05000271/FIN-2014004-02
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Finding | |
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| Title | Failure to Submit Reactor Building Crane Digital Control System Modification for Approval |
| Description | The inspectors identified a finding of very low safety significance (Green) and an associated Severity Level IV NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50.59, Changes, Tests and Experiments, when Entergy made changes to the reactor building crane that resulted in more than a minimal increase in the likelihood of occurrence of a malfunction of a structure, system, or component (SSC) important to safety previously evaluated in the Updated Final Safety Analysis Report (UFSAR). Specifically, Entergy did not recognize that they had removed redundancy from the control system needed to qualify the crane as single-failure proof. Entergy entered this issue into their corrective action program as condition report (CR)-VTY-2014-03028 and completed modifications to the crane that restored the independence of the redundant upper travel limits. The inspectors determined that the finding was more than minor because the change would have required NRC review and approval in order to qualify the crane as single-failure proof. Additionally, this finding was associated with the design control attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective of providing reasonable assurance that physical design barriers (e.g. fuel cladding) protect the public from radionuclide releases caused by accidents or events. Specifically, the design change increased the likelihood of a heavy load drop, which could have impacted the fuel in the spent fuel pool. This issue impeded the ability of the NRC to perform its regulatory oversight function because the failure to follow the requirements in 10 CFR 50.59 resulted in Entergy not submitting the change to the NRC for approval. Therefore, the enforcement aspects of this finding were processed using the Traditional Enforcement process. This violation is associated with a finding that has been evaluated by the SDP and communicated with an SDP color reflective of the safety impact of the deficient licensee performance. The SDP, however, does not specifically consider the regulatory process impact. Thus, although related to a common regulatory concern, it is necessary to address the violation and finding using different processes to correctly reflect both the regulatory importance of the violation and the safety significance of the associated finding. The inspectors evaluated this finding using IMC 0609, Attachment 4, Initial Characterization of Findings. The inspectors determined that the finding affected the Barrier Integrity cornerstone and evaluated the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 3, Barrier Integrity Screening Questions. The inspectors determined the finding was of very low safety significance (Green) because the crane was not operated over the spent fuel pool, nor was there an actual load drop. Per Subsection d.2 of Section 6.1, Reactor Operations, of the NRC Enforcement Policy, this is a Severity Level IV violation, because it is a 10 CFR 50.59 violation that results in conditions evaluated as having very low safety significance by the SDP. This finding has a cross-cutting aspect in the area of Human Performance, Avoid Complacency, because Entergy did not avoid complacency on the review of this design by recognizing and planning for the possibility of latent issues. The 50.59 screening was not reviewed to ensure it fully captured the final design from the vendor, and as a result, the vulnerability introduced by the digital controller was not considered. |
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
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| Report | IR 05000271/2014004 Section 1R18 |
| Date counted | Sep 30, 2014 (2014Q3) |
| Type: | NCV: Green |
| cornerstone | Barrier Integrity |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.18 |
| Inspectors (proximate) | E Burket J Schoppy N Day N Floyd R Mckinley S Barr S Rich S Rutenkroger T Fish T O'Hara |
| Violation of: | 10 CFR 50.59 |
| CCA | H.12, Avoid Complacency |
| INPO aspect | QA.4 |
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Finding - Vermont Yankee - IR 05000271/2014004 | |||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Vermont Yankee) @ 2014Q3
Self-Identified List (Vermont Yankee)
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