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| Start date | Site | Identified by | Title | Description | |
|---|---|---|---|---|---|
| 05000237/FIN-2018003-02 | 30 September 2018 23:59:59 | Dresden | Licensee-identified | Licensee-Identified Violation | Violation: Dresden Technical Requirements Manual (TRM) Control Program (Appendix G of TRM), Section 1.5, Program Implementation, requires that proposed changes to the TRM are screened and reviewed under the 10 CFR 50.59 process in accordance with plant specific procedures. Contrary to the above, in October 2017 Dresden station approved and implemented an extension to the surveillance frequency of DIS 150020, Division I & II Low Pressure Coolant Injection (LPCI) Pumps Suction and Injection Valves Circuitry Logic System Functional Test, on Unit 2 per the Surveillance Frequency Control Program (SFCP) without the required 50.59 review. |
| 05000237/FIN-2014004-01 | 30 September 2014 23:59:59 | Dresden | NRC identified | Failure to Perform an Adequate 10 CFR 50.59 Evaluation for Procedure DOP 130002 | The inspectors identified a NCV of 10 CFR 50.59, Changes, Tests and Experiments, when, on February 10, 2011, the licensee failed to complete a 10 CFR 50.59 evaluation when they revised procedure DOP 130002 to change the position of Motor Operated Valve (MOV) 213013, Reactor Inlet Isolation, such that the Isolation Condenser (IC) system would not meet its design requirement of removing 84.2E+06 BTUs in 20 minutes when initiated from its minimum Technical Specification(TS) level and maximum TS temperature. The inspectors determined that the licensees failure to identify that the valve position adjustment required a 10 CFR 50.59 evaluation was a performance deficiency. This finding was evaluated using traditional enforcement because it had the potential for impacting the NRCs ability to perform its regulatory function. This finding was more than minor because there was a reasonable likelihood that the change would have required NRC review and approval prior to implementation. Specifically, by establishing a new position setting of MOV 213013, the licensee failed to determine that the proposed change would cause isolation condenser tubes to become exposed in the design basis accident such that it adversely affected a Final Safety Analysis Report described design function, which required an evaluation to be performed. In accordance with IMC 0612, Appendix B, Issue Screening, traditional enforcement does apply as the violation impacted the regulatory process. Using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, Exhibit 2, Mitigating Systems Screening Questions, the issue screened as having very low safety significance (Green) because it was a design or qualification deficiency that did not represent a loss of the system and/or function, did not represent an actual loss of function of at least a single train for greater than its TS allowed outage time, and did not result in the actual loss of one or more trains of non-technical specification equipment. Inspectors assessed the violation in accordance with the Enforcement Policy, and determined it to be a Severity Level IV violation because it resulted in a condition evaluated by the SDP as having very low safety significance (Enforcement Policy example 6.1.d.2). This finding has a cross-cutting aspect of Design Margins (IMC 0310, H.6) in the area of human performance, for failing to carefully guard and maintain the IC design requirement of removing 84.2E+06 BTU in 20 minutes. |
| 05000237/FIN-2014403-02 | 31 March 2014 23:59:59 | Dresden | Licensee-identified | Licensee-Identified Violation | |
| 05000237/FIN-2013004-01 | 30 September 2013 23:59:59 | Dresden | NRC identified | Failure to Update the UFSAR for Reactor Water Cleanup Design Changes | A Severity Level IV NCV of 10 CFR 50.71(e), Periodic Update of the Final Safety Analysis Report (USFAR) and an accompanying Green finding were identified by the inspectors for the licensees failure to update the Updated Final Safety Analysis Report (UFSAR) for a design modification performed on the Unit 3 reactor water cleanup (RWCU) system. Specifically, the licensee did not update Dresden UFSAR Section 5.4.8, Reactor Water Cleanup System, to reflect changes made during a design modification installed on Unit 3 in 1997. The design changes included reducing the pipe dimension of RWCU piping outside of the primary containment and eliminating a string of regenerative and non-regenerative heat exchangers. The licensee also identified several high energy line break (HELB) calculations which did not include the design modification when determining the impact on environmentally qualified components affected by a failure of the RWCU system piping outside of the primary containment structure. Corrective actions included submitting a UFSAR change request to include the appropriate operating characteristics and specifications under the present design. In addition, the licensee