05000400/FIN-2015003-05
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Finding | |
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| Title | Failure to implement EQ Program Requirements |
| Description | The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion XVI, for the licensees failure to identify and correct a condition adverse to quality affecting the Environmental Qualification (EQ) Program. Specifically, the licensee failed to enter into the CAP the results of the vendor audit of the EQ program which resulted in the licensee blocking open D10 and D11 on June 16, 2015 while the unit was at 100 percent power. The resident inspectors questioned the main control room (MCR) about the doors being open and the licensee immediately closed D10 and D11. The licensee has entered the violation into their CAP as AR 754721, implemented interim guidance as an operations standing instruction (2015-024) not to open D10 or D11 while in mode 1-4. The opening of the tornado door between the main steam tunnel (MST) and the reactor auxiliary building (RAB) was a performance deficiency. The finding was screened in accordance with NRC IMC 0609.04, Initial Characterization of Findings, dated July 7, 2012. The finding was determined to affect the Initiating Events Cornerstone as the MST to RAB tornado door represented a barrier which left RAB systems and components vulnerable to harsh environment conditions should a high energy line break (HELB) occur during the time the doors were open. SDP screening determined that the finding could have affected equipment used to mitigate a LOCA, could have caused a reactor trip, could have resulted in internal flooding conditions, and could have affected equipment relied upon to transition the plant to a stable shutdown condition and required a detailed risk evaluation. A detailed risk evaluation was performed by a regional SRA in accordance with NRC IMC 0609 Appendix A. The major analysis assumptions included: a twenty hour exposure interval, HELBs postulated in all steam and feedwater piping in the MST, pipe break frequency from EPRI Report 1021086, no recovery credit for door closure, and a bounding CCDP value utilized. The CCDP was estimated using the NRC Shearon Harris SPAR model assuming a reactor trip initiator and bounding assumptions that the postulated RAB harsh environmental and flooding conditions would cause failure of the following equipment: auxiliary feedwater system, alternate seal injection system, RAB essential services chillers, component cooling water pumps, charging and safety injection pumps, and the residual heat removal pumps. The dominant sequence was a reactor trip, success of the reactor protection system, and failure of the reactor coolant pump (RCP) seals leading to an unmitigated RCP seal LOCA. The risk was mitigated by the short exposure period and the probability of steam and feedwater HELBs. The analysis determined that the finding represented an increase in core damage frequency of < 1.0 E-6/year, a GREEN finding of very low safety significance. This finding has a cross-cutting aspect in the area of Problem Identification and Resolution in the Corrective Action component because the licensee did not take appropriate corrective actions to address safety issues in a timely manner. |
| Site: | Harris  |
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| Report | IR 05000400/2015003 Section 4OA2 |
| Date counted | Sep 30, 2015 (2015Q3) |
| Type: | NCV: Green |
| cornerstone | Initiating Events |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71152 |
| Inspectors (proximate) | B Caballero G Hopper J Austin J Dodson M Bates M Riches |
| Violation of: | 10 CFR 50 Appendix B Criterion XVI |
| CCA | P.3, Resolution |
| INPO aspect | PI.3 |
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Finding - Harris - IR 05000400/2015003 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Harris) @ 2015Q3
Self-Identified List (Harris)
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