05000382/FIN-2012008-03

Finding

Title

Failure to Take Timely Corrective Action to Establish a Basis for Flood Control Measures

Description

The team identified a cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control , for the failure to establish measures to assure that applicable regulatory requirements and the design basis as defined in 10 CFR 50.2 are correctly translated into procedures. Specifically, the licensee has not determined a basis for the level at which flood control measures are initiated, two years after receiving a non-cited violation for the same deficiency. As an interim compensatory measure for a previous violation of inadequate technical specifications, the licensee modified their flooding procedure to include an action to start shutting flood control doors at a river level of 24 feet instead of 27 feet. The licensee recognized the need to establish a basis for initiating these actions at 24 feet, and issued a corrective action to track completion. The licensee extended the due date several times and had not completed it by the arrival of the inspection team. The inspection team questioned why the licensee had not completed the calculation to justify their basis for their compensatory measures, noting that it had been over two years since the original violation was identified. The inspectors verified through walk-downs, procedure reviews, and historical data that the licensees use of 24 feet did not represent an immediate operability concern, and that the current river level was sufficiently low to allow time for the licensee to correct the deficiency. This finding was entered into the licensees corrective action program as condition report CR-WF3-2012-03752. The failure to complete the corrective action to establish a basis for flood control measures in a timely manner was a performance deficiency. The performance deficiency was more than minor because it was associated with the protection from external events attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to verify through calculations or analysis that the actions taken to secure flood doors could be completed in time to protect safety related equipment from flooding due to a levee failure. In accordance with NRC Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, the issue was determined to affect the Mitigating Systems Cornerstone. In accordance with NRC Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings at Power , the issue was determined to have very low safety significance (Green) because it did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding, or severe weather initiating event. Specifically, the inspectors confirmed that the licensee could reasonably ensure the flood control doors could perform their safety function. This finding had a cross-cutting aspect in the human performance area, resources component in that the licensee failed to maintain long term plant safety by maintenance of design margins and ensuring engineering backlogs low enough to support safety.

03
Site:	Waterford
Report	IR 05000382/2012008 Section 4OA2
Date counted	Sep 30, 2012 (2012Q3)
Type:	Violation: Green
cornerstone	Mitigating Systems
Identified by:	NRC identified
Inspection Procedure:	IP 71152
Inspectors (proximate)	G Miller P Jayroe S Crane A Sanchez C Speer E Rueschr Smithm Young D Overland R Kellar R Kumana
CCA	H.6, Design Margins
INPO aspect	WP.2
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v • d • e

Finding - Waterford - IR 05000382/2012008

1(0)2(2)3(3)4(4)5(5)6(0)7(2)8(6)9(0)10(0)11(0)201(0)202(1)301(0)403(4)404(2)405(0)503(0)801(0)1(0)15(0)