reviewed all affected calculations to ensure no nonconservative outcomes resulted based on the design modifications installed. This finding was determined to be more than minor using IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated September 7, 2012 because, if left uncorrected, the performance deficiency could have led to a more significant safety concern. Specifically, failure to update the UFSAR with the actual RWCU system configuration prevented the inspectors from readily concluding that the design change would not require additional calculational analyses for HELB. The inspectors completed a Phase 1 significance determination of this issue using IMC 0609, Significance Determination Process, Attachment 0609.04, Initial Characterization of Findings, dated July 1, 2012 and IMC 0609, Appendix A, The Significance Determination Process (SDP) For Findings At-Power, dated July 1, 2012. The inspectors answered NO to all questions in Exhibit 2, Section A, Mitigating SSCs and Functionality, therefore the finding screened as Green (very low safety significance). In accordance with Section 6.1.d.3 of the NRC Enforcement Policy, this violation is categorized as Severity Level IV because the information was not used to make an unacceptable change to the facility or procedures since the design changes did not result in a reduction of the previous margin to the 10 CFR 100 guidelines nor did they challenge the environmental quality rating of safety related components in the vicinity of the RWCU system during a HELB event outside of containment. The inspectors determined that this finding did not reflect present performance because it is a legacy issue with changes made to the facility more than 16 years previously; therefore, there was no cross cutting aspect associated with this finding. |
| 05000010/FIN-2012012-01 | 31 December 2012 23:59:59 | Dresden | NRC identified | Failure to provide complete and accurate decommissioning status reports | During 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. |
| 05000237/FIN-2012002-08 | 31 March 2012 23:59:59 | Dresden | NRC identified | Failure to Make a Required 8 Hour Event Report Per 10 CFR 50.72(b)(3)(v)(D) | The inspectors identified a Severity Level IV NCV and associated finding of very low safety significance of 10 CFR 50.72(b)(3)(v)(D), Immediate Notification Requirements for Operating Nuclear Power Reactors, for the failure to report an event to the NRC within 8 hours, where an event or condition that at the time of discovery could have prevented the fulfillment of the safety function of structures or systems that are needed to mitigate the consequences of an accident. The licensee had not prepared any corrective actions by the end of the inspection period. The inspectors determined that a failure to report was an example of a violation that could impact the regulatory process and was subject to Traditional Enforcement. The inspectors determined that the underlying technical issue involved the inability to scram The inspectors determined that a failure to report was an example of a violation that could impact the regulatory process and was subject to Traditional Enforcement. The inspectors determined that the underlying technical issue involved the inability to scram |
| 05000237/FIN-2012008-03 | 31 March 2012 23:59:59 | Dresden | NRC identified | Failure to Provide Complete and Accurate Information to the NRC | The inspectors identified a Severity Level IV, Non-Cited Violation of 10 CFR 50.9(a), Completeness and Accuracy of Information, for the licensees failure to provide complete and accurate information to the NRC during a 2011 Triennial Fire Protection Inspection. Specifically, between July 7 and October 17, 2011, the licensee failed to inform the NRC that bottles containing 100 percent hydrogen were located in the plant in response to inspectors questions regarding flammable gas bottles. The licensee entered this issue into their corrective action program to document the incomplete response provided. The inspectors determined that the performance deficiency was more than minor because it impacted the regulatory process. Specifically, had the NRC known during the 2011 Triennial Fire Protection Inspection that the hydrogen bottles contained 100 percent hydrogen the inspectors would likely have documented a finding associated with the hydrogen bottles. The issue was a Severity Level IV Non-Cited Violation because the inspectors documented a finding of very low safety significance associated with the flammable hydrogen bottles once they determined that bottles containing 100 percent hydrogen were located in the plant. |
