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05000254/FIN-2018010-0130 September 2018 23:59:59Quad CitiesMinor ViolationOn March 13, 2013, the licensee initiated AR 1487225 to document and evaluate an installed weld nonconformance that attached core spray keep fill line 114342LX to pipe support M983FH1. The licensees immediate evaluation of the nonconforming weld documented that the pipe support would perform its function of restraining the pipe for all loading conditions. Although the inspectors concluded the immediate evaluation provided a reasonable expectation the pipe support would perform its function of restraining the pipe, the inspectors noted the licensee did not provide a more detailed evaluation of the nonconformance using acceptance guidance per procedure OPAA108115, Operability Determinations (CM-1). As a result of the inspectors inquiry, the licensee initiated AR 417429, performed a more detailed operability evaluation in EC 625648, and concluded both the piping and pipe support would be able to meet design allowable stress limits with the nonconforming weld configuration. The inspectors reviewed the current design calculation for pipe support M983FH1, analysis 27.0200.1053.019.031 and performed a field walkdown of the installed piping and pipe support configuration for core spray keep fill line 114342LX to verify the adequacy of information provided used in EC 625648. In addition, licensee procedure OPAA108115 also required corrective action at the next opportunity, normally the next refueling outage, with a provision for deferral with proper documented justification. As a result of inspector inquiry regarding the timeliness of the corrective action, the licensee initiated AR 4177210 which documented the nonconformance repair was deferred from Q1R23 (March 2015) and Q1R24 (March 2017) without documented justification. The licensee plans to repair the nonconforming weld in the upcoming Q1R25 (March 2019) outage. The inspectors determined that this is a minor violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, related to the licensees evaluation and timeliness of corrective action for a safety-related pipe support nonconformance. Screening: The inspectors used Inspection Manual Chapter 0612, Appendix E, Examples of Minor Issues, issued August 11, 2009 and determined that timeliness of corrective action and the lack of a detailed operability evaluation were minor issues. Specifically, the inspectors compared the weld nonconformance to a calculation error in Example 3a of Appendix E and concluded the issue was minor because licensee EC 625648 provided reasonable justification the nonconforming weld configuration will meet design allowable stress for all loading conditions without modification. Violation: This failure to comply with 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
05000336/FIN-2018011-0130 September 2018 23:59:59MillstoneReviews of Incoming Industry Operation Experience Not CompletedThe inspectors identified that Millstone could not demonstrate that incoming industry operational experience reports (ICES) since 2015 had been properly reviewed for applicability to Millstone and for those items that were applicable, were evaluated and corrective actions developed as necessary as required by program guidance. A population of over 1600 ICES reports were identified where it could not be determined if required reviews were complete. Because there are parallel processes which may have reviewed these items, additional review is necessary to determine whether this issue represents a performance deficiency that is of more than minor significance. Therefore, this item is characterized as an unresolved item (URI). The purpose of the operational experience program is to identify conditions adverse to quality (CAQs) found at other plants, evaluate whether the concern is applicable to either Millstone unit, and evaluate and develop corrective actions for those CAQs when necessary. The inspectors noted that a performance improvement report (PIR) is automatically created for the Dominion fleet whenever an OPEX report is received (regardless of its source). Once the corporate PIR is generated, each site is required to check a box that it was received and also disposition it. The PIR remains opened until each site has completed this action. Prior to 2015, the corporate Operating Experience Coordinator would perform an applicability review and assign the remaining items to the site for further evaluation. When the corporate organization was reorganized, the headquarters review of OPEX became mostly administrative and the individual sites were expected to fully disposition the report. Since 2015, more than 1600 OPEX records were discovered that required disposition for Millstone. These records were still open and no records exist to show whether reviews were completed. Therefore it is uncertain if all applicable ICES reports were reviewed. Planned Closure Actions: The NRC will conduct a problem identification and resolution annual sample using NRC IP 71152 once Dominion has notified the NRC that they have completed their review of the 1600 ICES reports. Licensee Actions: Dominion wrote Condition Report (CR) 1105042 to capture the issue, conducted an investigation, and developed a plan to review the 1600 ICES reports which have no documented reviews. Dominion anticipates this review will be completed by the end of the first quarter of 2019.Corrective Action Reference: CR 1105042NRC Tracking Number: 05000336 & 05000423/2018-011-01
05000263/FIN-2018012-0130 September 2018 23:59:59MonticelloInboard Main Steam Isolation Valve Closure Time Test Acceptance Criteria Did Not Account for the Design Basis Accident Containment Back Pressure and Pneumatic Supply Operating PressureThe inspectors identified a Green finding and an associated NCV of Title 10 of the Code of Federal Regulations(CFR), Part 50, Appendix B, Criterion XI, Test Control, for the failure to assure that applicable requirements and acceptance limits contained in the inboard main steam isolation valve (MSIV) design documents were incorporated into their test procedure. Specifically, the inboard MSIV closure time acceptance criteria contained in Functional Test Procedure 0255-07-IA-2, Main Steam Isolation Valve Functional Checks Test, did not account for the elevated containment pressure and the expected lower pneumatic supply pressure expected during design basis accidents.
05000336/FIN-2018403-0130 September 2018 23:59:59MillstoneSecurity
05000263/FIN-2018012-0230 September 2018 23:59:59MonticelloFailure to Implement Adequate Freeze Protection Monitoring for Condensate Storage Tank Instrumentation Piping in Response to Industry Operating ExperienceThe inspectors identified a Green finding and an associated NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to establish measures to ensure conditions adverse to quality are promptly identified and corrected. Specifically, the licensee failed to identify that monitoring of the CST instrument line heat tracing performed every 30 days was inadequate to assure the safety-related CST level instrumentation remained operable during extreme cold weather conditions
05000336/FIN-2018003-0130 September 2018 23:59:59MillstoneFailure to Assure that Safety-Related Service Water Piping Conformed to the Procurement DocumentsThe inspectors identified a Green finding and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion VII, Control of Purchased Material, Equipment, and Services, when the licensee failed to identify that a replacement service water pipe spool (JGD-1-25) was not in conformance with the American National Standards Institute (ANSI) B31.1 code, a condition of the purchase order, and was installed in the plant.
05000254/FIN-2018003-0130 September 2018 23:59:59Quad CitiesFailure to Maintain the Design Basis for Residual Heat Removal Torus Suction ValveThe inspectors identified a Green finding and associated Non-Cited Violation(NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 50, Appendix B, Criterion III, Design Control, when the licensee performed an in-field adjustment to the torque switch settings on RHR torus suction valve 110017C and failed to ensure measures were established to assure the valve could continue to meet its design basis requirements.
05000293/FIN-2018003-0130 September 2018 23:59:59PilgrimFailure to Identify an Adverse Condition Associated with Elevated Standby Gas Treatment System Accumulator LeakageThe inspectors identified a Green non-cited violation (NCV) of Technical Specifications 3.7.B.1.c because Entergy exceeded the TS allowed outage time for the standby gas treatment system (SBGT) when the station did not identify an adverse condition associated with elevated air accumulator leakage in the system.
05000254/FIN-2018010-0230 September 2018 23:59:59Quad CitiesMinor ViolationIn 2009, due to a control room envelope differential pressure test failure at another nuclear station, the licensee completed an engineering change to develop separate correction factors (uncertainty) for different test methods. The engineering change recommended procedure QCOS 575016, Control Room Envelope DP (Differential Pressure) Surveillance, be revised to perform additional testing using alternate test methods with reduced correction factors. However, the procedure was not revised. In January 2016, during the control room envelope differential pressure test, seven areas failed the acceptance criteria. The licensee utilized the engineering change and performed a temporary procedure change to use a different method with a reduced correction factor for testing. The test was successfully performed and acceptance criteria were met. After the test, the procedure reverted to the old method. A condition report was written regarding this issue and actions were assigned to perform repair of the control room boundary and determine if a more accurate instrument is needed. Although repairs were made to the control room boundary, the licensee has not yet determined if a more accurate instrument is needed. Also, the procedure was not revised to use the alternate methods. The inspectors determined this is a minor violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings for not having procedure appropriate to the circumstances. Screening: The inspectors determined this issue is not more than minor because the existing procedure is not incorrect but missing the steps the licensee could take when unsatisfactory results are obtained. Violation: This failure to comply with 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
05000254/FIN-2018003-0230 September 2018 23:59:59Quad CitiesFailure to Follow Procedures for Forced Helium Dehydration of a Multipurpose CanisterThe inspectors identified a Severity Level IV NCV of 10 CFR 72.150 when the licensee failed to follow procedures for the setup of the MPC FHD system. Specifically, during the setup for processing MPCs during the 2018 ISFSI loading campaign, the licensee failed to follow procedure OUMW671200, MPC Processing FHD for BWRs, Revision 1, Attachment 9, Step 1.2.1,which connected inlet and outlet hosing between the FHD skid and FHD manifold.
