I am a mind reader? This just came out on the internet site Dec 17. See you there.
PUBLIC MEETING ANNOUNCEMENT
Title: Meeting to Discuss Effectiveness of CDBI Inspections
Date(s) and Time(s): January 13, 2015, 12:30 PM to 03:30 PM
Location: NRC Three White Flint North, HQ-3WFN-9A32
11601 Landsdown Street
Rockville, MD
Category: This is a Category 2 meeting. The public is invited to participate in this meeting by
discussing regulatory issues with the Nuclear Regulatory Commission (NRC) at
designated points identified on the agenda.
Purpose: To conduct a public meeting with the industry and staff to share each organization's
perspective on the Effectiveness of the Component Design Bases Inspections
Dec 10:
So I got a question, why after that first CDBI inspection didn’t the NRC tell Entergy if we find another “even one more CDBI violation” we will severely punish you with a prolonged shutdown. Why didn’t Entergy do heavy duty scrub on all their licensing and design issue so they never had another violation?
How did it ever come to the point where it turned to it’s the NRC responsibility to find CDBI violations at Palisades?
updated Dec 10:Personally I think Palisades has become obstinate over finding and correcting CDBI issues.
How did we get here to a component design bases inspection? It came out of the Maine Yankee debacle. The regular inspector staff weren't catching all the violations...the NRC was forced to bring on a heavy duty inspection team for political reasons leading to uncovering a lot of missed violations and the premature shutdown of the plant.
OCTOBER 3, 2007
“Although the Commission is confident that the Reactor Oversight Process is superior to the Maine Yankee Independent Safety Assessment, we continue to improve the process. For example, in 2006, the NRC staff, at the direction of the Commission, significantly enhanced the way the NRC reviews design issues. The resulting Component Design Basis Inspection procedure, which is an important element of the Reactor Oversight Process, is a team inspection to verify that design bases have been correctly implemented for selected risk significant components and that operating procedures and operator actions are consistent with design and licensing bases.”
Here is a list of NRC component design bases inspection report since 2007. That is when they must have started these inspections. So we got 30 design and licensing violations since 2006 ...the inability to ever meet their plant licensing commitments.
I think it is the job of the engineering department and the NRC to provide a pristine licensing environment for the licensing operators up in the control room. More, the plant should be perfectly congruent with licensing and we should alway drive the plant licencing towards sustained safety. An operator walks into work for the day, all plant licensing conditions should be pristine and all of the engineering should make sure the components operate better than as designed. The plant needs to keep up in modernity. These staffs should dedicate their lives to support the operating staff. Always, if the plant had any transient or accident...basically in a accident, there should be no surprises with broken equipment and events should never occur outside the well worn path of plant licensing. There never should be any surprises for the operators in any accident and certainly we shouldn't have any events outside licensing and training...plant designs should always be informed with the lessons learned through the history of the plant and throughout the industry. Anything less is a abdication to the dedication of the operating crew...you are setting up the licensing staff to fail. So with any violation of the Maine Yankee Component Design Basis inspection you are screwing the operating staff.
I think it is the job of the engineering department and the NRC to provide a pristine licensing environment for the licensing operators up in the control room. More, the plant should be perfectly congruent with licensing and we should alway drive the plant licencing towards sustained safety. An operator walks into work for the day, all plant licensing conditions should be pristine and all of the engineering should make sure the components operate better than as designed. The plant needs to keep up in modernity. These staffs should dedicate their lives to support the operating staff. Always, if the plant had any transient or accident...basically in a accident, there should be no surprises with broken equipment and events should never occur outside the well worn path of plant licensing. There never should be any surprises for the operators in any accident and certainly we shouldn't have any events outside licensing and training...plant designs should always be informed with the lessons learned through the history of the plant and throughout the industry. Anything less is a abdication to the dedication of the operating crew...you are setting up the licensing staff to fail. So with any violation of the Maine Yankee Component Design Basis inspection you are screwing the operating staff.
