A Green self-revealing non-cited violation of
Technical Specification (TS) 5.4.1, Procedures, was identified for the licensees failure to adequately implement their inservice test procedure for the Unit 1 standby makeup pump (
SMP). Operators performed procedure steps out of sequence which resulted in the pumps discharge relief valve lifting, requiring valve replacement. The licensee entered this issue into their corrective action program as nuclear condition report (NCR) 1954266. The performance deficiency was considered to be more than minor because it was associated with the equipment performance 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, the
SMP was unavailable to perform its safety function during unplanned testing and maintenance. The internal events risk contribution was determined by the inspectors to be
3E-7 and thus required a senior reactor analyst to review for external events and
large early release frequency (
LERF) to ensure the finding was below the Green/White threshold. The external events contribution was determined to be
5E-7 and thus the total risk was
8E-7 and core damage frequency (
CDF) was determined to be the limiting metric. Consequently the finding was determined to be of very low safety significance (Green). This finding had a cross-cutting aspect of avoid complacency, as described in the human performance cross-cutting area, because the operators failed to implement appropriate error reduction tools such as formal three-way communications while performing the
SMP surveillance procedure. [H.12]
