05000331/FIN-2016004-02
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Finding | |
|---|---|
| Title | Inadequate Evaluation for a Change to the Low Pressure Coolant Injection Annunciator Response Procedure |
| Description | Severity Level IV. The inspectors identified a finding of very low safety significance (Green) and an associated Severity Level IV NCV of Title 10 of the Code of Federal Regulations (10 CFR), Part 50.59, Changes, Tests, and Experiments, when licensee personnel failed to perform an adequate written evaluation to demonstrate that a procedure change did not require a license amendment. Specifically, the licensee implemented a change to annunciator response procedure (ARP) 1C03B, Reactor and Containment Cooling and Isolation, that revised low pressure coolant injection (LPCI) system operability determination information which impacted the safety-related function of the LPCI system. The licensee entered the inspectors concerns into their corrective action program as condition report (CR) 02158897. Corrective actions included providing operating crew orders to preclude challenging the low pressure coolant injection systems function, performing a condition evaluation and revising the ARP. The inspectors determined the failure to provide an adequate evaluation that documented the basis for determining the change to ARP 1C03B did not require a license amendment was a performance deficiency. The performance deficiency was determined to be more than minor because it impacted the Mitigating System cornerstone attribute of procedure quality and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The finding was screened against the Mitigating Systems cornerstone and determined to be of very low safety significance because all of the associated questions in IMC 0609, Appendix A, were answered no. Violations of 10 CFR 50.59 are dispositioned using the traditional enforcement process because they are considered to be violations that potentially impede or impact the regulatory process. The inspectors reviewed Section 6.1.d.2 of the NRC Enforcement Policy and determined this violation was Severity Level IV because the resulting changes were evaluated by the Significance Determination Process (SDP) as having very low safety significance. The inspectors determined this finding affected the cross-cutting area of human performance, in the aspect of design margin, where margins are carefully guarded and changed only through a systematic and rigorous process. Specifically, the licensee made a decision to proceed with revising the annunciator response procedure using the results of a condition evaluation (a non-design basis document) in lieu of following their systematic and rigorous process for evaluating changes to the Updated Final Safety Analysis Report (UFSAR) [H.6]. |
| Site: | Duane Arnold  |
|---|---|
| Report | IR 05000331/2016004 Section 4OA2 |
| Date counted | Dec 31, 2016 (2016Q4) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71152 |
| Inspectors (proximate) | C Norton E Sanchez G Hansen J Cassidy J Steffes J Wojewoda K Stoedter V Myers |
| Violation of: | 10 CFR 50.59 |
| CCA | H.6, Design Margins |
| INPO aspect | WP.2 |
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Finding - Duane Arnold - IR 05000331/2016004 | |||||||||||||||||||||||||||||||||||||||||||
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Finding List (Duane Arnold) @ 2016Q4
Self-Identified List (Duane Arnold)
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