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05000285/FIN-2012004-032012Q3Fort CalhounFailure to Establish and Implement Adequate Procedures for Meteorological Monitoring and the Off-Site Dose Calculation ManualInspectors identified two examples of a non-cited violation of very low safety significance of Technical Specification 5.8.1 for the failure to adequately establish, implement, and maintain procedures for: (1) the onsite meteorological monitoring systems; and (2) reporting meteorological data in accordance with the Offsite Dose Calculation Manual requirements. The licensee entered these issues into the corrective action program as Condition Reports 2012-05658, 2012-05724 and 2012-05777. The failure to establish, implement, and maintain procedures to ensure the meteorological monitoring equipment is operable and required meteorological data is reported was a performance deficiency. This finding is more than minor because it affected the Public Radiation Safety cornerstone attribute of program and process. The failure to have and use applicable procedures to ensure the operability of the meteorological monitoring system and the accuracy of the Annual Radiological Effluent Release Report has the potential to impair public dose assessments of routine and accidental radioactive effluent releases. Using IMC 0609 Appendix D, Public Radiation Safety Significance Determination Process, the inspectors determined this finding to be of very low safety significance because the finding did not represent a significant degradation of the ability to assess dose to members of the public and the actual releases were well below established limits for members of the public. This finding has a cross-cutting aspect in the human performance area associated with the resources component because the licensee failed to ensure that personnel, procedures, and other resources were adequate for the operability of the meteorological monitoring system and implementation of Offsite Dose Calculation Manual requirements related to the annual effluent report.
05000285/FIN-2012004-042012Q3Fort CalhounFailure to Ensure Breaker Coordination of 480 VAC Electrical Power Distribution System Was MaintainedThe team identified a violation of 10 CFR 50 Appendix B Criteria III, Design Control. Specifically, the design modification package for the 480 VAC breaker replacements failed to ensure the breaker coordination for the 480 VAC electrical buses was maintained. As a result, feeder breaker 1B3A tripped unexpectedly during the fire event in the 1B4A switchgear. This performance deficiency also resulted in the loss of multiple buses on both trains of 480 VAC, including ECCS systems, from a single fault on a 480 VAC bus. This finding and its corrective actions will be managed by the NRCs Inspection Manual Chapter 0350 Oversight Panel. This finding is associated with Enforcement Action 12-121. The failure to ensure that the 480 VAC electrical power distribution system design requirements were maintained was a performance deficiency that was within OPPDs ability to foresee and prevent. The performance deficiency was reviewed using NRC Inspection Manual Chapter 0612, Appendix B, Issue Screening, and the issue was determined to be more than minor because it affected the Initiating Events Cornerstone attributes of protection against external events (i.e., fire) and design control. The issue adversely affected the associated cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The significance of this finding is bounded by the significance of the Red finding documented in Inspection Report 05000285/2012010. The licensee entered this issue into its corrective action program as CR 2011-6621. The performance deficiency had a cross-cutting aspect in the area of human performance associated with resources because OPPD failed to ensure that station procedures for engineering changes, plant modifications, inspections, installations, and maintenance contained sufficient details.
05000285/FIN-2012005-012012Q3Fort CalhounFailure to Update the Safety Analysis Report Solid WasteThe inspectors identified a cited violation of 10 CFR 50.71(e), Maintenance of Records, Making of Reports, for the failure to update the Updated Safety Analysis Report with a detailed description of the Original Steam Generator Storage Facility. Specifically, since December 2006, the licensee stored a significant source of radioactivity in the Original Steam Generator Storage Facility, but failed to describe the volume of waste, the principal sources of radioactivity, the total quantity of radioactivity, and the estimated dose rate at the site boundary per curie of radioactivity in the Updated Safety Analysis Report. The licensee has entered this violation into their corrective action program as Condition Report 2012-05725. This issue was evaluated using traditional enforcement because it has the potential to impact the NRCs ability to perform its regulatory function. This issue is being characterized as a Severity Level IV violation in accordance with Section 6.1.d.3 of the NRC Enforcement Policy. Cross-cutting aspects are not assigned to traditional enforcement violations. NOV summary: The inspectors identified a cited violation of 10 CFR 50.71(e), Maintenance of Records, Making of Reports, for the failure to update the Updated Safety Analysis Report with a detailed description of the Original Steam Generator Storage Facility. Specifically, since December 2006, the licensee stored a significant source of radioactivity in the Original Steam Generator Storage Facility, but failed to describe the volume of waste, the principal sources of radioactivity, the total quantity of radioactivity, and the estimated dose rate at the site boundary per curie of radioactivity in the Updated Safety Analysis Report. The licensee has entered this violation into their corrective action program as Condition Report 2012-05725. This issue was evaluated using traditional enforcement because it has the potential to impact the NRCs ability to perform its regulatory function. This issue is being characterized as a Severity Level IV violation in accordance with Section 6.1.d.3 of the NRC Enforcement Policy. Cross-cutting aspects are not assigned to traditional enforcement violations.
05000285/FIN-2013005-012013Q2Fort CalhounFailure To Post A High Radiation Area Resulting In A Dose Rate AlarmThe inspectors reviewed a self-revealing non-cited violation of Technical Specification 5.11.1, which was the result of a radiation protection technician failing to monitor changing radiological conditions and post a high radiation area. As a result, an operator entered a high radiation area with dose rates greater than 100 millirems per hour without knowing the dose rates in the area. In response, licensee representatives immediately surveyed the affected areas, posted the area as a high radiation area, documented the occurrence in the corrective action program as Condition Report 2013-02603, and prepared an Apparent Cause Analysis Report. The failure to post a high radiation area with dose rates greater than 100 millirems per hour is a performance deficiency. The performance deficiency was more than minor because it was associated with the Occupational Radiation Safety Cornerstone attribute of program and process (exposure control) and adversely affected the cornerstone objective of ensuring adequate protection of worker health and safety from exposure to radiation because the failure exposed workers to higher than anticipated radiation dose rates. The Occupational Radiation Safety Cornerstone was affected; therefore, the inspectors used Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, dated August 19, 2008, to determine the significance of the violation. The violation had very low safety significance because: (1) it was not an as low as is reasonably achievable finding, (2) there was no overexposure, (3) there was no substantial potential for an overexposure, and (4) the ability to assess dose was not compromised. This violation had a cross-cutting aspect in the human performance area, work practices component, because the licensee failed to hold proper pre-job briefings and follow station procedures requiring monitoring of changing radiological conditions to ensure personnel did not proceed in the face of unexpected circumstances.
05000285/FIN-2013005-022013Q2Fort CalhounFailure to Adequately Plan and Control Work Activities to Maintain Doses ALARAThe inspectors reviewed a self-revealing finding of very low safety significance involving the licensees failure to adequately plan and control work activities relating to the Chemical Volume Control System piping to maintain doses ALARA. Specifically, the work was fast-tracked, which caused issues with the understanding of the work scope and led to the mismanagement of foreseeable aspects in the ALARA planning process. In response, the licensee evaluated their ALARA process and entered the issue into their corrective action program as Condition Report 2012-20825. The failure to maintain doses ALARA due to inadequate planning was a performance deficiency. The performance deficiency is more than minor because it negatively affected the Occupational Radiation Safety Cornerstone, in that inadequate planning led to increased collective radiation dose for occupational workers. This resulted in a finding because no violation of regulatory requirements occurred, but the licensee failed to meet a self-imposed standard. The Occupational Radiation Safety Cornerstone was affected; therefore, the inspectors used Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, dated August 19, 2008, to determine the significance of the finding. The finding had very low safety significance because although the finding involved ALARA planning and work controls, the licensees latest three-year rolling average collective dose was less than 240 person-rem. This finding had a cross-cutting aspect in the human performance area, associated with the work control component, because the licensee failed to communicate, coordinate, and cooperate with each other during an activity in which interdepartmental communication was necessary.
