05000461/FIN-2016001-05
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Finding | |
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| Title | Failure to Assess and Manage Risk Increase for a Proposed Maintenance Activity |
| Description | A self-revealed finding of very low safety significance and an associated non-cited violation of 10 CFR 50.65 (a)(4) was identified on January 20, 2016, due to the licensees failure to assess and manage the risk increase from a proposed maintenance activity. Specifically, the licensee failed to manage the risk associated with racking out the continuous containment purge (CCP) A breaker, which resulted in the loss of both CCP trains, and led to an increase in primary to secondary containment differential pressure which exceeded the Technical Specification (TS) value. The licensee entered this issue into their CAP as AR 02614832. The proposed corrective actions to address this issue included creating a checklist to ensure validation of initial conditions is performed and providing training that reinforces the need to properly screen work order tasks with the appropriate risk factors. The inspectors determined that the failure to assess and manage the risk increase of a proposed maintenance activity, as required by 10 CFR 50.65 (a)(4), was more than minor because it was associated with the maintenance procedure quality attribute of the Barrier Integrity Cornerstone and adversely affected the cornerstone objective of providing reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, by not properly assessing the risk of racking out the CCP A breaker the licensee did not recognize the CCP B train would be impacted, which resulted in exceeding the TS value for primary to secondary containment differential pressure. Using IMC 0609, Attachment 4, Initial Characterization of Findings, and Appendix A, The Significance Determination Process for Findings at Power, issued June 19, 2012, the finding was screened against the Barrier Integrity Cornerstone and determined to be of very low safety significance because the finding did not represent an actual open pathway in the physical reactor containment, containment isolation system or heat removal components and it did not involve an actual reduction in function of hydrogen igniters in the reactor containment. The inspectors identified a cross-cutting aspect in the area of human performance, in the aspect of challenging the unknown, which states, individuals stop when faced with uncertain conditions; risks are evaluated and managed before proceeding. Specifically, when the licensee was preparing the work package for maintenance on the CCP system it was uncertain what activities had already been completed as part of a concurrent evolution. Instead of stopping and validating the configuration of plant equipment, assumptions were made, and the risk of the activity was not properly assessed or managed. (H.11) |
| Site: | Clinton  |
|---|---|
| Report | IR 05000461/2016001 Section 4OA3 |
| Date counted | Mar 31, 2016 (2016Q1) |
| Type: | NCV: Green |
| cornerstone | Barrier Integrity |
| Identified by: | Self-revealing |
| Inspection Procedure: | IP 71153 |
| Inspectors (proximate) | C Phillips E Sanchez-Santiago I Khan J Wojewoda K Stoedter M Jones M Learn S Mischke V Meghani W Schaup |
| Violation of: | 10 CFR 50.65(a)(4) |
| CCA | H.11, Challenge the Unknown |
| INPO aspect | QA.2 |
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Finding - Clinton - IR 05000461/2016001 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Clinton) @ 2016Q1
Self-Identified List (Clinton)
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