The inspectors identified a
NCV of
TS 4.2.2 for the failure to implement applicable American Society of Mechanical Engineers (
ASME) Operation and Maintenance (
OM) Code requirements for comprehensive in-service testing (
IST) of the A and B
decay heat removal (DH) pumps. Specifically, AmerGen used differential pressure
gauges that did not meet the data collection requirements for instrument accuracy. This finding is more than minor because it is similar to
IMC 0612, Appendix E, example 2C, in that, the issue was repetitive (2005 and 2007 comprehensive tests). Additionally, this finding is associated with the Equipment Performance Attribute of the
Mitigating Systems Cornerstone and the associated cornerstone objective of ensuring the reliability of systems that respond to
initiating events to prevent undesirable consequences. This finding was of very low safety significance because it involved a qualification deficiency that was confirmed not to result in a loss of operability. This finding has a cross-cutting aspect in the area of
PI&R, corrective actions program component, because AmerGen personnel identified the issue in 2005, but did not take appropriate CAs in a timely manner prior to testing the pumps in 2005 and 2007.
P.1(d) (Section 4OA2.a.3.c)
