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05000482/FIN-2018002-02Wolf Creek2018Q2Failure to Maintain Adequate Pressurization of the Control Room EnvelopeA self-revealed Green NCV of 10 CFR Part 50, Criterion III, Design Control, was identified when the licensee failed to adequately recognize that the cable spreading room floor was a control building ventilation isolation boundary. Specifically, the licensee cut openings in the floor/ceiling between the 2,032 foot and 2,016 foot elevations of the control building and the impact on the control room envelopes ability to pressurize was not recognized. This was a primary contributor to the train B control room emergency ventilation system being unable to maintain the appropriate pressure in the control room envelope.
05000324/FIN-2018001-01Brunswick2018Q1Inadequate Instruction to Perform Inspections on Emergency Ventilation DampersA self-revealing Green NCV of TS 5.4.1a, Procedures, was identified when the licensee failed to properly provide adequate work instructions associated with the control room emergency damper inspections. Specifically, the licensee disconnected the damper air supply line without adequate work instruction guidance, which caused a loss of Control Building Heating, Ventilation and Air Conditioning (HVAC) and Control Room Emergency Ventilation (CREV) Systems resulting in a safety system functional failure.
05000255/FIN-2017004-01Palisades2017Q4Improperly Connected M&TE Leads to Unexpected AFU Fan TripA finding of very low safety significance and an associated NCV of Title 10 of the Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was self-revealed when the licensee failed to follow step 5.4.4.b of Technical Specification surveillance procedure RT85DA, Control Room Emergency Ventilation Filtration Testing A Train. Specifically, the licensee failed to properly connect maintenance and test equipment (M&TE) across flow transmitter test taps which caused V26A, the air filter unit (AFU) VF26A fan, to stop 17 seconds after operators started the fan from the control room. The licensee entered this issue into their Corrective Action Program (CAP) as condition report (CR) CRPLP201705234. Corrective actions included coaching the vendor on ensuring M&TE is properly connected to plant equipment and ensuring suitable field oversight of the vendor during re-performance of the surveillance.The issue was determined to be more than minor in accordance with IMC 0612, Appendix B, Issue Screening, because it was associated with the Barrier Integrity cornerstone attribute of Human Performance and adversely affected the cornerstone objective of providing reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. The finding screened as having very low safety significance (Green) in accordance with IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, Exhibit 3, because the inspectors answered "No" to all screening questions. The finding had across-cutting aspect in the area of Human Performance, in the Field Presence aspect, for the failure to ensure supervisory and management oversight of work activities, including contractors and supplemental personnel (H.2).
05000333/FIN-2017002-01FitzPatrick2017Q2A Control Room Ventilation Subsystems Inoperable Longer than Allowed by Technical SpecificationsGreen. A self-revealing Green NCV of Technical Specification (TS) 3.7.3, Control Room Emergency Ventilation Air Supply (CREVAS) System, and TS 3.7.4, Control Room Air Conditioning (AC) System, was identified for the failure to declare one subsystem of the control room AC and CREVAS systems inoperable. Specifically, on August 16, 2016, control room operators failed to declare the A CREVAS and A control room AC subsystems inoperable due to a degraded damper actuator. As a result, the A CREVAS and A control room AC subsystems were inoperable from August 16, 2016, until a compensatory measure to assist the dam per linkage by hand as needed was implemented on September 19, 2016, which exceeded the TS allowed outage time. On October 4, 2016, FitzPatrick personnel replaced the actuator. This issue was entered into the corrective action program (CAP) as JAF-CR-2016-3593. The performance deficiency is more than minor because it is associated with the structure, system, and component (SSC) and barrier performance attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective of providing reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, this resulted in the A control room AC and A CREVAS subsystems being inoperable from August 16, 2016, to September 19, 2016, and the exceedance of the allowable TS out-of-service times. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 3 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) because the performance deficiency did not represent a degradation of the radiological barrier function provided for the control room, and the finding did not represent a degradation of the barrier function of the control room against smoke or a toxic atmosphere (i.e. the B train of both subsystems remained operable). This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Evaluation, because FitzPatrick personnel failed to thoroughly evaluate the problem such that resolution addressed the cause. Specifically, FitzPatrick failed to fully evaluate the degraded condition during troubleshooting following the failed post-maintenance test (PMT) on August 16, 2016. Thorough testing and evaluation of the degraded actuator would have led to the identification of the need for replacement to restore the damper and its actuator to fully operable status. (P.2)
05000334/FIN-2016001-01Beaver Valley2016Q1Failure to Properly Evaluate Control Room Envelope Test ResultsThe inspectors identified an NCV of Title 10 of the Code of Federal Regulations (CFR), Part 50, Appendix B, Criterion XI, Test Control, for FENOCs failure to properly evaluate the test results of the Control Room Envelope (CRE) unfiltered air in-leakage test performed in December 2015. Specifically, the test results exceeded the acceptance criteria specified in the test procedure and required further engineering evaluation to determine if the control room emergency ventilation system (CREVS) could meet its specified safety function. The inspectors identified that the engineering evaluation of the test results did not account for all of the in-leakage and resulted in a reasonable doubt of operability of CREVS. FENOCs immediate corrective action was to re-evaluate the December 2015 calculation and verify that CREVS remained operable with the increased in-leakage. FENOC entered the issue into their corrective action program, condition report (CR) 2016-03836. The performance deficiency is more-than-minor because it is associated with the human performance attribute of the Barrier Integrity cornerstone, and adversely affected the cornerstone objective of providing reasonable assurance that physical design barriers protect from radionuclide releases caused by accidents or events. Specifically, FENOCs evaluation did not account for in-leakage from the non-tested portions of the control room radiological barrier, and therefore, did not provide reasonable assurance that the control room dose would not exceed five rem during an uncontrolled release of radioactivity. Additionally, this issue is similar to example 3j and 3k of IMC 0612 Appendix E, Examples of Minor Issues, in that FENOCs December 2015 engineering evaluation failed to adequately account for CRE in-leakage and resulted in a reasonable doubt of the operability of CREVS. The inspectors determined that this finding was of very low safety significance (Green) because it only represented a degradation of the radiological barrier function provided for the control room. This finding has a cross-cutting aspect in the area of Human Performance, Conservative Bias, because FENOC did not take a conservative approach to decision making, particularly when the in-leakage information was incomplete (H.14).
