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05000334/FIN-2018411-01Security2018Q3
05000334/FIN-2018003-01Inadequate Verification of Full Low Head Safety Injection Suction Piping2018Q3A self-revealed Green non-cited violation (NCV) of technical specification(TS)5.4.1, Procedures, was identified when FENOC failed to adequately implement procedure 1OM-52.4.R.2.A, Station Startup Mode 6 to Mode 1 Administrative and Local Actions, to verify that the low head safety injection (LHSI) suction pipes were full of water. Specifically, the non-destructive examination (NDE) inspector incorrectly determined that the suction pipes were full, which led to inoperability of one or more trains of LHSI for in excess of four hours on May 22, 2018,when the suction lines were found to be voided.
05000334/FIN-2018011-01Duties of the Shift Technical Advisor for Control Room Evacuation during a Fire Event.2018Q3The inspectors identified a Green non-cited violation (NCV) of Technical Specification (TS) 5.4.1(a), Procedures, related to the duties of the Shift Technical Advisor (STA) in response to a serious fire requiring control room evacuation. Specifically, procedure 1OM-56C.4.E, Shift Technical Advisors Procedure, Revision 23, directs the STA to perform substantial plant equipment operations outside of the control room (i.e., opening breakers, operating valves, electrical switching, etc.). These duties preclude the STA from maintaining sufficient independence to provide advisory technical support to the Unit 1 and 2 Operating Shift Crews as required by NOP-OP-1002 Conduct of Operations, Revision 12, and Unit 1 TS 5.2.2.f.
05000334/FIN-2018411-02Security2018Q3
05000334/FIN-2018001-01Inadequate Procedure Adherence2018Q1A self-revealed Green finding was identified when the licensee failed to adequately implement procedure NOP-WM-1001, Order Planning Process. Specifically, FENOC personnel that made a change to work order testing requirements did not receive concurrence from a Unit 1 Senior Reactor Operator nor did they ensure that the original scope and/or intent of the test was met.
05000334/FIN-2018001-02Licensee-Identified Violation2018Q1Technical Specification 5.5.2 (c), Radioactive Effluent Controls Program, requires monitoring, sampling, and analysis of gaseous effluents. Contrary to the above, from 1989 to the present, the sample pump flow rates through several isokinetic nozzles was too high to allow for accurate monitoring and representative sampling. In 1989, automatic flow control features of some effluent monitoring instruments were disabled and in 2016, several new monitors were installed on the same isokinetic nozzle sample lines. Both of these actions prevents accurate monitoring and representative sampling.Significance/Severity: The inspectors evaluated this finding using IMC 0609.04, Initial Characterization of Findings, and IMC 0609, Appendix D, Public Radiation Safety Significance Determination Process. The inspectors determined that finding was of very low safety significance (Green).Corrective Action Reference(s): CR-2017-04211 and CR-2018-00283
05000334/FIN-2018010-01Inadequate Diesel Fuel Oil Temperature Protection2018Q1The team identified a finding of very low safety significance (Green) for the failure to ensure that diesel powered Diverse and Flexible Coping Strategies (FLEX) equipment would be reliable to mitigate postulated beyond-design basis external events during very low temperature conditions. Specifically, at temperatures below the site fuel cloud point (4 degrees Fahrenheit (F) to -7 degrees F), portable FLEX equipment, such as emergency diesel powered pumps, were susceptible to conditions in which their capability of starting and operating would be impacted due to fuel crystallizing or gelling and subsequent coating of fuel filter elements.
05000334/FIN-2018403-01Security2018Q1
05000334/FIN-2018403-02Security2018Q1
05000334/FIN-2018403-03Security2018Q1
05000334/FIN-2017004-01Inadequate Control of Entry into High Radiation Areas2017Q4A self-revealing, very low safety significance NCV of Technical Specification (TS) 5.7.1 for failure to control a high radiation area (HRA) was identified. On November 8, 2017, during independent spent fuel storage installation (ISFSI) dry cask loading campaign activities, the failure of multiple barriers resulted in a worker gaining access to an HRA while signed onto an incorrect radiation work permit (RWP) and a subsequent dose rate alarm. Specifically, a worker signed on to an incorrect RWP during a break, and did not recognize that the surveyed work area dose rates were higher than the RWP setpoints. Additionally, radiation protection personnel controlling access to the HRA failed to ensure that the worker was on the correct RWP per plant procedure requirements for a subsequent entry into anHRA. This resulted in the worker entering an HRA under the incorrect RWP and receiving a dose rate alarm of 1,070 millirem per hour. Upon receiving a dose rate alarm, the worker backed away from the area and reported the issue to radiation protection personnel. FENOCs immediate corrective actions included putting the work in a safe condition, performing follow-up surveys, and verifying remaining personnel trip tickets to ensure all individuals were on the correct RWP. FENOC entered the issue into their corrective action program (CAP) as condition report (CR) 2017-11206.The failure to control access to an HRA is a performance deficiency that was within FENOCs ability to foresee and correct and should have been prevented. The performance deficiency is more than minor because it is associated with the Program and Process attribute (Procedures) of the Occupational Radiation Safety cornerstone and adversely affected the cornerstone objective of ensuring adequate protection of worker health and safety from exposure to radiation from radioactive material during routine reactor operation. Specifically, the failure of multiple barriers resulted in a worker gaining access to an HRA while signed on to an incorrect RWP and receiving a dose rate alarm. IMC 0612, Appendix E, Section 6, Health Physics, General Screening Criteria, states that a performance deficiency involving more than one barrier or the loss of a significant barrier would be classified as a more-than-minor performance deficiency. Using IMC 0609,Appendix C, Occupational Radiation Safety Significance Determination Process, the finding was determined to be of very low significance (Green) because: (1) it was not an as low as reasonably achievable (ALARA) finding, (2) there was no overexposure, (3) there was no substantial potential for an overexposure, and (4) the ability to assess dose was not compromised. The finding was a human performance cross-cutting aspect associated with avoiding complacency because FENOC failed to ensure individuals recognize and plan for the possibility of mistakes and ensure individuals implement the appropriate error reduction tools, even when expecting a successful outcome (H.12)
05000334/FIN-2017007-01Non -Conservative Differential Pressure Value Used in Low Head Safety Injection Motor -Operated Valve Design Analysis2017Q4The NRC team identified a finding of very low safety significance (Green) involving a non- cited violation of 10 CFR 50, Appendix B, Criterion III, Design Control, because FENOC staff did not establish measures to assure that the design bases were correctly translated into specifications, drawings, procedures, and instructions. Specifically, for the recirculation phase following a postulated small break loss -of-coolant accident, engineering staff determined the maximum differential pressure fo r motor- operated valves MOV -1SI -863A and MOV -1SI -863B to be the low head safety injection pump shutoff head, but the actual configuration could have resulted in a higher differential pressure at the valve due to allowable reactor coolant system leakage past downstream pressure isolation valves . In response, FENOC staff initiated corrective action program condition report s and assessed the deficiency , and concluded that affected motor -operated valves remained functional although with reduced valve thrust design margin . 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. This finding was not assigned a cross -cutting aspect because the issue did not reflect current licensee performance.
