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05000298/FIN-2018003-0130 September 2018 23:59:59CooperNRC identifiedFailure to Provide Complete and Accurate Information in a License Amendment RequestThe inspectors identified that the licensee provided inaccurate information to the NRC in a license amendment request for an emergency action level scheme change. Specifically, the licensee provided information about the measurement ranges of a liquid effluent radiation monitor used in emergency action levels that was not accurate.
05000298/FIN-2018003-0230 September 2018 23:59:59CooperNRC identifiedFailure to Perform Process Applicability DeterminationThe inspectors identified a Green, non-cited violation of Technical Specification 5.4.1.a, Procedures, for the licensees failure to follow Administrative Procedure 0.9, Tagout, Revision 88, for performing a monthly audit and Process Applicability Determination. Specifically, the inspectors noted that a clearance order on the safety-related residual heat removal service water booster pump room fan coil unit was hanging for greater than 90 days with no Process Applicability Determination performed, which resulted in the power switch for the fan coil unit being unintentionally tagged out of its normal configuration for almost 2 years
05000298/FIN-2018003-0330 September 2018 23:59:59CooperSelf-revealingFailure to Provide Adequate Lubrication for Drywell Fan Coil UnitsThe inspectors reviewed a self-revealed finding for the licensees failure to implement Work Order 5060136 during maintenance on the drywell fan coil units. Specifically, on October 26, 2016, during bearing replacement work on drywell fan coil, unit D, maintenance personnel failed to properly reinstall auto-lubricator injection connectors after removing the interferences per the work order instructions. This error resulted in the failure of drywell fan coil, unit D, due to inadequate bearing lubrication, and ultimately led to a downpower and reactor shutdown.
05000298/FIN-2018002-0230 June 2018 23:59:59CooperSelf-revealingFailure to Maintain Adequate Work Instructions for Traversing In-Core Probe System Limit SwitchesA self-revealed, Green non-cited violation of Technical Specification 5.4, Procedures, was identified when the licensee failed to maintain Procedure 14.2.14, TIP Chamber Shield Maintenance, with adequate instructions for reinstalling the traversing in-core probe system in-shield limit switches. As a result, the licensee experienced multiple failures of the shield limit switches resulting in inoperable primary containment isolation valves.
05000298/FIN-2018011-0230 June 2018 23:59:59CooperNRC identifiedFailure to Ensure Adequate Design Control Measures are in Place Associated with RHR Service Water Booster Pump Room CoolingAn NRC-identified, Green, Non-cited Violation of Title 10, Code of Federal Regulations Part 50, Appendix B, Criterion III, Design Control, occurred for failure to assure that applicable regulatory requirements and the design basis were correctly translated into specifications, drawings, procedures, and instructions. Specifically, the licensee failed to incorporate malfunctions of the residual heat removal (RHR) service water booster pump (SWBP) room cooling temperature switch, which could cause environmental changes leading to functional degradation of system performance, into the design basis to verify the necessary protection system action be retained.
05000298/FIN-2018011-0130 June 2018 23:59:59CooperNRC identifiedFailure to Correct Extent of Condition of Surge Suppression Varistor FailuresAn NRC-identified, Green, Non-cited Violation of Title 10, Code of Federal Regulations Part 50, Appendix B, Criterion XVI, Corrective Action, occurred when the licensee failed to correct conditions adverse to quality associated with the corrective actions identified in Condition Report RCR 2002-1665 to verify that installed surge suppressor varistors were appropriately sized and that design information was correctly reflected in controlled drawings for the reactor protection system, diesel generator control circuits, and high pressure coolant injection control circuits.
05000298/FIN-2018011-0330 June 2018 23:59:59CooperNRC identifiedInadequate Design Basis Calculation for the EDG Rooms Temperature DistributionAn NRC-identified, Green, Non-cited Violation of Title 10, Code of Federal Regulations Part 50, Appendix B, Criterion III, Design Control, occurred for the licensees failure to ensure design control measures provide for verifying or checking the adequacy of design of the emergency diesel generator room ventilation system by use of alternate or simplified calculation methods, or by a suitable testing program. Specifically, the licensee incorrectly extrapolated the results of the test program, which led to an incorrect room temperature profile. Additionally, the design calculation did not assume potential failures of the CO2 dampers.
05000298/FIN-2018011-0430 June 2018 23:59:59CooperNRC identifiedIncorrect Classification of Potential Safety-Related ComponentsAn NRC-identified, Green, Non-cited Violation of Title 10, Code of Federal Regulations Part 50, Appendix B, Criterion III, Design Control, occurred for failure to assure that applicable regulatory requirements and the design basis were correctly translated into specifications, drawings, procedures, and instructions. Specifically, the inspectors identified three examples of the licensees failure to properly classify potential safety-related components in the emergency diesel generator ventilation system and RHR service water booster pump room cooling systems.
05000298/FIN-2018002-0130 June 2018 23:59:59CooperNRC identifiedFailure to Maintain Alarm Procedure for Service Water Booster Pump Ventilation Manual ActionsThe inspectors identified a Green non-cited violation of Technical Specification 5.4, Procedures, when the licensee failed to maintain Procedure 2.3_R-1 with the bounding time restrictions for required manual ventilation actions identified in Engineering Evaluation NEDC 92-064, Transient Temperature Rise in SWBP Room After Loss of Cooling, Revision 3C2. As a result, the licensee relied on procedure guidance that contained an incorrect, less restrictive allowance of 13 hours for completion of manual actions rather than the bounding 5.8-hour allowance described in NEDC92-064.
05000298/FIN-2018001-0131 March 2018 23:59:59CooperLicensee-identifiedLicensee-Identified ViolationTitle 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires, in part, that for those systems, structures, and components to which this appendix applies, Design control measures shall provide for verifying or checking the adequacy of design.Contrary to the above, between September 2003, and December 19, 2017, the licensee failed to verify or check the adequacy of design of quality-related components associated with the Division 1 and 2 emergency diesel generator 125 Vdc control power circuits. Specifically, in 2003, the licensee modified the design of the control power circuit through Part Evaluation (PE) 4222806 and replaced 24 original light bulb lamp assemblies with a different style of light bulb and a carbon film dropping resistor (vs. the original wire-wound design). This change created an unrecognized vulnerability that left the affected portions of the circuit with dropping resistors that provided insufficient protection from shorting due to indication light bulb failures. As a result, on December 19, 2017, the licensee declared both emergency diesel generators inoperable due to the design vulnerability.Significance/Severity Level: The finding created a design vulnerability in the emergency diesel generator control power circuits, and resulted in the Division 1 and 2 emergency diesel generators being declared inoperable at the time of discovery. Although the emergency diesel generators were declared inoperable, subsequent licensee analysis determined that the system retained its function, and maintained a reasonable expectation of operability while the design deficiencies existed. Accordingly, the inspectors assessed the significance of this finding in accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings at Power, dated June 19, 2012, and determined this finding was of very low safety significance (Green) because it was a deficiency affecting the design or qualification of a mitigating structure, system, or component (SSC), but the SSC maintained its operability. Corrective Action Reference(s):Immediate corrective actions included compensatory measures to remove light bulbs from the vulnerable lamp assemblies in order to eliminate the shorting hazard. This issue was entered into the licensees corrective action program as Condition Report CR-CNS-2017-07513, and the licensee initiated a root cause evaluation
05000298/FIN-2018010-0131 March 2018 23:59:59CooperNRC identifiedFailure to Maintain Satellite Phones in Locations That Provide Reasonable Assurance They Will Remain Available Following All Beyond Design Basis External EventsThe NRC inspection team identified a Green finding related to the licensees failure to maintain the station satellite phones in locations that would provide reasonable assurance the phones would remain available following all beyond design basis external events.
05000298/FIN-2017012-0131 December 2017 23:59:59CooperSelf-revealingInadequate Inspection Activities for Emergency Transformer BusThe inspectors reviewed a self -revealed, non- cited violation of Technical Specification 5.4.1.a for the licensees failure to implement Maintenance Procedure 7.3.41, Examination and High Pot Testing of Non- Segregated Buses and Associated Equipment, Revision 10, during inspection of the emergency station service transformer 4160 V bus bars. Specifically, the inspectors identified a violation of Technical Specification 5.4.1.a for the licensees failure to implement inspection instructions to examine the emergency transformer bus insulation for discoloration and to repair the associated components on March 23, 2015. As a result, the licensee did not properly assess corona -related degradation on the emergency transformer bus, which resulted in an emergency transformer bus fault and a loss of the emergency transformer and the supplemental diesel generator on January 17, 2017. Immediate corrective actions to restore compliance included replacement of the faulted portions of the emergency transformer bus, and extent of condition inspection and cleaning of the remainder of the emergency transformer bus bars . The long term corrective action is replacement of the emergency transformer bus insulation. The licensee entered this issue into the corrective action program as Condition Report CR- CNS -2017- 00223. The licensees failure to implement Maintenance Procedure 7.3.41 to properly assess degradation of the emergency station service transformer bus, in violation of Technical Specification 5.4.1.a, was a performance deficiency. The performance deficiency was determined to be more than minor, and therefore a finding, because it was associated with the equipment performance attribute of the Initiating Events Cornerstone, and affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown, as well as, power operations. Specifically, the finding resulted in the licensees failure to identify and repair indications of corona -related degradation on the emergency station service transformer bus, which resulted in an emergency station service transformer bus fault, and a loss of the emergency station service transformer and supplemental diesel generator on January 17, 2017. 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 required a detailed risk evaluation because it involved the partial loss of a support system that contributes to the likelihood of, or causes, an initiating event (loss -of-offsite power) and 3 the finding affected mitigation equipment (supplemental diesel generator). A senior reactor analyst performed a detailed risk evaluation in accordance with Inspection Manual Chapter 0609, Appendix A, Section 6.0, Detailed Risk Evaluation. The analyst concluded that the finding is of very low safety significance (Green). The performance deficiency had a cross -cutting aspect in the area of problem identification and resolution, associated with evaluation because the licensee failed to thoroughly evaluate emergency station service transformer bus discoloration and high potential test failures to ensure that resolutions addressed the causes and extent of conditions commensurate with their safety significance. Specifically, the licensee failed to thoroughly evaluate emergency station service transformer bus discoloration identified during the 2015 inspection, the hipot testing failures t hat followed the inspection, and the extent of condition of the 2015 testing and inspection deficiencies (P.2).
