05000298/FIN-2011002-05
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Finding | |
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Title | Failure to Notify the NRC within Eight Hours of a Nonemergency Event |
Description | The inspectors identified a Severity Level IV noncited violation of 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors, for the licensees failure to notify the NRC Operations Center within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> following discovery of an event meeting the reportability criteria as specified. Specifically, on January 18, 2011, while the B train of residual heat removal was inoperable for scheduled maintenance the A train experienced a fault which rendered it inoperable for its low pressure coolant injection function. As a result, both trains of residual heat removal were incapable of performing their system specified safety function of residual heat removal. The licensees evaluation of this condition determined that it was not a reportable event because both core spray pumps were operable and the D residual heat removal pump was available therefore the overall function of decay heat removal was maintained. The inspectors questioned this rational, because the apparent intent of the reporting criteria as described in NUREG 1022, Event Reporting Guidelines 50.72 and 50.73, Revision 2, section 3.2.7, was to cover an event or condition where structures, components, or trains of a safety system could have failed to perform their intended safety function as described in the plant safety analysis. Consultation with the Office of Nuclear Reactor Regulation determined that this was the intent of the criteria. As such, the inspectors determined that the licensee had failed to make a non-emergency 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> report as required by 10 CFR 50.72(b)(3)(v). The licensee submitted the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> report on January 21, 2011 and entered this issue into the corrective action program as Condition Report CR-CNS-2011-0618. The failure to make an applicable non-emergency 8-hour event notification report within the required time frame was determined to be a performance deficiency. The inspectors reviewed this issue in accordance with NRC Inspection Manual Chapter 0612 and the NRC Enforcement Manual. Through this review, the inspectors determined that traditional enforcement was applicable to this issue because the NRC\'s regulatory ability was affected. Specifically, the NRC relies on the licensees to identify and report conditions or events meeting the criteria specified in regulations in order to perform its regulatory function; and when this is not done, the regulatory function is impacted. The inspectors determined that this finding was not suitable for evaluation using the significance determination process, and as such, was evaluated in accordance with the NRC Enforcement Policy. The finding was reviewed by NRC management and because the violation was determined to be of very low safety significance, was not repetitive or willful, and was entered into the corrective action program, this violation is being treated as a Severity Level IV noncited violation consistent with the NRC Enforcement Policy. This finding had a crosscutting aspect in the area of human performance associated with the decision making component, in that, the licensee failed to use conservative assumptions in their decision making H.1(b) (Section 4OA3). |
Site: | Cooper |
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Report | IR 05000298/2011002 Section 4OA3 |
Date counted | Mar 31, 2011 (2011Q1) |
Type: | TEV: Severity level IV |
cornerstone | Miscellaneous |
Identified by: | NRC identified |
Inspection Procedure: | IP 71153 |
Inspectors (proximate) | M Chambers T Farina V Gaddy C Steely G George J Josey |
CCA | H.14, Conservative Bias |
INPO aspect | DM.2 |
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Finding - Cooper - IR 05000298/2011002 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Cooper) @ 2011Q1
Self-Identified List (Cooper)
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