LCO 3.0.4 states , in part, when an LCO is not met, entry into a MODE or other specified condition in the applicability shall only be made when the associated ACTIONS to be entered permit continued operation in the MODE for an unlimited period of time. Contrary to the above, on April 13, 2017, at 2347, the licensee changed modes on Unit 2 from Mode 4 to Mode 2 with the
primary containment inoperable. Specifically,
TS 3.6.1.1,
Primary Containment, requires
primary containment to be
operable in Modes 1, 2, and 3, however, the reactor was taken to Mode 2 with the primary containment still aligned for venting. In this condition, the drywell ventilation makes the primary c ontainment
inoperable due to the drywell and the suppression chamber being in communication to each other. This condition is allowed for two hours before the required action to shutdown to Mode 4 is required. Since the required action is not permitted for continued operation, a violation of
LCO 3.0.4 occurred. The cause of the event was the failure of operations personnel to initiate a tracking LCO for
primary containment being
inoperable in accorda nce with licensee procedure 0OI -01.01, BNP Conduct of Operations Supplement. The licensee determined a tracking LCO should have been initiated to ensure the
primary containment was restored to
operable prior to entering Mode 2. As immediate corrective actions, the licensee restored containment to
operable on April 14, 2017 , at 0030, and the Shift Manager and Control Room Supervisor were removed from shift. Further, a remediation plan was developed and implemented to assess the Shift Manager and Control Room Supervisor for watch standing and reinstatement . This finding is associated with the
Barrier Integrity Cornerstone. Using
IMC 0609, Appendix G, Shutdown Operations
Significance Determination Process, Attachment 1, Exhibit 4,
Barrier Integrity Screening Ques tions, the finding screened to G reen because it did not degrade the ability to close or isolate the containment, it did not degrade the physical integrity of reactor containment, and it did not involve an actual reduction in function of
hydrogen control . This issue was documented in the licensee s
CAP as
NCR 2116753.
