05000298/FIN-2010006-02
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Finding | |
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| Title | Failure to Monitor the Performance of the Emergency Lights Against the Maintenance Rule Criteria |
| Description | A noncited violation of 10 CFR 50.65(a)(2) was identified for the failure to monitor the performance of the emergency lighting system against the established performance criteria. The licensee included the emergency lighting system in the Maintenance Rule program and specified that the emergency light batteries must be capable of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of operation, as required by 10 CFR Part 50, Appendix R, Section iii.J. The team identified that the licensee did not perform tests that demonstrated the capability of the emergency lights to last for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />; therefore, the licensee failed to monitor the performance of the emergency lights against the established performance criteria. This finding was entered into the licensee\\\'s corrective action program under Condition Reports CR-CNS-201 0-08014 and CR-CNS-2010-08250. The failure to monitor the performance of the emergency lighting system against the performance criteria stated in the Maintenance Rule program was a performance deficiency. The performance deficiency was more than minor because it was associated with the protection against external events (fire) attribute of the Mitigating Systems Cornerstone and it adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to ensure that emergency lights would last for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> could adversely affect the ability of operators to perform all of the manual actions required to support safe shutdown in the event of a fire. The significance of this finding was evaluated using Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination Process, because the performance deficiency affected fire protection defense-in-depth strategies involving post fire safe shutdown systems. The finding was assigned a low degradation rating since the finding minimally impacted the performance and reliability of the fire protection program element. Specifically, the team determined that the licensee\\\'s preventive maintenance strategy provided reasonable assurance that the emergency lights would last sufficiently long for the operators to perform the most time-critical manual actions required to support safe shutdown in the event of a fire. The team also noted that operators were required to obtain and carry flashlights. Therefore, the finding screened as having very low safety significance (Green). This finding had a crosscutting aspect in the area of Human Performance associated with Decision Making because the licensee failed to identify possible unintended consequences of the decision to change the maintenance program for the emergency lights. Specifically, the licensee failed to identify that deleting emergency light testing impacted Maintenance Rule performance monitoring. |
| Site: | Cooper  |
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| Report | IR 05000298/2010006 Section 1R05 |
| Date counted | Dec 31, 2010 (2010Q4) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.05 |
| Inspectors (proximate) | A Vegel E Uribe G George J Mateychick J Watkins |
| CCA | H.14, Conservative Bias |
| INPO aspect | DM.2 |
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Finding - Cooper - IR 05000298/2010006 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Cooper) @ 2010Q4
Self-Identified List (Cooper)
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