05000388/FIN-2016003-01
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Finding | |
|---|---|
| Title | Inadequate Work Instructions for Breaching Internal Flood Barrier |
| Description | The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, because Susquehanna did not ensure that work instructions to breach a flood barrier appropriately incorporated design requirements for internal flooding so that equipment necessary to achieve and maintain safe shutdown would not be impacted. From August 30, 2016 to September 2, 2016, work instructions directed a breach of a flood barrier that was credited to provide assurance that equipment necessary for safe shutdown of the plant was protected against the effects of medium energy line breaks and, therefore, were not appropriate to the circumstances. Susquehanna entered this issue into their corrective action program (CAP) as condition report CR-2016-20472 and CR-2016-20859 and revised the work instructions to require a worker remain in the vicinity of the penetration to ensure that flooding could be secured prior to impacting equipment necessary to reach and maintain safe shutdown. This finding is more than minor because if left uncorrected, the performance deficiency had the potential to lead to a more significant safety concern. Specifically, had the breach been completed, it could have allowed a medium energy line break in one flooding area to communicate with another area, potentially impacting equipment necessary to achieve and maintain safe shutdown. The inspectors evaluated the finding using IMC 0609, Appendix A, Exhibit 2, "Mitigating System Screening Questions," and determined the finding to be of very low safety significance (Green) because the PD was not a design or qualification deficiency, did not involve an actual loss of safety function, did not represent actual loss of a safety function of a single train for greater than its technical specification allowed outage time, and did not screen as potentially risk-significant due to a seismic, flooding, or severe weather initiating event. The finding has a cross-cutting aspect of Human Performance, Work Management because Susquehanna did not implement a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. Implementation of Susquehannas work planning process did not ensure that the maintenance incorporated all requirements for protection against internal flooding and did not ensure that job site conditions were consistent with assumptions in engineering analyses. |
| Site: | Susquehanna  |
|---|---|
| Report | IR 05000388/2016003 Section 1R06 |
| Date counted | Sep 30, 2016 (2016Q3) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.06 |
| Inspectors (proximate) | D Schroeder J Furia J Grieves J Heinly J Nicholson N Embert O Masnyk-Bailey T Daun |
| Violation of: | 10 CFR 50 Appendix B 10 CFR 50 Appendix B Criterion V |
| CCA | H.5, Work Management |
| INPO aspect | WP.1 |
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Finding - Susquehanna - IR 05000388/2016003 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Susquehanna) @ 2016Q3
Self-Identified List (Susquehanna)
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