05000482/FIN-2015003-01
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Finding | |
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Title | Inadequate Implementation of the Breach Authorization Procedure |
Description | The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated with the licensees inadequate implementation of Procedure AP 10-104, Breach Authorization, Revision 34, which requires authorization to be obtained prior to breaching certain barriers and door 36042 to be within 0.25 inches of the closed position with door 36043 open. Specifically, control room door 36043, which is a fire, security, and control room ventilation isolation signal barrier, was fully opened prior to the breaching party obtaining required written authorization. Additionally, following the opening of normally closed control room door 36043, control room door 36042 was not adequately positioned, which resulted in a doubt on the operability of the control room envelope boundary. Wolf Creeks immediate corrective actions included closing door 36043 to restore the control room boundary, completing a breach authorization permit until repairs could be completed on door 36043, and entering the issue into its corrective action program as Condition Report 99097. This finding is more than minor because it is associated with the system, structure, and component and barrier performance attribute of the Barrier Integrity Cornerstone, and affected the associated cornerstone objective to provide reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and containment), including the radiological barrier functionality of the control room, are maintained and protect the public from radionuclide releases caused by accidents or events. Specifically, while control room door 36043 was opened and control room door 36042 was being credited as the control room envelope boundary, door 36042 was not in the required position to maintain the control room envelope operable, and there was a reasonable doubt on the operability of the control room envelope because neither operations nor stationed security personnel verified and recognized the required position of door 36042. In accordance with Inspection Manual Chapter 0609.04, Initial Characterization of Findings, and Exhibit 3 of Inspection Manual Chapter 0609, Appendix A, The Significance Determination process (SDP) for Findings At-Power, issued June 19, 2012, and April 29, 2015, respectively, the performance deficiency was a deficiency affecting the control room, auxiliary, reactor, or spent fuel pool building. The performance deficiency represented a degradation of the radiological barrier function, but the deficiency did not represent a degradation of the barrier function of the control room against smoke or a toxic atmosphere. Therefore, the inspectors determined the finding was of very low safety significance (Green). The finding has a cross-cutting aspect in the area of human performance, challenge the unknown, because Wolf Creek did not stop when faced with uncertain conditions or evaluate and manage risks before proceeding. Specifically, Wolf Creeks immediate actions to open door 36043 without a breach authorization permit and its actions to inadequately position door 36042 were not adequately evaluated prior to implementation, which resulted in door 36042 being left in a position inconsistent with Procedure AP 10-104 and a reasonable doubt on the operability of the control room envelope [H.11]. |
Site: | Wolf Creek |
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Report | IR 05000482/2015003 Section 1R15 |
Date counted | Sep 30, 2015 (2015Q3) |
Type: | NCV: Green |
cornerstone | Barrier Integrity |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.15 |
Inspectors (proximate) | D Dodson F Thomas N Taylor R Stroble |
Violation of: | 10 CFR 50 Appendix B Criterion V |
CCA | H.11, Challenge the Unknown |
INPO aspect | QA.2 |
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Finding - Wolf Creek - IR 05000482/2015003 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Wolf Creek) @ 2015Q3
Self-Identified List (Wolf Creek)
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