05000382/FIN-2013003-01

Finding

Title

Failure to provide design control measures to withstand the effects of flooding on the reactor auxiliary building roof

Description

The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, because the licensee did not provide design control measures for verifying or checking the adequacy of the features designed to withstand the effects of a probable maximum precipitation (PMP) flooding event on the reactor auxiliary building (RAB) roof areas. Specifically, the licensee did not provide an analysis to demonstrate that adequate flood protection existed from the effects of a PMP flooding event on safety-related components and electrical equipment located on the roof of the RAB in the main steam isolation valve (MSIV) wing areas. As a result, the licensee did not perform an analysis to determine if expected ponding levels from a PMP flooding event would challenge safety-related components and electrical equipment such as the emergency feedwater flow control and isolation valves and cables, main steam isolation valves and cables, atmospheric dump valves, and back-up nitrogen accumulator components. The licensee entered this issue into their corrective action program as CR-WF3-2012- 7520. The immediate corrective actions taken to restore compliance included the performance of a preliminary analysis to show that the installed scuppers and roof drains have margin to protect against a local PMP flooding event and that the ponding depth would have little or no affect on the safety-related equipment and cables located in the MSIV wing areas. The failure to provide design control measures for verifying or checking the adequacy of the features designed to withstand the effects of a local PMP on the RAB roof areas was a performance deficiency. The performance deficiency was more than minor because it was associated with the design control attribute of the Mitigating System 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 safety-related equipment located on the RAB roof in the MSIV wing areas are required to safely shutdown and maintain the reactor in a cold shutdown condition following accidents and anticipated operational occurrences. The inspectors used the NRC Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings and Appendix A, The Significance Determination Process for Findings At-Power, to evaluate this issue. The inspectors determined that the finding was of 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. The inspectors concluded that the finding reflected current licensee performance and involved a cross-cutting aspect in the corrective action program component of the problem identification and resolution area in that the licensee did not identify potential flooding issues completely, accurately, and in a timely manner commensurate with their safety significance.

01
Site:	Waterford
Report	IR 05000382/2013003 Section 1R01
Date counted	Jun 30, 2013 (2013Q2)
Type:	NCV: Green
cornerstone	Mitigating Systems
Identified by:	NRC identified
Inspection Procedure:	IP 71111.01
Inspectors (proximate)	M Davis G George D Allen R Azua M Baquera N Okonkwo M Williams D Bradley
Violation of:	10 CFR 50 Appendix B Criterion III, Design Control
CCA	P.1, Identification
INPO aspect	PI.1
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v • d • e

Finding - Waterford - IR 05000382/2013003

0(0)1(0)2(3)3(5)4(4)5(3)6(0)7(1)8(1)403(0)404(2)406(0)501(0)502(0)

IR 05000382/2013003: 1 2 3 4 5

Finding List (Waterford) @ 2013Q2

CCA Matrix: 2013Q2

	Q	CCA	Title
05000382/FIN-2012403-04	2012Q3	H.9	Security
05000382/FIN-2012403-03	2012Q3	H.10	Security
05000382/FIN-2012403-02	2012Q3	H.14	Security
05000382/FIN-2012403-01	2012Q3		Security
05000382/FIN-2012008-05	2012Q3	H.8	Failure to Develop Effective Corrective Actions to Preclude Repetition
05000382/FIN-2012008-04	2012Q3	H.8	Failue to Ensure Operator Knowledge of Equipment Status
05000382/FIN-2012008-03	2012Q3	H.6	Failure to Take Timely Corrective Action to Establish a Basis for Flood Control Measures
05000382/FIN-2012008-02	2012Q3	H.6	Failure to Take Corrective Action Associated with Emergency Feedwater Pump AB
05000382/FIN-2012008-01	2012Q3	P.5	Failure to Promptly Determine the Operability of the Emergency Diesel Generators
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-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-2012004-03	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-2012005-03	2012Q4		Reactor Auxiliary Building Roof Flood Protection Issue
05000382/FIN-2012005-02	2012Q4	P.2	Failure to Promptly Identify and Correct the Cause of Repetitive Failures Associated with Train a Component Cooling Water Radiation Monitor
05000382/FIN-2012005-01	2012Q4	H.5	Failure to Implement Control Measures to Ensure That Activated Materials Were Not Raised Above or Brought Near the Surface of the Refueling Pool, Causing a Locked High Radiation Area
05000382/FIN-2013002-03	2013Q1	P.2	Failure to Identify and Perform Testing to Demonstrate Local Manual Operation Action on SAFETY-RELATED AIR-OPERATED Valves
05000382/FIN-2013002-02	2013Q1	H.14	Failure to Perform an Adequate Operability Determination for Nitrogen Leak in MSIV
05000382/FIN-2013002-01	2013Q1	H.7	Failure to Identify and Control Potential Tornado Borne Missle Hazards
05000382/FIN-2012404-02	2013Q1	H.14	Security
05000382/FIN-2012404-01	2013Q1	H.7	Security
05000382/FIN-2013003-05	2013Q2	P.5	Failure to provide adequate post modification testing instructions for vibration monitoring on the feedwater piping system
05000382/FIN-2013003-04	2013Q2		Failure to submit an LER after discovery that manual handwheels on AOVs were not functional
05000382/FIN-2013003-03	2013Q2	H.13	Failure to comply with Action 4 of TS 3.3.1 during shutdown in Modes 4 and 5
05000382/FIN-2013003-02	2013Q2		Failure to Update Fuel Handling Accident Analysis in the Updated Final Safety Analysis Report
05000382/FIN-2013003-01	2013Q2	P.1	Failure to provide design control measures to withstand the effects of flooding on the reactor auxiliary building roof

Self-Identified List (Waterford)

	Q	Title
05000382/FIN-2012008-06	2012Q3	Licensee-Identified Violation
05000382/FIN-2012005-04	2012Q4	Licensee-Identified Violation
05000382/FIN-2012005-05	2012Q4	Licensee-Identified Violation

[Waterford Findings full list]

05000382/FIN-2013003-01

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