05000461/FIN-2017003-03

Finding

Title

Failure to Perform Engineering Evaluation to Determine the Cause of Failure of Snubbers

Description

The inspectors identified a finding of very low safety significance and an associated NCV of Title 10 Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to demonstrate compliance with the requirement as prescribed in procedure ERCL330, CPS Snubber Program, Revisions 1 and 2. Specifically, the licensee failed to perform engineering evaluations to determine the cause of failure of snubbers that did not satisfy their functional testing acceptance criteria. The licensee entered this issue into their CAP as ARs 04015242 and 04041302. As corrective actions, the licensee evaluated the components affected by the failed snubber and determined that no operability issues existed. The performance deficiency was determined to be more-than-minor in accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, because it was associated with the Mitigating Systems cornerstone attribute of Protection against External Factors and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability for mitigating systems to respond to initiating events. Specifically, compliance with ERCL330 would ensure the failed snubber wasevaluated for the cause of failure, to ensure the licensee identified other snubbers that may have been vulnerable to the same type of deficiency. This would ensure that any potential undesired loading on the piping system could be avoided and the affected safety-related residual heat removal and reactor water cleanup piping systems could continue to perform their design function of maintaining the pressure boundary and structural integrity following a postulated design basis seismic event. The inspectors determined the finding could be evaluated using the Significance Determination Processin accordance with IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, dated June 19, 2012, Exhibit 2, Mitigating Systems Screening Questions, for the Mitigating Systems cornerstone and then Exhibit 4, External Events Screening Question. The finding screened as having very low safety significance because in each instance, the inspectors answered No to Questions 1 and 2 ofExhibit 4. The inspectors determined this finding affected the cross-cutting area of human performance in the aspect of consistent process, where individuals use a consistent, systematic approach to make decisions. Specifically, the licensee failed to establish a systematic approach to evaluating snubbers that did not meet the acceptance criteria to ensure all required aspects were addressed. [H.13]

03
Site:	Clinton
Report	IR 05000461/2017003 Section 4OA2
Date counted	Sep 30, 2017 (2017Q3)
Type:	NCV: Green
cornerstone	Mitigating Systems
Identified by:	NRC identified
Inspection Procedure:	IP 71152
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:	10 CFR 50 Appendix B 10 CFR 50 Appendix B Criterion V
CCA	H.13, Consistent Process
INPO aspect	DM.1
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v • d • e

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-2017003-03

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