05000334/FIN-2017003-01Operability Determinations and Functionality Assessments2017Q3Inspection Scope The inspectors reviewed operability determinations for the following degraded or non- conforming conditions based on the risk significance of the associated components and systems: Unit 1 Anchor Darling double disk gate valves evaluation resulting from NRC Information Notice 2017- 03 on July 13, 2017 Unit 1 fire protection system functionality during a fire water header break on July 20, 2017 Impact on Unit 1 SSST 1A from nearby fire water header break on July 20, 2017 Unit 1 EDG exhaust piping not protected from tornado- generated missiles on July 25, 2017 Unit 1 degraded main steam valve room high energy line break door on July 26, 2017 Unit 2 inoperable DRPI impact on verifying operability of control rod F10 on August 25, 2017 Unit 1 EDG 1 -2 building exhaust damper missing louver on September 22, 2017 The inspectors evaluated the technical adequacy of the operability determinations to assess whether TS operability was properly justified and the subject SSC remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the TS s and UFSAR to FENOCs evaluations to determine whether the SSCs were operable. The inspectors confirmed, where appropriate, compliance with bounding limitations associated with the evaluations. Where compensatory measures were required to maintain operability , the inspectors determined whether the measures in place would function as intended and were properly controlled by FENOC. 11 b. Findings 10 CFR 50, Appendix B, Criterion III, Design Control, requires, in part, that measures shall be established to assure that the applicable regulatory requirements and the design basis for SSCs are correctly translated into specifications, drawing, procedures, and instructions. Contrary to the above, FENOC failed to correctly translate the design basis for protection against tornado generated missiles into their specifications and procedures. Specifically, FENOC did not adequately protect Unit 1 EDG s exhausts from tornado generated missiles. FENOC documented the condition adverse to quality in their CAP under condition report 2017 -07550 and took immediate compensatory actions. The inspectors evaluated FENOCs immediate compensatory measures, which included verifying that procedures are in place and training is current for performing actions in response to a tornado. Because this violation was identified during the discretion period covered by Enforcement Guidance Memorandum 15- 002, Revision 1, Enforcement Discretion for Tornado Missile Protection Non- compliance (ML16355A286) and because FENOC has implemented compensatory measures, the NRC is exercising enforcement discretion and is not issuing enforcement action and is allowing continued reactor operation
05000334/FIN-2017002-01Licensee-Identified Violation2017Q2The following violation of very low safety significance (Green) was identified by FENOC and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as a NCV . TS 3.7.8, "Service Water System", requires two service water trains to be operable. There is no associated action provided for both trains inoperable. LCO 3.0.3 states, in part, that when an LCO is not met and an associated action is not provided, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Act ion shall be initiated within one hour to place the unit, as applicable, in M ODE 3 within 7 hours. Contrary to the above, on August 20, 2015 and August 31, 2015 , FENOC had both trains of service water inoperable for greater than 7 hours while performing the service water full flow test and did not place Unit 2 in Mode 3. FE NOC entered this issue into the CAP as CR 2017- 04023. The inspectors evaluated this finding using IMC 0609.04, Initial Characterization of Findings . Because the finding represented a loss of function of a system, a detailed risk evaluation was performed. A Region I senior reactor analyst used the BVPS Unit 2 Standardized Plant Analysis Risk Model version 8.5 to perform the evaluation. A seismic initiating event frequency was obtained from the Risk Assessment of Operational Events Handbook Volume 2, External Events. A surrogate loss -of-offsite - power event was used applying the seismic initiating event frequency for BVPS with a train of service water being failed with no recovery assumed. The finding was determined to be of very low safety significance (Green) because the limited exposure time in this configuration resulted in a change in core damage frequency in the 1E -10/yr range. The dominant core damage sequence was a seismic event with failure of the EDG .
05000334/FIN-2017001-01Failure to Follow the ASME OM Code for a Failed Relief Valve Set Pressure Test2017Q1Severity Level IV. The inspectors identified a Severity Level IV NCV of Title 10 of the Code of Federal Regulations (CFR) 50.55a(z), Alternatives to codes and standards requirements, for FENOCs failure to obtain prior authorization for implementing an alternative to the American Society of Mechanical Engineers Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code). Specifically, until prompted by the inspectors, FENOC did not submit to the NRC and receive an alternative to the ASME OM Code requirement to not test the residual heat removal (RHR) relief valve, RV-1RH-721, during a recent refueling outage for Unit 1 when the charging system letdown relief valve, RV-1CH-203, failed to lift within three percent of set-pressure. FENOCs immediate corrective actions included performing a prompt operability determination, submitting a relief request, and entering the issue into the corrective action program (CAP) as condition report (CR) 2017-03937. The inspectors determined that this violation impacted the ability of the NRC to perform its regulatory oversight function, and was therefore subject to traditional enforcement. Section 2.2.1.c of the Enforcement Policy states that failure to receive prior NRC approval for changes in licensed activities when required is an example of impacting the ability of the NRC to perform its regulatory oversight function. After considering the factors in Section 2.2.1.c of the Enforcement Policy, the inspectors determined that the performance deficiency was a Severity Level IV violation because the change implemented by FENOC would likely be approved by the NRC. Because this violation involves the traditional enforcement process and does not have an associated finding that is more than minor, the inspectors did not assign a cross-cutting aspect to this violation in accordance with IMC 0612, Appendix B.
05000334/FIN-2017001-02Operability Determinations and Functionality Assessments2017Q110 CFR 50, Appendix B, Criterion III, Design Control, requires, in part, that measures shall be established to assure that the applicable regulatory requirements and the design basis for structures, systems, and components are correctly translated into specifications, drawing, procedures, and instructions. Contrary to the above, FENOC failed to correctly translate the design basis for protection against tornado-generated missiles into their specifications and procedures. Specifically, FENOC did not adequately protect Unit 1 and Unit 2s main steam safety and atmospheric dump valve exhausts from tornado-generated missiles. Additionally, FENOC did not adequately protect Unit 2s component cooling pumps and spent fuel from tornado-generated missiles by failing to include in their procedures actions for closing the tornado doors in the event of a tornado. The inspectors evaluated FENOCs immediate compensatory measures, which included verifying that procedures are in place and training is current for performing actions in response to a tornado. Because this violation was identified during the discretion period covered by Enforcement Guidance Memorandum 15-002, Revision 1, Enforcement Discretion for Tornado Missile Protection non-compliance (ML16355A286) and because FENOC has implemented compensatory measures, the NRC is exercising enforcement discretion, is not issuing enforcement action, and is allowing continued reactor operation.
05000334/FIN-2017403-01Security2017Q1
05000334/FIN-2016004-01Failure to Follow Procedure Results in an Inoperable A River Water Train2016Q4A self-revealing NCV of Title 10 of the Code of Federal Regulations (CFR) 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified for FENOCs failure to assure that activities affecting quality were accomplished in accordance with procedures. Specifically, FENOC failed to follow NOP-OP-1001, Clearance/Tagging Program, and clearance 1W11-30-MNM-002 when removing the clearance for the A bay of the main intake structure. This resulted in disabling the automatic start capability of the standby C river water pump and made the A river water train inoperable and unavailable. FENOCs immediate corrective action was to rack the breaker for the A river water pump to the disconnect position, which cleared the annunciator and restored operability to the A train of river water. FENOC entered this issue into their corrective action program (CAP) as condition report (CR) 2016-14253. The performance deficiency is more-than-minor because it is associated with the Human Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, FENOC incorrectly racked the A river water pump breaker onto the 1AE 4160 volts alternating current (VAC) safety bus while the C river water pump was already racked onto the bus. This caused the A train of river water to be inoperable and unavailable because the automatic start capability of the C pump was disabled. The inspectors determined that this finding was of very low safety significance (Green) because it did not represent a loss of system and/or function, an actual loss of function of a single train for greater than its technical specification allowed outage time, or an actual loss of function of one non-technical specification train designated as high safety significance. This finding has a cross-cutting aspect in Human Performance, Avoid Complacency, because the operators did not plan for the possibility of mistakes and did not implement appropriate error-reduction tools (H.12).
