05000483/FIN-2015009-04
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Finding | |
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| Title | Two Examples of a Failure to Properly Designate the Significance Level of Callaway Action Requests. |
| Description | The team identified two examples of a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to implement their corrective action program procedure. Specifically: (1) on November 20, 2014, the licensee designated the improper setting of the auxiliary feedwater flow control valve ALHV005 limit switches as Significance Level 5 (administrative close) instead of Significance Level 3 (lower tier cause evaluation) and (2) on December 9, 2014, the licensee downgraded the failure of the Modutronics card for valve ALHV0005 from Significance Level 1 (root cause analysis) to Significance Level 3 based on unverified assumptions of the failure mechanisms. Following failure of the Modutronics card for valve ALHV0005, the licensee assumed that the early failure was due to a manufacturing defect (infant mortality) without supporting data to prove this designation. The licensee entered these issues into the corrective action program as Callaway Action Requests 201506921 and 201507235. The two failures to properly designate the Significance Level of Callaway action requests constitute a performance deficiency. This finding was more than minor, and therefore, a finding because it adversely affected the Mitigating Systems Cornerstone attribute of Equipment Performance and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failures to properly designate the significance of the conditions precluded determining the appropriate cause determinations and extent of conditions and resulted in failure to correct the conditions before they further manifested themselves following a trip. Using Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, dated June 19, 2012, 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. This finding has a human performance cross-cutting aspect in the area of conservative bias in that the decision-making did not demonstrate a conservative/prudent choice in designating the significance level of the Callaway action requests based on two cases of unverified/incorrect information (H.14). |
| Site: | Callaway  |
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| Report | IR 05000483/2015009 Section 4OA5 |
| Date counted | Dec 31, 2015 (2015Q4) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 93812 |
| Inspectors (proximate) | D Proulx J Jacobson N Taylor R Kopriva |
| Violation of: | 10 CFR 50 Appendix B 10 CFR 50 Appendix B Criterion V Technical Specification |
| CCA | H.14, Conservative Bias |
| INPO aspect | DM.2 |
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Finding - Callaway - IR 05000483/2015009 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Callaway) @ 2015Q4
Self-Identified List (Callaway)
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