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 QSignificanceCCAIdentified byTitleDescription
05000410/FIN-2018003-022018Q3Severity level MinorNRC identifiedMinor ViolationDuring the review of Licensee Event Report (LER) 05000220/2017-002-01, Manual Reactor Scram Due to Presesure Oscillations, the inspectors identified a minor violation of 10 CFR 50.9, Completeness and accuracy of information. The LER was found to be inaccurate. Specifically, the LER timeline contained inaccurancies regarding the time operators entered a special operating procedure and did not include an actuation of high-pressure coolant injection (HPCI). The timeline stated at 2:10 AM operators entered the special operating procedure for Pressure Regulator Malfunction, due to reactor pressure oscillations of 2-3 psig. At 2:27 AM operators inserted a manual scram of the reactor due to pressure oscillations exceeding procedural limits. This information was confirmed by a review of the operational logs for March 20, 2017. During OI Investigation 1-2018-002, it was determined that this entry was not accurate and although an exact time could not be established is was estimated to have been at 2:20 AM vice 2:10 AM. Additionally the timeline did not include a mention that at 2:16 AM unexpected turbine trip signal was received and HPCI was initiated due to a tagging error. Operators reset HPCI at 2:18 AM and restored main feedwater flow to restore Reactor Vessel water level. A sixty day telephone notification instead of a written licensee event report was conducted for this invalid initiation of HPCI was completed on May, 11, 2017, as EN 52747 as allowed by 10 CFR 50.73(a)(2)(iv). Screening: Violations involving the submittal of inaccrurate or incomplete information are evaluated under Traditional Enforecement because they impact the NRCs regulatory process. Accordingly, the inspectors evlauted this issue against the example violations in Section 6.9 of the NRC Enforcement Policy. Inspectors concluded that the violation is of minor safety significance because the inaccurate information did not change the NRCs review of the licensee event report. Enforcement: 10 CFR 50.9 requires that information provided to the Commission by a licensee shall be complete and accurate in all material respects. Contrary to the above, on June 22, 2015, Entergy provided information to the Commission that was not complete and accurate in all material respects. In the licensee event report, Exelon documented incorrect information that resulted in the NRC launching a substation further inquiry (OI investigation), but did not substantiate that licensed operators deliberately failed to follow a Technical Specifications required procedure. Exelon identified the inaccuracy and entered the issue into the corrective action program (IR 04091110) on January 7, 2018, and submitted LER 05000220/2017-002-01 on August 18, 2018, revising the timeline to show operators entering N1-SOP-31.2 at 2:20 AM vice 2:10 AM. The disposition of this violation closed Licensee Event Report 05000220/2017-002-01
05000410/FIN-2018003-012018Q3GreenH.1NRC identifiedFailure to Ensure that Thermal Power is Less Than or Equal to the Licensed Power LimitThe inspectors identified a Green finding and associated non-cited violation (NCV) of the NMPNS Unit 2 Operating License (NPF-69), Condition 2.C(1), Maximum Power Level, when Exelon did not ensure that thermal power was less than or equal to the licensed power limit of 3988 megawatts-thermal (MWth). Specifically, on multiple occurrences between May 22, 2018 and October 19, 2018, licensed operators in the main control room did not appropriately monitor and control 2-hour average thermal power at or below the licensed power limit. The inspectors determined the 2-hour average thermal power exceeded the licensed power limit outside of normal steady-state fluctuations, and did not take timely, effective corrective action to reduce thermal power below the licensed power limit when the 2-hour average was found to exceed the licensed power limit
05000220/FIN-2018002-022018Q2GreenH.1NRC identifiedInadequate Procedure Causes Water Hammer Condition Resulting in Isolation and Inoperability of the 12 Train of the Emergency Condenser SystemThe inspectors identified a Green finding and associated NCVof 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, when Exelon did not provide appropriate quantitative or qualitative criteria and guidance to operators in procedure N1- OP- 13 Emergency Cooling System to return an emergency condenser loop to service without inducing a water hammer condition which caused operators to re-isolate the emergency condenser loop and declare it inoperable
05000410/FIN-2018002-012018Q2GreenP.1NRC identifiedFailure to Ensure Proper Control of the Standby Gas Treatment System Damper Valve, 2GTS*V2000B, Within Procedures, Materials, and Design Control MeasuresThe inspectors identified a Green finding and associated NCVof 10 CFRPart 50, Appendix B, Criterion III, Design Control, when Exelon failed to ensure proper control of the SGTS damper valve 2GTS*V2000B within procedures, materials, and design control measures. Specifically, on April 15, 2018 operators attempted to run B SGTS for containment purge; however, no flow was observed and the system was secured. Operators discovered the 2GTS*V2000B closed due to the failure of the operating mechanism to maintain control of the valve position.
05000220/FIN-2018001-012018Q1NRC identifiedPotential Failure to Submit an 8-Hour Event Notification for a Valid Actuation of HPCOn March 18, 2018,at 1:18 a.m., during the Unit 1maintenance outage while the unit was in cold shutdown, operators received multiple low level alarms on the GEMAC 11 and 12 level indications. Operators responded by adjusting reactor water cleanup reject flow and the feedwater minimum flow control valve to raise reactor water level. Upon the operators making the adjustment to reactor water level, the feedwater low flow control valve was slow to respond, but eventually opened more rapidly, and the increased flow from feedwater resulted in a rapid rise in reactor water level. At 1:28 a.m., indicated reactor water level rose to the 95-inch trip setpoint for the 11 and 12 Yarway level indication instruments, resulting in a turbine trip and HPCI initiation signal. The HPCI pumps were tagged out and thus did not inject, and the turbine was offline for the shutdown. The 11 and 12 Yarway level indication instruments provide reactor protection system logic inputs for reactor vessel water level; however, the Yarway level indication instruments are not density compensated. Therefore, under cold shutdown conditions, actual reactor vessel water level was lower than indicated water level on the 11 and 12 Yarways. During cold shutdown conditions, the GEMAC level instruments, which are calibrated to cold shutdown conditions, provide an accurate indication of actual reactor vessel water level. The GEMAC instruments both indicated well below the trip setpoint of 95 inches (indicated ~72 inches) when the turbine trip and HPCI initiation signal were received. Exelon determined that this event was not reportable under 10 CFR 50.72.Title 10 CFR 50.72(b)(3)(iv)(A) states, Any event or condition that results in valid actuation of any of the systems listed in paragraph (b)(3)(iv)(B) of this section, except when the actuation results from and is part of a pre-planned sequence during testing or reactor operation. (B) The systems to which the requirements of paragraph (b)(3)(iv)(A) of this section apply are: 10 (5) BWR reactor core isolation cooling system; isolation condenser system; and feedwater coolant injection system. Planned Closure Action(s): The inspectors requested the 10 CFR 50.72 subject matter experts at the Office of Nuclear Reactor Regulation (NRR) and Office of General Council (OGC) to review whether this was a valid actuation and thus reportable. The inspectors are opening an unresolved item (URI) to determine if a performance deficiency exists.Licensee Action(s): Licensee entered the concern into their corrective action program, and communicated with NRC Region I and NRR Staff. Exelons position is that the event was not reportable. Corrective Action Reference:IR 04116336 NRC Tracking Number: 05000220/2018001-01
05000410/FIN-2018001-022018Q1NRC identifiedPotential Inadequate 50.59 Evaluation for TS 3.3.1.1 Bases ChangeOn February 23, 2018, Exelon personnel performed a 50.59 Screening for a change to Unit 2 TS Bases 3.3.1.1, Reactor Protection System (RPS) Instrumentation, for MSIV and TSV surveillance testing. Exelon personnel performed this activity to address operating experience associated with the use of a test box that prevents a scram signal during RPS surveillance testing for TS 3.3.1.1 Function 5 MSIV Closure and Function 8 TSV Closure. TS Bases B 3.3.1.1, C.1, Revision 1 was revised to state, in part, For Function 5 (MSIV Closure), this would require both trip systems to have at least one channel associated with the MSIVs for each main steam line in one Trip Logic Channel (not necessarily the same main steam lines for both trip systems), Operable or in trip (or the associated trip system in trip). For Function 8 (Turbine Stop Valve Closure), this would require both trip systems to have the channels for one Trip Logic Channel, Operable or in trip (or the associated trip system in trip).The inspectors questioned whether the change to TS Bases B 3.3.1.1 resulted in a change to the implementation of TS 3.3.1.1. A licensee is permitted to make changes to their Technical Specification Bases documents without NRC review and approval. However, in certain cases, such as a change to the Technical Specification Bases that would change how the associated Technical Specification is applied, NRC review and approval would be required.Planned Closure Action(s): The inspectors sent written questions to request assistance from NRR to determine whether this change to the TS Bases reasonably would have required NRC review and approval. The inspectors are opening a URI to determine if this is violation of 10 CFR 50.59 and if it is more than minor. Licensee Action: Documented NRCs concern as AR 04055602. Exelons position is the change would not affect how TS 3.3.1.1, or its note, is applied and therefore NRC review was not required.Corrective Action Reference: AR04055602 NRC Tracking Number: 05000410/2018001-02
05000410/FIN-2017004-032017Q4GreenH.5NRC identifiedInadequate Operability Determination forImpairedInternal Flood BarrierAn NRC-identified Green NCV of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified when Exelon failed to perform an adequate operability determination in accordance with OP-AA-108-115, Operability Determinations, Revision 20, upon identification of Unit 2 degraded internal flood barriers that support operability of emergency core cooling system (ECCS) equipment. Specifically, from November 21 until December 10, 2017, Exelon failed to properly evaluate the excavation of internal flood barriers and concluded there was a reasonable expectation for operability of the supported ECCS systems. Exelon entered this issue into the CAP as IR 04082686. Corrective actions included conducting a detailed evaluation of operability for the supported safety-related systems, additional training associated with TS 3.0.9, including a focus on the need for risk assessments when entering TS 3.0.9, and a procedure change to CC-AA-201, Plant Barrier Control Program, and CC-NM-201-1001, Plant Barrier Control Program Implementation, which is the NMPNS specific procedure to address the vulnerabilities associated with impairing multiple required barriers. This finding is more than minor because it is associated with the human performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, from November 21 until December 10, 2017, Exelon failed to adequately evaluate the operability of a degraded internal flooding barrier and the potential impact on operability of the supported ECCS system equipment. The inspectors identified that the internal flood barrier was excavated such that there was not sufficient material to ensure adequate flood protection, and resulted in a reasonable doubt for the operability of the supported ECCS systems. This finding is also similar to example 3.j and 3.k of IMC 0612 Appendix E, Examples of Minor Issues, issued August 11, 2009, because the condition identified by the inspectors resulted in a reasonable doubt for the operability of the ECCS supported systems and additional analysis was necessary to verify operability. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, the inspectors determined that the finding was of very low safety significance (Green), because the finding was not a design or qualification deficiency, did not represent a loss of system safety function, and did not screen as potentially risk significant due to vulnerability to external initiating events. This finding has a cross-cutting aspect in the area of Human Performance, Work Management, because Exelon failed to implement a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. As a result, Exelon personnel failed to recognize that work activities that impaired internal flood barriers on both Division I and II low pressure ECCS pump rooms were executed simultaneously, which led to an unplanned entry into TS Limiting Condition for Operation (LCO) 3.0.9. (H.5)
