05000382/FIN-2014002-01
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Finding | |
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Title | Failure to Establish Procedures for Using the Alternate Emergency Fuel Oil Storage Tank Fill Line |
Description | The inspectors identified a non-cited violation of Technical Specification 6.8.1.a because the licensee did not establish written procedures to fill the diesel fuel oil storage tanks for their emergency onsite power sources. Specifically, the licensee did not establish procedures to fill the fuel oil storage tanks for the emergency diesel generators using the credited safety-related, seismic category 1 emergency fill line. The licensee entered this condition into their corrective action program as Condition Report CR-WF3-2014-00636. The immediate corrective action taken to restore compliance was to develop procedures to fill the emergency diesel generator fuel oil storage tanks using the safety-related, seismic category 1 emergency fill line and evaluate other alternative methods. The inspectors concluded that the failure to establish procedures to fill the fuel oil storage tanks for the emergency onsite power sources was a performance deficiency. The performance deficiency was more than minor because it was associated with the procedure quality attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, it reduced the licensees reliability and capability to fill the fuel oil storage tanks for the onsite power sources following a loss of offsite power or extreme weather event (e.g., a seismic or flooding event) that may last longer than seven days. The inspectors performed the initial significance determination for this issue. The inspectors used NRC Inspection Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, to evaluate the issue. The initial screening directed the inspectors to use Inspector Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At-Power, Exhibit 2, Section A, to determine the significance of the issue. The finding required a detailed risk evaluation because the performance deficiency could have resulted in a loss of safety function (onsite ac power) because the system may not have remained operable for its 30- day design basis accident mission time. Therefore, a Region IV senior reactor analyst performed a detailed risk evaluation for this issue. The analyst determined that the finding was of very low safety significance (Green) because the diesel generators would have remained functional for the 24-hour probabilistic risk assessment mission time. This detailed risk evaluation used the shorter mission time because after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the NRC assumed that the licensee had substantially more resources available to help mitigate the accident. The dominant core damage sequences included longer-term loss of offsite power events and the common cause failure of the diesel generators due to potential problems to refill the diesel fuel oil storage tanks after seven days. The relatively long period prior to ultimate diesel generator failure helped to minimize the risk. Additionally, the finding was not a significant contributor to the large early release frequency. The inspectors concluded that the finding reflected current licensee performance and involved an avoiding complacency cross-cutting aspect of the human performance area in that the licensee did not recognize and plan for the possibility of mistakes, latent issues and inherent risk, even while expecting successful outcomes. |
Site: | Waterford ![]() |
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Report | IR 05000382/2014002 Section 1R04 |
Date counted | Mar 31, 2014 (2014Q1) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.04 |
Inspectors (proximate) | C Speer G Werner J Brand M Davis P Elkmann R Latta S Hedger |
Violation of: | Technical Specification - Procedures Technical Specification |
CCA | H.12, Avoid Complacency |
INPO aspect | QA.4 |
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Finding - Waterford - IR 05000382/2014002 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Waterford) @ 2014Q1
Self-Identified List (Waterford)
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