Chapter (IMC) 0612, Appendix E, \'Minor Examples,\' in that Entergy did not perform an evaluation that was later determined to adversely affect safetyrelated equipment. The inspectors determined the finding was of very low safety significance (Green) using IMC 0609.04, Phase 1 - Initial Screening and Characterization of Findings in that the finding involved a qualification deficiency not resulting in the loss of operability of HPCI. The finding has a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action program because Entergy did not identify that exceeding the service life of the PCV-2301-238 diaphragm was a condition adverse to quality. |
| 05000293/FIN-2011008-02 | 2011Q1 | Pilgrim | Torus Air Temperature 10 CFR 50.65(a)(2) Performance Demonstration Not Met | The NRC identified a NCV of 10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, paragraph (a)(2), for Entergy\'s failure to adequately demonstrate primary containment system (a)(2) performance was effectively controlled through performance of appropriate preventive maintenance. Specifically, as evidenced by repeat functional failures of torus air temperature indication during the fall of 2009 and January 2010, the (a)(2) performance demonstration was no longer justified in accordance with Entergy\'s maintenance rule implementing procedure guidance. Entergy entered this issue in their corrective action process (CR-PNP-201100880) to evaluate corrective actions needed to address this issue. The inspectors determined that the finding was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, failures of torus air temperature indication present a challenge to operators who rely on the indication to diagnose and respond to initiating events. Per the guidance provided in Inspection Procedure 71111.12, Maintenance Effectiveness, issued 11/16/2009, inspectors considered this performance deficiency to be a Category III finding since a historical review revealed a continuing declining trend in performance of the instrument, as indicated by additional functional failures. Because this issue was classified as Category III, the inspectors determined the significance of this finding using IMC 0609.04, Phase 1 -Initial Screening and Characterization of Findings. The inspectors determined that this finding was of very low safety significance (Green) because it was not a design or qualification deficiency, did not represent a loss of safety system function, and did not screen as potentially risk significant due to external initiating events. The inspectors determined that this finding has a cross cutting aspect in the area of problem identification and resolution. Specifically, Entergy did not properly evaluate and classify the torus air temperature indication failures with respect to the maintenance rule. |
| 05000293/FIN-2012003-01 | 2012Q2 | Pilgrim | Failure to Verify the Adequacy of the Design of MCC-B18 with Respect to Internal Flooding | The inspectors identified a finding of very low safety significance (Green) involving a non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion III, Design Control , because Entergy did not verify the adequacy of the design of the Motor Control Center (MCC) B-18 enclosure. Specifically, Entergy had not previously evaluated the susceptibility of MCC B-18 to internal flooding from a potential pipe break by the use of calculational methods or by the performance of design reviews. Entergy entered this issue in the corrective action program (CR-PNP-2012-1351). The performance deficiency was determined to be more than minor because it is associated with the Design Control attribute of the Mitigating Systems cornerstone, and adversely affected the cornerstones objective to ensure the reliability of systems that respond to initiating events to prevent undesirable consequences. The inspectors used IMC 0609.04, Phase 1 Initial Screening and Characterization of Findings and IMC 0609 Appendix A, Exhibit 2, Mitigating Systems Screening. The finding was determined to be of very low safety significance (Green) because the finding was a design deficiency and did not represent a loss of system and/or function or the loss of a single train for greater than its Technical Specification outage time. The finding does not have a cross-cutting aspect since the verification of the MCC B18 design is not indicative of current licensee performance. Entergys current design change procedures require an evaluation of flooding vulnerabilities for new modifications. |
| 05000293/FIN-2012004-01 | 2012Q3 | Pilgrim | Inadequate Processing of Work Package Results in Reactor Scram | A finding of very low safety significance (Green) was identified for personnel not adequately classifying work in regards to processing an emergent work order. Specifically, personnel classified work on a reach rod position indication for valve 1-HO-163, Steam Jet Air Ejector (SJAE) steam supply valve, as minor maintenance, which resulted in the failure to identify and correct the reach rod indicator and position. This resulted in a degraded vacuum during a power maneuver and a subsequent reactor scram. Entergy entered this issue in the corrective action program (CR-PNP-2012-2304). The finding was determined to be more than minor because it was associated with the Configuration Control (i.e., Operating Equipment Lineup) attribute of the Initiating Events cornerstone, and adversely affected the cornerstones objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. The inspectors screened the issue for significance using IMC 0609.04, Phase 1 Initiating Screening and Characterization of Findings and IMC 0609 Appendix A, Exhibit 1, Initiating Events Screening. The finding was determined to be of very low safety significance (Green) because although the performance deficiency did result in a reactor scram, it did not cause a reactor scram combined with the loss of mitigating equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. This finding has a cross-cutting aspect in the Human Performance cross-cutting area, Work Control component, because Entergy did not appropriately plan and coordinate the repair of the SJAE steam supply valve by incorporating the operational impact of the work activity consistent with nuclear safety. |
