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MONTHYEARML22207A0492022-07-25025 July 2022 Information Request, Security IR 2022402 NLS2021035, Attachment/Enclosureport of Change and Summary of 50.54(q) Analysis - On-Shift Staffing Analysis, Rev. 32021-05-10010 May 2021 Attachment/Enclosureport of Change and Summary of 50.54(q) Analysis - On-Shift Staffing Analysis, Rev. 3 NLS2016063, Enclosure 2: Response to Areas of Requested Information in Appendix a of Generic Letter 2016-01, Monitoring of Neutron-Absorbing Materials in Spent Fuel Pools (Non-Proprietary Version)2016-10-27027 October 2016 Enclosure 2: Response to Areas of Requested Information in Appendix a of Generic Letter 2016-01, Monitoring of Neutron-Absorbing Materials in Spent Fuel Pools (Non-Proprietary Version) ML16125A5222016-05-0404 May 2016 FOIA/PA-2016-0455 - Resp 1 - Final, Agency Records Subject to the Request Are Enclosed ML15014A1602015-01-14014 January 2015 Attachment 2 - NRC Working Group Recommendations to Revise the Substantive Cross-Cutting Issue Process ML15014A1532015-01-14014 January 2015 Attachment 1- NEI Comments on NRC Working Group Recommendations to Revise the Substantive Cross-Cutting Issue Process ML13143A3312013-06-0606 June 2013 Operating Boiling-Water Reactor Licensees with Mark 1 and Mark 2 Containments Addresses List - Enclosure 2 ML12056A0522012-03-12012 March 2012 Enclosure 6 - List of Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status ML1003306012010-02-0808 February 2010 Compression Test of Concrete, 4000 Psi ML0933507512010-01-14014 January 2010 Temporary Instruction 2515/180, Managing Fatigue ML1003413132010-01-0808 January 2010 Compression Test of Concrete, 3000 Psi ML0911802472009-03-0909 March 2009 Enclosure 5 - FAQ Log ML0921105892009-03-0606 March 2009 Nebraska Game and Parks Commission Species by County List ML0917606542008-04-0404 April 2008 CNS Lr - Air Pollutants and Control Techniques - Particulate Matter, Control Techniques, EPA ML0917501832008-02-15015 February 2008 Lr - NPPD Statement on Addressing Climate Change ML0732400242007-10-25025 October 2007 Examples of Max Thermal Power License Conditions ML0721104332007-07-25025 July 2007 Questions from 1 Through 8 ML0628602342006-10-11011 October 2006 SERP Worksheet for SDP-Related Finding at Cooper Nuclear Station, Service Water Gland Seal Water Configuration Deficiency ML0628602412006-10-11011 October 2006 Analysis: Brief Description of Issue ML0628602402006-10-11011 October 2006 Analysis: Briefing Description of Issue ML0628602292006-10-11011 October 2006 Analysis: Brief Description of Issue ML0628300792006-10-0606 October 2006 Release Severity and Timing Classification Scheme (Severity, Timing) ML0627101442006-09-25025 September 2006 Violations (Violations Are Severity Level IV Unless Otherwise Stated) ML0623601172006-08-22022 August 2006 Identification and Resolution of Problems - SW System Alignment ML0623601262006-08-22022 August 2006 Loop Category ML0623601232006-08-22022 August 2006 Danger Will Robinson: If You Change Cell Locations You May Break the VB Code! ML0623601192006-08-22022 August 2006 Potential Risk Contribution from Large Early Release Frequency (LERF) ML0622205612006-08-0909 August 2006 SDP Phase 1 Screening Worksheet for IE, Ms, and B Cornerstones ML0622204842006-08-0909 August 2006 Undated Paper, Page 8, Table 2 ML0622204962006-08-0909 August 2006 Preliminary Risk Screening for Cooper Service Water Issues ML0622205002006-08-0909 August 2006 Danger Will Robinson: If You Change Cell Locations You May Break the V ML0622205442006-08-0909 August 2006 State the Performance Deficiency Exactly as Stated ML0618607002006-07-0303 July 2006 Enclosure - Final Significance Determination Cooper Nuclear Station, Service Water Gland Seal Water Configuration Deficiency ML0601805372005-06-27027 June 2005 CNS - 06-2005 - Initial Examination Written Reference Handout ML0628602152004-12-0202 December 2004 SERP Worksheet for DP-Related Finding at Cooper Nuclear Station, Service Water Gland Seal Water Configuration Deficiency ML0628601972004-11-30030 November 2004 E-Mail from Sanborn to Allen Et Al., Agenda for Region IV Serp'S on Thurs., Dec. 2, Outside Scope ML0628601862004-10-20020 October 2004 SERP Worksheet for SDP-Related Finding at Cooper Nuclear Station, Service Water Gland Seal Water Configuration Deficiency ML0619802422004-10-18018 October 2004 NRC Question B and CNS Answer ML0619802352004-10-18018 October 2004 NRC Question a and CNS Answer ML0619802282004-09-22022 September 2004 Condition Report CR-CNS-2004-06422, Alarm Procedure Errors ML0619404202004-09-21021 September 2004 CNS Answers to NRC Questions ML0623602872004-08-25025 August 2004 Memo from R. A. Gramm (NRR) to T. A. Bergman (Oedo), Subj: G20040484, Re-Issued Briefing Package for Drop-In Visit on September 2, 2004 by Nebraska Public Power District (NPPD) Officials... ML0628601042004-07-15015 July 2004 SERP Worksheet for SDP-Related Finding at Cooper Nuclear Station, Service Water Gland Seal Water Configuration Deficiency ML0628601052004-07-15015 July 2004 SERP Worksheet for SDP-Related Finding at Cooper Nuclear Station, Service Water Gland Seal Water Configuration Deficiency ML0628601062004-07-15015 July 2004 SERP Worksheet for SDP-Related Finding at Cooper Nuclear Station, Service Water Gland Seal Water Configuration Deficiency ML0628601092004-07-15015 July 2004 SERP Worksheet for SDP-Related Finding at Cooper Nuclear Station, Service Water Gland Seal Water Configuration Deficiency ML0619404382001-12-26026 December 2001 CNS Notification 10132527 ML0619403082001-06-12012 June 2001 CNS Surveillance Data Sheets - Procedure 7.3.1.11, Revision 3 2022-07-25
