05000461/FIN-2017003-01

Finding

Title

MSIV TS Leakage Limits Exceeded Due to Condition Based Maintenance Approach

Description

The inspectors documented a self-revealed finding of very low safety significance and an associated NCV of TS limiting condition for operation (LCO) 3.6.1.3, for the failure to follow station procedure ERAA200, Preventative Maintenance Program, Revision 3. Specifically, the licensee utilized a condition-based maintenance approach on the main steam isolation valves (MSIVs) that failed to monitor and trend equipment performance so that planned maintenance could be performed prior to the MSIVs exceeding the TS leakage limits. The licensee entered this issue into their CAP as AR 04009845. As corrective actions, the licensee repaired and tested the valves prior to returning the unit to the modes of applicability.The performance deficiency 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 it impacted the Barrier Integrity cornerstone attribute of configuration control and adversely affected the cornerstone objective of providing reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the monitoring and trending of local leak rate tests on the MSIVs did not provide performance data that would allow planned maintenance to the valves prior to the valves failing resulting in exceeding TSleakage requirements for the MSIVs. Using IMC 0609, Attachment 4, Initial Characterization of Findings, and Appendix A, The Significance Determination Process for Findings at Power, Exhibit 2, October 7, 2016, the finding was screened against the Barrier Integrity cornerstone Reactor Containment and did represent an actual open pathway in the physical integrity of reactor containment. The inspectors proceeded to Appendix H, Containment Integrity Significance Determination Process, and determined that it was a Type B finding that was related to a degraded condition that has potentially important implications for the integrity of the containment, without affecting the likelihood of core damage. The inspectors used Figure 6.1, Road Map for LERF based Risk Significance for Evaluation of Type-B Findings at Full Power and determined this finding is of very low safety significance (Green). The inspectors determined that this finding affected the cross-cutting area of human performance in the aspect of design margins, where the organization operates and maintains equipment within design margins. Special attention is placed on maintaining fission product barriers, defense-in-depth and safety related equipment. Specifically, the procedure for testing the MSIVs utilized an administrative limit that provided no margin to correct performance prior the valves becoming inoperable. [H.6]

01
Site:	Clinton
Report	IR 05000461/2017003 Section 1R15
Date counted	Sep 30, 2017 (2017Q3)
Type:	NCV: Green
cornerstone	Barrier Integrity
Identified by:	Self-revealing
Inspection Procedure:	IP 71111.15
Inspectors (proximate)	W Schaup E Sanchez-Santiago M Doyle J Wojewoda J Havertape L Rodriguez M Domke G Edwards S Mischke L Kozak
Violation of:	Technical Specification
CCA	H.6, Design Margins
INPO aspect	WP.2
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Finding - Clinton - IR 05000461/2017003

1(4)2(7)3(5)4(4)5(0)6(0)7(1)8(1)9(1)10(0)11(1)12(3)201(1)301(0)403(0)404(0)405(0)502(0)

IR 05000461/2017003: 1 2 3 4 5

Finding List (Clinton) @ 2017Q3

CCA Matrix: 2017Q3

	Q	CCA	Title
05000461/FIN-2016009-02	2016Q4	H.3	Failure to Scope SFP Temperature and Level Instruments into the Maintenance Rule Program
05000461/FIN-2016009-04	2016Q4	H.4	Failure to Verify the Adequacy of Design Assumptions Related to Time Critical Operator Actions
05000461/FIN-2016009-05	2016Q4		Failure to Promptly Identify that the Incapability of the RHR Design to Support TS Operability Requirements Was a CAQ
05000461/FIN-2016009-06	2016Q4	H.9	Failure to Follow the Operability Determination Process Following the Identification of a Control Room HVAC System Design Issue
05000461/FIN-2016004-01	2016Q4	P.1	Failure to Demonstrate the Condition of Flood Seals Was Being Effectively Controlled
05000461/FIN-2016009-01	2016Q4		Non Conservative Control Room Radiological Habitability Assessment
05000461/FIN-2016009-03	2016Q4		Failure to Amend the UFSAR Indicating Choice to Comply with 10 CFR 50.68(b)
05000461/FIN-2016004-02	2016Q4		Dry Cask Storage Procedures Were Not Adequate to Ensure Correct Field Configuration
05000461/FIN-2017001-02	2017Q1	H.14	Failed to Verify an Appropriate Alternate Method of Decay Heat Removal
05000461/FIN-2017001-04	2017Q1	H.1	Failure to Perform Maintenance on Residual Heat Removal Pump C Breaker in Accordance with Procedures
05000461/FIN-2017001-03	2017Q1	H.12	Failure to Develop and Review a Worker Tag Out
05000461/FIN-2017001-01	2017Q1	H.14	Plant Barrier Control Program Failed to Compensate for an Impacted Flood Barrier (
05000461/FIN-2017002-02	2017Q2	P.3	Failure to Perform Adequate Evaluation of Crane Rail Clips
05000461/FIN-2017002-07	2017Q2	H.1	Root Cause Evaluation Failed to Identify Corrective Action to Preclude Repetition
05000461/FIN-2017008-01	2017Q2	H.5	Failure to Perform Required S urveillances on Multiple Fire Dampers
05000461/FIN-2017002-06	2017Q2		Failure to Perform Preventive Maintenance on a Safety - Related Breaker Cubicl
05000461/FIN-2017002-05	2017Q2	H.11	Failure to Properly Classify a Shipment per DOT Regulations
05000461/FIN-2017002-04	2017Q2	H.6	Failure to Provide Sufficient Work Instructions for Performing Maintenance on the Control Room Ventilation System Charcoal Filte
05000461/FIN-2017002-03	2017Q2	H.12	Unexpected Start of the Division 3 Emergency Diesel Generato
05000461/FIN-2017002-01	2017Q2		Failure of Operators to Meet Time Critical Operator Actions
05000461/FIN-2017009-01	2017Q3	H.11	Failure to Evaluate Replacement Relay Dropout Voltage
05000461/FIN-2017201-01	2017Q3	H.5	Security
05000461/FIN-2017007-01	2017Q3	H.1	Failure to Evaluate Defeating Reactor Core Isolation Cooling System Interlocks and Trips before Adding Them to an Emergency Operating Support Procedure
05000461/FIN-2017003-01	2017Q3	H.6	MSIV TS Leakage Limits Exceeded Due to Condition Based Maintenance Approach
05000461/FIN-2017003-02	2017Q3	H.1	Failure to Adequately Control Access in Locked High Radiation Area
05000461/FIN-2017003-03	2017Q3	H.13	Failure to Perform Engineering Evaluation to Determine the Cause of Failure of Snubbers
05000461/FIN-2017003-04	2017Q3	H.14	Flow Control Valves Not Locked Out Results in Reactor Recirculation Pump Runback
05000461/FIN-2017003-05	2017Q3	H.9	Failure to Establish Secondary Containment Prior to Entering MODE 2

Self-Identified List (Clinton)

[Clinton Findings full list]

05000461/FIN-2017003-01

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