05000333/FIN-2015003-02
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Finding | |
|---|---|
| Title | Inadequate Instructions for Reactor Building Roof Replacement Result in Inadvertent Loss of Secondary Containment |
| Description | The inspectors identified a self-revealing violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, because FitzPatrick staff failed to provide instructions appropriate to the reactor building roof replacement project. Specifically, inadequate instructions were provided to ensure that roofing material removal would be performed in slow, deliberate manner, such that its effect on secondary containment could be assessed and operability maintained. As a result, this activity caused secondary containment to be inoperable for a period in excess of its four hour technical specification (TS) allowed outage time. As immediate corrective action, roofing material removal was stopped and the new roofing materials were installed to reseal the affected area of the reactor building roof. Secondary containment vacuum was restored to greater than the TS-required minimum after a period of 92 minutes and secondary containment was declared operable after a period of five hours and 26 minutes. The issue was entered into the corrective action program (CAP) as CRJAF- 2015-03260. The finding was more than minor because it is associated with the procedure quality attribute of the Barrier Integrity cornerstone, and affected the cornerstone objective to provide reasonable assurance that physical design barriers (fuel cladding, reactor coolant system (RCS), and containment) protect the public from radionuclide releases caused by accidents or events. Specifically, the work order (WO) did not provide adequate instruction to ensure that roofing material removal would be performed in slow, deliberate manner, coordinated between operations and maintenance personnel, and allowing adequate time after actions that could impact secondary containment such that their effect on secondary containment could be assessed and operability maintained. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 3 of IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At- Power, the inspectors determined that this finding was of very low safety significance (Green) because the performance deficiency was not a pressurized thermal shock issue, did not represent an actual open pathway in the physical integrity of the reactor containment, did not involve an actual reduction in function of hydrogen igniters in the reactor containment, and only represented a degradation of the radiological barrier function provided by the reactor building and standby gas treatment system. The finding had a cross-cutting aspect in the area of Human Performance, Avoid Complacency, because FitzPatrick staff did not adequately plan for the possibility of latent issues and inherent risk associated with the reactor building roof replacement project, such that the commencement of work resulted in a loss of secondary containment. |
| Site: | FitzPatrick  |
|---|---|
| Report | IR 05000333/2015003 Section 4OA3 |
| Date counted | Sep 30, 2015 (2015Q3) |
| Type: | NCV: Green |
| cornerstone | Barrier Integrity |
| Identified by: | Self-revealing |
| Inspection Procedure: | IP 71153 |
| Inspectors (proximate) | A Burritt B Sienel E Knutson P Kaufman R Rolph |
| Violation of: | 10 CFR 50 Appendix B Criterion V Technical Specification Technical Specification - Procedures |
| CCA | H.12, Avoid Complacency |
| INPO aspect | QA.4 |
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Finding - FitzPatrick - IR 05000333/2015003 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (FitzPatrick) @ 2015Q3
Self-Identified List (FitzPatrick)
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