05000334/FIN-2016004-02Licensee-Identified Violation2016Q4The following licensee-identified violation of NRC requirements was determined to be of very low safety significance and meets the NRC Enforcement Policy criteria for being dispositioned as a NCV. Radioactive material shipment B-4655, was made from Beaver Valley on May 5, 2016, to ResinSolutions in Erwin, TN. During a self-assessment performed by the FENOC staff on November 3, 2016, it was identified that the scaling factors used to determine the hard-to-detect nuclides listed on the manifest (NRC Form 540) for shipment B-4655 were incorrect. The scaling factors used to manifest the shipment were not for the waste stream shipped. Recalculation of the isotopic values using the correct waste stream scaling factors resulted in different numeric values for multiple radionuclides in the shipment, but did not cause a change in the proper shipping name, packaging, or labeling. 10 CFR 71.5 requires, in part, that radioactive materials be transported with an accurate shipment manifest. Contrary to the above, on May 5, 2016, FENOC transported radioactive materials with a shipment manifest that incorrectly stated that the radiological activity of the package was higher than the actual activity. FENOC documented this issue in CR 2016-13071, and provided a corrected shipment manifest to the recipient of the material. In accordance with IMC 0609, Appendix D, "Public Radiation Safety Significance Determination Process," the finding was determined to be of very low safety significance (Green) because FENOC had an issue involving transportation of radioactive material, but it did not involve a radiation limit that was exceeded, a breach of package during transport, a certificate of compliance issue, a low level burial ground nonconformance, or a failure to make notifications or provide emergency information.
05000334/FIN-2016003-01Failure to Identify Conditions Adverse to Quality Leads to Inoperable Emergency Bus Degraded Voltage Relays2016Q3The inspectors identified an NCV of Title 10 Code of Federal Regulations (CFR) 50, Appendix B, Criterion XVI, Corrective Action, for FENOCs failure to assure that a condition adverse to quality was promptly identified and corrected. Specifically, FENOC failed to promptly identify and correct a negative trend in setpoint drift and as found dropout voltage values in the AB 27N model 411T6375HF 4160 volts alternating current (VAC) and 480 VAC emergency bus degraded voltage relays. FENOCs immediate corrective actions included recalibrating or replacing the relays and entering the issue into their corrective action program (CAP) as condition report (CR) 2016-12018. The performance deficiency is more than minor because it is associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, FENOCs failure to promptly identify and address a negative trend in dropout voltage setpoint drift and as found values resulted in the reduced reliability of safety related bus degraded voltage relays (seven surveillance failures and inoperable degraded bus relays between 2011 and 2016). Inoperable emergency bus degraded voltage relays could lead to damage of safetyrelated equipment during a loss of offsite power. This finding is of very low safety significance (Green) because it does not represent a loss of system and/or function, an actual loss of function of a single train for greater than its technical specification allowed outage time, an actual loss of function of one non-technical specification trains designated as high safety significant, and did not involve a loss or degradation of equipment designed to mitigate a seismic, flooding, or severe weather initiating event. The finding has a crosscutting aspect in the area of Problem Identification and Resolution, Trending, because FENOC did not periodically analyze the results of the degraded voltage relay surveillances to provide early indication of a declining trend (P.4).
05000334/FIN-2016403-01Licensee-Identified Violation2016Q3
05000412/FIN-2016002-02Inadequate Compensatory Measures to Ensure the Effectiveness of an EAL2016Q2The inspectors identified an NCV of 10 CFR 50.54(q)(2) for FENOCs failure to follow and maintain the effectiveness of an emergency plan that meets the planning standards of 10 CFR 50.47(b)(4). Specifically, following the failure of the area radiation monitor (ARM) for the Unit 2 primary auxiliary building 773 elevation on April 23, 2016, FENOC did not establish adequate compensatory measures to ensure the effectiveness of the emergency action level (EAL) for loss of control of radioactive material, RU2. FENOCs immediate corrective actions included establishing appropriate compensatory measures for RU2, communicating the standards of EAL compensatory measures to radiation protection technicians verbally and via narrative logs, and entering this issue into their CAP as CR 2016-05975. The performance deficiency is more-than-minor because it is associated with the Facilities and Equipment attribute of the Emergency Preparedness cornerstone, and adversely affected the cornerstone objective to ensure that FENOC is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, FENOCs failure to establish adequate compensatory measures for an out-of-service ARM could have resulted in exceeding a NOUE EAL threshold for a loss of control of radioactive material without the condition being recognized until further degradation in the level of plant safety occurs. This finding was determined to be of very low safety significance (Green) since it was example of an ineffective EAL, such that a notification of unusual event (NOUE) would not be declared or would be declared in a degraded manner. This finding has a cross-cutting aspect in Human Performance, Documentation, because FENOC did not ensure that plant activities are governed by comprehensive procedures (H.7).
05000334/FIN-2016007-01Security2016Q2
05000334/FIN-2016002-01Procedure Change Results in Failure to Maintain the Design Basis for the Service Water System2016Q2The inspectors identified an NCV of Title 10 of the Code of Federal Regulations (CFR) 50, Appendix B, Criterion III, Design Control, for FENOCs failure to assure that the regulatory requirements and design basis for the Unit 2 service water system were correctly translated into procedures. Specifically, FENOC implemented a procedure revision in 2002 that inappropriately removed the step to declare the Unit 2 service water system inoperable while the non-seismic standby service water system is aligned to it. FENOCs immediate corrective actions included issuing instructions that prohibit planned testing of or swapping to the standby service water system and revising procedure 2OST-30.1A. FENOC entered the issue into their CAP as condition report (CR) 2016-01710. The performance deficiency is more-than-minor because it is associated with the Design Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, FENOCs revision to 2OST-30.1A in 2002 resulted in reduced reliability of the service water system while connected to the standby service water system for over ten hours on February 1, 2016, and nine hours on April 3, 2014. This finding was of very low safety significance (Green) because it did not represent a loss of system and/or function, an actual loss of function of a single train for greater than its technical specification allowed outage time, an actual loss of function of one non-technical specification trains designated as high safety significant, and did not involve a loss or degradation of equipment designed to mitigate a seismic, flooding, or severe weather initiating event. This finding does not have a cross-cutting aspect because it is not representative of current performance. The inadequate review of revision 17 to 2OST-30.1A was an isolated instance that occurred over 14 years ago. Furthermore, the most recent NRC inspection of Changes, Tests, or Experiments and Permanent Plant Modifications, performed in 2013, and the Component Design Basis Inspection, performed in 2014 did not document any findings related to procedure changes. (Section 1R15)
05000334/FIN-2016002-03Failure to Appropriately Utilize Multiple and Diverse Indications Results in Plant Transient2016Q2A self-revealing finding of NOP-OP-1002, Conduct of Operations, was identified for FENOCs failure to adequately implement operator fundamentals. Specifically, operators did not appropriately utilize multiple and diverse indications when making the decision to isolate electro-hydraulic control (EHC) to a Unit 1 main turbine governor valve. This resulted in an unanticipated reactor power reduction of 2.7 percent. FENOCs immediate corrective actions included re-opening the governor valve, verifying proper system response, and entering this issue into their corrective action program (CAP) as CR 2015-08263. The performance deficiency is more-than-minor because if left uncorrected, the performance deficiency had the potential to lead to a more significant safety concern. Additionally, example 4.b from IMC 0612 Appendix E details that a performance deficiency is more-than minor if it causes a reactor trip or other transient. This finding was determined to be of very low safety significance (Green) since it did not cause both a reactor trip and the loss of mitigation equipment relied upon to transition the plant to a stable shutdown condition. This finding has a cross-cutting aspect in Human Performance, Challenge the Unknown, because individuals did not consult the system expert when confronted with an unexpected condition (H.11).
