05000237/FIN-2016003-01
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Finding | |
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| Title | Failure to Assess Scope Changes to Corrective Maintenance Activities Affecting Safety-Related Structures, Systems, and Components |
| Description | A finding of very low safety significance and associated NCV of TS 5.4.1.a, Procedures, was self-revealed for the licensees failure to maintain maintenance procedures appropriate for the circumstances that could affect performance of safety related equipment. Specifically, procedures MAAA716010, Maintenance Planning, Revision 20 and DAP 1518, Work Order Supplemental Information and Lessons Learned, Revision 17 did not ensure that scope revisions in support of corrective maintenance activities performed on high pressure coolant injection (HPCI) piping in 2013 were properly reviewed and evaluated for technical adequacy directly resulting in a through-wall steam leak on the Unit 2 HPCI inlet drain pot drain piping and safety system inoperability in May 2016. Immediate corrective actions included the replacement of the failed piping section, a determination of the extent of condition of susceptible piping to include the scheduling of a replacement work window, and changes to the maintenance planning procedures requiring engineering scope determination and oversight of scope changes for safety related corrective maintenance. The performance deficiency was determined to be more than minor, and thus a finding, in accordance with IMC 0612, Appendix B, Issue Screening, dated September 7, 2012, because it was associated with the Mitigating Systems Cornerstone Attribute of Procedure Quality and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, the failure to ensure work planning procedures controlled the process of major revisions to corrective maintenance activities ensuring adequate engineering reviewing and assessment resulted in continued degradation and ultimate failure of the Unit 2 HPCI inlet drain pot drain piping. The inspectors applied IMC 0609, Attachment 4, Initial Characterization of Findings, issued June 19, 2012, to this finding. The inspectors answered No to all questions within Table 3, Significance Determination Process Appendix Router, and transitioned to IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, June 19, 2012. The inspectors answered No to all questions in Exhibit 2, Mitigating Systems Screening Questions. Therefore, the finding was screened as very low safety significance (Green). This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Evaluation, because the licensee failed to thoroughly evaluate corrective maintenance scope changes to ensure that resolutions address causes and extent of conditions commensurate with their safety significance. Specifically, the licensee incorrectly removed scope without engineering evaluation for adequacy from the Unit 2 HPCI inlet drain pot drain line corrective maintenance following a through wall leak in 2012. Piping that was identified as part of the extent of condition of the failure in 2012, was removed from the scope of corrective maintenance activities due to maintenance personnel short falls. This specific piping failed in May of 2016 resulting in the loss of the HPCI system safety function. [P.2] |
| Site: | Dresden  |
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| Report | IR 05000237/2016003 Section 4OA3 |
| Date counted | Sep 30, 2016 (2016Q3) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | Self-revealing |
| Inspection Procedure: | IP 71153 |
| Inspectors (proximate) | C Phillips G Roach J Cameron J Rutkowski R Elliott |
| Violation of: | Technical Specification |
| CCA | P.2, Evaluation |
| INPO aspect | PI.2 |
| Finding closed by | |
| IR 05000237/2016003 (24 October 2016) | |
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Finding - Dresden - IR 05000237/2016003 | ||||||||||||||||||||||||||||||||||||||
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Finding List (Dresden) @ 2016Q3
Self-Identified List (Dresden)
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