05000461/FIN-2017004-02
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Finding | |
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Title | Failure to Assess and Manage Risk Associated with the Performance of Control Rod Time Testing |
Description | The inspectors identified a finding of very low safety significance and a non-cited violation of 10 CFR 50.65(a)(4), Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, for the licensees failure to assess and manage the increase in risk that may result from proposed maintenance activities. Specifically, the licensee failed to assess and manage the increase in risk associated with performing control rod scram time testing in Mode 1, prior to performing the activity. As corrective actions, the licensee assessed the increase in risk for performing control rod scram time testing at power and developed a risk mitigation plan that was used to complete the testing. This performance deficiency was determined to be more than minor because the finding was associated with the human performance attribute of the Initiating Events cornerstone and impacted the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the failure to assess risk and develop a risk mitigation plan for control rod time testing at power contributed to an automatic reactor scram. Using IMC 0609, Attachment 4, Initial Characterization of Findings, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process, issued May 5, 2005, and Appendix M, Significance Determination Process Using Qualitative Criteria dated April 12, 2002, the finding was screened against the Initiating Events cornerstone and determined to be of very low safety significance. Specifically, the inspectors and the Region III Senior Reactor Analyst (SRA) determined that Appendix K was not directly applicable to this finding because the licensee performs qualitative evaluations of maintenance activities that have the potential to cause a transient rather than quantitative evaluations. The SRA used insights from Appendix K to support a qualitative SDP evaluation using the principles of Appendix M. The SRA determined that the maintenance activity could only result in an uncomplicated reactor transient event and that the increased risk of a transient compared to the baseline risk of the plant was of very low safety significance. The SRA considered the conditional core damage probability of an uncomplicated transient in this evaluation, which was less than 1E6, to conclude that the finding was Green. The inspectors determined this finding affected the cross-cutting area of human performance in the aspect of work management, where the organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. While performing the work order risk screening for completing the control rod scram time testing while the reactor was shut down, the screener identified that a new screening would be needed if the testing was performed at power. However, no holds were placed on the work order to ensure the risk screening was completed. [H.5] |
Site: | Clinton |
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Report | IR 05000461/2017004 Section 4OA3 |
Date counted | Dec 31, 2017 (2017Q4) |
Type: | NCV: Green |
cornerstone | Initiating Events |
Identified by: | NRC identified |
Inspection Procedure: | IP 71153 |
Inspectors (proximate) | W Schaup E Sanchez-Santiago R Baker N Fields G Hansen M Holmberg D Reeser G Roach K Stoedter |
Violation of: | 10 CFR 50.65 10 CFR 50.65(a)(4) |
CCA | H.5, Work Management |
INPO aspect | WP.1 |
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Finding - Clinton - IR 05000461/2017004 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Clinton) @ 2017Q4
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