05000387/FIN-2008005-01
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Finding | |
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| Title | Ineffective Evaluation and Incorporation of Operating Experience into the Corrective Action Program |
| Description | A self-revealing finding was identified for failing to properly implement PPL procedure NDAP-QA-0725 regarding the incorporation and evaluation of operating experience (OE) into the corrective action program and control of field work. Specifically, in December 2007 an industry operating experience report regarding the control of field work for nitrogen freeze seals in plant vital areas was entered into Susquehannas corrective action program. However, the inspectors identified that PPLs review and evaluation of this OE resulted in no corrective actions taken or planned and that the relevant information was not communicated to the affected station groups as required by NDAP-QA-0725, Appendix D. Inspectors determined that the lack of corrective actions and inadequate communication of industry OE were primary contributors to the Susquehanna Unit 2 Alert declaration on October 27, 2008. This emergency declaration was required when the oxygen level in the 2B residual heat removal (RHR) pump room, which is a plant vital area, dropped below the minimum allowable threshold of 19.5 percent, which is the Immediately-Dangerous-to-Life-and- Health (IDLH) limit. This finding was more than minor because the failure to properly implement NDAP-QA- 0725, Appendix D, to evaluate external industry OE, implement corrective actions, and communicate the OE information to those who performed the relevant tasks at Susquehanna resulted in prohibiting access to safety-related equipment in the RHR room, resulted in the declaration of an emergency event (Alert), and increased the Technical Specification (TS) out-of-service (OOS) time for the 2B RHR pump. This finding affected the equipment performance attribute of the Mitigating Systems cornerstone and was of very low safety significance (Green) because it was not a design or qualification deficiency, there was no loss of safety function, and it was not potentially risk significant due to external events. The finding was not a violation of regulatory requirements but represented a failure to properly implement NDAP-QA- 0725, Appendix D, in that external OE was not correctly evaluated and as a result, relevant information was not communicated to the affected work groups. PPL entered this issue into their corrective action program (CR # 1086125) and implemented corrective actions that included procedure revisions, reinforcement of procedure adherence, and training and qualification revisions. The inspectors determined that this finding has a cross-cutting aspect in the area of Problem Identification and Resolution (operating experience component) because PPL did not systematically or effectively evaluate and communicate industry OE to affected internal stakeholders in a timely manner. [IMC 0305 aspect: P.2(a). (Section 4OA3 |
| Site: | Susquehanna  |
|---|---|
| Report | IR 05000387/2008005 Section 4OA3 |
| Date counted | Dec 31, 2008 (2008Q4) |
| Type: | Finding: Green |
| cornerstone | Mitigating Systems |
| Identified by: | Self-revealing |
| Inspection Procedure: | IP 71153 |
| Inspectors (proximate) | R Fuhrmeister J Schoppy J Furia T Setzer P Presby P Finney F Jaxheimer G Newman R Torres P Krohn |
| CCA | P.5, Operating Experience |
| INPO aspect | CL.1 |
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Finding - Susquehanna - IR 05000387/2008005 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Susquehanna) @ 2008Q4
Self-Identified List (Susquehanna)
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