The inspectors identified an
AV of
Technical Specification 5.4.1.a, Procedures, for the failure of the licensee to implement an effective preventive maintenance (
PM) program for the turbine-driven
auxiliary feedwater (
TDAFW) pump governor linkage. Specifically, procedure M-11.5C,
AFW Pump Minor Mechanical Inspection and Maintenance, Revision 29, which includes steps for cleaning and lubricating the
TDAFW pump governor linkages, was not properly implemented. The cleaning and lubrication steps were inappropriately deleted during the work planning process for the
PM scheduled on the
TDAFW system. As a result, the governor linkages were not lubricated during the March 2008 maintenance period, which directly contributed to the failure of the
TDAFW pump as demonstrated by testing performed on December 2, 2008. Ginnas planned corrective actions include increased frequency of testing to validate the identified root cause and appropriate resolution, upgrades to the maintenance procedure for disassembly and lubrication of bearing wear surfaces and linkages, and guidance on the type of lubricant to use. In addition, corrective actions include enhancements to the scope of minor maintenance requirements on the
TDAFW pump to ensure that the linkage cleaning and lubrication is not missed, and establishing a 9-year periodicity to rebuild the governor and associated linkages. The inspectors determined that this finding is more than minor because it is associated with the procedure quality attribute of the
Mitigating Systems Cornerstone and affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to
initiating events to prevent undesirable consequences. Specifically, the failure to perform adequate maintenance resulted in the inoperability of the
TDAFW pump. This finding was assessed using
IMC 0609 and preliminarily determined to be White based on a Phase 3 analysis with a total (internal and external contributions)calculated conditional core damage frequency (CCDF) of 8.8E-6. This finding has across-cutting aspect in the area of human performance because Ginna did not establish appropriate controls to assess how changes to the
TDAFW PM program would impact operation of the
TDAFW system (
H.3.b per
IMC 0305).