05000334/FIN-2016201-04Security2016Q1
05000334/FIN-2016201-02Security2016Q1
05000334/FIN-2016201-01Security2016Q1
05000334/FIN-2016001-01Failure to Properly Evaluate Control Room Envelope Test Results2016Q1The inspectors identified an NCV of Title 10 of the Code of Federal Regulations (CFR), Part 50, Appendix B, Criterion XI, Test Control, for FENOCs failure to properly evaluate the test results of the Control Room Envelope (CRE) unfiltered air in-leakage test performed in December 2015. Specifically, the test results exceeded the acceptance criteria specified in the test procedure and required further engineering evaluation to determine if the control room emergency ventilation system (CREVS) could meet its specified safety function. The inspectors identified that the engineering evaluation of the test results did not account for all of the in-leakage and resulted in a reasonable doubt of operability of CREVS. FENOCs immediate corrective action was to re-evaluate the December 2015 calculation and verify that CREVS remained operable with the increased in-leakage. FENOC entered the issue into their corrective action program, condition report (CR) 2016-03836. The performance deficiency is more-than-minor because it is associated with the human performance attribute of the Barrier Integrity cornerstone, and adversely affected the cornerstone objective of providing reasonable assurance that physical design barriers protect from radionuclide releases caused by accidents or events. Specifically, FENOCs evaluation did not account for in-leakage from the non-tested portions of the control room radiological barrier, and therefore, did not provide reasonable assurance that the control room dose would not exceed five rem during an uncontrolled release of radioactivity. Additionally, this issue is similar to example 3j and 3k of IMC 0612 Appendix E, Examples of Minor Issues, in that FENOCs December 2015 engineering evaluation failed to adequately account for CRE in-leakage and resulted in a reasonable doubt of the operability of CREVS. The inspectors determined that this finding was of very low safety significance (Green) because it only represented a degradation of the radiological barrier function provided for the control room. This finding has a cross-cutting aspect in the area of Human Performance, Conservative Bias, because FENOC did not take a conservative approach to decision making, particularly when the in-leakage information was incomplete (H.14).
05000334/FIN-2016201-03Security2016Q1
05000334/FIN-2015004-01Inadequate Maintenance Rule Monitoring of the Auxiliary Feedwater System2015Q4The inspectors identified an NCV of Title 10 of the Code of Federal Regulations (CFR) 50.65, Requirements for monitoring the effectiveness of maintenance at nuclear power plants, for FENOCs failure to monitor the performance of the Unit 1 auxiliary feedwater (AFW) system against licensee-established goals. Specifically, FENOC did not identify and properly account for a maintenance preventable functional failure (MPFF) of the turbine driven auxiliary feedwater (TDAFW) pump, which demonstrated that performance of the Unit 1 AFW system was not being effectively controlled through appropriate preventive maintenance. FENOCs immediate corrective actions included entering this issue into their corrective action program, re-evaluating and classifying the TDAFW pump failure as a MPFF, performing a 10 CFR 50.65 (a)(1) evaluation of the Unit 1 AFW system, and placing the system in (a)(1) status. The performance deficiency was determined to be more-than-minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone, and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Additionally, example 7.d from IMC 0612 Appendix E details that a performance deficiency is more than minor if equipment performance problems were such that effective control of performance through appropriate preventive maintenance under (a)(2) could not be demonstrated. This finding was determined to be of very low safety significance (Green) since it was not a deficiency affecting the design or qualification of a mitigating structure, system, or component (SSC), it did not represent the loss of a system and/or function, it did not represent an actual loss of function of at least a single train or two separate safety systems out-of-service for greater than its technical specifications allowed outage time, and it did not represent an actual loss of a non-technical specification equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hours. This finding has a cross-cutting aspect in Human Performance, Avoid Complacency, because FENOC failed to consider the extent of condition and their causes following the failure of the Unit 1 TDAFW pump on January 6, 2014 (H.12).
05000412/FIN-2015007-03Unit 2 Alternative Post-Fire Shutdown Procedures Deficiencies for Some Postulated Spurious Operations2015Q3The team identified a finding of very low safety significance (Green) of BVPS Unit 2 License Condition 2.F, Fire Protection Program, for failure to implement and maintain all aspects of the approved FPP. Specifically, FENOCs alternative post-fire safe shutdown operating procedures for some postulated fire-induced spurious circuit operations did not provide adequate guidance to ensure that; (1) the charging system flow path was established for reactor coolant system (RCS) makeup; (2) service water was provided for emergency diesel generator (EDG) cooling; and (3) reactor coolant pump (RCP) seal injection flow was secured prior to reinitiating charging flow beyond a ten minute lapse to preclude a RCP seal loss of coolant accident (LOCA). This issue was determined to satisfy the criteria specified for the exercise of enforcement discretion for plants in transition to a fire protection program that meets the requirements of 10 CFR 50.48(C), National Fire Protection Association Standard NFPA 805. In response to a significant fire in the Unit 2 fire areas CB-1 (Instrument Relay Room), CB-2 (Cable Spread Room), CB-3 (Control Room), CB-6 (Control Building West Communication Room), and CT-1 (Cable Tunnel), control room operators would implement the 2OM-56C.4 series procedures. These procedures are collectively the alternative post-fire safe shutdown procedure. As directed by the alternative post-fire safe shutdown procedure, control room operators relocate to the alternate shutdown panel (ASP) to establish and maintain post-fire safe shutdown. The team reviewed these procedures and identified that procedures, specifically, 2OM-56C.4.B - Unit Supervisor Procedure, Rev. 32 effective October 21, 2014, 2OM-56C.4.F-1 ASP Activation, Rev. 12 effective March 2, 2007, and 2OM-56C.4.D -Nuclear Operator #1 Procedure, Rev. 24 effective October 21, 2014, did not provide adequate guidance to ensure that the alternative shutdown performance goals would be maintained considering some postulated fire-induced spurious operations. The team identified three deficiencies within these procedures: 2OM-56C.4.D directed operators to use a charging system flow path to establish RCS makeup that was not free of fire damage for associated alternative shutdown fire areas; 2OM-56C.4.F-1 did not have adequate steps to verify the 21A service water pump was operating and adequate service water cooling flow established to the 2-1 EDG; and, 2OM-56C.4.B did not have sufficient precautions or steps to preclude a RCP seal LOCA. The charging system flow path procedure errors occurred when FENOC made procedure changes effective October 21, 2014 to 2OM-56C.4.D to address a corrective action item for terminating a fire-induced spurious safety injection signal. FENOC inappropriately assumed a B train motor operated safety injection valve, 2SIS-MOV867B, would remotely operate open, but for the associated fire areas, its cables were subject to fire damage and the valve cannot be relied on to open. FENOC promptly initiated CR-2015-10757 and revised 2OM-56C.4.D to include a local operator manual action, consistent with the fire safe shutdown analysis, to establish charging flow for RCS makeup. The adequate service water flow for the 2-1 EDG procedure errors occurred because 2OM-56C.4.F-1 provided a table that included required positions for components on the ASP and did not specify alignment order or provide any precaution to verify adequate service water flow to the 2-1 EDG after it was started. The 21A SWP switch alignment was listed third in the table and the 2-1 EDG switch alignment was listed sixth in the table. For a LOOP scenario, the 21A SWP cannot be started until the 2-1 EDG is successfully started and its output breaker closed to the 4 kV vital bus. Additionally, during control room abandonment and relocation to the ASP, the 21A SWP could spuriously operate while the 2-1 EDG auto starts. For this scenario, the procedure lacked sufficient precaution to ensure service water flow was restored from the ASP in a timely manner. FENOC promptly