05000416/FIN-2012008-04
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Finding | |
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Title | Failure to Promptly Enter an NRC Violation Regarding the Standby Service Water System into the Corrective Action Program |
Description | The team identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, which states, in part, that Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformance are promptly identified and corrected. Specifically, on July 12, 2012, the NRC informed the licensee of a violation of 10 CFR 50.59 requirements, but the licensee failed to promptly identify this as an adverse condition and enter this condition into their corrective action program until July 19, 2012. The finding was entered into the licensee's corrective action program as CR-GGN-2012-10075. The team determined that the licensee's failure to promptly enter the NRC violation as condition adverse to quality into the corrective action program was a performance deficiency. This finding was more than minor because it adversely affected the design control attribute of the Mitigating Systems Cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to promptly document a violation of 10 CFR 50.59, which delayed an operability evaluation that ultimately determined that compensatory measures were required to ensure that the standby service water system could perform its specified safety function for its entire mission time. Using the Inspection Manual Chapter 0609, Appendix A, 'The Significance Determination Process for Findings At-Power, the team determined that the finding represented a loss of system safety function in that the standby service water system could not meet its 30-day mission time to provide decay heat removal. Therefore, a Detailed Risk Evaluation was necessary. In accordance with Manual analyst evaluated the risk of the degraded condition that resulted from the finding. According to the Risk Assessment of Operational Events Handbook Volume 1 - Internal Events, Section 4.1, Mission Time Modeling, in most events, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is sufficient time to bring numerous resources to bear on core cooling. In some events, the choice is conservative and the analysis results are overestimates. Additionally, the analyst determined that Section 4.2 on increasing mission time was not applicable to the subject finding because the decrease in standby service water system water inventory would be obvious and there would be days to respond with makeup sources. Therefore, the analyst determined that the finding was of very low safety significance (Green) because, although the standby service water system could not provide 30 days of decay heat removal without operator action to provide makeup water to the system, it would have been able to complete its 24-hour risk significant mission time. This finding had a crosscutting aspect in the area of problem identification and resolution, corrective action program component, because the licensee failed to ensure that issues potentially impacting nuclear safety are promptly identified, fully evaluated, and that actions are taken to address safety issues, in a timely manner, commensurate with their safety significance. Specifically, the licensee did not implement a corrective action program with a low threshold for identifying issues completely, accurately, and in a timely manner commensurate with their safety significance. |
Site: | Grand Gulf |
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Report | IR 05000416/2012008 Section 1R21 |
Date counted | Sep 30, 2012 (2012Q3) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.21 |
Inspectors (proximate) | I Anchondo N Okonkwo J Braisted |
CCA | P.1, Identification |
INPO aspect | PI.1 |
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Finding - Grand Gulf - IR 05000416/2012008 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Grand Gulf) @ 2012Q3
Self-Identified List (Grand Gulf)
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