05000382/FIN-2011002-01
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Finding | |
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| Title | Failure to follow Operability Determination Process for a Degraded and Non-Conforming condition Related to Reactor Coolant Pump N9000 Seals |
| Description | The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, because the licensee did not adequately implement the operability determination process requirements in accordance with EN-OP-104, Operability Determination Process. Specifically, the licensee did not frequently and regularly review a degraded and nonconforming condition associated with the reactor coolant pump N-9000 stage seals as required by EN-OP-104. As a result, the licensee did not perform a new operability determination after assumptions and compensatory measures identified in the original operability determination changed. This also led to compliance issues with technical specifications and missed maintenance rule functional failures. The licensee entered this issue into their corrective action program for resolution as CR-WF3-2011-1965. The immediate corrective actions included revising the operability determination to account for the current configuration. The planned corrective actions included the licensee replacing the degraded reactor coolant pump seals during the next two refueling outages. The finding is more than minor because it is associated with the equipment performance attribute of the initiating events cornerstone and affects the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the licensee did not frequently and regularly review a degraded and nonconforming condition that had the potential to lead to a small loss of coolant accident. The senior resident inspector performed the initial significance determination for the failure to perform an adequate operability determination associated with increased reactor coolant pump seal leakage when transitioning the plant to a shutdown condition, using NRC Inspection Manual 0609, Attachment 0609.04, Phase 1 Initial Screening and Characterization of Findings. The finding screened to a Phase 2 significance determination because the finding involved reactor coolant system leakage in excess of the technical specification limit of 1 gallon per minute for unidentified leakage (leakage was up to 6 gallons per minute). A Region IV senior reactor analyst performed a Phase 2 significance determination using Inspection Manual 0609, Appendix A, Determining the Significance of Reactor Inspection Findings for At-Power Situations. However, this particular finding was not well suited for the Phase 2 process. The senior reactor analyst subsequently performed a Phase 3 significance determination. The analyst found that the finding was of very low safety significance (Green). Potentially risk important sequences included those involving reactor coolant pump seal failures (where leakage could surpass the capacity of the charging system) and long term station blackout. The relatively small amount of leakage helped to mitigate the significance. The finding has a cross-cutting aspect in the corrective action program component of the problem identification and resolution area because the licensee did not thoroughly evaluate problems such that the resolutions address causes and extent of conditions, as necessary. This includes properly classifying, prioritizing, and evaluating for operability and report ability conditions adverse to quality P.1.c of IMC 0310] |
| Site: | Waterford  |
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| Report | IR 05000382/2011002 Section 1R12 |
| Date counted | Mar 31, 2011 (2011Q1) |
| Type: | NCV: Green |
| cornerstone | Initiating Events |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.12 |
| Inspectors (proximate) | P Elkmann M Davis J Clark R Azua D Overland |
| CCA | P.2, Evaluation |
| INPO aspect | PI.2 |
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Finding - Waterford - IR 05000382/2011002 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Waterford) @ 2011Q1
Self-Identified List (Waterford)
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