05000454/FIN-2018010-04
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Finding | |
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| Title | Use of 10 CFR 50.54(x) for Unit AFW Cross-Tie |
| Description | In 2008, the licensee added steps to Emergency Operating Procedure (EOP) 1/2BFR-H.1, Response to Loss of Secondary Heat Sink, to use the MDAFW train of a non-accident unit to combat a loss of all feedwater event in the opposite unit by using a recently installed unit cross-tie. The EOPs also directed operators to enter the technical specification LCO action statement for the unit donating the MDAFW train because the MDAFW trains were not designed and licensed to be shared between the reactor units.In 2011, the resident inspectors noted that the EOP change resulted in more than a minimal increase in the likelihood of occurrence of a malfunction of a SSC important to safety previously evaluated in the Updated Final Safety Analysis Report because the Updated Final Safety Analysis Report described the MDAFW trains as non-shared systems. However, the licensee implemented this change without prior NRC approval. As a result, the inspectors documented a Severity Level IV NCV of 10 CFR 50.59 in Inspection Report 05000454/2011004; 05000455/2011004 as NCV 05000454/2011004-02; 05000455/2011004-02, Modification of the Auxiliary Feedwater System Without Prior NRC Approval (REF: Accession No. ML 113070678).As corrective actions to this NCV, the licensee removed the steps in the EOPs that directed the unit cross-tie to be used and removed credit for the cross-tie in the stations Probabilistic Risk Assessment model. However, on August 8, 2017, the licensee added direction in EOP1/2BFR-H.1 to use the Unit Auxillary Feedwater cross-tie by invoking 10 CFR 50.54(x). Specifically, the change added a note and a caution that provided direction to initiate the MDAFW unit cross-tie before bleed and feed. The note stated:If at any time it has been determined that restoration of feed flow to any SG is untimely or may be ineffective in heat sink restoration, then the AF crosstie should be implemented per Step 5 (Page 8). The caution stated: The AF crosstie should be implemented per Step 5 if other attempts to restore feed flow to the SG(s) will not prevent the initiation of feed and bleed. Step 5 provided instructions on how to perform the cross-tie and did not include instructions on when to initiate it. The caution also stated Use of the AF crosstie requires invoking 50.54(x).During this inspection period, the inspectors challenged the use of 10 CFR 50.54(x) to implement this permanent change. In addition, the inspectors noted that the licensees 10 CFR 50.59 screening for the procedure change did not include in its review the added note and caution statements. Because the added note and caution were the only procedure provisions that provided direction on when to use the MDAFW cross-tie, the 10 CFR 50.59 screening did not review the instructions about when to use the MDAFW cross-tie. As a result, the screening failed to determine that the change may have required a technical specification change and, thus, a license amendment as originally planned.At the end of the inspection, the NRC continued to evaluateif a performance deficiency and or violation occurred. This Unresolved Item will remain open pending the outcome of this ongoing review. |
| Site: | Byron  |
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| Report | IR 05000454/2018010 Section 1R21 |
| Date counted | Mar 31, 2018 (2018Q1) |
| Type: | URI: |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.21M |
| Inspectors (proximate) | N Feliz-Adorno J Benjamin J Robbins G O'Dwyer S Kobylarz C Baron V Petrella J Corujo-Sandin M Jeffers |
| Violation of: | Pending |
| INPO aspect | |
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Finding - Byron - IR 05000454/2018010 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Byron) @ 2018Q1
Self-Identified List (Byron)
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