05000237/FIN-2011003-01
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Finding | |
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| Title | Failure to Include Adequate Acceptance Criteria in a Surveillance Test |
| Description | The inspectors identified an unresolved item regarding the failure to include adequate acceptance criteria in a surveillance test for equipment that is the sole source of make-up water to the shell of the isolation condensers and the spent fuel pools for both units during a design basis flood. On April 8, 2011, the inspectors observed the performance of Work Order (WO) 872864, D2/3 6Y PM Emergency Diesel Pump (Flood Pump) Operation. After the surveillance was completed, the inspectors reviewed the completed work package and identified that the work instructions did not include acceptance criteria for the surveillance. Work Order 872864 instructed the licensee, in part, to:
Throttle 2-inch brass valve until a discharge pressure of 50 psig (-0%, +2%) was reached; Record pump discharge pressure; Record engine speed; Record the number of gallons in the tank; Record the time required to fill the tank. Revision 2 of the WO instructions stated, Clarified work step #19 to perform test or tests at the discretion of the test engineer. Test discharge pressure to be determined by test engineer. The test engineer determined that the 2-inch brass valve was to be throttled until discharge pressures of 50, 75, and 100 pounds-force per square inch gauge (psig) were reached. Calculation DRE99-0035, Capacity and Discharge Head for Portable Isolation Condenser Make-Up Pumps to be used during Flood Conditions, revision 4, determined that the most demanding hydraulic requirement for the flood pump is 350 gallons per minute (gpm) at 47 psig. Dresdens Updated Final Safety Analysis Report (UFSAR), Section 3.4.1.1, External Flood Protection Measures, states, in part, that in the highly unlikely event that a probable maximum flood (PMF) is predicted (528 feet), the plant will shutdown in advance of the time predicted for flood stage occurrence, i.e., grade level (517.5 feet). The PMF flood procedure will be implemented upon a forecast of river levels exceeding 506.5 feet. When the water level reaches 509 feet both reactors will be shutdown, the drywells will be deinerted, and both vessels will be flooded. The reactors will be cooled to the lowest legal temperature as quickly as possible. If the water level reaches 513 feet at the plant site, cooling of the reactors will be transferred to the isolation condensers, which will thereafter maintain the primary system in a safe shutdown condition. If forecasted flood levels exceed 517 feet, a diesel-driven emergency flood pump will be connected by hoses to a fire system header in each unit. Through these fire system headers, the emergency flood pump will be capable of providing at least 175 gpm of flow to each unit. This flow will be used for make-up to the shell of the isolation condensers and the spent fuel pools. None of these requirements were referenced in the work order. Task 1 of WO 872864, MM D2/3 6Y PM Emergency Diesel Pump (Flood Pump) Operation, stated that the surveillance was found and left within acceptance criteria. The comments section of Task 2 of WO 872864, Ops Support Flood Emergency Makeup Pump Maintenance, stated there is no specific Acceptance Criteria in task-01. The licensee generated issue report (IR) 1209642, NRC Identified URI with Flood Acceptance Criteria, to address the inspectors concerns. Upon further discussions with the licensee, the inspectors noticed that until early 2007, the flood pump was classified as an augmented quality piece of equipment. Therefore, the flood pump was within the scope of the licensees Quality Assurance Topical Report (QATR). Since 2007, the flood pump had been classified as non-safety-related. Based on the definition of safety-related systems, structures and components, as described in Title 10 of the Code of Federal Regulations, Part 50.2, Definitions, and based on the fact that that the flood pump is utilized to mitigate the consequences of an event described in Section 3.4.1.1, External Flood Protection Measures, of the Dresden UFSAR, the inspectors were concerned that the flood pump has been misclassified as non-safety and it should be classified as a safety-related piece of equipment. At the end of the inspection period, the licensee was still working on identifying when and why the flood pump was downgraded from augmented quality to non-safety-related. The licensee generated IR 1239579, NRC Questions the Safety Classification of Diesel Flood Pump, to address the inspectors concerns. As part of this IR, the licensee generated an action to determine if the safety classification for the flood pump is appropriate based on Dresdens design bases. The inspectors considered this issue an unresolved item (URI) pending review of the licensees evaluation (URI 05000237/2011003-01; 05000249/2011003-01, Failure to Include Adequate Acceptance Criteria in a Surveillance Test). |
| Site: | Dresden  |
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| Report | IR 05000237/2011003 Section 1R01 |
| Date counted | Jun 30, 2011 (2011Q2) |
| Type: | URI: |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.01 |
| Inspectors (proximate) | D Jones D Melendez _Colon G Roach J Cameron J Corujo_Sandin T Gom Bielby M Ring T Go J Draper C Tilton J Corujo -Sandin M Munir R Winter A Dahbur D Melendez-Colon C Phillips C Moorej Draper L Jones J Corujo -Sandin R Orlikowski D Melendez-Colon C Phillips M Rin |
| INPO aspect | |
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Finding - Dresden - IR 05000237/2011003 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Dresden) @ 2011Q2
Self-Identified List (Dresden)
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