05000249/FIN-2018003-0130 September 2018 23:59:59DresdenFailure to Follow Maintenance Procedures for Assembling Unit 3 HPCI Room Cooler FanA self-revealing, Green non-cited violation (NCV) of Technical Specification (TS) 5.4, Procedures, was identified for the licensees failure to follow maintenance procedures DMP 570004, LPCI and HPCI Room Cooler Maintenance, and DEP 570004, HPCI Room Cooler Fan Preventive Maintenance, when assembling the Unit 3 HPCI room fan. Specifically, on one occasion when maintenance was performed on the fan, technicians installed the cam locking collar in the opposite direction of the fan shaft rotation, and on the other occasion, technicians tensioned the fan belt to the wrong value and misadjusted the alignment of the shaft sheave. Over time, this improper maintenance caused the inboard and outboard fan bearings to wear on the shaft, causing increased vibrations, and eventually leading to HPCI being declared inoperable to emergently work on the fan
05000336/FIN-2018010-0130 June 2018 23:59:59MillstoneOver-Duty Breakers on Safety-Related Buses on Unit 2The team identified a finding of very low safety significance (Green) and an associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion III, Design Control. Specifically, Dominion incorrectly concluded that the 480V safety-related breakers were conforming to the plants licensing basis following their identification that the calculated short circuit fault current exceeded the breaker rating. Dominions evaluation failed to take into consideration that non-class 1E loads fed from safety-related buses must be isolated from the class 1E system by fully qualified safety-related isolation devices (breakers). Dominions design basis requires that a circuit fault on the non-class 1E side of the isolation device shall not cause the loss of the associated safety-related system
05000293/FIN-2018002-0230 June 2018 23:59:59PilgrimLoss of Secondary Containment Integrity due to Simultaneously Opened Airlock DoorsA self-revealed Green finding was identified when personnel did not implement a procedure requiring the closure and verification of doors credited with specific design functions. Procedure 1.3.135, Control of Doors, requires station personnel to ensure closing and latching of doors. Failure to meet this requirement caused the loss of secondary containment integrity and unplanned entry into Technical Specification (TS) condition 3.7.C.1.
05000336/FIN-2018010-0430 June 2018 23:59:59MillstoneFlood Seals Not Installed in Unit 2 A EDG and Auxiliary Building PenetrationsThe team identified a finding of very low safety significance (Green) and associated NCV of 10 CFR Part 50, Appendix B, Criterion XIV, Corrective Actions. Dominion identified a condition adverse to quality but did not correct the condition. Specifically, Dominion performed evaluations and walk downs in 2012 and 2016 to validate that all necessary flood seals for design basis and beyond design basis flood events had been properly installed. Dominion determined that they could not verify 50 wall penetrations had seals installed and entered the deficiency into the corrective action program. The team noted that an electrical conduit that passed through a Unit 2 A emergency diesel generator (EDG) building exterior wall, located below the design basis flood height, was one of the penetrations in question. During the inspection, following NRC questions, Dominion removed the electrical conduit cover plate and confirmed that a seal was not installed.
05000293/FIN-2018410-0130 June 2018 23:59:59PilgrimSecurity
05000336/FIN-2018410-0130 June 2018 23:59:59MillstoneSecurity
05000336/FIN-2018010-0330 June 2018 23:59:59MillstoneFailure to Correct Part 21 Power Supply DefectsThe team identified a finding of very low safety significance (Green) and associated NCV of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings. Specifically, Dominion did not accomplish repairs to safety-related power supplies in accordance with instructions and procedures. The team identified that actions taken by Dominion to address Part 21 Report #48863, Foxboro Power Supply Potential Failures due to Defective Tie Wraps and Holder, were performed without procedure or engineering evaluations and the work activities performed were not documented. Specifically, instrumentation and control technicians altered the safety-related power supplies without approved design documents, plant procedures, or work orders, and records of the completed activities were not available
05000293/FIN-2018002-0330 June 2018 23:59:59Pilgrim480V Bus B6 Auto Transfer Function Degraded Due to Time Delay Relay FailureThe inspectors identified a Severity Level IV NCV of TS 3.5.A.2 because a component of the low pressure coolant injection system was inoperable between May 12, 2015, and May 3, 2017, during which time, on occasions, core spray systems were also not operable. Specifically, a relay, used to transfer the power feed for the low pressure coolant injection valves to the backup source in the event of a degraded voltage condition, failed during testing. As a result, under certain conditions, the transfer would not have automatically occurred. This condition existed through the operating cycle, during which time the core spray pumps were also inoperable when removed from service for scheduled maintenance.
05000254/FIN-2018002-0130 June 2018 23:59:59Quad CitiesFailure to Have a Procedure Appropriate to Circumstances for Degraded Voltage RelaysA finding of very low safety significance (Green) and a Non-Cited Violation of Title 10 of the Code of Federal Regulations (10 CFR) 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was self-revealed on April 16, 2018, for the licensees failure to establish a preventive maintenance procedure for the safety-related degraded voltage relays that was appropriate to the circumstances. Specifically, the licensee failed to ensure that the first-time functional test and calibration for relay 1274B241 (Procedure MAQC773524, Quad Cities NOAD Unit 2 Tech Spec Undervoltage Relay and Degraded Voltage Relay Calibration) was at an appropriate frequency to ensure that the relay would perform its Technical Specification function.
05000423/FIN-2018010-0230 June 2018 23:59:59MillstoneOver-Duty Breakers on Safety-Related Bus 34C on Unit 3The team identified a finding of very low safety significance (Green) and an associated NCV of 10 CFR Part 50, Appendix B, Criterion III, Design Control. Specifically, Dominion did not adequately evaluate the results of the Unit 3 short circuit calculations for the 4.16 kV breakers. Dominions evaluation of the short circuit calculation results did not identify that the breakers were non-conforming to the licensing basis. The teams review of the calculation results found that the momentary and interrupting duty ratings of the 4kV safety-related breakers associated with Bus 34C were not within their short-circuit ratings when evaluated under design fault condition and, therefore, not in accordance with the licensing basis of the plant.
05000293/FIN-2018002-0130 June 2018 23:59:59PilgrimFailure to Properly Implement the Fatigue Management Program Work Hour Controls for Covered WorkersThe inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) 26.205(d). During the period December 2017 to April 2018, Entergy did not properly control the work hours of several workers who performed work covered under 10 CFR 26.4(a). Specifically, on eleven occasions, workers exceeded one of the following work hour limits: (1) 16 work hours in any 24-hour period; (2) 72 hours in any 7-day period; or (3) 54 hours per week average over a 6-week rolling time period.
05000423/FIN-2018010-0530 June 2018 23:59:59MillstoneInadequate Test Control of ECCS Valve InterlocksThe team identified a finding of very low safety significance (Green) involving an NCV of 10 CFR Part 50, Appendix B, Criterion XI, Test Control. Specifically, Dominion did not ensure that all testing required to demonstrate that emergency core cooling system (ECCS) valve interlock circuits would perform satisfactorily was being performed. The team determined that certain interlocks associated with ECCS valve 3SIL*MV8804A control circuit were not properly tested to demonstrate that the valve would not open if interlocks had not been met or would open, when required, with minimum interlock requirements met during design basis accidents.
