05000336/FIN-2017001-03
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Finding | |
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Title | Licensee-Identified Violation |
Description | As discussed in Section 4OA2.2 of this report, the inspectors concluded that the ECCS minimum flow recirculation check valves should have been characterized as Category A valves, and should have been leak rate tested as per the IST Program. The associated LER is discussed in Section 4OA3.1. Title 10 CFR 50.55a, Codes and Standards, Section (f)(4), required in part, that throughout the service life of a pressurized water-cooled nuclear power facility, valves that are classified as Class 1, 2, or 3 must meet the IST requirements set forth in the ASME OM Code. Dominions Code of Record, ASME OM Code - 2001 Edition, Subsection ISTC-1300, Valve Categories, required that valves within the scope of Subsection ISTC-1300 shall be placed in one or more of the following categories, which included Category A (those valves for which seat leakage is limited 28 to a specific maximum amount in the closed position for fulfillment of their required function). The inspectors concluded that minimum flow recirculation check valve 2- CS-6A should have been a Category A valve, and leak rate tested, to assure fulfillment of its safety function (to mitigate the dose consequences of a postulated accident). Contrary to the above, since 1975, when the check valve 2-CS-6A was initially categorized, Dominion failed to appropriately categorize the subject valve and therefore did not meet the ASME OM Code requirements and 10 CFR 50.55a requirements. Specifically, failure to categorize the check valve as a Category A resulted in the valve not being subject to leak rate testing. This issue is more than minor because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors determined that the finding was of very low safety significance because it did not result in the loss of operability or functionality of a system or train, and the actual leakage through the check valve would not have resulted in a radiological dose in excess of regulatory requirements. Dominion entered the issue into the CAP as CR 582112 and CA 3013009. Because Dominion identified this issue of very low safety significance and it has been entered into their CAP, this finding is being treated as a licensee-identified NCV, consistent with Section 2.3.2.a of the NRC Enforcement Policy. This item was considered licensee-identified because it was identified by Dominion as a result of deliberate observation by licensee personnel, and was entered into their CAP. |
Site: | Millstone |
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Report | IR 05000336/2017001 Section 4OA7 |
Date counted | Mar 31, 2017 (2017Q1) |
Type: | NCV: |
cornerstone | Mitigating Systems |
Identified by: | Licensee-identified |
Inspection Procedure: | |
Inspectors (proximate) | C Highley H. Anagnostopoulus J Amberosini J Furia L Mckown S Pindale T Setzer |
Violation of: | 10 CFR 50.55a |
INPO aspect | |
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Finding - Millstone - IR 05000336/2017001 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Millstone) @ 2017Q1
Self-Identified List (Millstone)
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