05000254/FIN-2016001-02Quad Cities2016Q1Failure to Identify Structures, Systems, and Components as Safety-RelatedA finding of very low safety significance and an associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion II, Quality Assurance, was identified by the inspectors for the licensees failure to identify the structures, systems, and components to be covered by the quality assurance program, in that they did not properly classify a component of the control room emergency ventilation system as safety-related. The licensee documented the issue in their corrective action program under Issue Report 2596725. Immediate corrective actions included replacing Differential Pressure Switch (DPS) 0579550 and revising the control room ventilation procedure to allow operators to disable the interlock between the A and B trains of the control room emergency ventilation system. The procedure change eliminated the need for the DPS to be classified as safety-related (and therefore corrected the violation) because in the event of a failure of the DPS, the system would still be able to perform its safety function. The performance deficiency was determined to be more than minor and a finding because it was associated with the Barrier Integrity Cornerstone attribute of Design Control and affected the cornerstone objective of providing reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the B train of the control room emergency ventilation system is a habitability system that is provided to ensure control room operators are able to remain in the control room and operate the plant safely and to maintain the plant in a safe condition under accident conditions. The inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, Significance Determination Process, Appendix A, The Significance Determination Process for Findings at Power, issued June 19, 2012. The inspectors determined the finding to be of very low safety significance (Green) in accordance with Exhibit 3, Barrier Integrity Screening Questions, because the finding only represented a degradation of the radiological barrier function provided for the control room and did not represent a degradation of the barrier function of the control room against smoke or toxic atmosphere. This finding did not have a cross-cutting aspect because the performance deficiency was not indicative of current performance.
05000220/FIN-2016001-03Nine Mile Point2016Q1Inadequate Tagout Resulting in Reactor Building Closed-Loop Cooling Drain Down EventA self-revealing Green non-cited violation (NCV) of Technical Specification (TS) 6.4.1, Procedures, was identified when a Unit 1 Exelon operator did not maintain proper configuration control of a plant system during a system tagout for planned maintenance. Specifically, on January 25, 2016, a Unit 1 non-licensed operator manipulated a reactor building closed-loop cooling (RBCLC) system drain valve out of sequence while performing a tagout for the #13 shutdown cooling (SDC) HX for planned maintenance. This resulted in unintentional draining of the operating RBCLC system, annunciation of multiple alarms in the main control room, and operators entering abnormal operating procedures to recover the RBCLC system. As part of corrective actions, proper configuration was promptly restored and the operator involved in the event was given a remediation plan for requalification and placed on an operations excellence plan. This finding is more than minor because it is associated with the configuration control attribute of the Mitigating Systems cornerstone and adversely affected the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences; and if left uncorrected, the event had potential to lead to a more significant safety concern. Specifically, the failure to quickly isolate the drain down of the RBCLC system would have required a manual reactor scram, a manual trip of all five reactor recirculation pumps (RRPs), a manual isolation of the reactor water cleanup system, a loss of cooling to the spent fuel pool (SFP) cooling system, instrument air compressors, and the control room emergency ventilation system. The inspectors evaluated the finding using IMC 0609.04, Initial Characterization of Findings, and Exhibit 1 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power. The inspectors determined that this finding was of very low safety significance (Green) because the performance deficiency did not result in the loss of a support system, RBCLC, or affect mitigation equipment. This finding has a cross-cutting aspect in the area of Human Performance, Procedure Adherence, because the non-licensed operator failed to follow Exelons procedures and the instructions he received at the pre job brief stop when manipulating the drain valve. Specifically, the non-licensed operator rationalized, without being the designated performer of the tagout, that it was acceptable to perform a valve manipulation out of sequence with the tagout plan.
