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05000298/FIN-2011003-062011Q2CooperFailure to Correctly Translate Design Requirements into Installed Plant ConfigurationThe inspectors documented a self revealing, noncited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, associated with the licensees failure to assure that the applicable design basis for structures, systems, and components were correctly translated into specifications, procedures, and instructions. Specifically, the licensee failed to correctly translate the design requirements for the service water zurn strainers reduction gear to motor shaft into the installed plant equipment. This resulted in instances where the strainer motor was not able to perform its function of strainer backwash, an essential function, due to a failure of the wiper arm motor-to-gear box coupling. This issue was entered into the licensees corrective action program as Condition Report CR-CNS-2010-2213. The licensees failure to ensure that design requirements were correctly translated into installed plant equipment was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone, and affected the associated cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and is therefore a finding. Using Manual Chapter 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, the inspectors determined that a Phase 2/3 assessment was required because this was a design or qualification deficiency that did result in a loss of operability or functionality. The inspectors received support from the regional senior reactor analyst to evaluate this issue. As a bounding analysis, the analyst assumed: (1) the only time this design deficiency would cause an issue would be when strainer backwash was required due to debris loading; (2) the licensee had procedures already in place for manual actions in the event of a coupling failure; (3) the licensee would implement these actions before the strainer became inoperable due to debris loading; and (4) these actions were not complex and could easily be implemented. Given these assumptions the analyst determined that the finding was of very low safety significance (Green). This finding did not have a cross-cutting aspect because the most significant contributor did not reflect current licensee performance (Section 4OA2).
05000298/FIN-2011003-072011Q2CooperFailure to Adequately Assess and Manage Risk When Disabling A Hazard BarrierThe inspectors identified a noncited violation of 10 CFR 50.65(a)(4), Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, associated with the licensees failure to perform an adequate risk assessment for a planned maintenance activity. Specifically, on August 19, 2010, during maintenance activities on emergency diesel generator 2, maintenance personnel inappropriately blocked open the steam exclusion boundary door N-103 that protected both emergency diesel generators, without properly assessing the potential effects on the emergency diesel generators and without appropriate compensatory measures in place. As such, this resulted in both emergency diesel generators being inoperable. These issues were entered into the licensees corrective action program as Condition Report CR-CNS-2011-7660. The licensees failure to adequately assess and manage the risk of planned maintenance activities was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone, and affected the associated cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and is therefore a finding. Using Manual Chapter 0609, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process, the finding was determined to have very low safety significance. Specifically, Flowchart 1, Assessment of Risk Deficit, requires the inspectors to determine the risk deficit associated with this issue. The senior reactor analyst performed a bounding analysis and determined that the probability that a high energy line breaks, causing the failure of both emergency diesel generators and initiating a consequential loss of offsite power, can be calculated as 3.0 x 10-7. Given that the change in core damage frequency would be lower than this probability, the analyst determined that the finding was of very low safety significance (Green). The inspectors determined that this finding did not represent current performance because the guidance that formed the basis for the licensees decision making was developed and approved over two years ago (Section 4OA3).
05000298/FIN-2011003-082011Q2CooperFailure to Follow Procedure Results in Degraded Emergency Diesel GeneratorThe inspectors identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, regarding the licensees failure to follow written work instructions. Specifically, the inspectors identified that maintenance personnel, when unable to follow written instructions on torquing emergency diesel generator bolting due to mechanical interference, then used alternate methods. These methods contributed to the subsequent loosening of the bolting and degrading the capability of the emergency diesel generator. The licensee entered this issue into their corrective action program as Condition Report CR-CNS-2011-07653. The performance deficiency is more than minor since this failure to follow procedures resulted in a degraded emergency diesel generator which impacts the equipment performance attribute of the Mitigating Systems Cornerstone, and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). The finding was evaluated using Manual Chapter 0609.04, Phase 1 Initial Screening and Characterization of Findings, and was determined to be of very low safety significance (Green) because there was not a design or qualification deficiency that resulted in a loss of operability or functionality, it did not create a loss of system safety function or of a single train for greater than the technical specification allowed outage time, it did not represent an actual loss of risk significant equipment, and it did not affect seismic, flooding, or severe weather initiating events. The finding was determined to have a cross-cutting aspect in the area of human performance, associated with the work practices component, in that, personnel do not proceed in the face of uncertainty or unexpected circumstances. Specifically, when unable to torque emergency diesel generator bolting by following their written procedures, licensee personnel proceeded in the face of uncertainty by using alternate torque methods.
05000298/FIN-2011003-092011Q2CooperFailure to Initiate Condition Reports for Nonconformances Identified During System Walk DownsThe inspectors identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions, for the failure of licensee personnel to take actions to promptly correct a condition adverse to quality. Specifically, the licensee did not take any interim actions to eliminate procedure steps that allowed venting of emergency core cooling systems without determining the amount of gas accumulated and the potential impact on system operability. The performance deficiency associated with this finding involved the failure to correct a condition adverse to quality. This finding was more than minor because it affected the equipment performance attribute of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of the emergency core cooling systems to respond to initiating events and prevent undesirable consequences. Specifically, licensee personnel failed to promptly correct the previously identified condition adverse to quality of not tracking emergency core cooling system gas accumulation and its potential effects on system operability during surveillance testing. The inspectors performed the significance determination using NRC Inspection Manual Chapter 0609.04, Phase 1 Initial Screening and Characterization of Findings. The finding was determined to be of very low safety significance (Green) because it was not a design or qualification deficiency confirmed not to result in loss of operability or functionality; did not result in loss of a safety function, did not result in loss of safety function of a single train for longer than its allowed outage time, did not result in loss of a risk-significant nontechnical specification system per 10 CFR 50.65, and did not screen as potentially risk significant because of a seismic, flooding or severe weather initiating event. The finding was determined to have a cross-cutting aspect in the area of human performance, associated with the resources component, in that, the licensee failed to provide maintenance of design margins. Specifically, the licensee did not ensure that station procedure were adequate to assure nuclear safety, in that they did require measuring of the amount of entrained gas and any impact on equipment operability.
05000298/FIN-2011003-102011Q2CooperFailure to Promptly Correct an Adverse Condition Related to Emergency Core Cooling System VentingThe inspectors identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the failure of licensee personnel to follow the requirements of Procedure 0.5, Conduct of the Condition Report Process. Specifically, licensee personnel failed to initiate condition reports for adverse conditions related to the inability to remove air from emergency core cooling system piping. Licensee personnel identified that high pressure coolant injection system had an incorrect slope and that the core spray system had concentric reducers that could trap gas; however, personnel failed to initiate a condition report that documented the deficiency. The performance deficiency associated with this finding involved failure of personnel to follow the requirements of Procedure 0.5. Specifically, licensee personnel failed to initiate condition reports for adverse conditions that could result in gas voids in the emergency core cooling systems that could affect operability. The first and third examples are more than minor because the condition of not initiating condition reports for adverse conditions could become more significant if left uncorrected. Using Manual Chapter 0609.04, Phase 1 - Initial Screening and Characterization of Findings, the finding is determined to have very low safety significance because neither example resulted in any loss of safety function of any technical specification required equipment. This finding was determined to have a cross-cutting aspect in the problem identification and resolution area associated with the corrective action program component because licensee personnel failed to implement a corrective action program with a low threshold for identifying issues.
05000298/FIN-2011003-112011Q2CooperLicensee-Identified ViolationTechnical Specification 5.4.1.a Procedures, requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, Appendix A, Section 9.a, requires, in part, that maintenance that can affect the performance of safety-related equipment should be performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. Contrary to the above, in September 2009, the licensee failed to implement written procedures, documented instructions, or drawings appropriate to the circumstances for maintenance that can affect the performance of safety-related equipment. Specifically, the licensee failed to ensure that the work order used when reinstalling the overspeed governor bolting on emergency diesel generator 2 required the use of lubrication, which resulted in the bolting coming loose and resulting in the diesel being declared inoperable. The failure to properly plan maintenance activities on the emergency diesel generator 2 was a performance deficiency. Using Manual Chapter 0609.04, Phase 1 Initial Screening and Characterization of Findings, the inspectors determined this finding to be of very low safety significance because there was not a design or qualification deficiency that resulted in a loss of operability or functionality, it did not create a loss of system safety function or of a single train for greater than the technical specification allowed outage time, it did not represent an actual loss of risk significant equipment, and it did not affect seismic, flooding, or severe weather initiating events.
