05000382/FIN-2013003-03

Finding

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.

03
Site:	Waterford
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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v • d • e

Finding - Waterford - IR 05000382/2013003

0(0)1(0)2(3)3(5)4(4)5(3)6(0)7(1)8(1)403(0)404(2)406(0)501(0)502(0)

IR 05000382/2013003: 1 2 3 4 5

Finding List (Waterford) @ 2013Q2

CCA Matrix: 2013Q2

	Q	CCA	Title
05000382/FIN-2012403-04	2012Q3	H.9	Security
05000382/FIN-2012403-03	2012Q3	H.10	Security
05000382/FIN-2012403-02	2012Q3	H.14	Security
05000382/FIN-2012403-01	2012Q3		Security
05000382/FIN-2012008-05	2012Q3	H.8	Failure to Develop Effective Corrective Actions to Preclude Repetition
05000382/FIN-2012008-04	2012Q3	H.8	Failue to Ensure Operator Knowledge of Equipment Status
05000382/FIN-2012008-03	2012Q3	H.6	Failure to Take Timely Corrective Action to Establish a Basis for Flood Control Measures
05000382/FIN-2012008-02	2012Q3	H.6	Failure to Take Corrective Action Associated with Emergency Feedwater Pump AB
05000382/FIN-2012008-01	2012Q3	P.5	Failure to Promptly Determine the Operability of the Emergency Diesel Generators
05000382/FIN-2012004-01	2012Q3	P.5	Failure to Establish Procedural Controls to Ensure That Licensed Operators Could Perform Immediate and Time Critical Operator Actions Associated with Security and Fire Events
05000382/FIN-2012004-02	2012Q3	P.2	Failure to Identify and Correct Degraded Conditions Associated with the Auxiliary Component Cooling Water Heat Exchanger Outlet Temperature Control Valve
05000382/FIN-2012004-03	2012Q3	P.2	Failure to Identify and Correct a Torn Diaphragm of a SAFETY-RELATED Air Operated Valve Associated with the Emergency Feedwater System
05000382/FIN-2012004-04	2012Q3	H.13	Failure to Adequately Access and Manage Risk Before Performing Maintenance Activities Associated with NON-STANDARD Lifts
05000382/FIN-2012005-03	2012Q4		Reactor Auxiliary Building Roof Flood Protection Issue
05000382/FIN-2012005-02	2012Q4	P.2	Failure to Promptly Identify and Correct the Cause of Repetitive Failures Associated with Train a Component Cooling Water Radiation Monitor
05000382/FIN-2012005-01	2012Q4	H.5	Failure to Implement Control Measures to Ensure That Activated Materials Were Not Raised Above or Brought Near the Surface of the Refueling Pool, Causing a Locked High Radiation Area
05000382/FIN-2013002-03	2013Q1	P.2	Failure to Identify and Perform Testing to Demonstrate Local Manual Operation Action on SAFETY-RELATED AIR-OPERATED Valves
05000382/FIN-2013002-02	2013Q1	H.14	Failure to Perform an Adequate Operability Determination for Nitrogen Leak in MSIV
05000382/FIN-2013002-01	2013Q1	H.7	Failure to Identify and Control Potential Tornado Borne Missle Hazards
05000382/FIN-2012404-02	2013Q1	H.14	Security
05000382/FIN-2012404-01	2013Q1	H.7	Security
05000382/FIN-2013003-05	2013Q2	P.5	Failure to provide adequate post modification testing instructions for vibration monitoring on the feedwater piping system
05000382/FIN-2013003-04	2013Q2		Failure to submit an LER after discovery that manual handwheels on AOVs were not functional
05000382/FIN-2013003-03	2013Q2	H.13	Failure to comply with Action 4 of TS 3.3.1 during shutdown in Modes 4 and 5
05000382/FIN-2013003-02	2013Q2		Failure to Update Fuel Handling Accident Analysis in the Updated Final Safety Analysis Report
05000382/FIN-2013003-01	2013Q2	P.1	Failure to provide design control measures to withstand the effects of flooding on the reactor auxiliary building roof

Self-Identified List (Waterford)

	Q	Title
05000382/FIN-2012008-06	2012Q3	Licensee-Identified Violation
05000382/FIN-2012005-04	2012Q4	Licensee-Identified Violation
05000382/FIN-2012005-05	2012Q4	Licensee-Identified Violation

[Waterford Findings full list]

05000382/FIN-2013003-03

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