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05000498/FIN-2018002-01Licensee-Identified Violation2018Q2This violation of very low safety significance was identified by the licensee, has been entered into the licensees corrective action program and is being treated as a Non-Cited Violation, consistent with Section 2.3.2 of the Enforcement Policy. Violation: Technical Specification 6.8.1.a requires that, Written procedures shall be established, implemented, and maintained covering the activities referenced below: The applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Section 9.a, Procedures for Performing Maintenance, states, in part, that Maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. The licensee established Procedure COM-0001, Conduct of Maintenance, to guide maintenance craft on what to do if a condition or issue arises during a maintenance activity. Specifically, Section 1.4 Supervisor Responsibilities, states, in part, that, If we cannot find the problem with the component or piece of equipment, the issue must be raised to the Division Manager/General Supervisor BEFORE we close the work control document AND return the equipment to operations. Contrary to the above, on March 10, 2017, Unit 1 E1B undervoltage relay was found outside the technical specification acceptance criteria, and was retested until the relay it was back in tolerance and placed back into service (declared operable) instead of raising the issue up to the division manager for further evaluation. The issue was discussed with the electrical maintenance supervisor and the findings were documented in Condition Report 17-12616. The relay was declared operable and placed back into service. Subsequently, after review of the condition report, approximately 99 hours after the relay was declared inoperable, the relay was replaced, and the system declared operable. Significance/Severity Level: The inspectors determined the performance deficiency was more than minor because it adversely affected the equipment performance attribute of the Mitigating Systems Cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the undervoltage relay was outside its tolerance and placed back into service without correcting the cause of being outside its tolerance. The inspectors assessed the significance of the finding using Exhibit 2, Mitigating Systems Screening Questions, of Inspection Manual Chapter 0609, Appendix A, Significance Determination Process (SDP) for Findings At-Power, issued June 19, 2012, and determined this finding is not a deficiency affecting the design or qualification of a mitigating structure, system, and component that maintained its operability or functionality; the finding does not represent a loss of system and/or function; the finding does not represent an actual loss of function of at least a single train for greater than its Technical Specification-allowed outage time; and the finding does not represent an actual loss of function of one or more non-Technical Specification trains of equipment designated as high safety-significant. Therefore, the inspectors determined the finding was of very low safety significance (Green). Corrective Action Reference: Condition Report 17-12616
05000498/FIN-2018001-04Licensee-Identified Violation2018Q1This violation of very low safety significance was identified by the licensee and has been entered into the licensees corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.Violation: Title 10 CFR 50.9, Completeness and accuracy of information, requires, in part, that information required by the Commissions regulations, orders, or license conditions to be maintained by the licensee shall be complete and accurate in all material respects. STP Nuclear Operating Company, Unit 2 Renewed Facility Operating License Condition 2.E. Fire Protection states, in part, that the licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report through Amendment 62. Updated Final Safety Analysis Report Subsection 9.5.1.6.1 Administrative Controls states, in part that the operability/functional capability of the fire protection systems required to protect safe shutdown capability is assured through the implementation of an administrative program. This program includes compensatory actions for systems out-of-service.Procedure 0PGP03-ZF-0001, Fire Protection Program, Revision 31, Step 7.3 requires, in part, that completed fire watch logs Form 4 or their equivalent shall be retained for 3 years.Contrary to the above, the licensee failed to maintained information required by the Commissions regulations, orders, or license conditions that was complete and accurate in all material respects as evidenced by the following two examples:1. On May 25, 2016, the written fire watch log, documented on Form 4, for Unit 2 Fire Watch 10118, for Room 105, for the hours of 1928 and 2015, indicated that the hourly fire watches were conducted by passing through the areas covered by the fire watch. However, the fire watch never entered Room 105 for these 2 hours. The hourly fire watch patrol data is material to the NRC in that it provides sufficient evidence of compliance with regulatory requirements.2. On May 25-26, 2016, the electronic fire watch scanned logs for Unit 2 Fire Watch 10118, for Room 105 between the hours of 2105 on May 25, 2016, to 0504 on May 26, 2016, show that the 9 hourly fire watches were conducted by passing through the areas covered by the fire watch. However, a temporary scan point was placed at the base of the ladder in Room 002 to scan for Room 105. The hourly fire watch individuals never entered Room 105. The hourly fire watch patrol data is material to the NRC in that it provides sufficient evidence of compliance with regulatory requirements.Significance/Severity Level: Although this violation is willful, it was brought to the NRCs attention by the licensee, it involved isolated acts of low-level individuals, and it was addressed by appropriate remedial action. Therefore, this violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy. Corrective Action Reference: Condition Report 18-0948
05000498/FIN-2018001-03Licensee-Identified Violation2018Q1This violation of very low safety significancewas identified by the licensee and has beenentered into the licensees corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.Violation: Title 10 CFR50.48, Fire Protection, requires, in part, that licensees have a fire protection plan that outlines the plans for fire protection, fire detection, suppression capability, and limitation of damage.STP Nuclear Operating Company, Unit 2 Renewed Facility Operating License Condition 2.E. Fire Protection states, in part, that the licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report through Amendment 62. Updated Final Safety Analysis Report Subsection 9.5.1.6.1 Administrative Controls states, in part, that the operability/functional capability of the fire protection systems required to protect safe shutdown capability is assured through the implementation of an administrative program. This program includes compensatory actions for systems out-of-service.Procedure 0PGP03-ZF-0001, Fire Protection Program, Revision 31, Step 4.7.2.14, requires, in part, hourly fire watch personnel must pass through the areas covered by the fire watch and then sign and enter the time on the fire watch log, using the bar code reader, at least once every clock hour.Contrary to the above, on May 25 and 26, 2016, the licensees fire watch personnel failed to pass through the areas covered by the fire watch and then sign and enter the time on the fire watch log, using the bar code reader, at least once every clock hour. Specifically, two fire watch individuals documented conducting Unit 2 Fire Watch 10118 for Room 105 starting on May 25, 2016, at 1928 and finishing on May 26, 2016, at 0504 when in fact the individuals did not enter Room 105.Significance/Severity Level: Although this violation is willful, it was brought to the NRCs attention by the licensee, it involved isolated acts of low-level individuals, and it was addressed by appropriate remedial action. Therefore, this violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy. Corrective Action References: Condition Reports 16-7305, 16-7089, 16-7344, and 16-9077
05000499/FIN-2018001-02Failure to Promptly Identify and Correct a Condition Adverse to Quality Associated with Reactor Containment Fan Coolers2018Q1The inspectors identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI for the failure to promptly identify and correct a condition adverse to quality. Specifically, the backdraft damper of the Unit 2, train B reactor containment fan cooler failed to close, as designed, due to a failed closing spring. The backdraft damper had undergone a preventative maintenance activity one month prior to the failure, but the closing spring degradation was not identified.
05000498/FIN-2018001-01Failure to Perform a Maintenance Risk Assessment Prior to Conducting Maintenance2018Q1The inspectors identified a Green, non-cited violation of 10 CFR 50.65(a)(4) for the failure to perform a maintenance risk assessment prior to performing maintenance that could have resulted in a reactor shutdown. Specifically, maintenance performed to install bird netting on the Unit 1 deaerator structure above the balance of plant 13.8 kV transformers was not evaluated or identified as being a threat to stable power operations.
