05000483/FIN-2015001-01
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Finding | |
|---|---|
| Title | Failure to Perform Post-maintenance Testing on Safety-related Equipment Prior to Declaring it Operable |
| Description | The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to conduct post-maintenance testing after maintenance on safety-related equipment prior to declaring the system operable in accordance with Procedure ODP-ZZ-00002, Equipment Status Control, Revision 76. Specifically, the train A component cooling water system was declared operable before performing post-maintenance testing on the train A safety injection pump lube oil cooler cooling water outlet relief valve after this valve was replaced. Additionally, when the post-maintenance test was later performed, it failed to meet acceptance criteria. Despite the failure, the licensee did not enter the condition into their corrective action program nor write a new job to address the test failure in accordance with Procedure APA-ZZ-00322, Appendix E, Post Maintenance Test Program. The licensee entered this issue into their corrective action program as Callaway Action Request 201501853 and performed a second post-maintenance test, which was completed satisfactorily. The licensees failure to verify that all post-maintenance testing had been completed prior to declaring the system operable was a performance deficiency. The performance deficiency is more than minor, and therefore a finding, because it is similar to example 5.b in Inspection Manual Chapter 0612, Appendix E, Examples of Minor Issues, and it is associated with the equipment performance attribute of the Mitigating Systems Cornerstone 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). Specifically, on October 29, 2014, the train A component cooling water system was declared operable and returned to service for approximately 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> without completion of post-maintenance testing. When the post-maintenance testing was performed, it failed to meet the acceptance criteria due to system leakage at the flanged connection. No further actions were taken when the leakage was identified resulting in the train A component cooling water system having a known unevaluated degraded condition adversely affecting the reliability of the system between October 29, 2014, and March 19, 2015. Using Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the finding was determined to be of very low safety significance because it did not affect system design, did not result in a loss of system function, did not represent a loss of function of a single train for greater than its technical specifications allowed outage time, and did not cause the loss of function of one or more non-technical specification trains of equipment designated as high safety-significance. Specifically, the component cooling water leakage could be made up from a safety-related source without loss of function. This finding has a work management cross-cutting aspect in the human performance cross-cutting area because the licensee did not appropriately implement a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. Specifically, omitting the correct equipment out of service log entry from the post-maintenance test work task led to operations returning the equipment to service prior to it being tested [H.5]. |
| Site: | Callaway  |
|---|---|
| Report | IR 05000483/2015001 Section 1R12 |
| Date counted | Mar 31, 2015 (2015Q1) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.12 |
| Inspectors (proximate) | F Thomas M Langelier N O'Keefe T Hartman |
| Violation of: | 10 CFR 50 Appendix B Criterion V Technical Specification Technical Specification - Procedures |
| CCA | H.5, Work Management |
| INPO aspect | WP.1 |
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Finding - Callaway - IR 05000483/2015001 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Callaway) @ 2015Q1
Self-Identified List (Callaway)
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