The following violation of very low safety significance (Green) was identified by the licensee and was a violation of NRC requirements which met the criteria of the
NRC Enforcement Policy for being dispositioned as a Non-Cited Violation: • Improved
Technical Specification 5.6.1.1a requires that written procedures recommended in
Regulatory Guide (RG) 1.33, Revision 2, Appendix A, be established, implemented, and maintained.
RG 1.33, Appendix A, includes general operating procedures for Refueling &
Core Alterations in the list of recommended procedures. Plant Operating Manual
FP-601A, Operation of the Main Fuel Handling Bridge FHCR-1, Section 3.2.22, requires, in part, that a refueling
SRO be stationed during a core alteration. Contrary to this requirement, the licensee secured the refueling
SRO during activities determined to be a core alteration for approximately seven-hours on May 24, 2011. The licensee entered this issue into their
CAP as CR 467392. The significance of the finding was determined using Manual Chapter 0609,
Significance Determination Process, Appendix G, Checklist 4 (
PWR Refueling Operation,
RCS level > 23 ft) and determined to be of very low safety significance (Green), because it did not cause the loss of mitigating capability of core heat removal, inventory control, power availability, containment control, or reactivity control. Additional information regarding this
NCV is discussed in Section 4OA2 of this inspection report.