So there were 30 CDBI violations over the course of the five CDBI inspections. Obviously the NRC was doing a political CDBI inspection…partial inspections with the phony idea of clearing out all Maine Yankee CDBI like violations at Palisades or any plant. A type of inspection the NRC implied they were doing would look like this; maybe 30 violations on the first inspection and maybe one or two each of the rest the inspections.
The middle CDBI inspection in 2008, 2009 and 2011 with (4,2 and 4 violations ending in 11 violations in 2014) indicates the agency inappropriately limited the scope of the middle inspections or limited the number of violations the inspector could report in 2008, 2009 and 2011 time frame?
Right, as the behavior of Palisades was worsening in the middle years of this, the NRC was loosening the screws on Palisades right up to the late Sept 2011 yellow finding DC accident. Palisades was perilously declining all through the prior year and continued on to the other side of the yellow finding and the NRC was looking at them through a inappropriately loosening lens. The NRC needed the high hurdle of a unexpected set of incidences, accidents and plant trips before they could intervene to stabilizes the plant.
Was the NRC signaling regulatory laxity in the head winds of Palisades worsening behavior, in the lead up to Sept 2011? Was Entergy keying off that and destroying their plant safety culture?
If the agency took a really really hard stance on the CDBI violations…would Palisades have corrected their behavior way before Sept 2012 yellow finding?
These plants with all their components are tremendously complex and the majority of the safety components sit behind a barrier, with the components in operation we are mostly blinded...we can't see what is going on. Of even more complexity, all NRC and plant rules, policies, procedures and multiple organizational complexity. All of this in totality is really not understandable...can't be comprehensively understood in any information system provided to us. It is just the fact of life. At the bottom of this, it a easily apparent in this Palisades inspection and the totality of the component design inspection to date...the massive complexity dwarfs the capabilities of the staff of the NRc and Entergy. If the staff's resources dwarfed the complexity of system, all the known and unknown design component violations would have been cleared out of violations on the first inspection and their would have only been less than a handful after the first inspection to date. If the Palisades and NRC staff dwarfed the complexity of the system all through the design, construction and operations of the plant, then there never would have been the necessity of ever having a Component Design Basis Inspection violation at all...Maine Yankee would have been stall running and there would have never been such a thing as a CDBI.
You can’t understand how we go to the Component
Design Basis Inspection and the 2007 commissioner Klein speech, unless you understand
the nuclear industry's turmoil all throughout the 1990s and leading up to beyond the 2001 David Besse head problem.
1992 -I got fired from VY for raising safety issues?
Jan 1993 -President Clinton
1993 -Paul Blanch leaves Millstone
Nov 94 -midterms, house and senate now controlled by republicans
1995 -Shirley Jackson becomes NRC chairman June 96 -Galantis leaves Millstone and three Units shutdown
Nov 96 -Clinton reelected with 49% Dec 96 - Maine Yankee shuts down permanently
Nov 97 -Commonwealth Edison's whole nuclear system on fire and burning in Chicago, largest owner of nuclear plants in nation
*1998 -Permanent shutdown of two unit Zion
1999 -Jackson run out of office
July 1 -Jackson became president of Rensselaer Polytechnic Institute
Jan 2001 -President Bush
2002 –Davis Besse head
Do you know what complacency and negligence cost us, make bad actor pay the price with taking shortcuts... it massively drives up complexity not making one more kilowatt for our work. Think of the additional complexity Maine Yankee brought us, it was the symbol nationwide with licensees not maintaining the licensing conditions in their plants and there was tremendous amount of plant operational problems. Think of all the complexity the CDBI brings to us with a gaggle of inspectors dedicated to these inspections, the procedures of the NRC for this, all officials who manage this and the interaction with the licensee, and the effort of the licensees himself. Not one extra kilowatt is made from this. How much does negligence and ignorance really cost us? I think this is model with driving up most of the unnecessary complexity of the whole system...this is the price we a pay with a lesser perfection and the lack of appreciation of a beautiful world. This is the world that short term profits brings us and the quarterly financial reports. A beautiful world is a economical world on the long run, and god serves us all.
