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05000461/FIN-2017004-0431 December 2017 23:59:59ClintonNRC identifiedFailure to Perform an Evaluation in Accordance with 10 CFR 72.48 for Changes Made to the Time-to-Boil CalculationThe inspectors identified a Severity Level IV non-cited violation of 10 CFR 72.48(d)(1), Changes, Tests, and Experiments, for the licensees failure to perform a written evaluation which provides the bases for the determination that changes do not require a Certificate of Compliance amendment pursuant to 10 CFR 72.48(c)(2). Specifically, the licensee accepted Engineering Change Order ECO501825R0 (1), ECO501848R1 (1), and ECO501848R1 (4) on June 20, 2016, to the time-to-boil calculation as described in the HI-STORM FW Final Safety Analysis Report and incorrectly screened out performing an evaluation of those changes in accordance with 10 CFR 72.48. The licensee documented this issue in its CAP as AR 02714091 and AR 04081583. The licensee is performing a 10 CFR 72.48 evaluation for Engineering Change Order ECO501825R0 (1) and ECO501848R1 (4) while planning to revise the acceptance of ECO501848R1(1). The inspectors determined that the violation was of more than minor significance as the inspectors could not reasonably conclude that the above changes did not require prior NRC approval. The violation screened as a Severity Level IV non-cited violation using example 6.1.d.2 of the NRC Enforcement Policy. No cross-cutting aspect was identified since cross-cutting aspects are not assigned to traditional enforcement violations.
05000461/FIN-2016004-0231 December 2016 23:59:59ClintonSelf-revealingDry Cask Storage Procedures Were Not Adequate to Ensure Correct Field ConfigurationSeverity Level IV: A self-revealed violation of 10 CFR 72.150, Instructions, Procedures, and Drawings, was identified for the failure of the licensee to ensure that ISFSI procedures contained the appropriate level of detail for the circumstances such that important loading activities would be satisfactorily accomplished. Specifically, procedure HPP2226200, Revision 0, MPC Loading at Clinton, was not adequate to ensure that the Multi-Purpose Canister (MPC) was correctly oriented in the transfer cask (HI-TRAC) and procedure HPP2226300, Revision 4, MPC Sealing at Clinton, was not adequate to ensure that two thermocouples were appropriately installed during the hydrostatic test of the MPC. The licensee documented these issues in its corrective action program and took timely corrective actions. The violation was determined to be of more than minor significance using IMC 0612, Power Reactor Inspection Reports, Appendix E, Examples of Minor Issues. Example 4e is applicable to this violation in that the MPC was incorrectly oriented in the transfer cask and then loaded with spent fuel in this incorrect configuration. Example 4b is also applicable to this violation in that unexpected leakage occurred during the hydrostatic test as a result of the failure to install the thermocouples. Cross-cutting aspects are not assigned to traditional enforcement violations.
05000461/FIN-2016009-0331 December 2016 23:59:59ClintonNRC identifiedFailure to Amend the UFSAR Indicating Choice to Comply with 10 CFR 50.68(b)The team identified a Severity Level-IV NCV of 10 CFR 50.68, Criticality Accident Requirements, Paragraph (b)(8), for the licensee failure to amend the Updated Final Safety Analysis Report (UFSAR) to indicate they chose to comply with 10 CFR 50.68(b). Specifically, in 2005, the licensee chose to comply with 10 CFR 50.68(b) but did not amend the UFSAR following the issuance of the associated license amendment. The licensee captured this issue in their CAP as AR 02741851, reasonably confirmed compliance with 10 CFR 50.68(b) requirements (1) through (7) was maintained, and initiated plans to update the UFSAR to specifically indicate that Clinton Power Station chose to comply with 10 CFR 50.68(b). The Significance Determination Process does not specifically consider the impact to the regulatory process in its assessment of licensee performance. Therefore, it was necessary to address this violation, which potentially impacts the NRCs ability to regulate, using traditional enforcement to adequately deter non-compliance. Specifically, failure to update the UFSAR challenges the regulatory process because it serves as a reference document used, in part, for recurring safety analyses, evaluating License Amendment Request, and in preparation for and conduct of inspection activities. The team determined the traditional enforcement violation was a Severity Level-IV violation in accordance with Section 6.1.d.3 of the Enforcement Policy because the un-updated UFSAR had not been used to evaluate a facility or procedure change that resulted in a condition evaluated as having low-to-moderate or greater safety significance by the Significance Determination Process. However, it had a material impact on safety or licensed activities. Specifically, the un-updated UFSAR could be used to perform evaluations of facility or procedure changes, which would have the potential to result in unacceptable conditions and/or regulatory decisions. Traditional enforcement violations are not assessed for cross-cutting aspects.
