2011 Reactor Actions
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On December 27, 2011, the NRC issued a Notice of Violation to Carolina Power and Light Company for a violation of Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion XVI, “Corrective Action,” associated with a White Significance Determination Process finding involving the failure of Brunswick personnel to promptly identify and correct a condition adverse to quality involving the external flood barrier for the emergency diesel generator fuel oil tank rooms as of April 20, 2011. Specifically, the entrance enclosures which house the emergency diesel generator fuel oil tanks had several openings, unsealed pinholes, and a narrow gap along the perimeter of the base walls, which would allow water intrusion into the emergency diesel generator fuel oil tank rooms during a design basis external event (hurricane).
On December 20, 2011, the NRC issued a Notice of Violation to Progress Energy for a violation of 10 CFR 50.54(q) associated with a White Significance Determination Process finding involving the failure of Crystal River personnel to maintain in effect a standard emergency classification scheme which included facility effluent parameters. Specifically, for several years prior to June 2011, the General Emergency classification contained effluent radiation monitors threshold values greater than that which the instruments could accurately measure. During an actual emergency, these monitors would have been relied upon to determine initial offsite response measures, to assess the impact of the release of radioactive materials, and to provide criteria for determining the need for notification and participation of local and State agencies.
On December 8, 2011, the NRC issued a White Significance Determination Process finding and a Notice of Violations for two violations to Exelon Generation Company, LLC. as a result of inspections at the Limerick Generating Station, Unit 2. The White finding was based on the failure to ensure that sufficient technical guidance was contained in an operating procedure. This failure resulted in two valves failing to fully shut, which rendered two reactor systems inoperable for greater than the Technical Specification allowed outage time. The two violations are based on the Licensee’s failure to: 1) establish adequate procedures; and, 2) exceeding Technical Specifications for two reactor systems.
On December 6, 2011, the NRC issued a Notice of Violation to Duke Energy Carolinas, LLC for a violation of Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion III, “Design Control,” associated with a Yellow Significance Determination Process finding involving Duke Energy’s failure to perform a review for suitability of application of equipment essential to safety-related functions of structures, systems, and components. Specifically, Oconee personnel failed to maintain the Standby Shutdown Facility pressurizer heater breakers and associated electrical components in accordance with the licensing and design basis of the plant, which resulted in the Standby Shutdown Facility being inoperable from 1983, until June 1, 2011.
On November 21, 2011, the NRC issued a Notice of Violation to Entergy Nuclear Operations, Inc. for a violation of Technical Specification 5.4, “Procedures,” associated with a White Significance Determination Process finding involving multiple examples of Entergy’s failure to conduct safety-related activities as described in written procedures prior to and during a reactor startup operation. Specifically, on May 10, 2011, Pilgrim personnel failed to implement conduct of operations and reactivity control standards and procedures during a reactor startup which resulted in a reactor scram.
On November 17, 2011, the NRC issued a White finding to Entergy Operations, Inc. as a result of inspections at the Waterford Steam Electric Station Unit 3. The White finding involved the failure to use effective engineering controls to prevent leakage from reactor coolant pump seals to surrounding areas. This failure resulted in high levels of contamination which caused unexpected and unintended radiation doses to plant workers during outage activities. There were no NRC violations associated with the finding.
On August 25, 2011, the NRC issued a Notice of Violation to First Energy Nuclear Operating Company for three violations associated with a White Significance Determination Process finding involving work activity during the retraction of a stuck source range monitor (SRM) from the reactor vessel. The first violation involved the failure to perform an evaluation of the potential radiological hazards associated with the work activity, as required by 10 CFR 20.1501. The second violation involved the failure to perform a complete radiological characterization of the SRM, as required by Technical Specification (T.S.) 5.7.1.b. The third violation involved the failure to establish a procedure that addressed the control of highly radioactive materials removed from the reactor vessel, as well as, the failure to implement a procedure to ensure that the licensee’s ALARA plan contained steps to ensure that the ambient radiation field in the work areas were being controlled and that the workers actions were in accordance with ALARA considerations, as required by T.S. 5.4.1.
