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| Start date | Site | Title | Description | |
|---|---|---|---|---|
| 05000333/FIN-2018412-01 | 30 September 2018 23:59:59 | FitzPatrick | Security | |
| 05000387/FIN-2018011-01 | 30 September 2018 23:59:59 | Susquehanna | Failure to conduct proper testing of 125 VDC molded case circuit breakers to confirm their design adequacy long-term | The inspectors identified a Green non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XI, Test Control. Specifically, Susquehanna has not established a program to adequately exercise and test safety-related 125VDC molded case circuit breakers (MCCBs) since initial plant operation. |
| 05000354/FIN-2018003-05 | 30 September 2018 23:59:59 | Hope Creek | Minor Violation | During the review of LER 05000354/2018-003-00 and -01, Feedwater Isolation Valve Leakage Exceeded Technical Specification Limit, the inspectors identified a condition prohibited by TS. Specifically, TS 3.6.1.2.d requires that Primary Containment Leakage rates shall be limited to a combined leakage rate of less than or equal to 10 gpm for all containment isolation valves which form the boundary for the long-term seal of the feedwater lines, when tested at 1.10 Pa (1.1 times the calculated peak containment internal pressure related to the design basis accident) or 55.7 psig. TS surveillance requirement (SR) 4.6.1.2.g states that these valves be tested at least once per 18 months. Contrary to this requirement, on April 18, 2018, during the TS required SR for LLRT of the F032B, PSEG was unable to achieve the required test pressure and could not determine a leakage rate.Screening: The inspectors evaluated the issue above in accordance with the guidance in the NRCs Enforcement Policy, IMC 0612, Appendix B, Issue Screening, and Appendix E, Examples of Minor Issues, and determined the issue was a minor violation because, although PSEG did not successfully complete the TS required SR because they could not attain the required test pressure, there were no actual safety consequences. Specifically, PSEGs technical evaluation (70200206-0085) estimated the leak rate through the F032B to be approximately 3 gpm, and determined that the potential leakage through the F032B would not have posed a challenge to its ability to establish and maintain the required feedwater seal for 30 days post-LOCA. Enforcement: PSEG has taken actions to restore compliance by repairing and successfully testing the valve, and revising their LLRT procedures to: 1) update administrative limits and actions that are required when limits are exceeded; and, 2) include specify the exact size and length of tubing required for the testing. This inability to comply with TS 3.6.1.2.d constituted a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy. |
| 05000277/FIN-2018410-01 | 30 September 2018 23:59:59 | Peach Bottom | Security | |
| 05000352/FIN-2018003-02 | 30 September 2018 23:59:59 | Limerick | Failure to Correct Adverse Environmental Conditions Impacting Low Pressure Coolant Injection Outboard Primary Containment Isolation Valve | A self-revealed Green NCV of 10 CFR Part 50, Appendix B, Criterion XVI was identified when Exelon failed to correct adverse environmental conditions affecting the Unit 1 LPCI outboard PCIV actuator that resulted in long term water intrusion, corrosion, and failure of the valve to stroke closed. |
| 05000324/FIN-2018411-01 | 30 September 2018 23:59:59 | Brunswick | Security | |
| 05000341/FIN-2018003-02 | 30 September 2018 23:59:59 | Fermi | Failure to Ensure Electrolytic Capacitors Installed in the Plant Did Not Have Expired Shelf Lives | A finding of very low safety significance with an associated non-cited violation of 10 CFR 50, Appendix B, Criterion VIII, Identification and Control of Materials, Parts, and Components was self-revealed when the reactor water cleanup system inlet flow square root converter failed, resulting in a failure of the reactor water cleanup (RWCU) differential flow instrument and loss of automatic isolation function of the RWCU isolation valves. Specifically, electrolytic capacitors were installed in the RWCU system logic that had expired shelf lives, resulting in failures of the automatic isolation function of the RWCU system. |
| 05000341/FIN-2018003-03 | 30 September 2018 23:59:59 | Fermi | Failure to Identify a Condition Adverse to Quality on Division 2 Residual Heat Removal Service Water Outlet Flow Control Valve | A finding of very low safety significance and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, and TS 3.7.1 Residual Heat Removal Service Water (RHRSW) System, were self-revealed for the licensees failure to identify a condition adverse to quality on the Division 2 RHRSW outlet flow control valve E1150F068B. Specifically, troubleshooting and the associated post maintenance testing failed to identify and correct a failed anti-rotation key which resulted in an inoperable Division 2 RHRSW system for longer than its TS 3.7.1 allowed outage time. |
| 05000298/FIN-2018003-02 | 30 September 2018 23:59:59 | Cooper | Failure to Perform Process Applicability Determination | The inspectors identified a Green, non-cited violation of Technical Specification 5.4.1.a, Procedures, for the licensees failure to follow Administrative Procedure 0.9, Tagout, Revision 88, for performing a monthly audit and Process Applicability Determination. Specifically, the inspectors noted that a clearance order on the safety-related residual heat removal service water booster pump room fan coil unit was hanging for greater than 90 days with no Process Applicability Determination performed, which resulted in the power switch for the fan coil unit being unintentionally tagged out of its normal configuration for almost 2 years |
