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05000331/FIN-2017004-0231 December 2017 23:59:59Duane ArnoldNRC identifiedFailure to Evaluate Site Fire and Explosion Hazards in Accordance with 10 CFR 72.212(b) (6)The inspectors identified a Severity Level IV NCV of 10 CFR 72.212(b)(6), Conditions of General License Issued under 72.210, for the failure of thelicensee as of June 9, 2003, to determine whether or not reactor site parameters were enveloped by the cask design bases as considered in the Updated Final Safety Analysis Report (UFSAR). Specifically, the licensee failed to evaluate site-specific fire and explosion hazards that were allowed to be near the dry cask storage systems under its Administrative Control Procedure (ACP) 1412.2, Control of Combustibles, Revision 48. The licensee documented this issue in its CAP as CR 02228514 and CR 02228558 and took timely corrective actions.The inspectors determined that the violation was of more than minor significance using IMC 0612, Power Reactor Inspection Reports, Appendix E, Examples of Minor Issues. Example 4k is applicable to this issue in that the lack of evaluation showing that the quantity of combustible and flammable liquids stored near the dry cask storage system were bounded by the design basis in the UFSAR allowed for a credible unanalyzed fire and explosion scenario that could affect the important-to-safety dry cask storage system. The violation screened as a Severity Level IV NCV. Cross-cutting aspects are not assigned to traditional enforcement violations.
05000331/FIN-2016003-0130 September 2016 23:59:59Duane ArnoldNRC identifiedFailure to Satisfy 10 CFR 50.72 and 10 CFR 50.73 Reporting Requirements for a Condition that Could Have Prevented Fulfillment of a Safety FunctionThe inspectors identified a Severity Level IV NCV of 10 CFR Part 50.72(a)(1) and 10 CFR Part 50.73(a)(1) due to the licensees failure to make a required 8hour non-emergency notification and a 60 day Licensee Event Report to the NRC after discovering a loss of safety function for the reactor core isolation cooling (RCIC) system. The licensee documented this issue in the CAP as CR 02156273 and planned to perform a causal evaluation for the failure to recognize the reportable condition. The inspectors previously evaluated the RCIC systems loss of safety function under the SDP as a finding of very low safety significance (Green) as documented in Section 1R22.b of NRC Integrated Inspection Report 05000331/201600201 (ML16221A619). Violations of the NRCs reporting requirements 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 the guidance in Section 6.9, Paragraph d.9, of the NRC Enforcement Policy and determined the violation associated with the failure to report was a Severity Level IV Violation because the previously evaluated loss of safety function was determined to be a Green finding under the SDP. No cross cutting aspect was assigned to this issue due to the issue being a traditional enforcement violation.
05000331/FIN-2016407-0130 June 2016 23:59:59Duane ArnoldLicensee-identifiedLicensee-Identified Violation
05000331/FIN-2015007-0230 June 2015 23:59:59Duane ArnoldNRC identifiedFailure to Correctly Update the Updated Final Safety Analysis ReportThe inspectors identified a Severity Level IV NCV of 10 CFR 50.71(e) for failure to assure that the information included in the last update of the updated final safety analysis (UFSAR) report contained the latest information developed. The licensee implemented a change to the UFSAR, in preparation for License Amendment 243 that did not contain the latest information developed. Specifically, Section 5.4.6.1 (page 5.430 of Revision 17) was updated with a note that stated the reactor core isolation cooling system was not safety-related. In fact, the reactor core isolation cooling system had always been designated as safety-related. The licensee entered this issue into the CAP as CR 01974995 and prepared an updated final safety analysis report (UFSAR) change that removed the statement that the reactor core isolation cooling system was not safety-related. The inspectors determined that the update to the UFSAR with incorrect information was a performance deficiency in accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, issued on September 7, 2012. The inspectors concluded that traditional enforcement applied because the failure to correctly update the UFSAR impacted the regulatory process. The Enforcement Policy, dated February 4, 2015, Section 6.1.d.3, gave the example that if, a licensee fails to UFSAR 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; then this was a Severity Level IV violation. In this case, the UFSAR was updated incorrectly and did not, result in any unacceptable change to the facility or procedures. The inspectors determined this to be a similar example and therefore was more than minor and a Severity Level IV violation. This violation was not associated with a finding that was evaluated by the significance determination process. Therefore, a cross-cutting aspect was not assigned to this traditional enforcement violation.
