05000334/FIN-2013003-01
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Finding | |
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Title | Failure to Perform a Written Evaluation as Required by 50.59 |
Description | The inspectors identified a Severity Level (SL) IV NCV of 10 CFR 50.59, Changes, Tests and Experiments, and associated Green finding because FENOC did not perform a written 10 CFR 50.59 evaluation to support the adequacy of an abnormal operating procedure (AOP) for response to a security threat. Specifically, FENOC did not adequately implement the requirements of 10 CFR 50.59 and procedure NOBP-LP-4003A, FENOC 10 CFR 50.59 User Guidelines for procedure 1/2OM- 53C.4A.100.1 Security Threat Procedure. This procedure prescribed steps to exceed the reactor coolant system (RCS) maximum cooldown rate as described in the updated final safety analysis report (UFSAR) and technical specifications (TS) without a written evaluation supporting the adequacy of the AOP. FENOC generated CR-2013-06122, 06382, and 07557. FENOC revised the abnormal operating procedure (AOP) to comply with TS as part of the immediate corrective actions. The inspectors evaluated the performance deficiency using traditional enforcement in conjunction with the significance determination process (SDP) because the performance deficiency had the potential to impact the regulatory process. The finding is more than minor because if left uncorrected, could have the potential to lead to a more significant safety concern. Specifically, if the procedure were implemented during a security event, FENOC would exceed cooldown rates assumed in the UFSAR accident analyses, potentially challenging the integrity of the RCS. In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 1 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, the inspectors determined that this finding is of very low safety significance (Green) because the performance deficiency represented a transient initiator that would not cause a reactor trip and loss of mitigation equipment relied upon to transition the plant from the onset of a trip to a stable shutdown condition. Additionally, in accordance with Section 6.1.d.2 of the NRC Enforcement Policy, this violation is categorized as an SL IV because the resulting conditions were evaluated as having very low safety significance (Green) by the SDP. This finding has a cross-cutting aspect in the area of Human Performance, Work Practices because FENOC did not implement its regulatory applicability process which erroneously concluded that 50.59 was not applicable to implementation of procedure 1/2OM-53C.4A.100.1. Although the performance deficiency occurred in 2005, the inspectors determined this performance deficiency is indicative of current performance because subsequent revisions of 1/2OM-53C.4A.100.1 and 100.2 (the most recent revision implemented on December 12, 2012) did not identify the failure to adequately implement the 10 CFR 50.59 User Guidelines. |
Site: | Beaver Valley |
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Report | IR 05000334/2013003 Section 1R11 |
Date counted | Jun 30, 2013 (2013Q2) |
Type: | NCV: Green |
cornerstone | Initiating Events |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.11 |
Inspectors (proximate) | D Kern D Spindler E Carfang G Hunegs J Kulp N Floyd P Kaufman T Moslak T Ziev |
Violation of: | 10 CFR 50.59 Technical Specification - Procedures Technical Specification |
CCA | H.8, Procedure Adherence |
INPO aspect | WP.4 |
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Finding - Beaver Valley - IR 05000334/2013003 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Beaver Valley) @ 2013Q2
Self-Identified List (Beaver Valley)
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