Remember the complexity is so large, I believe the totality the NRC and Palisades staffs and our sampling regulator...we only see and clear a insignificant amount of the licensing and component/procedure defects. So we got 30 CDBI violations to date at Palisade, they must have cleared out a lot of violation before they invented the CDBI inspections and the Maine Yankee shutdown...what violation do we have left in the life of the Palisades? Maybe, thirty, fifty or a hundred... Who is to say, will they are catch all of them before end of life.
Yous see what the staff is facing with obsolete plant? Palisades has never been a pristine operational plant...this plant has been very troubled over decades. This never has been a pristine plant, they have been diry all their lives...this is not about nitpicking the plant on minor licensing and maintaining the quality of component issues here.
Remember the profound troubles with Palisades and all this massive attention by the NRC to Palisades over the decades is a zero sum game, especially with limited NRC resources...it steals NRC resources from other plants. It allows other plants to decline unseen and get into big troubles. Actually, this is how the NRC explained their actions in Davis Besse. Other bad actors and troubled plants in region III blinded us to the decline of Davis Besse. The refrain was, our inadequate agency processes prevented us from seeing the true conditions of the Davis Besse staff, we through DB was one of the better running plants, we then stuck our extra resources into the other troubles region III plants. We didn't have adequate inspection services on the approach to DB hole in the head at the site and our overwhelmed inspection services and limited agency processes didn't allow the agency see the decline of the plant into the hole in the head.
And we know, out the NRC's OIG report on San Onofre and events at Millstone, the lot of NRC officials up and down the levels of the NRC spoke over and over again about not having the capabilities to see the big picture because of a artificial ideological limitations on NRC inspection resources and their unconscionable sampling philosophy that only allows them to see less than 10% of the field of play with the little understood complexity of the technology and government. How we defaulted to this kind of regulator. You know that don't you; we are not just talking about the complexity of Palisades...basically the complexity of the NRC organization and their regulation and procedures. It is absolutely clear so much of this complexity is in the NRC itself and this dissociating caused by musical chairs in the commissioners office in recent years, one side of the NRC brain doesn't know what is in the other side of their brain, the hemispheres aren't talking and communicating with each other.
Yous see what the staff is facing with obsolete plant? Palisades has never been a pristine operational plant...this plant has been very troubled over decades. This never has been a pristine plant, they have been diry all their lives...this is not about nitpicking the plant on minor licensing and maintaining the quality of component issues here.
Remember the profound troubles with Palisades and all this massive attention by the NRC to Palisades over the decades is a zero sum game, especially with limited NRC resources...it steals NRC resources from other plants. It allows other plants to decline unseen and get into big troubles. Actually, this is how the NRC explained their actions in Davis Besse. Other bad actors and troubled plants in region III blinded us to the decline of Davis Besse. The refrain was, our inadequate agency processes prevented us from seeing the true conditions of the Davis Besse staff, we through DB was one of the better running plants, we then stuck our extra resources into the other troubles region III plants. We didn't have adequate inspection services on the approach to DB hole in the head at the site and our overwhelmed inspection services and limited agency processes didn't allow the agency see the decline of the plant into the hole in the head.
And we know, out the NRC's OIG report on San Onofre and events at Millstone, the lot of NRC officials up and down the levels of the NRC spoke over and over again about not having the capabilities to see the big picture because of a artificial ideological limitations on NRC inspection resources and their unconscionable sampling philosophy that only allows them to see less than 10% of the field of play with the little understood complexity of the technology and government. How we defaulted to this kind of regulator. You know that don't you; we are not just talking about the complexity of Palisades...basically the complexity of the NRC organization and their regulation and procedures. It is absolutely clear so much of this complexity is in the NRC itself and this dissociating caused by musical chairs in the commissioners office in recent years, one side of the NRC brain doesn't know what is in the other side of their brain, the hemispheres aren't talking and communicating with each other.