| 05000352/FIN-2018010-01 | 30 September 2018 23:59:59 | Limerick | Minor Violation | During this inspection, the team reviewed the details and status of Exelons corrective actions. Relative to EDG voltage, the TSs specified a lower limit of 4160 Vac; however, Exelons existing analysis determined the lower EDG voltage limit should be 4235 Vac. Exelon determined that this higher voltage value was necessary in order to ensure full EDG operability and qualification when considering a specific criteria (voltage drop during the loading sequence) as per NRC Regulatory Guide 1.9, Application and Testing of Safety-Related Diesel Generators in Nuclear Power Plants. The team determined that there was not an operability concern because Exelon determined that, although the voltage drop during the starting of the largest electrical load was slightly below the Regulatory Guide 1.9 value, all required loads would, in fact, successfully start and run as designed when started at the 4160 Vac level. Further, the EDG voltage regulators are designed and calibrated to operate the EDGs at 4235 Vac. Notwithstanding, the team identified that the associated EDG surveillance procedures did not contain the higher, administrative limit of 4235 Vac as an acceptance criterion (4160 Vac was specified). The team reviewed this issue using Inspection Manual Chapter 0612, Appendix B, Issue Screening, and determined that the use of non-conservative acceptance criterion was a minor procedure violation because the EDGs were controlled and operated to maintain voltage at 4235 Vac (and 4160 Vac does not render the EDGs inoperable), and EDG reliability or availability were not adversely affected. Exelon entered this minor violation in their corrective action program as IR 4164579 to document and correct this deficiency. For EDG frequency, the TSs allowed an acceptance band (58.8 61.2 Hertz), which is a range typical of EDG transient loading conditions. However, as described in WCAP-17308-NP, and as determined by Exelon engineering staff, a more narrow band (59.9 60.2 Hertz) is the appropriate operating range for steady state EDG operation. Exelon has appropriately maintained the narrow band as the acceptance criteria in the associated EDG surveillance procedures (compensatory action until TSs are revised). However, during this inspection, the team identified that in 2016, Exelon had slightly widened the acceptable band a one-tenth hertz to 59.8 60.2 Hertz. Further review by the team identified that this change was not properly evaluated in accordance with Exelons procedure change process. In particular, the procedure change received a less rigorous review than a 10 CFR 50.59 screen would have provided; and the team concluded that this screen should have been performed. In response, Exelon evaluated past surveillance results and analyzed the lower frequency value of 59.8 Hertz, and determined there to be no adverse consequence at 59.8 Hertz. The team reviewed Exelons analysis and similarly concluded that there was no adverse safety impact. The team reviewed this issue using Inspection Manual Chapter 0612, Appendix B, Issue Screening, and determined that the improper procedure change was a minor procedure violation because there were no adverse consequences and EDG reliability or availability were not adversely affected. Exelon entered this minor violation in there corrective action program as IR 4160819 and IR 4161542 to document and correct this deficiency. |
| 05000352/FIN-2018003-01 | 30 September 2018 23:59:59 | Limerick | Failure to Assess and Manage Risk Associated with Fuel Oil Storage Tank Maintenance | An NRC-identified Green NCV of 10 CFR 50.65(a)(4) was identified when Exelon failed to assess and manage risk associated with fuel oil storage tank maintenance by not properly evaluating and establishing compensatory actions for maintaining availability of associated EDGs |
| 05000277/FIN-2018003-02 | 30 September 2018 23:59:59 | Peach Bottom | Inadequate Corrective Actions Result in the Failure of the E-3 EDG | The inspectors identified a self-revealing preliminary White finding associated with an apparent violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, because Exelon did not perform adequate corrective actions on the E-3 EDG scavenging air check valve assembly. Specifically, Exelon did not perform an adequate repair of an interference fit pin joint during maintenance activities in April 2017 and did not correct an oil leak on the check valve dashpot assembly identified in September 2017, which resulted in the E-3 EDG failure on June 13, 2018. |
| 05000277/FIN-2018003-01 | 30 September 2018 23:59:59 | Peach Bottom | HPCI System Exhaust Pressure Switches Exceeded Documented Qualified Life | The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion III, Design Control, because Exelon did not establish measures to ensure that environmental qualification requirements for qualified components were correctly translated into procedures and instructions. Specifically, the end-of-life replacement requirements for the Unit 2 HPCI exhaust pressure switches were not translated into maintenance procedures and instructions. As such, Exelon did not replace the switches prior to the end of their documented qualified life. |
| 05000354/FIN-2018003-02 | 30 September 2018 23:59:59 | Hope Creek | Inadequate Procedures for Restoration of the A Reactor Feed Pump Turbine Following Maintenance | A self-revealing Green finding (FIN) was identified for PSEGs inadequate procedures that controlled the restoration of the A reactor feedwater pump turbine (RFPT) trip instrumentation following system maintenance. Specifically, the pumps axial position instrumentation was not re-zeroed following a rotor replacement. As a result, on May 21, 2018, the A RFPT tripped while HCGS was operating at approximately 97 percent rated thermal power (RTP), which led to an unplanned automatic recirculation runback to approximately 70 percent of RTP. |
| 05000296/FIN-2018003-01 | 30 September 2018 23:59:59 | Browns Ferry | Main Steam Relief Valves Lift Settings Outside of Technical Specifications Required Setpoints | A self-revealed SL IV NCV of Technical Specification (TS) 3.4.3, Safety Relief Valves, was identified when the licensee discovered, through as found test results, that three of the thirteen main steam relief valves (MSRVs) that were removed during the Spring 2018 Unit 3 outage had as found lift settings outside of the +/- 3 percent band required for their operability. The LER was associated with three of the thirteen MSRVs as found setpoints being outside of the +/- 3 percent setpoint band required for their operability. This was discovered on May 17, 2018, following as-found testing results conducted on all thirteen MSRVs that were removed during the refueling outage. The licensee determined that the three MSRV pilot discs had corrosion bonding to their valve seats as a result of their platinum anti-corrosion coatings flaking off. The licensee determined that these three MSRVs were inoperable for an indeterminate period of time from March 26, 2016, when the unit entered Mode 2 (beginning of operating cycle) to February 17, 2018, when the unit entered Mode 4 (beginning of refueling outage). The inspectors reviewed the licensee event report and determined that the report adequately documented the summary of the event including the cause and potential safety consequences. The inspectors also reviewed other documents that indicate that this type of failure is a known industry issue associated with this type of valve. |
