05000336/FIN-2013004-01
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Finding | |
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| Title | Inadequate Corrective Actions to Restore Degraded Unit 3 Main Feedwater Isolation Valves |
| Description | The inspectors identified a cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, for Dominions continued failure to take timely and effective corrective actions for conditions adverse to quality involving the degradation of the closing capability of four Unit 3 main feedwater isolation valves. Dominion had deferred correcting this condition over a period of six years (three refueling outages) which the inspectors noted in NCV 05000423/2012010-01, a Green NCV of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action. Dominion has since deferred repairs from the April 2013 refueling outage until the October 2014 outage. The violation is cited because Dominion has failed to restore compliance or demonstrate objective evidence of plans to restore compliance at the first opportunity in a reasonable period of time following initial identification in 2007 and documentation in 2012 NRC inspection reports. Dominion entered the issue into their CAP as CR507299 and plans to modify the valves in the 2014 refueling outage. The inspectors determined this issue was more than minor because it is similar to the more than minor examples, 4.f and 4.g of IMC 0612, Appendix E, Examples of Minor Issues. Specifically, Dominion did not correct a condition adverse to quality in a timely manner and resulted in a situation that impacted the operability of the feedwater isolation valves. Additionally, the finding is more than minor because it is associated with the design control attribute of the Barrier Integrity cornerstone, and adversely affected the cornerstones objective of providing reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and containment) protect the public from radionuclide releases caused by accidents or events. The inspectors determined that the finding was of very low safety significance (Green) because the issue did not represent an actual open pathway in the physical integrity of the reactor containment. In the event of a ruptured feedwater line, the train A main feedwater regulating valves and bypass valves would remain capable of closing to isolate feedwater flow. This finding had a cross-cutting aspect in the Human Performance area, Resources component, because Dominion did not maintain long term plant safety by minimizing longstanding equipment issues and ensuring maintenance and engineering backlogs which are low enough to support safety. Specifically, Dominion deferred the feedwater isolation valve replacement project from 3RFO15 to 3RFO16 because the design change could not be issued to support online work on the project required prior to the outage. Additionally, there were a number of outstanding technical issues for the design change that were not resolved in time despite the condition existing since 2007. |
| Site: | Millstone  |
|---|---|
| Report | IR 05000336/2013004 Section 1R15 |
| Date counted | Sep 30, 2013 (2013Q3) |
| Type: | Violation: Green |
| cornerstone | Barrier Integrity |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.15 |
| Inspectors (proximate) | B Haagensen D Silk E Dipaolo H. Anagnostopoulus J Amberosini L Mckown R Mckinley S Barr S Chaudhary K Reidm Patelm Modes B Haagensen J Krafty R Mckinley J Nicholson R Rolph S Chaudhary J Ambrosini T Hedigan D Lawyer |
| Violation of: | 10 CFR 50 Appendix B Criterion XVI |
| CCA | H.6, Design Margins |
| INPO aspect | WP.2 |
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Finding - Millstone - IR 05000336/2013004 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Millstone) @ 2013Q3
Self-Identified List (Millstone)
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