05000416/FIN-2016007-03
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Finding | |
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| Title | Failure to Obtain NRC Approval For Changes to Diesel Generator Trips and Flood Mitigation Strategy |
| Description | The team identified two examples of a Severity Level IV non-cited violation of 10 CFR 50.59(c)(2), Changes, Tests, and Experiments, for the licensees failure to conclude that modifications to the Division 3 diesel generator trip logic circuits and flood mitigation strategy would have required a license amendment. Specifically, from October 7 to November 3, 2016, the licensee removed the automatic high crankcase diesel generator trip and from March 5, 2013, to November 3, 2016, used an unapproved method for mitigating design basis flooding. The licensees 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 these issues, the licensee entered the issues into the corrective action program as Condition Reports CR-GGN-2016-08328 and CR-GGN-2016-08329 and will either prepare new evaluations under current regulatory guidelines, or submit a license amendment request to the NRC. The first example of a performance deficiency for the change to the Division 3 diesel generator trip logic 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 diesel generator automatic trips increased the likelihood of a malfunction of systems important to safety. The second example of a performance deficiency for a change to the flood mitigation strategy to rely on the construction of temporary sandbag barriers was more-than-minor because it was associated with the protection against external hazards 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. Additionally, the violation was 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 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 crosscutting aspects. |
| Site: | Grand Gulf  |
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| 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 | |
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Finding - Grand Gulf - IR 05000416/2016007 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Grand Gulf) @ 2016Q4
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