The NRC-identified a Green non-cited violation (
NCV) of
10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions, for failure to identify and correct a
condition adverse to quality. The licensee failed to identify that their procedures lacked actions to install control power jumpers that are required to defeat the
reactor coolant systems (
RCS) pressure interlocks for the
shutdown cooling (
SDC) suction line motor operated valves (
MOVs) when aligning the plant for hot leg injection (HLI) and then correct the condition. Following the identification of this procedural vulnerability, the licensee fabricated control power jumpers and revised procedure 1-GME-100.03, Installation and Removal of Temporary Power Jumpers for
MOV V3481, V3652, V3432 AND V3444, to provide direction for installation of power jumpers. In addition, the licensee performed a more detailed failure modes and effects analysis to ensure that the revised procedures accounted for all possible single failures. This issue has been entered into the licensees corrective action program (
CAP) as CR 2217631.The
PD was more than minor because it was associated with the Design Control attribute of the Mitigating System cornerstone objective of ensuring the capability of the low pressure safety injection (
LPSI) system to perform its required long term cooling safety function (HLI). The condition was evaluated by a Regional Senior Reactor Analyst and determined to have very low safety significance (Green) based on the low likelihood of a loss of coolant accident (
LOCA) and low likelihood of electrical failures requiring jumpers to be installed. This issue and corrective actions were documented in the licensees
CAP as Action Request (
AR) 2217631. This finding was not assigned a cross-cutting aspect because the underlying cause was a legacy issue and not indicative of current performance.
