A self-revealing Green non-cited violation (
NCV) of
10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified for the licensees failure to follow EGR-NGGC-0005, Engineering Change, during a modification of the
reactor protection system (
RPS). This resulted in having inadequate work instructions associated with
engineering change (EC) 75690 and
EC 86690, which resulted in a cross-tied configuration of independent trains of the
RPS and the
DC electrical system. The licensee entered this into the corrective action program (
CAP) as action request (
AR) 729926 and took immediate corrective actions to cut the cable and restore the independence of safety trains for both systems. The failure to have adequate work instructions for engineering changes as required by procedure EGR-NGGC-0005 was a performance deficiency. This finding is more than minor because it is 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 (i.e., core damage). Specifically, the cross-tied configuration rendered the
RPS and
DC electrical subsystem
inoperable because the required independence and redundancy of systems were eliminated. The finding was screened using
IMC 0609 Appendix A Exhibit 2.C, Reactivity Control Systems, dated June 19, 2012, and was determined to be of very low safety significance (Green) because the finding did not result in a mismanagement of reactivity by the operators. The performance deficiency had a cross-cutting aspect of teamwork in the area of human performance because the licensee failed to coordinate their activities between the work control planners and engineering to ensure nuclear safety was maintained.