05000298/FIN-2011003-122011Q2CooperLicensee-Identified ViolationTitle 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions, requires, in part, that Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. Contrary to the above, the licensee failed to promptly identify and correct a condition adverse to quality, associated with bolted fasteners on emergency diesel generator number 2. Specifically, the licensee had postponed implementation of a corrective action, from a previous loose bolting issue associated with the overspeed governor, to perform a 100 percent torque check of all fasteners on the diesel from June until August 2010 due to conflicting work week schedules. As a result, when the bolting was checked the bolts for the overspeed governor were found loose again, and the licensee determined that the loose bolts had been a result of improper maintenance performed when reassembling the joint from the previous bolting issue. Using Manual Chapter 0609.04, Phase 1 Initial Screening and Characterization of Findings, the inspectors determined this finding to be of very low safety significance because there was not a design or qualification deficiency that resulted in a loss of operability or functionality, it did not create a loss of system safety function or of a single train for greater than the technical specification allowed outage time, it did not represent an actual loss of risk significant equipment, and it did not affect seismic, flooding, or severe weather initiating events.
05000298/FIN-2012003-012012Q2CooperFailure to Perform Adequate Postmaintenance TestingThe inspectors documented a self-revealing, non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated with the failure to develop and specify adequate postmaintenance testing requirements in work instructions used to perform maintenance on Diesel Generator 1. Specifically, in October 2011, Work Order 4766672 did not specify adequate postmaintenance testing instructions to verify that the left bank air distributor was properly re-installed following a change in work scope. This issue was entered into the licensee\'s corrective action program as Condition Reports CR-CNS-2012-02532 and CR-CNS-2012-02566. The licensees failure to establish adequate work instructions, to include post maintenance testing requirements to verify equipment operability following maintenance, was a performance deficiency. The performance deficiency was more than minor because it affected the procedure quality attribute of the Mitigating Systems Cornerstone, and directly affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, the finding screened as potentially risk significant since the finding represented an actual loss of safety function of a single train for greater than its Technical Specification allowed outage time. When evaluated per Inspection Manual Chapter 0609, Appendix A, Determining the Significance of Reactor Inspection Findings for At-Power Situations, and the Cooper Phase 2 pre-solved table item, EDG1, the inspectors determined this finding to be of very low safety significance (Green). This finding had a cross-cutting aspect in the area of human performance associated with the resources component, because the licensee failed to provide complete, accurate and up-to-date work packages that specified the appropriate postmaintenance testing requirements following work scope change.
05000298/FIN-2012003-022012Q2CooperFailure to Ensure Compliance with the Requirements of Station Troubleshooting ProcedureThe inspectors documented a self-revealing, non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated with the failure to ensure compliance with the requirements of the stations troubleshooting plan generated in accordance with Procedure 7.0.1.7, Revision 15, Troubleshooting Plant Equipment. Specifically, licensee personnel failed to ensure that ground isolated test equipment was used during troubleshooting activities that affected the 250 Vdc bus. The licensee entered this deficiency into their corrective action program for resolution as Condition Report CR-CNS-2012-02717. The failure to follow the troubleshooting plan was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone, and affected the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and is therefore, a finding. Specifically, the licensee failed to ensure that ground isolated test equipment was used as specified in the troubleshooting plan contained in Work Order 4863518, Troubleshooting SS-IVTR-UPS2 and Transfer Switch, causing a ground and 0.8 volt drop on the 250 Vdc Bus 1A. The inspectors evaluated the finding using Inspection Manual Chapter 0609.04, Phase 1 Initial Screening and Characterization of Findings. The inspectors determined that the finding is of very low safety significance (Green) because the finding: (1) was not a design or qualification issue confirmed not to result in a loss of operability or functionality; (2) did not represent an actual loss of safety function of system or train; (3) did not result in the loss of one or more trains of nontechnical specification equipment; (4) did not screen as potentially risk significant due to seismic, flooding, or severe weather initiating event. The finding was determined to have a cross-cutting aspect in the area of human performance associated with the decision making component because the licensee failed to use conservative assumptions and conduct effectiveness reviews to validate the underlying assumptions that ground isolated test equipment was used as specified in the troubleshooting plan.
05000298/FIN-2012003-032012Q2CooperFailure to Recognize the Need for An Evaluation and to Properly Document the Bases for OperabilityThe inspectors identified two examples of a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated with the failure of the licensee to recognize the need for an evaluation and to properly document the bases for operability when a degrading nonconforming condition was identified. Specifically, the licensee did not consider all relevant information when assessing: (1) Diesel Generator 1 jacket water heater seismic operability with only two bolts fully engaged and; (2) the impact of a free floating absorbent bag discovered in the Diesel Generator 2 room sump for internal flooding analysis for a medium energy line break. The licensee entered these issues into their corrective action program for resolution as Condition Reports CR-CNS-2012-03137 and CR-CNS-2012-02767. The licensees failure to recognize the need for an evaluation and to properly document the bases for operability when a degraded nonconforming condition was identified was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone, and affected the associated cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and is therefore a finding. The inspectors evaluated the finding using Inspection Manual Chapter 0609.04, Phase 1 Initial Screening and Characterization of Findings. The inspectors determined that the finding is of very low safety significance (Green) because the finding: (1) was not a design or qualification issue confirmed not to result in a loss of operability or functionality; (2) did not represent an actual loss of safety function of system or train; (3) did not result in the loss of one or more trains of nontechnical specification equipment; (4) did not screen as potentially risk significant due to seismic, flooding, or severe weather initiating event. The finding was determined to have a cross-cutting aspect in the area of human performance associated with the decision making component because the licensee failed to use conservative assumptions and conduct effectiveness reviews to validate the underlying assumptions when determining Diesel Generator 1 jacket water heater seismic operability with only two bolts fully engaged and impact of a free floating absorbent bag in Diesel Generator 2 room sump for internal flooding analysis for a medium energy line break.
05000298/FIN-2012003-042012Q2CooperFailure to Maintain Design Control of the Standby Liquid Control System and Sumps Credited in the Internal Flooding AnalysisThe inspectors identified two examples of a non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, associated with the licensees failure to: (1) assure that the applicable seismic design basis requirements associated with the standby liquid control system storage tank was correctly translated into the plant design to ensure that the standby liquid control system would remain operable following a seismic event and; (2) maintain design control of sumps credited in the stations internal flooding analysis. These issues were entered into the licensees corrective action program as Condition Reports CR-CNS-2012-01918 for the standby liquid storage tank and CR-CNS-2012-02414, CR-CNS-2012-02509, CR-CNS-2012-02510, CR-CNS-2012-02752, and CR-CNS-2012-02767 for the oil absorbent bags. The licensees failure to maintain design control of the standby liquid control system and sumps credited for the stations internal flooding analysis was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the design control attribute of the Mitigating Systems Cornerstone, and affected the associated cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and is therefore a finding. The inspectors evaluated the finding using Inspection Manual Chapter 0609.04, Phase 1 Initial Screening and Characterization of Findings. The inspectors determined that the finding is of very low safety significance (Green) because the finding: (1) was not a design or qualification issue confirmed not to result in a loss of operability or functionality; (2) did not represent an actual loss of safety function of system or train; (3) did not result in the loss of one or more trains of nontechnical specification equipment; (4) did not screen as potentially risk significant due to seismic, flooding, or severe weather initiating event. The finding was determined to have a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action component because: (1) the licensee failed to thoroughly evaluate concerns with seismic analysis of the standby liquid control system such that the resolution addresses causes an extent of conditions, as necessary, during the development of NEDC 12-015; and (2) the licensee had the opportunity in 2010 and early 2012 during reviews of the internal flooding analysis to identify that oil absorbent bags contained in the sumps credited in the internal flooding analysis did not contain an analysis and were an unapproved modification.
05000298/FIN-2012003-052012Q2CooperFailure to Furnish Evidence of an Activity Affecting QualityThe inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVII, Quality Assurance Records, associated with the licensees failure to furnish evidence of an activity affecting quality associated with the emergency diesel generator jacket water cooling pumps. Specifically, the licensee failed to maintain design documents that detailed the amount of net positive suction head required for the diesel generator jacket water pumps to ensure that at the current low level alarm set point the pumps would not cavitate and potentially be damaged. The licensee generated a bounding operability evaluation to address this issue. This issue was entered into the licensees corrective action program as Condition Reports CR-CNS-2012-03262, and CR-CNS-2012-03305. The licensees failure to furnish evidence that showed the required net positive suction head for the jacket water pump was maintained at the current low level alarm set point was a performance deficiency. The performance deficiency was determined to be more than minor because it affected the design control attribute of the Mitigating Systems Cornerstone, and it directly affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and is therefore a finding. Using Inspection Manual Chapter 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, the finding was determined to have very low safety significance (Green) because it was not a design or qualification issue confirmed not to result in a loss of operability or functionality; did not represent an actual loss of safety function of system or train; did not result in the loss of one or more trains of nontechnical specification equipment; and did not screen as potentially risk-significant due to seismic, flooding, or a severe weather initiating event. This finding did not have a cross-cutting aspect because the most significant contributor of this finding did not reflect current licensee performance.
