05000298/FIN-2017003-02
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Finding | |
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Title | Failure to Account for Instrument Uncertainty in Safety-Related Ventilation Surveillance Procedures |
Description | The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, for multiple examples of the licensees failure to assure that required testing was performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. Specifically, on July 12, 2017, the inspectors identified that Surveillance Procedure 6.1SGT.501, Standby Gas Treatment A Carbon Sample, Carbon Adsorber and HEPA Filter In-place Leak Test, and Components Leak Test, Revision 16, failed to account for test instrument uncertainty in the surveillance acceptance criteria. In response to the inspectors question, the licensee discovered that instrument uncertainty was not accounted for in several standby gas treatment system surveillance procedures, as well as surveillance procedures for the control room emergency filter system; diesel generator ventilation system; control building essential ventilation system; emergency core cooling essential ventilation systems; and several emergency preparedness ventilation systems. Corrective actions to restore compliance included incorporation of instrument uncertainty into procedure changes for the affected surveillance procedures and verification that the new acceptance criteria did not challenge past operability for the affected systems. The licensee entered this issue into the corrective action program as Condition Report CR-CNS-2017-04229.The inspectors determined that the licensees failure to assure surveillance test procedures for safety-related ventilation systems incorporated test instrument uncertainty into acceptance criteria was a performance deficiency. Because the systems involved in this performance deficiency were systems that mitigate the consequences of accidents, the inspectors evaluated the finding under the Mitigating Systems Cornerstone. In accordance with Inspection Manual Chapter 0612, Appendix B, Issue Screening, dated September 7, 2012, the inspectors determined that the performance deficiency was more than minor, and therefore a finding, because it was a programmatic deficiency which adversely impacted the procedure quality 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 acceptance criteria for the licensees safety-related ventilation systems did not assure the availability of these systems to respond to accident conditions, as required by the technical specifications. The inspectors assessed the significance of this finding in accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings at Power, dated June 19, 2012, and determined this finding was of very low safety significance (Green) because it: was not a design deficiency; did not represent a loss of system and/or function; did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time; and did not result in the loss of a high safety-significant, nontechnical specification train. The finding had a cross-cutting aspect in the area of human performance associated with documentation because the licensee failed to ensure that the organization created and maintained complete, accurate, and up-to-date documentation [H.7]. |
Site: | Cooper ![]() |
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Report | IR 05000298/2017003 Section 1R22 |
Date counted | Sep 30, 2017 (2017Q3) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.22 |
Inspectors (proximate) | P Voss C Henderson C Young M Stafford C Jewett L Brookhart E Simpson J Kozal |
Violation of: | 10 CFR 50 Appendix B 10 CFR 50 Appendix B Criterion XI Technical Specification |
CCA | H.7, Documentation |
INPO aspect | WP.3 |
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Finding - Cooper - IR 05000298/2017003 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Cooper) @ 2017Q3
Self-Identified List (Cooper)
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