05000341/FIN-2016007-11

Finding

Title

Failure to Apply Design Control Measures to a Design Change Associated with NIAS Accumulator Capability

Description

The team identified a finding of very low safety significance (Green), and an associated NCV of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to apply design control measures to a design change associated with NIAS accumulator capacity. Specifically, the licensee did not verify that the reduced accumulator capacity was adequate during the entire time period that the compressor is expected to not be running, and ensure that operability limits and calibration tolerances contained in procedures were consistent with the new design. The licensee captured this issue in their CAP as CARD 16-26208, CARD 16-26561, and CARD 16-26607, and reasonably concluded that NIAS remained functional. The performance deficiency was determined to be more-than-minor because it was associated with the Mitigating Systems cornerstone attribute of equipment performance and affected the cornerstone objective of ensuring the availability, reliability, and capability of mitigating systems to respond to initiating events to prevent undesirable consequences. In addition, it was associated with the Barrier Integrity cornerstone attribute of SSC and barrier performance and affected the cornerstone objective of providing reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. The finding screened as of very-low safety significance (Green) because it did not result in the loss of operability or functionality of mitigating systems. Specifically, the licensee performed a bounding assessment that reasonably determined that the accumulator would maintain adequate pneumatic supply. In addition, with respect to the Barrier Integrity cornerstone, the finding only represented a potential degradation of the control room and standby gas ventilation systems. The team determined that the associated finding had a cross-cutting aspect in the area of Human Performance because the licensee did not carefully guarded margins and changed them only through a systematic and rigorous process. Specifically, the licensee failed to review and identify all of the design attributes associated with NIAS system before significantly reducing the accumulator capacity design margin in February 2016.

11
Site:	Fermi
Report	IR 05000341/2016007 Section 1R21
Date counted	Sep 30, 2016 (2016Q3)
Type:	NCV: Green
cornerstone	Mitigating Systems
Identified by:	NRC identified
Inspection Procedure:	IP 71111.21
Inspectors (proximate)	B Jose G Gardner G Nicely J Benjamin M Jeffers N Feliz-Adorno N Valos R Baker R Fernandes V Petrella
Violation of:	10 CFR 50 Appendix B 10 CFR 50 Appendix B Criterion III, Design Control
CCA	H.6, Design Margins
INPO aspect	WP.2
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v • d • e

Finding - Fermi - IR 05000341/2016007

8(0)1(12)2(7)3(3)4(6)5(0)6(0)7(16)201(1)403(0)404(0)405(0)406(1)502(0)