05000298/FIN-2012003-062012Q2CooperDesign Changes Not Appropriately Approved by the LicenseeThe inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, associated with the licensees failure to ensure that design changes were subject to design control measures commensurate with those applied to the original design and were approved by the designated responsible organization. Specifically, the licensee received a design level calculation from a vendor in support of service water pump C change out, but failed to appropriately review, accept and enter this calculation into their design basis. This issue was entered into the licensees corrective action program as Condition Report CR-CNS-2012-03634. The licensees failure to ensure that changes to the facility were subject to design control measures commensurate with those applied to the original design, and were approved by the designated responsible organization was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the design control attribute of Mitigating Systems Cornerstone, and affected the associated cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and is therefore a finding. Using Inspection Manual Chapter 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, the finding was determined to have very low safety significance (Green) because the finding: (1) was not a design or qualification issue confirmed not to result in a loss of operability or functionality; (2) did not represent an actual loss of safety function of system or train; (3) did not result in the loss of one or more trains of nontechnical specification equipment; (4) did not screen as potentially risk significant due to seismic, flooding, or severe weather initiating event. This finding had a cross cutting aspect in the area of human performance associated with the work practices component, because the licensee failed to adequately define and effectively communicates expectations regarding procedural compliance and personnel failed to follow procedures. Specifically, engineering department personnel failed to follow station procedures when receiving a new design basis calculation from a vendor.
05000298/FIN-2012003-072012Q2CooperFailure to Evaluate Changes for Adverse ImpactsThe inspectors identified four examples of a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated with the licensees failure to follow the requirements of station Procedure 0.8, 10CFR50.59 and 10CFR72 .48 Reviews, and evaluate changes made to safety related components for adverse impacts. Specifically, the inspectors identified four instances where the licensee personnel in multiple work groups failed to follow the requirements of station Procedure 0.8 and evaluate changes being made to safety related components for potentially adverse impacts prior to implementing these changes. This issue was entered into the licensee\'s corrective action program as Condition Reports CR-CNS-2012-02750, CR-CNS-2012-03366, CR-CNS-2012-03806, CR-CNS-2012-04033, and CR-CNS-2012-04456. The failure of station personnel to follow the requirements of station Procedure 0.8, 10CFR50.59 and 10CFR72 .48 Reviews, for modifications to safety related equipment was a performance deficiency. The performance deficiency was determined to be more than minor because if left uncorrected, the continued practice of modifying the facility without evaluating for adverse impacts had the potential to lead to a more significant safety concern. Specifically, unevaluated modifications to the facility could introduce adverse changes that result in systems not able to perform their intended safety function which would not be recognized. This finding affects the Mitigating Systems Cornerstone. Using Manual Chapter 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings, the finding was determined to have very low safety significance because the finding: (1) was not a design or qualification issue confirmed not to result in a loss of operability or functionality; (2) did not represent an actual loss of safety function of the system or train; (3) did not result in the loss of one or more trains of nontechnical specification equipment; and (4) did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The finding was determined to have a cross-cutting aspect in the area of human performance associated with the decision making component because the licensee failed to use conservative assumptions in decision making and adopt a requirement to demonstrate that the proposed action is safe in order to proceed rather than a requirement to demonstrate it is unsafe in order to disapprove the action.
05000298/FIN-2012003-082012Q2CooperNon-conservative Service Water Booster Pump A and D Differential Pressure Operability Limits During In-Service Surveillance TestingThe inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XI, Test Controls, for the licensees non-conservative service water booster pump A and D differential pressure operability limits. The licensee entered this deficiency into their corrective action program for resolution as Condition Report CR-CNS-2012-02497 and CR-CNS-2012-02500. The licensees nonconservative service water booster pump A and D differential pressure operability limits was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the procedural quality attribute of the Mitigating Systems Cornerstone, and affected the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and is therefore a finding. Specifically, the pump differential pressure operability limit for service water booster pump A and D was not correctly stated in the In-service Testing program so that the pumps would meet their 30 day mission time for a design basis accident with a degrading pump differential pressure. The inspectors evaluated the finding using Inspection Manual Chapter 0609.04, Phase 1 Initial Screening and Characterization of Findings. The inspectors determined that the finding is of very low safety significance (Green) because the finding: (1) was not a design or qualification issue confirmed not to result in a loss of operability or functionality; (2) did not represent an actual loss of safety function of system or train; (3) did not result in the loss of one or more trains of nontechnical specification equipment; (4) did not screen as potentially risk significant due to seismic, flooding, or severe weather initiating event. The finding was determined to have a cross cutting aspect in the area of problem identification and resolution associated with the corrective action component because the licensee failed to thoroughly evaluate concerns with operability limit for service water booster pump A and D such that the resolution address causes an extent of conditions, as necessary. Specifically, operability lower limit was identified during the initiation of Condition Report CR-CNS-2011-07980, but the licensee failed to update the operability limits during the review of the condition report.
05000298/FIN-2012003-092012Q2CooperFailure to Follow Radiation Work Permit RequirementsThe inspectors identified a non-cited violation of Technical Specification 5.4.1, associated with station personnels failure to follow radiation work permit requirements. Specifically, inspectors observed workers breaching a contaminated system during planned maintenance activities without radiation protection personnel present as specified by the radiation work permit requirements. This issue was entered into the licensees corrective action program as Condition Report CR-CNS-2012-02716. The inspectors determined that the failure of craft personnel to follow radiation work permit requirements when breaching contaminated systems was a performance deficiency. The performance deficiency was determined to be more than minor because if left uncorrected, the continued failure of craft personnel to follow radiation work permit requirements when breaching contaminated systems could become more significant, in that, it could lead to personnel contamination events and unplanned/unexpected dose, and is therefore a finding. The finding was associated with the Occupational Radiation Safety Cornerstone. Using Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, the inspector determined the finding to be of very low safety significance because: (1) it was not associated with as low as reasonably achievable (ALARA) planning or work controls; (2) there was no overexposure; (3) there was no substantial potential for an overexposure; and (4) the ability to assess dose was not compromised. The finding has a cross-cutting aspect in the area of human performance associated with the decision-making component because workers failed to use conservative assumptions in decision making when breaching a contaminated system for maintenance.
05000298/FIN-2012003-102012Q2CooperFailure to Perform a Radiation and Contamination SurveyThe inspectors reviewed a self-revealing, non-cited violation of 10 CFR 20.1501(a) for the failure to perform adequate radiation and contamination surveys. Specifically, a survey was not performed prior to power washing the reactor vessel studs during reactor cavity decontamination work as part of Refueling Outage 26. The absence of a survey resulted in an unanticipated airborne radioactivity area and unintended, unplanned dose to five workers. The issue was documented in Condition Report CR-CNS-2011-04891. The failure to perform a survey to evaluate the radiological conditions is a performance deficiency. The finding is more than minor because it negatively impacted the Occupational Radiation Safety Cornerstone attribute of program and process, in that, the lack of a survey did not ensure exposure control for workers. Using Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, the finding was determined to be of very low safety significance because: (1) it was not associated with ALARA planning or work controls; (2) there was no overexposure; (3) there was no substantial potential for an overexposure; and (4) the ability to assess dose was not compromised. This finding has a cross-cutting aspect in the area of human performance associated with the decision-making component because the radiation protection manager and cavity decontamination supervisor did not fully use radiological job plans and controls. Specifically, the radiation protection manager and cavity decontamination supervisor made the decision to power wash the vessel studs without using a written work plan.
05000298/FIN-2012003-112012Q2CooperALARA Program Failed to Prevent Unintended Doses for Refueling Floor Activities, Outage RE26Inspectors identified a finding of very low safety significance for the failure to follow ALARA planning and control procedures to maintain doses ALARA for refueling floor activities covered under Radiological Work Package 2011-05. Specifically, the licensee failed to follow an ALARA planning and work control procedure by not planning, evaluating, and implementing strategies to minimize dose increases to justify increases in the estimated collective dose. Consequently, there was an overage of 20 person-rem of unintended dose, which exceeded the dose estimate by 80 percent. The original dose estimate was 25 person-rem and actual dose was 45 person-rem. The finding and procedure concerns were documented in the licensees corrective action program as Condition Reports CR-CNS-2012-02551 and CR-CNS-2012-02652. The failure to follow the ALARA planning and controls procedure to prevent unplanned and unintended collective doses was a performance deficiency. This finding is greater than minor because it affected the Occupational Radiation Safety Cornerstone attribute of program and process, in that, failure to implement ALARA procedures adequately caused increased collective radiation dose for the job activity to exceed 5 person-rem and exceeded the planned dose by more than 50 percent. In addition, this type of issue is addressed in Example 6.j of Inspection Manual Chapter 0612, Appendix E, Examples of Minor Issues. Using the Occupational Radiation Safety Significance Determination Process, the inspectors determined that this finding was of very low safety significance because it involved ALARA planning and controls and the licensees latest rolling three-year average does not exceed 240 person-rem. This finding has a cross-cutting aspect in the area of human performance associated with the work control component because the licensee failed to evaluate the impact of work scope changes on human performance and interdepartmental communication and coordination prior to commencing work activities. Specifically, work groups, Health Physics, and the ALARA Planners did not effectively communicate how work scope changes of the radiation work permits would affect the dose estimate of the radiological work package.
