05000289/FIN-2014002-01
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Finding | |
|---|---|
| Title | Failure to Perform a 10 CFR 50.59 Evaluation for the BWST Seismic Qualifications |
| Description | The inspectors identified a Severity Level IV (SL-IV), Non-Cited Violation of 10 CFR 50.59, Changes, Tests, and Experiments, and an associated finding of very low safety significance (Green) for Exelons failure to perform a 50.59 evaluation review to determine whether a license amendment was required to align the borated water storage tank (BWST) to non-seismic piping. Specifically, Exelon staffs 50.59 screening accepted the alignment of the seismically qualified BWST to a non-seismically qualified clean-up system. The inspectors determined the alignment would involve a change to the BWST that adversely affects its Updated Final Safety Analysis Report chapter 5.1.1, Classes of Structures and Systems for Seismic Design, described design function of being seismically qualified. Additionally, the inspectors determined that following the 50.59 review Exelon placed the line-up in service. The inspectors determined these two actions were performance deficiencies that were reasonably within Exelons ability to foresee and prevent. Furthermore, the 50.59 screening credited unapproved operator manual actions to ensure functionality of the BWST. Exelon documented this as issue report 1631468 and implemented interim corrective actions to isolate the BWST from the clean-up system until a permanent resolution is determined and implemented. The inspectors determined the 50.59 violation regarding the failure to perform an evaluation was more than minor because the inspectors could not reasonably determine that the alignment would not have ultimately required NRC prior approval, because the BWST alignment was not in accordance with the current licensing basis and the evaluation credited the use of unapproved operator manual actions. The inspectors also determined that the performance deficiency of accepting and aligning the adverse clean-up line-up, challenging the BWST seismic qualification, was more than minor because it adversely affected the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors evaluated the finding using IMC 0609, Attachment 4, Initial Characterization of Findings, and Appendix A, The Significance Determination Process for Findings At-Power, and determined that this finding required a detailed risk evaluation. The detailed evaluation was performed which determined that the performance deficiency was a finding of very low safety significance (Green). Additionally, In accordance with Section 6.1.d.2 of the NRC Enforcement Policy, the 50.59 violation is categorized as a Severity Level IV. This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Operating Experience, in that the station did not effectively evaluate and internalize relevant external operating experience (Information Notice (IN) 2012-01) regarding connections between safety-related seismic and non-seismic qualified piping and components. |
| Site: | Three Mile Island  |
|---|---|
| Report | IR 05000289/2014002 Section 1R04 |
| Date counted | Mar 31, 2014 (2014Q1) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.04 |
| Inspectors (proximate) | D Werkheiser H Gray J Cruz J Heinly J Krafty J Kulp K Mangan R Rolph S Kennedyc Cahilld Werkheiser E Burket J Heinly K Mangan R Rolph S Barr T O'Hara W Cook |
| Violation of: | 10 CFR 50.59 |
| CCA | P.5, Operating Experience |
| INPO aspect | CL.1 |
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Finding - Three Mile Island - IR 05000289/2014002 | |||||||||||||||||||||||||||||||
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Finding List (Three Mile Island) @ 2014Q1
Self-Identified List (Three Mile Island)
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