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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.
05000390/FIN-2018001-01Watts Bar2018Q1Misapplication of Technical Specification Limiting Condition for Operation 3.0.6Inspectors identified a Green finding and associated non-cited violation (NCV) of Title 10 of the Code of Federal Regulations Part 50 (10 CFR 50), Appendix B, Criterion V, Instructions, Procedures, and Drawings, when the licensee failed to adhere to their current licensing basis (CLB) during the implementation of procedure 0-SOI-30.05, Auxiliary Bldg HVAC Systems, which governs the operation of the engineered safety feature (ESF) coolers serving as support systems for Technical Specification (TS) equipment. Specifically, based upon the documented CLB at the time, the licensee failed to enter the appropriate TS condition and action statement for the TS supported equipment when a single train of support ESF coolers was removed from service. With a single train of ESF coolers out of service, this rendered the TS supported equipment unable to meet the single failure criterion (SFC) requirement.
05000298/FIN-2017002-03Cooper2017Q2Loss of Control Room Ventilation Due to Improper Switch ManipulationThe 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).
05000354/FIN-2017008-01Hope Creek2017Q1Improper Preventive Maintenance Deletion Results in the Inoperability of the A Control Room HVAC SystemGreen . A self -revealing Green non- cited violation ( NCV ) of Technical Specification ( TS ) 6.8.1, Procedures and Programs, as described in Regulatory Guide (R G) 1.33, Revision 2, February 1978, was identified when PSEG did not maintain an appropriate preventive maintenance ( PM ) schedule for the A control room heating, ventilation and air conditioning (HVAC ) system. Specifically, PSEG inadvertently deactivated a PM activity to perform periodic cleaning of the A control room return air fan (AVH -415) low flow switch pitot tubes that resulted in the A train of the control room emergency filtration ( CREF ) to be 3 unavailable on November 23, 2016 . PSEG performed corrective actions to clean the clogged pitot tubes associated with the AH -415 flow switch, re -activate the inadvertently deleted PM, and identify the extent of condition in other systems . This issue was more than minor because it was associated with the structures, systems and components ( SSC ) and barrier performance attribute of the Barrier Integrity Cornerstone (under the areas to measure associated with the radiological barrier function of the control room); and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. The inspectors determined that the finding was of very low safety significance (Green) in accordance with IMC 0609, Attachment 4 and Appendix A, Exhibit 3, because the finding only represented a degradation of the radiological barrier function for the control room. The inspectors determined that there was no cross -cutting aspect associated with this finding since it was not representative of current PSEG performance. Specifically, the causal factors associated with this finding occurred in 2010, which was outside the nominal three- year period of consideration and were not considered representative of present performance in accordance with IMC 0612
05000250/FIN-2017001-02Turkey Point2017Q1Failure of Vital Battery Chargers Due to Conductive Dust / Particulate Foreign Material ExclusionAnnual Sample: (Opened) Unresolved Item (URI): Failure of Battery Chargers Due To Conductive Dust / Particulate Foreign Material Exclusion 18 a. Inspection Scope: The inspectors performed an in-depth review of AR 2183537 that documented an equipment apparent cause evaluation (EACE) associated with three Unit 3 battery chargers that tripped while in service. Thermo-Lag was being installed in support of fire protection modifications for Turkey Points transition to a risk-informed fire protection program, i.e. NFPA 805. The inspectors reviewed the associated corrective actions to verify they were completed as prescribed and that open actions were scheduled to complete commensurate with the safety significance of the activity. The inspectors walked down the battery chargers to verify selected corrective actions were completed and walked down the modification to HVAC unit V78 that was installed to prevent air from blowing directly into the battery charger ventilation louvers. The inspectors reviewed ARs that were generated during the EACE and evaluated the licensees disposition of these ARs to verify the licensees actions were in accordance with licensee procedure, PI-AA-104-1000, Corrective Action. During this inspection, on March 18, 2017, in a separate location of the plant, the 3A 4kV switchgear bus arc flashed in the reactor coil cubicle causing the 3A 4kV switchgear bus protective relay circuits to automatically deenergize the bus. The inspectors attended the licensees RCE failure investigation team meetings on this issue to obtain updates and gather facts on the arc flash and failed switchgear. The licensees RCE related to the 3A 4kV switchgear failure was in process at the end of this inspection period. The 3A 4kV switchgear room was undergoing Thermo-Lag passive fire barrier installation which was similar to the work in the new electrical equipment room (NEER) that housed the battery chargers. Documents reviewed are listed in the Attachment. This inspection constitutes one sample. b. Findings: Introduction: A URI was opened to determine if there is a performance deficiency related to the battery charger trips in the NEER and failure of the 3A 4kV switchgear bus. Description: On February 2, 2017, the 3A2 vital battery charger input breaker and motor control center (MCC) supply breaker tripped. Four minutes later, the D51 battery charger input breaker tripped. Subsequently, on February 8, 2017, the 3B2 vital battery charger input breaker and MCC supply breaker tripped, and a loud bang and possible flash were reported to have occurred in the lower level near the 4D MCC which supplies 480 Vac to the 3B2 charger. On February 13, the 4A2 and 4B2 battery chargers had difficulty load sharing with redundant battery chargers operating on their associated battery busses. The ARs associated with these separate issues include: AR 2184506, AR 2183540, AR 2183773, and AR 2185218. The licensee initiated an EACE on these issues, AR 2183537. For the battery charger trips that occurred on February 2, the licensee noted that Thermo-Lag work was in progress near the chargers in the NEER. At the time of the breaker trips, several employees were in the NEER performing cleanup from the Thermo-Lag activities. The licensee discovered a notable level of dust on horizontal surfaces in the NEER as well as inside the 3A2 and D51 battery charger cabinets. The licensee concluded the dust was conductive. The 3A2, D51 and 3B2 chargers, which were all located near each other and in the same room elevation, were cleaned and returned to service. The 4A2 and 4B2 battery chargers were also cleaned but it was noted those 19 chargers were in the same room but at a lower elevation. On February 8, the 3B2 charger tripped, despite it having been previously cleaned. It was noted at the time of the 3B2 charger trip that there were several employees installing Thermo-Lag in the NEER. The licensee concluded that the apparent cause of the breaker trips was conductive dust/particulate that may have been created by Thermo-Lag passive fire barrier installation in the vicinity of the battery chargers. The dust/particulate became airborne and settled on charger components. Corrective actions included cleaning all the chargers in the room and installing a modification which provided a sheet metal barrier on top of the D51, 3A2 and 3B2 battery chargers to deflect air from HVAC Unit V78 being blown directly into the louvered charger electrical cabinets. On March 18, 2017, in a separate location of the plant, the Unit 3A 4kV switchgear room, the 3A 4kV switchgear bus arc flashed in the reactor coil cubicle. The arc flash resulted in an explosion and the 3A 4kV switchgear bus was automatically deenergized by protective relay circuits. Similar to the NEER that housed the battery chargers, the 3A 4kV switchgear room was undergoing Thermo-Lag passive fire barrier installation. The deenergized 3A 4kV switchgear bus resulted in a Unit 3 automatic reactor trip. This event and NRC follow-up is described in section 4OA3 of this report. The licensee promptly chartered an RCE team to investigate the failure of the 4kV bus. The licensee noted that prior to the arc flash there were several employees in the 3A 4kV switchgear room performing similar Thermo-Lag installation. As an immediate corrective action, the licensee stopped all Thermo-Lag installation work in the entire fleet. The licensees RCE plan included determining if there were any common causes with the battery charger trips and the 4KV switchgear failure due to Thermo-Lag installations. A URI was identified because additional review is needed to determine if there were any common causes between the battery charger trips and anomalies and the 3A 4kV switchgear bus arc flash and to determine if this issue of concern constitutes a violation. Specifically, the inspectors will review the licensees RCE of the failed 4kV switchgear to determine if there are causes and corrective actions which were not identified during the investigation of the battery charger trip EACE, and if corrective actions could have prevented the 3A 4kV switchgear bus arc flash. (URI 05000250/2017001-02, Failure of Vital Battery Chargers Due to Conductive Dust / Particulate Foreign Material)
05000461/FIN-2016009-01Clinton2016Q4Non Conservative Control Room Radiological Habitability AssessmentThe team identified a finding of very-low safety significance (Green) and an associated NCV of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the licensee failure to use a technically appropriate analytical methodology in the control room radiological habitability calculation. Specifically, the licensee used a methodology that inappropriately characterized the control room heating, ventilation and air-conditioning (HVAC) system outside air intake design resulting in a calculated control room dose following a loss of coolant accident that exceeded the applicable limit. The licensee captured this issue in their CAP as AR 02742442, completed an operability evaluation, and issued an NRC event notification. The performance deficiency was determined to be more-than-minor 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 performance deficiency resulted in the control room expected dose following a loss of coolant accident to exceed the applicable limits prompting an operability evaluation. The finding screened as of very-low safety significance (Green) because it only represented a degradation of the radiological barrier function provided for the control room. Specifically, the finding did not affect the control room barrier function against smoke or a toxic atmosphere. The team did not identify a cross-cutting aspect associated with this finding because it was not confirmed to reflect current performance due to the age of the performance deficiency. Specifically, the affected calculations were performed more than 3 years ago.
05000461/FIN-2016009-04Clinton2016Q4Failure to Verify the Adequacy of Design Assumptions Related to Time Critical Operator ActionsThe team identified a finding of very-low safety significance (Green) and an associated NCV of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the licensee failure to verify the adequacy of design assumptions related to time critical operator actions made in calculations associated with the control room HVAC and RHR emergency SFP cooling functions. Subsequently, it was determined that operators did not fully understand the control room HVAC system operational demands and that the operational assumptions of the RHR emergency SFP cooling design were unrealistic. The licensee captured these issues into the CAP as AR 02739012, AR 03943566, and AR 02741909; reasonably demonstrated that SFP makeup sources would be available to cope with a prolonged loss of SFP cooling; conducted operator training; and provided refined procedural guidance to ensure the control room HVAC system would be operated consistent with the design assumptions. The performance deficiency was determined to be more-than-minor 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. Specifically, the pilot validations of the control room HVAC system operational assumptions demonstrated a significant reduction in margin due to, in part, a lack of operator understanding of the operational assumptions. Additionally, a preliminary review of procedures associated with SFP cooling and RHR determined the operational assumptions of the calculation related to RHR emergency SFP cooling were not bounding. The team determined that this finding was of very low safety significance (Green). Specifically, the control room HVAC system finding example only represented a degradation of the radiological barrier function provided for the control room in that it did not affect the control room barrier function against smoke or a toxic atmosphere. In addition, the finding example related to emergency SFP cooling did not cause SFP temperature to exceed the maximum analyzed limit, a detectible release of radionuclides, water inventory to decrease below the analyzed limit, or an adverse effect to the SFP neutron absorber or fuel loading pattern. The team determined that the finding had a cross-cutting aspect in the area of Human Performance because the operation and engineering organizations did not effectively communicate and coordinate their respective roles in developing the control room HVAC system validation in a manner that supported nuclear safety.
05000461/FIN-2016009-06Clinton2016Q4Failure to Follow the Operability Determination Process Following the Identification of a Control Room HVAC System Design IssueThe team identified a finding of very-low safety significance (Green), and an associated NCV of 10 CFR Part 50, Appendix B, Criterion V, Instruction, Procedures, and Drawings, for the licensee failure to follow the operability evaluation procedure after the identification of a significant design error associated with the control room HVAC system. Specifically, the licensee did not identify the affected safety function, and promptly restore or confirm system operability. The licensee captured these issues into the CAP as AR 03948266 and performed a preliminary engineering evaluation using another alternative analytical methodology that reasonably determined the control room HVAC system remained operable. The performance deficiency was determined to be more-than-minor 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. Specifically, the performance deficiency resulted in a condition where reasonable doubt on the operability of the control room HVAC system remained following the identification of a significant design error. The finding screened as of very-low safety significance (Green) because it only represented a degradation of the radiological barrier function provided for the control room. Specifically, the finding did not affect the control room barrier function against smoke or a toxic atmosphere. The team identified that the finding had a cross-cutting aspect in the area of Human Performance because the licensee did not provide training to maintain a knowledgeable workforce that would facilitate an adequate implementation of the operability evaluation process following the identification of a non-conforming design-related issue.