| 05000237/FIN-2011008-05 | 31 December 2011 23:59:59 | Dresden | NRC identified | Failure to Obtain NRC Approval for Change Adverse to Safe Shutdown | The inspectors identified a Severity Level IV, NCV of License Conditions 2.E and 3.G, for Units 2 and 3, and an associated finding of very low safety significance (Green) for the failure to obtain NRC approval prior to making a change, which was adverse to safe shutdown. Specifically, the licensee made a change to Administrative Technical Requirements, which permitted a suppression system to be inoperable without compensatory measures, thereby degrading the ability to suppress a fire and challenging the ability to achieve and maintain safe shutdown in the event of a fire. The licensee entered the issue into their corrective action program and issued an operations standing order to require fire watches, regardless of whether there was operable detection when a suppression system was out of service. The inspectors determined that this finding was more than minor because the change permitted suppression systems to be inoperable without any compensatory action. This finding was of very low safety significance because the majority of issues identified by fire watches would involve combustible materials, which would not result in ignition of a fire from existing sources of heat or electrical energy. The inspectors did not identify a cross-cutting aspect associated with the finding because the finding was not representative of current performance. |
| 05000237/FIN-2010002-01 | 31 March 2010 23:59:59 | Dresden | NRC identified | Failure to Record the Identity of Personnel Performing Post-Maintenance Tests | A finding of very low safety significance and associated NCV of 10 CFR Part 50, Appendix B, Criterion XVII, Quality Assurance Records, was identified by the inspectors for the licensees failure to record the identity of various personnel who performed seven post-maintenance tests (PMTs) related to Unit 3 EDG maintenance. Despite the PMTs being related to work on safety-related components, an activity affecting quality, neither the licensees procedure MA-AA-716-012, Post-Maintenance Testing, nor DAP 15-10, Post-Maintenance Testing Program, required the identity of the inspector or tester to be recorded. Completed corrective actions included adding PMT documentation requirements to DAP 15-10 and briefing individuals who perform PMTs. This finding was determined to be more than minor because the finding was similar to IMC 0612, Appendix E examples 1b since a portion of required records were irretrievably lost, and 2h since multiple examples were identified as failures to properly implement the same regulatory requirement. Following IMC 0612, Appendix B, it was apparent that this issue did not fall directly under a cornerstone and that incomplete information was recorded in the seven PMTs. Therefore, the Enforcement Policy was used to screen the severity in conjunction with the IMC 0612, Appendix E, Examples 1b and 2h. Since MA-AA-716-012, Post-Maintenance Testing, did not properly implement regulatory requirements, this finding has a cross-cutting aspect in the area of Human Performance, Resources because the licensee did not provide complete, accurate, and up-to-date procedures to plant personnel. H.2(c |
| 05000237/FIN-2009301-01 | 31 March 2009 23:59:59 | Dresden | NRC identified | Failure to Provide Complete and Accurate Information to the NRC Associated with Verifying No Operating Test Item Duplication with the Audit Test | The inspectors identified a Severity Level IV Non-Cited Violation (NCV) of 10 CFR 55.40, Implementation, 10 CFR 50.9, Completeness and accuracy of information, and 10 CFR 55.49, Integrity of examinations and tests. For the Dresden Station March 2009 NRC Initial Operator License Examination, the inspectors identified that the examination author and the facility reviewer had initialed Step 2.b and Step 3.a.(3) of Form ES-201-2, Examination Outline Quality Checklist, on August 15, 2008, and August 19, 2008, respectively, and Step 1.c of Form ES-301-3 Operating Test Quality Checklist, on January 15, 2009, and January 20, 2009, respectively, which indicated that the operating test did not duplicate items from the applicants audit test, when, upon NRC review, it was determined that six of the 23 dynamic simulator scenario events, and one of the 15 Job Performance Measures (JPMs) for the Reactor Operator (RO) candidates were duplicated from the applicants audit test. The finding was determined to be more than minor, because the integrity of the NRC initial operator licensing examination could have been compromised if, but for detection by the NRC examiners, the NRC examination had been administered with the duplication of the operating test items from the applicants audit test. The finding was determined to be of very low safety significance because the duplication of operating test items was discovered by the NRC examiners prior to administration of the NRC examination, the duplicate test items were either removed from the audit test or the NRC exam changed to remove the duplication, and the facility implemented examination security requirements for the audit test similar to that which was required for the NRC examination. The inspectors concluded that this finding had a cross-cutting aspect in the area of Human Performance, Work Practices, because the licensee did not define and effectively communicate expectations regarding procedural compliance and for personnel to follow procedures (i.e., in the development of the NRC initial operator license examination) (H.4(b)). (Section 4OA5.2) |