05000254/FIN-2015003-01Quad Cities2015Q3Failure to Evaluate Degraded or Non-Conforming Conditions for OperabilityA finding of very low safety significance and an associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified by the inspectors for the licensees failure to document degraded or non-conforming conditions in the corrective action program (CAP) and route or discuss the issue with Operations shift management so that operability of the affected components could be evaluated. Immediate corrective actions included entering the issues into the CAP and evaluating the issues for operability. The licensee captured the issue in the CAP as Issue Reports (IRs) 2537968 and 2537936. The finding was determined to be more than minor because, if left uncorrected, it could become a more significant safety concern. Specifically, the failure to identify degraded, non-conforming, or unanalyzed conditions in the CAP and bring those conditions to the attention of Operations shift management so that the operability of safety-related systems, structures, and components (SSCs) may be evaluated could lead to those SSCs being in an inoperable condition without the appropriate Technical Specification (TS) actions taken. The inspectors concluded this finding was associated with the Mitigating Systems Cornerstone. The finding was determined to be of very low safety significance because the control room emergency ventilation (CREV) and high pressure coolant injection (HPCI) systems remained operable. This finding had a cross-cutting aspect of identification in the area of problem identification and resolution because the licensee did not identify issues completely, accurately, and in a timely manner in accordance with the program. Specifically, when degraded and non-conforming conditions were identified, licensee personnel failed to promptly capture the issues in the CAP (P.1).
05000317/FIN-2014003-04Calvert Cliffs2014Q2Licensee-Identified ViolationTS 3.7.8, Control Room Emergency Ventilation System (CREVS), requires two CREVS trains operable during modes 1, 2, 3, 4, and during movement of irradiated fuel assemblies. With one CREVS train inoperable due to excessive bypass flow, TS 3.7.8, Condition E, is required to be entered. The required action is to restore CREVS train to operable status within seven days. This action was not completed within the required completion time because the issue was discovered after the required completion time had expired. Contrary to the above, one train of CREVS was inoperable from September 22, 2013, through October 3, 2014, due to the 12 PLFF discharge damper failure in its partially open position. As a result, Exelon operated in a condition prohibited by TS for approximately 4 days. Exelon entered this issue into their CAP as CR-2013-007736. In accordance with IMC 0609.04, Initial Characterization of Findings, and IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings at Power, Exhibit 3, Barrier Integrity Screening Questions, the inspectors determined that this finding is of very low safety significance (Green) because the finding only represented a degradation of the radiological barrier function provided for the control room.
05000220/FIN-2013005-01Nine Mile Point2013Q4Failure to Perform Surveillance Test for Unit 1 Smoke Removal DampersThe inspectors identified a Green NCV of Unit 1 license condition DPR-63, Section 2.D(7), Fire Protection, because CENG staff did not perform visual inspections of fire dampers associated with Unit 1 between 2002 and 2013 in accordance with the Fire Protection Program and Updated Final Safety Analysis Report (UFSAR) Section 10A.2.4.1.10.1.A. As a result, CENG staff determined 25 dampers were non-functional due to the surveillance test not being performed. CENG staffs planned corrective actions include revising the UFSAR to state that performance-based testing requirements apply only to non-smoke removal dampers. Further, the 25 smoke removal dampers will remain nonfunctional until visual inspections can be performed as planned in work order (WO) C92482273. This issue was entered into CENGs CAP as CR-2013-009208. This finding is more than minor because it is associated with the structure, system, and component (SSC) and barrier performance attribute of the Barrier Integrity cornerstone and affected the cornerstone objective of providing reasonable assurance that physical design barriers protect the operators in the control room from radionuclide releases caused by accidents or events. The finding was evaluated in accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 3 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, and the inspectors determined that this finding is of very low safety significance (Green) because the performance deficiency only represented a degradation of the smoke removal and radiological barrier function provided for the control room. This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, because CENG staff failed to identify smoke removal damper visual inspections were not being performed. Specifically, UFSAR section 10A.2.4.1.10.1.A, as part of license condition DPR-63 2.D(7) and the Fire Protection Program, requires CENG staff to perform visual inspections of smoke removal dampers, which was not being performed between 2002 and 2013, resulting in the control room envelope not being operable and 25 smoke removal dampers being declared non-functional. CENG performed an evaluation to determine if the control room habitability requirements contained in TS 3.4.5.f for the control envelope were met. CENG staff subsequently determined that Unit 1 control room habitability requirements of TS 3.4.5.f were met based on previous successful surveillance testing for control room operability testing under N1-ST-C9, Control Room Emergency Ventilation System Testing, Revision 01502.
05000483/FIN-2013004-02Callaway2013Q3Licensee-Identified ViolationTechnical Specification 3.7.10, Control Room Emergency Ventilation System (CREVS), requires that two control room emergency ventilation system trains shall be operable in Modes 1, 2, 3, and 4 and during movement of irradiated fuel assemblies. Contrary to the above, on April 18, 2013, with the plant in Mode 6 for Refueling Outage 19, Callaway workers impaired the control building envelope, causing the control room emergency ventilation system to be rendered inoperable while a fuel assembly was in movement in the fuel handling building. Specifically, licensee workers blocked open door DSK32013, breaching the control building ventilation system envelope, to run temporary power cables to the train B battery chargers. The inspectors evaluated the finding in accordance with Inspection Manual Chapter 0609, Appendix G, Shutdown Operations Significance Determination Process. The inspectors determined that the finding was of very low safety significance (Green) because it did not require a quantitative assessment as determined in Appendix G, Attachment 1, Checklist 4, PWR Refueling Operation: RCS level > 23\'OR PWR Shutdown Operation with Time to Boil > 2 hours And Inventory in the Pressurizer. Corrective actions included coaching of operations and planning staff on the correct modes of applicability for Technical Specification 3.7.10 and enhancing procedures and forms to evaluate the technical specification appropriately. This violation was entered into the licensees corrective action program as Callaway Action Request 201302882.
