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05000335/FIN-2012009-01Saint Lucie2012Q4Failure to Adequately Implement Design Changes ProcedureA self-revealing finding with two examples was identified for the licensees failure to adequately implement their design change process for post-modification testing (PMT). In the first example, the PMT procedure was not adequate for post-modification testing of the steam bypass control system (SBCS). In the second example, a PMT was not performed for the new turbine control system (TCS). The licensees failure to implement the requirements of design change procedure EN-AA- 205-1100 in both examples was a performance deficiency. Both examples were more than minor because they were associated with the Initiating Events cornerstone attribute of design control and adversely affected the cornerstone objective in that both resulted in unplanned reactor trips. This finding was assessed using Inspection Manual Chapter 0609, Appendix A, Significance Determination Process for Findings At-Power, Exhibit 1, Initiating Events Screening Questions, and determined to be of very low safety significance (Green). The cause of the SBCS event was related to the cross-cutting aspect of the need to ensure work activities are planned by incorporating risk insights as described in the Work Control component of the Human Performance cross-cutting area (H.3(a)). The cause of the TCS event was related to the cross-cutting aspect of the need to ensure supervisory and management oversight as described in the Work Practices component of the Human Performance cross-cutting area because station oversight allowed the new TCS to be put in service without the prescribed PMT being performed
05000335/FIN-2012004-02Saint Lucie2012Q3Failure to Implement Procedure EN-AA-205, Design Change PackagesA self-revealing, non-cited violation (NCV) of Technical Specification (TS) 6.8.1, was identified which requires written procedures be established, implemented, and maintained covering activities referenced in NRC Regulatory Guide 1.33, Revision 2, dated February 1978, including safety-related activities carried out during operation of the reactor plant. The licensees safety-related design control procedure EN-AA-205, Design Change Packages, was not implemented as written when a plant modification was performed on the reactor regulating system and steam bypass control system that affected a safety-related maintenance procedure that was not revised to reflect the design change. The licensee entered this violation in their corrective action program as action request 1786565. The licensees failure to fully implement procedure EN-AA-205, Design Change Packages, was a performance deficiency. The finding was determined to be more than minor because if left uncorrected, the deficiency could lead to a more significant safety concern. The inspectors evaluated the risk of this finding under the initiating events cornerstone using IMC 0609, Significance Determination Process, Appendix G, Shutdown Operations Significance Determination Process. The inspectors determined that the finding was of very low safety significance because it did not require a quantitative assessment as determined in Checklist 1. The finding involved a crosscutting aspect of complete and accurate procedures in the resources component of the human performance area (H.2.(c)). Specifically, the licensee failed to ensure that an adequate maintenance procedure was up to date to prevent an unexpected reactor plant temperature transient.