05000331/FIN-2008004-02
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Finding | |
|---|---|
| Title | Failure to Perform a TS Surveillance Requirement for the HPCI System Within the Specified Frequency |
| Description | A finding of very low safety significance and associated NCV of 10 CFR 50 Appendix B, Criterion III, Design Control was identified by the inspectors for the licensees failure to assure that applicable regulatory requirements and design basis were correctly translated into specifications, drawings, procedures and instructions. Specifically, following installation of a permanent modification to install a high pressure keep fill system for the high pressure coolant injection (HPCI) system discharge piping, the Surveillance Test Procedure (STP) implemented to document performance of Surveillance Requirement (SR) 3.5.1.1 for the HPCI system did not ensure that the minimum requirements for system operability were met. The licensee entered this issue into their CAP as CAP 060168, and invoked SR 3.0.3 to address the potentially missed SR. The issue was more than minor because the finding was associated with the Mitigating Systems Cornerstone attribute of design control of permanent modifications and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesired consequences. Specifically, the Operations department did not recognize that the implementation of the surveillance procedure which documented the performance of SR 3.5.1.1 for the HPCI system did not ensure that the minimum requirements for system operability were met and therefore had the potential to impact the availability and reliability of the HPCI system. The inspectors evaluated the finding using the SDP in accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of findings, Table 4a, for the Mitigating Systems Cornerstone. Because the finding does not represent an actual loss of safety function of a single train, and does not screen as risk significant due to an external initiating event, the finding was screened as very low safety significance (Green). The inspectors also determined that this finding had a cross-cutting aspect in the PI&R component of CAP, because the licensee did not properly classify, prioritize, and evaluate for operability a condition adverse to quality P.1(c). Specifically, the Operations and Engineering Departments failed to recognize that the system conditions established during performance of STP 3.5.1-13 had the potential to preclude performance of the SR and allow the condition to go unrecognized. (Section 1R18) |
| Site: | Duane Arnold  |
|---|---|
| Report | IR 05000331/2008004 Section 1R18 |
| Date counted | Sep 30, 2008 (2008Q3) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | |
| Inspectors (proximate) | J Neurauter T Go R Orlikowski R Baker |
| CCA | P.2, Evaluation |
| INPO aspect | PI.2 |
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Finding - Duane Arnold - IR 05000331/2008004 | ||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Duane Arnold) @ 2008Q3
Self-Identified List (Duane Arnold)
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