05000528/FIN-2013009-01
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Finding | |
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| Title | Failure to Translate Design Basis Requirements for Establishing Operability of the Spray Pond System |
| Description | The team identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, which states, in part, Measures shall be established to assure that applicable regulatory requirements and the design basis, are correctly translated into specifications, drawings, procedures, and instructions. These measures shall include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled. Specifically, prior to February 7, 2014, the licensee used Engineering Calculation 13-NS-C088, Mission Times for EW, SP, SI, AF, and DG systems, for establishing a 26-day mission time of the spray pond system instead of a 30-day availability time as required by Regulatory Guide 1.27, Ultimate Heat Sink For Nuclear Power Plants, and approved in their safety evaluation report. Consequently, spray pond system operability determinations performed per Procedure 40DP-9OP26, Operations PVAR Processing and Operability Determination/ Functional Assessment, used the incorrect mission time. In response to this issue, the licensee performed a review of the operability determinations in question using 30 days for the mission time and confirmed that the spray pond system remained operable and maintained an adequate safety margin. This finding was entered into the licensees corrective action program as Palo Verde Action Request (PVAR) 4500910. The team determined that the failure to ensure that design basis information associated with the mission time of the spray pond system was correctly translated into a procedure used to determine operability was a performance deficiency. This performance deficiency was more than minor because it adversely affected the Mitigating Systems Cornerstone attribute of Equipment Performance and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to use the correct mission time when determining operability was a significant deficiency of design control in that operability determination evaluations could establish nonconservative results that could lead to the spray pond system not being able to meet its design safety function. 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 because the licensee implemented an engineering study with inaccurate information establishing the incorrect mission time used in operability d.eterminations for the spray pond system. |
| Site: | Palo Verde  |
|---|---|
| Report | IR 05000528/2013009 Section 1R21 |
| Date counted | Mar 31, 2014 (2014Q1) |
| Type: | NCV: Green |
| cornerstone | Initiating Events |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.21 |
| Inspectors (proximate) | I Anchondo R Kopriva T Farnholtz W Sherbin B Jose C Hale C Osterholtz G Gardner |
| Violation of: | 10 CFR 50 Appendix B Criterion III, Design Control |
| CCA | H.7, Documentation |
| INPO aspect | WP.3 |
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Finding - Palo Verde - IR 05000528/2013009 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Palo Verde) @ 2014Q1
Self-Identified List (Palo Verde)
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