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| Start date | Site | Identified by | Title | Description | |
|---|---|---|---|---|---|
| 05000445/FIN-2016007-01 | 30 September 2016 23:59:59 | Comanche Peak | NRC identified | Failure to Update Final Safety Analysis Report Section 8.3.1.1.11 | The inspectors identified a Severity Level IV violation of 10 CFR 50.71(e) which states, in part, that the licensee shall update periodically the final safety analysis report originally submitted as part of the application for the license, to assure that the information included in the report contains the latest information developed. The submittal shall include the effects of all changes made in the facility or procedures as described in the final safety analysis report, or all safety analyses and evaluation performed by the licensee either in support of approved license amendments or in support of conclusions that changes did not require a license amendment in accordance with 10 CFR 50.59 (c)(2). Specifically, from October 9, 2012, to September 29, 2016, the licensee did not include the effects of changes to the K300 voltage relay setpoint or the safety evaluation in submittals to the Final Safety Analysis Report, Section 8.3.1.1.11, that supported the conclusion that the changes did not require a license amendment. In response to this issue, the licensee planned a corrective action to initiate a licensing document change request to update the final safety analysis report. This finding was entered into the licensees corrective action program as Condition Report CR-2016-008177. The inspectors determined that the licensees failure to initiate a Licensing Document Change Request, in accordance with Procedure STA-116, Maintenance of CPNPP Licensing Basis Documents, Operating License conditions and Technical Specifications, Revision 14, Instruction 6.1, to update the Final Safety Analysis Report, Section 8.3.1.1.11, for the setpoint revision of the K300 voltage relays was a performance deficiency. In accordance with Inspection Manual Chapter 0612, Appendix B, Issue Screening, dated September 7, 2012, this was determined to be a minor performance deficiency. This violation was evaluated using the traditional enforcement process because it had the potential for impacting the NRCs ability to perform its regulatory oversight function. The reactor oversight processs significance determination process does not consider violations that impact the NRCs regulatory oversight function. This violation was determined to be a Severity Level IV violation, consistent with the example in paragraph 6.1.d.3 of the NRC Enforcement Policy, dated August 1, 2016. Specifically, the licensee failed to update the final safety analysis report as required by 10 CFR 50.71(e), but the lack of up-to-date information has not resulted in any unacceptable change to the facility or procedures. The inspectors determined that this violation did not have a cross-cutting aspect because traditional enforcement violations are not assessed for cross-cutting aspects. |
| 05000445/FIN-2015002-03 | 30 June 2015 23:59:59 | Comanche Peak | NRC identified | Failure to Update the UFSAR for Restrictions Associated with Shared System Operations of Component Cooling Water | The inspectors identified a non-cited violation of 10 CFR 50.71(e), Maintenance of Records, Making Reports, associated with the licensees failure to update the Final Safety Analysis Report. Specifically, the licensee failed to update the Final Safety Analysis Report to include information detailing restrictions associated with shared system operations of the non-safeguards component cooling water loads between units. This issue does not represent an immediate safety concern because, at the time of identification, the component cooling water systems were not cross connected. The licensee entered this issue into the corrective action program for resolution as Condition Report CR-2014-007235. The licensees failure to update the Final Safety Analysis Report to reflect restrictions associated with shared system operations of the non-safeguards component cooling water loads was a performance deficiency. Because this performance deficiency had the potential to impact the NRCs ability to perform its regulatory function, inspectors evaluated the performance deficiency using traditional enforcement. Using Inspection Manual Chapter 0612, Power Reactor Inspection Reports, dated January 24, 2013, Appendix B, Issue Screening, and Appendix E, Examples of Minor Issues, the Reactor Oversight Program aspect of this performance deficiency was determined to be minor. Using the NRC Enforcement Policy, dated January 28, 2013, the performance deficiency was determined to be a Severity Level IV violation in accordance with Section 6.1.d.3, because the lack of upto-date information in the Final Safety Analysis Report had not resulted in any unacceptable changes to the facility or procedures. Inspectors determined that cross-cutting was not applicable to this finding because it was strictly a traditional enforcement issue. |
| 05000445/FIN-2014404-02 | 30 September 2014 23:59:59 | Comanche Peak | NRC identified | Security | |