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05000498/FIN-2017010-01Failure to Conduct Drills In Accordance with the Site Emergency Plan2017Q3The inspectors identified a non-cited violation of 10 CFR 50.54(q)(2) associated with the licensees failure to conduct correctly scoped drills as required by the site emergency plan in 2015 and 2016. Annually, the licensee was required to conduct a radiological monitoring drill involving taking samples on-site and offsite of air, vegetation, soil, and water samples. Semiannually, the licensee was required to conduct health physics drills which involved response to and analysis of simulated elevated airborne and liquid samples. During these years, the licensee failed to evaluate emergency response personnel demonstrating abilities addressing all of these criteria. This violation is not an immediate safety concern because drills were conducted involving the site health physics staff during the time period. This issue was entered into the licensees corrective action program in Condition Reports 17-15971 and 17-15974. The performance deficiency was more than minor because it was associated with the emergency response organization performance (drills and exercises) cornerstone attribute and adversely affected the Emergency Preparedness cornerstone objective of being capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. The finding was evaluated using Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, dated September 22, 2015. The finding was determined to be of very low safety significance (Green) because it was a failure to comply with NRC requirements, was not associated with the risk-significant planning standards, and was not a loss of a planning standard function. The finding had a cross-cutting aspect in the area of human performance associated with resources because the licensees procedure defining drill objectives and demonstration criteria did not address the entire scope of the drill types in question (H.1).
05000498/FIN-2017010-02Failure to Perform Required 50.54(q) Evaluations prior to Implementing Changes to the Emergency Plan2017Q3The NRC identified a Severity Level IV violation of 10 CFR 50.54(q)(3) for the failure to perform analyses demonstrating that changes to the emergency plan did not reduce the effectiveness of the plan before implementing the changes without prior NRC approval. The failure to perform required evaluations did not have any safety consequences; the inspectors verified that the changes did not reduce the effectiveness of the emergency plan. The issue was entered into the licensees corrective action program as Condition Report 2017-15956. The failure to perform analyses of the effect of changes in processes supporting emergency preparedness is a performance deficiency. The performance deficiency is more than minor because it affected the procedure quality (plan changes) cornerstone attribute and adversely affected the Emergency Preparedness cornerstone objective of being capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. The performance deficiency was assessed using traditional enforcement because the licensees failure to perform a required analysis impacted the regulatory process. The issue was evaluated using the NRCs Enforcement Policy, dated November 1, 2016, Section 6.6(d), and was determined to be a Severity Level IV violation because the violation did not affect radiological assessment or offsite notification. Traditional enforcement violations are not assessed for cross-cutting aspects.
05000498/FIN-2016010-01Failure to Follow Fire Protection Program Procedure Requirements2017Q210 CFR 50.48(a)(1 )(iv) requires, in part, that a licensee must have a fire protection plan that outlines the plans for fire protection, fire detection, suppression capability, and limitation of fire damage. STP Nuclear Operating Company Technical Specification 6;8.1.d requires, in part, that written procedures shall be established, implemented, and maintained covering the fire protection program implementation. Procedure ZFG-0001, "Fire Watch Program Guideline," Revision 10, Step 4.2 requires, in part, that each hourly fire watch shall be responsible for inspecting all areas of the room for possible indications of smoke, fire, or potential fire hazards, which includes looking behind all accessible areas, behind panels and components that may obscure the fire watches' view. Procedure ZFG-0001, "Fire Watch Program Guideline," Revision 11, Step 6.0, requires, in part, that a condition report shall be written for a missed fire watch. Procedure OPGP03-ZX-0002, "Condition Reporting Process," Revision 50, Step 3.7 requires, in part, that condition report owners are responsible for proper resolution of the condition, including ensuring that the condition report description is accurate and actions are initiated to address the condition. Contrary to the above, the licensee failed to implement written procedures covering the fire protection program as evidenced by the following two examples: 1. On May 8-15, 2014, hourly fire watches failed to follow Procedure ZFG-0001 and inspect all areas of the room for possible indications of smoke, fire, or potential fire hazards. Specifically, 20 fire watches, 17 in Unit 1 and 3 in Unit 2, were improperly performed as a result of improper written instructions provided by a supervisor to direct the hourly fire watches to only look at areas of impairments or transient fire loads instead of inspecting all areas of the room as required by fire protection program requirements. 2. On March 4, 2015, a supervisor failed to follow Procedure OPGP03-ZX-0002 when the supervisor closed a condition report and failed to ensure that the condition report description was accurate and actions were initiated to address the condition. Specifically, the supervisor documented inaccurate information in Condition Report 15-4871 that stated, in part, that when a fire watch for Unit 2, Mechanical Auxiliary Building, Room 67 was inadvertently closed, fire watch personnel routinely traversed through the area while performing rounds, and once identified the round was performed immediately with no issues identified. However, no fire watch personnel traversed the area because the room was locked and was not part of their normal route. Therefore, no fire watch personnel entered the room as documented in the condition report closure.
05000498/FIN-2017002-01Failure to Establish Procedures to Remove Reactor Vessel Head Vent Rig Results In Loss of Reactor Coolant System Inventory2017Q2Green . The inspectors documented a self -revealed, non -cited violation of Technical Specification 6.8.1.a, Regulatory Guide 1.33, Revision 2, February 1978, Appendix A, Section 9.d.(4). Specifically, inadequate written work instructions to remove the reactor vessel head vent rig and install a breathable foreign material exclusion cover resulted in installing a blind flange and a loss of reactor coolant system water while at lowered inventory. The licensee developed proper instructions and the blind flange was promptly removed to restore the vent path for the reactor vessel head. Reactor coolant system inventory was restored. This issue was entered into the licensees corrective action program as Condition Report 2017- 13155. The failure of the licensee to provide appropriate written work instructions to install a breathable foreign material exclusion cover following the removal of the reactor vessel head vent rig was a performance deficiency. The performance deficiency is more than minor because it was associated with the configuration control attribute of the Initiating Events Cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the licensee installed a blind flange, instead of a breathable foreign material exclusion cover on the reactor vessel head vent piping, which resulted in an inadvertent loss of reactor coolant during lowered inventory operations. Using Inspection Manual Chapter 0609, Appendix G, Shutdown Operations Significance Determination Process, dated May 9, 2014, Attachment 1, Exhibit 2, Initiating Events Screening Questions, the finding was determined to be of very low safety significance (Green) because the finding would not have resulted in a loss of decay heat removal if undetected for 24 hours, AND was determined to be self -limiting because level would have only lowered to the point at which it would have vented to the pressurizer and not lowered to the point of challenging decay heat removal function. The inspectors determined that the finding had a cross -cutting aspect in the area of human performance associated with work management. The licensee failed to implement an adequate process to execute work activities such that nuclear safety is the overriding priority. Specifically, contractors were supplied generic work instructions to remove the reactor coolant system head vent rig which resulted in a loss of reactor coolant system inventory (H.5).