05000331/FIN-2015001-0231 March 2015 23:59:59Duane ArnoldNRC identifiedFailure to Report Required Monitoring Results to the NRCThe inspectors identified a Severity Level (SL) IV NCV of 10 CFR 20.2206 for the licensees failure to report results of individual radiation exposure monitoring for individuals required to be monitored by 10 CFR 20.1502. Specifically, on or before April 30, 2014, the licensee failed to report results for all individuals requiring monitoring for the calendar year 2013 to the NRCs Radiation Exposure Information and Reporting System (REIRS) database. The issue was entered into the licensees CAP as CR 02028468. Immediate corrective actions included the resubmittal of radiation exposure data to the REIRS database, which included radiation exposure for all individuals that were required to be monitored. The violation of 10 CFR 20.2206 was assessed in accordance with the traditional enforcement path in IMC 0612, Appendix B, Issue Screening. The inspectors determined that traditional enforcement did apply because reporting failures impact the regulatory process. In accordance with the NRC Enforcement Policy, Section 6.9(d)(2), failures to make a timely written report as required by 10 CFR 20.2206 are categorized as SL IV violations. Cross-cutting aspects are not assigned to traditional enforcement violations.
05000331/FIN-2012002-0731 March 2012 23:59:59Duane ArnoldLicensee-identifiedLicensee-Identified ViolationThe licensee identified a Severity Level (SL) IV NCV of 10 CFR 50.9, Completeness and Accuracy of Information, on June 29, 2010, after it was discovered that six operator licenses did not have medical restrictions for use of Continuous Positive Airway Pressure (CPAP) devices. This issue was reviewed by the inspectors on September 17, 2010, and exited as an URI 05000331/2010004-05, pending further review by NRC and NRC doctors. Corrective actions included re-submittal of NRC Form 396 for the effected operators, documenting the issue in the corrective action program as CR 00580281, and performing an ACE. The licensee also developed a checklist of questions for licensed operators to answer semi-annually regarding the operators use of prescribed medication and reporting of medical conditions. On October 12, 2010, the NRC amended six reactor operator licenses to include the license condition, must use therapeutic devices as prescribed to maintain medical qualifications. The failure to include medical condition restrictions within six operator licenses was a performance deficiency. Because the performance deficiency is considered to potentially impede or impact the ability of the NRC to perform its regulatory oversight function, the performance deficiency was dispositioned using the traditional enforcement process. Per NRC Enforcement Policy, Section 6.4, failing to include medical condition restrictions within operator licenses, which did not adversely affect their ability to safely operate the facility was categorized as an example of a SL IV violation. Additionally, the control room operators performance was monitored and they continued to be evaluated as satisfactory during periodic testing and requalification testing. Because the violation was entered into the licensees CAP, compliance was restored in a reasonable period of time, and was not repetitive or willful; this violation is being treated as a non-cited SL IV violation, consistent with Section 2.3.2 of the NRC Enforcement Policy. The performance deficiency was not considered a finding using IMC 0612, Appendix B, Issue Screening, and did not impact the Reactor Oversight Program Cornerstones of Safety.
05000331/FIN-2011005-0131 December 2011 23:59:59Duane ArnoldNRC identifiedFailure to Make Required Eight Hour Event Report per 10 CFR 50.72(b)(3)(v)(B)A Severity Level (SL) IV NCV of 10 CFR 50.72(b)(3)(v)(B) was identified by the inspectors for the licensees failure to report within eight hours a condition that, at the time of discovery, could have prevented the fulfillment of the Residual Heat Removal (RHR) system Low Pressure Coolant Injection (LPCI) safety function. Specifically, on December 2, 2011, a sizable void was identified in the B LPCI discharge injection line resulting in the LPCI mode of RHR being declared inoperable. The licensee documented the issue into their corrective action program (CAP), reported the condition to the NRC on December 8, 2011, and, was in the process of reviewing the cause of the issue to determine additional corrective actions.The inspectors determined that the issue of concern represented a performancedeficiency because it was the result of the licensees failure to meet a regulatory requirement, and the cause was reasonably within the licensees ability to foresee and correct and should have been prevented. Because the performance deficiency is considered to potentially impede or impact the ability of the NRC to perform its regulatory oversight function, the performance deficiency was dispositioned using the traditional enforcement process. Per NRC Enforcement Policy, Section 6.9.d.9, failing to make a report required by 10 CFR 50.72 is categorized as an example of a Severity Level IV violation. Additionally, because the violation was entered into the licensees CAP, compliance was restored in a reasonable period of time, and was not repetitive or willful; this violation is being treated as a non-cited SL IV violation, consistent with Section 2.3.2 of the NRC Enforcement Policy. Because the performance deficiency was not considered a finding using IMC 0612, Appendix B, Issue Screening, and did not impact the Reactor Oversight Process Cornerstones of Safety, a cross-cutting aspect was not assigned.
