05000483/FIN-2014007-03
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Finding | |
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Title | Failure to Follow Procedures by Not Identifying a Conflict Between Two Procedures |
Description | The team identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, which states, in part, Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Specifically, on October 23, 2006, the licensee failed to follow Procedure APA-ZZ-00101, Processing Procedures, Manuals, and Desktop Instructions, when the reviewer did not realize that a revised step in Procedure EDP ZZ 01126, Lubrication Predictive Maintenance Program, Revision 6, conflicted with requirements in Procedure APA-ZZ-00500, Corrective Action Program. The licensee failed to identify that a new procedure step, which allowed licensee personnel the discretion to not initiate a Callaway Action Request when an abnormal or adverse condition was identified, was in conflict with expectations for initiating Callaway Action Requests for adverse conditions stated in Procedure APA-ZZ-00500. In response to this issue, the licensee will review their guidance documents and procedure training, along with their root cause procedure, because the conflict with the procedures had not been identified during the root cause investigation of the Essential Service Water Pump B lower motor bearing degradation. This finding was entered into the licensees corrective action program as Callaway Action Request (CAR) 201403046. The team determined that the failure to identify that a revised step in Procedure EDP-ZZ-01126 was conflicting with expectations for initiating Callaway Action Requests for adverse conditions stated in Procedure APA-ZZ-00500 was a performance deficiency. This finding was more than minor because if left uncorrected, it had the potential to lead to a more significant safety concern. Specifically, Revision 6 to Procedure EDP-ZZ-01126, Lubrication Predictive Maintenance Program, was revised to allow licensee personnel the discretion of not using the Callaway Action Request System to document an abnormal or adverse condition when a bad oil sample had been identified. Consequently, the lubrication predictive maintenance program procedure, as written, has the potential to miss diagnosing/reporting of equipment problems and degradation prior to equipment failure. The original oil sample taken in October 2012 indicated a degraded condition, and it was not until a subsequent oil sample taken in February 2013, caused the licensee to write a Callaway Action Request when the Essential Service Water Pump B lower motor bearing had degraded, and the pump was taken out-of-service for replacement. In accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, Exhibit 2, Mitigating Systems Screening Questions, the issue screened as having very low safety significance (Green) because it was a design or qualification deficiency that did not represent a loss of operability or functionality; did not represent an actual loss of safety function of the system or train; did not result in the loss of one or more trains of nontechnical specification equipment; and did not screen as potentially risk-significant due to seismic, flooding, or severe weather. This finding did not have a cross-cutting aspect because the most significant contributor did not reflect current licensee performance. |
Site: | Callaway |
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Report | IR 05000483/2014007 Section 1R21 |
Date counted | Jun 30, 2014 (2014Q2) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.21 |
Inspectors (proximate) | B Correll C Baron C Hale G Nicely J Braisted R Kopriva S Hedger T Farnholtz |
Violation of: | 10 CFR 50 Appendix B Criterion V |
INPO aspect | |
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Finding - Callaway - IR 05000483/2014007 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Callaway) @ 2014Q2
Self-Identified List (Callaway)
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