05000220/FIN-2014002-01
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Finding | |
|---|---|
| Title | Inadequate Design Control Measures Employed During Control Room HVAC Modification |
| Description | The inspectors identified a Green NCV of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion III, Design Control, because CENG did not implement adequate design controls to ensure piping in the Reactor Building Closed Loop Cooling (RBCLC) system remained operable while implementing a modification to the Unit 1 control room heating and ventilation system. Specifically, while implementing the modification, CENG personnel removed permanent plant supports and piping for the safetyrelated RBCLC system and did not fully assess how this change could impact the operability of the system with respect to a hydraulic shock or seismic acceleration event. In response to this observation, CENG initiated CR-2014-001676 and evaluated the condition for operability. Existing temporary supports were enhanced to provide additional margin by bracing the structure for horizontal loads. An extent of condition walkdown was performed and no additional issues of concern were identified. Subsequently, CENGs operability review determined the RBCLC system had remained operable. This finding was more than minor because it was associated with the design control attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, while implementing the modification, CENG removed permanent plant supports and piping for the safety-related RBCLC system and did not fully assess how this change could impact the operability of the system if a hydraulic shock or seismic acceleration occurred. This finding is also similar to examples 3.j and 4.k in IMC 0612, Appendix E, Examples of Minor Issues, where a temporary modification was installed without adequate design information and adequate design controls were not implemented leading to a reasonable doubt of operability of plant components. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, the inspectors determined this finding is of very low safety significance (Green) because the performance deficiency was a design or qualification deficiency that did not result in the inoperability of the RBCLC system. The finding has a cross-cutting aspect in the area of Human Performance, Work Management, because CENG failed to implement a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. Specifically, CENG failed to ensure that the installed temporary supports were adequate to ensure the RBCLC piping would not be stressed above code allowable values in the event of a seismic acceleration or hydraulic shock event prior to removing the permanently installed seismic supports. |
| Site: | Nine Mile Point  |
|---|---|
| Report | IR 05000220/2014002 Section 1R18 |
| Date counted | Mar 31, 2014 (2014Q1) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.18 |
| Inspectors (proximate) | D Kern D Schroeder E Burket E Miller K Kolaczyk S Barr S Mccarver |
| Violation of: | 10 CFR 50 Appendix B Criterion III, Design Control |
| CCA | , |
| INPO aspect | WP.1, WP.1 |
| ' | |
Finding - Nine Mile Point - IR 05000220/2014002 | |||||||||||||||||||||||||||||||||||||||||||
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Finding List (Nine Mile Point) @ 2014Q1
Self-Identified List (Nine Mile Point)
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