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05000324/FIN-2016004-0131 December 2016 23:59:59BrunswickNRC identifiedFailure to Submit a Licensee Event Report for a Condition Prohibited by Technical SpecificationSL IV. An NRC-identified severity level (SL) IV NCV of 10 CFR 50.73(a)(2)(i)(B) was identified for the failure of the licensee to provide a written report to the NRC within 60 days of identifying a condition which was prohibited by plant Technical Specifications (TSs). The licensee entered this issue into the corrective action program (CAP) as nuclear condition report (NCR) 2091608. The inspectors had previously evaluated the underlying technical issue and determined the failure to promptly identify and correct a condition adverse to quality, which resulted in the condition prohibited by Technical Specifications (TS), was a performance deficiency. The issue was documented as a Green NCV, 05000325;324/2016002-01, Failure to Identify Broken Auto Start Control Relay on Emergency Diesel Generator 1. The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it was necessary to address this violation which involved a failure to make a required report to the NRC and was considered to impact the regulatory process, using traditional enforcement to adequately deter non-compliance. Using the NRC Enforcement Policy, Section 6.9.d.9, the SL assigned to this violation was SL IV, because the licensee failed to make a report required by 10 CFR 50.73. This violation also meets the criteria for an NCV because it was not repetitive or willful, and was entered into the licensees CAP. Traditional enforcement violations are not assessed for cross-cutting aspects.
05000324/FIN-2016004-0231 December 2016 23:59:59BrunswickLicensee-identifiedLicensee-Identified ViolationThe following violation was identified by the licensee and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as a SL IV NCV. 10 CFR 55.33(e), states in part, To maintain an active status, a license holder shall actively perform the functions of an operator or senior operator on a minimum of seven 8-hour or five 12-hour shifts per calendar quarter. (f) If paragraph (e) is not met, before resumption of authorized representative of the facility licensee shall certify...(2) That the licensee has completed a minimum of 40 hours of shift function under the direction of an operator or senior operator as appropriate and that the position to which the individual will be assigned. The 40 hours must have included a complete tour of the plant and all required shift turnover procedures. 0 OI-01-01.05, License Activation and Maintenance, is a licensee written procedure to ensure 10 CFR 55.53(f) requirements are satisfied. Section 5.3.2(d) states, An inactive licensee must stand a minimum of four 12 hour shifts under the direction of an active license holder and in the position to which the individual will be assigned. The time on shift must have included a complete tour of the plant and all required shift turnover procedures under the direction of a Shift Manager or Control Room Supervisor with an active license. Contrary to the above, on October 16, 2016, the licensee identified that they failed to properly reactivate a licensed senior reactor operator (SRO) on June 10, 2016 and subsequently allowed the operator to stand watch in active licensed positions for a four month period. Because this issue had no adverse impacts to nuclear safety, no incidents or incorrect assessments made during this time frame by the individual in question, and the event has been entered into the licensees CAP as NCR 2070317, this violation is being treated as a SL IV NCV, consistent with the NRC Enforcement Policy.
05000324/FIN-2016003-0530 September 2016 23:59:59BrunswickLicensee-identifiedLicensee-Identified Violation10 CFR 50.9, Completeness and Accuracy of Information, requires, in part, that information required by statute or by the Commission's regulations, orders, or license conditions to be maintained by the licensee shall be complete and accurate in all material respects. WOs associated with safety-related activities are designated as quality-related records that are required to be maintained by the licensees Quality Assurance Program. Contrary to the above, on March 23, 2015, a contract QC inspector deliberately falsified the quality record for WO 2281641-05, resulting in the licensees maintaining of information that was incomplete and inaccurate. The WO is material to the NRC, as it provides documented evidence of compliance with QC inspection requirements. Using traditional enforcement, the SL assigned to this violation was SL IV, because there was a deliberate violation of regulatory requirements, and resulted in no or relatively inappreciable potential safety consequences. This violation also meets the criteria for a NCV because the licensee identified the violation and promptly provided the information concerning the violation, to the NRC. This issue was documented in the licensees CAP as NCR 739864.
