05000250/FIN-2013004-05
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Finding | |
|---|---|
| Title | Safety Injection Flow Path Not Isolated Due to Manual Valve Out of Position |
| Description | The inspectors identified a self-revealing non-cited violation of the limiting condition for operation specified by Unit 3 Technical Specification (TS) 3.4.9.3, Overpressure Mitigating Systems, which occurred as a result of the licensees failure to locally verify the closed position of manual valve 3-990 in accordance with OP-AA-100-1000, Conduct of Operations. The licensees failure to locally verify the closed position of manual valve 3-990 resulted in an unisolated high pressure safety injection flow path to the RCS for eight hours and 40 minutes which was greater than the TS 3.4.9.3 allowed outage time of four hours. Compliance with the TS was restored when the licensee isolated the flow path at the completion of in-service testing on February 28, 2013. Additionally, the licensee took corrective actions to fix the reach rod assembly and revised the procedures for verifying valve position and work order planning. The issue was entered into the licensees corrective action program as action request 1852222. The performance deficiency was more than minor because it was associated with the configuration control attribute of the initiating events cornerstone and adversely impacted the cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown operations. Specifically, the performance deficiency resulted in an open high pressure flow path to the reactor coolant system that degraded the overpressure mitigating systems ability to prevent a low temperature overpressure (LTOP) event. The inspectors assessed the finding using the initiating events cornerstone and evaluated the significance of the finding using Appendix G, Shutdown Operations Significance Determination Process, of Manual Chapter 0609. The inspectors determined that the finding required a detailed risk assessment because it was associated with a non-compliance with an LTOP technical specification. A Senior Reactor Analyst in NRC headquarters determined that the risk significance of the issue was very low (i.e., Green). The dominant accident sequence was an over-pressurization event caused by an inadvertent safety injection actuation, where the power-operated relief valves fail resulting in a through wall crack of the reactor coolant system. The finding was associated with a cross-cutting aspect in the resources component of the human performance area because the licensee failed to ensure that the work package contained adequate instructions for installation of roll pins instead of set screws in the reach rod assembly for valve 3-990 H.2(c). |
| Site: | Turkey Point  |
|---|---|
| Report | IR 05000250/2013004 Section 4OA3 |
| Date counted | Sep 30, 2013 (2013Q3) |
| Type: | NCV: Green |
| cornerstone | Initiating Events |
| Identified by: | Self-revealing |
| Inspection Procedure: | IP 71153 |
| Inspectors (proximate) | A Klett G Kolcum J Rivera M Endress M Riches R Reyes R Taylor T Hoeg W Pursley |
| Violation of: | Technical Specification |
| CCA | H.7, Documentation |
| INPO aspect | WP.3 |
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Finding - Turkey Point - IR 05000250/2013004 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Turkey Point) @ 2013Q3
Self-Identified List (Turkey Point)
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