IR 05000277/2015008

NRC Problem Identification & Resolution Inspection Report 05000277/2015008 and 05000278/2015008

ML15155B121
Person / Time
Site:	Peach Bottom
Issue date:	06/04/2015
From:	Fred Bower Reactor Projects Region 1 Branch 4
To:	Bryan Hanson Exelon Generation Co
BOWER, FL
References
IR 2015008
Download: ML15155B121 (18)

Text

June 4, 2015

SUBJECT:

PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 - NUCLEAR REGULATORY COMMISSION PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000277/2015008 AND 05000278/2015008

Dear Mr. Hanson:

On April 24, 2015, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Peach Bottom Atomic Power Station, Units 2 and 3. The enclosed report documents the inspection results, which were discussed on April 24, 2015, with Mr. Patrick Navin, Plant Manager, and other members of your staff.

This inspection examined activities conducted under your license as they relate to identification and resolution of problems and compliance with the Commissions rules and regulations and conditions of your license.

Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel. The inspectors concluded that Exelon was effective in identifying, evaluating, and resolving problems. Exelon personnel identified problems and entered them into the corrective action program at a low threshold. Exelon prioritized and evaluated issues commensurate with the safety significance of the problems and corrective actions were implemented in a timely manner. Lessons learned from industry operating experience were effectively reviewed and applied when appropriate.

Additionally, the inspectors concluded that self-assessments and audits reviewed during the inspection were critical, thorough, and effective in identifying issues.

This report documents one NRC-identified finding of very low safety significance (Green). If you disagree with the finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; and the NRC Senior Resident Inspector at the PBAPS. In addition, if you disagree with the cross-cutting aspect assigned to this finding, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Senior Resident Inspector at PBAPS. In accordance with Title 10 Code of Federal Regulations 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs Agencywide Documents Access Management System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Fred L. Bower, III, Chief Reactor Projects Branch 4 Division of Reactor Projects

Docket Nos.

50-277, 50-278 License Nos. DPR-44, DPR-56

Enclosure:

Inspection Report 05000277/2015008 and 05000278/2015008 w/Attachment: Supplementary Information

REGION I==

Docket Nos.

50-277 and 50-278

License Nos.

DPR-44 and DPR-56

Report Nos.

05000277/2015008 and 05000278/2015008

Licensee:

Exelon Generation Company, LLC

Facility:

Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3

Location:

Delta, PA

Dates:

April 6, 2015 through April 24, 2015

Team Leader:

Scott Barber, Senior Project Engineer

Inspectors:

Mike Orr, Reactor Inspector

Jeromy Petch, Reactor Engineer

Brian Smith, Peach Bottom Resident Inspector

Approved by:

Fred Bower, Chief

Reactor Projects Branch 4

Division of Reactor Projects

Enclosure

SUMMARY

IR 05000277/2015008 and 05000278/2015008; 04/06/15 - 04/24/15; Peach Bottom Atomic

Power Station, Units 2 and 3; Biennial Baseline Inspection of Problem Identification and Resolution, Problem Identification.

This NRC team inspection was performed by three regional inspectors and one resident inspector. One NRC-identified finding was identified during this inspection. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5, dated February 2014.

Problem Identification and Resolution

The inspectors concluded that Exelon was effective in identifying, evaluating, and resolving problems. Exelon personnel identified problems, entered them into the corrective action program at a low threshold, and prioritized issues commensurate with their safety significance.

Exelon appropriately screened issues for operability and reportability, and performed causal analyses that appropriately considered extent of condition, generic issues, and previous occurrences. The inspectors also determined that Exelon implemented corrective actions to address the problems identified in the corrective action program in a timely manner.

The inspectors concluded that PBAPS identified, reviewed, and applied relevant industry operating experience to Peach Bottom operations appropriately. In addition, based on those items selected for review, the inspectors determined that PBAPSs self-assessments and audits were thorough.

Based on the interviews the inspectors conducted over the course of the inspection, observations of plant activities, and reviews of individual corrective action program and employee concerns program issues, the inspectors did not identify any indications that site personnel were unwilling to raise safety issues, nor did they identify any conditions that could have had a negative impact on the sites safety conscious work environment.

Cornerstone: Initiating Events

Green.

The inspectors identified a finding of very low safety significance (Green) because PBAPS did not initiate issue reports (IR) to identify out-of-tolerance conditions for a number of single point vulnerability (SPV) instruments. An SPV instrument is any instrument for which a single failure could initiate a plant transient or cause a plant scram. Specifically, during routine preventative maintenance (PM) calibrations, certain SPV instruments as-found data was found outside expected tolerance bands, with many being significantly outside of their bands. In most cases, IRs were not written to document these adverse conditions contrary to station guidance.

