05000445/FIN-2015007-04
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Finding | |
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| Title | Failure to Evaluate Changes to Ensure They Did Not Require Prior NRC Approval |
| Description | The team identified a Severity Level IV, non-cited violation of 10 CFR 50.59, Changes, Test, and Experiments, which states in part, Section (c)(1), that a licensee may make changes in the facility as described in the Updated Safety Analysis Report without obtaining a license amendment pursuant to 10 CFR 50.90 only if: (i) a change to the technical specifications incorporated in the license is not required, and (ii) the change, test, or experiment does not meet any of the criteria in paragraph (c)(2). Section(c)(2), states in part, A licensee shall obtain a license amendment pursuant to Section 50.90 prior to implementing a proposed change, test, or experiment if the change, test, or experiment would: (ii) Result in more than a minimal increase in the likelihood of occurrence of a malfunction of a structure, system, or component (SSC) important to safety previously evaluated in the final safety analysis report. Specifically, on March 12, 2013, the licensee performed a 10 CFR 50.59 evaluation for the unprotected turbine driven auxiliary feedwater pump exhaust stack, and during the Applicability Determination phase, determined that exempting the exhaust stack from being protected was acceptable without NRC approval. The licensee failed to recognize that the proposed change would result in more than a minimal increase in the likelihood that the turbine driven auxiliary feedwater pumps steam exhaust piping would be susceptible to tornado driven missiles during a station black out, when the turbine driven auxiliary feedwater pump would be required to be operational. In response to this issue, the licensee has demonstrated that the auxiliary feedwater system is capable of safely shutting down the plant in the event of a tornado missile strike on the turbine driven auxiliary feedwater pumps steam exhaust piping and the single failure of an additional auxiliary feedwater pump. This finding was entered into the licensees corrective action program as Condition Report CR-2015-007625. The team determined that the licensees failure to implement the requirements of 10 CFR 50.59 and adequately evaluate changes to determine if prior NRC approval is required was a performance deficiency. Because this performance deficiency had the potential to impact the NRCs ability to perform its regulatory function, the team evaluated the performance deficiency using traditional enforcement. In accordance with Section 2.1.3.E.6 of the NRC Enforcement Manual, the team evaluated this finding using the significance determination process to assess its significance. In accordance with Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, the finding was determined to have 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. In accordance with Section 6.1.d.2 of the NRC Enforcement Policy, the team characterized this performance deficiency as a Severity Level IV violation. The team determined that this finding did not have a cross-cutting aspect because the most significant contributor did not reflect current licensee performance. |
| Site: | Comanche Peak  |
|---|---|
| Report | IR 05000445/2015007 Section 1R21 |
| Date counted | Sep 30, 2015 (2015Q3) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.21 |
| Inspectors (proximate) | C Baron C Smith J Watkins R Kopriva S Kobylarz T Farnholtz T Palmer |
| Violation of: | 10 CFR 50.59 10 CFR 50.90 Technical Specification |
| INPO aspect | |
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Finding - Comanche Peak - IR 05000445/2015007 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Comanche Peak) @ 2015Q3
Self-Identified List (Comanche Peak)
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