05000305/FIN-2009002-02
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Finding | |
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| Title | Inappropriate Application of a Dedicated Operator During a CCW Surveillance |
| Description | A finding of very low safety significance (Green) and associated NCV of10 CFR 50.65(a)(4) was identified by the inspectors for the failure to properly assess risk that resulted from risk significant maintenance being performed on the CCW system, when the licensee inappropriately applied criteria for the use of a dedicated operator to meet availability requirements. While assessing daily risk and maintenance activities for March 11, 2009,the inspectors noted that procedure SP-31-168A, Train A Component Cooling Pump and Valve Test - IST, Revision 15, was performed, yet did not contribute to the daily risk. The inspectors inquired about the basis for not including the test in the daily risk and were informed that the procedure contained steps for a dedicated operator to be stationed locally to accomplish tasks necessary to assure availability of the system. The inspectors reviewed procedure SP-31-168A to assess the controls that allowed the system to be considered available for risk management purposes. ProcedureSP-31-168A required the operator to be stationed locally, for the control room operator and the dedicated local operator to establish communications, for the local operator to be in possession of directions necessary to accomplish system restoration in the event of a need, and for the unit supervisor to provide the restoration order. The inspectors reviewed the guidance contained in NRC-endorsed industry guidance NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, for the definition of Unavailability, SSC. This definition states that SSCs out-of-service for testing are considered unavailable, unless the test configuration is automatically overridden by a valid starting signal, or the function can be promptly restored either by an operator in the control room or by a dedicated operator stationed locally for that purpose. Restoration actions must be contained in a written procedure, must be uncomplicated (a single action or a few simple actions), and must not require diagnosis or repair. Credit for a dedicated local operator can be taken only if (s)he is positioned at the proper location throughout the duration of the test for the purpose of restoration for the train should a valid demand occur. The intent of this paragraph is to allow licensees to take credit for restoration actions that are virtually certain to be successful (i.e., probability nearly equal to 1) during accident conditions. The inspectors concluded that the criteria requiring that the system be promptly restored either by an operator in the control room or by a dedicated operation stationed locally for that purpose was not met because the procedure used the unit supervisor to recognizethe condition and provide the order for restoration, a control room operator tocommunicate the order to the local dedicated operator, and the local dedicated operator to restore the condition. The inspectors noted that the licensee considered the fact that the procedure established communications between the control room operator and the dedicated operator would be sufficient to afford a high degree of certainty that system restoration would be completed if necessary. The inspectors disagreed because the control room operator was not dedicated and could be called to other tasks during an emergency, the procedure did not establish a requirement that the unit supervisor remain at the controls during the performance of the test, and the procedure did not establish requirements to ensure the reliability of the communications equipment. Additionally, the procedure was deficient because in the event on an emergency where the control room operator or unit supervisor may be needed to perform other tasks, it did not institute a requirement to restore the system alignment prior to performing those tasks. The inspectors also concluded that the criterion requiring that restoration actions . . .must not require diagnosis or repair was also not met because the procedure did not provide guidance specifying which indication or alarm would require the initiation of restoration actions. The inspectors interviewed operations department management to ascertain their understanding of expectations and the indications that the unit supervisor would use to make a decision for restoration. Operations management indicated that there could be multiple conditions that may require a restoration decision and that the unit supervisor would know when to make a restoration order. The inspectors concluded that without a singular alarm or indication that keyed the restoration decision, diagnosis of the systems actual performance would be required. Regarding the single operator requirement, the inspectors concluded that, if a remote operator were utilized to recognize and communicate restoration criteria for an operator stationed at the restoration site locally in the field, the remote operator must be equally as dedicated. That is to say, the remote operator should be dedicated and have procedural guidance defining restoration criteria; that the procedurally defined criteria do not require diagnosis or repair, that guidance existed (training, procedural, pre-job brief, etc.) which defined the elements necessary for communications activities; and that reliable and redundant communications methods had been verified to be functional(either by routine surveillance or through a pre-job test), all prior to the performance of the task. Additionally, if the remote or performing operators were the control room operator and was not dedicated, then the control room operator must have restoration criteria that need to be performed prior to the performing/assuming alternate duties. The inspector found that the licensee did not identify any restoration criteria for the control room operator as part of the procedure, training, or as part of the pre-job briefing for the activity. The inspectors asked the licensee to provide the risk information necessary to understand the significance of the activity if a dedicated operator were not credited for immediate restoration. Using the approved risk model in effect during the performance of the surveillance the licensee indicated that the risk, which was modeled as green at4.30E-5, would have been at 1.15E-4, yellow. The inspectors noted that this issue will require a historic review by the licensee and may impact out-of-service times for systems that input into both the maintenance rule and performance indicators. Additionally, the licensees misunderstanding of the requirements necessary to credit availability for a dedicated operator may extend into other procedures. Therefore, the inspectors concluded that the impact of the misapplication of maintenance rule guidance relative to out-of-service times for systems on both performance indicators and maintenance rule availability will be considered an unresolved item (URI) pending a review of the licensee corrective actions and extent-of-condition reviews for this issue (URI 05000305/2009002-02). |
| Site: | Kewaunee  |
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| Report | IR 05000305/2009002 Section 1R13 |
| Date counted | Mar 31, 2009 (2009Q1) |
| Type: | URI: |
| cornerstone | Initiating Events |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.13 |
| Inspectors (proximate) | A Dahbur J Jandovitz J Cassidy M Kunowski R Krsek K Barclay J Bozga R Edwards D Mcneil R Ruiz R Winterj Cassidym Kunowski S Burton K Barclay D Lawver |
| INPO aspect | |
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Finding - Kewaunee - IR 05000305/2009002 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Kewaunee) @ 2009Q1
Self-Identified List (Kewaunee)
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