05000237/FIN-2012002-05
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Finding | |
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| Title | Failure to Document a 10 CFR 50.59 Evaluation for Changes Made to the Facility |
| Description | The inspectors identified a Severity Level IV NCV of 10 CFR 50.59, Changes, Tests, and Experiments, having very low safety significance (Green) for the licensees failure to perform an adequate safety evaluation review for changes made to the facility involving the placement of chemical storage tanks. As part of its corrective action, the licensee entered the issue into its corrective action program as IR 1302573 and performed Engineering Change Evaluations (EC) 38018 and EC 387073 which determined that the control room envelope had been historically operable. The licensee planned to install a completely different design of the chemical addition system that would separate the sodium hypochlorite storage from the hydroxyethylidenediphosphonic acid (HEDP, a strong acid) storage. Completion of the modification is planned for August 2012. The underlying technical finding was evaluated under the SDP using NRCs IMC 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings, and the inspectors answered Yes to the question in Table 4a; Does the finding represent a degradation of the barrier function of the control room against smoke or a toxic atmosphere? The SDP required a Phase 3 analysis to resolve this type of finding. However, after consultation with a Region 3 Senior Reactor Analyst it was determined that no SDP methods or tools exist to determine the significance of the finding. Therefore, the finding was not suitable for evaluation using the SDP, so the risk significance was established in accordance with the qualitative criteria of Appendix M (dated December 22, 2006) of IMC 0609. Specifically, the qualitative decision-making attribute from Table 4.1 of Appendix M, Finding can be bounded using qualitative and/or quantitative information was applicable to this finding. The licensee performed two quantitative engineering evaluations regarding this finding. The first (EC 387018) determined the minimum level of sodium hypochlorite stored in the tanks necessary that if it were to completely interact with the HEPD and completely release all of the contained chlorine would render the control room envelope inoperable. The second (EC 387073) determined that the tanks would not have been affected by wind, seismic, or missile impacts with a level of sodium hypochlorite equal to or greater than the level necessary to make the control room envelope inoperable identified in EC 387018. Therefore, based upon a qualitative measure of risk determined in accordance with Appendix M, NRC Management concluded that the issue was of very low safety significance (Green). This finding has no cross-cutting aspect because it does not represent current licensee performance. |
| Site: | Dresden  |
|---|---|
| Report | IR 05000237/2012002 Section 4OA3 |
| Date counted | Mar 31, 2012 (2012Q1) |
| Type: | Finding: Green |
| cornerstone | Barrier Integrity |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71153 |
| Inspectors (proximate) | J Beavers J Cameron M Jones N Valos R Langstaff T Briley T Go Z Falevits A Dunlop C Phillips D Melendez Colon E Sanchez Santiago |
| INPO aspect | |
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Finding - Dresden - IR 05000237/2012002 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Dresden) @ 2012Q1
Self-Identified List (Dresden)
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