The finding is determined to be more than minor because it affected the reliability of the initiating cornerstones attribute of equipment performance and affected its objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during power operations. Specifically, by not identifying and trending out-of calibration SPVs in a timely manner, a resulting transient from the loss of a single feed pump or a single reactor recirculation pump is more likely to occur. The inspectors conducted a Phase 1 screening in accordance with NRC Inspection Manual Chapter (IMC) Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings, and determined that the finding was of very low safety significance (Green) because the finding 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 (e.g. loss of condenser, loss of feed water.) A loss of a single feed pump or a single recirculation pump typically results in a power reduction but not a reactor scram.

The inspectors determined that the finding had a cross-cutting aspect in the area of Problem Identification and Resolution, Identification. In the case of the finding, PBAPS did not ensure that degraded conditions, namely, out of tolerance SPV instruments, were promptly reported and documented in the corrective action program at a low threshold. (P.1)

.

REPORT DETAILS

4OA2 Problem Identification and Resolution

This inspection constitutes one biennial sample of problem identification and resolution as defined by Inspection Procedure 71152. All documents reviewed during this inspection are listed in the Attachment to this report.

.1 Assessment of Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed the procedures that described PBAPSs corrective action program at Peach Bottom. To assess the effectiveness of the corrective action program, the inspectors reviewed performance in three primary areas: problem identification, prioritization and evaluation of issues, and corrective action implementation. The inspectors compared performance in these areas to the requirements and standards contained in Title 10 Code of Federal Regulations 50, Appendix B, Criterion XVI, Corrective Action, and Exelon procedure LS-AA-125, Corrective Action Program Procedure. For each of these areas, the inspectors considered risk insights from the stations risk analysis and reviewed issue reports selected across the seven cornerstones of safety in the NRCs Reactor Oversight Process. Additionally, the inspectors attended multiple Station Ownership Committee and Management Review Committee meetings. The inspectors selected items from the following functional areas for review: engineering, operations, maintenance, emergency preparedness, radiation protection, chemistry, physical security, and radiation protection.

(1) Effectiveness of Problem Identification

In addition to the items described above, the inspectors reviewed system health reports, a sample of completed corrective and preventive maintenance work orders, completed surveillance test procedures and periodic trend reports. The inspectors also completed field walkdowns of various systems on site, such as the emergency diesel generators, high pressure coolant injection, reactor core isolation cooling, core spray, residual heat removal, and 4kV equipment rooms. Additionally, the inspectors reviewed a sample of issue reports written to document issues identified through internal self-assessments, audits, and the operating experience program. The inspectors completed this review to verify that PBAPS entered conditions adverse to quality into their corrective action program as appropriate.

(2) Effectiveness of Prioritization and Evaluation of Issues

The inspectors reviewed the evaluation and prioritization of a sample of issue reports issued since the last NRC biennial Problem Identification and Resolution inspection completed in May 2013. The inspectors also reviewed issue reports that were assigned lower levels of significance that did not include formal cause evaluations to ensure that they were properly classified. The inspectors review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of resolution. The inspectors assessed whether the evaluations identified likely causes for the issues and developed appropriate corrective actions to address the identified causes. Further, the inspectors reviewed equipment operability determinations, reportability assessments, and extent-of-condition reviews for selected problems to verify these processes adequately addressed equipment operability, reporting of issues to the NRC, and the extent of the issues.

(3) Effectiveness of Corrective Actions

The inspectors reviewed PBAPSs completed corrective actions through documentation review and, in some cases, field walkdowns to determine whether the actions addressed the identified causes of the problems. The inspectors also reviewed issue reports for adverse trends and repetitive problems to determine whether corrective actions were effective in addressing the broader issues. The inspectors reviewed PBAPSs timeliness in implementing corrective actions and effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors also reviewed a sample of issue reports associated with selected non-cited violations and findings to verify that PBAPS personnel properly evaluated and resolved these issues. In addition, the inspectors expanded the corrective action review to five years to evaluate PBAPS actions related to emergency diesel generator (EDG) maintenance and operation.

b.

Assessment

(1) Effectiveness of Problem Identification

Based on the selected samples, plant walkdowns, and interviews of site personnel in multiple functional areas, the inspectors determined that PBAPS generally identified problems and entered them into the corrective action program at a low threshold.

PBAPS initiated approximately 32,000 issue reports between May 2013 and April 2015.

