05000498/FIN-2016007-10
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Finding | |
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| Title | Failure to Correct Procedure Deficiencies Allowing Cooling Restoration to RCP Seals |
| Description | The team identified a Green, non-cited violation of Technical Specification 6.8.1.a., Procedures, which requires that written procedures shall be established, implemented, and maintained for procedures in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Procedures addressing combating emergencies involving loss of electric power are denoted in Appendix A, Section 6, Item c. Specifically, since July 2010, the licensee failed to maintain the loss of all alternating current power emergency procedure to ensure the procedure contained adequate direction to operators to mitigate a loss of reactor coolant pump seal cooling unique to the plants design. In response to this issue, the licensee initiated actions to consult with the plants design owners group to determine the best method of addressing this procedure vulnerability. Emergency operating procedure documentation and/or operator training will be revised based on owners group input. This issue was entered into the licensee's corrective action program as Condition Report CR 16-2126. The team determined that the failure to maintain procedures in accordance with accepted industry standards was a performance deficiency. The performance deficiency was determined to be more than minor, and therefore a finding, because it was associated with the Initiating Events cornerstone attribute of procedure quality, and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, operating procedures did not contain appropriate attributes to ensure timely action to prevent an increased likelihood of a reactor coolant pump seal loss of coolant accident following a station blackout. In addition, if left uncorrected, the performance deficiency would have the potential to lead to a more significant safety concern. Specifically, if the licensee used the procedure to mitigate a loss of all alternating current power event, the licensee may increase the risk of increased reactor coolant pump seal leakage, as well as potentially placing the safety-related component cooling water system in an unanalyzed condition. In accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, Exhibit 1, Initiating Events Screening Questions, the team determined a detailed risk evaluation was necessary because, after a reasonable assessment of degradation, the finding could result in exceeding the reactor coolant system leak rate for a small loss of coolant accident. Therefore, the senior reactor analyst performed a bounding detailed risk evaluation. The analyst determined that the change to the core damage frequency would be 1E-7 per year (Green). This finding had a cross-cutting aspect in the area of problem identification and resolution associated with evaluation because organizations failed to thoroughly evaluate issues to ensure that resolutions address causes and extent of condition commensurate with their safety significance. Specifically in 2014, the licensee received a non-cited violation associated with not having adequate procedures to address equipment malfunctions that caused a loss of reactor coolant pump seal cooling (Inspection Reports 05000498/2013007); however, the extent of condition review did not document any reviews of other procedures associated with reactor coolant pump seal cooling loss events to see if they allowed for seal cooling to be restored when seal temperatures were above 230 degrees F [P.2]. |
| Site: | South Texas  |
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| Report | IR 05000498/2016007 Section 1R21 |
| Date counted | Mar 31, 2016 (2016Q1) |
| Type: | NCV: Green |
| cornerstone | Initiating Events |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.21M |
| Inspectors (proximate) | C Baron C Stott G Gardner J Kirkland M Williams S Hedger T Fanelli T Farnholtz |
| Violation of: | Technical Specification - Procedures Technical Specification |
| CCA | P.2, Evaluation |
| INPO aspect | PI.2 |
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Finding - South Texas - IR 05000498/2016007 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (South Texas) @ 2016Q1
Self-Identified List (South Texas)
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