05000338/FIN-2011005-01
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Finding | |
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| Title | Failure to Follow Procedure to Ensure Proper Calibration of RHR Valve Control Circuit |
| Description | A self-revealing Green NCV of Technical Specification 5.4.1.a was identified for the licensees failure to implement procedures as required by Regulatory Guide 1.33, Appendix A, Section 8, Procedures for Control of Measuring and Test equipment and for Surveillance Tests, Procedures, and Calibrations, specifically calibration procedures for a control circuit associated with a residual heat removal (RHR) suction valve. The licensee entered this issue into their corrective action program as CR452756 2-RH-MOV-2700 will not open with proper pressure across the seat and properly calibrated the control circuit. The inspectors determined that the failure to use the appropriate test point as required by licensee procedure 2-ICP-RC-P-2402 for the calibration of comparator card PC-2402 C1-245 was a performance deficiency. The inspectors reviewed IMC 0612, Appendix E and determined the finding was more than minor because it was similar to example 4.c. In accordance with NRC Inspection Manual Chapter (IMC) 0609, Appendix G, Shutdown Operations Significance Determination Process, Attachment 1, Checklist 4, the inspectors conducted a Phase 1 SDP screening and determined the finding required a Phase 2 analysis because the calibration error degraded the licensees ability to recover DHR once it was lost. A phase 2 SDP evaluation was performed by a regional SRA in accordance with NRC IMC 0609 Appendix G, Attachment 2, Phase 2 SDP Template for PWR during Shutdown. The exposure time was < 1 day from when RHR was secured and the valve closed until the licensee restored normal function for the valve. The significant assumptions and influential factors affecting the risk included: (1) The PD only affected opening from the main control room, local manual operation was not affected, (2) Closing of the valve and valve position indication were not affected, (3) Procedural guidance existed for local manual operation, (4) RCS pressure remained low (380psig) during the exposure period, and (5) the plant had been shutdown since August 23, 2011, and decay heat was very low. Large Early Release Fraction (LERF) risk was not significant due to the exposure period existing long after shutdown. The result of the risk analysis was an increase in core damage frequency of < 1E-6 per year, a GREEN finding of very low safety significance. The cause of this finding involved the cross-cutting area of human performance, the component of work practices, and the aspect of human error prevention, H.4(a) because the licensee failed to utilize the human performance tool of self-checking when completing the calibration of comparator card PC-2402 C1-245. |
| Site: | North Anna  |
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| Report | IR 05000338/2011005 Section 1R22 |
| Date counted | Dec 31, 2011 (2011Q4) |
| Type: | NCV: Green |
| cornerstone | Initiating Events |
| Identified by: | Self-revealing |
| Inspection Procedure: | IP 71111.22 |
| Inspectors (proximate) | E Lea G Kolcum G Mccoy L Lake M Yoo R Clagg |
| CCA | H.12, Avoid Complacency |
| INPO aspect | QA.4 |
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Finding - North Anna - IR 05000338/2011005 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (North Anna) @ 2011Q4
Self-Identified List (North Anna)
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