Last cycle, what if they had a big accidents? In a accident, it really stresses the components and employees of the plant as never before. All of the 11 violation predisposes to the staff that lots of components will fail in a unexpectant manner in an accident. The violations might give inaccurate indication to the operator in the accident. All these violations and the ones not knowable and fixed, half blinds the operating crew. They are facing a indeterminate amount of failures and control room confusion in big accident. Do you think the staff is at the top of their game or dispirited and demoralized? That will play a huge part in this. A large proportion of the current and future violation are about detecting and correcting the declines of the components in a obsolete plant. I think we are here with a new kind of accident not acted upon by the NRC. Honestly, do you trust government...
I advocated replacing on a emergency bases the 20 oldest plants in the USA with new plants. You know what Fukushima tells us, it would have been tremendously more economical to replace the Daiichi plant and similar plants with new plants. Prior to the accident there just isn't enough money to replace the plant, after the accident it all looks like a once in a lifetime opportunity. You say it is too expensive and the burdens of doing it are too high a hurdle...history teaches us we have no idea what the true cost of complacency is. In the rear view mirror of history, we have wasted so much treasure and opportunity. Honestly, I know this is hard to swallow. i know the system has pretty much got us checkmated on shutting down dangerous plants...maybe if we gave them the opportunity of a future they would do the right thing. i think it is a lot more dangerous if we let the industry decay away as we envision it today. Inaction,complaceny and political gridlock cost us so much.
I have recently talked to a NRC 50.59 expert in region 1, he reminded me the early plants had skimpily plant licensing and their documentation was atrocious. We should always be thinking of that with these old plants. Keep in mind, the NRC is a shallow sampling regulator. They pick a number sample set...we have no idea of the real size of the cohort of all violation known but not recorded or unknown. They choose what they want us to see so all in the interest of their altruism.
Basically for the most recent component design inspections, these aren't new violations. These are violations and licensing defects that have been mostly around for decades and many come from before the plants first startup. Is this the third world of Guatemala where we are too poor and corrupt to develop their infrastructure...or are we the reflection of the best and brightest nation on the planet. Who are we? We have so much capability and opportunity wasted.
December 2, 2014 : SUBJECT: PALISADES NUCLEAR PLANT COMPONENT DESIGN BASES INSPECTION 05000255/2014008
11 violations
September 12, 2011 SUBJECT:PALISADES NUCLEAR PLANT COMPONENT DESIGN BASES INSPECTION AND TEMPORARY INSTRUCTION 2515/177, “MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING,DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS REPORT” 05000255/2011009
Four violations
January 15, 2009: SUBJECT: PALISADES NUCLEAR PLANT NRC COMPONENT DESIGN BASES INSPECTION (CDBI) INSPECTION REPORT 05000255/2008009(DRS)
Two violations
one violations
February 13, 2007 SUBJECT: PALISADES NUCLEAR PLANT NRC COMPONENT DESIGN BASES INSPECTION (CDBI) REPORT 05000255/2006009(DRS)
11 violations
Based on the results of this inspection, ten NRC-identified findings of very low safety significance were identified. The findings involved violations of NRC requirements. However, because of their very low safety significance, and because the issues were entered into your Corrective Action Program, the NRC is treating the issues as Non-Cited Violations (NCVs) in accordance with Section 2.3.2 of the NRC Enforcement Policy. Additionally, one licensee-identified violation is listed in Section 4OA7 of this report.
December 2, 2014: SUBJECT: PALISADES NUCLEAR PLANT COMPONENT DESIGN BASES INSPECTION 05000255/2014008
NRC-Identified and Self-Revealing Findings
Cornerstone: Initiating Events
• Green. The inspectors identified a finding having very low safety significance and an associated Non-Cited Violation (NCV) of 10 CFR Part 50.36(c)(3), “Surveillance Requirements,” for the failure to ensure the channel time delay for the degraded-voltage monitor was included in Technical Specification (TS) Surveillance Requirement (SR) 3.3.5.2.a. Specifically, the licensee failed to include in the TS SR the required time delay after the voltage relay trips before the preferred source of power is isolated and 1E electrical loads transferred to the stand-by Emergency Diesel Generators (EDGs). This finding was entered into the licensee’s Corrective Action Program and the licensee’s preliminary verification determined the degraded voltage monitors were still operable but degraded or non-conforming.NRC picture...is your gonads protected.
