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05000382/FIN-2018001-0131 March 2018 23:59:59WaterfordNRC identifiedFailure to Obtain NRC Staff Authorization Prior to Changing a Procedure that Impacts Implementation of Technical SpecificationsThe inspectors identified a Severity Level IV, non-cited violation of 10CFR50.59, Changes, Tests, and Experiments, Section (c)(1), for the licensees failure to submit and obtain authorization prior to implementation procedures described in the Final Safety Analysis Report
05000382/FIN-2017008-0331 December 2017 23:59:59WaterfordNRC identifiedTwo Examples of Failure to Submit and Receive Prior Authorization of Alternatives to ASME OM Code Leak Testing RequirementsThe team identified two examples of a Severity Level IV, non-cited violation of 10 CFR 50.55a(z), for failure to submit and obtain authorization prior to implementation of multiple alternatives to leak testing requirements of the American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) of Nuclear Power Plants Code. Specifically, prior to November 16, 2017, the licensee did not submit and receive prior authorization to alternative leak testing requirements for safety injection valves SI-512A and SI-602B.
05000382/FIN-2017010-0130 September 2017 23:59:59WaterfordNRC identifiedFailure to Evaluate Departures from Approved Methodologies for Reactor Vessel FluenceThe inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.59, Changes, Tests, and Experiments, Section (c)(1), which states, in part, that a licensee may make changes in the facility as described in the updated safety analysis report without obtaining a license amendment pursuant to 10 CFR 50.90 only if: (i) a change to the technical specifications incorporated in the license is not required, and (ii) the change, test, or experiment does not meet any of the criteria in paragraph (c)(2). Title 10 CFR 50.59, Section (c)(2)(viii), states, in part, that a licensee shall obtain a license amendment pursuant to Section 50.90 prior to implementing a proposed change, test, or experiment if the change, test, or experiment would result in a departure from a method of evaluation described in the updated safety analysis report used in establishing the design bases or in the safety analyses. Specifically, since January 2017, the licensee revised updated final safety analysis report Section 4.3.3.3 to reflect RAPTOR-M3G as the current licensing basis fluence method without first obtaining a license amendment. This finding was entered into the licensees corrective action program as Condition Report CR-WF3-2017-04748. The inspectors determined that the failure to evaluate proposed changes to determine if prior NRC review was required in accordance with 10 CFR 50.59 was a performance deficiency. Using NRC Inspection Manual Chapter 0612, Appendix B, Issue Screening, the inspectors determined that this performance deficiency had minor safety significance. In accordance with the NRC Enforcement Manual, violations of 10 CFR 50.59 are not processed through the Reactor Oversight Process significance determination process because this violation potentially impacted the ability of the NRC to perform its regulatory oversight function. Therefore, this violation was processed through traditional enforcement examples of Section 6.1 of the NRC Enforcement Policy. This violation was more than minor because there was a reasonable likelihood that the change would require NRC review and approval prior to implementation, similar to the more than minor example of a change in requirements in the NRC Enforcement Manual, Appendix E, Minor Violations Examples, dated September 9, 2013. Since the violation was associated with a performance deficiency of minor significance, the traditional enforcement violation was determined to be a Severity Level IV violation, consistent with the example in paragraph 6.1.d(2) of the NRC Enforcement Policy.
