05000348/FIN-2013002-01
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Finding | |
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| Title | Failure to Perform 50.59 Evaluation for Replacement of TDAFW Pump Governor |
| Description | An NRC-identified Green finding and associated Severity Level IV, NCV, of 10 CFR 50.59(d)(1), were identified for the failure to perform an evaluation of a turbine-driven auxiliary feed water (TDAFW) pump governor modification on Units 1 and 2 against the criteria in 10 CFR 50.59(c)(2), as directed by site procedure NMP-AD-010 and the selfimposed industry guidelines in Nuclear Energy Institute document NEI 96-07, Revision 1, for the implementation of 10 CFR 50.59. The licensee entered the issue in the corrective action program as condition report (CR) 606427 and addressed the operability of the TDAFW pumps. In addition, one of the corrective actions of the CR is the completion of the required 50.59 evaluation. The licensees failure to perform a 50.59 evaluation as required by 10 CFR 50.59(d)(1) was a performance deficiency. This performance deficiency was more-than-minor because it is 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 (i.e., core damage). Specifically, the licensee did not fully demonstrate that the availability, reliability, and capability of the TDAFW pump would be maintained through the modification of the pump governor. Additionally, the failure to perform a 50.59 evaluation was determined to be more-than-minor in accordance with the guidance in the NRC Enforcement Manual for traditional enforcement violations because there was a reasonable likelihood that the change could require Commission review and approval prior to implementation. The inspectors evaluated the significance of the finding using Inspection Manual Chapter 0609, Significance Determination Process (SDP), and determined the finding was of very low safety significance (Green). In accordance with the NRC Enforcement Policy, the violation of 10 CFR 50.59 was determined to be a Severity Level IV violation because it resulted in a condition evaluated as having very low safety significance (i.e., Green) by the SDP. This finding has a cross cutting aspect in the decision making component of the human performance area because the most significant causal factor of the performance deficiency was that the licensee did not use conservative assumptions in the determination of whether the TDAFW governor modification introduced adverse effects that required a 50.59 evaluation. |
| Site: | Farley  |
|---|---|
| Report | IR 05000348/2013002 Section 1R17 |
| Date counted | Mar 31, 2013 (2013Q1) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.17 |
| Inspectors (proximate) | J Rivera-Ortiz W Loo M Speck M Coursey T Chandler T Lighty J Sowa C Dykes T Su D Berkshire |
| Violation of: | 10 CFR 50.59 |
| CCA | H.14, Conservative Bias |
| INPO aspect | DM.2 |
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Finding - Farley - IR 05000348/2013002 | |||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Farley) @ 2013Q1
Self-Identified List (Farley)
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