05000277/FIN-2009002-03
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Finding | |
|---|---|
| Title | Departure from a Method of Evaluation without Prior NRC Approval |
| Description | An inspector-identified, Severity Level IV NCV of 10 CFR 50.59 was identified when PBAPS made a safety analyses change that departed from a method of evaluation described in the UFSAR without obtaining prior NRC approval and a license amendment. Specifically, PBAPS used a spent fuel pool criticality analysis methodology that was not previously approved by the NRC, and did not adopt an NRC-approved methodology en toto and apply it consistent with applicable terms, conditions, and limitations of that methodology. Corrective actions for this problem included entering the issue into the CAP and making plans to develop a technical evaluation that would demonstrate, using methodologies approved for PBAPS, that adequate margin to criticality exists for the nonconforming condition presented by degraded Boraflex in the SFP storage racks. Additionally, PBAPS submitted a LAR, to use alternative SFP criticality analyses, to the NRC on June 25, 2008. This deficiency was evaluated using the traditional enforcement process since it potentially impacts or impedes the NRCs ability to carry out its regulatory mission, in that, PBAPS did not request and receive prior NRC approval for changes in licensed activities. The finding is more than minor and a Severity Level IV violation because it is similar to example D.5 of Supplement I, Reactor Operations, to the NRCs Enforcement Policy. Specifically, the finding involved a violation of 10 CFR 50.59that resulted in conditions evaluated as having very low safety significance (i.e., Green) by the SDP. Using the Phase 1 SDP, the inspectors determined that the condition resulting from the violation of 10 CFR 50.59 screened to Green because it could affect the functionality of the fuel barrier (cladding) |
| Site: | Peach Bottom  |
|---|---|
| Report | IR 05000277/2009002 Section 1R18 |
| Date counted | Mar 31, 2009 (2009Q1) |
| Type: | NCV: Green |
| cornerstone | Barrier Integrity |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.18 |
| Inspectors (proximate) | M Brown G Johnson R Fuhrmeister F Bower J Tomlinson P Krohn E Torres |
| INPO aspect | |
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Finding - Peach Bottom - IR 05000277/2009002 | |||||||||||||||||||||||||||||||||||||
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Finding List (Peach Bottom) @ 2009Q1
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