05000336/FIN-2015201-01
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Finding | |
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Title | Failure to Obtain a License Amendment for the Removal of Credit for Charging Pump Flow during the Inadvertent Opening of the PORVs |
Description | 10 CFR 50.59(c)(1) states, in part, that a licensee may make changes in the facility as described in the final safety analysis report (as updated) without obtaining a license amendment pursuant to 10 CFR Part 50.90 only if a change to the technical specifications incorporated in the license is not required and the change does not meet any of the criteria in Paragraph (c)(2) of 10 CFR 50.59. 10 CFR 50.59(c)(2)(vi) requires, in part, that a licensee shall obtain a license amendment prior to implementing a proposed change if the change would create a possibility for a malfunction of an sse [system, structure, or component] important to safety with a different result than any previously evaluated in the [FSAR] (as updated). 10 CFR 50.59(c)(2)(viii) requires, in part, that a licensee shall obtain a license amendment prior to implementing a proposed change if the change would results in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. 10 CFR 50.59(a)(2) defines that a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses means changing any of the elements of the method described in the FSAR (as updated) unless the results of the analysis are conservative or essentially the same. Contrary to the above, on July 2, 2009, DNC changed Section 14.6.1 of the Millstone Unit 2 UFSAR removing credit for the charging pumps in the analysis for inadvertent opening of the PORVs without first obtaining a license amendment from the NRC when the change met the criteria in 10 CFR 50.59(c)(2). Specifically, removal of credit for charging pump flow for the inadvertent opening of the PORVs event in Section 14.6.1 of the UFSAR A. created a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the Millstone Unit 2 UFSAR. DNC did not take into account the single failure criterion, stated in Chapter 14 of the Millstone Unit 2 UFSAR. Under the licensee's new analysis, a failure of one HPSI pump, in accordance with the UFSAR single failure criterion discussion, would not provide long-term core coverage. Not providing long term core coverage during a malfunction of a HPSI pump is a different result than any previously evaluated; B. resulted in a departure from a method of evaluation described in the Millstone Unit 2 UFSAR used in establishing the design bases. DNC did not adhere to the single failure criterion, as stated in Chapter 14 of the Millstone Unit 2 UFSAR. The single failure criterion is relied on by the NRC to establish an appropriate level of conservatism in performing UFSAR design basis accident and event analyses. Removing the single failure from the Millstone Unit 2 UFSAR Section 14.6.1 analysis is a departure from a method of evaluation described in the UFSAR. |
Site: | Millstone |
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Report | IR 05000336/2015201 Section 1R17 |
Date counted | Jun 30, 2013 (2013Q2) |
Type: | Violation: Severity level Enforcement Discretion |
cornerstone | No Cornerstone |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.17 |
Inspectors (proximate) | B Bickett D Willis G Carpenter L Casey M Parker R Morris |
Violation of: | 10 CFR 50.59 10 CFR 50.90 Technical Specification |
INPO aspect | |
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Finding - Millstone - IR 05000336/2015201 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Millstone) @ 2013Q2
Self-Identified List (Millstone)
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