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| Start date | Site | Identified by | Title | Description | |
|---|---|---|---|---|---|
| 05000289/FIN-2014003-02 | 30 June 2014 23:59:59 | Three Mile Island | NRC identified | UFSAR Max Hypothetical Dose Not Updated, Consistent with Current Plant Conditions | The inspectors identified a Severity Level lV (SL-lV) NCV of 10 CFR 50.71(e), Maintenance of Records, Making of Reports, because TMI personnel did not update the Updated Final Safety Analysis Report (UFSAR) with information consistent with plant conditions. Specifically, TMI personnel did not remove reference to or correct information in UFSAR Section 14.2.2.3.4.a, Environmental Analysis of Loss of Coolant Accidents - Consequences of LOCA Radioactive Releases to the Environment, to reflect current plant conditions with regard to maximum hypothetical accident doses at the main control room, exclusion area boundary, or low population zone. Exelon documented this in issue report 1662515 to address the UFSAR discrepancy. This issue was determined to be within the traditional enforcement process because it had the potential to impede or impact the NRC's ability to perform its regulatory functions. Specifically, the issue was determined to have a material impact on licensed activities and was considered more than minor using section 7.3.D of the NRC Enforcement Manual. Using example d.3 of section 6.1 of the NRC Enforcement Policy, the inspectors determined that the violation was a SL-IV violation because the erroneous information was not used to make an unacceptable change to the facility or procedure. In accordance with inspection manual chapter 0612, section 07.03c, this traditional enforcement violation was not assigned a cross-cutting aspect. |
| 05000289/FIN-2012012-01 | 31 December 2012 23:59:59 | Three Mile Island | NRC identified | Failure to provide complete and accurate decommissioning status reports | During an NRC investigation completed on November 22, 2011, and a supplemental investigation completed on October 10, 2012, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below: 10 CFR 50.75(a) establishes requirements for indicating to the NRC how a licensee will provide reasonable assurance that funds will be available for the decommissioning process and states that for power reactor licensees, reasonable assurance consists of a series of steps as provided in paragraphs (b), (c), (e), and (f) of 10 CFR 50.75. 10 CFR 50.75(f)(2) states, in part, that power reactor licensees shall report at least every 2 years on the status of its decommissioning funding for each reactor or part of a reactor that it owns; and, that the information in this report must include, at a minimum, the amount of decommissioning funds estimated to be required pursuant to 10 CFR 50.75(b) and (c). 10 CFR 50.75(b)(1) states, in part, that for a holder of an operating license under 10 CFR Part 50, financial assurance for decommissioning shall be provided in an amount which may be more, but not less, than the amount stated in the table in paragraph (c)(1) adjusted using a rate at least equal to that stated in paragraph (c)(2). 10 CFR 50.75(c)(1) states the minimum amount required to demonstrate reasonable assurance of funds for decommissioning by reactor type and power level. 10 CFR 50.75(c)(2) requires, in part, that an adjustment factor be applied, which is based on escalation factors for labor and energy, and waste burial. 10 CFR 50.9(a) states, in part, that information provided to the Commission by a licensee shall be complete and accurate in all material respects. Contrary to the above, on March 31, 2005, March 31, 2006, March 31, 2007, and March 31,2009, Exelon Generation Company, LLC (Exelon) provided information on the status of its decommissioning funding that was not complete and accurate in all material respects, when it submitted the decommissioning funding status (DFS) reports pursuant to 10 CFR 50.75. Specifically, the March 31, 2005, March 31, 2007, March 31, 2006, and March 31, 2009, DFS reports stated that the decommissioning funds estimated to be required for each of the reactors, as listed in the report, were determined in accordance with 10 CFR 50.75(b) and the applicable formulas of 10 CFR 50.75(c). However, in multiple instances, the amount reported was a discounted value that was less than the minimum required amount specified by 10 CFR 50.75(b) and (c). This is a Severity Level IV violation. |
| 05000289/FIN-2011010-01 | 30 September 2011 23:59:59 | Three Mile Island | NRC identified | Security | OI Investigation/ unescorted access authorization/ 10 CFR 50.7 |
| 05000289/FIN-2011503-01 | 30 September 2011 23:59:59 | Three Mile Island | NRC identified | (Traditional Enforcement) Changes to EAL Basis Decreased the Effectiveness of the Plan without Prior NRC Approval | The inspector identified a finding of very low safety significance involving a Severity Level IV NCV of 10 CFR 50.54(q) for failing to obtain prior approval for an emergency plan change which decreased the effectiveness of the plan. Specifically, the licensee modified the Emergency Action Level (EAL) Basis in EAL HU6, which indefinitely extended the start of the 15-minute emergency classification clock beyond a credible notification that a fire is occurring or indication of a valid fire detection system alarm. This change decreased the effectiveness of the emergency plan by reducing the capability to perform a risk significant planning function in a timely manner. The violation affected the NRC\\\'s ability to perform its regulatory function because it involved implementing a change that decreased the effectiveness of the emergency plan without NRC approval. Therefore, this issue was evaluated using Traditional Enforcement. The NRC determined that a Severity Level IV violation was appropriate due to the reduction of the capability to perform a risk significant planning standard function in a timely manner. The licensee entered this issue into its corrective action program and revised the EAL basis to restore compliance. The finding was more than minor using IMC 0612, because it is associated with the emergency preparedness cornerstone attribute of procedure quality for EAL and emergency plan changes, and it adversely affected the cornerstone objective of ensuring 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. Therefore, the performance deficiency was a finding. Using IMC 0609, Appendix B, the inspector determined that the finding had a very low safety significance because the finding is a failure to comply with 10 CFR 50.54(q) involving the risk significant planning standard 50.47(b)(4), which, in this case, met the example of a Green finding because it involved one Unusual Event classification |