05000298/FIN-2012003-122012Q2CooperFailure to Maintain Design Control of the Essential Ventilation SystemThe inspectors identified a non-cited violation of 10 CFR 50 Part 50, Appendix B, Criterion III, Design Control, associated with the licensees failure to ensure that the control buildings essential ventilation system would maintain battery room temperatures such that the batteries would remain operable under all design conditions. Specifically, the essential ventilation system does not provide a heat source for the battery rooms and during cold weather conditions cannot maintain room temperatures above the minimum required for operability without the use of portable heaters. This issue was entered into the licensees corrective action program as Condition Report CR-CNS-2012-00724. The licensees failure to ensure that the essential ventilation system would support battery operability under all design conditions was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone, and affected the associated cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and is therefore a finding. Using Manual Chapter 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings, the finding was determined to have very low safety significance (Green) because the finding: (1) was not a design or qualification issue confirmed not to result in a loss of operability or functionality; (2) did not represent an actual loss of safety function of system or train; (3) did not result in the loss of one or more trains of nontechnical specification equipment; (4) did not screen as potentially risk significant due to seismic, flooding, or server weather initiating event. This finding had a cross-cutting aspect in the area of human performance associated with the decision-making component because the licensee failed to conduct adequate effectiveness reviews of safety-significant decisions to verify the validity of the underlying assumptions, and identify possible unintended consequences. Specifically, the licensee failed to recognize the use of portable heaters as a manual action which indicated an inadequate ventilation design.
05000298/FIN-2012003-132012Q2CooperFail to Correct a Condition Adverse to Quality for Determining the Number of Multiply Starts for a Single Diesel Generator Starting Air AccumulatorThe inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions, for the licensees failure to prepare an adequate design calculation demonstrating that a single diesel generator starting air accumulator was capable of performing multiple starts of an emergency diesel generator. The licensee entered this deficiency into their corrective action program for resolution as Condition Report CR-CNS-2012-03039. The licensees failure to prepare an adequate design calculation demonstrating that a single diesel generator starting air accumulator was capable of performing multiple starts of an emergency diesel generator was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the design control attribute of the Mitigating Systems Cornerstone, and affected the associated objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and is therefore a finding. The inspectors evaluated the finding using Inspection Manual Chapter 0609.04, Phase 1 Initial Screening and Characterization of Findings. The inspectors determined that the finding is of very low safety significance (Green) because the finding: (1) was not a design or qualification issue confirmed not to result in a loss of operability or functionality; (2) did not represent an actual loss of safety function of system or train; (3) did not result in the loss of one or more trains of nontechnical specification equipment; (4) did not screen as potentially risk significant due to seismic, flooding, or severe weather initiating event. The finding was determined to have a cross-cutting aspect in the area of human performance associated with the decision making component because the licensee failed to use conservative assumptions and conduct effectiveness reviews to validate the underlying assumptions when determining the number of multiple starts on one diesel generator starting air accumulator.
05000298/FIN-2012003-142012Q2CooperFailure to Use Design-Basis Parameter Values in Design-Related CalculationsThe inspectors identified a non-cited violation of 10 CFR 50, Appendix B, Criterion III, Design Control, associated with the licensees failure to ensure that design bases parameters documented in the Updated Safety Analysis Report were used for station activities. Specifically, the licensee based an operability evaluation and a door breach sensitivity study on a parameter value determined in a calculation instead of the value documented in the Updated Safety Analysis Report because they failed to recognize information in Final Safety Analysis Report Amendment 25 that described the turbine building sidings response to a high energy line break as design bases information. This issue was entered into the licensees corrective action program as Condition Reports CR-CNS-2011-10391 and CR-CNS-2011-11861. The licensees failure to maintain design control when performing an operability evaluation and sensitivity study, with respect to the turbine building high energy line break analysis, is a performance deficiency. This performance deficiency was determined to be more than minor because if left uncorrected, the licensees practice of basing design-related analyses on parameter values that dont represent the design bases has the potential to lead to a more significant safety concern. Specifically, if the licensee bases analyses on a particular parameter value that doesnt represent the design bases and if that parameter value differs from the corresponding design-basis value in a nonconservative manner, then the licensee could reasonably complete an operability assessment based on the nonconservative parameter value and determine that a safety-related system is operable, when an operability assessment based on the design-basis parameter value would have determined that the system is inoperable. As a result, a safety-related system could remain in an undetected inoperable state for an indefinite period of time, and is therefore a finding. Using Inspection Manual Chapter 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, the inspectors determined this finding has very low safety significance (Green) because it: (1) was not a design or qualification issue confirmed not to result in a loss of operability or functionality; (2) did not represent an actual loss of safety function of system or train; (3) did not result in the loss of one or more trains of nontechnical specification equipment; and (4) did not screen as potentially risk-significant due to seismic, flooding, or a severe weather initiating event. The finding was determined to have a cross-cutting aspect in the area of human performance associated with the decision-making component because the licensee failed to use conservative assumptions in decision making when they failed to recognize and control design bases information.
05000298/FIN-2012003-152012Q2CooperLicensee-Identified ViolationTitle 10 CFR Part 50, Appendix B, Criterion III, Design Control, states, in part, that, measures shall be established to assure that applicable regulatory requirements and the design bases, as defined in 10 CFR 50.2 and as specified in the license application, for those components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions. Contrary to the above, the licensee identified from April 1990 to May 2012, that they failed to maintain the design control of the residual heat removal suction strainers maximum calculated heat loss during design basis accident. The performance deficiency was determined to be more than minor because it was associated with the design control attribute of the Mitigating Systems Cornerstone, and affected the associated cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and is therefore a finding. The inspectors evaluated the finding using Inspection Manual Chapter 0609.04, Phase 1 Initial Screening and Characterization of Findings. The inspectors determined that the finding is of very low safety significance (Green) because the finding: (1) was not a design or qualification issue confirmed not to result in a loss of operability or functionality; (2) did not represent an actual loss of safety function of system or train; (3) did not result in the loss of one or more trains of nontechnical specification equipment; (4) did not screen as potentially risk significant due to seismic, flooding, or severe weather initiating event.
05000298/FIN-2012003-162012Q2CooperLicensee-Identified ViolationTitle 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions, requires, in part, that, Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. Contrary to the above, until April 17, 2012, the licensee identified a failure to follow procedure that resulted in the inadequate lubrication of service water valves SW-V-1281 and SW-V-1282, which caused them to become sticky and difficult to open. Service water valve SW-V-1282 was repaired and SW-V-1281 is currently clapped open. The performance deficiency was determined to be more than minor because it was associated with the design control attribute of the Mitigating Systems Cornerstone, and affected the associated cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and is therefore a finding. The inspectors evaluated the finding using Inspection Manual Chapter 0609.04, Phase 1 Initial Screening and Characterization of Findings. The inspectors determined that the finding is of very low safety significance (Green) because the finding: (1) was not a design or qualification issue confirmed not to result in a loss of operability or functionality; (2) did not represent an actual loss of safety function of system or train; (3) did not result in the loss of one or more trains of nontechnical specification equipment; (4) did not screen as potentially risk significant due to seismic, flooding, or severe weather initiating event.