05000220/FIN-2017004-012017Q4GreenH.13NRC identifiedMain Control Room Annunciators 10 CFR 50.65(a)(2) Demonstration Not MetAn NRC-identified Green non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 50.65 (a)(2), was identified because Exelon did not adequately demonstrate that the performance of the Unit 1 main control room (MCR) annunciators was effectively controlled through performance of appropriate preventive maintenance. Specifically, Exelon did not identify and properly account for functional failures of the MCR annunciators in June 2017, and therefore did not recognize that the annunciator system exceeded its performance criteria and required a Maintenance Rule (a)(1) evaluation. On December 7, 2017, Exelon entered the issue into their CAP as IR 04081698 and performed a review of the events identified by the inspectors that were applicable to the maintenance rule annunciator system. Corrective actions included Exelon determining that the events were functional failures, and initiated an (a)(1) evaluation based on the MCR annunciator system functional failures exceeding the designated performance criteria of an allowable one functional failure per 24 months.This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affects the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, following the two failures of the main control annunciator panel in June 2017, Exelon did not identify the failures as functional failures, and consequently, did not establish goals and monitoring criteria in accordance with 10 CFR 50.65(a)(1). In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The SDP for Findings At-Power, issued June 19, 2012, the inspectors determined that the finding was of very low safety significance (Green) because the finding did not affect the design or qualification of a mitigating structure, system, or component (SSC), did not represent a loss of system and/or function, did not involve an actual loss of a function of at least a single train or two separate safety systems for a greater time than allowed by technical specifications (TS), and did not represent an actual loss of function of one or more non-TS trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program. T his finding has a cross-cutting aspect in the area of Human Performance, Consistent Process, in that Exelon failed to use a consistent, systematic approach to make decisions. Specifically, Exelon did not ensure their review process for issues entered into the CAP was effectively implemented to ensure proper evaluations for all applicable maintenance rule systems affected by a n SSC failure. (H.13)
05000410/FIN-2017004-042017Q4GreenSelf-revealingIneffective Correction Action Results in Failure of Instrument Air SystemThe inspectors documented a self-revealing Green finding (FIN) of CNG-CA-1.01-1000, Corrective Action Program, Revision 01100, because Nine Mile Point Nuclear Station (NMPNS) failed to implement corrective actions at NMPNS Unit 2 to remove and replace all un-annealed red brass piping for the instrument air system during the April 2008 refueling outage. Specifically, on July 13, 2017, Unit 2 experienced a rupture of un-annealed red brass instrument air pipe which resulted in a feedwater pump trip and a reactor recirculation pump runback to 49 percent. Exelons corrective actions for the July 13, 2017 failure of un-annealed red brass instrument air piping included wrapping the instrument air piping with a material that both supports the piping and prevents potential stress corrosion cracking. Exelon has developed work orders to replace the piping in the upcoming outage in spring 2018. Exelon also improved staff training for accountability and work checking to verify that generated work orders are completed and closed out. Exelon entered this issue into the corrective action program (CAP) as issue report (IR) 04031685, and performed a corrective action program evaluation (CAPE). This finding is more than minor because it is associated with the design control attribute of the Initiating Events cornerstone and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. Specifically, NMPNS staff failed to complete corrective actions to replace Unit 2 un-annealed red brass instrument air piping, which was susceptible to stress corrosion cracking, resulting in a feedwater pump trip and a reactor recirculation runback to 49 percent on July 13, 2017. The inspectors evaluated the finding using IMC 0609, Attachment 4, Initial Characterization of Findings, issued on October 7, 2016, and Exhibit 1 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012. The inspectors determined that the finding was of very low safety significance (Green) because it did not result in the complete or partial loss of a support system that contributes to the likelihood of, or cause, an initiating event and affected mitigation equipment. The inspectors determined that this finding did not have a cross-cutting aspect because the performance deficiency occurred greater than 3 years ago; therefore, it is not considered to be indicative of current plant performance.
05000220/FIN-2017004-022017Q4GreenP.2NRC identifiedInadequate Fill and VentProcedure for Control Room Chiller Results in Unplanned LCO EntryAn NRC-identified Green NCV of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified for Exelons failure to ensure that activities affecting quality were prescribed in a manner appropriate to the circumstances for the Unit 1 control room chiller system. Specifically, Exelon procedure N1-OP-49, Control Room Ventilation System, Revision 03800, Section H.5, Venting of Control Room Chiller Circulating Water Pump 11 and 12 Discharge Piping, led personnel to inadequately fill and vent the 12 control room chiller during system restoration from maintenance, while in a single chiller lineup. As a result, on October 15, 2017, control room chiller 12 tripped on low flow, and due to a prior trip of 11A control room chiller compressor, an unplanned 7-day LCO in accordance with TS 3.4.5.e, Control Room Air Treatment System, was entered due to an insufficient number of available chiller compressors to provide adequate control room cooling. Exelon entered this issue into the CAP as IR 04090200. Corrective actions included generating a procedure change to correct N1-OP-49 Section H.5, which provides instruction for filling and venting when in a single chiller lineup This finding is more than minor because it is associated with the procedure quality attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective of providing reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, Exelon failed to prescribe an adequate fill and vent procedure for the Unit 1 control room chillers which led to a trip of the 12 chiller on low flow while troubleshooting of chiller compressor 11A was on-going, resulting in an unplanned TS LCO entry. The inspectors evaluated this finding using IMC 0609.04, Initial Characterization of Findings, and Exhibit 3 of IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The performance deficiency did not represent a degradation of the radiological barrier function provided for the control room. Additionally, the performance deficiency did not represent a degradation of the barrier function of the control room against smoke or a toxic atmosphere. Therefore, this finding was determined to be of very low safety significance (Green). This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Evaluation, because between 2014 and 2017 the inspectors noted over 20 issue reports documenting issues affecting reliability of the control room chiller system. Exelon failed to thoroughly evaluate the issues associated with the chillers to ensure that resolutions address causes and extent of conditions commensurate with their safety significance. Specifically, Exelon failed to effectively evaluate previous chiller trips and to prevent additional trips of the chiller system such as the one that occurred on October 15, 2017. (P.2) (Section 1R12.b.2)
05000220/FIN-2017004-052017Q4GreenLicensee-identifiedLicensee-Identified ViolationThe following violation of very low safety significance (Green) was identified by Exelon and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as a NCV. Title 10 CFR 50.65(a)(4) requires, in part, ...the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities. Exelon procedure WC-AA-101-1006, On-Line Risk Management and Assessment, Revision 001, Section 4.1.3, states to consider work activities that cause equipment to be unavailable (e.g., trains of systems) for assessment of risk under the requirements of 10 CFR 50.65(a)(4). Contrary to the above, on October 17, 2017, Exelon identified a discrepancy in PARAGON (risk software) that resulted in an improper risk assessment for the days planned work. Review and correction of the error resulted in an elevated risk condition of Yellow during Nine Mile Point Unit 1, 11 feedwater pump (FW) maintenance. This performance deficiency was determined to be more than minor because it adversely affected the human performance attribute of the Mitigating Systems cornerstone and affected cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, on October 17, 2017, Exelon identified a planned activity that resulted in an unplanned Yellow risk activity during planned maintenance of the 11 FW pump. In addition, IMC 0612, Appendix E, Examples of Minor Issues, under Section 7, Maintenance Rule, Example E for inadequate risk assessment states in part that a more-than-minor issue would put the plant into a higher licensee-established risk category. The finding was evaluated using IMC 0609, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process. The finding was determined to affect the overall plant risk with the 11 FW Pump being out of service for maintenance with PARAGON not elevating the overall plant risk from green to yellow. The risk deficit was elevated and determined to not be greater than 1E-6 event per year for Incremental Core Damage Probability Differential and not greater than 1E-7 events per year for Incremental Large Early Release Probability Differential. Therefore, the finding was determined to be of very low safety significance (Green). Exelon entered this issue into its CAP as IR 04064241.
05000410/FIN-2017002-012017Q2GreenH.4NRC identifiedInadequate Extent of Condition Results inUnplanned Yellow Risk ConditionThe inspectors identified a Green non-cited violation (NCV) of Title 10 of the Code of Federal Regulation (10 CFR) 50.65(a)(4), Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, when Exelon did not assess and manage the increase in risk for online maintenance activities. Specifically, on May 24, 2017, the inspectors identified a planned surveillance activity which caused unavailability of the A residual heat removal (RHR) system minimum flow valve that was not recognized by the Exelon staff as a, Yellow, elevated risk activity in accordance with their EOOS (Equipment Out of Service) probabilistic risk assessment (PRA) model. Exelon staff generated issue report (IR) 04015294 to address the failure to recognize the Yellow, elevated risk activity and failure to review adequate extent of condition. Corrective actions include evaluating PRA to assess if risk can be reduced to Green with compensatory actions and providing training to operations to enhance PRA modeling of system availability. Following review of the PRA model, Exelon plans to evaluate all surveillance procedures as part of extent of condition that could impact availability of the A RHR minimum flow valves.This performance deficiency is more than minor because it affected the human performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, on May 24, 2017, the inspectors identified a planned activity that resulted in an unplanned Yellow risk activity during planned maintenance that resulted in unavailability of a component used to support the A RHR system. Additionally, this issue is similar to Example 7.f of IMC 0612, Appendix E, Examples of Minor Issues, issued August 11, 2009, because the overall elevated plant risk placed the plant into a higher licensee-established risk category. The inspectors determined that this finding is of very low safety significance (Green). Because the incremental core damage probability deficit was less than 1E-6 and the incremental large early release probability was less than 1E-7, this finding was determined to be of very low safety significance (Green). The cause of the finding has a cross-cutting aspect in the area of Human Performance, Teamwork, because Exelon staff did not effectively communicate internally to ensure that corrective actions were being addressed to resolve concerns with risk associated with A RHR minimum flow valve availability. Specifically, Exelon staff incorrectly believed that integrated risk management guidance corresponded to PRA availability. Thus, it was assumed risk would remain Green during surveillance and maintenance activities that resulted in the A RHR minimum flow valve being unavailable; and a failure to recognize future maintenance activities that resulted in risk being Yellow. (H.4)
05000220/FIN-2017002-022017Q2GreenLicensee-identifiedLicensee-Identified ViolationThe following violation of very low safety significance (Green) was identified by Exelon and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as an NCV.Technical Specification 6.4 Procedures, Section 6.4.1, states, in part, that, written procedures and administrative policies shall be established, implemented and maintained ... that cover the following activities: a. The applicable procedures recommended in Regulatory Guide (RG) 1.33, Appendix A, November 3, 1972.Appendix A of RG 1.33 lists typical safety-related activities which should be covered by written procedures. Section I.1 of RG 1.33 includes procedures for performing maintenance which can affect the performance of safety-related equipment and should be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. Section 4.3.4 of MA-AA-796-024, Scaffold Installation, Inspection, and Removal, Revision 11 states to ensure an adequate inspection is performed upon completion of scaffold erection for planned maintenance. Contrary to the above, on June 29, 2017 it was identified by Exelon staff that a scaffold surrounding the 11 feedwater flow control valve, FCV-29-141, would have prevented manual operation as required in accordance with EOP-1, NMP1 EOP Support Procedure, Revision 01601 Attachment 26, Reactor Pressure Valve Level Control Through Feedwater Pumps 11 and 12 flow control valves, and other special operating procedures during the previous 45 days.The inspectors evaluated the finding using IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609 Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012. The inspectors determined that the finding was of very low safety significance (Green), because the finding was not a design or qualification deficiency, did not represent a loss of system safety function, and did not screen as potentially risk significant due to seismic, flooding, or severe weather initiating event. Because this violation was determined to be of very low safety significance and entered into the CAP as IR 4027382, it is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy.