05000461/FIN-2016002-0830 June 2016 23:59:59ClintonNRC identifiedFailure to Update the Updated Safety Analysis Report (USAR) Peak Suppression Pool TemperatureThe inspectors identified a Severity Level IV NCV of 10 CFR 50.71(e), Periodic Update of the (Final Safety Analysis Report) FSAR, for the licensees failure to update the USAR after updating a Safety Analysis Calculation. Specifically, the licensee did not update the USAR Section A3.8.3.1 and Table 15.2.91 to coincide with the most recent updates to the accident analysis of record. The licensee initiated AR 2664276 to document the discrepancy in the peak suppression pool temperature throughout the USAR and initiated actions to revise FSAR Section A3.8.3.1 and Table 15.2.91 to coincide with the most recent revision to EPUT0400. The inspectors determined that the failure to update the USAR in accordance with 10 CFR 50.71(e), Periodic Update of the FSAR, with the most accurate version of calculated peak suppression pool temperature during an accident was a performance deficiency. The performance deficiency was determined to be minor in accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated September 7, 2012; however, the reactor oversite programs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance, therefore, it was necessary to address this violation which impeded the NRCs ability to regulate using traditional enforcement to adequately deter non-compliance. The inspectors reviewed this issue in accordance with IMC 0612 and the NRC Enforcement Policy. Violations of 10 CFR 50.71(e) are dispositioned using the traditional enforcement process because they are considered to be violations that potentially impede or impact the regulatory process. The inspectors reviewed Section 6.1.d.3 of the NRC Enforcement Policy and determined this violation was Severity Level IV because the licensees failure to update the USAR as required by 10 CFR 50.71(e) had not yet resulted in any unacceptable change to the facility or procedures. No cross cutting aspect was assigned because traditional enforcement violations are not assessed for cross cutting aspects.
05000461/FIN-2016002-0930 June 2016 23:59:59ClintonNRC identifiedFailure to Update the Updated Safety Analysis Report (USAR) Condensate and Feedwater SystemThe inspectors identified a Severity Level IV NCV of Title 10 Code of Federal Regulations (CFR) 50.71(e), Periodic Update of the FSAR, for the licensees failure to update the FSAR after implementation of license amendment 149, for extended power uprate. Specifically, the licensee did not update USAR Section 10.4.7.1.2 Performance Requirements, for the condensate and feedwater system with the design requirements for a reactor thermal power rating of 3473 MWt. The licensee entered the issue into their CAP as AR 02656128 and is preparing a technical change package to update the USAR. The inspectors determined that the failure to update the USAR in accordance with 10 CFR 50.71(e), Periodic Update of the FSAR, with the design requirements for the condensate and feedwater system for a reactor thermal power rating of 3473 MWt was a performance deficiency. The performance deficiency was determined to be minor in accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated September 7, 2012; however, the reactor oversite programs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance, therefore, it was necessary to address this violation which impeded the NRCs ability to regulate using traditional enforcement to adequately deter non-compliance. The inspectors reviewed this issue in accordance with NRC IMC 0612 and the NRC Enforcement Policy. Violations of 10 CFR 50.71(e) are dispositioned using the traditional enforcement process because they are considered to be violations that potentially impede or impact the regulatory process. The inspectors reviewed Section 6.1.d.3 of the NRC Enforcement Policy and determined this violation was Severity Level IV because the licensees failure to update the USAR as required by 10 CFR 50.71(e) had not yet resulted in any unacceptable change to the facility or procedures. No cross cutting aspect was assigned because traditional enforcement violations are not assessed for cross cutting aspects.
05000461/FIN-2016001-0331 March 2016 23:59:59ClintonNRC identifiedFailure to Report a Condition that Could Have Prevented Fulfillment of a Safety FunctionThe inspectors identified a Severity Level IV non-cited violation of 10 CFR 50.72(b)(3)(v) for failing to report an event or condition, that at the time of discovery could have prevented the fulfillment of a safety function, to the NRC within eight hours. Specifically, control room operators placed both divisions of reactor water cleanup differential flow instruments in bypass, which rendered the instruments inoperable and resulted in a loss of the isolation function. The licensee entered this issue into the CAP as AR 02645140 and created an action to submit a licensee event report under 10 CFR 50.73(a)(2)(v). The inspectors determined that the failure to report an event or condition, that at the time of discovery could have prevented the fulfillment of a safety function, to the NRC within 8 hours as required by 10 CFR 50.72(b)(3)(v) was a performance deficiency. The inspectors reviewed this issue in accordance with IMC 0612 and the Enforcement Manual. Violations of 10 CFR 50.72 are dispositioned using the traditional enforcement process because they are considered to be violations that potentially impede or impact the regulatory process. The inspectors reviewed Section 6.9.d.9 of the NRC Enforcement Policy and determined this violation was Severity Level IV because the licensees failure to make the report, as required by 10 CFR 50.72, did not cause the NRC to reconsider a regulatory position or undertake substantial further inquiry. No cross-cutting aspect was assigned because cross-cutting aspects are not assigned to traditional enforcement only violations.
