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| Site | Quarter | Title | Description | |
|---|---|---|---|---|
| 05000298/FIN-2017002-03 | Cooper | 2017Q2 | Loss of Control Room Ventilation Due to Improper Switch Manipulation | The inspectors reviewed a self -revealed, non- cited violation of Technical Specification 5.4.1.a , for the licensees f ailure to implement System Operating Procedure 2.2.38, HVAC Control Building, Revision 43, during control building ventilation testing. Specifically, on December 7, 2016, when directed to turn off control building ventilation recirculation fan, RF- C-1A, operations personnel instead inadvertently turned off the operating control room emergency filtration system supply fan, 1 -SF -C-1A, resulting in the loss of the control room emergency filtration system function. Corrective actions to restore compliance included restoration of the control room emergency filtration supply fan and procedure changes to require peer checks for this surveillance test and similar 4 activities. The licensee entered this deficiency into the corrective action program as Condition Report CR -CNS -2016- 08744. The licensees failure to implement System Operating Procedure 2.2.38 , in violation of Technical Specification 5.4.1.a , was a performance deficiency. The performance deficiency was determined to be more than minor, and therefore a finding, because it was associated with the human performance attribute of the Barrier Integrity Cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers ( control room envelope) protect the public from radionuclide releases caused by accidents or events. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At -Power, dated June 19, 2012, the inspectors determined that the finding had very low safety significance (Green) because it did not represent a degradation of the barrier function of the control room against smoke or a toxic atmosphere. The finding had a cross -cutting aspect in the area of human performance associated with challenge the unknown, because the licensee did not stop when faced with uncertain conditions, and did not ensure that risks we re evaluated and managed before proceeding. Specifically, despite noting several a bnormalities with the switch being manipulated, operations personnel did not stop to evaluate the uncertain conditions nor did they evaluate the risks associated with proceeding (H.11). |
| 05000266/FIN-2017001-01 | Point Beach | 2017Q1 | Licensee-Identified Violation | The licensee identified a finding of very low safety significance (Green) and an NCV of TS 5.5.14, Safety Function Determination Program (SFDP), due to the failure to detect a loss of safety function and ensure appropriate actions were taken during maintenance activities conducted during performance of WO 40513133 for troubleshooting the check source drive mechanism for RE235, control room noble gas monitor, on January 18, 2017. In addition to the troubleshooting activities in WO 40513133, the licensee concurrently performed preventative maintenance on W14A, F16 control 32 room charcoal filter fan, and W13B2, control room recirculation fan. Due to these activities, the licensee implemented procedure NP 10.3.8, Safety Function Determination Program, to ensure that a loss of safety function was detected and the appropriate actions were taken for the equipment out of service associated with the CREFS. Specifically, NP 10.3.8, step 4.2.2 stated, Perform Loss of Safety Function Evaluation. Contrary to NP 10.3.8, step 4.2.2, an adequate loss of safety function evaluation was not performed for the CREFS system based on the equipment that was out of service. As a result of the inadequate loss of safety function evaluation, the licensee did not perform the Required Actions of TS limiting condition for operation (LCO) 3.7.9, Control Room Emergency Filtration System (CREFS), Condition C. The inadequate loss of safety function evaluation was identified when an operator wrote an action request that questioned condition of the CREFS during maintenance activities on January 18, 2017. TS 5.5.14, Safety Function Determination Program, required, in part, that if a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. Contrary to the above, on January 18, 2017, the licensee did not enter the appropriate Conditions and Required Actions of the LCO in which a loss of safety function existed. Specifically, the licensee did not adequately implement procedure NP 10.3.8, step 4.2.2, which resulted in the licensee not performing the Required Actions of TS LCO 3.7.9, Condition C. The licensee entered this issue into the CAP as AR 02183341. The inspectors determined that this issue was of very low safety significance (Green) after reviewing IMC 0609, Significance Determination Process, Attachment 0609.04, Initial Characterization of Findings, dated October 7, 2016 and IMC 0609, Appendix A, The Significance Determination Process (SDP) For Findings At-Power, dated July 1, 2012. The inspectors answered Yes to Question 1 in Exhibit 3, Section C, Control Room Auxiliary, Reactor, or Spent Fuel Pool Building. This resulted in the finding screening as Green. |
| 05000397/FIN-2014005-01 | Columbia | 2014Q4 | Licensee-Identified Violation | Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that measures shall be established for the selection and review for suitability of application o materials, parts, equipment, and processes that are essential to the safety-related functions of the structures, systems and components. Contrary to the above, from April 2010 to November 4, 2014, the licensee failed to establish measures to review the suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the structures, systems and components. Specifically, the licensee failed to review the suitability of parts for the safety related control room emergency filtration system resulting in non-qualified sealant and rivets used for the systems air handling units. The finding was of very low safety significance because the finding only represented a degradation of the radiological barrier function provided for the control room. This issue was entered into the licensees corrective action program as AR 316847, AR 317173 and AR 317184. |