05000220/FIN-2017001-022017Q1GreenNRC identifiedFailure to Identify and Correct a Non- Conforming Condition in Safety-Related UPSsGreen. The inspectors documented a self-revealing Green NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions, for the failure to identify and correct a non-conformance (an inadequate capacitor) in safety-related uninterruptable power supplies (UPSs) 162 and 172. Between 2008 and 2017, this non-conformance led to multiple component failures, loss of vital power supplies, plant transients, and in one case, loss of the emergency condenser safety function. Specifically, in 2003, during a preventative maintenance activity, NMPNS installed a commercially dedicated capacitor (part number C-805) that was not rated for the normal service temperature for the application. This resulted in chronic overheating, reduction of service life, and in seven cases failures (internal shorts of C-805) which resulted in the loss of the associated safety-related UPS. Upon identification, Exelon entered each failure into the CAP conducted an apparent cause evaluation (ACE) following the 2016 and 2017 failures, and developed corrective actions to replace the underrated capacitors. The performance deficiency was determined to be more than minor because it affected the equipment performance attribute of the Initiating Events Cornerstone and adversely affected the cornerstone objective of limiting the likelihood of events that upset plant stability and challenge the critical safety functions during shutdown as well as power operations. Specifically, the underrated capacitors failure resulted in the loss of a vital alternating current (AC) bus, a support system and in one case the unplanned loss of a safety function required to bring and maintain the plant in safe shutdown. In accordance with IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, a detailed risk assessment was required. Using the NMPNS Unit 1 Standardized Plant Analysis Risk (SPAR) Model Version: 8.21, model date January 28, 2010, a Region I senior reactor analyst ran a zero maintenance condition assessment with basic events for emergency condenser (EC) motor operated valve (MOV) 39-09R and EC MOV 39-10R, normally closed condensate return isolation valves, failed for a duration of one hour. The results were a CDP of 1.37E-08. The dominant risk sequences involved loss of feedwater and loss of offsite power. As a result, the finding is of very low safety significance (Green). The performance deficiency for this finding occurred in 2008. Because the performance deficiency occurred greater than 3 years ago and is not indicative of current performance based upon the corrective actions taken following the 2016 failure, there is no cross-cutting aspect assigned to this finding.
05000220/FIN-2017001-012017Q1GreenH.7NRC identifiedDeficient Design Control of Outboard MSIV Pilot Valve Instrument Air SupplyGreen. The inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion III, Design Control, for Exelons failure to correctly translate the design basis into the NMPNS Unit 1 instrument air system to ensure the Unit 1 outboard main steam isolation valves (MSIVs) were capable of performing their design function. Specifically, the NMPNS Unit 1 Updated Final Safety Analysis Report (UFSAR) states, Reliable operation of instrument air end users and in-line components is dependent on the filtration and removal of particulates greater than 40 microns. Additional filtration for various components exists where the 40 micron limit is not satisfactory. The MSIV pilot valves at Unit 1 have a tighter clearance than the 40 micron limit. However, contrary to the UFSAR, NMPNS did not install additional filtration upstream of the pilot valves. As a result, during a surveillance test conducted on December 10, 2016, foreign material in the instrument air system potentially contributed to the failure of an outboard MSIV. Exelons immediate corrective actions included entering this issue into its corrective action program (CAP) as issue report (IR) 03959732, performing an air purge of the instrument air system to remove foreign material from the system, and replacing the current style pilot valves with new style valves with larger clearances during the spring 2017 refueling outage. 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 of providing reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents for events. Specifically, Exelon failed to install additional filtration in the instrument air system upstream of the outboard MSIV pilot valve in accordance with the Unit 1 UFSAR even though the internal clearance of the pilot valve was significantly less than the 40 micron particulate limit. Additionally, example 3.j from IMC 0612, Appendix E, Examples of Minor Issues, provides a similar scenario to this issue. Example 3.j details that a performance deficiency is more than minor if the error results in a condition where there is a reasonable doubt of the operability of a system or component. This performance deficiency is more than minor because without the additional filtration defined in the UFSAR there 4 existed a reasonable doubt of operability for the Unit 1 outboard MSIVs. The finding was evaluated in accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 3 of IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, and determined to be of very low safety significance (Green). The finding has a cross-cutting aspect in the area of Human Performance, Documentation, because Exelon failed to create and maintain complete, accurate, and up-to-date documentation pertaining to instrument air sampling for high particulate. Specifically, Exelon failed to develop and implement a surveillance testing program for the instrument air system that would alert personnel that particulate greater than 5 microns could jeopardize the operability of the outboard MSIVs. (H.7)
05000220/FIN-2016004-012016Q4GreenLicensee-identifiedLicensee-Identified ViolationThe following violation of very low safety significance (Green) was identified by Exelon and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as an NCV. Technical Specification 6.4.1 for Unit 1 and TS 5.4.1 for Unit 2 state that, Written procedures shall be established, implemented, and maintained covering the following activities: ... d. Fire Protection Program Implementation. Procedure OP-AA-201-003, Fire Drill Performance, implements portions of the Exelon fire protection program, and OP-AA-201-003 states fire drills shall be conducted quarterly for each shift fire brigade. Contrary to the above, Exelon failed to correctly implement its fire brigade training program procedure. Specifically, Exelon failed to conduct fire drills for brigade teams A, C, and D for the third quarter 2015 as required by OP-AA-201-003 because of scheduling conflicts caused by emergent and planned work and station activities. For fire brigade A, the brigade was initially scheduled to perform a third quarter fire drill on July 22, 2015. However, that drill as well as subsequent drills which were scheduled to be performed on August 25, 2015, and September 30, 2015, respectively, were cancelled to facilitate other work activities. For fire brigade C, the third quarter drill which was scheduled for September 8, 2015 was cancelled because of station work load. For fire brigade D, a third quarter drill that was scheduled for September 24, 2015, was also canceled because of other work activities. On October 2, 2015, Exelon documented the missed quarterly drills in the CAP as IR 02564520. During the fourth quarter, crews A, C, and D each conducted a make-up drill as well as a regular quarterly drill. However on October 31, 2015, crew C failed its make-up drill. Crew C was remediated and passed a repeat drill on November 10, 2015. The inspectors determined that the performance deficiency was more than minor in accordance with IMC 0612, Appendix B, Issue Screening, because if left uncorrected, it could lead to a more significant safety concern. The inspectors decision was informed by examples 3j and 3k in IMC 0612, Appendix E, Examples of Minor Issues. The examples refer to an issue not being minor if significant programmatic deficiencies were identified with the issue that could lead to worse errors if left uncorrected. Specifically, 60 percent of the NMPNS fire brigade teams had missed their quarterly fire drill requirement which is indicative of a programmatic issue and there is a reasonable concern as to the effectiveness of the fire brigade since the required training had not been completed and one crew subsequently failed its next drill. Based on IMC 0609, Attachment 4, Initial Characterization of Findings, findings that involve discrepancies with the fire brigade are directed to IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power. From IMC 0609 Appendix A Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined that a the final significance must be determined using IMC 0609, Appendix M, Significance Determination Process Using Qualitative Criteria. The finding was determined to have very low safety significance (Green) because a prior similar violations significance bounded this findings significance. The prior similar violation occurred at NMPNS, which was documented in inspection report 05000220/410/2009006-01 as an NCV. Because this violation was determined to be of very low safety significance and entered into the CAP in IR 02564520, it is being treated as an NCV, consistent with section 2.2.3 of the NRC Enforcement Policy.
05000220/FIN-2016404-012016Q4GreenH.6NRC identifiedSecurity
05000220/FIN-2016003-012016Q3GreenLicensee-identifiedLicensee-Identified Violation10 CFR 50.54q(2) requires, in part, that the license holder shall follow and maintain the effectiveness of an emergency plan that meets the requirements in appendix E and, for nuclear power reactor licensees, the planning standards of 50.47(b). 10 CFR 50.47(b)(14) requires, in part, periodic exercises be conducted to evaluate major portions of emergency response capabilities and develop and maintain key skills. Exelon procedure EP-AA-122-100, Drills and Exercise Planning and Scheduling, Revision 6, implements this planning standard and requires health physics drills be performed every 6 months. Contrary to the above, from December 28, 2015 to July 15, 2016 Exelon failed to appropriately implement its approved emergency plan by not meeting planning standard 10 CFR 50.47(b)(14). Specifically, Exelon failed to conduct and document the performance of a required health physics drill for the second half of 2015 as required by step 4.4 of Exelon procedure EP-AA-122-100. This performance deficiency was determined to be more than minor because it impacted the Emergency Preparedness cornerstone objective of ERO readiness to ensure that Exelon is capable of implementing adequate measures to protect the health and safety of the public and its workers in the event of a radiological emergency. The finding was evaluated using IMC 0609 Appendix B, Emergency Preparedness Significance Determination Process. The finding was determined to affect planning standard 10 CFR 50.47(b)(14) and matched an example of a degraded planning standard function. Therefore, the finding was determined to be of very low safety significance (Green). Exelon has entered this issue into its CAP as IR 02686128.
05000220/FIN-2016403-012016Q2GreenNRC identifiedSecurity
05000410/FIN-2016002-012016Q2GreenNRC identifiedIneffective Corrective Action Results in Water Intrusion to Battery Switchgear RoomThe inspectors identified a Green finding (FIN) of PI-AA-125, Corrective Action Program, Revision 3, when Exelon failed to implement adequate corrective actions in March 2003, to prevent water intrusion into the Unit 2 normal switchgear building area at elevation 237. Specifically, on May 4, 2016, the inspectors observed water leaking into the normal switchgear room through a wall on elevation 237. The leakage was through a section of the wall that contained electrical junction boxes that were not sealed. The water progressed under inverter 2BYS-SWG001B, which led to the potential for a reactor scram from an electrical fault associated with uninterruptible power supply battery breakers. Previously, a reactor scram had occurred at Unit 2 on March 4, 2014, when the inverter was lost because of an electrical fault, as such this was a known initiating event single point vulnerability . Corrective actions included entering the issue into the corrective action program (CAP) (IR 02664534), generating work order (WO) C93414574 to seal or repair the wall, and installing temporary barriers to redirect any water away from the switchboard. The WO is scheduled to be performed in October 2016 with an action to assess moving the work to the refueling outage if needed to remove the electrical junction boxes to apply coating to the wall. The finding is more than minor because it is associated with the Protection Against External Factors attribute of the Initiating Events cornerstone and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. Specifically, Exelon did not ensure the surface area behind the electrical junction boxes was coated to prevent water intrusion into the normal switchgear room at elevation 237. The water intrusion through this area of the wall had the potential to cause an electrical fault on 2BYS-SWG001B resulting in a reactor scram similar to the reactor scram in March 2014. The inspectors evaluated this finding using IMC 0609.04, Initial Characterization of Findings, and Exhibit 1 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power. The inspectors determined that this finding was of very low safety significance (Green) because it did not represent the potential for both a reactor scram and a loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. The inspectors did not assign a cross-cutting aspect to this finding because the performance deficiency occurred greater than three years ago; therefore, it is not considered to be indicative of current plant performance.
