05000528/FIN-2013009-05
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Finding | |
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| Title | Improper Extension of Surveillance Interval for Surveillance Requirements Associated with the Engineered Safety Features Actuation Signal System Sequencer and Relays |
| Description | The team identified a Green, non-cited violation of Technical Specification 5.5.18, Surveillance Frequency Control Program which states, in part, This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met. Part (b) states, Changes of the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, Risk-Informed Method for Control of Surveillance Frequencies, Revision 1. Specifically, prior to February 3, 2014, previous regulatory commitments for the engineered safety features actuation signal system surveillance test frequencies were not properly addressed as required by Technical Specification 5.5.18.b and NEI 04-10. The licensee did not follow the guidance of NEI 04-10 when they revised the Surveillance Frequency Control Program to test each train of the engineered safety features actuation signal system from every 18 months to every 36 months. In response to this issue, the licensee confirmed that the engineered safety features actuation signal system remained operable because the system had been tested satisfactory and none of the technical specification surveillances were overdue. This finding was entered into the licensees corrective action program as Palo Verde Action Requests (PVARs) 4500910 and 4500874. The team determined that the failure to adequately address a regulatory commitment when extending the surveillance testing frequency associated with the engineered safety features actuation signal system was a performance deficiency. This performance deficiency was more than minor because it was associated with the Mitigating Systems Cornerstone attribute of Equipment Performance, and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of the engineered safety features actuation signal system to respond to initiating events to prevent undesirable consequences. Specifically, the NRC commitment identified in document RCTSAI 7673 committed the licensee to: the BOP ESFAS system will be fully tested at least every 18 months at the time of refueling. When making a change to the Surveillance Frequency Control Program associated with the surveillance test frequency of the engineered safety features actuation signal system, the licensee failed to collect and review all commitments made to the NRC as required by NEI 04-10, Risk-Informed Method for Control of Surveillance Frequencies, Revision 1, and failed to follow the requirements of NEI 99-04, Guidelines for Managing NRC Commitment Changes, Revision 0. In accordance with NRC 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 non-technical specification equipment; and did not screen as potentially risk-significant due to seismic, flooding, or severe weather. This finding had a cross-cutting aspect in the area of human performance because the licensee leaders did not use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority. |
| Site: | Palo Verde  |
|---|---|
| Report | IR 05000528/2013009 Section 1R21 |
| Date counted | Mar 31, 2014 (2014Q1) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.21 |
| Inspectors (proximate) | I Anchondo R Kopriva T Farnholtz W Sherbin B Jose C Hale C Osterholtz G Gardner |
| Violation of: | Technical Specification |
| CCA | H.3, Change Management |
| INPO aspect | LA.5 |
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Finding - Palo Verde - IR 05000528/2013009 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Palo Verde) @ 2014Q1
Self-Identified List (Palo Verde)
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