05000335/FIN-2013003-03Saint Lucie2013Q2Licensee-Identified ViolationDuring plant operation in Modes 1 through 4, Unit 1 TS 3.7.7 limiting condition of operation (LCO) for the control room emergency ventilation system (CREVS) requires two air conditioning units. Unit 2 TS 3.7.7.1, LCO for the control room emergency air cleanup system (CREACS) requires two independent CREACS be operable with at least one air conditioning unit per system. Both units technical specifications allow continued operation with only one air conditioning unit operable as long as the second air conditioning unit is restored to operability within seven days. Otherwise, the unit must be placed in hot standby within the next six hours. For Modes 5 and 6 or during movement of irradiated fuel assemblies, Unit 1 TS requires that with only one air conditioning unit operable, restore at least two air conditioning units to operable status within seven days or suspend movement of irradiated fuel assemblies. Unit 2 TS requires immediate operation of the remaining operable CREACS in the recirculation mode or immediately suspend movement of irradiated fuel assemblies. Contrary to the above, since initial plant startup, design errors associated with the control circuitry for both units control room air conditioning systems resulted in plant operation with less than two operable control room air conditioning systems for greater than the time allowed by TS. If initially in service, both units swing air conditioning unit (3C) would not have automatically restarted after a postulated loss of offsite power (LOOP). Due to heat loading, the Unit 2 CREACS typically operated with only one air conditioning unit in service with another in standby. The licensee determined that the standby air conditioning unit would not have started after a LOOP no matter which train was in standby. A review of Unit 1 control room logs showed that the 3C swing CREVS was last in operation with this design error on August 22, 2012 for a period of approximately 14 days which exceeded the TS LCO. Since initial Unit 2 startup, the TS LCO was not met with just one air conditioning unit in service. The performance deficiency described above was more than minor because it was associated with the barrier performance attribute of the barrier integrity cornerstone objective and challenged the ability of the control room air conditioning systems to automatically perform their radiological barrier design function after a LOOP coincident with a design basis accident. The inspectors used IMC 0609, Attachment 4 and Appendix A and G, and determined the finding was of very low safety significance or Green, because (1) the finding only represented a degradation of the barrier function provided for the control room (Appendix A, Exhibit 3) and (2) the finding did not impact any equipment necessary to maintain the unit in a safe shutdown condition (Appendix G). This finding has been entered into the licensees CAP as AR 1796780. Additional information regarding this finding is documented in Section 4OA3.2 of this report.
05000324/FIN-2013003-03Brunswick2013Q2Inadequate Work Order to Perform a Modification to the Control Room Emergency Ventilation SystemAn NRC-identified Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified, for the licensees failure to have an adequate instruction or procedure to perform a modification to the control room emergency ventilation system (CREV). The licensee took immediate action to return CREV to service and entered this issue into the CAP as NCR 578363. The inspectors determined that the failure of the licensee to have an adequate procedure for installing a jumper on the 2A CREV system was a performance deficiency. The finding was more than minor because it was associated with the configuration control attribute of the Barrier Integrity Cornerstone and affects the cornerstone objective to provide reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and containment) protect the public from radionuclide releases caused by accidents or events. Specifically, the failure to have an adequate procedure to install a jumper on the 2A CREV system resulted in the safety system functional failure of CREV. Using IMC 0609, Appendix A, issued June 19, 2012, the SDP for Findings At- Power, the inspectors determined the finding screened to a detailed risk evaluation because the finding represented a degradation of the radiological barrier function and smoke or toxic atmosphere function of the control room barrier. The regional SRA performed a Phase 3 analysis on the finding. A screening calculation was performed to estimate the impact the finding would have on the facility for conditions that would lead to plant shutdown, or failure of the filtering function of the ventilation system. The low likelihood of failure to recover the system, combined with the short time the deficiency existed, resulted in a finding of very low safety significance (Green). The finding has a cross-cutting aspect in the area of human performance associated with the work control attribute because the licensee did not appropriately coordinate work activities by incorporating the impact of changes to the work scope or activity on the plant when installing a ring lug jumper on the 2A CREV subsystem.