05000285/FIN-2015009-01Fort Calhoun2015Q4Failure to Take Adequate Corrective Action to Preclude Repetition of a Significant Condition Adverse to Quality Associated with Emergency Diesel Generator Room Water IntrusionsThe team identified an NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions, for the licensees failure to take corrective actions to prevent repetition of a significant condition adverse to quality. Specifically, since February 2009, the licensee failed to take corrective actions to prevent repetitive water intrusions from the Auxiliary Building HVAC room (Room 82) into the number one Emergency Diesel Generator room (Room 63). The inspectors determined that the licensees failure to implement corrective actions to preclude repetitive water intrusions into Room 63 was a performance deficiency. The performance deficiency was more than minor because it was associated with the protection against external factors attribute of the mitigating systems cornerstone. Specifically, water intrusion events from Room 82 into Room 63 could challenge the reliability of the emergency diesel generator when relied upon during a loss of offsite power. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, Exhibit 2, Mitigating Systems Screening Question, inspectors determined that the finding was of very low safety significance (Green). The finding has a problem identification and resolution cross-cutting aspect within the area of Resolution, because the licensee did not take effective corrective actions to address issues in a timely manner commensurate with their safety significance (P.3).
05000334/FIN-2015007-02Beaver Valley2015Q3Unit 1 Control Room HVAC Equipment Room Safe Shutdown Capability Affected by Smoke MigrationThe team identified a finding of very low safety significance (Green) involving a non-cited violation of 10 CFR 50 Appendix R, III.L.3. for failure to establish an alternative safe shutdown capability independent of the Unit 1 control room HVAC equipment room, sub-fire area CR-2. Specifically, a fire in CR-2 will generate heat and smoke that will rise to the Unit 1 main control room where post-fire safe shutdown equipment is remotely operated in response to a fire in CR-2. This issue was determined to satisfy the criteria specified for the exercise of enforcement discretion for plants in transition to a fire protection program that meets the requirements of 10 CFR 50.48(c), National Fire Protection Association Standard NFPA 805. Description. The team reviewed the Updated Fire Protection Appendix R Report, Rev. 31 for BVPS Unit 1 and noted that Duquesne Light Company filed an exemption request on January 14, 1985, in part for fire area CR-2, from the requirements of 10 CFR 50, Appendix R. The exemption request also redefined CR-2 as a subarea of the main control room fire area, CR-1, based on a ventilation shaft traversing the CR-2 ceiling and CR-1 floor. The exemption request redefined CR-2 and CR-1 as a single alternative shutdown fire area in accordance with Section III.G.3 of Appendix R. The NRC approved the exemption request in a letter dated December 4, 1986. The team noted that Duquesne Light Companys exemption request justified adequate separation for safe shutdown systems and fire suppression and detection within the affected fire area, but did not identify that operators would be required to remain in the main control room to operate safe shutdown equipment for a fire in CR-2. This is unlike the established safe shutdown capability for the main control room where operators would leave the main control room to locally operate safe shutdown equipment. Local operation of safe shutdown equipment ensured equipment and circuits were isolated from the effects of the fire and operators would not be subject to smoke or heat. The team noted that Updated Fire Protection Appendix R Report, Rev. 31 credited safe shutdown equipment for a fire in CR-2 to be operated from the main control room and procedure 1OM-56B.4.C, Safe Shutdown Following A Serious Fire in the Control Building, Rev. 12, specific to fires in CR-2 and CR-3, the relay room, provided operating instructions consistent with the fire safe shutdown analysis. The team additionally noted that the unqualified fire damper in the ventilation shaft between CR-2 and CR-1 can only be operated at a local panel inside CR-2. The team considered that operators remaining in the main control to establish post-fire safe shutdown for a fire in CR-2 was an alternative safe shutdown capability that was not independent of the fire area. In response to the teams concern for smoke and heat rising from CR-2 affecting operator visibility or main control room habitability, FENOC provided calculation, SCI- 17756-03, NFPA 805 Fire PRA Task 11c, Multi Compartment Fire Analysis for BVPS Unit 1, Rev. F. Attachment 3 of this calculation analyzed the potential for propagation of hot gases into the main control room via the non-fire rated ventilation duct shaft. The team determined the analysis was conservative and concluded that operators could remain in the main control room and would have more than one hour to initiate the Unit 2 main control room ventilation system in smoke purge mode. The team judged that procedure 1OM-56B.4.C, Safe Shutdown Following A Serious Fire in the Control Building, Rev. 12, was deficient because it did not provide any caution to control room operators that a fire in CR-2 could generate heat and smoke that could rise to the main control room. Additionally, the procedure did not provide any instructions to remove the heat and smoke such as by placing the Unit 2 main control room ventilation system in smoke purge mode. FENOC promptly entered this safe shutdown issue into their corrective action program (CAP) as CR-2015-10577 and intended to revise 1OM-56B.4.C, Safe Shutdown Following A Serious Fire in the Control Building, to include a note to initiate smoke purge mode of the Unit 2 control room ventilation system as needed for a fire in CR-2. The team considered FENOCs corrective actions appropriate. Analysis. The failure to establish an alternative safe shutdown capability independent of the Unit 1 control room HVAC equipment room, sub-fire area CR-2, is a performance deficiency (PD). This PD is more than minor because it is associated with the external events (fire) attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. Using IMC 0609, Appendix F, Fire Protection Significance Determination Process, the team determined that this issue screens to Green in task 1.3.1 because the reactor is able to reach and maintain safe shutdown: a conservative calculation determined the main control room operators would not be impaired. Cross-cutting aspects are not applicable to findings involving enforcement discretion. Enforcement. 10 CFR 50.48(b)(2) requires that all nuclear power plants licensed to operate before January 1, 1979, must satisfy the applicable requirements of 10 CFR 50, Appendix R, including specifically the requirements of Sections III.G, III.J, and III.O. 10 CFR Part 50, Appendix R, Section III.G.2 requires, in part, that, where cables or equipment of redundant trains of systems necessary to achieve and maintain hot shutdown conditions are located within the same fire area outside of primary containment, one of the stated means of ensuring that one of the redundant trains is free of fire damage shall be provided. The stated means include separation of cables and equipment and associated non-safety circuits of redundant trains through the use of specified fire barriers, distance, or suppression systems. 10 CFR part 50, Appendix R, Section III.G.3 requires, in part, that alternative or dedicated shutdown capability should be provided where the protection of systems whose function is required for hot shutdown does not satisfy the requirement of paragraph G.2 of this section. 10 CFR Part 50, Appendix R, Section III.L.3, in part, specifies that alternative shutdown capability shall be independent of the specific fire area. Contrary to the above, since December 4, 1986, BVPS Unit 1, a nuclear power plant licensed to operate before January 1, 1979, has not satisfied the applicable requirements of 10 CFR 50, Appendix R, Section III.G, in that the licensee did not provide alternative shutdown capability that was independent of a specific fire area where the protection of systems whose function is required for hot shutdown was not ensured to be free of fire damage. Specifically, for a fire in CR-2, FENOC required operators to remain in the main control room to operate safe shutdown equipment. However, the main control room was not independent of the fire area, since the main control room will be impacted by heat and smoke generated from a fire in CR-2. The violation was historical and occurred when Duquesne Light Company, a predecessor to FENOC, implemented a January 14, 1985, exemption request from the requirements of Appendix R. FENOC is in transition to NFPA 805 and, therefore, this NRC-identified violation was evaluated in accordance with the criteria established in Section 9.1 of the NRC Enforcement Policy, Enforcement Discretion for Certain Fire Protection issues (10 CFR 50.48). Specifically, because all of the criteria were met, the NRC is exercising discretion and not issuing a violation for this issue.
05000397/FIN-2015003-03Columbia2015Q3Failure to Provide Design Control Measures for Control Room Emergency ChillersThe inspectors identified a non-cited violation of 10 CFR 50, Appendix B, Criterion III, Design Control, for the licensees failure to verify the adequacy of the design of the control room HVAC system. Specifically, the licensee failed to demonstrate the ability of control room HVAC design to maintain the temperatures in the main control room below habitability and environmental qualification limits, for the duration of all accident scenarios. The licensee initiated Action Request 332565 to document the concern, issued night order 1662 to communicate the issue, aligned both control room air handling units to their respective chillers, created a quick card procedure to perform the chiller reset actions, and validated the quick card actions could be accomplished within 10 minutes. Additionally, the licensee determined that operators could restore the chillers during accident conditions within 90 minutes to prevent temperatures from exceeding equipment operability limits. The performance deficiency was more than minor because it adversely affected the design control attribute of the Mitigating Systems Cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using NRC Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined the finding was of very low safety significance because (1) the finding was not a deficiency affecting the design or qualification of a mitigating system; (2) the finding did not represent a loss of system and/or function; (3) the finding did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and (4) the finding does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hours. This finding had a cross-cutting aspec in the area of problem identification and resolution, evaluation, in that the licensee did not thoroughly evaluate issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance. Specifically, the licensee did not thoroughly evaluate the extent of condition from NRC-identified NCV 05000397/2013002-04, Failure to Obtain NRC Approval for Changes to Control Room HVAC Requirements, fo the effect of this change on other station calculations (P.2).
05000400/FIN-2015002-02Harris2015Q2Failure to Adequately Implement the Control Room Area HVAC System ProcedureAn NRC-identified Green non-cited violation (NCV) of Technical Specification (TS) 6.8.1, Procedures and Programs, was identified for the licensees inadequate implementation of procedure OP-173, Control Room Area HVAC System. Specifically, the licensee failed to adequately implement OP-173 Section 8.3, Placing the Control Room Area HVAC System into Recirculation Manually, and maintain a positive pressure in the main control room (MCR). The licensee entered this issue into the corrective action program (CAP) as action request (AR) 742947, and restored a positive pressure in the MCR. The licensee also revised the associated procedure OWP-RM-01, Control Room OAI (outside air intake) Radiation Monitors, to ensure appropriate actions are taken for the outside air intake supply when radiation monitors are inoperable. The failure to maintain positive pressure in the MCR in accordance with OP-173 was a performance deficiency. The performance deficiency was determined to be more than minor in accordance with IMC 0612, Appendix B, since it was associated with the procedure quality attribute of the barrier integrity cornerstone and adversely affected the cornerstone objective and, if left uncorrected, the performance deficiency would have the potential for leading to a more significant safety concern. Specifically, the buildup of carbon dioxide (CO2) would impair operators performance and actions. The inspectors evaluated the finding using Inspection Manual Chapter 0609, Significance Determination Process, Attachment 4 and Appendix G (June 19, 2012), Shutdown Operations Significance Determination Process. The inspectors determined the finding was associated with the barrier integrity cornerstone and required a detailed risk evaluation because the finding involved control room habitability during both normal and accident conditions. A detailed risk evaluation was completed by a regional SRA using the guidance of NRC IMC 0609 Appendix G and Appendix F, Fire Protection Significance Determination Process. A bounding analysis was performed considering potential demands on MCR habitability due to radiation and smoke effects. The major analysis assumptions included: an eleven day exposure period, recovery credit for MCR door closure, shutdown core damage radiation and fuel pool radiation events were considered. The dominant sequence was a fire impacting the MCR with smoke, failure of operators to isolate the MCR resulting in loss of the operators leading to loss of core heat removal. The risk of the performance deficiency was mitigated by the low initiating event probabilities and the recovery likelihood of MCR door closure. The result of the analysis was an increase in core damage frequency of < 1.0E-6/year, a green finding of very low safety significance. The finding had a cross-cutting aspect of Procedure Adherence, as described in the Human Performance cross-cutting area because the licensee failed to comply with OP-173.
05000272/FIN-2015007-01Salem2015Q1Post-fire Safe Shutdown Operator Manual Actions to Align Temporary Ventilation Not Assessed for Feasibility and ReliabilityThe team identified a finding of very low safety significance (Green) involving a noncited violation of Salem Unit 1 Technical Specification 6.8.1.f. for failure to implement and maintain written procedures for fire protection program implementation. S1.OP-AB.FIRE-0001, Control Room Fire Response, Revision 6 and by reference S1.OP-AB.CAV-0001, Loss of Unit 1 Control Area HVAC, Revision 3, were procedures for response to plant fires. Specifically, PSEG failed to implement and maintain procedure instructions for several operator manual actions that established temporary ventilation in safe shutdown areas cooled by Heating, Ventilation, and Air Conditioning (HVAC) equipment subject to fire damage within the Unit 1 Chiller Room. PSEG promptly entered these safe shutdown procedure issues into their corrective action program as notifications 20678200, 20678505, 20678294, and 20679351 for evaluation and longer term corrective actions. Immediate corrective actions included improving the accessibility of contingency fans used to establish temporary ventilation. This performance deficiency (PD) was more than minor because it is associated with the external events (fire) attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. This PD was also similar to more than minor example 3.k of Inspection Manual Chapter (IMC) 0612, Appendix E, Examples of Minor Issues, in that non-conservative calculation assumptions and programmatic deficiencies in assessing the feasibility and reliability of operator manual actions associated with temporary ventilation resulted in a condition where there was a reasonable doubt of the success of post-fire safe shutdown for a fire in the Chiller Room. The team used IMC 0609, Appendix F, Fire Protection Significance Determination Process, and determined that a phase 2 quantitative screening approach was necessary because the finding could affect the ability to reach and maintain a stable plant condition within the first 24 hours of a fire event or result in a delay in excess of 10 minutes for performing required actions necessary within 1 hour. The issue screened to Green, or very low safety significance, in task 2.5.5 of the phase 2 analysis because a safe shutdown success path was maintained through temporary ventilation, temperature monitoring, and operator manual actions. This finding did not have a cross-cutting aspect because it was determined to be a legacy issue and was considered to not be indicative of current licensee performance.
