05000352/FIN-2016001-03
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Finding | |
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Title | Inadequate Work Staging and Housekeeping Walkdowns During PreOutage Preparations |
Description | The inspectors identified a Green NCV of technical specification 6.8.1 for Exelons failure to properly control, store, and stage material in accordance with station procedures within Class I buildings during refueling outage preparation. Specifically, Exelon personnel did not secure numerous rolling carts staged in both units, did not secure welding blankets in the common pipe tunnel to prevent blocking floor drains, and did not properly build scaffolds to include engineering approval for scaffold procedure deviations. In addition, Exelons housekeeping and material condition program did not identify and resolve these conditions through the corrective action process during a time of increased activities in the plant. Exelon restrained the carts and other rolling equipment, removed the weld blankets, and removed, reworked, and evaluated scaffolding. This finding is more than minor because it adversely affected the protection against external factors (flood and seismic hazards) attribute of the mitigating systems cornerstone to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, the loose unattended welding blankets would have blocked the pipe tunnel floor drains during an analyzed internal flooding event which would result in structural failures if not identified and corrected by operations personnel; the unrestrained carts would translate and rotate during a seismic event which could potentially impact safety related equipment and challenge the function or barrier; and the scaffold clearance and attachment issues could potentially cause impact with ductwork, cable trays, hangers, and structural supports during a seismic event. In addition, the performance deficiency is similar to the more-than-minor example described in IMC 0612, Appendix E, example 4.A, in that Exelon routinely failed to perform engineering evaluations on similar issues. Using IMC 0609, Appendix A, Exhibit 2, the inspectors determined that this finding was of very low safety significance (Green). Specifically, the finding is a deficiency affecting the design or qualification of mitigating structures, systems, and components, and the actual functions of the structures, systems, and components were maintained. The inspectors determined that this finding has a cross-cutting aspect in the area of Human Performance, Training, because the organization did not provide sufficient training to maintain a knowledgeable workforce with respect to proper material handling and storage, awareness of flood hazards and floor drains, and scaffolding requirements. [H.9] |
Site: | Limerick |
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Report | IR 05000352/2016001 Section 1R20 |
Date counted | Mar 31, 2016 (2016Q1) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.2 |
Inspectors (proximate) | D Schroeder J Furia J Richmond M Fannon R Nimitz S Barber S Rutenkroger J Schussler |
Violation of: | Technical Specification - Procedures Technical Specification |
CCA | H.9, Training |
INPO aspect | CL.4 |
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Finding - Limerick - IR 05000352/2016001 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Limerick) @ 2016Q1
Self-Identified List (Limerick)
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