05000220/FIN-2012005-02Nine Mile Point2012Q4Inadequate Post Maintenance Test Results in Subsequent Failure of 11 CREVS FanA self-revealing Green NCV of TS 6.4.1 occurred because NMPNS failed to develop an adequate post maintenance test (PMT) to determine operability of the 11 control room emergency ventilation system. Specifically, troubleshooting on December 2 failed to identify a cause of the failure and an inadequate PMT was performed to determine operability. As a result the degraded system was returned to service even though it did not meet all the requirements for operability. The limiting condition for operation (LCO) was exited incorrectly, and the issue was not identified and resolved until subsequent surveillance testing. Following subsequent surveillance testing, the degraded circuit was repaired and a successful PMT was performed. The issue was entered into NMPNS CAP as CR-2012- 011027. This finding is more than minor because it adversely affected the structure, system, and component (SSC) and barrier performance attribute of the Barrier Integrity Cornerstone and affected the cornerstone objective of providing reasonable assurance that physical design barriers protect the operators in the control room from radionuclide releases caused by accidents or events. The finding was evaluated in accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 3 of IMC 0609, Appendix A. The inspectors determined that this finding is of very low safety significance (Green) because the performance deficiency only represented a degradation of the radiological barrier function provided for the control room. This finding has a cross-cutting aspect in the area of problem identification and resolution, because NMPNS failed to thoroughly evaluate the problem such that the resolution addressed the cause. Specifically, if NMPNS would have identified the cause of the problem and performed an adequate PMT, the system would not have been restored with a degraded condition
05000397/FIN-2012005-01Columbia2012Q4Failure to Provide Maintenance Procedures for Control Room Emergency Ventilation System DampersThe inspectors reviewed a self-revealing non-cited violation of Technical Specification 5.4.1.a, Procedures, for failure to provide suitable work instructions for maintenance on control room emergency ventilation system dampers. On November 11, 2011, operations received an unexpected annunciator indicating that control room emergency filtration damper WMA-AD-51A was bound in an intermediate position. Subsequent review determined that the linkages were misaligned on February 21-22, 2007, which subjected the swivels to excessive spring forces causing them to slip over a period of time. The inspectors reviewed the maintenance task outline in Work Order 01126994 and identified that the work instructions did not have appropriate steps to ensure the alignment of linkages associated with damper WMA-AD-51A. The licensee entered this issue into the corrective action program as Action Request 252200. This performance deficiency was more than minor because it adversely affected the procedure quality attribute of the Barrier Integrity Cornerstone objective to ensure that physical design barriers 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, the inspectors determined the finding was of very low safety significance because the finding only represented a degradation of the radiological barrier provided for by the control room. The inspectors determined that this finding did not have a cross-cutting aspect since the cause of the inadequate maintenance procedures was due to a performance deficiency that occurred in 2007, and therefore was not reflective of current licensee performance.
05000483/FIN-2012005-03Callaway2012Q4Determine Licensing Basis and Capability of One Vital Air Conditioning Unit to Cool Both Trains of Class 1EThe inspectors identified an unresolved item involving the licensing basis and cooling capability of the safety-related air conditioning units and the ability to cool both trains of safety-related switchgear, batteries, battery chargers, and inverters with a single train of cooling. On December 5, 2012, the inspectors identified an issue with the licensees plan to cope with / mitigate an inoperable vital switchgear Class 1E air conditioning unit. This system has two trains, each comprised of a chiller, fans and ductwork to cool the rooms containing its associated safety-related switchgear, battery, battery charger, and inverters. This system and its cooling function are not explicitly covered by technical specifications, while the supported systems are covered by technical specifications. In 2004, in an attempt to address the fact that these cooling trains are not covered by technical specifications, and therefore have no allowed outage time, the licensee created Final Safety Analysis Report Administrative Technical Specification 16.7.13. This specification states that if one of the trains of cooling is inoperable, the ESF switchgear and vital batteries/chargers may be considered operable for up to 7 days provided the following conditions are met: (1) all doors between trains are open; (2) safety-related transformers XNN05 and XNN06 for 120VAC are de-energized; (3) thermostats on the operable cooling unit are set below 80F; and (4) at least one Class 1E air conditioning unit is operable and capable of operating at full capacity. As described in Callaway Action Request 201009024, if one train of cooling were inoperable, operators would declare the associated switchgear, battery, charger, and inverters inoperable and enter associated technical specification action statements, then implement/verify the compensatory measures, then exit the action statements for up to 7 days. The inspectors questioned the technical basis for how the equipment that was cooled by this air conditioning unit would be able to function without cooling. Specifically, the inspectors questioned the adequacy of the single unit to cool both trains. On December 6, 2012, while the licensee was reviewing the inspectors concerns, they identified that heat load calculations GK-10, DC SWBD, Battery and ESF SWGR Room Temperatures with One 1E A/C Unit Inoperable, and GK-22, Eval. Inverter Loads, 92-1014, did not account for both trains of control building pressurization heaters being energized. This increases the heat load assumed in the calculation and required additional compensatory actions beyond the Final Safety Analysis Report 16.7.13 actions. The licensee revised a standing order to direct operations to secure the control room emergency ventilation system associated with the affected Class 1E air conditioning unit. This is achieved by placing three fans in pull-to-lock when using one cooling train to cool both electrical trains. The licensee initiated Callaway Action Request 201208550 to address this issue. The inspectors have the following concerns: (1) Callaway relies on compensatory measures to open all doors between trains of batteries and switchgear, posting fire watches, and de-energizing plant equipment (which is safety-related). The inspectors questioned the appropriateness and cooling capability of these measures, which were