05000416/FIN-2013004-01
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Finding | |
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| Title | Failure to Follow Procedure Results in Inadequate Operability Determination |
| Description | The inspectors identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, regarding the licensees failure to follow the requirements of Procedure EN-OP-104, Operability Determinations. Specifically, the inspectors identified that the licensee failed to establish an adequate basis for operability when a degraded or nonconforming condition had been identified. On August 30, 2013, Condition Report CR-GGN-2013-05604 was initiated to document a step change in the standby service water (SSW) siphon line K factor, which is a measure of flow through the siphon line. The K factor could have increased due to air entrapment in the siphon line that resulted from using air to mix the basin water following chemical treatments. The inspectors challenged the validity of the evaluation because the second step change in K factor, from 48 to 64, represented new information that had not been evaluated in the previous condition report. As an immediate corrective action, the licensee re-performed the operability determination and provided an adequate basis of operability by evaluating the system with the additional K factor data. Furthermore, the licensee verified the siphon line did not have any obstructions by observing the SSW basin levels equalize as water flowed through the siphon line. The licensee entered this issue into the corrective action process under Condition Report CR-GGN-2013-05687. The failure to perform an operability determination in accordance with procedure was a performance deficiency. The performance deficiency was more than minor, and is therefore a finding, because it is associated with the equipment performance attribute of the Mitigating Systems Cornerstone and adversely impacted the cornerstone objective of ensuring the reliability, availability and capability of systems that respond to initiating events to prevent undesirable consequences. Using NRC Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, the inspectors determined that the issue affected the Mitigating Systems Cornerstone. In accordance with NRC Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings at Power, the inspectors determined that the issue has very low safety significance (Green) because all applicable screening questions in Manual Chapter 0609, Appendix A, Exhibit 2, were answered no. The inspectors determined that the apparent cause of this finding was that the licensee had identified and used previously completed operability evaluations without verifying that the previously completed evaluations were fully applicable to the identified conditions. Therefore, the finding had a cross-cutting aspect in the problem identification and resolution area, corrective action program component because the licensee failed to properly evaluate for operability conditions adverse to quality. |
| Site: | Grand Gulf  |
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| Report | IR 05000416/2013004 Section 1R15 |
| Date counted | Sep 30, 2013 (2013Q3) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.15 |
| Inspectors (proximate) | J O'Donnell L Carson L Ricketson N Greene N Okonkwo P Elkmann R Kahler R Smith A Allen B Cecere B Rice G Guerra G Pick J Braisted |
| Violation of: | 10 CFR 50 Appendix B Criterion V |
| CCA | P.2, Evaluation |
| INPO aspect | PI.2 |
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Finding - Grand Gulf - IR 05000416/2013004 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Grand Gulf) @ 2013Q3
Self-Identified List (Grand Gulf)
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