05000416/FIN-2012003-04
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Finding | |
|---|---|
| Title | Failure to Implement a Surveillance Requirement to Assure that the Limiting Condition for Operation Will be Met |
| Description | The inspectors identified a non-cited violation of 10 CFR Part 50.36, Technical Specifications, involving the failure to implement a surveillance requirement to assure that the limiting conditions for operation of the ultimate heat sink will be met. Technical Specifications requires two cooling towers and two cooling basins, with the volume of the two basins constituting the entire inventory of the ultimate heat sink. Therefore, an interconnecting siphon line is installed to transfer water between the two cooling tower basins. That siphon line has the safety-related function of ensuring the availability of enough cooling water to satisfy ultimate heat sink requirements. Technical Specification 3.7.1 includes Surveillance Requirement 3.7.1.1, which verifies the water level in each cooling tower basin every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and Surveillance Requirement 3.7.1.2, which verifies each cooling tower fan every 31 days. However, the inspectors identified that Technical Specification 3.7.1 does not include a surveillance requirement to verify that the interconnecting siphon line will perform its safety-related function. On May 20, 2012, the licensee performed an operability test for the siphon line and determined that it was operable. The licensee is currently performing a preventative maintenance task as a compensatory action to ensure operability of the siphon line until a license amendment can be submitted to the NRC that establishes a surveillance requirement. The licensee documented this violation in Condition Reports CR-GGN-2012-08257 and CR-GGN-2012-08537. The violation is more than minor because it is associated with the design control attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, without a surveillance requirement that verifies the interconnecting siphon line can perform its safety-related function, the licensee cannot ensure that sufficient cooling water is available following an accident. The inspectors evaluated the finding using Inspection Manual Chapter (IMC) 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings and determined that the finding was of very low safety significance (Green) because the finding was a design or qualification deficiency confirmed not to result in a loss of operability or function; did not represent a loss of safety system function; did not represent actual loss of safety function of a single train for greater than its technical specification allowed outage time; 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 in the human performance area associated with the resources component because the licensee did not ensure that equipment was adequate to assure nuclear safety, in that the licensee had recently reviewed documentation associated with a modification to the siphon line but failed to identify that operability of the UHS could not be established without a technical specification surveillance requirement to ensure operability of the siphon line. |
| Site: | Grand Gulf  |
|---|---|
| Report | IR 05000416/2012003 Section 1R19 |
| Date counted | Jun 30, 2012 (2012Q2) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.19 |
| Inspectors (proximate) | R Smith A Barrett J Laughlin V Gaddy G Apger A Fairbanks B Rice J Braisted R Kumana |
| CCA | H.7, Documentation |
| INPO aspect | WP.3 |
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Finding - Grand Gulf - IR 05000416/2012003 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Grand Gulf) @ 2012Q2
Self-Identified List (Grand Gulf)
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