| 05000298/FIN-2013004-01 | Cooper | 2013Q3 | Failure to Maintain Design Control of the Control Room Emergency Filter System Safety-related Air Operated Valve | The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, associated with the licensees failure to ensure the correct materials were installed in the control room emergency filtration system air operated valve HV-AO-272. Specifically, incompatible grease was introduced into the valve causing increased friction and degrading stroke times. The licensee entered this deficiency into their corrective action program for resolution as Condition Report CR-CNS-2013-04327. The failure to ensure the correct materials were installed in the control room emergency filtration system air operated valve HV-AO-272 was a performance deficiency. This performance deficiency was more than minor, and therefore a finding, because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone. Specifically, the licensee introduced an incompatible grease into HV-AO-272 causing increased friction and degrading stroke times, thereby affecting the associated objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors evaluated the finding using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) For Findings At-Power, and determined that the finding was of very low safety significance (Green) because the finding: (1) was not a deficiency affecting the design and qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time; and (4) did not represent an actual loss of function of one or more nontechnical specification trains of equipment designated as high safety-significance in accordance with the licensees maintenance rule program. The finding has a cross-cutting aspect in the area of human performance associated with work practices component because the licensee personnel failed to define and effectively communicate expectations regarding procedural compliance and to ensure that personnel followed procedures. |
| 05000336/FIN-2012004-01 | Millstone | 2012Q3 | Inadequate Post Maintenance Test Directions following Design Change to 3HVC FN1B | The inspectors identified an NCV of 10 CFR 50, Appendix B, Criteria V, Instructions, Procedures, and Drawings, of very low safety significance (Green) for Dominions failure to adequately specify post maintenance test (PMT) requirements for the control room ventilation exhaust fan 1B (3HVCFN1B) following replacement of the breaker starter on June 19, 2012. Specifically, Dominion did not provide sufficient direction to the operations staff in the control room regarding the correct retest procedure or acceptance criteria to complete an adequate PMT. As a result, 3HVCFN1B was retested and returned to an operable status despite the inability of this fan to respond to a control building isolation (CBI) actuation signal. Subsequently, on June 21, 2012, train B heating and ventilation control room (HVC) was declared inoperable after the HVC system failed routine surveillance test SP 3614F.1-002, Control Room Emergency Filtration System Operability Test. Dominion identified that the auxiliary contacts for the 42x relay had not been correctly installed in the breaker for 3HVCFN1B, which would have prevented the automatic starting of the fan during a CBI signal. The PMT acceptance criteria, specified in design change MP3-11-01065 and translated into work order 53102451547 had been met but were not adequate to retest the breaker. Dominion entered this issue into their CAP as CR 492783. The finding is more than minor because it affected the Design Control attribute of the control room ventilation boundary barrier for the Barrier Integrity cornerstone. Additionally, the performance deficiency was similar to example 5.b in Appendix E of Manual Chapter 0612, Examples of Minor Issues. In accordance with IMC 0609, Significant Determination Process, the inspectors performed a Phase 1 analysis and determined that the finding was of very low significance because the finding represented a degradation of the control room radiological barrier function but not degradation against smoke or toxic gas. This finding had a cross-cutting aspect in the Human Performance cross-cutting area, Resources component, because Dominion failed to maintain accurate and up to date procedures and work packages for PMTs following installation of the design change to replace the breaker for 3HVCFN1B. |