The performance deficiency was determined to be more than minor because if left uncorrected, it would have the potential to lead to more significant safety concern. Specifically, by not incorporating the total time delay requirements into the Technical Specifications, (TS) the time could be changed without going through the TS change process, possibly leading to spurious trips of offsite power sources or possibly exceeding the accident analysis time is the FSAR. The inspectors determined the finding was of very low safety significance (Green) because it did not cause a reactor trip and the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. The inspectors did not identify a cross-cutting aspect associated with this finding because the finding was not representative of the licensee’s present performance. (Section 1R21.3.b(9))
Cornerstone: Mitigating Systems
• Green. The inspectors identified a finding of very low safety significance and associated Non-Cited Violation of 10 CFR Part 50, Appendix B, Criterion III, “Design Control” for the failure to ensure the safety-related Engineered Safeguard Systems trains would not be adversely affected by air entrainment when aligned to the Safety Injection and Refueling Water (SIRW) Tank. Specifically, calculation EA-C-PAL-0877D, assumed incorrectly only one train of the Engineered Safeguards System (ESS) was in operation when evaluating if the SIRW Tank reaches the limit for critical submergence during a tank drawdown. As part of their corrective actions, the licensee re-evaluated the scenarios of concern, performed an operability evaluation, and implemented compensatory actions.
The performance deficiency was determined to be more than minor because it impacted the Equipment Performance attribute of the Reactor Safety, Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, air entrainment into the ESS systems could potentially impact the operability of the system by air binding the pumps, reduce discharge flow, discharge pressure and/or delay injection. The inspectors determined the finding was of very low safety significance (Green) because the finding was a deficiency affecting the design or qualification of a mitigating structure system or component (SSC) but the SSC maintained its operability. The inspectors did not identify a cross-cutting aspect associated with this finding because the finding was not representative of the licensee’s present performance. (Section 1R21.3.b(1))
• Green. The inspectors identified a finding of very low safety significance and associated NCV of 10 CFR Part 50, Appendix B, Criterion III, “Design Control,” for the licensee’s failure to ensure the incoming feeder cables from startup transformer 1-2 to 2400 V safety-related Buses 1C and 1D were sized in accordance with their design basis, as described in Palisades FSAR Section 8.5.2. Specifically, the licensee failed to ensure the ampacity of the cables was at least as high as their maximum steady-state current. The licensee entered this finding into their Correction Action Program and verified the operability of the cables.
The performance deficiency was determined to be more than minor, because it impacted the Design Control attribute of the Reactor Safety, Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, cables were undersized with respect to the loading that would automatically occur as the result of a design basis accident. The inspectors determined the finding was of very low safety significance (Green) because the SSC maintained its operability and functionality. This finding had a crosscutting aspect in the area of Human Performance, associated with the Design Margin component, because the licensee did not ensure that equipment is operated and maintained within design margins, and margins are carefully guarded and changed only through a systematic and rigorous process. [H.6] (Section 1R21.3.b(2))
• Green. The inspectors identified a finding of very low safety significance and associated NCV of 10 CFR Part 50, Appendix B, Criterion III, “Design Control,” for the licensee’s failure to ensure electric motors are sized in accordance with the design basis, as discussed in Palisades FSAR Section 6.2.3.1. Specifically, the horsepower ratings of certain motors are less than power demands of their driven equipment, and they were not analyzed to ensure overheating would not occur. The licensee entered this finding into their Correction Action Program with a recommended action to analyze the effect of the condition, and has verified the operability of the motors.
