05000382/FIN-2011004-01
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Finding | |
|---|---|
| Title | Failure to Evaluate and Adequately Perform Preventive Maintenance Activities Associated with Dry Cooling Tower Process Analog Control Cards |
| Description | The inspectors identified a non-cited violation of 10 CFR 50.65 (a)(3) because the licensee did not adequately evaluate and take into account, where practical, industry operating experience related to preventive maintenance activities for the dry cooling tower process analog control cards. Specifically, internal and industry-wide operating experience documented previous failures of process analog control cards due to age-related degradation after about 15 years of services. The vendor and industry performed a benchmark in 2003, and noted that the average service life is about 12 to 15 years. The licensee initially provided a preventive maintenance activity to replace the cards on a 20 year interval. However, the licensee deleted the preventive maintenance activities in March of 2009. The licensee determined that the cards were non-critical and had no justification of deleting the preventive maintenance activities. The inspectors noted that after the deletion of the preventive maintenance activities and prior to the 15 year service internal, the licensee experienced additional unplanned failures of several process analog control cards that challenged dry cooling tower reliability. The licensee entered this issue into their corrective action program for resolution as CR-WF3- 2011-1356. The immediate corrective action includes the evaluation of the preventive maintenance activity for the dry cooling tower process analog control cards. The planned corrective action includes the reinstatement of the preventive maintenance activity that aligns with industry operating experience. The finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The process analog control card failures challenged the system availability and reliability. The inspectors performed the initial significance determination using NRC Inspection Manual Chapter 0609, Attachment 0609.04, Phase 1 Initial Screening and Characterization of Findings. The inspectors determined that the finding is of very low safety significance (Green) because the condition is not a design or qualification deficiency, did not represent the loss of a system safety function, did not represent an actual loss of a single train of equipment for more than its Technical Specification completion time, and did not screen as potentially risk-significant due to an external initiating event. This finding has a cross-cutting aspect in the operating experience component of the problem identification and resolution area in that the licensee did not implement and institutionalizes operating experience through change to station processes, procedures, equipment, and training programs |
| Site: | Waterford  |
|---|---|
| Report | IR 05000382/2011004 Section 1R12 |
| Date counted | Sep 30, 2011 (2011Q3) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.12 |
| Inspectors (proximate) | M Davis S Garchow J Melfi R Azua D Overland E Uribe |
| CCA | P.5, Operating Experience |
| INPO aspect | CL.1 |
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Finding - Waterford - IR 05000382/2011004 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Waterford) @ 2011Q3
Self-Identified List (Waterford)
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