05000298/FIN-2012002-03

Finding

Title

Failure to Appropriately Manage Risk for Maintenance in the Stations Switchyard

Description

The inspectors identified a non-cited violation of 10 CFR 50.65(a)(4), Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, associated with the licensees failure to manage risk associated with switchyard maintenance. Specifically, as a result of a risk assessment performed for planned work in the stations switchyard the licensee had identified required risk management actions for these activities to offset the increase in on-line risk. However, workers failed to implement these risk management actions during the performance of the work. This issue was entered into the licensees corrective action program as Condition Report CR-CNS-2011-12267. The licensees failure to implement required risk management actions to manage the increase in on-line risk during switchyard work was a performance deficiency. The performance deficiency was more than minor because it affected the protection against external factors attribute of the Initiating Events Cornerstone, and directly affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations, and is therefore a finding. Using Manual Chapter 0609, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process, flowchart 2, Assessment of RMAs, the inspectors determined the need to calculate the risk deficit to determine the significance of this issue. The inspectors contacted the regional senior reactor analyst who estimated the increase in risk caused by the unmonitored switchyard activity. For the five minute period of exposure, the frequency of the switchyard-centered loss of offsite power was increased by one order of magnitude. The result was an ICCDP of 1.0E-11. As such, this finding was determined to have very low safety significance. This finding had a cross-cutting aspect in the area of human performance associated with the work practices component, because the licensee failed to assure that human error prevention techniques, such as self and peer checking were used to assure that work activities were performed safely. Specifically, individuals working in the switchyard failed to self and peer check prior to moving aerial equipment in the switchyard without spotters

03
Site:	Cooper
Report	IR 05000298/2012002 Section 1R13
Date counted	Mar 31, 2012 (2012Q1)
Type:	NCV: Green
cornerstone	Initiating Events
Identified by:	NRC identified
Inspection Procedure:	IP 71111.13
Inspectors (proximate)	C Henderson J Josey J Laughlin S Garchow V Gaddy
CCA	H.12, Avoid Complacency
INPO aspect	QA.4
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v • d • e

Finding - Cooper - IR 05000298/2012002

1(0)2(9)3(16)4(13)5(12)6(0)7(6)8(0)301(1)403(0)404(4)501(0)503(0)801(0)31(0)

IR 05000298/2012002: 1 2 3 4 5 6 7 8 1

Finding List (Cooper) @ 2012Q1

CCA Matrix: 2012Q1

	Q	CCA	Title
05000298/FIN-2011004-01	2011Q3	H.7	Failure to Place the Essential Service Water System Strainers in (a)(1)
05000298/FIN-2011004-02	2011Q3		Failure to Scope Reactor Building Drain Components and Steam Exclusion Doors that Affect Safety-related Systems in the Maintenance Rule Monitoring Program
05000298/FIN-2011004-03	2011Q3	H.8	Failure to Assess and Manage Risk for Maintenance Near Electrical Towers That Could Impact Initiating Events
05000298/FIN-2011004-04	2011Q3	P.3	Failure to Assess and Manage Risk for Maintenance Near an Operating Reactor Feed Pump That Could Impact Initiating Events
05000298/FIN-2011004-05	2011Q3	H.12	Failure to Follow Procedure Results in Personnel Contamination
05000298/FIN-2011004-06	2011Q3	P.2	Failure to Identify, Correct, and Prevent Recurrence of a Significant Condition Adverse to Quality
05000298/FIN-2011004-07	2011Q3		Inadequate Procedure Results in Inoperable Essential Pump
05000298/FIN-2011005-07	2011Q4	H.14	Failure to Perform Required 10 CFR 50.59 Evaluations for Changes
05000298/FIN-2011202-02	2011Q4		Security
05000298/FIN-2011005-06	2011Q4	P.2	Failure to Correctly Translate Design Requirements into Installed Plant Configuration
05000298/FIN-2011005-05	2011Q4	P.1	Failure to Identify Deficient Performance During a Single-Facility Drill
05000298/FIN-2011005-03	2011Q4	H.12	Failure to Follow Procedures for Dose Rate Alarms Received by Two Individuals
05000298/FIN-2011005-02	2011Q4	H.2	Failure to Maintain Control and Continuous Coverage of a Posted Locked High Radiation Area
05000298/FIN-2011005-01	2011Q4	H.2	Failure to Conspicuously Post a High Radiation Area
05000298/FIN-2011005-04	2011Q4		Failure to Provide Complete and Accurate Solid Radwaste Shipment Information in Annual Reports
05000298/FIN-2012002-01	2012Q1	P.2	Failure to Maintain Design Control for Internal Flooding
05000298/FIN-2012002-02	2012Q1	P.2	Failure to Scope Required Components in the Stations Maintenance Rule Monitoring Program
05000298/FIN-2012002-03	2012Q1	H.12	Failure to Appropriately Manage Risk for Maintenance in the Stations Switchyard
05000298/FIN-2012002-04	2012Q1		Failure to Maintain Design Control of Standby Liquid Control System
05000298/FIN-2012002-05	2012Q1	H.7	Unevaluated Pre-conditioning for Core Spray Motor-operated Valves prior to Conducting As Found In-service Surveillance Testing
05000298/FIN-2012002-06	2012Q1	H.14	Failure to Follow Radiation Work Permit Requirements
05000298/FIN-2012002-07	2012Q1		Failure to Furnish Evidence of an Activity Affecting Quality
05000298/FIN-2012002-08	2012Q1	H.2	Failure to Follow Station Procedure Results in Inadequate Work Instructions

Self-Identified List (Cooper)

	Q	Title
05000298/FIN-2011005-08	2011Q4	Licensee-Identified Violation
05000298/FIN-2011005-09	2011Q4	Licensee-Identified Violation

[Cooper Findings full list]

05000298/FIN-2012002-03

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