| 05000293/FIN-2012005-01 | 2012Q4 | Pilgrim | Failure to Verify the Adequacy of the Design of the SBO Fuel Oil Transfer System | The inspectors identified a finding of very low safety significance (Green) involving a non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, because Entergy did not implement design control measures commensurate with those applied to the original design when a system modification was made to the Emergency Diesel Generators (EDG) fuel oil transfer system. Specifically, Entergy did not implement the design change or modification process when a Station Blackout Diesel Generator fuel oil transfer system was put in place in 1998 to meet the EDG support function of transferring sufficient fuel to meet the mission time of the EDG safety function. As a result, the fuel oil suction hose used was not in accordance with the design. Entergy replaced the degraded and non conforming hose, and documented this issue in their corrective action program (CR-PNP-2012-3428). The performance deficiency was determined to be more than minor because it is associated with the Design Control attribute of the Mitigating Systems cornerstone, and adversely affected the cornerstones objective to ensure the reliability of systems that respond to initiating events to prevent undesirable consequences. The finding was determined to be of very low safety significance (Green) because the finding was a design process deficiency and did not represent a loss of system and/or function or the loss of a single train for greater than its TS outage time. The finding does not have a cross-cutting aspect since the failure to implement the design change verification process is not indicative of current licensee performance. Entergys current design change procedures require design reviews of this type of in-field modification. |
| 05000293/FIN-2012005-02 | 2012Q4 | Pilgrim | Inadequate Corrective Actions for Station Blackout Battery | The inspectors identified a finding of very low safety significance (Green) because Entergy did not complete Shutdown Transformer Bus (A8) battery discharge testing within the required timeframe as required by procedure EN-LI-102, Corrective Action Process. Specifically, although Entergy identified in April 2011 that required battery testing had not been completed, as of this inspection, the testing had still not been completed. Entergy entered the issue into their corrective action program (CR-PNP-2012-5071). This finding was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective of ensuring the capability of systems that respond to initiating events to prevent undesirable consequences. The finding was determined to be of very low safety significance (Green) because it was not a design or qualification deficiency, did not represent a loss of system safety function, and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program component, because Entergy did not take appropriate corrective actions to address a safety issue in a timely manner. Specifically, Entergy did not perform vendor required discharge testing in a timeframe consistent with the safety significance of the equipment. |
| 05000293/FIN-2012005-03 | 2012Q4 | Pilgrim | Inadequate Design Control for Station Blackout Battery | The inspectors identified a finding of very low safety significance (Green) because Entergy did not verify the adequacy of the design of the Station Blackout (SBO) battery as required by procedure EN-DC-126, Engineering Calculation Process. Specifically, Entergy used an incorrect minimum voltage for the SBO battery resulting in the sizing calculation significantly overstating the available design margin. Entergy entered the issue into their corrective action program (CR-PNP-2012-5076). This finding was more than minor because it was associated with the design control attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective of ensuring the reliability of systems that respond to initiating events to prevent undesirable consequences. The finding was determined to be of very low safety significance (Green) because it was not a design or qualification deficiency, did not represent a loss of system safety function, and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. This finding has a cross-cutting aspect in the area of Human Performance, Resources Component, because Entergy did not ensure that accurate design documentation was available. Specifically, Entergy used the incorrect minimum voltage for the SBO battery, resulting in nonconservative conclusions in the battery sizing calculation. |
| 05000293/FIN-2012005-04 | 2012Q4 | Pilgrim | Failure to Evaluate Extent of Condition for B-15 Safety-Related Bus After Identifying an Overload Condition on the B-14 Safety-Related Bus | The inspectors identified a finding of very low safety significance (Green) involving a non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, because Entergy did not identify an overload condition on the B-15 bus after a similar overload condition was known to exist on the opposite train B-14 bus. Entergy specified an extent of condition review to be performed as a corrective action but was not successful in completing this review to identify the similar vulnerability to B-15. Entergys corrective actions included immediately reducing loading on the B-15 bus and revising procedures to prohibit overloading the B-15 bus. Entergy has captured these issues in condition reports CR-PNP-2012-2015, CRPNP- 2012-4185 and CR-PNP-2012-4884. The performance deficiency was determined to be more than minor because it is associated with the Equipment Performance attribute of the Mitigating Systems cornerstone, and adversely affected the cornerstones objective to ensure the availability of systems that respond to initiating events to prevent undesirable consequences. During certain accident scenarios, equipment electrically powered from the B-15 bus (Reactor Building Closed Cooling Water and Salt Service Water) would have been unavailable to mitigate the consequences of an event. The inspectors used IMC 0609.04, Phase 1 Initial Screening and Characterization of Findings and Inspection Manual Chapter (IMC) 0609 Appendix A, Exhibit 2, Mitigating Systems Screening. In accordance with Exhibit 2 of IMC 0609, this performance deficiency required a detailed risk analysis since the issue resulted in an actual loss of function of at least a single train for greater than its Technical Specifications (TS) allowed outage time. The Senior Risk Analyst performed a detailed risk evaluation and determined the finding to be of very low safety significance (Green) with a change in core damage frequency of 1.1E-7. This finding has a cross-cutting aspect in the Problem Identification and Resolution cross-cutting area, Corrective Action Program component, because Entergy did not thoroughly evaluate the problem with B-14 such that the resolution addressed the extent of condition for the same vulnerability to B-15. |