05000498/FIN-2016010-02Failure to Maintain Complete and Accurate Information for the Fire Protection Program2017Q210 CFR 50.9 requires, in part, that information required by the Commission's regulations, orders, or license conditions to be maintained by the licensee shall be complete and accurate in all material respects. STP Nuclear Operating Company Technical Specification 6.8.1.d requires, in part, that written procedures shall be established, implemented, and maintained covering the fire protection program implementation. Procedure ZFG-0001, "Fire Watch Program Guideline," Revision 10, Step 4.2 requires, in part, that each hourly fire watch shall be responsible for inspecting all areas of the room for possible indications of smoke, fire, or potential fire hazards, which includes looking behind all accessible areas, behind panels and components that may obscure the fire watches' view. Step 4.2.12 requires, in part, that after completing the inspection of the assigned area, scan the appropriate "Fire Watch Scan Point" above the fire watch posting. Procedure ZFG-0001, "Fire Watch Program Guideline," Revision 11, Step 6.0, requires, in part, that a condition report shall be written for a missed fire watch. Procedure OPGP03-ZX-0002, "Condition Reporting Process, Revision 50, Step 3. 7 requires, in part, that condition report owners are responsible for proper resolution of the condition, including ensuring that the condition report description is accurate and actions are initiated to address the condition. Contrary to the above, the licensee failed to ensure that information required by the Commission's regulations, orders, or license conditions to be maintained by the licensee shall be complete and accurate in all material respects as evidenced by the following three examples: 1. On May 8-15, 2014, the licensee failed to maintain complete and accurate records associated with hourly fire watches. Specifically, a total of 20 fire watch records, 17 in Unit 1 and 3 in Unit 2, were recorded (scanned) as being completed without inspecting all areas of the room for possible indications of smoke, fire, or potential fire hazards. This information was material to the NRC because the performance of fire watches enables the rapid detection, control, and suppression of a fire in accordance with the fire protection program requirements. 2. On March 4, 2015, the licensee failed to maintain complete and accurate records associated with a condition report. Specifically, a supervisor willfully documented inaccurate information in Condition Report 15-4871 that stated, in part, that when a fire watch for Unit 2, Mechanical Auxiliary Building, Room 67 was inadvertently closed, fire watch personnel routinely traversed through the area while performing rounds, and once identified the round was performed immediately with no issues identified. However, no fire watch personnel traversed the area because the room was locked and was not part of their normal route. Therefore, no fire watch personnel entered the room as documented in the condition report closure. This information was material to the NRC because condition reports associated with missed fire watches provide evidence of compliance with licensee procedures and NRC requirements. 3. On April 14, 2015, the licensee failed to maintain complete and accurate records associated with a condition report. Specifically, a supervisor deliberately documented inaccurate information in Condition Report 15-9793 that stated, in part, that field interviews with a fire watch manager and a fire watch lead indicated that the Unit 2 fire watches (FW8934) were properly performed. However, the supervisor did not confirm with the fire watch manager or a fire watch lead that the fire watches had been performed. This information was material to the NRC because condition reports associated with missed fire watches provide evidence of compliance with licensee procedures and NRC requirements.
05000498/FIN-2017002-02Failure to Establish Procedures for Control of High - Energy Line Break Barriers2017Q2Green . The inspectors identified a non -cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for failure to establish adequate procedures for the control of high -energy line break barriers. Specifically, on July 21, 2016, the inspectors identified that Procedure 0PGP03 -ZA -0514, Controlled System or Barrier Impairment, Revision 14, did not have any guidance on the control of barriers used for high -energy line breaks, despite the fact that the auxiliary feedwater pump room watertight doors are credited in the safety analyses for protection against such breaks. After discussing the acceptability of having both doors open simultaneously, the licensee shut the watertight door to auxiliary feedwater pump room for train A, and entered this condition into the licensees corrective action program as Condition Report 2016 -9006. The failure to prescribe procedures for the control of high -energy line break doors was a performance deficiency. This finding was more than minor because it was associated with the procedure quality 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. Specifically, Procedure 0PGP03 -ZA -0514, Controlled System or Barrier Impairment, Revision 14, did not provide adequate procedures for the control of hazard barriers, which called the operability of the train A auxiliary feedwater system into question. In accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At -Power, dated June 19, 2012, Exhibit 2, Mitigating Systems Screening Quest ions, the issue screened as having very low safety significance (Green) because it was a design or qualification deficiency that did not represent a loss of operability or functionality; did not represent an actual loss of safety function of the system or train; did not result in the loss of one or more trains of non- technical specification equipment; and did not screen as potentially risk significant due to seismic, flooding, or severe weather. The NRC determined that this finding did not have a cross -cutting aspect because the most significant contributor to the performance deficiency did not reflect current licensee performance. Specifically, the auxiliary feedwater pump evaluation was performed in 2000; therefore, the performance deficiency occurred outside of the nominal 3- year period for present performance.
05000498/FIN-2016010-03Licensee-Identified Violation2017Q2Title 10 CFR 50.48(a)(1)(iv) requires, in part, that a licensee must have a fire protection plan that outlines the plans for fire protection, fire detection, suppression capability, and limitation of fire damage. Technical Specification 6.8.1.d requires, in part, that written procedures shall be established, implemented, and maintained covering the fire protection program implementation. Procedure ZFG-0001, "Fire Watch Program Guideline," Revision 11, Step 2.5 defines a continuous fire watch, in part, as the act of monitoring an area for conditions that could lead to a fire without leaving the assigned area until relieved by another qualified fire watch person, or when the posting is closed. Step 5.2.8 requires, in part, that, for a continuous fire watch, the fire watch is to inspect _ the area of the posting to ensure the fire watch pays attention to any possible smells indicating problems (burning rubber, plastic, wood, etc.). Contrary to the above, on January 30, 2015, a continuous fire watch failed to inspect the area of the posting, Unit 2 Electrical Auxiliary Building, Elevation 23, Room 101, and failed to ensure they were attentive to any possible smells indicating problems. Specifically, the continuous fire watch was found inattentive. In accordance with Inspection Manual Chapter 0609 Appendix F, "Fire Protection Significance Determination Process," dated September 20, 2013, the inspectors determined that this finding has a very low safety significance (Green) per Task 1.3.1, "Screen Fire Finding for Ability to Achieve Safe Shutdown," because Train C was available for safe shutdown. This issue was entered into the licensee's corrective action program as Condition Report 15-2506.
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05000498/FIN-2017002-03Failure To Establish Adequate Procedures To Ensure Emergency Diesel Generator Access Flood Panels Would Meet Their Safety Function2017Q2Green . The inspectors identified a non -cited violation of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the failure to provide adequate written instructions for performing preventative maintenance to ensure the emergency diesel generator building access flood panels remain capable of performing their safety function. Specifically, the preventative maintenance work order model number 61046 was not adequate to detect degraded seal conditions, which were revealed during the flooding event on March 17, 2017. This issue was entered into the licensees corrective action program as Condition Report 2017- 12897. The licensee assembled a panel of individuals who were familiar with the design, and individuals responsible for the maintenance of these access panels and is still considering options to prevent future leakage. The failure to provide adequate written instructions for performing preventative maintenance to ensure diesel generator building access flood panels remain capable of performing their safety function was a performance deficiency. Specifically, preventative maintenance work order model number 61046 was not adequate to detect degraded seal conditions, which were revealed during the flooding event on March 17, 2017. The performance deficiency is. 4 more than minor, and therefore a finding, because it is associated with the protection against external f actors attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to identify degrading flood barriers could result in emergency diesel generator inoperability or failure during a design basis flooding event. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) For Findings At-Power, dated July 1, 2012, Exhibit 2, Mitigating System Screening Questions, the finding was determined to of very low safety significance (Green). Specifically, the finding was not a deficiency affecting the design or qualification of a mitigating structure, system, and component ; did not represent a loss of system and/or function; did not represent an actual loss of function of at least a single train for greater than its technical specification allowed outage time; and did not represent an actual loss of function of one or more than non- technical specification trains of equipment designated as high -risk significance for greater than 24 hours. The inspectors determined that this finding did not have a cross- cutting aspect because the most significant contributor to the performance deficiency did not reflect current licensee performance. Specifically, the emergency diesel generator access panels had not allowed water intrusion due to flooding within the last 3 years and, therefore, the licensee did not have a recent opportunity to understand that the preventative maintenance work order instructions were inadequate.
05000498/FIN-2017007-01Failure to Provide 8-HOUR Emergency Lighting in All Areas Where Operators Perform Manual Actions Required During an Alternative Shutdown2017Q1Green. The team identified a non-cited violation of License Condition 2.E for the failure to provide 8-hour emergency lighting in all areas where operators perform manual actions required during an alternative shutdown. As a compensatory measure, the licensee added flashlights to the procedure box in the essential cooling water intake structure. The team noted that operators were also required to carry a flashlight while on shift. The licensee entered this issue into their corrective action program as Condition Report 17-1741. The failure to provide 8-hour emergency lighting in all areas where operators perform manual actions required during an alternativ e shutdown was a performance deficiency. The performance deficiency was more than minor because it was associated with the protection against external events (fire) a ttribute of the Mitigating Systems Cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to provide 8-hour emergency lighting could adversely affect the ability of operators to perform the manual actions required for an alternative shutdown. The team determined this finding affected the Mitigating Systems Cornerstone. The team evaluated this finding using Ins pection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, dated September 20, 2013, because it affected the ability to reach and maintain safe shutdown conditions in case of a fire. The team determined this finding was of very low safety significance (Green) in Task 1.3.1 because it had a low degradation rating. The finding did not have a cross-cutting aspect since it was not indicative of present performance in that the performance deficiency occurred more than three years ago. Specifically, the team determined that the per formance deficiency existed since original construction.