The inspectors observed supervisors at the Station Ownership Committee and Management Review Committee meetings appropriately questioning and challenging issue reports to ensure that identified issues were appropriately characterized for significance level and investigation class. Based on the samples reviewed, the inspectors determined that PBAPS typically trended equipment and programmatic issues, and identified problems in issue reports in an appropriate manner. Additionally, inspectors concluded that personnel were identifying trends at low levels. PBAPS personnel initiated corrective action to address the questions and minor equipment observations identified by the inspectors during plant walkdowns. With the exception of the below finding regarding out of tolerance single point vulnerabilities not being adequately identified in the stations CAP, PBAPS identification of issues was appropriate. The details of this issue are described in the finding in Section 4OA2.1.c below.

(2) Effectiveness of Prioritization and Evaluation of Issues

The inspectors determined that PBAPS appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem. PBAPS screened issue reports for operability and reportability, categorized the issue reports by significance, and assigned actions to the appropriate department for evaluation and resolution. The issue report screening process considered human performance issues, radiological safety concerns, repetitiveness, adverse trends, and potential impact on the safety conscious work environment.

Based on the sample of issue reports reviewed, the inspectors noted that the guidance provided by Exelon corrective action program implementing procedures appeared sufficient to ensure consistency in categorization of issues. Operability and reportability determinations were performed when conditions warranted and the evaluations supported the conclusion. Causal analyses appropriately considered the extent of condition or problem, generic issues, and previous occurrences of the issue.

(3) Effectiveness of Corrective Actions

The inspectors concluded that corrective actions for identified deficiencies were, timely and adequately implemented. For significant conditions adverse to quality, PBAPS identified actions to prevent recurrence. The inspectors concluded that corrective actions to address the sample of NRC non-cited violations and findings since the last problem identification and resolution inspection were timely and effective.

c. Findings

Introduction.

The inspectors identified a finding of very low safety significance (Green)because PBAPS did not initiate issue reports (IR) to identify out-of-tolerance conditions for a number of single point vulnerability (SPV) instruments. An SPV instrument is any instrument for which a single failure could cause a significant power reduction or a plant scram. Specifically, during routine preventative maintenance (PM) calibrations, certain SPV instruments as-found data was found outside expected tolerance bands, with many being significantly outside of their bands. In most cases, IRs were not written to document these adverse conditions contrary to station guidance.

Description.

On August 30, 2013, PBAPS Unit 2 experienced an unplanned trip of the B reactor recirculation motor-generator (MG) set. PBAPS subsequently performed an apparent cause evaluation (ACE) and determined that the MG Set Lube Oil Temperature Switch (TS-4637B) was out of tolerance low and caused the B recirculation MG set to trip prematurely. During subsequent troubleshooting, the as-found calibration check of TS-4637B showed the trip set point to have drifted to 175 degrees F, when the desired set point was 210 degrees F +/- 1.1 degrees F. PBAPS reviewed TS-4637Bs as-found calibration history and found the temperature switch had a history of set point drift.

During each of PBAPSs calibration check PM activities, the temperature switch was able to be returned to within tolerance but no IR was written to document the out of tolerance conditions. Since there are no IRs written to document the as-found results, the component did not get identified as one that needed to be replaced. As a result of the ACE, PBAPS specified a corrective action, ACIT-1552843-17, to communicate the requirement to initiate an IR when instruments were outside of their expected tolerance bands. On December 13, 2013, ACIT-1552843-17 was completed when the PBAPS maintenance manager reinforced the need to initiate IRs for these adverse conditions at a maintenance all-hands meeting.

PBAPS procedure ER-AA-520, Revision 3, Instrument Performance Trending, states that an individual instrument could begin to show signs of failure by not meeting its nominal tolerance band or exceeding the leave alone zone for repeated calibrations.

The inspectors reviewed PBAPS ACE and associated corrective actions including an extent of condition for similar SPVs. PBAPS defines an SPV as any condition in which the failure of a single individual instrument could result in a power reduction of greater than twenty percent reactor power. For example, on February 25, 2015, PBAPS Unit 2 experienced a recirculation runback and rapid reduction in reactor power when the B feed water pump tripped due to the failure of a single reactor feed pump turbine (RFPT)exhaust vacuum pressure trip switch which was classified as an SPV. Because of PBAPS history with SPV instruments, the inspectors selected six groups of SPVs to review to determine if PBAPS staff initiated IRs for these conditions. The inspectors reviewed the calibration history for these groups before and after the December 13, 2013 maintenance all-hands meeting for the following instruments: the RFPT bearing lube oil pressure trip switches, the reactor feed pump suction pressure trip switches, the RFPT exhaust vacuum pressure trip switches, the RFPT stop valve oil pressure trip switches, the RFPT hydraulic power unit header pressure trip switches, and the RFPT bearing low oil pressure trip switches. The PBAPS staff characterized all of these instruments as SPVs.

