A self-revealing
NCV of
10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified. Specifically, Vogtle Electric Generating Plants (
VEGP)
MOV preventative maintenance (
PM) procedures lacked specific instructions that provided an adequate frequency for performing valve stem lubrication, which resulted in test failures of safety-related
MOVs and affected the reliability of the
MOVs safety functions. The licensee removed the
hardened grease, relubricated and successfully tested the
MOVs. They have entered the issue into their corrective action program and are in the process of revising existing maintenance procedures to change the
PM frequency from 54 months to 36 months for long stem, safety-related
MOV stem lubrication. The finding was more than minor because if left uncorrected other safety related
MOVs could be affected by the inadequate stem lubrication
PM frequencies. The finding is associated with the configuration control attribute of the
Barrier Integrity (BI) Cornerstone and affected the cornerstone objective of providing reasonable assurance that physical design barriers (e.g., containment) protect the public from radionuclide releases caused by accidents or events. Specifically,
Containment Spray (
CS) pump
sump suction isolation
MOVs experienced test failures and were declared
inoperable, which required operability evaluations, thereby challenging their reliability and capability to perform their safety function. Using the Phase 1 worksheet in Attachment 4 of Manual Chapter 0609,
Significance Determination Process, the finding affected the BI cornerstone and was of very low safety significance (Green) because it did not represent an actual open pathway in the physical integrity of reactor containment. Although the
CS sump suction
MOVs condition affected the mitigating system cornerstone, the finding analysis was assigned to the BI cornerstone because it best reflected the dominant risk of the finding. This finding has a cross-cutting aspect in the area of
PI&R, Corrective Action Program, because
VEGP did not thoroughly evaluate problems such that the resolutions addressed the causes and extent of condition
P.1(c). Specifically,
VEGP failed to thoroughly evaluate previous conditions of degraded and
hardened grease on safety related valves, such that the extent of the condition was considered and the cause was resolved
