I explained it on Feb 29, 2016 in a amazingly accurate post, in the early reports about this terribly chaotic organization. The best quotes: Junk Plant Fermi Can't File A Clean Event Report.
"This is the second time (2/02/1016) the turbine bypass flings open?"
"Again not reporting accurate (and timely) event reports."
"It starts out as a leak in the Turbine Building Closed Cooling. So this event occurred on Sept 13 and it takes them all this time to fix the event report. Sounds like the NRC provoking Fermi to fix inaccurate"
In the below, they should fire the training department top manager, the training department manager of licenced operators and the top operations manager of licenced operators. Or at least to publicly demote them. Get somebody else in there to get the job done.
The NRC is increasing finding simulator fidelity issues in serous plant transients and trips, such as Pilgrim and River Bend. The NRC has a pattern of not being about to detect simulator fidelity issues in training and simulator inspections before it shows as adventures in plant accidents. Many of the residents just don't have the expertise or time to catch it on their own. The NRC risk calculations, and thus penalty, isn't big enough to make the industry make their training simulators identical to the plants. Mostly big dog licencing on shift manage get these plum jobs in training. Anything to get off shift work. These guys have been on shift for decades, they are titans and untouchable to the rest of the licencing operators (Huge kiss asses all their lives subverting the professional licensed operator profession) The licencees operators to the one are extremely intelligent. They know when the simulator doesn't model the plant. They secretly kid between themselves with the traps on simulator un-fidelity. It is not that it mysteriously pops out of nowhere...its everyone knows it except the NRC and senior corporate managers and executives. It is an increasing culture of secrecy plant wide you should worry about. It managers burying the bad news to not fix expensive problems. It is a sense of intimidation by the bad dog training managers and operations managers, don't rock the boat. Its not the risk of few operators doing the wrong activities leading to highly improbable meltdown. It symbolizes a much wider global risk effecting all of organization everywhere with insider secrets and severe safety intimidation. It is a wide spread and global severe safety culture problem effecting everything the organization does. It the big dog managers and executives intimidating the little fish. How does anyone now know the actual real condition of the facility and it organization. It is when crazy stupid events and equipment problems just seemingly pops up out of nowhere. Really crazy stupid unexplained stuff popping up seemingly out of nowhere. Why didn't the operator get the NRC to fix their simulator?
"So they got a scram on cycling SRVs valves twice. It indicates problems with training"
It is rule, procedure, plant licencing, training, NRC reporting violations and preventable equipment problems on a massive level. It reminds me of Pilgrim in 2013. The NRC seems to be hiding the extent of the problem.
May 9, 2016
The NRC inspectors documented seven findings of very low safety
significance (Green) in this report. Six of these findings involved violations
of NRC requirements. In addition, the inspectors identified three performance
deficiencies that were associated with Severity Level IV violations of NRC
requirements evaluated through the traditional enforcement process. Two licensee-identified
violations are also documented in this report. One of these licensee identified
violations was determined to be of very low safety significance and the other
one was evaluated through the traditional enforcement process as Severity Level
IV. The NRC is treating each of these violations as Non-Cited Violations (NCVs)
consistent with Section 2.3.2.a of the NRC Enforcement Policy.
1) Green. A finding of very low safety significance with an
associated NCV of 10 CFR 55.46(c), “Plant-Referenced Simulators,” was self-revealed.
The licensee failed to ensure the plant-referenced simulator demonstrated
expected plant response to normal, transient, and accident conditions to which
the simulator was designed to respond. Specifically, the licensee failed to
maintain the simulator consistent with actual plant response.
The performance deficiency was of more than minor safety
significance because it adversely affected the human performance attribute of
the Initiating Events cornerstone and affected the cornerstone objective of
limiting the likelihood of events that upset plant stability and challenge
critical safety functions during shutdown as well as power operations.
2) Green. A finding of very low safety significance with an
associated NCV of 10 CFR 50.65, "Requirements for Monitoring the Effectiveness
of Maintenance at Nuclear Power Plants," was self-revealed when the failure
of a tube inside the east turbine building closed cooling water (TBCCW) heat
exchanger caused a trip of the TBCCW pumps and a manual reactor scram due to the
loss of all TBCCW. The heat exchanger tube failure occurred, in part, due to
the licensee’s failure to incorporate industry operating experience in order to
perform adequate preventive maintenance on the component.
