05000261/FIN-2015001-01
From kanterella
Jump to navigation
Jump to search
Finding | |
|---|---|
| Title | Inadequate 10 CFR 50.59 Evaluation Results in RPI System Inoperability |
| Description | The inspectors identified a severity level IV (SLIV) non-cited violation (NCV) of 10 CFR 50.59, Changes, Tests, and Experiments, for the licensees failure to obtain a license amendment prior to implementing a change to licensee procedure OST-20, Shiftly Surveillances. Specifically, a note was added to procedure OST-20 to allow the use of the Emergency Response Facility Information System (ERFIS) as an acceptable alternate method to determine Analog Rod Positon Indication (ARPI) System operability if the position indicators were not indicating properly. This change resulted in an associated Green NCV of Technical Specification (TS) 3.1.7, Rod Position Indication, for failing to shut down the reactor or follow remedial actions permitted by a TS action requirement when a Limiting Condition for Operation (LCO) was not met. Upon determination that the practice of crediting ERFIS for rod position indication (RPI) operability was not allowed by the current licensing basis (CLB), Standing Instruction 14-023 was issued to suspend the practice and condition report (CR) 720726 was written to document the issue. The licensees failure to obtain a license amendment for a change that resulted in a change to technical specifications incorporated in the license was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the mitigating systems cornerstone attribute of procedure quality and adversely affected the objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the procedure change adversely impacted the availability and capability of systems to respond to a design basis event because it allowed the use of a non CLB method for determining rod position after failure of the ARPI system. Rod position indication is required to determine maximum rod misalignment which is an initial assumption in the safety analysis that directly affects core power distributions and assumptions of available shutdown margin. The finding was screened using IMC 0609 Appendix A Exhibit 2.C, Reactivity Control Systems, dated June 19, 2012, and was determined to be of very low safety significance (Green) because the finding did not result in a mismanagement of reactivity by operators. The violation was determined to be a SLIV violation using the Enforcement Policy example 6.1.d.2, because it resulted in a condition having very low safety significance. No cross-cutting aspect was assigned in association with the ROP finding because the change to the procedure was performed greater than three years ago and did not reflect current licensee performance. |
| Site: | Robinson  |
|---|---|
| Report | IR 05000261/2015001 Section 1R15 |
| Date counted | Mar 31, 2015 (2015Q1) |
| Type: | TEV: Severity level IV |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.15 |
| Inspectors (proximate) | C Scott G Hopper J Viera K Ellis M Meeks |
| Violation of: | 10 CFR 50.59 Technical Specification - Procedures Technical Specification |
| INPO aspect | |
| ' | |
Finding - Robinson - IR 05000261/2015001 | |||||||||||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
Finding List (Robinson) @ 2015Q1
Self-Identified List (Robinson)
| |||||||||||||||||||||||