| 05000298/FIN-2018003-03 | 30 September 2018 23:59:59 | Cooper | Failure to Provide Adequate Lubrication for Drywell Fan Coil Units | The inspectors reviewed a self-revealed finding for the licensees failure to implement Work Order 5060136 during maintenance on the drywell fan coil units. Specifically, on October 26, 2016, during bearing replacement work on drywell fan coil, unit D, maintenance personnel failed to properly reinstall auto-lubricator injection connectors after removing the interferences per the work order instructions. This error resulted in the failure of drywell fan coil, unit D, due to inadequate bearing lubrication, and ultimately led to a downpower and reactor shutdown. |
| 05000341/FIN-2018003-01 | 30 September 2018 23:59:59 | Fermi | Failure to Apply Torque Values Described in Maintenance Procedure for Flexible Couplings on Emergency Diesel Generator 12 | A finding of very low safety significance with an associated non-cited violation of Technical Specification 5.4.1.a was self-revealed when plant operators discovered a pencil-thick lube oil leak coming from a flexible coupling on emergency diesel generator 12 during planned surveillance testing. Specifically, a lube oil leak developed when the flexible coupling located between the engine driven lube oil pump and the lube oil filter failed due to improper torque applied to the coupling On April 20, 2018, the licensee was performing a routine slow start surveillance of emergency diesel generator 12 (EDG12), when plant operators noted a pencil-thick lube oil leak from the flexible coupling fastener located between the engine driven lube oil pump and the lube oil filter with the engine running in idle. Plant operators subsequently shut down the engine, discontinued the surveillance, and EDG12 was declared inoperable. The licensee performed an investigation and found the flexible coupling fastener was torqued to 120 in/lbs. Maintenance procedure 35.307.008, Emergency Diesel Generator Engine General Maintenance, Enclosure X, Revision 44 required a torque value of 240260 in/lbs for the size of piping the fastener was on. The coupling was last disturbed in 2011, and the maintenance procedure at that time did not contain information regarding torque values for flexible couplings. A similar flexible coupling fastener failed in 2016 due to inadequate work instructions for torqueing flexible couplings (NCV 05000341/201600401, ADAMS Accession Number ML17030A328), and corrective actions were developed to use the vendor recommended values that had already been added to the maintenance procedure as Enclosure X in 2014. However, the corrective actions did not require all flexible couplings to be checked to ensure they were appropriately torqued. Opportunities existed for the licensee to ensure these flexible couplings were properly torqued according to vendor recommendations, either through scheduled maintenance online or during refueling and forced outages. Therefore, on April 20, 2018, another flexible coupling that was not checked as an extent of condition failed due to an under torqued condition. |
| 05000298/FIN-2018003-01 | 30 September 2018 23:59:59 | Cooper | Failure to Provide Complete and Accurate Information in a License Amendment Request | The inspectors identified that the licensee provided inaccurate information to the NRC in a license amendment request for an emergency action level scheme change. Specifically, the licensee provided information about the measurement ranges of a liquid effluent radiation monitor used in emergency action levels that was not accurate. |
| 05000277/FIN-2018003-03 | 30 September 2018 23:59:59 | Peach Bottom | Reactor Core Isolation Cooling System Pressure Switch Failure Results in Condition Prohibited by TS - EA-18-108 | On April 22, 2018, during a routine surveillance test of the RCIC system, the RCIC turbine tripped approximately 28 seconds after startup, prior to the system reaching rated flow and pressure. Concurrent with the RCIC trip, an alarm was received for RCIC turbine high exhaust pressure; however, local indications did not indicate a true high pressure in the exhaust line. Therefore, the RCIC system was declared inoperable and TS 3.5.3, Condition A was entered, which requires the RCIC system to be restored to operable within 14 days. Troubleshooting determined that the B RCIC exhaust pressure switch (PS-3-13-72b) had prematurely tripped at normal operating pressure due to an age-related failure of the instrument diaphragm and O-ring. The RCIC system had been previously verified as operable during its last surveillance run on January 16, 2018. Corrective Actions: The failed pressure switch was replaced and the station performed an extent of condition review/inspection of similar pressure switch instruments. Following replacement of the switch, RCIC was retested and restored to operable on April 23, 2018. Furthermore, actions were established to modify the turbine trip logic to remove the single point trip vulnerability. Corrective Action Reference: IR 4129583 Enforcement:Violation: Peach Bottom Unit 3 TS 3.5.3 requires that the RCIC system shall be operable in Mode 1, and if RCIC becomes inoperable, it shall be returned to operable status within 14 days or the plant shall be placed in Mode 3 within the next 12 hours. Contrary to the above, based on relevant causal information, Unit 3 RCIC was likely inoperable prior to April 22, 2018, for a period greater than the TS allowed outage time of 14 days, and Unit 3 had not been placed in Mode 3. Specifically, on April 22, 2018, the Unit 3 RCIC turbine tripped during startup for a routine surveillance test due to a degraded turbine exhaust pressure switch which resulted in an inoperability time of greater than 14days. Internal inspection on the switch identified that it failed due to corrosion from water intrusion which had existed for an extended period of time. Severity/Significance: For violations warranting enforcement discretion, IMC 0612 does not require a detailed risk evaluation; however, safety significance characterization is appropriate. A Region I SRA performed a best estimate analysis of the safety significance using the Peach Bottom Unit 3 Standardized Plant Analysis Risk (SPAR) model, Version 8.51 and Systems Analysis Programs for Hands-On Integrated Reliability Evaluations (SAPHIRE), Version 8.1.8. This model was used to evaluate the internal events increase in core damage frequency (CDF) per year. The SRA performed a site visit to review Exelons fire model output to estimate the external risk contributor of the issue. The final risk evaluation estimated the total (internal and external events risk) increase in CDF to be in the mid E-6/yr range, or of low