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| Quarter | Site | Title | Description | |
|---|---|---|---|---|
| 05000461/FIN-2016002-02 | 2016Q2 | Clinton | Inspection Fails to Identify Safety Related Cables Submerged in Cable Vault | The inspectors identified a finding of very low safety significance (Green) and associated NCV of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action Program, for the failure to identify a condition adverse to quality. Specifically, the licensee failed to identify that portions of the Division 1 SX safety related cables, which are not rated for submergence, were under water. The licensee entered this issue into their corrective action program as action requests AR 02648804 and AR 02648507. Operators took actions to pump out the water to ensure the cables were returned to a dry condition. The inspectors determined the licensees failure to identify a condition adverse to quality was contrary to 10 CFR 50, Appendix B, Criterion XVI, Corrective Action Program, and was a performance deficiency. The performance deficiency was determined to be more than minor because the finding was associated with the Mitigating Systems Cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, because the SX cables are not rated for submergence, they could degrade and affect the reliability of the SX system. The finding was screened against the Mitigating Systems cornerstone and determined to be of very low safety significance (Green) because the inspectors answer Yes to the question does the SSC maintain its operability or functionality. Specifically, the SX system submerged cables did not cause the SX system to be inoperable or nonfunctional. The inspectors determined that this finding had a cross-cutting aspect in the area of human performance in the aspect of resources, where leaders ensure that personnel, equipment and other resources are available and adequate to support nuclear safety. Specifically, the individuals performing the inspection did not have the necessary resources, such as training, procedures, drawings or a detailed pre-job brief, to identify the cables sloped downwards in the cable vault and were submerged in the water. (H.1) |
| 05000461/FIN-2016002-03 | 2016Q2 | Clinton | Failure to Properly Install Cable Vault Mitigating Equipment | The inspectors identified a finding of very low safety significance (Green) for the failure to incorporate human performance standards when developing work package instructions in accordance with MAAA716010,Maintenance Planning, Revision 23. Specifically, the licensee did not assure the cable vault dewatering system installation and maintenance work order (WO) included the appropriate details to troubleshoot and install the cable vault sump pumps and float switches. This resulted in installation of the equipment in a manner that prevented detection and removal of water from the cable vaults, allowing cables to remain submerged undetected. The licensee entered this issue into their CAP as AR 02668245. The corrective actions performed by the licensee included placing the sump pumps in the right location and adjusting the float switches to ensure the indications would alert operators when the vaults needed to be pumped. The inspectors determined that the failure to incorporate human performance standards when developing work package instructions in accordance with MAAA716010, Maintenance Planning, Revision 23, was a performance deficiency. The performance deficiency was determined to be more than minor because if left uncorrected the performance had the potential to lead to a more significant safety concern. Specifically, by not appropriately installing the sump pumps and float switches, the cables would be allowed to remain submerged undetected. The finding was screened against the Mitigating Systems cornerstone and determined to be of very low safety significance (Green) because the inspectors answer Yes to the question does the SSC maintain its operability or functionality?. This finding has a cross-cutting aspect in the area of human performance in the aspect of conservative bias, where individuals use decision making practices that emphasize prudent choices over those that are simply allowable. Specifically, because the licensee classified the cable vault dewatering system as a maintenance tool, they decided it was not necessary to include specific instructions within the WOs related to ensure the troubleshooting and re-installation activities were performed appropriately. (H.14) |