initiated CR-2015-1116 for long term resolution and issued Standing Operating Order 15-006 that the 2-1 EDG may not auto start and load during ASP activation. The potential for a RCP seal LOCA during execution of 2OM-56C.4.B can occur during a loss of offsite power scenario if the charging pump auto starts when the 2-1 EDG is started from the ASP and more than ten minutes has elapsed since RCP seal cooling was lost. 2OM-56C.4.B lacked sufficient precautions and procedure steps for local operator manual actions to ensure a RCP seal LOCA did not occur during the postulated LOOP scenario. FENOC promptly initiated CR-2015-11044 for long term resolution as part of transition to NFPA 805 and established interim compensatory measures in the form of fire watch patrols in the fire areas where these circuit interactions could occur. For all three post-fire alternative safe shutdown procedure deficiencies, the team concluded that FENOCs immediate and long term corrective actions were appropriate and commensurate with the risk significance. Analysis. Failure to ensure that the alternative post-fire safe shutdown operating procedures for some postulated fire-induced spurious circuit operations provided adequate guidance to ensure that; (1) the charging system flow path was established for RCS makeup; (2) service water was provided for EDG cooling; and (3) RCP seal injection flow was secured prior to reinitiating charging flow beyond a ten minute lapse to preclude a RCP seal LOCA is a PD. This PD is more than minor because it is associated with the external events (fire) attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring the reliability and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). FENOC reviewed the post-fire alternative safe shutdown procedure deficiencies and evaluated the issues through use of its fire PRA. FENOC determined that the change in core damage frequency attributed to the procedure issues was 1.9E-8 (Green). NRC staff reviewed this evaluation and concluded that the risk number was bounded by conservative assumptions and that this issue would be of no greater than very low safety significance. Cross-cutting aspects are not applicable to findings involving enforcement discretion. Enforcement. Beaver Valley Unit 2 License Condition 2.F requires in part that FENOC shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report (FSAR). BVPS Unit 2 Updated FSAR, Rev. 21, Section 9.5.1.1 states that the fire protection system is designed using the guidance of BTP CMEB 9.5-1, Rev. 2. BTP CMEB 9.5-1, Rev. 2, Section C.5.c.(3) requires that the alternative shutdown capability shall accommodate post-fire conditions where offsite power is available and where offsite power is not available for 72 hours and procedures shall be in effect to implement this capability. Contrary to above, since March 2, 2007, FENOC has not had procedures in effect to implement alternative shutdown capability that accommodates post-fire conditions where offsite power is available or is not available for 72 hours. Specifically, the BVPS Unit 1 alternative post-fire safe shutdown procedures did not ensure that: (1) RCS makeup function was established; (2) service water cooling was provided to the 2-1 EDG; and (3) the RCP seal injection flow was isolated to preclude a RCP seal LOCA. FENOC is in transition to NFPA 805 and therefore this NRC-identified violation was evaluated in accordance with the criteria established by Section A of the NRCs Interim Enforcement Policy Regarding Enforcement Discretion for Certain Fire Protection Issues (10 CFR Part 50.48) for a licensee in NFPA 805 transition. Specifically, because all of the criteria were met, the NRC is exercising discretion and not issuing a violation for this issue.
05000334/FIN-2015007-01Unanlayzed Condition Resulting from Unfused Direct Current Control Circuits2015Q3On April 30, 2014, FENOC identified a violation of very low safety significance of 10 CFR 50, Appendix R, Section III.G for BVPS Unit 1 in that unfused direct current (DC) control circuits for DC motors were routed from the turbine building through other fire areas. The DC breakers used to protect the motor power conductors were insufficient to protect the control conductors for these circuits and it is postulated that a fire induced short in one fire area could adversely impact safe shutdown equipment by overheating the cable and causing a secondary fire in other fire areas where the cable is routed. The team identified that FENOC did not establish a fire watch in one of the affected fire areas, the turbine building, as a compensatory measure. Therefore, because FENOC did not initiate immediate corrective action or compensatory measures or both within a reasonable time, enforcement discretion will not be exercised. This violation will be treated as a NRC-identified violation. In response to the NRC finding, FENOC promptly initiated a one hour roving fire watch patrol in the turbine building. The lack of compensatory measures in the turbine building occurred because administrative procedure, 1/2-ADM-1900, Fire Protection Program, used to determine compensatory measures for fire protection program deficiencies, was inadequate in its guidance to plant personnel for review of cable separation issues. For cable separation issues, 1/2-ADM-1900 required fire watches in only one of two affected adjacent fire areas. FENOC entered this issue into its corrective action program as condition report (CR) CR-2015-10546 and planned to revise 1/2-ADM-1900 to ensure fire watches were established in all affected fire areas that involved cable separation issues. FENOC initiated CR-2014-07961 to resolve the DC circuit non-conformance using National Fire Protection Association (NFPA) 805 performance based fire risk evaluations considering the low probability of a secondary cable fire due to overheating of cables associated with the pump motor control circuits during an electrical fault condition with no circuit protection. This finding was more than minor because it adversely affected the protection against external factors (i.e., fire) attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective of ensuring the availability and reliability of systems that respond to initiating events to prevent undesirable consequences. FENOC reviewed the cable routes and evaluated this issue through use of its fire probabilistic risk assessment (PRA). FENOC determined that the change in core damage frequency attributed to the issue for Unit 1 was 8.5E-7 per reactor year. NRC staff reviewed this evaluation and concluded that the risk numbers were bounded by conservative assumptions and that this issue would be of very low safety significance. This finding had a cross-cutting aspect in the area of Human Performance, Resources, because FENOC did not ensure that procedures were adequate to support nuclear safety. Specifically, 1/2-1900-ADM was too restrictive for safe shutdown circuit separation issues in that it mandated an hourly fire watch patrol in only one of the two adjacent fire areas and for this issue FENOC did not appropriately establish an hourly fire watch patrol in the Unit 1 turbine building. (H.1)
05000334/FIN-2015007-02Unit 1 Control Room HVAC Equipment Room Safe Shutdown Capability Affected by Smoke Migration2015Q3The team identified a finding of very low safety significance (Green) involving a non-cited violation of 10 CFR 50 Appendix R, III.L.3. for failure to establish an alternative safe shutdown capability independent of the Unit 1 control room HVAC equipment room, sub-fire area CR-2. Specifically, a fire in CR-2 will generate heat and smoke that will rise to the Unit 1 main control room where post-fire safe shutdown equipment is remotely operated in response to a fire in CR-2. This issue was determined to satisfy the criteria specified for the exercise of enforcement discretion for plants in transition to a fire protection program that meets the requirements of 10 CFR 50.48(c), National Fire Protection Association Standard NFPA 805. Description. The team reviewed the Updated Fire Protection Appendix R Report, Rev. 31 for BVPS Unit 1 and noted that Duquesne Light Company filed an exemption request on January 14, 1985, in part for fire area CR-2, from the requirements of 10 CFR 50, Appendix R. The exemption request also redefined CR-2 as a subarea of the main control room fire area, CR-1, based on a ventilation shaft traversing the CR-2 ceiling and CR-1 floor. The exemption request redefined CR-2 and CR-1 as a single alternative shutdown fire area in accordance with Section III.G.3 of Appendix R. The NRC approved the exemption request in a letter dated December 4, 1986. The team noted that Duquesne Light Companys exemption request justified adequate separation for safe shutdown systems and fire suppression and detection within the affected fire area, but did not identify that operators would be required to remain in the main