05000387/FIN-2015001-02Susquehanna2015Q1Control of Transient Combustible MaterialsThe inspectors identified a Green NCV of the PPL Unit 1 and Unit 2 Facility Operating License Condition 2.C.(6), Fire Protection Program (FPP), for PPL not adequately controlling the storage of transient combustibles in accordance with their fire protection program requirements. Specifically, combustible materials in excess of the maximum allowable transient combustible loading were stored without being evaluated by the site fire protection engineer (SFPE) or having compensatory actions identified. PPL immediately instituted a fire watch for the area. The SFPE subsequently evaluated the area and determined that the transient combustibles exceeded the maximum allowable transient combustible loading as determined by the fire protection plan. Inspectors determined the performance deficiency was more than minor based on affecting the protection against external factors attribute of the initiating events cornerstone and its objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as at power operations. Additionally, it was similar to example 4.k in IMC 0612 Appendix E, Examples of Minor Issues, in that transient combustibles were not within the fire hazard analysis limits and there was a credible fire scenario that existed involving the transient combustibles that would impact equipment important to safety, specifically both trains of the control structure heating, ventilation and air conditioning (HVAC), control structure chillers and standby gas treatment. In accordance with IMC 0609.04, Initial Characterization of Findings, and Attachment 1 of IMC 0609, Appendix F, Fire Protection SDP Phase 1 Worksheet, the inspectors determined that this finding is of very low safety significance (Green) because the performance deficiency did not impact the ability to reach and maintain safe shutdown conditions. Specifically, a postulated fire in the fire zone did not present the possibility of impacting more than one train of safe shutdown equipment. This finding had a cross cutting aspect of Work Management in the Human Performance area because multiple groups were responsible for bringing the transient combustibles into the area and the individuals failed to effectively communicate and coordinate their activities to ensure that transient combustible control processes were appropriately implemented (H.5).
05000352/FIN-2015001-01Limerick2015Q1Fire Safe Shutdown Diesel Generator Maintenance Program Did Not Account for Cold Temperatures due to Inadequate Specification for Fuel Oil Cloud PointThe inspectors identified an NCV of LGS Units 1 and 2 operating license condition 2.C(3), Fire Protection, because Exelon did not implement and maintain in effect all provisions of the NRC approved fire protection program. Specifically, Exelon did not implement and maintain a maintenance program to ensure the operability of the fire safe shutdown diesel (FSSD) generator by not ensuring a fuel oil supply specified or protected for typical winter cold temperatures. Exelons corrective actions included adding a fuel oil additive (modifiers which inhibit wax crystal growth) to improve low temperature flow and pour characteristics at a time when ambient temperatures were greater than the cloud point and initiating condition report IR 2463216. This finding is more than minor because it adversely affected the protection against external factors (fire) attribute of the mitigating systems cornerstone to ensure the reliability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the failure to ensure the cloud point of the diesel fuel oil was below the temperature of the surrounding air would impact the reliable operation of the equipment during low temperature conditions. Using IMC 0609, Appendix F, Fire Protection Significance Determination Process, the inspectors determined that this finding was of very low safety significance (Green) because the finding did not impact the ability of LGS Units 1 and 2 to achieve safe shutdown. Specifically, the cloud point of diesel fuel delivered onsite by the vendor was substantially lower than Exelons specification, unavailability of the FSSD generator would not by itself prevent LGS from reaching and maintaining safe shutdown, and the need for powered ventilation given a loss of normal HVAC during cold weather would be less than during hot weather. The inspectors determined that this finding has a cross-cutting aspect in the area of Human Performance, Resources, because Exelon did not ensure that cold weather preparedness procedures were adequate to support nuclear safety. Specifically, Exelon relied upon the cold weather procedures to establish reliable equipment operation during cold temperatures, but the procedures did not address diesel fuel cloud point for equipment stored and/or operated outdoors.
05000387/FIN-2014005-06Susquehanna2014Q4Licensee-Identified ViolationSecondary Containment Door Found Ajar On February 12, 2014, PPL identified a secondary containment door (Door 612) between the HVAC room and central railroad bay wedged open by a door sign. In order for secondary containment to be operable in the as-found mode of operation, Door 612 had to be secured. PPL immediately secured the door, entered the condition into their CAP (2014-04709), and reported the condition under LER 50-387; 388/2014-002. Contrary to TS 5.4.1a, PPL did not secure the secondary containment door and maintain system operability in accordance with OP-134-002, RB HVAC Zones 1 and 3 after realignment of the secondary containment. The finding was more than minor because it adversely impacted the barrier performance attribute of barrier integrity and was determined to be of very low safety significance (Green) in accordance with IMC 0609, Appendix A, since the finding only represented a degradation of the radiological barrier function provided by standby gas treatment system.
05000220/FIN-2014002-01Nine Mile Point2014Q1Inadequate Design Control Measures Employed During Control Room HVAC ModificationThe inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion III, Design Control, because CENG did not implement adequate design controls to ensure piping in the Reactor Building Closed Loop Cooling (RBCLC) system remained operable while implementing a modification to the Unit 1 control room heating and ventilation system. Specifically, while implementing the modification, CENG personnel removed permanent plant supports and piping for the safetyrelated RBCLC system and did not fully assess how this change could impact the operability of the system with respect to a hydraulic shock or seismic acceleration event. In response to this observation, CENG initiated CR-2014-001676 and evaluated the condition for operability. Existing temporary supports were enhanced to provide additional margin by bracing the structure for horizontal loads. An extent of condition walkdown was performed and no additional issues of concern were identified. Subsequently, CENGs operability review determined the RBCLC system had remained operable. This finding was more than minor because it was associated with the design control attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, while implementing the modification, CENG removed permanent plant supports and piping for the safety-related RBCLC system and did not fully assess how this change could impact the operability of the system if a hydraulic shock or seismic acceleration occurred. This finding is also similar to examples 3.j and 4.k in IMC 0612, Appendix E, Examples of Minor Issues, where a temporary modification was installed without adequate design information and adequate design controls were not implemented leading to a reasonable doubt of operability of plant components. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, the inspectors determined this finding is of very low safety significance (Green) because the performance deficiency was a design or qualification deficiency that did not result in the inoperability of the RBCLC system. The finding has a cross-cutting aspect in the area of Human Performance, Work Management, because CENG failed to implement a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. Specifically, CENG failed to ensure that the installed temporary supports were adequate to ensure the RBCLC piping would not be stressed above code allowable values in the event of a seismic acceleration or hydraulic shock event prior to removing the permanently installed seismic supports.
05000395/FIN-2013008-01Summer2013Q4Failure to Design the Safety-related Chiller Modification to Appropriate Quality StandardsThe team identified a non-cited violation of 10 CFR 50, Appendix B, Criterion III, Design Control, for the licensees failure to review the application of design processes prescribed for the heating, ventilation, and air conditioning (HVAC) system chillers for suitability, to assure that appropriate quality standards were specified and included in design documents, and to ensure that deviations from such standards were controlled. This was a performance deficiency. The licensee entered this issue into their corrective action program as condition reports 13-04803, 13-04804, and 13-04665. The licensee performed an operability evaluation and determined the A chiller was inoperable with the two remaining operable chillers providing compliance with technical specifications. The performance deficiency was more than minor because it was associated with the Design Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to establish adequate design control measures that required the review of applicable design processes for suitability resulted in a failure to meet specified quality objectives, which decreased the availability and reliability of the A chiller. The team determined the finding to be of very low safety significance (Green) because although the finding was a deficiency affecting the design of a mitigating system, structure, or component which failed to maintain its operability, it did not represent a loss of the system function or a single train for greater than its technical specification allowed outage time. The HVAC system remains operable with the two remaining chillers, B and C, in operation. The team determined the finding involved the cross-cutting aspect of supervisory and management oversight, within the Work Practices component of Human Performance area which states that, the licensee ensures supervisory and management oversight of work activities, including contractors, such that nuclear safety is supported. Specifically, V. C. Summer management did not ensure management oversight of work activities that provided for the administration of quality assurance necessary to support nuclear safety.
05000397/FIN-2013010-05Columbia2013Q4Failure to Comply with Plant Technical Specifications for Control Room Air Conditioning SystemThe inspectors identified a non-cited violation of Technical Specification 3.7.4, Control Room Air Conditioning (AC) System, involving the licensees failure to adequately test and maintain the control room heating, ventilation, and air conditioning (HVAC) system. The licensee entered this issue into their corrective action program as Action Request AR 279768. The performance deficiency was more than minor because it affected the equipment performance attribute of the Mitigating System Cornerstone objective and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors performed the initial significance determination for the failure of the Division 1 control room air conditioning unit using NRC Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions. The inspectors determined that the ventilation fan remained functional and capable of performing the probabilistic risk assessment function for at least 24 hours. Therefore the finding is of very low safety significance (Green). This finding had a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action program component because the licensee failed to thoroughly evaluate problems such that the resolutions address causes and extent of conditions, as necessary. Specifically, the licensee failed to fully evaluate the existence of degraded sacrificial anodes in safety-related room coolers such that corrective actions to address these issues were implemented in a timely manner, commensurate with their significance.
05000285/FIN-2013008-29Fort Calhoun2013Q2Use of Alternate Seismic Evaluation CriteriaThe team identified an unresolved item associated with the licensees use of alternate seismic criteria when evaluating site structures. The alternate seismic criteria were approved for use by the NRC for piping and HVAC systems but were not explicitly approved for structures. The team identified that the licensee applied an alternate seismic evaluation method called Alternate Seismic Criteria Methodology in place of the original USAR seismic criteria delineated in Appendix F. The use of ASCM was originally proposed to the NRC on December 2, 1988, as alternate design criteria for new designs, modifications, and reanalysis of piping and pipe supports, electrical raceways, HVAC ducting, and anchor bolts. The team reviewed licensing documents and correspondence, and concluded that the NRC approved the use of ASCM for piping and HVAC systems and that the licensee had assumed the NRC had tacitly approved ASCM for structural calculations because the NRC staff did not specifically deny its use in those areas. The licensee informed the team that ASCM was used in several structural seismic evaluations including the auxiliary building and intake structure. At the close of the inspection, other potentially affected structures were being evaluated by the licensee. The team is concerned that the licensee inappropriately used ASCM without NRC approval and that ASCM may be non-conservative with respect to the seismic evaluation criteria specified in the USAR, Appendix F. The effect of the alternative seismic analysis is not known because the seismic spectra are different and are too complex for a qualitative analysis. Additional NRC review and follow up will be required to determine if this issue represents a performance deficiency or constitutes a violation of NRC requirements. This issue is identified as URI 05000285/2013008-29, Use of Alternate Seismic Evaluation Criteria.
