05000416/FIN-2016007-02
From kanterella
Jump to navigation
Jump to search
Finding | |
|---|---|
| Title | Failure to Obtain NRC Approval For Changes to the Reactor Protection System |
| 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 more than a minimal increase in the likelihood of occurrence of a malfunction of a structure, system, or component important to safety previously evaluated in the final safety analysis report. Specifically, from June 24, 2014, until November 3, 2016, the licensee modified its reactor protection system to remove turbine first stage pressure instrumentation to measure reactor power, which resulted in a more than minimal increase of the likelihood of a malfunction. The failure to obtain a license amendment prior to implementing a change that resulted in a more than a minimal increase in the likelihood of occurrence of a malfunction of a system important to safety was a performance deficiency. In response to this issue, the licensee implemented compensatory actions to ensure the reactor protection system trips would be enabled when required, will either prepare a new evaluation under current regulatory guidelines, or submit a license amendment request to the NRC, and documented the condition in its corrective action program as Condition Report CR-GGN-2016-08298. This performance deficiency was more-than-minor because it was associated with the design control attribute of the Mitigating Systems Cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the elimination of the turbine first stage pressure instruments increased the likelihood of a malfunction of the reactor protection system. Additionally, the violation was similar to the more-than-minor examples in the NRC Enforcement Manual Appendix E, Minor Violations Examples, dated September 9, 2013. In accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, Exhibit 2, Mitigating Systems Screening Questions, the issue screened as having very low safety significance (Green) because it was a design or qualification deficiency that did not represent a loss of operability or functionality; did not represent an actual loss of safety function of the system or train; did not result in the loss of one or more trains of non-technical specification equipment; and did not screen as potentially risk significant due to seismic, flooding, or severe weather. 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: | Grand Gulf  |
|---|---|
| Report | IR 05000416/2016007 Section 1R17 |
| Date counted | Dec 31, 2016 (2016Q4) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.17 |
| Inspectors (proximate) | C Smith C Stott J Watkins T Farnholtz |
| Violation of: | 10 CFR 50.59 |
| INPO aspect | |
| ' | |
Finding - Grand Gulf - IR 05000416/2016007 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
Finding List (Grand Gulf) @ 2016Q4
| |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||