05000461/FIN-2016001-0431 March 2016 23:59:59ClintonNRC identifiedFailure to Report a Condition Prohibited by Technical SpecificationsThe inspectors identified a Severity Level IV non-cited violation of 10 CFR 50.73(a)(2)(i)(B) for failing to report to the NRC, within 60 days of discovery, a condition prohibited by the plants TS. Specifically, the licensee failed to notify the NRC of two instances where they failed to comply with TS 3.3.6.1 and TS 3.3.6.2 and enter the limiting condition for operation action statements when required. The licensee entered this issue into their CAP as AR 02619114 and subsequently issued a licensee event report on March 16, 2016. The inspectors determined that the failure to report a condition prohibited by the plants TS as required by 10 CFR 50.73(a)(2)(i)(B), within 60 days of discovery, was a performance deficiency. The inspectors reviewed this issue in accordance with IMC 0612 and the Enforcement Manual. Violations of 10 CFR 50.73 are dispositioned using the traditional enforcement process because they are considered to be violations that potentially impede or impact the regulatory process. The inspectors reviewed Section 6.9.d.9 of the NRC Enforcement Policy and determined this violation was Severity Level IV because the licensees failure to make the report, as required by 10 CFR 50.73, did not cause the NRC to reconsider a regulatory position or undertake substantial further inquiry. No cross-cutting aspect was assigned because cross-cutting aspects are not assigned to traditional enforcement only violations.
05000461/FIN-2015004-0131 December 2015 23:59:59ClintonNRC identifiedFailure to Update the Final Safety Analysis Report (FSAR) Hydrogen Water Chemistry SystemThe inspectors identified a Severity Level IV Violation of 10 CFR 50.71(e), Periodic Update of the FSAR (Final Safety Analysis Report), for the licensees failure to update the FSAR after installing a hydrogen water chemistry system into the plant to reduce rates of intergranular stress corrosion cracking in recirculation system piping and reactor vessel internals. Specifically, the licensee did not update Section 5.4.15, Hydrogen Water Chemistry System, of the FSAR to include a design basis and description of the process and the system used to periodically injection noble metals. The licensee entered this issue into the corrective action program as AR 02594259 and planned to revise the FSAR to include a design basis and description of the process and the system used to periodically injection noble metals. The inspectors determined that the failure to update the FSAR in accordance with 10 CFR 50.71(e), Periodic Update of the FSAR, with the design basis and description of the process and the system used to periodically injection noble metals was a performance deficiency warranting a significance evaluation. The inspectors reviewed this issue in accordance with NRC IMC 0612 and the NRC Enforcement Manual. Violations of 10 CFR 50.71(e) are dispositioned using the traditional enforcement process because they are considered to be violations that potentially impede or impact the regulatory process. The inspectors reviewed Section 6.1.d.3 of the NRC Enforcement Policy and determined this violation was Severity Level IV because the licensees failure to update the FSAR as required by 10 CFR 50.71(e) had not yet resulted in any unacceptable change to the facility or procedures. No cross cutting aspect was assigned because cross cutting aspects are not assigned to traditional enforcement only violations.
