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The inspectors identified a Green NCV of T … The inspectors identified a Green NCV of TS 6.8.1, Procedures, for Dominions failure to maintain an adequate procedure for reactor filling and draining that incorporates guidance contained in NRC Generic Letter 88-17. Specifically, OP2301E, Draining the RCS, permitted operation in a reduced RCS inventory condition without ensuring redundant means of level indication contrary to the inventory control requirements of OU-M2-201, Shutdown Safety Assessment Checklist. The failure to maintain an adequate procedure for operating in reduced inventory conditions is a performance deficiency. The inspectors determined this performance deficiency is more than minor because it is associated with the Initiating Events cornerstone attribute of equipment performance and affects the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown operations. Specifically, inadequate procedural guidance increased the likelihood that operators could experience a loss of level indication during the reduced inventory condition. The inspectors evaluated the significance of the finding using IMC 0609 Appendix G, Shutdown Operations Significance Determination Process, Attachment 1, Shutdown Operations Significance Determination Process Phase 1 Initial Screening and Characterization of Findings, and the issue screened to a Phase 2 analysis. Using the guidance contained in IMC 0609, Appendix G, Attachment 2, Phase 2 Significance Determination Process Template for PWR During Shutdown, the inspectors worked with regional and headquarters senior reactor analysts to determine the issue screened to Green. The inspectors determined this issue had a cross-cutting aspect in the area of Human Performance, Avoid Complacency, where individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Specifically, the latent error of considering L-112 and LI-112 as independent level instruments even though a single failure impacted both instruments contributed to the issue.both instruments contributed to the issue.

Discovered date

23:59:59, 30 June 2014 +

Docket

05000336 +

Event date

23:59:59, 30 June 2014 +

Finding integer

1 +

Finding type

Non-cited violation +

Generic letter

NRC Generic Letter 88-17, Loss of Decay Heat Removal +

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INPO aspect

QA.4 +

Identified by

NRC identified +

Inspection Manual Chapter

NRC Inspection Manual 0609, Appendix G + and NRC Inspection Manual 0609 Appendix G +

Inspection procedure

IP 71111.02 +

Inspection report

IR 05000336/2014003 +

L

L-112 +

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12:58:08, 25 September 2017 +