During an NRC inspection completed on November 17, 2006, a violation of NRC requirements was identified. In accordance with the
NRC Enforcement Policy, the violation is listed below: Title 10 Part 50, Appendix B, Criteria III states, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis, as defined in 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions. It further states that design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program. Title 10, Part 50.2 states, in part, that design bases means that information which identifies the specific functions to be performed by a structure, system, or component of a facility, and the specific values or ranges of values chosen for controlling parameters as reference bounds for design. These values may be (1) restraints derived from generally accepted state of the art practices for achieving functional goals, or (2) requirements derived from analysis (based on calculation and/or experiments) of the effects of a postulated accident for which a structure, system, or component must meet its functional goals. Contrary to the above, prior to August 12, 2006, the licensee had not ensured the adequacy of design of the
high pressure core spray (
HPCS) system by performance of design reviews or by use of alternate or simplified calculational methods. Specifically, the initiation of suction swap-over from the
reactor core isolation cooling tank to the suppression pool, a controlling parameter to ensure continued function of the
HPCS pump, was required to occur at 740.19 feet as derived by calculation IP-M-384, Revisions 0, 1, and 1B. However, this calculated value did not prevent significant air entrainment in the suction of the
HPCS pump and subsequent loss of function of the
HPCS pump. This violation is associated with a White
SDP finding.
