05000461/FIN-2016009-02

Finding

Title

Failure to Scope SFP Temperature and Level Instruments into the Maintenance Rule Program

Description

The team identified a finding of very-low safety significance (Green) and an associated NCV of Paragraph (b)(2)(i) of 10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, for the licensee failure to scope non-safety related mitigating structure, systems, and components (SSCs) used within an emergency operating procedure (EOP) into Maintenance Rule Program. Specifically, an EOP used spent fuel pool (SFP) low-level and high-temperature parameters as distinct entry criteria but the associated components were not included in the scope of the Maintenance Rule Program. The licensee captured the team concerns in their CAP as AR 02736193, performed an extent of condition to identify any other SSC addition to the EOPs requiring them to be added to the Maintenance Rule Program scope, and initiated plans to incorporate the affected SSCs into the Maintenance Rule Program scope. The performance deficiency was determined to be more-than-minor because it was associated with the Barrier Integrity cornerstone attribute of SSC performance and affected the cornerstone objective of providing reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, a key aspect of the Maintenance Rule is to ensure that maintenance activities are performed in a manner that provide reasonable assurance that SSCs within its scope perform reliably and are capable of providing their intended Maintenance Rule function(s). In the case of the SFP temperature instruments, the licensee was not performing preventive maintenance to ensure that degradation, such as instrument drift, did not adversely affect their ability to detect and alarm EOP entry conditions such that mitigating actions could be implemented to preserve secondary containment. The finding screened as of very-low safety significance (Green) because it only represented a degradation of the radiological barrier function provided for the control room. Specifically, the finding did not cause SFP temperature to exceed the maximum analyzed limit, a detectible release of radionuclides, water inventory to decrease below the analyzed limit, or an adverse effect to the SFP neutron absorber or fuel loading pattern. The team determined that the finding had a cross-cutting aspect in the area of human performance because the licensee did not use a systematic process for evaluating and implementing changes when updating the affected EOP in 2015.

02
Site:	Clinton
Report	IR 05000461/2016009 Section 1R21
Date counted	Dec 31, 2016 (2016Q4)
Type:	NCV: Green
cornerstone	Barrier Integrity
Identified by:	NRC identified
Inspection Procedure:	IP 71111.21
Inspectors (proximate)	J Benjamin J Robbins L Rodriguez M Jeffers N Feliz-Adorno
Violation of:	10 CFR 50.65
CCA	H.3, Change Management
INPO aspect	LA.5
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v • d • e

Finding - Clinton - IR 05000461/2016009

1(7)2(9)3(6)4(2)5(0)6(0)7(1)8(1)9(6)10(1)403(1)404(1)405(0)406(0)408(0)409(0)

IR 05000461/2016009: 1 2 3 4 5 6

Finding List (Clinton) @ 2016Q4

CCA Matrix: 2016Q4

	Q	CCA	Title
05000461/FIN-2016001-04	2016Q1		Failure to Report a Condition Prohibited by Technical Specifications
05000461/FIN-2016010-01	2016Q1	H.6	Failure to Perform Adequate Evaluation of Crane and Crane Support Structure Elements
05000461/FIN-2016001-02	2016Q1	H.1	Operability Determination Failed to Examine Test Failures
05000461/FIN-2016001-05	2016Q1	H.11	Failure to Assess and Manage Risk Increase for a Proposed Maintenance Activity
05000461/FIN-2016001-06	2016Q1	H.8	Inadequate Extent of Condition Associated with an ACE
05000461/FIN-2016001-03	2016Q1		Failure to Report a Condition that Could Have Prevented Fulfillment of a Safety Function
05000461/FIN-2016001-01	2016Q1	P.2	Failure to Identify a Degraded Safety-Related Support
05000461/FIN-2016002-02	2016Q2	H.1	Inspection Fails to Identify Safety Related Cables Submerged in Cable Vault
05000461/FIN-2016002-01	2016Q2	H.2	Material Unsecure in the Secured Material Zone
05000461/FIN-2016404-01	2016Q2	H.14	Security
05000461/FIN-2016002-05	2016Q2	H.13	Lack of Acceptance Criteria for Containment Visual Examinations
05000461/FIN-2016002-06	2016Q2	H.1	Failure to Perform Surface Examination Prior to Weld Repair of a Reactor Water Cleanup System Pipe
05000461/FIN-2016002-07	2016Q2		Failure to Obtain License Amendment prior to Operating Reactor Water Cleanup Bypass Switches
05000461/FIN-2016002-03	2016Q2	H.14	Failure to Properly Install Cable Vault Mitigating Equipment
05000461/FIN-2016002-08	2016Q2		Failure to Update the Updated Safety Analysis Report (USAR) Peak Suppression Pool Temperature
05000461/FIN-2016002-09	2016Q2		Failure to Update the Updated Safety Analysis Report (USAR) Condensate and Feedwater System
05000461/FIN-2016002-04	2016Q2	H.8	Inadequate Ultrasonic Examination for Service Water System Pipe Repaired
05000461/FIN-2016003-02	2016Q3	H.3	Exceeded Technical Specification Allowed Outage Time for Main Turbine Bypass System
05000461/FIN-2016403-01	2016Q3		Security
05000461/FIN-2016007-01	2016Q3	H.6	Failure to have Hose Configurations that were Verified to be able to Ensure a Timely and Successful Implementation of a FLEX Strategy
05000461/FIN-2016003-05	2016Q3	H.6	Spent Fuel Pool Liner Design Not Verified per Code
05000461/FIN-2016003-04	2016Q3		Failure to Prevent Recurrence of a Significant Condition Adverse to Quality
05000461/FIN-2016003-03	2016Q3	H.13	Failure to Perform a 50.59 Screening for Changing the Frequency of Exercising the Turbine Bypass Valves
05000461/FIN-2016003-01	2016Q3	H.12	Failure to Scope Fuel Building Ventilation Pressure Control into Maintenance Rule
05000461/FIN-2016004-01	2016Q4	P.1	Failure to Demonstrate the Condition of Flood Seals Was Being Effectively Controlled
05000461/FIN-2016009-06	2016Q4	H.9	Failure to Follow the Operability Determination Process Following the Identification of a Control Room HVAC System Design Issue
05000461/FIN-2016009-05	2016Q4		Failure to Promptly Identify that the Incapability of the RHR Design to Support TS Operability Requirements Was a CAQ
05000461/FIN-2016009-04	2016Q4	H.4	Failure to Verify the Adequacy of Design Assumptions Related to Time Critical Operator Actions
05000461/FIN-2016009-02	2016Q4	H.3	Failure to Scope SFP Temperature and Level Instruments into the Maintenance Rule Program
05000461/FIN-2016009-01	2016Q4		Non Conservative Control Room Radiological Habitability Assessment
05000461/FIN-2016004-02	2016Q4		Dry Cask Storage Procedures Were Not Adequate to Ensure Correct Field Configuration
05000461/FIN-2016009-03	2016Q4		Failure to Amend the UFSAR Indicating Choice to Comply with 10 CFR 50.68(b)

Self-Identified List (Clinton)

	Q	Title
05000461/FIN-2016001-07	2016Q1	Licensee-Identified Violation
05000461/FIN-2016003-06	2016Q3	Licensee-Identified Violation

[Clinton Findings full list]

05000461/FIN-2016009-02

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