05000250/FIN-2010005-05
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Finding | |
|---|---|
| Title | Licensee-Identified Violation |
| Description | Turkey Point Technical Specification 6.8.1.a, states that written procedures required by the Quality Assurance Topical Report (QATR) shall be implemented. The QATR commits to use the procedures in Appendix A of Regulatory Guide 1.33, which includes in Section 1.c, Equipment control (tagging). FPL implements this requirement, in part, with procedure 0-ADM-212.1, Operations In-plant Equipment Clearance Orders, which requires in Step 5.1.9, that Prior to approving an equipment clearance order, it shall be determined the impact on equipment availability to meet technical specifications. Contrary to the above, during preparation and execution of equipment clearance order 3- 10-01-001, for the Unit 3 high head safety injection system, the impact on equipment available to meet Unit 4 Technical Specifications requirements was not determined prior to approval. As a result, while implementing the clearance order, the Unit 4 high head safety injection system was rendered inoperable for a period of 36 minutes, until the manual isolation valve 3-867 was shut, as required by the clearance. The technical specification impact, diversion of Unit 4 high head safety injection to Unit 3 and entry of Unit 4 into TS 3.0.3 for 36 minutes, was determined after the clearance was implemented. When identified by the licensee during operator surveillance of control room indications, the manual valve was promptly shut in accordance with the clearance. The event was documented in the corrective action program as AR 584026584026and an investigation was initiated. A regional Senior Reactor Analyst evaluated the performance deficiency under the Phase 3 protocol of the Significance Determination Process. Based upon the results of this evaluation, the performance deficiency was characterized as of very low safety significance (Green). The NRCs most current Probabilistic Risk Assessment model for Turkey Point was used to perform the evaluation. The basic event for the common cause failure of the High Head Safety Injection valves, 843A and B, was set to always occur in the model as the surrogate for the performance deficiency. The major evaluation assumptions included a one hour exposure time and no potential to re-position either of the two valves during the exposure time. The dominant accident sequence was a Small Break Loss of Coolant Accident followed by operators failing to use the High Head Safety Injection hot leg injection path, given a failure of the cold leg injection path due to the performance deficiency. |
| Site: | Turkey Point  |
|---|---|
| Report | IR 05000250/2010005 Section 4OA7 |
| Date counted | Dec 31, 2010 (2010Q4) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | Licensee-identified |
| Inspection Procedure: | |
| Inspectors (proximate) | G Kuzo R Aiello R Carrion M Barillas S Stewart D Rich A Vargas A Sengupta R Kellner |
| INPO aspect | |
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Finding - Turkey Point - IR 05000250/2010005 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Turkey Point) @ 2010Q4
Self-Identified List (Turkey Point)
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