05000361/FIN-2011002-03
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Finding | |
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Title | Failure to Comply with Technical Specifications |
Description | The inspectors identified a noncited violation of Technical Specification 3.5.4, Refueling Water Storage Tank, for the failure of licensee personnel to comply with the technical specification. Specifically, the licensee did not enter the appropriate technical specification for an inoperable refueling water storage tank when it was potentially not capable of performing its specified safety function while aligned to the non-seismic spent fuel pool cooling and purification system for cleanup. On October 8, 2010, operations personnel placed administrative controls on system isolation valves to prevent the refueling water storage tank from being aligned to non-seismic systems. This issue was entered into the licensees corrective action program as Nuclear Notifications NN 201133936 and NN 201135761. The performance deficiency was determined to be more than minor and is therefore a finding because it is associated with the design control attribute of the Mitigating Systems Cornerstone and affects the associated cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using the NRC Inspection Manual 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings, the inspectors determined that a Phase 2 evaluation was required because the finding involved the potential loss of a safety function. A Phase 2 significance determination was performed using the pre-solved worksheet from the Risk Informed Inspection Notebook for the San Onofre Nuclear Generating Station, Revision 2.01a. Assuming both trains of high pressure injection were inoperable, the finding was Yellow, which warranted further review. Therefore, the analyst performed a bounding Phase 3 significance determination. Based on the licensees PRA calculation, consultation with licensee PRA personnel, and an understanding of the bounding and conservative assumptions incorporated in the analysis, the analyst determined that the licensees delta-CDF result of 7.6E-7/yr was clearly bounding, that the large early release frequency was negligible, and that the significance of the issue was very low. Since the apparent root cause determined the cause was due to weaknesses in the design change processes early in plant operations (between 1982 and 1995), and the licensees program has improved with respect to performing design changes, the inspectors determined that this finding was not reflective of current performance and therefore did not have a crosscutting aspect |
Site: | San Onofre |
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Report | IR 05000361/2011002 Section 1R15 |
Date counted | Mar 31, 2011 (2011Q1) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.15 |
Inspectors (proximate) | M Young R Kellar G Tutak B Hagar Z Hollcraft P Elkman G Guerra R Lantz S Garchow J Reynoso G Warnick C Osterholtz |
INPO aspect | |
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Finding - San Onofre - IR 05000361/2011002 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (San Onofre) @ 2011Q1
Self-Identified List (San Onofre)
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