| 05000293/FIN-2013003-01 | 2012Q2 | Pilgrim | Failure to Follow Procedures Results in Loss of Shutdown Cooling | A self-revealing NCV of Technical Specification (TS) 5.4.1, Procedures, was identified for operators not implementing procedures to supply safety-related alternate electrical power to shutdown cooling valves during shutdown cooling operation. Specifically, because operators did not perform all applicable steps in a procedure, a loss of shutdown cooling resulted when operators were shifting power supplies for the B train shutdown cooling suction and discharge valves on May 2, 2013. Corrective actions included restoring shutdown cooling following a prompt investigation of the event. Entergy has captured this event in their corrective action program (CAP) as CR-PNP-2013-3457. The performance deficiency is more than minor because it affects the objective of the Initiating Events cornerstone to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The unavailability of shutdown cooling for five hours challenged the safety function of decay heat removal (DHR) supplied by the residual heat removal (RHR) system. A review of IMC 0612, Appendix E, Examples of Minor Issues, found no more than minor examples that applied. The inspectors evaluated the finding using IMC 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings. The inspectors determined that the finding required further review using IMC 0609, Appendix G, Shutdown Operations Significance Determination Process, because the issue affected the safety of the reactor during a refueling outage. The inspectors determined that this finding was of very low safety significance (Green), using IMC 0609, Appendix G, Checklist 7, BWR Refueling Operation with Reactor Coolant System (RCS) Level >23. This determination did not require a further phase 2 or phase 3 analysis in that it did not increase the likelihood of a loss of RCS inventory; did not result in the loss of RCS level instrumentation; did not degrade Entergys ability to terminate a leak path or add RCS inventory; and did not degrade Entergys ability to recover DHR once it was lost. In addition, a loss of thermal margin did not occur since the change in RCS temperature resulted in less than 20 percent of the temperature margin to boil. The inspectors determined that this finding had a cross-cutting aspect in the Human Performance area, Work Practices component, because personnel did not follow procedures. |
| 05000293/FIN-2013004-01 | 2013Q3 | Pilgrim | Failure to Complete a Design Control Review for the SBO Fuel Oil Transfer System in a Timely Manner | The inspectors identified an NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, because Entergy did not complete a design control review for the station blackout (SBO) fuel oil transfer system in a timely manner. Entergy extended the corrective action due date out to greater than a year from the discovery of the original condition. Entergy has increased the priority of this design review and captured this issue in condition report CR-PNP-2013-6906. The performance deficiency was determined to be 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 capability of systems that respond to initiating events to prevent undesirable consequences. The failure to complete a timely design review of a credited support system for the onsite power safety function further extends the vulnerability of the safety function if the design review determines the system is inadequate. The inspectors used IMC 0609.04, Phase 1 Initial Screening and Characterization of Findings, and IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening. The finding was determined to be of very low safety significance (Green) because the finding was a design deficiency that did not result in the loss of system safety function or a loss of safety function of a single train for greater than its Technical Specification allowed outage time. The finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, because Entergy did not take appropriate corrective actions to address a safety issue in a timely manner, commensurate with its safety significance. |
| 05000293/FIN-2014008-01 | 2014Q4 | Pilgrim | Failure to Fully Derive the Causes of a Manual Scram | On August 22, 2013, Pilgrim station experienced a failed splice on a nonsafety- related power supply to a level control valve, which caused an electrical transient that directly led to the automatic trip of all three RFPs when combined with a latent issue related to a modification. Entergy performed a RCE of the event and identified the failed splice as a direct cause. Inspectors determined that Entergy failed to investigate the cause of the electrical transient in accordance with station CAP procedures sufficiently to ensure all of the root and contributing causes of the event were understood. Their investigation determined that the splice failed because it was improperly fabricated when it was installed in 1999 as a part of a modification package on balance of plant valves. The splice was inside a flexible conduit, had two splices on parallel wires places right next to each other instead of being staggered, and the splice had not been properly crimped. Entergy performed an extent of condition review to verify there were no other splices installed in flexible conduit by the same modification package. Entergy used multiple causal evaluation methods as part of their RCE. Three of these (event and causal factor charting, failure modes analysis, and the why staircase analysis) discussed the failed splice. Entergys CAP procedures state that neither the failure modes analysis nor the why staircase are acceptable stand-alone methods of evaluation. The failure modes analysis method is described in EN-LI-118-08, Failure Modes Analysis, Revision 2. This procedure states that the output of the failure modes analysis will only be the direct cause, so it must be used with another method. The why staircase method is described in EN-LI-118-11, Why Staircase, Revision 0. This procedure states that for human performance problems, the method may only get to the general area of the cause and most likely will require further analysis to establish the exact cause. In the why staircase for this RCE, Entergy stopped at failure to follow requirements of design change and (procedure) 3.M.3-51, which is a human performance issue. The event and causal factor charting method is described in EN-LI-118-01, Event and Causal Factor Charting, Revision 2, and is the only method of the three intended for stand-alone use. This procedure directs them to continue to investigate and develop the chart until one of the following limits is reached: (1) the cause is outside the control of Entergy, (2) the correction of the cause is determined to be cost prohibitive, (3) the primary effect is fully explained, or (4) there are no other causes that explain the effect being evaluated. Entergy terminated their chart at maintenance work practices, which does not meet any of the criteria listed in EN-LI-118-01. Ultimately, Entergy did not identify corrective actions to correct the cause of the failed splice and inspectors could not verify that actions taken to ensure other splices were not improperly installed were sufficient. The inspectors questioned why Entergy had not continued to investigate what caused the splice to be improperly fabricated in accordance with station procedures such that either appropriate corrective actions could be planned or justification as to why no corrective actions were required could be provided. In response to inspectors questions, Entergy entered the issue into the CAP as CR-PNP-2014-5796 and initiated additional causal analysis to determine why the splice was improperly fabricated. |
