05000387/FIN-2014004-03
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Finding | |
|---|---|
| Title | Adequacy of Secondary Containment and Standby Gas Treatment System Testing |
| Description | The NRC communicated the results of NRRs TIA on this subject by a memorandum dated May 6, 2014 (ADAMS ML14085A411). Subsequently, PPL initiated CR-1256036 to evaluate the need to change the affected TS SRs. In addition, PPL implemented the guidance provided in NRC Administrative Letter (AL) 98-10, Dispositioning of Technical Specifications that are Insufficient to Assure Plant Safety, which includes taking actions (e.g., compensatory measures, appropriate SGTS testing) during the interim. As stated in NRC Inspection 05000387&388/2012007, PPL implemented several actions to provide reasonable assurance that the secondary containment and the SGTS were capable of performing their intended functions including a temporary system modification to align all three zones of ventilation to the SGTS if either unit received an accident signal. PPLs interim actions ensured that the safety function of secondary containment would be maintained. The inspectors determined there was no performance deficiency because the issue of concern was not reasonably within PPLs ability to foresee and correct in that the NRC had explicitly approved the secondary containment testing methodology, which the station had been applying in compliance with TSs. Accordingly, NRC IMC 0612, Appendix B, Issue Screening, directs disposition of this issue using traditional enforcement in accordance with the Enforcement Policy. The inspectors used Enforcement Policy, Section 6.1.d.1, Reactor Operations, to evaluate the significance of this violation, and concluded that the violation was more than minor and best characterized as a Severity Level IV violation in that the issue was associated with allowances for surveillance requirements in Section 3.0 of TSs. In reaching this conclusion, the inspectors considered that the underlying technical finding would have been evaluated as having very low safety significance (i.e., Green) under the Reactor Oversight Process using NRC IMC 0609, Appendix A, Exhibit 3, Barrier Integrity Screening Questions, dated June 19, 2012, since the issue was only associated with the radiological barrier function of the auxiliary building and SGTS. 10 CFR 50.36(c)(3), Surveillance Requirements, requires, in part, that surveillance requirements related to testing assure that the necessary quality of systems and components are maintained and that the limiting conditions for operation will be met. Contrary to the above, from March 1984 to the present, the existing text for TS SRs 3.6.4.1.4 and 3.6.4.1.5 did not adequately demonstrate: (1) the quality of the secondary containment: and (2) that the LCOs were met. |
| Site: | Susquehanna  |
|---|---|
| Report | IR 05000387/2014004 Section 4OA3 |
| Date counted | Sep 30, 2014 (2014Q3) |
| Type: | Violation: Severity level Enforcement Discretion |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71153 |
| Inspectors (proximate) | C Graves E Burket F Bower J Cherubini J Greives T Daun |
| Violation of: | 10 CFR 50.36 Technical Specification |
| INPO aspect | |
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Finding - Susquehanna - IR 05000387/2014004 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Susquehanna) @ 2014Q3
Self-Identified List (Susquehanna)
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