05000285/FIN-2013005-032013Q2Fort CalhounFailure To Survey Resulting In Unintended Occupational DoseThe inspectors reviewed a self-revealing non-cited violation of 10 CFR Part 20.1501(a), which was the result of an inadequate survey to evaluate potential hazards from airborne radiation. As a result, a radiation worker received an uptake of 10 millirem in unintended dose. In response, the licensee immediately surveyed the area, performed whole body counts on the affected worker, decontaminated the affected worker, and documented the occurrence in the corrective action program as Condition Report 2012-19508. The failure to perform a survey to evaluate the radiological conditions and potential hazard from airborne radiation is a performance deficiency. The licensee had the ability to foresee a possible intake if the survey had been properly performed. The performance deficiency was more than minor because it was associated with the Occupational Radiation Safety Cornerstone attribute of program and process (exposure control) and adversely affected the cornerstone objective of ensuring adequate protection of worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. The Occupational Radiation Safety Cornerstone was affected; therefore, the inspectors used Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, dated August 19, 2008, to determine the significance of the violation. The violation had very low safety significance because: (1) it was not an as low as is reasonably achievable finding, (2) there was no overexposure, (3) there was no substantial potential for an overexposure, and (4) the ability to assess dose was not compromised. This violation had a cross-cutting aspect in the human performance area, work control component, because the licensee failed to maintain communication during activities in which interdepartmental coordination was necessary to assure plant and human performance, such as the need to keep personnel apprised of changing radiological conditions that affected work activities.
05000285/FIN-2013005-042013Q2Fort CalhounLicensee-Identified ViolationTitle 10 CFR Part 50.49, paragraph (d), states, in part, the applicant or licensee shall prepare a list of electric equipment important to safety. In addition, the applicant or licensee shall include the information in paragraphs (d)(1), (2), and (3) of this section for this electric equipment important to safety in a qualification file. The applicant or licensee shall keep the list and information in the file current and retain the file in auditable form for the entire period during which the covered item is installed in the nuclear power plant or is store for future use. Contrary to 10 CFR 50.49, paragraph (d), prior to December 12, 2012, the licensee failed to keep the list and information in the electric equipment qualification file current for electric equipment inside containment when the analysis of record for the Main Steam Line Break accident changed. The licensee entered this condition into the corrective action program as Condition Report 2012-03718. The finding is of very low safety significance, because it is a design or qualification deficiency confirmed not to result in the loss of operability or functionality of the system.
05000285/FIN-2013005-052013Q2Fort CalhounLicensee-Identified ViolationTitle 10 CFR Part 50.72, paragraph(b)(3)(ii)(B), states, in part, the licensee shall notify the NRC as soon as practical and in all cases within eight hours of the occurrence of any of the following event or condition that results in the nuclear power plant being in an unanalyzed condition that significantly degrades plant safety. Contrary to 10 CFR 50.72 (b)(3), from December 13, 2011, to July 23, 2012, the licensee failed to make a notification within eight hours of identifying a condition that resulted in the nuclear power plant being in an unanalyzed condition that significantly degraded plant safety when the licensee determined that various electrical components inside containment were not analyzed for harsh environment conditions caused by a postulated main steam line break. The licensee entered this condition into the corrective action program as CR 2012-03718. Consistent with the NRC Enforcement Policy, this violation is considered a Severity Level IV violation.
05000285/FIN-2014003-012014Q2Fort CalhounFailure to Control an Entry to a High Radiation Area Resulting in a Dose Rate AlarmThe inspectors reviewed a self-revealing, non-cited violation of Technical Specification 5.11.1.b, which resulted from an individual entering a high radiation area without being aware of the radiological conditions. Specifically, on July 19, 2013, an operator was performing valve lineup work in the reactor building. Although the operator was on a radiation work permit that allowed access to high radiation areas, access was only allowed with knowledge of the dose rates in the areas entered. As immediate corrective actions, the radiation protection supervisors coached the operator on properly informing Radiation Protection of his planned work areas and coached the radiation protection technician on having a more intrusive questioning attitude during briefings so that radworkers are properly informed of all hazards and radiological conditions. This issue was documented in the licensees corrective action program as Condition Report CR 2014-14693. The entry into a high radiation area without knowledge of the radiological conditions is a performance deficiency and is a violation of Technical Specification 5.11.1.b. The performance deficiency is more than minor because it is associated with the Occupational Radiation Safety cornerstone attribute of program and process (exposure control) and adversely affects the cornerstone objective of ensuring adequate protection of worker health and safety from exposure to radiation. Using Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, dated August 19, 2008, the inspectors determined the violation has very low safety significance because: (1) it was not an as low as is reasonably achievable finding, (2) there was no overexposure, (3) there was no substantial potential for an overexposure, and (4) the ability to assess dose was not compromised. This violation has a cross-cutting aspect in the human performance area, associated with teamwork, because the operator did not properly communicate his work locations to the radiation protection technician for briefing and the technician did not display a questioning attitude to understand the work locations for the operator to properly brief him and ensure nuclear safety was maintained.
05000285/FIN-2014004-012014Q3Fort CalhounFailure to Implement Procedural and alarm setpoint changes in support of an Operability EvalThe inspectors identified a Green finding for the licensees failure to implement procedural changes and water level alarm setpoint changes relied upon by operators to initiate compensatory actions to maintain the operability of raw water pump AC-10C. The licensee subsequently implemented these changes. The performance deficiency is more than minor because it is related to the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the reliability of systems that respond to initiating events to prevent undesirable consequences, in that the failure to implement the required procedure and setpoint changes increased the likelihood that the affected raw water pump cable would become inoperable after significant rainfall or flooding. The inspectors performed an initial screening of the finding in accordance with NRC Manual Chapter IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, dated July 1, 2012, this finding is of very low safety significance (Green) because it: (1) was not a deficiency affecting the design or qualification of a mitigating system; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and (4) does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hours. The finding has a cross-cutting aspect in the Human Performance area associated with the Avoiding Complacency aspect because operators did not recognize and plan for the possibility of mistakes and assumed that the necessary procedural and alarm setpoint changes had been made.
05000285/FIN-2014004-022014Q3Fort CalhounFailure to Maintain a Testing Program for the Containment Spray SystemThe inspectors identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, because the licensee failed to ensure that a surveillance test program was sufficient to demonstrate that the containment spray (CS) system would perform satisfactorily in service. Specifically, from February, 2014, to September, 2014, the licensee failed on several occasions to adequately adjust the frequency of testing for gas voids in the CS system upon identification of gas voids beyond acceptance criteria. Consequently, the test monitoring frequency did not ensure operability of the CS system between tests. Subsequently, the licensee increased the CS monitoring frequency. The performance deficiency is more than minor because it is associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the reliability of systems that respond to initiating events to prevent undesirable consequences. The inspectors performed an initial screening of the finding in accordance with NRC Manual Chapter IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, dated July 1, 2012, this finding is of very low safety significance (Green) because it: (1) was not a deficiency affecting the design or qualification of a mitigating system; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and (4) does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant for greater than 24 hours in accordance with the licensees maintenance rule program. The finding has a cross-cutting aspect in the Problem Identification and Resolution area and the Trending aspect because the licensee failed to trend and analyze information from the corrective action program and other assessments in the aggregate to identify programmatic and common cause issues.
05000285/FIN-2014004-032014Q3Fort CalhounFailure to Verify the Adequacy of the Design of the FO-10 to FO-1 Fuel Oil Transfer SystemThe inspectors identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control. because the licensee did not implement design-control measures commensurate with those applied to the original design when they implemented a system modification to the emergency diesel generators (EDGs) fuel oil transfer systems. Specifically, in 1991, the licensee did not implement the design change or modification process when they placed an auxiliary boiler underground fuel oil storage tank fuel oil transfer system into service to meet the support function of transferring sufficient fuel to meet the mission time of the EDGs safety function. The licensee has scheduled a design review of this modification. The performance deficiency is more than minor because it is associated with the Design Control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstones objective to ensure the reliability of systems that respond to mitigating events to prevent undesirable consequences. Despite not performing a design review of this modification, no loss of the fuel oil transfer system function occurred. The inspectors performed an initial screening of the finding in accordance with NRC Manual Chapter IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, dated July 1, 2012, this finding is of very low safety significance (Green) because it: (1) was not a deficiency affecting the design or qualification of a mitigating system; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and (4) does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safetysignificant for greater than 24 hours in accordance with the licensees maintenance rule program. The finding does not have a cross-cutting aspect because the failure to implement the design change verification process is not indicative of current licensee performance. The licensees current design change procedures require design reviews of this type of in-field modification.
