05000285/FIN-2016001-01
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Finding | |
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Title | Implementing a Procedure Change for Alternative Shutdown Cooling that would have Required NRC Approval |
Description | The inspectors identified a Severity Level IV non-cited violation of 10 CFR 50.59, Changes, Tests, and Experiments, for the failure to recognize that a change to the facility as described in the Updated Safety Analysis Report would require prior NRC review and approval. Specifically, the 10 CFR 50.59 evaluation revised a site procedure, without NRC approval, to substitute automatic flow control of shutdown cooling flow and temperature with manual control using the low pressure safety injection loop injection valves. The licensees corrective actions included revising the affected procedure to reflect the original automatic flow control. The licensee entered this issue in the corrective action program as Condition Report 2013-15342. The licensees failure to implement the requirements of 10 CFR 50.59 and adequately evaluate changes to determine if prior NRC approval is required was a performance deficiency. Because this violation had the potential to impact the NRCs ability to perform its regulatory function, the inspectors evaluated the violation using traditional enforcement. In accordance with Section 2.1.3.E.6 of the NRC Enforcement Manual, the team evaluated this finding using the significance determination process to assess its significance. The inspectors performed an initial screening of the finding in accordance with NRC Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated July 1, 2012. Using Inspection Manual Chapter 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions, dated July 1, 2012, the finding was determined to have very low safety significance (Green) because it: (1) was not a deficiency affecting the design or qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time; and (4) did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensees Maintenance Rule program. Therefore, in accordance with Section 6.1.d.2 of the NRC Enforcement Policy, the inspectors characterized this performance deficiency as a Severity Level IV violation. The inspectors determined that a cross-cutting aspect was not applicable because the issue involving the failure to perform an adequate 10 CFR 50.59 evaluation was strictly associated with a traditional enforcement violation. |
Site: | Fort Calhoun ![]() |
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Report | IR 05000285/2016001 Section 4OA3 |
Date counted | Mar 31, 2016 (2016Q1) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71153 |
Inspectors (proximate) | B Cummings C Roque-Cruz G George I Anchondo J Josey J Melfi P Elkmann R Hagar S Alferink S Janicki S Schneider |
Violation of: | 10 CFR 50.59 Technical Specification - Procedures Technical Specification |
INPO aspect | |
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Finding - Fort Calhoun - IR 05000285/2016001 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Fort Calhoun) @ 2016Q1
Self-Identified List (Fort Calhoun)
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