05000315/FIN-2014004-01
Finding | |
|---|---|
| Title | Failure to Follow Operability Determination Procedure |
| Description | A finding of very low safety significance with an associated non-citied violation of 10 CFR 50, Appendix B, Criterion V, Procedures, was identified by the inspectors for the failure to follow the Operability Determination Procedure, PMP-7030-OPR-001. Specifically, for instances of high oil level in the turbine-driven auxiliary feedwater (TDAFW) pump governor sight-glasses and high water concentrations in motor-driven auxiliary feedwater (MDAFW) pump bearings, components were assumed to be operable without supporting technical justification. Further, past operability assessments were not assigned for the conditions. During a review of action requests (ARs) associated with the auxiliary feedwater (AFW) system, the inspectors identified four instances since 2008 when th
licensee identified that oil level was high-out-of-sight in a TDAFW pump governor sightglass. The licensee did not assess certain impacts on operability even though several references identified potential adverse impacts with the noted oil level. The operations logs set an appropriate level as being between half-full (minimum) and visible in the sight-glass (maximum). The logs also contained a note stating if level was visible in the sight-glass, the pump was operable. Additionally, the vendor manual and a maintenance procedure cautioned against the level being high in the system. No documentation was provided that addressed these concerns. In regards to the MDAFW pumps, the inspectors identified ARs documenting periodic instances of high water concentrations in the pump bearings. When subsequent licensee analysis confirmed significantly high concentrations of water, no past operability assessments were done to assess any impacts the moisture may have had. In each instance of a high oil level or high moisture result, the licensee corrected the condition after discovery. The licensee also generated an AR to explore the inspectors concerns with regard to a lack of documented justification for operability while the conditions existed. The issue was more than minor because it adversely affected the Equipment Performance attribute of the Mitigating Systems Cornerstone. Specifically, the failure to properly assess the operability of safety related components (with all relevant information) can impact the availability, reliability, and capability of systems that respond to initiating events, in that components assumed to be operable may actually be in a condition where they cannot reliably perform their safety functions. Further, if left uncorrected, the issue could become a more significant safety concern as future operability determinations could also be deficient. The inspectors were also informed by IMC 0612, Appendix E, examples 3.j an 3.k, in that equipment inoperability is not a prerequisite for an issue being more than minor. Per the guidance, the inspectors determined reasonable doubt existed regarding the operability of components. The finding screened as Green, or very low safety significance, because the performance deficiency of failing to follow the Operability Determination procedure did not in itself represent a loss of system and/or function. The inspectors determined the finding had an associated cross-cutting aspect in the area of Problem Identification and Resolution. Specifically, the organization did not thoroughly evaluate issues to ensure resolutions address causes and extent of conditions commensurate with their safety significance (P.2). P.2, Evaluation, aligns with the Safety Culture Common Language attribute of PI.2, Evaluation, outlined in NUREG-2165. Examples under PI.2 include prioritizing and thoroughly investigating issues with regard to their safety significance. The licensee did not address all of the relevant information which could impact the operability determinations associated with the AFW pumps. |
| Site: | Cook  |
|---|---|
| Report | IR 05000315/2014004 Section 1R12 |
| Date counted | Sep 30, 2014 (2014Q3) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.12 |
| Inspectors (proximate) | V Megani J Ellegood J Mancuso K Riemer M Mitchell R Edwards T Taylor |
| Violation of: | 10 CFR 50 Appendix B Criterion V |
| INPO aspect | |
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Finding - Cook - IR 05000315/2014004 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Cook) @ 2014Q3
Self-Identified List (Cook)
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