05000298/FIN-2010004-012010Q3CooperFailure to Adequately Monitor the Performance of the Screen Wash SystemThe inspectors identified that the licensee failed to correctly determine that a plant power reduction caused by a clogged screen wash system for the circulating water system was a maintenance preventable functional failure that exceeded the plant level performance criteria. As a direct consequence, the licensee failed to assess this Maintenance Rule Program function per 10 CFR 50.65(a)(1) as required by station procedures. This issue was determined to involve a noncited violation of 10 CFR 50.65(a)(2) requirements for monitoring the effectiveness of maintenance at nuclear power plants. The licensee entered this issue in their corrective action program as CR-CNS-2010-05631. This finding is more than minor because failure to monitor the effectiveness of the screen wash system function CW-F01 affects the protection against external factors attribute of the initiating events cornerstone, since this system was intended to limit the likelihood of events that upset plant stability. The inspectors determined that this performance deficiency was an additional, but separate consequence of the obstructed screen wash system. The inspectors determined that this finding occurred as a separate consequence of the licensees functional failure assessment process, and that the system performance problem was not directly attributable to this finding. Therefore, this finding cannot be processed through the significance determination process, and was determined to be green using the guidance of Appendix B to Manual Chapter 0612 and Appendix D to Inspection Procedure 71111.12. The finding has a crosscutting aspect in the area of human performance associated with decision-making because the licensee did not use conservative assumptions in the functional failure evaluation of an obstructed screen wash system (H.1(b))
05000298/FIN-2010004-022010Q3CooperFailure to Follow Procedure Results in Repeat Equipment FailureA self-revealing finding was identified for the licensees failure to follow the guidance of Administrative Procedure 0.5.EVAL, Preparation of Condition Reports, Revision 21. Specifically, corrective actions to fix the Reactor Recirculation Motor Generator field breaker failure from 2009 failed to meet the measurable and reasonable criteria when the actions did not prevent a repeat failure of the same breaker and resulted in a fire in the breaker. The licensee entered this issue in their corrective action program as CR-CNS-2009-04115. The finding is more than minor because it adversely affected the protection against external factors (Fire), attribute of the initiating events cornerstone, and adversely affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Using Manual Chapter 0609, Significance Determination Process, Phase 1 Worksheet (Initial Screening and Characterization of Findings) the finding was determined to have very low safety significance since it did not contribute to the likelihood of a primary or secondary system loss-of-coolant accident, did not contribute to a loss of mitigation equipment, and did not increase the likelihood of a fire or internal/external flood. This finding has a crosscutting aspect in the corrective action program component of the problem identification and resolution area due to licensee corrective actions that failed to implement a resolution of field breaker failures.
05000298/FIN-2010004-032010Q3CooperLicensee-Identified ViolationTitle 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, requires activities affecting quality shall be prescribed by instructions appropriate to the circumstances. Contrary to this on December 21, 2009 Operations found the high pressure coolant injection turbine was not operable due to inadequate work instructions to prevent the mixing of unfiltered and filtered oil. Introduction of unfiltered oil resulted in particulate in the electronic governor remote unit leading to corrosion and binding of the electronic governor remote unit rendering the high pressure coolant injection system inoperable. The licensee entered this issue in their corrective action program as CR-CNS-2009-10691. This finding is of very low safety significance as determined by a Manual Chapter 0612 significance determination process Phase 3 analysis.
05000298/FIN-2010005-052010Q4CooperDiesel Generator Overspeed Governor Loose Bolting IssueThe inspectors identified an unresolved item associated with the loose bolting issue on the over speed governor of diesel generator two. Specifically, the issue concerns past operability of the diesel, adequacy of previous evaluations and corrective actions taken by the licensee, and procedure quality and use. On September 8, 2009, while performing a monthly surveillance run of diesel generator two, the overspeed governor trip mechanism was observed to be vibrating significantly. The licensee secured the diesel generator, and during subsequent inspection found that all eight nuts that that were used to retain the governor were loose (less than finger tight). The licensee determined that this event had been caused by gasket creep and thermal cycle effects, and had this been occurring over a very long period of time, approximately 30 years. The licensee took corrective actions based on these identified causes. Subsequently, on August 17, 2010, while performing bolt tightness checks the licensee discovered six of eight nuts that were used to retain the diesel generator two overspeed governor drive unit were loose (less than finger tight), and one bolt was at a reduced torque (48 ft-lbs). The licensee determined that the cause of this event was improper torque being applied to the nuts when they had been reassembled following the September 2009 issue along with thermal cycle effects. During review of the root cause report for the loose bolting issue found on diesel generator two in August 2010, the inspectors noted that this condition appeared to be a repeat occurrence of what had been found in September 2009, and as such, questioned the licensees determined cause for the 2010 issue. The inspectors also questioned key assumptions used by the licensee when evaluating this issue. Furthermore, the inspectors noted that the past operability evaluation that the licensee performed failed to consider all pertinent conditions that could have affected the equipments ability to perform its design basis function, specifically elevated vibrations associated with the asfound condition. As such, the inspectors determined that more inspection was necessary to resolve this issue. Accordingly, this issue is being considered an unresolved item pending further review. An unresolved item is an issue requiring further information to determine if it is acceptable, if it is a finding, or if it constitutes a violation of NRC requirements. As such, no analysis of this issue has occurred. Additional information was needed to determine whether a violation of regulatory requirements occurred. Pending further review of additional information provided by the licensee, this issue is being treated as an Unresolved Item 05000298/2010005-05, Diesel Generator Overspeed Governor Loose Bolting Issue.
05000298/FIN-2011003-012011Q2CooperFailure to Assess Potential Adverse Effects on Internal Flooding AnalysisThe inspectors identified two examples of a noncited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated with the failure of the licensee to ensure compliance with the requirements of station Procedure 3.3SAFE, Safety Assessment. Specifically, licensee personnel failed to identify the potential adverse impact to the station internal flooding analysis for the installation of a temporary chemical decontamination skid associated with the fuel pool cooling system, and meshing material installed around the handrails. The licensee performed an evaluation for the skid which demonstrated compliance, and removed the meshing material when it was identified. These issues were entered into the licensees corrective action program as Condition Reports CR-CNS-2011-2182, CR-CNS-2011-2232, CR-CNS-2011-2240, CR-CNS-2011-2242, CR-CNS-2011-2249, CR-CNS-2011-3551, CR-CNS-2011-5754, and CR-CNS-2011-5798. The failure to comply with the requirements of station Procedure 3.3SAFE and identify and evaluate the potential adverse impact to the stations internal flooding analysis of several configuration changes was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the design control attribute of the Mitigating Systems Cornerstone, and affected the associated cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and is therefore a finding. Using Manual Chapter 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, the finding was determined to have very low safety significance because the finding: (1) was not a design or qualification issue confirmed not to result in a loss of operability or functionality; (2) did not represent an actual loss of safety function of the system or train; (3) did not result in the loss of one or more trains of nontechnical specification equipment; and (4) did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The finding was determined to have a cross-cutting aspect in the area of human performance, associated with the decision making component, in that the licensee failed to use conservative assumptions in decision making. Specifically, the licensees qualitative analysis comparing the two hatches failed to take into account configuration differences associated with external structures around the hatch (H.1(b)) (Section 1R06).
05000298/FIN-2011003-022011Q2CooperFailure to Follow Procedure Results in Inadequate Operability DeterminationsThe inspectors identified multiple examples of a noncited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, regarding the licensees failure to follow the requirements of EN-OP-104, Operability Determinations. Specifically, the inspectors identified examples in which operations failed to properly document the basis for operability when a degraded or nonconforming condition had been identified. The licensee entered these issues into their corrective action program with individual condition reports for each issue. Corrective actions resulted in revised operability reviews and corrective actions to processes and training to prevent similar operability determination problems. The performance deficiency is more than minor because the condition of performing inadequate operability determinations could become more significant if left uncorrected. Unrecognized degradation of essential equipment impacts the equipment 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 (i.e., core damage). Using Manual Chapter 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, the finding was determined to have very low safety significance because the finding: (1) was not a design or qualification issue confirmed not to result in a loss of operability or functionality; (2) did not represent an actual loss of safety function of the system or train; (3) did not result in the loss of one or more trains of nontechnical specification equipment; and (4) did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. This finding was determined to have a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action component, in that, the licensee failed to thoroughly evaluate problems such that the resolutions addressed causes and extent of conditions. Specifically, licensee personnel failed to thoroughly evaluate conditions adverse to quality and perform meaningful operability determinations (P.1(c))(Section 1R15).
