05000483/FIN-2014007-08
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Finding | |
|---|---|
| Title | Inadequate Procedure for Cooling Instrumentation During a Station Blackout Event. |
| Description | The team identified a Green, non-cited violation of 10 CFR Part 50.63(a)(2) which states, in part, The reactor core and associated coolant, control, and protection systems, including station batteries and any other necessary support systems, must provide sufficient capacity and capability to ensure that the core is cooled and appropriate containment integrity is maintained in the event of a station blackout for the specified duration. Specifically, from April 15, 2011 to July 2, 2014, a change made to Emergency Operating Procedure Addendum 20, Control Room Cabinet Door List, Revision 003, required control room operators to open a minimum of one control room cabinet door during a station blackout. Emergency Operating Procedure Addendum 20, Revision 003, was completed without any analysis or calculations performed to justify whether the electronics in the cabinets would have sufficient cooling with a minimum of one door open during a station blackout. This could result in insufficient cooling to the Solid State Protection System (SSPS) and other essential controls during a station blackout. In response to this issue, the licensee initiated actions to make the procedures consistent regarding how many doors should be opened for the given cabinets, and for engineering to investigate how many doors should be opened. This finding was entered into the licensees corrective action program as Callaway Action Request (CAR) 201403029. The team determined that the failure to ensure that components located in control room cabinets, which provide input for the Solid State Protection System (SSPS), would remain operable during a station blackout, as assumed in the sites station blackout analysis, was a performance deficiency. This finding was more than minor because it adversely affected the Mitigating Systems Cornerstone attribute of Procedure Quality, and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the change made to EOP Addendum 20, Revision 003, had been completed without documented review of the sites station blackout analysis or its assumptions to justify whether the components in the cabinets would have sufficient cooling with a minimum of one door open per cabinet during a station blackout. By not analyzing the concern to determine the effect of the temperature of the instrumentation and components in the cabinets, the licensee may subject the electronic components contained in the cabinets to temperatures that could degrade their capability to ensure core cooling and containment integrity. 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. This finding had a cross-cutting aspect, pertaining to change management, in the area of human performance, because the licensee had not used a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority. Without documented results of an analysis or justification, for the 2011 evaluation, the assumptions could not be verified to justify their actions [H.3]. |
| Site: | Callaway  |
|---|---|
| Report | IR 05000483/2014007 Section 1R21 |
| Date counted | Jun 30, 2014 (2014Q2) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.21 |
| Inspectors (proximate) | B Correll C Baron C Hale G Nicely J Braisted R Kopriva S Hedger T Farnholtz |
| Violation of: | 10 CFR 50.63 |
| CCA | H.3, Change Management |
| INPO aspect | LA.5 |
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Finding - Callaway - IR 05000483/2014007 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Callaway) @ 2014Q2
Self-Identified List (Callaway)
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