05000445/FIN-2015007-03
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Finding | |
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| Title | Failure to Follow Operability Determination Procedure for Tornado Missile Impact of Diesel Vents |
| Description | The team identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, which states, in part, Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. Operability Determination Procedure STI-422.01 Step 6.2 G, states in part, ODs should be documented in sufficient detail so the basis for the determination can be understood during subsequent reviews....justification for the basis of the operability should be documented. Specifically, on May 4, 2015, the licensee had performed an operability determination for tornado driven missiles impacting the diesel generator fuel oil vent piping. The licensee failed to follow the operability evaluation procedure in that they did not adequately justify the basis of the operability. The team identified that the licensee had not adequately justified the exclusion of horizontally generated missiles in their analysis. In response to this issue, the licensee re-performed the operability determination, using a revised analysis using the correct parameters for horizontal missiles generated by a tornado, and concluded that the diesel generators would still perform their safety function. This finding was entered into the licensees corrective action program as Condition Report CR 2015-005848. The team determined that the licensees failure to follow procedure for performing an operability determination for the diesel generator fuel oil vent piping was a performance deficiency. This finding was more than minor because it was associated with the protection against external factors attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to adequately document the basis for operability of the diesel generator system because it excluded horizontal tornado missiles in the analysis. In accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, Exhibit 2, Mitigating Systems Screening Questions, the issue screened as having very low safety significance (Green) because it was a design or qualification deficiency that did not represent a loss of operability or functionality; did not represent an actual loss of safety function of the system or train; did not result in the loss of one or more trains of non-technical specification equipment; and did not screen as potentially risk significant due to seismic, flooding, or severe weather. The team determined that this finding had a crosscutting aspect in the area of problem identification and resolution, because the organization failed to thoroughly evaluate issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance (P.2). |
| Site: | Comanche Peak  |
|---|---|
| Report | IR 05000445/2015007 Section 1R21 |
| Date counted | Sep 30, 2015 (2015Q3) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.21 |
| Inspectors (proximate) | C Baron C Smith J Watkins R Kopriva S Kobylarz T Farnholtz T Palmer |
| Violation of: | 10 CFR 50 Appendix B Criterion V |
| CCA | P.2, Evaluation |
| INPO aspect | PI.2 |
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Finding - Comanche Peak - IR 05000445/2015007 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Comanche Peak) @ 2015Q3
Self-Identified List (Comanche Peak)
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