05000461/FIN-2011005-08

Finding

Title

Licensee-Identified Violation

Description

10 CFR 50, Appendix B, Criterion XI, Test Control, requires, in part, that a test program shall be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures. The test program shall include preoperational tests. Test results shall be documented and evaluated to assure that test requirements have been satisfied. Contrary to the above, on February 8, 2006, January, 22, 2008, and May 30, 2009, the licensee failed to assure that test requirements were satisfied following replacement of turbine control valve fast closure pressure switches 1C71N005A, 1C71N005B, and 1C71N005C, respectively. Specifically, on each occasion, the licensee failed to identify that RPS response time testing was required by TSSR 3.3.1.1.17 prior to declaring these pressure switches operable and returning them to service. This resulted in the licensee operating at conditions where these pressure switches were required without assurance that the components were operable. Each of the pressure switches was subsequently satisfactorily tested as directed by the surveillance frequency of TSSR 3.3.1.1.7. The licensee performed an apparent cause evaluation and determined that this required post-maintenance test was not included in the work instructions because its post-maintenance testing procedures did not identify this test as a required test following the maintenance activity. The licensee revised its post-maintenance testing procedures to address this test. The inspectors determined that this violation was associated with a licensee-identified finding of more than minor safety significance because, had the post-maintenance testing procedures not been updated to include RPS response time testing as a required post-maintenance test for these pressure switches, switches that received maintenance could be returned to service with unsatisfactory RPS response times. The inspectors determined that this violation was of very low safety significance (i.e., Green) because when the licensee subsequently performed RPS response time testing for these pressure switches, the results were satisfactory. This violation is being treated as a non-cited violation consistent with Section 2.3.2 of the NRC Enforcement Policy. The licensee entered this violation into its corrective action program as AR 01258051. The licensee submitted LER 05000461/2011-003-00 on October 13, 2011, to report this issue as a condition prohibited by TS. Refer to Section 4OA3.1 of this inspection report for the review and closure of the LER.

08
Site:	Clinton
Report	IR 05000461/2011005 Section 4OA7
Date counted	Dec 31, 2011 (2011Q4)
Type:	NCV: Green
cornerstone	Mitigating Systems
Identified by:	Licensee-identified
Inspection Procedure:
Inspectors (proximate)	B Kemker D Lords J Cassidy J Draper J Mcghee M Bielby M Ring R Jickling S Mischke T Bilik
INPO aspect
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v • d • e

Finding - Clinton - IR 05000461/2011005

1(0)2(6)3(6)4(6)5(8)6(0)7(0)8(3)9(1)10(0)11(0)201(0)202(0)301(0)403(1)404(1)405(1)501(0)502(0)20(0)24(0)25(0)6(0)

IR 05000461/2011005: 1 2 3 4 5 6 7 8

Finding List (Clinton) @ 2011Q4

CCA Matrix: 2011Q4

	Q	CCA	Title
05000461/FIN-2011002-06	2011Q1		Apparent Interaction Between Non-Safety Related and Safety-Related Portions of the NSPS Causing Spurious Component Actuations
05000461/FIN-2011002-01	2011Q1	H.11 H.12	Failure to Control Transient Combustible Materials in Accordance with Fire Protection Program
05000461/FIN-2011002-02	2011Q1		Failure to Meet Surveillance Testing Requirement for Hydrogen Igniters in Accessible Areas of the Primary Containment and Drywell
05000461/FIN-2011002-03	2011Q1	H.7	Inadequate Testing Controls to Perform Surveillance Testing of Hydrogen Igniters in the Primary Containment and Drywell
05000461/FIN-2011002-04	2011Q1		Reactor Coolant System Pressure Isolation Valve Leakage Surveillance Test Procedure Questions
05000461/FIN-2011009-01	2011Q1		Failure to Ensure Fire Door was Closed and Latched
05000461/FIN-2010502-02	2011Q2		Changes to EAL Basis Decreased the Effectiveness of the Plan without Prior NRC Approval
05000461/FIN-2011003-04	2011Q2		NIOSH Approval of SCBAs
05000461/FIN-2011003-05	2011Q2		Missing Respirator Spectacle Kits
05000461/FIN-2011003-03	2011Q2		Surveillance Testing of Control Room Ventilation System
05000461/FIN-2011403-01	2011Q2	H.2	Security
05000461/FIN-2011008-03	2011Q2	P.2	Failure to Perform Effectiveness Review
05000461/FIN-2011008-02	2011Q2	H.7	Failure to Maintain a Quality Record As Evidence of an Activity Affecting Quality of Safety-related Equipment Due to Inappropriate Corrective Actions
05000461/FIN-2011008-01	2011Q2	H.14	Failure to Account for Cable Resistance in Operability Determinations
05000461/FIN-2011003-02	2011Q2		Failure to Meet Surveillance Testing Requirement for Reactor Coolant System Pressure Isolation Valves
05000461/FIN-2011003-01	2011Q2		Deficiencies with RCIC Room Heat Up Analyses
05000461/FIN-2010502-01	2011Q2		(Traditional Enforcement) Changes to EAL Basis Decreased the Effectiveness of the Plan without Prior NRC Approval
05000461/FIN-2011004-06	2011Q3	H.1	Missing Respirator Spectacle Kits
05000461/FIN-2011004-05	2011Q3	H.13	Failure to Evaluate Operability of Control Room Ventilation System for Degraded Flow Condition
05000461/FIN-2011004-04	2011Q3	H.14	Failure to Meet Technical Specification 3.7.3 for Operability of Control Room Ventilation System
05000461/FIN-2011004-03	2011Q3	P.3	Failure to Correct a Condition Adverse to Quality for Improperly Implemented Engineering Corrective Actions
05000461/FIN-2011004-02	2011Q3	H.9	Failure to Implement Package Design Specifications
05000461/FIN-2011004-01	2011Q3	H.2	Failure to Perform Code Required Cause and Effect Failure Evaluations for Diesel Starting Air and Fuel Oil System Relief Valves
05000461/FIN-2011005-02	2011Q4	H.8	Failure to Control the Work Hours of a Covered Worker
05000461/FIN-2011005-04	2011Q4	P.5	Unacceptable Preconditioning of Reactor Core Isolation Cooling System Check Valve Prior to Leak Rate Test Measurement
05000461/FIN-2011005-05	2011Q4	H.12	Failure to Implement Appropriate Radiological Controls for the Removal of Insulation in a Posted High Contamination Area
05000461/FIN-2011005-06	2011Q4		Failure to Implement Appropriate Radiological Controls After Radiation Protection Identified that a Worker Was Potentially Contaminated Due to Inappropriate Protective Clothing
05000461/FIN-2011005-01	2011Q4		Failure to Properly Apply an Approved ASME Code Case
05000461/FIN-2011405-01	2011Q4	H.13	Security
05000461/FIN-2011005-03	2011Q4		Review of Licensees Compliance with TS 3.6.4.3 During Operations with the Potential to Drain the Reactor Vessel

Self-Identified List (Clinton)

	Q	Title
05000461/FIN-2011002-05	2011Q1	Licensee-Identified Violation
05000461/FIN-2011003-06	2011Q2	Licensee-Identified Violation
05000461/FIN-2011404-01	2011Q3	Security
05000461/FIN-2011005-07	2011Q4	Licensee-Identified Violation
05000461/FIN-2011005-08	2011Q4	Licensee-Identified Violation

[Clinton Findings full list]

05000461/FIN-2011005-08

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