05000461/FIN-2015003-0330 September 2015 23:59:59ClintonNRC identifiedFailure to Obtain a License Amendment prior to Making Modifications to Secondary ContainmentThe inspectors identified a Severity Level IV NCV of 10 CFR 50.59(d)(1), Changes, Tests, and Experiments, on December 18, 2014, for the licensees failure to provide a written evaluation showing that a change to the secondary containment did not require a license amendment. Specifically, the licensee eliminated the tornado wind and tornado missile loading conditions from the fuel building railroad airlock enclosure walls, roof and associated outer door Seismic Category I design requirements. However, the licensee failed to provide a written evaluation describing why the change would not result in more than a minimal increase in the likelihood of occurrence of a malfunction of a structure, system or component important to safety. The licensee documented the issue in the CAP as AR 02534694. Corrective actions included complying with TS anytime the inner railroad bay door is opened by entering the applicable action statements, evaluating weather conditions and impact to plant risk and establishing the necessary mitigating actions required prior to opening the door. The inspectors determined that the licensees failure to provide a written evaluation that documented the basis for determining that the change to the secondary containment did not require a license amendment was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the design control attribute of the Barrier Integrity cornerstone, and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers (fuel cladding, reactor coolant system and containment) protect the public from radionuclide releases caused by accidents or events. In addition, the associated violation was determined to be more than minor because the inspectors could not reasonably determine if the changes to secondary containment would have required prior NRC approval. Violations of 10 CFR 50.59 are dispositioned using the traditional enforcement process instead of the significance determination process (SDP) because they are considered to be violations that potentially impede or impact the regulatory process. However, if possible, the underlying technical issue is evaluated under the SDP to determine the severity of the violation. In this case, the finding was screened against the Barrier Integrity cornerstone, and determined to be of very low safety significance because the finding did not represent a degradation only of the radiological barrier function for the standby gas treatment system nor did it represent a degradation of the function of the control room against smoke or toxic atmosphere. The inspectors determined this finding has a cross-cutting aspect of procedure adherence in the area of human performance because the licensee failed to follow the 50.59 regulatory process as defined in procedure LS-AA-104-1000, 50.59 Resource Manual, Revision 9. (H.8)
05000461/FIN-2014005-0431 December 2014 23:59:59ClintonNRC identifiedFailure to Update the Updated Safety Analysis Report - Combustible Gas Control System Supply Fan Motor 1VR08C FunctionThe inspectors identified a Severity Level IV non-citied violation of 10 CFR 50.71(e), Periodic Update of the Updated Safety Analysis Report (USAR), and an associated Green finding for the licensees failure to update the USAR with the correct description of the function of the combustible gas control system supply fan motor, 1VR08C. Specifically the licensee did not update Section 9.4.5.5 of the USAR to include the correct function of 1VR08C as described in a commitment made to the NRC in the licensees letter U600850. Consequently the licensee performed a 10 CFR 50.59 evaluation for abandoning a portion of the system that did not consider the correct function of the component. The licensee entered this issue into thei corrective action program as AR 1692665, removed 1VR08C from the modification plan and is updating the USAR with the correct function for this component. The inspectors determined that the failure to update the USAR with the correct function of 1VR08C was a performance deficiency. The performance deficiency was determined to be more than minor in accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated September 7, 2012, because, if left uncorrected, the performance deficiency would have the potential to lead to a more significant safety concern and is therefore a finding. Specifically, failure to update the USAR with the correct safety related function of 1VR08C could result in the licensee making operability and functionality determinations based on incorrect assumptions. Additionally, the failure to update the USAR with the correct function of the fan was more than minor because it was associated with the Barrier Integrity cornerstone attribute of design control, plant modifications and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. The finding was screened against the Barrier Integrity cornerstone and determined to be of very low safety significanc because the finding does not represent an actual open pathway in the physical integrity of reactor containment, containment isolation system, and heat removal components and it did not involve an actual reduction in function of hydrogen igniters in reactor containment. The performance deficiency associated with this finding did not reflect current licensee performance; therefore, no cross cutting aspect was identified with this finding. Additionally, in accordance with Section 6.1.d.3 of the NRC Enforcement Policy, this violation was categorized as Severity Level IV because the licensees failure to update the USAR as required by 10 CFR 50.71(e) had not yet resulted in any unacceptable change to the facility or procedures. (Section 4OA2.7.b)
05000461/FIN-2014004-0630 September 2014 23:59:59ClintonNRC identifiedModifications to Steam Dryer Tie Bars 28 and 30 Without a 10 CFR 50.59 Safety EvaluationThe inspectors identified a Severity Level IV non-citied violation of 10 CFR 50.59(d)(1), Changes, Test, and Experiments, for the licensees failure to perform a written evaluation, which provided the bases for the determination that a change did no require a license amendment. Specifically, the licensee made a change pursuant t 10 CFR 50.59(c) with the installation of 12 inch holes adjacent to welds attaching tie bar 28 and 30 to the steam dryer vane assembly and did not provide a basis for th determination that this change would not result in a more than a minimal increase in th likelihood of occurrence of a malfunction of an system structure or component important to safety. The licensee entered this finding into the CAP as IR 02223135 and identified a action to secure a detailed assessment of these degraded tie bar locations from the steam dryer vendor. The licensee also consulted with the steam dryer vendor and made a qualitative assessment that the additional unflawed and unaltered portion of the fillet welds present at the end of the tie bar 28 and 30 locations provided a reasonable basis t conclude that these tie bars would not fail and affect the operability of safety-relate components. The inspectors determined that the failure to provide a written evaluation, which provided the basis for the determination that a change did not require a license amendment, was a performance deficiency. Specifically, the licensee failed to provide a basis for not applying for a license amendment associated with increased likelihood of a SD failure that impacts safety-related equipment due to reduced structural support available at tie bars 28 and 30. The performance deficiency was determined to be more than minor in accordance with IMC 0612, "Power Reactor Inspection Reports," Appendix B, "Issue Screening," dated September 7, 2012, because it was associated with the Initiating Events cornerstone attribute of equipment performance and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. In addition, the associated violation was determined to be more than minor because the inspectors could not reasonably determine if the changes to the SD at tie bars 28 and 30 would have required NRC prior approval. Per IMC 0609, Attachment 4, Initial Characterization of Findings, and Appendix A, The Significance Determination Process for Findings at Power, the finding was screened against the Initiating Events cornerstone and determined to be of very low safety significance (Green) because the finding did not cause a reactor trip and the loss of mitigating equipment relied upon to transition from the onset of the trip to a stable. The performance deficiency associated with this finding did not reflect current licensee performance; therefore, no cross cutting aspect was identified with this finding. In accordance with Section 6.1.d.2 of the NRC Enforcement Policy, this violation was categorized as Severity Level IV because the resulting changes were evaluated by the SDP as having very low safety significance.
