05000336/FIN-2017003-01
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Finding | |
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Title | Inadequate Procedure Results in Inadvertent Lowering of Spent Fuel Pool Level |
Description | A self-revealing NCV of very low safe ty significance (Green) of Technical Specification (TS) 6.8, Procedures, was identified because Dominion did not adequately establish Operating Procedure (OP) 2305, Spent Fuel Pool Cooling and Purification System. Specifically, from initial issuance until June 20, 2017, the procedure did not direct operators to verify the primary demineralizer bypass valve was closed while lining up to fill the spent fuel pool from the coolant waste receiver tanks, resulting in an unexpected loss of spent fuel pool inventory. Dominion has documented this condition within their corrective action program (CAP) as condition report (CR) 1064323, revised procedure OP 2305, and performed an apparent cause evaluation. The inspectors determined that the finding was more than minor because it was associated with the procedure quality attribute of the Barrier Integrity cornerstone and adversely affected its objective to provide reasonable assurance that physical design barriers, such as fuel cladding, protect the public from radionuclide releases caused by accidents or events. Specifically, spent fuel pool level was inadvertently lowered when operators aligned the system in accordance with OP 2305, which resulted in a reduced net positive suction head for the spent fuel pool cooling pumps as indicated by control room alarm. The finding screened to be of very low safety significance (Green) because it did not result in a loss of spent fuel pool water inventory below the minimum analyzed level limit and did not cause the spent fuel pool temperature to exceed the maximum analyzed temperature limit. This finding has a cross-cutting aspect in the Human Performance cross-cutting area, Avoid Complacency because Dominion did not recognize and plan for the possibility of a latent deficiency in procedure OP 2305 when used while the primary demineralizers were bypassed. [H.12] |
Site: | Millstone |
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Report | IR 05000336/2017003 Section 4OA2 |
Date counted | Sep 30, 2017 (2017Q3) |
Type: | NCV: Green |
cornerstone | Barrier Integrity |
Identified by: | Self-revealing |
Inspection Procedure: | IP 71152 |
Inspectors (proximate) | J Fuller L Mckown C Highley B Dionne J Deboer C Roettgen R Rolph H Anagnostopoulos J Greives |
Violation of: | Pending Technical Specification - Procedures |
CCA | H.12, Avoid Complacency |
INPO aspect | QA.4 |
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Finding - Millstone - IR 05000336/2017003 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Millstone) @ 2017Q3
Self-Identified List (Millstone)
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