| 05000461/FIN-2016002-04 | 2016Q2 | Clinton | Inadequate Ultrasonic Examination for Service Water System Pipe Repaired | On May 17, 2016, the inspectors identified a finding of very-low safety significance and associated NCV of 10 CFR 50, Appendix B, Criterion IX, Control of Special Processes, for the licensees failure to ensure that nondestructive testing was controlled and accomplished using qualified procedures in accordance with applicable codes and standards. Specifically, the licensee did not implement an angle beam ultrasonic (UT) examination to detect cracking in a degraded SX pipe prior to implementation of a weld overlay repair. The licensee subsequently performed the required UT examination to confirm the absence of cracks and documented the issue in the CAP in AR 02671724. The inspectors determined that this finding was more than minor because if left uncorrected, the failure to perform the UT would become a more significant safety concern. Specifically, if left uncorrected, the use of an unqualified UT examination for detection of cracks could result undetected cracks that propagate to failure during service. The inspectors determined this finding was of very low safety significance (Green) based on answering yes to the questions in Part A of Exhibit 2, Mitigating Systems Screening Questions, in IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Specifically, the inspectors answered yes to the screening question If the finding is a deficiency affecting the design or qualification of a mitigating SSC (structures, systems, or components), does the SSC maintain its operability or functionality? because the licensee subsequently performed appropriate UT examination to confirm that cracks were not present. The finding had a cross-cutting aspect in the area of Human Performance for Procedure Adherence, because the licensee failed to follow processes, procedures, and work instructions to ensure that the appropriate UT examination was applied to the degraded SX pipe. (H.8) |
| 05000461/FIN-2016002-05 | 2016Q2 | Clinton | Lack of Acceptance Criteria for Containment Visual Examinations | The inspectors identified a finding of very-low safety significance and associated NCV of 10 CFR 50.55a(g)(4). Specifically, the licensee failed to define acceptance criteria for containment visual examinations. Consequently, active containment liner degradation on a containment penetration was identified and returned to service without comparing to defined acceptance criteria. The licensee verified through visual examination that the liner thickness was marginally affected by the corrosion and documented this issue in the Corrective Action System in AR 02671728. The inspectors determined that the failure to define and incorporate acceptance criteria in the containment visual examination procedure as required by 10 CFR 50.55a(g)(4) was a performance deficiency. The inspectors determined that this issue was more than minor in accordance with IMC 0612, Appendix B, Issue Screening, dated September 7, 2012, because the inspectors answered yes to the more than minor question If left uncorrected, would the performance deficiency have the potential to lead to a more significant safety concern in that active containment penetration degradation may not be properly evaluated and/or promptly corrected. Specifically, the inspectors were concerned that without acceptance standards, unacceptable containment degradation may be returned to service and adversely affect containment leakage or structural integrity. The inspectors determined this finding was of very-low safety significance (Green) based on answering no to Questions B.1 and B.2 of the Exhibit 3, Barrier Integrity Screening Questions, in IMC 0609, Attachment A, The Significance Determination Process (SDP) for Findings At-Power, issued on June 19, 2012. Specifically, the inspectors answered no to the screening question associated with an actual open pathway (e.g., breach) in the containment and no to the question associated with reduction in function of hydrogen igniters in containment. A subsequent visual examination performed by the licensee confirmed only marginal degradation of the liner thickness. The inspectors determined that this finding had a cross-cutting aspect in the area of human performance in the aspect of consistent process, where individuals use a consistent, systematic approach to make decisions. Specifically, the lack of acceptance criteria allowed various interpretations for disposing of identified conditions that were inconsistent. (H.13) |
