05000454/FIN-2018002-02
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Finding | |
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Title | Licensee-Identified Violation |
Description | A violation of very low safety significance was identified by the licensee, has been entered into the licensees corrective action program, and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy
Violation: Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.Licensee procedure ERAA321, Administrative Requirements for Inservice Testing, stated in Step 4.10.5, that acceptance criteria are established using the reference values and the applicable ASME [American Society of Mechanical Engineers] Code. Paragraph ISTA3160, Test and Examination Procedures, of the ASME Operation and Maintenance of Nuclear Power Plants (OM) Code required in part that, Tests and examinations shall be performed in accordance with written procedures. The procedures shall contain the Owner-specified reference values and acceptance criteria. Paragraph ISTA9230, Inservice Test and Examination Results, of the ASME OM Code required, in part, that The results of tests and examinations shall be documented and shall include the following: comparison with allowable ranges of test and examination values, and analysis deviations and requirements for corrective action.Contrary to the above, from July 1, 2016, to May 30, 2018, the licensees procedures did not clearly document acceptance range, alert range, and required action values for the diesel oil (DO) transfer pump IST surveillance tests in accordance with the ASME OM Code. This resulted in several instances where the pump being tested did not meet IST criteria, but no action was taken. Significance/Severity Level: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedural Quality attribute of the Mitigating Systems Cornerstone and adversely impacted the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to clearly identify the acceptance criteria, alert range and required action ranges resulted an in organizational failure to declare the pumps inoperable and to perform required analysis of the equipments condition. The inspectors assessed the significance of the finding using SDP Appendix A and concluded the issue was of very low safety significance (i.e., Green).Corrective Action References: (1) AR 04142617, Acceptance Criteria Not Clearly Listed in DO Pump Procedures, and (2) AR 04142370, DO Pump Test Packages are Not Routed to the IST Coordinator. |
Site: | Byron |
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Report | IR 05000454/2018002 Section 4OA2 |
Date counted | Jun 30, 2018 (2018Q2) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | Licensee-identified |
Inspection Procedure: | IP 71152 |
Inspectors (proximate) | J Mcghee C Hunt D Betancourt C Thompson E Duncan |
Violation of: | 10 CFR 50 Appendix B Criterion V |
INPO aspect | |
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Finding - Byron - IR 05000454/2018002 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Byron) @ 2018Q2
Self-Identified List (Byron)
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