to moderate safety significance. The SRA evaluated the internal and external events risk contribution due to the inoperability of the RCIC system for an assumed 47 day exposure time. 16 The analyst used the guidance in the Risk Assessment Standardization Project (RASP) Handbook, Volume I, Section 2.4, Revision 2.0, to estimate an exposure time using a time divided by two (t/2) approach. This would represent the time from the last successful surveillance test divided by two. The approach is appropriate for periodically operated components that fail due to a degradation mechanism that gradually could affect the component during the standby period. Given this approach, the internal event contribution was calculated to estimate the internal event risk increase due to the conditional failure of the RCIC pump to successfully start. The increase for internal events was estimated at 2.5E-6/yr increase in CDF. The dominant sequence involved a loss of condenser heat sink, with operator action failure to depressurize, and HPCI system failures. The SRA noted from discussions with Exelon staff that the RCIC system was assumed to be non-recoverable given the nature of the failure. To estimate the external risk contribution, the SRA had several discussions and a site visit to review Exelons preliminary fire model outputs for the conditional failure of the RCIC system for the 47 days. The 47 days included a conservative additional day for repair time. The SRA reviewed Exelons fire risk analysis and noted that one of the dominant risk increase contributors was fire within the 13kV switchgear room. Several other fire areas were reviewed and the SRA noted that the core damage sequences appeared technically reasonable given the plant areas and values assumed for mitigating equipment. Exelons preliminary results showed an increase in external event CDF/yr for the conditional failure of RCIC for 47 days to be approximately 4.5E-6/yr. The SRA determined the results to be reasonable. Exelons model for internal events resulted in an increase in CDF/yr of 1.05E-6/yr which was considered to compare well with the NRC SPAR model. Exelon performed a review of the large early release frequency (LERF) impact and determined an overall increase in LERF due to both external and internal events for the RCIC failure for 47 days to be a nominal 6E-8/yr. Therefore, the SRA review of the dominant sequences and Exelons LERF results affirmed that LERF did not increase the risk over that determined from the increase in CDF. Basis for Discretion: The inspectors determined that the maintenance strategy for these switches was consistent with requirements and standards that existed at the time and that there was no relevant operating experience that would have reasonably necessitated consideration of additional maintenance actions. As a result, no performance deficiency was identified. The inspectors assessment considered: The industry, regulatory, and Exelon service life standards were reviewed for static O-ring pressure switches. Exelons assessment of the pressure switch service condition (critical, mild conditions, low-duty cycle) required a preventive maintenance task to perform periodic calibration and to replace the switch as-required. There was no time-based replacement task prescribed by any standard for this switch. The inspectors determined that Exelons assessment was adequate and the corresponding preventive maintenance activities met applicable standards. The subject pressure switch was installed during original construction and the calibration results of the pressure switch had been satisfactory from 2003 until the 2018 failure. The inspectors reviewed the maintenance and calibration history on the pressure switch and did not identify any adverse trends or conditions adverse to 17 quality that would have required further evaluation or replacement of the pressure switch. Industry operating experience information available to Exelon did not identify the potential for the age-related failure mode of the pressure switch o-ring and diaphragm that occurred at Peach Bottom. The NRC determined that it was not reasonable for Exelon to have been able to foresee and prevent this violation of NRC requirements, and as such, no performance deficiency existed. Therefore, the NRC has decided to exercise enforcement discretion in accordance with Sections 2.2.4 and 3.10 of the NRC Enforcement Policy and refrain from issuing enforcement action for the violation of TSs (EA-18-108). Further, because Exelons actions did not contribute to this violation, it will not be considered in the assessment process or the NRC Action Matrix |
| 05000354/FIN-2018003-03 | 30 September 2018 23:59:59 | Hope Creek | inadequate Procedures for Fuel Conditioning Results in Multiple Fuel Leaks | The inspectors documented a self-revealing Green NCV of TS 6.8.1, Procedures and Programs, when PSEG did not maintain adequate procedures for fuel conditioning. Specifically, PSEGs procedure for selecting the appropriate fuel PCI rules, NF-AB-440, BWR Fuel Conditioning, did not provide adequate guidance for protection of the fuel during restart from the April 2018 refueling outage (RF21). As a result, PSEGs selection non-conservative PCI rules resulted in three PCI fuel leaks. |
| 05000366/FIN-2018003-01 | 30 September 2018 23:59:59 | Hatch | Inoperability of 2A EDG Due to Inadequate Acceptance Criteria for Determining Cleaning Requirements of Emergency Diesel Generator Day Tanks | The inspectors documented a Green, self-revealing, non-cited violation of Unit 2 Technical Specification 5.4.1(a) for the licensees failure to incorporate preventative maintenance criteria for Emergency Diesel Generator (EDG) day tanks as recommended by Regulatory Guide (RG) 1.33, 9.a. Specifically, procedure 52SV-R43-001-0, Diesel, Alternator, and Accessories Inspection, Ver. 30.4, did not contain deterministic criteria in the visual inspection of the fuel filters to initiate the cleaning of the EDG day tanks and thus prevent EDG inoperability. The EDG day tanks had never been inspected and cleaned. |
| 05000354/FIN-2018403-01 | 30 September 2018 23:59:59 | Hope Creek | Security | |
| 05000296/FIN-2018012-01 | 30 September 2018 23:59:59 | Browns Ferry | Failure to correct an inoperable 250V Shutdown Board Battery Charger | A self-revealed, Green, NCV of Technical Specifications (TS) 3.8.4 was identified when the licensee failed to correct an inoperable 250V Shutdown Board (SDBD) 3EB Battery Charger on Unit 3. Specifically, in 2014 the 250V SDBD 3EB Battery Charger was entered into the Corrective Action Program (CAP) as a Condition Adverse to Quality (CAQ), but no actions were taken to correct the condition, which led to the component being in inoperable for longer than the allowed outage time defined in TS 3.8.4. |