05000265/FIN-2018001-0231 March 2018 23:59:59Quad CitiesFailure to Establish Design Standard for Unit 2 Residual Heat Removal Service Water PumpsThe inspectors identified a finding of very low safety significance (Green) and a Non-Cited Violation of 10 CFR 50, Appendix B, Criterion III, Design Control, for the licensees failure to ensure that the design bases standard and other requirements necessary to assure adequate quality were included in the design documents for the Unit 2 residual heat removal service water pumps. Consequently, the licensee failed to ensure the Unit 2 pumps were designed and constructed in accordance with the Standards of the Hydraulic Institute as identified in the Updated Final Safety Analysis Report.
05000263/FIN-2018001-0131 March 2018 23:59:59MonticelloFailure to Follow Procedure for Storage of Equipment Near Safety-Related EquipmentThe inspectors identified a finding of very low safety significance (Green) with an associated Non-Cited Violation (NCV) of Title 10 of the Code of Federal Regulations (CFR) Part 50, Appendix B Criterion V for the failure to accomplish activities affecting quality as prescribed by documented procedures. Specifically, the licensee failed to follow procedure 4 AWI04.02.01, Housekeeping for storage of items or equipment near safety-related equipment. On two separate occasions, the inspectors identified items being stored near safety-related equipment that did not comply with procedure requirements.
05000254/FIN-2018001-0331 March 2018 23:59:59Quad CitiesHalf Scram Due to Low Voltage on 24/48 Vdc SystemA finding of very low safety significance (Green) and a Non-Cited Violation of Technical Specification 5.4.1, Procedures, was self-revealed on January 11, 2018, for the licensees failure to perform an equalizing charge on the Unit 1B 24/48 Vdc battery prior to returning the 24/48 Vdc battery to a normal configuration following a test discharge, which was required by station procedures. The failure to follow procedures led to a low voltage condition and caused a Unit 1B channel half scram in the reactor protection system.
05000254/FIN-2018001-0431 March 2018 23:59:59Quad CitiesEnforcement Action: EA18021: EDG Non-conformance for Tornado Missiles (EGM 15002)On June 10, 2015, the NRC issued Regulatory Issue Summary (RIS) 201506, Tornado Missile Protection (ML15020A419), focusing on the requirements regarding tornado-generated missile protection and required compliance with the facility-specific licensing basis. The RIS also provided examples of noncompliance that had been identified through different mechanisms and referenced Enforcement Guidance Memorandum (EGM) 15002, Enforcement Discretion For Tornado Generated Missile Protection Non-Compliance, which was also issued on June 10, 2015, (ML15111A269) and revised on February 7, 2017 (ML16355A286). The EGM applies specifically to a structure, system, and component (SSC) that is determined to be inoperable for tornado-generated missile protection. The EGM stated that a bounding risk analysis performed for this issue concluded that tornado missile scenarios do not represent an immediate safety concern because their risk is within the LIC504, Integrated Risk-Informed Decision-Making Process for Emergent Issues, risk acceptance guidelines. In the case of Quad Cities Nuclear Generating Station, the EGM provided for enforcement discretion of up to 3 years from the original date of issuance of the EGM. The EGM allowed NRC staff to exercise this enforcement discretion only when a licensee implements, prior to the expiration of the time mandated by the limiting conditions for operation (LCO), initial compensatory measures that provided additional protection such that the likelihood of tornado missile effects were lessened. In addition, licensees were expected to follow these initial compensatory measures with more comprehensive compensatory measures within approximately 60 days of issue discovery. The comprehensive measures should remain in place until permanent repairs are completed or until the NRC dispositions the non-compliance in accordance with a method acceptable to the NRC such that discretion is no longer needed. In 1967, the NRC issued general design criterion to which the Quad Cities Nuclear Generating Station was evaluated against. Quad Cities Updated Final Safety Analysis Report (UFSAR), Section 3.1, Conformance with NRC General Design Criteria, discusses this criterion and its applicability to the sites design. Specifically, UFSAR Section 3.1.1.2, Criterion 2Performance Standards, states, those systems and components essential to the prevention of accidents or to mitigation of their consequences shall be designed, fabricated, and erected to performance standards that will enable the facility to withstand, without loss of the capability to protect the public, the additional forces that might be imposed by natural phenomena such as earthquakes, tornadoes, flooding conditions, winds, ice, and other local site effects. Section 3.1.1.2 further states that plant equipment which is important to safety is designed to permit safe plant operation and to accommodate all design basis accidents for all appropriate environmental phenomena at the site without loss of their capability. On March 1, 2018, during an engineering review of the Quad Cities, Units 1 and 2 facility design, the licensee identified a nonconforming condition with the aforementioned general design criterion. Specifically, the licensee identified that the three EDG systems intake stacks, exhaust stacks, fuel oil storage tank vent lines, and diesel oil day tank vent lines were inadequately protected against tornado missiles. As a result of the nonconforming condition, the licensee declared the Units 1, 2, and 12 EDG systems inoperable and entered the Technical Specifications (TS) LCO required action statements. The condition was reported to the NRC in Event Notice 53235 as an unanalyzed condition and a condition that could have prevented fulfillment of a safety function. Corrective Actions: The licensee documented the inoperability and functionality of the affected SSCs and the applicable TS LCO action statements in the CAP and in the control room operating log. The shift manager notified the NRC resident inspector of implementation of EGM 15002 and documented the implementation of the compensatory measures to establish the SSCs as operable but nonconforming prior to expiration of the required LCO action statements. The licensees initial (and final) compensatory measures included: verification that procedures and training for a tornado watch or warning were in place to provide additional instructions for operators to respond in the event of tornados or high winds, and a potential loss of SSCs vulnerable to the tornado missiles; confirmation of readiness of equipment and procedures dedicated to the Diverse and Flexible Coping Strategy (FLEX); verification that training was up to date for individuals responsible for implementing preparation and emergency response procedures; establishment of a heightened level of station awareness and preparedness relative to identifying tornado missile vulnerabilities; and revision to procedure QCOA 001010, Tornado Watch-Warning, Severe Thunderstorm Warning, or Severe Winds, to include guidance for unobstructing and/or repairing crimped diesel fuel oil tank vent lines. Corrective Action References: IR 1281009: Tornado Missile Protection Unresolved Item and IR 4110003: EDG Non-Conformance for Tornado Missiles Enforcement: Violation: The enforcement discretion was applied to the required shutdown actions of the following TS LCOs for both units: TS 3.0.3: General Shutdown LCO (cascading or by reference from other LCOs); and TS 3.8.1: AC SourcesOperating. Severity/Significance: The subject of this enforcement discretion, associated with tornado missile protection deficiencies, was determined to be less than red (i.e., high safety significance) based on a generic and bounding risk evaluation performed by the NRC in support of the resolution of tornado-generated missile non-compliances. The bounding risk evaluation is discussed in Enforcement Guidance Memorandum 15002, Revision 1, Enforcement Discretion for Tornado-Generated Missile Protection Non-Compliance, and can be found in ADAMS Accession No. ML16355A286. Basis for Discretion: The NRC exercised enforcement discretion in accordance with Section 2.3.9 of the Enforcement Policy and EGM 15002 because the licensee initiated initial compensatory measures that provided additional protection such that the likelihood of tornado missile effects were lessened. The licensee reviewed their initial compensatory measures to determine if more comprehensive compensatory measures were warranted. Upon their review, the licensee concluded that their initial compensatory measures were sufficient to satisfy both the short-term and long-term actions required by the EGM and therefore no additional actions were necessary for enforcement discretion. The disposition of this enforcement discretion closes URI05000254/201100904; 05000265/ 201100904: Tornado Missile Protection of the Emergency Diesel Generator Air Intake and Exhaust.
