05000335/FIN-2014003-01
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Finding | |
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| Title | Failure to Follow the Nuclear Design Control Procedure for Auxiliary Feedwater Valves |
| Description | A self-revealing, non-cited violation (NCV) of Technical Specification (TS) 6.8.1, was identified which requires that written procedures be established, implemented, and maintained covering activities referenced in NRC Regulatory Guide 1.33, Revision 2, dated February 1978, including safety-related activities carried out during operation of the reactor plant. The licensee failed to comply with Quality Instruction ENG-QI 1.0, Nuclear Engineering Design Control, when an unauthorized modification was implemented during maintenance on two auxiliary feedwater (AFW) valves. Consequently, the unauthorized modification was the direct cause of the failure of one of the valve stems. Corrective actions included the proper installation of new stems in the valves. The licensees failure to comply with Quality Instruction ENG-QI 1.0, Nuclear Engineering Design Control, and modifying the AFW valve and plug assembly by drilling and pinning at a different location than what was specified on the maintenance assembly procedure was a performance deficiency. The performance deficiency was determined to have more than minor significance because if left uncorrected, the failure to comply with the engineering design control procedure to ensure adequate assembly of AFW valves could lead to a more significant safety concern. Specifically, failure of an AFW pump discharge valve could result in an inadequate steam generator heat sink during a design basis accident. Using Manual Chapter 0609.04, Significance Determination Process (SDP) Initial Characterization of Findings, Table 2, dated June 19, 2012, the finding was determined to affect the Mitigating Systems Cornerstone. The finding occurred while the Unit was at power. Manual Chapter 0609 Appendix A, Significance Determination Process for Findings At-Power, Exhibit 2 - Mitigating Systems Screening Questions dated, June 19, 2012, was used to further evaluate this finding. The finding screened as Green because none of the logic questions under the cornerstone applied. The finding involved the cross-cutting area of Human Performance, in the aspect of Conservative Bias (H.14), in that, the licensee did not make a conservative decision to stop work when the maintenance procedure did not address installation of a used valve stem. Instead the licensee chose to move forward with the maintenance because the procedure did not specifically prohibit installation of a used stem. |
| Site: | Saint Lucie  |
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| Report | IR 05000335/2014003 Section 4OA2 |
| Date counted | Jun 30, 2014 (2014Q2) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | Self-revealing |
| Inspection Procedure: | IP 71152 |
| Inspectors (proximate) | J Reyes P Mckenna T Morrissey |
| Violation of: | Technical Specification - Procedures Technical Specification |
| CCA | H.14, Conservative Bias |
| INPO aspect | DM.2 |
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Finding - Saint Lucie - IR 05000335/2014003 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Saint Lucie) @ 2014Q2
Self-Identified List (Saint Lucie)
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