05000255/FIN-2014004-04
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Finding | |
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| Title | Licensee-Identified Violation |
| Description | The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as an NCV. Title 10 CFR 50.55a(f)(4) requires, in part, that pumps and valves classified as ASME Code Class 1, 2, or 3 must meet the IST requirements set forth in the ASME OM Code and addenda, to the extent practical within the limitations of design, geometry, and materials of construction of the components. Contrary to that requirement, the licensee failed to test left train AFW flow control valves CV-0727 and CV-0749 in accordance with the ASME OM code requirements or the NRC-approved Valve Relief Request (VRR-18), for a period of approximately 6 years. In June 2013, the licensee identified that the alternate method for testing the AFW flow control valves, approved in 2007 by VRR-18 for the current 10-year IST interval, was not being performed. The approved alternate method for testing the regulating capability of these valves was to validate that the A/B AFW pump flow rates were within TS limits during the quarterly pump surveillance test. However, the quarterly surveillance test methodology was revised after the VRR was submitted to no longer provide AFW flow to the steam generators during testing, instead flowing water in a recirculation loop, and therefore not testing the regulating capability of the flow control valves. The licensee identified the issue during a focused self-assessment of the IST program and entered the issue into their CAP as CR-PLP-2013-2522, Alternate Testing Not Being Performed as Approved by Valve Relief Request for CV-0727 and CV-0749, on June 6, 2013. The valves were stroke time tested, in accordance with the ASME OM Code requirements, in November 2013, and every quarter thereafter, using the quarterly technical specification surveillance valve test procedure. The inspectors determined that the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems Cornerstone and adversely impacted the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the licensee did not perform Code-required timed valve strokes for several years, which adversely affected the ability to verify that the valves would operate as required. The inspectors evaluated the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process for Findings at Power, Exhibit 2, Mitigating Systems Screening Questions, and answered Yes to Question 1: If the finding is a deficiency affecting the design or qualification of a mitigating SSC, does the SSC maintain its operability or functionality? Therefore, the issue was determined to be of very low safety significance. |
| Site: | Palisades  |
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| Report | IR 05000255/2014004 Section 4OA7 |
| Date counted | Sep 30, 2014 (2014Q3) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | Licensee-identified |
| Inspection Procedure: | |
| Inspectors (proximate) | A Garmoe A Scarbeary E Duncan J Cassidy J Lennartz T Bilik |
| Violation of: | Technical Specification - Procedures Technical Specification 10 CFR 50.55a |
| INPO aspect | |
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Finding - Palisades - IR 05000255/2014004 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Palisades) @ 2014Q3
Self-Identified List (Palisades)
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