On August 24, 2011, the NRC issued a Confirmatory Order (Effective Immediately) to Entergy Nuclear Operations Inc. and Entergy Operations Inc. (collectively Entergy) to formalize commitments made as a result of an ADR mediation session held on July 18, 2011 in Washington DC. By letter dated May 20, 2011, the NRC identified an apparent violation of 10 CFR 50.7 to Entergy Operations Inc. based on the NRC’s Office of Investigations, March 17, 2011 report (OI Case No. 4-2010-053). Specifically, the NRC had reached a preliminary conclusion that an employee at the River Bend Station was rated lower in his/her 2008 annual performance appraisal based in part on the employee questioning the qualifications necessary to perform certain work activities in compliance with applicable plant procedure(s).
Prior to the issuance of the NRC’s May 20, 2011 letter but following a separate NRC inquiry, Entergy conducted its own internal investigation of the circumstances giving rise to the apparent violation. The NRC recognized that as a result of its investigation, Entergy took several specific actions at the River Bend Station and several fleet-wide actions. The fleet-wide actions included conducting supervisory and Employee Concerns Program personnel training on 10 CFR 50.7; reviewing all closed internal retaliation type cases in 2008 and 2009; reviewing all 2009 appraisals for employees with overall “improvement required” rating; and revising several quality-affecting procedures.
As a result of the settlement agreement from the ADR mediation session, Entergy agreed to take a number of additional fleet-wide actions. A summary of those fleet-wide actions are: (1) reorganizing the quality control organization’s reporting structure; (2) reinforcing the company’s commitment to a safety conscious work environment through a written communication from a senior Entergy nuclear executive; (3) reviewing and, as necessary, revising the existing general employee training on 10 CFR 50.7 to include insights from the circumstances giving rise to this matter; (4) reviewing and, as necessary, revising training to new supervisors for 10 CFR 50.7 to include insights from the circumstances giving rise to this matter; and (5) conducting an effectiveness review of the Employee Concerns Program enhancements and training that were implemented relating to the underlying matter. Entergy also agreed to conduct a plant wide safety culture survey at the River Bend Station prior to December 31, 2012.
In recognition of Entergy’s prior actions and in exchange for the additional actions Entergy agreed to take as described in the enclosed confirmatory order, the NRC agreed not to pursue further action relating to this matter which may have otherwise resulted in the issuance of a Notice of Violation with a base civil penalty had it not reached a settlement agreement.
On August 17, 2011, the NRC issued a Notice of Violation to Northern States Power Company for a violation associated with a White Significance Determination Process finding. The violation involved the failure to maintain the direct current electrical power subsystems operable in Modes 1 through 4, as required by Technical Specification 3.8.4. Specifically, from December 21, 1994 to approximately October 22, 2010, all battery chargers in Unit 1 were susceptible to a common mode failure under design basis accident conditions. Under those conditions, the battery chargers would stop providing an output, or “lock-up,” when their alternating current input voltage dropped below their nameplate minimum voltage at the battery charger motor control center.
On August 8, 2011, the NRC issued a White Significance Determination Process finding and Notice of Violation (NOV) for two violations to Dominion Nuclear Connecticut, Inc. as a result of inspections at the Millstone Power Station Unit 2. The finding was based on multiple human performance errors, and the NOV was based on two violations which involved the licensee’s failure to meet its Technical Specifications requirements. Together these failures caused and exacerbated the February 12, 2011, unanticipated eight percent reactor power increase during the main turbine control valve testing.
On August 4, 2011, the NRC issued a Notice of Violation to SONGS for a Severity Level III violation involving the failure to certify that the qualifications and status of a senior operator licensee were current and valid and that the senior operator licensee had completed a minimum of 40 hours of shift functions under the direction of an operator or senior operator, as required by 10 CFR 55.53(e) and (f). Specifically, on October 21 and October 27, 2010, the licensee did not certify that qualifications of the senior operator licensee were current and valid and scheduled the senior operator to perform licensed activities (core alterations) as refueling senior operator supervisor while his license was INACTIVE. Additionally, the senior operator was not medically qualified in accordance with ANSI 3.4 (1996) to perform licensed duties.
