05000313/FIN-2015004-02
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Finding | |
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Title | Failure to Identify and Correct Rain Water Accumulation in the Emergency Diesel Generator System Exhausts |
Description | The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for failure to identify a condition adverse to quality. Specifically, the licensee failed to identify rain water accumulation in the exhaust systems for the Units 1 and 2 emergency diesel generators due to clogged water drains. As a result, rainwater in the exhaust piping may have caused the emergency diesel generators to exceed the seismic rating of the exhaust systems during a seismic event. The inspector identified that when ANO removed the rain shields in 1998, they planned to implement periodic drain line cleaning to avoid clogging, but never created the preventive maintenance item to implement the cleaning. In response, the licensee cleaned the drain lines, drained the exhaust pipes, and implemented preventative maintenance activities to periodically clean the drain lines. This issue was entered into the licensees corrective action program as Condition Report CR-ANO-C-2015-04570. The failure to identify that rainwater was accumulating in all four emergency diesel exhaust systems and could impact the availability of the system is a performance deficiency. The performance deficiency is more than minor because it affected the protection against external factors attribute of the Mitigating Systems Cornerstone objective 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, operators failed to recognize that drain lines were blocked during routine operations to drain the exhaust lines, which allowed rain water to accumulate that exceeded the allowed seismic loading of the piping. Using NRC Manual Chapter 0609, Appendix A, Determining the Significance of Reactor Inspection Findings for At-Power Situations, the inspectors determined that a detailed risk evaluation was required. A senior reactor analyst performed a detailed risk evaluation and determined that the increase in core damage frequency was 1.3E-7/year (Green). The dominant risk was determined to involve seismically induced losses of offsite power. Emergency feedwater and a Unit 2 emergency diesel generator remained available to successfully avoid core damage. The inspectors determined this finding has a cross-cutting aspect in the area of Avoid Complacency because the primary cause of the performance deficiency involved the failure to plan for or recognizing latent conditions involving clogged drain lines [H.12]. |
Site: | Arkansas Nuclear |
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Report | IR 05000313/2015004 Section 1R18 |
Date counted | Dec 31, 2015 (2015Q4) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.18 |
Inspectors (proximate) | A Barrett B Tindell G Guerra J Dixon M Kennard M Tobin N O 'Keefew Sifre |
Violation of: | 10 CFR 50 Appendix B Criterion XVI |
CCA | H.12, Avoid Complacency |
INPO aspect | QA.4 |
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Finding - Arkansas Nuclear - IR 05000313/2015004 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Arkansas Nuclear) @ 2015Q4
Self-Identified List (Arkansas Nuclear)
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