05000263/FIN-2011005-05
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Finding | |
|---|---|
| Title | Failure to Make a Required 60 Day Event Report Per 10 CFR 50.73(a)(2)(vii)(A-D) |
| Description | The inspectors identified a Severity Level IV NCV and associated finding of very low safety significance of 10 CFR 50.73(a)(2)(vii)(A-D), Licensee Event Report System, for the failure to report an event to the NRC within 60 days, where a single cause or condition caused two independent trains to become inoperable in a single system designed to help maintain safe reactor shut down, remove residual heat, control radioactive releases, or mitigate accidents. Specifically, on September 29, 2011, the licensee identified that the surveillance test procedures being used to demonstrate load reject capabilities of both EDGs had never contained the correct load rejection testing requirements from the applicable design documents. As a result, the surveillances were considered never met, and both EDGs were declared inoperable. During their evaluation and subsequent reporting of the issue, the licensee failed to recognize that the inoperability of both diesel generators caused by a single common cause was reportable to the NRC within 60 days under the 50.73 common cause criterion. The licensee entered this issue into their corrective action program (CAP 1318116). Corrective actions for this issue included plans to revise their existing licensee event report (LER) and to perform an apparent cause evaluation to further evaluate the issue. The inspectors determined that the failure to report required plant events or conditions to the NRC in accordance with reporting requirements was a performance deficiency because it was the result of the failure to meet a requirement or a standard, the cause was reasonably within the licensees ability to foresee and correct, and should have been prevented. In addition, it had the potential to impede or impact the regulatory process. As a result, the NRC dispositions violations of 10 CFR 50.73 using the traditional enforcement process instead of the SDP. However, if possible, the underlying technical issue is evaluated using the SDP. In this case, the inspectors determined that the licensee failed to develop and implement adequate Emergency Diesel Generator (EDG) testing procedures during their transition to the Improved Technical Specifications in 2006, which resulted in both EDGs being declared TS inoperable, but available for use. The inspectors determined that the performance deficiency was more than minor because it was associated with the Mitigating Systems Cornerstone attributes of Human Performance and Procedure Quality and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Using IMC 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings, the inspectors determined that the finding had very low safety significance because they answered No to all five questions contained in Column 2 of the Table 4a worksheet. As a result, the inspectors determined that the finding had very low safety significance (Green). In accordance with Section 6.9.d.9 and 6.9.d.10 of the NRC Enforcement Policy, this violation was categorized as Severity Level IV because it was an example where the licensee failed to make a report required by 10 CFR 50.73; it represented a failure to identify all applicable reporting codes on an LER that may impact the completeness or accuracy of other information submitted to the NRC; and the underlying technical issue was evaluated by the SDP and determined to be of very low safety significance. The inspectors determined that the contributing cause that provided the most insight into the performance deficiency affected the cross-cutting area of Problem Identification and Resolution, having corrective action program components, and involving aspects associated with properly classifying and evaluating for reportability conditions adverse to quality P.1(c). |
| Site: | Monticello  |
|---|---|
| Report | IR 05000263/2011005 Section 4OA3 |
| Date counted | Dec 31, 2011 (2011Q4) |
| Type: | TEV: Severity level IV |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71153 |
| Inspectors (proximate) | M Munir C Zoia K Riemer M Phalen K Stoedter S Thomas R Walton P Voss J Beavers S Bell |
| CCA | P.2, Evaluation |
| INPO aspect | PI.2 |
| Finding closed by | |
| IR 05000263/2011005 (1 February 2012) | |
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Finding - Monticello - IR 05000263/2011005 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Monticello) @ 2011Q4
Self-Identified List (Monticello)
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