The inspectors identified 31 PM activities from the group of SPVs where the as-found tolerance data was outside the expected tolerance or leave alone zone as defined in PBAPS procedure MA-AA-716-011, Revision 11, Attachment 2, As Found Condition Codes. Seventeen of the PM activities occurred following the Unit 2 MG set trip on August 30, 2013. Of these 17 activities, PBAPS could only retrieve two IRs that were written to document these out of tolerance conditions. According to PBAPS procedure MA-AA-716-011, if the condition is coded as outside the expected tolerance but able to be adjusted to within tolerance, the procedure step refers personnel to initiate an IR in accordance with procedure PI-AA-120, Revision 1, Issue Identification and Screening Process. Thus, the inspectors identified a number of cases where IRs were not written to document these out of tolerance conditions which was contrary to internal licensee procedural guidance. As a result of this inspection, PBAPS initiated IR 02485800 to evaluate the inspectors concern for the group of SPVs that were not appropriately identified and trended in the CAP.

Analysis.

The inspectors identified a performance deficiency in that PBAPS personnel did not initiate IRs for multiple out-of-tolerance SPV instruments. The finding is determined to be more than minor because it affected the reliability of the initiating cornerstones attribute of equipment performance and affected its objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during power operations. Specifically, by not identifying and trending out-of calibration SPVs in a timely manner, a resulting transient from the loss of a single feed pump or a single reactor recirculation pump is more likely to occur. The inspectors conducted a Phase 1 screening in accordance with NRC Inspection Manual Chapter (IMC) Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings, and determined that the finding was of very low safety significance (Green) because the finding 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 (e.g. loss of condenser, loss of feed water.) A loss of a single feed pump or a single recirculation pump typically results in a power reduction but not a reactor scram.

The inspectors determined that the finding had a cross-cutting aspect in the area of Problem Identification and Resolution, Identification. In the case of the finding, PBAPS did not ensure that degraded conditions, namely, out of tolerance SPV instruments, were promptly reported and documented in the corrective action program at a low threshold.

(P.1)

Enforcement.

This finding does not involve enforcement because no regulatory requirement violation was identified. This finding constituted a failure to adhere to a non-quality assurance program related procedure. Because this finding does not involve a violation and has very low safety significance, it is identified as FIN 05000278/279/2015008-01, Failure to Initiate IRs for Out-of-Calibration SPVs.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed a sample of issue reports associated with review of industry operating experience, including 10 CFR 21 reports, to determine whether PBAPS personnel appropriately evaluated the operating experience information for applicability to Peach Bottom and had taken appropriate actions, when warranted. The inspectors also reviewed evaluations of operating experience documents associated with a sample of NRC generic communications to ensure that PBAPS personnel adequately considered the underlying problems associated with the issues for resolution via their corrective action program. In addition, the inspectors observed various plant activities to determine if the station considered industry operating experience during the performance of routine and infrequently performed activities.

b.

Assessment

The inspectors determined that PBAPS appropriately considered industry operating experience information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues when appropriate. In most cases, the inspectors determined that operating experience was appropriately applied and lessons learned were communicated and incorporated into plant operations and procedures when applicable. The inspectors also observed that industry operating experience was routinely discussed and considered during the conduct of Station Ownership Committee and Management Review Committee meetings.

During review of a specific 10 CFR 21 report, the inspectors noted that PBAPS did not adequately implement corrective actions by transferring vendor recommended actions into plant procedures related to a problem with the Wide Range Neutron Monitor (WRNM). Specifically, on August 9, 2007, PBAPS initiated IR 659120 for the receipt of a 10 CFR 21 report concerning GE Safety Communication SC 07-16, Wide Range Set Parameters Concern. The GE SC 07-16 indicated that an anomaly can occur anytime a user entered parameter is changed. The anomaly changes the Hi-Hi reactor period scram setpoint by a factor of 10 meaning that an original value of 19 seconds would be changed to 190 seconds. On September 21, 2007, the licensee identified that certain procedures, such as, SI2N-60C-WRNM-A1MX and IC-11-00395, Calibration and Alignment for NUMAC Wide Range Neutron Monitor would be affected by this 10 CFR Part 21 report. Plant staff concluded that these procedures would need to be revised to include a statement to verify that the top-level display trip set points represent the desired values upon exit from SET PARAMETERS or at final restoration.