05000298/FIN-2011003-032011Q2CooperFailure to Follow Procedure Results in Personnel ContaminationsThe inspectors reviewed a self-revealing, noncited violation of Technical Specification 5.4.1, resulting from workers who entered a posted contamination area without required protective clothing and were contaminated as a result. The condition was detected when contamination monitors alarmed during the workers attempt to process out of the radiologically controlled area. The workers were then decontaminated prior to exiting. The licensee entered the issue into the corrective action program as Condition Report CR-CNS-2011-03311. The corrective actions included communication of the issue throughout the department. The failure to follow radiation work permit requirements is a performance deficiency. The finding was more than minor because it was associated with the Occupational Radiation Safety Cornerstone attribute (exposure control) of program and process and affected the cornerstone objective, in that, working in an area outside the scope of the radiation work permit and not following protective clothing requirements resulted in personnel contaminations. Using the Occupational Radiation Safety Significance Determination Process, the inspectors determined the finding to have very low safety significance because: (1) it was not associated with ALARA planning or work controls, (2) there was no overexposure, (3) there was no substantial potential for an overexposure, and (4) the ability to assess dose was not compromised. The finding was determined to have a cross-cutting aspect in the area of human performance, associated with the work control component, in that, the licensee failed to appropriately coordinate work activities by incorporating actions to address plant conditions that may affect work activities. Specifically, the radiation protection technician failed to verify current conditions prior to briefing workers on expected plant conditions that may affect work activities (H.3(b))(Section 1R20.1).
05000298/FIN-2011003-042011Q2CooperCommunication of an NRC Inspectors Presence by Station PersonnelThe inspectors identified a Severity Level IV noncited violation of 10 CFR 50.70, Inspections, associated with the licensees failure to ensure that the arrival and presence of NRC inspectors was not communicated to persons at the facility. Specifically, a radiation protection technician manning the access point to the drywell informed other individuals entering the drywell to perform work of inspectors presence and location during an unannounced walkdown of the drywell to observe licensee work activities. This issue was entered into the licensees corrective action program as Condition Report CR-CNS-2011-4124. Licensee personnels action of announcing the presence and location of NRC inspectors during an unannounced walkdown inspection was a performance deficiency. The inspectors reviewed this issue in accordance with NRC Inspection Manual Chapter 0612 and the NRC Enforcement Manual. Through this review, the inspectors determined that traditional enforcement was applicable to this issue because the NRC\'s regulatory ability was affected. Specifically, the NRC relies on its ability to perform unannounced inspections to evaluate licensee performance, and communicating the presence and location of NRC inspectors affects their ability to perform these inspections, and as such the regulatory function is impacted. The inspectors determined that this finding was not suitable for evaluation using the significance determination process, and as such, was evaluated in accordance with the NRC Enforcement Policy. The finding was reviewed by NRC management and because the violation was determined to be of very low safety significance, was not repetitive or willful, and was entered into the corrective action program, this violation is being treated as a Severity Level IV noncited violation consistent with the NRC Enforcement Policy. The inspectors determined that there was no cross-cutting aspect associated with this finding because this issue was not indicative of current performance because the violation did not affect any of the safety culture components (Section 1R20.3).
05000298/FIN-2011003-052011Q2CooperFailure to Follow Radiation Work Permit RequirementsThe inspectors reviewed a self-revealing, noncited violation of Technical Specification 5.4.1, resulting from workers who failed to follow radiation work permit requirements and entered a high radiation area, after climbing from one scaffold to another. As corrective action, the licensee posted the area, searched for similar situations in the plant, and entered the issue into the corrective action program as Condition Reports CR-CNS-2011-0318 and -03217. The failure to follow radiation work permit requirements is a performance deficiency. The finding was more than minor because it was associated with the Occupational Radiation Safety Cornerstone attribute (exposure control) of program and process and affected the cornerstone objective, in that, working in an area outside the scope of the radiation work permit and not knowing the dose rates in the high radiation area had the potential to increase personnel dose. Using the Occupational Radiation Safety Significance Determination Process, the inspectors determined the finding to have very low safety significance because: (1) it was not associated with ALARA planning or work controls; (2) there was no overexposure; (3) there was no substantial potential for an overexposure; and (4) the ability to assess dose was not compromised. The finding has a human performance cross-cutting aspect associated with work practices component because the individuals did not use peer or self-checking before climbing to the second scaffold (H.4(a))(Section 2RS01).
05000298/FIN-2011003-062011Q2CooperFailure to Correctly Translate Design Requirements into Installed Plant ConfigurationThe inspectors documented a self revealing, noncited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, associated with the licensees failure to assure that the applicable design basis for structures, systems, and components were correctly translated into specifications, procedures, and instructions. Specifically, the licensee failed to correctly translate the design requirements for the service water zurn strainers reduction gear to motor shaft into the installed plant equipment. This resulted in instances where the strainer motor was not able to perform its function of strainer backwash, an essential function, due to a failure of the wiper arm motor-to-gear box coupling. This issue was entered into the licensees corrective action program as Condition Report CR-CNS-2010-2213. The licensees failure to ensure that design requirements were correctly translated into installed plant equipment was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone, and affected the associated cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and is therefore a finding. Using Manual Chapter 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, the inspectors determined that a Phase 2/3 assessment was required because this was a design or qualification deficiency that did result in a loss of operability or functionality. The inspectors received support from the regional senior reactor analyst to evaluate this issue. As a bounding analysis, the analyst assumed: (1) the only time this design deficiency would cause an issue would be when strainer backwash was required due to debris loading; (2) the licensee had procedures already in place for manual actions in the event of a coupling failure; (3) the licensee would implement these actions before the strainer became inoperable due to debris loading; and (4) these actions were not complex and could easily be implemented. Given these assumptions the analyst determined that the finding was of very low safety significance (Green). This finding did not have a cross-cutting aspect because the most significant contributor did not reflect current licensee performance (Section 4OA2).
05000298/FIN-2011003-072011Q2CooperFailure to Adequately Assess and Manage Risk When Disabling A Hazard BarrierThe inspectors identified a noncited violation of 10 CFR 50.65(a)(4), Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, associated with the licensees failure to perform an adequate risk assessment for a planned maintenance activity. Specifically, on August 19, 2010, during maintenance activities on emergency diesel generator 2, maintenance personnel inappropriately blocked open the steam exclusion boundary door N-103 that protected both emergency diesel generators, without properly assessing the potential effects on the emergency diesel generators and without appropriate compensatory measures in place. As such, this resulted in both emergency diesel generators being inoperable. These issues were entered into the licensees corrective action program as Condition Report CR-CNS-2011-7660. The licensees failure to adequately assess and manage the risk of planned maintenance activities was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone, and affected the associated cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and is therefore a finding. Using Manual Chapter 0609, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process, the finding was determined to have very low safety significance. Specifically, Flowchart 1, Assessment of Risk Deficit, requires the inspectors to determine the risk deficit associated with this issue. The senior reactor analyst performed a bounding analysis and determined that the probability that a high energy line breaks, causing the failure of both emergency diesel generators and initiating a consequential loss of offsite power, can be calculated as 3.0 x 10-7. Given that the change in core damage frequency would be lower than this probability, the analyst determined that the finding was of very low safety significance (Green). The inspectors determined that this finding did not represent current performance because the guidance that formed the basis for the licensees decision making was developed and approved over two years ago (Section 4OA3).
05000298/FIN-2011003-082011Q2CooperFailure to Follow Procedure Results in Degraded Emergency Diesel GeneratorThe inspectors identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, regarding the licensees failure to follow written work instructions. Specifically, the inspectors identified that maintenance personnel, when unable to follow written instructions on torquing emergency diesel generator bolting due to mechanical interference, then used alternate methods. These methods contributed to the subsequent loosening of the bolting and degrading the capability of the emergency diesel generator. The licensee entered this issue into their corrective action program as Condition Report CR-CNS-2011-07653. The performance deficiency is more than minor since this failure to follow procedures resulted in a degraded emergency diesel generator which impacts the equipment 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 (i.e., core damage). The finding was evaluated using Manual Chapter 0609.04, Phase 1 Initial Screening and Characterization of Findings, and was determined to be of very low safety significance (Green) because there was not a design or qualification deficiency that resulted in a loss of operability or functionality, it did not create a loss of system safety function or of a single train for greater than the technical specification allowed outage time, it did not represent an actual loss of risk significant equipment, and it did not affect seismic, flooding, or severe weather initiating events. The finding was determined to have a cross-cutting aspect in the area of human performance, associated with the work practices component, in that, personnel do not proceed in the face of uncertainty or unexpected circumstances. Specifically, when unable to torque emergency diesel generator bolting by following their written procedures, licensee personnel proceeded in the face of uncertainty by using alternate torque methods.