05000498/FIN-2017009-01Failure to Implement Written Procedures Covering the Fire Protection Program2017Q1During NRC investigations conducted March 25, 2015 through February 24, 2017, two violations of NRC requirements were identified. In accordance with the NRC Enforcement Policy, the violations are listed below: A. 10 CFR 50.48(a)(1 )(iv) requires, in part, that a licensee must have a fire protection plan that outlines the plans for fire protection, fire detection, suppression capability, and limitation of fire damage. STP Nuclear Operating Company's Technical Specification 6.8.1.d requires, i n part, that written procedures shall be established, implemented, and maintained covering the fire protection program implementation. Procedure ZFG-0001, "Fire Watch Program Guideline," Revision 10, Step 4.2, requires, in part, that each hourly fire watch shall be responsible for inspecting all areas of the room for possible indications of smoke, fire, or potential fire hazards, which includes looking behind all accessible areas, behind panels and components that may obscure the fire watches' view. Procedure ZFG-0001, "Fire Watch Program Guideline," Revision 11, Step 6.0, requires, in part, that a condition report shall be written for a missed fire watch. Procedure OPGP03-ZX-0002, "Condition Reporting Process," Revision 50, Step 3.7, requires, in part, that condition report owners are responsible for proper resolution of the condition, including ensuring that the condition report description is accurate and actions are initiated to address the condition. Contrary to the above, the licensee failed to implement written procedures covering the fire protection program, as evidenced by the following two examples: 1. On May 8-15, 2014, hourly fire watches failed to follow Procedure ZFG-0001 and inspect all areas of the room for possible indications of smoke, fire, or potential fire hazards. Specifically, 20 fire watches, 17 in Unit 1, and 3 in Unit 2, were improperly performed as a result of improper written instructions provided by a supervisor that directed the hourly fire watches to only look at areas of impairments or transient fire loads instead of inspecting all areas of the room, as required by fire protection program requirements. 2. On March 4, 2015, a supervisor fa iled to follow Procedure OPGP03-ZX-0002 when the supervisor closed a condition report and failed to ensure that the condition report description was accurate and actions were initiated to address the condition. Specifically, the supervisor documented inaccurate information in Condition Report 15-4871 that stated, in part, that when a fire watch for Unit 2, Mechanical Auxiliary Building, Room 67 was inadvertently closed, fire watch personnel routinely traversed through the area while performing rounds, and once identified the round was performed immediately with no issues identified. However, no fire watch personnel traversed the area because the room was locked and it was not part of their normal route. Therefore, no fire watch personnel entered the room as documented in the condition report closure. B. 10 CFR 50.9 requires, in part, that information required by the Commission's regulations, orders, or license conditions to be maintained by the licensee shall be complete and accurate in all material respects. STP Nuclear Operating Company Technical Specification 6.8.1.d requires, in part, that written procedures shall be established, implemented, and maintained covering the fire protection program implementation. Procedure ZFG-0001, "Fire Watch Program Guideline," Revision 10, Step 4.2, requires, in part, that each hourly fire watch shall be responsible for inspecting all areas of the room for possible indications of smoke, fire, or potential fire hazards, which includes looking behind all accessible areas and behind panels and components that may obscure the fire watches' view. Step 4.2.12 requires, in part, that after completing the inspection of the assigned area, scan the appropriate "Fire Watch Scan Point" above the fire watch posting. Procedure ZFG-0001, "Fire Watch Program Guideline," Revision 11, Step 6.0, requires, in part, that a condition report shall be written for a missed fire watch. Procedure OPGP03-ZX-0002, "Condition Reporting Process," Revision 50, Step 3.7, requires, in part, that condition report owners are responsible for proper resolution of the condition, including ensuring that the condition report description is accurate and actions are initiated to address the condition. Contrary to the above, the licensee failed to ensure that information required by the Commission's regulations, orders, or license conditions maintained by the licensee are complete and accurate in all material respects, as evidenced by the following three examples: 1. On May 8-15, 2014, the licensee failed to maintain complete and accurate records associated with hourly fire watches. Specifically, a total of 20 fire watch records, 17 in Unit 1, and 3 in Unit 2 were recorded (scanned) as being completed without inspecting all areas of the room for possible indications of smoke, fire, or potential fire hazards. This information was material to the NRC because the performance of fire watches enables the rapid detection, control, and suppression of a fire in accordance with the fire protection program requirements. 2. On March 4, 2015, the licensee failed to maintain complete and accurate records associated with a condition report. Specifically, a supervisor willfully documented inaccurate information in Condition Report 15-4871 that stated, in part, that when a fire watch for Unit 2, Mechanical Auxiliary Building, Room 67, was inadvertently closed, fire watch personnel routinely traversed through the area while performing rounds, and once identified the round was performed immediately with no issues identified. However, no fire watch personnel traversed the area because the room was locked and it was not part of their normal route. Therefore, no fire watch personnel entered the room, as documented in the condition report. This information was material to the NRC because condition reports associated with missed fire watches provide evidence of compliance with licensee procedures and NRC requirements. 3. On April 14, 2015, the licensee failed to maintain complete and accurate records associated with a condition report. Specifically, a supervisor deliberately documented inaccurate information in Condition Report 15-9793 that stated, in part, that field interviews with a fire watch manager and a fire watch lead indicated that the Unit 2 fire watches (FW8934) were properly performed. However, the supervisor did not confirm with the fire watch manager or a fire watch lead that the fire watches had been properly performed. This information was material to the NRC because condition reports associated with missed fire watches provide evidence of compliance with licensee procedures and NRC requirements. This is a Severity Level Ill problem (NRC Enforcement Policy Section 2.2.1.d) .
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05000498/FIN-2016406-01Security2016Q2
05000498/FIN-2016406-02Security2016Q2
05000498/FIN-2016002-02Failure to Control Steam Generator Water Levels at Low Power2016Q2The inspectors documented a self-revealed, non-cited violation of Technical Specification 6.8.1.a, Procedures, for failure to implement procedures for power operation as described in Regulatory Guide 1.33, Revision 2, Appendix A, Section 2.g, dated February 1978. Specifically, the procedure the licensee used for low power operation failed to include adequate instructions for the control of steam generator water levels, which resulted in a plant cooldown, a letdown isolation, a pressurizer power-operated relief valve lift, and unplanned entry into two technical specification action statements. The licensee entered this issue into the corrective action program as Condition Report 2015-26657. The inspectors determined that the failure to control steam generator water levels due to an inadequate procedure during lower power operations was a performance deficiency. The performance deficiency is more than minor because it is associated with the procedure quality attribute of the Initiating Events Cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the failure to control steam generator water levels resulted in a plant cooldown, a reactor coolant system letdown isolation, a pressurizer power-operated relief valve to lift, and unplanned entry into two technical specification action statements. The inspectors screened this finding using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) For Findings At-Power, dated June 19, 2012. The finding screened as Green per Section B. of Exhibit 1, Initiating Events Screening Questions, because the finding did not result in exceeding the reactor coolant system leak rate for a small loss-of-coolant accident, did not affect other systems used to mitigate a loss-of-coolant accident resulting in a total loss of their function, and did not cause 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. Inspectors determined the finding had a cross-cutting aspect of training in the human performance area because the organization failed to provide training and ensure knowledge was transferred to maintain a knowledgeable, technically competent workforce and instill nuclear safety values. Specifically, because the licensee provided start-up training and simulator based training, skill of the craft vice detailed procedures was thought to be adequate for controlling steam generator water levels at low power (H.9).