05000298/FIN-2017012-0231 December 2017 23:59:59CooperNRC identifiedInadequate Testing Activities for Emergency Transformer BusThe inspectors identified a non- cited violation of Technical Specification 5.4.1.a for the licensees failure to maintain Maintenance Procedure 7.3.41, Examination and High Pot Testing of Non- Segregated Buses and Associated Equipment, Revision 10, to contain adequate instructions for testing of the emergency station service transformer 4160 V bus. Specifically, the inspectors identified a violation of Technical Specification 5.4.1.a for the licensees failure to maintain adequate instructions for performing high potential testing of the emergency transformer bus bars between March 23, 2015, and April 18, 2017. As a result, the licensee did not properly assess corona- related degradation on the emergency transformer bus, which resulted in an emergency transformer bus fault and a loss of the emergency transformer and the supplemental diesel generator on January 17, 2017. Immediate corrective actions to restore compliance included replacement of the faulted portions of the emergency transformer bus, and extent of condition inspection and cleaning of the remainder of the emergency transformer bus bars. Long term corrective actions include replacement of the emergency transformer bus insulation and revision of high potential testing procedure instructions. The licensee entered this issue into the corrective action program as Condition Report CR- CNS -2017- 02164. The licensees failure to maintain Maintenance Procedure 7.3.41 to properly assess degradation of the emergency station service transformer bus, in violation of Technical Specification 5.4.1.a, was a performance deficiency. The performance deficiency was determined to be more than minor, and therefore a finding, because it was associated with the equipment performance attribute of the Initiating Events Cornerstone, and affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown, as well as, power operations. Specifically, the finding resulted in the licensees failure to identify and repair indications of corona -related degradation on the emergency station service transformer bus, which resulted in an emergency station service transformer bus fault, and a loss of the emergency station service transformer and the supplemental diesel generator on January 17, 2017. 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 required a detailed risk evaluation because it involved the partial loss of a support system that contributes to the likelihood of, or causes, an initiating event (loss -of-offsite power) and the finding affected mitigation equipment (supplemental diesel generator). A senior reactor analyst performed a detailed risk evaluation in accordance with Inspection Manual Chapter 0609, Appendix A, Section 6.0, Detailed Risk Evaluation. The analyst concluded that the finding is of very low safety significance (Green). 4 The performance deficiency had a cross-cutting aspect in the area of human performance, associated with change management , because the licensee failed to use a systematic process for evaluating and implementing a change so that nuclear safety remained the overriding priority. Specifically, on March 23, 2015, the licensee changed the Maintenance Procedure 7.3.41 bus testing method from performance of a megger test to performance of a high potential test, but failed to use a systematic process to evaluate the change to ensure that the new test had instructions that were adequate and consistent with industry Institute of Electrical and Electronics Engineers standards (H.3).
05000298/FIN-2017003-0330 September 2017 23:59:59CooperNRC identifiedLoss of Control Room Ventilation Due to Inadequate Post-Maintenance Testing ActivitiesThe inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, for the licensees failure to assure that all testing required to demonstrate that the control room emergency filter system would perform satisfactorily in service was identified and performed in accordance with written test procedures. Specifically, on May 25, 2017, following corrective maintenance to replace bent positioning rods for the A and B discharge dampers for the control room supply fans, the licensee failed to ensure that all testing described in Maintenance Procedure 7.0.5, CNS Post-Maintenance Testing, Revision 53, was identified and performed, in order to assure that the control room filter system would be able to perform its safety function. As a result, on May 26, 2017, after the licensee restored the system back to service, the in-service B discharge damper was found partially closed, resulting in the supply fan failing to meet minimum flow requirements and the control room emergency filter system being declared inoperable. Corrective actions to restore compliance included replacement of the damper positioning arm, interim actions requiring post-maintenance testing after each repositioning of the dampers, and long term actions to modify the damper control arms to prevent bending and improve position verification methods. The licensee entered this deficiency into the corrective action program as Condition Report CR-CNS-2017-05794.The licensees failure to assure that adequate post-maintenance testing was identified and performed for work on the control room supply fan discharge dampers was a performance deficiency. Using Inspection Manual Chapter 0612, Appendix B, Issue Screening, dated September 7, 2012, the inspectors determined the performance deficiency was more than minor, and therefore a finding, because it was associated with the structure, system, and component, and barrier performance attribute of the Barrier Integrity Cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers (control room envelope) protect the public from radionuclide releases caused by accidents or events. Specifically, the finding resulted in control room supply fan B failing to meet minimum flow requirements and the control room emergency filter system being declared inoperable. 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 had very low safety significance (Green) because it did not represent a degradation of the barrier function of the control room against smoke or a toxic atmosphere. The finding had a cross-cutting aspect in the area of problem identification and resolution associated with evaluation. Specifically, the licensee failed to ensure that the organization thoroughly evaluated indications of degraded supply fan flow that occurred during testing, and failed to properly assess bent discharge damper positioning rod deficiencies discovered during the maintenance activities, to ensure that resolutions addressed causes and extent of conditions were commensurate with their safety significance ( P. 2).
05000298/FIN-2017003-0130 September 2017 23:59:59CooperSelf-revealingFailure to Ensure Suitability of Materials for the Reactor Building Northeast Fan Coil UnitThe inspectors reviewed a self-revealed, non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to assure that appropriate measures were established for the selection and review for suitability of application of materials, parts, equipment, and processes that were essential to the safety-related functions of a reactor building fan coil unit. Specifically, on March 9, 2016, the licensee installed a new coil for the reactor building northeast quad fan coil unit, but failed to assure the suitability of application of the materials, parts, and equipment associated with the new coil design in that the new component had measurably higher air resistance across the coil than the previous design. As a result, on August 1, 2017, the fan coil unit failed air flow surveillance testing during the next performance of the test, resulting in the fan coil unit being declared inoperable. Corrective actions to restore compliance included cooling coil cleaning activities, implementation of compensatory measures to restore operability, and generation of a work order to replace the degraded cooling coil. The licensee entered this deficiency into the corrective action program as Condition Report CR-CNS-2017-04701.The licensees failure to assure that the newly designed coil installed in the northeast quad fan coil unit was appropriately reviewed for suitability and adequacy was a performance deficiency. The performance deficiency was evaluated using Inspection Manual Chapter 0612, Appendix B, Issue Screening, dated September 7, 2012, and was associated with the Mitigating Systems Cornerstone. 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 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 performance deficiency resulted in the northeast quad fan coil unit being declared inoperable. 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 had very low safety significance (Green) because it: was not a design deficiency where the component maintained operability; did not represent a loss of system and/or function; did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time; and did not result in the loss of a high safety-significant, nontechnical specification train. The finding had a cross-cutting aspect in the area of human performance associated with design margins, because the licensee failed to ensure that the organization operated and maintained equipment within design margins, and failed to ensure that these margins were carefully guarded and changed only through a systematic and rigorous process with special attention placed on maintaining safety-related equipment. Specifically, although the new fan coil units air flow immediately degraded from 7950 scfm to 7360 scfm after coil installation in 2016, which significantly degraded the margin to the minimum flow requirements, the licensee did not take action to address the degraded performance until it failed subsequent air flow testing (H.6).
05000298/FIN-2017003-0230 September 2017 23:59:59CooperNRC identifiedFailure to Account for Instrument Uncertainty in Safety-Related Ventilation Surveillance ProceduresThe inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion XI, Test Control, for multiple examples of the licensees failure to assure that required testing was performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. Specifically, on July 12, 2017, the inspectors identified that Surveillance Procedure 6.1SGT.501, Standby Gas Treatment A Carbon Sample, Carbon Adsorber and HEPA Filter In-place Leak Test, and Components Leak Test, Revision 16, failed to account for test instrument uncertainty in the surveillance acceptance criteria. In response to the inspectors question, the licensee discovered that instrument uncertainty was not accounted for in several standby gas treatment system surveillance procedures, as well as surveillance procedures for the control room emergency filter system; diesel generator ventilation system; control building essential ventilation system; emergency core cooling essential ventilation systems; and several emergency preparedness ventilation systems. Corrective actions to restore compliance included incorporation of instrument uncertainty into procedure changes for the affected surveillance procedures and verification that the new acceptance criteria did not challenge past operability for the affected systems. The licensee entered this issue into the corrective action program as Condition Report CR-CNS-2017-04229.The inspectors determined that the licensees failure to assure surveillance test procedures for safety-related ventilation systems incorporated test instrument uncertainty into acceptance criteria was a performance deficiency. Because the systems involved in this performance deficiency were systems that mitigate the consequences of accidents, the inspectors evaluated the finding under the Mitigating Systems Cornerstone. In accordance with Inspection Manual Chapter 0612, Appendix B, Issue Screening, dated September 7, 2012, the inspectors determined that the performance deficiency was more than minor, and therefore a finding, because it was a programmatic deficiency which adversely impacted the procedure quality 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 acceptance criteria for the licensees safety-related ventilation systems did not assure the availability of these systems to respond to accident conditions, as required by the technical specifications. The inspectors assessed the significance of this finding in accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings at Power, dated June 19, 2012, and determined this finding was of very low safety significance (Green) because it: was not a design deficiency; did not represent a loss of system and/or function; did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time; and did not result in the loss of a high safety-significant, nontechnical specification train. The finding had a cross-cutting aspect in the area of human performance associated with documentation because the licensee failed to ensure that the organization created and maintained complete, accurate, and up-to-date documentation (H.7).
