05000261/FIN-2014002-04
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Finding | |
|---|---|
| Title | Failure to Provide Adequate Design Control Measures for Diesel Fuel Oil Cloud Point |
| Description | The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion III, Design Control, because the licensee failed to provide adequate design control measures to ensure appropriate specifications were translated into procedures for diesel fuel oil (DFO) to ensure that the DFO temperatures remained above the DFO cloud point. The licensee entered this into the CAP as action request (AR) 664223 and took immediate corrective actions to change the cloud point acceptance criteria from 23 degrees to 10 degrees Fahrenheit and revise procedure OP-925, Cold Weather, to install temporary heaters if outside temperatures fell below 15 degrees Fahrenheit. The licensees failure to provide design control measures to ensure that the DFO temperature was maintained such that the cloud point was not reached was a performance deficiency. This finding is more than minor because it is associated with the protection against external factors 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 (i.e., core damage). Specifically, during periods of cold weather the DFO temperature could have been allowed to fall below its cloud point and affect operation of the emergency diesel generator (EDG) and/or the dedicated shutdown diesel generator operation due to the DFO transfer system becoming inoperable. The inspectors evaluated the significance of this finding using IMC 0609 Appendix A, dated June 19, 2012, The Significance Determination Process (SDP) for Findings at Power, Exhibit 2, Mitigating Systems Screening Questions. The inspectors determined that this finding was of very low safety significance (Green) because the finding is a deficiency affecting the design or qualification of a mitigating SSC; however, the SSC maintained its operability or functionality since the design conditions were not actually reached. The performance deficiency had a cross-cutting aspect of Design Margins in the area of Human Performance because the licensee failed to recognize that additional actions were required to maintain operability of the DFO system when ambient temperatures are below the maximum administrative limit even though samples are reviewed monthly per the DFO Testing Program. |
| Site: | Robinson  |
|---|---|
| Report | IR 05000261/2014002 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) | B Collins C Scott G Hopper K Ellis M Bates |
| Violation of: | 10 CFR 50 Appendix B Criterion III, Design Control |
| CCA | H.6, Design Margins |
| INPO aspect | WP.2 |
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Finding - Robinson - IR 05000261/2014002 | |||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Robinson) @ 2014Q1
Self-Identified List (Robinson)
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