05000327/FIN-2012002-04
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Finding | |
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| Title | Inadequate 10 CFR 50.59 Evaluation for Implementation of Manual Actions to Cool RHR Suction Piping During a Mode 4 Loss of Coolant Accident |
| Description | The inspectors identified a Severity Level IV (SL-IV) non-cited violation (NCV) of 10 CFR 50.59, Changes, Tests, and Experiments, for the licensees failure to obtain a license amendment pursuant to 10 CFR 50.90 prior to implementing local operator manual action (OMA) changes to Technical Specifications (TS) Bases 3.5.3 and abnormal operating procedure (AOP)-R.02 that were specified in Engineering Document Change (EDC) 22487. The 10 CFR 50.59 performed to support EDC 22487 was inadequate in that the 50.59 did not identify that prior NRC approval was required for implementation of the changes. Specifically, the licensee revised AOPR. 02, Shutdown LOCA, and TS Bases 3.5.3, ECCS - Shutdown, to include OMAs to cool the residual heat removal (RHR) system suction piping as part of RHR realignment to establish emergency core cooling system (ECCS) flow in the event of a loss-of-coolant-accident (LOCA) while RHR was aligned to the reactor coolant system for shutdown cooling in operational Mode 4. The new OMAs added for cooling the RHR suction piping had, in effect, changed the intent of the note in TS limiting condition for operation 3.5.3, and were beyond the scope of what the NRC had previously reviewed and approved in Technical Specification Change 07-05. The licensee entered this issue into the corrective action program as problem evaluation report 535471. The finding was determined to be more than minor because prior NRC review and approval was required before changing the AOP and the TS Bases to include the OMAs for cooling the RHR suction piping as part of ECCS realignment in the event of a Mode 4 LOCA. The inspectors reviewed this issue, in accordance with Inspection Manual Chapter 0612 and the NRC Enforcement Policy, and determined that traditional enforcement was applicable to this issue because it impacted the ability of the NRC to perform its regulatory oversight function. 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 inspectors determined that this finding was of very low safety significance because, since implementation of EDC 22487, the OMAs to cool the RHR suction piping would not have been required if a LOCA had occurred during the times that RHR shutdown cooling was in service in Mode 4. The finding was reviewed by NRC management and because the violation was determined to be of very low safety significance, was not willful or repetitive, 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. The violation was not screened for associated cross-cutting aspects because it involved traditional enforcement. |
| Site: | Sequoyah  |
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| Report | IR 05000327/2012002 Section 1R17 |
| Date counted | Mar 31, 2012 (2012Q1) |
| Type: | TEV: Severity level IV |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.17 |
| Inspectors (proximate) | M Thomas C Young M Speck B Collins A Vargas P Braxton A Alen W Deschaine S Shaeffer |
| INPO aspect | |
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Finding - Sequoyah - IR 05000327/2012002 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Sequoyah) @ 2012Q1
Self-Identified List (Sequoyah)
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