05000298/FIN-2017003-02

Finding

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].

02
Site:	Cooper
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

1(6)2(4)3(3)4(0)5(0)6(0)7(0)8(0)9(2)10(5)11(1)12(2)301(0)403(0)404(0)501(0)

IR 05000298/2017003: 1 2 3

Finding List (Cooper) @ 2017Q3

CCA Matrix: 2017Q3

	Q	CCA	Title
05000298/FIN-2016004-01	2016Q4	H.12	Failure to Maintain Reactor Vessel Assembly Procedure to Ensure Adequate Moisture Separator Shielding
05000298/FIN-2016004-03	2016Q4	H.1	Failure to Maintain Service Water Pump Maintenance Procedure
05000298/FIN-2016004-04	2016Q4		Failure to Maintain Main Steam System Operating Procedure
05000298/FIN-2016004-02	2016Q4	H.3	Failure of an Analysis to Demonstrate that Changes Did Not Reduce the Effectiveness of the Emergency Plan
05000298/FIN-2016403-01	2016Q4	H.13	Security
05000298/FIN-2017001-03	2017Q1	H.11	Failure to Identify a Condition Adverse to Quality
05000298/FIN-2017001-06	2017Q1	H.7	Failure to Install Correct Mechanical Stop and Verify Proper Operation
05000298/FIN-2017001-05	2017Q1	H.5	Loss of Shutdown Cooling due to Relay Maintenance
05000298/FIN-2017001-04	2017Q1	H.6	Failure to Address Nonconforming Pipe Thinning in Accordance with the ASME Code
05000298/FIN-2017001-02	2017Q1	P.2	Failure to Identify a Condition Adverse to Quality Associated with the 250 Vdc Electrical System
05000298/FIN-2017001-01	2017Q1	P.1	Failure to Maintain Alternate Shutdown Emergency Procedure
05000298/FIN-2017010-05	2017Q2		Failure to adopt appropriate procedures in accordance with 10 CFR Part 21
05000298/FIN-2017010-04	2017Q2	P.2	Failure to Monitor No. 2 Diesel Generator under 50.65(a)(1) due to Inadequate Maintenance Rule Evaluation
05000298/FIN-2017010-03	2017Q2	P.4	Programmatic Failure to Identify and Correct Adverse Trends
05000298/FIN-2017010-02	2017Q2	H.13	Failure to Perform Timely Operability Determinations
05000298/FIN-2017010-01	2017Q2	P.3	Failure to Assign Corrective Actions to Prevent Recurrence of High Pressure Coolant Injection Failure
05000298/FIN-2017009-02	2017Q2	H.1	Failure to Implement an Adequate Procedure for Equipment Control
05000298/FIN-2017009-01	2017Q2	H.11	Exceeding the Technical Specification A llowed Out of Service Time of the Division I RHR System
05000298/FIN-2017002-03	2017Q2	H.11	Loss of Control Room Ventilation Due to Improper Switch Manipulation
05000298/FIN-2017002-02	2017Q2	H.1	Loss of Control Room Ventilation Due to Ineffective Preventive Maintenance Strategy
05000298/FIN-2017002-01	2017Q2	H.5	Failure to Assess Operability of Technical Specification System Functions during Surveillance Testing
05000298/FIN-2017011-01	2017Q3	P.2	Emergency Transformer Bus Failure due to Inadequate Inspection and Testing Activities
05000298/FIN-2017003-01	2017Q3	H.6	Failure to Ensure Suitability of Materials for the Reactor Building Northeast Fan Coil Unit
05000298/FIN-2017003-02	2017Q3	H.7	Failure to Account for Instrument Uncertainty in Safety-Related Ventilation Surveillance Procedures
05000298/FIN-2017003-03	2017Q3	P.2	Loss of Control Room Ventilation Due to Inadequate Post-Maintenance Testing Activities

Self-Identified List (Cooper)

	Q	Title
05000298/FIN-2017002-04	2017Q2	Licensee-Identified Violation

[Cooper Findings full list]

05000298/FIN-2017003-02

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