05000237/FIN-2018001-0131 March 2018 23:59:59DresdenEnforcement Action: EA18016: Unanalyzed Condition for Tornado MissilesOn June 10, 2015, the NRC issued Regulatory Issue Summary (RIS) 201506, Tornado Missile Protection (ML15020A419), focusing on the requirements regarding tornado generated missile protection and required compliance with the facility-specific licensing basis. The RIS also provided examples of noncompliance that had been identified through different mechanisms and referenced Enforcement Guidance Memorandum (EGM) 15002, Enforcement Discretion For Tornado Generated Missile Protection Non-Compliance, which was also issued on June 10, 2015 (ML15111A269) and revised on February 7, 2017 (ML16355A286). The discretion applied to Technical Specification (TS) limiting condition for operations (LCOs) that would require a reactor shutdown or mode change if the licensee could not meet the required actions within the TS completion time due to structures, system, and components (SSCs) declared inoperable because of tornado generated missile issues. The EGM stated that a bounding risk analysis performed for this issue concluded that tornado missile scenarios do not represent an immediate safety concern because their risk is within the LIC504, Integrated Risk-Informed Decision-Making Process for Emergent Issues, risk acceptance guidelines. In the case of Dresden Station, the EGM provided for enforcement discretion of up to three years from the original date of issuance of the EGM. The EGM allowed the licensee to re-establish operability when the licensee implemented, prior to the expiration of the time mandated by the affected LCOs, initial compensatory measures that provided additional protection such that the likelihood of tornado missile effects were lessened followed by more comprehensive compensatory measures within 60 days of issue discovery. The enforcement discretion was also conditional to the comprehensive measures remaining in place until permanent repairs are completed or until the NRC dispositions the non-compliance in accordance with a method acceptable to the NRC such that discretion is no longer needed. Section 3.5 of the Dresden Power Station Updated Final Safety Analysis Report (UFSAR) states in part that SSCs important to safety shall be adequately protected against missiles generated by various causes, including natural phenomena. On February 12, 2018, the licensee initiated IR 04103159, identifying a nonconforming condition of Section 3.5. Specifically, the vent lines for the U2, U2/3, and U3 emergency diesel generator (EDG) fuel oil tanks were not adequately protected from tornado-generated missiles. The licensee declared fuel oil tanks and their associated EDGs inoperable, and promptly implemented compensatory measures designed to reduce the likelihood of tornado-generated missile effects. The condition was reported to the NRC as Event Notice (EN) 53204 as an unanalyzed condition and potential loss of safety function. Corrective Action(s): The licensee documented the inoperability of the SSCs in the Corrective Action Program (CAP) and in the control room operating log. In addition, the affected TS LCO conditions applicable in the mode of operation at the time of discovery were documented in the control room operating log. The shift manager notified the NRC resident inspector of implementation of EGM 15002, and documented the implementation of the compensatory measures to establish the SSCs operable but nonconforming prior to expiration of the LCO required action. The licensees immediate compensatory measures included: Verifying that procedures were in place and training was current for performing actions in response to a tornado event. Verifying that procedures were in place and training was current to respond to a tornado watch, such as: (1) actions to be taken relating to tornado missile hazards; (2) potential restoration of equipment important to maintaining safe shutdown conditions that is unavailable at the time of the tornado watch; (3) warning and protection strategies for personnel; and (4) damage assessment and restorative actions for equipment that may be damaged during a tornado. Establishing a heightened level of station awareness and preparedness relative to identified tornado missile vulnerabilities. The licensees longer term compensatory measure was to modify DOA001002, Tornado Warning Severe Winds procedure to include actions for damage assessment and restorative actions for systems with a vulnerability to damage from tornado missiles. Corrective Action Reference: IR 04103159
05000249/FIN-2018012-0131 March 2018 23:59:59DresdenFailure to Ensure that Thermal Overload Relays are Sized Properly for Throttling Motor Operated ValvesThe team identified a finding having very-low significance and an associated Non-Cited Violation of Title 10 of the Code of Federal Regulations,Part 50, Appendix B, Criterion III, Design Control.Specifically, Dresden had not verified that thermal overload relays on Unit 3 safety-related motor operated valves 3-1301-3, 3-1501-21A & 21B, 3-1501-18A & 18B, 3-1501-38A & 38B, 3-3-2301-10, 3-1501-3A & 3B, were properly sized to support the design function of repetitive jogging and throttling the valves in response to design basis transients or accidents.
05000254/FIN-2018001-0131 March 2018 23:59:59Quad CitiesRepeat Use of Written Exams During Licensed Operator Requalification ExaminationsThe inspectors identified a Severity Level IV Non-Cited Violation of 10 CFR 55.49, Integrity of Examinations and Tests, due to the licensee engaging in an activity that compromised the integrity of an examination. Specifically, the Quad Cities 2015 Licensed Operator Requalification (LOR) written examinations were duplicated from the 2013 LOR written examinations, the 2017 LOR written examinations were duplicated from the 2015 LOR examinations, and four individuals were administered the same written examinations from the previous requalification examination cycle.
05000237/FIN-2017004-0131 December 2017 23:59:59DresdenFailure to Follow Procedure,Results in Non-Functional Fire DoorThe inspectors identified a finding of very-low safety significance and associated NCV of Technical Specification 5.4.1.c for the licensees failure to implement the established Fire Protection Program procedures which ensure Fire Barrier Integrity. Specifically, the licensee ran an electrical cable through the doorway of an automatically closing fire door. This was contrary to Procedure DFPP 417501, which requires in part that fire doors must not be blocked open by props or any other material in its closing path. The licensee took immediate actions to restore the fire door, by removing the obstruction and entered the issue into their Corrective Action Program (CAP). The inspectors determined that the performance deficiency was more-than-minor because it affected the Mitigating Systems cornerstone objective since the electrical cable could have prevented the fire door from performing its function. The finding was of very-low safety significance per Task 1.4.3A of IMC 0609, Appendix F. Specifically, the total combustible loading on both sides of the affected fire door was representative of a fire duration less than 1.5 hours. The inspectors determined the finding had a cross-cutting aspect in the area of Human Performance, associated with the Training component, because the licensee failed to provide training and ensure knowledge transfer to maintain a knowledgeable, technically competent workforce and instill nuclear safety values. Specifically, the licensee believed the performance deficiency was caused by the one of the new temporary contractors brought onto the site to work in support of the D2R25 refueling outage. (H.9)
05000423/FIN-2017004-0131 December 2017 23:59:59MillstoneFailure to Maintain RCS Pressure during Solid Plant CooldownA self-revealed NCV of very low safety significance (Green) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified wherein, on October 13, 2017, Dominion failed to accomplish an activity affecting quality, Plant Cooldown, in accordance with approved procedures. Specifically, during solid plant cooldown, over the course of 18 seconds, reactor coolant system (RCS) pressure increased from 350 psia to 472 psia, which exceeded the limit of 435 psia established by Attachment 1, RCS Cooldown Curves, of operating procedure OP 3208, Plant Cooldown, Revision 028. Dominion operations staff took prompt actions to restore RCS pressure within limits and completed a required engineering evaluation to determine the effect of the out of limit condition on the structural integrity of the RCS. Dominion entered this issue into the corrective action program (CAP) as condition report (CR) 1080842 and completed a root cause evaluation of the event. This finding was determined to be more than minor because it adversely affected the configuration control attribute of the Barrier Integrity cornerstone objective to provide reasonable assurance that physical design barriers (RCS) protect the public from radionuclide releases caused by accidents or events. The inspectors evaluated the finding using IMC 0609, Appendix G, Attachment 1, Shutdown Operations Significance Determination Process Phase 1 Initial Screening and Characterization of Findings, and determined the finding to be of very low safety significance (Green). The finding had a cross-cutting aspect in the area of Human Performance related to Work Management because the licensee did not implement an adequate process of planning, controlling, and executing work activities such that nuclear safety was the overriding priority. Specifically, Dominion failed to recognize the increased risk of isolating instrument air during solid plant operations. (H.5)
