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The inspectors documented a self-revealingThe inspectors documented a self-revealing non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, for the failure to provide an appropriate maintenance tagout. Specifically, maintenance tagout LPSI-013-A-2SI-14C for maintenance on the Unit 2 low pressure safety injection header C incorrectly specified that the reactor coolant system level should be less than 70 inches to work on the low pressure safety injection header components which resulted in a loss of reactor coolant system inventory. The licensee has entered this issue into the corrective action program as Condition Report CR-ANO-2-2012-2645. The failure to provide an appropriate tagout for maintenance on the low pressure safety injection header was a performance deficiency. Specifically, the reactor coolant system level should have been lowered to less than 65 inches rather than less than 70 inches, as stated in the tagout, to prevent the loss of reactor coolant inventory. The performance deficiency is more than minor because it is associated with the configuration control attribute of the Initiating Events Cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during power operations, and is therefore a finding. Using Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, and Appendix G, Shutdown Operation, Attachments 1 and 2, it was determined that because this finding increased the likelihood of a loss of RCS inventory, especially during reduced inventory condition, a Phase 2 analysis was required. The senior reactor analyst determined the finding to have very low safety significance (Green) because even without operator action residual heat removal would not have been lost and there were no other complicating issues. The finding has a cross-cutting aspect in the area of human performance, associated with the resources component, in that the licensee failed to ensure that personnel equipment, procedures, and other resources are available and adequate to assure nuclear safety. Specifically, station Procedure OP-2103.011, Draining the Reactor Coolant System, Revision 48, was not up to date and accurate for determining the appropriate reactor vessel level for the development of the maintenance tagout.the development of the maintenance tagout.  
23:59:59, 31 December 2012  +
05000313  +  and 05000368  +
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19:04:18, 30 September 2017  +
23:59:59, 31 December 2012  +
Failure to Provide an Accurate Maintenance Tagout Results in Loss of Reactor Coolant System Inventory  +