The following violation of very low significance was identified by the licensee and is a violation of NRC requirements which meets the criteria of the
NRC Enforcement Policy for being dispositioned as an
NCV.
Technical Specification 3.0.4 for Perry requires in part that 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 or other specified condition in the Applicability for an unlimited period of time. Contrary to the above, October 18, 2011, the licensed was conducting a startup and changed modes to Mode 2 when the backfeed line was not available to support the requirement of
TS 3.8.1 for two offsite sources. The licensee identified that the system disconnects in the
switchyard had been opened for maintenance during a forced outage and tagged out by the distribution operator through switching orders acted on by the Perry control room. The disconnects were not closed prior to the startup because the actions to do so were not tracked in the control room. The issue was documented in CR-2011-03926 and immediate actions were taken in coordination with the central dispatcher to clear the tags and close the disconnects. The failure to ensure on startup that the requirements for compliance with
TS 3.8.1 were met on startup is a performance deficiency. The inspectors determined that the finding was more than minor because it was similar to
IMC 0612, Appendix E, example 2.g in that the mode change was made without all required equipment being
operable. The performance deficiency is associated with the
Mitigating Systems Cornerstone attribute of Configuration Control and adversely impacted the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to
initiating events to prevent undesirable consequences. The finding was reviewed for significance in accordance with
IMC 0609,
Significance Determination Process, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of findings, Table 3b for the
Mitigating Systems Cornerstone. The inspectors determined the finding was of very low safety significance because it was not a design/qualification deficiency, did not represent a loss of system safety function, did not result in a loss of function of a single train for greater than its TS-allowable outage time, did not result in a loss of function of nonsafety-related risk-significant equipment and was not risk-significant due to external events