05000254/FIN-2017004-0131 December 2017 23:59:59Quad CitiesRepeat Use of Written Exams during Licensed Operator Requalification Examinationsa. Inspection ScopeThe following inspection activities were conducted during the weeks of October 9 and October 16, 2017, to assess: (1) the effectiveness and adequacy of the facility licensees implementation and maintenance of its systems approach to training (SAT) based LORT Program put into effect to satisfy the requirements of 10 CFR 55.59; (2) conformance with the requirements of 10 CFR 55.46 for use of a plant referenced simulator to conduct operator licensing examinations and for satisfying experience requirements; and (3) conformance with the operator license conditions specified in 10 CFR 55.53. The documents reviewed are listed in the Attachment to this report.Licensee Requalification Examinations (10 CFR 55.59(c); SAT Element 4 as Defined in 10 CFR 55.4): The inspectors reviewed the licensees program for development and administration of the LORT biennial written examination and annual operating tests to assess the licensees ability to develop and administer examinations that are acceptable for meeting the requirements of 10 CFR 55.59(a).- The inspectors conducted a detailed review of one biennial requalification written examination versions to assess content, level of difficulty, and quality of the written examination materials. (02.03)- The inspectors conducted a detailed review of ten job performance measures and four simulator scenarios to assess content, level of difficulty, and quality of the operating test materials.(02.04)- The inspectors observed the administration of the annual operating test to assess the licensees effectiveness in conducting the examination(s), including the conduct of pre-examination briefings, evaluations of individual operator and crew performance, and post-examination analysis. The inspectors evaluated the performance of one crew in parallel with the facility evaluators during two dynamic simulator scenarios, and evaluated various licensed crew members concurrently with facility evaluators during the administration of several job performance measures. (02.05)- The inspectors assessed the adequacy and effectiveness of the remedial training conducted since the last requalification examinations and the training planned for the current examination cycle to ensure that they addressed weaknesses in licensed operator or crew performance identified during training and plant operations. The inspectors reviewed remedial training procedures and individual remedial training plans. (02.07) Conformance with Examination Security Requirements (10 CFR 55.49): The inspectors conducted an assessment of the licensees processes related to examination physical security and integrity (e.g., predictability and bias) to verify compliance with 10 CFR 55.49, Integrity of Examinations and Tests. The inspectors observed the implementation of physical security controls (e.g., access restrictions and simulator I/O controls) and integrity measures (e.g., security agreements, sampling criteria, bank use, and test item repetition) throughout the inspection period. (02.06)Conformance with Operator License Conditions (10 CFR 55.53): The inspectors reviewed the facility licensee's program for maintaining active operator licenses and to assess compliance with 10 CFR 55.53(e) and (f). The inspectors reviewed the procedural guidance and the process for tracking on-shift hours for licensed operators, and which control room positions were granted watch-standing credit for maintaining active operator licenses. Additionally, medical records for seven licensed operators were reviewed for compliance with 10 CFR 55.53(I). (02.08)Conformance with Simulator Requirements Specified in 10 CFR 55.46: The inspectors assessed the adequacy of the licensees simulation facility (simulator) for use in operator licensing examinations and for satisfying experience requirements. The inspectors reviewed a sample of simulator performance test records (e.g., transient tests, malfunction tests, scenario based tests, post-event tests, steady state tests, and core performance tests), simulator discrepancies, and the process for ensuring continued assurance of simulator fidelity in accordance with 10 CFR 55.46. The inspectors reviewed and evaluated the discrepancy corrective action process to ensure that simulator fidelity was being maintained. Open simulator discrepancies were reviewed for importance relative to the impact on 10 CFR 55.45 and 55.59 operator actions as well as on nuclear and thermal hydraulic operating characteristics. (02.09)Problem Identification and Resolution (10 CFR 55.59(c); SAT Element 5 as Defined in 10 CFR 55.4): The inspectors assessed the licensees ability to identify, evaluate, and resolve problems associated with licensed operator performance (a measure of the effectiveness of its LORT Program and their ability to implement appropriate corrective actions to maintain its LORT Program up to date). The inspectors reviewed documents related to licensed operator performance issues (e.g., licensee condition/problem identification reports including documentation of plant events and review of industry operating experience from previous 2 years). The inspectors also sampled the licensees quality assurance oversight activities, including licensee training department self-assessment reports. (02.10)This inspection constituted one Biennial LOR Program inspection sample as defined in IP 71111.1105.b. FindingsIntroduction: While performing an assessment of the licensees processes related to examination physical security and integrity (e.g. predictability and bias) to verify compliance with 10 CFR 55.49, Integrity of Examinations and Tests, the inspectors 10 identified that Quad Cities 2015 LOR written examinations were duplicated from the 2013 LOR examinations, that 2017 LOR written examinations were duplicated from the 2015 LOR examinations, and that four individuals were administered the same written examinations from the previous exam cycle.Description: The inspectors identified that, with few exceptions, the licensee had duplicated or reused questions from the 2015 written exam when they created the 2017 written exam. The licensee created six LOR written exam versions (i.e., AF), one for each crew. For the 2017 biennial exam, the licensee essentially swapped exam versions from 2015 that were given to each crew (i.e., the 2015 Version A was given to crew B in 2017 and Version B was given to crew A, etc.). The inspectors noted that no crew received the same exam version in 2017 as they did in 2015. However, due to crew personnel adjustments/realignments, the inspectors requested the licensee to investigate if, and how many, operators were going to receive the same exam in 2017 as in 2015. The licensee identified that one reactor operator had already taken the same exam in 2017 that they were given in 2015. In addition, the licensee also identified that two additional licensed operators were scheduled to take the same exam they had taken in 2015, but they had not yet been given the exam due to the exam schedule. After discussing the issue and concern with the inspectors, the licensee decided to administer those two individuals different exam versions to which they had not been previously exposed. In addition, the inspectors inquired how long the particular set of exam versions had been reused and swapped among the crews (i.e., before 2015). The licensee reviewed biennial written exams in 2013 and 2011 and determined the exam content was different and stated, there was no predictable pattern in exam versions. After reviewing all of the 2013 exam versions, the inspectors identified that three versions were a mixture of questions between reused and new questions. For example, 2013 Version A was a mixture of questions of 2015 exam Versions C and D and twounique questions. The 2013 Version B was a mixture of 2015 Version C and D and seven unique questions. The 2013 Version F was a mixture of 2015 D and F and fiveunique questions. The three remaining versions from 2013 were replicated in 2015, but given to different crews. The inspectors requested the licensee determine the number of personnel that took the same exam in 2015 as in 2013, and the licensee identified three individuals who were given the same exam in 2013 and 2015 (two senior reactor operators and one reactor operator). The inspectors are considering this issue to be an unresolved item (URI) concerning whether the repeated use of a biennial written examination for sequential requalification programs (consecutive 24 month periods), and the resulting predictability induced to the examination process, constitutes a violation of 10 CFR 55.49, Integrity of Examinations and Tests. The inspectors have requested the licensee provide the written examinations in question to the inspectors for further review. The inspectors will review individual questions of the written examinations in order to determine if there were sufficient differences between the examinations to characterize the examinations as either different or similar. The results of the review will be used to determine if a violation of 10 CFR 55.49 requirements exists. (URI 05000254/201700401; 05000265/201700401: Repeat Use of Written Exams during Licensed Operator Requalification Examinations)
05000263/FIN-2017004-0131 December 2017 23:59:59MonticelloFailure to Maintain Radiation Exposure ALARAA finding of very low safety significance (Green) was self-revealed due to the licensee having unplanned and unintended occupational collective radiation dose because of deficiencies in the licensees radiological work planning and work control program. Specifically, the licensee failed to properly incorporate ALARA strategies, insights while planning, and executing work activities during the 1R28 refueling outage. The Reactor Water Cleanup (RWCU) Inlet Outboard Isolation Valve MO2398 was scheduled for replacement during the outage. The initial dose estimate for this activity was 4.5 person-rem. However, 13.776 actual person-rem of dose was received. This issue was caused by poor radiological planning and work execution of this task. The licensee entered this issue into their Corrective Action Program (CAP) item 1558234. The finding was more than minor because it was associated with the program and process attribute of the Occupation Radiation Safety Cornerstone. Additionally, this issue affected the cornerstone objective of ensuring the adequate protection of the workers health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. Additionally, the finding is very similar to IMC 0612, Appendix E, Examples of Minor Issues, dated August 11, 2009, Example 6.i. This example provides guidance that an issue is not minor if the actual collective dose exceeded 5 person-rem and exceeded the planned, intended dose by more than 50 percent. The inspectors determined that this finding was of very low safety significance (Green) because Monticello Nuclear Generating Plants current 3year rolling average collective is 64.637 person-rem (20142016). This is less than the 240 person-rem/unit referenced within IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, dated August 19, 2008. This finding had a cross-cutting aspect in the area of Human Performance, related to the cross-cutting aspect of Work Management, in that the outage plan did not adequately plan, control and execute work activities to ensure the RWCU Inlet Outboard Isolation Valve MO2398 replacement remained ALARA. (H.5)
