A self-revealed finding of very low safety significance was identified with an associated non-cited violation of
10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. The licensee failed to incorporate operating experience into its preventive maintenance practices associated with steam bypass system control circuit cards. Specifically, during two operating experience driven initiatives performed by the licensee in 2001 and 2007, and once again on September 24, 2011, the licensee failed to implement any preventive maintenance activity for critical component circuit cards, which resulted in age-related failure and a reactor
scram on November 29, 2011. The licensee initiated corrective actions to replace system circuit cards, perform periodic replacement/refurbishment maintenance activities, and trend circuit card performance during routine calibration. The finding was of more than minor significance because it was sufficiently similar to
IMC 0612, Power Reactor Inspection Reports, Appendix E, Examples of Minor Issues, Example 7(c), in that this violation of
10 CFR 50.65(a)(3) had a consequence ... such as equipment problems attributable to failure to take industry operating experience into account when practicable. The finding was a licensee performance deficiency of very low safety significance because it: (1) did not contribute to the likelihood of a loss-of-coolant accident initiator, (2) did not contribute to both the likelihood of a reactor
scram AND the likelihood that mitigation equipment or functions would not be available, and (3) did not increase the likelihood of a fire or internal/external flooding event. The inspectors concluded that this finding affected the cross-cutting area of human performance. Specifically, in the area of work control, the licensee did not appropriately coordinate work activities by incorporating actions to plan work activities to support long-term equipment reliability by scheduling maintenance as more preventive than reactive