05000498/FIN-2016002-01Inadequate Scaffold Procedure to Ensure Safety-Related Equipment Not Impacted2016Q2The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the failure to provide an adequate scaffold procedure to ensure that safety-related equipment would not be impacted. Specifically, Procedure 0PGP03-ZM-0028, Erection and Use of Temporary Scaffolding, Revision 20, did not give scaffold clearance parameters when constructing scaffold around safety-related mechanical and structural components, nor did it direct an engineering evaluation if scaffold is in contact with safety-related components or when clearances cannot be met. The licensee entered this issue into the corrective action program as Condition Report 16-5503. The failure to have adequate procedural guidance for erecting temporary scaffold in the vicinity of safety-related components was a performance deficiency. Specifically, Procedure 0PGP03-ZM-0028, Erection and Use of Temporary Scaffolding, Revision 20, only described scaffold clearance around safety-related electrical equipment, but not safety-related mechanical and structural components. The performance deficiency is more than minor, and therefore a finding, because if left uncorrected could become a more safety significant safety issue following a seismic event. Specifically, the continued practice of building scaffolding in contact with safety-related equipment and without an engineering evaluation could lead to damage, inoperability, or unavailability during system perturbations or following a seismic event. The inspectors evaluated this finding in accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) For Findings At-Power, dated June 19, 2012, Exhibit 2, Mitigating Screening Questions. The inspectors determined the finding was of very low safety significance (Green) because the finding did not: 1) affect the design or qualification of a mitigating structure, system, and component; 2) represent a loss of system and/or function; 3) represent an actual loos of function of at least a single train for greater than its technical specification allowed outage time or two separate safety systems for greater than its technical specification allowed outage time; or 4) represent an actual loss of function of one or more technical specification trains of equipment designated as high safety significance in accordance with the licensees maintenance rule program for greater than 24 hours. The inspectors determined that the finding has a cross-cutting aspect of self-assessment in the problem identification and resolution area, because the licensee had not recently conducted a periodic and critical review of the temporary scaffold program and procedures (P.6).
05000498/FIN-2016007-09Failure to Ensure Adequate Design Control Measures in Place to Mitigate a Loss of Normal Feedwater Flow Event2016Q1The team identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, which states, in part, that Measures shall be established to assure that applicable regulatory requirements and the design basis...for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures and instructions. Specifically, since August 1, 2001, the licensee failed to translate into procedures that a loss of normal feedwater flow event would be mitigated consistent with the licensees design basis assumptions. In response to this issue, the licensee initiated actions to establish interim emergency operating procedure directions for the licensed operators to ensure that credited safety-related equipment is used with priority in the event if this were to occur at the plant. The emergency operating procedure is being revised to ensure permanent corrective action is taken. This finding was entered into the licensee's corrective action program as Condition Report CR 16-1694. The team determined that the failure to establish measures to assure that the design bases was correctly translated into procedures and instructions was a performance deficiency. The performance deficiency was determined to be more than minor, and therefore a finding, because it was associated with the Mitigating Systems cornerstone attribute of procedure quality, and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. In addition, if left uncorrected, the performance deficiency would have the potential to lead to a more significant safety concern. Specifically, if the licensee used the procedure to mitigate a loss of normal feedwater flow event, the licensee may place the plant in an unanalyzed condition. In accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, Exhibit 2, Mitigating Systems Screening Questions, the issue screened as having very low safety significance (Green) because it was a design or qualification deficiency that did not represent a loss of operability or functionality. The team determined that this finding did not have a cross-cutting aspect because the most significant contributor did not reflect present licensee performance.
05000498/FIN-2016001-03Licensee-Identified Violation2016Q1Technical Specification 6.8.1.a. states, in part, written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, Appendix A, Section 9.a requires, in part, that maintenance that can affect the performance of safety-related equipment should be performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstance. The licensee established procedure 0PMP04-ZG-0022, Hills McCanna/Rockwell/Edwards Ball Valve Maintenance, Revision 24, to meet the Regulatory Guide 1.33 requirement for rebuilding chemical and volume control system (CVCS) mixed bed demineralizer drain valve CV-123A, a safety-related valve. Step 5.10 of this procedure directs stem seals to be installed during bonnet reassembly. Contrary to the above, on October 26, 2015, the licensee failed to follow Step 5.10 that directs stem seals to be installed during bonnet reassembly. Specifically, the stem seals were installed in the wrong locations and, on November 13, 2015, resulted in a 12-15 gpm RCS leak rate when the CVCS mixed bed demineralizer 1A was placed in service. A search for the leak determined that CV-123A was leaking by due to the lower stem seals being improperly installed. The licensee restored compliance by correctly rebuilding valve CV-123A, demineralizer 1A drain valve, in accordance with the approved procedure. The finding was of very low safety significance because the finding did not affect other systems used to mitigate a LOCA resulting in a loss of their function. This issue was entered into the licensees corrective action program as Condition Report 15-25192.
05000498/FIN-2016007-02Failure to Verify the Adequacy Calculations Associated with Direct Current Circuit Breakers2016Q1The team identified two examples of a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, which states, in part, the 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. Specifically, since March 22, 1988, the licensee failed to verify the adequacy of the molded case circuit breakers to perform their design basis function using appropriate time-current curves and tolerances or Class 1E 125 Vdc molded case circuit breakers to assure adequate trip response times, instantaneous trip accuracies, and rates of change of the sensed variable (the short circuit current). In response to this issue, the licensee determined that the 125 Vdc system would remain operable while implementing corrective actions to revise their design calculations to incorporate the appropriate time-current curves and current tolerances in design calculations. This violation was entered into licensees corrective action program as Condition Reports CR 16-2196 and CR 16-2117. The team determined that the failure to verify the adequacy of the design of Class 1E 125 Vdc molded case circuit breakers was a performance deficiency. The performance deficiency was determined to be more than minor, and therefore a finding, 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. Specifically, the failure to verify the adequacy of the molded case circuit breakers to perform their design basis function using appropriate time-current curves and tolerances adversely affected the capability of the 125 Vdc systems. Additionally, independent inspector calculations confirmed that the calculation errors resulted in a reasonable doubt on the operability of the 125 Vdc molded case circuit breakers. In accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, Exhibit 2, Mitigating Systems Screening Questions, the team determined the finding to be of very low safety significance (Green) because the finding was a deficiency affecting the design or qualification of a structure, system, or component, and the structure, system, or component maintained its operability or functionality. The team determined that this finding did not have a cross-cutting aspect because the most significant contributor did not reflect present licensee performance.
05000498/FIN-2016001-02Licensee-Identified Violation2016Q1Technical Specification 6.8.1.a states, in part, written procedures shall be established, implemented, and maintained covering applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Section 3.a of appendix A to Regulatory Guide 1.33, Revision 2, requires procedures for the startup, operation, and shutdown or the RCS, and Section 9.c requires procedures for repair or replacement of major equipment that is expected to be repaired or replaced during the life of the plant. Contrary to the above, the licensee failed to have procedures established for the operation of the RCS and for the repair of major equipment that is expected to be repaired during the life of the plant. Specifically, on November 2, 2015, without procedural guidance, the Unit 1 reactor coolant pump 1C was recoupled with the RCS at approximately 66 feet in the cavity. Coupling the pump to the motor in this condition introduced unfiltered RCS water into the seal cartridge area. On November 11, 2015, operations placed reactor coolant pump 1C into service and immediately noted a higher than normal leak off from the number 1 seal. Several attempts were made to adjust the seal and reduce the leakage, but on November 13, 2015, the decision was made to depressurize and cool down the RCS to repair the seal. The licensee discovered that foreign material from the unfiltered RCS had contaminated the seal. The licensee determined that this occurred during pump recoupling while at 66 feet in the reactor cavity. This finding has a very low safety significance (Green) because the finding did not result in an RCS leak rate that exceeded that of a small LOCA or have likely affected other systems that are used to mitigate a LOCA resulting in a total loss of their function. This issue was entered into the licensees corrective action program as Condition Report 15-24818.
