05000382/FIN-2013004-03
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Finding | |
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| Title | Failure to Accomplish Activities Affecting Quality on a Degraded Safety-Related Solenoid Valve In Accordance With Procedure Requirements |
| Description | The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, because the licensee did not accomplish activities affecting quality on a degraded safety-related train B component cooling water (CCW) bypass valve (CC-134B) in accordance with maintenance procedure EN-MA-101, Fundamentals of Maintenance. Specifically, the licensee did not control and perform testing on a leaking solenoid valve related to the operation of a safety-related bypass valve (CC-134B) after maintenance personnel removed the degraded equipment from service as required by Section 5.10 of EN-MA-101. As a result, the licensee could not characterize and determine the cause of the leakage for the safety-related valve. The inspectors determined that this would challenge the safety function of the valve to provide CCW to the ultimate heat sink following a tornado event. The licensee entered this condition into their corrective action program as CR-WF3-2012-05991, CR-WF3-2012-06288, and CR-WF3-2013-04047. The immediate corrective actions taken to restore compliance included the installation of a new valve and debriefing personnel about controlling equipment removed from service when combining preventative and corrective maintenance tasks in one work order. The failure to control failed equipment removed from the plant to determine the cause in accordance with maintenance procedure requirements was a performance deficiency. The performance deficiency was more than minor because it was associated with the equipment performance attribute of the Mitigating System 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. Specifically, the degraded condition challenged the safety function of the valve (CC-134B) to limit the loss of CCW through damaged portions of the dry cooling tower fans following a tornado-generated missile strike. The inspectors used the NRC Inspection Manual 0609, Attachment 4, Initial Characterization of Findings, to evaluate this issue. The finding required a detailed analysis because it was potentially risk significant for an external event (tornado). Therefore, the senior reactor analyst performed a bounding detailed risk evaluation. The senior reactor analyst determined that the finding was of very low safety significance (Green). The bounding change to the core damage frequency was less than 3E-7/year. The finding was not significant with respect to the large early release frequency. The dominant core damage sequences included tornado induced losses of offsite power, failure of the dry cooling tower pressure boundary, failure to isolate the damaged dry cooling tower, and failure to recover instrument air. The redundant train A component cooling water system combined with the tornado frequency helped to reduce the risk exposure. The inspectors concluded that the finding reflected current licensee performance and involved a cross-cutting aspect in the work control component of the human performance area in that the licensee did not appropriately coordinate work activities by incorporating actions to address the impact of changes to work scope or activity on plant and human performance. |
| Site: | Waterford  |
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| Report | IR 05000382/2013004 Section 1R19 |
| Date counted | Sep 30, 2013 (2013Q3) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.19 |
| Inspectors (proximate) | L Ricketson M Davis G Werner L Carson E Ruesch C Alldredge C Steely N Greene T Farina J O'Donnell C Speer P Hernandez |
| Violation of: | 10 CFR 50 Appendix B Criterion V |
| CCA | H.5, Work Management |
| INPO aspect | WP.1 |
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Finding - Waterford - IR 05000382/2013004 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Waterford) @ 2013Q3
Self-Identified List (Waterford)
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