| 05000461/FIN-2016002-06 | 2016Q2 | Clinton | Failure to Perform Surface Examination Prior to Weld Repair of a Reactor Water Cleanup System Pipe | The inspectors identified a finding of very-low safety significance and associated NCV of 10 CFR 50.55a(g)(4). Specifically, the licensee failed to perform a surface examination to detect cracking on reactor water cleanup small-bore piping prior to performing a weld repair. The license documented the issue in the CAP as AR 02671726 and AR 02685332 and performed an operability review. The licensee has prepared a work order to perform a surface exam of the existing weld and surrounding area. The inspectors determined that the failure to perform the surface examination prior to weld repair of RWCU pipe 1G33C001B as required by 10 CFR 50.55a(g)(4) was a performance deficiency. The inspectors determined that this issue was more-than-minor in accordance with IMC 0612, Appendix B, because it adversely affect the Initiating Events Cornerstone attribute of barrier integrity and because the answer to the question of If left uncorrected, would the performance deficiency have the potential to lead to a more significant safety concern? was yes. Specifically, the lack of a surface exam may result in the entire defect not being removed during the repair and the potential existed for a cracked pipe to remain in service. This could lead to a repeat leak of reactor coolant. The inspectors determined this finding was of very-low safety significance (Green) based on answering no to Question A.1 and A.2 of the Exhibit 1, Initiating Events Screening Questions, in IMC 0609, Attachment A, The Significance Determination Process (SDP) for Findings At-Power. Specifically, the inspectors answered no to the screening question associated with a reactor coolant system leak exceeding the leak rate for a small loss of coolant accident (LOCA) and no to the screening question associated with systems used to mitigate a LOCA. A subsequent visual examination of the weld repair revealed an absence of cracking and the licensee also planned to perform a follow-up surface examination of the repaired area to look for cracking. The inspectors determined that this finding had a cross-cutting aspect in the area of human performance in the aspect of resources, where leaders ensure that personnel, equipment, procedures and other station resources are available and adequate to support nuclear safety. Specifically, the work order that performed the work did not specify a surface examination of the base metal prior to welding. (H.1) |
| 05000461/FIN-2016002-07 | 2016Q2 | Clinton | Failure to Obtain License Amendment prior to Operating Reactor Water Cleanup Bypass Switches | The inspectors identified a Severity Level IV NCV of 10 CFR 50.59(a)(1), Changes, Tests, and Experiments, and an associated Green finding for the licensees failure to perform an adequate written safety evaluation to provide the basis that changes to the Updated Safety Analysis Report (USAR) and station procedures did not involve an unreviewed safety question. Specifically, the licensee changed the USAR and station procedures to allow operators to a defeat the safety function of the reactor water cleanup (RWCU) isolation valves to prevent unwarranted isolation signals during normal operation without obtaining prior Commission approval. The licensee entered this issue into their CAP as AR 02685337 and will be changing station procedures to prevent placing the RWCU leak detection divisional bypass switches in bypass except for instrument channel maintenance, testing or calibration. The inspectors determined that the licensees failure to perform an adequate written safety evaluation to provide the basis that changes to the USAR and station procedures did not involve an unreviewed safety question 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 Initiating Events cornerstone and adversely affected the cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The finding was screened against the Initiating Events cornerstone and determined to be of very low safety significance (Green) because the finding did not result in exceeding the RCS leak rate for a small LOCA and did not affect other systems used to mitigate a LOCA resulting in a total loss of their function (e.g. Interfacing System LOCA). No cross cutting aspect was assigned because the inspectors determined the performance deficiency was not indicative of current plant performance. Violations of 10 CFR 50.59 are dispositioned using the traditional enforcement process because they are considered to be violations that potentially impede or impact the regulatory process. The inspectors reviewed Section 6.1.d.2 of the NRC Enforcement Policy and determined this violation was Severity Level IV because the resulting changes were evaluated by the SDP as having very low safety significance. |
