05000255/FIN-2016009-01
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Finding | |
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| Title | Failure to Document 50.59 Evaluation for Removal of Eight Hour Operator Rounds from the FSAR |
| Description | The inspectors identified a Severity Level IV, Non-Cited Violation of Title 10 of the Code of Federal Regulations (CFR), Part 50.59, Changes, Tests, and Experiments, and an associated finding of very low safety significance (Green) for the licensees failure to maintain records of a change in the facility which included a written evaluation that provided the bases for the determination that the change did not require a license amendment. Specifically, the licensee failed to have a written evaluation that provided the bases for why removal of the 8-hour operator rounds credited to detect a Spent Fuel Pool (SFP) dilution event from the Final Safety Analysis Report did not require a license amendment. The licensee entered this issue into their Corrective Action Program (CAP) as CR-PLP-2016-03055 and issued a standing order to log SFP level every eight hours as an immediate corrective action. The licensees planned corrective actions include preparation of a 10 CFR 50.59 evaluation for the change. The inspectors determined that the failure to perform a 10 CFR 50.59 evaluation for the change to the Final Safety Analysis Report which removed the eight hour operator rounds credited to detect a SFP dilution event was contrary to 10 CFR 50.59(d)(1), and was a performance deficiency. The inspectors determined the performance deficiency was more than minor, and a finding, because it was associated with the barrier integrity cornerstone attribute of Configuration Control and adversely affected the associated Cornerstone Objective of ensuring that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the removal of the 8-hour operator rounds is associated with the boron concentration reactivity control in the SFP and could adversely affect the fuel claddings function to protect the public from radionuclide releases. In addition, the associated violation was determined to be more-than-minor because the inspectors could not reasonably determine that the changes would not have ultimately required NRC prior approval. The inspectors evaluated the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings at Power, dated June 19, 2012, Exhibit 3, for the Barrier Integrity cornerstone and were directed to further evaluate the significance of the finding using IMC 0609 Appendix M, Significance Determination Process Using Qualitative Criteria, dated April 12, 2012. The inspectors performed the qualitative evaluation described in IMC 0609, Appendix M, and determined the significance of the finding to be of very low safety significance (Green) by considering the availability of other measures the licensee had in place to detect a SFP dilution event. In accordance with Section 6.1.d of the NRC Enforcement Policy this violation is categorized as Severity Level IV because the resulting changes were evaluated by the SDP as having very-low safety significance (i.e., Green finding). The inspectors determined the associated finding had a cross-cutting aspect in the area of Human Performance because the licensee did not ensure their staff were adequately trained in the implementation of the 10 CFR 50.59 rule. Specifically, the licensee staff did not realize that a change which fundamentally alters the existing means of performing or controlling design functions (removal of the 8-hour operator rounds for detecting a SFP dilution event in lieu of an automatic alarm) is adverse and requires an evaluation. |
| Site: | Palisades  |
|---|---|
| Report | IR 05000255/2016009 Section 1R17 |
| Date counted | Sep 30, 2016 (2016Q3) |
| Type: | NCV: Green |
| cornerstone | Barrier Integrity |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.17 |
| Inspectors (proximate) | A Shaikh I Khan L Rodriguez V Petrella |
| Violation of: | 10 CFR 50.59 |
| CCA | H.9, Training |
| INPO aspect | CL.4 |
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Finding - Palisades - IR 05000255/2016009 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Palisades) @ 2016Q3
Self-Identified List (Palisades)
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