Inspectors identified an
NCV of
10 CFR 50, Appendix B, Criterion XVI, Corrective Action, when Ginna failed to promptly identify and correct a
condition adverse to quality associated with out-of-specification oil samples for the A
residual heat removal (
RHR) and A safety injection pumps. Specifically, Ginna did not submit the oil samples for analysis for 37 days and when informed of out-of-specification conditions on the A safety injection pump on February 18, 2008, and the issue was not documented or assessed in the Ginna corrective action program until February 25, 2008. This finding is greater than minor because it is associated with the equipment performance attribute of the
Mitigating Systems cornerstone and affected the cornerstones objective to ensure the availability, reliability, and capability of systems that respond to
initiating events to prevent undesirable consequences. Specifically, by not promptly assessing the significance of the out-of-specification oil samples, the potential inoperability of the safety injection pump was not evaluated. The inspectors determined that this finding was of very low safety significance (Green), because the finding is not a design or qualification deficiency, did not represent a loss of a safety function, and did not screen as potentially risk significant due to external events. This finding is similar to example 3.k in
Appendix E of IMC 0612, in that the oil sample program had programmatic weaknesses that could
lead to worse conditions if not corrected. This finding has a cross-cutting aspect in the area of problem identification and resolution because Ginna had not implemented appropriate corrective actions to ensure oil samples that are out-of-specification are promptly assessed (
P.1.d per
IMC 0305)
