05000333/FIN-2016004-01
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Finding | |
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| Title | Failure to Ensure Proper Configuration Control of a PCIV During Planned Maintenance |
| Description | Green. The inspectors identified a Green NCV of Technical Specification (TS) 5.4, Procedures, because Entergy staff did not implement procedure AP-12.06, Equipment Status Control, as required. Specifically, Entergy personnel did not recognize the impact of a change associated with the tagout of a C residual heat removal (RHR) system primary containment isolation valve (PCIV). This resulted in motor operated valve 10MOV-13C being electrically isolated in the open position without being recognized as a PCIV and without proper entry into TS 3.6.1.3. Entergy restored the valve to operable status, entered this issue into their corrective action program (CAP) as condition report (CR)-JAF-2016-4419, and conducted meetings with each operating crew to discuss the event and reinforce standards for equipment status control and maintaining a questioning attitude. Training was also provided to operators to review the scenario and discuss requirements associated with PCIVs. This finding is more than minor because it was associated with the configuration control attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective of providing reasonable assurance that physical design barriers (containment) protect the public from radionuclide releases caused by accidents or events. Specifically, Entergy staff did not recognize the impact of a change associated with the tagout of a containment isolation valve. The change in the tagout resulted in a failure to isolate the containment isolation valve and enter TS 3.6.3.1 prior to maintenance. The finding was similar to Example 3.j in Appendix E of IMC 0612, Examples of Minor Issues, issued August 11, 2009. Since the PCIV was in an open position with power removed, a reasonable doubt of operability existed due to the valves inability to close to perform its containment isolation function. The inspectors evaluated this finding using IMC 0609.04, Initial Characterization of Findings, issued October 7, 2016; Exhibit 3 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012; and Appendix H of IMC 0609, Containment Integrity Significance Determination Process, issued May 6, 2004. Using Exhibit 3 of IMC 0609, Appendix A, Section B, Reactor Containment, the finding directed the use of IMC 0609, Appendix H because it represented an actual open pathway in the physical integrity of reactor containment (i.e. valve). Using IMC 0609, Appendix H, the finding was classified as a Type B finding because it was related to a degraded condition that had potentially important implications for the integrity of containment, without affecting the likelihood of core damage (i.e. containment isolation was precluded by the isolation valve being failed in the open position, however the low pressure coolant injection function remained 4 available). Using Table 6.1, Phase 1 Screening-Type B Findings at Full Power, for a boiling water reactor, Mark 1 Containment, the inspectors were directed to perform a Phase 2 Assessment because the structure, system, and component (SSC) affected by the finding was a containment isolation valve. Using Table 6.2, Phase 2 Risk Significance-Type B Findings at Full Power, the inspectors determined that the failure of the containment isolation valve critical to suppression pool integrity/scrubbing was less than 3 days, and therefore was of very low safety significance (Green). This finding has a cross-cutting aspect in the area of Human Performance, Challenge the Unknown, because Entergy failed to maintain a questioning attitude to identify an improper configuration associated with a PCIV tagout during maintenance planning and execution. Specifically, a tagout writer modified the configuration for a containment isolation valve, which was not challenged or questioned during subsequent reviews. This resulted in the PCIV being tagged out in the open position, a condition that rendered the valve inoperable. [H.11] |
| Site: | FitzPatrick  |
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| Report | IR 05000333/2016004 Section 4OA2 |
| Date counted | Dec 31, 2016 (2016Q4) |
| Type: | NCV: Green |
| cornerstone | Barrier Integrity |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71152 |
| Inspectors (proximate) | A Burritt B Sienel D Kern E Miller J Deboer P Finney S Horvitz S Pindale |
| Violation of: | Technical Specification - Procedures |
| CCA | H.11, Challenge the Unknown |
| INPO aspect | QA.2 |
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Finding - FitzPatrick - IR 05000333/2016004 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (FitzPatrick) @ 2016Q4
Self-Identified List (FitzPatrick)
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