| 05000237/FIN-2007004-03 | 30 September 2007 23:59:59 | Dresden | NRC identified | Inadequate Reactor Operators Shift Turnover | The inspectors identified a performance deficiency involving a Severity Level IV Violation of Technical Specification (TS) 5.4.1 for the failure of two Nuclear Station Operators (NSOs) to follow station procedures during shift turnover. The licensees corrective actions for this issue included: 1) the Unit Supervisor had an alternate operator relieve the on-coming operator involved with improper turnover, 2) the licensee convened a fact finding investigation to determine the facts of the event, 3) the licensee increased the awareness of the operators at the facility to the importance of proper shift turnover, and 4) the licensee took disciplinary action toward the two individuals. Description: On January 16, 2007, the inspectors observed an abbreviated shift turnover between the on-coming and off-going NSOs, licensed reactor operators, at the NSO work station at Dresden Power Station, Unit 2. The inspectors observed the on-coming operator enter the control room approximately 15 minutes after normal shift turnover, the on-coming operator spoke briefly with the off-going operator, and the off-going operator exited the control room. At the time of this event, Unit 2 was in an elevated risk profile (yellow) due to various plant components, such as the 2C and 2D containment cooling service water pumps and the 2C and 2D low pressure coolant injection pumps, being out of service. The inspectors questioned if the turnover could have been sufficient to allow the on-coming operator to gain the appropriate level of knowledge of plant status for safe operations and communicated this observation to the on-duty Unit 2 Supervisor. The Unit 2 Supervisor had the on-coming operator relieved by another qualified operator and commenced a fact finding investigation into the matter. Both operators were questioned, individually, within 24 hours of the event to determine to what extent they performed shift turnover. Verification of the card reader transaction history report for the control room door showed that the two operators were in the control room for less than three minutes together during their shift turnover. This issue was referred to the NRC Office of Investigations (OI) due to potential wrongdoing. (OI Report 3-2007-009) During various interviews, including the licensees fact finding investigation and OI interviews, the on-coming operator stated that: 1) he did not perform a panel walk down of the control room back panels and common panels associated with the unit; 2) he did not review the operating logs for the unit prior to turnover; 3) he did not tour the main control panels for the unit with the off-going operator; and 4) he did not discuss all the information regarding the unit status with the off-going operator. The on-coming operator indicated to the Shift Operations Superintendent that he knew this did not constitute a proper shift turnover, but the operator felt this was acceptable since he was on shift eight hours previously and had a firm understanding of plant conditions. The 26 Enclosure on-coming operator also stated that this decision was due to his late arrival to the control room and that he made a bad decision. The inspectors concluded that the NSO shift turnover was inadequate and did not comply with the requirements in operating procedure OP-AA-112-101, Shift Turnover and Relief. Specifically, Section 3.1 requires that, All shift personnel are responsible for reviewing and understanding the logs, checklist and turnover sheets applicable to their shift position before assuming the shift, Section 3.2 requires that, the off-going operator shall not leave his/her work area until he/she is satisfied that his/her relief is fully aware of existing conditions, and Section 4.1.3 requires shift personnel to, VERIFY important operating parameters, especially those relating to safety systems, as identified on the turnover sheet prior to assuming the shift. Additionally, Operator Aid #159, Nuclear Station Operator Turnover Checklist, further outlines the requirements of the operating procedures, including for example, the on-coming NSO must read the control room logs, tour main control panels, tour main control room back and common panels, and discuss system status with the off-going operator. Shift turnover provides power plant operators with the appropriate level of knowledge of plant conditions and system configurations to allow safe operation of the reactor core and support systems. Operators are required to react to postulated accident scenarios in order to help mitigate predicted