control room to operate safe shutdown equipment for a fire in CR-2. This is unlike the established safe shutdown capability for the main control room where operators would leave the main control room to locally operate safe shutdown equipment. Local operation of safe shutdown equipment ensured equipment and circuits were isolated from the effects of the fire and operators would not be subject to smoke or heat. The team noted that Updated Fire Protection Appendix R Report, Rev. 31 credited safe shutdown equipment for a fire in CR-2 to be operated from the main control room and procedure 1OM-56B.4.C, Safe Shutdown Following A Serious Fire in the Control Building, Rev. 12, specific to fires in CR-2 and CR-3, the relay room, provided operating instructions consistent with the fire safe shutdown analysis. The team additionally noted that the unqualified fire damper in the ventilation shaft between CR-2 and CR-1 can only be operated at a local panel inside CR-2. The team considered that operators remaining in the main control to establish post-fire safe shutdown for a fire in CR-2 was an alternative safe shutdown capability that was not independent of the fire area. In response to the teams concern for smoke and heat rising from CR-2 affecting operator visibility or main control room habitability, FENOC provided calculation, SCI- 17756-03, NFPA 805 Fire PRA Task 11c, Multi Compartment Fire Analysis for BVPS Unit 1, Rev. F. Attachment 3 of this calculation analyzed the potential for propagation of hot gases into the main control room via the non-fire rated ventilation duct shaft. The team determined the analysis was conservative and concluded that operators could remain in the main control room and would have more than one hour to initiate the Unit 2 main control room ventilation system in smoke purge mode. The team judged that procedure 1OM-56B.4.C, Safe Shutdown Following A Serious Fire in the Control Building, Rev. 12, was deficient because it did not provide any caution to control room operators that a fire in CR-2 could generate heat and smoke that could rise to the main control room. Additionally, the procedure did not provide any instructions to remove the heat and smoke such as by placing the Unit 2 main control room ventilation system in smoke purge mode. FENOC promptly entered this safe shutdown issue into their corrective action program (CAP) as CR-2015-10577 and intended to revise 1OM-56B.4.C, Safe Shutdown Following A Serious Fire in the Control Building, to include a note to initiate smoke purge mode of the Unit 2 control room ventilation system as needed for a fire in CR-2. The team considered FENOCs corrective actions appropriate. Analysis. The failure to establish an alternative safe shutdown capability independent of the Unit 1 control room HVAC equipment room, sub-fire area CR-2, is a performance deficiency (PD). This PD is more than minor because it is associated with the external events (fire) attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. Using IMC 0609, Appendix F, Fire Protection Significance Determination Process, the team determined that this issue screens to Green in task 1.3.1 because the reactor is able to reach and maintain safe shutdown: a conservative calculation determined the main control room operators would not be impaired. Cross-cutting aspects are not applicable to findings involving enforcement discretion. Enforcement. 10 CFR 50.48(b)(2) requires that all nuclear power plants licensed to operate before January 1, 1979, must satisfy the applicable requirements of 10 CFR 50, Appendix R, including specifically the requirements of Sections III.G, III.J, and III.O. 10 CFR Part 50, Appendix R, Section III.G.2 requires, in part, that, where cables or equipment of redundant trains of systems necessary to achieve and maintain hot shutdown conditions are located within the same fire area outside of primary containment, one of the stated means of ensuring that one of the redundant trains is free of fire damage shall be provided. The stated means include separation of cables and equipment and associated non-safety circuits of redundant trains through the use of specified fire barriers, distance, or suppression systems. 10 CFR part 50, Appendix R, Section III.G.3 requires, in part, that alternative or dedicated shutdown capability should be provided where the protection of systems whose function is required for hot shutdown does not satisfy the requirement of paragraph G.2 of this section. 10 CFR Part 50, Appendix R, Section III.L.3, in part, specifies that alternative shutdown capability shall be independent of the specific fire area. Contrary to the above, since December 4, 1986, BVPS Unit 1, a nuclear power plant licensed to operate before January 1, 1979, has not satisfied the applicable requirements of 10 CFR 50, Appendix R, Section III.G, in that the licensee did not provide alternative shutdown capability that was independent of a specific fire area where the protection of systems whose function is required for hot shutdown was not ensured to be free of fire damage. Specifically, for a fire in CR-2, FENOC required operators to remain in the main control room to operate safe shutdown equipment. However, the main control room was not independent of the fire area, since the main control room will be impacted by heat and smoke generated from a fire in CR-2. The violation was historical and occurred when Duquesne Light Company, a predecessor to FENOC, implemented a January 14, 1985, exemption request from the requirements of Appendix R. FENOC is in transition to NFPA 805 and, therefore, this NRC-identified violation was evaluated in accordance with the criteria established in Section 9.1 of the NRC Enforcement Policy, Enforcement Discretion for Certain Fire Protection issues (10 CFR 50.48). Specifically, because all of the criteria were met, the NRC is exercising discretion and not issuing a violation for this issue.
05000334/FIN-2015003-01Failure to Correct a Low Oil Level in the Condensate Pump Motor2015Q3A self-revealing finding was identified for FENOCs failure to correct a low oil level in the lower motor bearing of the Unit 1 A condensate pump in accordance with NOP-LP- 2001, Corrective Action Program. Specifically, FENOC incorrectly cancelled the work order to add oil to the A condensate pump motor and installed a placard on the oil level sight glass with incorrect minimum and maximum oil levels. This led to the motor bearing failure, which caused the pump to trip on overcurrent, and required the operators to insert a manual reactor trip. FENOC entered the issue into their correct action program, condition report (CR) 2015-05256. The performance deficiency was more-than-minor because it was associated with the human performance attribute of the Initiating Events cornerstone, and adversely affected the cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, NOP-LP-2001, section 4.2.3, states that condition report/correct action owners should ensure that actions are developed to resolve the primary cause identified in the condition report. Instead of correcting the low oil level in the motor, FENOC cancelled the work order to add oil. This subsequently caused the operators to trip the plant when the condensate pump motor bearing overheated and the motor tripped on overcurrent. The inspectors determined that this finding was of very low safety significance (Green) because it did not cause a reactor trip and the loss of mitigation equipment. This finding has a crosscutting aspect in the area of Human Performance, Consistent Process, because FENOC did not seek input from the appropriate work group (engineering) prior to cancelling the work order to add oil to the condensate pump motor (H.13)
05000334/FIN-2015008-01Failure to Initiate a Condition Report for an Adverse Condition2015Q2A Green self-revealing finding of NOP-LP-2001, Corrective Action Program, was identified after FENOC failed to generate a condition report for a condition adverse to quality. Specifically, FENOC did not initiate a condition report when a lifted lead was identified during preventative maintenance and installation of the Unit 1 main transformer. As a result, corrective actions were not taken and this led to an unplanned downpower from 100 percent to 15 percent reactor power on January 31, 2014. The performance deficiency was more-than-minor because it was associated with the Equipment Performance attribute of the Initiating Events cornerstone, and adversely affected the cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. This finding was determined to be of very low safety significance (Green), because it did not cause a reactor trip and the loss of mitigation equipment. This finding has a cross-cutting aspect in the area of Human Performance, Field Presence, because FENOC failed to ensure supervisory and management oversight of work activities, including contractors and supplemental personnel (H.2).
