05000387/FIN-2016004-05
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Finding | |
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Title | LERs Associated with Reactor Coolant Pressure Boundary Leakage |
Description | Enforcement. TS 3.4.4, "RCS" requires RCS leakage be limited to no pressure boundary leakage in Mode 1. Contrary to this, pressure boundary leakage from a LPRM instrument housing and from socket weld #8 occurred between plant start-up in December 2015 and plant shutdown on June 6, 2016, and existed while in Mode 1. The inspectors determined that these violations of TS 3.4.4 are more than minor, but not the result of performance deficiencies. Specifically, for the first event, though leakage likely existed during the previous refueling outage when personnel were performing unrelated maintenance and inspection activities, it was likely too small to reasonably identify and correct. Similarly, for the 2016 leak identified in weld #8, the leakage causes were not within Susquehannas ability to foresee as they had replaced the weld with the industry recommended 2 x 1 taper configuration and used qualified procedures and personnel. The Susquehanna staff had also measured the susceptibility of the attached piping for vibrational inputs. In accordance with the NRC Enforcement Policy guidance and IMC 0612, these violations are being treated under the traditional enforcement process and best characterized as a Severity Level (SL) IV (very low safety significance) violation, similar to example d.1 in NRC Enforcement Policy, Section 6.1, Reactor Operations. Although a performance deficiency was not identified, to verify that the issue was of very low safety significance, the inspectors considered risk insights obtained by using IMC 0609, SDP, Appendix A, Exhibit 1, Initiating Events Screening Questions. The inspectors determined that these TS violations would screen to Green (very low safety significance) because the boundary leakage would not have exceeded the leak rate for a small loss of coolant accident (LOCA) and would not affect any LOCA accident mitigating systems or components. Therefore, the inspectors considered that the SL IV characterization was appropriate. The licensee entered these issues into the Susquehannas CAP as CR-2016-14544 and CR-2016-14366. Because these issues are of very low safety significance, it has been determined that it was not reasonable for Susquehanna to be able to foresee and prevent, and as such no performance deficiencies exist. The NRC has decided to exercise enforcement discretion in accordance with Sections 2.2.4 and 3.5 of the NRC Enforcement Policy and refrain from issuing enforcement action for the violation of TS (EA-16-283). Further, because Susquehanna's actions did not contribute to this violation, it will not be considered in the assessment process or the NRC's Action Matrix. |
Site: | Susquehanna |
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Report | IR 05000387/2016004 Section 4OA3 |
Date counted | Dec 31, 2016 (2016Q4) |
Type: | NCV: Green |
cornerstone | Initiating Events |
Identified by: | NRC identified |
Inspection Procedure: | IP 71153 |
Inspectors (proximate) | B Smith D Schroeder E Gray J Deboer J Furia J Greives P Ott S Anderson T Daun |
Violation of: | Technical Specification - Procedures |
INPO aspect | |
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Finding - Susquehanna - IR 05000387/2016004 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Susquehanna) @ 2016Q4
Self-Identified List (Susquehanna)
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