05000382/FIN-2016008-0431 December 2016 23:59:59WaterfordNRC identifiedDeparture from Approved Method to Determine Steam Generator Internal Loads During Main Steam Line BreakThe team identified a Severity Level IV non-cited violation of 10 CFR 50.59(c)(2),Changes, Tests, and Experiments, for the licensees failure to obtain a license amendment prior to implementing a proposed change, test, or experiment that would result in a departure from a method of evaluation described in the final safety analysis report (as updated) used in establishing the design bases or in the safety analyses. Specifically, the licensee departed from their approved CEFLASH-4A methodology to determine steam generator internal differential loads caused by a main steam line break to an unapproved TRANFLOW methodology. In response to this issue, the licensee entered the issue into the corrective action program as Condition Report CR-WF3-2016-07639 and initiated actions to prepare a new evaluation under current regulatory guidelines or to submit a license amendment request to the NRC.The licensees failure to obtain a license amendment prior to implementing a change that resulted in a departure from a method of evaluation described in the final safety analysis report (as updated) used in establishing the design bases or in the safety analyses, as required by 10 CFR 50.59(c)(2) was a violation. In accordance with the NRC Enforcement Manual, violations of 10 CFR 50.59 are not processed through the Reactor Oversight Process significance determination process because this violation potentially impacted the ability of the NRC to perform its regulatory oversight function. Therefore, this violation was processed through traditional enforcement examples of Section 6.1 of the NRC Enforcement Policy. This violation was more-than-minor because there was a reasonable likelihood that the change would require NRC review and approval prior to implementation, similar to the more-than-minor example of a change in requirements in the NRC Enforcement Manual,Appendix E, Minor Violations Examples, dated September 9, 2013. In accordance with the NRC Enforcement Policy, the significance determination process was used to inform the significance of the failure to obtain a license amendment prior to implementing a proposed change. The departure from the original CEFLASH-4A method to the TRANFLOW method to determine differential loads on steam generator internal structures following a main steam line break event was associated with the design control attribute of the Barrier Integrity Cornerstone and adversely affected the objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. 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 issue screened as having very low safety significance (Green) because the issue would not result in the complete or partial loss of a support system that contributes to the likelihood of an initiating event, or result in the steam generators violating accident leakage performance criterion. Since the violation was determined to be Green in the significance determination process, the traditional enforcement violation was determined to be a Severity Level IV violation, consistent with the example in paragraph 6.1.d(2) of the NRC Enforcement Policy. Traditional enforcement violations are not assessed for cross-cutting aspects.
05000382/FIN-2015407-0131 March 2016 23:59:59WaterfordNRC identifiedSecurity
05000382/FIN-2015407-0231 March 2016 23:59:59WaterfordNRC identifiedSecurity
05000382/FIN-2014011-0131 December 2014 23:59:59WaterfordLicensee-identifiedLicensee-Identified ViolationTitle 10 CFR 50.73, Licensee event report system, requires, in part, that a license shall submit a licensee event report (LER) within 60 days after the discovery of a reportable event. Contrary to the above, on July 21, 2013, the licensee failed to submit an LER within 60 days after the discovery of a reportable event. Specifically, the licensee failed to submit an LER within 60 days of the discovery of the inoperable train B EDG due to the exhaust fan failure, which was a reportable event that was discovered on May 22, 2013. On August 21, 2013, the licensee identified the failure to submit the LER within 60 days after the discovery of the event and entered the issue into the corrective action program as Condition Report CR-WF3-2013-4025. The LER was submitted by the licensee on September 11, 2013. The inspector determined that traditional enforcement is applicable to this violation since it is a violation that impacted the regulatory process. The inspector determined that this is a Severity Level IV violation in accordance with the NRC Enforcement Policy, Section 6.9.d.9.
05000382/FIN-2013004-0130 September 2013 23:59:59WaterfordNRC identifiedFailure to Make a Report Required by 10 CFR 21.21The team identified a violation of 10 CFR 21.21 that occurred when the licensee failed to submit a report or interim report on a deviation in a basic component within 60 days of discovery. The failure of the licensee to adequately evaluate deviations in basic components and to report defects is a performance deficiency. The NRCs significance determination process (SDP) considers the safety significance of findings by evaluating their potential safety consequences. This performance deficiency was of minor safety significance. The traditional enforcement process separately considers the significance of willful violations, violations that impact the regulatory process, and violations that result in actual safety consequences. Traditional enforcement applied to this finding because it involved a violation that impacted the regulatory process. Supplement VII to the version of the NRC Enforcement Policy that was in effect at the time the violation was identified provided as an example of a violation of significant regulatory concern (Severity Level III), An inadequate review or failure to review such that, if an appropriate review had been made as required, a 10 CFR Part 21 report would have been made. Based on this example, the NRC determined that the violation met the criteria to be cited as a Severity Level III violation. However, because of the circumstances surrounding the violation, including the removal from service of the affected components by an unrelated manufacturers recall, the severity of the cited violation is being reduced to Severity Level IV. Cross-cutting aspects are not assigned to traditional enforcement violations.