05000410/FIN-2016002-022016Q2GreenP.1NRC identifiedFailure to Identify Wide Range Level Indication Impacts Operability of HPCS and RCICThe inspectors identified a Green NCV of Unit 2 Technical Specification (TS) 3.5.1, Emergency Core Cooling (ECCS) Systems-Operating, and TS 3.5.3, Reactor Core Isolation Cooling (RCIC) System, for failure to ensure all necessary attendant instrumentation required for the systems to perform their specified safety functions were capable of performing their related support function in all require modes of applicability. Specifically, the inspectors identified the Unit 2 wide range level indication to be inaccurate during Mode 2 and at 200 pounds per square inch gauge (psig) reactor pressure, a mode of applicability requiring both high-pressure core spray (HPCS) and RCIC to be operable. This resulted in a high level trip signal being locked preventing HPCS or RCIC from auto initiating, rendering the systems inoperable. Upon identification, Exelon generated issue report (IR) 02667837 to address the inspectors concern regarding the wide range level indication. An action was created to evaluate the impact of the wide range level discrepancy with regard to its impact on safety-related functions to supply water in the TS Mode of Applicability. Exelon also plans to assess the need for a TS amendment. The performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, Exelon failed to recognize that the wide range level indication did not provide accurate indication at low reactor pressures and temperatures, preventing automatic safety-related functions associated with high drywell pressure automatic initiation signals and manual start functions. This would require operators to manually open the HPCS and RCIC injection valves during these conditions should a loss of offsite power or loss-of-coolant accident occur. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, the inspectors determined that the finding was of very low safety significance (Green), because the finding was not a design or qualification deficiency, did not represent a loss of system safety function, and did not screen as potentially risk significant due to seismic, flooding, or severe weather initiating event. The finding had a cross-cutting aspect in the area of Problem Identification and Resolution, Identification. Exelon personnel had many opportunities, including during the reactor startup in May of 2016, to question operability of the instrumentation that provides input for automatic initiation and isolation signals. As a result, Exelon personnel failed to identify that the wide range level indication did not support operability of the HPCS and RCIC systems during reactor startup on May 5, 2016. (P.1)
05000410/FIN-2016002-032016Q2GreenH.4Self-revealingFailure to Understand Radiological Conditions Results in Unintended ExposureA self-revealing NCV of TS 5.4.1 Procedures was identified when a worker performed a radiological work activity without notifying radiation protection personnel and, as a result, did not comply with procedure RP-AA-1008, Unescorted Access to and Conduct in Radiologically Controlled Areas, Revision 5, in being briefed on the necessary radiological work controls and conditions for performance of the Unit 2 reactor seal cleaning work activity. Specifically, on April 11, 2016, a worker entered the Unit 2 reactor cavity to perform inspection of the reactor seal that was highly contaminated. Although not previously discussed with radiation protection staff, the worker cleaned the highly contaminated reactor seal with rags and carried the highly contaminated rags (5 rem/hr) in his hand out of the reactor cavity, which resulted in unplanned radiation exposure to the workers hand. Exelons immediate corrective actions included reinforcing the need to properly communicate radiological work activities with radiation protection, and require workers to carry WOs with them to improve communications with radiation protection. Exelon entered the issue into the corrective action program (CAP) as IR 02654591. The failure of the worker to discuss the full scope of the radiological work activity with radiation protection staff, who were subsequently not effectively briefed on the expected radiological work conditions and requisite radiological controls needed for the work activity, is a performance deficiency that was reasonably within Exelons ability to foresee and correct. The finding was determined to be more than minor because it affected the human performance attribute of the Occupational Radiation Safety cornerstone objective. Using IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, the finding was determined to be of very low safety significance (Green) because it did not involve: (1) as low as reasonably achievable (ALARA) occupational collective exposure planning and controls, (2) an overexposure, (3) a substantial potential for overexposure, or (4) an impaired ability to assess dose. The finding is self-revealing because Exelon was made aware of the situation when an air monitor alarmed. The finding had a cross-cutting aspect of Human Performance, Team Work, since individuals and work groups did not communicate and coordinate their activities within and across organizational boundaries to ensure nuclear safety was maintained. Specifically, the worker did not adequately communicate to radiation protection staff, the reactor seal cleaning activity to be performed. As a result, radiation protection personnel did not prescribe sufficient radiological controls for this high-contamination work activity, and led to an unintended exposure to the workers hand.
05000410/FIN-2016001-052016Q1Severity level IVLicensee-identifiedLicensee-Identified ViolationThe holder of an operating license under this part shall submit a Licensee Event Report (LER) for any event of the type described in this paragraph within 60 days after the discovery of the event. (v) Any event or condition that could have prevented the fulfillment of the safety function of structures or systems that are needed to: (C) Control the release of radioactive material. Contrary to the above from June 2, 2014, until October 5, 2015, Exelon failed to submit an LER notification to the NRC within 60 days after discovery of a condition which could have prevented the safety function of a SSC needed to control the release of radioactivity on April 2, 2014 at 11:20 a.m. Specifically, secondary containment being declared inoperable due to both airlock doors being open at the same time in Mode 5 with an OPDRV in progress. The inspectors reviewed the violation using IMC 0612, Appendix B and the NRC Enforcement Policy. This violation impacted the regulatory process so traditional enforcement applies. Comparing this violation to the examples in the NRC Enforcement Policy Chapter 6, the violation matches Severity Level IV Example 6.9.d.9, a licensee fails to make a report required by 10 CFR 50.72 or 10 CFR 50.73. The NRC did not rely upon the information to make any regulatory decisions, and the error did not result in increased scope or effort of NRC inspections. Compliance was restored when Exelon submitted LER 05000410/2014-007-01 to correct the public record and inform the NRC. Exelon staff entered the issue into its CAP.
05000410/FIN-2016001-012016Q1GreenH.5NRC identifiedInadequate Procedure Leading to Failure to Manage Elevated Risk during Preventive MaintenanceThe inspectors identified a non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 50.65(a)(4), Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, when Exelon did not assess and manage the increase in risk for online maintenance activities. Specifically on February 12, 2016, Exelon did not assess and manage risk during Unit 2 planned testing associated with the A residual heat removal (RHR) system heat exchanger (HX). The inspectors identified that although the testing would render the A RHR minimum flow valve 2RHS*MOV4A unavailable, this was not considered as part of the planned maintenance window, which resulted in an increase in risk during the unavailability of 2RHS*MOV4A. When properly calculated, plant risk should have been indicated as Yellow for the day and not Green. Exelon generated issue report (IR) 02625546 to document the inspectors concern regarding the status of the availability associated with the A RHR minimum flow valve during test setup for the A RHR HX. Exelon corrective actions included evaluating the risk management activities to be implemented when the minimum flow valves are subject to maintenance or testing activities to ensure future work is properly screened. This finding is more than minor because it is associated with the configuration control attribute of the Mitigating Systems cornerstone and adversely affected the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, Exelons failure to plan for the unavailability of the A RHR minimum flow valve resulted in Unit 2 being placed in an unplanned elevated risk category (i.e., Yellow) without ensuring adequate compensatory measures were established and briefed to ensure maximum availability, reliability, and capability of the system. This issue is similar to Example 7.f of IMC 0612, Appendix E, Examples of Minor Issues, because the overall elevated plant risk placed the plant into a higher licensee-established risk category. The inspectors evaluated the finding using Phase 1, Initial Screening and Characterization worksheet in Attachment 4 and IMC 0609, Significance Determination Process. For findings within the Initiating Events, Mitigating Systems, and Barrier Integrity cornerstones, Attachment 4, Table 3, Paragraph 5.C, directs that if the finding affects the licensees assessment and management of risk associated with performing maintenance activities under all plant operating or shutdown conditions in accordance with Baseline Inspection Procedure 71111.13, Maintenance Risk Assessment and Emergent Work Control, the inspectors shall use IMC 0609, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process, to determine the significance of the finding. The inspectors used Flowchart 1, Assessment of Risk Deficit, to analyze the finding and calculated incremental core damage probability using Equipment Out Of Service (EOOS), Exelons risk assessment tool. The inspectors determined that had this condition existed for the full duration of the Technical Specification (TS) limiting condition for operation (LCO), the incremental conditional core damage probability would have been 3.46E-9. Because the incremental core damage probability deficit was less than 1E-6 and the incremental large early release probability was less than 1E-7, this finding was determined to be of very low safety significance (Green). This finding has a cross-cutting aspect in the area of Human Performance, Work Management, because Exelon did not properly implement a process of planning, controlling, and executing the work activity such that nuclear safety was the overriding priority. Specifically, Exelon did not ensure risk was properly assessed during the planning process in accordance with WC-AA-101-1006, On-Line Risk Management and Assessment, Revision 001, prior to testing the A RHR HX, which caused unavailability of the A RHR minimum flow valve during certain periods of the test.
05000410/FIN-2016001-022016Q1GreenH.8NRC identified50.65(a)(4) Risk Evaluation Not Properly Performed Prior to Residual Heat Removal Heat Exchanger TestingThe inspectors identified a Green non-cited (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 50.65(a)(4), Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, for Exelons failure to take risk management actions (RMAs) as required by procedure OP-AA-108-117, Protected Equipment Program, Revision 004, during a Unit 2, Division III, emergency switchgear electrical maintenance window on January 27, 2016. Specifically contrary to procedure OP-AA-108-117, during planned maintenance, Exelon failed to post the unit coolers in the A and B RHR pump and HX rooms, the C RHR pump room, and their associated breakers as protected equipment although their inoperability would have resulted in both trains of the standby gas treatment system (SBGT) being inoperable which would require entry into Technical Specification (TS) Limiting Condition for Operation (LCO) 3.0.3 and a short term shutdown action statement. Upon identification, Exelon generated IR 02617915 to document this issue. Corrective actions included creating an action item to evaluate Attachment 3 of N2-OP-52 and to determine the relevance of the TS LCO 3.0.3 entry requirement. The inspectors determined the performance deficiency to be more than minor because it was associated with the structure, system, and component (SSC) and barrier performance attribute of the Barrier Integrity cornerstone and adversely affected the associated cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, contrary to OP-AA-108-117, Exelon personnel failed to include the unit coolers for the Unit 2 RHR pump and HX rooms and their associated breakers, whose unavailability would have resulted in the inoperability of both trains of SBGT and necessitated entry into LCO 3.0.3. Additionally, Examples 7.e, 7.f, and 7.g from IMC 0612, Appendix E, Examples of Minor Issues, provided similar scenarios to this issue. Example 7.e details that a performance deficiency is more than minor if a failure to include accurate TS requirements in a risk assessment and if done properly, would have required RMAs, or additional RMAs under applicable plant procedures. The inspectors evaluated the finding using Phase 1, Initial Screening and Characterization worksheet in Attachment 4 to IMC 0609, Significance Determination Process. For findings within the Initiating Events, Mitigating Systems, and Barrier Integrity cornerstones, Attachment 4, Table 3, Paragraph 5.C, directs that if the finding affects the licensees assessment and management of risk associated with performing maintenance activities under all plant operating or shutdown conditions in accordance with Baseline Inspection Procedure 71111.13, Maintenance Risk Assessment and Emergent Work Control, the inspectors shall use IMC 0609, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process, to determine the significance of the finding. The inspectors used Flowchart 2, Assessment of RMAs, to analyze the finding and calculated incremental core damage probability using EOOS, Exelons risk assessment tool, and found the result to be less than 1E-6. The inspectors determined that had this condition existed for the full duration of the TS LCO, the incremental core damage probability would have been 6.8E-7. Because the incremental core damage probability deficit was less than 1E-6 and the incremental large early release probability was less than 1E-7, this finding was determined to be of very low safety significance (Green). This finding has a cross-cutting aspect in the area of Human Performance, Procedure Adherence, because Exelon failed to follow processes, procedures and work instructions. Specifically, Exelon failed to follow procedure OP-AA-108-117, which led to the failure to protect the unit coolers for the RHR pump rooms, HX rooms, and associated breakers which could have led to a TS LCO 3.0.3 entry.
