05000446/FIN-2017002-02
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Finding | |
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| Title | Inadequate Operability Evaluation for Safety - related Pipe Supports |
| Description | Green . The inspector s identified a non- cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, that occurred when the licensee failed on two occasions to perform an adequate operability determination associated with multiple safety -related pipe supports. Specifically, the operability determination of multiple carbon steel pipe support clamps exposed to boric acid and a bent sway strut pipe restraint lacked the engineering rigor necessary to provide a high degree of confidence to support the operability of the components. Subsequently, the inspector s concluded that the licensee established reasonable expectation for operability once engineering provided the control room with further analysis on the degraded conditions, and the new information was reviewed and accepted. This issue was entered into the licensees corrective action program as Condition Report CR -2017- 05418. The licensee's failure to perform adequate operability determinations per plant procedures was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the equipment performance attribute of the Mitigating System cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee: (1) failed to perform the required corrosion evaluation for a comparison of material wastage against design dimensions of the pipe support clamps; (2) failed to perform a visual inspection of the material condition of the pipe support clamps as required by the work order; ( 3) used non- seismic design tolerances for the qualification of a seismically qualified strut in the immediate operability determination; and (4) failed to consider that the bent condition of the strut occurred after the previously accepted visual examinations on the same pipe support. All these issues could have resulted in safety -related components failing to perform their specified safety function during accident conditions. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, dated October 7, 2016, and Inspection Manual Chapter 0609, Appendix A, Significance Determination Process for Findings At -Power, Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined the finding was of very low safety significance (Green) because the finding: (1) it was not a design deficiency; (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 technical specification allowed outage time; (4) and did not result in the loss of a high safety - significant non- technical specification train. This finding had a cross -cutting aspect in the area of problem identification and resolution associated with resolution because the licensee failed to adequately assess the degraded condition of the pipe supports in a complete and accurate manner to support a reasonable expectation of operability [P.1]. |
| Site: | Comanche Peak  |
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| Report | IR 05000446/2017002 Section 1R08 |
| Date counted | Jun 30, 2017 (2017Q2) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.08 |
| Inspectors (proximate) | J Josey R Kumana S Janicki M Chambers L Carson J O'Donnell K Clayton I Anchandoj Joseyr Kumana S Janicki M Chambers L Carson J O'Donnell K Clayton I Anchondo M Haire |
| Violation of: | 10 CFR 50 Appendix B Criterion V |
| CCA | P.1, Identification |
| INPO aspect | PI.1 |
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Finding - Comanche Peak - IR 05000446/2017002 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Comanche Peak) @ 2017Q2
Self-Identified List (Comanche Peak)
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