05000298/FIN-2015001-01
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Finding | |
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| Title | Inadequate Operations Procedure |
| Description | The inspectors identified a non-cited violation of Technical Specification 5.4.1.a, associated with the inadequate Operations Procedure 2.2.7, Condensate Storage and Transfer System, Revision 56. Specifically, the procedure did not require that the affected system, either the high pressure coolant injection system or the reactor core isolation cooling system, be declared inoperable when one or more of the high pressure coolant injection or reactor core isolation cooling test return line isolation valves, HPCI-MOV-21, HPCI-MOV-24, RCIC-MOV-30, or RCIC-MOV-33, were moved off of their closed (passive safety function position) seats. The license entered this deficiency into their corrective action program for resolution as Condition Report CR-CNS-2015-00274. The failure to establish and maintain a correct filling procedure required by Technical Specification 5.4.1.a. was a performance deficiency and resulted in the licensees failure to declare the high pressure coolant injection and reactor core isolation cooling systems inoperable when required to do so. The performance deficiency is more than minor, and therefore a finding, because it is associated with the procedural quality attribute of the Mitigating Systems Cornerstone, and affected the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the high pressure coolant injection and reactor core isolation cooling systems were not declared inoperable when their test return line isolation valves, HPCI-MOV-21, HPCI-MOV-24, RCIC-MOV-30, and RCIC-MOV-33, were taken off their normally closed (passive safety function position) seats. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Finding At-Power, dated June 19, 2012, inspectors determined that the finding was of very low safety significance (Green) because the finding: (1) was not a deficiency affecting the design or qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality; (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, or two separate safety systems out-ofservice for longer than their technical specification allowed outage time; and (4) did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program. The finding has a cross-cutting aspect in the area of human performance associated with Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction techniques. Specifically, licensee personnel fell into a pattern of acceptance regarding Procedure 2.2.7. This resulted in a failure to question the lack of an operability caution statement, even though there was other guidance in the inservice inspection program to that effect [H.12]. |
| Site: | Cooper  |
|---|---|
| Report | IR 05000298/2015001 Section 1R22 |
| Date counted | Mar 31, 2015 (2015Q1) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.22 |
| Inspectors (proximate) | C Henderson D Bradley E Coffman G Warnick J Nance P Nizov R Azua R Latta |
| Violation of: | Technical Specification - Procedures Technical Specification |
| CCA | H.12, Avoid Complacency |
| INPO aspect | QA.4 |
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Finding - Cooper - IR 05000298/2015001 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Cooper) @ 2015Q1
Self-Identified List (Cooper)
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