05000461/FIN-2012004-02
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Finding | |
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Title | Failure to Perform Adequate Past Operability Evaluations for Emergency Core Cooling System Relief Valves |
Description | The inspectors identified a finding of very low safety significance associated with the licensees failure to correctly evaluate the past operability of two emergency core cooling system (ECCS) relief valves that failed bench testing following replacement during the C1R13 refueling outage. No violation of regulatory requirements was identified because revised evaluations by the licensee determined that the valves would have satisfied their safety functions. The licensee entered this issue into its corrective action program for evaluation and initiated corrective actions to revise the past operability evaluations to correct gross errors in the original evaluations. The finding was of more than minor significance since the failure to correctly evaluate a degraded/nonconforming condition potentially affecting the operability of structures, systems, and components (SSC) required to be operable by Technical Specifications (TS) would become a more significant safety concern, if left uncorrected, because it could reasonably result in an unrecognized condition of an SSC failing to fulfill a safety-related function. The finding was a licensee performance deficiency of very low safety significance because it: (1) was not a design or qualification deficiency; (2) did not represent an actual loss of function of a system; (3) did not represent an actual loss of function of a single train or two separate trains for greater than its TS allowed outage time; (4) did not represent an actual loss of function of one or more non-TS trains of equipment designated as high safety 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 since licensee engineering staff failed to thoroughly and correctly evaluate past operability of the two ECCS relief valves due to inattention to detail. Human error prevention techniques were not appropriately employed to support human performance. The most significant concerns were that the independent technical reviewer did not independently validate information contained in the past operability evaluations by reviewing the valve test records and, that neither the independent technical reviewer nor the engineering supervisory reviewer challenged the unwarranted past operability conclusion reached for the 1E12-F025C test failure. |
Site: | Clinton |
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Report | IR 05000461/2012004 Section 1R12 |
Date counted | Sep 30, 2012 (2012Q3) |
Type: | Finding: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.12 |
Inspectors (proximate) | B Kemker D Lords D Passehl J Beavers J Bozga J Draper M Ring R Ruiz S Mischke |
CCA | H.12, Avoid Complacency |
INPO aspect | QA.4 |
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Finding - Clinton - IR 05000461/2012004 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Clinton) @ 2012Q3
Self-Identified List (Clinton)
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