05000335/FIN-2015007-02
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Finding | |
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| Title | Failure to Establish Appropriate Procedural Limitations to Prevent Exceeding Non-LOCA Event Analysis Assumptions for Steam Generator Blowdown Flow Rate |
| Description | An NRC-identified non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion III, Design Control, was identified for the licensees failure to assure that design basis assumptions for steam generator blowdown (SGBD) flow rate were translated into procedural guidance. Specifically, procedures 1-NOP-23.02 and 1-AOP-09.03 for Unit 1, and 2-NOP-23.02 and 2-AOP-09.03 for Unit 2, allowed SGBD flow rates significantly in excess of the assumed values in non-loss of coolant accident (LOCA) event analyses. The licensee entered the issue into their corrective action program as action requests (ARs) 2030177, 2031217, and 2031218. The licensees immediate corrective actions included performing a functionality assessment of the SGBD systems for both units, which included; re-performing the event analyses, issuing an operations department night order to temporarily provide operators appropriate direction for limiting the SGBD system flow, and plans to update the analyses of record, plant procedures, and the UFSAR with new system limitations. The performance deficiency was determined to be more than minor because it affected the procedure quality attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring reliability, availability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee did not ensure the capability of the secondary side heat removal systems to respond to design basis non-LOCA events because analysis assumptions were not translated into procedural limitations for the SGBD system. The inspectors determined the finding to be of very low safety significance (Green) because the finding was a deficiency affecting the design or qualification of a mitigating structure, system, or component (SSC), and the SSC maintained its operability or functionality. The inspectors determined that the issue was indicative of present licensee performance because the analyses were performed in 2013. The finding was associated with the cross-cutting aspect of design margins, in the area of human performance, because the organization did not operate and maintain equipment within design margins. |
| Site: | Saint Lucie  |
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| Report | IR 05000335/2015007 Section 1R17 |
| Date counted | Mar 31, 2015 (2015Q1) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.17 |
| Inspectors (proximate) | G Ottenberg J Bartley M Orr M Riley S Herrick |
| Violation of: | 10 CFR 50 Appendix B Criterion III, Design Control |
| CCA | H.6, Design Margins |
| INPO aspect | WP.2 |
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Finding - Saint Lucie - IR 05000335/2015007 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Saint Lucie) @ 2015Q1
Self-Identified List (Saint Lucie)
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