05000277/FIN-2009004-01
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Finding | |
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| Title | Failure to Perform a 50.59 Review Prior to Installing Jumpers on E Wrnm |
| Description | An inspector-identified, Severity Level IV NCV of 10 CFR 50.59 was identified when PBAPS made temporary alterations to their facility to address a degradedcondition without performing a 50.59 review. Specifically, PBAPS installed a jumper that bypassed the trip feature of the Unit 3 \'E\' wide-range neutron monitoring (WRNM) system instead of using the WRNM bypass switch as is described in their plant\'s Final Safety Analysis Report (FSAR). Exelon entered this issue into their CAP and the jumper was subsequently removed restoring the original system configuration. Because this was a violation of 10 CFR 50.59, it was considered a violation that potentially impeded or impacted the regulatory process; therefore, this violation was dispositioned using the traditional enforcement process. This finding was more than minor because there was a reasonable possibility that the change requiring a 10 CFR 50.59 Safety Evaluation (SE) would require NRC review and approval prior to implementation in accordance with 10 CFR 50.59(c)(2). This possibility is based on the likelihood that a second WRNM could be bypassed, with the bypass switch built into the WRNM system, without resulting in a trip of the associated reactor protection system (RPS). This condition would be contrary to the design of the WRNM and RPS, thereby . creating the possibility for a malfunction of a structure, system, and component (SSC) important to safety with a different result than any previously evaluated in the FSAR (as updated). Although the SOP is not designed to assess traditional enforcement violations, the NRC assesses the significance of 10 CFR 50.59 violations through the SOP for risk insights. Accordingly, the inspectors evaluated the finding in accordance with IMC 0609, SOP, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings, Table 4a, for the Mitigating Systems cornerstone. The issue, associated with the installation of the one jumper, was determined to be of very low safety significance (Green) since the issue was determined to be a qualification issue confirmed not to result in loss of operability of the system. This violation involved a facility change that likely would have required a license amendment before its implementation. Comparing this item to the examples in NRC Enforcement Policy, Supplement I, Reactor Operations, this finding is similar to Item 0.5, Violations of 10 CFR 50.59 that result in conditions evaluated as having very row safety significance (i.e., Green) by the SOP. This is a Severity Level IV violation. Additionally, this finding was determined to have a crosscutting aspect in the area of Human Performance, Decision Making component, which states the licensee should use conservative assumptions in decision making and adopt a requirement to demonstrate that the proposed action is safe. Specifically, Exelon did not perform a 10 CFR 50.59 safety evaluation or screening when making a temporary alteration to the RPS system which would be installed for the remainder of the operating cycle |
| Site: | Peach Bottom  |
|---|---|
| Report | IR 05000277/2009004 Section 1R18 |
| Date counted | Sep 30, 2009 (2009Q3) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.18 |
| Inspectors (proximate) | M Brown S Barr P Finney R Nimitz F Bower A Ziedonis P Krohn J Commisky |
| CCA | H.14, Conservative Bias |
| INPO aspect | DM.2 |
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Finding - Peach Bottom - IR 05000277/2009004 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Peach Bottom) @ 2009Q3
Self-Identified List (Peach Bottom)
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