05000410/FIN-2014003-03

Finding

Title

Loss of Spent Fuel Cooling Pump due to Inadequate Procedures

Description

A self-revealing NCV of TS 5.4.1, Procedures, was identified at Unit 2 for Exelons failure to provide procedures to override valve 2SFC*AOV154, filters inlet isolation valve, prior to loss of offsite power (LOOP) testing. Specifically, procedures N2-OSP-EGS-R004, Operating Cycle Diesel Generator Simulated Loss of Offsite Power With ECCS Division I & II, Revision 01200, and N2-VLU-01, Valve Lineup and Valve Operations, Revision 00001, did not contain adequate guidance to differentiate between overriding the valve (open position) and repositioning the valve to its non-failure position (closed position). As a result, on March 28, 2014, while implementing N2-OSP-EGS-R004, the spent fuel cooling pump A tripped off and had to be restored. Exelon entered the loss of spent fuel pool (SFP) cooling into the corrective action program (CAP) as CR-2014-002507. Corrective actions included coaching the individuals involved and reinforcing Exelons expectations regarding what information should be discussed during pre-job briefs. This finding is more than minor because it is associated with the configuration control attribute of the Barrier Integrity cornerstone and affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, if N2-OSP-EGS-R004 and Figure 3, Operation of Bettis Actuators, of N2-VLU-01 are not revised, there is the potential for plant operators to incorrectly assume that Section 3.0 of N2-VLU-01 Figure 3 is the valve lineup required by the N2-OSP-EGS-R004, closing 2SFC*AOV154 and causing a subsequent pump trip where the loss of cooling may have more significant consequence leading to an increase in the temperature of the spent fuel cooling pump. In accordance with IMC 0609.04, Initial Characterization of Findings, issued June 19, 2012, the inspectors used IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, issued June 19, 2012, because the SFP was still isolated from the reactor core at the time of the finding. Using Appendix A Exhibit 3 Barrier Integrity Screening Questions Section D, Spent Fuel Pool (SFP), the inspectors determined that this finding is of very low safety significance (Green) because although the performance deficiency adversely affected decay heat removal capabilities from the SFP, the pool temperature did not exceed the maximum analyzed temperature limit specified in the sitespecific licensing basis, the performance deficiency did not involve a fuel handling error, did not affect the SFP neutron absorber, and did not result in a loss of SFP water inventory. This finding has a cross-cutting aspect in the area of Human Performance, Challenge the Unknown, because Exelon did not ensure that individuals stopped in the face of uncertain conditions. Specifically, after recognizing that N2-VLU-01 Figure 3 contained multiple sections that were not clearly labeled, plant operators did not stop and consult the senior reactor operator but continued on with an erroneous assumption as to which section to use.

03
Site:	Nine Mile Point
Report	IR 05000410/2014003 Section 4OA3
Date counted	Jun 30, 2014 (2014Q2)
Type:	NCV: Green
cornerstone	Barrier Integrity
Identified by:	Self-revealing
Inspection Procedure:	IP 71153
Inspectors (proximate)	A Bolger A Rosebrook C Graves D Schroeder E Burket E Miller G Stock J Furia K Kolaczyk N Floyd
Violation of:	Technical Specification - Procedures Technical Specification
CCA	H.11, Challenge the Unknown
INPO aspect	QA.2
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v • d • e

Finding - Nine Mile Point - IR 05000410/2014003

1(0)2(2)3(4)4(1)5(4)6(0)7(4)201(0)202(0)403(0)404(5)301(0)

IR 05000410/2014003: 2 1 3 4

Finding List (Nine Mile Point) @ 2014Q2

CCA Matrix: 2014Q2

	Q	CCA	Title
05000220/FIN-2013007-01	2013Q3	H.7	Failure to Identify and Correct a Condition Adverse to Quality Associated With HPCS Medium Voltage Power Supply Cables
05000220/FIN-2013010-01	2013Q3	H.1	Improper Bus Restoration Results in a Loss of Shutdown Cooling
05000220/FIN-2013010-02	2013Q3	H.12	Configuration Control error results in loss of a vital DC Bus
05000220/FIN-2013005-01	2013Q4	P.1	Failure to Perform Surveillance Test for Unit 1 Smoke Removal Dampers
05000410/FIN-2013005-02	2013Q4	P.2	Failure to Implement Procedural Requirements for Evaluating Control Room Deficiencies as Operator Workarounds
05000220/FIN-2013005-03	2013Q4		Inadequate DSC Welding Procedure to Control and Monitor Hydrogen Concentrations
05000220/FIN-2014002-01	2014Q1		Inadequate Design Control Measures Employed During Control Room HVAC Modification
05000410/FIN-2014002-02	2014Q1	H.14	Invalid Low Reactor Water Level Results in Unit 2 Automatic Reactor Scram
05000220/FIN-2014404-01	2014Q2		Security
05000220/FIN-2014404-02	2014Q2		Security
05000220/FIN-2014404-03	2014Q2		Security
05000410/FIN-2014003-01	2014Q2		Inadequate Surveillance Testing of Reactor Core Isolation Cooling during 165 psig Reactor Pressure Test for Surveillance Requirement 3.5.3.4
05000220/FIN-2014003-02	2014Q2	P.3	Failure to Correct a Significant Condition Adverse to Quality in a Timely Manner
05000410/FIN-2014003-03	2014Q2	H.11	Loss of Spent Fuel Cooling Pump due to Inadequate Procedures
05000410/FIN-2014003-04	2014Q2		Failure to Identify Single-Point Vulnerabilities Results in a Manual Reactor Scram

Self-Identified List (Nine Mile Point)

	Q	Title
05000220/FIN-2013405-01	2013Q3	Licensee-Identified Violation
05000220/FIN-2014404-04	2014Q2	Licensee-Identified Violation
05000220/FIN-2014404-05	2014Q2	Licensee-Identified Violation

[Nine Mile Point Findings full list]

05000410/FIN-2014003-03

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