05000354/FIN-2014003-01
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Finding | |
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| Title | Inadequate Procedural Guidance for Responding to an Internal Flooding Event in the HPCI and RCIC Rooms |
| Description | The inspectors identified a Green NCV of TS 6.8.1.a, Procedures because PSEG procedures HC.OP-AR.ZZ-0006 and HC.OP-AR.ZZ-0022 could potentially complicate an internal flooding event and adversely affect assumptions in Hope Creeks flood design. Specifically, the procedures did not ensure operator response would not communicate the high pressure coolant injection (HPCI) and reactor core isolation cooling (RCIC) watertight rooms and potentially render two safety-significant single train systems inoperable. In addition to entering the issue into the corrective action program (CAP) as NOTFs 20646334, 20646335 and 20620653586, PSEGs corrective actions include a planned revision of the annunciator response procedures and issuance of a standing order to the Operations department staff. The performance deficiency is more than minor because it was associated with the procedure quality attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, PSEG procedures HC.OP-AR.ZZ-0006 and HC.OP-AR.ZZ-0022 could potentially complicate an internal flooding event and adversely affect assumptions in Hope Creeks flood design, since the procedures did not ensure operator response would not communicate the HPCI and RCIC watertight rooms and potentially render multiple trains of safety-related SSCs inoperable. This performance deficiency was also similar to examples 3.j and 3.k of NRC IMC 0612, Appendix E, in that communicating the two watertight rooms created a reasonable doubt of operability of the HPCI and RCIC systems. PSEG plans to perform a detailed technical evaluation to evaluate the impact of internal flood propagation in the HPCI and RCIC rooms. The finding was evaluated in accordance with Exhibits 2 and 4 of NRC IMC 0609, Appendix A, The SDP for Findings At-Power, dated June 19, 2012. Since opening the watertight door during an internal flooding event could bypass the flood protection feature and potentially degrade two or more trains of a multi-train system or function, a detailed risk assessment was performed. The finding was determined to be of very low safety significance (Green). Since the change in core damage frequency was sufficiently low, no further evaluation for large early release was required. The inspectors determined that the finding had a cross cutting aspect in the Human Performance area associated with Training, in that PSEG did not provide adequate training and ensure knowledge transfer to maintain a knowledgeable, technically competent workforce and instill nuclear safety values. Specifically, operator training did not ensure operator response to internal flooding would not result in communicating two watertight rooms containing safety significant single-train systems. |
| Site: | Hope Creek  |
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| Report | IR 05000354/2014003 Section 1R06 |
| Date counted | Jun 30, 2014 (2014Q2) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.06 |
| Inspectors (proximate) | G Dentel H Gray J Hawkins S Ibarrola |
| Violation of: | Technical Specification - Procedures Technical Specification |
| CCA | H.9, Training |
| INPO aspect | CL.4 |
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Finding - Hope Creek - IR 05000354/2014003 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Hope Creek) @ 2014Q2
Self-Identified List (Hope Creek)
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