| 05000289/FIN-2009006-02 | 30 June 2009 23:59:59 | Three Mile Island | NRC identified | Inadequate Decay Heat River Water Equipment | The team identified a Severity Level IV NCV of 10 CFR 50.59, Changes, Tests and Experiments, for the failure to obtain a license amendment pursuant to 10 CFR 50.90 prior to implementing a change to the components credited to be operable for the decay heat river system. The team reviewed a modification and associated safety evaluation that removed the internals of the decay heat river water strainer. Exelons 10 CFR 50.59 safety evaluation credited the operation of three nonsafety- related traveling screens to perform this strainers safety functions in order to allow the change to the facility without a license amendment. The team determined that because the screens were not safety-related structures, systems, or components, they could not be used to meet the system operability requirements as discussed in Technical Specification 3.3 Emergency Core Cooling, Reactor Building Emergency Cooling and Reactor Building Spray Systems. Use of these components would require a change to the TS, and, therefore, the 10 CFR 50.59 process screening should have determined the process cannot be used. Following identification of the issue Exelon performed an operability evaluation to ensure the system could respond to credited design basis events and performed an apparent cause evaluation to determine the cause of the performance deficiency. The failure to submit this change prevented the NRC from performing its regulatory function and the issue was evaluated under traditional enforcement guidance. The team determined that this issue was more than minor because there was a likelihood that the activity would have required NRC approval prior to implementation. The severity level of the violation was determined to be Severity Level IV because there was no willful aspect and the finding was determined to be of very low safety significance. The finding was determined to have a crosscutting aspect in Human Performance- Decision Making which states the licensee should use conservative assumptions in decision making and adopts a requirement to demonstrate that the proposed action is safe. (H.1(b)) |
| 05000289/FIN-2005009-03 | 31 December 2005 23:59:59 | Three Mile Island | NRC identified | Failure to Report Medical Conditions for Three Licensed Operators | The inspectors identified a Green (Severity Level IV) noncited violation of 10 CFR 50.74 for failure to report changes in medical conditions per Section 3.2.1 of Exelon administrative procedure OP-AA-105-101, Administrative Process For NRC License And Medical Requirements, Rev. 8. As a result, potentially disqualifying medical conditions for three operators were not reported to the NRC within the required 30-day time frame. In addition, for one of the operators, the medical condition ultimately required a change on his license. The licensee promptly entered this issue into their corrective action program (issue reports 164042, 189592, and 195798). This violation is more than minor because it had the potential to impact the NRCs ability to perform its regulatory function, and it was evaluated using the traditional enforcement process. This finding is of very low safety significance because at no time did the individual stand watch without the medical condition being satisfied. In addition, the facility licensee was timely in their reporting of the medical conditions to the NRC when they received the pertinent information. The cause of the finding is related to the cross-cutting area of corrective actions, because it occurred after completion of actions to address a previous NCV for the failure to notify NRC of change in medical status of licensed operators. The cause of the finding is also related to the cross-cutting area of human performance, because multiple station operators did not comply with established procedures for reporting of potentially disqualifying medical conditions. |
| 05000289/FIN-2004005-01 | 31 December 2004 23:59:59 | Three Mile Island | NRC identified | Plant Modification Decreased Effectiveness of Emergency Plan Without Prior NRC Approval, Deficient 10 CFR 50.54(Q) Evaluation | A non-cited violation of 10 CFR 50.54(q) was identified for not properly maintaining the TMI Radiological Emergency Plan (the Plan) up-to-date to address a modification made within the owner controlled area. Specifically, plant modifications which blocked the south gate access bridge resulted in a decrease in effectiveness in the Plan without prior NRC approval. Corrective actions included discussions with the local railroad company to establish a memorandum of understanding, establishment of a shift night order, training for emergency directors, reassessment of south gate accessibility, and entry of the issue into the licensee's corrective action program as issue reports 260849, 260697, 266937, 269032, 282239 and 282851 A contributing cause of this finding is related to the cross-cutting area of problem identification and resolution, because (1) the 10 CFR 50.54(q) evaluation did not identify the potential that a train (or crossing gate) malfunction could occur and cause delays in accessing or leaving the site, despite several such occurrences; (2) evaluation of the issue following three train (or crossing gate) malfunctions in October 2004 was cursory in that it did not take positive actions to verify contingency actions were identified, understood, and trained upon; and (3) substantive corrective actions such as establishing a memorandum of understanding with the railroad and establishing written guidance shift manager/emergency director guidance for this contingency were not developed until repeatedly questioned by the inspectors. This finding was of very low safety significance, because it did not constitute a loss of a planning standard function required by 10 CFR 50.47(b)(2) or (b)(3). |
| 05000289/FIN-2004005-03 | 31 December 2004 23:59:59 | Three Mile Island | NRC identified | Untimely Licensee Event Report for Both Trains of High Pressure Injection Being Inoperable | A non-cited violation of 10 CFR 50.73 was identified for untimely submittal of a licensee event report (LER). In March 2004, station personnel had all necessary information available to identify that both trains of high pressure injection (HPI) had been inoperable for a brief period in 2003. The issue was not reported until December 2004, following identification by the inspectors. A contributing cause of this finding is a shortcoming in problem identification in the cross-cutting area of PI&R in that station personnel did not consider unavailability of the emergency power supply to the second HPI train and associated technical specification requirements when determining reportability of this condition. Additionally, the original operability determination did not correctly address seismic qualification of HPI support systems until identified by the inspectors. Corrective actions included submittal of the condition report, training for station personnel, and entering the issue into the corrective action program as issue report 267630. |