05000263/FIN-2014009-06
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Finding | |
|---|---|
| Title | Failure to Perform a Written Safety Evaluation |
| Description | 10 CFR 50.59(d)(1) required, in part, that the licensee maintain records of changes to the facility, of changes in procedures, and of tests and experiments made pursuant 10 CFR 50.59(c). These records must include a written evaluation which provides the bases for the determination that the change, test, or experiment does not require a license amendment pursuant to Paragraph (c)(2) of this section. 10 CFR 50.59(c)(2)(ii) required that a licensee shall obtain a license amendment pursuant to 10 CFR 50.90 prior to implementing a proposed change, test, or experiment if the change, test, or experiment would result in more than a minimal increase in the likelihood of occurrence of a malfunction of a structure, system, or component important to safety previously evaluated in the FSAR (as updated). Contrary to the above, on or about January 30, 2012, the licensee failed to perform and maintain a written evaluation as required by 10 CFR 50.59(d)(1) to demonstrate a change to its facility did not require a license amendment. Specifically, the licensee incorrectly concluded no 10 CFR 50.59 evaluation was required prior to implementing EC 19415, Berm Construction for A.6, Acts of Nature, and Procedure A.6, Acts of Nature, Revision 41 based on screening SCR120027. Therefore, an evaluation was not performed and without an evaluation the licensee could not have ascertained if a license amendment would have been required for this change as required by Section (c)(2)(ii). Specifically, the NRC determined the external flooding mitigation plan implemented by the licensee was unable to mitigate the consequences of the design basis PMF. In accordance with Section 6.1.c.6 of the NRC Enforcement Policy, this violation was classified as a Severity Level III Violation. The licensee entered this issue into its corrective action program as CAP 01399840 and implemented appropriate corrective actions. NRC Enforcement Policy Section 3.3, Violations Identified Because of Previous Enforcement Action, states in part, The NRC may refrain from issuing an NOV or a proposed civil penalty for a Severity Level II, III, or IV Violation that is identified after the NRC has taken enforcement action, if the violation is identified by the licensee as part of the corrective action for the previous enforcement action and the violation has the same or similar root cause as the violation for which enforcement action was previously taken. In this case, the issue was identified by the licensee after the NRC had already taken enforcement action for another related violation evaluated as having substantial safety significance by the SDP. The previous violation was documented in NRC Inspection Report 05000263/2013009 on August 29, 2013. As part of the corrective action for the previous enforcement action, the licensee documented the incorrect 10 CFR 50.59 screening in its CAP and implemented appropriate corrective actions. Therefore, in accordance with the NRC Enforcement Policy, and after consultation with the Director of the Office of Enforcement and the Region III Regional Administrator, the NRC has decided to exercise enforcement discretion in accordance with Section 3.3 of the NRC Enforcement Policy and to refrain from issuing enforcement action for the violation. In accordance with the NRCs Reactor Oversight Process, this condition will not be considered in the assessment process or the NRCs Action Matrix. |
| Site: | Monticello  |
|---|---|
| Report | IR 05000263/2014009 Section 4OA4 |
| Date counted | Dec 31, 2014 (2014Q4) |
| Type: | Violation: Severity level Enforcement Discretion |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 95002 |
| Inspectors (proximate) | B Kemker G Hansen J Corujo-Sandin J Rutkowski K Riemer M Ziolkowski P Voss R Edwards P Chaput W Wang |
| Violation of: | 10 CFR 50.59 10 CFR 50.90 |
| INPO aspect | |
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Finding - Monticello - IR 05000263/2014009 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Monticello) @ 2014Q4
Self-Identified List (Monticello)
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