05000461/FIN-2015003-03
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Finding | |
|---|---|
| Title | Failure to Obtain a License Amendment prior to Making Modifications to Secondary Containment |
| Description | The inspectors identified a Severity Level IV NCV of 10 CFR 50.59(d)(1), Changes, Tests, and Experiments, on December 18, 2014, for the licensees failure to provide a written evaluation showing that a change to the secondary containment did not require a license amendment. Specifically, the licensee eliminated the tornado wind and tornado missile loading conditions from the fuel building railroad airlock enclosure walls, roof and associated outer door Seismic Category I design requirements. However, the licensee failed to provide a written evaluation describing why the change would not result in more than a minimal increase in the likelihood of occurrence of a malfunction of a structure, system or component important to safety. The licensee documented the issue in the CAP as AR 02534694. Corrective actions included complying with TS anytime the inner railroad bay door is opened by entering the applicable action statements, evaluating weather conditions and impact to plant risk and establishing the necessary mitigating actions required prior to opening the door. The inspectors determined that the licensees failure to provide a written evaluation that documented the basis for determining that the change to the secondary containment did not require a license amendment was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the design control attribute of the Barrier Integrity cornerstone, and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers (fuel cladding, reactor coolant system and containment) protect the public from radionuclide releases caused by accidents or events. In addition, the associated violation was determined to be more than minor because the inspectors could not reasonably determine if the changes to secondary containment would have required prior NRC approval. Violations of 10 CFR 50.59 are dispositioned using the traditional enforcement process instead of the significance determination process (SDP) because they are considered to be violations that potentially impede or impact the regulatory process. However, if possible, the underlying technical issue is evaluated under the SDP to determine the severity of the violation. In this case, the finding was screened against the Barrier Integrity cornerstone, and determined to be of very low safety significance because the finding did not represent a degradation only of the radiological barrier function for the standby gas treatment system nor did it represent a degradation of the function of the control room against smoke or toxic atmosphere. The inspectors determined this finding has a cross-cutting aspect of procedure adherence in the area of human performance because the licensee failed to follow the 50.59 regulatory process as defined in procedure LS-AA-104-1000, 50.59 Resource Manual, Revision 9. [H.8] |
| Site: | Clinton  |
|---|---|
| Report | IR 05000461/2015003 Section 1R18 |
| Date counted | Sep 30, 2015 (2015Q3) |
| Type: | TEV: Severity level IV |
| cornerstone | Barrier Integrity |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.18 |
| Inspectors (proximate) | A Shaikh C Phillips E Sanchez-Santiago J Bozga M Jones P Louden S Mischke W Schaup |
| Violation of: | 10 CFR 50.59 Technical Specification - Procedures Technical Specification |
| CCA | H.8, Procedure Adherence |
| INPO aspect | WP.4 |
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Finding - Clinton - IR 05000461/2015003 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Clinton) @ 2015Q3
Self-Identified List (Clinton)
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