| 05000293/FIN-2014008-02 | 2014Q4 | Pilgrim | Failure to Complete Several Corrective Actions as Required by Program Requirements | In 2013, four reactor scrams occurred at Pilgrim which resulted in two PIs in the Initiating Events cornerstone crossing the Green to White threshold. To address these risk significant performance issues, both individually and collectively, Entergy performed four RCEs for the individual scram events which occurred on January 10, February 8, August 22, and October 14. Additionally, Entergy performed a RCE to assess the commonalities between the four scram events and CCA to assess if any safety culture aspects caused or significantly contributed to the events. EN-LI-102, Corrective Action Program, Revision 23, provides instructions for the administration of Entergy corrective action process, including the identification, reporting, evaluation, and correction of a broad range of problems, areas for improvements, and standards performance deficiencies. Issues addressed in the corrective action process must include Adverse Conditions and Conditions Adverse to Quality, and can include minor problems that may be precursors to more significant events, areas for improvement and standards performance deficiencies identified during assessments and other activities. To that end, EN-LI-102 contains instructions for review and approval of corrective action development, response and documentation, and due date extensions. Section 5.6(4) of EN-LI-102 states that corrective action response must address the intent of the action and must not indicate correction or implementation based on future action. In review of the corrective action plans and status of completed or scheduled corrective actions to address the risk-significant performance issues, inspectors identified multiple deficiencies in implementing the CAP procedure. As documented in section 4OA4.02.03.a.1, a.2, a.4, and d.2 of this report, inspectors identified that some of the corrective actions specified in the RCEs were not completed in accordance with CAP requirements. Specifically, inspectors identified: Several of the human performance related corrective actions from the RCE of a scram on January 10, 2013, during surveillance testing had been cancelled or closed. To determine whether the closure of the corrective actions was appropriate, inspectors reviewed a sampling of recently performed surveillances and observed performance of maintenance in the field. During this review, inspectors noted that several procedures did not have critical steps annotated as such, one procedure directed work to be performed following system restoration, and identified examples of technicians proceeding with testing when challenged with test equipment challenges or unexpected system response. Ultimately, inspectors determined that observations of maintenance execution did not support closure or cancellation of corrective actions identified in the RCE and determined that the numerous procedure deficiencies and human performance issues identified by inspectors represented conditions adverse to quality that were reasonably within Entergys ability to identify and correct by execution of corrective actions identified in the RCE; Despite corrective actions to upgrade severe weather procedures to address deficiencies revealed during a winter storm on February 8, 2013, inspectors identified that the procedure changes did not fully meet the intent of the corrective actions because there were no substantive changes to the procedures for pre-storm actions. Additionally, inspectors determined that the inadequate guidance for pre-storm actions represented a condition adverse to quality that was reasonably within Entergys ability to identify and correct by execution of corrective actions identified in the RCE; An action to send a transformer insulator that faulted offsite for vendor analysis was not completed as required by CAP requirements. Despite being selfidentified by Entergy in preparation for the inspection, this deficiency still existed at the time of the inspection; and One of two effectiveness reviews for a RCE was not completed as required by CAP requirements. Entergy entered the issues into the CAP as CR-PNP-2014-5909, CR-PNP-2014-5976, CR-PNP-2014-5977, CR-PNP-2014-5682, CR-PNP-2014-5625, CR-PNP-2014-5826, CR-PNP-2014-5735, and CR-PNP-2014-06067 and took action to address the identified deficiencies. In particular, for the first example, Entergy revised the RCE to include additional corrective actions for procedural reviews prior to performance of work and enhanced oversight of maintenance activities. For the second example, Entergy made numerous additional changes to severe weather procedures. As discussed in section 4OA4.02.05.b.1, Entergys site safety culture review adequately identified the components of nuclear safety culture that caused or significantly contributed to the four scram events. In particular, inspectors noted Entergy identified that implementation of the stations CAP has not been effective in ensuring adequate corrective actions are taken to address issues in a timely manner, and Entergy identified corrective actions to improve performance in this area. As discussed in section 4OA4.02.05.a.5, inspectors identified examples of approved corrective actions intended to address challenges in CAP implementation not being completed as prescribed. For these corrective actions, inspectors discussion with Entergy personnel revealed that the performance improvement department determined that the actions were not producing the desired results, and decided to implement CAP training instead. However, Entergy did not present these change to the CARB for approval of the revision as required by EN-LI-102. This was entered into the CAP as CR-PNP-2014-06040. Ultimately, inspectors determined that the specific deficiencies in execution of corrective actions identified by inspectors were symptomatic of the identified challenges in CAP implementation, and correspondingly determined that corrective actions specified in the common cause and safety culture evaluations were not effective at ensuring that performance issues identified by the numerous RCEs were corrected. |
