05000461/FIN-2009003-01
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Finding | |
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Title | Failure to Evaluate Safety Function of Suppression Pool Makeup System |
Description | The inspectors identified a finding of very low safety significance associated with the licensees failure to recognize a potential loss of safety function for the suppression pool makeup system following the loss of upper containment pool inventory when spent fuel pool cooling system flow control valve 1FC004A failed closed. No evaluation was performed to ensure that the suppression pool makeup systems safety function would be fulfilled with less than Technical Specification (TS) minimum containment upper pool level. The licensee subsequently performed an evaluation and determined that sufficient margin existed such that the system would have been able to fulfill its safety function with limited margin. Corrective actions to address the inadequate reportability review included training for licensed senior reactor operators and development of a formal operability/reportability review process template. No violation of regulatory requirements was identified. The finding would become a more significant safety concern if left uncorrected and was therefore, more than a minor concern. Specifically, the failure to correctly recognize and evaluate a potential loss of a safety function of systems, structures, and components when performing operability or past operability evaluations could reasonably result in an unrecognized condition of a system failing to fulfill its safety-related function. Because the suppression pool makeup system was primarily associated with long-term decay heat removal following certain design basis accidents, the inspectors concluded that this issue was associated with the Mitigating Systems Cornerstone. The finding was of very low safety significance because the issue: (1) was not a design or qualification deficiency; (2) did not represent an actual loss of safety function of a system; (3) did not represent an actual loss of safety function of a single train for greater than its TS allowed outage time; (4) did not represent an actual loss of safety function of one or more non-TS trains of equipment designated as risk significant; and (5) did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The inspectors concluded that this finding affected the cross-cutting area of human performance because the licensee did not have a formal process in place with adequate guidance and training to enable licensed senior reactor operators, whose responsibility it was to evaluate a potential loss of safety function, to correctly do so. As a result, senior reactor operators did not adequately review the TS Bases to understand and evaluate whether the system was able to fulfill its safety function. (IMC 0305 H.1(a) |
Site: | Clinton |
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Report | IR 05000461/2009003 Section 1R15 |
Date counted | Jun 30, 2009 (2009Q2) |
Type: | Finding: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.15 |
Inspectors (proximate) | J Draper M Mitchell M Ring S Mischke A Scarbeary B Kemker C Brown D Lords D Reeserb Kemkerc Brown D Lords D Szwarc J Bozga J Cassidy M Ring R Orlikowski S Bell S Mischke |
CCA | H.13, Consistent Process |
INPO aspect | DM.1 |
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Finding - Clinton - IR 05000461/2009003 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Clinton) @ 2009Q2
Self-Identified List (Clinton)
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