05000456/FIN-2013003-03Braidwood2013Q2Implications of Control Room Ventilation Monthly SurveillanceThe inspectors identified an Unresolved Item (URI) regarding the use of TS Limiting Condition for Operation (LCO) 3.7.10 during the monthly control room ventilation system surveillance. Specifically, the inspectors questioned whether a step in procedure 0BwOSR 3.7.10.1-1, Control Room Ventilation Filtration Surveillance (Train A), to realign the VC suction source, and which appeared to defeat an automatic engineered safety feature (ESF) realignment, impacted the filtration system (Condition A) or control room envelope (CRE) boundary (Condition B) of the LCO. At 4:05 p.m. on May 8, 2013, the licensee commenced a routine monthly surveillance of the A VC filtration train using procedure 0BwOSR 3.7.10.1-1, Control Room Ventilation Filtration Surveillance (Train A). During performance of the surveillance, at 7:09 p.m., the licensee noted that B VC train damper 0VC08Y was unexpectedly open when it should have been closed. Approximately 25 minutes later, the damper repositioned closed. Operators were dispatched to inspect the damper and heard an abnormal grinding noise coming from the hydramotor. Consultation with the system engineer indicated that the grinding noise was likely caused by a degraded bearing. As a result, the licensee declared the B train of VC inoperable and entered LCO 3.7.10, Condition A, One VC Filtration System Train Inoperable for Reasons Other Than Condition B. Condition B stated, One or More VC Filtration System Trains Inoperable Due to Inoperable CRE Boundary in Mode 1, 2, 3, or 4. The licensee elected to continue with the routine surveillance on the A VC train. Step F5.1 of procedure 0BwOSR 3.7.10.1-1 directed Operations to enter LCO 3.7.10, Condition A, for the A VC train while the makeup filter selector switch was repositioned from auto to outside air then turbine building and back to auto as part of a contact check. The licensee entered LCO 3.7.10, Condition A, for the A VC train at 4:33 a.m. on May 9, 2013, and exited that Condition at 4:35 a.m. For those 2 minutes, both Units also entered LCO 3.0.3, since the A and B VC trains were simultaneously inoperable due to LCO 3.7.10, Condition A. During plant status activities on the morning of May 9, 2013, the inspectors noted discussions among senior plant personnel about whether LCO 3.7.10, Condition B (not Condition A) was actually the correct Condition to be entered while performing Step F5.1 of procedure 0BwOSR 3.7.10.1-1. The inspectors reviewed the TSs and discussed the system design with the VC system engineer. The VC system is designed such that when the makeup air suction is from outside air, the system would automatically realign the source air to the turbine building upon an air intake high radiation signal or a safety injection signal. When the makeup filter selector switch is not in the auto position, this automatic realignment will not occur, and manual actions would be required for the system to perform its ESF function. Additionally, the inspectors reviewed the licensees Control Room Habitability Program (CRHP), which included the following definitions: CONTROL ROOM ENVELOPE (CRE) BOUNDARY: A combination of walls, floor, roof, ducting, doors, penetrations, and equipment that physically form the CRE. CONTROL ROOM HABITABILITY SYSTEMS (CRHS): The plant systems that help ensure CRE habitability. This includes the Control Room emergency ventilation/filtration system and the Control Room HVAC systems. The CRE boundary is considered as an integral part of the CRHS, since it is critical to maintaining CRE habitability. The inspectors view was that the automatic realignment feature of the A VC train, which was blocked at the time the switch was not in auto, did not constitute part of the CRE boundary as defined in the CRHP. In addition, manual actions were required for the safety-related system to perform its ESF design function. As a result, the inspectors communicated to licensee management their view that Condition A was the correct Technical Specification Action Statement (TSAS) to be entered when performing the surveillance. Following this discussion, the licensee continued to believe that Condition B was the correct TSAS to enter when performing this surveillance. The inspectors also communicated their concerns that main control room logs, as officially recorded, did not completely and accurately capture the events that occurred on the night shift from May 8 to May 9, 2013. During plant status activities on May 9, the inspectors reviewed the main control room operating logs at approximately 6:30 a.m., and noted the log entries for entering LCO 3.7.10, Condition A, for the 0A VC train, and LCO 3.0.3, at 4:33 a.m. and exiting those LCOs at 4:35 a.m. However, later that morning when the logs were reviewed again, the inspectors noted those log entries had been revised. The log entries were annotated with, Late Entry 1030 5/9/13, and referenced entry into LCO 3.7.10, Condition B, and made no mention of LCO 3.0.3. There was no indication that anything had been revised or that LCO 3.0.3 had been entered. As a result of the inspectors concerns, the licensee generated IR 1519660, Lack of Detail in Log Entries, on May 30, 2013. Additionally, an Operations Noteworthy Event briefing sheet was created on June 12, 2013, and discussed with all Operating crews. The Noteworthy Event briefing sheet included the statement, Initially, LCO 3.0.3 was entered, but was retracted on days. LCO 3.7.10, Condition B, was determined to be the correct LCO entry. On July 8, 2013, the licensee again performed the monthly VC surveillance. Upon review of the main control room logs, the inspectors noted that LCO 3.7.10, Condition A, had been entered from 11:14 a.m. to 11:33 a.m. while alternating the suction source between outside and turbine building air. When questioned why the Noteworthy Event briefing sheet instructed Operating crews to enter Condition B and yet the crews entered Condition A, the licensee stated they were waiting for a more comprehensive review of the issue before revising the surveillance procedure. At the end of the inspection period, the inspectors were in the process of discussing the issue with NRC staff in the Office of NRR, reviewing the licensees determination of LCO applicability, and reviewing control room ventilation system design documentation. Pending additional information from the NRR staff, a complete understanding of the licensees position, and a more detailed understanding of the VC system design, this issue is considered a URI. (URI 05000456/2013003-03; 05000457/2013003-03, Implications of Control Room Ventilation Monthly Surveillance)
05000271/FIN-2013008-01Vermont Yankee2013Q2Improper Maintenance Rule Scoping of the Reactor Building HVAC SystemThe inspectors identified a NCV of Title 10 Code of Federal Regulations (10 CFR) 50.65(b)(2) because Entergy did not properly scope the reactor building heating, ventilation and air conditioning (HVAC) system within the stations maintenance rule program. Specifically, the inspectors determined Entergy did not properly scope the reactor building HVAC system, specific to the systems function to run and assist in area temperature control, into the maintenance rule program as required. The system is directly used in the emergency operating procedure (EOP)-4, Secondary Containment Control, to assist in mitigating a high temperature condition. The inspectors determined that this finding was more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the reliability of systems that respond to initiating events to prevent undesirable consequences. Specifically, reliably starting reactor building HVAC system could mitigate or lessen the severity of a high temperature condition in the reactor building during an event or system which requires EOP-4 entry. The performance deficiency was also determined to be similar to more than minor example 7.d per IMC 0612, Appendix E, Examples of Minor Issues. The inspectors completed a Phase 1 screening of the finding per IMC 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings, and determined the finding to be of very low safety significance (Green) because the performance deficiency was not a design or qualification deficiency, did not involve an actual loss of safety function, did not represent actual loss of a safety function of a single train for greater than its technical specification allowed outage time, and did not screen as potentially risk-significant due to a seismic, flooding, or severe weather initiating event. The inspectors did not identify a cross-cutting aspect associated with the finding because the underlying performance aspects occurred in the late 1990s and no recent operating experience was identified that would reasonably have prompted Entergy to review their scoping adequacy.
05000397/FIN-2013002-04Columbia2013Q1Failure to Obtain NRC Approval for Changes to Control Room HVAC RequirementsThe inspectors identified a non-cited violation of 10 CFR 50.59, Changes, Tests, and Experiments, because the licensee failed to obtain a license amendment, pursuant to 10 CFR 50.90, prior to implementing a change to the control room heating, ventilation and air conditioning system (HVAC). Specifically, through the course of several Final Safety Analysis Report amendments, the licensee changed the control room habitability requirements from 75 degrees Fahrenheit (F) 3 degrees F to 85 degrees F effective temperature without obtaining a license amendment. The violation was evaluated using Section 2.2.4 of the NRC Enforcement Policy, because the violation may impact the ability for the NRC to perform its regulatory oversight function. 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 to the main control room design requirements. 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 does not represent a degradation of the radiological barrier function provided for the control room and does not represent a degradation of the barrier function of the control room against smoke or a toxic atmosphere. Therefore, in accordance with Section 6.1.d of the NRC Enforcement Policy, the significance was determined to be at Severity Level IV, since the impact of the incorrect changes was evaluated as having very low safety significance by the significance determination process. This issue was entered into the licensee\'s corrective action program as AR 280119, and therefore, this violation is treated as SL-IV NCV consistent with Section 2.3.2 of the NRC Enforcement Policy. This violation did not have a cross-cutting aspect because it was strictly associated with a traditional enforcement violation
05000219/FIN-2013002-02Oyster Creek2013Q1Licensee-Identified ViolationTechnical specification 3.17.A, Control Room Heating, Ventilating, and Air Conditioning (HVAC) System , requires that The control room HVAC system shall be operable during all modes of operation. With one control room HVAC system determined inoperable, technical specification 3.17.B requires Exelon to verify once per 24 hours the partial recirculation mode of operation for the operable system, or place the operable system in the partial recirculation mode. On October 29, 2012, the B control room HVAC system experienced flow oscillations, was taken out of service and A control room HVAC system was placed in service. On November 1, 2012, Exelon operators initially declared the B control room HVAC inoperable due to the observed flow oscillations; however, Exelon operators, in error, subsequently determined that the B control room HVAC was not required to be operable in the cold shutdown mode of operation. Exelon discovered the error on November 9, 2012 during troubleshooting activities on the B control room HVAC system. Contrary to technical specification 3.17.B, Exelon did not verify or place the A control room HVAC system in the partial recirculation mode daily from October 29, 2012 until November 9, 2012. Exelon entered this issue into the corrective action program as IR 1438918. The inspectors determined that the finding was of very low safety significance (Green) in accordance with NRC IMC 0609, Appendix G, Shutdown Operations Significance Determination Process, Appendix 1, Checklist 7, because the finding did not affect core heat removal guidelines, did not affect inventory control guidelines, did not affect AC power guidelines, did not affect containment control guidelines, did not affect reactivity control guidelines and did not require a quantitative assessment.
05000305/FIN-2013002-03Kewaunee2013Q1Failure to Provide Fire Detection and Fixed Fire Suppression in a III.G.3 AreaThe inspectors identified a finding of very low safety significance and associated non-citied violation of 10 CFR Part 50, Appendix R, Section III.G.3, Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979, for the licensees failure to meet the requirement for fire detection and a fixed fire suppression system in the control room heating, ventilation, and air conditioning (HVAC) room (fire zone AX-35). Specifically, the licensee failed to provide fire detection and a fixed fire suppression system in the HVAC equipment room. The licensee entered this into the CAP as corrective actions (CA)075268 and CA08365; and CRs CR108948 and CR463976. The finding was determined to be more than minor because it was associated with the Mitigating Systems Cornerstone attribute of Protection Against External Factors (Fire), and adversely affected the Cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the lack of area-wide detection and suppression systems could increase the response time and complicate fire fighting activities. That could result in a loss of both trains of safe shutdown equipment required for safe shutdown of the plant. The inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Initial Characterization of Findings, dated July 19, 2012. Using Table 3, SDP Appendix Router, the inspectors answered Yes to Question E.2.(2), Does the finding involve fixed fire protection systems or the ability to confine a fire? because the finding involved failure to provide fire detection and fixed suppression in the control room HVAC room. As a result, the finding was evaluated using IMC 0609, Appendix F, Fire Protection Significance Determination Process, dated February 28, 2005. A detailed risk evaluation was performed by a Region III Senior Reactor Analyst (SRA), which concluded that the finding was of very low risk significance (green). The inspectors did not identify a cross-cutting aspect associated with this finding, because this was an original design issue, and the finding was not representative of current performance.
05000354/FIN-2013007-01Hope Creek2013Q1Failure to Conduct Maintenance on the CR HVAC System in Accordance with the ProcedureA self-revealing, Green NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified because PSEG failed to perform maintenance on the A control room air conditioning train in accordance with the documented procedure steps. Specifically, PSEG personnel failed to follow the maintenance procedure as written by stopping and restarting the A control room ventilation train prior to completing the monitoring period and obtaining the tuning parameters required by the procedure. PSEGs corrective actions included entering this issue into its corrective action program as notification 20575256, conducting an apparent cause investigation, restoring the system to an operable status, conducting a training needs analysis, and revising the maintenance procedure. This finding is more than minor because it is associated with the human performance attribute of the barrier integrity cornerstone, and affected the cornerstone objective maintaining the radiological barrier functionality of the control room. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 3 of IMC 0609, Appendix A, The Significance Determination Process (SDP) 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 represents a degradation of only the radiological barrier function provided for the control room. This finding has a cross-cutting aspect in the area of human performance, work control because PSEG did not appropriately control work activities by incorporating actions to address the need for work groups to communicate, coordinate, and cooperate with each other during activities in which interdepartmental coordination is necessary to assure plant and human performance. Specifically, maintenance personnel did not communicate to operations personnel that the maintenance activity was not completed or that the A control room ventilation should not be stopped and restarted.
05000354/FIN-2013007-02Hope Creek2013Q1Failure to Take Timely Corrective Action for an Identified Design Deficiency with the CR HVAC SystemThe inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, because PSEG failed to promptly correct a design deficiency in the control room chilled water circulating low flow pump trip logic. Specifically, PSEG failed to take timely action to develop and implement a modification to add a 10 second time delay to the pump trip logic. PSEGs corrective actions included entering this issue into their corrective action program as notification 20567269, conducting an apparent cause investigation, and developing and implementing design change packages to modify the low flow control room air conditioning chilled water circulating pump trip logic. This finding is more than minor because it is associated with the systems, structures, and components (SSC) and barrier performance attribute of the barrier integrity cornerstone, and affected the cornerstone objective of maintaining the radiological barrier functionality of the control room. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 3 of IMC 0609, Appendix A, The Significance Determination Process (SDP) 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 represents a degradation of only the radiological barrier function provided for the control room. This finding does not have a cross-cutting aspect associated with it because, although the performance deficiency occurred within the last three years, the performance characteristic associated with the untimely corrective action for this deficiency is not indicative of PSEGs current performance. PSEG demonstrated improved performance in response to trips of the A control room ventilation in June and July 2012 caused by chilled water pump low flow by taking timely corrective action to develop and implement a design change package for the modification to the low flow trip logic that had been identified in 2011. PSEG also identified an additional deficiency in the low flow trip logic and took timely action to correct it in mid- 2012. Additionally, since PSEG identified that a modification to the low flow pump trip logic was necessary, PSEG has implemented a new station process in the fall of 2012, ER-AA- 2001-1001, Evaluation of Equipment Reliability Strategies, to evaluate the timeliness, effectiveness, and mitigating actions of proposed strategies developed for equipment reliability based on risk significance. Based on demonstrated improved performance in recent months as well as this new station process, which would have increased the priority and accelerated the implementation of these modifications, it is unlikely that this performance deficiency would occur again under similar circumstances.
