05000445/FIN-2014003-01
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Finding | |
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| Title | Failure to Follow 10 CFR 50.59 for a Change to the Spent Fuel Pool Configuration |
| Description | The inspectors identified a non-cited violation of 10 CFR 50.59, Changes, Tests, and Experiments, for failure to conduct an adequate written evaluation and submit a license amendment for a change to the facility that required a technical specification amendment. Specifically, the licensee changed Procedure NUC-211, Surveillance of Region II Storage Limitations, Revision 1, to allow for storage of uprated fuel in Region II (high density racks) of the spent fuel pool using a methodology for fuel burnup penalties that had not been previously approved by the NRC and therefore, required an amendment to Technical Specification 3.7.17 Spent Fuel Assembly Storage prior to implementation. Subsequently, the licensee stopped all fuel movement in Region II of the spent fuel pool unless notifying the NRC prior to the movement. The licensee entered the finding into the corrective action program as Condition Report CR-2014-004693. The failure to perform an adequate 10 CFR 50.59 evaluation and obtain prior NRC approval for a change to the facility that involved a change to the technical specifications was a performance deficiency. The inspectors concluded that this issue involved traditional enforcement because it had the potential for impacting the NRCs ability to perform its regulatory function. This performance deficiency is more than minor because it was associated with the reactivity control attribute of the Barrier Integrity Cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Because the significance determination process does not directly address spent fuel pool criticality, a senior reactor analyst evaluated this issue using Inspection Manual Chapter 0609, Appendix M, Significance Determination Process Using Qualitative Criteria. Based on calculations provided by the licensee, the analyst determined that even with all uncertainties included in the calculations, the spent fuel pools would remain subcritical under all conditions, including a complete dilution of the borated water. The analyst qualitatively considered a completed dilution of the spent fuel pools to be a very low probability event. Therefore, the analyst concluded that this issue was of very low safety significance (Green). Because this issue was considered to be Green, it is treated as a Severity Level IV violation in traditional enforcement. The inspectors determined that the finding was not representative of current license performance and no cross-cutting aspect was assigned. |
| Site: | Comanche Peak  |
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| Report | IR 05000445/2014003 Section 1R18 |
| Date counted | Jun 30, 2014 (2014Q2) |
| Type: | NCV: Green |
| cornerstone | Barrier Integrity |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.18 |
| Inspectors (proximate) | D Proulx G Guerra J Kramer J Watkins L Brandt L Carson N Greene R Kumana S Alferink W Sifre W Walker |
| Violation of: | 10 CFR 50.59 Technical Specification - Procedures Technical Specification |
| INPO aspect | |
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Finding - Comanche Peak - IR 05000445/2014003 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Comanche Peak) @ 2014Q2
Self-Identified List (Comanche Peak)
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