| 05000293/FIN-2014008-03 | 2014Q4 | Pilgrim | Parallel White Unplanned Scrams per 7000 Critical Hours PI Finding | The inspectors identified deficiencies regarding Entergys execution of corrective actions documented in the RCEs, as well as understanding of some of the causes of the issues. Specifically, inspectors identified several examples in the RCEs where corrective actions were not completed as intended or were closed prematurely. Additionally, for one of the RCEs, inspectors determined that Entergy failed to investigate a deficient condition sufficiently to ensure they fully understood all of the causes of the event. Inspectors determined that the specific deficiencies in execution of CAP procedures discussed in the findings in sections 02.02.e.1 and 02.03.f.1 of this report were indicative of the CAP implementation weakness that Entergy identified as part of their common cause and safety culture evaluations. Correspondingly, inspectors determined that corrective actions specified in the common cause and safety culture evaluations were not effective at ensuring that all the causes of the performance issues were understood and that corrective actions taken were adequate to address the identified root and contributing causes. Taken collectively, the issues associated with the two White PIs represent a significant weakness, as discussed in IP 95002. |
| 05000293/FIN-2014008-04 | 2014Q4 | Pilgrim | Parallel White Unplanned Scrams with Complications PI Finding | The inspectors identified deficiencies regarding Entergys execution of corrective actions documented in the RCEs, as well as understanding of some of the causes of the issues. Specifically, inspectors identified several examples in the RCEs where corrective actions were not completed as intended or were closed prematurely. Additionally, for one of the RCEs, inspectors determined that Entergy failed to investigate a deficient condition sufficiently to ensure they fully understood all of the causes of the event. Inspectors determined that the specific deficiencies in execution of CAP procedures discussed in the findings in sections 02.02.e.1 and 02.03.f.1 of this report were indicative of the CAP implementation weakness that Entergy identified as part of their common cause and safety culture evaluations. Correspondingly, inspectors determined that corrective actions specified in the common cause and safety culture evaluations were not effective at ensuring that all the causes of the performance issues were understood and that corrective actions taken were adequate to address the identified root and contributing causes. Taken collectively, the issues associated with the two White PIs represent a significant weakness, as discussed in IP 95002. |
| 05000336/FIN-2012004-01 | 2012Q3 | Millstone | Inadequate Post Maintenance Test Directions following Design Change to 3HVC FN1B | The inspectors identified an NCV of 10 CFR 50, Appendix B, Criteria V, Instructions, Procedures, and Drawings, of very low safety significance (Green) for Dominions failure to adequately specify post maintenance test (PMT) requirements for the control room ventilation exhaust fan 1B (3HVCFN1B) following replacement of the breaker starter on June 19, 2012. Specifically, Dominion did not provide sufficient direction to the operations staff in the control room regarding the correct retest procedure or acceptance criteria to complete an adequate PMT. As a result, 3HVCFN1B was retested and returned to an operable status despite the inability of this fan to respond to a control building isolation (CBI) actuation signal. Subsequently, on June 21, 2012, train B heating and ventilation control room (HVC) was declared inoperable after the HVC system failed routine surveillance test SP 3614F.1-002, Control Room Emergency Filtration System Operability Test. Dominion identified that the auxiliary contacts for the 42x relay had not been correctly installed in the breaker for 3HVCFN1B, which would have prevented the automatic starting of the fan during a CBI signal. The PMT acceptance criteria, specified in design change MP3-11-01065 and translated into work order 53102451547 had been met but were not adequate to retest the breaker. Dominion entered this issue into their CAP as CR 492783. The finding is more than minor because it affected the Design Control attribute of the control room ventilation boundary barrier for the Barrier Integrity cornerstone. Additionally, the performance deficiency was similar to example 5.b in Appendix E of Manual Chapter 0612, Examples of Minor Issues. In accordance with IMC 0609, Significant Determination Process, the inspectors performed a Phase 1 analysis and determined that the finding was of very low significance because the finding represented a degradation of the control room radiological barrier function but not degradation against smoke or toxic gas. This finding had a cross-cutting aspect in the Human Performance cross-cutting area, Resources component, because Dominion failed to maintain accurate and up to date procedures and work packages for PMTs following installation of the design change to replace the breaker for 3HVCFN1B. |
| 05000336/FIN-2012004-02 | 2012Q3 | Millstone | Corrective Action to Prevent Recurrence Ineffective to Preclude Repetition of a Significant Condition Adverse to Quality | A self-revealing Green NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, was identified when the corrective action to prevent recurrence of a significant condition adverse to quality did not preclude repetition of the event. Specifically, Dominion generated a corrective action to prevent recurrence during a root cause evaluation (RCE) for a reactor power transient that occurred in February 2011 and a similar event occurred in November 2011, which was determined to be a repeat of the February 2011 event. Dominion entered this issue into their corrective action program (CAP) as condition report (CR) 488587. This finding was more than minor because if left uncorrected, it has the potential to lead to a more significant safety concern. The inspectors determined that this finding was associated with the Mitigating System Cornerstone and was reactivity control systems degradation related to reactivity management due to command and control issues identified in Dominions RCEs for both the February and November 2011 events. Additional screening through the SDP directed the inspectors to Appendix M Significance Determination Process Using Qualitative Criteria. Based upon the results of this evaluation and taking into account mitigating factors associated with additional corrective actions taken following the November 2011 event, and Dominions acceptable performance during the November 2011 through September 2012 time period, the NRC has concluded that the finding was of very low safety significance (Green). This finding has a cross-cutting aspect in the Problem Identification and Resolution cross-cutting area, Corrective Action Program component, because Dominion did not take appropriate corrective actions to address significant conditions adverse to quality and preclude their repetition. |
