05000445/FIN-2015002-04
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Finding | |
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| Title | Failure to Evaluate and Appropriately Approve Design Changes |
| Description | The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, associated with the licensees failure to ensure that design changes were subject to design control measures commensurate with those applied to the original design and were approved by the designated responsible organization. Specifically, the licensee changed required embedment depths for safety-related concrete expansion anchors associated with manhole covers but failed to re-perform the design calculation to demonstrate that the new embedment depth was sufficient for tornado loading. The licensee performed an operability determination which established a reasonable expectation for operability pending final resolution of the issue. This issue was entered into the licensees corrective action program as Condition Report CR-2015-003152. The licensees failure to ensure that changes to the facility were subject to design control measures commensurate with those applied to the original design, and were approved by the designated responsible organization was a performance deficiency. This performance deficiency was more than minor, and therefore a finding, because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affected the associated objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee changed required embedment depths for safety-related concrete expansion anchors associated with manhole covers but failed to re-perform the design calculation to demonstrate that the new embedment depth was sufficient for tornado loading. Using Inspection Manual Chapter (IMC) 0609, Appendix A, The Significance Determination Process (SDP) for Findings AtPower, dated June 19, 2012, inspectors determined that this finding was of very low safety significance (Green) because the finding: (1) was not a deficiency affecting the design and qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality, (2) did not represent a loss of system and/or function, (3) did not represent an actual loss of function of at least a single train for longer than its allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time, and (4) does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety significant for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in accordance with the licensees maintenance rule program. The inspectors determined that this finding does not have a cross-cutting aspect because the most significant contributor of this finding occurred more than three years ago and does not reflect current licensee performance. |
| Site: | Comanche Peak  |
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| Report | IR 05000445/2015002 Section 4OA2 |
| Date counted | Jun 30, 2015 (2015Q2) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71152 |
| Inspectors (proximate) | C Cowdrey E Schrader G Guerra J Josey J Kirkland J Larsen M Bloodgood M Williams P Elkmann R Kumana T Farina T Hipschman |
| Violation of: | 10 CFR 50 Appendix B Criterion III, Design Control Technical Specification |
| INPO aspect | |
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Finding - Comanche Peak - IR 05000445/2015002 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Comanche Peak) @ 2015Q2
Self-Identified List (Comanche Peak)
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