05000397/FIN-2012005-04Columbia2012Q4Failure to Perform Adequate Surveillance Testing of the Control Room Air Conditioning SystemThe inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, for the failure of the licensee to perform required surveillance testing of the control room heating, ventilation and air conditioning (HVAC) system. On October 30, 2012, the inspectors identified that the licensees procedures for testing the heat removal capability of the control room HVAC system tested the service water pump house coolers but did not test any components in the control room HVAC system. Following identification of this issue, the shift manager declared Technical Specification Surveillance Requirement 3.7.4.1 missed for both trains of control room HVAC and applied Surveillance Requirement 3.0.3 which allowed the licensee to delay declaring the limiting condition for operation not met for a limited period of time following the performance of a risk assessment. This issue was entered into the licensees corrective action program as Action Request 273408. 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 decision to test a service water pump house room cooler in place of the control room HVAC cooler was made at the time of improved standard technical specifications implementation around 1998 and was therefore not reflective of current licensee performance.
05000397/FIN-2012004-03Columbia2012Q3Failure to Maintain Adequate Procedural Guidance for Critical Switchgear Ventilation SystemsThe inspectors identified a non-cited violation of Technical Specification 5.4.1.a, Procedures, for the licensees failure to maintain adequate procedures associated with critical switchgear ventilation systems. Specifically, licensee Procedure ABN-HVAC, HVAC Trouble, Revision 10, incorrectly directs entry into Technical Specification 3.7.1, Standby Service Water (SW) System and Ultimate Heat Sink (UHS), Condition B, for periods when critical switch gear fans were out of service. As corrective action, the licensee changed the procedures to reflect the correct technical specification action statements that should be entered when critical switchgear ventilation systems are taken out of service. This issue was entered into the licensees corrective action program as Action Request AR 268099. This performance deficiency was more than minor because it adversely affected the procedural quality attribute of the Mitigating Systems Cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, the inspectors determined this finding to be of very low safety significance (Green) because it was not a deficiency or qualification deficiency, did not represent a loss of system and/or function, did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time or two separate safety systems out of service for greater than its technical specification allowed outage time, and the finding did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hours. The inspectors did not assign a cross-cutting aspect to this finding because the inadequate procedural guidance for critical switchgear ventilation systems was made in 2009 and is not reflective of current performance.
05000254/FIN-2012004-02Quad Cities2012Q3Control Room HVAC Rcu Head Bolts Not Torqued\ A self-revealed finding of very low safety significance (Green) and associated NCV of TS 5.4.1.a was identified for the licensees failure to specify torque values for the control room ventilation refrigeration condensing unit condenser head in the work instructions performed on January 19, 2012. The inspectors identified that this issue had a cross-cutting aspect in the area of Human Performance - Decision Making (H.1(b)). Inspectors determined that a contributor to this finding was that the Maintenance and Engineering Departments did not verify the assumptions or identify unintended consequences with possible variance in the interpretation and implementation of work instructions stating, tighten bolts using a crisscross pattern and good mechanical judgment, vice specifying a torque value from MA-MW-736-600. Although this work practice had been in place for years, mechanics questioned the lack of a torque value during the post leak repair to restore operability. Engineering replied with mechanical judgment rather than specifying a torque value indicating that the practice was indicative of current performance. The heat exchanger leak was repaired and the head reassembled with nominal torque values. The performance deficiency was more than minor because the performance deficiency, if left uncorrected, had the potential to lead to a more significant event. The inspectors performed an SDP Phase 1 screening for the finding using IMC 0609, Attachment 04, Initial Characterization of Findings, and IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, and answered the first four questions No. Therefore, the finding screened as very low safety significance, or Green.
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.
05000321/FIN-2012002-02Hatch2012Q1Failure to Perform an Adequate Design Modification for Replacement of the TSC Air Conditioning UnitAn unresolved item was identified to determine if a violation of regulatory requirements occurred when on December 21, 2011, the Hatch TSC climate control air condition unit tripped due to an overload condition. The cause of the overload condition was attributed to a design modification on November 11, 2011, which installed a control transformer that was undersized to maintain full system air conditioning load. From November 4 to November 10, 2011, Hatch implemented a design change to the TSC ventilation system, DCP SNC330548, Remove/Replace Cooling Coil and Condensing Unit serving TSC (1X75-B001 and 1X75-B002). On November 10, 2011, the TSC ventilation system was returned to service following replacement of the cooling coils and condensing unit. On December 21, 2011, Operations department personnel noted TSC ambient temperature was increasing and the TSC condensing units were not operating. The TSC ventilation system was restarted by resetting the cooling coil and condensing unit control circuit transformer and the licensee commenced an investigation to determine the cause of the trip. Hatch determined that the transformer for the cooling coil and condensing unit control circuit was not rated to supply full control circuit load under high load demand and that a conjectured thermostat adjustment in the TSC had resulted in the HVAC system responding to a cooling demand that exceeded the protective trip set point for the control transformer. The requirements for TSC functionality are documented in Section T 4.0 of the Hatch Unit 1 and Unit 2 technical requirements manual (TRM), Section 3.10.1. The ventilation system for filtration and climate control of the TSC is required for TSC functionality. A suitable environment must be maintained in the TSC for personnel occupancy and equipment operation during radiological events. The licensee performed a functionality assessment (CR 386124) and determined that the heat load of the condensing unit between November 10, 2011, and December 20, 2011, would require only one circuit of the dual unit cooling coil and condensing unit. This determination was made using the maximum ambient temperature recorded during the period (83F) and assuming that the TSC HVAC thermostat was set to maintain the temperature in the TSC at 75 F as recommended in the TSC activation procedure, 73EP-EIP-063-0. With only one circuit of cooling in operation, the electrical load on the control transformer is within the rating of the undersized transformer. Therefore, during this period, the licensee concluded TSC ventilation was functional for climate control of the TSC. On December 21, 2011, at 0522, Operations department personnel noted TSC ambient temperature was increasing. Hatch determined that a thermostat adjustment in the TSC had resulted in the HVAC system responding to a high load cooling demand (both cooling coils and condensing units) that exceeded the protective trip set point for the undersized control transformer. This condition prohibited the TSC ventilation system from cooling the TSC and thus the TSC ventilation system was not available to provide the required climate control function. NRC inspectors concluded since the TSC HVAC thermostat was susceptible to adjustment at any time during the period the undersized control transformer was in service, and that adjustment to the thermostat during a TSC activation could cause high cooling demand which could trip the transformer, the TSC was nonfunctional for the entire period the undersize control transformer was installed in the system. Although the TRM states that the TSC air conditioning system is required for the TSC to be functional, clarification is required by the inspectors to determine if the licensee committed to maintaining climate control for the TSC. Review of the licensees NUREG 0696, NUREG 0737, and pertinent Generic Letter responses is required to determine whether climate control affects functionality and whether this issue constitutes a violation of 10 CFR Part 50.54(q), and the planning standards in 10 CFR 50.47(b) (8). URI 05000321,366/2012002-02, Installation of a transformer for the TSC cooling coil and condensing unit control circuit not adequately designed to provide full system load.
05000387/FIN-2011003-04Susquehanna2011Q2Licensee-Identified ViolationOn January 3,2011, PPL identified that a single point vulnerability existed in the RB heating, ventilation and air conditioning (HVAC) system in which the failure of a single nonsafety-related temperature controller coincident with outside ambient air temperatures below 10 degrees-Fahrenheit could result in a spurious SLD isolation causing simultaneous isolation of MSlVs, HPCI, and RCIC. The Updated Final Safety Analysis Report (UFSAR) 3.12.2.2.a states that failure of any nonsafetyrelated SSC shall not result in failure of any safety-related SSC. Additionally, UFSAR 3.12.2.1.1 states that redundant systems are separated from each other so that single failure of a component will not interfere with the proper operation of its redundanVdiverse component. This issue was determined to be a violation of 10 CFR 50 Appendix B, Criterion lll, Design Control, because PPL failed to ensure that the design requirements specified above were correctly translated into specifications, drawings, procedures and instructions. The performance deficiency was determined to be more than minor because the finding was associated with the Mitigating Systems cornerstone attribute of Design Control, and affected the cornerstone objective to ensure the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors evaluated the finding using IMC 0609, Attachment 4, lnitial Screening and Characterization of Findings, and determined the finding was Green because it was design or qualification deficiency confirmed not to result in a loss of operability or functionality because the two required conditions had not occurred simultaneously. The issue was entered into PPL\'s CAP as CR 1337940.
05000461/FIN-2011003-03Clinton2011Q2Surveillance Testing of Control Room Ventilation SystemThe inspectors initiated an Unresolved Item pending additional review and resolution of open questions to determine whether the licensee s VC system monthly operability surveillance test procedure contained the appropriate requirements and acceptance limits for intake filtered flow rate from applicable design documents and whether operators appropriately addressed the operability of VC Train A after identifying a degraded condition that could have affected the ability of the system to perform its safety function. The inspectors reviewed the licensee s performance of surveillance testing that was accomplished in accordance with CPS 9070.01, Control Room HVAC Air Filter Package Operability Test Run, Revision 26d. This surveillance test procedure was performed to satisfy TSSRs 3.7.3.1 and 3.7.3.2, which required the licensee to operate each VC subsystem with flow through the makeup filter Y 10 continuous hours with the heater operating and with flow through the recirculation filter for Y 15 minutes, respectively. The surveillance frequency is every 31 days. As described in the Bases for TS 3.7.3, the ability of the VC system to maintain the habitability of the Control Room envelope is an explicit assumption for the safety analyses presented in the UFSAR. The high radiation mode of the VC system is assumed to operate following a design basis accident. The VC system is designed to maintain a habitable environment in the Control Room envelope for a 30-day continuous occupancy after a design basis accident, without exceeding 5 Rem total effective dose equivalent (TEDE) as required by 10 CFR 50, Appendix A, Criterion 19. The UFSAR Chapter 15 accident analyses assumed that for a design basis LOCA, the VC system intake filtered flow rate is 3000 A 10% cubic feet per minute (cfm). During testing of VC Train A on April 1, 2011, an operator noted that the filtered make up flow was oscillating between 2300 and 2880 cfm; however, as stated in Step 8.1.2.h of the test procedure, flow should have been 2700 to 3300 cfm. The operator annotated the test procedure with a note stating that the flow was low and initiated AR 01196342 to have the condition evaluated and corrected. Operators reviewed the acceptance criteria in Section 9.1 of the test procedure and did not find any upper or lower limits for flow rate. Operators noted that the Control Room differential pressure remained positive with the degraded flow condition and, therefore, concluded that VC Train A remained operable and signed off the completed test procedure as satisfactory with no further evaluation. Operators did not request a formal operability evaluation from engineering even though the VC system has a required licensing basis function and the degraded condition could have affected the ability of the system to perform its safety function. During review of the completed surveillance test procedure and AR 01196342, the inspectors questioned: (1) whether VC Train A remained operable with intake filtered flow less than design, and (2) the absence of an appropriate quantitative acceptance criterion for filtered flow rate in the test procedure to assure that the system would be capable of fulfilling its design safety function. The inspectors noted that TSSRs 3.7.3.1 and 3.7.3.2 do not specify upper or lower limits for system intake filtered flow rate, nor do any other VC system TSSRs. Only the administrative program requirement for VC system filter testing in TS 5.5.7 specifies a 3000 cfm intake filtered flow rate, but this testing is performed much less frequently (i.e., every 2 years vice every month). The inspectors reviewed CPS 9866.01, VG/VC HEPA (High Efficiency Particulate Air) Filter Leak Test, Revision 26 and noted that this procedure for system filter testing contained appropriate filtered flow acceptance criteria. Because the UFSAR Chapter 15 LOCA analyses assumes that the VC system intake filtered flow rate is 3000 A 10%, the inspectors determined that system operability would be questionable with system flow not within these limits. For determining the radiological consequences of a design basis LOCA to Control Room operators from external radiation sources, Calculation C-002, Post LOCA Control Room Operator Dose from External Sources, Revision 2, assumes the intake filtered flow rate is at the upper limit of 3300 cfm. The higher value provides a maximum value for iodine buildup in the charcoal bed under normal conditions. For determining the radiological consequences of a design basis LOCA using the alternate source term methodology, Calculation C-020, Reanalysis of Loss of Coolant Accident (LOCA) Using the Alternate Source Term Methodology, Revision 3, assumes the intake filtered flow rate is 2700 cfm. Under this analysis, the lower the flow rate the higher the dose to Control Room operators since less filtered air is being provided to the Control Room envelope. Both of the above calculations support the accident analyses to ensure that post accident dose to Control Room occupants in the event of a LOCA would be less than 5 Rem TEDE. The licensee investigated the low flow condition two weeks later on April 15th and discovered that the VC Train A flow controller was not functioning properly. The flow controller was replaced with a new one and post-maintenance testing was completed satisfactorily. The licensee documented the flow controller problem in AR 012003343 and subsequently performed a past operability evaluation. The licensee s evaluation concluded that the system remained operable with the degraded flow condition because there was sufficient margin in the Control Room post-LOCA dose analysis. The inspectors reviewed the licensee s evaluation and concluded that the results were reasonable. In response to the inspectors questions, the licensee initiated AR 01207896 to review the absence of an appropriate quantitative acceptance criterion for filtered flow rate in the surveillance test procedure. In addition, the licensee initiated AR 01239007 to perform an apparent cause evaluation addressing the timeliness of the formal operability assessment and whether the absence of appropriate acceptance criteria in Section 9.1 of CPS 9070.01 influenced the decision by licensed operators to accept the results of the surveillance test and not request a formal operability evaluation from engineering upon discovery of the degraded condition during testing. At the end of this inspection period, the licensee had just entered this issue into its corrective action program to investigate the cause and to identify appropriate corrective actions. This issue is considered to be an Unresolved Item (URI 05000461/2011003-03, Surveillance Testing of Control Room Ventilation System) pending additional review and resolution of open questions to determine: (1) whether the surveillance test procedure contained the appropriate requirements and acceptance limits for VC system intake filtered flow rate from applicable design documents, and (2) whether operators appropriately addressed the operability of VC Train A after identifying a degraded condition that could have affected the ability of the system to perform its safety function.