| 05000354/FIN-2011002-01 | 2011Q1 | Hope Creek | Licensee-Identified Violation | Hope Creek TS 6.8.4.i, lnseryice Testing Program, requires the inservice testing of ASME Code Class 1,2, and 3 components in accordance with the ASME Boiler and Pressure Vessel Code. ASME Code requires that l BCPSV-4425, the RHR shutdown cooling common suction relief valve, a Class 1 valve, be tested every 24 months and that it open within a lift setpoint of +/- 3o/o of the specified code safety valve lift setting. Contrary to this requirement, on November 1, 2010, PSEG identified that l BCPSV-4425 opened above the +/- 3% acceptable range. Since the valve was last tested on October 25,2007, this constituted a failed late surveillance test. PSEG entered this issue into their CAP as notification 20484572. This licensee-identified NCV is of very low safety significance based on a Phase 1 SDP screening, because the relief valve lifted below the maximum rating of the piping. Thus, the condition resulted in the inoperability of the valve, but did not result in a loss of system safety function. |
| 05000387/FIN-2014002-03 | 2014Q1 | Susquehanna | Licensee-Identified Violation | 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires in part, that activities affecting quality shall be prescribed by documented instructions and procedures of a type appropriate to the circumstances. Contrary to the above, prior to July 6, 2012, it was identified that PPL had not incorporated adequate written guidance in TP-264-032, Core Flow Calibration, Revision 5, to require iteration of the procedural steps used for the calibration check if flow instrumentation summer gains were adjusted. This resulted in core flow for the A recirculation loop being adjusted to approximately 2.4 Mlb/hr below actual loop flow and the B recirculation loop being adjusted to approximately 0.2 Mlb/hr below actual loop flow. PPL entered the issue into the corrective action program as CR 1708878. Inspectors determined this finding to be of very low safety significance (Green) in accordance with IMC 0609, Attachment 4, Initial Characterization of Findings, and Appendix A, The Significance Determination Process (SDP) for Findings At-Power, because none of the logic questions under the barrier integrity cornerstone applied, indicating the issue screened to Green. Inspectors reviewed PPLs technical evaluation and determined that there was adequate margin in the thermal limit calculations to ensure that no safety or operating limits were exceeded. This issue was discussed in further detail within Section 4OA3 of this report. |
| 05000387/FIN-2015002-01 | 2015Q2 | Susquehanna | Failure to Assess a Non-Conforming Condition for its Impact on Component Operability | The inspectors identified a finding of very low safety significance (Green) and associated NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, when Susquehanna staff did not assess component operability following identification of a potentially non-conforming condition. Specifically, Susquehanna did not assess for operability a potential non-conforming condition associated with inadequate testing of the primary containment airlock inboard equalizing valve which was identified during the review of industry operating experience. Susquehannas corrective actions to restore compliance included entering this issue in their CAP as CR-2015-15187, performing a prompt operability determination of the Unit 1 primary containment airlock inboard equalizing valve, including completion of the requirements in SR 3.0.3 for a missed surveillance, and performing testing on the Unit 2 valve which adequately demonstrated that the PCIV was operable prior to entering into a mode of TS applicability. The inspectors determined that the finding was more than minor because it was associated with the SSC and Barrier performance attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective of providing reasonable assurance that the physical design barriers (containment) protect the public from radionuclide releases caused by accidents or events. Specifically, inadequate actions to evaluate the impact of the condition adverse to quality on the operability of the Unit 1 PCIV resulted in a reasonable doubt of operability of the barrier. In accordance with IMC 0609.04, Initial Characterization of Findings, dated June 19, 2012, and Exhibit 2 of IMC 0609, Appendix A, The SDP for Findings At-Power, dated June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) because the performance deficiency did not represent an actual open pathway in the physical integrity of reactor containment and heat removal components or involve the actual reduction in function of hydrogen igniters in containment. This finding has a cross-cutting aspect in the area of Human Performance, Avoid Complacency, because Susquehanna did not perform a thorough review of the work and planned activity but rather relied on past successes and assumed conditions. Specifically, the control room staff did not assess the condition for operability believing that it was similar to previous CRs documenting a review of operating experience. |
