05000289/FIN-2009006-02
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Finding | |
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Title | Inadequate Decay Heat River Water Equipment |
Description | The team identified a Severity Level IV NCV of 10 CFR 50.59, Changes, Tests and Experiments, for the failure to obtain a license amendment pursuant to 10 CFR 50.90 prior to implementing a change to the components credited to be operable for the decay heat river system. The team reviewed a modification and associated safety evaluation that removed the internals of the decay heat river water strainer. Exelons 10 CFR 50.59 safety evaluation credited the operation of three nonsafety- related traveling screens to perform this strainers safety functions in order to allow the change to the facility without a license amendment. The team determined that because the screens were not safety-related structures, systems, or components, they could not be used to meet the system operability requirements as discussed in Technical Specification 3.3 Emergency Core Cooling, Reactor Building Emergency Cooling and Reactor Building Spray Systems. Use of these components would require a change to the TS, and, therefore, the 10 CFR 50.59 process screening should have determined the process cannot be used. Following identification of the issue Exelon performed an operability evaluation to ensure the system could respond to credited design basis events and performed an apparent cause evaluation to determine the cause of the performance deficiency. The failure to submit this change prevented the NRC from performing its regulatory function and the issue was evaluated under traditional enforcement guidance. The team determined that this issue was more than minor because there was a likelihood that the activity would have required NRC approval prior to implementation. The severity level of the violation was determined to be Severity Level IV because there was no willful aspect and the finding was determined to be of very low safety significance. The finding was determined to have a crosscutting aspect in Human Performance- Decision Making which states the licensee should use conservative assumptions in decision making and adopts a requirement to demonstrate that the proposed action is safe. (H.1(b)) |
Site: | Three Mile Island ![]() |
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Report | IR 05000289/2009006 Section 1R21 |
Date counted | Jun 30, 2009 (2009Q2) |
Type: | TEV: Severity level IV |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.21 |
Inspectors (proximate) | K Mangan W Sherbin D Orr S Kobylarz J Tifft L Doerflein P Mckenna |
CCA | H.14, Conservative Bias |
INPO aspect | DM.2 |
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Finding - Three Mile Island - IR 05000289/2009006 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Three Mile Island) @ 2009Q2
Self-Identified List (Three Mile Island)
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