05000285/FIN-2012301-06
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Finding | |
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| Title | Four Examples of Inadequate Procedures for the Barrier Integrity Cornerstone |
| Description | The team identified a finding of very low safety significance involving a non-cited violation of Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, with four examples. Example 1. The normal operating instruction for reactor coolant pumps, OI-RC- 9, Reactor Coolant Pump Operation, contains pump trip requirements that conflict with the pump trip requirements provided in the Abnormal Operating Procedure AOP-35, Reactor Coolant Pump Malfunctions. After identification, the licensee entered this issue in the corrective action program as Condition Report 2012-03145. Example 2: Annunciator Response Procedure ARP-DCS-SCEAPIS incorrectly directs the operators to restore a control element assembly group to within proper overlap using manual group mode, instead of manual individual mode. After identification, the licensee entered the issue into the corrective action program as Condition Report 2011-07172. Example 3: Neither the Annunciator Response Procedure ARP-DCS-SCEAPIS, nor the control element assembly Abnormal Operating Procedure AOP-02, CEA and Control System Malfunctions, address excessive overlap between control element assembly groups caused by operator error instead of a digital control system failure. After identification, the licensee entered the issue into the corrective action program as Condition Report 2011-09653. Example 4: The licensees Abnormal Operating Procedure AOP-21, Reactor Coolant System High Activity, has multiple values for high reactor coolant system activity requirements that conflict on whether or not it is necessary to initiate a plant shutdown. Additionally, this procedure is not current with the most recent action levels contained in SO-O-43 Fuel Reliability Management Plan. This fuel reliability management plan currently lists four action levels, while the actions in the abnormal operating procedure are based on five action levels. The fifth action level actions would not be performed since no fifth action level is defined in SO-O-43. After identification, the licensee entered the issue into the corrective action program as Condition Report 2012-03143. These failures to prescribe activities affecting quality by procedures or to include the appropriate acceptance criteria are performance deficiencies. Each example is more than minor and is therefore a finding because it adversely affects the procedure quality attribute of the barrier integrity cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. These examples either could have significantly affected, or were shown during examination preparation and administration to have actually affected the operator\'s ability to perform the activity affecting quality. In accordance with Inspection Manual Chapter 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings, a phase 1 screening was performed and each example except for Example 1 was determined to be of very low safety significance (Green) because the fuel cladding barrier was affected but did not affect the reactor coolant system or containment barriers. Example 1 was determined to be of very low safety significance (Green) because the finding: (1) did not represent only a degradation of the radiological barrier function provided for the control room, or auxiliary building, or spent fuel pool; (2) did not represent a degradation of the barrier function of the control room against smoke or a toxic atmosphere; (3) did not represent an actual open pathway in the physical integrity of reactor containment system, containment isolation system, and heat removal components; and (4) did not involve an actual reduction in function of hydrogen ignitors in the reactor containment. The finding has a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action program component because the licensee did not implement a corrective action program with a low threshold for identifying issues in that licensed operators deviate from procedures when procedures cannot be implemented as written without writing necessary condition reports to fix the deficient procedures. |
| Site: | Fort Calhoun  |
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| Report | IR 05000285/2012301 Section 4OA5 |
| Date counted | Jun 30, 2012 (2012Q2) |
| Type: | NCV: Green |
| cornerstone | Barrier Integrity |
| Identified by: | NRC identified |
| Inspection Procedure: | |
| Inspectors (proximate) | T Buchanan T Farina B Larson C Osterholtz G Apger M Hay R Devercellyb Larson D Strickland K Clayton M Haire N Hernandez T Buchana |
| CCA | P.1, Identification |
| INPO aspect | PI.1 |
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Finding - Fort Calhoun - IR 05000285/2012301 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Fort Calhoun) @ 2012Q2
Self-Identified List (Fort Calhoun)
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