05000341/FIN-2016003-01

Finding

Title

Failure to Perform an Operability Determination for Division 1 RPV Reference Leg Backfill System Not Providing Adequate Flow

Description

The inspectors identified a finding of very low safety significance with an associated non-cited violation of Title 10 of the Code of Federal Regulation (10 CFR) 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," for the licensees failure to complete an operability determination as required by plant procedures. Specifically, the licensee failed to perform an operability determination for a degraded/non-conforming condition described in CARD 1625608, Division 1 RPV [Reactor Pressure Vessel] Reference Leg Backfill System Not Meeting Minimum Recommended Flow, to assess the impact on affected RPV level and pressure instrumentation when the minimum reference leg backfill flow rate could not be maintained. The licensee entered this violation into its CAP for evaluation and identification of appropriate corrective actions. An operability determination was subsequently documented in CARD 1625608. The finding was of more than minor safety significance because it was related to the equipment performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to perform an operability determination for the degraded/nonconforming condition could potentially have led to inoperable RPV level and pressure instruments without the licensees knowledge. In this case, during an event involving a rapid depressurization of the RPV, the affected instruments may have caused later than expected initiation of the required automatic actuation signals for the reactor protection system and emergency core cooling system and may have provided operators with erroneous indications. The finding was determined to be of very low safety significance because it did not represent an actual loss of function of a single train for greater than its Technical Specification (TS) allowed outage time nor did it represent a loss of function of a non-TS train designated as high safety significant in accordance with the licensees Maintenance Rule Program. The inspectors determined this finding affected the cross-cutting area of problem identification and resolution and the cross-cutting aspect of evaluation. The licensee did not thoroughly evaluate the problem after it was identified with respect to the effect the degraded/non-conforming condition would have on operability of the RPV level and pressure instruments commensurate with their safety significance [IMC 0310 P.2]

01
Site:	Fermi
Report	IR 05000341/2016003 Section 1R15
Date counted	Sep 30, 2016 (2016Q3)
Type:	NCV: Green
cornerstone	Mitigating Systems
Identified by:	NRC identified
Inspection Procedure:	IP 71111.15
Inspectors (proximate)	B Dickson B Kemker J Bozga P Smagacz R Edwards V Meghani V Myers
Violation of:	10 CFR 50 Appendix B 10 CFR 50 Appendix B Criterion V
CCA	P.2, Evaluation
INPO aspect	PI.2
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v • d • e

Finding - Fermi - IR 05000341/2016003

8(0)1(12)2(7)3(3)4(6)5(0)6(0)7(16)201(1)403(0)404(0)405(0)406(1)502(0)

