05000482/FIN-2013008-10
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Finding | |
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Title | Failure to Provide Procedure Instructions to Remove Thermal Overload Bypass Jumpers |
Description | The team identified a Green, non-cited violation of 10 CFR 50, Appendix B, Criterion III, Design Control, which states, in part, Measures shall be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions. The design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program. Specifically, in 1994, the licensee was committed to the requirements specified in Regulatory Guide 1.106, Thermal Overload Protection for Electric Motors on Motor-Operated Valves, Revision 1, to remove the thermal overload bypass jumpers during maintenance and testing. The licensee failed to translate the requirements into Procedure MGE LT-099, MOV Diagnostic Testing, and failed to include procedural guidance to remove the thermal overload bypass jumpers when performing maintenance testing that strokes the valve from the control room. Also, the Wolf Creek Updated Safety Analysis Report, Section 8.3.1.1.2, has incomplete information which does not support Regulatory Guide 1.106, in that it does not state that the thermal overload bypass jumpers should be removed when performing maintenance testing that strokes the valve. The licensee has entered this issue into their corrective action program as Condition Reports CR-73120 and CR-73219. The team determined that the licensees failure to provide procedure instructions to remove the thermal over-load bypass jumpers during motor-operated valve diagnostic testing as committed to in Regulatory Guide 1.106, Revision 1, was a performance deficiency. This finding was more than minor because it was associated with the Procedure Quality attribute of the Reactor Safety, Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to include procedural guidance to remove the thermal overload bypass jumpers when performing maintenance testing that strokes the valve from the control room, and to include the requirements of Regulator Guide 1.106 in the Updated Safety Analysis Report, Section 8.3.1.1.2, that the bypass jumpers will be removed during testing of the motor-operated valves. In accordance with NRC Inspection Manual Chapter 0609, Appendix A, Exhibit 2, the inspectors determined the finding was of very low safety significance (Green), because the finding was not a design deficiency and did not result in the loss of operability or functionality. This finding did not have a cross-cutting aspect because the most significant contributor to the performance deficiency did not reflect current licensee performance. |
Site: | Wolf Creek |
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Report | IR 05000482/2013008 Section 1R21 |
Date counted | Sep 30, 2013 (2013Q3) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.21 |
Inspectors (proximate) | S Garchow B Correll A Sengupta H Leake R Kopriva T Farnholtz |
Violation of: | 10 CFR 50 Appendix B Criterion III, Design Control |
INPO aspect | |
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Finding - Wolf Creek - IR 05000482/2013008 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Wolf Creek) @ 2013Q3
Self-Identified List (Wolf Creek)
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