05000461/FIN-2012002-02
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Finding | |
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Title | Unacceptable Preconditioning of LOW Pressure Coolant Injection from Residual Heat Removal a Check Valve Prior to Leak Rate Test Measurement |
Description | The inspectors identified a finding of very low safety significance with an associated non-cited violation of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings. The licensee failed to establish an adequate procedure to perform required leak rate testing for the Low Pressure Coolant Injection from Residual Heat Removal A Check Valve. Specifically, the surveillance test procedure resulted in unacceptable preconditioning of the valve prior to a leak rate test measurement due to improper test sequencing. In addition, the licensee failed to correctly evaluate a failed leak rate test of the valve. The licensee entered this issue into its corrective action program for evaluation and initiated corrective actions to revise the test procedure and train engineering personnel. The finding was of more than minor significance since it was associated with the Procedure Quality attribute for the containment and adversely affected the Barrier Integrity Cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Because the preconditioning altered the as-found condition of the check valve, the data collected through the performance of the surveillance test was not fully indicative of the true valve performance trend. Additionally, the licensees failure to correctly evaluate the initial failed leak rate test would become a more significant safety concern if left uncorrected because it could reasonably result in an unrecognized condition with a check valve failing to fulfill a safety-related function. Therefore, this performance deficiency had a direct effect on the licensees ability to fully assess the past operability, as well as the ability to trend as-found data for the purpose of assessing the reliability of the check valve. The finding was a licensee performance deficiency of very low safety significance because it would not result in exceeding the Technical Specification limit for reactor coolant system leakage and would not have likely affected mitigation systems resulting in a loss of safety function. In addition, the finding did not represent an actual open pathway in the physical integrity of the reactor containment. Based on consultation and review with the Regional Senior Reactor Analyst, the inspectors concluded that the finding did not result in an increase in the likelihood of an initiating event such as an inter-system loss-of-coolant accident or a containment bypass event because the redundant isolation valve and closed loop system piping passed leak rate measurement testing during the refueling outage with considerable margin. The inspectors concluded that this finding affected the cross-cutting area of human performance. Specifically, the licensee did not have adequately trained and knowledgeable personnel available to correctly evaluate the cause of the initial failed leak rate measurement test and to ensure that appropriate actions to correct the test sequence in the procedure were identified |
Site: | Clinton |
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Report | IR 05000461/2012002 Section 1R12 |
Date counted | Mar 31, 2012 (2012Q1) |
Type: | NCV: Green |
cornerstone | Barrier Integrity |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.12 |
Inspectors (proximate) | B Kemker C Brown D Lords D Szwarc J Bozga J Cassidy M Ring R Orlikowski S Bell S Mischke |
CCA | H.9, Training |
INPO aspect | CL.4 |
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Finding - Clinton - IR 05000461/2012002 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Clinton) @ 2012Q1
Self-Identified List (Clinton)
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