05000331/FIN-2014004-03
Finding | |
|---|---|
| Title | Failure to Perform Causal Evaluations for A Standby Filter Unit Issues |
| Description | A finding of very low safety significance with no associated violation was identified by the inspectors for the licensees failure to accomplish procedure PI-AA-204, Condition Identification and Screening Process, Revision 24. Specifically, on September 4, 2014, the inspectors identified that an inappropriate significance level (SL) was assigned t
CRs 01976835 and 1977206 following the extension of a planned TS Limiting Condition for Operation (LCO) (treated as an unplanned LCO) due to the failure of the A standby filter unit (SFU) exhaust isolation AV-7322A to close in a timely manner during surveillance testing. Although the apparent failure mechanism was known and several corrective actions were taken, an apparent cause evaluation (ACE) was not performed (or ACEnonperformance justified) to review the cause of the mispositioning as well as why adequate post maintenance testing was not performed following charcoal replacement in January of 2014. The licensee entered the issues into the CAP as CR 01989031, and performed ACEs to evaluate why the speed control valve was out of position closed, why an adequate post maintenance test (PMT) was not performed in January of 2014, and why the inappropriate SL was assigned following the unplanned LCO. The inspectors determined that the issue of concern represented a performance deficiency because it was the result of the licensees failure to meet a procedural requirement, and the cause was reasonably within the licensees ability to foresee and correct and should have been prevented. Per PI-AA-204, Attachment 3, CRs 01976835 and 01977206 documented extensions of planned LCO entries and should have been assigned SL 2-level ACEs (or non-performance justifications). The performance deficiency was determined to be more than minor and a finding because if left uncorrected, failing to evaluate the cause of inadequate PMTs following maintenance on safety-related equipment would have the potential to lead to a more significant safety concern. The inspectors applied IMC 0609, Attachment 4, Initial Characterization of Findings, to this finding. The inspectors answered No to all questions within Table 3 SDP Appendix Router, and transitioned to IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power. Because the finding only represented a degradation of the radiological barrier function provided for the control room per Exhibit 3 Barrier Integrity Screening Questions, the finding screened as very low safety significance (Green). The inspectors determined that the performance characteristic of the finding that was the most significant causal factor of the performance deficiency was associated with the cross-cutting aspect of H.13, Consistent Process, and involvin individuals using a consistent systematic approach to making decisions. Specifically, th failure to appropriately characterize the unplanned LCO to invoke appropriate causa evaluations demonstrated an inconsistency in licensee decision making within the CAP [H.13] |
| Site: | Duane Arnold  |
|---|---|
| Report | IR 05000331/2014004 Section 1R19 |
| Date counted | Sep 30, 2014 (2014Q3) |
| Type: | Finding: Green |
| cornerstone | Barrier Integrity |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.19 |
| Inspectors (proximate) | B Palagi C Lipa C Zoia J Steffes L Haeg V Myers |
| CCA | H.13, Consistent Process |
| INPO aspect | DM.1 |
| ' | |
Finding - Duane Arnold - IR 05000331/2014004 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
Finding List (Duane Arnold) @ 2014Q3
Self-Identified List (Duane Arnold)
| ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||