05000237/FIN-2011002-04Dresden2011Q1Failure to Perform Surveillance Testing on East Turbine Building Vent HVAC Smoke DetectorsThe inspectors identified a finding of very low safety significance and associated NCV of the Dresden Nuclear Power Station Renewed Facility Operating License for the licensees failure to perform adequate testing on four smoke detectors in the east turbine building ventilation system ductwork. This violation was presented to the licensee late in the inspection period and the licensee did not have time to develop corrective actions before the end of the inspection period. Using IMC 0612, Appendix B, Issue Screening, issued on January 1, 2010, the inspectors determined that this finding was more than minor. The inspectors were unable to resolve the more than minor issue based on the examples in IMC 0612, Appendix E, Examples of Minor Issues, dated August 11, 2009. The inspectors did, however, determine that the performance deficiency was associated with the Reactor Safety Mitigating Systems Cornerstone attribute of equipment performance. The failure to perform adequate testing on four smoke detectors in the east turbine building ventilation ductwork could impact the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors completed a Phase 1 significance determination of this issue using IMC 0609, Significance Determination Process, Appendix A, Attachment 0609.04, dated January 10, 2008. The inspectors determined that the finding affected fire protection defense-in-depth strategies and, therefore, per Table 3b, referred to IMC 0609, Appendix F, dated February 28, 2005. The inspectors determined that the Finding Category was Fixed Fire Protection Systems and the inspectors determined that there was a low degree of degradation since the non-functional detectors only detected smoke from a single source and there were no combustibles of concern located near the detectors. Since the degree of degradation was low, the issue screened as Green. The inspectors determined that this finding has a cross-cutting aspect in the area of Work Control because the licensee did not appropriately plan work activities by incorporating the need for planned contingencies. (H.3(a)).
05000237/FIN-2011002-03Dresden2011Q1Adequacy of Control Room Ventilation Smoke Purge FunctionThe inspectors identified an Unresolved Item regarding the adequacy of the Control Room Ventilation Smoke Purge Function. The inspectors identified that the inlet and outlet to the Control Room Ventilation A Train are within 5 feet of one another on the exterior of the turbine building. The UFSAR Section 6.4.4.3 describes the smoke purge function. The control room HVAC system is designed to isolate and maintain the design conditions within the control room during fires in either the control room or outside the emergency zone. Smoke detectors, located in the control room return air ducts, will annunciate in the control room and the Train A HVAC system will be switched manually to the smoke purge mode. During this mode, the system supplies 100% outdoor air. This will prevent the recirculation of smoke into any of the occupied areas in the event of fire while exhausting 100% of the return air to the outdoors. The smoke purge capability is only available on Train A. The UFSAR Section 6.4.4.3 states, A smoke detector in the Train A control room HVAC System outside air intake will annunciate and the Train A HVAC system will be manually switched to the recirculation mode. This will prevent the intake of smoke into the control room envelope in the event of an outside fire adjacent to the Train A HVAC system outside air intake. This statement is only partially correct. The smoke detector will also prevent the ventilation system from entering the smoke purge mode and will automatically take the system out of the smoke purge mode if it detects smoke. To completely isolate the control room from outside smoke takes manual action. The licensing basis and adequacy of design of the control room ventilation smoke purge function due to the location of the system inlet and outlet is an Unresolved Item pending additional inspector review. (URI 05000237/2011002-03; 05000249/2011002-03)
05000237/FIN-2011002-01Dresden2011Q1Satisfactory Performance of a Surveillance Test Procedure That Was Later Demonstrated to be Not Capable of Being PerformedThe inspectors identified a non-cited violation (NCV) of the Dresden Nuclear Power Station Renewed Facility Operating License having very low safety significance (Green) for the licensees failure to perform adequate post-maintenance testing (PMT) on one smoke detector in the Control Room Ventilation System ductwork. During a walkdown of the Control Room Ventilation System, the inspectors identified that three smoke detectors in the ventilation ducts had been replaced in June 2010 and one was never tested successfully upon its return to service. During the course of this inspection, the inspectors identified several procedure quality issues. The inspectors reviewed WO 902046-01,D2/3 Annual PM Control Room HVAC System Smoke Detector Test, performed on November 25, 2008. This work order was to perform surveillance test DFPS 4183-14, Unit 2/3 Control Room HVAC Smoke Detector Annual Surveillance Procedure, Revision 9. The test results identified that Alarm 2/3-2223-89-C1, Control Room/East Turbine Building Smoke Detector Trouble, would not alarm when the following detectors were sprayed with test gas: Fn2/3-8941-017, Located in the Control Room Main Return Duct; Fn2/3-8941-018, Located in the Control Room HVAC Equipment Room Train B Exhaust Duct; and Fn2/3-8941-013, Located on the Main Control Room HVACX outside air supply duct. The 2/3-2223-89-C1, Control Room/East Turbine Building Smoke Detector Trouble, alarms at Panel 2/3-2223-89 in the Unit 2 switchgear room if a detector loses power. Other alarms at Panel 2/3-2223-89 and in the Control Room alarmed when the detectors were sprayed with test gas. The licensee wrote Issue Report (IR) 849580, Problems Encountered during Performance of DFPS 4183-14, to document the issue. The problem with the test procedure, in this case, was that per DFPS 4183-14 the 2/3-2223-89-C1 alarm was expected to annunciate when the detector was sprayed with test gas. As mentioned above, the 2/3-2223-89-C1 alarm is not designed to annunciate when sprayed with test gas but only when the detector loses power. This was not recognized by the licensee at the time even though the 2/3-2223-89-C1 alarm had not annunciated during the performance of DFPS 4183-14 since the first performance of the surveillance test in 2006. (See paragraph 4OA2.3 for more detail.) The licensee generated WO 1191692-01, Problems Encountered During Performance of DFPS 4183-14, to troubleshoot the failure of 2/3-2223-89-C1 to alarm when sprayed with test gas. The result of this work order was that all three smoke detectors needed to be replaced. This was documented in IR 957560, Three Smoke Detectors Require Replacement. Issue Report 957560 stated that the scope of work requested was to touch jumper between terminal 9 and 10 of each detector to determine if annunciator 2/3-2223-89-C1 alarmed. The author of the IR stated that annunciator 2/3-2223-89-C1 alarmed for each smoke detector and, therefore, the detectors were bad and needed to be replaced. In this case, the troubleshooting procedure did not identify that the cause of the failure of the 2/3-2223-89-C1 alarm to annunciate was a design issue and not an equipment issue. This was not recognized by the licensee at the time. However, surveillance test DFPS 4183-14 was performed again, per WO 1191661-01, D2/3 Annual PM Control Room HVAC System Smoke Detector Test, on February 3, 2010, this time with no issues regarding annunciator 2/3-2223-89-C1. The inspectors questioned how this could happen since the detectors, identified as bad in IR 957560 had yet not been replaced and no work had been performed on any of the smoke detectors in question. The system manager explained that steps within DFPS 4183-14 did not require the verification that annunciator 2/3-2223-89-C1 ever extinguished. Therefore, if the annunciator was in alarm at the beginning of the surveillance test, for whatever reason, then the test would have passed without issue. This issue would make DFPS 4183-14 inadequate because the surveillance could have passed without proper equipment operation. The inspectors searched and reviewed operator logs and corrective action program documents to determine if annunciator 2/3-2223-89-C1 was in alarm at the time the surveillance test was performed on February 3, 2010, and found no log entries or issue reports that would indicate that annunciator 2/3-2223-89-C1 was in alarm. The inspectors re-reviewed WO 1191661-01 and identified that there were separate steps to verify the annunciators on the 923-5 panel in the control room and the 2/3-2223-89 panel in the U2 switchgear room were reset after each individual smoke detector was tested. If the 2/3-2223-89 panel C1 alarm was in at the beginning of the test and would not extinguish, this should have been noted in the WO and/or in an IR. The inspectors concluded that this was not a valid explanation. The licensee performed fact finding based on the inspectors questions why this surveillance test passed when it should not have. The inspectors discussed the fact finding results with the licensee manager that performed the fact finding on April 6, 2011. The licensee found no explanation why the test passed. The individual that performed the test stated that the performance of that specific test could not be recalled. The satisfactory performance of DFPS 4183-14 on February 3, 2010, was unexplained. The unexplained satisfactory performance of a surveillance test procedure, that was later demonstrated to be not capable of being performed as written, was an Unresolved Item pending inspector review of additional licensee evaluation. (URI 05000237/2011002-01; 05000249/2011002-01) The inspectors reviewed WO 1264824-04, Three Smoke Detectors Require Replacement, performed on June 11, 2010, in which the smoke detectors were replaced and were to be post-maintenance tested. Smoke detector 2/3-8941-013, located on the Main Control Room HVAC outside air supply duct, was replaced but was not tested. The function of detector 2/3-8941-013 was to prevent or reposition ventilation dampers such that if smoke was detected coming into the building from outside, the smoke purge function of the control room ventilation system would be prevented. The WO stated that the dampers would not reposition to the smoke purge position, therefore, smoke detector 2/3-8941-013 could not be tested. This also meant that the control room ventilation smoke purge capability was non-functional. The smoke purge capability was still non-functional at the end of the inspection period. Troubleshooting was ongoing as of April 12, 2011, and the extent of the problems with smoke purge was unknown so there was no scheduled repair date. The smoke detector alarming in the control room should also result in manually switching to the isolation mode to prevent further smoke from entering the control room. The isolation dampers were separate for the smoke purge dampers and were functional. The inspectors determined the smoke purge control capability of detector 2/3-8941-013 could not be tested but the alarm function could have been tested and was not.
