05000400/FIN-2015002-02
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Finding | |
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| Title | Failure to Adequately Implement the Control Room Area HVAC System Procedure |
| Description | An NRC-identified Green non-cited violation (NCV) of Technical Specification (TS) 6.8.1, Procedures and Programs, was identified for the licensees inadequate implementation of procedure OP-173, Control Room Area HVAC System. Specifically, the licensee failed to adequately implement OP-173 Section 8.3, Placing the Control Room Area HVAC System into Recirculation Manually, and maintain a positive pressure in the main control room (MCR). The licensee entered this issue into the corrective action program (CAP) as action request (AR) 742947, and restored a positive pressure in the MCR. The licensee also revised the associated procedure OWP-RM-01, Control Room OAI [outside air intake] Radiation Monitors, to ensure appropriate actions are taken for the outside air intake supply when radiation monitors are inoperable. The failure to maintain positive pressure in the MCR in accordance with OP-173 was a performance deficiency. The performance deficiency was determined to be more than minor in accordance with IMC 0612, Appendix B, since it was associated with the procedure quality attribute of the barrier integrity cornerstone and adversely affected the cornerstone objective and, if left uncorrected, the performance deficiency would have the potential for leading to a more significant safety concern. Specifically, the buildup of carbon dioxide (CO2) would impair operators performance and actions. The inspectors evaluated the finding using Inspection Manual Chapter 0609, Significance Determination Process, Attachment 4 and Appendix G (June 19, 2012), Shutdown Operations Significance Determination Process. The inspectors determined the finding was associated with the barrier integrity cornerstone and required a detailed risk evaluation because the finding involved control room habitability during both normal and accident conditions. A detailed risk evaluation was completed by a regional SRA using the guidance of NRC IMC 0609 Appendix G and Appendix F, Fire Protection Significance Determination Process. A bounding analysis was performed considering potential demands on MCR habitability due to radiation and smoke effects. The major analysis assumptions included: an eleven day exposure period, recovery credit for MCR door closure, shutdown core damage radiation and fuel pool radiation events were considered. The dominant sequence was a fire impacting the MCR with smoke, failure of operators to isolate the MCR resulting in loss of the operators leading to loss of core heat removal. The risk of the performance deficiency was mitigated by the low initiating event probabilities and the recovery likelihood of MCR door closure. The result of the analysis was an increase in core damage frequency of < 1.0E-6/year, a green finding of very low safety significance. The finding had a cross-cutting aspect of Procedure Adherence, as described in the Human Performance cross-cutting area because the licensee failed to comply with OP-173. |
| Site: | Harris  |
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| Report | IR 05000400/2015002 Section 1R15 |
| Date counted | Jun 30, 2015 (2015Q2) |
| Type: | NCV: Green |
| cornerstone | Barrier Integrity |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.15 |
| Inspectors (proximate) | R Kellner R Williams W Loo W Pursley A Butcavage A Sengupta G Hopper J Austin J Parent M Riches P Lessard R Hamilton |
| Violation of: | Technical Specification - Procedures Technical Specification |
| CCA | H.8, Procedure Adherence |
| INPO aspect | WP.4 |
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Finding - Harris - IR 05000400/2015002 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Harris) @ 2015Q2
Self-Identified List (Harris)
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