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05000249/FIN-2017003-0130 September 2017 23:59:59DresdenGranted Notice of Enforcement Discretion 173001: LCO 3.1.7 Required Action B.1 per TS 3.1.7, Standby Liquid Control SystemInspection Scope The inspectors reviewed the licensees response to and assessment of a through- wall leak that developed on the Unit 3 SLC A pump discharge piping . Specifically, on September 12, 2017, during a system operational pressure test, licensee personnel observed a through- wall leak from the forged body of a 1.5 stainless steel pipe T in the Unit 3 SLC system. The affected component is a part of the ASME Code Class 2 boundary. Due to the piping being ASME Code Class 2, it was required to be immediately isolated in accordance with Technical Requirements Manual 3.4.a, Structural Integrity. Isolating this piping resulted in both trains of the Unit 3 SLC system becoming inoperable as the leak was unisolable from both pumps. With both trains inoperable, the licensee entered Limiting Condition for Operation ( LCO ) 3.1.7, Required Action B.1 which requires the restoration of at least one train of SLC within 8 hours. 15 The inspectors examined the sites actions to uncover the issue with the Unit 3 SLC system , their actions to address the issue once it was identified, and their compensatory actions associated with the receipt of the Notice of Enforcement Discretion ( NOED ). The inspectors also reviewed licensee documents to verify that information contained in the NOED request was accurate. Inspection activities included gathering additional information regarding the licensees bases for requesting the NOED; examining the sites decision -making process for the issue; reviewing the licensees condition evaluation; observing the licensees compensatory actions; and evaluating the licensees operability determination. To correct this issue and exit the NOED, the licensee completed replacement of the affected Unit 3 pipi ng and connections, satisfactorily tested the replaced components, and declared the Unit 3 SLC system operable. Documents reviewed are listed in the Attachment. This event follow up review constituted one sample as defined in IP 71153 05. b. Findings Introduction : The inspectors opened an unresolved item associated with a potential noncompliance with TS 3.1.7 Required Action B.1 that occurred on September 12, 2017. NOED 17 3001 was granted by the NRC staff agreeing not to enforce compliance with the TS completion time for an additional 35 hours. Description : On September 10, 2017, with the Unit 3 SLC system in standby operation, an equipment operator performing rounds noted sodium pentaborate crystallization build -up under piping insulation. The licensee removed the insulation from the potential leak location, and noted a dry sodium pentaborate stain on the back of a forged piping T on the 1.5 stainless steel discharge line of the A SLC pump. The licensee Shift Manager made an immediate operability determination of operable based on the dry nature of the stain and its location being on a forged body , and not at a connection or weld location. The licensees initial evaluation surmised the stain was historical in nature and was from an adjacent valve packing leak. In the event that further investigation of the stain indicated a through -wall leak, the licensee investigated American Society of Mechanical Engineers ( ASME ) code compliant permanent and temporary repair options, to include the construction of an Engineered Clamp. This method was eventually dismissed as supports required for the clamp would have been impractical based on system configuration. On September 12, 2017, the licensee cleaned the stain off of the piping T and performed a visual inspection for leakage with the system at full operating pressure. During this test, a leak was observed emanating from the body of the piping T. Due to the leak occur ring within the ASME Code Class 2 boundary, the licensee was required to isolate it in accordance with Technical Requirements Manual 3.4.a, Structural Integrity. Isolating this piping resulted in both trains of the Unit 3 SLC system becoming inoperable, and therefore the licensee entered LCO 3.1.7, Required Action B.1, with an 8 hour required action. With a through wall leak discovered and the plant in a short duration shutdown LCO, the licensee implemented a repair plan for a permanent piping replacement and requested a NOED from the NRC to complete repairs prior to entering Required Action C.1 and C.2, which require placing the Unit in Mode 3 (hot shutdown) and Mode 4 (cold shutdown) within 12 and 36 hours , respectively. The NRC granted a NOED for an additional 35 hours at 5:46 p.m. on September 12, 2017. Consistent with NRC policy, the NRC agreed not to enforce 16 compliance with the specific TSs in this instance, but will further review the cause(s) that created the apparent need for enforcement discretion to determine whether there is a performance deficiency, if the issue is more than minor, or if there is a violation of requirements. This issue will be tracked as an unresolved item. (Unresolved Item 05000249/2017003 01, Granted Notice of Enforcement Discretion 17 3001: LCO 3.1.7 Required Action B.1 per TS 3.1.7, Standby Liquid Control System )
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05000336/FIN-2017007-0130 September 2017 23:59:59MillstoneFailure to Replace Auxiliary Feedwater Solenoid Valves within the Required FrequencyThe inspection team identified a Green non-cited violation of Technical Specification 6.8.1.a, Procedures, because Dominion did not implement procedures as required by Regulatory Guide 1.33, Revision 2, Appendix A.9, Procedures for Performing Maintenance, to properly maintain the environmental qualification of safety-related auxiliary feedwater solenoid valves 2-FW-43AS and 2-FW-43BS. Specifically, Dominion failed to implement the recurring work event task and associated work order to ensure that these auxiliary feedwater solenoid valves were replaced prior to exceeding the qualified life of the solenoid coil and elastomer components. Dominion entered this issue into their corrective action program as condition report 1076005, planned replacement of the solenoid valves, and calculated an alternate ambient temperature for use in determining the qualified life of the solenoid valves. Dominion re-performed the qualified life calculation using this revised ambient temperature and extended the qualified life to support operability. The inspection team determined that this issue was more than minor because it adversely impacted the equipment performance attribute of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. This issue is also similar to more- than-minor examples 3.j and 3.k presented in IMC 0612, Appendix E, Examples of Minor Issues. Specifically, this performance deficiency resulted in a condition where there was reasonable doubt as to the operability and reliability of the solenoid valves for both auxiliary feedwater regulating valves, and thus, both trains of auxiliary feedwater. As such, Dominion needed to conduct additional engineering evaluation to extend the service life of the solenoid valves, thus justifying that the valves would continue to perform their safety function. The inspection team determined the finding to be of very low safety significance (Green) because the finding was a deficiency affecting the reliability of a mitigating structure, system, or component, and the structure, system, or component maintained its operability or functionality. The inspection team determined that no cross-cutting aspect was applicable because the finding was not indicative of current performance.
05000293/FIN-2017007-0130 September 2017 23:59:59PilgrimFailure to Incorporate the Correct Design Limit for the Condensate Storage Tank Water TemperatureThe team identified a finding of very low safety significance (Green) involving a non- cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion III, Design Control, in that Entergy did not translate the design basis limit for nil ductility transition (NDT) temperature into plant procedures. Specifically, Entergy specified in their procedures and tank heating setpoint calculation the low temperature limit for the two condensate storage tanks (CSTs) to be a non-conservative value, because it was based on the concern of CST freezing rather than the more limiting material service temperature of the downstream safety-related piping. In response, Entergy staff evaluated and confirmed current operability of the CST, and planned to evaluate and revise the affected procedures and tank heating setpoint calculation. This finding was more than minor because if left uncorrected, the performance deficiency would have the potential to lead to a more significant safety concern. Specifically, the minimum CST temperature value stated in procedures, based on an incorrect tank freezing assumption, could potentially result in not providing the full margin of protection against brittle fracture behavior in safety-related piping leading to the reactor vessel. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The SDP for Findings At-Power, the team determined the issue screened as having very low safety significance (Green) because it did not represent an actual loss of safety function of the system or train, did not result in the loss of one or more trains of non- technical specification (TS) equipment, and did not screen as potentially risk significant due to seismic, flooding, or severe weather. This finding was not assigned a cross-cutting aspect because the issue did not reflect current licensee performance.