05000461/FIN-2014004-0530 September 2014 23:59:59ClintonNRC identifiedFailure to Update the Updated Safety Analysis Report (USAR) - SD Structural Integrity FunctionThe inspectors identified a Severity Level IV non-cited violation of 10 Code of Federal Regulations (CFR) 50.71(e), Periodic Update of the Final Safety Analysis Report, and an associated Green finding for the licensees failure to update the report with a description of the basis for the steam dryer (SD) structural integrity submitted to the NRC in support of an extended power uprate license amendment. Specifically, the licensee did not update Section 3.9.5.1.1.9, Steam Dryers, of the Updated Safety Analysis Report (USAR) to include analysis and inspections of the steam dryer each refueling outage that provide the basis for steam dryer structural integrity. Consequently, the licensee had not completed an inspection of the steam dryer during the most recent refueling outage. The licensee entered this issue into the corrective action program (CAP) as issue report (IR) 02223135 and initiated actions to evaluate the Updated Safety Analysis Report for revision to include description of the structural integrity function of the steam dryer The inspectors determined that the licensees failure to update the USAR with the basis for steam dryer structural integrity submitted to the NRC was a performance deficiency. The performance deficiency was determined to be more than minor in accordance wit IMC 0612, "Power Reactor Inspection Reports," Appendix B, "Issue Screening," date September 7, 2012, because, if left uncorrected, the performance deficiency would hav the potential to lead to a more significant safety concern and is therefore a finding. Failur to update the Updated Safety Analysis Report with the basis for steam dryer structura integrity could result in a failure to maintain the structural integrity of the steam dryer Specifically, insufficient steam dryer inspections could result in failure to detect structurally significant cracking and result in a steam dryer failure which generates debris that adversely affects the function of safety-related components such as the main stea isolation valves (MSIVs). Additionally, the failure to update the USAR with the basis fo steam dryer structural integrity was more than minor because it was associated with th Initiating Event cornerstone attribute of equipment performance and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions. Using IMC 0609, Attachment 4, Initial Characterization of Findings, and Appendix A The Significance Determination Process for Findings at Power, the finding was screened against the Initiating Events cornerstone and determined to be of very low safety significance (Green) because the finding did not cause a reactor trip and the loss of mitigating equipment relied upon to transition from the onset of the trip to a stable condition. The performance deficiency associated with this finding did not reflect current licensee performance; therefore, no cross cutting aspect was identified with this finding. In accordance with Section 6.1.d.3 of the NRC Enforcement Policy, this violation was categorized as Severity Level IV because the licensees failure to update the USAR as required by 10 CFR 50.71(e) had not yet resulted in any unacceptable change to the facility or procedures.
