05000498/FIN-2016007-07

Finding

Title

Failure to Implement Administrative Controls for a Nonconservative Technical Specification of Standby Diesel Generator Frequency Variation

Description

The team identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions, which states, in part, Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. Specifically, since 1997, the licensee failed to correct a condition adverse to quality by imposing administrative controls in response to a nonconservative Technical Specification. In response to this issue, the licensee performed an operability determination regarding past performance on the auxiliary feedwater motor-driven pumps and concluded that they have always retained their safety function. This violation was entered into the licensees corrective action program as Condition Report CR 16-2176. The team determined that the failure to impose administrative limits in surveillance procedures to promptly correct a condition adverse to quality was a performance deficiency. The performance deficiency was determined to be more than minor, and therefore a finding, because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Additionally, if left uncorrected, the performance deficiency would have the potential to become a more significant safety concern. Specifically, operation of the motor driven auxiliary feedwater pumps with a diesel generator frequency acceptance criteria of up to 2 percent would allow operation in a regime where the pumps would not perform their safety function when called upon. In accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, Exhibit 2, Mitigating Systems Screening Questions, the issue screened as having very low safety significance (Green) because it was a design or qualification deficiency that did not represent a loss of operability or functionality. This finding had a cross-cutting aspect in the area of human performance associated with change management because the licensee failed to use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority. Specifically, the licensee did not properly evaluate the need to take appropriate interim corrective actions before the appropriate guidance was endorsed [H.3].

07
Site:	South Texas
Report	IR 05000498/2016007 Section 1R21
Date counted	Mar 31, 2016 (2016Q1)
Type:	NCV: Green
cornerstone	Mitigating Systems
Identified by:	NRC identified
Inspection Procedure:	IP 71111.21M
Inspectors (proximate)	C Baron C Stott G Gardner J Kirkland M Williams S Hedger T Fanelli T Farnholtz
Violation of:	10 CFR 50 Appendix B Criterion XVI Technical Specification - Procedures Technical Specification
CCA	H.3, Change Management
INPO aspect	LA.5
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v • d • e

Finding - South Texas - IR 05000498/2016007

1(3)2(2)3(0)4(0)5(0)6(0)7(10)8(0)9(0)10(3)301(0)401(0)402(0)403(0)405(0)406(2)407(1)501(0)

IR 05000498/2016007: 1 2 3 4 5 6 7 8 9 10

Finding List (South Texas) @ 2016Q1

CCA Matrix: 2016Q1

	Q	CCA	Title
05000498/FIN-2015404-01	2015Q3		Security
05000498/FIN-2015004-01	2015Q4	H.8	Failure to Track and Incorporate Actual Plant Data into Simulator Operability Testing
05000498/FIN-2015004-02	2015Q4		Failure to Maintain the Emergency Plan Up to Date With the Safety Evaluation Report
05000498/FIN-2016007-01	2016Q1	H.13	Failure to Perform Adequate Periodic Testing of Molded Case Circuit Breakers
05000498/FIN-2016007-06	2016Q1	H.14	Failure to Correct Conditions Adverse to Quality Associated with the Eagle 21 System
05000498/FIN-2016007-08	2016Q1	H.8	Failure to Ensure Sufficient Capacity and Capability of Mitigating Systems during a Station Blackout Event
05000498/FIN-2016001-01	2016Q1	H.14	Failure to Identify and Correct Faulty NI-36 Channel
05000498/FIN-2016007-10	2016Q1	P.2	Failure to Correct Procedure Deficiencies Allowing Cooling Restoration to RCP Seals
05000498/FIN-2016007-02	2016Q1		Failure to Verify the Adequacy Calculations Associated with Direct Current Circuit Breakers
05000498/FIN-2016007-04	2016Q1		Failure to Perform Adequate On-going Class 1E Qualification for the Qualified Display Processing System
05000498/FIN-2016007-05	2016Q1		Failure to Control Software Tools Commensurate with the Importance to Safety
05000498/FIN-2016007-07	2016Q1	H.3	Failure to Implement Administrative Controls for a Nonconservative Technical Specification of Standby Diesel Generator Frequency Variation
05000498/FIN-2016007-09	2016Q1		Failure to Ensure Adequate Design Control Measures in Place to Mitigate a Loss of Normal Feedwater Flow Event
05000498/FIN-2016007-03	2016Q1		Failure to Include Applicable Safety System Criteria in the Final Safety Analysis Report

Self-Identified List (South Texas)

	Q	Title
05000498/FIN-2015404-02	2015Q3	Licensee-Identified Violation
05000498/FIN-2016001-02	2016Q1	Licensee-Identified Violation
05000498/FIN-2016001-03	2016Q1	Licensee-Identified Violation

[South Texas Findings full list]

05000498/FIN-2016007-07

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