A self-revealing non-cited violation (
NCV) of
Technical Specification (TS) 5.4.1 was identified for failure to adequately implement the procedure to stroke reactor building spray (
RBS) valves, which resulted in a loss of
Reactor Coolant System (
RCS) inventory while in Mode 5. The inspectors determined that the loss of
RCS inventory while in Mode 5 was a performance deficiency. The finding was considered to be more than minor because it affected the Configuration Control attribute of the Reactor Safety/Initiating Events Cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown, as well as power operations. The finding was determined to be of very low safety significance. This was based initially on a determination that the event did not meet the loss of control criteria in
MC 0609, Appendix G, and also on the Phase 1 screening criteria found in Manual Chapter (MC) 0609, Appendix G, Shutdown Operations
Significance Determination Process, Attachment 1, Checklist 2. This finding has a cross-cutting aspect of appropriate coordination of work activities
H.3.b], including incorporating actions to address interdepartmental coordination, the need to keep personnel apprised of work status, the operations impact of work activities, and plant conditions that may affect work activities, as described in the work control component of the human performance cross-cutting area. (Section 1R22
