05000382/FIN-2013003-03
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Finding | |
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Title | Failure to comply with Action 4 of TS 3.3.1 during shutdown in Modes 4 and 5 |
Description | The inspectors identified a non-cited violation of Waterford Steam Electric Station, Unit 3, Technical Specification (TS) Limiting Condition of Operation (LCO) 3.3.1 because the licensee did not take action to suspend operations that involved reactivity changes to accomplish startup activities with only one excore nuclear instrumentation (ENI) logarithmic (log) channel operable. Specifically, the licensee did not take action to suspend operations involving diluted water additions to the volume control tank and temperature increases with a positive moderator temperature coefficient (MTC) without the required number of operable log channels. As a result, the licensee did not comply with Action 4 of TS LCO 3.3.1 because they did not suspend all operations involving positive reactivity changes with the exception of minimum reactivity additions due to temperature fluctuations or operations, which are necessary to maintain fluid inventory. The licensee entered this issue into their corrective action program as CR-WF3-2013-2166 and CR-WF3- 2013-3182. The immediate corrective actions taken to restore compliance included the discontinued use of water additions to the volume control tank and the increase of RCS temperatures with a positive MTC until the licensees personnel returned an additional log channel to service. The failure to comply with TS LCO 3.3.1, Action 4, was a performance deficiency. The performance deficiency was more than minor because it was associated with the configuration control attribute of the Barrier Integrity cornerstone and affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the LCO for the log power channels ensures that adequate information is available to verify core reactivity conditions while shutdown to minimize the probability of the occurrence of postulated events. The inspectors used Checklist 4 contained in Attachment 1 of the NRC Inspection Manual Chapter 0609, Appendix G, Shutdown Operations Significance Determination Process Phase 1 Operational Checklists, to evaluate this finding. The inspectors determined that the finding did not meet the reactivity guidelines because the licensee did not comply with TS LCO 3.3.1, Action 4. The inspectors determined that the finding was of very low safety significance (Green) because it did not require a quantitative assessment and was not similar to any of the examples requiring a phase two or phase three analyses. The inspectors also determined that the licensee maintain the required shutdown margin to preclude inadvertent criticality in the shutdown condition. The inspectors concluded that the finding reflected current licensee performance and involved a cross-cutting aspect in the decision-making component of the human performance area in that the licensee did not make a safety-significant decision using a systematic process, especially when faced with uncertain or unexpected plant conditions, to ensure safety was maintained. This included obtaining interdisciplinary input and reviews on safety-significant decisions. |
Site: | Waterford ![]() |
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Report | IR 05000382/2013003 Section 1R20 |
Date counted | Jun 30, 2013 (2013Q2) |
Type: | NCV: Green |
cornerstone | Barrier Integrity |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.2 |
Inspectors (proximate) | M Davis G George D Allen R Azua M Baquera N Okonkwo M Williams D Bradley |
Violation of: | Technical Specification |
CCA | H.13, Consistent Process |
INPO aspect | DM.1 |
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Finding - Waterford - IR 05000382/2013003 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Waterford) @ 2013Q2
Self-Identified List (Waterford)
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