05000315/FIN-2013002-03
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Finding | |
|---|---|
| Title | Licensee-Identified Violation |
| Description | The licensee identified a violation of 10 CFR 50.9, completeness and accuracy of information, for submitting a revised Emergency Action Level (EAL) scheme that was inaccurate in a material respect. While implementing the scheme, the licensee identified that CA7 and CS7 require indication of vessel level that is below the lowest measurement capability of installed instrumentation. Due to system configuration, NLI-1000, the reactor vessel level full range instrument, cannot measure below a level of 612.8 feet. This creates a condition where the instrument would indicate that vessel level remained at 612.8 even though inventory might be well below 612.8. Without that information, entry into CA7 or CS7 may not occur. After identifying the error, the licensee determined that a change to the EAL to conform to the as-configured plant could not be made without prior NRC approval. The licensee also discussed the condition with the NRC staff and provided a letter on October 26, 2012, regarding the error. The inspectors reviewed the information provided by the licensee and concluded that because the NRC approved the EAL and correction would require NRC approval, the erroneous information was material to the NRC and was a violation of 10 CFR 50.9. The inspectors reviewed the Enforcement Manual and Enforcement Policy and concluded that since the inaccurate information was identified after it was relied on to be accurate to approve the EAL scheme, enforcement action was warranted. Because the violation did not conform to any examples of Severity Level 1 through III, and there were no willful aspects, the inspectors determined that the violation was of Severity Level IV. Because the licensee identified the error, the inspectors concluded that the violation could be treated as a licensee identified NCV. The inspectors reviewed the issue under the Reactor Oversight Process and concluded that since the licensee had not implemented the inaccurate EALs and the EAL scheme in effect remained viable, there was no Reactor Oversight Process aspect to the issue. |
| Site: | Cook  |
|---|---|
| Report | IR 05000315/2013002 Section 4OA7 |
| Date counted | Mar 31, 2013 (2013Q1) |
| Type: | TEV: Severity level IV |
| cornerstone | Mitigating Systems |
| Identified by: | Licensee-identified |
| Inspection Procedure: | |
| Inspectors (proximate) | R Walton N Feliz P Laflamme M Phalen J Lennartz J Ellegood |
| Violation of: | 10 CFR 50.9 |
| INPO aspect | |
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Finding - Cook - IR 05000315/2013002 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Cook) @ 2013Q1
Self-Identified List (Cook)
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