05000298/FIN-2017011-0130 September 2017 23:59:59CooperNRC identifiedEmergency Transformer Bus Failure due to Inadequate Inspection and Testing ActivitiesAV. The inspectors identified a preliminary low -to-moderate safety significance (White) finding with two NRC- identified apparent violations of Technical Specification 5.4.1.a, for the licensees failure to implement and maintain Maintenance Procedure 7.3.41, Examination and High Pot Testing of Non- Segregated Buses and Associated Equipment, Revision 10, during testing and inspection of the emergency station service transformer 4160 V bus bars. Specifically, the inspectors identified: 1. A violation of Technical Specification 5.4.1.a, for the failure to implement inspection instructions to examine the emergency transformer bus insulation for discoloration and repair the associated components on March 23, 2015; and 2. A violation of Technical Specification 5.4.1.a, for the failure to maintain adequate instructions for performing high potential testing of the emergency transformer bus bars between March 23, 2015 , and April 18, 2017. As a result, the licensee did not properly assess corona- related degradation on the emergency transformer bus, which resulted in a n emergency transformer bus fault and a loss of the emergency transformer and the supplemental diesel generator on January 17, 2017. Corrective actions to restore compliance included replacement of the faulted portions of the emergency transformer bus, extent of condition inspection and cleaning of the remainder of the emergency transformer bus bars, long term corrective actions to replace the emergency transformer bus insulation, and revision of high potential testing procedure instructions. The licensee entered these issues into the corrective action program as Condition Reports CR- CNS -2017- 00223 and CR -CNS -2017 -02164. The licensees failure to implement and maintain Maintenance Procedure 7.3.41 to properly assess degradation of the emergency station service transformer bus, in violation of Technical Specification 5.4.1.a, was a performance deficiency. The performance deficiency was determined to be more than minor, and therefore a finding, because it was associated with the equipment performance attribute of the Initiating Events Cornerstone and affected the cornerstone objective to limit the likelihood of events that upset plant stability and 3 challenge critical safety functions during shutdown, as well as power operations. Specifically, the finding resulted in an emergency transformer bus fault and a loss of the emergency transformer and the supplemental diesel generator. Using NRC 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 required a detailed risk evaluation because it involve d the partial loss of a support system that contributes to the likelihood of, or causes, an initiating event (loss -of-offsite power), and the finding affected mitigation equipment (supplemental diesel generator). A senior reactor analyst performed a detailed risk evaluation in accordance with Inspection Manual Chapter 0609, Appendix A, Section 6.0, Detailed Risk Evaluation. The calculated increase in core damage frequency was dominated by station blackout initiators. The NRC preliminarily determined that the increase in core damage frequency for internal and external initiators was 6.3E -6/year, a finding of low -to-moderate risk significance (White). The performance deficiency had a cross -cutting aspect in the area of problem identification and resolution associated with evaluation, because the licensee failed to thoroughly evaluate emergency transformer electrical bus discoloration and high potential test failures to ensure that resolutions addressed the causes and extent of conditions commensurate with their safety significance (P.2 ).
05000298/FIN-2017009-0230 June 2017 23:59:59CooperSelf-revealingFailure to Implement an Adequate Procedure for Equipment ControlGreen . The team reviewed a self-revealed, non-cited violation of Technical Specification 5.4.1.a, Procedures, for the licensees failure to maintain Station Procedure 2.0.2, Conduct of Operations Procedure, Operator Logs and Reports, Revision 106, for conducting sealed valve audits. Specifically, this procedure only checked that the seals were installed, and did not check that the valves were in the correct position. This resulted in an extended period of time that the Division I residual heat removal (RHR) system was unknowingly inoperable. The licensees immediate corrective action was to revise Station Procedure 2.0.2 to include direction s to check the position of sealed valves in addition to checking that the valve sealing devices were installed. The licensee entered this issue into their corrective action program as Condition Report CR- CNS -2017- 00553. Failure to maintain Station Procedure 2.0.2 for conducting sealed valve audits, in violation of Technical Specification 5.4.1.a, was a performance deficiency. This performance deficiency is more than minor , and therefore a finding, because it affected the con figuration control attribute of the Mitigating Systems Cornerstone and adversely impacted 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 correctly identify and correct out of position Division I RHR minimum flow isolation valves resulted in unnecessarily and unknowingly extending the inoperability time of the Division I RHR subsystem by 39-45 days. Using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Findings At -Power, the inspectors determined that the violation required a detailed risk evaluation because the finding represented a loss of safety function for greater than its technical specification allowed outage time. A senior reactor analyst performed the risk evaluation and determined that the violation was of very low safety significance (Green). The team determined the finding had a cross-cutting aspect within the human performance area, resources, because leaders did not ensure that personnel, equipment, procedures, and other resources were available and adequate to support nuclear safety. Specifically, the licensee had approved Station Procedure 2.0.2, Conduct of Operations Procedure, Operator Logs and Reports, Revision 106, for conducting sealed valve audits without including the fundamental direction to ensure that the sealed valves were in the correct position (H.1).
05000298/FIN-2017002-0130 June 2017 23:59:59CooperNRC identifiedFailure to Assess Operability of Technical Specification System Functions during Surveillance TestingGreen . The inspectors identified a non- cited violation of Technical Specification 5.4.1.a, for the licensees fail ure to follow Station Procedure 0.26, Surveillance Program, Revision 70, and to assess the operability of alternate shutdown reactor pressure instrumentation during surveillance testing. Specifically, the licensee failed to assess the operability of the hig h pressure coolant injection turbine steam inlet pressure instrument that provides indications of reactor pressure for the alternate shutdown panel when the instrument was isolated during surveillance testing. As a result, operations personnel failed to r ecognize that the instrument was inoperable and failed to enter the appropriate technical specification action statements . As immediate corrective actions, the licensee validated that the alternate shutdown reactor pressure function was inoperable and that Technical Specification 3.3.3.2, Altern ate Shutdown System, Condition A, should have been entered, and generated a procedure change request to ensure T echnical Specification 3.3.3.2 would be entered during future surveillances . The licensee entered this deficiency into the corrective action program as Condition Report CR -CNS -2017- 02280. The licensees failure to assess the operability of alternate shutdown reactor pressure instrument ation when the high pressure coolant injection turbine inlet steam pr essure instrument was isolated for 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 hum an 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. Specifically, the alternate shutdown reactor pressure instrument was inoperable when the high pressure coolant injection turbine inlet pressure instrument was isolated for surveillance testing, and the appropriate technical specification action statement was not entered. 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 had very low safety significance (Green) because it: was not a design deficiency; did not repr esent a loss of system and/or function; did not represent an 3 actual loss of function; did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time; and did not result in the loss of a high safety -significant nontechnical specification train. 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 the isolation of the high pressure coolant injection turbine inlet pressure instrument during surveillance testing (H.5).
05000298/FIN-2017010-0230 June 2017 23:59:59CooperNRC identifiedFailure to Perform Timely Operability DeterminationsGreen. The team identified a Green non-cited violation of Technical Specification 5.4.1.a, for the licensees multiple failures to immediately evaluate operability of degraded or nonconforming conditions. The team identified multiple examples of these operability determinations not being performed within one shift, as required by procedure. Further, aggregate data indicated routine noncompliance with procedural requirements to document operability immediately and without delay. The licensee entered this violation into its corrective action program as Condition Report CR-CNS-2017-03937, and began evaluating actions to restore compliance. Multiple failures to perform immediate operability determinations timely as required by station procedures is a performance deficiency. This performance deficiency is more than minor because it was associated with the equipment performance attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of system s that respond to initiating events to prevent undesirable consequences. Using Inspection Manual Chapter 0609, Appendix A, dated June 19, 2012, the inspectors determined that the finding had very low safety significance (Green) because it did not result in the loss of operability or functionality of any system or train. This finding has a consistent process cross-cutting aspect in the human performance cross-cutting area because operators failed to use a consistent, systematic approach to make decisions regarding operability using the organizations well-defined decision making process (H.13)
05000298/FIN-2017010-0530 June 2017 23:59:59CooperNRC identifiedFailure to adopt appropriate procedures in accordance with 10 CFR Part 21Severity Level IV. The team identified a violation of 10 CFR 21.21(a), for the licensees failure to adopt appropriate procedures to evaluate deviations and failures to comply to identify those associated with substantial safety hazards. Specifically, Procedure EN-LI-108, 10 CFR 21 Evaluations and Reporting, Revision 5C0, was inadequate to ensure that the correct reportability call was made for a manufacturing flaw discovered in a relay that had resulted in a loss of safety function for the high pressure coolant injection system on April 25, 2016. In particular, the procedure (1) led the licensee to incorrectly conclude that a substantial safety hazard could not be created, (2) allowed a limited extent of condition in performing the substantial safety hazard evaluation such that similarly dedicated parts were not included in the scope, and (3) included incorrect guidance in Attachment 9.3. Corrective actions to restore compliance included re-evaluation of the defect under Part 21 requirements and a procedure adequacy review of the EN-LI-108-01 procedure. The licensee entered this issue into the corrective action program as Condition Reports CR-17-03936 and CR-17-04143. The failure to adopt appropriate procedures to evaluate deviations and failures to comply to identify those associated with substantial safety hazards, in violation of 10 CFR 21.21(a), was a performance deficiency. The NRCs reactor oversight process considers the safety significance of findings by evaluating their potential safety consequences. Using Inspection Manual Chapter 0612, Appendix B, Issue Screening, dated September 7, 2012, the team determined that the performance deficiency was of minor safety significance under the reactor oversight process because it involved a failure to make a report; however the underlying equipment failure was previously evaluated as having very low safety significance. The traditional enforcement process separately considers the significance of willful violations, violations that impact the regulatory process, and violations that result in actual safety consequences. Traditional enforcement applied to this finding because it involved a violation that impacted the regulatory process. The team used the NRC Enforcement Policy, dated November 1, 2016, to determine the significance of the violation. The inspectors determined that the violation was similar to Examples 6.9.d.10 and 6.9.d.13 of the Enforcement Policy, because although the procedure resulted in an inadequate reportability review and the issue was not reported as a manufacturing flaw, the licensee had reported some aspects of the event under the requirements of 10 CFR 50.73. As a result, the team determined that the violation should be classified as a Severity Level IV violation. Cross-cutting aspects are not assigned to traditional enforcement violations.
