05000271/FIN-2013005-01
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Finding | |
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Title | Inadequate Corrective Actions to Restore Switchgear Room Flood Boundary |
Description | A self-revealing cited violation of Title 10 Code of Federal Regulations (10 CFR) 50, Appendix B, Criterion XVI, Corrective Action, was identified because Entergy did not promptly correct two separate conditions adverse to quality related to flood protection of the switchgear rooms. Specifically, within one conduit a mechanical screw-type flood seal that rotated in place was removed and not promptly replaced with a reliable foam seal and within a second conduit a mechanical screw-type flood seal was left installed and not promptly replaced with a reliable foam seal, allowing for two flooding pathways into the switchgear rooms. The inadequate seals were identified on March 23, 2013, following water intrusion into the switchgear room manholes, and the NRC documented a Green NCV in Inspection Report (IR) 05000271/2013003, ML13224A068; however, the intended corrective actions were not implemented. This violation is cited because Entergy failed to restore compliance within a reasonable period of time after the initial NCV was identified. On November 7, 2013, Entergy restored compliance by installing a SYLGARD foam seal in both the MH-S2 Spare-4 conduit and MH-S2 40805B conduit. This finding is more than minor because it is associated with the protection against external events attribute of the Mitigating Systems cornerstone and affected the objective to ensure the availability and reliability of systems that respond to external events to prevent undesirable consequences. Specifically, the failed flood barriers provided an external flooding pathway that could impact the reliability and availability of both electrical switchgear rooms during a design basis flood event. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 4 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, the inspectors determined that this finding was of very low safety significance (Green) because, in spite of the failed flood barriers, sufficient water removal capability was available to ensure there was no loss of electrical switchgear safety function. The switchgear would still have been able to perform its function because the water level would have been maintained below floor level using the additional sump pump capacity available on site. The inspectors determined that the finding has a cross-cutting aspect in the area of Human Performance, Resources component, because Entergy did not have complete, accurate, and up-to-date design documentation, drawings, and procedures for the switchgear room manhole conduit seals. Specifically, Entergy did not establish a flood seals program and program document, procedure, or drawing that tracked which conduits had mechanical screw-type flood seals and which had SYLGARD foam seals H.2(c). |
Site: | Vermont Yankee |
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Report | IR 05000271/2013005 Section 1R06 |
Date counted | Dec 31, 2013 (2013Q4) |
Type: | Violation: Green |
cornerstone | Mitigating Systems |
Identified by: | Self-revealing |
Inspection Procedure: | IP 71111.06 |
Inspectors (proximate) | C Lally J Furia J Laughlin J Schoppy R Mckinley S Rich S Rutenkrogerj Furiar Latta R Mckinley S Rich S Rutenkroger T Hedigan |
Violation of: | 10 CFR 50 Appendix B Criterion XVI |
CCA | H.7, Documentation |
INPO aspect | WP.3 |
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Finding - Vermont Yankee - IR 05000271/2013005 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Vermont Yankee) @ 2013Q4
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