05000324/FIN-2014004-0530 September 2014 23:59:59BrunswickNRC identifiedImplementation of Dry Cask Annulus Cooling to Remain in an Analyzed Thermal ConditionAn NRC-identified Severity Level IV (SLIV) non-cited violation (NCV) of very low safety significance of 10 CFR 72.150, Instructions, Procedures, and Drawings, was identified for the failure of the licensee to have adequate procedures to ensure the design basis peak fuel cladding limit would not be exceeded during outer transfer cask draining operations. Specifically, on August 25, 2014, Licensee Procedure IFS-NGGC-0016, ISFS DSC Sealing Operations, did not include a 24-hour waiting period between flushing an draining the annulus region of the cask before moving the cask to the storage facility, t ensure that the fuel cladding temperature limits are not exceeded. The inspectors determined the failure to have an adequate procedure to ensure the design basis peak fuel cladding limit would not be exceeded during draining operations was a performance deficiency. Consistent with guidance in Section 2.2 of the NRC Enforcement Policy, Independent Spent Fuel Storage Installations (ISFSIs) are not subject to the SDP and, thus, traditional enforcement will be used for these facilities. The inspectors determined the violation was more than minor because, if left uncorrected, the failure to allow a proper cooldown of the fuel after flushing, prior to draining to move the cask, coul lead to a more significant safety concern in that fuel damage could occur. Consistent with the guidance in Section 2.6.D of the NRC Enforcement Manual, if a violation does not fit an example in the Enforcement Policy Violation Examples, it should be assigned a severity level: (1) Commensurate with its safety significance; and (2) informed by similar violations addressed in the Violation Examples. The inspectors found no similar violations in the Violations Examples. Since the licensee waited 24 hours prior to the final drain down, the violation was determined to be of very low safety significance (Severity Level IV). Crosscutting aspects are not assigned to traditional enforcement violations. The licensee documented this issue in the Corrective Action Program (CAP) as NCR 705130.
05000324/FIN-2013003-0730 June 2013 23:59:59BrunswickNRC identifiedFailure to Update the UFSAR for the Removal of the Chlorine Detection SystemAn NRC-identified SLIV NCV of 10 CFR 50.71(e) was identified for the licensees failure to revise the UFSAR with information consistent with plant conditions. Specifically, from August 6, 2006 to the present, the licensee did not remove reference to or correct information to reflect current plant conditions related for the chlorine detection system used by the CREV in UFSAR Sections 6.4, Habitability System and 9.4.1, Control Building Ventilation System. The licensees corrective actions include revising the UFSAR. The licensee entered this issue into the CAP as NCR 614474. The inspectors determined the failure of the licensee to update the UFSAR after removing the chlorine detection function from the safety-related CREV as required by 10 CFR 50.71.e and in accordance with Procedure REG-NGGC-0101, Final Safety Analysis Report Revisions, was a performance deficiency. This issue is considered within the traditional enforcement process because it has the potential to impede or impact the NRCs ability to perform its regulatory functions. The inspectors used the Enforcement Policy, Supplement I Reactor Operations, to evaluate the significance of this violation. Similar to Enforcement Policy, Section 6.1, example d.3, the inspectors determined the violation was a SLIV violation since the erroneous information not updated in the UFSAR has not resulted in any unacceptable change to the facility or procedures.
05000324/FIN-2009002-0231 March 2009 23:59:59BrunswickNRC identifiedFailure to Perform a 10 CFR 50.59 Evaluation for a Plant Modification (Section 1R18)The inspectors identified a severity level IV NCV of 10 CFR 50.59, Changes, Tests, and Experiments for failing to perform a written safety evaluation prior to implementing a change to the facility as described in the Updated Final Safety Analysis Report (UFSAR), when the Unit 1 and Unit 2 reactor building instrument air standby compressors were permanently abandoned. The licensee entered the issue into their corrective action program and performed a written safety evaluation of the condition. The inspectors determined that, until identified by NRC inspectors, the licensee had not performed a 10 CFR 50.59 safety evaluation for the abandonment of the instrument air standby compressors, and this is a performance deficiency. Because this is a violation of 10 CFR 50.59, it is considered to be a violation which potentially impedes or impacts the regulatory process. Therefore, such violations are dispositioned using the traditional enforcement process instead of the Significance Determination Process. This finding was determined to be more than minor because their was a reasonable likelihood that the change requiring a 10 CFR 50.59 safety evaluation would require Commission review and approval prior to implementation in accordance with 10 CFR 50.59(c)(2). This likelihood is based on the increased likelihood of loss of reactor building instrument air, reactor scram, and closure of the outboard MSIVs, which is an occurrence of a malfunction of a structure, system, or component (SSC) that is analyzed in the UFSAR. To determine the significance of the violation, the inspectors completed a significance determination review using IMC 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At Power Situations. The finding impacted the initiating events cornerstone. Because the finding does not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions will not be available, this finding has very low safety significance. The cause of the finding is not related to a cross-cutting aspect because the performance deficiency is not indicative of current licensee performance. (Section 1R18