05000382/FIN-2013004-0430 September 2013 23:59:59WaterfordLicensee-identifiedLicensee-Identified ViolationTitle 10 CFR, Part 55.9, Completeness and Accuracy of Information, requires that information provided to the Commission by an applicant for a license or by a licensee ... shall be complete and accurate in all material respects. Contrary to the above, on September 13, 2012, an NRC Form 396, Certification of Medical Examination by Facility Licensee, was submitted to the NRC for a licensed operator applicant with inaccurate information. Specifically, a restriction for corrective lenses was omitted, even though the applicants medical exam stated that the individual required corrective lenses. An operating license was granted by the NRC to the individual without a corrective lens restriction. The error was identified during the operators subsequent annual medical examination in July 2013, after which the operator reported to licensing that an additional restriction was being placed on his license though his vision had not changed. The licensee confirmed that the operator had not performed any licensed duties and a revised NRC Form 396 was submitted to Region IV on July 29, 2013. The licensee documented the deficiency in Condition Report 2013-03181. The submission of inaccurate information to the NRC is a violation. The violation was evaluated using the traditional enforcement process because it impacted the NRCs ability to perform its regulatory function. The violation was determined to be Severity Level IV because it fits the example of Enforcement Policy Section 6. 4.d.1(d), Violation Examples: Licensed Reactor Operators. This section states, SL IV violations involve, for example ... an individual operator who met ANSI/ANS 3.4, Section 5, as certified on NRC Form 396, required by Title 10, Part CFR 55.23, but failed to report a condition that would have required a license restriction to establish or maintain medical qualification based on having the undisclosed medical condition. In this case, the individual operator did report the condition to the licensee, but the licensee failed to include that information in its original license application to the NRC.
05000382/FIN-2013007-0130 September 2013 23:59:59WaterfordNRC identifiedWillful Violation of Documentation ProceduresThis letter refers to an investigation initiated by the U. S. Nuclear Regulatory Commissions (NRC) Office of Investigations (OI) in March 2012 at Waterford Steam Electric Station, Unit 3 (Waterford 3). The purpose of the investigation was to determine whether an individual employed as an electrical contractor at Waterford 3 falsified procedure paperwork. As a result of the investigation, the NRC confirmed that, contrary to the following, the former electrical contractor willfully falsified procedure paperwork by signing a work package with the initials of another person. Contrary to the above, on November 16, 2010, a contract employee willfully signed work package 224179, Task 6, Documentation of Cable Installation for Cable number 3SSPP82, step 4.3.5, Sections 10.1.8, 10.2.19, and 10.3.1 (one example) with the initials of another person, for work that he did not perform and did not state that he was signing for the other person. The former electrical contractors falsifications were discovered by your staff through an internal investigation in November 2011. However, the NRC considered the violation to have been more significant than minor, because it involved willfulness, and therefore, the NRC has classified the violation at Severity Level IV, in accordance with the Enforcement Policy. The NRC considered issuance of a Notice of Violation (NOV) for this issue. However, the NRC credits the identification of the issue to the licensee. As stated in the Enforcement Manual, Section 6.6.5.B, and in accordance with the Enforcement Policy, the NRC may disposition a licensee-identified Severity Level IV willful violation involving a low level individual as a Non-Cited Violation (NCV).
05000382/FIN-2013003-0430 June 2013 23:59:59WaterfordNRC identifiedFailure to submit an LER after discovery that manual handwheels on AOVs were not functionalThe inspectors identified a non-cited violation of 10 CFR 50.73(a)(1) because the licensee did not submit a Licensee Event Report (LER) in a timely manner after the discovery of a reportable event. Specifically, the licensee failed to submit a required LER within 60 days after the discovery of a condition that affected the manual hand-wheel operation of safety related air operated valves following a loss of their corresponding back-up nitrogen accumulators. The licensee determined that the manual hand-wheel function on the essential chiller and emergency feedwater isolation and backup flow control valves did not work. The licensee was aware of the condition that existed but did not adequately evaluate the condition as a part of their reportability review. The licensee entered this issue into their corrective action program as CR-WF3-2013-2564. The immediate corrective actions taken to restore compliance included a new reportability review of the condition and the development of an LER. The failure to submit a required LER within 60 days after discovery of a condition that required a report was a violation of NRC requirements. The inspectors determined that this violation was also a performance deficiency. However, the inspectors determined that the performance deficiency was minor. The inspectors considered this issue to be within the traditional enforcement process because it had the potential to impact the NRC\'s ability to perform its regulatory oversight function. The inspectors used the NRC Enforcement Policy to evaluate the significance of this violation. The inspectors determined that the violation was a Severity Level IV because it was similar to an example provided in Section 6.9 of the NRC Enforcement Policy. The inspectors did not assign a cross-cutting aspect to this non-cited violation because there was no finding associated with this traditional enforcement violation.