05000298/FIN-2017002-0230 June 2017 23:59:59CooperSelf-revealingLoss of Control Room Ventilation Due to Ineffective Preventive Maintenance StrategyGreen . The inspectors reviewed a self -revealed, non- cited violation of Technical Specification 5.4.1.a , for the licensees failure to maintain work order instructions for control room supply fan maintenance resulting in the loss of the control room emergency filtration system. Specifically, prior to October 23, 2016, work order instructions for periodic preventive maintenance on the SF- C-1A supply fan failed to include industry recommended checks to ensure that the bearings were adequately engaged with the fan shaft, and failed to include proper work sequencing to ensure vibration data trending was meaningful. The ineffective preventive maintenance strategy resulted in the failure of the control room supply fan i nboard bearing during operation and a loss of the control room emergency filtration system function. Corrective actions to restore compliance included repair of the s upply fan and changes to improve the effectiveness of the fans preventive maintenance strategy. The licensee entered this deficiency into the corrective action program as Condition Report CR- CNS -2016- 07426. The licensees failure to maintain work order instructions for control room supply fan maintenance , in violation of Technical Specification 5.4.1.a , was a performance deficiency. The performance deficiency was more than minor , and therefore a finding, because it was associated with the structure, system, and component (SSC) and barrier performance attribute of the Barrier Integrity Cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers ( control room envelope) protect the public fro m radionuclide releases caused by accidents or events. Using Inspection Manual Chapter 0609, Appendix G, Attachment 1, Shutdown Operations Significance Process Phase 1 Initial Screening and Characterization of Findings, dated May 9, 2014, the inspectors determined that the finding had very low safety significance (Green) because the inspectors answered no to all of the Barrier Integrity screening questions. The finding had a cross -cutting aspect in the area of human performance associated with resourc es, because the licensee failed to ensure that personnel, equipment, procedures, and other resources we re available and adequate to support nuclear safety (H.1).
05000298/FIN-2017010-0330 June 2017 23:59:59CooperNRC identifiedProgrammatic Failure to Identify and Correct Adverse TrendsGreen. The team identified a Green non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, for the licensees programmatic failure to promptly identify adverse trends and enter them into the corrective action program. Often, when adverse trends were identified, they were addressed using informal processes. This was particularly the case for safety culture-related trends such as adverse trends in organizational behaviors. The licensee entered this violation into its corrective action program as Condition Report CR-CNS-2017-03938, and took action to formalize identification processes for potential adverse trends. The programmatic failure to promptly identify adverse trends as required by station procedures was a performance deficiency. This performance deficiency is more than minor because if left uncorrected, it has the potential to become a more significant safety concern. Specifically, failure to arrest an adverse trend, particularly in organizational behaviors, could lead to increased likelihood of a worker-induced initiating event or a failure to effectively mitigate an accident. Using Inspection Manual Chapter 0609, Appendix A, dated June 19, 2012, the inspectors determined that the finding had very low safety significance (Green) because it did not result in the loss of operability or functionality of any system or train. This finding has a trending cross-cutting aspect in the problem identification and resolution cross- cutting area because the organization failed to use available information in the aggregate to identify programmatic and common cause issues (P.4).
05000298/FIN-2017002-0330 June 2017 23:59:59CooperSelf-revealingLoss of Control Room Ventilation Due to Improper Switch ManipulationThe inspectors reviewed a self -revealed, non- cited violation of Technical Specification 5.4.1.a , for the licensees f ailure to implement System Operating Procedure 2.2.38, HVAC Control Building, Revision 43, during control building ventilation testing. Specifically, on December 7, 2016, when directed to turn off control building ventilation recirculation fan, RF- C-1A, operations personnel instead inadvertently turned off the operating control room emergency filtration system supply fan, 1 -SF -C-1A, resulting in the loss of the control room emergency filtration system function. Corrective actions to restore compliance included restoration of the control room emergency filtration supply fan and procedure changes to require peer checks for this surveillance test and similar 4 activities. The licensee entered this deficiency into the corrective action program as Condition Report CR -CNS -2016- 08744. The licensees failure to implement System Operating Procedure 2.2.38 , in violation of Technical Specification 5.4.1.a , was a performance deficiency. The performance deficiency was determined to be 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 ( control room envelope) protect the public from radionuclide releases caused by accidents or events. 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 had very low safety significance (Green) because it did not represent a degradation of the barrier function of the control room against smoke or a toxic atmosphere. The finding had a cross -cutting aspect in the area of human performance associated with challenge the unknown, because the licensee did not stop when faced with uncertain conditions, and did not ensure that risks we re evaluated and managed before proceeding. Specifically, despite noting several a bnormalities with the switch being manipulated, operations personnel did not stop to evaluate the uncertain conditions nor did they evaluate the risks associated with proceeding (H.11).
05000298/FIN-2017002-0430 June 2017 23:59:59CooperLicensee-identifiedLicensee-Identified ViolationTechnical Specification 5.7.1 states, in part, that high radiation areas w ith dose rates greater than 0.1 rem/hr at 30 centimeters shall be barricaded and conspicuously posted as a high radiation area. Contrary to the above, on November 2, 2016, a high radiation area with does rates greater than 0.1 rem/hr at 30 centimeters was not barricaded and conspicuously posted as a high radiation area. Specifically, a radiation protection technician (RPT) identified an unposted high radiation area at the control rod drive (CRD) A pump filter area on r eactor building 881 feet southea st quadrant. D ose rates of 120 mrem/hr at 30 centimeters from the CRD filter were identified. This issue was identified as a result of a RPTs deliberate and focused observations during the course of performing their normal duties of performing radiological surveys. The licensee documented this issue in the corrective action program as Condition Report CR- CNS -2016 -00788. The finding was determined to be of very low safety significance (Green) because it was not an ALARA planning issue, there was no overexposure or potential for overexposure, and the licensees ability to assess dose was not compromised.
05000298/FIN-2017010-0430 June 2017 23:59:59CooperNRC identifiedFailure to Monitor No. 2 Diesel Generator under 50.65(a)(1) due to Inadequate Maintenance Rule EvaluationGreen. The team identified a non-cited violation of 10 CFR 50.65(a)(1)/(a)(2), for the licensees failure to perform an a(1) evaluation and establish a(1) goals when the No. 2 diesel generator a(2) preventive maintenance demonstration became invalid. Specifically, on April 28, 2017, the No. 2 diesel generator exceeded its performance criteria when it experienced a second maintenance rule functional failure, but the licensee failed to perform an associated a(1) evaluation. The licensee had failed to appropriately evaluate a February 4, 2017, failure associated with the No. 2 diesel generator jacket water heater failure in the Maintenance Rule Program and, as a result, the site failed to evaluate and monitor the equipment under 10 CFR 50.65(a)(1) as required. Corrective actions taken by the licensee to restore compliance included reevaluation of the February 4, 2017, functional failure and performance of an a(1) evaluation. The issue was entered into the licensees corrective action program as Condition Report CR-17-03930. The licensees failure to monitor the No. 2 diesel generator in accordance with the requirements of 10 CFR 50.65(a)(1), due to incorrectly evaluating one maintenance rule functional failure, in violation of 10 CFR 50.65(a)(1)/(a)(2), was a performance deficiency. The inspectors screened the performance deficiency using Inspection Manual Chapter 0612, Appendix B, Issue Screening, dated September 7, 2012, and determined that the issue was more than minor, and therefore a finding, because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events. 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 had very low safety significance (Green) because it: was not a design deficiency; did not represent a loss of system and/or function; did not represent an actual loss of function; did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time; and did not result in the loss of a high safety-significant nontechnical specification train. The finding had a cross-cutting aspect in the area of problem identification and resolution associated with evaluation, because the licensee failed to ensure that the organization thoroughly evaluated 5 the No. 2 diesel generator issues to ensure that resolutions addressed causes and extent of conditions commensurate with their safety significance (P.2)
05000298/FIN-2017009-0130 June 2017 23:59:59CooperSelf-revealingExceeding the Technical Specification A llowed Out of Service Time of the Division I RHR SystemGreen . The team reviewed a self -revealed, non -cited violation of Technical Specific ation 3.5.1, Emergency Core Cooling Systems Operating, for the licensees failure to restore the Division I residual heat removal system (RHR) during clearance restoration, which resulted in exceeding the applicable technical specification action compl etion time . Specifically, from October 7, 2016, to February 5, 2017, the licensee failed to restore Division I RHR minimum flow isolation valves for RHR pumps A and C to the open position prior to reinstalling the valve sealing devices following maintenan ce perform ed during Refueling Outage 29. The licensees immediate corrective action was to restore the Division I RHR subsystem to operable status by sealing open the minimum flow isolation valves for RHR pumps A and C. The licensee entered this issue in to their corrective action program as C ondition Report CR- CNS -2017- 0055 3. The licensees failure to properly restore the Division I RHR system during clearance restoration resulted in exceeding the applicable technical specification action completion time , in violation of Technical Specification 3.5.1, whi ch 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 Mitigating Systems C ornerst one and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to pr event undesirable consequences. Specifically, the failure to follow technical specification requirements t o ensure the availability, reliability, and capability of the Division I RHR sub system directly affe cted the cornerstone objective. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At -Power, dat ed June 19, 2012, the inspectors determined that the finding required a detail ed risk evaluation because it involved an actual loss of function of at least a single train for greater than its technical spec ification allowed outage time. A detai led risk ev aluation (Attachment 2) calculated an increase in core damage frequency of 4.7E -7 for the 89 days, 12 hours, and 49 minutes exposure period. Therefore, this violation was of very low safety significance (Green). The team determined the finding had a cros s- cutting aspect within the human performance area, challenge the unknown, because individuals fail ed to perform adequate job -site reviews to identify and resolve unexpected conditions. Specifically, operations personnel restoring the Division I RHR subsy stem did 3 not ensure that the minimum flow isolation valves were repositioned to the correct position of sealed open (H.11).
