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The team identified two examples of a GreeThe team identified two examples of a Green, non-cited violation of Technical Specification 6.8.1, which states, in part, Written procedures shall be established, implemented, and maintained, covering the activities including procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A.6.w, Acts of Nature (e.g., tornado, flood, damn failure, earthquakes). Specifically, in the first example, prior to August 27, 2015, the licensee failed to establish adequate procedures to ensure the manual actions required within specified time limits can be completed before full draindown of the ultimate heat sink (wet cooling tower basins) after a tornado event. In the second example, prior to August 27, 2015, the licensee failed to establish adequate procedures to clarify whether the main steam isolation valve area was considered outdoors and therefore subject to the requirements for unmonitored items stored in the protected area. Unsecured scaffold material stored in this area had not been evaluated for potential to become projectiles and endangering nearby safety-related equipment during high winds. In response to this issue, the licensee inspected the area and secured all loose debris. This finding was entered into the licensees corrective action program as Condition Reports CR-WF3-2015-05624 and CR-WF3-2015-05601. The team determined that the failure to maintain adequate procedures to ensure compliance with technical specifications and Regulatory Guide 1.33 was a performance deficiency. This finding was more than minor because it was associated with the procedure quality 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 establish adequate procedures to ensure availability of mitigating equipment during and after an event involving acts of nature. 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 to Exhibit 4, External Events Screening Questions, because both examples involved a design basis tornado. Per Exhibit 4, the issue screened to a more detailed risk evaluation because: 1) the first issue could starve safety systems of water, failing the safety function, and 2) the second issue could cause a plant trip and a loss of condenser heat sink initiating event. Therefore, the Region IV senior reactor analyst performed a more detailed risk evaluation that included both issues. Given that there was no change in core damage frequency for the first issue, and the change in core damage frequency for the second example was 1.2 x 10-9 per year, combined, the analyst determined that the finding was of very low safety significance (Green). This finding had a cross-cutting aspect in the area of problem identification and resolution, evaluation, because the licensee failed to thoroughly evaluate issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance (P.2).rate with their safety significance (P.2).  
23:59:59, 30 September 2015  +
05000382  +
23:59:59, 30 September 2015  +
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12:59:12, 25 September 2017  +
23:59:59, 30 September 2015  +
Inadequate Procedures for Design Basis Tornado Event  +