The team identified an unresolved item (
URI) for failure to follow procedures during performance of a TS required
PT for ND pump 1B. Specifically, steps in completed procedure PT/1/A/4204/001B were signed by an individual that was not qualified to sign the steps, the individual signed steps as completed which were not performed, and the individual designated a non-conditional step as being not applicable (N/A). This item is unresolved pending further NRC review of the circumstances surrounding these examples of failure to follow procedures.Analysis: Failure to follow procedures PT/1/A/4204/001B and OMP 4-1 is a performance deficiency. This finding is related to the procedure quality attribute of the
mitigating systems cornerstone and affects the objective of ensuring the availability, reliability, and capability of systems that respond to
initiating events to prevent undesirable consequences. The failure to follow procedures did not affect the pump performance during the periodic test and there was no actual loss of safety function. Enforcement:
10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Procedure OMP 4-1, Use of Operating and Periodic Test Procedures, Revision 28 stated that procedure users shall be qualified to perform the task, initial or check each step after the action is completed, and shall not N/A any non-conditional step, unless approved. Contrary to the above, during the performance of PT/1/A/4204/001B, 1B ND Pump Performance Test, Revision 72, on October 2, 2005, the procedure user signed certain steps without having the appropriate qualifications, initialed steps as being completed that were not performed, and marked N/A on a non-conditional step without documented approval. This condition has existed since October 2, 2005. The licensee entered this item into the corrective action program as
PIP M-06-1462. This finding is identified as
URI 05000369/2006007-01, Failure to Follow Procedure During ND Pump 1B Performance Test. This finding is unresolved pending further NRC review of the circumstances surrounding these examples of failure to follow procedures.