| 05000461/FIN-2016002-08 | 2016Q2 | Clinton | Failure to Update the Updated Safety Analysis Report (USAR) Peak Suppression Pool Temperature | The inspectors identified a Severity Level IV NCV of 10 CFR 50.71(e), Periodic Update of the (Final Safety Analysis Report) FSAR, for the licensees failure to update the USAR after updating a Safety Analysis Calculation. Specifically, the licensee did not update the USAR Section A3.8.3.1 and Table 15.2.91 to coincide with the most recent updates to the accident analysis of record. The licensee initiated AR 2664276 to document the discrepancy in the peak suppression pool temperature throughout the USAR and initiated actions to revise FSAR Section A3.8.3.1 and Table 15.2.91 to coincide with the most recent revision to EPUT0400. The inspectors determined that the failure to update the USAR in accordance with 10 CFR 50.71(e), Periodic Update of the FSAR, with the most accurate version of calculated peak suppression pool temperature during an accident was a performance deficiency. The performance deficiency was determined to be minor in accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated September 7, 2012; however, the reactor oversite programs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance, therefore, it was necessary to address this violation which impeded the NRCs ability to regulate using traditional enforcement to adequately deter non-compliance. The inspectors reviewed this issue in accordance with IMC 0612 and the NRC Enforcement Policy. Violations of 10 CFR 50.71(e) are dispositioned using the traditional enforcement process because they are considered to be violations that potentially impede or impact the regulatory process. The inspectors reviewed Section 6.1.d.3 of the NRC Enforcement Policy and determined this violation was Severity Level IV because the licensees failure to update the USAR as required by 10 CFR 50.71(e) had not yet resulted in any unacceptable change to the facility or procedures. No cross cutting aspect was assigned because traditional enforcement violations are not assessed for cross cutting aspects. |
| 05000461/FIN-2016002-09 | 2016Q2 | Clinton | Failure to Update the Updated Safety Analysis Report (USAR) Condensate and Feedwater System | The inspectors identified a Severity Level IV NCV of Title 10 Code of Federal Regulations (CFR) 50.71(e), Periodic Update of the FSAR, for the licensees failure to update the FSAR after implementation of license amendment 149, for extended power uprate. Specifically, the licensee did not update USAR Section 10.4.7.1.2 Performance Requirements, for the condensate and feedwater system with the design requirements for a reactor thermal power rating of 3473 MWt. The licensee entered the issue into their CAP as AR 02656128 and is preparing a technical change package to update the USAR. The inspectors determined that the failure to update the USAR in accordance with 10 CFR 50.71(e), Periodic Update of the FSAR, with the design requirements for the condensate and feedwater system for a reactor thermal power rating of 3473 MWt was a performance deficiency. The performance deficiency was determined to be minor in accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated September 7, 2012; however, the reactor oversite programs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance, therefore, it was necessary to address this violation which impeded the NRCs ability to regulate using traditional enforcement to adequately deter non-compliance. The inspectors reviewed this issue in accordance with NRC IMC 0612 and the NRC Enforcement Policy. Violations of 10 CFR 50.71(e) are dispositioned using the traditional enforcement process because they are considered to be violations that potentially impede or impact the regulatory process. The inspectors reviewed Section 6.1.d.3 of the NRC Enforcement Policy and determined this violation was Severity Level IV because the licensees failure to update the USAR as required by 10 CFR 50.71(e) had not yet resulted in any unacceptable change to the facility or procedures. No cross cutting aspect was assigned because traditional enforcement violations are not assessed for cross cutting aspects. |
| 05000482/FIN-2005008-03 | 2005Q4 | Wolf Creek | Failure to Ensure Redundant Safe Shutdown Systems Located in the Same Fire Area Are Free of Fire Damage | The team identified a noncited violation of License Condition 2.C.(5), Fire Protection (Section 9.5.1, SER; Section 9.5.1.8, SSER #5), for failure to ensure that redundant trains of safe shutdown systems in the same fire area were free of fire damage. The licensee credited manual actions to mitigate the effects of fire damage in lieu of providing the physical protection required by 10 CFR Part 50, Appendix R, Section III.G.2 SNUPPS FSAR Appendix 9.5E provided the design comparison between the plants fire protection program and 10 CFR Part 50, Appendix R. The comparison to Section III.G, Fire Protection of Safe Shutdown Capability, states, Redundant trains of systems required to achieve and maintain hot standby are separated by 3-hour-rated fire barriers, or the equivalent provided by III.G.2, or else a diverse means of providing the safe shutdown capability exists that is unaffected by the fire. Wolf Creek has interpreted diverse means as by any reasonable means including local valve and breaker operations as long as they are within the scope of normal operator duties. The team disagrees with this interpretation. The NRC staff does not recognize the use of manual actions as meeting the technical requirements of Appendix R, Section