05000387/FIN-2010005-08Susquehanna2010Q4Licensee-Identified ViolationPPL CRs 1072993 and 1091573 (September and November 2008) questioned the configuration and TS aspects of the Susquehanna secondary containment airlock dampers. Further evaluation was conducted in CR 1095433. CRs 1072993 and 1091573 questioned whether the airlock dampers were Zone III containment isolation valves (they are listed in Table B. 3.6.4.2-1 as secondary containment system automatic isolation dampers) and noted they were not consistent with the FSAR design description of two dampers in series powered from independent trains. Per the FSAR, the only safety-related function of the RB heating, ventilation, and air-conditioning (HVAC) system is the automatic isolation function on high drywell pressure, low reactor vessel level, and high radiation in the refuel floor exhaust duct or railroad access shaft. Thus, only the Zone III automatic isolation dampers in the HVAC system would be considered SCIVs. The evaluation identified that for most airlocks, the series isolation valves separate the safety-related and nonsafety-related sides of the Zone III ventilation piping (HD 17502 A&B for Unit 1 and HD 27502 A&B for Unit 2). Thus, the airlock dampers do not perform the Zone III isolation function in these cases and the FSAR design basis does not apply. This is consistent with the guidance in NUREG 800, NRC Standard Review Plan. However for airlocks I-707 and II-707, the ducting from those airlocks is routed downstream of the HD 17502 or 27502 dampers (the nonsafety-related side) and therefore HD 17534 C for Unit 1 and HD 27534 C for Unit 2 in conjunction with the outer airlock door provide isolation of the safety-related and nonsafety-related side to the system. Thus, the damper/door pair perform the Zone III isolation function. Therefore, HD 17534 C and 27534 C are Zone III isolations valves and are SCIVs. This design is not consistent with the FSAR design basis and TS Limiting Condition for Operation (LCO) Action Statement for TS 3.6.4.2 should be entered when either the outer airlock door or damper for the I-707 and II-707 airlocks are inoperable for maintenance. CR 1095433 conducted a past operability review and identified that door 715 of airlock I-707 was propped open between September 9, 2003 and September 10, 2003 and door 716 of airlock II-707 was proper open between January 21, 2003 and April 18, 2003. Both of these instances exceeded the TS 3.6.4.2 Action Statement LCO time limits and would have required the plant be shut down to Mode 4 until the secondary containment isolation damper/door pair could be restored to an operable status or failed in the closed position. Therefore, PPL had operated in a condition prohibited by TS on two occasions in 2003. CR 1095433 also conducted a review for reportability. PPL correctly determined that 10 CFR 50.73 only requires an LER to be submitted for events which occurred within three year of the date of discovery unless the event involved an actuation of the RPS while the reactor was critical. Thus, an LER was not required. Operating in a condition prohibited by TS is a performance deficiency that was reasonably within PPLs ability to foresee and prevent. The issue is more than minor since it affects the configuration control attribute of the Barrier Integrity cornerstone objective to provide reasonable assurance that physical design barriers (fuel cladding, reactor coolant system (RCS), and containment) protect the public from radionuclide releases caused by accidents or events. Specifically, the performance deficiency represented a non-secured penetration in secondary containment. The issue screens to very low safety-significance (Green) when evaluated using IMC 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, because the finding only impacts secondary containment, does not affect the integrity of primary containment, and did not represent an actual open pathway. This issue is documented in PPL CAP as CR 1334937.
05000269/FIN-2010009-02Oconee2010Q4Failure to Adequately Monitor Performance of the Standby Shutdown Facility HVAC System as Required by 10 CFR 50.65An NRC-identified non-cited violation of 10 CFR 50.65(a)(2), was identified for failure to demonstrate that Standby Shutdown Facility (SSF) Ventilation system performance was being effectively controlled through the preventive maintenance (PM) program, or place the system in 10 CFR 50.65(a)(1) status due to SSF Heating Ventilation and Air Conditioning (HVAC) system maintenance rule functional failures beyond established performance criteria. The failure to perform adequate performance or condition monitoring on the SSF HVAC system was a performance deficiency (PD). This PD was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective in that the licensee failed to demonstrate effective control of the SSF HVAC system through appropriate preventive maintenance. The finding was determined to have very low safety significance (Green) because it did not result in the actual loss of safety function of one or more non-Technical Specification equipment trains, designated as risk-significant per 10CFR50.65, for greater than 24 hours. The cause of the finding was directly related to the human performance crosscutting aspect associated with resources, for the licensee not ensuring their maintenance rule procedures were adequate to provide clear and accurate directions on how to classify functional failures.
05000255/FIN-2010004-05Palisades2010Q3Ground on Preferred AC Bus due to Improperly Installed Electrical BushingThe inspectors identified a finding of very low safety significance (Green) and associated NCV of 10 CFR 50 Appendix B, Criterion V for failure to accomplish activities affecting quality as prescribed by the documented instructions, procedures, or drawings. Specifically, the licensee replaced a solenoid valve on a safety-related chiller in a manner that permitted a ground to develop on a preferred electrical bus after two years of operations. The licensee repaired the solenoid valve and entered the issue into the CAP as CR-PLP-2010-03234. The issue was more than minor because it adversely affected the Equipment Performance attribute of the Mitigating Systems Cornerstone, whose objective is to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the ground reduced the reliability of the associated safety-related electrical bus. Further, correction of the ground rendered the control room Heating, Ventilation and Air Conditioning (HVAC) chiller inoperable. The finding screened as Green because there was no loss of system safety function. The licensee determined the cause to be an improperly tightened electrical bushing, and that the proper tightening of bushings was part of electrical maintenance training. Therefore, human error prevention techniques used by the craft during assembly were not sufficient to preclude the bushing from being improperly tightened.
05000461/FIN-2009005-05Clinton2009Q4Changes to EAL HU6 Potentially Decrease the Effectiveness of the Plans without Prior NRC ApprovalThe inspectors reviewed changes implemented to the Clinton Station Radiological Emergency Plan Annex EALs and EAL Basis. In Revision 12, the licensee changed the basis of EAL HU6, Fire not extinguished within 15 minutes of detection within the protected area boundary by adding two statements. The two changes added to the EAL basis stated that if the alarm could not be verified by redundant control room or nearby fire panel indications, notification from the field that a fire exists starts the 15-minute classification and fire extinguishment clocks. The second change stated the 15-minute period to extinguish the fire does not start until either the fire alarm is verified to be valid by additional control room or nearby fire panel instrumentation, or upon notification of a fire from the field. These statements conflict with the previous Clinton Station Annex, Revision 11, basis statements and potentially decrease the effectiveness of the Plans. Clinton Station Radiological Emergency Plan Annex, Revision 11, EAL HU6 initiating condition stated, Fire not extinguished within 15 minutes of detection, or explosion, within the protected area boundary. The threshold values for HU6 were, in part: 1) Fire in any Table H2 area not extinguished within 15 minutes of Control Room notification or verification of a Control Room alarm, or 2) Fire outside any Table H2 area with the potential to damage safety systems in any Table H2 area not extinguished within 15 minutes of Control Room notification or verification of a Control Room alarm. Table H2, Vital Areas, were identified as containment, auxiliary building, fuel building, control building (excluding chemistry lab), diesel generator and HVAC building, and screenhouse. The basis defined fire as combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fires. Observation of flame is preferred but is not required if large quantities of smoke and heat are observed. The basis for Revision 11, EAL HU6 thresholds 1 and 2 stated, in part, the purpose of this threshold is to address the magnitude and extent of fires that may be potentially significant precursors to damage to safety systems. As used here, notification is visual observation and report by plant personnel or sensor alarm indication. The 15-minute period begins with a credible notification that a fire is occurring or indication of a valid fire detection system alarm. A verified alarm is assumed to be an indication of a fire unless personnel dispatched to the scene disprove the alarm within the 15-minute period. The report, however, shall not be required to verify the alarm. The intent of the 15-minute period is to size the fire and discriminate against small fires that are readily extinguished (e.g., smoldering waste paper basket, etc.). Revision 12 of the Clinton Station Radiological Emergency Plan Annex, changed the threshold basis for EAL HU6 by adding the following two statements: 1) If the alarm cannot be verified by redundant control room or nearby fire panel indications, notification from the field that a fire exists starts the 15-minute classification and fire extinguishment clocks, and 2) The 15-minute period to extinguish the fire does not start until either the fire alarm is verified to be valid by utilization of additional control room or nearby fire panel instrumentation, or upon notification of a fire from the field. The two statements added to the basis in Revision 12 conflict with the Revision 11 threshold basis and initiating condition. The changed threshold basis in Revision 12 could add an indeterminate amount of time to declaring an actual emergency until a person responded to the area of the fire and made a notification to the control room of a fire in the event that redundant control room or nearby fire panel indications were not available. Pending further review and verification by the NRC to determine if the changes to EAL HU6 threshold basis potentially decreased the effectiveness of the Plans, this issue was considered an Unresolved Item (URI 05000461/2009005-05)
05000255/FIN-2009006-02Palisades2009Q4Failure to Translate the Design Basis for the CV-11 Control Room HVAC Chiller Into Specifications and DrawingsA finding of very low safety-significance (Green) and associated NCV of 10 CFR Part 50, Appendix B, Criterion III, Design Control, was identified by the inspectors for the licensees failure to translate and incorporate design basis criteria that ensured the functionality of TDRs for the CR HVAC chillers into design drawings, procedures and work instructions for implementation. Specifically, even though the licensee reduced the replacement interval frequency for the chiller mounted TDRs due to high vibration levels to ensure functionality, and then initiated Work Orders (WOs) to perform this replacement, one WO was closed without replacing the TDRs as intended, and the second WO was not approved for implementation. This issue was entered into the licensees corrective action program. The inspectors determined that the finding was more than minor because this failure to establish measures to translate and incorporate design basis criteria to ensure the functionality of TDRs for the CR HVAC chillers could lead to the inability of the chillers to respond to design basis events. Specifically, the finding screened as of very low safety-significance (Green) because the finding did not represent loss of system safety function. This finding has an associated cross-cutting aspect in the area of problem identification and resolution because the licensee failed to thoroughly evaluate problems such as that the resolution addresses causes and extent of condition, as necessary. This includes properly evaluating for operability conditions adverse to quality. P.1(c)
05000263/FIN-2009007-06Monticello2009Q4Inadequate Tornado Missile Protection for the EDG System ComponentsThe inspectors identified an unresolved item (URI) regarding the design and licensing basis for the standby diesel generator (EDG) building ventilation system and whether the ventilating system had to be protected from the effects of a design basis tornado. During a walkdown of the EDG building, the inspectors noted that temperature control dampers in the ventilation system were mounted flush with the outside walls of the building with only a metal grating serving as a barrier for tornado missiles. The inspectors questioned the adequacy of the design and received the licensee position that the EDG building was a Class 1 building designed to protect the EDG and the fuel oil day tank from tornado missiles. However, the licensee stated that the temperature control dampers and ventilation fans (V-SF-9 and - 10) were not designed to be protected from a tornado missile. The licensee stated that the designer and the licensee intended on protecting Class 1 equipment required to assure safe-shutdown of the reactor from a missile event based on the credibility of the missile. The licensee agreed that the ventilation fans were necessary for the EDGs to be operable and that the EDGs could only run for a short period of time without the fans running. However, the licensee maintained that the EDGs could perform their safe-shutdown function without the ventilation fans. The inspectors disagreed as the EDGs could not run long enough to shut the reactor down, remove latent and decay heat, and maintain the reactor in a cold shutdown condition following the loss of the EDG ventilation systems. The licensee maintained that a single missile could not take out both fans as a full height reinforced concrete wall separated the two ventilation systems. The inspectors reviewed the original design submittal (NSP-1 dated October 17, 1969), and found that the Class 1 equipment included the Standby Diesel Generator System, and the Emergency Buses and other electrical gear to and including power equipment required for safe-shutdown. The ventilation systems were not included in the list of Class 1 equipment or in the list of Class 2 equipment. However, the licensee believed the ventilation systems were considered Class 2 based on the last entry in the Class 2 list: All Other Piping and Equipment not listed under Class 1. After further research, the licensee stated that there was no specific statement regarding the EDG building ventilation in any licensing document. The inspectors identified the following statements in various licensing documents. Section 2.2.4, Standby Diesel Generating Building, of the USAR stated, the principal function of this building is to provide a safe enclosure and protection for the Enclosure 22 standby diesel generators and portions of the power distribution systems enclosed therein. Section 2.2.4.1, Structure Description, stated, in part, A north-south (sic) interior wall of reinforced concrete extends the full height of the structure providing physical separation of the diesel generator systems. The original Monticello SER, Section 3.1.2, Meteorology, stated, in part, that the facility structures and systems, which are necessary for a safe-shutdown of the reactor are designed to withstand the effects of wind loadings and potential missiles resulting from a tornado. In the current Revision 25 of the USAR the inspectors noted the following: Section 8.4.1.1, Design Basis, stated that two independent EDGs provide redundant standby power sources. Section 8.4.1.1.b stated, The EDG sets shall be complete package units with all auxiliaries necessary to make them self-sufficient power sources capable of automatic start at any time and capable of continued operation at rated full load voltage and frequency until either manually or automatically stopped. Section 8.4.1.1.d stated, The EDGs shall be located in Class 1 structures. Section I.4.3.14, HVAC Systems, stated: The only HVAC Equipment required for safe-shutdown are the ECCS Room Coolers, V-AC-5 (Division I) and V-AC-4 (Division II), located in respective Reactor Building corner rooms on the 920-foot elevation, and the EDG supply fan, V-SF-9 for EDG No. 12, and V-SF-10 for EDG No.11. USAR Table J.4.5-1, Appendix R Safe-shutdown Equipment List, identified fans V-SF-9 and -10 as safe-shutdown equipment. The inspectors concluded that the EDG ventilation fans were an auxiliary necessary for the EDG system and that the term EDGs in the USAR included all of the auxiliaries for the EDGs; therefore, the ventilation fans were necessary for safe-shutdown of the reactor (to achieve and maintain cold shutdown). Based on no actual licensing document specifically mentioning the EDG ventilation, the necessity of the fans for EDG operability, the USAR references to the fans being safe-shutdown equipment, and the NSP-1 statement that the full-height wall separated the EDG systems, the inspectors concluded that the fans and temperature control dampers should be considered Class 1 equipment and should have been protected from tornado missiles, as well as the effects of tornadoes on the ventilation ducts as described in RIS 2006-023, Post Tornado Operability of Ventilating and Air Conditioning Systems Housed in Emergency Diesel Generator Rooms. However, because this issue was not clearly defined in the original licensing documents, this will be an unresolved item pending consultation with NRC headquarters for clarification of whether the EDG building ventilation was or was not required to be a Class 1 system. (URI 05000263/2009007-006
