The inspectors identified a Green, non-cited violation of
Technical Specification 5.4.1.a, Procedures, for the failure to establish procedure instructions for work authorization denials or deferrals. Specifically, this led to a 60 day extended unavailability of the diverse
auxiliary feedwater actuation system when corrective maintenance was inappropriately deferred by the operations department. Failure to provide adequate procedural guidance in the event of a denied work authorization, a circumstance anticipated to occur, is a performance deficiency. The performance deficiency is more than minor, because it affected the equipment performance attribute of the
Mitigating Systems Cornerstone objective to ensure the availability and reliability of equipment that responds to an initiating event. Specifically, because the corrective maintenance was not performed in a timely manner, both trains of the diverse
auxiliary feedwater actuation system remained in bypass for an additional 60 days whereby the system was not capable of performing its required safety function. The inspectors evaluated the significance of the finding using
Inspection Manual Chapter 0609, Appendix A,
Significance Determination Process for Findings at Power, Exhibit 2,
Mitigating Systems Screening Questions, Section A, Question 2, which required a detailed risk evaluation because the finding involved a loss of system safety function. A Region IV senior reactor analyst performed a detailed risk assessment of the finding and determined that the finding was of very low safety significance (Green). The inspectors determined that the finding had a cross-cutting aspect in the human performance area of Work Management. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. Specifically, the Unit Operations Managers decision to deny the work authorization was based on conservative but faulty assumptions, and if other work groups with greater specific technical knowledge had been involved, the corrective maintenance likely would have proceeded [H.5]
