05000244/FIN-2014002-02
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Finding | |
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| Title | Failure to Ensure the Design Basis Analysis for the Emergency Diesel Generators Accounted for Limiting Cold Weather Conditions and Loading |
| Description | The inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50, Appendix B, Criterion III, Design Control, because CENG did not ensure that the requirements and the design basis as specified in the Updated Final Safety Analysis Report (UFSAR) and Ginna TS bases were correctly translated into specifications, drawings, procedures, and instructions. Specifically, CENG failed to ensure the design basis analysis for the emergency diesel generators (EDGs) accounted for worst case EDG loading and EDG room heat loads during cold weather conditions, which resulted in a condition where there was a reasonable doubt of the operability of the EDGs. CENGs immediate corrective actions included entering the issue into its CAP, conducting an operability determination, and implementing compensatory measures via Engineering Change Package (ECP) 13-001076. The inspectors determined that CENGs failure to provide for verifying or checking the adequacy of design, such as by the performance of design reviews and calculations in accordance with 10 CFR 50, Appendix B, Criterion III, to ensure that EDG room temperatures would not challenge EDG operability, was a performance deficiency that was within CENGs ability to foresee and correct and should have been prevented. This finding is more than minor because it is associated with the design control attribute of the Mitigating Systems cornerstone and affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, following a design basis event during design basis extreme weather conditions, the EDG room temperatures could reach sub-freezing conditions that had not been previously analyzed. This condition could have impacted EDG availability, reliability, and capability if EDG fuel oil temperatures reached their cloud point, if jacket water pressure instrumentation sensing lines froze and resulted in a low jacket water pressure condition, and as other lines like service water (SW) pressure instruments for the jacket water and lube oil cooler froze or approached freezing. Additionally, the finding is similar to Example 3.j. of IMC 0612, Appendix E, Examples of Minor Issues, issued August 11, 2009, in that the EDG design basis analysis failed to consider worst case conditions, which resulted in a reasonable doubt on the operability of the EDGs that necessitated the implementation of compensatory actions via an ECP, extensive data gathering, modification of and evaluation utilizing the GOTHIC computer model, planned permanent modifications, and a past operability determination addressing two lines that could potentially freeze. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green), because the performance deficiency was a deficiency affecting the design of a mitigating SSC, and the SSC maintained its operability. In accordance with IMC 0612, the finding does not have a cross-cutting aspect, because the performance deficiency likely occurred during original plant design, would not likely occur today under similar circumstances, and is not reflective of present plant performance. |
| Site: | Ginna  |
|---|---|
| Report | IR 05000244/2014002 Section 1R15 |
| Date counted | Mar 31, 2014 (2014Q1) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.15 |
| Inspectors (proximate) | D Dodson D Schroeder D Silk E Burket M Orr N Perry |
| Violation of: | Technical Specification - Procedures 10 CFR 50 Appendix B Criterion III, Design Control Technical Specification |
| INPO aspect | |
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Finding - Ginna - IR 05000244/2014002 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Ginna) @ 2014Q1
Self-Identified List (Ginna)
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