05000461/FIN-2015003-04
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Finding | |
|---|---|
| Title | Failure to enter appropriate TS action statement for inoperable radiation monitors during OPDRV activities |
| Description | The inspectors identified a finding, and an associated NCV of TS 3.3.6.1, Primary Containment and Drywell Isolation Instrumentation, and TS 3.3.6.2, Secondary Containment Isolation Instrumentation, due to the failure to enter the appropriate TS action statement and take the required actions when the containment radiation monitoring instrumentation was inoperable during operations with the potential to drain the reactor vessel (OPDRVs). Specifically, with the containment ventilation dampers closed, the containment radiation monitoring instrumentation was unable to perform its safety function of sending a containment isolation signal to various equipment if elevated containment radiation levels occurred during OPDRVs. The licensee documented the issue in the CAP as AR 02566708. The inspectors identified this issue after the maintenance on the containment ventilation system and the OPDRVs were completed. Therefore, the TS non-compliance was no longer in effect. The inspectors determined that the failure to enter TS 3.3.6.1 and TS 3.3.6.2 when the containment radiation monitoring instrumentation was not able to perform its safety function during an OPDRV was a performance deficiency. The performance deficiency was more than minor because it was associated with the systems, structures and components and barrier performance attributes of the Barrier Integrity cornerstone, and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events, and is therefore a finding. Based on a detailed risk evaluation, the finding screened as very low safety significance because the reactor water level was confirmed to be greater than the minimum level required for movement of irradiated fuel assemblies (i.e., greater than 228 above the flange) during all OPDRV time windows. This finding had a cross-cutting aspect of conservative bias in the area of human performance because the licensee relied solely on the successful completion of the surveillance requirements to determine the radiation monitor instrumentation was operable rather than considering the impact the closed dampers would have on their ability to fulfill their safety function. [H.14] |
| Site: | Clinton  |
|---|---|
| Report | IR 05000461/2015003 Section 4OA3 |
| Date counted | Sep 30, 2015 (2015Q3) |
| Type: | NCV: Green |
| cornerstone | Barrier Integrity |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71153 |
| Inspectors (proximate) | A Shaikh C Phillips E Sanchez-Santiago J Bozga M Jones P Louden S Mischke W Schaup |
| Violation of: | Technical Specification |
| CCA | H.14, Conservative Bias |
| INPO aspect | DM.2 |
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Finding - Clinton - IR 05000461/2015003 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Clinton) @ 2015Q3
Self-Identified List (Clinton)
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