05000298/FIN-2011009-01
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Finding | |
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Title | Inadequate Post-Fire Safe Shutdown Procedures |
Description | An apparent violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, and Criterion XVI, Corrective Action, with a preliminary white significance, was identified for failure to ensure that some steps contained in Emergency Procedures at Cooper Nuclear Station would work as written and the concurrent failure to assure that a condition adverse to quality was promptly identified and corrected, respectively. Specifically, steps in Emergency Procedure 5.4 POST-FIRE, Post-Fire Operational Information, and Emergency Procedure 5.4 FIRE-SID, Fire Induced Shutdown From Outside Control Room, intended to reposition motor operated valves from the motor starter cabinet, would not have worked as written because the steps were not appropriate for the configuration of three valve motor starters. This finding was entered into the licensee\\\'s corrective action program under Condition Reports CR-CNS-201 0-08193 and CR-CNS-2010-08242, however the licensee failed to adequately correct the procedure and the procedure remained unworkable. The failure to verify that procedure steps needed to safely shutdown the plant in the event of a fire would actually reposition motor operated valves to the required positions and the simultaneous failure to address the previous finding that the same procedure steps would not work as written, was a performance deficiency. This finding was more than minor safety significance because it impacted the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to external events (such as fire) to prevent undesirable consequences. This finding affected both the procedure quality and protection against external factors (such as fires) attributes of this cornerstone objective. This finding was determined to have a preliminary low-to-moderate safety significance (White) during a Phase 3 evaluation using best available information. This problem, which has existed since 1997, involves risk factors that were not dependent on specific fire damage. The scenarios of concern involve larger fires in specific areas of the plant which trigger operators to implement fire response procedures to place the plant in a safe shutdown condition. Since some of those actions could not be completed using the procedures as written, this would challenge the operators\\\' ability to establish adequate core cooling. This finding had a crosscutting aspect in the Corrective Action Program component, under the Problem Identification and Resolution area (P.1 (c) - Evaluation), because the licensee failed to properly evaluate the circuit operation or conduct verification tests to ensure that corrective actions for a previous violation would reliably position the three valves. Upon identification of this issue, both emergency procedures were revised to assure correct valve alignment by manually operating the valve locally. Therefore, this finding does not represent a current safety concern. |
Site: | Cooper ![]() |
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Report | IR 05000298/2011009 Section 1R05 |
Date counted | Mar 31, 2011 (2011Q1) |
Type: | Violation: White |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.05 |
Inspectors (proximate) | A Vegel E Uribe G George J Mateychick J Watkins S Alferink |
CCA | P.2, Evaluation |
INPO aspect | PI.2 |
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Finding - Cooper - IR 05000298/2011009 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Cooper) @ 2011Q1
Self-Identified List (Cooper)
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