05000348/FIN-2013003-01
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Finding | |
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Title | Failure to Properly Maintain Procedures to Ensure Reactor Vessel Head Vent Path was Preserved |
Description | A self-revealing non-cited violation (NCV) of Technical Specification (TS) 5.4.1, Procedures, was identified for the licensees failure to establish procedures recommended in Regulatory Guide (RG) 1.33. Specifically, the licensee did not properly establish written procedures for maintaining a vent path of the unit 2 reactor vessel head. As a result of not maintaining a vent path during a refueling outage, the indicated reactor coolant system level did not match actual level and operator action was required to restore level to 128 feet, 6 inches. The licensee wrote condition report (CR) 632668 to document the event. The failure to establish procedures to ensure an open vent path of the reactor vessel head when required was a performance deficiency. This performance deficiency was more than minor because it was associated with the procedural quality attribute of the initiating events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown operations. The procedure quality attribute of the initiating event (IE) cornerstone was determined to be adversely affected because procedure FNP-2-SOP- 1.11, Reactor Coolant System Filling and Venting Dynamic Method, did not provide instructions to establish a reactor vessel vent path as required by procedure FNP-2- UOP-4.1, Controlling Procedure for Refueling. This resulted in an unplanned RCS level decrease to 127 feet, 6 inches when the licensee was controlling level at 128 feet, 6 inches. The significance of this finding was screened using IMC 0609, Appendix G, Shutdown Operations Significance Determination Process and IMC 0609, Appendix G, Attachment 1: Phase 1 Operational Checklists for both PWRs and BWRs. The finding screened as Green, because it did not require a quantitative assessment per checklist 3 of the attachment and it did not represent an inadvertent loss of two feet of RCS inventory when not in midloop as described in Table 1 of Appendix G. The finding was related to the cross-cutting aspect of human error prevention techniques (pre-job briefings) in the work practices component of the human performance area because the licensee failed to discuss the expected configuration of the reactor vessel head vent path to ensure a vent path was properly established as required. |
Site: | Farley |
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Report | IR 05000348/2013003 Section 1R20 |
Date counted | Jun 30, 2013 (2013Q2) |
Type: | NCV: Green |
cornerstone | Initiating Events |
Identified by: | Self-revealing |
Inspection Procedure: | IP 71111.2 |
Inspectors (proximate) | F Ehrhardt W Loo M Coursey P Niebaum B Collins T Lighty J Sowa W Pursley A Butcavage |
Violation of: | Technical Specification - Procedures Technical Specification |
CCA | H.12, Avoid Complacency |
INPO aspect | QA.4 |
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Finding - Farley - IR 05000348/2013003 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Farley) @ 2013Q2
Self-Identified List (Farley)
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