IR 05000341/2016003: 1 2 3

Finding List (Fermi) @ 2016Q3

CCA Matrix: 2016Q3

	Q	CCA	Title
05000341/FIN-2015004-01	2015Q4	H.12	Failure to Satisfy Technical Specification Requirements During an Unplanned Operation with the Potential to Drain the Reactor Vessel
05000341/FIN-2015007-01	2015Q4	P.2	Failure to Comply with ASME B30.16 for Planned Engineered Lifts
05000341/FIN-2015403-01	2015Q4		Security
05000341/FIN-2016001-04	2016Q1	P.4	Failure to Incorporate Operating Experience into Preventive Maintenance Activities Associated with the TBCCW System
05000341/FIN-2016001-09	2016Q1	H.1	Inadvertent Reactor Water Low Level Reactor Protection System Actuation Due to Operator Error
05000341/FIN-2016001-08	2016Q1		Failure to Follow Apparent Cause Evaluation Procedure
05000341/FIN-2016001-07	2016Q1		Inadequate Test Criteria in SGTS Flow/Heater Operability Surveillance Test
05000341/FIN-2016001-06	2016Q1		Failure to Translate Design Requirements of the RHRHVAC System into Procedures
05000341/FIN-2016001-02	2016Q1	H.14	Failure to Correctly Interpret and Implement TS Requirements for RPS Trip Functions
05000341/FIN-2016001-01	2016Q1		Failure of the Plant-Referenced Simulator to Demonstrate Expected Plant Response for Safety Relief Valves
05000341/FIN-2016001-03	2016Q1		Failure to Satisfy 10 CFR 50.72 and 10 CFR 50.73 Reporting Requirements for Loss of RPS Trip Safety Functions
05000341/FIN-2016001-05	2016Q1		Failure to Satisfy 10 CFR 50.73 Reporting Requirements for a Condition Prohibited by the Plants Technical Specifications
05000341/FIN-2016001-10	2016Q1		Failure to Satisfy 10 CFR 50.72 and 10 CFR 50.73 Reporting Requirements for Primary Containment Isolation Valve Actuations
05000341/FIN-2016002-05	2016Q2		Failure to Use Correct Material in a Feedwater Heater Level Control Valve Resulted in a Loss of Feedwater Heater Drains and a Reactor Recirculation System Runback
05000341/FIN-2016002-03	2016Q2	H.9	Loss of Power Instrumentation TS 3.3.8.1 Applicability Following Bus 64C Potential Transformer Fuse Failures
05000341/FIN-2016002-01	2016Q2	H.12	Failure to Control Combustible Materials
05000341/FIN-2016406-01	2016Q2	H.13	Security
05000341/FIN-2016201-01	2016Q2		Security
05000341/FIN-2016002-02	2016Q2		Inadequate Test Procedure Used for Measuring and Determining Average Silt Levels in the Service Water Reservoir
05000341/FIN-2016002-04	2016Q2	P.2	Failure to Control the Work Hours of Covered Workers
05000341/FIN-2016002-06	2016Q2		Failure to Implement Adequate Preventive Maintenance on Spare Terminals in Safety-Related Motor Control Centers
05000341/FIN-2016003-02	2016Q3		Fluctuating Background Effect on Accident Range Noble Gas Monitor
05000341/FIN-2016007-02	2016Q3	P.6	Failure to Verify the Adequacy of the Voltage Supplied to Transformer #64 Load Tap Changer
05000341/FIN-2016007-07	2016Q3	P.6	Failure to Ensure that Protective Devices for the Loads Required at the Beginning of a LOCA Would Not Trip Under Degraded Voltage Conditions
05000341/FIN-2016007-13	2016Q3	P.2	Failure to Identify a CAQ Associated with Over-Dutied 480V Safety-Related Switchgear Breakers
05000341/FIN-2016003-01	2016Q3	P.2	Failure to Perform an Operability Determination for Division 1 RPV Reference Leg Backfill System Not Providing Adequate Flow
05000341/FIN-2016007-01	2016Q3		Inadequate Procedure for Addressing Non-Functional MDCT Fan Motor Brake System
05000341/FIN-2016003-03	2016Q3	H.8	Failure to Follow Procedures During Concrete Placement of Flexible Storage Facility Buildings
05000341/FIN-2016007-16	2016Q3	H.13	Failure to Timely Identify, Document, and Evaluate Conditions that Challenge Operability
05000341/FIN-2016007-15	2016Q3	H.14	Failure to Identify that a Non-Conservative Min-K Insulation Volume Calculation Error Was Nonconforming to the ECCS Suction Strainer Licensing Basis
05000341/FIN-2016007-14	2016Q3		Failure to Identify that an Inadequate Minimum MSIV Accumulator Air Pressure Setpoint Was CAQ
05000341/FIN-2016007-12	2016Q3	H.4	Failure to Identify an Out-of-Specification Pressure Reading on the Nitrogen Supply to the A MDCT Fan Motor Brake System
05000341/FIN-2016007-11	2016Q3	H.6	Failure to Apply Design Control Measures to a Design Change Associated with NIAS Accumulator Capability
05000341/FIN-2016007-10	2016Q3		Non Conservative ECCS Suction Strainer Min-K Combined Generation and Transport Factors
05000341/FIN-2016007-09	2016Q3		Failure to Evaluate the Acceptability of Drywell Coatings with Respect to Potential ECCS Suction Strainer Blockage
05000341/FIN-2016007-08	2016Q3		Inadequate Containment Debris Inspections Acceptance Criteria
05000341/FIN-2016007-06	2016Q3		Failure to Ensure that the MSIVs Would Close Within the TS Required Timeframe and as Described in the UFSAR
05000341/FIN-2016007-05	2016Q3		Failure to Leak Test All Division 2 NIAS Boundary Isolation Valves
05000341/FIN-2016007-04	2016Q3		Failure to Periodically Test the EDG Capability to Start and Accelerate All of the Sequenced Loads Within the Applicable Limits
05000341/FIN-2016007-03	2016Q3	H.4	Failure to Verify the Ability to Manually Throttle Safety-Related MOVs during a DBA

Self-Identified List (Fermi)

	Q	Title
05000341/FIN-2015004-02	2015Q4	Licensee-Identified Violation
05000341/FIN-2016001-11	2016Q1	Licensee-Identified Violation
05000341/FIN-2016001-12	2016Q1	Licensee-Identified Violation
05000341/FIN-2016002-07	2016Q2	Licensee-Identified Violation

[Fermi Findings full list]

05000341/FIN-2016003-01

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