III.G.2. The components being operated are identified as required for operation of safe shutdown systems or are subject to potential spurious operation impacting the shutdown. The local manual actions are being performed because of fire damage to electrical cables related to those components and are meant to compensate for damage or maloperation of safe shutdown equipment caused by fire This finding is greater than minor because it impacted the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to external events (such as fire) to prevent undesirable consequences (i.e., core damage). The team found that the manual operator actions implemented to mitigate the effects of fire damage were reasonable (as defined in Enclosure 2 of NRC Inspection Procedure 71111.05T, Fire Protection (Triennial)), and could be performed within the analyzed time limits. Therefore, in accordance with Enclosure 2 of NRC Inspection Procedure 71111.05T, the finding was determined to be of very low safety significance (Green), and the significance determination process was not entered. |
| 05000482/FIN-2008006-01 | 2008Q1 | Wolf Creek | Twenty-One Examples of Failure to Follow Seismic Requirements of Scaffolding Procedure | The team identified a non-cited violation of 10 CFR Part 50 Appendix B Criterion V, in which 21 scaffolds in 10 plant areas that were in contact with or closer to plant equipment than procedure allowed. The procedure required engineering evaluations did not contain any technical bases as to the acceptability of as built scaffolds. Subsequent engineering evaluation of each of the incorrect scaffolding installations confirmed that the configurations did not challenge operability. The NRC identified previous concerns with the erection of scaffolds, yet the licensee failed to take action to correct this issue. The team evaluated the significance of this finding using Phase 1 of Inspection Manual Chapter 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations, and determined that the finding was of very low safety significance because the issue resulted in 21 unevaluated scaffolds which are likely not to challenge the ability of the plant to safely shutdown after an earthquake. As such, under Phase 1 screening, the deficiency is not related to a qualification or design deficiency, it did not represent a loss of safety function for a train or system as defined in the plant specific risk-informed inspection notebook, and did not screen as risk significant for seismic external events, because the affected systems were considered degraded, but operable. Using these inputs, the performance deficiency screened to Green. The team determined that the finding had a human performance crosscutting aspect in the area associated with decision making because the licensee failed to adopt a requirement to demonstrate that the proposed action is safe in order to proceed rather than a requirement to demonstrate that it is unsafe in order to disapprove the action. Specifically, Wolf Creek Generating Station did not conduct any review of engineering decisions to verify the validity of the underlying assumption that equipment and scaffolding could be in contact or closer than the established limit (H.1(b)) (Section 40A2.e(1)) |
| 05000482/FIN-2008006-02 | 2008Q1 | Wolf Creek | Failure to Take Corrective Action For Missed Compensatory Measures | The team identified a finding because the licensee failed to take timely corrective actions to address a previously identified NRC finding. Finding 2007002-04 was issued because the licensee had failed to establish compensatory actions in response to the failure of all main annunciator board alarms. Failure to have compensatory measures inhibited the licensee in their efforts to determine the cause of the alarm failures. Corrective actions repaired the equipment that caused of the annunciator failure, but were unrelated to the failure to follow procedures and take compensatory measures. The team determined that this was a performance deficiency because the licensee had committed to take corrective actions in response to the previous non-cited violation but failed to do so in a timely manner. The inspectors determined that this violation was greater than minor because it met the intent of Manual Chapter 0612, Appendix E, Example 4.a., in that, there were several examples of the licensee failing to take corrective actions in response to NRC identified non-cited violations and findings, indicating that the licensee routinely failed to perform engineering evaluations on similar issues. The inspectors performed a Phase I Significance Determination Process evaluation and determined that the violation was screened as being very low safety significance, Green, because all of the answers to the Phase I Worksheet Mitigating Systems Column were no. The team also determined that this finding has crosscutting aspects in the problem identification and resolution area associated with the corrective action program in that the licensee failed to implement timely or effective corrective actions (P.1(d) (Section 40A2.e (2)). |