| 05000387/FIN-2015002-02 | 2015Q2 | Susquehanna | Entry into a High Radiation Area without Radiological Briefing | A self-revealing finding of very low safety significance (Green) and associated NCV of SSES Unit 2 TS 5.7.1 was identified because Susquehanna did not comply with a radiological posting barrier and other protective measures for HRA entry. Specifically, on October 10, 2014, two workers entered the turbine building roof, a posted HRA, but the workers were not on the proper RWP and were not briefed on the radiological conditions prior to entry. Upon receiving a dose rate alarm, the workers exited the HRA and reported the issue to radiation protection personnel. Susquehanna entered the issue into the CAP as condition report CR-2014-31911. The inspectors determined that Susquehannas inadequate adherence to a high radiation area (HRA) posting, which requires a HRA RWP and a radiological briefing prior to entry, was a performance deficiency that was within Susquehannas ability to foresee and correct and should have been prevented. The inspectors determined that the finding was more than minor because it adversely affected the human performance attribute of the Occupational Radiation Safety cornerstone objective. Specifically, the individual violated the RWP and briefing requirements designed to protect the worker from unnecessary radiation exposure. The issue was also similar to example 6.h in IMC 0612, Appendix E. Using IMC 0609, Appendix C, Occupational Radiation Safety SDP, dated August 19, 2008, the finding was determined to be of very low safety significance (Green) because it did not involve: (1) as low as is reasonably achievable (ALARA) occupational collective exposure planning and controls, (2) an overexposure, (3) a substantial potential for overexposure, or (4) an impaired ability to assess dose. This finding has a cross-cutting aspect of Human Performance, Challenge the Unknown, because the workers did not stop when faced with uncertain conditions. Specifically, the workers did not use a questioning attitude during the pre-job brief or when they encountered the HRA posting on the access to the turbine building roof. |
| 05000387/FIN-2015002-03 | 2015Q2 | Susquehanna | Incorrect Implementation of the Ventilation Filter Testing Program | The inspectors identified a finding of very low safety significance (Green) and associated NCV of 10 CFR 50, Appendix B, Criterion XI, Test Control, because Susquehanna did not ensure representative samples were obtained from Engineered Safety Feature (ESF) filter ventilation systems and did not establish written test procedures. Specifically, subsequent to refilling charcoal test canisters for the activated charcoal absorber of both trains of the SBGT System, new charcoal was added to the activated charcoal absorber which was not exposed to the same service conditions as the bulk of the absorber section as required by TS 5.5.7, Ventilation Filter Testing Program, and written test procedures were not established for this activity. As corrective action for the identified issue, Susquehanna replaced the charcoal in the A and B trains of SBGT and the A and B trains of CREOASS activated charcoal absorber beds and test canisters between January and February 2015 and initiated condition reports CR-2014-39116 and CR-2015-01443. The inspectors determined that the finding was more than minor because it was associated with the Procedure Quality Attribute of the Barrier Integrity Cornerstone and it adversely affected the cornerstone objective to provide reasonable assurance that physical barriers protect the public from radionuclide releases caused by accidents or events. Specifically, since 2001, work instructions did not prevent the contamination of test canisters with charcoal that was not representative of the in-service conditions of the adsorber bed and the introduction of new charcoal into the test canisters likely provided better results during periodic surveillance testing which were not representative of actual conditions. In accordance with IMC 0609.04, Initial Characterization of Findings, dated June 19, 2012, and Exhibit 3 of IMC 0609, Appendix A, The SDP for Findings At-Power, dated June 19, 2012, the inspectors determined that the finding was of very low safety significance (Green) because it only represented a degradation of the radiological barrier function provided for the control room and SBGT system. This finding has a cross-cutting aspect in the area of Human Performance, Documentation, because the activities for sampling the activated charcoal beds were not governed by comprehensive, high-quality programs, processes, and procedures nor were the design documentation, procedures, and work packages complete, thorough and accurate. |
| 05000387/FIN-2015002-04 | 2015Q2 | Susquehanna | Multiple Violations of Work Hour Limitations by Licensed Operators | The inspectors identified a finding of very low safety significance (Green) and associated NCV of 10 CFR 26.205, Work Hours, because Susquehanna did not ensure that the working hours of licensed operators were maintained within regulatory limits. Specifically, numerous instances of violations were identified in the operations department in which individuals exceeded the required work hour limits while performing duties subject to work hour controls. In review of the issue, the inspectors identified that Susquehanna inappropriately excluded some works hours performing non-covered work from the total accumulated work hours, which allowed individuals to perform covered work while in excess of the work hour limits without meeting the requirements for applying a waiver. Susquehanna entered the issue into the CAP as CR-2015-15708 and initiated action to evaluate the extent of the matter and communicate the issue with the operations department, reinforce the standards for work hour tracking with station personnel, and ensure work hours are appropriately tracked. The inspectors determined that the finding was more than minor because Susquehanna inadequately implemented the requirements of 10 CFR 26.205 and NDAP-QA-0025 routinely. Therefore, if the performance deficiency were left uncorrected, the continued process of not including all hours accumulated toward work hour limits and allowing workers to exceed work hour limits, had the potential to lead to a more significant safety concern. The finding was also similar to IMC 0612, Appendix E, "Examples of Minor Issues," Example 9.a. In accordance with IMC 0609.04, Initial Characterization of Findings, dated June 19, 2012, and Exhibits 1 and 2 of IMC 0609, Appendix A, The SDP for Findings At-Power, dated June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) because no transients, loss of function of a mitigating system, or mismanagement of reactivity occurred as a result of licensed operators performing covered work while not in compliance with the work hour limits specified in 10 CFR 26.205. This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Identification, because Susquehanna did not identify the issues completely, accurately, and in a timely manner. Specifically, Susquehanna identified violations of work hour limits on multiple occasions but the CRs were not in sufficient detail to ensure they were appropriately prioritized and assigned for resolution. Individuals did not recognize that work performed doing non-covered work was to be counted as hours accumulated towards the work hour limitations and thus discounted the violations as erroneous. |
