05000374/FIN-2015002-04
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Finding | |
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| Title | Failure to Include Limiting Conditions for Operation in the Technical Specifications |
| Description | The inspectors identified a Severity Level IV NCV of 10 CFR 50.36, Technical Specifications, having very low safety significance (Green), for the licensees failure to ensure that limiting conditions for operation (LCOs) were contained in the stations Technical Specifications (TSs). Specifically, as of March 15, 2015, through the Unit 2 Core Operating Limits Report (COLR), Cycle 16, Revisions 1 and 2, the licensee introduced new Operating Limits for Lost Jet Pump Plug Seals Mitigation Strategy, that created new LCOs as defined by 50.36(c)(2) but did not incorporate these LCOs into the TSs. The licensee incorrectly believed that because the COLR was revised via the 50.59 process and the special content that accounted for the existence of the plugs was developed using NRC-approved methodologies, the change was acceptable and no change to the TSs was obtained from the NRC. This finding was considered more than minor because it was associated with the design control attribute of the Barrier Integrity Cornerstone and adversely affected the cornerstone objective of providing reasonable assurance that physical design barriers (fuel cladding, reactor coolant system (RCS), and containment) protect the public from radionuclide releases caused by accidents or events. Specifically, the Unit 2 COLR was revised in a manner that created new LCOs, and further, could have resulted in the operation of Unit 2 outside of its approved TSs and license. Operating the unit in accordance with its NRC-approved TSs could have resulted in the plant operating in an unanalyzed condition that could have resulted in fuel failure. The finding involves the potential for a failed safety/relief valve (SRV) or turbine bypass valve concurrent with complete flow blockage to a peripheral fuel assembly, with a simultaneous breakdown of control room operator knowledge of the special steps required by the COLR revision. Given standard operating practices and the significant amount of extra attention and sensitivity placed on the jet pump plugs and their potential effect, an error that results in licensed operators failing to comply with the restrictive limits of the COLR would be very unlikely. Additionally, a read-and-sign was required of all Unit 2 control room operators and supervisors delineating the special compensatory measures to be taken in the event that a COLR base case component, such as an SRV, were to fail. Further, the inspectors considered the relatively short duration of time (March 1523, 2015) where the plug material parameters were sufficient to cause plugging of an orifice coincident with plant power levels that could challenge the fuel integrity limits. Given these factors, the inspectors determined that the likelihood of a failed COLR base case component, combined with the operation of the unit in an unanalyzed condition in accordance with the NRC-approved TSs, combined with a blocked orifice that could result in fuel clad damage was very low. Given the very low likelihood of the event scenario to occur and the low consequences if it were to occur, the inspectors concluded that the finding was of very low safety significance (Green). The inspectors determined that this finding had a cross-cutting aspect in the area of Human Performance, Change Management, because the licensee leaders did not ensure the use of a systematic process for evaluating and implementing change so that nuclear safety remained the overriding priority (H.3). |
| Site: | LaSalle  |
|---|---|
| Report | IR 05000374/2015002 Section 1R18 |
| Date counted | Jun 30, 2015 (2015Q2) |
| Type: | TEV: Severity level IV |
| cornerstone | Barrier Integrity |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.18 |
| Inspectors (proximate) | A Dunlop C Hunt D Chyu D Krause J Robbins M Holmberg M Kunowski R Ruiz R Zuffa |
| Violation of: | 10 CFR 50.36 Technical Specification |
| CCA | H.3, Change Management |
| INPO aspect | LA.5 |
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Finding - LaSalle - IR 05000374/2015002 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (LaSalle) @ 2015Q2
Self-Identified List (LaSalle)
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