| 05000482/FIN-2008006-03 | 2008Q1 | Wolf Creek | Failure to Take Corrective Actions For Missed Operability Evaluation | The team identified a violation of 10 CFR Part 50 Appendix B Criterion XVI because the licensee failed to take timely corrective actions to address a previously identified non-cited violation. Non-cited Violation 2007003- 05 was issued because the licensee had failed to perform an operability evaluation following bearing replacement on the Train B emergency exhaust system fan. Corrective actions were not related to the missed performance of the operability evaluation, but the equipment failure. The team determined that this was a performance deficiency because the licensee had committed to take corrective actions in response to the previous non-cited violation but failed to do so in a timely manner. The inspectors determined that this violation was greater than minor because it met the intent of Manual Chapter 0612, Appendix E, Example 4.a. in that there were several examples of the licensee failing to take corrective actions in response to NRC identified non-cited violations and findings, indicating that The licensee routinely failed to perform engineering evaluations on similar issues. The inspectors performed a Phase I Significance Determination Process evaluation and determined that the violation was screened as being very low safety significance, Green, because all of the answers to the Phase I Worksheet Mitigating Systems Column were no. The team also determined that this finding has crosscutting aspects in the problem identification and resolution area associated with the corrective action program in that the licensee failed to implement timely or effective corrective actions. (P.1(d) (Section 40A2.e (3)) |
| 05000482/FIN-2008006-04 | 2008Q1 | Wolf Creek | Failure to Take Timely Corrective Action To Establish Monitoring Frequency of AFW Pump Governor Null Set Drift | The team identified a violation of 10 CFR Part 50 Appendix B Criterion XVI because the licensee failed to take timely corrective actions to address a previously identified finding. Finding 05000482/2008010 was issued because the licensee had failed to establish an acceptable monitoring frequency on their turbine driven auxiliary feedwater pump speed governor null-drift as recommended by a Part 21 report from Engine Systems, Inc. The corrective actions to establish the monitoring for the null-drift were not implemented. The team determined that this was a performance deficiency because the licensee had committed to take corrective actions in response to the previous non-cited violation but failed to do so in a timely manner. The team determined that this violation was greater than minor because it met the intent of Manual Chapter 0612, Appendix E, Example 4.a., in that, there were several examples of the licensee failing to take corrective actions in response to NRC identified non- cited violations and findings, indicating that The licensee routinely failed to perform engineering evaluations on similar issues. The team performed a Phase I Significance Determination Process evaluation and determined that the violation was screened as being very low safety significance, Green, because all of the answers to the Phase I Worksheet Mitigating Systems Column were no. The team also determined that this finding has crosscutting aspects in the problem identification and resolution area associated with the corrective action program in that the licensee failed to implement timely or effective corrective actions (P.1(d) (Section 40A2.e (4)) |
| 05000482/FIN-2008006-05 | 2008Q1 | Wolf Creek | Failure to Take Timely Corrective Action to Correct Annunciator Feed Configuration Deficiencies. | The team identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, regarding the failure to identify and correct conditions adverse to quality associated with non-cited violation 2006-004-02 documented in Inspection Report 2006-004. Specifically, the licensee did not address in the apparent cause evaluation and corrective actions the failure to follow procedures for inspecting the transmitters resulting in an inadequate inspection of installed Barton pressure transmitters for known potential manufacturing defects which resulted in a previous violation of Administrative Procedure (AP) 28-011, Resolving Deficiencies Impacting SSCs, Revision 1. The licensee inappropriately credited transmitter inspections that occurred several years prior to receipt of the vendor recommendation as sufficient to resolve this issue. This finding was more than minor because it could reasonably be viewed a precursor to a significant event and affected the equipment performance attribute