| 05000445/FIN-2013007-04 | 30 June 2013 23:59:59 | Comanche Peak | NRC identified | Failure to Update the FSAR for the APDGs in Accordance with Regulatory Guide 1.70-1995 | The inspectors identified a Severity level IV, non-cited violation of 10 CFR 50.71(e)(4), requires the UFSAR be updated, at intervals not exceeding 24 months, and states in part, the revisions must reflect all changes made in the facility or procedures described in the UFSAR. Specifically, prior to June 20, 2013, the inspectors identified the alternate power diesel generator system was not described in sufficient detail in the FSAR as required. This finding was entered into the licensees corrective action program as Condition Report CR-2013-006256. The inspectors determined that the failure to update the Final Safety Analysis Report to include the description of the APDG system in section 8.3.1 AC Power Systems was a performance deficiency. The issue is a performance deficiency because it was a failure to meet requirement, 10 CFR 50.71(e)(4), and it was within the licensees ability to correct the problem. Using Inspection Manual Chapter 0612, Appendix B, the performance deficiency was assessed through both the Reactor Oversight Process and traditional enforcement because the finding had the potential for impacting the NRCs ability to perform its regulatory function. The finding resulted in a minor performance deficiency. For traditional enforcement, the inspectors used the Enforcement Policy, in accordance with Section 6.1.d.3, and determined the violation to be a Severity Level IV, non-cited violation, because the licensee failed to update the UFSAR as required by 10 CFR 50.71(e)(4), but the lack of up-to-date information had not resulted in any unacceptable change to the facility or procedures. This violation did not have a cross-cutting aspect. |
| 05000445/FIN-2012301-01 | 30 June 2012 23:59:59 | Comanche Peak | Licensee-identified | Licensee-Identified Violation | 10 CFR 50.9(a) requires, in part, that information provided to the Commission by a licensee shall be complete and accurate in all material aspects. On June 5, 2012, the NRC gave approval to the licensee to administer a written examination to initial operating license applicants on June 19, 2012. The approval was made based on content of the written examination provided to the NRC on June 4, 2012. In this version of the written examination, Question 71 had been revised based on NRC comments so that it had only one correct answer. Previous draft revisions of the question had two plausible correct answers. The written examination was administered on June 19, 2012. On June 20, 2012, the licensee was conducting the post written examination analysis in accordance with NUREG-1021, ES-403, Section D.3.b. As part of this, the licensee reviews performance on missed questions for training deficiencies and wording problems. While completing this analysis, the licensee identified that the version of Question 71 on the administered written examination was not the version that was approved on June 5, 2012. The licensee notified the NRC of the issue on the same day (June 20, 2012), and completed an extent of condition review that showed that this was the only written examination question provided in the form inconsistent with the questions approved on June 5, 2012. The violation was of very low safety significance because the performance deficiency did not contribute to the NRC making any incorrect regulatory decisions regarding issuance of operating licenses. The licensee entered this issue into their corrective action program as Condition Report CR-2012-006252. |
| 05000445/FIN-2011006-01 | 30 September 2011 23:59:59 | Comanche Peak | NRC identified | Failure to Conclude a Change to the Final Safety Analysis Report Required Prior NRC Review and Approval | The team identified a Severity Level IV noncited violation of 10 CFR 50.59, Changes, Tests, and Experiments, associated with the failure to conclude that a change to the Final Safety Analysis Report required prior NRC review and approval prior to implementation. Specifically, the licensee made changes to the Final Safety Analysis Report that resulted 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 entered the finding in the corrective action program as Condition Report CR 2011-008509. This finding was more than minor because there was a reasonable likelihood that the change would require a prior NRC approval. Violations of 10 CFR 50.59 are violations that potentially impede or impact the regulatory process and are processed through traditional enforcement. As required by Section 7.3 of the Enforcement Policy, the team performed a Phase 1 screening in accordance with Manual Chapter 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, to determine the significance of the finding. The team determined that the finding is of very low safety significance (Green) because the finding: (1) was not a design or qualification issue confirmed not to result in a loss of operability or functionality; (2) did not represent an actual loss of safety function of the system or train; (3) did not result in the loss of one or more trains of nontechnical specification equipment; and (4) did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. Since violations of 10 CFR 50.59 may result in conditions evaluated as having very low safety significance by the Significance Determination Process, the team categorized the finding as Severity Level IV in accordance with the Enforcement Manual. The finding was a violation determined to be of very low safety significance, was not repetitive or willful, and was entered into the corrective action program. Therefore, this violation is being treated as a noncited violation consistent with the NRC Enforcement Policy. The team did not identify a crosscutting aspect with this finding since this performance issue occurred in 2004 and is not reflective of current performance. |
