05000397/FIN-2016007-01
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Finding | |
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Title | Programmatic Concern Pertaining to Columbia Generating Stations Procedures |
Description | The team identified a Green, non-cited violation of Technical Specification 5.4, Procedures, Section 5.4.1, which states, in part, Written procedures shall be established, implemented, and maintained covering the following activities: a. The applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978; Regulatory Guide 1.33, Revision 2, Appendix A, Section 1, Administrative Procedures, Subsection d, specifies Procedure Adherence and Temporary Change Method. This requirement includes plant Procedure SWP-PRO-01, Procedure and Work Instruction Use and Adherence, Revision 27; Procedure SWP-PRO-02, Preparation, Review, Approval and Distribution of Procedures, Revision 42; and Procedure SWP-PRO-03, Writers Manual, Revision 21, which identify the requirements governing procedural requirements utilized at Columbia Generating Station. Specifically, from June 6 through June 23, 2016, multiple examples of procedural compliance were identified with the station procedures. These examples include failure to follow procedures, inadequate procedures, not correctly translating design requirements into procedures, validation of procedures, and the distribution of procedures. In response to this issue, the licensee reviewed each individual concern and confirmed that there were no operability concerns. The licensee has also placed each identified concern into their corrective action program and will address each issue. This finding was entered into the licensees corrective action program as Action Request (AR) 00351364. The team determined that the licensees failure to follow guidance procedures for implementation, adherence, accuracy, verification, and distribution of station procedures, was a performance deficiency. This finding was more than minor because it was associated with the procedures attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, failing to have accurate procedures, and to comply with these procedures, was a significant programmatic deficiency that could adversely affect the reliability and capability of systems used to prevent undesirable consequences. In accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, Exhibit 2, Mitigating Systems Screening Questions, the issue screened as having very low safety significance (Green) because it was a design or qualification deficiency that did not represent a loss of operability or functionality; did not represent an actual loss of safety function of the system or train; did not result in the loss of one or more trains of nontechnical specification equipment; and did not screen as potentially risk-significant due to seismic, flooding, or severe weather. The team determined that this finding had a cross-cutting aspect in the area of human performance, resources, where the licensee will ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety. Specifically, the licensee had not ensured that site procedures were adequate to support plant activities (H.1). |
Site: | Columbia |
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Report | IR 05000397/2016007 Section 1R21 |
Date counted | Jun 30, 2016 (2016Q2) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.21M |
Inspectors (proximate) | I Anchondo J Braisted J Mchugh R Kopriva S Graves |
Violation of: | Technical Specification |
CCA | H.1, Resources |
INPO aspect | LA.1 |
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Finding - Columbia - IR 05000397/2016007 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Columbia) @ 2016Q2
Self-Identified List (Columbia)
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