| 05000331/FIN-2018003-02 | 30 September 2018 23:59:59 | Duane Arnold | Minor Violation | During Mode 1 power operations on July 9, 2018, the licensee had both doors of a secondary containment airlock open simultaneously, and a minor violation of Technical Specification (TS) 3.6.4.1 Secondary Containment was self-revealed. During the time both doors were open, approximately 3 seconds, the allowable penetration opening area was exceeded and rendered the secondary containment inoperable. Technical Specification 3.6.4.1 requires secondary containment to be operable in Modes 1, 2 and 3. Technical Specification Surveillance Requirement 3.6.4.1.2 supports secondary containment operability by verifying that either the outer door(s) or the inner door(s) in each secondary containment access opening are closed. The posted instructions at each secondary containment airlock door stated, ATTENTION Push Button To Be Held In For 2 Seconds Prior To Opening Door, to be of a type appropriate for traversing the containment airlock. Contrary to the above, at approximately 1:34 p.m. on July 9, 2018, while operating in Mode 1 at 97 percent power, two individuals simultaneously traversing through opposite doors of a secondary containment airlock each failed to hold the airlock interlock push button for two seconds prior to opening their respective doors resulting in a momentarily inoperability of secondary containment. Operability was restored upon the immediate closure of one of the two doors. Subsequently, maintenance was unable to recreate the condition and satisfactorily performed Surveillance Test Procedure (STP) 3.6.4.102, Secondary Containment Airlock Verification, and GMPELEC44,Section A5.1,Airlock Door Interlock Checks.The licensee entered this |
| 05000354/FIN-2018003-04 | 30 September 2018 23:59:59 | Hope Creek | Enforcement Action (EA)-18-044: EGM on Dispositioning BWR Licensee Noncompliance With TS Containment Requirements During Operations With A Potential For Draining The Reactor Vessel (EGM-11-003) | From April 19 through April 29, 2018, HCGS performed OPDRVs without establishing secondary containment integrity. An OPDRV is an activity that could result in the draining or siphoning of the reactor pressure vessel water level below the top of fuel, without crediting the use of mitigating measures to terminate the uncovering of fuel. TS 3.6.5.1, Secondary Containment Integrity, requires that secondary containment integrity be maintained, and is applicable during OPDRVs. The required action for this specification without secondary containment integrity in this condition of applicability is to suspend OPDRVs. As reported in LER 05000354/2018-001, HCGS conducted the following OPDRVs during the period of secondary containment inoperability: Control rod drive mechanism replacements; Local power range monitor replacements; and Cavity let down via Reactor Water Clean Up system. Additionally, an unplanned OPDRV occurred due to RHR system relief valves seat leakage. NRC EGM 11-03, EGM on Dispositioning BWR Licensee Noncompliance With TS Containment Requirements During Operations With A Potential For Draining The Reactor Vessel, Revision 3, provides, in part, for the exercise of enforcement discretion only if the licensee demonstrates that it has met specific criteria during an OPDRV activity. The inspectors assessed that HCGS adequately implemented these criteria. In accordance with EGM 11-003, in order to continue to receive enforcement discretion, a license amendment request (LAR) must be submitted and accepted for review within 12 months of the NRC staffs publication of the generic change that occurred on December 20, 2016. The inspectors verified that PSEG submitted the required LAR on September 20, 2017 (ADAMS Accession No. ML17265A847), and that it was subsequently accepted by the NRC for review by a letter dated October 25, 2017 (ADAMS Accession No. ML17299A009). Corrective Action: PSEG submitted an LAR to adopt TS Task Force Traveler 542, Reactor Pressure Vessel Water Inventory Control, on September 20, 2017, that was subsequently accepted by the NRC for review on October 25, 2017. (After the end of the inspection period, on October 30, 2018, the NRC staff responded (ML18260A203) to PSEGs LAR dated September 20, 2017, and issued License Amendment No. 213 that revised the technical specifications to adopt TSTF-542, Revision 2. Corrective Action Reference: 20792923 15 Enforcement: Violation: TS 3.6.5.1, Secondary Containment Integrity, requires that secondary containment integrity be maintained, and is applicable during OPDRVs. The required action for this specification without secondary containment integrity in this condition of applicability is to suspend OPDRVs. Contrary to the above, from April 19 through April 29, 2018, HCGS performed OPDRVs without secondary containment integrity. Therefore, set and maintain secondary containment integrity during OPDRVs without suspending the operation was considered a condition prohibited by TSs as defined by 10 CFR 50.73(a)(2)(i)(B). Basis for Discretion: The NRC is exercising enforcement discretion in accordance with Section 3.5, Violations Involving Special Circumstances, of the NRC Enforcement Policy because all criteria described in EGM 11-003 were met and enforcement discretion was previously authorized by EA-2017-071; therefore, no enforcement action will be issued for this violation. The disposition of this violation closes LER 05000354/2018-001-00. |
| 05000331/FIN-2018002-02 | 30 June 2018 23:59:59 | Duane Arnold | Minor Violation | Minor Violation: On June 19, 2016, while operating at 82 percent power, two secondary containment access airlock doors were opened simultaneously during surveillance testing as part of STP 3.6.4.102, Secondary Containment Airlock Verification. The inspectors determined this event was caused by inadequate procedural guidance which directed the user to attempt to open one airlock door while the other door was already open. During this test, the interlock failed because the permanent magnets had rotated and were misaligned. This failure could have been identified without challenging airlock interlock integrity if the second airlock door wasnt held open. The failure to have adequate procedural guidance for testing the secondary containment airlock doors was a violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, which requires licensees to have procedures appropriate to the circumstance when performing safety-related activities. In response to this issue, the licensee immediately closed the airlock doors. In addition, the licensee submitted a TS change request to address the concurrent opening of two secondary containment airlock doors. The licensees corrective action program is tracking the TS change as CR 02034076, Secondary Containment Airlock Doors #225 and 228 Both Opened. Screening: The issue screened as minor because all of the questions associated with a minor issue found in IMC 0612, Appendix B were answered No due to the licensee reestablishing secondary containment operability immediately after the second airlock door opened. In addition, the inspectors considered the failure to have an appropriate procedure was less than a Severity Level IV violation in accordance with the NRCs Enforcement Policy. Violation: The failure to comply with 10 CFR Part 50, Appendix B, Criterion V, constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy. The disposition of this violation closes LER 05000331/2016001. |
