05000331/FIN-2010003-01
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Finding | |
|---|---|
| Title | Failure to Follow the Procedures for Performing Operability Determinations |
| Description | A finding of very low safety significance and associated NCV of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified by the inspectors for the failure of the licensee to follow procedure EN-AA-203-1001, Operability Determinations/Functionality Assessments, and Administrative Control Procedure (ACP) 110.1, Conduct of Operations. Specifically, the Shift Manager failed to make an Immediate Operability Determination (IOD) that addressed the impact of the degraded conditions in the drywell cooling system on Primary Containment, and to provide sufficient detail for an independent person to understand the basis for the decision. These actions were contrary to step 4.3 of EN-AA-203-1001 and Attachment 10 of ACP 110.1, and represented a performance deficiency warranting further investigation. The licensee entered the issues into their Corrective Action Program (CAP) as CAP 074069 and Condition Report (CR) 568618, and completed an Operability Recommendation (OPR), OPR 000427, that determined the Primary Containment was operable, but degraded, as a result of the drywell cooling system condition. The performance deficiency was determined to be more than minor because, if left uncorrected, failure to properly implement the operability procedures could result in safety-related components being incorrectly declared operable rather than inoperable or operable but degraded or non-conforming (a more significant safety concern). The inspectors evaluated the finding using the SDP in accordance with IMC 0609, Table 4a for the Barrier Integrity Cornerstone. Because inspectors answered No to all four questions under the Containment Barrier column, the finding was determined to be of very low safety significance (Green). The finding had a cross-cutting aspect in the area of Human Performance, Decision Making, because the licensee did not use conservative assumptions in decision making and adopt a requirement to demonstrate that the proposed action is safe in order to proceed rather than a requirement to demonstrate that it is unsafe in order to disapprove the action. Specifically, not evaluating the degraded condition of the drywell cooling system to determine its impact on Primary Containment operability was a non-conservative assumption in the IOD. |
| Site: | Duane Arnold  |
|---|---|
| Report | IR 05000331/2010003 Section 1R15 |
| Date counted | Jun 30, 2010 (2010Q2) |
| Type: | NCV: Green |
| cornerstone | Barrier Integrity |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.15 |
| Inspectors (proximate) | K Riemer R Orlikowski M Mitchell R Baker R Murray A Scarbeary P Smagacz |
| CCA | H.14, Conservative Bias |
| INPO aspect | DM.2 |
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Finding - Duane Arnold - IR 05000331/2010003 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Duane Arnold) @ 2010Q2
Self-Identified List (Duane Arnold)
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