05000440/FIN-2014005-05
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Finding | |
|---|---|
| Title | Licensee-Identified Violation |
| Description | Title 10 CFR, Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, states in part that, activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances. The requirements of Criterion V apply to Criterion XVI of Appendix B, Corrective Action, which states, in part, that Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deviations, defective material and equipment, and non-conformances are promptly identified and corrected. Contrary to the above requirements, on October 27, 2014, the licensee completed a surveillance to time the operation of main steam line drain valves and could not determine the stroke time for one of the valves; 1N22F420C had a failed position indication element resulting in the inability to time the valve. The valve was declared inoperable and TSs were entered as appropriate. However, no corrective action document was initiated, contrary to procedure NOPLP2001, Corrective Action Program, which requires that, Condition Reports will be initiated upon discovery of any degraded condition that affects a safety structure, system, or component or any USAR described system, structures, or component. The main steam drain system is described in the USAR and the CAP is intended to meet the requirement of Criterion V to provide a quality procedure to support the requirements of Criterion XVI. The performance deficiency of failing to write a corrective action document was discovered when the valve timing failed again during a performance of the test on December 15, 2014, and the operators noted that no repairs had been made since the conduct of the test in October 2014, during which the valve stroke timing test initially failed. The performance deficiency was documented in the CAP as CR 201418329. The finding was determined to be more than minor in accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated September 7, 2012, because the finding was associated with the Mitigating Systems Cornerstone attribute of equipment performance and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Additionally, if left uncorrected, the performance deficiency would become a more significant safety concern. The finding was evaluated using IMC 0609, Significance Determination Process, Attachment 0609.4, Initial Characterization of Findings, dated June 19, 2012. Exhibit 2 of Appendix A, the Mitigating Systems Screening Questions, Section A.1, Mitigating SSCs and Functionality, was checked as Yes because the finding is a deficiency affecting design or qualification. As a result, the finding screens as very low safety significance. |
| Site: | Perry  |
|---|---|
| Report | IR 05000440/2014005 Section 4OA7 |
| Date counted | Dec 31, 2014 (2014Q4) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | Licensee-identified |
| Inspection Procedure: | |
| Inspectors (proximate) | D Reeser J Beavers J Nance M Kunowski M Marshfield R Edwards B Palagi |
| Violation of: | 10 CFR 50 Appendix B Criterion V Technical Specification Technical Specification - Procedures |
| INPO aspect | |
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Finding - Perry - IR 05000440/2014005 | |||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Perry) @ 2014Q4
Self-Identified List (Perry)
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