05000315/FIN-2015004-03
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Finding | |
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| Title | Failure to Evaluate the Adverse Effects of TRM Section Deletion |
| Description | The inspectors identified a Severity Level (SL) IV NCV of 10 CFR 50.59(d)(1), Changes, Tests, and Experiments, with an associated finding of very low safety significance (Green), for the licensees failure to perform a written safety evaluation that provided the bases for the determination that the removal of Technical Requirements Manual (TRM) Section 8.4.3, ASME Code Class 1, 2, and 3 Components did not require a license amendment. TRM Section 8.4.3 directed the implementation of the Inservice Inspection (ISI) Program for ASME Class 1, 2, and 3 components and directed actions if nonconformances were discovered. The licensee had received a violation in 2014 for removing the same requirement via a 50.59 Evaluation. The inspectors reviewed the corrective actions for the previous violation. The licensee had restored the section via guidance to operators, revised the wording of the TRM section, and then subsequently deleted the section from the plants current licensing basis again via the 50.59 Screening process. The inspectors determined the licensee had incorrectly referenced NRC inspection guidance dealing with the operability of components when providing a basis for the deletion. Further, the operability determination process could result in less restrictive actions being taken for some degraded ASME components as compared to the TRM requirements. Therefore, the change should have received a 50.59 Evaluation. The licensee entered the issue into their CAP. The issue was more than minor because it adversely affected the Mitigating Systems Cornerstone. Specifically, a series of changes (which ultimately resulted in the deletion of TRM Section 8.4.3) had an adverse effect on component reliability given that required actions to address nonconformances within the ISI program were removed. In addition, violations of Title 10 of the Code of Federal Regulations (CFR) 50.59 are disposed using the traditional enforcement process in addition to the SDP because they are considered to be violations that potentially impede or impact the regulatory process. The associated traditional enforcement violation was determined to be more than minor because the inspectors could not reasonably determine if the changes would have ultimately required NRC prior-approval. The finding screened as Green, or very low safety significance, because there was no actual known loss of functionality of components. The traditional enforcement violation was categorized as SL IV because the associated finding screened as Green in the SDP. The inspectors determined that the finding had a cross-cutting aspect in the area of problem identification and resolution because the licensee did not take effective corrective action to address the issue. Specifically, the licensee received a previous finding for not evaluating the adverse effects of deleting TRM Section 8.4.3. As part of the corrective actions, the licensee revised and then deleted the TRM section; however, the resulting adverse effects were not recognized nor subsequently evaluated (P.3). |
| Site: | Cook  |
|---|---|
| Report | IR 05000315/2015004 Section 4OA2 |
| Date counted | Dec 31, 2015 (2015Q4) |
| Type: | TEV: Severity level IV |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71152 |
| Inspectors (proximate) | G Edwards J Ellegood J Mancuso K Riemer T Go T Taylor |
| Violation of: | 10 CFR 50.59 |
| INPO aspect | |
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Finding - Cook - IR 05000315/2015004 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Cook) @ 2015Q4
Self-Identified List (Cook)
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