05000237/FIN-2014004-01
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Finding | |
|---|---|
| Title | Failure to Perform an Adequate 10 CFR 50.59 Evaluation for Procedure DOP 130002 |
| Description | The inspectors identified a NCV of 10 CFR 50.59, Changes, Tests and Experiments, when, on February 10, 2011, the licensee failed to complete a 10 CFR 50.59 evaluation when they revised procedure DOP 130002 to change the position of Motor Operated Valve (MOV) 213013, Reactor Inlet Isolation, such that the Isolation Condenser (IC) system would not meet its design requirement of removing 84.2E+06 BTUs in 20 minutes when initiated from its minimum Technical Specification(TS) level and maximum TS temperature. The inspectors determined that the licensees failure to identify that the valve position adjustment required a 10 CFR 50.59 evaluation was a performance deficiency. This finding was evaluated using traditional enforcement because it had the potential for impacting the NRCs ability to perform its regulatory function. This finding was more than minor because there was a reasonable likelihood that the change would have required NRC review and approval prior to implementation. Specifically, by establishing a new position setting of MOV 213013, the licensee failed to determine that the proposed change would cause isolation condenser tubes to become exposed in the design basis accident such that it adversely affected a Final Safety Analysis Report described design function, which required an evaluation to be performed. In accordance with IMC 0612, Appendix B, Issue Screening, traditional enforcement does apply as the violation impacted the regulatory process. Using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, Exhibit 2, Mitigating Systems Screening Questions, the issue screened as having very low safety significance (Green) because it was a design or qualification deficiency that did not represent a loss of the system and/or function, did not represent an actual loss of function of at least a single train for greater than its TS allowed outage time, and did not result in the actual loss of one or more trains of non-technical specification equipment. Inspectors assessed the violation in accordance with the Enforcement Policy, and determined it to be a Severity Level IV violation because it resulted in a condition evaluated by the SDP as having very low safety significance (Enforcement Policy example 6.1.d.2). This finding has a cross-cutting aspect of Design Margins [IMC 0310, H.6] in the area of human performance, for failing to carefully guard and maintain the IC design requirement of removing 84.2E+06 BTU in 20 minutes. |
| Site: | Dresden  |
|---|---|
| Report | IR 05000237/2014004 Section 1R15 |
| Date counted | Sep 30, 2014 (2014Q3) |
| Type: | TEV: Severity level IV |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.15 |
| Inspectors (proximate) | A Smith D Lords G Roach J Beavers J Cameron J Kutlesa J Laughlin S Barr |
| Violation of: | 10 CFR 50.59 Technical Specification - Procedures Technical Specification |
| CCA | H.6, Design Margins |
| INPO aspect | WP.2 |
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Finding - Dresden - IR 05000237/2014004 | |||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Dresden) @ 2014Q3
Self-Identified List (Dresden)
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