05000461/FIN-2011005-03
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Finding | |
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| Title | Review of Licensees Compliance with TS 3.6.4.3 During Operations with the Potential to Drain the Reactor Vessel |
| Description | During the refueling outage on December 6, 2011, the licensee performed OPDRV activities. Entry into this operational condition changes the applicability of many TSs, such that several TS systems are required to be operable prior to commencing OPDRV activities that otherwise would not be required to be operable with the unit shutdown. Among several requirements during OPDRV activities, TS Limiting Condition for Operation (LCO) 3.6.4.3 requires two VG subsystems (or trains) to be operable. Of the two trains of VG, only the B train was operable at the time. The A VG train had been inoperable since an emergent equipment issue was found during the performance of a Division 1 DG integrated surveillance test. In order to perform OPDRV activities prior to restoring VG train A to an operable status, the licensee chose to apply TS 3.0.4.a. TS 3.0.4.a states 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. If the licensee was to commence OPDRV activities, TS 3.6.4.3 would not be met since only one VG subsystem was operable. Condition A of TS 3.6.4.3 requires that if one subsystem of VG is inoperable, the other subsystem shall be returned to operable status within 7 days. If that action cannot be met during its 7-day completion time with OPDRVs in progress, then TS 3.6.4.3 Condition C would require the operable VG subsystem be placed in operation or initiate actions to suspend OPDRVs. In support of OPDRV activities, on December 6th at 12:06 a.m., the licensee placed the operable B VG subsystem into service. At 1:15 a.m. on-shift operations personnel completed CPS 3007.01C005, Operations With a Potential for Draining the Reactor Vessel Checklist, Revision 2a, to verify compliance with TSs prior to entering the OPDRV operational condition. On December 6th at 9:53 a.m., with VG train B in operation, the licensee commenced OPDRV activities and, according to Control Room logs, entered TS LCO 3.6.4.3 Required Actions A.1 (restore the inoperable VG subsystem to operable within 7 days) and C.1 (place the operable VG subsystem in operation immediately). Later that day, at 2:37 p.m., operators secured the B VG subsystem but continued to perform OPDRV activities. Control Room logs stated that the B VG subsystem was secured; but operators did not document exiting TS 3.6.4.3 Required Action C.1, nor did they describe the basis for making that decision. Later the same day at 7:45 p.m., the licensee exited the OPDRV condition, thereby making TS 3.6.4.3 no longer applicable. When the inspectors questioned why VG B had been secured during OPDRV conditions and while in TS 3.6.4.3 Required Action C.1, the shift manager informed the inspectors that the decision to secure VG B was made because open primary containment penetrations with VG in service were adversely impacting the operation of the containment ventilation system. Also, another reason provided to inspectors at the time was that a request had been made to perform welding within the secondary containment boundary, which would by procedure CPS 3319.01, Standby Gas Treatment (VG), Revision 16, require an engineering evaluation to be performed. The same procedure also stated that welding and grinding have no detrimental effect on the efficiency of VG charcoal absorbers. In response to inspectors questions regarding this sequence of events, the licensee initiated AR 01298874, NRC Question Concerning Use of ITS 3.0.4. The action request stated that the decision to secure VG B was made in order to utilize the 7-day clock provided by LCO 3.6.4.3 Condition A. The licensee concluded that although Required Action C.1 was entered, it was not necessary to do so, and this, therefore, permitted exiting Required Action C.1 until the 7-day completion time of Condition A had expired. The licensee referenced Task Interface Agreement (TIA) 2009-005, Reevaluation of Implementation of Limiting Condition for Operation 3.0.4.a, Mode Change Limitations, at Palisades Nuclear Plant, and summarized the NRCs position to be the following: ...it is not necessary for the Required Actions to be completed prior to entering the Applicability when using 3.0.4.a, but it is advisable when there is no operational reason to defer taking the Required Actions. The inspectors reviewed the TIA and noted that while the NRC stated that the Palisades licensee did not violate TS LCO 3.0.4.a in that instance because completion of all Required Actions prior to transitioning to a Mode of Applicability was not a requirement in that case, the NRC Guidance Section of the TIA then stated: It should be emphasized that, to implement the mode transition allowance of LCO 3.0.4.a, licensees should have a reasonable expectation that the TS Required Actions will be completed within their specified completion times. The inspectors discussed the issue with staff in the Technical Specification Branch of the NRC Office of Nuclear Reactor Regulation (NRR). Through these discussions, the inspectors and NRR staff agreed that the actions taken in regard to the licensees interpretation and application of TS LCO 3.0.4.a and LCO 3.6.4.3 warranted further review. This issue is considered to be an Unresolved Item pending additional review by the NRC staff |
| Site: | Clinton  |
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| Report | IR 05000461/2011005 Section 4OA5 |
| Date counted | Dec 31, 2011 (2011Q4) |
| Type: | URI: |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | |
| Inspectors (proximate) | A Shaikh B Kemker B Orlikowski D Lords D Reeser J Draper J Laughlin S Mischke V Myersb Kemkerd Lords J Cassidy J Draper J Mcghee M Bielby M Ring R Jickling S Mischke T Bilik |
| INPO aspect | |
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Finding - Clinton - IR 05000461/2011005 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Clinton) @ 2011Q4
Self-Identified List (Clinton)
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