05000298/FIN-2011003-092011Q2CooperFailure to Initiate Condition Reports for Nonconformances Identified During System Walk DownsThe inspectors identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions, for the failure of licensee personnel to take actions to promptly correct a condition adverse to quality. Specifically, the licensee did not take any interim actions to eliminate procedure steps that allowed venting of emergency core cooling systems without determining the amount of gas accumulated and the potential impact on system operability. The performance deficiency associated with this finding involved the failure to correct a condition adverse to quality. This finding was more than minor because it affected the equipment performance attribute of the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of the emergency core cooling systems to respond to initiating events and prevent undesirable consequences. Specifically, licensee personnel failed to promptly correct the previously identified condition adverse to quality of not tracking emergency core cooling system gas accumulation and its potential effects on system operability during surveillance testing. The inspectors performed the significance determination using NRC Inspection Manual Chapter 0609.04, Phase 1 Initial Screening and Characterization of Findings. The finding was determined to be of very low safety significance (Green) because it was not a design or qualification deficiency confirmed not to result in loss of operability or functionality; did not result in loss of a safety function, did not result in loss of safety function of a single train for longer than its allowed outage time, did not result in loss of a risk-significant nontechnical specification system per 10 CFR 50.65, and did not screen as potentially risk significant because of a seismic, flooding or severe weather initiating event. The finding was determined to have a cross-cutting aspect in the area of human performance, associated with the resources component, in that, the licensee failed to provide maintenance of design margins. Specifically, the licensee did not ensure that station procedure were adequate to assure nuclear safety, in that they did require measuring of the amount of entrained gas and any impact on equipment operability.
05000298/FIN-2011003-102011Q2CooperFailure to Promptly Correct an Adverse Condition Related to Emergency Core Cooling System VentingThe inspectors identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the failure of licensee personnel to follow the requirements of Procedure 0.5, Conduct of the Condition Report Process. Specifically, licensee personnel failed to initiate condition reports for adverse conditions related to the inability to remove air from emergency core cooling system piping. Licensee personnel identified that high pressure coolant injection system had an incorrect slope and that the core spray system had concentric reducers that could trap gas; however, personnel failed to initiate a condition report that documented the deficiency. The performance deficiency associated with this finding involved failure of personnel to follow the requirements of Procedure 0.5. Specifically, licensee personnel failed to initiate condition reports for adverse conditions that could result in gas voids in the emergency core cooling systems that could affect operability. The first and third examples are more than minor because the condition of not initiating condition reports for adverse conditions could become more significant if left uncorrected. Using Manual Chapter 0609.04, Phase 1 - Initial Screening and Characterization of Findings, the finding is determined to have very low safety significance because neither example resulted in any loss of safety function of any technical specification required equipment. This finding was determined to have a cross-cutting aspect in the problem identification and resolution area associated with the corrective action program component because licensee personnel failed to implement a corrective action program with a low threshold for identifying issues.
05000298/FIN-2011003-112011Q2CooperLicensee-Identified ViolationTechnical Specification 5.4.1.a Procedures, requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, Appendix A, Section 9.a, requires, in part, that maintenance that can affect the performance of safety-related equipment should be performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. Contrary to the above, in September 2009, the licensee failed to implement written procedures, documented instructions, or drawings appropriate to the circumstances for maintenance that can affect the performance of safety-related equipment. Specifically, the licensee failed to ensure that the work order used when reinstalling the overspeed governor bolting on emergency diesel generator 2 required the use of lubrication, which resulted in the bolting coming loose and resulting in the diesel being declared inoperable. The failure to properly plan maintenance activities on the emergency diesel generator 2 was a performance deficiency. Using Manual Chapter 0609.04, Phase 1 Initial Screening and Characterization of Findings, the inspectors determined this finding to be of very low safety significance because there was not a design or qualification deficiency that resulted in a loss of operability or functionality, it did not create a loss of system safety function or of a single train for greater than the technical specification allowed outage time, it did not represent an actual loss of risk significant equipment, and it did not affect seismic, flooding, or severe weather initiating events.
05000298/FIN-2011003-122011Q2CooperLicensee-Identified ViolationTitle 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions, requires, in part, that Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. Contrary to the above, the licensee failed to promptly identify and correct a condition adverse to quality, associated with bolted fasteners on emergency diesel generator number 2. Specifically, the licensee had postponed implementation of a corrective action, from a previous loose bolting issue associated with the overspeed governor, to perform a 100 percent torque check of all fasteners on the diesel from June until August 2010 due to conflicting work week schedules. As a result, when the bolting was checked the bolts for the overspeed governor were found loose again, and the licensee determined that the loose bolts had been a result of improper maintenance performed when reassembling the joint from the previous bolting issue. Using Manual Chapter 0609.04, Phase 1 Initial Screening and Characterization of Findings, the inspectors determined this finding to be of very low safety significance because there was not a design or qualification deficiency that resulted in a loss of operability or functionality, it did not create a loss of system safety function or of a single train for greater than the technical specification allowed outage time, it did not represent an actual loss of risk significant equipment, and it did not affect seismic, flooding, or severe weather initiating events.
05000298/FIN-2011005-012011Q4CooperFailure to Conspicuously Post a High Radiation AreaThe inspector identified a non-cited violation of Technical Specification 5.7.1, resulting from the licensees failure to conspicuously post a high radiation area during Refueling Outage 26. As corrective action, the licensee immediately stopped work and posted the area as required. The licensee documented the issues in apparent cause evaluation performed for Condition Report CR-CNS-2011-04891. The failure to conspicuously post a high radiation area is a performance deficiency. The finding was more than minor because it was associated with the program and process attribute (exposure control) of the Occupational Radiation Safety Cornerstone and affected the cornerstone objective, in that, the failure to conspicuously post a high radiation area had the potential to increase personnel dose. Using NRC Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, the inspector determined the finding to be of very low safety significance because: (1) it was not associated with as low as reasonably achievable (ALARA) planning or work controls; (2) there was no overexposure; (3) there was no substantial potential for an overexposure; and (4) the ability to assess dose was not compromised. The finding has a human performance cross-cutting aspect associated with work practices component because the licensee did not ensure appropriate supervisory oversight of work activities to support nuclear safety.
05000298/FIN-2011005-022011Q4CooperFailure to Maintain Control and Continuous Coverage of a Posted Locked High Radiation AreaThe inspector identified a non-cited violation of Technical Specification 5.7.2, resulting from the licensees failure to maintain controls by not providing continuous coverage in a posted locked high radiation area with dose rates greater than 1000 mrem per hour at 30 cm during Refueling Outage 26. As corrective action, the licensee performed an apparent cause evaluation and documented the issues identified in Condition Report CR-CNS-2011-09785. The failure to maintain controls in a posted locked high radiation area is a performance deficiency. The finding was more than minor because it was associated with the program and process attribute (exposure control) of the Occupational Radiation Safety Cornerstone and affected the cornerstone objective, in that, the failure to maintain controls and not provide continuous radiation protection coverage in a posted locked high radiation area with dose rates greater than 1000 mrem per hour at 30 cm had the potential to increase personnel dose. Using NRC Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, the inspector determined the finding to be of very low safety significance because: (1) it was not associated with as low as reasonably achievable (ALARA) planning or work controls; (2) there was no overexposure; (3) there was no substantial potential for an overexposure; and (4) the ability to assess dose was not compromised. The finding has a human performance cross-cutting aspect associated with work practices component because the licensee did not ensure appropriate supervisory oversight of work activities to support nuclear safety.
05000298/FIN-2011005-032011Q4CooperFailure to Follow Procedures for Dose Rate Alarms Received by Two IndividualsThe inspector reviewed a self-revealing, non-cited violation of Technical Specification 5.4.1, resulting from workers who failed to follow procedures to exit the area when two dose rate alarms were received while performing decontamination work in the reactor cavity during Refueling Outage 26. As corrective action, the licensee performed an apparent cause evaluation and documented the issues identified in Condition Report CR-CNS-2011-04891. The failure to follow procedures is a performance deficiency. The finding was more than minor because it was associated with the program and process attribute (exposure control) of the Occupational Radiation Safety Cornerstone and affected the cornerstone objective, in that, the failure to follow radiation procedures and not leave the work area after receipt of a dose rate alarm had the potential to increase personnel dose. Using NRC Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, the inspector determined the finding to be of very low safety significance because: (1) it was not associated with as low as is reasonably achievable (ALARA) planning or work controls; (2) there was no overexposure; (3) there was no substantial potential for an overexposure; and (4) the ability to assess dose was not compromised. The finding has a human performance cross-cutting aspect associated with work practices component because the individuals failed to use self- and peer-checking human error prevention techniques.