| 05000298/FIN-2018011-02 | 30 June 2018 23:59:59 | Cooper | Failure to Ensure Adequate Design Control Measures are in Place Associated with RHR Service Water Booster Pump Room Cooling | An NRC-identified, Green, Non-cited Violation of Title 10, Code of Federal Regulations Part 50, Appendix B, Criterion III, Design Control, occurred for failure to assure that applicable regulatory requirements and the design basis were correctly translated into specifications, drawings, procedures, and instructions. Specifically, the licensee failed to incorporate malfunctions of the residual heat removal (RHR) service water booster pump (SWBP) room cooling temperature switch, which could cause environmental changes leading to functional degradation of system performance, into the design basis to verify the necessary protection system action be retained. |
| 05000331/FIN-2018011-01 | 30 June 2018 23:59:59 | Duane Arnold | Failure to Translate Environmental Qualification Requirements into Maintenance Procedures/Instructions | The inspectors identified a finding of very-low safety significance (Green), and associated Non-Cited Violation (NCV) of Title 10 of the Code of Federal Regulations (CFR), Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to establish measures to assure that Environmental Qualification (EQ) requirements for qualified components correctly translated into procedures and instructions. Specifically, the inspectors identified two examples of the licensees failure to ensure that the EQ requirements for O-ring installed in EC290 connector/plug-in cable assemblies were translated into the associated maintenance procedures and instructions(i.e.,EQ Files, warehouses storage requirements). The licensee failed to correctly establish an end-of-life replacement schedule for the O-ring used in the cable assemblies installed in the dry well and failed to establish a 2-year shelf-life for the O-ring stored in the warehouse. |
| 05000296/FIN-2018002-02 | 30 June 2018 23:59:59 | Browns Ferry | Inoperable Residual Heat Removal (RHR) Pump Results in Condition Prohibited by Technical Specifications | A self-revealed SL IV NCV of TS 3.5.1 and 3.6.2.3 was identified when the licensee discovered that the 3A RHR pump was inoperable for longer than the allowed outage time and follow on action completion time. |
| 05000298/FIN-2018002-01 | 30 June 2018 23:59:59 | Cooper | Failure to Maintain Alarm Procedure for Service Water Booster Pump Ventilation Manual Actions | The inspectors identified a Green non-cited violation of Technical Specification 5.4, Procedures, when the licensee failed to maintain Procedure 2.3_R-1 with the bounding time restrictions for required manual ventilation actions identified in Engineering Evaluation NEDC 92-064, Transient Temperature Rise in SWBP Room After Loss of Cooling, Revision 3C2. As a result, the licensee relied on procedure guidance that contained an incorrect, less restrictive allowance of 13 hours for completion of manual actions rather than the bounding 5.8-hour allowance described in NEDC92-064. |
| 05000259/FIN-2018002-01 | 30 June 2018 23:59:59 | Browns Ferry | HPCI System Over Pressurization due to Failure to Maintain Procedure | A self-revealed, Green, NCV of 10 CFR 50, Appendix B, Criterion V Instructions, Procedures, and Drawings was identified for failure to maintain procedure 2-SR-3.8.4.3(MB-2) Revision 11, Main Bank 2 Battery Service Test. Specifically, the licensee failed to evaluate the impact of an emergent, Unit 2 procedure revision to a step intended to mitigate over pressurizing Unit 1 High Pressure Coolant Injection (HPCI) system |
| 05000324/FIN-2018011-02 | 30 June 2018 23:59:59 | Brunswick | Failure to Evaluate Effects of MOV Space Heaters on Qualified Life | The NRC identified a Green finding and associated non-cited violation of 10 CFR 50.49(e)(5) for the licensees failure to evaluate the effects of additional heat rise on the qualified life of Limitorque controls. |
| 05000277/FIN-2018010-01 | 30 June 2018 23:59:59 | Peach Bottom | Failure to Identify Time-Critical Action | The inspectors identified a green finding because Exelon did not identify, validate, and incorporate a time-critical action referenced in calculation PF-0016-025, Fire Area 025 Fire Safe Shutdown Analysis, in accordance with Sections 4.2 and 4.3 of OP-AA-102-106, Operator Response Time Program. Specifically, Exelon did not identify a 10-minute time-critical action to take the transfer/isolation switch for the high pressure coolant injection (HPCI) inboard steam isolation valve (MO-2(3)-23-015), to the EMERG position |
| 05000341/FIN-2018002-04 | 30 June 2018 23:59:59 | Fermi | Failure to Identify a Condition Adverse to Quality on Division 2 Residual Heat Removal Service Water Outlet Flow Control Valve | A self-revealed TBD finding and an associated apparent violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, and Technical Specification 3.7.1 Residual Heat Removal Service Water (RHRSW) System, were identified for failure to identify a condition adverse to quality while performing corrective maintenance on Division 2 RHRSW outlet flow control valve E1150F068B prior to returning the Division 2 RHRSW system to service. Specifically, troubleshooting and associated post maintenance testing failed to identify and correct a failed anti-rotation key which resulted in an inoperable Division 2 RHRSW system for longer than its Technical Specification 3.7.1 allowed outage time. |