used as a basis for assuring the operability of the supported safety-related systems. Specifically: a. the temporary air flow paths did not appear to ensure adequate air flow between trains b. portions of the temporary air flow path went through a corridor that was not cooled, allowing unaccounted-for heat, as well as loss of cooled air, since there was no way to efficiently move all the cooled air to the other trains room with a corridor between the individual train rooms c. one safety-related control room ventilation system is rendered inoperable by implementing the compensatory measures d. the heat loads and cooling capacity were not adequately accounted for (see below) (2) The licensees creation of Final Safety Analysis Report Administrative Technical Specification 16.7.13, appeared to conflict with existing technical specifications that covered the situation. Specifically, cooling was required to support the safety functions of the associated safety-related batteries, battery chargers, inverters, and switchgear. The definition of operable in technical specifications stated that for a system to be considered operable, all necessary cooling systems must also be capable of performing their related support functions. Part 9900 guidance for assessing operability further states that, in order to be considered operable, structures, systems and components must be capable of performing the safety functions specified by its design within the range of specified physical conditions, which would include room temperature, and accident loading Creating a Final Safety Analysis Report specification and limiting condition for operation allowing the support system to be out of service would not alleviate the need to consider the impact to the operability of the supported systems. (3) The inspectors found that the electrical equipment heat load evaluated in calculation GK-10 did not appear to adequately account for all heat sources, and may not have provided an adequate technical basis for credited heat removal. a. Sensible and latent heat added to the switchgear rooms by outside air from the control building pressurization fans were not included in calculations. During accidents, the control building pressurization fans add outside air to raise the pressure in the control building to minimize in-leakage, but would add sensible and latent heat that was not included in heat removal calculations. b. The DC switchgear and battery rooms are located directly above the AC switchgear rooms. An assumption for the DC switchgear and battery rooms stated that heat will be removed through the floor, while another assumption for the AC switchgear room stated that heat will be removed through the ceiling. (4) The inspectors questioned whether both trains of supported equipment would satisfy the design and licensing basis of the plant with a single train of cooling. Specifically, loss of the single operable cooling train would lead to failure of both trains of supported equipment such that the plant would no longer be able to withstand a single failure without prior NRC approval. The inspectors noted that the licensee has actually implemented the compensatory measures described above and declared the supported systems operable by relying on one train of cooling, including December 17- 18, 2012, when train A chiller had a refrigerant leak and again on December 22, 2012, through January 5, 2013, when train B chiller had a refrigerant leak. The above concerns must be addressed before an evaluation of the combined effect of these concerns can be performed. In response, the licensee created Callaway Action Request 201208908 to re-evaluate their current practice and the basis for using a single cooling unit. The inspectors were concerned that the licensee implemented a Final Safety Analysis Report change that conflicted with existing requirements in technical specifications and created a condition where the plant would be subject to loss of both trains with a single failure of the operating train of cooling without prior NRC approval. In addition, the technical basis for this Final Safety Analysis Report change may not have adequately accounted for the maximum expected heat loads, and may not have demonstrated air flows to remove heat loads from both trains simultaneously. Additional information was needed to determine whether the concerns discussed above involve one or more violations of 10 CFR Part 50, Appendix B, Criterion III, Design Control, 10 CFR 50.59, Changes, Tests and Experiments, Technical Specification 3.8.1, AC Sources Operating, Technical Specification 3.8.4, DC Sources Operating, Technical Specification 3.8.7, Inverters Operating, and Technical Specification 3.8.9, Distribution Systems Operating. Pending further evaluation of the above issues by the licensee and subsequent review by inspectors, this issue will be tracked as unresolved item (URI) 05000483/2012004-03, Determine Licensing Basis and Capability of One Vital Air Conditioning Unit to Cool Both Trains of Class 1E Electrical Equipment.
05000324/FIN-2012002-01Brunswick2012Q1Failure to Identify and Correct a Refrigerant Leak in the Instrument Air Dryer SystemA self-revealing non-cited violation of 10 CFR 50 Appendix B, Criteria XVI, Corrective Action, was identified for the licensees failure to promptly identify and correct a condition adverse to quality related to the Control Room Air Conditioning (AC) system and the Control Room Emergency Ventilation (CREV) system. Specifically, the licensee failed to identify and correct a slow refrigerant leak in the instrument air dryer in the control building HVAC instrument air system, rendering both the control room AC and CREV systems inoperable. Upon discovery, the instrument air dryer was bypassed, air pressure was restored, and the control room AC and CREV systems were restored. The licensee entered this issue into the corrective action program as Action Request (AR) 502214. The failure to identify and correct the slowly lowering refrigerant pressure was a performance deficiency. This finding was more than minor because it was associated with the structure, system, and component (SSC) and barrier performance attribute of the Barrier Integrity Cornerstone. It also adversely affected the cornerstone objective of maintaining a radiological barrier for the control room. Specifically, the finding led to a loss of all air conditioning and filtering capability of control room air. The significance determination process was completed in accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Phase 1 Initial Screening and Characterization of Findings, Table 4a for the Barrier Integrity Cornerstone. The finding was determined to be of very low safety significance (Green) because it only affected the radiological barrier function of the control room, and does not represent a degradation of the smoke or toxic atmosphere barrier function of the control room. This finding has a cross-cutting aspect in the corrective action program component of the Problem Identification and Resolution area because the licensee did not identify the issue completely, accurately, and in a timely manner commensurate with its safety significance.