The performance deficiency was of more than minor safety
significance because it was associated with the equipment performance attribute
of the Initiating Events cornerstone and adversely affected the cornerstone
objective of limiting the likelihood of events that upset plant stability and
challenge critical safety functions during shutdown as well as power
operations.
3) Green. A finding of very low safety significance with an
associated NCV of Technical Specification (TS) 5.4, “Procedures,” was
self-revealed when a valid automatic reactor scram signal and isolation signal
for multiple primary containment isolation valves was actuated. A reactor
operator, who was maintaining RPV water level and reactor pressure following a
plant scram, did not initiate reactor core isolation cooling (RCIC) system flow
in time to maintain level above the Level 3 reactor protection system actuation
setpoint.
The performance deficiency was of more than minor safety
significance because it was associated with the Human Performance attribute of
the Initiating Events cornerstone and adversely affected the cornerstone
objective of limiting the likelihood of events that upset plant stability and
challenge critical safety functions during shutdown as well as power
operations.
Cornerstone: Mitigating Systems
4) Green. The inspectors identified a finding of very low
safety significance with an associated NCV of TS 5.4, “Procedures.” Specifically,
the licensee failed to enter TS 3.3.1.1, Condition C when the high pressure stop
valve (HPSV) closure and high pressure control valve (HPCV) fast closure reactor
protection system (RPS) trip functions became inoperable while the main turbine
bypass valves cycled open during a plant transient on January 6, 2016.
The performance deficiency was of more than minor safety
significance because a failure to correctly implement TS Limiting Condition for
Operation (LCO) requirements has the potential to lead to a more significant
safety concern if left uncorrected. Specifically, a failure to declare an LCO
not met, enter the applicable condition(s), and follow the applicable actions
could reasonably result in operations outside of established safety margins or
analyses.
Green. The inspectors identified a finding of very low
safety significance with an associated NCV of 10 CFR 50, Appendix B, Criterion
III, “Design Control.” Specifically, the licensee failed to demonstrate the
residual heat removal heating, ventilation, and air conditioning (RHRHVAC)
system would be able to maintain a required minimum temperature of 40 degrees
Fahrenheit (°F) for the emergency diesel generator (EDG) fuel oil storage tank
(FOST) rooms under minimum design conditions, potentially rendering the EDGs
inoperable.
The performance deficiency was of more than minor safety
significance because a failure to correctly incorporate design requirements
into plant procedures has the potential to lead to a more significant safety
concern if left uncorrected. Specifically, since the EDG FOST rooms were
unmonitored and a subsequent calculation demonstrated the RHRHVAC system was
not able to maintain the minimum required temperature in the rooms as described
in the design basis, the EDGs could have been rendered inoperable without the
licensee’s knowledge.
Cornerstone: Barrier Integrity
5) Green. The inspectors identified a finding of very low
safety significance with an associated NCV of 10 CFR 50, Appendix B, Criteria
V, “Instructions, Procedures, and Drawings.” Specifically, the licensee failed
to include appropriate quantitative or qualitative acceptance criteria in its
surveillance test procedures for fulfilling the monthly Technical Specification
surveillance requirement to demonstrate operability of the standby gas
treatment system (SGTS).
The performance deficiency was of more than minor safety
significance because it was associated with the procedure quality attribute for
the control room and auxiliary building and adversely affected the Barrier
Integrity cornerstone objective to provide reasonable assurance that physical
design barriers protect the public from radionuclide releases caused by
accidents or events. Specifically, by not providing appropriate acceptance criteria
by which the operability of the SGTS trains could be assessed, the ability of
the SGTS to collect and treat the design leakage of radionuclides from the
primary containment to the secondary containment during an accident could not
be assured. The finding was determined to be of very low safety significance
because it involved only a degradation of the radiological barrier function
provided by the SGTS. The inspectors concluded that because this condition has
existed for greater than three years, this issue would not be reflective of
current licensee performance and no cross-cutting aspect was identified.
