05000440/FIN-2016007-02
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Finding | |
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| Title | Use of Unapproved Standard for Site Flooding Modifications and Analysis |
| Description | The inspectors identified a Severity Level IV, NCV of 10 CFR 50.59, Changes, Tests, and Experiments, having very-low safety significance (Green) for the licensees failure to conclude that site flooding modifications and associated analysis included a standard that resulted in a departure from the method of evaluation as described in the Updated Final Safety Analysis Report. Specifically, the licensee used a new method for evaluation of design basis flooding at Perry Nuclear Power Plant that is different from the method described in the Updated Final Safety Analysis Report and not approved by the NRC. The inspectors determined that the licensees use of an unapproved methodology for site flooding modifications and associated analysis that constituted a departure from a method of evaluation was contrary to 10 CFR 50.59(c)(2)(8) and was a performance deficiency. Specifically, the licensee used a new method for evaluation of design basis flooding at Perry Nuclear Power Plant that is different from the method described in the Updated Final Safety Analysis Report and not approved by the NRC. The performance deficiency was determined to be more-than-minor, and a finding, because it affected the cornerstone attribute of protection against external factors and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. In addition, the associated violation was determined to be more-than-minor because the inspectors determined that there was a reasonable likelihood that the changes would have required prior NRC approval. The inspectors determined that finding could be evaluated using the SDP in accordance with IMC 0609, Significance Determination Process. Using Attachment 0609.04, Initial Characterization of Findings, Table 2 the inspectors determined that the finding affected the Mitigating Systems cornerstone. As a result, the inspectors evaluated the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, for the Mitigating Systems cornerstone. The inspectors answered Yes to question A.1 in Exhibit 2 Mitigating Systems Screening Questions. Specifically, the inspectors determined the finding did not result in systems, structures, and components not being able to maintain their operability or functionality. Therefore, the inspectors determined the significance of this finding to be of very-low safety significance (Green). In accordance with Section 6.1.d of the NRC Enforcement Policy this violation is categorized as Severity Level IV because the resulting changes were evaluated by the SDP as having very-low safety significance (i.e., green finding). The inspectors determined that this finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Problem Identification, for the licensees failure to identify issues completely, accurately, and in a timely manner. Specifically, the licensees 50.59 review committee failed to accurately identify the methodology change concern in Evaluation 14-01234 during a review documented in CR2015-14025. |
| Site: | Perry  |
|---|---|
| Report | IR 05000440/2016007 Section 1R17 |
| Date counted | Jun 30, 2016 (2016Q2) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.17 |
| Inspectors (proximate) | A Shaikh J Hafeez M Domke R Daley |
| Violation of: | 10 CFR 50.59 |
| CCA | P.1, Identification |
| INPO aspect | PI.1 |
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Finding - Perry - IR 05000440/2016007 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Perry) @ 2016Q2
Self-Identified List (Perry)
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