05000298/FIN-2013007-012013Q3CooperFailure to Take Adequate Corrective Action for a Condition Adverse to Fire ProtectionThe team identified a Green non-cited violation of License Condition 2.C.(4), Fire Protection, for the failure to implement and maintain in effect all provisions of the approved fire protection program. Specifically, the team identified that the licensee failed to implement adequate corrective actions for a condition adverse to fire protection related to circuits that could disable the automatic starting of the electric driven fire pump due to fire damage. The licensee entered this finding into its corrective action program under Condition Report 2013-05866 The failure to promptly identify and correct a condition adverse to fire protection was a performance deficiency. This finding is more than minor because it is associated with the Mitigating Systems cornerstone attribute of Protection Against External Events (fire) and affects the associated cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The team performed a walkdown of both, electric and diesel, fire pump circuits from the control room to the fire pump house. The control room has fire pump switches and status lights in the sprinkler control and fire alarm panel. The control room is continuously manned and fire extinguishers are available for manual fire suppression. The fire pump circuits in the cable spreading room are routed in separate conduits in parallel with no fixed ignition sources near the conduits. Transient combustibles in the cable spreading room are limited and strictly controlled. Transient combustibles are only a potential threat where the conduits vertically go through the floor. The fire pump circuits in the seal water pump area and hallway (control building elevation 903) are not routed near any fixed ignition sources. Combustible materials are stored near the conduits in the multipurpose facility, but there are no significant ignition sources or work areas nearby. Using Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, the finding was assigned a low degradation rating, because the wiring was routed in conduits through areas with limited combustibles and no ignition sources; consequently this finding is of very low safety significance (Green) per Attachment 1, Task 1.3.1, Question 1. The finding did not have a cross-cutting aspect since it was not indicative of present performance in that the performance deficiency occurred more than three years ago.
05000298/FIN-2015403-012015Q1CooperSecurity
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05000298/FIN-2015403-032015Q1CooperSecurity
05000298/FIN-2015403-042015Q1CooperSecurity
05000298/FIN-2015403-052015Q1CooperLicensee-Identified Violation
05000298/FIN-2016008-012016Q3CooperPossible Failure to Ensure that the Assumptions in the Engineering Analysis Remain ValidAs part of the transition to a performance-based, risk-informed fire protection program, the licensee adopted the requirements of NFPA 805. NFPA 805 requires the following in Section 2.6: Monitoring. A monitoring program shall be established to ensure that the availability and reliability of the fire protection systems and features are maintained and to assess the performance of the fire protection program in meeting the performance criteria. Monitoring shall ensure that the assumptions in the engineering analysis remain valid. The team reviewed selected samples of equipment monitored by the licensee using Procedure 3-CNS-DC-357, NFPA 805 Monitoring Program, Revision 0, to ensure that the licensees program properly implemented the requirements of NFPA 805, Section 2.6. The team also reviewed Engineering Report Number ER2015-002, NFPA 805 Fire Protection Monitoring Program, Revision 2. The team observed that for components used in the fire probabilistic risk assessment, the unavailability time for those components was monitored using the existing maintenance rule monitoring program. These components included the: Control rod drive pumps Core spray pumps Emergency diesel generators Emergency station service transformer Startup station service transformer High pressure core spray pump Instrument air compressors Residual heat removal pumps Standby liquid control pumps Service water pumps The team noted that the action levels for availability in the maintenance rule monitoring program were greater than the assumptions in the fire probabilistic risk assessment. With this observation, the team questioned the licensee as to whether this met the requirement in NFPA 805 to maintain the assumptions in the engineering analysis. The licensee informed the team that they had performed a sensitivity analysis to determine the significance of monitoring at a higher level of unavailability via the maintenance rule. This analysis determined an increase in core damage frequency for the additional unavailability time that could be accrued above the assumption for availability in the fire probabilistic risk assessment and up to the maintenance rule monitoring value for unavailability. This increase in core damage frequency was then determined to be acceptable if it did not exceed 1.0E-6/year. The team noted that for an individual component this screening criterion would not exceed more than 2 percent of the licensees baseline fire core damage frequency. The team was aware that some particular aspects of the monitoring program were being discussed between the industry and the NRCs Office of Nuclear Reactor Regulation during periodic public meetings which discussed Frequently Asked Question 10-0059, NFPA 805 Monitoring. The monitoring program and the sensitivity analysis approach used by the licensee are enveloped in these discussions. The team determined that additional information is required to determine if a performance deficiency exists. Specifically, the team needed to determine if the licensees action to set the action levels for the availability of some plant components at the components maintenance rule monitoring values and the performance of a riskinformed sensitivity analysis in an attempt to ensure that the assumptions in the engineering analysis remained valid would be an acceptable approach. Judgment on the suitability of this approach is pending further resolution of the monitoring program during discussions of Frequently Asked Question 10-0059, NFPA 805 Monitoring. The licensee entered this issue of concern into the corrective action program as Condition Report CR-CNS-2016-05109. This issue of concern is being treated as Unresolved Item 05000298/2016008-01, Possible Failure to Ensure that the Assumptions in the Engineering Analysis Remain Valid.
05000298/FIN-2017002-012017Q2CooperFailure to Assess Operability of Technical Specification System Functions during Surveillance TestingGreen . The inspectors identified a non- cited violation of Technical Specification 5.4.1.a, for the licensees fail ure to follow Station Procedure 0.26, Surveillance Program, Revision 70, and to assess the operability of alternate shutdown reactor pressure instrumentation during surveillance testing. Specifically, the licensee failed to assess the operability of the hig h pressure coolant injection turbine steam inlet pressure instrument that provides indications of reactor pressure for the alternate shutdown panel when the instrument was isolated during surveillance testing. As a result, operations personnel failed to r ecognize that the instrument was inoperable and failed to enter the appropriate technical specification action statements . As immediate corrective actions, the licensee validated that the alternate shutdown reactor pressure function was inoperable and that Technical Specification 3.3.3.2, Altern ate Shutdown System, Condition A, should have been entered, and generated a procedure change request to ensure T echnical Specification 3.3.3.2 would be entered during future surveillances . The licensee entered this deficiency into the corrective action program as Condition Report CR -CNS -2017- 02280. The licensees failure to assess the operability of alternate shutdown reactor pressure instrument ation when the high pressure coolant injection turbine inlet steam pr essure instrument was isolated for surveillance testing, in violation of Station Procedure 0.26, was a performance deficiency. The performance deficiency was determined to be more than minor , and therefore a finding, because it was associated with the hum an 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. Specifically, the alternate shutdown reactor pressure instrument was inoperable when the high pressure coolant injection turbine inlet pressure instrument was isolated for surveillance testing, and the appropriate technical specification action statement was not entered. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, the inspectors determined that the finding had very low safety significance (Green) because it: was not a design deficiency; did not repr esent a loss of system and/or function; did not represent an 3 actual loss of function; did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time; and did not result in the loss of a high safety -significant nontechnical specification train. The finding had a cross -cutting aspect in the area of human performance associated with work management. Specifically, the licensee failed to implement a process of planning, controlling, and executing work activities such that nuclear safety was the overriding priority, including the identification and management of risk commensurate with the isolation of the high pressure coolant injection turbine inlet pressure instrument during surveillance testing (H.5).
05000298/FIN-2017002-022017Q2CooperLoss of Control Room Ventilation Due to Ineffective Preventive Maintenance StrategyGreen . The inspectors reviewed a self -revealed, non- cited violation of Technical Specification 5.4.1.a , for the licensees failure to maintain work order instructions for control room supply fan maintenance resulting in the loss of the control room emergency filtration system. Specifically, prior to October 23, 2016, work order instructions for periodic preventive maintenance on the SF- C-1A supply fan failed to include industry recommended checks to ensure that the bearings were adequately engaged with the fan shaft, and failed to include proper work sequencing to ensure vibration data trending was meaningful. The ineffective preventive maintenance strategy resulted in the failure of the control room supply fan i nboard bearing during operation and a loss of the control room emergency filtration system function. Corrective actions to restore compliance included repair of the s upply fan and changes to improve the effectiveness of the fans preventive maintenance strategy. The licensee entered this deficiency into the corrective action program as Condition Report CR- CNS -2016- 07426. The licensees failure to maintain work order instructions for control room supply fan maintenance , in violation of Technical Specification 5.4.1.a , was a performance deficiency. The performance deficiency was more than minor , and therefore a finding, because it was associated with the structure, system, and component (SSC) and barrier performance attribute of the Barrier Integrity Cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers ( control room envelope) protect the public fro m radionuclide releases caused by accidents or events. Using Inspection Manual Chapter 0609, Appendix G, Attachment 1, Shutdown Operations Significance Process Phase 1 Initial Screening and Characterization of Findings, dated May 9, 2014, the inspectors determined that the finding had very low safety significance (Green) because the inspectors answered no to all of the Barrier Integrity screening questions. The finding had a cross -cutting aspect in the area of human performance associated with resourc es, because the licensee failed to ensure that personnel, equipment, procedures, and other resources we re available and adequate to support nuclear safety (H.1).
