05000348/FIN-2011010-01
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Finding | |
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| Title | Failure to Implement Design Control Measures to Verify the Adequacy of CST Design |
| Description | The team identified a non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion III, \\\"Design Control,\\\" (with two examples) for the licensee's failure to implement design control measures to verify the adequacy of design inputs, assumptions, or limiting plant conditions which were relied upon in the design basis analyses used to demonstrate the adequacy of Condensate Storage Tank (CST) design. The licensee entered these issues into their Corrective Action Program (CAP) as Condition Reports (CRs) 355226, 355293, and 355294. The licensee performed operability evaluations in support of current operability and implemented additional compensatory measures to ensure that CST level would be maintained above the condenser hotwell make-up elevation pending completion of proposed long term corrective actions which included a license amendment request to increase the minimum volume of water specified by the limiting condition for operation in Technical Specification (TS) 3.7.6. The failure to utilize conservative design inputs, assumptions, or limiting plant conditions when implementing design control measures to verify the adequacy of CST design was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the mitigating systems cornerstone attribute of design control and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the finding challenged the assurance that the CST contained an adequate volume of water to support its safety function to supply condensate to the Auxiliary Feedwater (AFW) system in response to design basis events. In accordance with NRC IMC 0609.04, \\\"Initial Screening and Characterization of Findings,\\\" the team used the mitigating systems column to perform a Phase 1 Significance Determination Process (SDP) screening and determined the finding to be of very low safety significance (Green) because it was not a design issue resulting in loss of function, did not represent an actual loss of a system safety function, did not result in exceeding a TS allowed outage time, and did not affect external event mitigation. This analysis was based on information contained in licensee operability determinations which demonstrated that, although the TS required minimum volume of 150,000 gallons was non-conservative, reasonable assurance existed such that the volume of CST water below the condenser hotwell make-up elevation was sufficient for the tank to perform its safety function. A cross-cutting aspect was not identified because the design basis calculation associated with the finding was approved on March 25, 1999, and did not represent current licensee performance. [Section 1R21.2.3] |
| Site: | Farley  |
|---|---|
| Report | IR 05000348/2011010 Section 1R21 |
| Date counted | Dec 31, 2011 (2011Q4) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.21 |
| Inspectors (proximate) | D Jones M Shlyamberg S Sandal R Nease J Eargle P Wagner |
| INPO aspect | |
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Finding - Farley - IR 05000348/2011010 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Farley) @ 2011Q4
Self-Identified List (Farley)
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