05000331/FIN-2013004-01
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Finding | |
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| Title | Extent of Condition Not Properly Evaluated |
| Description | A finding of very low safety significance and associated non-citied violation (NCV) of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified by the inspectors for the licensees failure to accomplish safety-related procedure EN-AA-203-1001, Operability Determinations/Functionality Assessments. Specifically, during the Fall 2012 refueling outage, the licensee failed to evaluate the extent of condition under a prompt operability determination (POD) for the A residual heat removal service water (RHRSW) subsystem after identifying several locations of the B RHRSW supply piping that was less than the minimum acceptable wall thickness. By not performing a POD, the operations shift manager (OSM) was not able to perform his or her responsibility to review, assess, and approve the operability call regarding the potential for wall thinning of the A RHRSW piping. The licensee entered the inspectors concerns into the CAP as Condition Report (CR) 01892263. The licensee completed a POD to evaluate the extent of wall thinning condition for the A RHRSW subsystem and determined that the A RHRSW subsystem was operable but with reduced margin to design specifications. This was reviewed and approved by the OSM. The inspectors determined that the issue of concern represented a performance deficiency because it was the result of the licensees failure to meet a procedural 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 if left uncorrected, failing to properly assess the impact of extent of condition for operability on similar structures, systems, or components (SSCs) would have the potential to lead to a more significant safety concern. The inspectors applied IMC 0609, Attachment 4, Initial Characterization of Findings, to this finding. Because the finding pertained to operations while the plant was both shutdown and operating, the inspectors referenced both IMC 0609, Appendix G, Shutdown Operations Significance Determination Process, and IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power. Per IMC 0609, Appendix G, the inspectors determined that the finding did not require a quantitative assessment and therefore screened as very low safety significance (Green). Additionally, per IMC 0609, Appendix A, the inspectors determined that although the finding was a deficiency affecting the design and qualification of the SSC, the SSC maintained its operability and therefore also screened as very low safety significance (Green). The inspectors determined that the performance characteristic of the finding that was the most significant causal factor of the performance deficiency was associated with the cross-cutting aspect of Human Performance, having Decision Making components, and involving the licensee making safety or risk-significant decisions using a systematic process, especially when faced with uncertain or unexpected plant conditions, to ensure safety is maintained. Further, this includes formally defining the authority and roles for decisions affecting nuclear safety, and implementing these roles and authorities as designed. Specifically, the evaluation of extent of condition for the identified pipe wall thinning of the B RHRSW subsystem was not performed under the systematic operability determination process which resulted in bypassing the OSMs role in assessing and approving operability following the identification of a degraded or non-conforming condition. |
| Site: | Duane Arnold |
|---|---|
| Report | IR 05000331/2013004 Section 1R21 |
| Date counted | Sep 30, 2013 (2013Q3) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.21 |
| Inspectors (proximate) | A Shaikh C Lipa L Haeg R Murray V Myers |
| Violation of: | 10 CFR 50 Appendix B Criterion V |
| CCA | H.13, Consistent Process |
| INPO aspect | DM.1 |
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Finding - Duane Arnold - IR 05000331/2013004 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Duane Arnold) @ 2013Q3
Self-Identified List (Duane Arnold)
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