05000461/FIN-2017007-01
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Finding | |
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| Title | Failure to Evaluate Defeating Reactor Core Isolation Cooling System Interlocks and Trips before Adding Them to an Emergency Operating Support Procedure |
| Description | The inspectors identified a Severity Level IV NCV of Title 10 Code of Federal Regulations (CFR) 50.59(d)(1), Changes, Test, and Experiments, and an associated finding, for the licensees failure to perform a written evaluation which provided the bases for the determination that a change did not require a license amendment. Specifically, the licensee made a change pursuant to 10 CFR 50.59(c) with the change to an emergency operating procedure (EOP) support procedure to incorporate three reactor core isolation cooling (RCIC) system interlock defeats and did not provide a basis for the determination that this change would not create a possibility for a malfunction of a structure, system or component (SSC ) important to safety with a different result than any previously evaluated in the updated safety analysis report. The licensee entered this issue into the CAP as action request ( AR ) 04056394 and planned to perform a screening for the procedure change. 3 This performance deficiency was determined to be more than minor in accordance with Inspection Manual Chapter (IMC) 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated September 7, 2012, because it was associated with the Mitigating Systems cornerstone attribute of procedure quality and affected the cornerstone objective of ensuring the availability, reliability, and capability of mitigating systems to respond to initiating events to prevent undesirable consequences. Specifically, the change did not ensure RCIC system reliability and availability during and following design basis accidents because it introduced a new failure mode and added reliance on monitoring activities and manual actions. 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 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. Traditional enforcement applied to this finding because it involved a violation that impacted the regulatory process. The inspectors determined it to be of Severity Level IV significance because it resulted in a condition evaluated by the SDP as having very low safety significance (Enforcement Policy example 6.1.d.2). The team determined that this finding had a cross -cutting aspect of Resources in the area of Human Performance because the licensee did not ensure that procedures, and other resources were available and adequate to support nuclear safety. Specifically, the procedure which required a 50.59 screening for changes to EOP support procedures, was not explicit in requiring the screening. [H.1] |
| Site: | Clinton  |
|---|---|
| Report | IR 05000461/2017007 Section 4OA2 |
| Date counted | Sep 30, 2017 (2017Q3) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71152 |
| Inspectors (proximate) | E Sanchez-Santiago M Jones V Petrella B Bartlett R Ng S Mischke L Kozak |
| Violation of: | 10 CFR 50.59 |
| CCA | H.1, Resources |
| INPO aspect | LA.1 |
| ' | |
Finding - Clinton - IR 05000461/2017007 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Clinton) @ 2017Q3
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