05000461/FIN-2017004-03
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Finding | |
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Title | Failure to Identify the Extent of Condition for an Inadequate 10 CFR 50.59 Evaluation |
Description | The inspectors identified a finding of very low safety significance and a non-cited violation of 10 CFR 50, Appendix B, Criterion II, Quality Assurance Program, for the licensees failure to follow a procedure that implemented the Quality Assurance Program requirements. Specifically, the licensee failed to follow procedure PIAA1251003, Corrective Action Program Evaluation Manual, and identify the extent of condition for a lack of proficiency in applying the licensing basis when performing 10 CFR 50.59 evaluations. The licensee documented this issue in their CAP as AR 04075581. The licensee planned an Updated Safety Analysis Report (USAR) Upgrade Project which reportedly would include a review of safety evaluations for USAR changes that dated back to 1986 and determined the scope of this project would be adequate to identify the extent of condition for this issue. The inspectors determined that this issue was more than minor because if left uncorrected it had the potential to lead to a more significant safety concern. Specifically, because the extent of condition review was not adequate, there is a potential for other safety systems to have been adversely affected by a lack of proficiency in applying the licensing basis during safety related system changes. As a result, safety-related systems may not be able to perform intended safety functions as defined in the USAR. This issue would also adversely affect the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). The finding was screened against all cornerstones and determined to be of very low safety significance because the finding met each of the applicable screening questions to be characterized as having very low safety significance. The inspectors determined this finding affected the cross-cutting area of human performance in the aspect of procedure adherence, which stated individuals follow processes, procedures, and work instructions. Specifically, when the NRC violation was documented in the CAP previously it was not appropriately classified in accordance with PIAA120 and was also incorrectly closed to an unrelated evaluation. This contributed to the failure to appropriately perform an extent of condition. [H.8] |
Site: | Clinton |
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Report | IR 05000461/2017004 Section 4OA5 |
Date counted | Dec 31, 2017 (2017Q4) |
Type: | NCV: Green |
cornerstone | Mitigating Systems |
Identified by: | NRC identified |
Inspection Procedure: | IP 92723 |
Inspectors (proximate) | W Schaup E Sanchez-Santiago R Baker N Fields G Hansen M Holmberg D Reeser G Roach K Stoedter |
Violation of: | 10 CFR 50 Appendix B Criterion II |
CCA | H.8, Procedure Adherence |
INPO aspect | WP.4 |
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Finding - Clinton - IR 05000461/2017004 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Clinton) @ 2017Q4
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