05000298/FIN-2014002-03
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Finding | |
|---|---|
| Title | Failure to Evaluate Changes to Ensure They Did Not Require Prior Approval |
| Description | Inspectors identified a non-cited violation of 10 CFR 50.59, Changes, Test, and Experiments, and associated Green finding, associated with the licensees failure to adequately evaluate changes to determine if prior NRC approval is required. Specifically, from 1987 through February 11, 2014, the licensee failed to obtain a license amendment pursuant to Section 50.90 prior to implementing a proposed change that would result in a departure from a method of evaluation described in the Updated Safety Analysis Report. This does not represent an immediate safety concern because the licensee performed an operability assessment for the potentially undersized expansion anchors, which established a reasonable expectation for operability pending resolution of the identified issue. The licensee entered this deficiency into their corrective action program as Condition Report CR-CNS-2014-00776. 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 performance deficiency had the potential to impact the NRCs ability to perform its regulatory function, inspectors evaluated the performance deficiency using traditional enforcement. In accordance with Section 2.1.3.E.6 of the NRC Enforcement Manual, inspectors evaluated this finding using the significance determination process to assess its significance. Using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 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-ofservice for longer than their technical specification allowed outage time; (4) did not represent an actual loss of function of one or more nontechnical specification trains of equipment designated as high safety-significance in accordance with the licensees maintenance rule program; and (5) did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding, or severe weather event. Therefore, in accordance with Section 6.1.d.2 of the NRC Enforcement Policy, inspectors characterized this performance deficiency as a Severity Level IV violation. There was no cross-cutting aspect assigned to this finding because this issue does not reflect present licensee performance. |
| Site: | Cooper  |
|---|---|
| Report | IR 05000298/2014002 Section 4OA2 |
| Date counted | Mar 31, 2014 (2014Q1) |
| Type: | NCV: Green |
| cornerstone | Other |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71152 |
| Inspectors (proximate) | C Henderson D Allen J Josey P Elkmann |
| Violation of: | 10 CFR 50.59 Technical Specification |
| INPO aspect | |
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Finding - Cooper - IR 05000298/2014002 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Cooper) @ 2014Q1
Self-Identified List (Cooper)
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