05000456/FIN-2016007-01
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Finding | |
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| Title | |
| Description | The team identified an Unresolved Item (URI) regarding the identification of significant conditions adverse to quality (SCAQs) in the CAP. Specifically, the team determined that the CAP, as implemented by PI-AA-125,Corrective Action Program, and PI-AA-120, Issue Identification and Resolution, appeared to not ensure that SCAQs were appropriately identified and corrected to prevent recurrence. Chapter 16 of the Braidwood Quality Assurance Topical Report (QATR) describes the licensees program to identify and correct conditions adverse to quality. Procedure PI-AA-125 implemented the requirements established in the QATR. During this inspection, the team reviewed the CAP procedure to determine how it ensured that SCAQs were identified and resolved. As part of this review, the team requested a copy of identified SCAQs over the last two years and were subsequently informed that none had been identified. Issue #1 - The team reviewed the QATR and noted that the following requirements applied: Section 2.1 stated that measures are required to assure that the cause of any significant condition adverse to quality is determined and that corrective actions to prevent recurrence [CAPRs] are implemented. Section 2.2.1, Significant Conditions Adverse to Quality, stated that in cases of significant conditions adverse to quality the cause of the condition must be determined and documented, the resolution determined and documented, and the corrective actions taken and documented to prevent recurrence. Step 2.116 of Appendix D of the QATR defined a significant condition adverse to quality as, a condition, which if left uncorrected, could have a serious effect on safety or operability. The team reviewed procedure PI-AA-125 and PI-AA-120, which delineated the process for the identification and screening of issues, and identified that these procedures did not include a provision to classify an identified issue as a SCAQ. The team also noted that the definition of a SCAQ was not being used to determine whether a RCE was needed; therefore, a CAPR did not appear to be directly associated with a SCAQ. Based on the above, the team questioned whether CAP procedure PI-AA-125 prescribed a process through which SCAQs were identified and documented, and corrective actions taken and documented to prevent recurrence as required by the QATR. The team discussed this issue with the licensee. The licensee stated that since the terms SCAQ and condition adverse to quality (CAQ) were not explicitly defined in NRC regulations, that they had created a graded approach of significance level and likelihood (which included risk and uncertainty) to ensure that items were properly dispositioned and the level of resources and rigor applied appropriately followed the CAP governance. The licensee further stated that the graded approach, along with a well-trained management team that has nuclear safety and conservative decision-making as their primary focus, provided for an effective CAP. Finally, the licensee stated that even if a CAPR was not issued, that CAs would prevent recurrence of the events entered into the CAP. The team questioned whether a CAPR and a CA would be equally effective as corrective actions to prevent the recurrence of issues dispositioned in the CAP. The licensee agreed that the two types of CAs were treated differently. For example, 1) the MRC was required to assess changes to the intent of a CAPR, which was not required for a CA, 2) an effectiveness review may not necessarily be assigned if an issue was corrected using only a CA, and 3) if there was a desire to suspend or modify a previously implemented CAPR, then a risk analysis and MRC concurrence was necessary; which was not the case for a CA. At the end of the inspection it was not clear how procedures PI-AA-120 and PI-AA-125 ensured that SCAQs were identified and documented, and corrective actions taken and documented to prevent recurrence. Additionally, it was not clear if the licensees process implemented the requirements in the QATR. Resolution of this issue will be based on additional NRC review to determine if a violation of NRC requirements occurred. Issue #2 - The team identified an example of a potential SCAQ for which the licensee implemented CAs that failed to prevent the issue from recurring. Specifically, for a December 30, 2013 oil leak on the inboard bearing housing of the Unit 1 Train B (1B) SX pump, the licensees CAs restored operability, but were not adequate to prevent recurrence and consequently an oil leak recurred on November 18, 2014. Both of these oil leaks resulted in the licensee declaring the 1B SX pump inoperable and required entry into Technical Specification (TS) Limited Condition for Operation (LCO) 3.7.8 (reference Non-Cited Violation (NCV) 05000456/201400502; Failure to Correct Undersized Essential Service Water Pump Bearing Casing Drain Line Resulted in System Inoperability). The team questioned whether the oil leaks on the inboard pump bearing housing of the 1B SX pump should have been categorized as a SCAQ as defined in the licensees QATR. Specifically, QATR Section 2.116, Definitions, defined a SCAQ as, A condition, which if left uncorrected, could have a serious effect on safety or operability. In this case, although the oil leakage at the inboard pump bearing housing first identified in 2013 was specifically addressed through repairs, the CAs were not adequate to prevent recurrence and a second oil leak occurred in 2014 that caused a serious effect on the operability of the 1B SX pump (i.e. rendered the 1B SX pump inoperable). Additionally, the team considered this issue to have a potentially serious effect on operability, because if left uncorrected the oil leakage would have depleted the oil supply reservoir resulting in a loss of lubrication to the pump shaft bearings that could damage the pump shaft and require substantial repairs to return the pump to operation. The team discussed this issue with the licensee. The licensees response was that because there was no potential for common cause failure, and there was no significant change to plant risk after removing the 1B SX pump from service, the events discussed above were appropriately screened as Significance Level 3 issues. The licensee also stated that a SCAQ would typically be assigned for a Significance Level 1 or 2 issue, but even if an issue was assigned this level of significance, it would not necessarily be categorized as a SCAQ. At the end of the inspection it was not clear how the definition of SCAQ in the QATR was utilized in the CAP. Resolution of this issue will be based upon additional NRC review and a determination of whether the failure of the 1B SX pump constituted a SCAQ as defined in the QATR. |
| Site: | Braidwood  |
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| Report | IR 05000456/2016007 Section 4OA2 |
| Date counted | Sep 30, 2016 (2016Q3) |
| Type: | URI: |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71152 |
| Inspectors (proximate) | D Betancourt D Kimble D Sargis E Duncan J Benjamin T God Betancourt E Duncan G O'Dwyer J Bozga M Holmber |
| INPO aspect | |
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Finding - Braidwood - IR 05000456/2016007 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Braidwood) @ 2016Q3
Self-Identified List (Braidwood)
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