05000237/FIN-2013004-01
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Finding | |
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| Title | Failure to Update the UFSAR for Reactor Water Cleanup Design Changes |
| Description | A Severity Level IV NCV of 10 CFR 50.71(e), Periodic Update of the Final Safety Analysis Report (USFAR) and an accompanying Green finding were identified by the inspectors for the licensees failure to update the Updated Final Safety Analysis Report (UFSAR) for a design modification performed on the Unit 3 reactor water cleanup (RWCU) system. Specifically, the licensee did not update Dresden UFSAR Section 5.4.8, Reactor Water Cleanup System, to reflect changes made during a design modification installed on Unit 3 in 1997. The design changes included reducing the pipe dimension of RWCU piping outside of the primary containment and eliminating a string of regenerative and non-regenerative heat exchangers. The licensee also identified several high energy line break (HELB) calculations which did not include the design modification when determining the impact on environmentally qualified components affected by a failure of the RWCU system piping outside of the primary containment structure. Corrective actions included submitting a UFSAR change request to include the appropriate operating characteristics and specifications under the present design. In addition, the licensee reviewed all affected calculations to ensure no nonconservative outcomes resulted based on the design modifications installed. This finding was determined to be more than minor using IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated September 7, 2012 because, if left uncorrected, the performance deficiency could have led to a more significant safety concern. Specifically, failure to update the UFSAR with the actual RWCU system configuration prevented the inspectors from readily concluding that the design change would not require additional calculational analyses for HELB. The inspectors completed a Phase 1 significance determination of this issue using IMC 0609, Significance Determination Process, Attachment 0609.04, Initial Characterization of Findings, dated July 1, 2012 and IMC 0609, Appendix A, The Significance Determination Process (SDP) For Findings At-Power, dated July 1, 2012. The inspectors answered NO to all questions in Exhibit 2, Section A, Mitigating SSCs and Functionality, therefore the finding screened as Green (very low safety significance). In accordance with Section 6.1.d.3 of the NRC Enforcement Policy, this violation is categorized as Severity Level IV because the information was not used to make an unacceptable change to the facility or procedures since the design changes did not result in a reduction of the previous margin to the 10 CFR 100 guidelines nor did they challenge the environmental quality rating of safety related components in the vicinity of the RWCU system during a HELB event outside of containment. The inspectors determined that this finding did not reflect present performance because it is a legacy issue with changes made to the facility more than 16 years previously; therefore, there was no cross cutting aspect associated with this finding. |
| Site: | Dresden  |
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| Report | IR 05000237/2013004 Section 1R15 |
| Date counted | Sep 30, 2013 (2013Q3) |
| Type: | TEV: Severity level IV |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.15 |
| Inspectors (proximate) | A Shaikh E Sanchez-Santiago R Elliott G Roach D Melendez-Colon P Pelke T Go V Meghani D Lords |
| Violation of: | 10 CFR 50.71(e) 10 CFR 50.71 |
| INPO aspect | |
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Finding - Dresden - IR 05000237/2013004 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Dresden) @ 2013Q3
Self-Identified List (Dresden)
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