05000498/FIN-2016001-01Failure to Identify and Correct Faulty NI-36 Channel2016Q1Inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, for the licensees failure to identify a condition adverse to quality. Specifically, the licensee failed to identify that a faulty logarithmic amplifier was producing inaccurate intermediate range nuclear instrument channel NI-36 indications. This resulted in multiple instances of delays in the change of state of reactor trip instrumentation permissive P-6 when shutting down the reactor. The licensee replaced NI-136s log current amplifier using approved procedures and returned the channel to service. This issue was entered into the corrective action program as Condition Report 16-1227. The licensees failure to identify a condition adverse to quality regarding intermediate range nuclear instrument channel NI-36 was a performance deficiency. Specifically, the licensee failed to identify a faulty log current amplifier in intermediate range nuclear instrument channel NI-36, which led to multiple instances of inaccurate indication and delays in the change of state of reactor trip instrumentation permissive P-6, when shutting down the reactor that required operator action and unplanned technical specification entries. This performance deficiency is more than minor and, therefore, a finding because it impacts the equipment 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. The inspectors screened this finding using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) For Findings At-Power, dated June 19, 2012. The finding screened as Green per Section A of Exhibit 2, Mitigating Systems Screening Questions, because the finding did not affect the design or qualification of a mitigating structure, system, or component; the finding did not represent a loss of the system and/or function; the finding did not represent an actual loss of function of at least a single train for greater than its Technical Specification allowed outage time; and the finding did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule for more than 24 hours. Inspectors determined the finding had a cross-cutting aspect of conservative bias in the human performance area because leaders did not take a conservative approach to decision making, particularly when information is incomplete or conditions are unusual. Specifically, the licensee made the decision not to enter their procedure for preventing recurring equipment problems process, even though entry criteria to do so was met, because of a false confidence that the correct cause had already been identified (H.14).
05000498/FIN-2016007-10Failure to Correct Procedure Deficiencies Allowing Cooling Restoration to RCP Seals2016Q1The team identified a Green, non-cited violation of Technical Specification 6.8.1.a., Procedures, which requires that written procedures shall be established, implemented, and maintained for procedures in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Procedures addressing combating emergencies involving loss of electric power are denoted in Appendix A, Section 6, Item c. Specifically, since July 2010, the licensee failed to maintain the loss of all alternating current power emergency procedure to ensure the procedure contained adequate direction to operators to mitigate a loss of reactor coolant pump seal cooling unique to the plants design. In response to this issue, the licensee initiated actions to consult with the plants design owners group to determine the best method of addressing this procedure vulnerability. Emergency operating procedure documentation and/or operator training will be revised based on owners group input. This issue was entered into the licensee's corrective action program as Condition Report CR 16-2126. The team determined that the failure to maintain procedures in accordance with accepted industry standards was a performance deficiency. The performance deficiency was determined to be more than minor, and therefore a finding, because it was associated with the Initiating Events cornerstone attribute of procedure quality, and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, operating procedures did not contain appropriate attributes to ensure timely action to prevent an increased likelihood of a reactor coolant pump seal loss of coolant accident following a station blackout. In addition, if left uncorrected, the performance deficiency would have the potential to lead to a more significant safety concern. Specifically, if the licensee used the procedure to mitigate a loss of all alternating current power event, the licensee may increase the risk of increased reactor coolant pump seal leakage, as well as potentially placing the safety-related component cooling water system in an unanalyzed condition. In accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, Exhibit 1, Initiating Events Screening Questions, the team determined a detailed risk evaluation was necessary because, after a reasonable assessment of degradation, the finding could result in exceeding the reactor coolant system leak rate for a small loss of coolant accident. Therefore, the senior reactor analyst performed a bounding detailed risk evaluation. The analyst determined that the change to the core damage frequency would be 1E-7 per year (Green). This finding had a cross-cutting aspect in the area of problem identification and resolution associated with evaluation because organizations failed to thoroughly evaluate issues to ensure that resolutions address causes and extent of condition commensurate with their safety significance. Specifically in 2014, the licensee received a non-cited violation associated with not having adequate procedures to address equipment malfunctions that caused a loss of reactor coolant pump seal cooling (Inspection Reports 05000498/2013007); however, the extent of condition review did not document any reviews of other procedures associated with reactor coolant pump seal cooling loss events to see if they allowed for seal cooling to be restored when seal temperatures were above 230 degrees F (P.2).
05000498/FIN-2016007-03Failure to Include Applicable Safety System Criteria in the Final Safety Analysis Report2016Q1The team identified a Severity Level IV, non-cited violation of 10 CFR 50.34(b)(2), Final Safety Analysis Report which requires, in part, that the final safety analysis report shall include a description and analysis of the structures, systems, and components of the facility, with emphasis upon performance requirements, the bases, with technical justification therefor, upon which such requirements have been established, and the evaluations required to show that safety functions will be accomplished. The description shall be sufficient to permit understanding of the system designs and their relationship to safety evaluations. Specifically, since March 22, 1988, the licensee failed to include, in the final safety analysis report, the safety system criteria specified by IEEE 603-1980 and IEEE 7.4-3-2 for the Eagle 21 control system, which described the facility, presented the design bases, and the limits on its operation. This violation does not represent an immediate safety concern. In response to this issue, the licensee created corrective actions to determine the appropriate information to include in the next update to the updated final safety analysis report. This violation was entered into the licensees corrective action program as Condition Report CR 16-1281. The team determined that the failure to revise the final safety analysis report with the supplemental information that presented the design bases of the qualified display processing system was a violation of 10 CFR 50.34(b)(2). The violation was more than minor because the design basis information affected certain safety system functions (i.e., the auxiliary feedwater system control valves), which had a material impact on safety. Because the issue affected the NRCs ability to perform its regulatory function, the inspectors evaluated this violation using the traditional enforcement process. The inspectors used the NRC Enforcement Policy, Subsection 6.1, Reactor Operations, dated February 4, 2015, to evaluate the significance of this violation. This violation is similar to example 6.1.d.3 in the Enforcement Policy. Therefore, this was a Severity Level IV violation because the violation represented a failure to update the final safety analysis report as required by 10 CFR 50.34(b)(2), but the lack of up-to-date information has not resulted in any unacceptable change to the facility or procedures. The team determined there was no cross-cutting aspect because cross-cutting aspects are not assigned to traditional enforcement violations.
05000498/FIN-2016007-05Failure to Control Software Tools Commensurate with the Importance to Safety2016Q1The team identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion XII, Control of Measuring and Test Equipment, which states, Measures shall be established to assure that tools, gages, instruments, and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specified periods to maintain accuracy within necessary limits. Specifically, since March 22, 1988, the licensee failed to establish measures to assure that the Class 1E Eagle 21 software tools and testing devices were properly controlled commensurate with their importance to the test and evaluation of the Class 1E integrated computer system, which ensures compliance with the functional, performance, and interface requirements of the system. In response to this issue, the licensee placed control of the tools and testing equipment under the nuclear quality assurance program. This violation was entered into the corrective action program as Condition Report CR 16-1985. The team determined that the failure to control software tools and testing devices used in activities affecting quality of the Class 1E Eagle 21 system was a performance deficiency. The performance deficiency was determined to be more than minor, and therefore a finding, because it would have the potential to lead to a more significant safety concern. Specifically, the failure to control the software tools and testing devices would lead to potential errors being introduced to these tools and the safety-related Eagle 21 system. In accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, Exhibit 2, Mitigating Systems Screening Questions, the team determined the finding to be of very low safety significance (Green) because the finding was a deficiency affecting the design or qualification of a structure, system, or component, and the structure, system, or component maintained its operability or functionality. The team determined that this finding did not have a cross-cutting aspect because the most significant contributor did not reflect present licensee performance.