05000410/FIN-2016001-042016Q1Severity level IVLicensee-identifiedLicensee-Identified ViolationEight-hour reports. If not reported under paragraphs (a), (b)(1), or (b)(2) of this section, the licensee shall notify the NRC as soon as practical and in all cases within eight hours of the occurrence of any of the following: (v) Any 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: (C) Control the release of radioactive material. Contrary to the above, from April 2, 2014, until October 5, 2015, Exelon failed to submit an EN to the NRC within 8 hours upon discovery on a condition which could have prevented the safety function of a SSC needed to control the release of radioactivity on April 2, 2014, at 11:20 a.m. Specifically, secondary containment being declared inoperable due to both airlock doors being open at the same time in Mode 5 with an OPDRV in progress. The inspectors reviewed the violation using IMC 0612 Appendix B, Issue Screening, and the NRC Enforcement Policy. This violation impacted the regulatory process so traditional enforcement applies. Comparing this violation to the examples in the NRC Enforcement Policy Chapter 6, the violation matches Severity Level IV Example 6.9.d.9, a licensee fails to make a report required by 10 CFR 50.72 or 10 CFR 50.73. The NRC did not rely upon the information to make any regulatory decisions and the error did not result in increased scope or effort of NRC inspections. Compliance was restored when Exelon submitted LER 05000410/2014-007-01, Secondary Containment Inoperable due to Simultaneous Opening of Airlock Doors, to correct the public record and inform the NRC. Exelon staff entered the issue into its CAP.
05000220/FIN-2016001-032016Q1GreenH.8Self-revealingInadequate Tagout Resulting in Reactor Building Closed-Loop Cooling Drain Down EventA self-revealing Green non-cited violation (NCV) of Technical Specification (TS) 6.4.1, Procedures, was identified when a Unit 1 Exelon operator did not maintain proper configuration control of a plant system during a system tagout for planned maintenance. Specifically, on January 25, 2016, a Unit 1 non-licensed operator manipulated a reactor building closed-loop cooling (RBCLC) system drain valve out of sequence while performing a tagout for the #13 shutdown cooling (SDC) HX for planned maintenance. This resulted in unintentional draining of the operating RBCLC system, annunciation of multiple alarms in the main control room, and operators entering abnormal operating procedures to recover the RBCLC system. As part of corrective actions, proper configuration was promptly restored and the operator involved in the event was given a remediation plan for requalification and placed on an operations excellence plan. This finding is more than minor because it is associated with the configuration control attribute of the Mitigating Systems cornerstone and adversely affected the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences; and if left uncorrected, the event had potential to lead to a more significant safety concern. Specifically, the failure to quickly isolate the drain down of the RBCLC system would have required a manual reactor scram, a manual trip of all five reactor recirculation pumps (RRPs), a manual isolation of the reactor water cleanup system, a loss of cooling to the spent fuel pool (SFP) cooling system, instrument air compressors, and the control room emergency ventilation system. The inspectors evaluated the finding using IMC 0609.04, Initial Characterization of Findings, and Exhibit 1 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power. The inspectors determined that this finding was of very low safety significance (Green) because the performance deficiency did not result in the loss of a support system, RBCLC, or affect mitigation equipment. This finding has a cross-cutting aspect in the area of Human Performance, Procedure Adherence, because the non-licensed operator failed to follow Exelons procedures and the instructions he received at the pre job brief stop when manipulating the drain valve. Specifically, the non-licensed operator rationalized, without being the designated performer of the tagout, that it was acceptable to perform a valve manipulation out of sequence with the tagout plan.
05000220/FIN-2015009-022015Q3GreenP.2NRC identifiedInadequate Maintenance Rule Monitoring of Unit 1 600 VAC Breaker Super SystemThe inspectors identified a Green NCV of 10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, under section (a)(1) and (a)(2) for failing to properly monitor the 600 volt alternating current (VAC) system at Unit 1 in accordance with established maintenance rule reliability criteria to assure that breakers were capable of performing their intended function. Specifically, the inspectors identified four events that were not evaluated against the established (a)(2) reliability criteria. This resulted in a failure to evaluate the 600 VAC system for potential corrective actions in accordance with (a)(1) and did not ensure effective control through preventative maintenance to show the system was capable of performing its intended function in accordance with (a)(2). Exelons immediate corrective actions included evaluations of the failures and planning for a maintenance rule expert panel for consideration of placing the system into (a)(1) where corrective actions could be developed to return the system to (a)(2) monitoring. Exelon also noted that IR 2416790 documented the challenge associated with overcurrent trip device drift and subsequent pump failures. This IR was open at the time of the inspection with actions to determine if a replacement is possible and to present any potential options to Plant Health Committee in October 2015. This performance deficiency is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the overcurrent trip devices associated with Unit 1 600 VAC General Electric (GE)-AK breakers were unreliable and resulted in the trip of five safety-related pumps between April 2013 and February 2014. Only one of the five functions was evaluated by Exelon. This impacted the ability of these pumps to be able to perform their function to provide cooling to their respective systems. In accordance with IMC 0609.04, Initial Characterization of Findings, and IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, the inspectors determined this finding was of very low safety significance (Green) because this finding did not represent an actual loss of system safety 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 represent an actual loss of function of one or more non-TS trains of equipment designated as high safety-significant in accordance with Exelons maintenance rule program for greater than 24 hours. This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Evaluation, because Exelon failed to thoroughly evaluate the failures against the monitoring criteria specified for the Unit 1 600 VAC breaker super system. Specifically, between April 2013 and February 2014, four breaker failures were identified by the inspectors that were not evaluated against the Unit 1 600 VAC breaker super system, which prevented compliance with 10 CFR 50.65 (a)(1) to ensure corrective actions are established to return the system to (a)(2) monitoring.
05000410/FIN-2015003-012015Q3GreenH.11Self-revealingUse of Incorrect Grounding Cart Results in Loss of Electrical BusThe inspectors identified a self-revealing Green finding (FIN) for Exelon Generation Company, LLC (Exelon) personnels failure to stop when met with unexpected conditions as required by procedure HU-AA-101, Human Performance Tools and Verification Practices. On August 21, 2015, a Unit 2 division of normal switchgear was unintentionally deenergized which required an unplanned down power to 90 percent and special operating procedure entry. The loss of the switchgear was the result of installation of an incorrect sized grounding cart in the electric fire pump breaker cubicle during breaker maintenance. Use of the correct sized grounding cart was discussed during the pre-job brief. This resulted in the loss of the electric fire pump, half of the drywell coolers, a heater drain pump, and unplanned reactivity change. Exelon entered this issue into their corrective action program (CAP) for resolution and developed corrective actions which included developing procedures for the use of grounding carts and evaluating where other skill-of-the-craft work may pose the same risk. This finding is more than minor because it is associated with the human performance attribute of the Initiating Events cornerstone and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 1 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, the inspectors determined that this finding is of very low safety significance (Green). The finding has a cross-cutting aspect in the area of Human Performance, challenge the unknown, because Exelon personnel failed to stop when faced with uncertain conditions. Specifically, after having been briefed on the different stab sizes for 1200 amp and 2000 amp grounding carts, Exelon personnel failed to stop and notify supervision when faced with unlabeled grounding carts stored in the same location, Exelon personnel failed to notify supervision or compare stab sizes to ensure the correct grounding cart was used.
05000220/FIN-2015009-012015Q3GreenP.2NRC identifiedFailure to Identify and Correct a Condition Adverse to Quality Associated with Secondary Containment LeakageThe inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50, Appendix B, Criterion XVI, Corrective Actions, because between 2007 and 2015, Exelon staff did not promptly identify and correct a deficiency associated with Unit 2 reactor building service water pipe penetration W-3177-C. Specifically, on August 20, 2015, during Exelon staffs investigation of an inspector concern associated with the service water pipe penetration into secondary containment, a leakage path into secondary containment was discovered and was not previously identified and evaluated for impact on operability of Unit 2 secondary containment. Exelon generated issue report (IR) 2544831 to document the newly identified condition. The assessment included a review of previously identified leakage paths that were being tracked in accordance with procedure, previously performed secondary containment drawdown leakage testing, and a comparison to the maximum allowable flow rate leakage area. The assessment concluded that based on the gap that was identified at secondary containment penetration W-3177-C, there was a new total of 1.783 square inches of surface area allowing leakage into the Unit 2 secondary containment. Exelon determined this to be acceptable because calculations for secondary containment drawdown testing allows for up to 33.6 square inches of surface area causing in-leakage into secondary containment. Given 1.783 square inches of total identified leakage being less than the allowable 33.6 square inches, there was reasonable assurance that standby gas treatment system will be able to perform its drawdown function and maintain secondary containment vacuum 0.25 inches of vacuum water gauge in accordance with Technical Specification (TS) 3.6.4.1, Secondary Containment. This performance deficiency was more than minor because it impacted the design control attribute of the Barrier Integrity cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, Exelons staff failed to identify the degraded penetration seal that impacted the reasonable assurance of Unit 2 secondary containment operability. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 3 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, the inspectors determined this finding was of very low safety significance (Green) because the finding only represented a degradation of the radiological barrier function provided for the control room, or auxiliary, spent fuel pool, or standby gas treatment system (i.e., secondary containment). This finding had a cross-cutting aspect in the area of Problem Identification and Resolution, Evaluation, because Exelon staff failed to properly evaluate the condition identified in multiple IRs to determine the extent of condition associated with secondary containment water in-leakage. Specifically, between 2007 and 2015, three IRs were generated and a 2012 structural monitoring review documented the service water penetration water in-leakage and the issue was not appropriately evaluated for the potential for a service water pipe through-wall leak or the potential impact on secondary containment.