On July 18, 2011, the NRC issued a violation of 10 CFR 50, Appendix B, Criterion XVI, associated with a White Significance Determination Process finding involving the failure to assure that the cause of a significant condition adverse to quality was determined and corrective actions taken to preclude repetition. Specifically, between November 3, 2008 and June 14, 2010, the licensee failed to preclude shading coils from repetitively becoming loose material in the M2 reactor trip contactor. The licensee failed to identify that the loose parts in the trip contactor represented a potential failure of the contactor if they became an obstruction; and therefore, failed to preclude repetition of this significant condition adverse to quality, that subsequently resulted in the contactor failing.
On June 10, 2011, the NRC issued a violation of 10 CFR 50, Appendix B, Criterion XVI and Criterion V, associated with a White Significance Determination Process finding involving the failure to establish measures to assure a condition adverse to quality was corrected and ensure the activities affecting quality were prescribed by documented procedures appropriate to the circumstances. Specifically, Violation 05000298/2008008-1, dated June 13, 2008, identified a condition adverse to quality in that two procedures would not work as written. While correcting that violation, the licensee failed to perform sufficient evaluation of the circuits to identify and correct a problem with three motor-operated valves needed to establish core cooling. Failure to correct the condition adverse to quality resulted in inadequate procedures in that they contained steps that were inappropriate to the circumstances because they would not work as written to reposition the three motor-operated valves.
On May 9, 2011, the NRC issued a violation of Technical Specifications associated with a Red Significance Determination Process finding involving the failure to implement an IST program in accordance with the American Society of Mechanical Engineers (ASME), Code for Operation and Maintenance of Nuclear Power Plants (OM Code), 1995 Edition, 1996 Addenda, Section ISTC 4.1. In a letter dated June 8, 2011, the Tennessee Valley Authority (TVA) appealed the Final Significance Determination of this Red Finding. The NRC performed an independent review of this finding and in a letter dated August 16, 2011, concluded that TVA failed to establish adequate programs, as required by 10 CFR Part 50.55a(b)3(ii), to ensure that motor-operated valves continued to be capable of performing their design basis safety functions. The inadequacy of TVA programs resulted in the Unit 1 LPCI outboard injection valve, 1-FCV-74-66, being left in a significantly degraded condition and the Unit 1 LPCI/RHR Loop II unable to fulfill its safety function. The basis and outcome of the final risk significance determination evaluation on this Red finding remained unchanged.
On March 14, 2011, the NRC issued a violation of 10 CFR Part 50, Appendix B, Criterion V, associated with a White Significance Determination Process finding involving the failure to provide appropriate quantitative or qualitative acceptance criteria related to maintenance on the 2A emergency diesel generator. Specifically, on January 17, 2010, a work order package did not contain a final torque verification to ensure that the 2A diesel generator upper lube oil cooler spool piece connections were torqued to the required values. As a result, the spool piece flange connection to the upper lube oil cooler did not meet the minimum torque ranges, and, subsequently, during routine testing on November 17, 2010, the flange connection on the 2A diesel generator upper lube oil cooler failed. Because the 2A diesel generator was inoperable since January 17, 2010, and because the licensee was not aware of the inoperability, the Technical Specification allowed outage time of 14 days was also exceeded.
On January 31, 2011, the NRC issued a Notice of Violation to Carolina Power and Light Company for two violations associated with two White Significance Determination Process findings. The first violation involved the failure to adequately implement requirements, as required by Technical Specifications 5.8.1, “Procedures,” of multiple procedures during an uncontrolled cooldown of the Reactor Coolant System (RCS) and subsequent safety injection. Specifically, on March 28, 2010, following a reactor trip, the licensee: (1) failed to take required procedural actions to stop an uncontrolled cooldown that resulted in a safety injection; (2) failed to identify a loss of component cooling water flow to the thermal barrier heat exchangers coincident with a failure to identify a loss of charging pump suction that resulted in inadequate seal injection flow; (3) re-energized electrically faulted equipment that damaged surrounding equipment and resulted in electrical ground alarms, which required an Alert emergency declaration. The second violation involved failure to adequately design and implement operator training based on learning objectives as required by 10 CFR 55.59(c)4. Specifically, prior to March 28, 2010, training lesson material failed to identify the basis of a procedural action involving reactor coolant pump seal cooling, as required by a systems approach to training, as defined in 10 CFR 55.4.