05000382/FIN-2013003-0230 June 2013 23:59:59WaterfordNRC identifiedFailure to Update Fuel Handling Accident Analysis in the Updated Final Safety Analysis ReportThe inspectors identified a Severity Level IV non-cited violation for the licensees failure to update the final (updated) safety analysis report in accordance with 10 CFR 50.71(e). Specifically, from July 1981 to April 18, 2013, the licensee failed to update the methodology, the data input, and the resulting limits for the fuel bundle drop accident analysis in the Waterford Steam Electric Station, Unit 3, Updated Final Safety Analysis Report (UFSAR), Section 15.7.3.4, Design Basis Fuel Handling Accidents. This violation was entered into the licensees corrective action program as Condition Report CR-WF3-2013-0193. The failure to update the methodology, the data input to the calculation, and the resulting limits for the fuel bundle drop accident analysis in Section 15.7.3.4 of the UFSAR in accordance with 10 CFR 50.71(e) is a performance deficiency. This performance deficiency was evaluated using traditional enforcement because it has the potential to impact the NRCs ability to perform its regulatory function. The inspectors used the NRC Enforcement Policy to evaluate the significance of this violation. Consistent with the NRC Enforcement Policy, the inspectors determined that the performance deficiency is a Severity Level IV non-cited violation. This noncited violation had no cross-cutting aspect because there was no finding associated with this traditional enforcement violation.
05000382/FIN-2011005-0331 December 2011 23:59:59WaterfordNRC identifiedFailure to Periodically Update the Updated Final Safety Analysis ReportThe inspectors identified a non-cited violation of 10 CFR 50.71 Maintenance of Records, because the licensee failed to update their updated final safety analysis report with submittals that include a change made to the facility. Specifically, the licensee built the low level radwaste storage facility in 1995 on the owner controlled area for interim radwaste storage of dry and solidified radioactive waste and failed to update the updated final safety analysis report to include these changes. This issue was entered in the licensees corrective action program as condition report WF3-2011-07711. This issue was dispositioned using traditional enforcement because it had the potential for impacting the NRCs ability to perform its regulatory function. The finding is more than minor because it has a material impact on licensed activities in that stored radwaste materials with a significant radioactive source term has been relocated from the plant radiologically controlled area to the owner controlled area. In addition, the radwaste management program has been affected because the licensee was not originally licensed to act as a low level waste facility. However, the termination of the Barnwell Low Level Radioactive Waste Management facility has forced the licensee to build such a storage area and make changes to the facility, significantly increasing the onsite storage capacity. The inspectors determined that this finding did not reflect present performance because it is an issue with changes made to the facility more than 15 years previously. Therefore, there was no cross-cutting aspect associated with this finding. This finding is characterized as a Severity Level IV non-cited violation in accordance with NRC Enforcement Policy, Section 6.1, and was treated as a non-cited violation consistent with Section 2.3.2.a of the NRC Enforcement Policy
05000382/FIN-2011004-0830 September 2011 23:59:59WaterfordNRC identifiedFailure to Submit a LER within 60 days after Discovery of an EventThe inspectors identified a non-cited violation of 10 CFR 50.73(a)(1) because the licensee did not submit required Licensee Event Reports (LERs) within 60 days after discovery of conditions that required a report. Specifically, the inspectors identified three instances of untimely LERs submittals for conditions related to an inoperable emergency feedwater pump, a single point vulnerability of spent fuel pool pumps, and a degraded fuel oil supply line for the Train A emergency diesel generator. The licensee submitted the reports at 332,163, and 101 days after discovery of the conditions, respectively. As a result, the licensee exceeded the 60 days for each condition that required a report. The inspectors noted that this is also contrary to the licensees reportability procedure UNT-006-010, Event Notification and Reporting. The licensee entered this issue into their corrective action program for resolution as CR-WF3-2010-5923. The immediate corrective actions include the performance of a human performance error review. The inspectors considered this issue to be within the traditional enforcement process because it has the potential to impede or impact the NRC\'s ability to perform its regulatory function. The inspectors used the NRC Enforcement Policy to evaluate the significance of this violation. The inspectors concluded that the violation is more than minor because it occurred repeatedly within a two year period and the licensee missed opportunities to identify the issue. The NRC relies on the licensee to identify and report conditions or events meeting the criteria specified in regulations in order to perform its regulatory function, and when this is not done, this impacts the NRCs ability to carry out its statutory mission. The finding has a cross-cutting aspect in the work practices component of the human performance area because the licensee did not define and effectively communicate expectations regarding procedural compliance
