05000400/FIN-2014007-03
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Finding | |
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| Title | Failure to Establish Appropriate Procedural Limitations to Prevent Exceeding TS Limits and Safety Analysis Assumptions |
| Description | The team identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to assure that applicable regulatory requirements in technical specification (TS) 3.7.1.1 and design basis inputs in accident analyses were translated into procedural guidance. Specifically, the licensee did not follow their inservice test program guidance to account for surveillance test equipment instrument uncertainty when establishing the acceptability of Main Steam Safety Valve lift setpoints required by TS 3.7.1.1. Following identification by the team, the licensee generated nuclear condition report 697100 and performed an evaluation of the remaining available margin to the overpressure limit in the safety analysis, and discovered that, after potential instrument uncertainty was taken into account, the margin remained positive, but was reduced from approximately 19 psig to approximately 6 psig. The licensees failure to assure that applicable regulatory requirements in TS 3.7.1.1 and design basis assumptions in accident analyses were correctly translated into procedural guidance, as required by 10 CFR Part 50, Appendix B, Criterion III, was a performance deficiency. The performance deficiency was determined to be more than minor because, if left uncorrected, it had the potential to lead to a more significant safety concern. Specifically, by not accounting for the measurement and test equipment uncertainties as required by the inservice test program, it could have led to the actual lift setpoints exceeding the inputs used in the design basis safety analyses. The team determined the finding to be of very low safety significance (Green) because the finding was a deficiency affecting the design or qualification of a mitigating structure, system, or component (SSC), and the SSC maintained its operability. The team determined that no cross-cutting aspect was applicable because the finding was not indicative of current licensee performance. |
| Site: | Harris  |
|---|---|
| Report | IR 05000400/2014007 Section 1R21 |
| Date counted | Sep 30, 2014 (2014Q3) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.21 |
| Inspectors (proximate) | A Ruh C Baron G Ottenberg M Riley R Nease R Patterson S Kobylarz |
| Violation of: | Technical Specification - Procedures 10 CFR 50 Appendix B Criterion III, Design Control Technical Specification |
| INPO aspect | |
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Finding - Harris - IR 05000400/2014007 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Harris) @ 2014Q3
Self-Identified List (Harris)
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