The inspectors identified an
NCV of
Technical Specification 6.8.1, Procedures and Programs, because Oyster Creek operators did not adequately implement procedures when performing a plant shutdown. Specifically, the operators did not ensure that all personnel on shift had received Just-in-Time-Training for their role in the shutdown; operators did not perform a reactivity Heightened Level Awareness brief for the shutdown, and did not insert source range monitors (
SRMs) in accordance with procedure. These performance deficiencies contributed to two unanticipated criticalities during the shutdown. Exelon entered this issue into their corrective action program as
IR 2412093 and conducted a root cause analysis. This finding is more than minor because it affected the procedure quality attribute of the
Mitigating Systems cornerstone and affected the cornerstone objective to ensure the reliability and capability of systems that respond to
initiating events. Specifically, Exelon did not implement procedures during the plant shutdown which contributed to two unanticipated returns to criticality which required operator action to mitigate. The inspectors screened this issue using
IMC 0609.04, Initial Characterization of Findings, Exhibit 2 of
IMC 0609, Appendix A, The
Significance Determination Process for Findings At-Power, and
IMC 0609 Appendix M,
Significance Determination Process Using Qualitative Criteria. Inspectors determined this finding was of very low safety significance (Green). This finding has a cross-cutting aspect in the area of Human Performance, Procedure Adherence, because licensed operators did not implement processes, procedures and work instructions during the plant shutdown.