05000313/FIN-2017003-01
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Finding | |
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Title | Failure to Maintain Service Water Train Separation |
Description | The inspectors identified a non- cited violation of Technical Specification 5.4.1.a for the licensees failure to maintain train separation between safety -related service water trains when swapping the swing high pressure injection (HPI) pump between trains. Specifically, by following procedure OP 1104.002, Makeup and Purification System Operation, Revision 89, operators cross -tied service water trains, placing the system in an unanalyzed condition. This condition resulted in the train A electrical equipment room emergency chiller and train B reactor building emergency cooling coils being inoperable for a maximum of 25 minutes per occurrence. Additionally, it was determined that service water temperatures over the past 3 years did not result in an actual loss of function associated with these components if a design basis accident would have occurred. The immediate corrective actions were to assess past operability for not maintaining service water train separation and to revise Operating Procedure 1104.002 with adequate work instructions to maintain service water train separation. The licensee entered this deficiency into the corrective action program as Condition Report CR -ANO -1-2017- 02518. The licensees failure to maintain safety -related service water train separation when swapping the swing HPI pump between trains was a performance deficiency. The performance deficiency was more than minor because it was associated with the procedural quality attribute of the Mitigating Systems Cornerstone, and adversely affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events. Specifically, the licensees failure to maintain service water train separation placed the system in an unanalyzed condition and was subsequently determined to cause the train A electrical equipment room emergency chiller and train B reactor building emergency cooling coils to be inoperable for a maximum of 25 minutes per occurrence . Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Finding s At-Power, dated June 19, 2012, the inspectors determined that the finding had very low safety significance (Green) because it: was not a design deficiency; did not represent a loss of system and/or function; did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time; and did not result in the loss of a high safety -significant , non -technical specification train. Specifically, inspectors confirmed that service water temperatures were never high enough to result in an actual loss of function for either limiting component. The finding had 3 a cross -cutting aspect in the area of human performance associated with conservative bias because the licensee failed to determine whether the proposed action was safe to proceed, rather than unsafe in order to stop. Specifically, in December 2015 when this approach was revise d to declare only the non- protected service water train inoperable, the licensee did not ensure that the transition lineup was analyzed to be within safety analyses before adopting the revised steps. [H.14] |
Site: | Arkansas Nuclear |
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Report | IR 05000313/2017003 Section 1R04 |
Date counted | Sep 30, 2017 (2017Q3) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.04 |
Inspectors (proximate) | C Henderson B Tindell J Dixon R Azua T Sullivan M Tobin J Choate S Hedger |
Violation of: | Technical Specification |
CCA | H.14, Conservative Bias |
INPO aspect | DM.2 |
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Finding - Arkansas Nuclear - IR 05000313/2017003 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Arkansas Nuclear) @ 2017Q3
Self-Identified List (Arkansas Nuclear)
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