IR 05000382/2012008: 1 2 3 4 5 6

Finding List (Waterford) @ 2012Q3

CCA Matrix: 2012Q3

	Q	CCA	Title
05000382/FIN-2011005-01	2011Q4	H.14	Inoperable Train of Containment Cooling System
05000382/FIN-2011005-03	2011Q4		Failure to Periodically Update the Updated Final Safety Analysis Report
05000382/FIN-2011007-08	2011Q4	P.6	Failure to Adequately Manage the Risk Involved with a Maintenance Window for the Turbine Driven Essential Feedwater Pump
05000382/FIN-2011007-07	2011Q4	H.14	Failure to Provide an Adequate Basis for Temperature Limits of Auxiliary Component Cooling Water Pump Motor Bearings
05000382/FIN-2011007-06	2011Q4		Failure to Establish an Analysis of the Effect of Reverse Rotation of Dry Cooling Tower Fan Motors Resulting from a Tornado Event
05000382/FIN-2011007-05	2011Q4		Failure to Establish an Analysis to Support the Adequacy of the Four Inch Bulkhead Drain to Protect the Ultimate Heat Sink During Flood Events
05000382/FIN-2011007-04	2011Q4		Failure to Provide Adequate Preventive Maintenance Procedures for Aluminum/Copper Electrical Connections to the Ultimate Heat Sink Transformers
05000382/FIN-2011007-03	2011Q4		Failure to Provide an Adequate Basis for Extrapolation of Vendor Supplied Pump Net Positive Suction Head Values
05000382/FIN-2011007-02	2011Q4		Failure to Establish an Adequate Containment Spray Pump Design Basis Verification Surveillance Test
05000382/FIN-2011007-01	2011Q4		Failure to Assure Design Basis Input was Correctly Translated into Design Basis Calculations
05000382/FIN-2011005-05	2011Q4		Failure to Follow Work Order Instructions to Install a Swagelok Fitting on a Main Feedwater Isolation Valve Tube Connection
05000382/FIN-2011005-04	2011Q4	H.7	Failure to Translate Tornado Impact on the Ultimate Heat Sink During a Refueling Outage
05000382/FIN-2011005-02	2011Q4	P.5	Failure to Identify and Correct a Condition Adverse to Quality Associated with the Main Feedwater Isolation Valves
05000382/FIN-2012002-01	2012Q1		Failure to Develop Preventive Maintenance Tasks for Critical Limit Switches on Component Cooling Water Inlet Isolation Valves
05000382/FIN-2012002-02	2012Q1	H.7	Failure to Identify and Perform Testing to Demonstrate Performance of SAFETY-RELATED Valves
05000382/FIN-2012007-02	2012Q1		Failue to Calculate Adequate Cooling Provided to Diesel Generator B within Required Time
05000382/FIN-2012007-01	2012Q1		Failure to Adequately Evaluate the Impact of Fire Damage on the Dry Cooling Tower Fans
05000382/FIN-2012202-01	2012Q2	P.1	Security
05000382/FIN-2012003-02	2012Q2	H.14	Failure to Provide Adequate Design Control Measures for Verifying or Checking the Adequacy of the Ultimate Heat Sink Thermal Performance Analysis
05000382/FIN-2012003-01	2012Q2	H.7	Failure to Establish Adequate Procedural Guidance to Control Feedwater Heater Level Control Valves
05000382/FIN-2012004-03	2012Q3	P.2	Failure to Identify and Correct a Torn Diaphragm of a SAFETY-RELATED Air Operated Valve Associated with the Emergency Feedwater System
05000382/FIN-2012004-04	2012Q3	H.13	Failure to Adequately Access and Manage Risk Before Performing Maintenance Activities Associated with NON-STANDARD Lifts
05000382/FIN-2012004-02	2012Q3	P.2	Failure to Identify and Correct Degraded Conditions Associated with the Auxiliary Component Cooling Water Heat Exchanger Outlet Temperature Control Valve
05000382/FIN-2012004-01	2012Q3	P.5	Failure to Establish Procedural Controls to Ensure That Licensed Operators Could Perform Immediate and Time Critical Operator Actions Associated with Security and Fire Events
05000382/FIN-2012008-01	2012Q3	P.5	Failure to Promptly Determine the Operability of the Emergency Diesel Generators
05000382/FIN-2012008-02	2012Q3	H.6	Failure to Take Corrective Action Associated with Emergency Feedwater Pump AB
05000382/FIN-2012008-03	2012Q3	H.6	Failure to Take Timely Corrective Action to Establish a Basis for Flood Control Measures
05000382/FIN-2012008-04	2012Q3	H.8	Failue to Ensure Operator Knowledge of Equipment Status
05000382/FIN-2012008-05	2012Q3	H.8	Failure to Develop Effective Corrective Actions to Preclude Repetition
05000382/FIN-2012403-01	2012Q3		Security
05000382/FIN-2012403-02	2012Q3	H.14	Security
05000382/FIN-2012403-03	2012Q3	H.10	Security
05000382/FIN-2012403-04	2012Q3	H.9	Security

Self-Identified List (Waterford)

	Q	Title
05000382/FIN-2011005-06	2011Q4	Licensee-Identified Violation
05000382/FIN-2012003-03	2012Q2	Licensee-Identified Violation
05000382/FIN-2012008-06	2012Q3	Licensee-Identified Violation

[Waterford Findings full list]

05000382/FIN-2012008-03

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