05000317/FIN-2015004-01
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Finding | |
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| Title | Failure to Implement Procedures for the Control of Hazard Barriers During Maintenance |
| Description | The inspectors identified a Green NCV of Technical Specification (TS) 5.4.1.a for Exelons failure to implement procedures as required by Regulatory Guide (RG) 1.33, Appendix A, Section 1, Administrative Procedures, during replacement of the 11 service water (SRW) pump motor, resulting in the SRW pump room door, a high energy line break (HELB) barrier, being impaired. This rendered the safety-related equipment protected by the HELB barrier inoperable. The inspectors determined that the failure to properly implement Exelon procedures EN-1-135, Control of Barriers, Revision 00202, and CC-AA- 201, Plant Barrier Control Program, Revision 11, was a performance deficiency that was reasonably within Exelons ability to foresee and prevent. Upon identification, Exelon staff entered this issue into their corrective action program (CAP) as issue report (IR) 2586773. Exelons immediate corrective actions included halting of impairing hazard barriers without considering the degraded barriers effect on equipment operability. The inspectors reviewed IMC 0612, Appendix B, Issue Screening, and determined the performance deficiency was more than minor because it adversely affected the equipment performance attribute of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, Exelons actions in blocking open the HELB barrier resulted in a condition where structures, systems, and components (SSCs) necessary to mitigate the effects of a HELB may not have functioned as required; therefore, the reliability of these protected SSCs was adversely impacted. In accordance with IMC 0609, Attachment 4, Initial Characterization of Findings, issued on June 19, 2012, and IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, issued on June 19, 2012, the inspectors determined that a detailed risk evaluation was necessary to disposition the significance of this finding because the finding represented a loss of the SRW system. A regional Senior Reactor Analyst (SRA) performed a detailed risk evaluation using an exposure interval of 10 minutes as the maximum time the condition was allowed in the plant. Using these inputs yielded an initiating event frequency of 4E-9/year. From discussions with the inspectors, the analyst confirmed a list of affected equipment. The analyst bounded the scenario by assuming all mitigating equipment would be lost which gave a maximum change in core damage frequency of 4E-9/year. Since the bounded change in core damage frequency was less than 1E-6, the finding was determined to be of very low safety significance (Green). The inspectors determined that the finding had a cross-cutting aspect in the area of Human Performance, Work Management, because Exelon did not implement a process of planning, controlling, and executing work activities such that nuclear safety was the overriding priority. Specifically, Exelons process for planning and controlling maintenance did not identify the applicability of Exelon procedure CC-AA-201. |
| Site: | Calvert Cliffs  |
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| Report | IR 05000317/2015004 Section 1R04 |
| Date counted | Dec 31, 2015 (2015Q4) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.04 |
| Inspectors (proximate) | A Dimitriadis C Highley C Roettgen H. Anagnostopoulus J Schoppy K Mangan P Ott P Presby R Clagg S Pindale |
| Violation of: | Technical Specification - Procedures Technical Specification |
| CCA | H.5, Work Management |
| INPO aspect | WP.1 |
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Finding - Calvert Cliffs - IR 05000317/2015004 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Calvert Cliffs) @ 2015Q4
Self-Identified List (Calvert Cliffs)
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