05000336/FIN-2015004-02
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Finding | |
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Title | Turbine Driven Auxiliary Feedwater Pump Corrective Actions to Prevent Recurrence |
Description | The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, for Dominions failure to take corrective action to prevent repetition for a significant condition adverse to quality according to the definition in PI-AA-200, Corrective Action. Specifically, PI-AA-200 lists unplanned entry into a TS action that results in taking a unit off-line as an example of a significant condition adverse to quality. On July 26, 2014, Dominion performed a TS required shutdown of Unit 2 due to the inoperability of the turbine driven auxiliary feedwater (TDAFW) pump. Dominion cancelled the root cause evaluation (RCE) assigned to investigate the cause of the plant shutdown, stating that the direct cause of the shutdown was foreign material in the flow orifice in a recirculation line for the TDAFW pump. No corrective actions to prevent recurrence (CAPRs) were assigned after the direct cause was determined. Dominion entered this issue into their CAP as CR1019514. This performance deficiency was determined to be more than minor in accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated September 7, 2012, because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and adversely affected its objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, taking CAPRs will help to ensure the availability and reliability of the TDAFW pump. This finding was evaluated in accordance with IMC 0609, Significance Determination Process, Attachment 4, Initial Characterization of Findings, and IMC 0609, Appendix A, Exhibit 2, and screened as very low safety significance (Green) since it was not a qualification or design deficiency, did not represent a loss of system or function, and did not exceed its TS allowed outage time. The inspectors determined this issue had a cross cutting aspect in Human Performance, Consistent Process, where individuals use a consistent, systematic approach to make decisions. Specifically, Dominion inappropriately used the corrective action procedure to change the causal evaluation category without properly balancing the risk of the decision, and therefore did not develop CAPRs for a significant condition adverse to quality. |
Site: | Millstone |
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Report | IR 05000336/2015004 Section 4OA3 |
Date counted | Dec 31, 2015 (2015Q4) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71153 |
Inspectors (proximate) | B Haagensen C Highley G Dentel H. Anagnostopoulus J Ambrosini J Deboer K Reid L Mckown M Modes |
Violation of: | 10 CFR 50 Appendix B Criterion XVI Technical Specification - Procedures Technical Specification |
CCA | H.13, Consistent Process |
INPO aspect | DM.1 |
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Finding - Millstone - IR 05000336/2015004 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Millstone) @ 2015Q4
Self-Identified List (Millstone)
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