05000458/FIN-2015007-02
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Finding | |
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| Title | Failure to Obtain Prior NRC Approval for a Change in Reactor Core Isolation Cooling Injection Point |
| Description | The team identified a Severity Level IV, Green, non-cited violation of 10 CFR 50.59, Changes, Tests, and Experiments, Section (c)(2) which 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 result in more than a minimal increase in the frequency of occurrence of an accident previously evaluated in the final safety analysis report (as updated). Specifically, prior to October 8, 2015, the licensee failed to correctly evaluate that a spurious reactor core isolation cooling actuation injecting into the feedwater line resulted in a more than minimal increase in the frequency of occurrence of the loss of feedwater heating accident previously evaluated in the updated final safety analysis report. In response to this issue, the licensee initiated a condition report to document completion of a new evaluation under current regulatory guidelines. This finding was entered into the licensees corrective action progam as Condition Report CR-RBS-2015-7259. The team determined that the failure to perform an adequate evaluation of a design change was a performance deficiency. This finding was also evaluated using traditional enforcement because it had the potential to impact the NRCs ability to perform its regulatory function. This finding was more than minor because it was associated with the design control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and there was a reasonable likelihood that the change would have required NRC review and approval prior to implementation. Specifically, the licensee failed to correctly evaluate that a spurious reactor core isolation cooling actuation injecting into the feedwater line resulted in a more than minimal increase in the frequency of occurrence of the loss of feedwater heating accident previously evaluated in the updated final safety analysis report. 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 where the mitigating structure, system, or component maintained its operability or functionality. Since the violation is associated with a Green reactor oversight process violation, 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. There is no cross-cutting aspect assigned to this performance deficiency because the performance deficiency is not indicative of current performance and also because cross-cutting aspects are not assigned to traditional enforcement violations. |
| Site: | River Bend  |
|---|---|
| Report | IR 05000458/2015007 Section 1R17 |
| Date counted | Dec 31, 2015 (2015Q4) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.17 |
| Inspectors (proximate) | R Azua P Jayroe B Parks T Hipschmanj Watkinsl Brandt M Williams T Farnholtz |
| Violation of: | 10 CFR 50.59 |
| INPO aspect | |
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Finding - River Bend - IR 05000458/2015007 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (River Bend) @ 2015Q4
Self-Identified List (River Bend)
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