05000461/FIN-2012005-0231 December 2012 23:59:59ClintonNRC identifiedFailure to Satisfy 10 CFR 50.73 Reporting Requirements for a Condition Prohibited by Technical SpecificationsThe inspectors identified a finding of very low safety significance with an associated Severity Level IV Non-Cited Violation of the NRCs reporting requirements in 10 CFR 50.73, Licensee Event Report System. The licensee failed to submit a required Licensee Event Report (LER) within 60 days after the discovery of an event that was reportable in accordance with 10 CFR 50.73(a)(2)(i)(B) as a condition which was prohibited by the plants Technical Specifications (TS) and 10 CFR 50.73(a)(2)(v)(B) as a condition that could have prevented the fulfillment of a safety function. The condition involved an inoperable diesel generator (DG) for longer than the TS completion time for restoration. The licensee subsequently submitted the required LER. Because this violation of the NRCs reporting requirements affected the NRC\\\'s ability to perform its regulatory function, the inspectors evaluated the violation using the traditional enforcement process in accordance with the NRC Enforcement Policy and assessed the significance of the underlying issue using the Significance Determination Process. The finding was of more than minor significance because the NRC relies on licensees to identify and report conditions or events meeting the criteria specified in the TS and the regulations in order to perform its regulatory function and, therefore if left uncorrected it could lead to a more significant safety concern. The inspectors previously determined that the underlying issue (i.e., the failure to correctly assemble a DG ventilation system damper that resulted in an inoperable DG) was a finding of very low safety significance during a detailed risk evaluation. Consistent with the guidance in Section 6.9, Paragraph d.9, of the NRC Enforcement Policy, the violation associated with this finding was determined to be a Severity Level IV Violation. This finding affected the cross-cutting area of human performance. Specifically, the licensees decision making process while evaluating the reportability of the condition with respect to the reporting requirements in 10 CFR 50.73 was inadequate.
05000461/FIN-2012012-0131 December 2012 23:59:59ClintonNRC identifiedFailure to provide complete and accurate decommissioning status reportsDuring an NRC investigation completed on November 22, 2011, and a supplemental investigation completed on October 10, 2012, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below: 10 CFR 50.75(a) establishes requirements for indicating to the NRC how a licensee will provide reasonable assurance that funds will be available for the decommissioning process and states that for power reactor licensees, reasonable assurance consists of a series of steps as provided in paragraphs (b), (c), (e), and (f) of 10 CFR 50.75. 10 CFR 50.75(f)(2) states, in part, that power reactor licensees shall report at least every 2 years on the status of its decommissioning funding for each reactor or part of a reactor that it owns; and, that the information in this report must include, at a minimum, the amount of decommissioning funds estimated to be required pursuant to 10 CFR 50.75(b) and (c). 10 CFR 50.75(b)(1) states, in part, that for a holder of an operating license under 10 CFR Part 50, financial assurance for decommissioning shall be provided in an amount which may be more, but not less, than the amount stated in the table in paragraph (c)(1) adjusted using a rate at least equal to that stated in paragraph (c)(2). 10 CFR 50.75(c)(1) states the minimum amount required to demonstrate reasonable assurance of funds for decommissioning by reactor type and power level. 10 CFR 50.75(c)(2) requires, in part, that an adjustment factor be applied, which is based on escalation factors for labor and energy, and waste burial. 10 CFR 50.9(a) states, in part, that information provided to the Commission by a licensee shall be complete and accurate in all material respects. Contrary to the above, on March 31, 2005, March 31, 2006, March 31, 2007, and March 31,2009, Exelon Generation Company, LLC (Exelon) provided information on the status of its decommissioning funding that was not complete and accurate in all material respects, when it submitted the decommissioning funding status (DFS) reports pursuant to 10 CFR 50.75. Specifically, the March 31, 2005, March 31, 2007, March 31, 2006, and March 31, 2009, DFS reports stated that the decommissioning funds estimated to be required for each of the reactors, as listed in the report, were determined in accordance with 10 CFR 50.75(b) and the applicable formulas of 10 CFR 50.75(c). However, in multiple instances, the amount reported was a discounted value that was less than the minimum required amount specified by 10 CFR 50.75(b) and (c). This is a Severity Level IV violation.
