05000456/FIN-2015001-04
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Finding | |
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Title | Licensee-Identified Violation |
Description | On February 19, 2014, the licensee identified that Braidwood Station had not complied with TS 3.4.3, RCS Pressure and Temperature Limits, between March 2011 and October 2013, during startup of the plant following plant refueling outages. Braidwood TS 3.4.3 stated, RCS pressure, RCS temperature, and RCS heat up and cooldown rates shall be maintained within the limits specified in the PTLR (Pressure Temperature Limits Report.) The PTLR is generated by Westinghouse and contains graphs depicting the acceptable operating ranges of RCS pressure and temperature supported by the analysis. The lower bound of these graphs was 0 pounds per square inch gauge (psig). Braidwood Procedure BwOP RC-9 was used by the station to fill the loops. This procedure allowed RCS piping pressure to go as low as 28 inches of mercury (or about14 psig) which was below the lower limit of the PTLR acceptable region. At the licensees request, Westinghouse performed the additional analysis needed to expand the lower value of the curves and determined that the lower bounding parameter could be revised to14.7 psig with no impact to RCS barriers. The analysis was subsequently revised and the PTLR was revised to designate the lower boundary accordingly. Title 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality be prescribed by procedures appropriate to the circumstances. Contrary to the above, from March 2011 through October 2013, BwOP RC-9 allowed RCS pressures to be lower than the analyzed bound of the parameter inputs of the PTLR graphs and, as a result, was not appropriate to the circumstances. The finding was more than minor because it impacted the Procedural Quality attribute of the Barrier Integrity Cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that the RCS design barrier would function to protect the public from radionuclide release caused by accidents or events. Given the analytical conclusions that the condition was acceptable with the new lower bounding parameter, the inspectors determined that the issue was of very low safety significance (Green). The licensee entered this issue into their CAP as IR 1625970 and corrective actions consisted of updating the PTLR. |
Site: | Braidwood ![]() |
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Report | IR 05000456/2015001 Section 4OA7 |
Date counted | Mar 31, 2015 (2015Q1) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | Licensee-identified |
Inspection Procedure: | |
Inspectors (proximate) | B Boston D Betancourt E Duncan J Benjamin M Garza R Edwards T Go |
Violation of: | 10 CFR 50 Appendix B Criterion V Technical Specification Technical Specification - Procedures |
INPO aspect | |
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Finding - Braidwood - IR 05000456/2015001 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Braidwood) @ 2015Q1
Self-Identified List (Braidwood)
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