05000317/FIN-2016003-01
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Finding | |
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Title | Deficient Design Control of Air Pressure Available for Unit 1 Component Cooling Water Air Operated Valves |
Description | The inspectors identified a Green non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion III, Design Control, for Exelons failure to establish measures to assure that the design basis was correctly translated into specifications affecting safety related functions of air operated valves (AOV). Specifically, when implementing a design change, Exelon failed to verify the air pressure supplied to AOVs in the component cooling (CC) water system was adequate to ensure that the valves would have performed their safety function to close during certain specific accident conditions. The inspectors determined that Exelons failure to verify ECP-15-000213 ensured that air pressure supplied to safety related Unit 1 CC heat exchanger (HX) outlet AOVs was sufficient to support their safety function of closing during a design basis accident (DBA) was a performance deficiency that was reasonably within its ability to foresee and correct and should have been prevented. Exelons immediate corrective actions included conducting an engineering evaluation that demonstrated the operability of the CC system in the degraded condition and increasing the air pressure supplied to the CC HX outlet valves to ensure the valves are capable of fully closing during a DBA. Exelon entered this issue into its corrective action program (CAP) as action request (AR) 02680281. The inspectors reviewed IMC 0612, Appendix B, Issue Screening, and determined the issue is more than minor because it adversely affected the design control attribute of the Barrier Integrity cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. The inspectors also reviewed IMC 0612, Appendix E, Examples of Minor Issues, and found it was sufficiently similar to Example 3.j, in that the design analysis deficiency resulted in a condition where reasonable doubt existed regarding the operability of the Unit 1 CC HX outlet valves. In accordance with IMC 0609, Attachment 4, Initial Characterization of Findings, issued on June 19, 2012, and IMC 0609, Appendix A, The Significance Determination Process for Findings at Power, issued on June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) since, the finding did not involve an actual open pathway in the physical integrity of reactor containment. The inspectors determined that the cause of the finding has a cross-cutting aspect in the area of Human Performance, Documentation, because Exelons AOV program, as implemented by ER-AA-410, Air Operated Valve Implementing Program, Revision 2, did not require that complete, accurate, and up-to-date documentation on the CC HX outlet valves design be maintained. [H.7] |
Site: | Calvert Cliffs |
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Report | IR 05000317/2016003 Section 1R15 |
Date counted | Sep 30, 2016 (2016Q3) |
Type: | NCV: Green |
cornerstone | Barrier Integrity |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.15 |
Inspectors (proximate) | A Dimitriadis A Rosebrook C Roettgen E Torres H. Anagnostopoulus J Nicholson R Clagg S Barr |
Violation of: | 10 CFR 50 Appendix B 10 CFR 50 Appendix B Criterion III, Design Control |
CCA | H.7, Documentation |
INPO aspect | WP.3 |
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Finding - Calvert Cliffs - IR 05000317/2016003 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Calvert Cliffs) @ 2016Q3
Self-Identified List (Calvert Cliffs)
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