05000280/FIN-2011004-02
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Finding | |
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Title | Failure to Consider Instrument Uncertainty and Establish Calibration Controls for Rotameters Used to Vent Gas from ECCS Systems |
Description | An NRC-identified non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion XI, Test Control, (with two examples) was identified for the failure to establish measures to apply rotameter instrument measurement error and appropriate instrument calibration controls or standards when using instruments of this type to determine the size of voids discovered as a result of ECCS system venting. The issue was entered into the licensees corrective action program (CAP) as CR419024 and CR419243. The failure to establish and implement measures (1) to ensure the application of +/- 5% rotameter instrument error to as-found void measurement, and (2) to ensure that rotameters calibrated to standard pressure conditions were used when utilizing those instruments to evaluate the size of as-found voids were performance deficiencies. The performance deficiencies were greater than minor, because, if left uncorrected, they could result in a more significant safety concern. Specifically, the performance deficiencies represented programmatic issues and if instrument error and/or appropriate calibration standards were not applied to instruments used for future void characterization, then sufficient measurement error could reasonably result such that as-found voids, which challenge or exceed established acceptance criteria, may not be identified as intended by post venting evaluations. The finding was screened for significance using the Mitigating Systems cornerstone column of Inspection Manual Chapter (IMC) 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, and determined to be of very low safety significance (Green) because the finding did not represent a design or qualification deficiency, did not represent the loss of a safety system function, did not represent the loss of a train for greater than the allowed outage time, did not represent the loss of risk significant equipment for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and was not potentially risk significant due to external events. Because the licensee had failed to implement complete, accurate, and up-to-date controls necessary to ensure that rotameter error and calibration standards were adequately addressed by procedures used to evaluate the impact of voids on emergency core cooling systems, this finding is assigned a cross-cutting aspect in resources component of the human performance area |
Site: | Surry |
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Report | IR 05000280/2011004 Section 4OA5 |
Date counted | Sep 30, 2011 (2011Q3) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | |
Inspectors (proximate) | D Jones G Wiseman J Nadel S Sanchez S Sandal S Walker B Collins |
CCA | H.7, Documentation |
INPO aspect | WP.3 |
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Finding - Surry - IR 05000280/2011004 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Surry) @ 2011Q3
Self-Identified List (Surry)
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