Other Findings
6) Severity Level IV. The inspectors identified a Severity
Level IV NCV of the 10 CFR 50.72(a)(1), “Immediate Notification Requirements
for Operating Nuclear Power Reactors,” and 10 CFR 50.73(a)(1), “Licensee Event
Report [LER] System.” Specifically, the licensee failed to make a required 8-hour
non-emergency notification call to the NRC Operations Center after discovery of
a condition that could have prevented the fulfillment of the safety function to
shut down the reactor on February 21, 2015, and on January 6, 2016 (two
separate occurrences). In addition, the licensee failed to submit a required
LER within 60 days after discovery of the event on February 21, 2015.
Subsequently, the licensee made an 8-hour notification call on February 25,
2016 to the NRC Operations Center via the Emergency Notification System to
report the two events (Event Notices 51755 and 51756). On March 2, 2016, the licensee
updated Event Notices 51755 and 51756 to include an additional reporting criterion.
The licensee submitted LER 05000341/2015-008-00, “Turbine Stop Valve Closure and
Turbine Control Valve Fast Closure Reactor Protection System Functions Considered
Inoperable Due to Open Turbine Bypass Valve,” on March 29, 2016, to report the
February 2015 event. The licensee entered this issue into its corrective action
program to evaluate the cause for its failure to satisfy the reporting
requirements and to identify appropriate corrective actions.
7) Severity Level IV. The inspectors identified a Severity
Level IV NCV of 10 CFR 50.73(a)(1), “Licensee Event Report [LER] System,” for
the licensee’s failure to submit a required LER within 60 days after the
discovery of an event on July 28, 2015, that was reportable in accordance with
10 CFR 50.73(a)(2)(i)(B) as a condition prohibited by the plant’s Technical
Specifications. The condition involved the licensee’s failure to complete
required actions for an inoperable ultimate heat sink reservoir and for both emergency
diesel generators in one division inoperable within the allowed completion times.
The licensee subsequently submitted LER 05000341/2015-009-00, “Condition Prohibited
by Technical Specification Due to Missed Entry into LCO [Limiting Condition for
Operation] Condition,” on March 31, 2016, to report the event. The licensee
entered this issue into its corrective action program to evaluate the cause for
its failure to satisfy the reporting requirements and to identify appropriate
corrective actions.
8) Green. The inspectors identified a finding of very low
safety significance for the licensee’s failure to implement its procedure
standards when performing an apparent cause evaluation for a condition adverse
to quality. Specifically, the inspectors determined that the licensee did not
adequately develop the direct and apparent cause of the problem in the
evaluation, did not correctly assess the impact of relevant internal and
external operating experience, and did not identify appropriate corrective
actions to address management behaviors that resulted in the problem. No
violation of regulatory requirements was identified because the scope of issues
evaluated by the licensee’s procedure standards for performing the apparent
cause evaluation was not limited to safety-related structures, systems, and
components. The performance deficiency was of more than minor safety
significance because it would have the potential to lead to a more significant
safety concern if left uncorrected. Specifically, the failure to adequately
perform apparent cause evaluations could result in ineffective corrective
actions for conditions adverse to quality and safety. The finding was
determined to be of very low safety significance based on a qualitative
evaluation of the potential consequences of the performance issue. The
inspectors considered the three examples evaluated in the licensee’s apparent
cause evaluation and found the significance of each performance issue was not
greater than very low safety significance. The inspectors concluded this
finding affected the cross-cutting aspect of evaluation in the problem identification
and resolution area. The licensee did not adequately evaluate the problem to
ensure corrective actions would address the causes and extent of conditions
commensurate with safety significance. Specifically, the apparent cause
evaluation failed to identify and understand the basis for management decisions
that contributed to the problem; therefore, corrective actions to address appropriate
changes in management behaviors were not developed [IMC 0310, P.2]. (Section 4OA2.2)
9) Severity Level IV. The inspectors identified a Severity
Level IV NCV of 10 CFR 50.72(a)(1), “Immediate Notification Requirements for
Operating Nuclear Power Reactors,” and 10 CFR 50.73(a)(1), “Licensee Event
Report [LER] System.” Specifically, the licensee failed to make a required 8-hour
non-emergency notification call to the NRC Operations Center and also failed to
submit a required within 60 days after discovery of a condition that resulted
in the valid actuation of containment isolation signals affecting containment
isolation valves in more than one system on September 13, 2015, and September
14, 2015 (two separate occurrences). Subsequently, the licensee made an 8-hour
notification call on February 27, 2016 to the NRC Operations Center via the
Emergency Notification System to report the events (Event Notice 51391, third
update). The licensee entered this issue into its corrective action program to
evaluate the cause for its failure to satisfy the reporting requirements and to
identify appropriate corrective actions.
