05000416/FIN-2016007-01
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Finding | |
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| Title | Inadequate Technical Specification Surveillance Requirements for Reactor Protection System |
| Description | The team identified a Green non-cited violation of 10 CFR 50.36, Technical Specifications, which requires that surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met. Contrary to this requirement, from June 24, 2014, until November 3, 2016, the licensee failed to include in its technical specification a surveillance requirement to assure that the facility operation will be within safety limits. Specifically, after modifying its reactor protection system to remove turbine first stage pressure instrumentation, the licensee failed to adjust the interval at which it calibrates the average power range monitor channels during surveillance tests to ensure the signals were accurately indicating the true core average power and that reactor protection system trips were enabled when required to assure the facility will be within safety limits. The licensees failure to ensure surveillance requirements relating to calibration to ... assure that ... facility operation will be within safety limits, and that the limiting conditions for operation will be met was a performance deficiency. In response to this issue, the licensee implemented compensatory actions to ensure the reactor protection system trips would be enabled when required, and documented the condition in its corrective action program as Condition Report CR-GGN-2016-08297. This performance deficiency was more-than-minor because it was associated with the thermal limit design control attribute of the Barrier Integrity Cornerstone objective to provide reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and containment) protect the public from radionuclide releases caused by accidents or events. Specifically, the surveillance requirements did not assure calibration of the average power range monitors to ensure an accurate measurement of reactor power such that the reactor protection system trips were enabled at 35.4 percent power. In accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At- Power, dated June 19, 2012, Exhibit 2, Mitigating Systems Screening Questions, the issue screened as having very low safety significance (Green) because it was a design or qualification deficiency that did not represent a loss of operability or functionality; did not represent an actual loss of safety function of the system or train; did not result in the loss of one or more trains of non-technical specification equipment; and did not screen as potentially risk significant due to seismic, flooding, or severe weather. This finding had a cross-cutting aspect in the area of human performance associated with change management because the licensee failed to use a systematic process for evaluating and implementing changes to the reactor protection system so that nuclear safety remains the overriding priority [H.3]. |
| Site: | Grand Gulf  |
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| Report | IR 05000416/2016007 Section 1R17 |
| Date counted | Dec 31, 2016 (2016Q4) |
| Type: | NCV: Green |
| cornerstone | Barrier Integrity |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.17 |
| Inspectors (proximate) | C Smith C Stott J Watkins T Farnholtz |
| Violation of: | 10 CFR 50.36 |
| CCA | H.3, Change Management |
| INPO aspect | LA.5 |
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Finding - Grand Gulf - IR 05000416/2016007 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Grand Gulf) @ 2016Q4
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