05000498/FIN-2016007-08Failure to Ensure Sufficient Capacity and Capability of Mitigating Systems during a Station Blackout Event2016Q1The team identified a Green, non-cited violation of 10 CFR 50.63(a)(2) which states, in part, The reactor core and associated coolant, control, and protection systems, including station batteries and any other necessary support systems, must provide sufficient capacity and capability to ensure that the core is cooled and appropriate containment integrity is maintained in the event of a station blackout for the specified duration. Specifically, since September 12, 2013, the battery sizing and load profile calculations of the channel I (A train) direct current battery bus failed to include proper design data for expected loads and possible worst case load currents. In response to these issues, the licensee determined the battery bus was operable and the licensee initiated actions to analyze the effects of the change in calculation methodology, as well as to account for the additional loads. This finding was entered into the licensee's corrective action program as Condition Reports CR 16-1794, CR 16-2197, and CR 16-2236. The team determined that the failure to ensure the capacity and capability of protection systems to provide support for core cooling and containment integrity maintenance in the event of a station blackout was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the equipment 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. In addition, if left uncorrected, the performance deficiency would have the potential to lead to a more significant safety concern. Specifically, if the channel I emergency safety features direct current bus were required to support loads for the four hour coping period, the licensee may subject components used to ensure core cooling and containment integrity to conditions that were not assumed in their station blackout analysis. In accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At- Power, dated June 19, 2012, Exhibit 2, Mitigating Systems Screening Questions, the issue screened as having very low safety significance (Green) because it was a design or qualification deficiency that did not represent a loss of operability or functionality; did not represent an actual loss of safety function of the system or train; did not result in the loss of one or more trains of non-technical specification equipment; and did not screen as potentially risk significant due to seismic, flooding, or severe weather. This finding had a cross-cutting aspect in the area of human performance associated with procedure adherence because the licensee failed to follow process, procedures, and work instructions. Specifically, the licensee did not follow the calculation change process procedures to complete an impact review of pertinent licensing information associated with station blackout when the battery load assumptions were revised in the station blackout coping calculation (H.8).
05000498/FIN-2016007-01Failure to Perform Adequate Periodic Testing of Molded Case Circuit Breakers2016Q1The team identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, which states, in part, a test program shall assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. Specifically, since March 22, 1988, the licensee failed to assure that all testing required to demonstrate that the safety-related molded case circuit breakers would perform satisfactorily in service was performed in accordance with the acceptance limits contained in Institute of Electrical and Electronics Engineers (IEEE) 308-1974. In response to this issue, the licensee determined that the molded case circuit breakers will remain operable while implementing corrective actions to ensure the appropriate testing requirements of the molded case circuit breaker were included in the test programs. This violation was entered into the licensees corrective action program as Condition Report CR 16-2166. The team determined that the failure to detect deterioration and demonstrate operability of molded case circuit breakers through appropriate testing was a performance deficiency. The performance deficiency was determined to be more than minor, and therefore a finding, because it was associated with the equipment performance 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. Specifically, inadequate periodic testing to detect deterioration and to demonstrate continued operability was a significant programmatic deficiency that would adversely affect the reliability of Class 1E molded case circuit breakers to perform satisfactorily in service. In accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, Exhibit 2, Mitigating Systems Screening Questions, the team determined the finding to be of very low safety significance (Green) because the finding was a deficiency affecting the design or qualification of a structure, system, or component, and the structure, system, or component maintained its operability or functionality. This finding had a cross-cutting aspect in the area of human performance associated with consistent practices because the licensee did not use a consistent, systematic approach to make decisions. Specifically, the licensee did not use a consistent approach to determine which molded case circuit breakers would or would not be tested (H.13).
05000498/FIN-2016007-06Failure to Correct Conditions Adverse to Quality Associated with the Eagle 21 System2016Q1The team identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, which states, in part, Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. Specifically, since September 24, 2014, the licensee failed to establish measures to assure that deficiencies, deviations, defective material and equipment, and nonconformances that were responsible for malfunctions in the Class 1E Eagle 21 system were corrected. In response to this issue, the licensee performed an operability determination which determined the system was operable but in a degraded condition. This violation was entered into the licensees corrective action program as Condition Report CR 16-2220. The team determined that the failure to correct conditions adverse to quality in the Class 1E Eagle 21 system that were nonconformances with requirements was a performance deficiency. The performance deficiency was determined to be more than minor, and therefore a finding, because it was associated with the equipment performance 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. Specifically, the failure to correct conditions adverse to quality in the Class 1E Eagle 21 system adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of the protective action implemented by the qualified display processing system. In accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, Exhibit 2, Mitigating Systems Screening Questions, the issue screened as having very low safety significance (Green) because it was a design or qualification deficiency that did not represent a loss of operability or functionality; did not represent an actual loss of safety function of the system or train; did not result in the loss of one or more trains of non-technical specification equipment; and did not screen as potentially risk significant due to seismic, flooding, or severe weather. This finding had a cross-cutting aspect in the area of human performance associated with conservative bias because the licensee individuals failed to use decision making practices that emphasize prudent choices over those that are simply allowable (H.14).
05000498/FIN-2016007-07Failure to Implement Administrative Controls for a Nonconservative Technical Specification of Standby Diesel Generator Frequency Variation2016Q1The team identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions, which states, in part, Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. Specifically, since 1997, the licensee failed to correct a condition adverse to quality by imposing administrative controls in response to a nonconservative Technical Specification. In response to this issue, the licensee performed an operability determination regarding past performance on the auxiliary feedwater motor-driven pumps and concluded that they have always retained their safety function. This violation was entered into the licensees corrective action program as Condition Report CR 16-2176. The team determined that the failure to impose administrative limits in surveillance procedures to promptly correct a condition adverse to quality was a performance deficiency. The performance deficiency was determined to be more than minor, and therefore a finding, because it was associated with the equipment performance 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. Additionally, if left uncorrected, the performance deficiency would have the potential to become a more significant safety concern. Specifically, operation of the motor driven auxiliary feedwater pumps with a diesel generator frequency acceptance criteria of up to 2 percent would allow operation in a regime where the pumps would not perform their safety function when called upon. In accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, Exhibit 2, Mitigating Systems Screening Questions, the issue screened as having very low safety significance (Green) because it was a design or qualification deficiency that did not represent a loss of operability or functionality. This finding had a cross-cutting aspect in the area of human performance associated with change management because the licensee failed to use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority. Specifically, the licensee did not properly evaluate the need to take appropriate interim corrective actions before the appropriate guidance was endorsed (H.3).
05000498/FIN-2016007-04Failure to Perform Adequate On-going Class 1E Qualification for the Qualified Display Processing System2016Q1The team identified a Green, non-cited violation of 10 CFR 50.55a(h)(2) Protection Systems, which requires, in part, for nuclear power plants with construction permits issued after January 1, 1971, but before May 13, 1999, protection systems must meet the requirements in IEEE Std. 279-1971, Criteria for Protection Systems for Nuclear Power Generating Stations. Specifically, since approximately 1993, the licensee failed to demonstrate qualification of the Eagle 21 system, on a continuing basis, by appropriate methods for equipment whose qualified life is less than the design life of the system. This violation was entered into the licensees corrective action program as Condition Report CR 16-2214. The team determined that the failure to perform on-going qualification testing of installed Eagle 21 components whose qualified life was less than the design life was a performance deficiency. The performance deficiency was determined to be more than minor, and therefore a finding, because it was associated with the equipment performance 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. Specifically, inadequate on-going equipment qualification adversely affects the availability, reliability, and capability of Class 1E components to meet their safety functional requirements throughout their service lives. In accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, Exhibit 2, Mitigating Systems Screening Questions, the team determined the finding to be of very low safety significance (Green) because the finding was a deficiency affecting the design or qualification of a structure, system, or component, and the structure, system, or component maintained its operability or functionality. The team determined that this finding did not have a cross-cutting aspect because the most significant contributor did not reflect present licensee performance.