Approximately seven years later, on November 26, 2014, PBAPS Unit 2 experienced an unexpected half scram resulting from the G wide range neutron monitors. Upon investigation, plant staff found that this was caused by conditions described in the Part 21 report and that multiple affected procedures were not identified by IR 659120 and specifically, procedures SI3N-60C-WRNM-A(B-H)1MX were not identified. The NRC determined that procedures SI2N-60C-WRNM-A(B-H)1MX were identified in the IR 659120 and corrective action to revise the procedures was not executed prior to the Unit 2 half scram on November 26, 2014. The inspectors noted that PBAPS staff did not to provide timely implementation of the recommended actions for this Part 21 report.

The inspectors independently evaluated the deficiency noted above for significance in accordance with the guidance in IMC 0612, Appendix B, Issue Screening, and Appendix E, Examples of Minor Issues. The inspectors noted that Unit 2 experienced a half scram condition and not an actual scram. Another scram signal would be required for the plant to scram; therefore, this condition had only minimal safety impact. Thus, the inspectors determined this issue was a deficiency of minor significance, and therefore, was not subject to enforcement action in accordance with the NRCs Enforcement Policy. PBAPS had previously documented in IR 02418039 for this issue.

c. Findings

No findings were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors reviewed a sample of audits, including the most recent audit of the corrective action program, focused area self-assessments, and check-in self-assessments performed by PBAPS. Inspectors performed these reviews to determine if PBAPS entered problems identified through these assessments into the corrective action program, when appropriate, and whether PBAPS initiated corrective actions to address identified deficiencies. The inspectors evaluated the effectiveness of the audits and assessments by comparing audit and assessment results against self-revealing and NRC-identified observations made during the inspection.

b.

Assessment

The inspectors concluded that focused area self-assessments, check-in self-assessments, and audits were critical, thorough, and effective in identifying issues.

The inspectors observed that PBAPS personnel knowledgeable in the subject completed these audits and self-assessments in a methodical manner. PBAPS staff completed these audits and self-assessments to a sufficient depth to identify issues which were then entered into the corrective action program for evaluation. The station implemented corrective actions associated with the identified issues commensurate with their safety significance.

c. Findings

No findings were identified.

.4 Assessment of Safety Conscious Work Environment

a. Inspection Scope

During interviews with station personnel, the inspectors assessed the safety conscious work environment at Peach Bottom. Specifically, the inspectors interviewed personnel to determine whether they were hesitant to raise safety concerns to their management or the NRC. The inspectors also interviewed the station Employee Concerns Program coordinator to determine what actions are implemented to ensure employees were aware of the program and its availability with regards to raising safety concerns. The inspectors reviewed the Employee Concerns Program files to ensure that PBAPS entered issues into the corrective action program when appropriate.

b.

Assessment

During interviews, Peach Bottom staff expressed a willingness to use the corrective action program to identify plant issues and deficiencies and stated that they were willing to raise safety issues. The inspectors noted that no one interviewed stated that they personally experienced or were aware of a situation in which an individual had been retaliated against for raising a safety issue. All persons interviewed demonstrated an adequate knowledge of the corrective action program and the Employee Concerns Program. Based on these limited interviews, the inspectors concluded that there was not evidence of an unacceptable safety conscious work environment and there were not significant challenges to the free flow of information.

c. Findings

No findings were identified.

4OA6 Meetings, Including Exit

On April 24, 2015, the inspectors presented the inspection results to Mr. Patrick Navin, Plant Manager, and other members of the Peach Bottom staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

M. Massaro, Site Vice President

P. Navin, Plant Manager

P. Breidenbaugh, Director - Maintenance

M. Herr, Director - Operations

D. Dullum, Sr. Regulatory Engineer

M. Flynn, Sr. Regulatory Specialist

J. Armstrong, Regulatory Assurance Manager

M. Mitchell, Employee Concerns Representative

S. Griffith, Security Operations Manager

S. Sturm, Security Programs Lead

D. Hild, Acting Shift Operations Superintendent

C. Weichler, Operations Shift Manager

E. Wright, Operations Shift Supervisor

C. Dye, HPSW/ESW System Engineer

E. Fredrickson, Engineering NSSS Manager

B. Holmes, Radiation Protection Manager

F. Leone, Chemistry Manager

D. Baracoo, Radiation Engineering Manager

R. Stiltner, Maintenance I & C Manager

J. Dorris, Maintenance Planning

G. Thompson, Maintenance Planning

B. Binz, Engineering Programs

D. Wheeler, Maintenance Rule Coordinator

R. Brower, Engineering Modification Design Senior Manager

G. Cilluffo, Buried Pipe Corrosion Engineer

M. Simon, EDG Systems Manager

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened and Closed

Open

FIN

05000278/279/2015008-01 Failure to Initiate IRs for Out-of-

Calibration SPVs.