05000327/FIN-2013002-03
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Finding | |
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| Title | Failure to Promptly Identify and Correct Conditions Adverse to Quality |
| Description | The inspectors identified a Green NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, associated with three examples of the licensees failure to promptly identify and correct conditions adverse to quality. Specifically, the licensee failed to promptly correct (1) the conduit penetration seals entering the ERCW building, (2) two penetrations in the wall of the ERCW building below the probable maximum flood level that were not sealed, and (3) two diesel generator drain lines that could not be isolated. The licensee entered the finding into the CAP as PERs 594536, 594568, 610005, and 622421. The failure to promptly identify and correct conditions adverse to quality was a performance deficiency. The performance deficiency was determined to be more than minor because if left uncorrected, the licensees continued failure to promptly identify and correct conditions adverse to quality could result in more risk significant equipment being inoperable for longer periods of time without the licensee realizing, and is therefore a finding. The inspectors performed the significance determination using NRC Inspection Manual Chapter 0609, Significance Determination Process. Because the finding affected the Mitigating Systems Cornerstone while the plant was at power, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, evaluates the finding using Appendix A. Using Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the finding was determined to have very low safety significance because the finding: (1) was not a design or qualification issue confirmed not to result in a loss of operability or functionality; (2) did not represent an actual loss of safety function of the system or train; (3) did not result in the loss of one or more trains of nontechnical specification equipment; and (4) did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding, or severe weather initiating event. In addition, this finding had a human performance cross-cutting aspect associated with decision making. Specifically, the licensee failed to use conservative assumptions in decision making regarding the timely opening of manhole 33 for physical inspection to be able to quantitatively determine the in leakage value for the degraded condition and put in place an adequate comp measure. Also, the licensee incurred excessive delay in plugging of two ERCW building holes as well as evaluation of the potential water intrusion into the EDG building during flooding events |
| Site: | Sequoyah  |
|---|---|
| Report | IR 05000327/2013002 Section 4OA2 |
| Date counted | Mar 31, 2013 (2013Q1) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71152 |
| Inspectors (proximate) | S Shaeffer G Smith M Coursey W Deschaine |
| Violation of: | 10 CFR 50 Appendix B Criterion XVI |
| CCA | H.14, Conservative Bias |
| INPO aspect | DM.2 |
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Finding - Sequoyah - IR 05000327/2013002 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Sequoyah) @ 2013Q1
Self-Identified List (Sequoyah)
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