05000387/FIN-2011003-02
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Finding | |
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Title | Failure to lmplement Risk Management Actions during Dual Unit Elevated Risk |
Description | The inspectors identified a Green NCV of 10 CFR 50.65(aX4), related to the failure by PPL to manage risk for Reactor Building (RB) Plenum maintenance, as assessed, on June 1, 2011 . Specifically, PPL determined that the maintenance would result in an Orange risk for both units. Risk management actions (RMAs) designated in its risk assessment, such as protecting risk significant equipment, were developed as required. However, during an equipment walkdown, the inspectors identified that a significant number of these RMAs were not implemented while the maintenance activity was being preformed. Specifically, the inspectors identified that none of the core spray divisions or safety relief valves (SRVs) on either unit had been protected. The inspectors also identified that Unit 1 Division ll low pressure coolant injection system (LPCI) had not been protected and Unit2 Division I LPCI was only partially protected, Finally, the inspectors identified that some Unit 1 Division ll residual heat removal (RHR) shutdown cooling equipment listed as protected in the Station Leadership Report had not been protected. This issue was documented in PPL\'s CAP as Condition Report (cR) 1441159. The inspectors determined that the performance deficiency was more than minor due to its similarity to examples 3.j and 3.k of IMC 0612, Appendix E, Examples of Minor lssues. The issue also affected the human performance attribute of the Mitigating Systems Cornerstone and the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the issue was programmatic based on the extent of protected equipment deficiencies, and five consecutive quarters of 10 CFR 50.65(aX4) violations. The issue affected the Mitigating Systems cornerstone attribute and objective because of the timing of the violation during dual-unit Orange risk, and that if left uncorrected could lead to more significant issues, such as pre-event human error that impacts mitigating equipment availability during a subsequent initiating event with already elevated plant risk. Since the exposure time of the deficiency was limited to four hours ind with consideration of other RMAs taken by PPL, this finding is determined to be of very low safety significance (Green). This finding was determined to have a cross-cutting aspect in Problem ldentification and Resolution, (Pl&R) CAP. Specifically, although PPL had conducted a root cause analysis (RCA) in response to the adverse trend of 10 CFR 50.65 a(4) violations, interim corrective actions proved inadequate to prevent another violation of this regulation for the fifth consecutive quarter. |
Site: | Susquehanna |
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Report | IR 05000387/2011003 Section 1R13 |
Date counted | Jun 30, 2011 (2011Q2) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.13 |
Inspectors (proximate) | P Kaufman J Furia A Rosebrook P Finney J Brand P Krohn E Torres J Greives |
CCA | P.3, Resolution |
INPO aspect | PI.3 |
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Finding - Susquehanna - IR 05000387/2011003 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Susquehanna) @ 2011Q2
Self-Identified List (Susquehanna)
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