05000331/FIN-2009002-03
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Finding | |
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| Title | Failure to Perform required actions for existing LCO conditions during in-vessel fuel movements |
| Description | A finding of very low safety significance and associated NCV of Technical Specifications (TSs) was identified by the inspectors for the operators failing to perform required actions for existing limiting condition for operation (LCO) conditions, involving TS equipment declared inoperable, during in-vessel fuel movements. The inspectors determined that the failure to perform TS LCO required actions during in-vessel fuel movement was contrary to Refueling Operations TS required actions and therefore was a performance deficiency. The licensee entered this issue into their corrective action program as CAP 064489. The core alterations were suspended to comply with the TSs until the issue was resolved. Actions were taken to ensure that the control rods with the inoperable rod position indicators were fully inserted and to electrically disarm the control rod drives. Once the required actions were completed, the fuel shuffle was recommenced. The performance deficiency was determined to be more than minor because the finding was associated with the Mitigating Systems Cornerstone attribute of human performance 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, when changes to in-plant conditions affect previously performed required actions for equipment declared inoperable, the failure to perform the TS LCO required actions for the new plant conditions could lead to a more significant safety concern by unknowingly exceeding allowed outage times established for specific LCOs. This human error could, in turn, challenge mitigating systems availability, reliability, and capability to respond to initiating events. The inspectors determined that this finding only degraded the reactivity control function of the Mitigating Systems Cornerstone and only affected the safety of a reactor during refueling operations after the entry conditions had been met and shutdown cooling had been initiated. Using IMC 0609, Appendix G, Shutdown Operations SDP, and Checklist 7, BWR Refueling Operation with RCS Level > 23, contained in Attachment 1, the inspectors determined that the finding did not require a quantitative assessment. Using Figure 1, this finding screened as very low safety significance (Green). The inspectors also determined that this finding has a cross-cutting aspect in the area of Human Performance, Decision Making, because the licensee did not adopt a requirement to demonstrate that the proposed action was safe in order to proceed rather than a requirement to demonstrate that it is unsafe in order to disapprove the action. Specifically, the requirements of RFP-403 and IPOI-8 to verify readiness to commence in-vessel fuel movements did not adequately provide for a review of inoperable TS equipment completed LCO actions to ensure core alteration TSs for reactivity control were met during the fuel movements H.1(b) |
| Site: | Duane Arnold  |
|---|---|
| Report | IR 05000331/2009002 Section 1R15 |
| Date counted | Mar 31, 2009 (2009Q1) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.15 |
| Inspectors (proximate) | M Holmberg K Riemer R Orlikowski R Baker J Neurauter T Go A Scarbeary |
| CCA | H.14, Conservative Bias |
| INPO aspect | DM.2 |
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Finding - Duane Arnold - IR 05000331/2009002 | ||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Duane Arnold) @ 2009Q1
Self-Identified List (Duane Arnold)
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