Technical Specification 3.6.5.1,
Secondary Containment Integrity requires, in part, that
secondary containment be
operable during
OPDRV activities in OPCON*. The action statement with
secondary containment inoperable in OPCON* is to suspend operations with a potential to drain the reactor vessel. Contrary to the above, from 9:30 a.m. until 5:31 p.m. on October 31, 2013, Hope Creek did not comply with this TS action statement or the
EGM 11-003 Revision 1 guidance, and
secondary containment should have been
operable. The failure to comply with this guidance resulted in a condition prohibited by TSs until the condition was corrected by restoring the automatic isolation function of the drain-down path, complying with both the
EGM guidance and TSs at 5:31 p.m. on October 31, 2013.
PSEG entered this issue into the
CAP as notification 20631218. The inspectors determined that the finding was of very low safety significance (Green) in accordance with NRC
IMC 0609, Appendix G, Shutdown Operations
Significance Determination Process, because the finding did not represent a finding that required quantitative assessment.