05000461/FIN-2012004-0330 September 2012 23:59:59ClintonNRC identifiedPast Operability/Reportability Determination for Inoperable Division 1 Diesel Generator Due to Ventilation System Damper FailureOn March 1, 2012, operators started the Division 1 DG for a monthly surveillance test and immediately noted a lack of expected air flow in the room from the ventilation supply fan and that the doors between the DG rooms did not have the usual high differential pressure between them. Operators secured the Division 1 DG and DG room supply fan (1VD01CA) after the engine had been running for about 45 minutes. With the ventilation fan secured, the licensee discovered that the ventilation supply damper hydramotor coupling was disconnected, causing the damper not to open (or to fail closed) when the ventilation fan started. Operators declared the Division 1 DG inoperable upon discovering the failed damper. As discussed in Section 1R12.1.b.1 of this inspection report, the licensee completed an equipment apparent cause evaluation for the damper failure and concluded that maintenance craftsmen had failed to sufficiently tighten a locknut on the coupling when the hydramotor was replaced on September 29, 2010, due to inadequate guidance in the maintenance procedure. The Division 1 DG and DG room supply fan had last operated satisfactorily during monthly testing on January 25, 2012. The inspectors noted that the licensee had not considered this to be a demand or run failure for the DG and had not reported the event in accordance with 10 CFR 50.73, Licensee Event Report System, Paragraph (a)(2)(i)(B), as a condition which was prohibited by the plants TS for an inoperable DG longer than the TS completion time for restoration. The inspectors reviewed the guidance in NUREG 1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73, Revision 2 and questioned the licensees conclusion that the event was not reportable based on the time of discovery. NUREG 1022, Section 3.2.2, states in part: Generally, an operation or condition prohibited by the technical specifications existed and is reportable if surveillance testing indicates that equipment (e.g., one train of a multiple train system) was not capable of performing its specified safety functions (and thus was inoperable) for a period of time longer than allowed by technical specifications (i.e., LCO (limiting condition for operation) allowed outage time, or completion time for restoration of equipment in ISTS (Improved Standard Technical Specifications)). The guidance further states: For the purposes of evaluating the reportability of a discrepancy found during surveillance testing that is required by the technical specifications... it should be assumed that the discrepancy occurred at the time of its discovery unless there is firm evidence, based on a review of relevant information such as the equipment history and the cause of failure, to indicate that the discrepancy existed previously. Based on the known cause of failure, it appeared to the inspectors that had there been an event involving a LOOP with a demand for the Division 1 DG to run at any time after it was last successfully tested on January 25th, the damper would have failed at that time; and, therefore the DG had been inoperable since it was last demonstrated to be operable on January 25th. The inspectors discussed this issue with the licensee and in response to the inspectors questions, the licensee initiated AR 01401926 to further review its past operability/reportability conclusion. This issue is considered to be an unresolved item (URI 05000461/2012004-3, Past Operability/Reportability Determination for Inoperable Division 1 DG Due to Ventilation System Damper Failure) pending additional review to determine whether this issue was reportable in accordance with 10 CFR 50.73(a)(2)(i)(B) as a condition which was prohibited by the plants TS.
05000461/FIN-2010003-0130 June 2010 23:59:59ClintonNRC identifiedFailure to Satisry 10 CFR 50.72 and 50.73 Reporting RequirementsThe inspectors identified a finding of very low safety significance with an associated Severity Level IV non-cited violation of the NRC‟s reporting requirements in 10 CFR 50.72(a)(1), Immediate Notification Requirements for Operating Nuclear Power Reactors, and 10 CFR 50.73(a)(1), Licensee Event Report System. The licensee failed make a required 8-hour non-emergency notification call to the NRC Operations Center and failed to submit a required Licensee Event Report within 60 days after discovery on October 7, 2009, of a condition that resulted in the plant being in an unanalyzed condition that significantly degraded plant safety and could have prevented fulfillment of the safety function of the emergency core cooling system. No immediate corrective actions were taken to address this finding; however, the licensee entered this issue into its corrective action program for evaluation. This finding was of more than minor significance because the NRC relies on licensees to identify and report conditions or events meeting the criteria specified in the Technical Specifications and the regulations in order to perform its regulatory function. Because this issue affected the NRC\\\'s ability to perform its regulatory function, the inspectors evaluated it using the traditional enforcement process and assessed the significance of the underlying issue using the SDP. The underlying technical issue (i.e., interconnecting floor drains between the Residual Heat Removal A‟ Pump Room and the Radwaste Pipe Tunnel) was determined to be a finding of very low safety significance during a Phase 3 Significance Determination Process evaluation. Consistent with the guidance in Supplement I, Paragraph D.4, of the NRC Enforcement Policy, the violation associated with this finding was determined to be a Severity Level IV Violation. This finding affected the cross-cutting area of human performance because the licensee did not use conservative assumptions in decision making while evaluating the reportability of the unanalyzed condition with respect to the reporting requirements in 10 CFR 50.72(a)(1)(ii) and 50.73(a)(1).