IR 05000341/2016007: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16

Finding List (Fermi) @ 2016Q3

CCA Matrix: 2016Q3

	Q	CCA	Title
05000341/FIN-2015004-01	2015Q4	H.12	Failure to Satisfy Technical Specification Requirements During an Unplanned Operation with the Potential to Drain the Reactor Vessel
05000341/FIN-2015007-01	2015Q4	P.2	Failure to Comply with ASME B30.16 for Planned Engineered Lifts
05000341/FIN-2015403-01	2015Q4		Security
05000341/FIN-2016001-04	2016Q1	P.4	Failure to Incorporate Operating Experience into Preventive Maintenance Activities Associated with the TBCCW System
05000341/FIN-2016001-09	2016Q1	H.1	Inadvertent Reactor Water Low Level Reactor Protection System Actuation Due to Operator Error
05000341/FIN-2016001-08	2016Q1		Failure to Follow Apparent Cause Evaluation Procedure
05000341/FIN-2016001-07	2016Q1		Inadequate Test Criteria in SGTS Flow/Heater Operability Surveillance Test
05000341/FIN-2016001-06	2016Q1		Failure to Translate Design Requirements of the RHRHVAC System into Procedures
05000341/FIN-2016001-02	2016Q1	H.14	Failure to Correctly Interpret and Implement TS Requirements for RPS Trip Functions
05000341/FIN-2016001-01	2016Q1		Failure of the Plant-Referenced Simulator to Demonstrate Expected Plant Response for Safety Relief Valves
05000341/FIN-2016001-03	2016Q1		Failure to Satisfy 10 CFR 50.72 and 10 CFR 50.73 Reporting Requirements for Loss of RPS Trip Safety Functions
05000341/FIN-2016001-05	2016Q1		Failure to Satisfy 10 CFR 50.73 Reporting Requirements for a Condition Prohibited by the Plants Technical Specifications
05000341/FIN-2016001-10	2016Q1		Failure to Satisfy 10 CFR 50.72 and 10 CFR 50.73 Reporting Requirements for Primary Containment Isolation Valve Actuations
05000341/FIN-2016002-05	2016Q2		Failure to Use Correct Material in a Feedwater Heater Level Control Valve Resulted in a Loss of Feedwater Heater Drains and a Reactor Recirculation System Runback
05000341/FIN-2016002-03	2016Q2	H.9	Loss of Power Instrumentation TS 3.3.8.1 Applicability Following Bus 64C Potential Transformer Fuse Failures
05000341/FIN-2016002-01	2016Q2	H.12	Failure to Control Combustible Materials
05000341/FIN-2016406-01	2016Q2	H.13	Security
05000341/FIN-2016201-01	2016Q2		Security
05000341/FIN-2016002-02	2016Q2		Inadequate Test Procedure Used for Measuring and Determining Average Silt Levels in the Service Water Reservoir
05000341/FIN-2016002-04	2016Q2	P.2	Failure to Control the Work Hours of Covered Workers
05000341/FIN-2016002-06	2016Q2		Failure to Implement Adequate Preventive Maintenance on Spare Terminals in Safety-Related Motor Control Centers
05000341/FIN-2016003-02	2016Q3		Fluctuating Background Effect on Accident Range Noble Gas Monitor
05000341/FIN-2016007-02	2016Q3	P.6	Failure to Verify the Adequacy of the Voltage Supplied to Transformer #64 Load Tap Changer
05000341/FIN-2016007-07	2016Q3	P.6	Failure to Ensure that Protective Devices for the Loads Required at the Beginning of a LOCA Would Not Trip Under Degraded Voltage Conditions
05000341/FIN-2016007-13	2016Q3	P.2	Failure to Identify a CAQ Associated with Over-Dutied 480V Safety-Related Switchgear Breakers
05000341/FIN-2016003-01	2016Q3	P.2	Failure to Perform an Operability Determination for Division 1 RPV Reference Leg Backfill System Not Providing Adequate Flow
05000341/FIN-2016007-01	2016Q3		Inadequate Procedure for Addressing Non-Functional MDCT Fan Motor Brake System
05000341/FIN-2016003-03	2016Q3	H.8	Failure to Follow Procedures During Concrete Placement of Flexible Storage Facility Buildings
05000341/FIN-2016007-16	2016Q3	H.13	Failure to Timely Identify, Document, and Evaluate Conditions that Challenge Operability
05000341/FIN-2016007-15	2016Q3	H.14	Failure to Identify that a Non-Conservative Min-K Insulation Volume Calculation Error Was Nonconforming to the ECCS Suction Strainer Licensing Basis
05000341/FIN-2016007-14	2016Q3		Failure to Identify that an Inadequate Minimum MSIV Accumulator Air Pressure Setpoint Was CAQ
05000341/FIN-2016007-12	2016Q3	H.4	Failure to Identify an Out-of-Specification Pressure Reading on the Nitrogen Supply to the A MDCT Fan Motor Brake System
05000341/FIN-2016007-11	2016Q3	H.6	Failure to Apply Design Control Measures to a Design Change Associated with NIAS Accumulator Capability
05000341/FIN-2016007-10	2016Q3		Non Conservative ECCS Suction Strainer Min-K Combined Generation and Transport Factors
05000341/FIN-2016007-09	2016Q3		Failure to Evaluate the Acceptability of Drywell Coatings with Respect to Potential ECCS Suction Strainer Blockage
05000341/FIN-2016007-08	2016Q3		Inadequate Containment Debris Inspections Acceptance Criteria
05000341/FIN-2016007-06	2016Q3		Failure to Ensure that the MSIVs Would Close Within the TS Required Timeframe and as Described in the UFSAR
05000341/FIN-2016007-05	2016Q3		Failure to Leak Test All Division 2 NIAS Boundary Isolation Valves
05000341/FIN-2016007-04	2016Q3		Failure to Periodically Test the EDG Capability to Start and Accelerate All of the Sequenced Loads Within the Applicable Limits
05000341/FIN-2016007-03	2016Q3	H.4	Failure to Verify the Ability to Manually Throttle Safety-Related MOVs during a DBA

Self-Identified List (Fermi)

	Q	Title
05000341/FIN-2015004-02	2015Q4	Licensee-Identified Violation
05000341/FIN-2016001-11	2016Q1	Licensee-Identified Violation
05000341/FIN-2016001-12	2016Q1	Licensee-Identified Violation
05000341/FIN-2016002-07	2016Q2	Licensee-Identified Violation

[Fermi Findings full list]

05000341/FIN-2016007-11

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