05000317/FIN-2012002-01
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Finding | |
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Title | Failure to Establish a Test Program for Auxiliary Feedwater Emergency Air Accumulators |
Description | The inspectors identified an NCV of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, due to Constellations failure to establish a test program to demonstrate that the auxiliary feedwater (AFW) air-operated valves (AOVs) will operate as design with the emergency air accumulators and associated air pressure control valves (PCVs). Specifically, on January 26, 2012, the inspectors identified that safety related AFW emergency PCVs were replaced without a functional post maintenance test (PMT). The inspectors also identified that the AFW emergency air system had not being tested since the emergency air accumulators were installed in the 1980s and the 1990s. Constellation immediate corrective actions included entering the issues in their corrective action program (CAP), performing a functional test of the installed PCVs, performing an operability determination for the AFW emergency air system, and developing a testing procedure to periodically verify operation of AFW AOVs using the emergency air system. The finding is more than minor because it is associated with the equipment performance attribute of the Mitigating System cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, a reasonable doubt of operability existed because the capability of the AFW AOVs to operate using the backup air supply had not been demonstrated since original installation. In addition, if this issue was left uncorrected, it could have resulted in a greater safety concern because there was potential for build-up of particulate and condensation in the tight fits of the PCVs which could impact reliable operation. The inspectors determined that the finding is of very low safety significance because the performance deficiency was not a design or qualification deficiency, did not involve an actual loss of safety function, did not represent actual loss of safety function of a single train for greater than its TS allowed outage time, and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The finding has a cross-cutting aspect in the area of problem identification and resolution, CAP, because Constellation did not ensure that issues potentially impacting nuclear safety were promptly identified, fully evaluated, and actions were taken to address safety issues in a timely manner commensurate with their safety significance. Specifically, Constellation did not implement a CAP with a low threshold for identifying test control issues associated with the AFW system [P.1.(a) per IMC 0310 |
Site: | Calvert Cliffs |
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Report | IR 05000317/2012002 Section 1R19 |
Date counted | Mar 31, 2012 (2012Q1) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.19 |
Inspectors (proximate) | S Pindale E Gray G Dentel T Burns S Kennedy R Rolph E Torres K Cronk |
CCA | P.1, Identification |
INPO aspect | PI.1 |
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Finding - Calvert Cliffs - IR 05000317/2012002 | |||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Calvert Cliffs) @ 2012Q1
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