05000445/FIN-2017002-05
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Finding | |
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| Title | Failure to Translate Design Requirements Into the As Built Facility |
| Description | Green. The inspectors identified a non- cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, associated with the licensees failure to assure that applicable regulatory requirements and the design bases, as defined in 10 CFR 50.2 and as specified in the license application, for those structure, systems and components to which this appendix applies, were correctly translated into specifications, drawings, procedures, and instructions. Specifically, from initial construction through March 2017, the licensee failed to fully incorporate applicable moderate energy line break design requirements for fire protection piping located in the vicinity of the station service water pumps, the latter which are needed to ensure the capability to shut down the reactor and maintain it in a safe shutdown condition following a moderate energy line break. This issue does not represent an immediate safety concern because when the lines were identified the licensee took prompt action to isolate and depressurize them, and the licensee has implemented plant modifications. The licensee entered this issue into the corrective action program as Condition Report CR -2016- 008147. The failure to incorporate applicable design requirements into specifications for moderate energy line break protection was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the design control attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, from initial construction through March 2017, the licensee failed to fully incorporate applicable design requirements for components needed to ensure the capability to shut down the reactor and maintain it in a safe shutdown condition following a moderate energy line break. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, dated July 1, 2012, and Inspection Manual Chapter 0609, Appendix A, Significance Determination Process for Findings At -Power , Exhibit 2, Mitigating Systems Screening Questions, dated 5 October 7, 2016, the inspectors determined the finding required a detailed risk evaluation because the finding involved a deficiency affecting the design and qualification of a mitigating structure, system, or component, and resulted in a loss of operability, and represented an actual loss of function of at least a single train for longer than its allowed outage time. A senior reactor analysts from Region IV performed a detailed risk evaluation and determined that the bounding increase in core damage frequency for this issue was 5.1E -8/year for Unit 1 and 2.9E -10/year for Unit 2, and was therefore of very low safety significance (Green ). The inspectors did not assign a cross -cutting aspect because the performance deficiency was not reflective of present performance |
| Site: | Comanche Peak  |
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| Report | IR 05000445/2017002 Section 4OA3 |
| Date counted | Jun 30, 2017 (2017Q2) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71153 |
| Inspectors (proximate) | J Josey R Kumana S Janicki M Chambers L Carson J O 'Donnellk Clayton I Anchandoj Joseyr Kumana S Janicki M Chambers L Carson J O 'Donnellk Clayton I Anchondo M Haire |
| Violation of: | 10 CFR 50 Appendix B 10 CFR 50 Appendix B Criterion III, Design Control |
| INPO aspect | |
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Finding - Comanche Peak - IR 05000445/2017002 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Comanche Peak) @ 2017Q2
Self-Identified List (Comanche Peak)
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