05000298/FIN-2016001-02
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Finding | |
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Title | Failure to Assess Operability of Technical Specification System Functions during Surveillance Testing |
Description | The inspectors identified a non-cited violation of Technical Specification 5.4.1.a, for the licensees failure to follow Station Procedure 0.26, Surveillance Program, and assess the operability of high pressure coolant injection steam line isolation instrumentation during surveillance testing. Specifically, the licensee failed to assess the operability of required isolation instrumentation when maintentance personnel opened terminal box 392 during surveillance testing and temporarily invalidated its environmental qualification. Licensee procedures required operations personnel to either establish compensatory measures to restore the terminal box during an event, or declare the instrumentation inoperable and enter the applicable technical specification actions when the terminal box was opened. As an immediate corrective action, the licensee implemented Standing Order 2016-03, which directed operators to establish compensatory measures, if applicable, or declare the affected equipment inoperable when environmentally qualified terminal boxes would be opened during testing. The licensee entered this issue into their corrective action program for resolution as Condition Reports CR-CNS-2016-00320 and CR-CNS-2016-00476. The licensees failure to assess the operability of high pressure coolant injection instrumentation when the associated terminal box was opened during surveillance testing, in violation of Station Procedure 0.26, was a performance deficiency. The performance deficiency was determined to be more than minor, and therefore a finding, because it was associated with the structure, system, component, and barrier performance attribute of the Barrier Integrity Cornerstone, and adversely affected the cornerstone objective to ensure the radiological barrier functionality of containment isolation. Specifically, with terminal box 392 open, its environmental qualification was temporarily invalidated, making the high pressure coolant injection low steam pressure and high steam flow containment isolation instrumentation inoperable during surveillance testing. In addition, two other terminal boxes and their associated surveillances were impacted by the performance deficiency. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, the inspectors determined that the finding had very low safety significance (Green) because it: (1) did not represent an actual open pathway in the physical integrity of reactor containment, containment isolation system, or heat removal components; and (2) 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 work management. Specifically, the licensee failed to implement a process of planning, controlling, and executing work activities such that nuclear safety was the overriding priority, including the identification and management of risk commensurate with opening terminal box 392 during surveillance testing [H.5]. |
Site: | Cooper |
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Report | IR 05000298/2016001 Section 1R22 |
Date counted | Mar 31, 2016 (2016Q1) |
Type: | NCV: Green |
cornerstone | Barrier Integrity |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.22 |
Inspectors (proximate) | C Henderson G Warnick J O'Donnell M Phalen P Voss W Sifre |
Violation of: | Technical Specification - Procedures Technical Specification |
CCA | H.5, Work Management |
INPO aspect | WP.1 |
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Finding - Cooper - IR 05000298/2016001 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Cooper) @ 2016Q1
Self-Identified List (Cooper)
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