05000361/FIN-2009004-05
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Finding | |
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Title | Failure to Specify Appropriate Requirements in Procurement Documents |
Description | A self-revealing noncited violation of 10 CFR Part 50, Appendix B, Criterion IV, Procurement Document Control, was identified for the failure of procurement engineering personnel to include requirements necessary to assure adequate quality in a safety-related component. Specifically, on June 2, 2006, the procurement document did not specify limits on the amount of moisture allowed in the hydraulic fluid used during refurbishment of hydraulic dump valves at an off-site vendor, resulting in a main feedwater isolation valve and a main steam isolation valve being inoperable for greater than their technical specification allowed outage time. These occurrences were documented in Licensee Event Report 2007-004-00 and Unit 2 was shutdown in order to determine the extent of condition. The licensee determined these valve failures were caused by corrosion due to the introduction of moisture-contaminated Fyrquel hydraulic fluid at the vendor facility. The procurement documents used to contract the replacement and refurbishment services did not include any moisture limits, nor did the vendor documents which were reviewed and approved by the licensee, although these limits were specified in both maintenance and operations procedures at the time. This finding was entered into the licensees corrective action program as Action Request AR 071000901. The failure to include moisture limits in the procurement documents in order to maintain the quality of a safety-related component was a performance deficiency. The finding is more than minor because it is associated with the equipment performance attribute of the mitigating systems cornerstone and affects the cornerstone objective to ensure the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors evaluated the issue using the Significance Determination Process Phase 1 Screening Worksheet for the Initiating Events, Mitigating Systems, and Barriers Cornerstones provided in Manual Chapter 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings. The inspectors determined that this finding represented a loss of safety function of a single train for greater than the technical specification allowed outage time. This required that a Phase 2 estimation be completed. Because the Phase 2 risk-informed notebook did not include appropriate targets for the equipment conditions at the time of discovery, the senior reactor analyst determined that a Phase 3 analysis was required. The analyst calculated a total ACDF of 1.5 x 10-8, therefore this finding is of very low safety significance. A crosscutting aspect is not assigned since the cause of the performance deficiency is not indicative of current performance |
Site: | San Onofre |
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Report | IR 05000361/2009004 Section 4OA3 |
Date counted | Sep 30, 2009 (2009Q3) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | Self-revealing |
Inspection Procedure: | IP 71153 |
Inspectors (proximate) | M Haire N O'Keefe R Kellar A Allen G Warnick J Reynoso |
INPO aspect | |
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Finding - San Onofre - IR 05000361/2009004 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (San Onofre) @ 2009Q3
Self-Identified List (San Onofre)
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