05000298/FIN-2011005-042011Q4CooperFailure to Provide Complete and Accurate Solid Radwaste Shipment Information in Annual ReportsInspectors identified a non-cited violation of 10 CFR 50.9, Completeness and Accuracy of Information, because the Annual Radiological Effluent Release Reports for 2008, 2009, and 2010 were not complete and accurate in all material respects with regard to solid radwaste shipped offsite from Cooper Nuclear Station. Specifically, the numbers of solid radwaste shipments, locations, burial volumes, and total activity amounts were not correct. This issue was entered in the licensees corrective action program as Condition Reports CR-CNS-2011-06921 and CR-CNS-2011-11740. This issue was dispositioned using traditional enforcement because the failure to provide complete and accurate information in Annual Radiological Effluent Release Reports has the potential to impact the NRCs ability to perform its regulatory function. This violation is characterized as a Severity Level IV violation consistent with Sections 2.2.1 and 6.9 of the NRC Enforcement Policy. This finding was determined to be of very low safety significance. No cross-cutting aspect was identified because this performance deficiency was dispositioned using traditional enforcement
05000298/FIN-2011005-052011Q4CooperFailure to Identify Deficient Performance During a Single-Facility DrillThe inspector identified a non-cited violation of 10 CFR 50.47(b)(14) for failure to correct a deficiency in drill or exercise performance. Specifically, the licensee failed to identify an inaccurate protective action recommendation during the critique of a Control Room Simulator drill conducted May 18, 2011. The failure to identify an inaccurate protective action recommendation is a performance deficiency. This finding is more than minor because it impacted the drills and emergency response organization performance attributes of the Emergency Preparedness Cornerstone. The finding had a credible impact on the cornerstone objective because inaccurate protective action recommendations affect the licensees ability to implement adequate measures to protect the health and safety of the public. This finding was evaluated using the Emergency Preparedness Significance Determination Process and was determined to be of very low safety significance because it was associated with the emergency preparedness planning standards and was not a functional failure or degraded performance. The finding was entered into the corrective action program as Condition Report CR-CNS-2011-10277. The finding has a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action program component because the program did not have a low enough threshold to completely and thoroughly identify incorrect performance.
05000298/FIN-2011005-062011Q4CooperFailure to Correctly Translate Design Requirements into Installed Plant ConfigurationThe inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, associated with the licensees failure to assure that the design basis requirements associated with a turbine building high energy line break were correctly translated into the plant design to ensure the 4160 volt switchgear and emergency diesel generators would remain functional following a line break. This issue was entered into the licensees corrective action program as Condition Report CR-CNS-2011-10618. The inspectors determined that the licensees failure to ensure that design requirements were correctly translated into installed plant equipment was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the design control attribute of the Mitigating Systems Cornerstone, and affected the associated cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and is therefore a finding. Using Manual Chapter 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, the finding was determined to have very low safety significance because the finding: (1) was not a design or qualification issue confirmed not to result in a loss of operability or functionality; (2) did not represent an actual loss of safety function of the system or train; (3) did not result in the loss of one or more trains of nontechnical specification equipment; and (4) did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The finding was determined to have a cross-cutting aspect in the area of problem identification and resolution, associated with the corrective action component, in that, the licensee failed to thoroughly evaluate concerns with high energy line break doors and this resulted in the resolutions taken not addressing the causes.
05000298/FIN-2011005-072011Q4CooperFailure to Perform Required 10 CFR 50.59 Evaluations for ChangesThe inspectors identified a non-cited violation of 10 CFR 50.59, Changes, Test, and Experiments, associated with the licensees failure to adequately evaluate changes in order to ensure that they did not require prior NRC approval. Specifically, the inspectors determined that the re-analysis of the turbine building peak pressure in response to a high energy line break event that the licensee had performed used a different calculation method than what had originally been used to support the stations licensing basis. This re-analysis was performed for the purpose of gaining margin on the station doors credited with protecting safety-related equipment from the line break event. This new method resulted in a lower peak turbine building pressure. This issue was entered into the licensees corrective action program as Condition Reports CR-CNS-2011-10391 and CR-CNS-2011-11861. The licensees failure to implement the requirements of 10 CFR 50.59 and adequately evaluate changes was a performance deficiency. The performance deficiency is greater than minor because the failure to follow the requirements of 10 CFR 50.59 and receive prior NRC approval for changes in licensed actions impacted the NRCs regulatory ability, and is, therefore, a finding. Since violations of 10 CFR 50.59 are considered to impede or impact the regulatory process they are dispositioned using the traditional enforcement process. The enforcement manual specifies that the severity level is determined in parallel with the Significance Determination Process. As such, the inspectors concluded that this issue also represented a performance deficiency under the Reactor Oversight Process because the licensee failed to appropriately evaluate the proposed change in accordance with the requirements of Station Procedure 0.8, 10CFR50.59 and 10CFR72.48 Reviews. The performance deficiency was determined to be more than minor because it was associated with the design control attribute of the Mitigating Systems Cornerstone, and affected the associated cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and is therefore a finding. Using Manual Chapter 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings, the finding was determined to have very low safety significance because the finding: (1) was not a design or qualification issue confirmed not to result in a loss of operability or functionality; (2) did not represent an actual loss of safety function of the system or train; (3) did not result in the loss of one or more trains of nontechnical specification equipment; and (4) did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The inspectors reviewed this issue in accordance with NRC Inspection Manual Chapter 0612 and the NRC Enforcement Manual and Enforcement Policy and concluded that because the violation was determined to be of very low safety significance, was not repetitive or willful, and was entered into the corrective action program, this violation is being treated as a Severity Level IV non-cited violation consistent with the NRC Enforcement Policy. The finding was determined to have a cross-cutting aspect in the area of human performance, associated with the decision-making component in that the licensee failed to use conservative assumptions in decision making when they failed to recognize that the new calculation methodology was a change to a previously approved methodology
05000298/FIN-2011005-082011Q4CooperLicensee-Identified ViolationProcedure 9.EN-RP-101, Access Control for Radiologically Controlled Areas, Revision 9, Step 6.8.7, states that each person entering a locked high radiation area shall have a documented pre-job brief using Form RP-800 given by radiation protection personnel. Additionally, Radiological Work Permit/Specific Work Permit 2011-0438, Task 5, which was used by the decontamination workers during the work activities within the Reactor Cavity, stated that, All entries into locked high radiation areas require a documented pre-job briefing by radiation protection using the Form RP-800 prior to entry. This briefing will include established stay times, and work areas will have turn back dose rates. Contrary to this requirement, on April 21, 2011, the decontamination workers were not briefed with the use of Form RP-800. Thus, they were not provided stay times and turn back dose rates while working in the reactor cavity, which was posted as a locked high radiation area. Since the failure to perform a required pre-job brief using Form RP-800 in a posted locked high radiation area was addressed in the licensees original apparent cause evaluation for Condition Report CR-CNS-2011-04891 in detail, this violation is being treated as a licensee-identified non-cited violation.
05000298/FIN-2011005-092011Q4CooperLicensee-Identified Violation10 CFR 50, Appendix B, Criterion III, Design Control, states in part that measures shall be established to ensure the suitability of parts that are essential to the safety-related functions of systems. Contrary to this requirement, Cooper Nuclear Station identified in their root cause evaluation legacy issues with inadequate design control of both the service water strainer and the strainer blowdown valve. The design inadequacies were introduced at the time of initial installation of the service water strainers in 1973. Previous actions to correct the conditions had not prevented failure. The performance deficiency was determined to be more than minor because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone, and affected the associated cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and is therefore a finding. Using Manual Chapter 0609, Attachment 4, Phase 1 - Initial Screening and Characterization of Findings, the finding was determined to have very low safety significance because the finding: (1) was not a design or qualification issue confirmed not to result in a loss of operability or functionality; (2) did not represent an actual loss of safety function of the system or train; (3) did not result in the loss of one or more trains of nontechnical specification equipment; and (4) did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event.
05000298/FIN-2012005-012012Q4CooperInadequate Maintenance Procedure for the Service Water Pump RoomThe inspectors identified a non-cited violation of Technical Specification 5.4.1.a, associated with the inadequate Maintenance Procedures 7.2.15, Service Water Pump Column Maintenance and Bowl Assembly Replacement, Revision 35, Maintenance Procedure 7.2.16, Backup Fire Pump Maintenance , Revision 14, and Maintenance Procedure 7.2.30, Service Water Strainer Maintenance, Revision 19. Specifically, those procedures did not address the number of required temporary heaters and required power sources during a loss of offsite power during design basis cold weather temperature of -5 degrees Fahrenheit with service water pump room hatches removed or doors open during maintenance. The issue was entered into their corrective action program for resolution as Condition Reports CR-CNS-2012-07891, CR-CNS-2012-08184, and CR-CNS-2012-08371. The licensees inadequate procedural direction to establish temporary heating in the service water pump during cold weather condition with the hatches removed or doors open, was a performance deficiency. This performance deficiency was determined to be more than minor, and is therefore a finding, because it was associated with the procedural quality attribute of the Mitigating Systems Cornerstone, in that the inadequate procedures did not identify the number of temporary heaters and their power supplies that would be necessary to maintain the service water system operable/functional during a loss of offsite power coincident with the licensing basis cold weather conditions, and thereby affecting the associated cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors evaluated the finding using Inspection Manual Chapter 0609, Appendix G, Shutdown Operations Significance Determination Process, Checklist 7, BWR Refueling Operation with RCS Level > 23\', and determined that the finding is of very low safety significance (Green) because the finding did not require a quantitative risk assessment because adequate mitigating equipment remained available and the finding did not constitute a loss of the diesel generator capable of supplying one division of the onsite safety related power distribution subsystems, as defined in Appendix G. The finding was determined to have a cross-cutting aspect in the area of problem identification and resolution, associated with the corrective action program, in that the licensee failed to thoroughly evaluate an independent heating system.