05000237/FIN-2011005-01Dresden2011Q4Bus 23 Pot Fuse Drawer Resulting in the Inoperability of the Control Room Emergency Ventilation Air Condition SystemA self-revealed finding of very low safety significance and associated NCV of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified on October 24, 2011, when two electrical maintenance technicians performing a clearance boundary safety verification opened a Bus 23 potential transformer (POT) fuse drawer causing an undervoltage load shed signal that resulted in the inoperability of the control room emergency ventilation (CREV) air conditioning system. Corrective actions taken included an electrical maintenance department clock reset and stand down to discuss the event and consequences of taking actions in the plant without proper guidance. Further licensee planned corrective actions include presenting to Operations and the Configuration Control Committee the possibility of installing robust barriers or locking devices on bus POT installations. A self-revealed finding of very low safety significance and associated NCV of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified on October 24, 2011, when two electrical maintenance technicians performing a clearance boundary safety verification opened a Bus 23 potential transformer (POT) fuse drawer causing an undervoltage load shed signal that resulted in the inoperability of the control room emergency ventilation (CREV) air conditioning system. Corrective actions taken included an electrical maintenance department clock reset and stand down to discuss the event and consequences of taking actions in the plant without proper guidance. Further licensee planned corrective actions include presenting to Operations and the Configuration Control Committee the possibility of installing robust barriers or locking devices on bus POT installations.
05000313/FIN-2011002-03Arkansas Nuclear2011Q1Inadequate Procedural Guidance Results in Damaged Emergency Control Room Ventilation System Air DamperThe inspectors documented a self-revealing noncited violation of Technical Specification 5.4.1.a for the inadequate maintenance work order and procedure that resulted in damaging the damper, CV-7910, VSF-9 makeup air supply, during planed maintenance activities. Specifically, work order 52220286 referenced a procedurally controlled temporary modification, that referred to an incorrect engineering change document, was vaguely written and led to the installation of the wrong flange cover and resulted in a damaged damper and challenged the control room envelope integrity. The licensee repaired the damaged damper and entered the issue into corrective action program as Condition Report CR-ANO-C-2010-2429. The failure of the licensee to provide adequate procedural guidance, that led to the installation of the wrong flange cover and resulted in a bent damper, CV-7910, associated with the Unit 1 control room emergency ventilation system was a performance deficiency. This was determined to be within the licensees ability to foresee and correct and is a violation of a unit 1 technical specification. The performance deficiency was determined to be more than minor because it was associated with the procedure quality attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective provide reasonable assurance that the physical design barriers protect the public from radionuclide releases caused by accidents or events, and is therefore a finding. Using Manual Chapter 0609.04, Phase 1 - Initial Screening and Characterization of Findings, the finding was determined to have very low safety significance, Green, because the finding did not represent a degradation of the barrier function for the control room against radiation, smoke or toxic gas. The finding was determined to have no cross-cutting aspects due to the procedure change that took place in 2005 and is not indicative of current plant performance.
05000220/FIN-2011002-02Nine Mile Point2011Q1Inadequate Corrective Actions to Correct Motor Control Center Spring Clip Engagement lssues.The inspectors identified a finding of very low safety significance associated with a non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion XVl, Corrective Action, for Nine Mile Point Nuclear Station\'s (NMPNS) failure to take adequate corrective actions for a condition adverse to quality. Specifically, between January 26, 2009, and November 29, 2010, NMPNS did not implement adequate corrective actions to address a lack of spring clip engagement for 600 volt General Electric 7700 line motor control centers (MCCs). As a result, the breaker for the control room emergency ventilation system fan failed to correctly operate when required. NMPNS entered this issue into its corrective action program (CAP) and implemented a physical verification of spring clip engagement. The finding was more than minor because it was associated with the structure, system, and component (SSC), and barrier performance attribute of the Barrier lntegrity cornerstone, and affected the cornerstone objective to provide reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and containment) protect the public from radionuclide releases caused by accidents or events. The finding was determined to be of very low safety significance, because the finding did not represent a degradation of the radiological barrier function of the control room, and the finding did not represent a degradation of the barrier function of the control room against smoke or a toxic atmosphere. This finding had a cross-cutting aspect in the area of problem identification and resolution, corrective action program component, because NMPNS did not thoroughly evaluate the initial component failures such that the resolutions addressed the causes and extent of conditions. Specifically, NMPNS did not properly prioritize and evaluate spring clip engagement issues over 22 months.