05000334/FIN-2015002-01Failure to Utilize Respiratory Protection as Specified by the Radiation Work Permi2015Q2The inspectors identified a self-revealing NCV of Technical Specification 5.4.1, Procedures, for FENOCs failure to utilize respiratory protection, as required by the applicable radiation work permit (RWP), for entry into the 722-foot elevation of the solid radioactive waste building on March 12, 2014. This resulted in the unplanned internal exposure of one worker. Immediate corrective actions included reestablishing RWP controls of the area and entering this issue into their corrective action program as condition report 2015-06636. The inspectors determined that the performance deficiency is more than minor because it affected the Program and Process attribute of the Occupational Radiation Safety cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. The inspectors evaluated the finding using NRC Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, and determined the finding to be of very low safety significance (Green) because it was not related to as low as (is) reasonably achievable (ALARA), did not result in an overexposure or a substantial potential for overexposure, and did not compromise the licensee's ability to assess dose. The finding has a cross-cutting aspect of Human Performance, Conservative Bias, in that individuals did not use decision making-practices that emphasized prudent choices over those that are simply allowable. Specifically, a radiation protection technician did not use conservative decision making practices and make prudent choices when entering an area with unknown radiological conditions. Examples of non-conservative decision making included: failure to wear respiratory protection when entering into unknown radiological conditions, the failure to complete and evaluate an air sample prior to entry, and not taking into account the adverse radiological conditions of the adjoining area above (735 foot elevation). (H.14)
05000412/FIN-2015002-02Failure to Perform Maintenance in accordance with Licensee Maintenance Process2015Q2A self-revealing finding was identified for FENOCs failure to perform maintenance on the Unit 2 feedwater heater drain system in accordance with FENOCs maintenance process, NOP-WM-4006, Conduct of Maintenance. Specifically, FENOC did not adjust the A first point feedwater heater normal and high level control valve (LCV) controllers to their specified setpoints. As a result, the A heater and separator drain pumps tripped and this led to an unplanned power reduction from 100 percent to 60 percent reactor power on April 12, 2015. FENOCs corrective action included adjusting the setpoints of the LCV controllers to their specified setpoints and entering the issue into their corrective action program as condition report 2015-05088. The performance deficiency was more-than-minor because it was associated with the Configuration Control attribute of the Initiating Events cornerstone, and adversely affected the cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Additionally, the performance deficiency was similar to example 4.b in IMC 0612 Appendix E, in that failing to follow procedure caused a reactor transient. This finding was determined to be of very low safety significance (Green) because it did not cause a reactor trip and the loss of mitigation equipment. This finding has a cross-cutting aspect in the area of Human Performance, Training, because FENOC failed to ensure knowledge transfer to maintain a knowledgeable, technically competent workforce and instill nuclear safety values. Specifically, FENOC did not ensure that knowledge was adequate to perform maintenance on the A first point feedwater heater LCVs (H.9).
05000334/FIN-2014007-01Security2014Q4
05000334/FIN-2014403-01Security2014Q4
05000334/FIN-2014005-02Failure to Properly Ship Category 2 Radioactive Material2014Q4The inspectors identified an NCV of 10 CFR 71.5, Transportation of licensed material, and 49 CFR 172, Subpart I, Safety and Security Plans. Specifically, FENOC personnel shipped a category 2 radioactive material of concern (RAM-QC) on public highways to a waste processor without adhering to a transportation security plan. FENOCs corrective actions included revising procedure NOP-OP-5201, Shipment of Radioactive Material Waste, to reflect the appropriate Department of Transportation requirements for shipment of Category 2 radioactive material. FENOC entered the issue into their corrective action program as CR 2014-17260. The issue is more than minor because it is associated with the Program and Process attribute of the Public Radiation Safety cornerstone and adversely affected its objective to ensure the safe transport of radioactive material on public highways in accordance with regulations. The finding was determined to be of very low safety significance (Green) because FENOC had an issue involving transportation of radioactive material, but it did not involve: (1) a radiation limit that was exceeded; (2) a breach of package during transport; (3) a certificate of compliance issue; (4) a low level burial ground nonconformance; or (5) a failure to make notifications or provide emergency information. The inspectors determined that the finding did not have a cross-cutting aspect because the issue was not reflective of current plant performance. Specifically, FENOC implemented changes to the radioactive waste shipment procedure that addressed applicable requirements and implemented a formal process for reviewing pending regulatory changes for impacts to FENOC operations and support activities.
05000334/FIN-2014005-01Failure to Adequately Implement Risk Management Actions2014Q4The inspectors identified an NCV of 10 CFR 50.65(a)(4), Requirements for monitoring the effectiveness of maintenance at nuclear power plants, for FENOCs failure to implement adequate risk management actions (RMAs) associated with maintenance on the alternate intake structure A bay. Specifically, FENOC did not establish a contingency plan for the maintenance activity as required by FENOCs risk management procedure. FENOC entered the issue into their corrective action program as CR 2015-00267. The performance deficiency is more than minor because it is associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected its objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, FENOCs failure to implement a contingency plan resulted in an increase in the duration of an elevated risk condition and unavailability of equipment relied upon to mitigate the consequences of a loss of the main intake structure. The finding was determined to be of very low safety significance (Green) because the incremental core damage probability (ICDP) for the event was less than 1.0 E-6. The inspectors determined that this finding had a cross-cutting aspect in the Human Performance, Work Management, because the FENOC work process failed to adequately manage the risk commensurate to the work (H.5).
05000412/FIN-2014004-01Inadequate Plant Startup Procedure Led to Manual Reactor Trip2014Q3A self-revealing NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings was identified for FENOCs failure to have an adequate plant startup procedure. Specifically, 2OM-52.4A, Raising Power from 5% to Full Load Operation, did not adequately address plant startup with one condensate pump in operation. This led to an inability to adequately control steam generator (SG) level when the second condensate pump was started which required the operators to trip the reactor. FENOC is in the process of implementing corrective actions to revise procedure 2OM-52.4A and to address the human performance errors associated with this event. Additionally, FENOC entered the issue into their corrective action program as condition report (CR) 2014-09256. The finding is more than minor because it is associated with the procedure quality and human performance attributes of the Initiating Events cornerstone and affected the cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the inadequate procedure led to SG level fluctuations that could not be adequately controlled when the second condensate pump was started, and required the operators to trip the reactor. The inspectors determined that this finding is of very low safety significance (Green), because while it did result in a reactor trip, it did not cause a loss of mitigation equipment relied upon to transition the plant from the onset of a trip to a stable shutdown condition. The finding has a cross-cutting aspect in Human Performance, Challenge the Unknown, because FENOC operators did not stop when faced with uncertain conditions. Specifically, the adequacy of the procedure was not sufficiently questioned when the plant was not in the normal start up configuration of two running condensate pumps nor later when the condensate pump discharge header pressure low alarm occurred.
05000412/FIN-2014003-01Failure to Follow Procedure Results in Inoperable SI Accumulator2014Q2A self-revealing NCV of technical specification (TS) 5.4.1 was identified because the unit 2 B safety injection (SI) accumulator was made inoperable when FENOC operators did not follow procedural requirements to align nitrogen to the accumulator. Specifically, the operators did not align the nitrogen header to the accumulator prior to opening the valve to repressurize the accumulator. The inspectors noted that this resulted in the accumulator pressure falling below the TS pressure limit which required FENOC to declare the accumulator inoperable. FENOCs corrective actions included immediately realigning the system, restoring accumulator pressure and entering the issue into their corrective action program, CR 2014-09260. The performance deficiency is more than minor because it is associated with the configuration control attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, FENOC did not have reasonable assurance that the nitrogen pressure in the B SI accumulator was sufficient to ensure injection into the core during an accident due to the misalignment of the nitrogen header. This finding is of very low safety significance (Green) because the performance deficiency was not a design or qualification deficiency, did not involve an actual loss of safety function, did not represent actual loss of a safety function of a single train for greater than its technical specification allowed outage time, and did not screen as potentially risk-significant due to a seismic, flooding, or severe weather initiating event. This finding has a cross-cutting aspect in the area of Human Performance, Avoid Complacency, because FENOC operators did not recognize the possibility of mistakes and did not implement appropriate error reduction tools while attempting to re-pressurize the B SI accumulator. (H.12)
05000334/FIN-2014003-03Licensee-Identified Violation2014Q2Technical Specification 5.7.2, High Radiation Area, requires, in part, that locked doors be provided for each high radiation area in which the intensity of radiation exceeds 1000 millirem per hour. Contrary to the above, on April 26, 2014, for approximately 2.5 hours, the door to the Regenerative Heat Exchanger room was not locked. FENOCs immediate corrective action included placing chains and padlocks on this door and all similar style entrances to locked high radiation areas, entering this issue into their corrective action program (CR-2014-07646), and performing a root cause evaluation. The finding is of very low safety significance, Green, because it did not involve ALARA, there was no overexposure, there was no substantial potential for an overexposure, and the ability to assess dose was not compromised.
