05000298/FIN-2015008-03
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Finding | |
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| Title | Main Steam Isolation Valve Scram Closure condition Prohibited By Technical Specifications |
| Description | The team identified two examples of a non-cited violation of Technical Specification 3.3.1.1, Reactor Protection System Instrumentation, required Action A, for the licensees failure to place inoperable main steam isolation valve closure scram channels in trip within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when Surveillance Requirement 3.3.1.1.9 to perform channel functional testing was not met. Specifically, on January 31 and May 16, 2015, the licensee tested inboard main steam isolation valves MS-AOV-80A and MS-AOV-80B limit switches associated with main steam isolation valve closure scram channel multiple times prior to declaring them operable. The licensee did not evaluate for pre-conditioning of the limit switches to determine if the actual as-found condition was masked, and did not ensure the discrepancy was corrected, before repeating the surveillance test. This resulted in repetitive testing to achieve acceptable results that led to declaring the limit switches operable. The station did enter the required action statements for Technical Specification 3.3.1.1 for MS-AOV-80A limit switch A on May 16, 2015, and MS-AOV-80B limit switch A on May 19, 2015. All inboard main steam isolation valve limit switches in question were replaced during Planned Outage 2015-01 conducted from May 30 to June 1, 2015. The licensee entered this issue into the corrective action program as condition reports CR-CNS-2015-03456, CR-CNS-2015-03483, and CR-CNS-2015-03484. The licensees failure to adequately assess operability during multiple performances of channel functional surveillance testing for reactor protection system main steam isolation valve closure scram function in violation of Technical Specification 3.3.1.1, Reactor Protection System Instrumentation, is a performance deficiency. The performance deficiency was determined to be more than minor, and therefore a finding, because it was associated with the human performance attribute of the mitigating systems cornerstone and affects the associated cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events. Specifically, the licensee did not evaluate for pre-conditioning of the limit switches to determine if the actual as-found condition was masked, and ensure the discrepancies were corrected, before repeating the surveillance test. This resulted in repetitive testing to achieve acceptable results that led to declaring the limit switches operable. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Finding At-Power, dated June 19, 2012, the inspectors determined that the finding was of very low safety significance (Green) because the finding: (1) did not affect a single reactor protection system trip signal to initiate a reactor scram and the function of other redundant trips or diverse methods of reactor shutdown (e.g. other automatic reactor protection system trips, alternate rod insertion, or manual reactor trip capacity); (2) did not involve control manipulations that unintentionally added positive reactivity (e.g., cold-water injection, inadvertent control rod movement, recirculation pumps speed control); and (3) did not result in a mismanagement of reactivity by the operator(s) (e.g., reactor power exceeding the licensed power limit, inability to anticipate and control changes in reactivity during crew operations). The finding has a cross-cutting aspect in the area of human performance associated with procedural adherence because individuals did not follow processes, procedures, and work instructions [H.8]. |
| Site: | Cooper  |
|---|---|
| Report | IR 05000298/2015008 Section 4OA2 |
| Date counted | Jun 30, 2015 (2015Q2) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71152 |
| Inspectors (proximate) | C Henderson E Ruesch J Melfi P Jayroe |
| Violation of: | Technical Specification - Procedures Technical Specification |
| CCA | H.8, Procedure Adherence |
| INPO aspect | WP.4 |
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Finding - Cooper - IR 05000298/2015008 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Cooper) @ 2015Q2
Self-Identified List (Cooper)
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