Licensee-Identified Violations
10) Technical
Specification 3.7.2, “Emergency Equipment Cooling Water (EECW) /Emergency
Equipment Service Water (EESW) System and Ultimate Heat Sink (UHS),” Required
Actions, Note 1, states: “Enter applicable Conditions and Required Actions of
LCO 3.8.1, ‘AC [Alternating Current] Sources – Operating,’ for diesel generators
made inoperable by UHS.” Technical Specification 3.8.1, Condition A is required
when one EDG is inoperable and Condition B is required when both EDGs in one
division are inoperable.
Technical Specification 3.8.1, Required Actions A.1 and B.1,
state: “Perform SR 3.8.1.1 for operable offsite circuit(s) within 1 hour and
once per 8 hours thereafter,” and TS 3.8.1, Required Action A.3, states:
“Verify the status of CTG 11- 1 once per 8 hours.” Contrary to the above, on
July 28, 2015, with the Division 2 UHS reservoir inoperable, the licensee
failed to enter the applicable conditions and required actions of TS 3.7.2 and
subsequently, failed to enter TS 3.8.1 for both Division 2 EDGs made inoperable
by an inoperable UHS reservoir. Consequently, with both EDGs in one division
inoperable, the licensee failed to complete TS 3.8.1, Required Actions A.1 and
B.1, to perform SR 3.8.1.1 for operable offsite circuits within 1 hour and once
per 8 hours thereafter, and also failed to complete TS 3.8.1, Required Action
A.3, to verify the status of CTG 11-1 once per 8 hours. In addition, with the
required actions and associated completion times of Conditions A and B not met,
the licensee failed to complete TS 3.8.1, Required Action G, to be in Mode 3
within 12 hours. The failure to complete these TS required actions is a
violation of TS 3.8.1.
11) Title 10 of the CFR,
Paragraph 50.72(a)(1)(ii) requires, in part, that the licensee shall notify the
NRC Operations Center via the Emergency Notification System of those non-emergency
events specified in Paragraph (b) that occurred within three years of the date
of discovery and 10 CFR 50.72(b)(3) requires, in part, that the licensee shall notify
the NRC as soon as practical and in all cases within eight hours of the occurrence
of any of the applicable conditions. Moreover, 10 CFR 50.72(b)(3)(iv)(A) requires,
in part, that the licensee report any event or condition that results in valid actuation
of any of the systems listed in Paragraph (b)(3)(iv)(B) and 10 CFR
50.72(b)(3)(iv)(B)(2) lists general containment isolation signals affecting containment
isolation valves in more than one system or multiple MSIVs.
In addition, 10 CFR 50.73(a)(1) requires, in part, that the
licensee submit an LER for any event of the type described in this paragraph
within 60 days after the discovery of the event and 10 CFR 50.73(a)(2)(iv)(A)
requires, in part, that the licensee report any event or condition that
resulted in manual or automatic actuation of any of the systems listed in
Paragraph (a)(2)(iv)(B). Paragraph (a)(2)(iv)(B)(2) in 10 CFR 50.73 lists
general containment isolation signals affecting containment isolation valves in
more than one system or multiple MSIVs.
Contrary to the above:
1. The licensee failed to notify the NRC Operations Center
via the Emergency Notification System of a non-emergency event specified in
Paragraph (b) within eight hours of an event on September 14, 2015. The event
involved the valid manual and automatic actuation of the primary containment
isolation logic for multiple MSIVs.
2. The licensee failed to submit a required LER within 60
days after discovery of an event on September 14, 2015. The event involved the
valid manual and automatic actuation of the primary containment isolation logic
for multiple MSIVs. Violations of 10 CFR 50.72 and 10 CFR 50.73 are is positioned
using the traditional enforcement process because they are considered to be
violations that potentially impede or impact the regulatory process. In accordance
with Section 6.9.d.9 of the NRC Enforcement Policy, this violation was
categorized as Severity Level IV because the licensee failed to make a report
to the NRC as required by 10 CFR 50.72(a)(1)(ii) and 10 CFR 50.73(a)(1). The licensee
entered this violation into its CAP as CARD 16-20564.
