05000382/FIN-2014002-04
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Finding | |
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| Title | Failure to Establish Adequate Design Control Measures for the Selection and Review for the Suitability of Application of Molded Case Circuit Breakers |
| Description | A self-revealing, non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, occurred because the licensee did not establish design control measures for the selection and review for the suitability of application of a molded case circuit breaker that was essential to the safety-related function of a shutdown cooling heat exchanger fan cooler. Specifically, the licensee did not select and review for the suitability of the correct safety-related circuit breaker for the application to provide circuit fault protection to the train B shutdown cooling heat exchanger air handling unit fan motor. The licensee entered this condition into their corrective action program as Condition Reports CR-WF3-2013-02316 and CR-WF3-2013-04644. The immediate corrective action taken to restore compliance included the replacement of the breaker with a breaker more suitable for the application to protect the air handling unit fan motor. The planned corrective actions included an extent of condition review for other installed breakers and the revision of work order instructions to eliminate the practice of substituting and using the factory acceptance testing for pre-installation and post-maintenance tests, respectively. The inspectors concluded that the failure to establish design control measures for the selection and review for suitability of application for the correct safety-related circuit breaker was a performance deficiency. The performance deficiency was more than minor because it was associated with the design control 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. Specifically, the incorrect breaker affected the availability, reliability, and capability of the shutdown cooling heat exchanger fan coolers to remove heat from the shutdown cooling heat exchanger areas following a design basis accident. The inspectors performed the initial significance determination. The inspectors used the NRC Inspection Manual 0609, Attachment 4, Initial Screening and Characterization of Findings. The initial screening directed the inspectors to use Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, Section A, to determine the significance of the finding. The finding required a detailed risk evaluation because it involved a potential loss of one train of safety-related equipment for longer than the technical specification allowed outage time. The total exposure period was 23 days. The allowed outage time was 7 days. A Region IV senior reactor analyst performed the detailed risk evaluation and determined that the change to the core damage frequency was 5E-13/year (Green). The dominant core damage sequences included loss of offsite power events, failure of both trains of containment spray, and the failure of a pressurizer safety relief valve to remain closed. The equipment that helped mitigate the risk included the emergency diesel generators and the essential feedwater systems. The inspectors concluded that the finding reflected current licensee performance and involved a cross-cutting aspect of avoiding complacency in the human performance area because the licensee did not recognize and plan for the possibility of mistakes, latent issues, and inherent risk on relying on 21 year old vendor information and installing a breaker without pre-installation and adequate post-maintenance testing. |
| Site: | Waterford  |
|---|---|
| Report | IR 05000382/2014002 Section 4OA2 |
| Date counted | Mar 31, 2014 (2014Q1) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | Self-revealing |
| Inspection Procedure: | IP 71152 |
| Inspectors (proximate) | C Speer G Werner J Brand M Davis P Elkmann R Latta S Hedger |
| Violation of: | 10 CFR 50 Appendix B Criterion III, Design Control 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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