05000298/FIN-2017010-0130 June 2017 23:59:59CooperNRC identifiedFailure to Assign Corrective Actions to Prevent Recurrence of High Pressure Coolant Injection FailureGreen. The team identified a non-cited violation of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to assign corrective actions to preclude repetition of a significant condition adverse to quality associated with the loss of the high pressure coolant injection system. Specifically, between July 28, 2016, and June 29, 2017, the licensee failed to assign or complete corrective actions to prevent recurrence to address the failure of a relay coil that resulted in a loss of safety function for the single train high pressure coolant injection system. Corrective actions to restore compliance included reevaluation of the corrective 3 actions assigned to the root cause of the condition and the creation of corrective actions to prevent recurrence for the condition. The licensee entered this deficiency into the corrective action program as Condition Report CR 17 03544. The licensees failure to assign corrective actions to preclude repetition of a significant condition adverse to quality, in violation of 10 CFR 50, Appendix B, Criterion XVI, was a performance deficiency. The performance deficiency was evaluated using Inspection Manual Chapter 0612, Appendix B, Issue Screening, dated September 7, 2012, and was associated with the Mitigating Systems cornerstone. The team determined that the performance deficiency was more than minor, and therefore a finding, because if left uncorrected, the performance deficiency would have the potential to lead to a more significant safety concern. Specifically, the licensees failure to assign corrective actions to preclude repetition of a significant condition adverse to quality could reasonably result in the condition recurring and creating more safety-significant equipment failures. 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 had very low safety significance (Green) because it: was not a design deficiency; did not represent a loss of system and/or function; did not represent an actual loss of function; did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time; and did not result in the loss of a high safety-significant non-technical specification train. The finding had a cross-cutting aspect in the area of problem identification and resolution associated with resolution, because the licensee failed to ensure that the organization took effective corrective actions to address issues in a timely manner commensurate with their safety significance (P.3).
05000298/FIN-2017001-0331 March 2017 23:59:59CooperNRC identifiedFailure to Identify a Condition Adverse to QualityThe 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 identify a condition adverse to quality for Division 1 residual heat removal service water booster pump A, in accordance with Station Procedure 0-CNS-LI-102, Corrective Action Process, Revision 6. Specifically, on January 5, 2017, the inspectors identified an oil level lower than normally expected, oil on the pump skid, and an oil droplet formed on the Division 1 residual heat removal service water booster pump A inboard bearing sight glass. The inspectors informed the control room of this condition, and the licensee determined the oil leakage from the pumps sight glass would have prevented the pump from operating for the required 30 days during a design basis accident. The immediate corrective action was to repair the Division 1 residual heat removal service water booster pump A inboard bearing sight glass, restoring operability of the pump. The licensee entered this deficiency into the corrective action program as Condition Report CR-CNS-2017-00054. The licensees failure to identify a condition adverse to quality for Division 1 residual heat removal service water booster pump A, in violation of Station Procedure 0-CNS-LI-102, was a performance deficiency. The performance deficiency was determined to be more than minor, and therefore a finding, because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events. Specifically, the oil leakage from the service water booster pump A inboard bearing sight glass would have prevented the pump from operating for its required 30-day mission time during a design basis accident and resulted in the pump being declared inoperable. 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 had very low safety significance (Green) because it: was not a design deficiency; did not represent a loss of system and/or function; did not represent an actual loss of function; did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time; and did not result in the loss of a high safety significant nontechnical specification train. The finding had a cross-cutting aspect in the area of human performance associated with challenge the unknown because the licensee failed to stop when faced with uncertain conditions and failed to ensure that risks are evaluated and managed before proceeding. Specifically, the licensee did not maintain a questioning attitude during job-site reviews to identify and resolve unexpected conditions, including lower than the expected oil level in the service water booster pump A inboard bearing sight glass, oil on the pump skid, and an oil droplet formed on the bottom of the sight glass (H.11).
05000298/FIN-2017001-0431 March 2017 23:59:59CooperNRC identifiedFailure to Address Nonconforming Pipe Thinning in Accordance with the ASME CodeThe inspectors identified a non-cited violation of 10 CFR 50.55a(g)(4) for the licensees failure to use an approved method to disposition an American Society of Mechanical Engineers Code nonconforming condition in the residual heat removal service water system. Specifically, the licensee identified multiple locations with localized pipe thinning below the American Society of Mechanical Engineers Code B31.1 design minimum pipe-wall thickness during an ultrasonic examination but failed to use an approved method to calculate a new acceptable pipe-wall thickness. As a corrective action to restore compliance, the licensee replaced this section of piping on November 1, 2016, during Refueling Outage 29. The licensee entered this issue into the corrective action program as Condition Reports CR-CNS-2016-05558 and CR-CNS-2016-05963. The licensees failure to use an approved method to calculate a new minimum allowable pipe-wall thickness, in violation of 10 CFR 50.55a(g)(4), was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the design control attribute of the Mitigating System Cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, calculating an allowable minimum pipe-wall thickness value that is below the American Society of Mechanical Engineers code design minimum value reduces the pipings structural integrity, potentially leading to the failure of the piping. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings AtPower, dated June 19, 2012, inspectors determined the finding screened as having very low safety significance (Green) because it: was not a design deficiency; did not represent a loss of system and/or function; did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time; and did not result in the loss of a high safety-significant nontechnical specification train. This finding had a cross-cutting aspect in the area of human performance associated with design margins because the licensee failed to operate and maintain the residual heat removal service water system within the American Society of Mechanical Engineers code minimum pipe-wall thickness. Specifically, having identified that the affected pipe location was below the allowable pipe-wall thickness, the licensee opted to calculate and accept a new minimum pipe-wall thickness value that was not consistent with code requirements instead of repairing the affected piping at the time of discovery (H.6).
05000298/FIN-2017001-0531 March 2017 23:59:59CooperSelf-revealingLoss of Shutdown Cooling due to Relay MaintenanceThe inspectors reviewed a self-revealed, non-cited violation of Technical Specification 5.4.1.a, for the licensees failure to implement Maintenance Procedure 7.3.16, Low Voltage Relay Removal and Installation, Revision 22, for relay replacement work. Specifically, on October 28, 2016, the licensee failed to evaluate the potential impact of primary containment isolation system relay PCIS-REL-K27 work on shutdown cooling relay PCIS-REL-K30, which was mounted next to K27 and shared a common mounting rail. As a result, the licensee did not identify the potential of losing residual heat removal shutdown cooling, and while installing the K27 relay and snapping it into the mounting rail, workers caused a momentary actuation of relay K30 and a loss of residual heat removal shutdown cooling. Corrective actions to restore compliance included restoration of shutdown cooling, completion of the K27 relay maintenance with shutdown cooling out of service, and an outage risk management procedure change that prohibited work on or near shutdown cooling relays while the system was required to be in service. The licensee entered this deficiency into the corrective action program as Condition Report CR-CNS-2016-07645. The licensees failure to implement Maintenance Procedure 7.3.16, in violation of Technical Specification 5.4.1.a, 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 Initiating Events Cornerstone and affected the associated cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown operations. Using Inspection Manual Chapter 0609, Appendix G, Attachment 1, Shutdown Operations Significance Process Phase 1 Initial Screening and Characterization of Findings, dated May 9, 2014, the inspectors determined that the finding did not require a quantitative assessment because the event occurred when the refuel canal/cavity was flooded. Therefore, the finding screened as very low safety significance (Green). The finding had a cross-cutting 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 primary containment isolation system relay work activities to ensure residual heat removal shutdown cooling was not adversely impacted (H.5).
05000298/FIN-2017001-0131 March 2017 23:59:59CooperNRC identifiedFailure to Maintain Alternate Shutdown Emergency ProcedureThe inspectors identified a non-cited violation of Technical Specification 5.4.1.a for the licensees failure to maintain Emergency Procedure 5.1ASD, Alternate Shutdown, Revision 17, for establishing reactor equipment cooling system flow to the high pressure coolant injection system fan coil unit. Specifically, the licensee failed to maintain Emergency Procedure 5.1ASD with adequate instructions to place the reactor equipment cooling system north or south critical loop in service and verify reactor equipment system flow to the high pressure cooling injection system fan coil unit during some control room evacuation scenarios. The immediate corrective actions were to assess operability of the high pressure coolant injection system during control room evacuations that are not related to fire scenarios, and to revise Emergency Procedure 5.1ASD with instructions to open the criticalloop supply valves (REC-MOV-711 or REC-MOV-714) in the control room or locally, and verify reactor equipment system flow to the high pressure coolant injection fan coil unit. The licensee entered this deficiency into the corrective action program as Condition ReportCR-CNS-2017-01403. The licensees failure to maintain Emergency Procedure 5.1ASD to establish reactor equipment cooling system flow to the high pressure coolant injection fan coil unit during some control room evacuation scenarios, in violation of Technical Specification 5.4.1.a, was a performance deficiency. The performance deficiency was determined to be more than minor, and therefore a finding, because it was associated with the procedural quality attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events. Specifically, the licensee did not provide instructions to establish reactor equipment cooling system flow to the high pressure coolant injection system fan coil unit, which would have complicated operator response during a control room evacuation. 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 had very low safety significance (Green) because it: was not a design deficiency; did not represent a loss of system and/or function; did not represent an actual loss of function; did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time; and did not result in the loss of a high safety-significant nontechnical specification train. The finding had a cross-cutting aspect in the area of problem identification and resolution associated with identification. Specifically, the licensee failed to implement a corrective action program with a low threshold for identifying issues during the required annual review of emergency procedures (P.1).
