05000317/FIN-2013002-01
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Finding | |
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| Title | Failure to Establish Adequate Design Control Measures for Diesel Fuel Oil Cloud Point |
| Description | The inspectors identified an NCV of 10 CFR 50, Appendix B, Criterion III, Design Control, because Constellation failed to provide design control measures to assure appropriate specifications were translated into procedures for diesel fuel oil (DFO) in the No.11 fuel oil storage tank (FOST). Specifically, Constellations cloud point maximum specification for DFO is above historical minimum temperatures recorded in the vicinity of CCNPP. The inspectors determined that Constellation did not have adequate measures in place such as a calculation, temperature monitoring, and/or procedures to assess the operability of the DFO transfer system from the No. 11 FOST for sustained outdoor temperatures below the cloud point specification temperature but above the minimum expected temperature the site may experience. Constellation entered this issue in their corrective action program (CAP). Immediate corrective actions included adding a note in Operations turnover sheet to determine No.11 FOST DFO operability if ambient temperatures dropped below 10F at the site. Planned corrective actions include performing a calculation to determine cold weather effects on the No.11 FOST. This finding is more than minor because it is associated with the protection against external factors attribute of the Mitigating Systems cornerstone and affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, a reasonable doubt of operability existed because the minimum temperature limits and duration of low temperature had not been established for diesel generator operability and historical low temperatures have been below the cloud point of the DFO. If left uncorrected, the performance deficiency has the potential to lead to a more significant safety concern because an inadequate cloud point specification could impact emergency diesel generator (EDG) and/or station blackout (SBO) diesel operation during an actual event during extreme low temperature conditions. The inspectors evaluated the significance of this finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings at Power, Exhibit 2, Mitigating Systems Screening Questions. The inspectors determined that this finding was of very low safety significance (Green) because the finding is a deficiency affecting the design or qualification of a mitigating structure, system, and component (SSC); however, the SSC maintained its operability or functionality. This finding did not have a cross-cutting aspect because the most significant contributor of the performance deficiency was not reflective of current licensee performance. Specifically, the most reasonable opportunity to identify this issue was in 1994 when Constellation reviewed this issue in response to Information Notice (IN) 94-19, Emergency Diesel Generator Vulnerability to Failure from Cold Fuel Oil. |
| Site: | Calvert Cliffs  |
|---|---|
| Report | IR 05000317/2013002 Section 1R04 |
| Date counted | Mar 31, 2013 (2013Q1) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.04 |
| Inspectors (proximate) | A Rosebrook D Schroeder E Torres K Kennedy R Rolph S Shaffer T Burns |
| Violation of: | 10 CFR 50 Appendix B Criterion III, Design Control |
| INPO aspect | |
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Finding - Calvert Cliffs - IR 05000317/2013002 | |||||||||||||||||||||||||||||||||||||||||||
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Finding List (Calvert Cliffs) @ 2013Q1
Self-Identified List (Calvert Cliffs)
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