05000261/FIN-2016001-05
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Finding | |
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| Title | Failure to Adequately Maintain Emergency Operating Procedures EOP-ECA-0.0 and EOP-E-0 |
| Description | The NRC identified a Green NCV of TS 5.4.1.a for the licensees failure to adequately maintain procedures EOP-ECA-0.0, Loss of All AC Power, and EOP-E-0, Reactor Trip or Safety Injection, as recommended in Regulatory Guide (RG) 1.33, Quality Assurance Program Requirements (Operations), Revision 2, dated February 1978. Specifically, both procedures contained inadequate procedure steps. Revision four of EOP-ECA-0.0, contained a step that could delay or prevent the restoration of a charging pump when electrical power was available to do so. This could have led to a loss of reactor coolant system (RCS) pressure control. Revision six of EOP-E-0, contained a step that could have led to the restoration of seal injection to overheated reactor coolant pump (RCP) seals with subsequent RCP seal damage and RCS leakage. The licensee submitted procedure revision requests (PRRs) 2009136 and 2009217 to correct the procedures. The licensee entered this issue into their CAP as CR 2009602. The licensees failure to adequately maintain the emergency operating procedures by having inadequate procedure steps, was a performance deficiency. The performance deficiency was determined to be more than minor because, if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, steps in EOP-ECA-0.0 and EOP-E-0 could lead to one or more of the following during an event: unnecessary reduction in core sub-cooling margin, loss of RCS pressure control, RCP seal damage, and/or excessive RCS leakage. The finding is associated with the procedure quality attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems needed to respond to initiating events to prevent undesired consequences. Using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, the inspectors determined that the finding was of very low safety significance (Green) because the finding: (1) was not a deficiency affecting the design and qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality; (2) did not represent a loss of a safety system and/or function; (3) did not represent an actual loss of function of at least a single train of a plant system for longer than its TS allowed outage time, or two separate safety systems out-of-service for longer than their TS allowed outage time; and (4) did not represent an actual loss of function of one or more non-TS trains of equipment designated as high safety-significance in accordance with the licensees maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The finding has a cross-cutting aspect in the area of human performance associated with avoiding complacency because individuals did not recognize and plan for the possibility of mistakes and latent issues when performing EOP verification and validation. |
| Site: | Robinson  |
|---|---|
| Report | IR 05000261/2016001 Section 4OA5 |
| Date counted | Mar 31, 2016 (2016Q1) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | |
| Inspectors (proximate) | A Nielsen C Scott D Bacon G Hopper J Parent K Ellis W Loo |
| Violation of: | Technical Specification - Procedures Technical Specification |
| CCA | H.12, Avoid Complacency |
| INPO aspect | QA.4 |
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Finding - Robinson - IR 05000261/2016001 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Robinson) @ 2016Q1
Self-Identified List (Robinson)
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