| 05000397/FIN-2012002-03 | Columbia | 2012Q1 | Failure to Validate Compensatory Measures During Maintenance | The inspectors identified a non-cited violation of Technical Specification 3.7.3, Control Room Emergency Filtration (CREF) System, for the licensees failure to provide adequate compensatory measures during maintenance on the control room emergency filtration system. Specifically, the licensee failed to validate that the compensatory measures used in Procedure PPM 1.3.57, Barrier Impairment, Revision 26, were adequate to limit dose to operators to within FSAR limits during maintenance on the control room emergency filtration system. The licensee issued a stop work order pending resolution of appropriate compensatory measures. The inspectors identified this issue during follow-up inspections of Action Request 256748 that documented transferring of dedicated individual duties during maintenance to unqualified individuals. This issue was entered into the licensees corrective action program as Action Request 256960. The failure to provided adequate compensatory measures during maintenance on the control room emergency filtration system was a performance deficiency. This finding was more than minor because it affected the procedure quality attribute of the Barrier Integrity Cornerstone objective of providing reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents. The inspectors used Inspection Manual Chapter 0609.04, Phase 1 Initial Screening and Characterization of Findings, and determined the finding was of very low safety significance (Green) since it only represented a degradation of the radiological barrier function provided for the control room. The inspectors determined that a cross-cutting issue was not applicable since the procedure that introduced the mitigating measures was first introduced in 2008 without verification that the mitigating measures were adequate and, therefore, not reflective of current plant performance |
| 05000424/FIN-2011004-02 | Vogtle | 2011Q3 | Loss of Both Trains of Control Room Emergency Filtration System (CREFS) Actuation Instrumentation | Technical Specification (TS) 3.3.7, Limiting Condition for Operation (LCO) Applicability, LCO 3.3.7 Condition P, requires that when four intake radiological gas monitor channels are inoperable, operators must place one CREFS train in each unit in the emergency mode within 1 hour. Contrary to the above, on September 22, 2011, the licensee discovered that AHV12153 was closed. This condition prevented air flow past all four radiological gas monitors rendering them inoperable. A review of the plant computer system showed that the valve was closed on September 19, at 2015. Thus for a period of approximately two and half days, Unit 1 & 2 were operated in a condition prohibited by TS 3.3.7, which is applicable in Modes 1, 2, 3 and 4. This finding is not greater than green using the IMC 609 Phase 1 worksheet due to the finding only representing a degradation of the radiological barrier function provided for the control room. The licensee has entered this issue into their corrective action program as CR 353533, completed a basic cause determination, drafted LER 05000424,425/2011-003, and immediately restored the valve to its proper position |
| 05000397/FIN-2010003-01 | Columbia | 2010Q2 | Failure to Translate Appropriate Acceptance Criteria | The inspectors reviewed a Green self-revealing noncited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings for Energy Northwests failure to include acceptance criteria appropriate to the circumstances in surveillance testing Procedure TSP-CREFZ801, Control Room Envelope Unfiltered In-leakage Tracer Gas Test, Revision 2. Specifically, Energy Northwest personnel incorrectly documented a design bases unfiltered air in-leakage value as an administrative limit in the surveillance testing procedure. This led to a delay in declaring the control room emergency filtration system inoperable and a delay in the implementation of mitigating actions to protect control room occupants in the event of an accident. The violation has been placed in the licensees corrective action program and corrective actions are being implemented. The performance deficiency is more than minor because it affects the procedure quality attribute of the Barrier Integrity Cornerstone for maintaining the radiological barrier functionality of the control room. This performance deficiency was of very low safety significance (Green) because the finding represented a degradation of only the radiological barrier function provided for the control room. Also, if left uncorrected, incorrectly documenting design bases acceptance criteria could lead to a more significant safety concern. Specifically, incorrectly documenting design bases acceptance criteria could lead personnel to rely on equipment to perform a specified safety function when it is incapable of doing so. This finding has a crosscutting aspect in the area of problem identification and resolution, self and independent assessments, in that the licensee failed to conduct self assessments that are of sufficient depth. Specifically, Energy Northwest focused too narrowly on the affect of licensing changes, in a 2007 self assessment, on the licensing organization instead of the impact of licensing changes to the organization as a whole |
| 05000354/FIN-2005004-04 | Hope Creek | 2005Q3 | Untimely License Event Report for the A' CREF Subsystem | The inspectors identified that PSEG did not submit a licensee event report to document the A control room emergency filtration system was inoperable for greater than seven days on two occasions in February 2005, a condition that is prohibited by Technical Specifications. The finding was determined to be a non-cited violation of 10 CFR 50.73, Licensee Event Report System. PSEGs corrective actions included reinforcing procedure requirements to screen equipment problems for reportability Traditional enforcement applies because a failure to report a safety event in a timely manner has the potential to impact the NRCs ability to perform its regulatory function. This finding was reviewed by NRC management because the finding was related to traditional enforcement. The review determined the finding to be a Severity Level IV violation consistent with Supplement I.D of the NRC Enforcement Policy. The finding is not suitable for Significance Determination Process evaluation because it did not have an actual impact on the initiating events, mitigating systems, or barrier integrity cornerstone. |