The inspectors identified a self-revealing Green
NCV of
10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, because Entergy staff did not implement the prescribed maintenance instructions during the refurbishment of the airoperated valve (
AOV) actuator for a drywell floor drain containment isolation valve. Specifically, Entergy staff used a lubricant other than the type specified per the equipment manual, which was incompatible with the seals in the valve. Entergys immediate corrective actions included entering the issue into their corrective action program as CR-VTY-2013- 05763, performing a rebuild of the valve, and troubleshooting the as-found condition. This finding is more than minor because it is associated with the
SSC and barrier performance attribute of the
Barrier Integrity cornerstone and affected the cornerstone objective to provide reasonable assurance that physical design barriers (e.g., containment) protect the public from radionuclide releases caused by accidents or events. Specifically, when tested, the valve exceeded the maximum allowable
stroke time for closure and was declared
inoperable. In accordance with
IMC 0609.04, Initial Characterization of Findings, and Exhibit 3 of
IMC 0609, Appendix A, The
Significance Determination Process (
SDP) for Findings At-Power, issued June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) because it was associated with the functionality of the reactor containment but did not represent an actual open pathway in the physical integrity of containment, containment isolation system, and heat removal components. This finding has a cross-cutting aspect in the area of Human Performance, Procedure Adherence, because Entergy personnel did not properly implement the requirements prescribed in the maintenance instructions. Specifically, during the refurbishment of the valves actuator, Entergy staff did not use the lubricant specified in the equipment manual referenced in the work order.
