05000317/FIN-2015010-01
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Finding | |
|---|---|
| Title | Untimely Actions to Test or Inspect DFO Check Valves Relied on for Safety |
| Description | The inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50, Appendix B, Criterion XVI, Corrective Action, because Exelon did not assure that conditions adverse to quality were promptly corrected. Specifically, from November 2012, until October 28, 2015, Exelon did not ensure that diesel fuel oil (DFO) transfer system header check valves DFO-146 and DFO-148 were properly tested or inspected to ensure they would perform their safety function. This issue was previously documented as a NCV of 10 CFR 50, Appendix B, Criterion XI, Test Control, in inspection report 05000317, 318/2013003. The inspectors determined that not promptly correcting a condition adverse to quality previously documented in an NCV was a performance deficiency that was within Exelons ability to foresee and prevent. This finding is more than minor because it is associated with the protection against external factors attribute of the Mitigating Systems cornerstone and affects the cornerstone objective of ensuring the capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the safety function of DFO-146 and DFO-148, to close on the failure of a fuel oil storage tank to prevent draining the unaffected tank had never been verified though test or inspection since initial plant construction; therefore, reasonable doubt exists whether the valves remained capable of performing that function. The inspectors evaluated the significance of this finding using IMC 0609, Appendix A, The Significance Determination Process for Findings at Power, Exhibit 2, Mitigating Systems Screening Questions. The inspectors determined that this finding was of very low safety significance (Green) because the finding did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding, or severe weather event. The inspectors determined that this finding had a cross-cutting aspect in the area of Human Performance Procedure Adherence because Exelon staff did not follow station processes, procedures, and work instructions. Specifically, Exelon staff did not ensure corrective action due date extensions and cancellations were justified, evaluated for adverse consequences, and presented to the Management Review Committee (MRC) as required by station procedures. As a result, corrective actions to restore compliance were not completed in a timely manner. |
| Site: | Calvert Cliffs  |
|---|---|
| Report | IR 05000317/2015010 Section 4OA2 |
| Date counted | Dec 31, 2015 (2015Q4) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71152 |
| Inspectors (proximate) | D Schroeder J Deboer L Micewski R Clagg |
| Violation of: | 10 CFR 50 Appendix B Criterion XVI 10 CFR 50 Appendix B Criterion XI |
| CCA | H.8, Procedure Adherence |
| INPO aspect | WP.4 |
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Finding - Calvert Cliffs - IR 05000317/2015010 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Calvert Cliffs) @ 2015Q4
Self-Identified List (Calvert Cliffs)
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