05000382/FIN-2016008-04
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Finding | |
|---|---|
| Title | Departure from Approved Method to Determine Steam Generator Internal Loads During Main Steam Line Break |
| Description | The team identified a Severity Level IV non-cited violation of 10 CFR 50.59(c)(2),Changes, Tests, and Experiments, for the licensees failure to obtain a license amendment prior to implementing a proposed change, test, or experiment that would result in a departure from a method of evaluation described in the final safety analysis report (as updated) used in establishing the design bases or in the safety analyses. Specifically, the licensee departed from their approved CEFLASH-4A methodology to determine steam generator internal differential loads caused by a main steam line break to an unapproved TRANFLOW methodology. In response to this issue, the licensee entered the issue into the corrective action program as Condition Report CR-WF3-2016-07639 and initiated actions to prepare a new evaluation under current regulatory guidelines or to submit a license amendment request to the NRC.The licensees failure to obtain a license amendment prior to implementing a change that resulted in a departure from a method of evaluation described in the final safety analysis report (as updated) used in establishing the design bases or in the safety analyses, as required by 10 CFR 50.59(c)(2) was a violation. In accordance with the NRC Enforcement Manual, violations of 10 CFR 50.59 are not processed through the Reactor Oversight Process significance determination process because this violation potentially impacted the ability of the NRC to perform its regulatory oversight function. Therefore, this violation was processed through traditional enforcement examples of Section 6.1 of the NRC Enforcement Policy. This violation was more-than-minor because there was a reasonable likelihood that the change would require NRC review and approval prior to implementation, similar to the more-than-minor example of a change in requirements in the NRC Enforcement Manual,Appendix E, Minor Violations Examples, dated September 9, 2013. In accordance with the NRC Enforcement Policy, the significance determination process was used to inform the significance of the failure to obtain a license amendment prior to implementing a proposed change. The departure from the original CEFLASH-4A method to the TRANFLOW method to determine differential loads on steam generator internal structures following a main steam line break event was associated with the design control attribute of the Barrier Integrity Cornerstone and adversely affected the objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. In accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012,Exhibit 1, Initiating Events Screening Questions, the issue screened as having very low safety significance (Green) because the issue would not result in the complete or partial loss of a support system that contributes to the likelihood of an initiating event, or result in the steam generators violating accident leakage performance criterion. Since the violation was determined to be Green in the significance determination process, the traditional enforcement violation was determined to be a Severity Level IV violation, consistent with the example in paragraph 6.1.d(2) of the NRC Enforcement Policy. Traditional enforcement violations are not assessed for cross-cutting aspects. |
| Site: | Waterford  |
|---|---|
| Report | IR 05000382/2016008 Section 4OA5 |
| Date counted | Dec 31, 2016 (2016Q4) |
| Type: | TEV: Severity level IV |
| cornerstone | No Cornerstone |
| Identified by: | NRC identified |
| Inspection Procedure: | |
| Inspectors (proximate) | D Merzke E Ruesch F Ramirez G George M Hayes T Hipschman |
| Violation of: | 10 CFR 50 Appendix B Criterion XVI 10 CFR 50.59 |
| INPO aspect | |
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Finding - Waterford - IR 05000382/2016008 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Waterford) @ 2016Q4
Self-Identified List (Waterford)
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