05000263/FIN-2017007-0130 September 2017 23:59:59MonticelloInadequate Fire Barrier Inspection ProcedureThe inspectors identified a finding of very-low significance (Green) and an associated Non-Cited Violation of License Condition 2.C.4 of the Monticello Nuclear Generating Plant,Unit No. 1,Renewed Facility Operating License for implementing an alternative compensatory measure that was adverse to safety shutdown.Specifically, the licensee approved the installation of a temporary fuel oil pump, in lieu of a continuous fire watch, which reduced the defense in depth of the Fire Protection Program.The inspectors determined that the use of a temporary fuel oil pump in the event of afire, in lieu of a continuous fire watch, constituted an adverse change to the Fire Protection Program,was contrary to License Condition 2.C.4 and a performance deficiency. The performance deficiency was more-than-minor because it affected the Protection Against External Factors 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, the use of the alternative compensatory measure reduced the defense in depth of the Fire Protection Program by failing to provide compensatory measures to reduce the likelihood of occurrence of a fire and failing to provide prompt detection of a fire.In accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Initial Characterization of Findings, Table 2 the inspectors determined the finding affected the Initiating Events cornerstone. The finding degraded fire protection defense-in-depth strategies, and the inspectors determined, using Table 3, that it could be evaluated using Appendix F, Fire Protection Significance Determination Process.The inspectors determined that the finding represented a low degradation and was screened as having very-low safety significance (Green) in Task 1.3.1 of IMC 0609, Appendix F,because repair activities were in place that would have maintained safe shutdown(SSD)conditions and were reasonably achievable.This finding had a cross-cutting aspect in the Conservative Bias component of the Human Performance cross-cutting area. Specifically, the licensee implemented an alternate compensatory measure that only focused on the emergency diesel generator operability and hence, the post-SSD strategy of the plant without considering the defense in depth requirements of their Fire Protection Program to prevent, detect, and suppress a fire that could affect equipment needed for SSD of the plant.
05000336/FIN-2017003-0130 September 2017 23:59:59MillstoneInadequate Procedure Results in Inadvertent Lowering of Spent Fuel Pool LevelA self-revealing NCV of very low safe ty significance (Green) of Technical Specification (TS) 6.8, Procedures, was identified because Dominion did not adequately establish Operating Procedure (OP) 2305, Spent Fuel Pool Cooling and Purification System. Specifically, from initial issuance until June 20, 2017, the procedure did not direct operators to verify the primary demineralizer bypass valve was closed while lining up to fill the spent fuel pool from the coolant waste receiver tanks, resulting in an unexpected loss of spent fuel pool inventory. Dominion has documented this condition within their corrective action program (CAP) as condition report (CR) 1064323, revised procedure OP 2305, and performed an apparent cause evaluation. The inspectors determined that the finding was more than minor because it was associated with the procedure quality attribute of the Barrier Integrity cornerstone and adversely affected its objective to provide reasonable assurance that physical design barriers, such as fuel cladding, protect the public from radionuclide releases caused by accidents or events. Specifically, spent fuel pool level was inadvertently lowered when operators aligned the system in accordance with OP 2305, which resulted in a reduced net positive suction head for the spent fuel pool cooling pumps as indicated by control room alarm. The finding screened to be of very low safety significance (Green) because it did not result in a loss of spent fuel pool water inventory below the minimum analyzed level limit and did not cause the spent fuel pool temperature to exceed the maximum analyzed temperature limit. This finding has a cross-cutting aspect in the Human Performance cross-cutting area, Avoid Complacency because Dominion did not recognize and plan for the possibility of a latent deficiency in procedure OP 2305 when used while the primary demineralizers were bypassed. (H.12)
05000293/FIN-2017007-0230 September 2017 23:59:59PilgrimInadequate Design Verification of Emergency Diesel Generator Under- Frequency Alarm SetpointThe team identified a finding of very low safety significance (Green) involving an NCV of 10 CFR Part 50, Appendix B, Criterion III, Design Control, in that Entergy did not adequately verify that the emergency diesel generator (EDG) under-frequency alarm setpoint was in accordance with design basis requirements. Specifically, the EDG under- frequency alarm was set at a value less than the prescribed industry standard to protect equipment, and station procedures did not contain instructions to address the EDG under- frequency condition. In response, Entergy staff evaluated and confirmed current EDG operability and initiated actions to correct the under-frequency range in the alarm setpoint and to provide appropriate operator response guidance in operating procedures. 3 This finding was more than minor because it was associated with the design control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The SDP for Findings At-Power, the team determined that this finding was of very low safety significance (Green) because it was a design deficiency confirmed not to result in the loss of operability or functionality. The team determined that this finding had a cross-cutting aspect in the area of Human Performance, Avoid Complacency, because Entergy did not plan for the possibility of latent issues while processing a plant modification where the bases for EDG alarm functions were incorrect.
05000336/FIN-2017002-0130 June 2017 23:59:59MillstonePotential Untimely Corrective Action for Anchor Darling Double Disc Gate ValvesThe inspectors identified that Dominion has not implemented corrective actions to address potential substantial safety hazards associated with several safety significant valves at Millstone Unit 2 that was reported in a 10 CFR Part 21 notification letter dated February 25, 2013. Specifically, after establishing a corrective action plan, to date Dominion has not implemented actions to either evaluate or inspect susceptible valves. However, inspectors need to compare actions taken to Dominions CAP requirements and review industry recommendations to address the Part 21 letter to determine if this represents a performance deficiency or violation of NRC requirements. As a result, the NRC has opened an unresolved item (URI) related to this issue of concern. Description. In 2012, Browns Ferry Nuclear Plant Unit 1 experienced a failure of an isolation valve due to a failure of the valve stem to wedge anti-rotation wedge pin as noted in a 10 CFR Part 21 Notification Letter dated January 4, 2013. Subsequent analysis by Flowserve, owner of Anchor/Darling, determined the cause was a manufacturing defect, wherein the wedge pin installation torque was insufficient to meet the design needs of the valve. Flowserve further concluded that other valves of this type, Anchor Darling double disc gate valves in motor operated valve (MOV) applications with Limitorque or Rotork actuators, could be susceptible to similar failures. As documented in the associated 10 CFR Part 21 Notification Letter from Flowserve dated February 25, 2013, Millstone was susceptible to a potential substantial safety hazard due to this potential failure mechanism. Dominion captured this condition in CR504097 and determined that the following Millstone Unit 2 valves were susceptible: CS-4.1A, Containment Spray Header Isolation CS-4.1B, Containment Spray Header Isolation CS-13.1A, RWST Outlet Isolation CS-13.1B, RWST Outlet Isolation CS-16.1A, Containment Sump Outlet Header Isolation CS-16.1B, Containment Sump Outlet Header Isolation The Dominion fleet MOV Program owner accepted the action (CA284339) to establish a corrective action plan on November 21, 2014, approximately 21 months after 10 CFR Part 21 notification by Flowserve. The corrective action plan for the susceptible valves included valve performance monitoring consistent with current MOV program requirements as well as stem position monitoring during travel every cycle which would indicate potential degradation of the wedge pin. Ultimate resolution for each location incorporates valve disassembly, intrusive inspection, and re-torque of the stem/wedge connection to mitigate the notified potential substantial safety hazard. To date, Dominion has not performed stem position monitoring, contrary to their corrective action plan, thereby limiting their capacity to identify wedge pin degradation without assessment of the change. Furthermore, due to the invasive nature of the ultimate resolution as well as the safety functions of the susceptible locations, final corrective actions for each valve must be performed with the unit offline. Dominion initially established ultimate resolution at each location in spring of either 2016 or 2017 without alignment to an outage schedule or cycle plan. On February 16, 2016, because the 2016 valves would be worked during a refueling outage, the facilities safety review committee met, extending due dates until June 1, 2017. Immediately preceding the spring 2017 refueling outage, Dominion realigned ultimate resolution for the susceptible valves to the fall 2018 and spring 2020 refuel outages due to failure to receive parts required to complete contingency maintenance. Ultimately, from February 25, 2013, through the present, the inspectors identified that Dominion delayed implementation of corrective actions for multiple potential substantial safety hazards that was communicated in a 10 CFR Part 21 notification letter. However, inspectors need to compare actions taken to Dominions CAP requirements and review industry recommendations to address the Part 21 letter to determine if this represents a performance deficiency or violation of NRC requirements. (URI 05000336/2017002-01, Potential Untimely Corrective Action for Anchor Darling Double Disc Gate Valves)