of the mitigating systems cornerstone and the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events. Using Manual Chapter 0609, Significance Determination Process, Phase 1 worksheets, the inspectors determined that the finding is of very low significance because it did not represent an actual loss of a safety function or operability and was not potentially risk significant due to external events. The inspectors also determined that this finding has crosscutting aspects in the problem identification and resolution area associated with the corrective action program in that the licensee failed to identify the issue completely and thoroughly evaluate the problem such that the problem was resolved (P.1(a), P.1(c) (Section 40A2.e (5) |
| 05000482/FIN-2008006-06 | 2008Q1 | Wolf Creek | Failure to Take Timely Corrective Action to Correct Barton Transmitter Defects | Green. The team identified a finding for failure to implement corrective action for abandoned in place annunciator feed wiring deficiencies. Condition Report 2005-003275 was initiated because Cables ST-009 and ST-019 were field-spliced together to prevent electrical shocks such that the system configuration did not match the system drawing. Work Order 07-292004-000 was initiated to correct this condition but was closed as unworkable. Condition Report 2005-003275 was closed to this closed work order even though the condition was not corrected, leaving the system in a condition not reflected in drawings or design documents. This configuration could result in further shocks, and further configuration control issues. The main annunciator system and its feeds are not safety-related, and therefore this performance deficiency is not a violation of NRC requirements. The failure to implement corrective actions for an identified configuration control issue is a performance deficiency. This item affects the mitigating systems cornerstone. The team determined that this violation was greater than minor because it met the intent of Manual Chapter 0612, Appendix E, Example 4.a. in that there were several examples of the licensee failing to take corrective actions in response to findings, indicating that The licensee routinely failed to perform engineering evaluations on similar issues. The team performed a Phase I Significance Determination Process evaluation and determined that the violation was screened as being very low safety significance, Green, because all of the answers to the Phase I Worksheet Mitigating Systems Column were no. The team also determined that this finding has crosscutting aspects in the problem identification and resolution area associated with the corrective action program in that the licensee failed to implement timely or effective corrective actions. (P.1(d) (Section 40A2.e (6)) |
| 05000483/FIN-2008006-01 | 2008Q1 | Callaway | Nonconservative Technical Specifications for Battery INTER-CELL Connection Resistance | The team identified a Green noncited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, because the licensee failed to ensure that Technical Specification Surveillance Requirements for the NK11 and NK14 safety-related batteries established limits that met the design requirements. Specifically, until questioned by the team the licensee failed to determine the required design value needed to assure plant safety as requested in Callaway Action Request 200706561. The licensee determined that 69 micro-ohms should be the actual allowed inter-cell voltage limit to meet the design requirements versus an allowed Technical Specification limit of 150 micro-ohms. The performance deficiency associated with this finding involved the failure to ensure that the NK11 and NK14 safety-related batteries would remain operable if all the inter-cell connections measured 150 micro-ohms as allowed by Technical Specification Surveillance Requirements 3.8.4.2 and 3.8.4.5. This finding was greater than minor because it was associated with the Mitigating Systems cornerstone attribute of maintenance and testing and affects the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Manual Chapter 0609.04, \\\\\\\"Phase 1 Initial Screening and Characterization of Findings,\\\\\\\" the finding was determined to have very low safety significance because it was a design deficiency confirmed not to result in loss of operability. The finding had a cross-cutting aspect in the area of problem identification and resolution associated with operating experience because the licensee failed to evaluate in a timely manner relevant internal and external operating experience P.2(a) (Section 4OA2.e) |