| 05000298/FIN-2018002-02 | 30 June 2018 23:59:59 | Cooper | Failure to Maintain Adequate Work Instructions for Traversing In-Core Probe System Limit Switches | A self-revealed, Green non-cited violation of Technical Specification 5.4, Procedures, was identified when the licensee failed to maintain Procedure 14.2.14, TIP Chamber Shield Maintenance, with adequate instructions for reinstalling the traversing in-core probe system in-shield limit switches. As a result, the licensee experienced multiple failures of the shield limit switches resulting in inoperable primary containment isolation valves. |
| 05000298/FIN-2018011-03 | 30 June 2018 23:59:59 | Cooper | Inadequate Design Basis Calculation for the EDG Rooms Temperature Distribution | An NRC-identified, Green, Non-cited Violation of Title 10, Code of Federal Regulations Part 50, Appendix B, Criterion III, Design Control, occurred for the licensees failure to ensure design control measures provide for verifying or checking the adequacy of design of the emergency diesel generator room ventilation system by use of alternate or simplified calculation methods, or by a suitable testing program. Specifically, the licensee incorrectly extrapolated the results of the test program, which led to an incorrect room temperature profile. Additionally, the design calculation did not assume potential failures of the CO2 dampers. |
| 05000333/FIN-2018411-02 | 30 June 2018 23:59:59 | FitzPatrick | Security | |
| 05000333/FIN-2018411-01 | 30 June 2018 23:59:59 | FitzPatrick | Security | |
| 05000325/FIN-2018002-01 | 30 June 2018 23:59:59 | Brunswick | Automatic Reactor Trip due to Perceived Loss of Stator Cooling Water | A self-revealing Green finding (FIN) was identified for the failure to properly implement a modification to the turbine control system (TCS). The modification ultimately resulted in an automatic reactor trip on April 7, 2018, due to a turbine trip caused by a perceived loss of stator cooling water. The TCS system improperly generated a loss of stator cooling turbine trip when the TCS measured higher than expected stator cooling water flow rates |
| 05000324/FIN-2018011-01 | 30 June 2018 23:59:59 | Brunswick | Failure to Justify Qualified Life Extension of ASCO Solenoid Operated Valves | The NRC identified a Green finding and associated non-cited violation of 10 CFR 50.49(e)(5) for the licensees failure to justify life extensions of ASCO solenoid operated valves (SOVs |
| 05000298/FIN-2018011-01 | 30 June 2018 23:59:59 | Cooper | Failure to Correct Extent of Condition of Surge Suppression Varistor Failures | An NRC-identified, Green, Non-cited Violation of Title 10, Code of Federal Regulations Part 50, Appendix B, Criterion XVI, Corrective Action, occurred when the licensee failed to correct conditions adverse to quality associated with the corrective actions identified in Condition Report RCR 2002-1665 to verify that installed surge suppressor varistors were appropriately sized and that design information was correctly reflected in controlled drawings for the reactor protection system, diesel generator control circuits, and high pressure coolant injection control circuits. |
| 05000341/FIN-2018002-01 | 30 June 2018 23:59:59 | Fermi | Failure to Document a Condition Assessment Resolution Document for Reactor Recirculation Motor-Generator Set A Brush Gear Sparking | A self-revealed Green finding was identified for failure to document a Condition Assessment Resolution Document (CARD) for 5-inch rooster tail sparking on reactor recirculation motor-generator set A brush gear, which ultimately resulted in a manual recirculation pump A trip and plant transient. |
| 05000324/FIN-2018002-02 | 30 June 2018 23:59:59 | Brunswick | Enforcement Action 18-080: Implementation of EGM 11-003, Revision 3, Enforcement Guidance Memorandum on Dispositioning Boiling Water Reactor Licensee Noncompliance with Technical Specification Containment Requirements during Operations with a Potential for Draining the Reactor Vessel (OPDRV) | During the Unit 1 spring 2018 refueling outage, the OPDRVs activities are listed below: March 7, 2018: 148 gallons per minute (gpm) leakage associated with local leak rate testing (LLRT) of valves 1-G31-F001 and -F004.March 8, 2018: 82 gpm leakage for A RHR loop draining to support maintenance.March 12, 2018: 81.2 gpm leakage to replace the local power range monitors and intermediate power range dry tubes.March 14, 2018: 71.2 gpm leakage to replace the local power range monitors.March 15, 2018: 25 gpm leakage to replace A recirculation pump seal package.March 22, 2018: 25 gpm leakage to replace A recirculation pump seal package.March 27, 2018: 164 gpm leakage to facilitate control rod drive system venting.March 28, 2018: 288 gpm leakage to account for leakage past scram discharge and vent valves during testing.These activities took place without secondary containment being operable. Corrective Actions: EGM 11-003 allows enforcement discretion regarding secondary containment operability during Mode 5 OPDRV activities provided the licensee meets certain requirements. The licensee met the stipulations of the EGM by executing their procedure 1SP-16-100, EGM 11-003 OPDRV Activities, Rev 001, for each OPDRV activity during the Unit 1 Spring 2018 refueling outage. Additionally, as required by the EGM, the licensee submitted a license amendment request (BSEP 17-0060) on June 29, 2017. The amendment was approved on April 13, 2018, and will be implemented prior to the 2019 Unit 2 spring refueling outage. Corrective Action Reference: The issue was entered into the licensees corrective action program as NCR 2189536. Violation: TS 3.6.4.1, Secondary Containment, requires that secondary containment be operable and is applicable during OPDRVs. The required action if secondary containment is inoperable in this condition is to initiate actions to suspend OPDRVs immediately. Contrary to the above, on activities listed above, the licensee failed to maintain secondary containment operable while performing OPDRVs on Unit 1. Severity/Significance: According to EGM 11-003, the NRC considers enforcement discretion related to secondary containment operability during Mode 5 OPDRV activities provided the licensee meets certain requirements such as monitoring vessel level, maintaining capability to isolate leakage paths, providing minimum makeup flow rate, etc. These requirements provide a reasonable assurance of public health and safety during draining activities in Mode 5 while the secondary containment is inoperable 13 Enclosure Discretion Basis: The NRC exercised enforcement discretion in accordance with Section 3.5, Violations Involving Special Circumstances, of the NRC Enforcement Policy and, therefore, will not issue enforcement action for this violation. These violations were identified during the discretion period described in EGM 11-003, Revision 3, and the licensee met the criteria established in the EGM prior to and during these activities. |