05000220/FIN-2015002-012015Q2GreenH.11Self-revealingFailure to Notify of Changes to Work ScopeThe inspectors identified a self-revealing NCV of Unit 1 Technical Specification (TS) 6.4.1, Procedures, for failure to follow the planned scaffold erection work scope that resulted in two personnel receiving unplanned internal exposures. Specifically, on January 6, 2015, workers erecting scaffolding changed the work scope that specified the use of new equipment and used unsurveyed highly contaminated scaffold parts instead, without notifying radiation protection staff of the change in work scope that resulted in two workers receiving unplanned, unintended internal radiation exposures. The failure to follow the planned work scope is a performance deficiency. The performance deficiency constitutes a finding that is more than minor because the performance deficiency was associated with the Occupational Radiation Safety attribute of program and process and adversely affected the cornerstone objective in the protection of workers from exposure to radioactive material. Specifically, failure to follow the planned work scope resulted in two personnel receiving unplanned internal exposures. The finding is not subject to traditional enforcement because it did not affect the regulatory process or result in actual safety consequences. Using IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, the finding was of very low safety significance (Green) because it did not involve: (1) as low as reasonably achievable (ALARA) occupational collective exposure planning and controls, (2) an overexposure, (3) a substantial potential for overexposure, or (4) an impaired ability to assess dose. The cause of the finding is related to the cross-cutting area of Human Performance, Challenge the Unknown, because when workers discovered potentially contaminated scaffold materials in the work area, they did not question whether or not it was appropriate to use the material in their job and did not raise the question to their supervisors or Exelon Generation Company, LLC (Exelon) radiation protection technicians prior to deviating from the planned and briefed work scope. As a result, the radiological risks were not evaluated before proceeding to utilize the unsurveyed highly contaminated components, which resulted in unintended internal radiation exposures to the workers.
05000220/FIN-2015002-022015Q2GreenLicensee-identifiedLicensee-Identified Violation10 CFR 50.55a(g)(4)(ii) states, in part, inservice examination of components and system pressure tests conducted during successive 120-month inspection intervals must comply with the requirements of the latest edition and addenda of the Code incorporated by reference in paragraph (a) of this section 12 months before the start of the 120-month inspection interval. The second 10-year ISI interval program was based on the ASME B&PV Code, Section XI, 1989 Edition with no addenda and was applicable from April 5, 1998, thru April 4, 2008. ASME B&PV Code Section XI, 1989 states, in part, In instances where a location may be found at the time of the examination that does not meet >90 percent coverage, the process outlined in the EPRI TR will be followed. EPRI TR-112657, Section 6.4, Item 4 states A new relief request will be generated for any RI-ISI piping element selection for which greater than 90 percent examination coverage is not achieved. EPRI TR-112657, Section 6.4, also goes on to state Consistent with the requirements of Code Case N-460, an examination will be considered limited if less than or equal to 90 percent coverage is obtained. This relief request addresses piping element selections for the second ISI interval where less than 90 percent of the examination volume was obtained. Contrary to the above, from April 4, 2009, until February 16, 2015, Exelon failed to submit a relief request to the NRC for instances found at the time of the examination that did not meet greater than 90 percent coverage as required. This violation impacts the regulatory process; therefore, traditional enforcement applies. This violation is similar to Example 6.9.d.1 of the NRC Enforcement Policy dated February 4, 2015. This is an example of a Severity Level IV finding. Exelon identified the issue during a self assessment and entered the issue into their CAP as IR 01991177 and IR 02450858.
05000220/FIN-2015001-012015Q1GreenH.11NRC identifiedFailure to Declare Notice of Unusual Event Following Sodium Bisulfite Spill in Unit 1 ScreenhouseThe inspectors documented a Green NRC-identified NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50.54(q)(2) when Exelon failed to declare a Notice of Unusual Event Emergency Action Level (EAL) (HU3.1) when entry conditions were met. Specifically, on February 4, 2015, between 9:55 a.m. and 11:15 a.m., access to the Screenhouse was prohibited due to the release of a toxic gas that adversely affected normal plant operations following a spill of sodium bisulfite. Immediate corrective actions included Exelon entering the issue into their corrective action program (CAP) as issue report (IR) 02474142, formally evaluating the decision-making process used during the incident, and clarifying responsibilities for air sampling and the reporting of samples during incidents in the future. This finding is more than minor because it was associated with the Emergency Preparedness cornerstone attribute of Emergency Response Organization Performance, and affected the cornerstone objective of ensuring that a licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, between 9:55 a.m. and 11:15 a.m., access to the Unit 1 Screenhouse was prohibited due to the release of sodium bisulfite to the Screenhouse, affecting normal plant operations of the station. This finding was evaluated using IMC 0609, Appendix B, Emergency Preparedness SDP, Section 4, Failure to Implement. The performance deficiency is associated with the emergency classification planning standard and is considered a Risk-Significant Planning Standard (RSPS). The failure to declare a Notice of Unusual Event when directed by the EAL Matrix is considered a lost or degraded RSPS in accordance with Section 4 of IMC 0609. Section 4.3.c and Attachment 1 of IMC 0609, Appendix B, provide the significance determination for a Failure to Implement, and the performance deficiency was determined to be of very low safety significance (Green). The inspectors determined that the cross-cutting aspect that contributed most to the root cause is Human Performance, Challenge the Unknown: Individuals stop when faced with uncertain conditions. Risks are evaluated and managed before proceeding. Specifically, during the event, an unknown substance was released and at no point was atmospheric analysis used in the EAL declaration decision-making process. Furthermore, although spill response personnel were experiencing symptoms that were not consistent with exposure to a spill of sodium bisulfite, this unexpected condition was not fully assessed by NMPNS for significance and reportability in accordance with procedures.
05000410/FIN-2015001-022015Q1GreenH.12Self-revealingFailure to Perform an Adequate Review of Planned Work Activities Results in a Manual Reactor ScramThe inspectors documented a self-revealing Green finding (FIN) for Exelons failure to properly review a work package associated with the replacement of a reactor vessel level recorder as required by MA-AA-716-234, FIN Team Process, Revision 8. Specifically, on February 18, 2015, control room operators manually scrammed Unit 2 when reactor vessel water level unexpectedly rose above desired limits during a planned replacement of Unit 2 reactor vessel level recorder 2ISC-LR1608. The unplanned rise in reactor water level occurred when daisy chained leads associated with the level recorder were lifted, which caused an interruption in the feedwater level control circuit. The inspectors determined that Exelons failure to ensure measures were in place to address the impact on reactor vessel level prior to level recorder replacement in accordance MA-AA-716-234 was a performance deficiency that was reasonably within Exelons ability to foresee and correct and should have been prevented. This finding is more than minor because it is associated with the human performance attribute of the Initiating Events cornerstone and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. Specifically, Exelon did not ensure measures were in place to prevent an adverse impact on the feedwater level control system during level recorder replacement. This resulted in a rapid rise in reactor water level and subsequent manual reactor scram. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 1 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) because while the performance deficiency caused a reactor scram, it did not result in the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. The finding has a cross-cutting aspect in the area of Human Performance, Avoid Complacency, because Exelon failed to recognize and plan for the possibility of mistakes, latent issues, and inherent risk even while expecting successful outcomes. Specifically, Exelon did not ensure measures were in place to address the impact of the level recorder replacement on the feedwater level control system.
05000220/FIN-2014007-042014Q4GreenLicensee-identifiedLicensee-Identified Violation10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program. In addition, NRC letter dated June 2, 1977, required all licensees to verify existing plant design or propose modifications to ensure onsite emergency power systems met certain criteria including Staff Position 1. Staff Position 1(c)(2) stated the DGV protection time delay duration, shall minimize the effect of short duration disturbances from reducing the availability of the offsite power source(s). Staff Position 1(c)(3) stated the DGV protection time delay shall be established such that the allowable time duration of a DGV condition at all distribution system levels shall not result in failure of safety systems or components. Contrary to the above, prior to October 9, 2014, Exelon did not adequately evaluate the sequencing of Unit 2 safety-related loads and associated transient voltages to the Unit 2 Class 1E accident initiated motors and MOVs on the-safety related buses and MCCs during the initiation of a design basis loss of coolant event, subsequent unit trip, and resulting sag of the 115kV grid. Specifically, Exelon did not ensure the chosen DGV protection time delay duration: (1) minimized the effect of short duration disturbances from reducing the availability of offsite power sources; and, (2) maintained voltage requirements for safety-related loads to ensure that failures of safety-related systems would not occur. Exelon did not identify the resulting voltage transients, minimum 4kV motor and 600V MOV starting voltages, associated motor actuator output torque, and control circuit voltages to safety-related MOV motors. Exelon identified these deficiencies as a result of their review of NRC RIS 2011-12R1 and contracted in September 2014 to have the electrical calculations revised. Initial results, using the grid operator specified grid sag of 3.5 percent following a unit trip, indicated that the transient 4KV safety bus voltage would be too low to reset the DGV relays. This would result in the unintended disconnection of offsite power and transfer to the EDG. Immediate actions included reevaluation of the postulated grid sag and transient 4 kV bus voltages. Exelons subsequent assessment concluded that grid stability had improved and offsite power remained operable. The team reviewed Exelons assessment and immediate actions and found them to be reasonable. Exelon entered this issue into the corrective action program as IRs 2393336 and 2392930. The team determined that the finding was of very low safety significance (Green) in accordance with IMC 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, Mitigating Systems, because it was a design deficiency confirmed not to result in loss of operability or functionality.
