05000382/FIN-2017010-01
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Finding | |
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| Title | Failure to Evaluate Departures from Approved Methodologies for Reactor Vessel Fluence |
| Description | The inspectors identified a Severity Level IV, non-cited violation of 10 CFR 50.59, Changes, Tests, and Experiments, Section (c)(1), which states, in part, that a licensee may make changes in the facility as described in the updated safety analysis report without obtaining a license amendment pursuant to 10 CFR 50.90 only if: (i) a change to the technical specifications incorporated in the license is not required, and (ii) the change, test, or experiment does not meet any of the criteria in paragraph (c)(2). Title 10 CFR 50.59, Section (c)(2)(viii), states, in part, that a licensee shall obtain a license amendment pursuant to Section 50.90 prior to implementing a proposed change, test, or experiment if the change, test, or experiment would result in a departure from a method of evaluation described in the updated safety analysis report used in establishing the design bases or in the safety analyses. Specifically, since January 2017, the licensee revised updated final safety analysis report Section 4.3.3.3 to reflect RAPTOR-M3G as the current licensing basis fluence method without first obtaining a license amendment. This finding was entered into the licensees corrective action program as Condition Report CR-WF3-2017-04748. The inspectors determined that the failure to evaluate proposed changes to determine if prior NRC review was required in accordance with 10 CFR 50.59 was a performance deficiency. Using NRC Inspection Manual Chapter 0612, Appendix B, Issue Screening, the inspectors determined that this performance deficiency had minor safety significance. 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. Since the violation was associated with a performance deficiency of minor significance, 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. |
| Site: | Waterford  |
|---|---|
| Report | IR 05000382/2017010 Section 1R18 |
| Date counted | Sep 30, 2017 (2017Q3) |
| Type: | TEV: Severity level IV |
| cornerstone | Other |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.18 |
| Inspectors (proximate) | R Latta G George |
| Violation of: | 10 CFR 50.59 |
| INPO aspect | |
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Finding - Waterford - IR 05000382/2017010 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Waterford) @ 2017Q3
Self-Identified List (Waterford)
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