Junk Plant Cooper: Six "Slap On The Wrist" Violations Associated with Procedures

The magnitude of it is eye popping. It is a Entergy managed plant. The Risk Perspectives based violation is just not big enough to change behavior at Cooper or any other plant is the USA.

I mean, does the NRC broadly keep a tract of procedure related problems? If it continues to go up, it means the ROP is ineffective...

 May 1, 2017

SUBJECT: COOPER NUCLEAR STATION – NRCINTEGRATED INSPECTION REPORT 05000298/2017001

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Green. The inspectors reviewed a self-revealed, non-cited violation of Technical Specification 5.4.1.a, for the licensee’s 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 licensee’s 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.

Green. The inspectors identified a non-cited violation of Technical Specification 5.4.1.a for the licensee’s 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 critical loop 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 Report CR-CNS-2017-01403.

• Green. The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, “Instructions, Procedures, and Drawings,” associated with the licensee’s 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.

Green. The inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, “Instructions, Procedures, and Drawings,” associated with the licensee’s 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 pump’s 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 licensee’s 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.

Green. The inspectors identified a non-cited violation of 10 CFR 50.55a(g)(4) for the licensee’s 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.

Green. The inspectors reviewed a self-revealed, non-cited violation of Technical Specification 3.0.4 for the licensee’s 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.