05000324/FIN-2009005-03
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Finding | |
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Title | Inadequately Monitored Maintenance Rule MOV |
Description | The inspectors identified a Green NCV of 10 CFR 50.65(a)(1), Requirements for monitoring the effectiveness of maintenance at nuclear power plants, for the licensees failure to monitor the performance or condition of motor-operated valve (MOV) MS-V28 in a manner sufficient to provide reasonable assurance that it was capable of fulfilling its intended functions. As a result, the licensee did not recognize that the valve was incapable of opening against design differential pressure and failed to take appropriate corrective actions to ensure that the valve could fulfill its emergency operating procedure (EOP) function. After the issue was identified, the licensee altered its operating procedures to compensate for the valve not opening against design differential pressure and entered it into their corrective action program (AR #356800). The failure to adequately monitor the performance or condition of MOV MS-V28 in a manner to provide reasonable assurance that the valve was capable of fulfilling its intended function is a performance deficiency. The performance deficiency was more than minor because it is associated with the Mitigating Systems cornerstone attribute of equipment performance, and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, the performance deficiency affected the reliability of the MOV MS-V-28 and its use in EOPs to restore feed to the reactor. Inspectors evaluated the finding using NRC IMC 0609, Significance Determination Process, Appendix A. Since the finding represents an actual loss of a function of non-Technical Specifications equipment designated as risk-significant for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the finding required a phase two significance analysis. The Brunswick phase 2 SDP spreadsheet indicated that the finding was greater than green but did not detail to the cases requiring MS-V28 operation therefore a phase 3 SDP analysis was completed by a regional SRA. The phase 3 SDP analysis was performed in accordance with NRC Inspection Manual Chapter 0609 appendix A utilizing the NRC SPAR model and output from the licensees full scope PRA model. The result was a risk increase for the finding of <1E-6 for core damage frequency (cdf) and <1E-7 for large early release frequency (LERF). The dominant sequences were transient initiators with spurious level instrument generated main steam isolation valve (MSIV) closure and the inability to restore main feedwater due to the performance deficiency coupled with failure to achieve successful depressurization and use of low pressure makeup systems leading to core damage. The risk was mitigated by the low initiating event frequency for transient conditions which would allow MSIV reopening and recovery of main feedwater. The availability of low pressure injection systems was also a factor reducing the risk. The result of the phase 3 analysis was that the finding was characterized as having very low safety significance, a Green finding. The cause of this finding was directly related to the problem evaluation cross-cutting aspect in the corrective action program component of the Problem Identification and Resolution cross-cutting area because the licensee failed to adequately evaluate the failure of MS-V28 in November 2008. (P.1(c)) |
Site: | Brunswick |
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Report | IR 05000324/2009005 Section 1R12 |
Date counted | Dec 31, 2009 (2009Q4) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.12 |
Inspectors (proximate) | M Bates L Miller R Musser G Kolcum |
CCA | P.2, Evaluation |
INPO aspect | PI.2 |
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Finding - Brunswick - IR 05000324/2009005 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Brunswick) @ 2009Q4
Self-Identified List (Brunswick)
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