05000335/FIN-2015007-01
From kanterella
Jump to navigation
Jump to search
Finding | |
|---|---|
| Title | Failure to Submit a License Amendment Request for Unit 1 RPS |
| Description | An NRC-identified severity level IV (SL IV) non-cited violation (NCV) of 10 CFR 50.59(c)(2)(ii) and an associated finding of very low safety significance (Green) was identified for the licensees failure to obtain a license amendment prior to implementing a change to the Unit 1 reactor protective system (RPS). The failure to obtain a license amendment for the change resulted in the implementation of a modification that did not conform with the licensees current licensing basis. The licensees failure to obtain NRC approval prior to implementing the change to the Unit 1 RPS was determined to impact the regulatory process because the change required NRC review and approval prior to implementation. The licensee entered this issue into their corrective action program as action requests (ARs) 2029652 and 2030820, planned to restore the RPS configuration into conformance, and performed a prompt operability determination which concluded that there was a reasonable expectation that the RPS channels remained operable and could perform their required design basis functions. The performance deficiency was determined to be more than minor because it was associated with the design control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the modification did not ensure the reliability of the RPS to respond to a design basis event because the design requirements for physical separation of RPS channels A and C were not met and resulted in a condition where revision or rework would be required to resolve the physical separation concerns. The team determined the finding to be of very low safety significance (Green) because the finding did not affect a single RPS trip signal to initiate a reactor scram and the function of other redundant trips or diverse methods of reactor shutdown, did not involve control manipulations that unintentionally added positive reactivity, and did not result in a mismanagement of reactivity by operators. The traditional enforcement violation was evaluated using the NRC Enforcement Policy dated January 28, 2013, and revised February 4, 2015. The inspectors determined the violation was SL IV per Section 6.1.d.2 because the associated finding was evaluated by the SDP as having very low safety significance (i.e., Green). The inspectors determined the finding was indicative of present licensee performance and was associated with the cross-cutting aspect of change management, in the area of human performance, because the licensee did not use a systematic process for evaluating and implementing a change such that nuclear safety remained the overriding priority. |
| Site: | Saint Lucie  |
|---|---|
| Report | IR 05000335/2015007 Section 1R17 |
| Date counted | Mar 31, 2015 (2015Q1) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.17 |
| Inspectors (proximate) | G Ottenberg J Bartley M Orr M Riley S Herrick |
| Violation of: | 10 CFR 50.59 |
| CCA | H.3, Change Management |
| INPO aspect | LA.5 |
| ' | |
Finding - Saint Lucie - IR 05000335/2015007 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
Finding List (Saint Lucie) @ 2015Q1
Self-Identified List (Saint Lucie)
| ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||