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.3 Identification and Resolution of Problems - SW System Alignment
- a. Inspection Scope The inspectors reviewed the root cause analysis and corrective actions regarding a configuration error that occurred when the gland water systems for both divisions of the SW system remained cross-connected for 20 days.
- b. Findings Introduction. A self-revealing finding was identified when the gland water supplies for both SW divisions were discovered to be cross-connected. The finding has potential safety significance greater that very low significance. This is an unresolved item (URI) pending completion of the SDP.
Description. Cooper Nuclear Station is equipped with two divisions of SW, each containing two pumps. The two pumps within a division discharge to a common header which passes through a discharge strainer and continues on to the plant. Each division supplies its own gland water from a tap downstream of the discharge strainer which then splits and goes to each pump. A cross-connect exists between the two gland water supplies which is only used during maintenance activities. If the supplies are cross-connected, the division of SW that is not supplying its own gland water must be declared inoperable.
On February 8, control room operators received trouble alarms on both the Division 1 and 2 SW gland water supplies. In accordance with the alarm response procedure, an operator was dispatched to the SW pump room where it was determined that the alarm was caused by low pressure on each of the gland water systems. There are no operability limits associated with gland water pressure, only gland water flow, which was verified to be acceptable. Since the alarm cleared, no further actions were taken and the occurrence was documented in the Corrective Action Program (CAP) as Notification 1029449.
On February 11, an additional trouble alarm was received on the Division 2 SW gland water supply. The gland water flow was found to be acceptable and the alarm cleared, however, the licensee performed the additional action of verifying the gland water valve lineup. As a result, it was discovered the Division 2 gland water supply valve was shut and the cross-connect valve was open. In response, the licensee immediately declared SW, Division 2 inoperable as well as EDG 2, Division 2 of RHR, and Reactor Equipment Cooling (REC) Division 2. The valve lineup was restored per SOP 2.2.71, "Service Water System," Revision 69, and the affected equipment was declared operable.
Further investigation into this valve misalignment indicated that it had existed since maintenance had been performed on the Division 2 SW discharge strainer on January 21, or approximately 20 days. The apparent cause of this configuration control error was the failure to follow instructions contained in the clearance order for the maintenance performed on the discharge strainer. Clearance Order SWB-1-4324147 SW-STNR-B stated to "release tags and restart [the] strainer lAW [in accordance with]
2.2.71." Neither operator assigned to remove the clearance tags was aware of this
statement nor did they utilize SOP 2.2.71 when restoring the system following the maintenance.
Analysis. The failure to adequately control the configuration of safety systems was considered to be a performance deficiency. This finding affected the Mitigating Systems
.Cornerstone and was more than minor since it was associated with the configuration control of the SW system. The finding was also determined to have potential safety significance greater than very low significance since it resulted in a reliance on Division 1 to maintain operability of Division 2 and rendered EDG 1 inoperable for 20 days.
Enforcement. TS 5.4.1(a) requires written procedures to be implemented as recommended by RG 1.33, Revision 2, Appendix A, February 1978. Appendix A recommends procedures for equipment control. Contrary to this requirement, the licensee failed implement the instructions in Clearance Order SWB-1 -4324147 SW-STRN-B by not restoring the system in accordance with the system operating procedure following maintenance. Pending determination of the finding's safety significance, the finding is identified as URI 50-298/04-02-01, Service Water Valve Misalignment.