05000400/FIN-2010005-03
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Finding | |
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Title | Failure to comply with the limiting conditions for operation, while the Refueling Water Storage Tank was aligned to the non-seismically qualified Fuel Pool Purification System |
Description | The inspectors identified a Green NCV of TS 3.1.2.6, Borated Water Sources, for the failure to comply with the limiting conditions for operation, while the Refueling Water Storage Tank (RWST) was aligned to the non-seismic Fuel Pool Purification system (FPPS) for purification, causing the RWST to be inoperable. Specifically, when FPPS was aligned to the RWST, the licensee did not declare the RWST inoperable. The licensee took corrective actions (AR #422180) and revised OP-116.1, FPPS, to remove the capability to purify the RWST in Modes 1 through 4. The failure to comply with the actions of TS Limiting Condition for Operation (LCO) 3.1.2.6 while the Refueling Water Storage Tank (RWST) was aligned to the nonseismic FPPS for purification on May 24, 2010, causing the RWST to be inoperable, was a performance deficiency. The performance deficiency was more than minor because it affected the Design Control attribute of the Mitigating System cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, when the FPPS was aligned to the RWST, the licensee did not declare the RWST inoperable. The inspectors evaluated the significance of this finding Using Attachment 4 of IMC 0609, the significance of this finding was determined to be of very low safety significance (Green) because it was a design or qualification deficiency confirmed not to result in loss of operability or functionality, did not represent a loss of system safety function, did not represent actual loss of safety function of a single train for longer than its TS Allowed Outage Time, did not represent an actual loss of safety function of one or more non-TS Trains of equipment designated as risk-significant, and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The finding had a cross-cutting aspect of Conservative Assumptions, as described in the Decision Making component of the Human Performance cross-cutting area because, assumptions used in the justification to support the procedure change (i.e. a license amendment was not deemed required to support the procedure change) to OP- 116.01 were non-conservative and the review of the issue in May 2010 did not adequately validate the assumptions (H.1(b)). |
Site: | Harris |
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Report | IR 05000400/2010005 Section 1R18 |
Date counted | Dec 31, 2010 (2010Q4) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.18 |
Inspectors (proximate) | R Kellner A Nielsen J Rivera-Ortiz R Hamilton W Loo J Austin M Bates S Walker R Musser D Mas-Penaranda M Coursey P Lessard J Eargle N Childs |
CCA | H.14, Conservative Bias |
INPO aspect | DM.2 |
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Finding - Harris - IR 05000400/2010005 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Harris) @ 2010Q4
Self-Identified List (Harris)
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