05000237/FIN-2013002-02
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Finding | |
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Title | Deficiency In Abnormal Operating Procedures for Site Response to External Flooding Events |
Description | The inspectors identified a finding and an associated Apparent Violation (AV) of Technical Specification (TS) Section 5.4. 1. Technical Specification 5.4.1 requires, in part, that written procedures be established, implemented, and maintained covering the following activities: \\\"the applicable procedures recommended in Regulatory Guide (RG) 1.33. Revision 2, Appendix A, February 1978.\\\" RG 1.33. Revision 2, Appendix A, Paragraph 6 addresses \\\"Procedures for Combating Emergencies and Other Significant Events\\\" and Item w addresses \\\"Acts of Nature (e.g ., tornado, flood, dam failure, earthquakes).\\\" From February 20, 1991, to November 21, 2012, the licensee failed to establish a procedure addressing all of the effects of an external flooding scenario on the plant. Specifically, DOA 0010-04, \\\"Floods,\\\" did not account for reactor vessel inventory make up during an external flooding scenario up to and including the probable maximum flood event which could result in reactor vessel water level lowering below the top of active fuel. This finding does not represent an immediate safety concern in that the licensee now has procedures for providing reactor vessel make up water during an external flood scenario up to and including a PMF event. The inspectors determined that the licensee\\\'s failure to consider reactor vessel inventory make up during an external flooding scenario up to and including the PMF was a performance deficiency warranting a significance evaluation. The finding was determined to be more than minor in accordance with Inspection Manual Chapter (IMC) 0612, \\\"Power Reactor Inspection Reports,\\\" Appendix B, \\\"Issue Screening,\\\" dated September 7, 20 12, because it was associated with the Mitigating Systems Cornerstone attribute of procedure quality and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. A Significance and Enforcement Review Panel (SERP), using IMC 0609, Appendix M, \\\"Significance Determination Process Using Qualitative Criteria,\\\" dated April 12, 2012, preliminarily determined the finding to be of low to moderate safety significance (White). The inspectors determined that this finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, Self and Independent Assessments, since it involves the failure to identify the lack of procedural steps to address a critical function during a comprehensive self assessment of the flooding strategy. |
Site: | Dresden |
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Report | IR 05000237/2013002 Section 4OA2 |
Date counted | Mar 31, 2013 (2013Q1) |
Type: | Violation: White |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71152 |
Inspectors (proximate) | D Betancourt G Roach J Cameron J Rutkowskid Jonesd Melendez Colon G Roach J Cameron J Corujo Sandin T Goc Cast |
Violation of: | Technical Specification - Procedures Technical Specification |
CCA | P.6, Self-Assessment |
INPO aspect | CL.2 |
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Finding - Dresden - IR 05000237/2013002 | ||||||||||||||||||||||||||||||||||||||
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Finding List (Dresden) @ 2013Q1
Self-Identified List (Dresden)
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