| 05000387/FIN-2015003-01 | 2015Q3 | Susquehanna | RHR Shutdown Cooling Procedure Not Maintained Consistent with Technical Specification Requirements | Inspectors identified a finding of very low safety significance (Green) and associated NCV of SSES Unit 1 and 2 TS 5.4.1, Procedures, because Susquehanna did not maintain the procedure for operation of the residual heat removal (RHR) shutdown cooling (SDC) system consistent with the requirements in TS 3.4.8, RHR Shutdown Cooling- Hot Shutdown. As TS 3.4.8 requires two RHR SDC loops to be operable and, if no reactor recirculation pumps (RRPs) are running, one of the loops to be in-service in Mode 3 below the RHR cut in permissive pressure (98 psig), inspectors determined that OP-1(2)49-002, RHR Shutdown Cooling, was not maintained appropriately because a change to the procedure precluded operation of the system between 40 psig and the RHR cut in permissive pressure (98 psig). Susquehanna entered the issue into the corrective action program (CAP) as CR-2015-22882 and CR-2015-24137 and revised the procedure to remove the requirement that precluded operation of the SDC system between 40 psig and the RHR cut in permissive pressure This finding is more than minor because it is associated with the procedure quality attribute of the Mitigating Systems cornerstone and adversely affected its objective to ensure the availability and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the 40 psig procedural limit impacted the availability and capability of RHR to be placed in SDC between 98 psi, the cut-in permissive for the system, and 40 psig. In accordance with Exhibit 2 of IMC 0609, Appendix A, The SDP for Findings At-Power, the inspectors determined that this finding is of very low safety significance (Green) because the performance deficiency was not a design or qualification deficiency, did not involve an actual loss of safety function, did not represent actual loss of a safety function of a single train for greater than its TS allowed outage time, and did not screen as potentially risk-significant due to a seismic, flooding, or severe weather initiating event. This finding had a cross-cutting aspect in the area of Human Performance, Change Management because Susquehanna did not use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority (H.3). Specifically, implementation of Susquehannas procedure change process did not ensure that the RHR SDC procedure was maintained consistent with the requirements of plant TSs. |
| 05000387/FIN-2015003-02 | 2015Q3 | Susquehanna | C EDG Rendered Inoperable by Switch Manipulation during Training Simulation | A self-revealing finding of very low safety significance (Green) and associated NCV of 10 CFR 50 Appendix B, Criterion V, Instructions, Procedures and Drawings, was identified when Susquehanna inadvertently operated the C emergency diesel generator (EDG) mode switch during the performance of a job performance measure (JPM). Specifically, the student performing the JPM operated plant equipment that was contrary to the quality assurance program requirement to only simulate equipment operation. Susquehanna entered the issue into the CAP as CR-2015-19578, the C EDG mode switch was restored to the Remote position, and the operating crew performed a walk-down of the C EDG to confirm proper standby alignment, restoring operability of the EDG. Inspectors determined that the finding was more than minor because it was associated with the Human Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring the reliability of systems that respond to initiating events to prevent undesirable consequences. Specifically, improper manipulation of the C EDG mode switch while simulating a task resulted in an inoperable condition since the EDG would not have auto started, if required. In accordance with Exhibit 2 of IMC 0609, Appendix A, The SDP for Findings At-Power, dated June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) because the performance deficiency was not a design or qualification deficiency, did not involve an actual loss of safety function, did not represent actual loss of a safety function of a single train for greater than its TS allowed outage time, and did not screen as potentially risk-significant due to a seismic, flooding, or severe weather initiating event. This finding had a cross-cutting aspect in the area of Human Performance, Avoid Complacency because Susquehanna did not implement appropriate error reduction tools (H.12). Specifically, personnel did not implement appropriate human error prevention tools (e.g. self-check, stop-think-act-review) in accordance with station processes. |
| 05000387/FIN-2015003-03 | 2015Q3 | Susquehanna | Secondary Containment Inoperability due to Improperly Controlled Access to the Reactor Building Roof | A self-revealing finding of very low safety significance (Green) and associated NCV of SSES Unit 1 and 2 TS 5.4.1, Procedures, was identified because Susquehanna incorrectly implemented procedures for maintaining secondary containment integrity. Specifically, on July 27, 2015, maintenance technicians rendered secondary containment for both units inoperable for approximately 44 minutes when a secondary containment boundary door was opened to access the reactor building roof. Susquehanna entered the issue into the CAP as CR-2015-20857 and CR-2015-24442, restored the boundary, and verified the integrity of secondary containment. The finding was more than minor because it was associated with the Human Performance (Routine OPS/Maintenance Performance) attribute of the Barrier Integrity cornerstone, and affected the cornerstone objective of providing reasonable assurance that physical design barriers (Secondary Containment) protect the public from radionuclide releases caused by accidents or events. Specifically, opening the secondary containment barrier did not maintain reasonable assurance that the secondary containment would be capable of performing its safety function in the event of a reactor accident. The inspectors evaluated the finding in accordance with IMC 0609, Appendix A, "The SDP for Findings At-Power," Exhibit 3, for the Barrier Integrity cornerstone, dated June 19, 2012. The inspectors determined the finding was of very low safety significance (Green) because only represented a degradation of the radiological barrier function of secondary containment provided by the standby gas treatment (SBGT) system. This finding had a cross-cutting aspect in the area of Human Performance, Teamwork because Susquehanna did not effectively communicate and coordinate their activities within and across organizational boundaries to ensure nuclear safety was maintained (H.4). Specifically, when the work plan was changed to accessing the reactor building roof through secondary containment, the change was not effectively communicated to operations department personnel to ensure the secondary containment impairment was appropriately controlled. |