05000255/FIN-2009002-02
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Finding | |
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Title | Failure to Implement Technical Specification |
Description | On February 20, 2009, the inspectors identified an NCV of Technical Specification (TS) 5.4, Procedures. Specifically, the licensee failed to revise procedures needed to implement TS amendment 236. Amendment 236 revised license requirements for storage of fuel in the Spent Fuel Pool (SFP) and was prepared, in part, pursuant to Confirmatory Action Letter (CAL) RIII-08-003. The licensee notified the NRC via letter on February 11 that the amendment had been implemented. During review of licensee actions to lift the CAL, the inspectors identified that the licensee had not revised affected procedures. The licensee entered the issue into their corrective action program(CAP) and revised procedures prior to adding new fuel to the pool. The inspectors determined that the failure to revise affected procedures prior to implementation of the TS amendment was more than minor because it is associated with the Procedure Quality attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective of limiting the likelihood of an initiating event. Specifically, the criticality analysis relies on geometric controls to maintain the effective neutron multiplication factor (Keff) below one and the procedures ensure the controls are in place. Because the licensee did not load any fuel to a location prohibited by the TS, the finding is not of more than very low safety significance. The inspectors determined the finding included a cross-cutting aspect in the area of human performance, work control, coordination of work activities (H.3.(b)). Specifically, during implementation of the amendment, the licensee failed to coordinate between licensing, operations and engineering to ensure all procedures affected by the change were reviewed and revised where needed. (4OA5 |
Site: | Palisades |
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Report | IR 05000255/2009002 Section 4OA5 |
Date counted | Mar 31, 2009 (2009Q1) |
Type: | NCV: Green |
cornerstone | Initiating Events |
Identified by: | NRC identified |
Inspection Procedure: | |
Inspectors (proximate) | N Valos J Ellegood J Giessner T Taylor |
CCA | H.5, Work Management |
INPO aspect | WP.1 |
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Finding - Palisades - IR 05000255/2009002 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Palisades) @ 2009Q1
Self-Identified List (Palisades)
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