05000440/FIN-2009007-01Perry2009Q2Failure to Maintain Procedures for Post-Fire Operation of Control Room HVAC Fans and Control of Remote Shutdown Room Toolbox InventoryThe inspectors identified a finding of very low safety-significance and associated NCV of Technical Specification (TS) 5.4.1a for failure to maintain procedures for post-fire operation of control room heating, ventilation, and air conditioning (HVAC) Train A fans and for control of the Division 1 remote shutdown room toolbox inventory. Specifically, Procedure ARI-H13-P904-0001-B6, Control Room HVAC Train A Tripped, stated that if a fire has occurred and the Train A fans have tripped, then restart the Train A fans in emergency recirculation mode. The correct action was to restore Train B fans in emergency recirculation mode. In addition, Procedure IOI-11 Control Room Isolation, Attachment 20, contained a list of equipment operators were to obtain from the toolbox, located by the alternate remote shutdown panel, following a control room fire. The list included nine items; one of the items consisting of three FRS-R 4-Amp fuses was missing. The procedure should have been revised to remove the requirement to obtain the fuses. The licensee entered this finding into their corrective action program as CR 09-60317 and CR 09-60373.The finding was determined to be more than minor because the finding was associated with the mitigating system cornerstone attribute of procedure quality and affected the cornerstones objective of ensuring the capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to maintain the procedures could have complicated plant safe shutdown in the event of a fire. The inspectors determined that the finding was of very low safety-significance since the procedure deficiencies did not substantially impact performance in the event of a fire
05000255/FIN-2008005-01Palisades2008Q4Inadequate Testing of Control Room ChillersThe inspectors identified a finding of very low safety significance (Green) and an associated NCV of 10 CFR 50, Appendix B, Criterion XI, Test Control, for the inadequate testing of the heat removal capacity of the Control Room Heating, Ventilation, and Air Conditioning (CR HVAC) system. Specifically, the licensee isolated refrigerant hot gas bypass flow during the test which increased the heat removal capability of the chiller. The licensee entered the issue into their corrective action program as condition report (CR) PLP-2008-3993 and re-performed portions of the engineering basis calculation to demonstrate margin to account for the hot gas bypass flow. The finding is more than minor because, in accordance with IMC 0612, Appendix E, Examples of Minor Issues, the inspectors determined that the finding was similar to Example E.3.j and resulted in a reasonable doubt as to the operability of the chiller. Based upon a review of the licensees revised calculation for the CR HVAC system acceptance criteria and the Technical Specification (TS) requirements, the finding screens as very low safety significance (Green) using the Phase 1 SDP worksheets. The inspectors determined that the finding included a cross-cutting aspect in the area of human performance, resources, and complete and accurate procedures (H.2(c)) because the surveillance procedure unacceptably preconditioned the chiller. (1R15
05000327/FIN-2008006-01Sequoyah2008Q2Fire Detectors in 480 V Shutdown Board Room 2B2 Not Installed According to NFPA CodeA Green NCV of Unit 2 License Condition 13, Fire Protection, was identified since fire detectors in the Unit 2 480 Volt shutdown board room 2B2 were not installed according to the applicable National Fire Protection Association code. Specifically, two detectors were located near forced ventilation fresh air inlets. The licensee entered this issue into their corrective action program and promptly posted a continuous fire watch in the fire area. This finding is a performance deficiency because the licensee did not properly locate the smoke detector or the heating, ventilating and air conditioning (HVAC) system supply air inlet registers to adequately comply with the applicable industry code of record for the facility. As a result two of the four smoke detectors would not be effective in detecting fires. The finding is more than minor because it is associated with the reactor safety, mitigating systems, cornerstone attribute of protection against external factors, i.e. fire, and it substantially affects the objective of ensuring reliability and capability of systems that respond to initiating events. Considering the degree of system degradation, the length of time the problem existed, the calculated fire frequency for the fire area and shutdown systems independent of the fire area the finding was of very low safety significance
05000498/FIN-2008002-01South Texas2008Q2CRE HVAC Makeup Fan 11B Failure to StartThe inspectors reviewed a self-revealing noncited violation of 10 CFR Part 50, Appendix B, Criteria III, for an inadequate design control package that resulted in incorrect instantaneous over current breaker trip point settings. On September 11, 2006, control room envelope heating, ventilation, and air conditioning make up Fan 11B failed to start due to an incorrect instantaneous over current breaker setting, set as part of Design Change Package 98-687-4. When the package was prepared the Class 1E design criteria that was in effect led the licensee to set the instantaneous over current breaker settings based on locked rotor nameplate data G motors. Because the locked rotor nameplate data of the motor control fed motors were not documented the licensee failed to identify that some of the motors were locked rotor nameplate data J motors. As a result, the breaker trip point setting was set too low leaving some motors susceptible to spurious tripping since the implementation of the change in 2000. Further investigation revealed several missed opportunities in previous years to identify the incorrect settings, resulted from human performance and program and process issues. There are no crosscutting aspects since the issue is greater than 2 years old and the licensees processes have changed considerably between 1998 and 2006. This finding was more than minor because it affected the Barrier Integrity attribute of structure, system, and component and barrier performance under maintaining the radiological barrier function of the control room and it affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events by maintaining the operational capability of the control room envelope heating, ventilation, and air conditioning boundary. Using the Significance Determination Process Phase 1 worksheets the finding was determined to have very low safety significance because the finding only represented a degradation of the radiological barrier function of the control room (Section 40A3)
05000280/FIN-2008002-04Surry2008Q1Licensee-Identified ViolationSurry Power Station (SPS) Operating License Condition 3.I states, in part, that the Licensee shall implement and maintain in effect the provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report. Branch Technical Position (BTP) Chemical Engineering Branch (CMEB) 9.5-1, which incorporated the guidance of Appendix A to BTP Auxiliary Systems Branch (ASB) 9.5-1 and the technical requirements of Appendix R to 10 CFR Part 50, established the regulatory and licensing requirements for the fire protection program at SPS. Section 9.10.1 of the UFSAR states, in part, Compliance with these criteria is contained in the following documents: Fire Protection Program document. Section 6.1.o of VPAP-2401, Fire Protection Program, Rev. 28, states that penetration seals must provide equal or greater fire rating than that of the fire barrier. Contrary to the above, the licensee failed to have any sealant providing a fire rating in two fire penetrations in the block walls that separate the Unit 1 and Unit 2 Main Control Room HVAC rooms (Fire Area 5) from the north stairwell (Fire Area 68). This violation is of very low safety significance because the violation did not affect ignition frequencies, detection, or suppression system performance. This issue was entered into the licensees corrective action program as CR 090704
05000324/FIN-2007006-01Brunswick2007Q4Capability of Emergency Diesel Generators to Meet Design and Licensing RequirementsThe team identified an Unresolved Item (URI) for failure to translate a key analytical assumption related to operation of the back draft and check dampers into specifications and ultimately into the installed hardware. The teams review of design calculation 0VA- 0033, Tornado Analysis of Diesel Generating Building, Rev. 1 identified the following concerns: nAssumption 7 of this calculation stated that the back draft/check dampers are assumed open in the normal outward flow direction during an atmospheric depressurization event associated with a tornado. The assumption also states that during the subsequent atmospheric repressurization associated with a tornado, the back draft/check dampers would open in the reverse direction to allow reverse inward flow when the Differential Pressure (dP) across damper exceeds 80 psf. There was no surveillance to verify the ability of the back draft/check dampers to open in reverse direction. Furthermore, the teams review of specification 226-002, Sheet Metal Work, Rev. 12; drawings SHW-D-10490, SHW P 2230 Backdraft Damper w/Extra Deep Frame, Rev. C and 9527-01-4283, Technocheck Valve, Rev. 0 (check damper); walk down observations; and interviews with plant personnel identified that the installed back draft and check dampers could not open in the reverse direction. Therefore, conclusions of the calculation 0VA-0033 about the maximum dPs for the structures and the ductwork were not valid or conservative. nAdditionally, this calculation and the design specification failed to address the effects of the high dP predicted in this calculation on the EDG building HVAC hardware other than the ductwork (e.g., in-line fans, recirculation dampers, etc). Progress Energy had not verified that the specified assumptions were translated into the procured and installed HVAC hardware for the EDG building. The analysis for the EDG building HVAC system did not assure that the critical analytical assumption were implemented; thus making it undetermined that the EDG building HVAC system, that serviced all four (4) EDGs for both units of Brunswick Nuclear Plant, would function during and following the design basis tornado. This condition has existed since original plant licensing. This finding was entered into the licensees corrective action program as NCR 00259088 with actions to evaluate the ability of the EDGs actual installed equipment to satisfy the intended safety function during and following the design basis tornado event. This issue is identified as URI 05000325/2007006, 05000324/2007006- 01, Capability of Emergency Diesel Generators to Meet Design and Licensing Requirements. This item is unresolved pending NRC review of the of the licensees analysis of the effects of the as-built configuration on the EDG building HVACs ability to satisfy the intended safety function during and following the design basis tornado event.
05000327/FIN-2007006-01Sequoyah2007Q3Failure to Use Appropriate Assumptions in Design CalculationsThe team identified a violation of 10 CFR 50, Appendix B, Criterion III, Design Control, associated with TVAs failure to use appropriate assumptions in design calculations at the Sequoyah Nuclear Plant. TVAs failure to use appropriate assumptions in design calculations resulted in a significant increase in the calculated maximum room temperatures for the Emergency Core Cooling System pump rooms as well as the TDAFW pump room. This increase in the calculated maximum room temperatures led to a reasonable doubt about the operability of components in the affected rooms. Description. Design Criteria Document SQN-DC-V-13.9.3, Auxiliary Building Ventilation and Cooling, Table T1.34 established the design temperatures for the TDAFW pump room for normal and abnormal conditions. This document established a maximum room temperature of 110 F for an abnormal operational event. TVA calculation SQN-31CD053- EPM-RG-060987, Revision 2 was developed, in part, to determine if the capacity of the installed direct current (DC) fan equipment for the TDAFW pump was adequate to maintain the maximum design temperature of 110 F specified in the design criteria document. The calculation determined the air temperature needed to maintain the abnormal design temperature based on the heat input load calculated in SQN-31CD053- EPM-DLM01-030887, HVAC Cooling Load Calculation: Aux. Bldg. TDAFW pump, Revision 2 and determined an inlet air temperature of 80 F. Based on a preliminary calculation, the installed fan would maintain the TDAFW pump room at 131 F instead of 110 F. This issue was entered into the CAP as PER 126928. A review of the environmental qualification (EQ) list of equipment inside that room indicated that the equipment is qualified to at an ambient temperature of 215 F which is higher than the 110F specified in the design criteria document. Another design calculation with inappropriate assumptions was Engineered Safety Features (EFS) room cooler calculation, 30-DO53-EPM-BVC-052788, Emergency Raw Cooling Water (ERCW) River Water Temperatures Effect on ESF Coolers, Rev. 7. The incorrect assumption was the use of input cooler air flow rates that were higher than the minimum design flow rate. In this case, the non conservative nominal value of 4933 cubic feet per minute (CFM) was used as opposed to the minimum design airflow rate of 4439 CFM in order to calculate maximum accident room temperature. Deficient assumptions included using an ERCW supply temperature and flow rate that were not worst case for the calculations. As a result of the use of non conservative input values in the ESF maximum room temperature calculations, the installed room coolers were not capable of maintaining the analyzed temperatures for the ESF rooms. The licensee performed a preliminary calculation which showed a significant reduction in margin between the calculated maximum room temperatures and design limits. In the case of the 1B-B Centrifugal Charging Pump (CCP) room, the design temperature limit was exceeded by .6 degrees. The team determined the 1B-B CCP to be operable because of additional margin available with respect to environmental qualification. Analysis. The TVA\'s failure to use appropriate assumptions for ESF and TDAFW pump maximum room temperature calculations is a performance deficiency associated with the Mitigating Systems cornerstone. This finding is more than minor because if left uncorrected problems in Design Control could lead to a more serious safety concern as many other safety-related design calculations rely upon these design outputs. This finding was reviewed for cross-cutting aspects and none were identified.
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