05000298/FIN-2012005-022012Q4CooperFailure to Adequately Monitor the Performance of Roof DrainsThe inspectors identified a non-cited violation of 10 CFR 50.65(a)(2), Requirements for monitoring the effectiveness of maintenance at nuclear power plants. Specifically, the licensee failed to appropriately consider the availability of the reactor building, diesel generator building,and control building roof drains when evaluating whether their performance or condition had been demonstrated to be effectively controlled. The licensee entered this issue in their corrective action program as Condition Report CR-CNS-2012-05993. The licensees failure to effectively monitor the performance of maintenance rule scoped equipment in accordance with 10 CFR 50.65(a)(2) was a performance deficiency. The performance deficiency was determined to be more than minor, and is therefore a finding, because it is associated with the protection against the external factors attribute of the Mitigating Systems Cornerstone, in that the failure to appropriately evaluate availability of the roof drains could result in their not being able to perform their intended function when required, thereby affecting the associated cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process For Findings At-Power, the finding was determined to have very low safety significance (Green) because the finding did not involve the loss or degradation of equipment or function specifically designed to mitigate a flooding event. The inspectors determined that the apparent cause of this finding was that the licensee had performed an inadequate evaluation with regard to Condition Report CR-CNS-2011-01859 and failed to recognize and correct the lack of appropriate monitoring criteria for the roof drains. Therefore, the finding has a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action component because the licensee failed to thoroughly evaluate problems such that the resolutions address causes.
05000298/FIN-2012005-032012Q4CooperFailure to Follow Procedural Requirements During Roof InspectionThe inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated with the licensees failure to follow the requirements of Station Procedure 0.27.1, Periodic Structural Inspections of Structures, Revision 7. Specifically, the licensee failed to identify and remove foreign material from the diesel generator building roof which could have interfered with the ability of the roof drains and scuppers to remove water during a flooding event. The issue was entered into the licensees corrective action program as Condition Report CR-CNS-2012-08833. The failure to follow the requirements of a station procedure was a performance deficiency. The performance deficiency was determined to be more than minor, and is therefore a finding, because it is associated with the protection against the external factors attribute of the Mitigating Systems Cornerstone, in that the failure to recognize and remove foreign material from the diesel generator roof could have resulted in the roof drains and scuppers not being able to perform their intended function when required, thereby affecting the associated cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process For Findings At-Power, the finding was determined to be of very low safety significance (Green) because the finding: (1) was not a deficiency affecting the design or qualification of a mitigating structure, system, or component and did not result in a loss of operability or functionality; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separate safety systems out-of-service for longer than its technical specification allowed outage time; and (4) did not represent an actual loss of function of one or more nontechnical specification trains of equipment designated as high safety-significance in accordance with the licensees maintenance rule program. The inspectors determined that the apparent cause of this finding was that the licensee had failed to use conservative assumption, when determining what constituted foreign material on the diesel generator roof. Therefore, the finding has a cross-cutting aspect in the area of human performance associated with the decision-making component because the licensee failed to use conservative assumptions in decision-making and adopt a requirement to demonstrate that the proposed action is safe in order to proceed rather than a requirement to demonstrate it is unsafe in order to disapprove the action.
05000298/FIN-2012005-042012Q4CooperFailure to Consider All Relevant Information and Appropriately Assess Operability when a Degraded Nonconforming Condition was IdentifiedThe inspectors identified a non-citied violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated with the licensees failure to follow the requirements of Station Procedure 0.5OPS, Operations Review of Condition Reports/Operability Determination, Revision 38, and properly document the basis for operability when a degraded or nonconforming condition is identified. Specifically, the inspectors identified that the licensee had failed to consider all relevant information when assessing operability of diesel generator 2, supported by service water system Division II, with service water system Division I hatches removed for Zurn strainer A replacement during design basis cold weather temperature of -5 degrees Fahrenheit with a loss of off-site power. The licensee entered these issues into their corrective action program for resolution as Condition Reports CR-CNS-2012-08148 and CR-CNS-2012-08292. The licensees failure to consider all relevant information and appropriately assess operability when a nonconforming condition was identified was a performance deficiency. This performance deficiency was determined to be more than minor, and is therefore a finding, because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone, in that the inadequate operability determination failed to identify the number of temporary heaters and their power supplies that would be necessary to maintain Division II of the service water system functional to support operability of diesel generator 2, during a loss of offsite power coincident with the licensing basis cold weather conditions, and thereby affecting the associated cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors evaluated the finding using Inspection Manual Chapter 0609, Appendix G, Shutdown Operations Significance Determination Process, Checklist 7, BWR Refueling Operation with RCS Level > 23\\\', and determined that the finding is of very low safety significance (Green) because the finding did not require a quantitative risk assessment because adequate mitigating equipment remained available and the finding did not constitute a loss of the diesel generator capable of supplying one division of the onsite safety related power distribution subsystems, as defined in Appendix G. The inspectors determined that the apparent cause of this finding was that operators had failed to verify their assumptions associated with the compensatory measures to maintain service water system Division II function and support operability of diesel generator 2. Therefore, the finding has a crosscutting aspect in the area of human performance associated with the decision-making component because the licensee failed to use conservative assumptions in decision-making and adopt a requirement to demonstrate that the proposed action is safe in order to proceed rather than a requirement to demonstrate it is unsafe in order to disapprove the action.
05000298/FIN-2012005-052012Q4CooperFailure to Maintain Design Control of the Service Water Booster PumpsThe inspectors documented a self-revealing, non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, associated with the licensees failure to correctly translate certain parts of the design bases into installed plant equipment. Specifically, the licensee failed to ensure that unused flushing ports on the service water booster pump casing were either welded, or not installed, during procurement. This failure resulted in the licensee installing a new service water booster pump with unused flushing ports that were not welded during installation of service water booster pump D, which resulted in degradation of the pumps casing and the pump not being able to perform its specified safety function. The licensee entered this deficiency into their corrective action program for resolution as Condition Reports CR-CNS-2012-07365 and CR-CNS-2012-07378. The failure to maintain design control of the service water booster pumps was a performance deficiency. This performance deficiency was determined to be more than minor, and is therefore a finding, because it was associated with the design control attribute of the Mitigating Systems Cornerstone, in that the licensee installed a service water booster pump with an unused flushing port not welded, which resulted in degradation of the pumps casing and the pump not being able to perform its specified safety function, and thereby affecting the associated cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors evaluated the finding using Inspection Manual Chapter 0609, Appendix G, Shutdown Operations Significance Determination Process, Checklist 7, BWR Refueling Operation with RCS Level > 23\', and determined that the finding is of very low safety significance (Green) because the finding did not require a quantitative risk assessment because adequate mitigating equipment remained available and the finding did not constitute a loss of shutdown cooling, as defined in Appendix G. The finding was determined to have a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action component because the licensee failed to thoroughly evaluate concerns with whether or not the unused flushing ports on service water booster pump D should be welded.