05000298/FIN-2017002-032017Q2CooperLoss of Control Room Ventilation Due to Improper Switch ManipulationThe inspectors reviewed a self -revealed, non- cited violation of Technical Specification 5.4.1.a , for the licensees f ailure to implement System Operating Procedure 2.2.38, HVAC Control Building, Revision 43, during control building ventilation testing. Specifically, on December 7, 2016, when directed to turn off control building ventilation recirculation fan, RF- C-1A, operations personnel instead inadvertently turned off the operating control room emergency filtration system supply fan, 1 -SF -C-1A, resulting in the loss of the control room emergency filtration system function. Corrective actions to restore compliance included restoration of the control room emergency filtration supply fan and procedure changes to require peer checks for this surveillance test and similar 4 activities. The licensee entered this deficiency into the corrective action program as Condition Report CR -CNS -2016- 08744. The licensees failure to implement System Operating Procedure 2.2.38 , in violation of Technical Specification 5.4.1.a , was a performance deficiency. The performance deficiency was determined to be more than minor, and therefore a finding, because it was associated with the human performance attribute of the Barrier Integrity Cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers ( control room envelope) protect the public from radionuclide releases caused by accidents or events. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At -Power, dated June 19, 2012, the inspectors determined that the finding had very low safety significance (Green) because it did not represent a degradation of the barrier function of the control room against smoke or a toxic atmosphere. The finding had a cross -cutting aspect in the area of human performance associated with challenge the unknown, because the licensee did not stop when faced with uncertain conditions, and did not ensure that risks we re evaluated and managed before proceeding. Specifically, despite noting several a bnormalities with the switch being manipulated, operations personnel did not stop to evaluate the uncertain conditions nor did they evaluate the risks associated with proceeding (H.11).
05000298/FIN-2017002-042017Q2CooperLicensee-Identified ViolationTechnical Specification 5.7.1 states, in part, that high radiation areas w ith dose rates greater than 0.1 rem/hr at 30 centimeters shall be barricaded and conspicuously posted as a high radiation area. Contrary to the above, on November 2, 2016, a high radiation area with does rates greater than 0.1 rem/hr at 30 centimeters was not barricaded and conspicuously posted as a high radiation area. Specifically, a radiation protection technician (RPT) identified an unposted high radiation area at the control rod drive (CRD) A pump filter area on r eactor building 881 feet southea st quadrant. D ose rates of 120 mrem/hr at 30 centimeters from the CRD filter were identified. This issue was identified as a result of a RPTs deliberate and focused observations during the course of performing their normal duties of performing radiological surveys. The licensee documented this issue in the corrective action program as Condition Report CR- CNS -2016 -00788. The finding was determined to be of very low safety significance (Green) because it was not an ALARA planning issue, there was no overexposure or potential for overexposure, and the licensees ability to assess dose was not compromised.
05000298/FIN-2017010-012017Q2CooperFailure to Assign Corrective Actions to Prevent Recurrence of High Pressure Coolant Injection FailureGreen. The team identified a non-cited violation of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to assign corrective actions to preclude repetition of a significant condition adverse to quality associated with the loss of the high pressure coolant injection system. Specifically, between July 28, 2016, and June 29, 2017, the licensee failed to assign or complete corrective actions to prevent recurrence to address the failure of a relay coil that resulted in a loss of safety function for the single train high pressure coolant injection system. Corrective actions to restore compliance included reevaluation of the corrective 3 actions assigned to the root cause of the condition and the creation of corrective actions to prevent recurrence for the condition. The licensee entered this deficiency into the corrective action program as Condition Report CR 17 03544. The licensees failure to assign corrective actions to preclude repetition of a significant condition adverse to quality, in violation of 10 CFR 50, Appendix B, Criterion XVI, was a performance deficiency. The performance deficiency was evaluated using Inspection Manual Chapter 0612, Appendix B, Issue Screening, dated September 7, 2012, and was associated with the Mitigating Systems cornerstone. The team determined that the performance deficiency was more than minor, and therefore a finding, because if left uncorrected, the performance deficiency would have the potential to lead to a more significant safety concern. Specifically, the licensees failure to assign corrective actions to preclude repetition of a significant condition adverse to quality could reasonably result in the condition recurring and creating more safety-significant equipment failures. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, the inspectors determined that the finding had very low safety significance (Green) because it: was not a design deficiency; did not represent a loss of system and/or function; did not represent an actual loss of function; did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time; and did not result in the loss of a high safety-significant non-technical specification train. The finding had a cross-cutting aspect in the area of problem identification and resolution associated with resolution, because the licensee failed to ensure that the organization took effective corrective actions to address issues in a timely manner commensurate with their safety significance (P.3).
05000298/FIN-2017010-022017Q2CooperFailure to Perform Timely Operability DeterminationsGreen. The team identified a Green non-cited violation of Technical Specification 5.4.1.a, for the licensees multiple failures to immediately evaluate operability of degraded or nonconforming conditions. The team identified multiple examples of these operability determinations not being performed within one shift, as required by procedure. Further, aggregate data indicated routine noncompliance with procedural requirements to document operability immediately and without delay. The licensee entered this violation into its corrective action program as Condition Report CR-CNS-2017-03937, and began evaluating actions to restore compliance. Multiple failures to perform immediate operability determinations timely as required by station procedures is a performance deficiency. This performance deficiency is more than minor because it was associated with the equipment performance attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of system s that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, dated June 19, 2012, the inspectors determined that the finding had very low safety significance (Green) because it did not result in the loss of operability or functionality of any system or train. This finding has a consistent process cross-cutting aspect in the human performance cross-cutting area because operators failed to use a consistent, systematic approach to make decisions regarding operability using the organizations well-defined decision making process (H.13)
05000298/FIN-2017010-032017Q2CooperProgrammatic Failure to Identify and Correct Adverse TrendsGreen. The team identified a Green non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, for the licensees programmatic failure to promptly identify adverse trends and enter them into the corrective action program. Often, when adverse trends were identified, they were addressed using informal processes. This was particularly the case for safety culture-related trends such as adverse trends in organizational behaviors. The licensee entered this violation into its corrective action program as Condition Report CR-CNS-2017-03938, and took action to formalize identification processes for potential adverse trends. The programmatic failure to promptly identify adverse trends as required by station procedures was a performance deficiency. This performance deficiency is more than minor because if left uncorrected, it has the potential to become a more significant safety concern. Specifically, failure to arrest an adverse trend, particularly in organizational behaviors, could lead to increased likelihood of a worker-induced initiating event or a failure to effectively mitigate an accident. Using Inspection Manual Chapter 0609, Appendix A, dated June 19, 2012, the inspectors determined that the finding had very low safety significance (Green) because it did not result in the loss of operability or functionality of any system or train. This finding has a trending cross-cutting aspect in the problem identification and resolution cross- cutting area because the organization failed to use available information in the aggregate to identify programmatic and common cause issues (P.4).