05000293/FIN-2017002-0430 June 2017 23:59:59PilgrimImproper System Restoration Results in Suppression Pool InoperabilityA self-revealing Green NCV of TS 5.4.1.a, Procedures, was identified on March 31, 2017, when operators did not follow procedures and caused an inadvertent increase in the suppression pool water level. The inspectors determined that the operators did not restore the core spray system valve line-up as prescribed in Attachment 11 of Entergy Procedure 2.2.20, Core Spray, and the maintenance safety tag clearance sheet. Operator implementation of these documents is directed by Entergy Procedure EN-OP-102, Protective Caution Tagging, section 5.19(4)(b). As corrective actions, Entergy performed additional management oversight of control room operations and performed a root cause evaluation (RCE). This issue was entered into the CAP as CR-2017-2785. The performance deficiency is more than minor because it is associated with the equipment reliability attribute of the Mitigating Systems cornerstone objective and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the out of specification conditions on March 31, 2017, impacted suppression pool reliability because the suppression pool was not maintained within parameters required to ensure operability. Additionally, significant analysis was necessary to show the suppression pool and associated supports remained functional when TS requirements were not met. Using IMC 0609, Appendix A, Exhibit 2, issued June 19, 2012, The Significance Determination Process for Findings At-Power, the inspectors determined the finding was of very low safety significance (Green) because the finding did not affect the design or qualification of a mitigating structure, system, or component (SSC), the finding did not represent a loss of system and/or function, the finding did not represent an actual loss of a function of a single train for greater than the TS allowed outage time (AOT), and the finding did not represent an actual loss of a function of one or more non-TS trains of equipment. Specifically, the suppression pool, including downcomers and supports, remained functional following the influx of water. The finding has a cross-cutting aspect in the area of Human Performance - Procedure Adherence, because Entergy personnel did not follow processes, procedures, and work instructions. Specifically, Entergy personnel did not follow procedures and work instructions during the restoration of the core spray system. (H.8)
05000254/FIN-2017002-0230 June 2017 23:59:59Quad CitiesFailure to Ensure Two Low Pressure ECCS Systems Operable in MODE 4The inspectors identified a finding of very low safety significance and an associated non-cited violation of Technical Specification (TS) 3.0.1 on April 12, 2017,for the licensees failure to meet TS Limiting Condition for Operation (LCO) 3.5.2, Emergency Core Cooling Systems (ECCS)Shutdown. Specifically, on April 12, 2017, the licensee failed to ensure two low pressure ECCS subsystems were operable in Mode 4 in accordance with TS LCO 3.5.2 and failed to verify the LCO action conditions were met. Immediate corrective actions included restoring the 1A core spray pump to an operable status within 4 hours in order to comply with TS 3.5.2. This issue was entered into the licensees CAP as IR 3997127.The performance deficiency was determined to be more than minor, and a finding, because it impacted the Mitigating Systems Cornerstone attribute of Equipment Performance and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). The finding was screened using IMC 0609, Appendix G, Attachment 1, Shutdown Operations Significance Determination Process Phase 1 Initial Screening and Characterization of Findings, against the questions in Exhibit 3, Mitigating Systems Screening Questions. The inspectors answered No to all of the questions and determined the finding could be screened as very low safety significance. The inspectors determined this finding affected the cross-cutting aspect of Human Performance, in the aspect of Work Management, because the licensee failed to ensure proper controls were in place while performing multiple activities which rendered multiple low pressure ECCS systems inoperable. In addition, the licensee failed to identify and manage the risk associated with performing multiple evolutions concurrentlyso that TS LCO 3.5.2 would be met and the required actions taken as necessary (H.5).
05000263/FIN-2017002-0130 June 2017 23:59:59MonticelloLow Reactor Water Level During Shutdown of 11 Reactor Feedwater PumpA self-revealed finding of very-low safety significance and a Non-Cited Violationof Technical Specification 5.4.1.a occurred on April 15, 2017, due the licensees failure to establish, implement and maintain procedures regarding shutdown operations. Specifically, Operations Manual B.06.05-05 did not account for the state of the opposite train of feedwater when shutting down the 11 Reactor Feedwater Pump. Licensee use of the inadequate procedure placed equipment in a configuration where no condensate flow path to the reactor existed causing reactor water level to lower to a point where trip/isolation set-points were reached. This caused an unplanned Reactor Protection System (RPS) trip and Partial Group II Isolation. The licensee initiated Corrective Action Program (CAP) 1555785 to document the reactor water level transient, RPS trip and Partial Group II Isolation. Immediate corrective actions includedopening the 11 Reactor Feedwater Pump discharge valve to restore reactor water level allowing reset of the Group II isolation and RPS trip. Subsequent licensee actions included development of expectations via an Operations Memo and revision to Operations Manual B.06.0505 as well as Procedure 2204 and Procedure 2167 to ensure abnormal equipment lineups are addressed such that unexpected procedure interactions are avoided.The inspectors determined the failure to establish, implement and maintain procedures regarding shutdown operations as required by Technical Specification 5.4.1.a was a performance deficiency that required an evaluation. The inspectors assessed the significance of this finding using IMC 0609, Attachment 4, and IMC 0609, Appendix A, Exhibit 1, Section B, and determined a detailed risk evaluation was required because the finding caused a reactor trip and loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition (e.g., loss of feedwater). A Senior Reactor Analyst performed a detailed risk evaluation using bounding assumptions and the change in Core Damage Frequency was calculated to be 9E7/year (Green). The inspectors determined that the contributing cause that provided the most insight into the performance deficiency was associated with the cross-cutting area of Human Performance, Change Management aspect, because licensee leaders did not use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority.
05000293/FIN-2017002-0530 June 2017 23:59:59PilgrimDamper Failure Causes Loss of Secondary ContainmentA self-revealing Green NCV of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, and TS 3.7.C.2, Containment Systems Secondary Containment, was identified because Entergy did not establish an appropriate interval to overhaul the secondary containment isolation dampers. As a result, the refueling floor supply isolation dampers were operated beyond the recommended overhaul interval and subsequently failed. Entergys corrective actions included cleaning, lubricating, and post-work testing the failed refueling floor supply isolation dampers. This issue was entered into the CAP as CR 2017-0494. The performance deficiency is more than minor because it is associated with the SSC and barrier performance attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective of providing reasonable assurance that physical design barriers (containment) protect the public from radionuclide releases caused by accidents or events. Specifically, Entergys preventative maintenance (PM) for the refueling floor supply isolation dampers was inadequate to ensure the availability and reliability of SSCs required to maintain secondary containment operable. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 3 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, the inspectors determined that this finding was of very low safety significance (Green) because the performance deficiency only represented a degradation of the radiological barrier function provided by the reactor building and standby gas treatment system (SBGTS). The finding has a cross-cutting aspect in the area of Problem Identification and Resolution - Resolution, in that Entergy personnel did not take effective corrective actions to address issues in a timely manner. Specifically, in 2016, Entergy personnel identified there were deficiencies in the PM program with technical justifications for deferring PMs. Entergy reasonably had the opportunity to identify which PMs were not performed within recommended guidelines and make appropriate changes as needed. (P.3)