05000410/FIN-2014005-042014Q4NRC identifiedAssessment of UPS3B Failure Which Resulted in a Reactor ScramIntroduction. A URI was identified pending Exelons revision and approval of their root cause report associated with the failure of UPS3B that caused a Unit 2 reactor scram on March 4, 2014 Description. Unit 2 is equipped with two 10-kVA UPSs (2VBB-UPS3A and 2VBBUPS3B) that feed RPS logic trip channel loads and main steam line isolation valves control solenoids through their associated distribution panels. 2VBB-UPS3B feeds the RPS trip system B. The loads are normally energized from 600 volts alternating current (VAC) non-safety-related power. In the case of the loss of normal supply power, an inverter allows the loads to receive power from its backup direct current source. In the case of an inverter failure, the UPS can be fed from an alternate non-safety-related 600 VAC source. Each UPS is connected to its associated distribution panel through two redundant electric protective assemblies connected in series. The electric protective assemblies provide redundant protection to the RPS system and other associated essential circuits against overvoltage, undervoltage, and under frequency conditions in the non-safety-related power sources. On March 4, 2014, 2VBB-UPS3B experienced a capacitor failure on an associated circuit card. This failure prevented the UPS from transferring to its alternate source of power causing the electrical protective assemblies to trip, a loss of cooling water to the reactor recirculation pumps, and a subsequent reactor trip. Exelon staff documented the issue in CR-2014-001725 and performed a root cause analysis. Using investigative root cause techniques outlined in procedure CNG-CA-1.01-1004, Root Cause Analysis, Revision 00801, Exelon staff determined the root cause to be a lack of vendor and industry guidance and internal/external operating experience resulting in lack of PM task to preclude backplane failure. The corrective actions to prevent recurrence involved revising the PM strategy in the IQ Review and Maximo database to include replacement of all single-point vulnerable components in 2VBA*UPS2A/2B and 2VBB-UPS3A/3B. During inspection of Unit 2 LER 2014-003-00, Uninterruptible Power Supply Failure and Subsequent Manual Scram, the inspectors reviewed the root cause report associated with this event. The inspectors discovered that, although the root cause postulated that warping/cracking of the backplane contributed to UPS3B failure, when new information regarding the backplane that contradicted this root cause was discovered, Exelo personnel did not properly enter this new information into the CAP or elevate the concern to Exelon plant management. Specifically, the engineering staff and a vendor representative had examined the UPS3B backplane during the Unit 2 refueling outage and found no indication of cracking or warping. This examination occurred following management review committee approval of the root cause. This information, along with other testing performed on the UPS3B during the refueling outage, showed that the theory for potential backplane warping/cracking likely was not the actual root cause and that the corrective actions developed for backplane replacement may not prevent recurrence of the UPS failure. Exelon documented the inspectors observation in IR 2416757 and plans to evaluate the issue further and to reopen and update the root cause report. This issue will be opened as a URI pending Exelon revision of the root cause report; and NRC review of the root cause report to determine whether the issue contains performance deficiency, whether or not that performance deficiency is more than minor, and whether a violation exists. Exelon is tracking this issue through their CAP database with a date to determine root cause revision requirements by December 19, 2014. (URI 05000410/2014005-04, Assessment of UPS3B Failure Which Resulted in a Reactor Scram)
05000410/FIN-2014005-032014Q4GreenH.12NRC identifiedMissed Surveillance Test of Alternate Decay Heat Removal Secondary Containment Isolation ValvesThe inspectors identified a Green NCV of Unit 2 Technical Specification (TS) 5.4, Procedures, for Exelons failure to properly perform procedure N2-OSP-GTS-R001, Secondary Containment Integrity Test, Revision 01100. Specifically, Exelon staff failed to ensure spectacle flanges associated with alternate decay heat (ADH) secondary containment isolation were properly installed. As a result, surveillance testing associated with ADH check valves 2ADH*V21A/B and 2ADH*V22A/B was not performed to ensure secondary containment integrity as required by N2-OSP-GTS-R001. Exelon immediately entered this issue into their CAP as issue report (IR) 2403311. Exelon entered TS Surveillance Requirement (SR) 3.0.3, Limiting Condition for Operability Applicability, which is used when a licensee discovers that a surveillance test requirement has not been performed. As required by the TS, Exelon completed a risk evaluation of the missed surveillance and determined large early release frequency remained low without ADH secondary containment isolation. Exelon also performed extent-of-condition inspections for other systems which may not have proper alignment to ensure they are meeting TS requirements. On December 4, Exelon rotated the spectacle flanges to the no flow isolation position to ensure secondary containment integrity was maintained The finding is more than minor because it is associated with the configuration control attribute of the Barrier Integrity cornerstone objective to provide reasonable assurance tha physical design barriers protect the public from radionuclide releases caused by accident or events. Specifically, by performing N2-OSP-GTS-R001 in 2012 and 2014 without first ensuring the spectacle flanges were properly installed, Exelon did not verify the secondar containment requirements of TS SR 3.4.6.1 were maintained. Additionally, this issue wa similar to Example 3.d in IMC 0612, Appendix E, Examples of Minor Issues, in that th failure to implement the TS SR as required was not minor if the surveillance had not bee conducted. By not correctly testing the secondary containment in 2012 and 2014, the SR o TS 3.4.6.1 was not met. In accordance with IMC 0609.04, Initial Characterization o Findings, and Exhibit 3 of IMC 0609, Appendix A, The Significance Determination Proces for Findings At-Power, the inspectors determined this finding is of very low safet significance (Green) because the finding only represents a degradation of the radiologica barrier function provided for the control room, or auxiliary, spent fuel pool (SFP), or standb gas treatment system (boiling water reactor). This finding has a cross-cutting aspect in th area of Human Performance, Avoid Complacency, because Exelon staff did not implemen appropriate error reduction tools. Specifically, operators did not use error reduction tools t ensure the spectacle flanges were installed in the no flow position and as a result, the failed to leak test the ADH check valves in the secondary containment drawdown test a required by N2-OSP-GTS-R001 (H.12).
05000410/FIN-2014007-012014Q4GreenP.5NRC identifiedDeficient Design Control of NMP Unit 1 Electrical Calculations to Evaluate Minimum Voltages to Class 1E Accident Initiated Motors and MOVs during a Design Basis EventThe team identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Appendix B, Criterion III, Design Control, for failure to verify and assure, in Nine Mile Point Unit 1 design basis calculations, that adequate voltages would be available to Class 1E accident initiated motors, motor-operated valves (MOV), and control circuits powered from the 4160 V, 600 V, and 120 V distribution systems during a design basis loss-of-coolant accident (LOCA) with offsite power available. Specifically, Exelon did not identify and evaluate the minimum transient voltage for the design basis LOCA event regarding accident initiated motors, MOVs, and control circuits, and did not evaluate the capability of the safety-related main steam isolation valve motor brakes. Immediate corrective action included preliminary calculations using the design grid voltage sag, which determined the Reserve Service Station Transformer load tap changers, motor control center (MCC) control circuits, MOVs, and the main steam isolation valve motor brakes would have adequate voltage to remain capable of performing their safety functions. Exelon entered the issues into their corrective action program as issue reports 2386719, 2386824, 2387652, 2387888, 2392928, and 2393299. This finding was more than minor because it was associated with the design control attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The team determined the finding was of very low safety significance because it was a design deficiency confirmed not to result in a loss of safety-related MCC MOV operability or functionality. This team assigned a cross-cutting aspect associated with this finding because the long-standing performance deficiency continued during and after Exelons review of related internal and external operating experience from 2012 to 2014. The team determined this finding had a cross-cutting aspect in the area of Problem Identification and Resolution, Operating Experience (Aspect P.5), because Nine Mile Point Unit 1 staff did not effectively collect, evaluate, and implement relevant internal and external operating experience in a timely manner.
05000220/FIN-2014007-022014Q4GreenP.5NRC identifiedDeficient Design Control of NMP Unit 1 Electrical Protection Design to Ensure Survivability of Safety-Related LoadsThe team identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for failure to verify the adequacy of the Nine Mile Point Unit 1 electrical design during a design basis loss of coolant accident (LOCA) event with sustained degraded grid voltage (DGV). Specifically, Exelon did not verify Class 1E loads would not be damaged or become unavailable for a design basis LOCA with a degraded voltage condition between the degraded voltage setpoint and the loss of voltage setting for the degraded voltage time delay of 21 +/- 3 seconds and subsequent reconnection to the emergency diesel generator. Immediate corrective actions included preliminary evaluation of the safetyrelated MOV that operate during the first 21 seconds of the accident, which determined there was reasonable assurance the MOV protective devices would not actuate during sustained DGV concurrent with a design basis LOCA. Exelon entered this issue into their corrective action program as issue reports 2387818 and 2392780. The finding was more than minor because it was associated with the design control attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The team determined the finding was of very low safety significance (Green) because it was a design deficiency confirmed not to result in loss of operability or functionality. The team determined this issue had a cross-cutting aspect in the area of Problem Identification and Resolution, Operating Experience (Aspect P.5), because the organization did not effectively collect, evaluate, and implement relevant internal and external operating experience in a timely manner. Despite NRC Regulatory Issue Summary 2012-11, Adequacy of Station Electric Distribution System Voltages, and NRC Component Design Bases Inspections identifying similar performance deficiencies at other Exelon facilities during the last 3 years, the Nine Mile Point staff did not effectively evaluate and resolve this operating experience.
05000220/FIN-2014005-012014Q4Severity level IIINRC identifiedIncomplete and Inaccurate Medical Information Provided by Exelon Which Impacted Issuance of Initial and Renewal LicensesExelon Generation Company, LLC (Exelon) identified two AVs: (1) An AV of Title 10 of the Code of Federal Regulations (10 CFR) 50.9, Completeness and Accuracy of Information; and (2) An AV of 10 CFR 50.74, Notification of Change in Operator or Senior Operator Status. Specifically, during an internal audit in July 2014, Exelon identified that between September 2002 and February 2012, NMPNS staff submitted certified copies of an NRC reactor operator and/or senior operator license applications for seven applicants that did not specify that the applicants required a restriction in order to maintain medical qualifications. The NRC issued the reactor operator and senior operator initial and renewed licenses for the seven applicants, but without the necessary medical restrictions (AV #1). From June 2002 through August 2014, Exelon had numerous additional opportunities to identify these potentially disqualifying medical conditions and that license conditions were required during the biennial licensed operator requalification program reviews and medical examinations. On September 25, 2014, a period that exceeded 30 days from when the conditions were identified, the facility notified the NRC of these medical conditions via a letter requesting amendment to the seven operators licenses to include the appropriate restrictions (AV #2). The NRC issued the license amendment with the new restrictions. The NRC inspectors also identified an additional example of both AVs which had not been reported by Exelon to the NRC in the September 25, 2014 letter. On November 5, 2014, Exelon requested termination of the license for that operator. This issue was entered into Exelons corrective action program (CAP) The inspectors determined that Exelons failure to provide complete and accurate information to the NRC in the reactor operator and senior operator license applications and to notify the NRC of a change in a reactor operator or senior operators status for a condition which was known by Exelon were performance deficiencies that were within their ability to foresee and correct and should have been prevented. The inspectors determined that traditional enforcement applies, as the issue affected the NRCs ability to perform its regulatory function. Namely, the NRC requires Exelon to ensure all licensed operators meet the medical conditions of their licenses. If, during the term of the individual operator license, an operator develops a permanent physical or mental disability that causes the operator to fail to meet the requirements of 10 CFR 55.21, Medical Examination, the licensee shall notify the NRC within 30 days of learning of the diagnosis, in accordance with 10 CFR 50.74(c). Additionally, the NRC issued reactor operator and senior operator licenses to the applicants based on information that was not complete and accurate in all material aspects. The performance deficiencies were screened against the Reactor Oversight Process per the guidance of IMC 0612, Appendix B, Issue Screening. No associated Reactor Oversight Process finding was identified and no cross-cutting aspect was assigned. These issues constitute AVs in accordance with the NRCs Enforcement Policy, and their final significance will be dispositioned in separate future correspondence. (Section 1R11)
05000220/FIN-2014007-032014Q4GreenNRC identifiedDeficient Design Control of Protective Device Sizing for Unit 1 Core Spray Injection Motor-Operated ValvesThe team identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion III, Design Control, because Exelon did not verify the design adequacy of Nine Mile Point Unit 1 electrical power to safety-related MOVs to support their design function during design basis events. Specifically, Exelon did not verify that the thermal/magnetic breaker (TMB) protection on core spray (CS) loop injection MOV circuits 1V-40-01, 1V-40-09, 1V-40-10, and 1V-40-11 were properly sized to support the design function of repetitive MOV operation (throttling) in response to a design basis loss-of-coolant accident (LOCA). Routine throttling operation of the CS injection valves could potentially cause a TMB trip and loss of power to the MOV leading to the valve failing in an indeterminate position and not being capable of performing its design function to control reactor pressure vessel (RPV) level. Immediate corrective action included guidance to control room operators to close three of the MOVs when required to maintain RPV level and only use MOV 1V-40-09 which had a TMB tripping design of 17 seconds Exelon entered this issue into its corrective action program as issue report 2393386. The finding was more than minor because it is associated with the design control attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The team determined that the finding was of very low safety significance (Green) because it was a design deficiency confirmed not to result in loss of operability or functionality. The team determined that the central cause of this finding was not reflective of current performance or current plant modification processes. Therefore no cross-cutting aspect was assigned.