05000298/FIN-2017001-0631 March 2017 23:59:59CooperSelf-revealingFailure to Install Correct Mechanical Stop and Verify Proper OperationThe inspectors reviewed a self-revealed, non-cited violation of Technical Specification 3.0.4 for the licensees failure to install the correct reactor core isolation cooling pressure control valve, RCIC-AOV-PCV23, mechanical stop and verify proper operation of the system prior to entering a mode of applicability for Technical Specification 3.5.3. This condition resulted in RCIC-AOV-PCV23 going fully open during surveillance testing following Refueling Outage 29, causing a pressure transient. This transient caused a failure of the reactor core isolation cooling turbine lube oil cooler gasket, lifting of a pressure relief valve, and a water leak. The licensee immediately shut down the reactor core isolation cooling system and declared it inoperable. The immediate corrective actions were to restore RCIC-AOV-PCV23 from the closed mechanical stop to the required open mechanical stop and to replace the turbine lube oil cooler gasket to restore operability of the system. The licensee entered this deficiency into the corrective action program as Condition Report CR-CNS-2016-08122 and initiated a root cause evaluation to investigate this condition. The licensees failure to install the correct reactor core isolation cooling pressure control valve, RCIC-AOV-PCV23, mechanical stop and verify proper operation of the system prior to entering a mode of applicability for Technical Specification 3.5.3, in violation of Technical Specification 3.0.4, was a performance deficiency. The performance deficiency was determined to be more than minor, and therefore a finding, because it was associated with the design control attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events. Specifically, the licensee installed RCIC-AOV-PCV23 with the incorrect mechanical stop, and proper valve operation was not verified after installation during Refueling Outage 29, which caused the reactor core isolation cooling system to lose function during surveillance testing. This transient caused a failure of the reactor core isolation cooling turbine lube oil cooler gasket and an associated water leak. 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 required a detailed risk evaluation because it represented a loss of system and/or function. In the detailed risk evaluation, the analyst assumed the reactor core isolation cooling system was unavailable for 50 hours. The analyst used the Test/Limited Use Version COOPER-DEESE-HCI03 of the Cooper SPAR model run on SAPHIRE, Version 8.1.5. The analyst updated the initiating event frequencies for transients, losses of condenser heat sink, losses of main feed water, grid related losses of offsite power, and switchyard centered losses of offsite power to the more recent values from the 2014 update to the industry data found in INL/EXT-14-31428, Initiating Event Rates at U.S. Nuclear Power Plants, 1998-2013, Revision 1. From this, the finding was determined to have an increase in core damage frequency of 8.4E-8/year and to be of very low safety significance (Green). Transients, losses of condenser heat sink, and losses of main feed water were the dominant core damage sequences. The automatic depressurization system and the reactor protection system remained to mitigate these sequences. The finding had a cross-cutting aspect in the area of human performance associated with documentation because the licensee failed to create and maintain complete, accurate, and up-to-date documentation associated with RCIC-AOV-PCV23 design drawings and the maintenance procedure for setting and testing the mechanical stop (H.7).
05000298/FIN-2017001-0231 March 2017 23:59:59CooperNRC identifiedFailure to Identify a Condition Adverse to Quality Associated with the 250 Vdc Electrical SystemThe 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 identify a condition adverse to quality associated with Station Procedure 2.2.24.1, 250 Vdc Electrical System (Div 1), Revision 14, in accordance with Station Procedure 0-CNS-LI-102, Corrective Action Process, Revision 6. Specifically, the licensee failed to identify that Station Procedure 2.2.24.1 contained inadequate instructions to ensure the oncoming charger 1C output voltage was matched with the bus 1A voltage when transferring bus 1A from charger 1A to charger 1C, so that technical specification bus voltage requirements would remain met. This resulted in an unexpected and initially unrecognized decline in voltage on the bus to below the required minimum of 260.4 Vdc. This condition required the licensee to declare the Division 1 250 Vdc electrical system and Division 1 residual heat removal low pressure coolant injection system inoperable. The immediate corrective action was to adjust the charger 1C float voltage greater than 260.4 Vdc to restore operability of the Division 1 250 Vdc electrical and residual heat removal low pressure coolant injection systems. The licensee entered this deficiency into the corrective action program as Condition Reports CR-CNS-2016-08658 and CR-CNS-2017-00750. The licensees failure to identify a condition adverse to quality associated with Station Procedure 2.2.24.1, to ensure technical specification bus voltage requirements were met, in violation of Station Procedure 0-CNS-LI-102, was a performance deficiency. The performance deficiency was determined to be more than minor, and therefore a finding, because it was associated with the procedural quality attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events. Specifically, charger 1C, when in service, did not maintain battery 1A terminal voltage within the requirements of Surveillance Requirement 3.8.4.1, which required the licensee to declare the Division 1 250 Vdc electrical system and the Division 1 residual heat removal low pressure coolant injection system inoperable. 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 had very low safety significance (Green) because it: was not a design deficiency; did not represent a loss of system and/or function; did not represent an actual loss of function; did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time; and did not result in the loss of a high safety-significant, nontechnical specification train. The finding had a cross-cutting aspect in the area of problem identification and resolution associated with evaluation. Specifically, the licensee failed to thoroughly evaluate the charger 1C float voltage issue to ensure that the resolution addressed the cause and extent of condition commensurate with the safety significance (P.2).
05000298/FIN-2016004-0331 December 2016 23:59:59CooperSelf-revealingFailure to Maintain Service Water Pump Maintenance ProcedureThe inspectors reviewed a self-revealed, non-cited violation of Technical Specification 3.6.4.2, Secondary Containment Isolation Valves, for the licensees failure to maintain secondary containment isolation valve HV-AOV-265 operable as a result of erecting scaffolding that interfered with valve operation. Specifically, between June 29, 2016, and September 14, 2016, the licensee erected scaffolding in close proximity of valve HV-AOV-265, such that, during valve stroking, the scaffolding would pinch the actuator air line and prevent the valve from closing, rendering the valve inoperable for approximately 10 weeks. This resulted in the licensees need to reduce power to approximately 50 percent in order to comply with technical specifications upon discovery. Immediate corrective actions included removal of the scaffolding, replacement of the pinched air line, and restoration of the valve to operable status. The licensee entered this deficiency into the corrective action program as Condition Report CR-CNS-2016-05608 and initiated a root cause evaluation to investigate this condition. The licensees failure to implement Procedure 7.0.7, Scaffolding Construction and Control, Revision 34, to ensure scaffolding did not adversely affect plant equipment, in violation of Technical Specification 3.6.4.2, 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, and component and barrier performance attribute of the Barrier Integrity Cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers (secondary containment) protect the public from radionuclide releases caused by accidents or events. Specifically, the improperly erected scaffolding prevented the operation of a secondary containment isolation valve, rendering it inoperable for approximately 10 weeks. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings AtPower, dated June 19, 2012, the inspectors determined that the finding had very low safety significance (Green) because it only represented a degradation of the radiological barrier function provided for the control room, reactor building, spent fuel pool building, or standby gas treatment system. The finding had a cross-cutting aspect in the area of human performance associated with resources. Specifically, the licensee failed to ensure that personnel, equipment, procedures, and other resources were available and adequate to support nuclear safety (H.1).
05000298/FIN-2016004-0431 December 2016 23:59:59CooperSelf-revealingFailure to Maintain Main Steam System Operating ProcedureThe inspectors reviewed a self-revealed, non-cited violation of Technical Specification 5.4.1.a for the licensees failure to maintain Station Procedure 2.2.56, Main Steam System, Revision 49, to prevent a main steam line high flow Group 1 primary containment isolation signal when opening an inboard main steam isolation valve. Specifically, the licensee failed to maintain Station Procedure 2.2.56 with adequate differential pressure limits for reopening closed main steam isolation valves during plant shutdown, which caused the unexpected closure of all the open main steam isolation and drain valves during the plant cooldown process. This resulted in a loss of the main steam line decay heat removal path, which caused reactor coolant system pressure and temperature to increase by approximately 13 psig and 3 degrees Fahrenheit, respectively, during the event. The immediate corrective actions were to reset the Group 1 isolation signal and open the main steam line drain valves to recommence plant cooldown. The licensee entered this deficiency into the corrective action program as Condition Report CR-CNS-2016-05835, and the licensee initiated an apparent cause evaluation to investigate this condition. The licensees failure to maintain Station Procedure 2.2.56 to prevent a main steam line high flow Group 1 isolation signal when opening an inboard main steam isolation valve, in violation of Technical Specification 5.4.1.a, was a performance deficiency. The performance deficiency was determined to be more than minor, and therefore a finding, because it was associated with the procedural quality attribute of the Initiating Events Cornerstone and affected the associated cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown. Specifically, the Group 1 isolation signal closed the main steam line drain valves, which resulted in a loss of the main steam line decay heat removal path and caused reactor coolant system pressure and temperature to increase. The inspectors determined Inspection Manual Chapter 0609, Appendix G, Attachment 1, Shutdown Operations Significance Determination Process Phase 1 Initial Screening and Characterization of Findings, dated May 9, 2014, was not applicable because plant temperature and pressure were not within the normal residual heat removal/decay heat removal system operating parameters. 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 screened as having very low safety significance (Green) because it did not cause both a reactor trip and the loss of mitigation equipment relied upon to transition the plant from the onset of a trip to a stable shutdown condition. A cross-cutting aspect was not assigned to this finding because the performance deficiency occurred in 1988 when the licensee changed the procedural limits for differential pressure across the main steam isolation valves when reopening them, and therefore, was not indicative of current licensee performance.
