The St. Lucie Unit 1
Technical Specification 6.8.1(a) states, in part, that the licensee shall establish, implement, and maintain the applicable procedures recommended in Appendix A of
Regulatory Guide 1.33, Rev. 2, 1978. Section 9(a) of Appendix A to
Regulatory Guide 1.33, Rev.2, states, in part, that maintenance that can affect the quality of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. Contrary to the above requirements, on April 12, 2015, the licensee did not implement adequate maintenance instructions that were appropriate to the circumstances as specified by
WO 40296976 to ensure that the 1C
AFW pump was correctly aligned and returned to service. Specifically, the work order instructions required Attachment 10 of procedure 1-PMM-09.04,
Auxiliary Feedwater Turbine Mechanical and Electrical Over speed Trip Tests, to be completed as part of the pump restoration. Attachment 10 of procedure 1-PMM-09.04 included a step to position valve V08385 to the open position, and this step was not completed. The licensee entered this issue into the
CAP as
AR 02042311. The failure to adequately implement the work instructions in
WO 40296976 requiring completion of Attachment 10 of procedure 1-PMM-09.04, to ensure the valve was correctly aligned was a performance deficiency. The performance deficiency was more than minor because it was associated with the equipment performance attribute of the
mitigating systems cornerstone and adversely impacted the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to
initiating events. The finding was of very low safety significance (Green) because the inspector answered No to all of the associated
Mitigating Systems screening questions within
IMC 0609, Attachment 4, Initial Characterization of Findings. Because this violation was of very low safety significance and was entered
CAP, this violation is being treated as a
NCV, consistent with Section 2.3.2 o f the
NRC Enforcement Policy.