| 05000445/FIN-2010006-05 | 30 June 2010 23:59:59 | Comanche Peak | NRC identified | Failure to Provide Accurate Information in Response to Generic Letter 2007-01, Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients | The team identified a noncited violation of 10 CFR 50.9, Completeness and Accuracy of Information, which states, in part, that information provided to the Commission by a licensee shall be complete and accurate in all material respects. Specifically, on June 20, 2007, the licensee asserted in their response to Generic Letter 2007-01, Inaccessible or Underground Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients, Request 2, that Comanche Peak periodically performs visual inspection for corrosion and degradation of cable tray supports and a preventive maintenance program for inspection/removal of water from manholes. The team determined the licensee had no preventive maintenance program or procedures in place to govern the inspection or preventive maintenance activities described in their response, and there was no evidence that these manholes, raceways, and supports had ever been inspected prior to November 2009. This finding was entered into the licensees corrective action program as Condition Report CR-2010- 005784. The team determined that the failure to provide accurate information in the licensees response to Generic Letter 2007-01 was a performance deficiency. The finding is more than minor because the information was material to the NRCs decision-making processes. Specifically, the information requested by Generic Letter 2007-01 was to enable NRC staff to determine whether the applicable regulatory requirements identified in the generic letter (10 CFR Part 50, Appendix A, General Design Criteria 4, 17, and 18; 10 CFR 50.65(a)(1); 10 CFR Part 50, Appendix B, Criterion XI), were being met with regard to the operational readiness of critical systems that could cause a plant transient or mitigate accidents, and to obtain further information on cable failures. |
| 05000445/FIN-2009005-05 | 31 December 2009 23:59:59 | Comanche Peak | NRC identified | Failure to Report as Required by 10 CFR 26.27 | The inspectors identified a noncited violation of 10 CFR 26.27 for the failure of an individual to comply with the licensees fitness-for-duty requirements. The licensee implemented immediate compensatory measures for this deficiency by briefing the event and providing personnel with the implications of such an activity and by reviewing implementing procedures, policies, and training. The licensee entered the noncited violation into the corrective action program as Condition Report CR-2009-000104. The failure to comply with the licensees requirements affecting fitness-for-duty is a performance deficiency. This issue was dispositioned using traditional enforcement. In accordance with Section IV.A.4 of the NRC Enforcement Policy, this issue is considered a Severity Level IV violatio |
| 05000445/FIN-2008003-08 | 30 June 2008 23:59:59 | Comanche Peak | Licensee-identified | Licensee-Identified Violation | Part 50.54Q of Title 10 of the Code of Federal Regulations states, in part, that a licensee shall maintain and follow emergency plan that meets the requirements of 10 CFR 50.47(b) and Appendix E to Part 50; 10 CFR Part 50, Appendix E, IV(E)(8) requires a licensee have a near-site emergency operations facility (EOF); the requirements for a licensee with a near-site EOF to have an Alternate EOF are found in NUREG-0696 and 0737. Contrary to this, in 2005 the licensee changed the location of its Alternate EOF from the Hood County Law Enforcement Center to the Daffin Industrial Park without making concurrent changes to its Emergency Plan to describe the Alternate EOF currently in service. The error was not identified for 3 years although the licensee had several opportunities to identify the discrepant condition. This issue was identified in the licensees CAP as Smart Form 2008 000746. This finding is a Severity Level IV violation because a licensees failure to maintain accurate information in its emergency plan affects the NRCs ability to perform its regulatory function, the finding is not similar to the Severity Level I, II, or III examples found in the Enforcement Policy, and the Daffin Industrial Park Alternate EOF meets the requirements of 10 CFR Part 50 Appendix E, IV (E)(8), NUREG 0696 and 0737 |
| 05000445/FIN-2004003-01 | 30 June 2004 23:59:59 | Comanche Peak | Self-revealing | Entry into a high radiation area without a briefing on radiation dose rates | On November 4, 2003, an individual entered a high radiation area without contacting radiation protection personnel for a briefing on the dose rates in the area, despite verbal and posted instructions to the contrary. Dose rates within the room were as high as 250 millirems per hour at 30 centimeters from the source of radiation. The licensee was alerted to the situation when the individual's electronic dosimeter alarmed because the dose rate setpoint was exceeded. The occurrence was a violation of Technical Specification 5.7.1.e. The violation involved the act of a low-level individual; however, the licensee failed to promptly provide information concerning the violation to appropriate NRC personnel, in accordance with Section VI.A.1.d(1) of the NRC Enforcement Policy. Therefore, the finding could not be treated as a noncited violation The failure to contact radiation protection personnel for a briefing on radiation dose rates prior to entering a high radiation area is a performance deficiency because it resulted in the licensee's failure to meet a requirement in its technical specifications. Because there are willful aspects of the violation, it is subject to traditional enforcement. The willful aspects notwithstanding, the inspector used the Occupational Radiation Safety Significance Determination Process described in Manual Chapter 0609, Appendix C, to analyze the significance of the finding. The inspector determined that the finding was of very low safety significance because it did not involve (1) ALARA planning and controls, (2) an overexposure, (3) a substantial potential for overexposure, or (4) an impaired ability to assess dose. The finding was entered into the licensee's corrective action program as SMF-2003-3594, and the individual was appropriately disciplined. This finding also had crosscutting aspects associated with human performance. |