05000483/FIN-2016002-03
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Finding | |
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| Title | Failure to Adequately Evaluate Operability for a Degraded Condition |
| Description | The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to perform an adequate operability assessment when a degraded or nonconforming condition was identified. Specifically, after the licensee identified that a severe water hammer transient would occur following a loss of off-site power, the licensee generated an operability evaluation that relied on judgement and inaccurate information which failed to establish a reasonable expectation of operability. Following questions from inspectors the licensee determined that this judgement was not correct and performed a new evaluation to ensure operability of the essential service water system. The licensee entered this issue into their corrective action program as Callaway Action Request 201605488. The licensees failure to properly assess and document the basis for operability when a severe water hammer occurred in the essential service water system was a performance deficiency. The performance deficiency is more than minor, and therefore a finding, because it is associated with the equipment performance attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, severe water hammer transients in the essential service water system due to a loss of off-site power, result in a condition where structures, systems, and components necessary to mitigate the effects of accidents may not have functioned as required. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, inspectors determined that this finding was of very low safety significance (Green) because the finding: did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic event, and (1) was not a deficiency affecting the design and qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality, (2) did not represent a loss of system and/or function, (3) did not represent an actual loss of function of at least a single train for longer than its allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time, and (4) does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in accordance with the licensees maintenance rule program. This finding has a cross-cutting aspect of conservative bias in the human performance area because the licensee failed to demonstrate that a proposed action was safe in order to proceed, rather than unsafe in order to stop. Specifically, the licensees use of unsupported judgement and incorrect data resulted in an evaluation that failed to demonstrate a reasonable expectation of operability [H.14]. |
| Site: | Callaway  |
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| Report | IR 05000483/2016002 Section 1R15 |
| Date counted | Jun 30, 2016 (2016Q2) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.15 |
| Inspectors (proximate) | J Drake J Josey J O'Donnell M Langelier N Taylor P Hernandez R Kopriva T Hartman |
| Violation of: | 10 CFR 50 Appendix B 10 CFR 50 Appendix B Criterion V |
| CCA | H.14, Conservative Bias |
| INPO aspect | DM.2 |
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Finding - Callaway - IR 05000483/2016002 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Callaway) @ 2016Q2
Self-Identified List (Callaway)
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