05000458/FIN-2014302-01
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Finding | |
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Title | Inadequate System Operating Procedures with Two Examples |
Description | Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, states, in part, Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. Contrary to this, System Operating Procedure SOP-0049, 125 VDC SYSTEM (SYS # 305), Revision 29, did not have the necessary qualitative acceptance criteria (procedure steps) to accomplish the required activity of transferring the 125 VDC standby switchgear ENB-SWG01A to the backup charger using Section 5.7 of this procedure. During in-plant job performance measure validation for the initial exam, licensed operators were unable to simulate the transfer using System Operating Procedure SOP-0049. This procedure directed the operators to use an operator aid that, according to the procedure, was located inside panel BYS-TRS4. The operator aid was not inside the panel and was never found. Because of this, the job performance measure had to be rejected and another developed. To correct this issue, the licensee added the appropriate steps to System Operating Procedure SOP-0049 that were originally located in the missing operator aid and released it for use as Revision 30 on December 11, 2014. This procedure deficiency was entered into the licensees corrective action program as Condition Report CR-RBS-2014-05684. System Operating Procedure SOP-0071, ROD CONTROL AND INFORMATION SYSTEM (SYS # 500), Revision 29, did not have the necessary qualitative acceptance criteria (procedure steps) to accomplish the required activity of clearing a rod-block after pulling a control rod to raise reactor power during a start-up. During exam administration, an applicant for a senior reactor license could not get the rod block and associated alarm reset during a scenario using "Method 1" as described in System Operating Procedure SOP-0071. This procedure had incorrect guidance in Section 5.13 using "Method 1" in that the ROD SELECT CLEAR push button must be pressed several times to clear the rod block and this method only directed a single push of this button to reset the rod block and its associated alarm. Because of this, the applicant struggled to get through the reactivity change for the reactor during the scenario. To correct this issue, the licensee is working through the procedure change process for this procedure and has informed the licensed operator crews of the issue with "Method 1" until the appropriate steps are corrected within the procedure and it is released as Revision 30. This procedure deficiency was entered into the licensees corrective action program as Condition Report CR-RBS-2014-06331. The failure of these two procedures to have the appropriate qualitative criteria to complete these two activities was a performance deficiency. The finding was more than minor because it is associated with the procedure quality attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective of ensuring availability, reliability, and capability of systems needed to respond to initiating events to prevent undesired consequences. Specifically, inadequate procedures could adversely affect the operating crews ability to take appropriate actions to ensure reactor safety is being maintained. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, the team determined that the finding was of very low safety significance (Green) because the finding: (1) was not a deficiency affecting the design and qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two s eparate safety systems out-of-service for longer than their technical specification allowed outage time; and (4) did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significance in accordance with the licensees maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The finding has a cross-cutting aspect in the area of human performance associated with documentation because the organization did not ensure that the procedures were accurate and up to date for these activities [H.7]. |
Site: | River Bend |
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Report | IR 05000458/2014302 Section 4OA5 |
Date counted | Dec 31, 2014 (2014Q4) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | |
Inspectors (proximate) | C Cowdrey C Steely K Clayton M Hayes M Kennard V Gaddy |
Violation of: | 10 CFR 50 Appendix B Criterion V Technical Specification Technical Specification - Procedures |
CCA | H.7, Documentation |
INPO aspect | WP.3 |
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Finding - River Bend - IR 05000458/2014302 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (River Bend) @ 2014Q4
Self-Identified List (River Bend)
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