05000237/FIN-2014003-01
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Finding | |
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Title | Failure to Take Appropriate Corrective Action When a Maintenance Rule Performance Goal for the Standby Coolant System was Not Met |
Description | The inspectors identified a finding of very low safety significance and non-cited violation of 10 CFR 50.65(a)(1), Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, for the licensees failure to take corrective actions by performing an (a)(1) determination when the standby coolant supply system preventative maintenance (a)(2) demonstration was failed. Specifically, in November 2013, the standby coolant supply system exceeded its maintenance rule performance criteria when it experienced an additional maintenance preventable functional failure. The licensee failed to appropriately account for this failure in their Maintenance Rule Program and, as a result, the site failed to perform appropriate corrective action, by failing to perform an (a)(1) determination in accordance with Procedures ERAA310, Implementation of the Maintenance Rule, and ERAA-3101005, Maintenance RuleDispositioning Between (a)(1) and (a)(2), Revision 6. Corrective actions taken by the licensee to address this issue included performing a maintenance rule (a)(1) determination and placing the system into (a)(1) status. The issue was entered into the licensees corrective action program as issue report (IR) 1644740, NRC Questions D2R23 Performance of DOS 390001, and IR 1650033, MRule A1 Determination Needed for Missed MRFF Z391. The performance deficiency was determined to be more than minor because the finding was associated with the Mitigating Systems Cornerstones attribute of Equipment Performance and affected the cornerstones objective of ensuring the availability and reliability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the licensee failed to identify a functional failure during a periodic (a)(2) demonstration purposed to provide reasonable assurance that the structures, systems, and components (SSCs), the standby coolant injection valve MO 23902, was capable of performing its intended function as specified in licensee emergency operating procedure DEOP 050003, Alternate Water Injection Systems, Revision 22. In accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Initial Characterization of Findings, Table 2, the inspectors determined the finding affected the Mitigating Systems cornerstone. As a result, the inspectors determined the finding could be evaluated using Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2 for the Mitigating Systems cornerstone. The inspectors answered Yes to the question Does the finding represent a loss of system and/or function and determined that a Detailed Risk Evaluation was required. The Senior Reactor Analysts (SRAs) evaluated the finding using the Dresden Standardized Plant Analysis Risk (SPAR) model version 8.18 and Systems Analysis Programs for Hands-on Integrated Reliability Evaluations (SAPHIRE) version 8.0.9.0 software. The exposure time for the unavailability of the Standby Coolant Supply Valve 23902 was assumed to be the maximum value of one year. The result was a delta core damage frequency (CDF) of 6.6E8/yr. The dominant sequence was a medium loss of coolant accident initiating event with a failure of suppression pool cooling, a failure of power conversion system recovery, and a failure of late injection. Based on the Detailed Risk Evaluation, the SRAs determined that the finding was of very low safety significance (Green). This finding had a crosscutting aspect in Human Performance, Procedure Adherence, because the licensee failed to appropriately document the failure of a standby coolant supply valve in accordance with periodic test procedure DOS 390001, Standby Coolant Supply Functional Test. [H.8] |
Site: | Dresden |
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Report | IR 05000237/2014003 Section 1R12 |
Date counted | Jun 30, 2014 (2014Q2) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.12 |
Inspectors (proximate) | C Tilton D Lords D Reeser G Roach J Cameron M Holmberg M Jones M Learn M Morris M Porfirio R Edwards T Go |
Violation of: | 10 CFR 50.65(a)(1) 10 CFR 50.65 |
CCA | H.8, Procedure Adherence |
INPO aspect | WP.4 |
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Finding - Dresden - IR 05000237/2014003 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Dresden) @ 2014Q2
Self-Identified List (Dresden)
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