The inspectors identified a non-cited violation of
10 CFR 50.65(a)(4) for failure to implement a procedurally-required risk management activity for an orange risk activity. The licensee failed to provide required management oversight of a critical step in a surveillance test of the
Auxiliary Feedwater System Train 1. The surveillance test rendered the train
inoperable and unavailable. The licensee entered the issue into their corrective action program. The finding is greater than minor using the guidance of
IMC 0612, Appendix B, Section 3 (Minor Questions), question (5)(i) and question (2). The licensee failed to implement prescribed significant compensatory measures for an elevated risk activity; and if the practice were left uncorrected, the issue would become a more significant safety concern involving programmatic issues. The finding was of very low safety significance, using
IMC 0612, Appendix K, flowchart 2, because the incremental core damage frequency associated with the surveillance was less than 1 X 10-6. A contributing cause of the finding is related to the cross-cutting element of human performance (H4.(b)) in that there were varying expectations on the extent of procedure compliance, and some personnel were not complying with all elements of applicable procedures