05000220/FIN-2014005-022014Q4NRC identifiedFailure to Make Timely Reports of Changes in Licensed Operator Medical Status Which Impacted Issuance of Initial and Renewal LicensesExelon Generation Company, LLC (Exelon) identified two AVs: (1) An AV of Title 10 of the Code of Federal Regulations (10 CFR) 50.9, Completeness and Accuracy of Information; and (2) An AV of 10 CFR 50.74, Notification of Change in Operator or Senior Operator Status. Specifically, during an internal audit in July 2014, Exelon identified that between September 2002 and February 2012, NMPNS staff submitted certified copies of an NRC reactor operator and/or senior operator license applications for seven applicants that did not specify that the applicants required a restriction in order to maintain medical qualifications. The NRC issued the reactor operator and senior operator initial and renewed licenses for the seven applicants, but without the necessary medical restrictions (AV #1). From June 2002 through August 2014, Exelon had numerous additional opportunities to identify these potentially disqualifying medical conditions and that license conditions were required during the biennial licensed operator requalification program reviews and medical examinations. On September 25, 2014, a period that exceeded 30 days from when the conditions were identified, the facility notified the NRC of these medical conditions via a letter requesting amendment to the seven operators licenses to include the appropriate restrictions (AV #2). The NRC issued the license amendment with the new restrictions. The NRC inspectors also identified an additional example of both AVs which had not been reported by Exelon to the NRC in the September 25, 2014 letter. On November 5, 2014, Exelon requested termination of the license for that operator. This issue was entered into Exelons corrective action program (CAP) The inspectors determined that Exelons failure to provide complete and accurate information to the NRC in the reactor operator and senior operator license applications and to notify the NRC of a change in a reactor operator or senior operators status for a condition which was known by Exelon were performance deficiencies that were within their ability to foresee and correct and should have been prevented. The inspectors determined that traditional enforcement applies, as the issue affected the NRCs ability to perform its regulatory function. Namely, the NRC requires Exelon to ensure all licensed operators meet the medical conditions of their licenses. If, during the term of the individual operator license, an operator develops a permanent physical or mental disability that causes the operator to fail to meet the requirements of 10 CFR 55.21, Medical Examination, the licensee shall notify the NRC within 30 days of learning of the diagnosis, in accordance with 10 CFR 50.74(c). Additionally, the NRC issued reactor operator and senior operator licenses to the applicants based on information that was not complete and accurate in all material aspects. The performance deficiencies were screened against the Reactor Oversight Process per the guidance of IMC 0612, Appendix B, Issue Screening. No associated Reactor Oversight Process finding was identified and no cross-cutting aspect was assigned. These issues constitute AVs in accordance with the NRCs Enforcement Policy, and their final significance will be dispositioned in separate future correspondence. (Section 1R11)
05000410/FIN-2014004-012014Q3GreenH.1NRC identifiedLoss of Secondary Containment due to Loss of Auxiliary Boiler SystemThe inspectors identified a Green finding (FIN) of CNG-PR-1.01-1005, Control of Technical Procedure Format and Content, Revision 00500, because Exelon Generation Company, LLC (Exelon) provided Unit 2 operators with an inadequate auxiliary boiler system operating procedure. Specifically, N2-OP-48, Auxiliary Boiler System, Revision 01100.00, did not provide operators adequate detail to properly establish chemistry requirements for water conductivity of the auxiliary boiler system. On March 23, 2014, when Unit 2 experienced a trip of the auxiliary boiler system due to inadequate water conductivity, operators became challenged with system restoration which caused an unplanned loss of secondary containment and entry into Technical Specification (TS) 3.6.4.1, Secondary Containment. Exelon generated condition report (CR)-2014-002281 regarding this issue. Immediate corrective actions included updating chemistry requirements associated with auxiliary boiler procedures, implementing new preventive maintenance (PM) strategies for significant components associated with the auxiliary boilers, and implementing new performance monitoring plans. This finding is more than minor because it affected the procedure quality attribute of the Barrier Integrity cornerstone and affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, over the past 2 years, the auxiliary boilers have experienced trips as a result of insufficient procedural guidance. On March 23, 2014, the inadequate procedural guidance resulted in a trip and subsequent loss of reactor building (RB) differential pressure (DP). This caused an unplanned entry into the secondary containment emergency operating procedure and an unplanned entry into TS 3.6.4.1, which presented unnecessary challenges and distractions to operators during a planned downpower. In accordance with IMC 0609.04, Initial Characterization of Findings, the inspectors used IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, because secondary containment was declared inoperable following a loss of building heating. Using Appendix A, Exhibit 3, Barrier Integrity Screening Questions, Section C, Control Room, Auxiliary, Reactor, or Spent Fuel Pool Building, the inspectors determined that this finding is of very low safety significance (Green) because although the performance deficiency resulted in a trip of the auxiliary boiler system and a loss of secondary containment, the RB DP was restored to greater than 0.25 inches of water, within the allowable limiting condition for operation time, and did not result in a failure of the ability for secondary containment to maintain isolation or impact the ability for standby gas treatment system to maintain secondary containment. This finding has a cross-cutting aspect in the area of Human Performance, Resources, because Exelon did not ensure personnel, equipment, procedures, and other resources were available and adequate to support nuclear safety. Specifically, the inadequate management oversight of the auxiliary boilers resulted in numerous failures of the auxiliary boilers due to inadequate knowledge transfer, inaccurate classifications of maintenance rule functional failures for the system, inadequate procedures for boiler operation, and inadequate procedures for the prompt restoration of secondary containment when the auxiliary boiler system is not available (H.1).
05000220/FIN-2014404-042014Q2GreenLicensee-identifiedLicensee-Identified Violation
05000410/FIN-2014003-042014Q2GreenSelf-revealingFailure to Identify Single-Point Vulnerabilities Results in a Manual Reactor ScramA self-revealing Green Finding (FIN) was identified at Unit 2 against procedure CNG-AM-1.01-2000, Scoping and Identification of Critical Components, Revision 00200. Specifically, Exelon staff performed an inadequate AP-913 evaluation in 2006. This evaluation failed to identify that reactor recirculation pump (RRP) switches S101A and S101B were single-point vulnerable components, so mitigating strategies to ensure proper operation to minimize plant risk were not developed. As a result, on December 2, 2013, both RRPs failed to properly shift from fast to slow speed resulting in a loss of all recirculation flow through the core and requiring operators to insert a manual reactor scram in accordance with plant procedures. Exelon generated CR-2013-009735, performed a root cause analysis (RCA), and developed corrective actions which included revising procedure N2-OP-29, Reactor Recirculation System, Revision 01801, to direct operators to manually start the low frequency motor generator sets, implementing a preventive maintenance activity for these switches, and developing plans to replace the switches during the next refueling outage (RFO). This finding is more than minor because it is associated with the equipment performance attribute of the Initiating Events cornerstone and adversely impacted the associated cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Additionally, the performance deficiency is similar to Example 4b of IMC 0612, Appendix E, Examples of Minor Issues, in that the error resulted in a plant trip. Specifically, the failure to identify switches S101A and S101B as single-point vulnerabilities and develop appropriate mitigating strategies resulted in the failure of the switches and a manual reactor scram on December 2, 2013. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 1 of IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, issued June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green); the performance deficiency did not cause both a reactor trip and the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition (e.g.; loss of condenser, loss of feedwater). The inspectors did not assign a cross-cutting aspect to this finding because the performance deficiency was determined to have occurred in 2006, and the guidance in the current revision of CNG-AM-1.01-2000, Appendix A, was sufficient for Exelons root cause team to determine the switches should have been screened in. Therefore, this finding is not indicative of current licensee performance and no cross-cutting issue was assigned.
05000220/FIN-2014404-052014Q2GreenLicensee-identifiedLicensee-Identified Violation
05000220/FIN-2014404-012014Q2GreenNRC identifiedSecurity
05000410/FIN-2014003-012014Q2GreenNRC identifiedInadequate Surveillance Testing of Reactor Core Isolation Cooling during 165 psig Reactor Pressure Test for Surveillance Requirement 3.5.3.4The inspectors identified a NCV of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, due to Exelon staffs procedures for meeting Unit 2 Technical Specification (TS) Surveillance Requirement (SR) 3.5.3.4 being inadequate since they did not test all required functions over the pressure range they were required since the start of plant operation. Specifically, inspectors identified that reactor core isolation cooling (RCIC) was being started with the flow controller in manual during the 165 pounds per square inch gauge (psig) reactor pressure test as opposed to automatic, which is its normal lineup. As a result, the RCIC system has not been adequately tested to develop flow at low reactor pressures to ensure that the surveillance had been met and that the RCIC system met its design basis. This finding is more than minor because it affected the equipment performance attribute of the Mitigating Systems cornerstone and its objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. This finding is similar to Example 3.d in IMC 0612, Power Reactor Inspection Reports, Appendix E, Examples of Minor Issues. Specifically, the inadequate testing of the RCIC system with reactor pressure 165 psig has led to uncertainty in the reliability and capability of the system to perform at low reactor pressures. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, the inspectors determined that this finding is of very low safety significance (Green) because the deficiency affects only the design or qualification of a mitigating SSC; and the design or qualification issue is not currently impacting its operability. The inspectors did not assign a cross-cutting aspect to this finding because the performance deficiency is not indicative of present performance because Exelons incorrect interpretation for conducting TS SR 3.5.3.4 did not occur within the last 3 years.
05000220/FIN-2014404-022014Q2GreenNRC identifiedSecurity
05000220/FIN-2014003-022014Q2GreenP.3NRC identifiedFailure to Correct a Significant Condition Adverse to Quality in a Timely MannerThe inspectors identified an NCV of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XVI, Corrective Action, for failure to ensure that corrective actions to preclude repetition for a significant condition adverse to quality were implemented in a timely manner. Specifically, corrective actions to preclude repetition for the April 16, 2013, loss of shutdown cooling event to revise two inadequate Unit 1 procedures had not been completed over a year later. If left uncorrected, the inspectors determined there was the potential for 10 different pumps and breakers to unexpectedly trip upon restoration of a direct current (DC) bus. The loss of several of these pumps and loads would result in an unexpected plant transient or require a manual reactor trip. Exelon wrote condition report (CR)-2014-005693 in response to the inspectors questions and determined that inadequate resources were assigned to this corrective action to preclude repetition. Procedures N1-OP-47A, 125 (volts direct current) VDC Power System, and N1-SOP- 47A.1, Loss of DC, were subsequently revised and issued on June 12, 2014. This finding is more than minor because it impacted the procedure quality attribute of the Initiating Events cornerstone and adversely affected the associated cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, if left uncorrected, there was the potential for 10 different pumps and breakers to unexpectedly trip upon restoration of a DC bus. Several of these pumps and loads would result in an unexpected plant transient or require a manual reactor trip. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 1 of IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, the inspectors determined that this finding is of very low safety significance (Green) because the finding did not involve the complete or partial loss of a support system that contributes to the likelihood of, or cause, an initiating event and affected mitigation equipment. This finding has a cross-cutting aspect of in the area of Problem Identification and Resolution, Resolution, because Exelon did not take effective corrective actions to address an issue in a timely manner commensurate with its safety significance. Specifically, Exelon failed to implement corrective actions to prevent recurrence (CA#1 from CR-2013-002926), to revise procedures N1-SOP-47A.1 and N1-OP- 47A to contain adequate guidance to ensure recovery from a loss of a DC bus would not result in an unexpected plant transient a year after the event occurred.