05000261/FIN-2008002-01
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Finding | |
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| Title | Failure to determine the cause of and take corrective actions to preclude repetition of an identified programmatic deficiency in foreign-material-exclusion controls |
| Description | Introduction: The inspectors identified a Green non-cited violation of 10 CFR 50.65(a)(4) for the licensees failure on March 10 to perform a risk assessment before establishing maintenance boundaries which removed a boric acid injection flow path from service. As a result of that failure, the licensee incorrectly determined that removing a boric acid injection path from service did not increase plant risk, while according to the sites riskassessment model, removing a boric acid injection path from service increased plant risk from Green to Yellow. On March 10 before authorizing maintenance boundaries to be established that included removing a boric acid injection flow path from service, the licensee failed to assess the increase in plant risk that resulted from this plant configuration. This failure was contrary to site procedure OMM-048, Work Coordination and Risk Assessment, which requires, in part, the use of the licensees risk-assessment methodology to perform an adequate risk review prior to authorizing maintenance boundaries to be established, and that designated licensee personnel remain cognizant of the safety significance of the plant configuration. This finding was more than minor because it is related to a risk assessment and management issue where the licensee failed to consider risk significant systems, structures, or components and support systems that were unavailable during maintenance, in that the licensee failed to consider a boric acid injection flow path that was unavailable during maintenance. As directed by the Phase 1 worksheet in Manual Chapter 0609, Attachment 4, Table 3b, the significance of this finding was evaluated using Manual Chapter 0609, Appendix K. In accordance with Flowchart 1 of Appendix K, because this finding was not related to Risk Management Actions only and because the Risk Deficit was calculated to be less than 1.0E-6, this finding screened as Green. The finding has a cross-cutting aspect in the area of Human Performance because the operations staff did not appropriately plan the work activity of establishing maintenance boundaries by incorporating risk insights of the sites risk model. (H.3(a)) 10 CFR 50.65(a)(4) requires, in part, that before performing maintenance activities, the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities. Furthermore, licensee procedure OMM-048, Work Coordination and Risk Assessment, requires, in part, the use of the licensees riskassessment methodology to perform an adequate risk review prior to authorizing maintenance boundaries to be established, and that designated licensee personnel remain cognizant of the safety significance of the plant configuration. Contrary to the above, on March 10 before performing the maintenance activity of removing a boric acid injection path from service, the licensee failed to assess and manage the increase in risk that would result from that proposed maintenance activity, in that the licensee failed to assess that risk and consequently failed to recognize that this maintenance activity placed the plant in an increased-risk condition. Because this finding was of very low safety significance and has been entered into the licensees corrective action program as AR 269817, consistent with Section VI.A of the NRC Enforcement Policy, this violation is being treated as a non-cited violation, and is designated as NCV 05000261/2008002-01, Failure of the licensee to assess the increased risk resulting from removing a boric acid injection path from service. |
| Site: | Robinson  |
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| Report | IR 05000261/2008002 Section 4OA2 |
| Date counted | Mar 31, 2008 (2008Q1) |
| Type: | URI: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71152 |
| Inspectors (proximate) | A Hutto D Bollock M Coursey D Mills E Michel J Rivera-Ortiz R Hamilton W Loo H Gepford J Austin J Hickey R Mussere Morrisr Hagar R Musser |
| CCA | H.5, Work Management |
| INPO aspect | WP.1 |
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Finding - Robinson - IR 05000261/2008002 | |||||||||||||||||
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Finding List (Robinson) @ 2008Q1
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