consequences. Insufficient knowledge of plant status increases the likelihood that an operator could perform an error of commission/omission which could magnify the consequences resulting from postulated accident scenarios or potentially introduces additional initiating events through incorrect equipment manipulations. At the time of this event, Unit 2 was in an elevated risk profile (yellow) due to various plant components. This increased risk profile amplified the importance of knowing and understanding plant conditions. Therefore, inadequate shift turnovers unnecessarily increase the risk to public health and safety. The inspectors supported by the regional staff determined that the licensed operators knew the requirements to be followed during shift turnover at the NSO work station based upon their extensive work experience and the testimonies given during the licensees fact finding investigation. The OI investigation report concluded that the operators deliberately failed to perform shift turnover and relief procedure requirements. Failure to follow these requirements was a willful act promoted by the on-coming operator arriving late in the control room. Analysis: The inspectors and the regional office staff concluded that there was no Significance Determination Process finding associated with this case. Because this performance deficiency involved a willful act, this issue was dispositioned using the traditional enforcement process instead of the Significance Determination Process. The violation of TS 5.4.1 was categorized in accordance with the NRC Enforcement Policy. The failure to follow the shift turnover procedure, absent willfulness, had no actual safety consequences, and constitutes a minor violation. Considering willfulness on part of the operators, a Severity Level IV violation is warranted. The violation is being cited because it was willful and was identified by the NRC. Enforcement: Dresden Nuclear Power Station, Unit 2, Technical Specification (TS) 5.4.1 states, in part, that written procedures shall be established, implemented, and 27 Enclosure maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, dated February 1978. Regulatory Guide 1.33, (1)(g) states that a typical safety-related activity that should be covered by written procedures is shift and relief turnover. Dresden Nuclear Power Station uses operating procedure OP-AA-112-101, Shift Turnover and Relief, and Operator Aid #159, Nuclear Station Operator (NSO) Turnover Checklist, to meet TS 5.4.1 at the NSO position. Operating procedure OP-AA-112-101, Section 3.1, requires that, all shift personnel are responsible for reviewing and understanding the logs, checklist and turnover sheets applicable to their shift position before assuming the shift. Section 3.2 requires that, the off-going operator shall not leave his/her work area until he/she is satisfied that his/her relief is fully aware of existing conditions. Section 4.1.3 requires shift personnel to, VERIFY important operating parameters, especially those relating to safety systems, as identified on the turnover sheet prior to assuming the shift... Operator Aid #159 requires the on-coming NSO to perform the following before relieving shift: READ control room logs from last date on-shift or previous four days, whichever is less. DISCUSS with off-going NSO all items on unit and common turnover sheets, shift and daily surveillances, and any other pertinent information. TOUR main control panels and DISCUSS: Status of safety related systems, Running equipment and safety train alignments, Inoperable equipment, including instrumentation, LCORAs (limiting condition for operation required action), including surveillance requirements, Reasons for annunciator alarms, C/O (clearance order) and surveillance work in progress, and Abnormal events over past 24 hours. TOUR main control room back panels. TOUR main control room common panels. Contrary to the above, on January 16, 2007, two NSOs failed to perform a proper shift turnover and relief at Dresden Unit 2 when the operators did not comply with operating procedure OP-AA-112-101 and Operator Aid # 159. Specifically, the on-coming operator did not read the control room logs for the last date on-shift, did not tour the main control room back panels, and did not tour the main control room common panels. The on-coming and off-going operators did not tour the main control panels, and did not discuss all the information regarding unit status. The off-going operator left the work area without the on-coming operator being fully aware of existing conditions. A Notice of Violation (NOV) was issued (VIO 05000237/2007004-03). See Enclosure 1 of this Inspection Report. The NRC has concluded that information regarding the reason for the violation, the corrective actions taken and planned to correct the violation and prevent recurrence and the date when full compliance was achieved is already adequately addressed in this report and this violation is closed |