05000440/FIN-2011005-04
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Finding | |
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Title | Failure To Maintain The Plant Underdrain System Within USAR Described Capabilities |
Description | The inspectors identified a finding of very low safety significance (Green) and associated NCV of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to maintain the plant underdrain system as described in the Updated Safety Analysis Report (USAR) using adequate design control measures. Specifically, the inspectors determined that the plant underdrain systems condition was unable to support maintaining a design underground water table level of less than 568 feet with the automatic level detection and pumping system as described the USAR. As a result of this inability to maintain the system, a postulated Chapter 15 accident associated with a possible radiation waste tank failure required recalculation to demonstrate radiation safety for the public. The issue was placed in the licensees corrective action program as CR 2011-07169, Plant Underdrain Groundwater Level Readings Non-Conservative Acceptance Criteria. The site took immediate actions to upgrade the installed system and is utilizing temporary manually operated pumps to assist the normally installed systems. The performance deficiency was screened in accordance with IMC 0612, Appendix B, Issue Screening and determined to be more than minor. None of the IMC 0612, Appendix E examples described this scenario but the inspectors determined that if left uncorrected the performance deficiency had the potential to lead to a more significant radiological safety concern by creating a liquid effluent release path that was not evaluated for radiological dose impact to the public prior to discharge and thus was more than minor. The finding was reviewed for significance in accordance with IMC 0609, Attachment 0609.04, Phase 1 Initial Screening and Characterization of Findings, and determined that the finding affected the Public Radiation Safety cornerstone, Effluent Release Program. The finding was then reviewed for significance by the inspectors in accordance with IMC 0609, Appendix D, Public Radiation Safety Significance Determination Process, and determined to be of very low safety significance. Specifically, the finding did not involve radioactive material control or the radiological environmental monitoring program. The finding was not a failure to implement the radiological effluent release program and public doses values were not greater than 10 CFR Part 50, Appendix I, criteria or 10 CFR 20.1301(e) criteria. The finding was associated with a cross-cutting aspect in the Corrective Action Program component of the Problem Identification and Resolution cross-cutting area because the licensee did not thoroughly evaluate problems such that the resolutions addressed causes and extent of conditions. Specifically, numerous deficiencies previously identified with the plant underdrain system were not addressed in enough detail to thoroughly evaluate the problem and extent of condition to allow the system to maintain the plant underground water table at USAR described level |
Site: | Perry |
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Report | IR 05000440/2011005 Section 1R22 |
Date counted | Dec 31, 2011 (2011Q4) |
Type: | NCV: Green |
cornerstone | Pr Safety |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.22 |
Inspectors (proximate) | D Hoang J Beavers J Bozga J Giessner L Jones M Bielby M Marshfield R Edwards R Langstaff T Hartman V Meghani |
CCA | P.2, Evaluation |
INPO aspect | PI.2 |
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Finding - Perry - IR 05000440/2011005 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Perry) @ 2011Q4
Self-Identified List (Perry)
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