05000348/FIN-2009003-06Farley2009Q2Licensee-Identified Violation10 CFR 50, Appendix B, Criterion III, Design Control, requires in part that measures shall be established to assure the design basis for those SSCs to which this appendix applies are correctly translated into procedures and instructions. Contrary to this on September 24, 2008, the licensee determined that surveillance test procedure FNP-0-STP-123.0, Control Room Emergency Ventilation Performance Test, contained an incorrect formula constant for the cross sectional area of the control room ventilation duct used to establish the required flow conditions for performance of the test. Specifically, the test procedure utilized a constant for the cross sectional duct area that was 0.42 square feet when actual cross sectional duct area was 0.39 square feet. This error resulted in the performance of a surveillance test documented in work order W00703732 where actual system flow rate was lower than that required for performance of the test. The licensee determined surveillance test procedures FNP-0-STP-123.3, CREFS Pressurization Unit Heater Performance Test and FNP-0-STP-916.0, CREFS Pressurization Unit Heater Operability Test, also referenced the incorrect duct cross sectional area and were similarly affected. This was identified in the licensees CAP as CR 2008109679. The licensee was able to demonstrate through subsequent analysis for those tests performed at lower than recorded system flow rates, sufficient margin remained to support system operability. This finding was assessed using Inspection Manual Chapter 0609 Significance Determination Process Phase 1 screening worksheet for mitigating systems cornerstone and determined to be of very low safety significance (GREEN) because it did not result in an actual loss of safety function of a single train for greater than the TS allowed outage time and was not potentially risk-significant due to external events
05000324/FIN-2009002-05Brunswick2009Q1Inadequate Maintenance Procedure for the Control Room Air Conditioning and Emergency Ventilation Instrument Air System (Section 4OA2)A self-revealing Green NCV of Technical Specification (TS) 5.4.1, Procedures, was identified for inadequate maintenance procedures for the control room air conditioning and emergency ventilation system instrument air dryer. As a result, on January 21, 2009, the control room air conditioning and emergency ventilation instrument air system lost air pressure, rendering the control room air conditioning (AC) system and the control room emergency ventilation (CREV) system inoperable. The licensee entered the issue into their corrective action program and changed maintenance and operating procedures to prevent recurrence. The failure to implement adequate maintenance procedures for the control room air conditioning and emergency ventilation instrument air system is a performance deficiency. This performance deficiency is more than minor because it is associated with structure, system, and component (SSC), and barrier performance attribute of the Barrier Integrity Cornerstone. It also adversely affected the cornerstone objective of maintaining a radiological barrier for the control room. The finding was determined to be of very low safety significance because it only affected the radiological barrier function of the control room, and does not represent a degradation of the smoke or toxic atmosphere barrier function of the control room. The cause of the finding is related to the cross-cutting area of human performance, resources component, complete and accurate documentation aspect, because the licensee did not incorporate adequate guidance for maintaining the control room AC and CREV instrument air dryer in their maintenance procedures. (H.2(c)) (Section 4OA2
05000334/FIN-2009002-01Beaver Valley2009Q1Licensee-Identified ViolationBeaver Valley Unit 1 and Unit 2 TS 3.7.10 requires, in part, that an adequate Control Room Envelope (CRE) be maintained or restored within 90 days. This protects the CRE during postulated accident and hazardous conditions. Contrary to TS 3.7.10, the licensee determined that an inadequate CRE existed, due in part to a degraded (damper corrosion) normal intake damper, which is postulated to have existed for longer than the TS allowed time. The separate Control Room Emergency Ventilation System (CREVS) was not affected. The licensee identified the excessive inleakage condition during a surveillance test. The licensee had failed to to identify this component as a CRE boundary and perform routine inspection and maintenance. Upon finding the excessive in-leakage, the licensee implemented compensatory actions to mitigate the possibility of in-leakage to the control room and completed repairs to the affected dampers and seals. The licensee entered this issue into their corrective action program as CR 08-49260 and reviewed their CRE maintenance program. The inspectors determined that the failure to maintain an adequate CRE is a violation of TS 3.7.10 identified by the licensee that affects the containment barrier cornerstone. The violation is considered of very low safety significance since it represents a degradation of the radiological barrier of the control room. This is considered a licensee-identified violation (Green), NCV of Technical Specification 3.7.10
05000346/FIN-2008003-01Davis Besse2008Q2CREVS Train 2 Inoperable Due to Loss of Refrigerant ChargeThe inspectors identified a non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, when the licensee did not correct a condition adverse to quality, associated with a refrigerant leak on the regulating valve for Control Room Emergency Ventilation System (CREVS) Train 2, that eventually rendered CREVS Train 2 inoperable based on a loss of refrigerant charge. This finding is greater than minor because it is associated with the System, Structures, and Components (SSC) and Barrier Performance attribute of the Barrier Integrity cornerstone and negatively affected the cornerstone objective to ensure the availability, reliability, and capability of systems used to maintain the radiological barrier functionality of the control room, particularly for CREVS to maintain a suitable environment for safety-related equipment and operators. The licensee entered the equipment issue into their corrective action program. The finding is of very low safety significance because the finding only represents a degradation of the radiological barrier function provided for the control room. The cause of the finding is related to the cross-cutting aspect of problem identification and resolution (P1.(d)) in that the licensee did not take actions to correct the refrigerant leak in a timely manner, commensurate with the issues safety significance
05000346/FIN-2008002-05Davis Besse2008Q1Licensee-Identified ViolationTechnical Specification 3.7.6.1 states control room emergency ventilation system requires two independent control room emergency ventilation systems (monitors) be operable while plant is operating in modes 1, 2, 3, and 4. With both channels of station vent normal range radiation monitoring instrumentation inoperable, TS LCO 3.7.6.1 Action C requires that within one hour the control room normal ventilation system be isolated and at least one control room emergency ventilation train placed in operation. Contrary to this requirement, on October 16 and 22, 2007, both trains of Station Vent Radiation Monitors were inoperable for more that one hour without entering into TS 3.7.6.1 Action C. This issue was entered into the licensees Corrective Action Program as CR 07-29410. The issue is of very low safety significance because it did not involve ALARA planning or work controls, an overexposure, substantial potential for overexposure, or the ability to assess radiation dose