05000298/FIN-2017010-042017Q2CooperFailure to Monitor No. 2 Diesel Generator under 50.65(a)(1) due to Inadequate Maintenance Rule EvaluationGreen. The team identified a non-cited violation of 10 CFR 50.65(a)(1)/(a)(2), for the licensees failure to perform an a(1) evaluation and establish a(1) goals when the No. 2 diesel generator a(2) preventive maintenance demonstration became invalid. Specifically, on April 28, 2017, the No. 2 diesel generator exceeded its performance criteria when it experienced a second maintenance rule functional failure, but the licensee failed to perform an associated a(1) evaluation. The licensee had failed to appropriately evaluate a February 4, 2017, failure associated with the No. 2 diesel generator jacket water heater failure in the Maintenance Rule Program and, as a result, the site failed to evaluate and monitor the equipment under 10 CFR 50.65(a)(1) as required. Corrective actions taken by the licensee to restore compliance included reevaluation of the February 4, 2017, functional failure and performance of an a(1) evaluation. The issue was entered into the licensees corrective action program as Condition Report CR-17-03930. The licensees failure to monitor the No. 2 diesel generator in accordance with the requirements of 10 CFR 50.65(a)(1), due to incorrectly evaluating one maintenance rule functional failure, in violation of 10 CFR 50.65(a)(1)/(a)(2), was a performance deficiency. The inspectors screened the performance deficiency using Inspection Manual Chapter 0612, Appendix B, Issue Screening, dated September 7, 2012, and determined that the issue was more than minor, and therefore a finding, because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, the inspectors determined that the finding had very low safety significance (Green) because it: was not a design deficiency; did not represent a loss of system and/or function; did not represent an actual loss of function; did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time; and did not result in the loss of a high safety-significant nontechnical specification train. The finding had a cross-cutting aspect in the area of problem identification and resolution associated with evaluation, because the licensee failed to ensure that the organization thoroughly evaluated 5 the No. 2 diesel generator issues to ensure that resolutions addressed causes and extent of conditions commensurate with their safety significance (P.2)
05000298/FIN-2017010-052017Q2CooperFailure to adopt appropriate procedures in accordance with 10 CFR Part 21Severity Level IV. The team identified a violation of 10 CFR 21.21(a), for the licensees failure to adopt appropriate procedures to evaluate deviations and failures to comply to identify those associated with substantial safety hazards. Specifically, Procedure EN-LI-108, 10 CFR 21 Evaluations and Reporting, Revision 5C0, was inadequate to ensure that the correct reportability call was made for a manufacturing flaw discovered in a relay that had resulted in a loss of safety function for the high pressure coolant injection system on April 25, 2016. In particular, the procedure (1) led the licensee to incorrectly conclude that a substantial safety hazard could not be created, (2) allowed a limited extent of condition in performing the substantial safety hazard evaluation such that similarly dedicated parts were not included in the scope, and (3) included incorrect guidance in Attachment 9.3. Corrective actions to restore compliance included re-evaluation of the defect under Part 21 requirements and a procedure adequacy review of the EN-LI-108-01 procedure. The licensee entered this issue into the corrective action program as Condition Reports CR-17-03936 and CR-17-04143. The failure to adopt appropriate procedures to evaluate deviations and failures to comply to identify those associated with substantial safety hazards, in violation of 10 CFR 21.21(a), was a performance deficiency. The NRCs reactor oversight process considers the safety significance of findings by evaluating their potential safety consequences. Using Inspection Manual Chapter 0612, Appendix B, Issue Screening, dated September 7, 2012, the team determined that the performance deficiency was of minor safety significance under the reactor oversight process because it involved a failure to make a report; however the underlying equipment failure was previously evaluated as having very low safety significance. The traditional enforcement process separately considers the significance of willful violations, violations that impact the regulatory process, and violations that result in actual safety consequences. Traditional enforcement applied to this finding because it involved a violation that impacted the regulatory process. The team used the NRC Enforcement Policy, dated November 1, 2016, to determine the significance of the violation. The inspectors determined that the violation was similar to Examples 6.9.d.10 and 6.9.d.13 of the Enforcement Policy, because although the procedure resulted in an inadequate reportability review and the issue was not reported as a manufacturing flaw, the licensee had reported some aspects of the event under the requirements of 10 CFR 50.73. As a result, the team determined that the violation should be classified as a Severity Level IV violation. Cross-cutting aspects are not assigned to traditional enforcement violations.
05000313/FIN-2007006-032007Q4Arkansas NuclearPotential for actuation of high/low interface valves.License Conditions 2.c.(8) and 2.C.(3)(b) for Units 1 and 2, respectively, specifies, "EOI shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in Appendix 9A to the SAR and as approved in the Safety Evaluation dated March 31, 1992." Further, as required by 10 CFR 50.48(b), "With respect to all other fire protection features covered by Appendix R, all nuclear power plants licensed to operate before January 1, 1979, must satisfy the applicable requirements of Appendix R to this part, including specifically the requirements of Sections III. G, III.J, and III. O." Section III. G.3.a specifies that aalternative or dedicated shutdown capability and its associated circuits in the area under consideration should be provided where the protection of systems whose function is required for hot shutdown does not satisfy the requirements of Section III.G.2. Generic Letter 81-12, "Fire Protection Rule," provided guidance on implementing Section III. G. of 10 CFR Part 50 Appendix R. The licensee did not meet the guidance and failed to adequately protect high/low pressure interfaces from the effects of a fire in order to prevent a loss-of-coolant accident. Additionally, the NRC response to Generic Letter 86-10, "Implementation of Fire Protection Requirements," Question 5.3.10, specified that the safe shutdown capability in an alternative shutdown system should not be adversely affected by a fire in any plant area, which results in spurious actuation of the redundant valves in any high/low pressure interface line. Contrary to the above, the licensee failed to provide alternative shutdown capability in the control room for circuits related to high/low interface valves as required specified by 10 CFR Part 50, Appendix R, Sections III. G and III. L. Specifically, the licensee failed to evaluate the impact of numerous pairs of high/low pressure interface valves and determine whether operators had time to respond or whether modifications would be required to correct the failure to adequately protect these valve combinations. Because the licensee committed to adopting NFPA 805 and changing their fire protection program license basis to comply with 10 CFR 50.48, this issue is covered by enforcement discretion in accordance with the NRC Enforcement Policy. Specifically, the licensee: (1) would have identified and addressed this issue during the conversion to NFPA 805, (2) had entered this issue into their corrective action program and implemented appropriate compensatory measures, (3) demonstrated the finding would not be categorized under the Reactor Oversight Process as Red or a Severity Level I violation, and (4) submitted their letter of intent prior to December 31, 2005. The inspector determined that this violation meets the criteria for enforcement discretion for plants in transition to a risk-informed, performance-based fire protection program as allowed per 10 CFR 50.48. Since all the criteria were met, the NRC is exercising enforcement discretion for this issue.
05000313/FIN-2013009-022013Q4Arkansas NuclearFailure to Maintain Adequate Staffing for Operators to Perform a Simultaneous Alternative Shutdown of Both Units and Staff the Fire BrigadeThe team identified an Unresolved Item (URI) concerning the failure to implement and maintain in effect all provisions of the approved fire protection program as defined by License Conditions 2.C.(8) for Unit 1 and 2.C.(3)(b) for Unit 2. Specifically, the licensee failed to maintain adequate staffing for operators to perform a simultaneous alternative shutdown of both units and staff the fire brigade. Further NRC staff evaluations will be required to determine if this issue is more than minor. The licensee provided the minimum operations shift staffing requirements in Procedure EN-OP-115, Conduct of Operations, Revision 14. This procedure required that the Unit 1 shift be comprised of a shift manager, control room supervisor, shift technical advisor, two licensed control board operators, two non-licensed auxiliary operators, a waste control operator, and a communicator. This procedure required the same staffing for Unit 2, but it noted that the Unit 2 communicator could serve as the alternate shutdown operator (a Unit 2 specific position). The licensee would use Procedure 1203.002, Alternate Shutdown, Revision 24, to perform an alternative shutdown for Unit 1 and Procedure 2203.014, Alternate Shutdown, Revision 26, to perform an alternative shutdown for Unit 2. The alternative shutdown procedure for Unit 1 required actions from the shift manager, control room supervisor, shift technical advisor, two control board operators, and two auxiliary operators. The alternative shutdown procedure for Unit 2 required actions from the shift manager, control room supervisor, shift technical advisor, two control board operators, two auxiliary operators, and the alternate shutdown operator. The licensee only required one communicator to respond to the technical support center to make the required notifications. The licensee would use Procedure 1203.029, Remote Shutdown, Revision 10, to perform a remote shutdown for Unit 1. The remote shutdown procedure required actions from the shift manager, control room supervisor, and two control board operators. Unlike the alternative shutdown procedure, it did not require actions from the two auxiliary operators. The licensee delineated operator responsibilities for alternative and remote shutdowns for both units in Calculation CALC-85-E-0086-02, Manual Action Feasibility and Common Results, Revision 4. The team noted that this calculation was not consistent with the current staffing. The calculation had not been updated after the 2007 addition of an auxiliary operator position or the 2012 addition of an alternate shutdown operator position for Unit 2. The team determined through discussions with the licensee that the fire brigade was composed of four non-licensed operators and one security officer. The waste control operator from each unit was assigned to the fire brigade and designated as the potential fire brigade leader, depending on the unit affected. In the event of an alternative shutdown of Unit 2, the licensee credited the waste control operator from Unit 2 as the fire brigade leader and the waste control operator from Unit 1, two auxiliary operators from Unit 1, and the security officer as the remaining fire brigade members. The licensee discussed operator responsibilities for an alternative shutdown of Unit 2 coincident with a remote shutdown of Unit 1, but did not discuss operator responsibilities for a simultaneous alternative shutdown of both units. The team concluded that the licensee failed to maintain adequate staffing for operators to perform a simultaneous alternative shutdown of both units and staff the fire brigade. Specifically, the licensee required actions from all operators other than the two waste control operators during a simultaneous alternative shutdown of both units. This left the two waste control operators and the security officer as the only assigned fire brigade members that could respond to a potential control room fire. The team reviewed the fire protection licensing basis. Since the control rooms were located in the same fire area, the team concluded that the licensee must be able to perform a simultaneous alternative shutdown of both units and staff the fire brigade. The team noted that the licensee did not have an exemption from this requirement. The licensee identified this non-compliance in 2006 and documented this issue in Condition Report CR-ANO-C-2006-00048, Corrective Action 36. In response to this concern, the licensee performed a risk evaluation but failed to initiate any corrective actions or compensatory measures. In 2007 and 2012, the licensee subsequently added the auxiliary operator and alternate shutdown operator positions, respectively, for an alternative shutdown of Unit 2. During each addition, the licensee failed to ensure the adequate staffing for operators to perform a simultaneous alternative shutdown of both units and staff the fire brigade. The licensee determined that alternative shutdown of both units would not be required since a fire in one control room would not be capable of causing circuit damage in equipment located in the other control room. The licensee developed detailed fire models to demonstrate this position as part of the transition to NFPA-805. The licensees License Amendment Request for Unit 2, dated March 27, 2012 (ML12087A113) has been submitted to the NRC and is under review by the NRC staff. The result of the NRC staff review of this analysis will be required to determine if this issue is more than minor. This issue is being treated as an unresolved item: URI 05000313;05000368/2013009-002, Failure to Maintain Adequate Staffing for Operators to Perform a Simultaneous Alternative Shutdown of Both Units and Staff the Fire Brigade.
