The NRC identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to promptly identify a condition adverse to quality. Specifically, following post cleaning tests of the A and C component cooling system (CCS) heat exchangers (HX), a negative fouling factor was recorded to meet the fouling factor acceptance criteria without being entered into the licensees CAP to determine if the data was credible and representative of the HX performance. The violation was entered into the licensees corrective action program as problem evaluation report 969404 and an operability determination was performed that provided reasonable assurance of operability while corrective actions are being evaluated. The licensees failure to promptly identify the negative fouling factor as a condition adverse to quality was a performance deficiency. The team determined that the performance deficiency was more than minor, because if left uncorrected, it had the potential to lead to a more significant safety concern. Specifically, if the licensee fails to evaluate abnormal fouling factor test results then the potential exists for parameter uncertainties to go undetected and potentially result in test results that are not representative of adequate HX performance. The team determined the finding to be of very low safety significance (Green) because the finding was not a design deficiency, did not represent a loss of system and/or function, and did not represent the loss of any trains of Technical Specification or Non- Technical Specification equipment. The finding has a cross cutting aspect in the Conservative Bias component of the Human Performance area as defined in NRC IMC 0310, because the licensee failed to use decision-making practices that emphasize prudent choices over those that are simply allowable. Specifically, the licensee failed to recognize that a negative fouling factor while less than the test acceptance criteria, did not represent an expected test result (H.14).
Failure To Identify A Condition Adverse To Quality For Negative Fouling Factors
05000390/FIN-2015007-02
IR 05000390/2015007
≤31 March 2015 ≥31 March 2015
≤1 July 2014 ≥1 July 2014
~IR 05000390/2015000
~IR 05000390/2015001
~IR 05000390/2015002
~IR 05000390/2015003
~IR 05000390/2015004
~IR 05000390/2015005
~IR 05000390/2015007
~IR 05000390/2015009
~IR 05000390/2015010
~IR 05000390/2015301
~IR 05000390/2015403
~IR 05000390/2015404
~IR 05000390/2015405
~IR 05000390/2015406
~IR 05000390/2015407
~IR 05000390/2015408
~IR 05000390/2015410
~IR 05000390/2015502
~IR 05000390/2015602
~IR 05000390/2015603
~IR 05000390/2015604
~IR 05000390/2015605
~IR 05000390/2015608
~IR 05000390/2015609
~IR 05000390/2015610
~IR 05000390/2015611
~IR 05000390/2015613
~IR 05000390/2015614
~IR 05000390/2015615
~IR 05000390/2015616
~IR 05000391/2015601
~IR 05000391/2015602
~IR 05000391/2015603
~IR 05000391/2015604
~IR 05000391/2015605
~IR 05000391/2015606
~IR 05000391/2015607
~IR 05000391/2015609
~IR 05000391/2015610
~IR 05000391/2015611
~IR 05000391/2015613
Watts Bar 2015
!Licensee-identified ≥1 July 2014 Watts Bar ≤31 March 2015 23:59:59
Licensee-identified ≥1 July 2014 Watts Bar ≤31 March 2015 23:59:59
Watts Bar