05000259/FIN-2009008-01
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Finding | |
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Title | Violation of Technical Specification 5.4.1 for Failure to Develop Adequate Procedures to Ensure Tornado Depressurization Protection of the Emergency Diesel Generators |
Description | The inspectors identified a Green non-cited violation (NCV) of TS 5.4.1 for the failure to have an adequate procedure that would ensure tornado depressurization protection of the emergency diesel generators (EDGs). Abnormal Operating Instruction, 0-AOI-100-7, Severe Weather, did not provide guidance on how to provide pressure equalization of the EDG building for mitigating atmospheric depressurization associated with tornado conditions that could impact the EDG building ventilation system. The design of the EDG ventilation system intake and exhaust dampers requires the dampers to be manually opened prior to a tornado depressurization event to ensure the EDG building and ventilation system remain intact and operable during and after a tornado. This finding was entered into the licensees corrective action program as problem evaluation report (PER) 206919. As an immediate corrective action, the licensee added steps to procedure 0-AOI-100-7 to station an operator in the EDG building to perform required manual actions in the event of a tornado warning in the area. This finding is more than minor because it affects the Mitigating Systems Cornerstone objective of ensuring the availability, reliability, and operability of the EDGs to perform the intended safety function during a design basis event and the cornerstone attribute of Procedure Quality, i.e. Operating (Post Event) Procedures (AOPs). The inspectors assessed the finding using a Phase I Significance Determination Process (SDP) screening which determined a Phase III SDP evaluation was required due to the fact that the finding involved the loss or degradation of equipment specifically designed to mitigate a severe weather initiating event (e.g., tornado doors). The loss of this equipment by itself, during the external initiating event it was intended to mitigate, would degrade two or more trains of a multi-train safety system. A Phase III SDP evaluation was performed in accordance with NRC Inspection Manual Chapter 0609 Appendix A by a regional Senior Reactor Analyst using the NRC Standardized Plant Analysis Risk (SPAR) model. The analysis determined that the performance deficiency resulted in a core damage frequency (CDF) risk increase of less than 1E-6. Therefore, the finding was characterized as having very low safety significance (Green). The large early release frequency (LERF) result was less than 1E-7 which would not override the CDF risk characterization. The dominant sequence was a tornado which caused damage to the EDG dampers for all EDGs and resulted in a loss of offsite power (LOOP). The risk was mitigated by the low initiating event likelihood for tornadoes and the probability for EDG recovery which was proceduralized. The inspectors determined that the use of operating experience (OE) information was a significant cause of this performance deficiency. Regulatory Information Summary 2006-03, Post Tornado Operability of Ventilation and Air Conditioning Systems as well as an internal licensee OE had raised a similar concern. The licensee was unaware of the vulnerability of the EDG ventilation system to tornado depressurization events until it was brought to their attention by the inspectors. The licensees failure to use available OE is directly related to the OE component of the cross-cutting area of Problem Identification and Resolution and the aspect of implementing OE through changes to procedures (P.2.(b)) |
Site: | Browns Ferry ![]() |
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Report | IR 05000259/2009008 Section 1R21 |
Date counted | Dec 31, 2009 (2009Q4) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.21 |
Inspectors (proximate) | J Leivo R Aiello R Berryman H Campbell C Even R Patterson B Desai J Kent |
CCA | P.5, Operating Experience |
INPO aspect | CL.1 |
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Finding - Browns Ferry - IR 05000259/2009008 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Browns Ferry) @ 2009Q4
Self-Identified List (Browns Ferry)
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