05000261/FIN-2012007-01
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Finding | |
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| Title | Failure to Take Adequate Corrective Action to Preclude Repetition of a Significant Condition Adverse to Quality Associated with the Refueling Water Storage Tank Purification |
| Description | A self-revealing Green NCV of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, was identified for the licensees failure to take adequate corrective actions to prevent recurrence (CAPR) in response to a significant condition adverse to quality (SCAQ) associated with the purification of the Refueling Water Storage Tank (RWST). Specifically, on March 16, 2012, with the plant in Mode 4, the licensee aligned the non-seismically qualified Spent Fuel Pool Demineralizer to the seismically qualified boundary of the RWST to perform purification of the RWST. This action rendered the RWST inoperable. This issue was previously identified as a significant condition adverse to quality in May 2011, but the corrective actions taken failed to preclude repetition. The licensee entered this issue in the corrective action program as Nuclear Condition Report (NCR) 524619. As immediate corrective actions, the licensee removed the SFP purification system from service and replaced the caution tags on valves SFPC-805A, Refueling Water Purification Pump Suction from RWST and SFPC-805B, RWST Return, with a Clearance. The licensee plans to revise several operating procedures to correctly apply Technical Specifications implications into procedural steps and they also plan to implement Engineering Change (EC) 80584, to perform a seismic qualification of the spent fuel pool / RWST purification system to allow alignment to the RWST without affecting operability. The licensees failure to take adequate corrective actions to prevent recurrence of a SCAQ, aligning the non-seismically qualified spent fuel pool demineralizer system for purification of the safety related and seismically qualified RWST, was a performance deficiency. The finding was more than minor because if left uncorrected, it has the potential to lead to a more significant safety concern. The finding was determined to affect the mitigating systems cornerstone objective of ensuring the availability, reliability, and capability of systems to respond to initiating events to prevent undesirable consequences. Specifically, during a seismic event the purification piping could break and cause a loss of inventory in the RWST which is used in accident mitigation. Inspection Manual Chapter (IMC) 0609, Attachment 4, Table 4a, Phase 1 Initial Screening and Characterization of Findings, determined that this finding was within the mitigating systems (MS) cornerstone and was potentially risk significant due to a seismic external event and therefore required a Phase 3 SDP analysis. A phase 3 risk assessment was performed by a regional Senior Risk Analyst (SRA) using the NRC SPAR model. The analysis determined that the risk increase of the performance deficiency was an increase in core damage frequency less than 1E-6/year a GREEN finding of very low safety significance. The cross cutting aspect of the finding was directly related to the CAP component of the Problem Identification and Resolution area, because the licensee failed to take appropriate corrective actions to address safety issues. Specifically, the licensees corrective actions regarding the alignment of the purification system to the RWST were not adequate to solved the issue and prevent recurrence |
| Site: | Robinson |
|---|---|
| Report | IR 05000261/2012007 Section 4OA2 |
| Date counted | Jun 30, 2012 (2012Q2) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | Self-revealing |
| Inspection Procedure: | IP 71152 |
| Inspectors (proximate) | R Taylor J Quinones W Deschaine J Worosilo D Lanyi G Hopper |
| CCA | P.3, Resolution |
| INPO aspect | PI.3 |
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Finding - Robinson - IR 05000261/2012007 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Robinson) @ 2012Q2
Self-Identified List (Robinson)
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