05000341/FIN-2012002-01
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Finding | |
|---|---|
| Title | Licensee-Identified Violation |
| Description | TS 5.4.1 requires the licensee to establish, implement, and maintain applicable written procedures for the safety-related systems and activities recommended in Regulatory Guide 1.33, Revision 2, Appendix A. Section 9.a, Procedures for Performing Maintenance, of Regulatory Guide 1.33, Revision 2, Appendix A, further states, in part, that: Maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. Revision 20 of the licensees Work Conduct Manual, MWC10, Work Package Preparation, describes requirements for configuration control. Step 4.10.2.3.e states, Upon completion of the maintenance activity or prior to completing the work package (work activity), all temporary alterations shall be removed and the equipment/SSCs shall be returned to the As-Designed condition. Contrary to the above, on February 22, 2012, the licensee failed to properly restore the configuration of Division 1 H2O2 sample pump following maintenance. Specifically, the pump discharge tubing hoses were left unconnected causing the system to trip when it was attempted to be restarted. The inspectors reviewed this issue using the guidance contained in Appendix B, Issue Screening, of Inspection Manual Chapter 0612, Power Reactor Inspection Reports. The inspectors determined the violation was more than minor because it was associated with the Barrier Integrity Cornerstone attribute of Configuration Control and affected the cornerstone objective of providing reasonable assurance that physical design barriers (containment) protect the public from radionuclide releases caused by accidents or events. Specifically, the as-found condition of the H2O2 sample pump discharge tubing potentially introduced a leakage path from the primary containment to the secondary containment. The inspectors evaluated the finding using IMC 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings, using the Phase 1 Significance Determination Process worksheet for the Barrier Integrity Cornerstone. The finding screened as very low safety significance (Green) because the inspectors answered No to the screening questions under the Containment Barrier column of Table 4a. Specifically, because maintenance had installed Swagelok fittings on the ends of the discharge tubing, an actual open pathway in the physical integrity of the primary containment did not exist. The licensee had entered this issue into their corrective action program as CARD 12 21428. A local leak rate test was performed for the as-found condition which measured the leakage at 28.1 scfh (standard cubic feet per hour), which added a small amount to the existing primary containment total leakage rate (70.44 scfh). The total leakage rate remained below the TS 3.6.1.1 limit of La (296.3 scfh). |
| Site: | Fermi  |
|---|---|
| Report | IR 05000341/2012002 Section 4OA7 |
| Date counted | Mar 31, 2012 (2012Q1) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | Licensee-identified |
| Inspection Procedure: | |
| Inspectors (proximate) | A Dahbur T Bilik M Mitchell R Morris A Wilson R Jones J Cameron P Smagacz S Bell |
| INPO aspect | |
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Finding - Fermi - IR 05000341/2012002 | |||||||||||||||||||||||||||||||||||||||||
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Finding List (Fermi) @ 2012Q1
Self-Identified List (Fermi)
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