05000282/FIN-2014007-03
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Finding | |
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Title | Failure to Evaluate Past Operability and Reportability of the Cooling Water System |
Description | The inspectors identified a finding of very low safety significance and non-cited violation of Title 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, for the licensees failure to accomplish FPPAARP01, CAP Action Request Process, to notify the shift manager of an operability/reportability concern and initiate a CAP for past periods of plant operation with a cooling water (CL) system strainer isolated. Specifically, with a CL header strainer isolated, a seismic event could lead to operation of the remaining CL strainer with excessive flow (e.g., outside analyzed limits) and adversely affect safety-related components cooled by the CL system. The licensee entered this issue into the CAP and initiated actions to evaluate past periods of operation with isolated CL strainers. The inspectors determined that the licensees failure to accomplish procedure FPPAARP01 was a performance deficiency. The performance deficiency was determined to be more than minor in accordance with IMC 0612, "Power Reactor Inspection Reports," Appendix B, "Issue Screening," because, if left uncorrected the performance deficiency would have the potential to lead to a more significant safety concern. Additionally, the performance deficiency was also determined to be more than minor because it was associated with the Mitigating Systems Cornerstone attribute of design control and adversely affected the Cornerstone objective of ensuring the availability, reliability, and capability of mitigating systems to respond to initiating events. The inspectors utilized IMC 0609, Significance Determination Process, Attachment 0609.04, Initial Characterization of Findings, and IMC 0609, Appendix A, The Significance Determination Process For Findings At-Power. The inspectors answered Yes to Question 2 of Section A of Exhibit 2, Mitigating Systems Screening Questions, since the CL system may not have been able to perform its design cooling functions during past periods of operation with one CL header strainer isolated. Therefore, the finding required a detailed risk evaluation which had been previously completed by a Senior Reactor Analyst (SRA) for the original finding (NCV 05000282/201300702; 05000306/201300702). Specifically, the SRA had previously determined that the bounding core damage frequency for this issue was 1.9E7/yr. and concluded the total risk increase to the plant due to this finding was of very low risk significance (Green). The inspectors determined that the performance characteristic of the finding that was the most significant causal factor of the performance deficiency was associated with the cross-cutting aspect of Human Performance, Consistent Process, and involving individuals using a consistent, systematic approach to make decisions. Specifically, the licensee failed to use the CAP process, in evaluation of the past operability and reportability of the CL system with the CL system strainers isolated. |
Site: | Prairie Island |
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Report | IR 05000282/2014007 Section 4OA2 |
Date counted | Jun 30, 2014 (2014Q2) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71152 |
Inspectors (proximate) | K Riemer L Haeg M Holmberg P Laflamme S Sheldon |
Violation of: | 10 CFR 50 Appendix B Criterion V |
CCA | H.13, Consistent Process |
INPO aspect | DM.1 |
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Finding - Prairie Island - IR 05000282/2014007 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Prairie Island) @ 2014Q2
Self-Identified List (Prairie Island)
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