05000331/FIN-2010003-0330 June 2010 23:59:59Duane ArnoldNRC identifiedFailure to Submit LER per 10 CFR 50.73(a)(2)(v)(A) and (D)A Severity Level IV NCV of 10 CFR Part 50.73(a)(2)(v)(A) and (D) was identified by the inspectors for the failure of the licensee to report an event or condition that could have prevented the fulfillment of the Turbine Stop Valve Closure and Turbine Control Valve Fast Closure reactor protection system (RPS), and the End-of-Cycle Recirculation Pump Trip (EOC-RPT) safety functions, which are relied upon to shutdown the reactor and maintain it in a shutdown condition, and mitigate the consequences of an accident. The licensee entered the violation into their corrective action program as Action Request (AR) 392462 and CR 568620. Violations of 10 CFR 50.73 are considered to be violations that potentially impact the regulatory process and are dispositioned using the traditional enforcement process instead of the Reactor Oversight Process SDP. Because the performance deficiency was not more than minor and not a finding per IMC 0612, Appendix B, Issue Screening, a cross-cutting aspect was not assigned to this violation.
05000331/FIN-2008005-0231 December 2008 23:59:59Duane ArnoldNRC identified10 CFR 50.59 Safety Evaluation Not Performed for Change in Method of EvaluationA finding of very low safety significance and associated NCV of 10 CFR Part 50.59, Changes, Tests, and Experiments, was identified by the inspector for the licensees failure to provide a documented basis that a change in the method of evaluation for small bore torus attached piping systems as defined in the Plant Unique Analysis Report (PUAR) for torus attached piping did not require prior NRC approval. Because the issue affected the NRCs ability to perform its regulatory function, this issue was evaluated using the traditional enforcement process. The finding was determined to be more than minor because the inspector could not reasonably determine that the change would not have ultimately required NRC prior approval. The finding was determined to be of very low safety significance by the NRCs significance determination process because it was a design deficiency that did not result in actual loss of safety function. This finding had a cross-cutting aspect in the area of Human Performance, Decision Making, because the licensee failed to use conservative assumptions in licensee did neither verify the validity of their justification to not reevaluate the HPCI steam exhaust vacuum breaker piping attached to the modified HPCI steam exhaust piping nor identify adverse consequences due to changes in the HPCI steam exhaust piping resonant frequency content
05000331/FIN-2007003-0230 June 2007 23:59:59Duane ArnoldNRC identifiedFailure to Provide Complete and Accurate Information to the NRC on NRC Form 396Severity Level IV: The inspectors identified a Level IV NCV of 10 CFR 50.9, Completeness and Accuracy of Information. The inspectors identified that the facility licensee, on March 30, 2007, submitted to the NRC, an NRC Form 396, Certification of Medical Examination By Facility Licensee, for a licensed operator applying for renewal of his reactor operator license, that was not complete and accurate in all material respects. Specifically, the NRC Form 396 certified that the licensed operator was not required to have a corrective lens restriction on his license. When the NRC questioned the licensee on the accuracy of the most recent biennial medical examination on the submitted NRC Form 396, the licensee submitted a revised NRC Form 396 on April 19, 2007. The revised NRC Form 396 included a new date for the most recent biennial medical examination, but also showed that the licensed individual was required to have a corrective lens restriction added to his license. This information was material to the NRC because the NRC relies on this certification to determine whether an applicant meets the requirements to operate the controls of a nuclear power plant pursuant to 10 CFR Part 55. The finding was determined to be more than minor because the information associated with the license renewal of the individual was provided to the NRC under a signed statement by the Site Vice President and could have impacted an NRC licensing decision. The licensed operator could have been, without NRC intervention, issued a license without a corrective lens restriction added to his license. The finding was determined to be of low safety significance because the license renewal application for the reactor operator was not renewed until complete and accurate information was received on a revised NRC Form 396 that showed a corrective lens restriction for the licensed individual. (Section 4OA5.1)
05000331/FIN-2007401-0130 June 2007 23:59:59Duane ArnoldNRC identifiedSecurity
05000331/FIN-2005013-0131 December 2005 23:59:59Duane ArnoldNRC identifiedUFSAR Change Reducing Capability of the Automatic Runback of the Recirculation Pumps on a Feedwater Pump TripThe inspectors identified a Severity Level IV Non-Cited Violation of 10 CFR 50.59 in that the licensee failed to perform an adequate safety evaluation review for changes made to the facility as described in the Updated Final Safety Analysis Report (UFSAR). Specifically, the licensee adversely changed the description in the UFSAR of the license basis function of the recirculation pump runback in that the recirculation runback feature could no longer prevent a reactor scram if a feedwater pump tripped. Within the 10 CFR 50.59 evaluation, the licensee failed to provide a basis for why this malfunction of the recirculation pumps runback logic (equipment important to safety) did not present more than a minimal increase in the likelihood of occurrence of a malfunction of a Structures, Systems, and Components (SSC) important to safety Because the issue affected the NRCs ability to perform its regulatory function, this finding was evaluated using the traditional enforcement process. The finding was determined to be more than minor because the inspectors could not reasonably determine that the UFSAR change, which adversely affected equipment important to safety, would not have ultimately required NRC approval. The finding was determined to be of very low safety significance (Green) because the recirculation runback feature was not a mitigating function.