05000317/FIN-2013002-02
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Finding | |
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Title | Inadequate Technical Specification Surveillance Testing of the Diesel Fuel Oil Transfer System |
Description | The inspectors identified an NCV of Technical Specification (TS) surveillance requirement (SR) 3.8.1.7 because Constellation failed to adequately perform SR associated with the DFO transfer system. Specifically, since approximately 1996, Constellation did not test the 2A EDG fuel oil transfer system aligned to the No. 21 FOST. The No. 21 FOST is the credited tank in the plants licensing bases. Immediate corrective actions included entering this issue into the CAP and entering TS SR 3.0.3 for a missed surveillance which required performing a probabilistic risk assessment and performing the missed surveillance within 31 days. Corrective actions planned includes revising the quarterly EDG surveillance procedure to test the 2A EDG while aligned to the No. 21 FOST and develop and implement a testing program to periodically test each EDG aligned to the normal and alternate FOSTs. This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating System 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, Constellations testing program did not provide assurance that no obstruction exists in the DFO transfer system. If left uncorrected, this issue potentially would result in a greater safety concern in that an obstruction could exist would not be identified until an actual event requiring the 2A EDG to be aligned to the No. 21 FOST as described in the safety analysis. In accordance with IMC 0609.04, Initial Characterization of Findings and Exhibit 2 of IMC 0609, Appendix A, Significance Determination Process For Findings At-Power, issued June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) because the performance deficiency was not a design or qualification 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 greater than its TS allowed outage time; and did not represent an actual loss of function of one or more non-TS trains of equipment designated as high safety significance. The inspectors determined that the finding has a cross-cutting aspect in the area of Problem Identification and Resolution, CAP, because Constellation did not ensure that issues potentially impacting nuclear safety are promptly identified, fully evaluated, and that actions are taken to address safety issues in a timely manner, commensurate with their significance. Specifically, Constellation did not take appropriate corrective actions to address safety issues and adverse trends in a timely manner associated with previously identified inadequate testing programs of risk significant equipment. |
Site: | Calvert Cliffs |
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Report | IR 05000317/2013002 Section 1R22 |
Date counted | Mar 31, 2013 (2013Q1) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.22 |
Inspectors (proximate) | A Rosebrook D Schroeder E Torres K Kennedy R Rolph S Shaffer T Burns |
Violation of: | Technical Specification - Procedures Technical Specification |
CCA | P.3, Resolution |
INPO aspect | PI.3 |
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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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