05000244/FIN-2013005-01
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Finding | |
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| Title | Failure to Identify and Correct Non-Hydrostatically Sealed Penetrations into Battery Room ?B |
| Description | The inspectors identified a finding associated with an apparent violation of Title 10 of the Code of Federal Regulations (10 CFR) 50, Appendix B, Criterion XVI, Corrective Action, for Constellation Energy Nuclear Group, LLC (CENG) staffs failure to assure that conditions adverse to quality were promptly identified and corrected. Specifically, CENG failed to identify the need to hydrostatically seal two cable penetrations between manhole 1 and battery room B after the sites design basis flood height was changed during the NRC Systematic Evaluation Program (SEP) in 1983; promptly correct the significant adverse condition in May 2013 when the condition was identified and take timely action in early September 2013 when CENG was presented with evidence challenging its May 2013 evaluation related to manhole 1 and the improperly sealed penetrations. As a result, various Deer Creek flooding scenarios could have resulted in flooding of both battery rooms. Immediate corrective actions included placing this issue in the corrective action program (CAP) as condition report (CR)-2013-003407, CR-2013- 005262, and CR-2013-005643; and hydrostatically sealing the penetrations on October 4, 2013. This finding is more than minor because it is associated with the protection against external factors attribute of the Mitigating Systems cornerstone and 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, propagating flood water could damage mitigating equipment needed to prevent core damage with a flood below the design basis level of 273.8 feet because of the unsealed penetrations in manhole 1. 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, the inspectors utilized Section B, External Event Mitigation Systems (Seismic/Fire/Flood/Severe Weather Protection Degraded), of Appendix A and determined the finding involved the loss or degradation of equipment or function specifically designed to mitigate a flooding initiating event, which requires the inspector to go to Exhibit 4, External Events Screening Questions. The inspectors determined that a detailed risk evaluation (DRE) was needed because the loss of equipment and function would degrade two or more trains of a multi-train system or function, and the loss of equipment and function would degrade one or more trains of a system that supports a risk-significant system or function. The staff determined that, currently, there is not an existing SDP risk tool that is suitable to assess the significance of this finding with high confidence, mainly because of the uncertainties associated with extreme flood frequency extrapolations based on limited available historical data. Therefore, the risk evaluation was performed using IMC 0609, Appendix M, Significance Determination Process Using Qualitative Criteria. The change in core damage frequency (CDF) estimates ranged from Green, a finding of very low safety significance, to Yellow, a finding of substantial safety significance. A significance and enforcement review panel (SERP) held on January 28, 2014, made a preliminary determination that the finding was of low to moderate safety significance (White) based on quantitative and qualitative evaluations. This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, because CENG personnel did not thoroughly evaluate problems such that the resolutions addressed causes. Such evaluations should include properly classifying, prioritizing, and evaluating operability and reportability of conditions adverse to quality. Specifically, CENG personnel had an opportunity to thoroughly evaluate and assess impacts to the plant such that resolutions addressed causes, when two unsealed penetrations into battery room B were identified in May 2013; CENGs evaluation associated with CR-2013-003407 was not thorough and did not consider all flow paths for flooding through manhole 1. Additionally, the condition adverse to quality was not properly evaluated for operability. CENG personnel had an additional opportunity to thoroughly evaluate and assess impacts to the plant such that resolutions addressed causes and properly evaluate for operability when inspectors presented evidence of degraded manhole 1 conditions, e.g., clogged manhole drains, to CENG management on September 5, 2013 P.1(c). |
| Site: | Ginna  |
|---|---|
| Report | IR 05000244/2013005 Section 1R01 |
| Date counted | Dec 31, 2013 (2013Q4) |
| Type: | Violation: White |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.01 |
| Inspectors (proximate) | A Ziedonis B Pinson D Schroedera Bolgerc Cahill D Dodson M Patel M Scott N Perry T Hedigan T Moslakb Klukard Schroeder M Mclaughlin M Scott R Lorson |
| Violation of: | 10 CFR 50 Appendix B Criterion XVI |
| CCA | P.2, Evaluation |
| INPO aspect | PI.2 |
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Finding - Ginna - IR 05000244/2013005 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Ginna) @ 2013Q4
Self-Identified List (Ginna)
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