05000244/FIN-2013005-02
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Finding | |
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Title | Programmatic Failure to Scope SSCs within the Maintenance Rule Monitoring Program |
Description | The inspectors identified an NCV of 10 CFR 50.65(b), because CENG staff did not include safety-related and non-safety-related structures, systems, and components (SSCs) within the scope of the maintenance rule monitoring program. Specifically, CENG staff failed to appropriately include an estimated 90 safety-related and non-safety-related SSCs within the scope of the maintenance rule monitoring program, which could have resulted in a failure to detect SSC degradation and to provide reasonable assurance that these SSCs are capable of fulfilling their intended functions. Immediate corrective actions included placing these issues into the CAP as CR-2013-002083, CR-2013-004444, CR-2013-004993, CR- 2013-006139, CR-2013-006628, and CR-2013-006674. The finding is more than minor because if left uncorrected, the finding could become a more significant safety concern. Specifically, the failure to monitor SSC performance and condition could have resulted in a failure to detect SSC degradation and to provide reasonable assurance that these SSCs are capable of fulfilling their intended functions. The failure to adequately scope an estimated 90 or more components could have resulted in the failure to detect degradation within multiple systems and to provide reasonable assurance that these SSCs are capable of fulfilling their intended functions. Additionally, this issue is similar to Example 3j described in IMC 0612, Appendix E, Examples of Minor Issues, which states that issues are not minor if significant programmatic deficiencies were identified with the issue that could lead to worse errors if uncorrected. The inspectors evaluated the finding using IMC 0612, Attachment 0609.04, Initial Characterization of Findings. The attachment instructs inspectors to utilize IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Exhibit 2, Mitigating Systems Screening Questions, of IMC 0609, Appendix A, the inspectors determined that the finding did not represent an actual loss of function of one or more non-technical specification trains of equipment. Therefore, the inspectors determined the finding was of very low safety significance (Green). This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, because CENG personnel did not thoroughly evaluate problems such that the resolutions addressed causes and extent of conditions. Specifically, CENG had multiple opportunities following the inspectors identification of maintenance rule scoping issues on March 27, 2013, and prior to November 7, 2013, to thoroughly evaluate recent maintenance rule scoping problems such that the resolutions addressed causes and extent of conditions P.1(c). |
Site: | Ginna |
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Report | IR 05000244/2013005 Section 1R12 |
Date counted | Dec 31, 2013 (2013Q4) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.12 |
Inspectors (proximate) | A Bolger C Cahill D Dodson M Patel M Scott N Perry T Hedigan T Moslak |
Violation of: | 10 CFR 50.65(b) 10 CFR 50.65 |
CCA | P.2, Evaluation |
INPO aspect | PI.2 |
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Finding - Ginna - IR 05000244/2013005 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Ginna) @ 2013Q4
Self-Identified List (Ginna)
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