05000331/FIN-2012005-04
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Finding | |
|---|---|
| Title | Failure to Accomplish Safety/Relief Valve Test Instructions |
| Description | A finding of very low safety significance and associated NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was self-revealed on October 24, 2012, for the licensees failure to accomplish instructions for functional testing of the main steam line safety/relief valve PSV-4402 pilot valve. Specifically, a model work order to perform testing of the pilot valve required the main steam lines to be drained; however, the decision was made to allow performance of the testing following removal of the main steam line plugs. Due to a minor leak of the closed safety/relief valve nitrogen accumulator isolation valve, the testing and the resultant brief opening of the pilot valves solenoid valve caused nitrogen to reposition the pilot valve disc of the safety/relief valve. This then resulted in momentary opening of PSV-4402 and discharge of approximately 700 gallons of reactor cavity water into the drained suppression pool. The licensee entered the issue into the Corrective Action Program (CAP) as Condition Report (CR) 01816385. The licensee revised the model work orders for safety/relief valve pilot valve functional testing and was in the process of creating separate return-toservice tasks to ensure that testing of the pilot valves could not be performed unless the main steam lines were drained. The inspectors determined that testing of PSV-4402 without the main steam line plugs installed represented a performance deficiency because it was the result of the licensees failure to meet a regulatory requirement, and the cause was reasonably within the licensees ability to foresee and correct and should have been prevented. The performance deficiency was determined to be more than minor and a finding because it was associated with the Initiating Events Cornerstone attributes of configuration control and human performance and adversely affected the cornerstone objective of limiting the likelihood of events that upset plant stability during shutdown operations. The inspectors applied IMC 0609.04, Initial Characterization of Findings, to this finding. Because the finding pertained to an event while the plant was shutdown, Table 3 instructed reference of IMC 0609, Appendix G, Shutdown Operations Significance Determination Process, and IMC 0609, Appendix G, Attachment 1, Shutdown Operations Significance Determination Process Phase 1 Operational Checklists for Both PWRs and BWRs. Because all attributes IMC 0609, Appendix G, Attachment 1, Checklist 7 BWR Refueling Operation with Reactor Coolant System (RCS) Level > 23, were met throughout the event, the finding did not require a quantitative analysis and screened as very low safety significance (Green). The inspectors determined that the contributing cause that provided the most insight into the performance deficiency was associated with the cross-cutting aspect of Human Performance, having Decision-Making components, and involving the licensee using conservative assumptions in decision making and adopting a requirement to demonstrate that a proposed action is safe in order to proceed rather than a requirement to demonstrate that it is unsafe in order to disapprove an action. |
| Site: | Duane Arnold |
|---|---|
| Report | IR 05000331/2012005 Section 4OA3 |
| Date counted | Dec 31, 2012 (2012Q4) |
| Type: | NCV: Green |
| cornerstone | Initiating Events |
| Identified by: | Self-revealing |
| Inspection Procedure: | IP 71153 |
| Inspectors (proximate) | R Orlikowski M Phalen D Jones L Haeg J Draper R Murray S Bell R Elliott |
| CCA | H.14, Conservative Bias |
| INPO aspect | DM.2 |
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Finding - Duane Arnold - IR 05000331/2012005 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Duane Arnold) @ 2012Q4
Self-Identified List (Duane Arnold)
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