05000298/FIN-2016004-0231 December 2016 23:59:59CooperNRC identifiedFailure of an Analysis to Demonstrate that Changes Did Not Reduce the Effectiveness of the Emergency PlanThe inspectors identified a non-cited violation of 10 CFR 50.54(q)(3) for the licensees failure to perform an analysis demonstrating that proposed emergency plan implementing procedure changes did not reduce the effectiveness of the emergency plan. Specifically, the licensees 50.54(q) evaluation failed to demonstrate that Emergency Plan Implementing Procedure 5.7.1, Emergency Classification, Revision 54, changes, associated with Emergency Action Level SG2.1 and the fission product barrier matrix, did not result in a reduction in effectiveness. The corrective action was to revise 10 CFR 50.54(q) Evaluation 2016-011 to provide additional information about the ability of emergency coordinators in the Technical Support Center and Emergency Operations Facility to classify using the revised emergency action levels. The licensee entered this deficiency into the corrective action program as Condition Report CR-CNS-2016-05697. The licensees failure to perform an analysis demonstrating that proposed changes to Emergency Plan Implementing Procedure 5.7.1 did not reduce the effectiveness of the emergency plan, in violation of 10 CFR 50.54(q)(3), was a performance deficiency. The finding was more than minor, and therefore a finding, because it was associated with the procedure quality attribute (emergency action level changes) of the Emergency Preparedness Cornerstone and adversely affected the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, the licensees ability to ensure that adequate measures are taken to protect the health and safety of the public is degraded if the licensee performs inadequate analyses of the effects of changes to the emergency plan. Using Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, Attachment 2, dated September 22, 2015, the inspectors determined that the finding was of very low safety significance (Green) because it was not associated with a risk-significant planning standard function or a planning standard function. This finding had a cross-cutting aspect in the area of human performance, associated with change management, because the licensee failed to use a systematic process for evaluating and implementing changes so that nuclear safety remains the overriding priority. Specifically, the licensee did not have an adequate understanding of the licensing basis for making changes to emergency action levels (H.3).
05000298/FIN-2016403-0131 December 2016 23:59:59CooperNRC identifiedSecurity
05000298/FIN-2016004-0131 December 2016 23:59:59CooperSelf-revealingFailure to Maintain Reactor Vessel Assembly Procedure to Ensure Adequate Moisture Separator ShieldingThe inspectors reviewed a self-revealed, non-cited violation of Technical Specification 5.4.1.a for the licensee's failure to ensure sufficient radiological work controls were in place when the reactor pressure vessel moisture separator was installed during vessel reassembly. Specifically, the licensee failed to maintain sufficient detail in Station Procedure 7.4Reassembly, Reactor Vessel Reassembly, Revision 13, to ensure that the moisture separator had adequate water shielding during lifts, such that radiation fields were appropriately controlled. The licensee took immediate corrective action to ensure resubmergence of the radiologically significant sections of the moisture separator and restore the requisite water shielding, thereby restoring ambient refuel floor radiological conditions. The licensee entered this deficiency into the corrective action program as Condition Report CR-CNS-2016-07552. The licensee's failure to ensure sufficient radiological work controls were in place when the reactor pressure vessel moisture separator was lifted during vessel reassembly, in violation of Technical Specification 5.4.1.a, was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the program and process attribute of the Occupational Radiation Safety Cornerstone and adversely affected the cornerstone objective to ensure adequate protection of worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. Specifically, the failure to have sufficient procedural guidance to maintain adequate water shielding on the moisture separator resulted in unanticipated elevated dose rates on the refuel floor and unplanned radiological exposures to workers in the immediate work area. Using Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, dated August 19, 2008, the inspectors determined that the violation had very low safety significance (Green) because: (1) it was not an as low as reasonably achievable (ALARA) 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. The inspectors determined that the finding had a cross-cutting aspect in the area of human performance associated with avoiding complacency. Specifically, the licensee failed to recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes and failed to implement appropriate error reduction tools (H.12).
05000298/FIN-2016008-0130 September 2016 23:59:59CooperNRC identifiedPossible Failure to Ensure that the Assumptions in the Engineering Analysis Remain ValidAs part of the transition to a performance-based, risk-informed fire protection program, the licensee adopted the requirements of NFPA 805. NFPA 805 requires the following in Section 2.6: Monitoring. A monitoring program shall be established to ensure that the availability and reliability of the fire protection systems and features are maintained and to assess the performance of the fire protection program in meeting the performance criteria. Monitoring shall ensure that the assumptions in the engineering analysis remain valid. The team reviewed selected samples of equipment monitored by the licensee using Procedure 3-CNS-DC-357, NFPA 805 Monitoring Program, Revision 0, to ensure that the licensees program properly implemented the requirements of NFPA 805, Section 2.6. The team also reviewed Engineering Report Number ER2015-002, NFPA 805 Fire Protection Monitoring Program, Revision 2. The team observed that for components used in the fire probabilistic risk assessment, the unavailability time for those components was monitored using the existing maintenance rule monitoring program. These components included the: Control rod drive pumps Core spray pumps Emergency diesel generators Emergency station service transformer Startup station service transformer High pressure core spray pump Instrument air compressors Residual heat removal pumps Standby liquid control pumps Service water pumps The team noted that the action levels for availability in the maintenance rule monitoring program were greater than the assumptions in the fire probabilistic risk assessment. With this observation, the team questioned the licensee as to whether this met the requirement in NFPA 805 to maintain the assumptions in the engineering analysis. The licensee informed the team that they had performed a sensitivity analysis to determine the significance of monitoring at a higher level of unavailability via the maintenance rule. This analysis determined an increase in core damage frequency for the additional unavailability time that could be accrued above the assumption for availability in the fire probabilistic risk assessment and up to the maintenance rule monitoring value for unavailability. This increase in core damage frequency was then determined to be acceptable if it did not exceed 1.0E-6/year. The team noted that for an individual component this screening criterion would not exceed more than 2 percent of the licensees baseline fire core damage frequency. The team was aware that some particular aspects of the monitoring program were being discussed between the industry and the NRCs Office of Nuclear Reactor Regulation during periodic public meetings which discussed Frequently Asked Question 10-0059, NFPA 805 Monitoring. The monitoring program and the sensitivity analysis approach used by the licensee are enveloped in these discussions. The team determined that additional information is required to determine if a performance deficiency exists. Specifically, the team needed to determine if the licensees action to set the action levels for the availability of some plant components at the components maintenance rule monitoring values and the performance of a riskinformed sensitivity analysis in an attempt to ensure that the assumptions in the engineering analysis remained valid would be an acceptable approach. Judgment on the suitability of this approach is pending further resolution of the monitoring program during discussions of Frequently Asked Question 10-0059, NFPA 805 Monitoring. The licensee entered this issue of concern into the corrective action program as Condition Report CR-CNS-2016-05109. This issue of concern is being treated as Unresolved Item 05000298/2016008-01, Possible Failure to Ensure that the Assumptions in the Engineering Analysis Remain Valid.
05000298/FIN-2016002-0330 June 2016 23:59:59CooperSelf-revealingFailure to Maintain Design Control for High Pressure Coolant Injection System Electrical CircuitThe inspectors reviewed a self-revealed, non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to verify the adequacy of design of the high pressure coolant injection auxiliary lube oil pump 125 Vdc starter circuit. Specifically, in 1984, the licensee modified the design of the starter circuit and eliminated a resistor that served to protect the circuit from shorting due to indication light bulb failures. As a result, on April 26, 2016, a shorted light bulb resulted in the loss of power to the auxiliary lube oil pump, rendering the high pressure coolant injection system inoperable and unavailable. Immediate corrective actions included replacing the light socket and blown fuse and changing out the nonessential light bulb with an essential bulb. This event was entered into the licensees corrective action program as Condition Report CR-CNS-2016-02318, and the licensee initiated a root cause evaluation to investigate the failure. The licensees failure to verify the adequacy of design of the high pressure coolant injection auxiliary lube oil pump starter circuit in accordance with 10 CFR Part 50, Appendix B, Criterion III, 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 adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, at the time the modification was installed, the licensee had not taken sufficient actions to ensure that the electrical circuit was protected from light bulb shorting failures, resulting in the high pressure coolant injection system ultimately being rendered inoperable. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings AtPower, dated June 19, 2012, inspectors determined that the finding required a detailed risk evaluation because it represented a loss of the system and function of high pressure coolant injection. The inspectors determined that the finding was of very low safety significance (Green) through performing a detailed risk evaluation. A cross-cutting aspect was not assigned to this finding because the performance deficiency occurred in 1984, and therefore, is not indicative of current licensee performance (Section 4OA3).
05000298/FIN-2016002-0130 June 2016 23:59:59CooperNRC identifiedFailure 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-2016002-0230 June 2016 23:59:59CooperNRC identifiedFailure 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)
05000298/FIN-2016001-0231 March 2016 23:59:59CooperNRC identifiedFailure to Assess Operability of Technical Specification System Functions during Surveillance TestingThe 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).
