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The team identified a Green NCV of 10 CFR … The team identified a Green NCV of 10 CFR 50.65, Requirements for monitoring the effectiveness of maintenance at nuclear power plants which states, in part, that the licensee shall monitor the performance or condition of structures, systems, or components, against licensee-established goals, in a manner sufficient to provide reasonable assurance that these structures, systems, and components are capable of fulfilling their intended functions. These goals shall be established commensurate with safety and, where practical, take into account industry-wide operating experience. Specifically, from March of 2012 until October of 2012, the licensee allowed the maintenance rule program to deteriorate by not performing initial screenings in a timely fashion. In some cases, the initial screenings were being done months later and the actual evaluation of the equipment status was not being performed at all for a period of eight months. Consequently, several components, including electrical relays and electrical load centers, were not being evaluated in accordance with program requirements. Additionally, the licensee was not implementing the operating experience program as required by this regulation. The licensee discontinued performance of level 1 and level 2 operating experience evaluations by direction from the senior management in August of 2012 based on resource concerns. Several examples where operating experience was not properly evaluated included the containment spray pump low oil issues (ACA 2008-5695), vendor manual updates, and loose fasteners (both electrical and mechanical) from San Onofre Nuclear Generating Station Licensee Event Reports (LER) 3612007005, 3612007006, and 3612008006. This finding was entered into the licensees Corrective Action Program as CR 2012-17572. The team determined that the failure to adequately implement the maintenance rule was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because if left uncorrected it could lead to a more serious concern. Using Manual Chapter 0609, Attachment 4, Significance Determination Process router on Table 3, it sends the user to Appendix G for Shutdown Operations Significance Determination Process. Using Checklist 4 of Appendix G for the given plant conditions, the finding was determined to have very low safety significance (Green) because the finding did not 1) increase the likelihood of a loss of RCS inventory, or 2) degrade the licensees ability to terminate a leak path or add RCS inventory when needed, or 3) degrade the licensees ability to recover decay heat removal once it is lost. This finding was determined to have a cross-cutting aspect in the area of human performance associated with the decision-making component because the licensee did not use conservative assumptions in decision making and did not identify the possible unintended consequences of suspending maintenance rule program activities and the corresponding impact on the program.d the corresponding impact on the program.

Discovered date

23:59:59, 31 December 2012 +

Docket

05000285 +

Event date

23:59:59, 31 December 2012 +

Finding integer

4 +

Finding type

Non-cited violation +

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DM.2 +

IR 05000285/2012012 +

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19:05:17, 30 September 2017 +

Person