05000298/FIN-2016002-02
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Finding | |
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Title | Failure to Follow Work Instructions for Post-Maintenance Testing of Safety-Related Ventilation Systems |
Description | The inspectors identified two examples of a non-cited violation of Technical Specification 5.4.1.a, associated with the licensees failure to perform required postmaintenance testing for safety-related ventilation systems in accordance with documented instructions, prior to system restoration. Specifically, the licensee failed to follow work order instructions contained in Work Orders 5062878 and 5065112 for (1) performing surveillance testing to measure the airflow of emergency diesel generator supply fan coil unit HV-DG-1C following maintenance, and (2) performing leak testing of a newly created control room ventilation boundary penetration. Corrective actions included performing the required surveillance test for the diesel generator ventilation unit, retesting the control room penetration in accordance with the procedure, and initiating site-wide communications discussing the errors and reemphasizing procedural adherence. The licensee entered these deficiencies into their corrective action program for resolution as Condition Reports CR-CNS-2016-02207 and CR-CNS-2016-02232. The licensees failure to perform required post-maintenance testing for safety-related ventilation systems, in accordance with documented instructions, was a performance deficiency. This performance deficiency was associated with multiple cornerstones. The first example of the performance deficiency was more than minor, and therefore a finding, because it was associated with the human performance attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to measure supply fan coil unit HV-DG-1C airflow resulted in delayed identification that the maintenance had resulted in degraded flow through the ventilation unit. The second example of the performance deficiency was more than minor, and therefore a finding, because it was associated with the human performance attribute of the Barrier Integrity Cornerstone and affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases and that the radiological barrier functionality of the control room is maintained. Specifically, the licensees failure to follow post-maintenance testing instructions resulted in a challenge to the operability of the newly created control room boundary penetration seal. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, the inspectors determined that the finding was of very low safety significance (Green) because it did not represent a design or qualification deficiency; did not represent a loss of safety function; did not represent a loss of a single train for greater than its technical specification allowed outage time; did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating events; did not represent an actual open containment pathway; and did not involve a reduction in function of hydrogen igniters. The finding had a crosscutting aspect in the area of human performance associated with work management, because the licensee failed to implement a process of planning, controlling, and executing work activities such that nuclear safety was the overriding priority, including the need for coordination with different work groups or job activities. Specifically, the licensee failed to control, execute, and coordinate safety-related ventilation work activities to ensure all required post-maintenance testing was completed satisfactorily prior to declaring the associated equipment operable (Section 1R19). [H.5] |
Site: | Cooper ![]() |
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Report | IR 05000298/2016002 Section 1R19 |
Date counted | Jun 30, 2016 (2016Q2) |
Type: | NCV: Green |
cornerstone | Barrier Integrity, Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.19 |
Inspectors (proximate) | C Henderson C Young G Guerra G Warnick J Kirkland J Melfi N Greene P Elkmann P Voss |
Violation of: | Technical Specification |
CCA | H.5, Work Management |
INPO aspect | WP.1 |
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Finding - Cooper - IR 05000298/2016002 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Cooper) @ 2016Q2
Self-Identified List (Cooper)
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