05000334/FIN-2014003-02Removal of Missile Barrier Renders Containment Inoperable2014Q2The inspectors identified a Green non-cited violation of TS limiting condition for operation (LCO) 3.6.1, Containment. Specifically, the inspectors determined that FENOC removed the missile barriers for the unit 1 and unit 2 containment equipment hatches while in a mode when containment was required to be operable. As a result FENOC did not have adequate tornado protection for containment and then did not take the actions directed by the LCO action statement when the LCO was not met. FENOC entered the issue into their corrective action program, CR 2014-11878, and placed the procedures to remove the missile barriers on administrative hold. The performance deficiency is 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 protect the public from radionuclide releases caused by accidents or events. In accordance with IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 3, Barrier Integrity Screening Questions, this finding screens to Green, very low safety significance. This finding has a cross-cutting aspect in the area of conservative bias where individuals use decision making-practices that emphasize prudent choices over those that are simply allowable and that a proposed action is determined to be safe in order to proceed, rather than unsafe in order to stop. Specifically, FENOC did not adequately consider the containment operability implications of removing the missile barriers for the unit 1 and unit 2 containment equipment hatches while in a mode where containment is required to be operable. (H14)
05000334/FIN-2014002-03Licensee-Identified Violation2014Q110 CFR 50.54(q)(2) Conditions of Licenses requires, in part, that licensees maintain an emergency plan that meets the requirements of 10 CFR 50, Appendix E and the planning standards in 10 CFR 50.47(b). 10 CFR 50.47(b)(4) requires use of a standard emergency classification and action level (EAL) scheme. Additionally, 10 CFR 50, Appendix E, Section IV.C.2 states that the licensee maintain the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications that an EAL has been exceeded. Contrary to the above, on March 2, 2014, FENOC failed to declare a Notification of Unusual Even (NOUE) in a timely manner. Specifically, while performing an evolution to fill the safety injection accumulator, a containment residual heat removal system smoke alarm was received at 9:20 pm on March 1, 2014. The Shift Manager determined the alarm was invalid and was likely due to a relief valve that lifted during the fil evolution causing the smoke alarm. However, the EAL basis for HU4, Fire within the Protected Area not extinguished within 15 minutes, specifies that the alarm must be assumed to be an indication of a fire unless a person on scene can disprove the alarm within 15 minutes. After further review, FENOC determined that conditions did exist for an NOUE, in accordance with EAL HU4, and declared a NOUE at 12:13 am on March 2, 2014. The finding was determined to be of very low safety significance (Green) in accordance with Section 4.3 and Attachment 1 of IMC 0609 Appendix B, Emergency Preparedness SDP, for failing to adequately implement the emergenc plan by not making an emergency declaration (NOUE) during an actual event in a timely manner. This event was documented in FENOCs corrective action program as CR 2014-04517.
05000334/FIN-2014002-02Main Transformer Fault due to Static Electrification2014Q1A self-revealing, Green finding was identified because FirstEnergy Nuclear Operating Company (FENOC) did not evaluate technical information provided in a vendor report as required by FENOC procedures: 1/2-ADM-2017, Control of Vendor Technical Information and NOP-CC-1003, Vendor Manuals and Vendor Technical Information. Specifically, FENOC did not take action to address the recommendation in the ABB Inc.Life Assessment Report, dated September 2, 2008, to prevent the running of all the main transformer oil pumps when the oil temperature is below 50C. As a result on January 6, 2014 the Beaver Valley main transformer failed resulting in a reactor trip. Following the trip FENOC conducted an apparent cause evaluation and determined the transformer failure resulted from static electrification caused by improper cooling system operation. FENOC subsequently performed corrective actions included a review of engineering training and updating the operating procedures for the main transformer at both units. The inspectors determined the actions to be reasonable. The inspectors determined the performance deficiency is more than minor because it is associated with the equipment performance attribute of the Initiating Events cornerstone, and adversely impacted 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 main transformer faulted due to improper guidance on transformer cooling bank operation which resulted in a plant trip. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 1 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, the inspectors determined that this finding is of very low safety significance (Green) because the performance deficiency did not cause both a reactor trip and the loss of mitigating equipment. This finding has a cross-cutting aspect in the area of Human Performance, Design Margin, in that FENOC did not ensure that equipment margin was carefully guarded and changed through a systematic and rigorous process. Specifically, FENOC did not ensure that the vendor technical review process implemented main transformer operating margin guidance that resulted in the failure of the transformer (H.6).
05000334/FIN-2014002-01Inadequate Post Maintenance Testing Procedures Resulted in TDAFW Pump Inoperability2014Q1A self-revealing, Green NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified because FENOC did not establish appropriate post maintenance test procedures for the Turbine Driven Auxiliary Feedwater (TDAFW) pump following trip/throttle valve maintenance that required the removal and reinstallation of the governor. Specifically, FENOC identified in their apparent cause evaluation that vendor technical information regarding the verification of stable governor operating temperature following governor compensating needle valve adjustment was not incorporated into surveillance and post maintenance testing procedures. Because of this omission FENOC did not identify an incorrect governor compensating needle valve adjustment during post maintenance testing on November 1, 2103 and declared the TDAFW pump operable when it was not able to perform its safety function. As a result, the TDAFW pump tripped on overspeed following a reactor trip on January 6, 2014. Following the event, FENOC entered the issue into the corrective action program (CR-2014-0177), performed an apparent cause evaluation, and took corrective actions to update TDAFW pump surveillance and maintenance procedures to ensure the establishment of a stable governor temperature during post maintenance testing runs. The inspectors determined the actions to be reasonable. The inspectors determined the performance deficiency is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and adversely impacted the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the inadequate post maintenance testing procedure resulted in the inoperability of the TDAFW pump. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 1 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, the inspectors determined that a detailed risk evaluation was required because the finding represented an actual loss of function of a single train of auxiliary feedwater (AFW) for greater than its Technical Specification allowed outage time. The detailed risk evaluation determined that the finding was of very low safety significance (Green). This finding did not have a cross-cutting aspect because the most recent opportunity for FENOC to include the appropriate vendor information in the post maintenance testing procedure was in 2009 and is not indicative of current performance.
05000334/FIN-2013008-01Untimely Problem Identification and Corrective Action for Degraded Auxiliary Feedwater Pump Steam Supply Valve2013Q4The inspectors identified a finding of very low safety significance involving a noncited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, related to FENOCs problem identification and corrective action to address the November 2011 failure of steam driven auxiliary feedwater (SDAFW) pump steam supply valve 2MSS-SOV105C. Specifically, the inspectors identified that FENOC did not promptly identify and correct the elevated valve temperature condition that led to the coil failure of a solenoid operated steam admission valve for the SDAFW pump. Consequently, 2MSS-SOV105C failed again on June 19, 2012, due to solenoid insulation damage which resulted from elevated valve temperature. FENOC entered this issue into the corrective action program for resolution as condition report 2013-19448, updated procedures to evaluate elevated temperatures on SDAFW pump steam admission valves, and initiated condition report 2013-19250 to evaluate the adequacy of planned maintenance on the valves. The finding was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, FENOC did not ensure that adequate operational margin was available when 2MSS-SOV105C steam leak-by caused the valve actuator solenoid temperature to exceed 356F. Consequently, seven months following the valve actuator solenoid coil replacement, coil insulation degraded and rendered 2MSS-SOV105C inoperable and unavailable. In accordance with IMC 0609.04, Initial Characterization of Findings, and IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, dated June 19, 2012, the inspectors determined that this finding was of very low safety significance (Green). This finding has a cross-cutting aspect in the area of Human Performance, Resources, because FENOC did not ensure that personnel, equipment, procedures, and other resources were available and adequate to support operability of safety-related equipment. Specifically, design margin was not maintained for a safety-related solenoid-operated valve which resulted in its failure and the long-standing equipment issue of leak-by past the valve was not addressed through adequate monitoring and preventive maintenance of the valve solenoid.
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