05000298/FIN-2013003-01
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Finding | |
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| Title | Failure to Adequately Assess Risk and Implement Risk Management Actions for Proposed Maintenance |
| Description | The inspectors identified two examples of a non-cited violation of 10 CFR 50.65(a)(4), Requirements for Monitoring the Effectiveness for Maintenance at Nuclear Power Plants, for the licensees failure to adequately assess risk and implement risk management actions associated with maintenance activities affecting outflow paths that had been credited in the internal flooding analysis for a moderate-energy line break in the service water pump room. The licensees corrective actions included immediately reevaluating the risk associated with the subject activities, implementing additional risk-management actions, and reconfiguring a drain hose associated with the activity. The licensee entered these deficiencies into their corrective action program for resolution as Condition Reports CR-CNS-2013-03813 and CR-CNS-2013-04347. The licensees failure to adequately assess the risk and implement required riskmanagement actions for proposed maintenance activities was a performance deficiency. This performance deficiency was more than minor and was therefore a finding because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affected the associated objective. Specifically, by failing to evaluate the risk associated with the maintenance activities, the licensee failed implement risk management actions to restrain staged tools, materials, and equipment to prevent blockage of outflow paths that had been credited in the internal-flooding analysis for a moderate-energy line break in the service water pump room. Because these outflow paths help ensure the availability of systems that respond to initiating events to prevent undesirable consequences, blockage of those paths affected that availability, and thereby affected the cornerstone objective. In accordance with Inspection Manual Chapter 0609, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process, Flowchart 1, Assessment of Risk Deficit, the inspectors determined the need to calculate the risk deficit to determine the significance of this issue. A senior reactor analyst performed a bounding detailed risk evaluation which determined that the incremental core damage probability associated with this finding was less than 1 X 10-6, so the finding has very low safety significance (Green). The finding has a cross-cutting aspect in the area of human performance associated with the work practices component because the licensee personnel failed to define and effectively communicate expectations regarding procedural compliance and to ensure that personnel followed procedures. |
| Site: | Cooper  |
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| Report | IR 05000298/2013003 Section 1R13 |
| Date counted | Jun 30, 2013 (2013Q2) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.13 |
| Inspectors (proximate) | L Ricketson G Guerra B Baca L Carson J Josey J Quichocho C Henderson |
| Violation of: | 10 CFR 50.65(a)(4) 10 CFR 50.65 |
| CCA | H.8, Procedure Adherence |
| INPO aspect | WP.4 |
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Finding - Cooper - IR 05000298/2013003 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Cooper) @ 2013Q2
Self-Identified List (Cooper)
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