A
Severity Level IV noncited violation of
Technical Specification 3.3.11 was identified for the failure to include the resistance temperature detectors in the channel calibration for the
shutdown cooling heat exchanger temperature instruments. Specifically, prior to the implementation of Improved Technical Specifications, the licensee did not perform testing of the resistance temperature detectors. Following the implementation of Improved Technical Specifications, the licensee did not perform an in-place qualitative assessment of the resistance temperature detectors' behavior. This issue was entered into the corrective action program as CRDR 280178
The failure to perform a complete
shutdown cooling heat exchanger temperature loop channel calibration is determined to have greater than minor significance because the licensee's failure to report the condition impacted the NRC's ability to perform it's regulatory function. Therefore, this finding was considered applicable to traditional enforcement. Although the
significance determination process is not designed to assess the significance of violations that potentially impact or impede the regulatory process, the finding can be assessed using the
significance determination process. Using the Phase 1 worksheet in Manual Chapter 0609, "
Significance Determination Process," this finding is determined to be of very low safety significance because it only affected the mitigating system cornerstone and the resistance temperature detectors were found to be within calibration.