05000498/FIN-2015004-02Failure to Maintain the Emergency Plan Up to Date With the Safety Evaluation Report2015Q4The inspectors identified a non-cited violation of 10 CFR 50.54(q)(2) for failure to maintain the emergency plan in accordance with the approved safety evaluation report. Specifically, the licensee failed to meet 10 CFR 50.47(b)(2) requirements for timely augmentation of response capabilities, in accordance with the approved safety evaluation report. Following an update to the safety evaluation report in 1993, the licensee failed to update the emergency response organization staff augmentation time requirements to commence at the time of an emergency declaration vice from the time of an emergency notification. To restore compliance, the licensee updated the emergency plan in accordance with the current safety evaluation report. Failure to maintain the site emergency plan in accordance with the approved safety evaluation report, dated May 20, 1993, was a performance deficiency. Specifically, the licensee failed to update the ERO staff augmentation time requirements to commence at the time of an emergency declaration, as required by the NRC safety evaluation report. This performance deficiency is more than minor because it is associated with the procedure quality attribute of the Emergency Preparedness Cornerstone and adversely affected the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. This finding was evaluated using Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process (SDP), dated September 22, 2015, and was determined to be of very low safety significance (Green) per Table 5.2-1, Significance Examples 50.47(b)(2), because the staffing processes do not meet the threshold of routinely not capable of ensuring timely augmentation of the on shift emergency response staff to the extent that more than one required ERO functional area (in accordance with E-plan commitments) would not be filled. No cross-cutting aspect is assigned because the performance deficiency is not indicative of present performance.
05000498/FIN-2015004-01Failure to Track and Incorporate Actual Plant Data into Simulator Operability Testing2015Q4The inspectors identified a finding, associated with simulator operability testing, for the failure of the licensee to track and incorporate actual plant data into their cyclic operability tests, as required by American National Standards Institute-3.5-2009, Nuclear Power Plant Simulators for Use in Operator Training and Examination. With the exception of one transient, the licensee exclusively used engineering analysis from the RETRAN code as baseline data without reference to plant events that may have been related to the required transient tests. This issue was entered into the licensees corrective action program as Condition Report 15-21463. The failure to track and incorporate plant events into baseline data for simulator operability testing is a performance deficiency. It is more than minor and, therefore, a finding because it is associated with the human performance attribute of the Mitigating Systems Cornerstone and negatively affected the objective to ensure the reliability and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, if simulator performance is not being compared to the most relevant baseline data from the plant, the reliability of the simulator performance is reduced. Using Inspection Manual Chapter 0609, Significance Determination Process, Phase 1 worksheets, and the corresponding Appendix I, Licensed Operator Requalification SDP (block 14), the finding was determined to have very low safety significance (Green) because it is a Simulator testing, maintenance, or modification deficiency. This finding has a cross-cutting aspect in the procedure adherence component of the human performance cross-cutting area because the licensee failed to ensure that individuals follow processes, procedures, and work instructions in that the American National Standards Institute-3.5-2009 guidance for selecting baseline data for simulator testing was not followed.
05000498/FIN-2015404-02Licensee-Identified Violation2015Q3
05000498/FIN-2015404-01Security2015Q3
05000498/FIN-2015002-03Licensee-Identified Violation2015Q2Technical Specification 3.7.1.2, Auxiliary Feedwater System, requires, in part, that four independent steam generator AFW pumps and associated flow paths shall be operable with one steam turbine-driven AFW pump capable of being powered from an operable steam supply system. Action B of Technical Specification 3.7.1.2 allows the turbine-driven AFW pump to be inoperable for 72 hours or the requirements of the Configuration Risk Management Program must be applied. Contrary to the above, the turbine-driven AFW pump was inoperable for greater than 72 hours without application of the Configuration Risk Management Program. Specifically, the licensee failed to recognize that the turbine-driven AFW pump did not meet acceptance criteria for a surveillance performed on March 4, 2015. During a review of surveillance documentation on March 11, 2015, the licensee recognized that the pump had failed the surveillance and was inoperable until repairs could be completed. As a result, the pump was inoperable from March 4, 2015 to March 14, 2015, which exceeded the technical specification allowed outage time of 72 hours. This finding has very low safety significance (Green) because the finding did not lead to an actual loss of safety function of the system or cause a component to be inoperable. This issue was entered into the licensees corrective action program as Condition Report 2015-5477.
05000498/FIN-2015002-02Failure to Properly Dedicate Essential Chiller Purge Check Valves2015Q2The inspectors documented a self-revealing, non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the failure to have adequate measures for the selection and review for suitability of application of parts that are essential to the safety-related functions of structures, systems and components. Specifically, the licensee failed to properly inspect and test essential chiller condenser purge check valves during the stations commercial dedication process to ensure proper function in their safety-related application. The licensee has entered the issue into the corrective action program as Condition Report 15-4990 and has implemented corrective actions to the technical evaluation that will adequately measure and test the purge check valve in the future. The failure to properly inspect and test essential chiller condenser check valves during the stations commercial dedication process to ensure proper function in the safety-related application was a performance deficiency. This performance deficiency is more than minor because it adversely affected the equipment performance attribute of the Mitigating Systems Cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, on January 18, 2015, March 5, 2015, and March 21, 2015, the inadequately dedicated purge check valves resulted in a trip of the essential chiller, rendering the train inoperable and challenging plant operations. Using NRC Inspection Manual 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined the finding was of very low safety significance (Green) because it did not affect the design or qualification of the system, did not result in a loss of system function, did not represent a loss of function of a single train for greater than its technical specifications allowed outage time, and did not cause the loss of function of one or more non-technical specification trains of equipment designated as high safety-significance. The inspectors determined that the finding did not have a cross-cutting aspect because the main contributor to the cause of the performance deficiency occurred in 1993.
05000498/FIN-2015002-01Failure to Follow Hurricane Plan Procedure to Secure Missile Hazards During Tropical Storm Bill2015Q2Inspectors identified a non-cited violation of Technical Specification 6.8.1.a for failure to follow Procedure 0PGP03-ZV-0002, Hurricane Plan, Revision 7. Specifically, on June 15 through 16, 2015, the licensee failed to remove loose trash and materials inside the protected area to protect against potential missile hazards in accordance with Data Sheet 3 of Procedure 0PGP03-ZV-0002 in preparation for Tropical Storm Bill. The licensee has entered this issue into the corrective action program as Condition Report 15-17110. The failure of the licensee to address and control potential missile hazards on site, on the Unit 1 mechanical auxiliary building roof, turbine deck, and around standby transformer 1 was a performance deficiency. Specifically, on June 16, 2015, the licensee failed to follow Data Sheet 3 of Procedure 0PGP03-ZV-0002, Hurricane Plan, Revision 7, to adequately secure potential missile hazards in preparation for Tropical Storm Bill. The performance deficiency was determined to be more than minor because it was associated with the protection against external factor attribute and adversely affected the Initiating Event Cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during power operations. Using NRC Inspection Manual 0609, Appendix A, Exhibit 1, Initiating Events Screening Questions, the inspectors determined the finding was of very low safety significance (Green) because it did not cause 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. The inspectors determined the finding had a cross-cutting aspect in the area of problem identification and resolution associated with resolution. Specifically, the licensee failed to take effective corrective action from previous NRC-identified instances in the past where the licensee had loose material and debris that could become a missile hazards during a severe weather event (P.3).
05000498/FIN-2015201-02Security2015Q1
05000498/FIN-2015403-01Security2015Q1
05000498/FIN-2014408-01Licensee-Identified Violation2015Q1
05000498/FIN-2015201-01Security2015Q1
05000498/FIN-2015201-03Security2015Q1
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