05000277/FIN-2009004-02
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Finding | |
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Title | Inadequate Procedure Adherence Results in the Loss of Safety Function of Systems Supplied by the Sgig System |
Description | A self-revealing Green NCV was identified for failure to comply with Technical Specification (TS) 5.4.1 J Procedures, which required that procedures be established, implemented, and maintained for the safety grade instrument gas (SGIG) system. Specifically, the SGIG Pressure Building Circuit Outlet Block Valve (HV-0-7C-1 0) was manipulated without procedure guidance, was out of its normal position, and resulted in the inoperability of certain valves associated with the primary containment and containment atmosphere dilution (CAD) systems for both units. Based on the above, the inspectors determined that manipulating the SGIG Pressure Building Circuit Outlet Block Valve (HV-0-7C-10) without procedure guidance was a performance deficiency that was reasonably within PBAPS\'s ability to foresee and prevent. The inspectors concluded that the manipulating HV-0-7C-10 without a procedure was a more than minor finding because it was associated SSC and barrier performance attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that the containment would protect the public from radionuclide releases caused by accidents or events. Specifically, certain valves associated with the primary containment and containment atmosphere dilution (CAD) systems could not be operated as designed due to this valve being out of its normal position. Traditional enforcement does not apply since there were no actual safety consequences or potential for impacting the NRC\'s regulatory function, and the finding was not the result of any willful violation of NRC requirements. Accordingly, the inspectors assessed the finding in accordance with IMC 0609, SOP, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings, Table 4a, for the Containment Barrier cornerstone. The finding was determined to be of very low safety significance (Green) since the finding did not represent an actual open pathway in the physical integrity of the reactor containment (isolation valves). The inspectors determined that this finding had a cross-cutting aspect in the area of Human Performance, Work Practices component, because human error prevention techniques, such as peer and self checking, were inadequately used to prevent mispositioning the SGIG Pressure Building Circuit Outlet Block Valve (HV-0-7C-10). (IMC 0305 Aspect H.4(a) |
Site: | Peach Bottom |
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Report | IR 05000277/2009004 Section 4OA3 |
Date counted | Sep 30, 2009 (2009Q3) |
Type: | NCV: Green |
cornerstone | Barrier Integrity |
Identified by: | Self-revealing |
Inspection Procedure: | IP 71153 |
Inspectors (proximate) | M Brown S Barr P Finney R Nimitz F Bower A Ziedonis P Krohn J Commisky |
CCA | H.12, Avoid Complacency |
INPO aspect | QA.4 |
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Finding - Peach Bottom - IR 05000277/2009004 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Peach Bottom) @ 2009Q3
Self-Identified List (Peach Bottom)
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