05000324/FIN-2013010-01
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Finding | |
|---|---|
| Title | Failure to Identify and Correct Flood Protection Degradation in Safety-Related Buildings |
| Description | The NRC identified an AV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, with two examples. The first example involved the failure of the licensee to promptly identify and correct conditions adverse to quality associated with flood protection of multiple safety-related buildings. Specifically, the licensee failed to promptly identify or correct safety-related buildings that contained openings that would have adversely impacted their ability to mitigate external flooding of these buildings in the event of a design basis probable maximum hurricane (PMH). The second example involved the failure of the licensee to correct a significant condition adverse to quality. Specifically, the licensee failed to implement a corrective action to preclude repetition by not adequately developing an engineering program to mitigate the consequences of external events (flooding, high winds, and seismic) that ensured appropriate equipment classifications, with interfacing programs of maintenance rule (MR) and zero tolerance for equipment failures. This resulted in a violation of technical specification (TS) 3.7.2, Service Water (SW) System and Ultimate Heat Sink, and TS 3.5.2, Emergency Core Cooling System (ECCS) Shutdown, since the inoperability of the required number of service water pumps (SWPs) would violate TS 3.7.2, and TS 3.5.2 since SW cools the residual heat removal (RHR) system heat exchangers. The inspectors determined the failure to identify and correct the missing and degraded flood barriers in multiple safety-related buildings, and the failure to implement a corrective action to preclude repetition by not developing an engineering program to mitigate the consequences of external events that ensured appropriate equipment classifications, with interfacing programs of MR and zero tolerance for equipment failures, was a performance deficiency. The finding was more than minor because it was associated with the protection against external factors attribute (flood hazard) of the Mitigating Systems Cornerstone and adversely affects the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, nine of the ten Unit 1 and Unit 2 SWPs would be potentially inoperable and unavailable during specified PMH events. Because the finding involved reactor shutdown operations and conditions, IMC 0609, Appendix G, Shutdown Operations Significance Determination Process (SDP), Attachment 1, issued May 25, 2004, Phase 1 Operational Checklists for Both pressurized water reactors (PWRs) and boiling water reactors (BWRs), was used. The inspectors used Checklist 5, BWR Hot Shutdown: Time to Boil < 2 Hours, and determined the finding increased the likelihood that a loss of decay heat removal (DHR) will occur due to failure of the system itself or support systems, degraded the licensees ability to cope with a loss of offsite power (LOOP), degraded the licensees ability to add reactor coolant system (RCS) inventory when needed, and degraded the licensees ability to establish an alternate core cooling path if DHR could not be re-established for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Further, the performance deficiency involved external events. Consequently a Phase 2 analysis could not be performed and the issue screened directly to a Phase 3 analysis. The significance of this issue is To Be Determined (TBD) and its final significance will be dispositioned in separate transmittal. The issue is not an immediate safety concern because the licensee has taken appropriate corrective actions. The finding has a cross-cutting aspect in the area of human performance associated with the field presence attribute because deviations from standards and expectations were not corrected promptly, and the licensee did not ensure supervisory and management oversight of work activities, including contractors. Specifically, licensee management failed to ensure degradation associated with flood protection of the safety-related buildings was identified and corrected. |
| Site: | Brunswick  |
|---|---|
| Report | IR 05000324/2013010 Section 1R01 |
| Date counted | Dec 31, 2013 (2013Q4) |
| Type: | Violation: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.01 |
| Inspectors (proximate) | G Hopper J Dodson R Bernhard R Croteau C Evans D Jacksong Hopperj Dodson M Lesser R Bernhard S Sparksm Cattsm Schwieg G Hopper |
| Violation of: | 10 CFR 50 Appendix B Criterion XVI Technical Specification |
| CCA | H.2, Field Presence |
| INPO aspect | LA.2 |
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Finding - Brunswick - IR 05000324/2013010 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Brunswick) @ 2013Q4
Self-Identified List (Brunswick)
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