05000387/FIN-2014009-02
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Finding | |
|---|---|
| Title | Failure to Conduct Timely Initial Operability Determinations |
| Description | The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for PPLs failure to complete and document initial operability determinations in a timely manner in accordance with station procedures. Specifically, station personnel failed to complete and document initial operability determinations in a timely manner, consistent with PPL procedure NDAP-QA- 0703, Operability Assessments and Requests for Enforcement Discretion, Revision 24. In response to this issue, PPL issued Operations Directive 14-01 to reiterate the expectation that operations complete the initial operability screening within eight hours or the end of shift, whichever is shorter, as delineated in NDAP-QA-0703. Additionally, the station continues to conduct Periodic Operability Review Meetings to review a sample of operability determinations for consistency with NDAP-QA-0703. The station entered this issue into the corrective action program as condition reports 2014-18806 and 2014- 19008 for further evaluation. This finding is more than minor because if left uncorrected, the continued performance of untimely initial operability determinations could become a more significant safety concern. Specifically, the failure to assess operability in a timely manner can lead to exceeding technical specification allowed completion times and required actions, up to and including required plant shutdowns. Additionally, this issue is similar to items 3.j and 3.k in IMC 0612, Appendix E, Examples of Minor Issues. Given the duration of time the deficiency has existed, combined with the number of examples identified during the inspection, the inspectors considered this issue to be programmatic. In accordance with IMC 0609, Significance Determination Process, Attachment 4, Initial Characterization of Findings, Table 2, Cornerstones Affected by Degraded Condition or Programmatic Weakness, inspectors determined this performance deficiency affected the Mitigating Systems Cornerstone. Using IMC 0609, Appendix A, The SDP for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, issued June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) since question A.1 was answered Yes because the performance deficiency did not result in the loss of operability or functionality of any structure, system, or component. Additionally, the inspectors did not identify any instances where an untimely initial operability screening resulted in exceeding a TS allowed outage time. The inspectors determined that this finding had a Human Performance cross-cutting aspect related to change management. In this case, PPL revised procedure NDAP-QA- 0703 in March 2013 to change the guidance on timeliness without executing a change management plan to determine if the organization would be able to adhere to the more restrictive guidelines given that other corrective actions were in place to increase the required documentation for an initial operability determination. The inspectors determined that this finding had a human performance cross-cutting aspect related to Change Management. In this case, PPL revised procedure NDAP-QA-0703, in March 2013, to change the guidance on timeliness without executing a change management plan to determine if the organization would be able to adhere to the more restrictive guidelines given that other corrective actions were in place to increase the required documentation for an initial operability determination. [H.3] |
| Site: | Susquehanna  |
|---|---|
| Report | IR 05000387/2014009 Section 4OA2 |
| Date counted | Jun 30, 2014 (2014Q2) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71152 |
| Inspectors (proximate) | A Defrancisco B Bickett F Bower T Daun |
| Violation of: | 10 CFR 50 Appendix B Criterion V Technical Specification Technical Specification - Procedures |
| CCA | H.3, Change Management |
| INPO aspect | LA.5 |
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Finding - Susquehanna - IR 05000387/2014009 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Susquehanna) @ 2014Q2
Self-Identified List (Susquehanna)
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