05000387/FIN-2016003-02
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Finding | |
|---|---|
| Title | Risk Management Actions Not Adequately Implemented |
| Description | The inspectors identified a Green NCV of 10 CFR 50.65(a)(4) because Susquehanna did not assess and manage the increase in risk from online maintenance activities. From September 11 to 16, 2016, there were multiple affected areas that the fire protection engineer or designee did not walk down to inspect for fire impairments resulting in deficiencies not being corrected prior to releasing work and no fire watch was established for the impairments. Susquehanna removed the combustible materials from the areas or stationed a fire watch, and entered these issues into their CAP as CR-2016-21125, CR-2016-21423, CR-2016-21616, and CR-2016-21741. This finding is more than minor because it adversely impacted the protection against external factors attribute of the Mitigating Systems cornerstone objective to ensure the capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, not implementing the required risk management actions (RMAs) for the only available safe shutdown pathway placed the station in a much higher risk condition in the event of an internal fire. The inspectors evaluated the finding in accordance with IMC 0609, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process. Since the performance deficiency was related to maintenance activities affecting structure, system, and components needed for fire mitigation, Appendix K directed the significance to be determined by an internal NRC management review using risk insights. IMC 0609, Appendix F, Attachment 1 Fire Protection Significance Determination Process Phase 1 Worksheet, was used to develop this risk insight. Based on the nature and quantity of combustible materials in the areas, combined with the relatively short duration of which the fire risk was unmitigated, inspectors determined that it was of very low safety significance (Green). The finding was determined to have a cross-cutting aspect in the area of Human Performance, Avoid Complacency, in that, individuals did not plan for latent issues and inherent risk, even while expecting successful outcomes. Specifically, combustible materials were not appropriately controlled as required by OI-013-002, Fire Risk Management, Revision 10, because in some cases they were assumed to be exempt from the program requirement or staff did not tour the areas because they assumed there were no combustible materials present based on past experience. |
| Site: | Susquehanna  |
|---|---|
| Report | IR 05000387/2016003 Section 1R13 |
| Date counted | Sep 30, 2016 (2016Q3) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.13 |
| Inspectors (proximate) | D Schroeder J Furia J Grieves J Heinly J Nicholson N Embert O Masnyk-Bailey T Daun |
| Violation of: | 10 CFR 50.65 10 CFR 50.65(a)(4) |
| CCA | H.12, Avoid Complacency |
| INPO aspect | QA.4 |
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Finding - Susquehanna - IR 05000387/2016003 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Susquehanna) @ 2016Q3
Self-Identified List (Susquehanna)
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