This performance deficiency was determined to be more than minor, because it impacted the Design Control attribute of the Reactor Safety, Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, motors serving loads with power demands in excess of the motor horsepower ratings were not analyzed to ensure that motor damage would not occur. The inspectors determined the finding was of very low safety significance (Green) because the SSC maintained its operability and functionality. This finding had a crosscutting aspect in the area of Human Performance, associated with the Design Margin component, because the licensee failed to ensure that equipment is operated within design margins, and margins are carefully guarded and changed only through a systematic and rigorous process. [H.6] (Section 1R21.3.b(3))
• Green. The inspectors identified a finding of very low safety significance and associated NCV of 10 CFR Part 50, Appendix B, Criterion III, “Design Control,” for the licensee’s failure to ensure that voltages on the 480V system do not exceed equipment ratings. Specifically, the licensee increased the output voltage of the supply transformers to the 480V safety-related buses by 2.5 percent, but failed to ensure the resulting voltages would not exceed equipment ratings when the system is powered from the station power transformer or emergency diesel generator. The licensee entered this finding into their Correction Action Program and verified the operability of the affected equipment.
The performance deficiency was determined to be more than minor, because it impacted the Design Control attribute of the Reactor Safety, Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to verify or check the voltage increase on the 480V system to ensure the maximum allowable voltage would not exceed equipment ratings. The inspectors determined the finding was of very low safety significance (Green) because the affected SSCs maintained their operability and functionality. The inspectors did not identify a cross-cutting aspect associated with this finding, because the finding was not representative of the licensee’s present performance. (Section 1R21.3.b(4))
• Green. The inspectors identified a finding of very low safety significance and associated Non-Cited Violation of Technical Specifications 5.5.7, "Inservice Testing Program," for the failure to perform comprehensive pump testing of Containment Spray Pump P-54A in accordance with the code of record. Specifically, the licensee did not rerun a comprehensive pump test, as required by the code’s ISTB-6300 “Systematic Error” section. As part of their corrective actions, the licensee entered the issue into the Corrective Action Program, and determined the component remained operable.
The performance deficiency was determined to be more than minor because it impacted the Equipment Performance attribute of the Reactor Safety, Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, failing to perform testing as required could result in the degradation of the equipment being undetected. The finding screened as having very low safety significance because the finding was a deficiency affecting the design or qualification of a mitigating structure system or component (SSC) but the SSC maintained its operability. The findings had a cross-cutting aspect in the area of Problem Identification and Resolution, Evaluation, because the licensee failed to thoroughly evaluate the issue to ensure that resolutions address causes and extents of conditions commensurate with their safety significance. [P.2] (Section 1R21.3.b(5))
• Green. The inspectors identified a finding of very low safety significance and associated NCV of 10 CFR Part 50, Appendix B, Criterion XI, “Test Control,” for the licensee’s failure to have adequate acceptance criteria in the emergency diesel generator surveillance procedures. Specifically, the licensee failed to ensure the surveillance test procedures for the emergency diesel generator largest load rejection test bounded the power demand of the largest load, as required by Technical Specification SR 3.8.1.5. The licensee entered this finding into their Correction Action Program and verified the operability of the emergency diesel generators.
The performance deficiency was determined to be more than minor, because it impacted the Procedure Quality attribute of the Reactor Safety, Mitigating Systems Cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems to respond to initiating events to prevent undesirable consequences. Specifically, the surveillance procedure error could result in acceptance of test results that did not satisfy Technical Specification SR 3.8.1.5 for rejection of a load greater than or equal to the emergency diesel generator’s single largest predicted post-accident load. The inspectors determined the finding was of very low safety significance (Green) because the SSC maintained its operability and functionality. This finding had a cross-cutting aspect in the area of Human Performance, associated with the Resources component, because the licensee failed to ensure that personnel, equipment, procedures, and other resources are adequate to assure nuclear safety by maintaining long term plant safety.
[H.1] (Section 4OA2.1.b(1))
Cornerstone: Barrier Integrity
• Green. The inspectors identified a finding of very low safety significance (Green) and associated NCV of 10 CFR Part 50, Appendix B, Criterion III, “Design Control,” for the licensee’s failure to correctly translate design valve leakage limits into the applicable test procedure. Specifically, the acceptance criterion for emergency core cooling system (ECCS)/containment spray (CS) recirculation isolation valves CV-3027 and CV-3056 had not been correctly adjusted to account for the higher differential pressure associated with ECCS operation under post-accident conditions. The licensee entered this finding into their Corrective Action Program to correct the valve leakage limit.
