05000440/FIN-2016008-02
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Finding | |
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| Title | Failure to Provide Instructions to Completely Vent Reference Legs |
| Description | The inspectors identified a finding of very low safety significance and an associated non-cited violation (NCV) of Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, for the licensees failure to follow fleet procedure NOPSS3001, Procedure Review and Approval, and to ensure that a newly developed hardcard was properly reviewed and approved prior to implementation. Specifically, the licensee characterized the hardcard development and implementation as only an administrative change, and was thereby exempted from the fleet procedure review process for new procedures. The licensee entered this finding into the corrective action program (CAP) as condition report (CR) 201603033 and planned to perform a causal review to ensure that actions taken in response to information provided in operations administrative instruction, OAI1703, Hardcards, have received appropriate review under 10 CFR 50.59. The inspectors determined that the failure to follow the licensees fleet and site-specific procedures to ensure that a newly developed hardcard was properly reviewed and approved prior to implementation was a performance deficiency. The performance deficiency was more than minor because, if left uncorrected, the performance deficiency had the potential to lead to a more significant safety concern. Specifically, by not performing review and approval activities in accordance with established procedures, the licensee might unintentionally challenge the operators by requiring equipment manipulation that impose unnecessary plant transients, which would result in unwarranted challenges to safety related equipment. Additionally, the performance deficiency was more than minor because it was associated with the procedure quality attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown, as well as power operations, and was therefore a finding. The finding was determined to be of very low safety significance because the finding did not cause a reactor trip and the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition. The inspectors determined this finding had a cross-cutting aspect of conservative bias in the human performance area where individuals use decision making-practices that emphasize prudent choices over those that are simply allowable and a proposed action is determined to be safe in order to proceed, rather than unsafe in order to stop. Specifically, when the licensee determined to develop the hardcard procedure as an administrative change, the decision precluded the opportunity for the licensee to properly evaluate that the procedure actions did not adversely impact existing station procedures and equipment [IMC 0310, H.14]. |
| Site: | Perry  |
|---|---|
| Report | IR 05000440/2016008 Section 4OA5 |
| Date counted | Mar 31, 2016 (2016Q1) |
| Type: | NCV: Green |
| cornerstone | Initiating Events |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 93812 |
| Inspectors (proximate) | D Szwarc I Hafeez J Havertape P Louden R Baker W Schaup |
| Violation of: | 10 CFR 50 Appendix B Criterion V |
| CCA | H.14, Conservative Bias |
| INPO aspect | DM.2 |
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Finding - Perry - IR 05000440/2016008 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Perry) @ 2016Q1
Self-Identified List (Perry)
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