05000461/FIN-2010003-0230 June 2010 23:59:59ClintonNRC identifiedFailure to Perform an Adequate 10 CFR 50.59 Evaluation for CPS Procedure 3711.01The inspectors identified a finding of very low safety significance with an associated NCV of 10 CFR 50.59, Changes, Tests and Experiments. The licensee failed to perform an adequate 10 CFR 50.59 evaluation and obtain a license amendment prior to implementing CPS 3711.01, CPS (Clinton Power Station) Operations with the Potential to Drain the Reactor Vessel (OPDRV), Revision 0 on January 11, 2010. The procedure established a definition of an OPDRV for use in determining the applicability of several TS requirements while in Modes 4 and 5. The licensee failed to recognize that implementing this new procedure, in effect, constituted a change to the TS incorporated into its licensing basis, which would, therefore, require a license amendment pursuant to 10 CFR 50.59(c)(1)(i) and 10 CFR 50.90. No immediate corrective actions were taken to address this finding; however, the licensee entered this issue into its corrective action program for evaluation. The finding was of more than minor significance because there was a reasonable likelihood that the change requiring a 10 CFR 50.59 evaluation would require NRC review and approval prior to implementation. Because this issue affected the 3 Enclosure NRC\'s ability to perform its regulatory function, the inspectors evaluated it using the traditional enforcement process and assessed the significance of the underlying issue using the SDP. Based on the results of a modified Phase 2 SDP evaluation, this finding was determined to be of very low safety significance. Consistent with the guidance in Supplement I, Paragraph D.5, of the NRC Enforcement Policy, the violation associated with this finding was determined to be a Severity Level IV Violation. The inspectors concluded that this finding affected the cross-cutting area of human performance. Specifically, the licensee did not use conservative decision making to demonstrate that the proposed action did not require prior NRC approval. The inspectors noted that the licensee was aware of potential concerns regarding the new procedure prior to completing the initial 10 CFR 50.59 evaluation and again prior to revising the evaluation in response to concerns raised by the inspectors; however, the incorrect conclusion was reached in both revisions of the evaluation that the new procedure was not a change to the TS and that a license amendment was not necessary. (IMC 0310 H.1(b))
05000461/FIN-2009502-0131 December 2009 23:59:59ClintonNRC identifiedImplementation of a Change which Decreased the Effectiveness of the Emergency PlanThe inspectors identified a NCV of 10 CFR 50.54(q) associated with 10 CFR 50.47(b)(2) because the licensee failed to obtain prior NRC approval for a change made to its emergency plan that decreased the effectiveness of the plan. Specifically, the licensee removed staffing and capabilities from the minimum on-shift emergency response staffing requirements from the Clinton Power Station Emergency Plan Annex, Section 2, Table B-1. The licensee entered this issue into their corrective action program and replaced staffing back on-shift as required by the 1998 emergency plan annex. This finding was more than minor and of very low safety-significance using IMC 0609, Appendix B, because the finding was associated with the Emergency Preparedness Cornerstone attribute of emergency response organization readiness for minimum on-shift emergency response staffing. Because the finding affected the NRCs ability to perform its regulatory function, the inspectors evaluated the significance using the traditional enforcement process. This finding was determined to be a Severity Level IV violation because the licensee failed to meet an emergency planning requirement not directly related to assessment and notification. The inspectors determined that this finding had a cross-cutting aspect in the area of Human Performance, decision making because the licensee did not initially recognize that the removal of minimum on-shift emergency response staffing decreased the effectiveness of the emergency plan (H.1.(b)).
05000461/FIN-2009004-0330 September 2009 23:59:59ClintonNRC identifiedFailure to Update the Final Safety Analysis ReportThe inspectors identified a Non-Cited Violation of 10 CFR 50.71, Maintenance of Records, Making of Reports, associated with the licensees failure to correctly update the Updated Final Safety Analysis Report (UFSAR) when modifying TS requirements for the Control Room ventilation system during implementation of Improved Standard Technical Specifications. Specifically, the licensee failed to change the specified safety function description for the system to maintain positive pressure within the Control Room envelope with respect to adjacent areas during all operating modes, except when the system is in the recirculation mode or when the system is in the maximum outside air purge mode. This directly contributed to the licensees failure to correctly evaluate the operability of Control Room ventilation system Train B when the system was unable to maintain the Control Room envelope at a positive pressure relative to adjacent areas while operating in the normal mode. Subsequent evaluation by the inspectors determined that the safety function description in the UFSAR was inaccurate and the system was operable with the degraded/ nonconforming condition. The licensee entered this violation into its CAP to investigate the cause and to identify appropriate corrective actions. Because the issue affected the NRCs ability to perform its regulatory function, the violation was reviewed under the traditional enforcement process. In addition, the underlying technical issue was evaluated using the Significance Determination Process. The finding was determined to be a Severity Level IV violation because it was similar to a Severity Level IV violation example in the NRC Enforcement Policy, Supplement I--Reactor Operations. The finding would become a more significant safety concern if left uncorrected and was therefore more than a minor concern. Specifically, the failure to correctly evaluate a degraded/nonconforming condition potentially affecting the operability of a system, structure, or component (SSC) required to be operable by TS could reasonably result in an unrecognized condition of an SSC failing to fulfill a safety-related function. Because the Control Room ventilation system supports the radiological barrier function to protect operators inside the Control Room following certain design basis accidents, the inspectors concluded that this issue was associated with the Barrier Integrity Cornerstone. The finding was of very low safety significance because it involved only a degradation of the radiological barrier function provided for the Control Room. The inspectors did not identify a cross-cutting aspect related to this finding