The performance deficiency was determined to be more than minor because it impacted the Design Control attribute of the Barrier Integrity Cornerstone and adversely affected the associated cornerstone objective to provide reasonable assurance that containment could protect the public from radionuclide releases caused by accidents or events. Specifically, leakage approaching the procedural values would exceed analyzed dose calculations. The finding screened as of very low safety significance (Green) because the finding did not represent an actual open pathway in the physical integrity of reactor containment, containment isolation system, or heat removal components and did not involve an actual reduction in function of hydrogen igniters in the reactor containment. The inspectors determined this finding did not have an associated cross-cutting aspect because it was not representative of present performance. (Section 1R21.3.b(6))
• Green. The inspectors identified a finding of very low safety significance (Green) and associated NCV of 10 CFR Part 50, Appendix B, Criterion VII, “Control of Purchased Material, Equipment, and Services,” for the licensee’s failure to identify non-safety-related sub-components improperly supplied with safety-related valves. Specifically, ECCS/CS recirculation isolation valves CV-3027 and CV-3056, which were installed in 2007, were supplied with non-safety-related sub-components. These components were identified as non-safety-related on the vendor drawings. In addition, the licensee later installed a section of non-safety-related tubing on valve CV-3027 based on the incorrect vendor drawing. The licensee entered this finding into their Corrective Action Program to correct the valve drawings and replace the non-safety-related parts.
The performance deficiency was determined to be more than minor because it impacted the Design Control attribute of the Barrier Integrity Cornerstone and adversely affected the associated cornerstone objective to provide reasonable assurance that containment could protect the public from radionuclide releases caused by accidents or events. Specifically, the licensee failed to identify non-safety-related sub-components improperly supplied with safety-related valves which would form part of the containment barrier under post-accident conditions. The finding screened as of very low safety significance (Green) because the finding did not represent an actual open pathway in the physical integrity of reactor containment, containment isolation system, or heat removal components and did not involve an actual reduction in function of hydrogen igniters in the reactor containment. The inspectors determined this finding did not have an associated cross-cutting aspect because it was not representative of the licensee’s present performance. (Section 1R21.3.b(7))
• Green. The inspectors identified a finding of very low safety significance and associated NCV of 10 CFR Part 50, Appendix B, Criterion XI, “Test Control,” for the licensee’s failure to establish an adequate test program for the Shutdown Cooling (SDC) Heat Exchangers (HXs) to demonstrate they can perform as designed. Specifically, the licensee failed to take actions to ensure the SDC HXs’ heat transfer capability met its design bases, as assumed in design bases calculations.
The performance deficiency was determined to be more than minor because it impacted the Design Control attribute of the Barrier Integrity Cornerstone and adversely affected the associated cornerstone objective to provide reasonable assurance that containment could protect the public from radionuclide releases caused by accidents or events. Specifically, the licensee failed to verify the SDC HXs heat transfer capability met their design bases, as assumed in design bases calculations, to limit containment temperatures and pressures during an event. The finding screened as of very low safety significance (Green) because the finding did not represent an actual open pathway in the physical integrity of reactor containment, containment isolation system, or heat removal components and did not involve an actual reduction in function of hydrogen igniters in the reactor containment. The inspectors determined this finding had an associated cross-cutting aspect, Conservative Bias, in the Human Performance cross-cutting area. Specifically, on several occasions when the licensee identified the need to perform testing and/or inspection of the SDC HXs, the licensee did not take actions because they did not believe any regulatory requirements or technical issues existed that required the testing and/or inspections. [H.14] (Section 1R21.3.b(8))
B. Licensee-Identified Violations
Violations of very low safety or security significance or Severity Level IV that were identified by the licensee have been reviewed by the NRC. Corrective actions taken or planned by the licensee have been entered into the licensee’s Corrective Action Program (CAP). These violations and CAP tracking numbers are listed in Section 4OA7 of this report.
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