05000266/FIN-2011002-04
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Finding | |
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| Title | Unacceptable Preconditioning of Technical Specification Required Surveillance Test |
| Description | A finding of very low safety significance and associated non-cited violation of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, was identified by the inspectors for the licensees unacceptable preconditioning of a technical specification required surveillance test on September 14, 2010, and January 18, 2011. Specifically, by performing procedure PC 97, Part 7, service water flushes of the Unit 2 containment fan cooler (CFC) units prior to the performance of the fan cooler units monthly surveillance tests, the licensee failed to ensure that work activities were sequenced in a manner that preserved the as-found conditions of the structure, system, and component (SSC), which constituted unacceptable preconditioning. Upon notification from the inspectors of this issue, the licensee initiated a condition report and subsequently performed a condition evaluation that proposed permanent corrective actions such as procedure changes to explicitly prohibit such sequencing of activities. Additionally, in the interim, the licensee immediately communicated to its operators the need to sequence the activities appropriately. The finding was determined to be more because it was associated with the Barrier Integrity Cornerstone attribute of SSC and Barrier Performance and adversely affected the cornerstone objective of providing reasonable assurance that physical design barriers (containment, in this case) protect the public from radionuclide releases caused by accidents or events. Specifically, because the preconditioning altered the as-found condition of the CFCs, the data collected through the performance of the procedure TS 34 surveillance tests were not fully indicative of the true equipment performance trends of the CFCs. Therefore, this performance deficiency had a direct effect on the licensees ability to fully assess the past operability of the system, as well as the ability to trend as-found data to assess the reliability of the CFCs. The inspectors determined that the finding has a cross-cutting aspect in the area of human performance, work control, because the licensee did not appropriately coordinate work activities by failing to incorporate actions to address the impact of work on different job activities, H.3(b). |
| Site: | Point Beach  |
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| Report | IR 05000266/2011002 Section 1R15 |
| Date counted | Mar 31, 2011 (2011Q1) |
| Type: | NCV: Green |
| cornerstone | Barrier Integrity |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.15 |
| Inspectors (proximate) | M Kunowski M Phalen M Thorpe-Kavanaugh P Cardona-Morales R Ruiz R Winter S Burton T Bilik A Dahbur J Bozga J Jandovitz K Carrington |
| CCA | H.5, Work Management |
| INPO aspect | WP.1 |
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Finding - Point Beach - IR 05000266/2011002 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Point Beach) @ 2011Q1
Self-Identified List (Point Beach)
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