05000352/FIN-2009002-02
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Finding | |
|---|---|
| Title | Failure to Obtain License Amendment for TS Bases Change |
| Description | The inspectors identified a Severity Level IV NCV of 10 CFR 50.59, Changes, Test, and Experiment, for failing to obtain a Technical Specification (TS)license amendment for a change made to the TS Bases concerning offsite power source operability. Changes made to TS Bases 3/4.8.1 required a change in the TS, because the change caused the bases to be in direct conflict with the requirements of TS Limiting Condition for Operation 3.8.1, AC Sources Operating, through the application of associated TS surveillance requirements. Exelon entered this issue into the CAP and issued night orders to operators which required declaring an offsite power supply inoperable when an offsite power supply feeder breaker became unavailable to an emergency bus. Because this was a violation of 10 CFR 50.59, it was considered to be a violation which potentially impedes or impacts the regulatory process. Therefore, such violations are characterized using the traditional enforcement process. In this case, the licensee failed to perform an adequate safety evaluation in accordance with 10 CFR 50.59 because the approved change to the technical specification basis was in conflict with the TS surveillance requirements. This change required prior approval from the NRC before its implementation. Comparing this item to the examples in NUREG 1600, Supplement I, Reactor Operations, this finding is more than minor because NRC approval would have been required. The inspectors completed a Significance Determination Review using NRC IMC 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings. Using the Phase I Screening worksheet the finding was determined to be of very low safety significance (Green) since the finding did not represent an actual loss of safety function for greater than the TS allowed outage time. Comparing this item to the examples in NUREG 1600, Supplement I, this finding is similar to Item D.5, Violations of10 CFR 50.59 that result in conditions evaluated as having very low safety significance(i.e., Green) by the SDP. This is an example of a Severity Level IV violation. Since the TS Bases change was made in 2000, the inspectors determined that this finding was not reflective of current licensee performance and, therefore, did not have a cross-cutting aspect |
| Site: | Limerick  |
|---|---|
| Report | IR 05000352/2009002 Section 1R18 |
| Date counted | Mar 31, 2009 (2009Q1) |
| Type: | TEV: Severity level IV |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.18 |
| Inspectors (proximate) | N Sieller P Krohn E Dipaolo T Moslak K Young S Barr |
| INPO aspect | |
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Finding - Limerick - IR 05000352/2009002 | |||||||||||||||||||||||||||||||||||||||
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Finding List (Limerick) @ 2009Q1
Self-Identified List (Limerick)
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