| 05000259/FIN-2018412-01 | 30 June 2018 23:59:59 | Browns Ferry | Security | |
| 05000387/FIN-2018002-03 | 30 June 2018 23:59:59 | Susquehanna | Inadequate Justification for Deferral of Corrective Actions for certain Degraded Safety-Related Components | The inspectors identified a Green finding and associated NCV of TS 5.4.1, Procedures, when the licensee failed to promptly correct numerous operable but nonconforming or degraded safety-related components. |
| 05000387/FIN-2018002-04 | 30 June 2018 23:59:59 | Susquehanna | EGM on Dispositioning BWR Licensee Noncompliance With TS Containment Requirements During Operations With A Potential For Draining The Reactor Vessel (EGM-11-03) | From April 2 through April 24, 2018, Susquehanna performed OPDRVs without establishing secondary containment integrity. An OPDRV is an activity that could result in the draining or siphoning of the reactor pressure vessel water level below the top of fuel, without crediting the use of mitigating measures to terminate the uncovering of fuel. TS 3.6.4.1, Secondary Containment, requires that secondary containment be operable, and is applicable during OPDRVs. The required action for this specification if secondary containment is inoperable in this condition of applicability is to initiate actions to suspend OPDRVs immediately. As reported in LER 05000387/2018-001, Susquehanna conducted the following OPDRVs during the period of secondary containment inoperability: Recirculation system maintenance and pump replacement; Reactor water cleanup system flushes and maintenance; RHR system maintenance; Hydraulic control unit and control rod drive system maintenance; Local power range monitor replacements, including Intermediate Range Monitor 1E Dry Tube replacement; Control rod drive mechanism replacements; and Core spray instrument line flush. NRC EGM 11-03, EGM on Dispositioning BWR Licensee Noncompliance With TS Containment Requirements During Operations With A Potential For Draining The Reactor Vessel, Revision 3, provides, in part, for the exercise of enforcement discretion only if the licensee demonstrates that it has met specific criteria during an OPDRV activity. The inspectors assessed that Susquehanna adequately implemented these criteria. In accordance with EGM 11-003, in order to continue to receive enforcement discretion, a license amendment request (LAR) must be submitted and accepted for review within 12 months of the NRC staffs publication of the generic change, which occurred on December 20, 2016. The inspectors verified that Susquehanna submitted the required LAR on September 20, 2017 (ADAMS Accession No. ML17265A434), and that it was subsequently accepted by the NRC for review by a letter dated October 16, 2017 (ADAMS Accession No. ML17290A024).Corrective Action: Susquehanna submitted an LAR to adopt TS Task Force Traveler 542, Reactor Pressure Vessel Water Inventory Control, on September 20, 2017.Corrective Action Reference: AR-2015-01733 Enforcement: Violation: TS 3.6.4.1, Secondary Containment, requires that secondary containment be operable, and is applicable during OPDRVs. The required action for this specification if secondary containment is inoperable in this condition of applicability is to initiate actions to suspend OPDRVs immediately. Therefore, failing to maintain secondary containment operability during OPDRVs without initiating actions to suspend the operation was considered a condition prohibited by TSs as defined by 10 CFR 50.73(a)(2)(i)(B). Contrary to the above,from April 2 through April 24, 2018, Susquehanna performed OPDRVs without establishing secondary containment integrity. Basis for Discretion: The NRC is exercising enforcement discretion in accordance with Section 3.5, Violations Involving Special Circumstances, of the NRC Enforcement Policy because all criteria described in EGM 11-003 were met, enforcement discretion was previously authorized by EA-2017-089, and the licensee submitted an LAR on September 20, 2017 which was subsequently accepted by the NRC for review on October 16, 2017, and, therefore, will not issue enforcement action for this violation. The disposition of this violation closes LER 05000387/2018-001-00. |
| 05000352/FIN-2018002-01 | 30 June 2018 23:59:59 | Limerick | Failure to Conduct Adequate Radiation Surveys and Evaluate Potential Radiological Hazards | A self-revealing Green finding and associated NCV of 10 CFR 20.1501, Surveys and Monitoring: General, was identified when Exelon failed to perform adequate loose surface contamination surveys of the Unit 1 RWCU isolation valve room prior to authorizing work to hang shadow shielding near the HV-051-1F017A valve, and also during the conduct of the work itself. Exelon also did not identify very high levels of loose surface contamination on overhead piping and structures which surrounded the work area. This failure resulted in unplanned internal radiation exposures to three personnel, including an RPT who was assigned to monitor the radiological aspects of the work. |
| 05000298/FIN-2018011-04 | 30 June 2018 23:59:59 | Cooper | Incorrect Classification of Potential Safety-Related Components | An NRC-identified, Green, Non-cited Violation of Title 10, Code of Federal Regulations Part 50, Appendix B, Criterion III, Design Control, occurred for failure to assure that applicable regulatory requirements and the design basis were correctly translated into specifications, drawings, procedures, and instructions. Specifically, the inspectors identified three examples of the licensees failure to properly classify potential safety-related components in the emergency diesel generator ventilation system and RHR service water booster pump room cooling systems. |
| 05000352/FIN-2018002-02 | 30 June 2018 23:59:59 | Limerick | Unit 1 Core Spray Pump Failed to Start Resulting in Condition Prohibited by Technical Specifications | The inspectors identified a Severity Level IV NCV of Unit 1 Technical Specification 3.5.1 because one core spray subsystem was inoperable from July 17, 2017, until October 5, 2017. Specifically, the Unit 1 C core spray pump did not start upon demand during testing and was declared inoperable because the pumps associated circuit breaker closing charging springs were not charged. |
| 05000387/FIN-2018002-01 | 30 June 2018 23:59:59 | Susquehanna | Control Structure Chiller Inoperability Due to Identified Refrigerant Leaks Not Corrected | 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 XVI, Corrective Action was self-revealed when the licensee failed to promptly correct a condition adverse to quality associated with the B control structure chiller which rendered the B control structure chiller inoperable. |