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A self-revealing non-cited violation, with … A self-revealing non-cited violation, with two examples, of Technical Specification 5.4.1.a, Procedures, was identified for the failure to follow the reactivity management procedures. On two occasions, operators failed to take prudent actions to ensure that reactor power did not exceed the licensed limit of 3565 megawatts thermal while performing activities known to cause power increases. On February 17, 2014, while performing chemical and volume control system inservice check valve testing on the discharge check valve of the train A centrifugal charging pump, operators performed a dilution of the reactor coolant system for normal power maintenance while reactivity was also being affected by the testing of the charging pump check valve, resulting in exceeding 100 percent power. On March 6, 2014, while returning the reactor to full power following data collection on the main turbine control valves, operators used an automatic power ramp to a setpoint of only 3 megawatts below 100 percent, without accounting for the overshoot that would result from the selected ramp rate, resulting in exceeding 100 percent power. In both cases, operators were alerted by an alarm indicating that the 1-minute average power level exceeded 100 percent. The inspectors reviewed station procedure GEN 00-004 Power Operation, and noted a requirement in Attachment A: For pre-planned evolutions that are expected to cause a transient rise in reactor power that could exceed the licensed power level, prudent actions should be taken to reduce power prior to the evolution. Failure to take prudent action to maintain the reactor within licensed power limits prior to performing activities known to cause an increase in reactor power levels is a performance deficiency. The performance deficiency was more than minor because it affected both the configuration control attribute of reactivity control as well as the human performance attribute of procedure adherence of the Barrier Integrity Cornerstone, and impacted the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. The inspectors screened the finding using the reactivity control screening questions found in Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Section C; question number 3 referred the inspectors to Inspection Manual Chapter 0609, Appendix M, Significance Determination Using Qualitative Criteria. NRC Management performed the qualitative assessment and determined that the finding was of very low safety significance (Green) because the relatively small magnitude of the overpower events, the prompt operator actions to return power to below the licensed limits upon discovery, and the fact that overpower events did not result in any failure of the fuel cladding. The inspectors determined that the finding had a conservative bias cross-cutting aspect in the area of human performance. Specifically, the affected evolutions were known in advance to have positive reactivity impacts; however, operators did not consider reducing power in the case of the check valve testing, nor was a slow approach to the maximum reactor power level used to avoid overshoot during dynamic turbine loading for the turbine valve data collection in order to prevent licensed power levels from being exceeded.licensed power levels from being exceeded.

Discovered date

23:59:59, 31 March 2014 +

Docket

05000482 +

Event date

23:59:59, 31 March 2014 +

Finding integer

2 +

Finding type

Non-cited violation +

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INPO aspect

DM.2 +

Identified by

Self-revealing +

Inspection Manual Chapter

NRC Inspection Manual 0609/Appendix A, The Significance Determination Process (SDP) for Findings At-Power + and NRC Inspection Manual 0609/Appendix M, Significance Determination Process Using Qualitative Criteria +

Inspection procedure

IP 71111.13 +

Inspection report

IR 05000482/2014002 +

Inspector

N O'Keefe +, P Hernandez +, R Stroble +, L Ricketson +, David Proulx +, Peter Jayroe +, Charley Peabody +, Gary Callaway + and David You +

Modification date"Modification date" is a predefined property that corresponds to the date of the last modification of a subject and is provided by <a rel="nofollow" class="external text" href="https://www.semantic-mediawiki.org/wiki/Help:Special_properties">Semantic MediaWiki</a>.

04:21:03, 22 February 2018 +

Person