05000382/FIN-2011003-0230 June 2011 23:59:59WaterfordNRC identifiedFailure to Update the FSAR following Modifications to the Reactor Coolant Pump Vapor SealsThe inspectors identified a Severity Level IV noncited violation of 10 CFR 50.71(e) because the licensee did not revise the Final Safety Analysis Report (FSAR), as updated, with information consistent with plant conditions. Specifically, the licensee did not update Section 5.4.1.3 of the FSAR for Waterford Steam Electric Station, Unit 3, following modifications to the reactor coolant pump vapor seals in 2007 and 2009, respectively. As a result, the licensee did not promptly identify and correct FSAR noncompliance. The licensee entered this issue into their corrective action program for resolution as CR-WF3-2010-7421. The planned corrective actions include revising the FSAR, as updated, and replacing the degraded reactor coolant pump seals during the next two refueling outages. The inspectors considered this issue to be within the traditional enforcement process because it has the potential to impede or impact the NRC\'s ability to perform its regulatory function. The inspectors used the NRC Enforcement Policy to evaluate the significance of this violation. The inspectors concluded that the violation was more than minor because the longstanding and incorrect information in the FSAR, as updated, had a material impact on safety and licensed activities. The material impact was that the modifications to the reactor coolant pump vapor seals, created the conditions for a reactor coolant pump seal loss of coolant accident inside containment, which could have potentially impacted licensed activities. The inspectors determined the violation was a Severity Level IV (very low safety significance) since the information that was not updated in the FSAR, was not used to make an unacceptable change to the facility nor did it impact a licensing or safety decision by the NRC. The inspectors determined there was a cross-cutting aspect in the corrective action component of the problem identification and resolution area. Specifically, the licensee did not thoroughly evaluate and take adequate actions in a timely manner to update the FSAR to be consistent with plant conditions.
05000382/FIN-2005004-0330 September 2005 23:59:59WaterfordNRC identifiedChange to a Method of Evaluation Without Prior NRC ApprovalThe inspectors identified a Severity Level IV noncited violation of 10 CFR 50.59 for the failure to obtain NRC approval prior to implementing a change to the facility that resulted in a departure from a method of evaluation described in the final safety analysis report used in establishing the design bases. Specifically, the licensee implemented a change that assumed the unprotected dry cooling towers would not be impacted during a tornado event. This change was implemented based on the inappropriate use of a Tornado Missile Risk Evaluation method of evaluation not previously approved by the NRC. The licensee implemented this change to compensate for a licensee identified analysis error that adversely affected the ultimate heat sink capability following a tornado event. The licensee entered this deficiency into their corrective action program for resolution. The cause of this finding is related to the crosscutting element of human performance The finding is greater than minor in that it affected the mitigating systems cornerstone attribute of equipment availability and function during a design bases tornado event. Regional and NRR staff determined that the change made by the licensee resulted in a departure from a method of evaluation described in the final safety analysis report used in establishing the design bases and that the change would require NRC approval under 10 CFR 50.59 guidance. In accordance with the NRC Enforcement Manual, violations of 10 CFR 50.59 are not processed directly through the significance determination process. Therefore, this issue was considered applicable as traditional enforcement. Although the significance determination process is not designed to assess significance of violations that potentially impact or impede the regulatory process, the technical result or condition of a 10 CFR 50.59 violation can be assessed through the significance determination process. The inspectors and the Region IV reactor analyst discussed the significance of this finding. A significance Determination Process Phase 1 screening was performed and the finding was determined to have very low safety significance because there was no actual loss of mitigating system safety function per Generic Letter 91-18 guidance.