Technical Specification 5.4.1.a states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures in
Regulatory Guide 1.33, Quality Assurance Program Requirements, Revision 2, Appendix A, February 1978
NRC Regulatory Guide 1.33, Appendix A, Section 1.d. requires procedures for Procedure Adherence and Temporary Change Method. Procedure APA-ZZ-00100, Written Instructions Use and Adherence, Revision 32, a procedure intended to meet the above requirements, Section 4.1, Rules for Written Instructions, states in part, 4.1.8. Perform procedures or written instructions in the following manner: Numbered or lettered steps are performed in sequence 4.1.9. Sections of a procedure or work instruction may be performed out of sequence or concurrently if allowed by the document. Steps within a section MUST be performed in the order written. Additionally, for procedures identified as Continuous Use, it states in part
4.6.2.c. Perform the step as written in the sequence specified. Contrary to the above, on November 18, 2014, the licensee failed to implement a procedure required by
Technical Specification 5.4.1.a. Specifically, a licensed operator failed to comply with Sections 4.1 and 4.6 of Procedure APA-ZZ-00100 when he entered multiple sections of Procedure
OSP-BB-VL006,
RCS Pressure Isolation Valves Inservice Tests
IPTE, which was not allowed by the document. The operator directed the closing of the breakers for all four safety injection
accumulator isolation valves at the same time when the procedure directed testing one valve at a time and restoring after each test. Using NRC Inspection Manual 0609, Appendix A, Exhibit 2,
Mitigating Systems Screening Questions, the finding was determined to be of very low safety significance because it did not affect the design or qualification of a system, did not result in a loss of system function, did not represent a loss of function of a single train for greater than its technical specifications allowed outage time, and did not cause the loss of function of one or more non-technical specification trains of equipment designated as high safety significance. This violation was entered into the licensees corrective action program as Callaway Action Request 201408530.
