05000298/FIN-2014002-02
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Finding | |
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| Title | Failure to Follow Operability Procedure |
| Description | The inspectors identified two examples of a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated with the licensees failure to perform an adequate operability determination in accordance with Station Procedure 0.5OPS, Operations Review of Condition Reports/Operability Determination. Specifically, the licensee failed to adequately evaluate the effect on operability for (1) taking electrical relays out of their seismically qualified configuration and (2) a degraded nonconforming condition created by using non-design bases inputs in a design bases analysis. To correct the first issue, the licensee will declare the service water pumps inoperable during activities that involve opening the switchgear doors and to correct the second issue, the licensee performed subsequent analyses using Manual Chapter 0326, Section C.10, guidance to demonstrate a reasonable expectation of operability. The licensee entered these deficiencies into their corrective action program for resolution as Condition Reports CR-CNS-2014-00464, and CR-CNS-2014-01109. The failure to properly assess and document the basis for operability when degraded or nonconforming conditions are identified was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensees failure to properly assess and document the basis for operability resulted in conditions of unknown operability for degraded nonconforming conditions. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, inspectors determined that the finding was of very low safety significance (Green) because the finding: (1) was not a deficiency affecting the design and 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 their 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 finding has a cross-cutting aspect in the area of human performance associated with conservative bias because individuals did not use decision-making practices that emphasize prudent choices over those that are simply allowable to ensure that a proposed action was determined to be safe in order to proceed, rather than unsafe in order to stop. |
| Site: | Cooper  |
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| Report | IR 05000298/2014002 Section 1R15 |
| Date counted | Mar 31, 2014 (2014Q1) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.15 |
| Inspectors (proximate) | C Henderson D Allen J Josey P Elkmann |
| Violation of: | 10 CFR 50 Appendix B Criterion V Technical Specification Technical Specification - Procedures |
| CCA | H.14, Conservative Bias |
| INPO aspect | DM.2 |
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Finding - Cooper - IR 05000298/2014002 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Cooper) @ 2014Q1
Self-Identified List (Cooper)
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