A finding of very low safety significance and an associated non-cited violation of Title 10 of the Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was self-revealed for the licensees failure to implement
foreign material exclusion (
FME) controls during the implementation of modification
Work Order 1649339, Modify the Target Rock to Increase the Volume per
Engineering Change 394119, and was contrary to MAAA716008,
Foreign Material Exclusion Program, Revision 9. The failure to implement
FME controls during maintenance led to the failure of the Unit 2 Target Rock
safety relief valve solenoid valve during surveillance testing on April 5, 2016. The licensees corrective actions included replacing the Target Rock
safety relief valve solenoid valve. In addition, the licensee made procedure revisions to the standard template for welding activities to ensure that a
FME plan is developed when performing butt welds or weld repairs. The licensee entered this issue into their corrective action program as
Issue Report 2703233. The finding was determined to be more than minor because the finding was associated with the
Mitigating Systems Cornerstone attribute of Equipment Performance. The inspectors determined the finding represented a potential loss of the valve function and, therefore, a detailed risk evaluation was required. A regional senior risk analyst performed a detailed risk evaluation and determined the finding was of very low safety significance. This finding had a cross-cutting aspect in the area of Human Performance, Work Management, because the licensee did not implement a process of planning, controlling, and executing work activities such that nuclear safety was an overriding priority. Specifically, during the implementation of
Work Order 1649339 and subsequent revisions, the licensee failed to control and execute the work while following
FME processes and procedures [H.5].
