05000387/FIN-2014009-01
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Finding | |
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| Title | |
| Description | The inspectors identified a Green non-cited violation (NCV) of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for PPLs failure to take adequate corrective actions for a condition adverse to quality involving the emergency service water (ESW) and residual heat removal service water (RHRSW) systems. Specifically, PPL did not take timely and appropriate corrective actions to address carbon steel pipe wall thinning on the B ESW and B RHRSW discharge piping on the lower level of the ESW pump house. PPL completed immediate corrective actions including cleaning the affected piping, conducting ultrasonic testing (UT) thickness testing of the affected piping, calculating acceptance criteria for the UT tests (minimum wall thickness), and calculating a degradation rate of the piping given worst case historical corrosion and water in the environment. Additional actions included initiation of multiple condition reports (CR) to enter the issues into the corrective action program (CR-2014-18803, CR-2014-18945, CR-2014-18932), and plans to add the piping to the PPL Pipe Corrosion Program (PCP) for trending and future examination consideration. The finding is more than minor because if left uncorrected, the performance deficiency had the potential to lead to a more significant safety concern. Specifically, the wetting and associated external corrosion of the piping without appropriate monitoring could adversely impact the structural integrity of the B RHRSW and ESW headers. In addition, the finding is similar to the example 3.i in Inspection Manual Chapter (IMC) 0612 Appendix E, Examples of Minor Issues, because PPL had to perform calculations to assess whether the actual wall thickness met minimum structural integrity requirements. In accordance with IMC 0609, Significance Determination Process, Attachment 4, Initial Characterization of Findings, Table 2, Cornerstones Affected by Degraded Condition or Programmatic Weakness, inspectors determined this performance deficiency affected the Mitigating Systems Cornerstone. Using IMC 0609, Appendix A, The SDP for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, issued June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) because the finding does not represent an actual loss of function of one or more non-Tech Spec Trains of equipment designated as high safety-significant in accordance with PPLs maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The inspectors determined that this finding had a human performance cross-cutting aspect related to Consistent Process because PPL did not use their decision making process consistently to re-evaluate decisions to ensure they remained appropriate when previous decisions were called into question. Specifically, despite repeated identification of pipe wetting conditions and observations of worsening corrosion, plant personnel did not reevaluate structural integrity. Additionally, plant personnel used an inconsistent approach in dealing with the issue, as was demonstrated by the difference in treatment to prevent corrosion on the A train of the RHRSW and ESW systems. [H.13] |
| Site: | Susquehanna  |
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| Report | IR 05000387/2014009 Section 4OA2 |
| Date counted | Jun 30, 2014 (2014Q2) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71152 |
| Inspectors (proximate) | A Defrancisco B Bickett F Bower T Daun |
| Violation of: | 10 CFR 50 Appendix B Criterion XVI |
| CCA | H.13, Consistent Process |
| INPO aspect | DM.1 |
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Finding - Susquehanna - IR 05000387/2014009 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Susquehanna) @ 2014Q2
Self-Identified List (Susquehanna)
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