05000298/FIN-2016001-0131 March 2016 23:59:59CooperNRC identifiedFailure to Follow ASME Code Requirements when taking Corrective Actions for a Pump in the Required Action RangeThe inspectors identified a non-cited violation of 10 CFR 50.55a, Codes and Standards, for the licensees failure to follow the ASME Code for Operation and Maintenance of Nuclear Power Plants when addressing the performance of reactor equipment cooling pump A within the high required action range of the inservice testing program. Specifically, on February 11, 2016, the licensee failed to follow ASME Subsection ISTB 6200(b) when engineering personnel, taking corrective action to address pump performance, failed to either correct the cause of the deviation or establish new reference values for the pump. Instead of establishing new reference values, the licensee performed an analysis to administratively raise the upper required action range limit, creating a wider range of acceptable pump operation than allowed by Table ISTB-5100-1, Centrifugal Pump Test Acceptance Criteria. The licensee entered this issue into the corrective action program as Condition Report CR-CNS-2016-00920, took action to reevaluate and rebaseline the pump with new reference values, and performed an extent of condition review to determine if other equipment was impacted by similar interpretations of the code. The licensees failure to establish new reference values for reactor equipment cooling pump A in accordance with the ASME Code was a performance deficiency. The performance deficiency was determined to be 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 actions initially taken by the licensee would have required a relief request; could have delayed identification of a degrading pump trend due to the creation of a wider range of acceptable operation; and the licensees generic interpretation, that the Table ISTB-5100-1 acceptable range could be administratively expanded, represented a programmatic vulnerability. The inspectors used Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, and determined that the finding had very low safety significance (Green) because it did not represent a design or qualification deficiency, did not represent a loss of safety function for a single train for greater than its technical specification allowed outage time, and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. This finding had a cross-cutting aspect in the area of problem identification and resolution associated with evaluation. Specifically, the licensee failed to thoroughly evaluate performance of reactor equipment cooling pump A in the required action range to ensure that the resolution correctly addressed the causes of the degraded performance (P.2).
05000298/FIN-2015004-0131 December 2015 23:59:59CooperNRC identifiedDiesel Fuel Oil Cloud Point Acceptance Criteria not in accordance with ASTM D975, Revision 1989aThe inspectors identified a non-cited violation of Technical Specification 5.5.9, Diesel Fuel Oil Testing Program, for the licensees failure to establish an emergency diesel generator fuel oil cloud point acceptance criterion in accordance with ASTM D975, Standard Specification for Diesel Fuel Oils. Specifically, the diesel fuel oil cloud point acceptance criterion of = 32F specified in the licensees diesel fuel oil testing program procedures was not in accordance with the ASTM limit of = 3.2F and was not technically justified as described by the standard. Corrective actions included development of an evaluation which concluded that the appropriate acceptance criterion was = 15F based on the most limiting day tank room temperatures during accident conditions; verification that the cloud point of the fuel onsite at the time was 8.6F, which met this criterion; and establishment of compensatory measures to monitor and administratively control the cloud point until fuel oil program procedures could be revised. The licensee entered this deficiency into the corrective action program as Condition Reports CR-CNS-2015-06745, CR-CNS-2015-06717, CR-CNS-2015-06718, and CR-CNS-2015-7150. The licensees failure to establish a diesel fuel cloud point acceptance criterion in accordance with ASTM D975, in violation of Technical Specification 5.5.9, was a performance deficiency. The performance deficiency was determined to be more than minor, and therefore a finding, because it was associated with the procedure quality attribute of the Mitigating Systems Cornerstone, and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, failure to establish a diesel fuel cloud point acceptance criterion in accordance with ASTM D975 could result in formation of wax crystals affecting the capability to transfer the fuel oil from the storage tanks to the emergency diesel generator engine cylinders. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process for Finding 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 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; and (4) did 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. The finding had a cross-cutting aspect in the area of human performance associated with documentation because the licensee failed to create and maintain complete, accurate, and up-to-date documentation for the worst case temperature at which the emergency diesel generator fuel oil would be stored (H.7).
05000298/FIN-2015004-0231 December 2015 23:59:59CooperNRC identifiedFailure to Update the Updated Safety Analysis ReportThe inspectors identified two examples of a non-cited violation of 10 CFR 50.71(e), Maintenance of Records, Making Reports, for the licensees failure to update the Updated Safety Analysis Report for the reactor equipment cooling system and fire protection program to ensure that the report contained the latest information. Specifically, licensing personnel failed to update the Updated Safety Analysis Report when implementing License Amendment 232, in May 2009, for changes associated with the reactor equipment cooling system and again in April 2015, when the licensee implemented License Amendment 248 for the fire protection program transition to meet the requirements of NFPA-805. The licensee initiated corrective actions to update the affected sections, and initiated an extent of condition evaluation to identify other similar portions of the Updated Safety Analysis Report that may not have been updated. The licensee entered these deficiencies into the corrective action program as Condition Reports CR-CNS-2015-05948, CR-CNS-2015-06240, and CR-CNS-2015-06483. The licensees failure to update the Updated Safety Analysis Report for the reactor equipment cooling system and fire protection program to ensure that the information included within the report contained the latest information developed in accordance with 10 CFR 50.71(e) was a performance deficiency. This performance deficiency was screened using Inspection Manual Chapter 0612, Appendix B, Issue Screening, dated September 7, 2012, and was determined to be minor in the Reactor Oversight Process, and therefore, it was not evaluated as a finding using the significance determination process. In accordance with the NRC Enforcement Policy, the performance deficiency was evaluated using the traditional enforcement process because it had the potential for impacting the NRCs ability to perform its regulatory function. Under the traditional enforcement process, this performance deficiency was determined to be more than minor and a Severity Level IV violation because it was consistent with the example in Paragraph 6.1.d.3 of the NRC Enforcement Policy, dated February 4, 2015. Specifically, the licensee failed to update the Updated Safety Analysis Report as required by 10 CFR 50.71(e), but the lack of up-to-date information has not resulted in any unacceptable change to the facility or procedures. No cross-cutting aspect was assigned to this violation because there was no Reactor Oversight Process finding associated with the performance deficiency.
05000298/FIN-2015004-0331 December 2015 23:59:59CooperNRC identifiedFailure to Perform a Complete Evaluation of the Licensee Interface With Offsite OrganizationsThe inspectors identified a non-cited violation of 10 CFR 50.54(t)(2), for the licensees failure to include an evaluation of the adequacy of the interfaces with state and local governments in a review of emergency preparedness program elements in Audit 2014-06, dated November 7, 2014. Specifically, the licensee failed to include an evaluation of this interface when audit personnel did not provide offsite officials with an opportunity to provide their view of the adequacy of the interface to the audit team. Corrective actions included development of lessons learned for future audits and reengagement with state and local governments to assure adequate interface existed during the most recent emergency preparedness audits. The licensee entered this deficiency into the corrective action program as Condition Report CR-CNS-2015-06403. The failure to perform an evaluation for adequacy of the interface with state and local governments was a performance deficiency. The performance deficiency was determined to be more than minor, and therefore a finding, because it was associated with the offsite emergency preparedness attribute of the Emergency Preparedness Cornerstone, and affected the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, the ability to implement adequate measures to protect the health and safety of the public could be affected if communication and coordination problems between the licensee and offsite agencies are not detected and corrected. The finding was evaluated using Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, dated September 22, 2015, and was determined to have very low safety significance (Green) because it was a failure to comply with NRC requirements, was not a loss of planning standard function, and was not a degraded planning standard function. The finding had a cross-cutting aspect in the area of problem identification and resolution associated with evaluation because the licensee failed to thoroughly evaluate issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance. Specifically, the audit team failed to fully evaluate the potential for problems to exist with the adequacy of the interface with state and local governments (P.2).
05000298/FIN-2015003-0730 September 2015 23:59:59CooperLicensee-identifiedLicensee-Identified ViolationTechnical Specification 3.3.6.1, Primary Containment Isolation Instrumentation, Action A.1, requires that inoperable high main steam line flow isolation channel(s) be placed in trip in 12 hours. Contrary to the above, from November 21, 2014, to February 19, 2015, the licensee failed to place three inoperable Division II high main steam line flow isolation channels in trip within 12 hours, because the licensee failed to properly implement the requirements of TSTF-493, Clarify Application of Setpoint Methodology for Limiting Safety System Settings, for main steam differential pressure indicating switches. The licensee recalibrated the main steam differential pressure indicating switches in question and re-stored the setpoints to the pre TSTF-493 values. The performance deficiency was more than minor, and therefore a finding, because it was associated with the design control attribute of the Barrier Integrity Cornerstone, and affected the associated cornerstone objective to ensure the containment functionality was maintained. 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 screened as having very low safety significance (Green) because it did not represent an actual: (1) open pathway in the physical integrity of reactor containment (valves, airlocks, etc.) containment isolation system (logic and instrumentation), and heat removal components; and (2) reduction in function of hydrogen igniters in the reactor containment. The license entered this deficiency into the corrective action program as Condition Report CR-CNS-2015-03315.
05000298/FIN-2015003-0130 September 2015 23:59:59CooperNRC identifiedFailure to Ensure Turbine Building Design Calculation was Correct and JustifiedThe inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion III, Design Control, which states, in part, Measures shall be established to assure that applicable regulatory requirements and the design basis, as defined in 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions. Specifically, prior to September 29, 2015, the licensee prepared Calculation NEDC 13-028, Ultimate Internal Pressure of Turbine Building Blowout Panels and Metal Wall System, Revision 1, in accordance with Engineering Procedure 3.4.7, to ensure pressure relief in the turbine building due to a main steam line break would occur at less than or equal to 0.5 pounds per square inch differential pressure as stated in Amendment 25 to the Cooper Nuclear Station Final Safety Analysis Report. However, the inspectors determined that the methodology and assumptions employed in Calculation NEDC 13-028 were not adequate and could not conclude that it ensured siding failure as required. In response to this issue, the licensee performed an operability determination to ensure that safety-related structures, systems, and components and the control room were not adversely affected by a main steam line break. The licensee entered this deficiency into the corrective action program as Condition Report CR-CNS-2015-05705. The licensees failure to ensure that a turbine building design calculation was correct and justified was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the design control 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, Calculation NEDC 13-028 did not ensure that safety-related structures, systems, and components and the control room, which are necessary for responding to initiating events, would not be adversely affected by a main steam line break in the turbine building. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, Mitigating Systems Screening Question, dated June 19, 2012, inspectors determined that the finding was of very low safety significance (Green) because it: (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 their technical specification allowed outage time; and (4) did 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. This finding had a crosscutting aspect in the area of human performance associated with conservative bias because individuals failed to use decision making practices that emphasize prudent choices over those that are simply allowed. (H.14).