05000387/FIN-2015002-03
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Finding | |
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| Title | Incorrect Implementation of the Ventilation Filter Testing Program |
| Description | The inspectors identified a finding of very low safety significance (Green) and associated NCV of 10 CFR 50, Appendix B, Criterion XI, Test Control, because Susquehanna did not ensure representative samples were obtained from Engineered Safety Feature (ESF) filter ventilation systems and did not establish written test procedures. Specifically, subsequent to refilling charcoal test canisters for the activated charcoal absorber of both trains of the SBGT System, new charcoal was added to the activated charcoal absorber which was not exposed to the same service conditions as the bulk of the absorber section as required by TS 5.5.7, Ventilation Filter Testing Program, and written test procedures were not established for this activity. As corrective action for the identified issue, Susquehanna replaced the charcoal in the A and B trains of SBGT and the A and B trains of CREOASS activated charcoal absorber beds and test canisters between January and February 2015 and initiated condition reports CR-2014-39116 and CR-2015-01443. The inspectors determined that the finding was more than minor because it was associated with the Procedure Quality Attribute of the Barrier Integrity Cornerstone and it adversely affected the cornerstone objective to provide reasonable assurance that physical barriers protect the public from radionuclide releases caused by accidents or events. Specifically, since 2001, work instructions did not prevent the contamination of test canisters with charcoal that was not representative of the in-service conditions of the adsorber bed and the introduction of new charcoal into the test canisters likely provided better results during periodic surveillance testing which were not representative of actual conditions. In accordance with IMC 0609.04, Initial Characterization of Findings, dated June 19, 2012, and Exhibit 3 of IMC 0609, Appendix A, The SDP for Findings At-Power, dated June 19, 2012, the inspectors determined that the finding was of very low safety significance (Green) because it only represented a degradation of the radiological barrier function provided for the control room and SBGT system. This finding has a cross-cutting aspect in the area of Human Performance, Documentation, because the activities for sampling the activated charcoal beds were not governed by comprehensive, high-quality programs, processes, and procedures nor were the design documentation, procedures, and work packages complete, thorough and accurate. |
| Site: | Susquehanna  |
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| Report | IR 05000387/2015002 Section 2RS6 |
| Date counted | Jun 30, 2015 (2015Q2) |
| Type: | NCV: Green |
| cornerstone | Initiating Events, Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71124.06 |
| Inspectors (proximate) | F Bower H Gray J Greives J Kulp N Graneto T Daun A Turilin B Smith C Graves |
| Violation of: | Technical Specification - Procedures Technical Specification 10 CFR 50 Appendix B Criterion XI |
| CCA | H.7, Documentation |
| INPO aspect | WP.3 |
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Finding - Susquehanna - IR 05000387/2015002 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Susquehanna) @ 2015Q2
Self-Identified List (Susquehanna)
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