05000298/FIN-2012005-062012Q4CooperFailure to Perform Radiation Surveys Before Allowing Work to CommenceThe inspectors reviewed a self-revealing, non-cited violation of 10 CFR 20.1501(a), Standards for Protection against Radiation, Subpart F, Surveys and Monitoring, associated with the licensees failure to perform an adequate radiation survey to determine and evaluate radiological hazards workers could be exposed to during a planned work activity. The licensee entered this issue into the stations corrective action program as Condition Report CR-CNS-2012-09336. The failure to perform an adequate radiation survey was a performance deficiency. This performance deficiency was determined to be more than minor, and is therefore a finding, because it was associated with the program and process attribute (exposure control) of the Occupational Radiation Safety cornerstone, in that workers were allowed to enter an area of unknown radiation dose rates and received an unintended and unexpected radiation exposure, thereby affecting the associated cornerstone objective to ensure the adequate protection of the workers health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. Using Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, the finding was determined to be of very low safety significance (Green) because: (1) it was not associated with as low as is reasonably achievable (ALARA) planning; (2) it did not involve an overexposure; (3) there was no substantial potential for an overexposure; and (4) the licensees ability to assess dose was not compromised. The inspectors determined that the apparent cause of this finding was that radiation protection personnel at the control point failed to verify their assumptions associated with current survey data prior to allowing workers into a locked high radiation area. Therefore, this finding has a cross-cutting aspect in the area of human performance associated with the decision-making component because the licensee failed to use conservative assumptions in decision-making and adopt a requirement to demonstrate that the proposed action is safe in order to proceed rather than a requirement to demonstrate it is unsafe in order to disapprove the action.
05000298/FIN-2012005-072012Q4CooperFailure to Follow Radiation Protection ProceduresThe inspectors reviewed a self-revealing, non-cited violation of Technical Specification 5.4.1.a, which resulted from a worker failing to follow radiation protection procedures. In response, the licensee investigated the occurrence, coached the individual on human performance, and entered the issue into the corrective action program as Condition Report CR-CNS-2011-04915. The failure to follow radiation protection procedures was a performance deficiency. The performance deficiency was more than minor because it was associated with the Occupational Radiation Safety Cornerstone attribute (exposure control) of program and process and affected the cornerstone objective in that working outside the scope of procedures by accessing the higher dose rates behind the installed shielding had the potential to increase personnel dose. Using Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, the inspectors determined the finding had very low safety significance because: (1) it was not an as low as is reasonably achievable finding; (2) there was no overexposure; (3) there was no substantial potential for an overexposure; and (4) the ability to assess dose was not compromised. This finding had a cross-cutting aspect in the human performance area, work practices component, in that the licensee failed to provide adequate management oversight of work activities such that nuclear safety was maintained.
05000298/FIN-2012005-082012Q4CooperFailure to Perform an Adequate Radiological SurveyThe inspectors reviewed a self-revealing, non-cited violation of 10 CFR 20.1501(a) for the licensees failure to perform an adequate radiological survey. In response, the licensee immediately restricted access to the torus area, performed a follow-up survey, and entered the issue into the corrective action program as Condition Report CR-CNS-2012-07577. The failure to perform an adequate radiological survey is a performance deficiency. The performance deficiency was more than minor because it was associated with the Occupational Radiation Safety Cornerstone attribute (exposure control) of program and process and affected the cornerstone objective in that the inadequate survey did not ensure exposure control for radiation workers. Using Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, the inspectors determined the finding had very low safety significance because: (1) it was not an as low as is reasonably achievable finding; (2) there was no overexposure; (3) there was no substantial potential for an overexposure; and (4) the ability to assess dose was not compromised. This finding had a crosscutting aspect in the human performance area, work control component, because the licensee failed to incorporate job site conditions that impacted radiological safety.
05000298/FIN-2012005-092012Q4CooperFailure to Follow Procedure and Initiate Condition Reports When Degraded Nonconforming Conditions Were IdentifiedThe inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, associated with the licensees failure to follow the requirements of Station Procedure 0.5CR, Condition Report Initiation, Review, and Classification, Revision 19, and enter conditions adverse to quality in the stations corrective action program. Specifically, station personnel performing walkdowns for Temporary Instruction 2515/187, Inspection of Near-Term Task Force Recommendation 2.3 Flooding Walkdowns, failed to initiate condition reports for degraded or nonconforming conditions as they were identified. The licensee entered this issue into their corrective action program for resolution as Condition Report CR-CNS-2012-06753. The failure to follow the requirements of Station Procedure 0.5CR and initiate condition reports when degraded nonconforming conditions were identified was a performance deficiency. The performance deficiency was determined to be more than minor, and is therefore a finding, because it is associated with the equipment performance attribute of the Mitigating Systems Cornerstone, in that the failure to write condition reports when degraded conditions were identified resulted in equipment being in an unevaluated state and its ability to perform its function being unknown, thereby affecting the associated cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process For Findings At-Power, the finding was determined to have very low safety significance (Green) because the finding did not involve the loss or degradation of equipment or function specifically designed to mitigate a flooding event. The inspectors determined that the apparent cause of this finding was that licensee personnel failed to make safety/risk-significant decisions using a systematic process when degraded conditions were identified during in plant walkdowns. Therefore, the finding has a cross-cutting aspect in the area of human performance associated with the decision making component because the licensee failed to make safety/risk-significant decisions using a systematic process when faced with uncertain plant conditions.
05000298/FIN-2012005-102012Q4CooperLicensee-Identified ViolationTitle 10 CFR Part 50, Appendix B, Criterion III, states, in part, that, measures shall be established to assure that the design bases are correctly translated into specifications. Contrary to the above, measures established by the licensee did not assure that the design bases was correctly translated into specifications. Specifically, as of October 20, 2012, a vendor calculation, previously used by the licensee for the diesel generator 1 voltage regulator seismic evaluation, did not use the correct safety factors as specified in the updated safety analysis report. Using Manual Chapter 0609, Appendix G, Shutdown Operations Significance Determination Process, Checklist 7, BWR Refueling Operation with RCS Level > 23\', and determined that the finding is of very low safety significance (Green) because the finding did not require a quantitative risk assessment because adequate mitigating equipment remained available and the finding did not constitute a loss of shutdown cooling, as defined in Appendix G. This violation was entered into the corrective action program as Condition Report CR-CNS-2012-07717
05000298/FIN-2012005-112012Q4CooperLicensee-Identified ViolationTechnical Specification Section 5.7.1 requires, in part, that each entryway to high radiation areas in which the deep dose equivalent in excess of 100 millirem, but less than 1000 millirem in one hour (measured at 12 inches from the source of radiation) be barricaded and conspicuously posted as a high radiation area. Contrary to this requirement, on October 25, 2012, the 859 southeast quadrant sump under the torus area was a posted high radiation area, but the high radiation area swing gate was tied open,and thus not barricaded. This issue was documented in the licensees corrective action program as Condition Report CR-CNS-2012-08062. Using Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, the inspectors determined the finding had very low safety significance (Green) because: (1) it was not an as low as is reasonably achievable finding; (2) there was no overexposure; (3) there was no substantial potential for an overexposure; and (4) the ability to assess dose was not compromised.
05000298/FIN-2016002-012016Q2CooperFailure to Meet Technical Specification Requirements for Traversing In-Core Probe B Ball Valve (The inspectors identified a non-cited violation of Technical Specification 3.6.1.3, Primary Containment Isolation Valves, for the licensees failure to maintain traversing incore probe B ball valve, a primary containment isolation valve, operable for its containment isolation function. Specifically, on May 5, 2016, from 5:20 a.m. until 1:08 p.m., the licensee failed to maintain the traversing in-core probe B ball valve operable or isolate its flow path within 4 hours of indications that the mechanical in-shield limit switch had failed. This failure prevented the ball valve from performing its containment isolation function. The licensee took immediate corrective actions upon discovery to restore compliance with Technical Specification 3.6.1.3 by de-energizing the ball valves solenoid operating valve, causing it to close. The licensee entered this deficiency into their corrective action program for resolution as Condition Report CR-CNS-2016-03665. The licensees failure to maintain the traversing in-core probe B ball valve, a primary containment isolation valve, operable for its containment isolation function, in violation of Technical Specification 3.6.1.3, was a performance deficiency. 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 adversely 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 containment is maintained. Specifically, the traversing in-core probe B ball valve was unable to perform its primary containment isolation function with a failed mechanical inshield limit switch. 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 an actual open pathway in the physical integrity of reactor containment (valves, airlocks, etc.), containment isolation system (logic and instrumentation), and heat removal components; and did not involve an actual reduction in function of hydrogen igniters in the reactor containment. The finding had a cross-cutting aspect in the area of human performance associated with conservative bias because the licensee failed to use decision making practices that emphasized prudent choices over those that were simply allowable and failed to ensure proposed actions were determined to be safe in order to proceed, rather than unsafe in order to stop. Specifically, the licensee failed to validate the assumption that the traversing in-core probe B ball valve would fulfill its containment isolation function with a failed mechanical in-shield limit switch, and failed to validate the degraded condition prior to exceeding the 4-hour completion time of Technical Specification 3.6.1.3 (Section 1R12). (H.14)
05000298/FIN-2016002-022016Q2CooperFailure to Follow Work Instructions for Post-Maintenance Testing of Safety-Related Ventilation SystemsThe 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)
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