05000483/FIN-2017007-02
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Finding | |
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| Title | Safety Injection Piggyback Valve EJ-HV-8804A Valve Interlocks Not Tested |
| Description | The team identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, which requires, in part, that a test program shall be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written procedures. Specifically, prior to August 3, 2017, the licensee failed to have a program to completely test the interlock circuit for safety injection pump and recirculation suction isolation valves, EJ-HV-8804A and EJ-HV-8804B. When the licensee personnel performed a review the interlock circuits for the valves, they identified that there had been gaps in the testing. In response to this issue, the licensee investigated all of the testing activities associated with the valve interlock circuits and identified that in 2010, a comprehensive test of the circuits had been performed as the result of a modification. The licensee has entered this issue into their corrective action program as Condition Report CR-201703962. The team determined that the failure to develop and implement testing programs for verifying that the circuits for the multiple interlocks associated with safety injection valve EJ-HV-8804A would perform as designed was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to establish a testing program to verify that the valve interlock circuits for valve EJ-HV-8804A were being tested. A failure of the interlocks and an operator error could result in an inadvertent release path to the environment. In accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, Exhibit 2, Mitigating Systems Screening Questions, the issue screened as having very low safety significance (Green) because it was a design or qualification deficiency that did not represent a loss of operability or functionality; did not represent an actual loss of safety function of the system or train; did not result in the loss of one or more trains of non-technical specification equipment; and did not screen as potentially risk-significant due to seismic, flooding, or severe weather. The team determined that this finding did not have a cross-cutting aspect because the most significant contributor did not reflect current licensee performance. |
| Site: | Callaway  |
|---|---|
| Report | IR 05000483/2017007 Section 1R21 |
| Date counted | Sep 30, 2017 (2017Q3) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.21M |
| Inspectors (proximate) | I Anchando J Watkins A Palmer |
| Violation of: | 10 CFR 50 Appendix B 10 CFR 50 Appendix B Criterion XI |
| INPO aspect | |
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Finding - Callaway - IR 05000483/2017007 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Callaway) @ 2017Q3
Self-Identified List (Callaway)
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