| 05000483/FIN-2008006-02 | 2008Q1 | Callaway | Licensee-Identified Violation | Technical Specification 5.4.1.d requires that AmerenUE maintain a fire protection program. Procedure APA-ZZ-0071, Control of Impairments of Fire Protection Systems and Components, requires personnel to maintain the integrity of plant fire doors. Contrary to this, security officers identified during routine tours on March 6, March 20, July 18, and July 31, 2007, which personnel failed to maintain the integrity of Fire Door 15031. This licensee documented these deficiencies in Callaway Action Requests 200702037, 200702596, 200706810, and 200707100, respectively. This finding is of very low safety significance because the exposed fire area contained no potential damage targets that are unique from those in the exposing fire are |
| 05000528/FIN-2004006-02 | 2004Q2 | Palo Verde | Failure to Provide an Evaluation of a Change to the Facility as Described in the UFSAR, Under 10 CFR 50.59 Requirements | The team identified a Severity Level IV violation of 10 CFR 50.59 requirements for failing to evaluate a modification to spent fuel storage in the spent fuel pools. The team reviewed CRDR 2524176, regarding the lack of a criticality analysis to support the use of rod capture tubes, which hold individual harvested fuel pins, in the spent fuel rack. The team reviewed the licensee's process of storing individual fuel pins, removed from a parent fuel assembly, and placed in rod capture tubes to be located in guide tubes of another host assembly. This resulted in a component that had nuclear fuel pins, of varying enrichment and depletion, stored as a regular fuel assembly in the spent fuel pools. The team noted that Section 9.1 of the UFSAR specifically described the storage of spent fuel in regions based upon fuel assembly initial enrichment, actual burnup, and actual decay time. The UFSAR does not describe the storage of individual pins in these regions. The licensee previously interpreted this as meaning the UFSAR did not prohibit such storage, and would not require consideration of enrichment, burnup, and decay of individual pins. The licensee failed to provide an evaluation of a change to the facility as described in the UFSAR, under 10 CFR 50.59 requirements. The licensee subsequently performed an evaluation of the criticality under station procedure 72DP-9NF01, "Control of SNM Transfer and Inventory," which was found acceptable The issue was determined to be more than minor, through Inspection Manual Chapter 0612, Appendix B, in that it affected the barrier integrity cornerstone attribute of human performance, and could have represented a more significant issue if left uncorrected. In accordance with the NRC Enforcement Manual, violations of 10 CFR 50.59 are not processed through the significance determination process. Therefore, this issue was considered applicable to traditional enforcement. Although the significance determination process is not designed to assess significance of violations that potentially impact or impede the regulatory process, the result of a 10 CFR 50.59 violation can be assessed significance through the significance determination process. The team leader and the Region IV senior reactor analyst discussed the significance of this finding. An SDP Phase 1 screening was performed and the finding was determined to have very low safety significance because there was no actual loss of the barrier integrity function. The licensee entered this issue into its corrective action program as CRDR 2711241. |
| 05000528/FIN-2006011-03 | 2006Q3 | Palo Verde | 10 CFR 50.59 Reviews not performed or Inadequate for multiple changes to spray pond chemistry control procedure | A noncited violation of 10 CFR 50.59 was identified for making nine revisions to Procedure 74DP-9CY04, System Chemistry Specification, a procedure described in the Updated Final Safety Analysis Report between 1998 and 2004. Specifically, the licensee failed to perform evaluations for Revisions 3, 6, 8, 10, 12, 24, 28, 32, and 36 and performed inadequate evaluations for Revisions 10 and 36, to assess the potential impact of the changes on the safety-related components in the spray pond system. Each of these changes revised spray pond chemistry parameter limits which were subsequently determined to have contributed to heat exchanger fouling. Failure to adequately evaluate the impact of changes to the Chemistry Control Program was a performance deficiency. Because this violation had the potential to impact the NRC?s regulatory function, and because the associated significance was determined to be Green using Phase 3 of the significance determination process, this violation is being treated as a Severity Level IV violation. This issue was entered into the Corrective Action Program under CRDR 2902498. Because this violation was of very low safety significance and has been entered into the corrective action program, it is being treated as a noncited violation consistent with Section VI.A of the Enforcement Policy: NCV 05000528; 05000529; 05000530/2006011-03, 50.59 Reviews Not Performed or Inadequate for Multiple Changes to Spray Pond Chemistry Control Procedure. |