During this inspection, several examples of procedural non-compliance were identified that were associated with the station corrective action program procedure. An adverse performance trend in procedural compliance appeared to be developing in several cornerstone elements. The specific procedural adherence issues were associated with
AD-AA-106 Corrective Action Process Program Procedure, Section 4.6.2.2, Class B Evaluations where the licensee had not implemented the requirement to initiate new condition reports following a class B Common Cause Analysis when a potential adverse trend was validated. One non-cited violation of
10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified
The issue was of very low safety significance based on the inspector risk significance screening of this finding in accordance with NRC Inspection Manual Chapter 0610*, Power Reactor Inspection Reports, Appendix B, Thresholds for Documentation. Because the failure to initiate Condition Reports (CRs) when common causes or trends were identified did not have an actual or credible impact on safety, the issue was not evaluated using
NRC Manual Chapter 0609,
Significance Determination Process. However, the finding was more than minor based on extenuating circumstances (Group 3 Questions). The finding was considered to be a substantive cross-cutting issue because the issue was captured in a number of examples noted in the different functional areas examined during the inspection and across plant departments which indicated an adverse performance pattern.
