05000336/FIN-2014011-01
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Finding | |
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| Title | Failure to Complete a 10 CFR 50.59 Evaluation for Removal of SLOD |
| Description | The NRC identified a Severity Level III AV of Title 10 of the Code of Federal Regulations (10 CFR) 50.59, Changes, Tests, and Experiments, for Dominions failure to complete a 10 CFR 50.59 evaluation and obtain a license amendment for a change made to the facility as described in the Updated Final Safety Analysis Report (UFSAR). Specifically, Dominion removed a special protection system (SPS), known as severe line outage detection (SLOD), which was described in the UFSAR. Dominion concluded in the 10 CFR 50.59 screening that a full 10 CFR 50.59 evaluation was not required and, therefore, prior NRC approval was not needed to implement this change. The team concluded that prior NRC approval likely was required because the removal of SLOD may have resulted in more than a minimal increase in the likelihood of occurrence of a malfunction of the offsite power system as described in the UFSAR. Dominion has documented condition reports CR 553967 and CR 551068, and participated in a root cause evaluation with Northeast Utilities to determine whether the relay operations that initiated the events of May 25, 2014, were appropriate for the circumstances. Dominion also implemented a compensatory measure by issuing an Operations Standing Order for interim guidance on offsite line outages and plant generation output. The team determined that the failure of Dominion to complete a 10 CFR 50.59 evaluation of the modification for the removal of the SLOD system involved traditional enforcement because it impacted the NRCs ability to perform its regulatory function. This AV was determined to be more than minor because the team determined that the change to the facility required a full 10 CFR 50.59 evaluation and it likely would have required Commission review and approval prior to implementation. The severity level of this AV was determined, in part, using SDP risk significance in accordance with the NRC Enforcement Policy. A Region I Senior Risk Analyst conducted a conditional core damage probability estimate and determined that it was most properly characterized at a Severity Level III. Cross-cutting aspects are not assigned to traditional enforcement violations. |
| Site: | Millstone  |
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| Report | IR 05000336/2014011 Section 4OA5 |
| Date counted | Sep 30, 2014 (2014Q3) |
| Type: | TEV: Severity level III |
| cornerstone | Initiating Events |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 93812 |
| Inspectors (proximate) | C Highley E Dipaolo H. Anagnostopoulus J Ambrosini J Deboer J Schoppy L Mckown P Presbyr Rolphw Cook W Schmidt B Haagensen C Cahill C Lally D Jackson E Burket J Patel P Cataldo P Ottb Bickettb Klukar C Crisden D Jackson H Nieh J Trapp L Casey P Cataldo R Mckinley |
| Violation of: | 10 CFR 50.59 |
| INPO aspect | |
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Finding - Millstone - IR 05000336/2014011 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Millstone) @ 2014Q3
Self-Identified List (Millstone)
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