05000400/FIN-2013009-01
From kanterella
Jump to navigation
Jump to search
Finding | |
|---|---|
| Title | Failure to Submit a License Amendment Request for a Digital Modification to the Solid State Protection System |
| Description | The inspectors identified a SL IV Green NCV of 10 CFR 50.59, Changes, Tests, and Experiments, for the licensees failure to obtain a license amendment before implementing a change that created the possibility of a malfunction of a system, structure, or component important to safety with a different result than previously evaluated. The licensee did not follow guidance in Nuclear Energy Institute document NEI 01-01, Guidelines on Licensing Digital Upgrades, Rev. 1, (referenced in licensee Procedure EGR-NGGC-0157, Engineering of Plant Digital Systems and Components, Rev. 7), which resulted in the licensee implementing a change that created the possibility of common cause software malfunctions of the reactor protection system and engineered safety features actuation systems not previously evaluated in the Updated Final Safety Analysis Report. This failure to follow NEI guidance when implementing a change was a performance deficiency. The licensee entered this issue into their corrective action program, performed an evaluation that provided a reasonable expectation of operability, and initiated development of a license amendment request. The performance deficiency was determined to be more than minor because it was 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). Additionally, in accordance with the guidance in the NRC Enforcement Manual, the 10 CFR 50.59 violation was more than minor because there was reasonable likelihood that the change would require NRC approval prior to implementation. The inspectors evaluated the significance of the finding using IMC 0609, The Significance Determination Process, and determined the finding was of very low safety significance (Green). In accordance with the Enforcement Policy, the violation of 10 CFR 50.59 was determined to be a SL IV violation because it resulted in a condition evaluated as having very low safety significance (i.e., Green) by the SDP. The finding had 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 failed to oversee the work activities of vendors such that nuclear safety was supported. |
| Site: | Harris  |
|---|---|
| Report | IR 05000400/2013009 Section 1R17 |
| Date counted | Sep 30, 2013 (2013Q3) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.17 |
| Inspectors (proximate) | A Alen R Nease T Fanelli |
| Violation of: | 10 CFR 50.59 |
| CCA | H.2, Field Presence |
| INPO aspect | LA.2 |
| ' | |
Finding - Harris - IR 05000400/2013009 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
Finding List (Harris) @ 2013Q3
Self-Identified List (Harris)
| |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||