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05000313/FIN-2015405-052015Q2Arkansas NuclearLicensee-Identified Violation
05000313/FIN-2016004-012016Q4Arkansas NuclearFailure to Pre-plan Walkdown to Avoid Impacting Safety BusGreen. The inspectors documented a self-revealed finding and associated non-cited violation of Unit 1 Technical Specification 5.4.1.a, for the failure to properly pre-plan and perform a pre-modification walkdown in the Unit 1 train A safety-related switchgear room so that the walkdown would not adversely affect the performance of train. As a result, licensee personnel inadvertently de-energized the A3 switchgear and associated ac buses, which resulted in the loss of one train of spent fuel pool cooling. Operators restored spent fuel pool cooling, the licensee evaluated the human error and performed a training stand-down to ensure pre-job walkdowns did not impact plant equipment. The licensee entered this issue into the corrective action program as Condition Report CR-ANO-1-2016-04356. The failure to perform a plant walkdown in a manner that did not impact safety-related switchgear is a performance deficiency. The performance deficiency is more than minor because it adversely affected the human performance attribute of the barrier integrity cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, de-energizing the safety-related switchgear resulted in the loss of one train of spent fuel pool cooling and an increase in risk level from Green to Yellow. The inspectors evaluated the finding with NRC Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, Exhibit 3, Barrier Integrity Screening Questions, because the appendix provides the most applicable guidance, regardless of whether the unit was at-power or shutdown. The inspectors determined that the finding screened as having very low safety significance (Green) because the finding did not cause the spent fuel pool to exceed the maximum analyzed temperature, did not damage fuel cladding, did not result in a loss pool water inventory below the minimum analyzed level, and did not affect the pool neutron absorber or soluble boron concentration. The inspectors determined this finding has a cross-cutting aspect in the human performance area of Avoid Complacency, because the primary cause of the performance deficiency involved the failure to plan for the possibility of mistakes and use appropriate error reduction tools. (H.12)
05000313/FIN-2016004-022016Q4Arkansas NuclearFailure to Design Pipe Support for VibrationGreen. The inspectors documented a self-revealed finding and associated non-cited violation of 10 CFR 50 Appendix B Criterion III for the licensees failure to verify that the decay heat removal (DHR) system drain piping configuration and supports could withstand vibrations created during low pressure and high flow conditions. As a result, a cracked weld and unisolable leak in the DHR system occurred due to high cycle fatigue caused by those conditions. To correct this issue, the licensee repaired the leaking weld and designed and installed a new piping support and piping configuration to reduce vibrations during the expected operating conditions. The licensee entered this issue into the corrective action program as Condition Report CR-ANO-1-2016-03225. The failure to design the decay heat removal system piping to withstand expected vibrations from the systems cavitating venturis is a performance deficiency. The performance deficiency is more than minor because it was associated with the design control attribute of the initiating events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, inadequate design of the DHR system piping support resulted in a leak that could have challenged the capability of both trains of the DHR system during shutdown on September 29, 2016. The inspectors performed an initial screening of the finding in accordance with NRC Inspection Manual Chapter (IMC) 0609, "Significance Determination Process," issued October 7, 2016, and were directed to IMC 0609, Appendix G, Attachment 1, "Shutdown Operations Significance Determination Process Phase 1 Screening and Characterization of Findings, since the finding pertained to a degraded condition while the plant was shutdown. Using IMC 0609, Appendix G, Attachment 1, dated May 9, 2014, the inspectors determined that the finding required a Phase 2 evaluation. A senior reactor analyst performed a Phase 2 evaluation in accordance with IMC 0609, Appendix G, Attachment 2, Phase 2 Significance Determination Process Template for PWR during Shutdown, dated February 28, 2005. The senior reactor analyst performed a Phase 2 evaluation which used realistic break characteristics and plant configuration changes to determine the significance to be of very low safety significance (Green). The inspectors determined this finding did not have a cross-cutting aspect because the most significant contributor did not reflect current licensee performance. Specifically, the licensee last reviewed and modified the pipe support configuration in 1996
05000313/FIN-2016004-032016Q4Arkansas NuclearLicensee-Identified ViolationThe licensee identified that the Unit 1 emergency diesel generator governors were left in droop mode at all times, so that during a loss of offsite power the speed and frequency of the EDGs would decrease as loading increased and cause a reduction in speed and capability from safety-related motors. The licensee determined that some EDG-powered safety-related motors would not have been capable of providing the required flow rate for a short period of time, but this did not prevent them from performing their safety function. Title 10 CFR Part 50, Appendix B, Criterion V, Instruction, Procedures, & Drawings, states, in part, that activities affecting quality shall be prescribed by procedures of a type appropriate to the circumstance. Contrary to the above, as of November 2, 2016, the procedure for Unit 1 EDG operations, an activity affecting quality, was not appropriate to the circumstance. Specifically, Procedure OP-1104.036, Emergency Diesel Generator Operation, Revision 74, did not state to set the speed droop settings for both A and B EDGs to zero when not load sharing with another power source and did not specify this as a requirement for the EDGs when in an emergency standby condition. The licensee immediately set the speed droop settings for both EDGs to zero and changed the procedure. The licensee documented the issue in their corrective action program as Condition Report CR-ANO-1-2016-04333. Using NRC Inspection Manual Chapter 0609, Appendix A, "The Significance Determination Process (SDP) For Findings At-Power, dated June 19, 2012, the inspectors determined the finding to be of very low safety significance (Green) because the deficiency did not result in a loss of a safety function.
05000313/FIN-2016004-042016Q4Arkansas NuclearLicensee-Identified ViolationDuring the fall 2016 Unit 1 refueling outage, the licensee foreign object search and retrieval (FOSAR) inspections in the steam generator bowls and reactor vessel identified a number of foreign objects, including an 8-inch metal rod. Discussions with the licensee indicated that some of the debris constituted foreign material that should have been prevented from being introduced into the RCS by the foreign material exclusion program. The inspectors concluded that the foreign material was most likely introduced during the previous refueling outage. During the prior operating cycle, the licensees chemistry sampling identified increased RCS activity, and subsequent fuel bundle examinations of fuel removed from the core identified wear marks through the cladding of two adjacent fuel pins. The fuel assembly with the damage was not placed back into the RCS. Since there was no evidence of broken components inside the RCS, the licensee concluded that the most likely cause was the introduction of foreign material. While it was not possible to determine whether any of the foreign material had actually caused the fuel damage, the inspectors concluded that the licensee had failed to control foreign material and prevent it from entering the RCS. Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be accomplished in accordance with documented instructions, procedures, or drawings of a type appropriate to the circumstances. Licensee Procedure EN-MA-118, Foreign Material Exclusion, Revision 10, an Appendix B quality-related procedure, provides instructions for controlling foreign material. Procedure EN-MA-118, Step 5.5, requires, in part, that all material and tools that were introduced to the FME zone are accounted for. Contrary to the above, between January 25, and March 1, 2015, the licensee failed to ensure that all material and tools that were introduced to the FME zone were accounted for. Specifically, the licensee failed to maintain adequate FME control, leading to two damaged cladding pins and slightly elevated dose rates in the RCS piping, as well as another piece of metallic FME in the vessel, as documented in CR-ANO-1-2016-03340. This issue was documented in the licensees corrective action program under CR-ANO-1-2016-03521. Corrective actions taken include a search for the foreign material and permanent removal of the fuel assembly from the core. Prior to 2012, the NRCs Significance Determination Process in IMC 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, contained guidance to screen all more than minor performance deficiencies affecting fuel barriers to very low safety significance. The inspection manual chapters were restructured in 2012, and the screening was inadvertently omitted, though the NRC was in the process of reinstating that same guidance. Therefore, after consultation with the Office of Nuclear Reactor Regulation, the inspectors determined that this finding is of very low safety significance (Green).
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