05000341/FIN-2012007-02
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Finding | |
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| Title | Inadequate Safety Evaluation for the Online Noble Chemical Metal Process |
| Description | The inspectors identified a Severity Level IV, Non-Cited Violation (NCV) of 10 CFR 50.59(d)(1), Changes, Tests, and Experiments, and an associated (Green) finding for the licensees failure to provide an adequate written safety evaluation to demonstrate that application of the On-Line NobleChemTM(OLNC) process did not require a license amendment. Specifically, the licensee had not provided an evaluation to demonstrate that application of the OLNC process did not increase the likelihood for hydrogen induced detonation and piping failures for six areas of the balance of plant (BOP) piping susceptible to hydrogen accumulation. The licensee entered the issue into its corrective action program as CARD 12-20812 and intended to revise safety evaluation No.10-0286 to provide an adequate written basis for the OLNC process prior to the next scheduled application of OLNC materials. The finding was determined to be more than minor because the inspectors could not reasonably determine if the application of the OLNC process would not have required NRC prior approval (e.g., a license amendment). The finding was also determined to be more than minor because the finding was associated with the Initiating Events Cornerstone attribute of Equipment Performance and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions. Absent NRC identification, the licensee would have continued to introduce OLNC materials into the reactor feed system without confirming that the OLNC process did not increase the likelihood for hydrogen induced detonation and piping failures in the BOP piping segments that would upset plant stability and challenge safety systems. The finding was of very low safety significance because the finding did not contribute to both the likelihood of a reactor trip AND the likelihood that mitigation equipment or functions will not be available. This finding has a cross-cutting aspect in the Decision Making component of the Human Performance cross-cutting area because the licensee did not use conservative assumptions to ensure the proposed action was safe. Specifically, the licensees failure to provide a written safety evaluation, which demonstrated that application of the OLNC process did not increase the likelihood for hydrogen induced detonation and piping failures was the result of a non-conservative assumption that the OLNC process was safe. |
| Site: | Fermi  |
|---|---|
| Report | IR 05000341/2012007 Section 1R17 |
| Date counted | Mar 31, 2012 (2012Q1) |
| Type: | Finding: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.17 |
| Inspectors (proximate) | M Holmberg R Langstaff A Dahbur J Gilliam H Peterson I Hafeez |
| CCA | H.14, Conservative Bias |
| INPO aspect | DM.2 |
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Finding - Fermi - IR 05000341/2012007 | |||||||||||||||||||||||||||||||||||||||||
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Finding List (Fermi) @ 2012Q1
Self-Identified List (Fermi)
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