05000335/FIN-2013002-01
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Finding | |
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Title | Failure to Promptly Identify and Correct a Condition Adverse to Quality for Alignment of the SAFETY-RELATED Refueling Water Tank to a NON-SEISMIC Spent Fuel Pool Purification System |
Description | An NRC identified non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, was identified for the failure to promptly identify and correct a condition adverse to quality (CAQ) involving alignment of the safety-related refueling water tank (RWT) to a non-seismic spent fuel pool (SFP) purification system. Corrective actions included implementing administrative actions to preclude this alignment when the RWT is required to be operable. The finding was more than minor because it affected the configuration control attribute of the mitigating systems cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically the alignment of the safety-related RWT to the nonseismic SFP purification system created a CAQ and rendered the RWT inoperable for greater than its allowed outage time. The inspectors evaluated the finding in accordance with NRC Inspection Manual Chapter 0609, Significant Determination Process, Attachment 4 and Appendix A and determined that the finding required a phase 3 evaluation by a senior reactor analyst. The analyst calculated the change in conditional core damage probability (ACCDP) due to the postulated loss of the RWT during an event, multiplied by the frequency of a seismic event that could require the use of the RWT (e.g., loss of coolant accident) and applied an exposure time factor (4 days/7 days). The dominant sequence was a steam generator tube rupture which proceeds to core damage due to a lack of high or low pressure injection water supply. The risk was mitigated by the low probability of a seismic event. The analysis determined that the risk increase of the performance deficiency was an increase in large early release frequency less than 1E-7/year which is a GREEN finding of very low safety significance. The cause of the finding involved the cross-cutting area of problem identification and resolution, the component of corrective action program, and the aspect of complete and thorough evaluation, P.1(c); because the licensee failed to properly evaluate for operability the practice of aligning a seismically qualified RWT to a non-seismic purification system. |
Site: | Saint Lucie ![]() |
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Report | IR 05000335/2013002 Section 4OA2 |
Date counted | Mar 31, 2013 (2013Q1) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71152 |
Inspectors (proximate) | W Loo R Reyes T Morrissey T Hoeg M Speck D Rich S Sandal |
Violation of: | 10 CFR 50 Appendix B Criterion XVI |
CCA | P.2, Evaluation |
INPO aspect | PI.2 |
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Finding - Saint Lucie - IR 05000335/2013002 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Saint Lucie) @ 2013Q1
Self-Identified List (Saint Lucie)
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