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TS 3.4.6 requires, in part, that the leaka … TS 3.4.6 requires, in part, that the leakage from each RCS PIV shall be within limits in Modes 1, 2, and 3. TS 3.4.6, Condition A, states that with one or more flow paths with leakage from one or more RCS PIVs not within the limit, isolate the high pressure portion of the affected system from the low pressure portion by use of one closed manual, deactivated automatic, or check valve within 4 hours. TS 3.4.6, Condition B, states that if the required action and associated completion time of Condition A is not met, be in Mode 3 within 12 hours and Mode 4 within 36 hours. TS 3.6.1.3 requires, in part, that each primary containment isolation valve be operable in Modes 1, 2, and 3. TS 3.6.1.3, Condition C, states, in part, that with one or more penetration flow paths with leakage rate not within limit, restore leakage rate to within the limit within 4 hours. TS 3.6.1.3, Condition E, states, in part, that if the required action and associated completion time of Condition C is not met, be in Mode 3 within 12 hours and Mode 4 within 36 hours. Contrary to the above, RCS PIV 1E12-F042C was found with leakage in excess of the limit during leak rate measurement surveillance testing on December 7, 2011. The licensee determined the cause for the failure was due to wear on the valve guide ribs and excessive disc to rib clearances, such that the disc became cocked when closing and it did not fully seat. In addition, testing of this valve during the previous operating cycle to satisfy TSSR 3.4.6.1 was not correctly performed, for which the licensee had taken action in accordance with TSSR 3.0.3. Based on the cause determination and the previous missed surveillance of 1E12-F042C, the inspectors concluded that this valve had not been capable of performing its specified safety function (and thus was inoperable) for a period of time before its discovery longer than allowed by TS 3.4.6 and TS 3.6.1.3. The inspectors performed a Phase 1 SDP review of this finding using the guidance provided in IMC 0609, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings. In accordance with Table 4a, Characterization Worksheet for IE, MS, and BI Cornerstones, the inspectors determined that that this finding was a licensee performance deficiency of very low safety significance (Green) because the finding would not result in exceeding the TS limit for RCS 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 valve test failure did not result in an increase in the likelihood of an initiating event such as an intersystem LOCA 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. This violation of TS 3.4.6 and TS 3.6.1.3 is being treated as a non-cited violation consistent with Section 2.3.2 of the NRC Enforcement Policy. The licensee entered this violation into its corrective action program as AR 01305725. The licensee submitted LER 05000461/2011-006-00 to report this issue as a condition prohibited by TS. Refer to Section 4OA3.2 of this inspection report for the review and closure of the LER.ort for the review and closure of the LER.

Discovered date

23:59:59, 31 March 2012 +

Docket

05000461 +

Event date

23:59:59, 31 March 2012 +

Finding integer

5 +

Finding type

Non-cited violation +

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Hours

4.62963e-5 d (0.00111 hours, 6.613757e-6 weeks, 1.522e-6 months) +, 1.388889e-4 d (0.00333 hours, 1.984127e-5 weeks, 4.566e-6 months) + and 4.166667e-4 d (0.01 hours, 5.952381e-5 weeks, 1.3698e-5 months) +

Identified by

Licensee-identified +

Inspection Manual Chapter

NRC Inspection Manual 0609 +

Inspection report

IR 05000461/2012002 +

Inspector

J Cassidy +, S Mischke +, M Ring +, D Lords +, Dariusz Szwarc +, Robert Orlikowski +, Brian Kemker +, John Bozga +, Charles Brown + and Stephen Bell +

LER

05000461/LER-2011-006, Regarding Condition Prohibited by Technical Specifications Due to Failed Missed Surveillance +

Modification date"Modification date" is a predefined property that corresponds to the date of the last modification of a subject and is provided by <a rel="nofollow" class="external text" href="https://www.semantic-mediawiki.org/wiki/Help:Special_properties">Semantic MediaWiki</a>.

03:14:59, 30 May 2018 +

Person