05000458/FIN-2015009-03
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Finding | |
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| Title | Failure to Provide Adequate Procedures for Post-scram Recovery |
| Description | The team reviewed a self-revealing, non-cited violation of Technical Specification 5.4.1.a for the licensees failure to establish, implement and maintain a procedure required by Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Specifically, Procedure OSP-0053, Emergency and Transient Response Support Procedure, Revision 22, which is required by Regulatory Guide 1.33, inappropriately directed operations personnel to establish feedwater flow to the reactor pressure vessel using the startup feedwater regulating valve as part of the post-scram actions. The startup feedwater regulating valve operator characteristics are non-linear and not designed to operate in the dynamic conditions immediately following a reactor scram. To correct the inadequate procedure, the licensee implemented a change to direct operations personnel to utilize one of the main feedwater regulating valves until the plant is stabilized. This issue was entered in the licensees corrective action program as Condition Report CR-RBS-2015-00657. This performance deficiency is more than minor, and therefore a finding, because it is associated with the procedure quality attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the procedure directed operations personnel to isolate the main feedwater regulating valves and control reactor pressure vessel level using the startup feedwater regulating valve, whose operator was not designed to function in the dynamic conditions associated with a post-scram event from high power, and this challenged the capability of the system. The team performed an initial screening of the finding in accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, the team determined that the finding is of very low safety significance (Green) because it: (1) was not a deficiency affecting the design or qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time; and (4) did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program. This finding has an evaluation cross-cutting aspect within the problem identification and resolution area because the licensee failed to thoroughly evaluate this issue to ensure that the resolution addressed the cause commensurate with its safety significance. Specifically, the licensee failed to properly evaluate the design characteristics of the startup feedwater regulating valve operator before implementing the procedure to use the valve for post-scram recovery actions [P.2]. |
| Site: | River Bend  |
|---|---|
| Report | IR 05000458/2015009 Section 4OA5 |
| Date counted | Jun 30, 2015 (2015Q2) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | Self-revealing |
| Inspection Procedure: | IP 93812 |
| Inspectors (proximate) | D Bradley J Drake T Hartman T Pruett |
| Violation of: | Technical Specification |
| CCA | P.2, Evaluation |
| INPO aspect | PI.2 |
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Finding - River Bend - IR 05000458/2015009 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (River Bend) @ 2015Q2
Self-Identified List (River Bend)
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