05000333/FIN-2013002-02
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Finding | |
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| Title | Failure to Submit an LER for a Condition Prohibited by TS 3.0.4 |
| Description | The inspectors identified a Severity Level (SL) IV non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 50.73, Licensee Event Report [LER] System, because a violation of technical specification (TS) 3.0.4 for a reactor mode change being made from Mode 4 to Mode 2 without satisfying the TS required conditions for alignment of the containment air dilution and standby gas treatment (SGT) systems in Mode 2 was not reported to the NRC within 60 days of when it should reasonably have been discovered. Specifically, in Modes 1, 2, and 3, TS surveillance requirement (SR) 3.6.1.3.1 allows the 20-inch and 24-inch primary containment vent and purge valves to be open for inerting, deinerting, pressure control, or other reasons provided that valve 27MOV- 120 in the full flow line to the SGT system is closed. This is to ensure that there would be no damage to the SGT filters if a loss-of-coolant accident (LOCA) were to occur with the vent and purge valves open. However, on November 24, 2012, operators transitioned the reactor from Mode 4 to Mode 2 while the 20-inch and 24-inch containment vent and purge valves, and valve 27MOV-120, were open. This condition was not reported to the NRC within 60 days of when it should reasonably have been discovered. As immediate corrective action, FitzPatrick staff entered the issue into the corrective action program as condition report (CR)-JAF-2013-01097. The inspectors determined that the failure to submit an LER within 60 days in accordance with 10 CFR 50.73 was a performance deficiency that was reasonably within Entergys ability to foresee and correct. Because the issue impacted the regulatory process, in that a violation of site TSs was not reported to the NRC within the required timeframe, thereby delaying the NRCs opportunity to review the matter, the inspectors evaluated this performance deficiency in accordance with the traditional enforcement process. Using example 6.9.d.9 from the NRC Enforcement Policy, the inspectors determined that the violation was a SL IV (more than minor concern that resulted in no or relatively inappreciable potential safety or security consequence) violation, because Entergy personnel failed to make a report required by 10 CFR 50.73 when information that the report was required had been reasonably within their ability to have identified. In accordance with Inspection Manual Chapter (IMC) 0612, Power Reactor Inspection Reports, traditional enforcement issues are not assigned cross-cutting aspects. |
| Site: | FitzPatrick  |
|---|---|
| Report | IR 05000333/2013002 Section 4OA2 |
| Date counted | Mar 31, 2013 (2013Q1) |
| Type: | TEV: Severity level IV |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71152 |
| Inspectors (proximate) | S Mccarver J Laughlin E Knutson B Sienel A Burritt E Miller |
| Violation of: | 10 CFR 50.73 Technical Specification |
| INPO aspect | |
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Finding - FitzPatrick - IR 05000333/2013002 | |||||||||||||||||||||||||||||||||||
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Finding List (FitzPatrick) @ 2013Q1
Self-Identified List (FitzPatrick)
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