05000483/FIN-2014007-02
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Finding | |
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| Title | 10 CFR 50.59 Screen for the Auxiliary Feedwater Motor Operated Control Valves Thermal Overload Relays |
| Description | The team identified a Severity Level IV, non-cited violation of 10 CFR Part 50.59, Changes, Tests and Experiments, which states, in part, A licensee may make changes in the facility as described in the final safety analysis report, make changes in the procedures as described in the final safety analysis report, and conduct tests or experiments not described in the final safety analysis report without obtaining a license amendment only if: (ii) The change, test, or experiment does not meet any of the criteria in paragraph (c)(2) of this section. Paragraph (c)(2), states in part: A licensee shall obtain a license amendment prior to implementing a proposed change, test, or experiment if the change, test, or experiment would: (ii) Result in more than a minimal increase in the likelihood of occurrence of a malfunction of a structure, system, or component (SSC), important to safety previously evaluated in the final safety analysis report. Specifically, on September 5, 2008, the licensee failed to complete a 10 CFR Part 50.59 Evaluation when they initiated Final Safety Analysis Report Change Notice (FSARCN)08-012 to Final Safety Analysis Report Section 8.3.1.1.2, to exempt auxiliary feedwater control valves (ALHV0005, 0007, 0009, and 0011) from the requirements of Regulatory Guide 1.106, Thermal Overload Protection for Electric Motors on Motor-Operated Valves, Revision 1. For these auxiliary feedwater control valves, the licensee chose to leave the thermal overload relays in the motor operated valve circuits continuously, but failed to periodically test them to ensure continued functional reliability and the accuracy of the trip point. In response to this issue, the licensee verified that no actual safety consequences had occurred with the auxiliary feedwater system motor operated control valves. This finding was entered into the licensees corrective action program as Callaway Action Request (CAR) 201403369. The team determined that the licensees failure to identify that the proposed Final Safety Analysis Report change to their commitment to Regulatory Guide 1.106 Revision 1, requiring an evaluation to be performed, was a performance deficiency. This finding was evaluated using traditional enforcement because it had the potential for impacting the NRCs ability to perform its regulatory function. This finding was more than minor because there was a reasonable likelihood that the change would have required NRC review and approval prior to implementation. Specifically, during the 10 CFR Part 50.59 screen, the licensee failed to determine that the proposed Final Safety Analysis Report change to their commitment to Regulatory Guide 1.106, Revision 1, did involve a change to a structure, system, or component, such that it did adversely affect an Final Safety Analysis Report described design function, which required an evaluation to be performed. In accordance with Inspection Manual Chapter 0612, Appendix B, Issue Screening, traditional enforcement does apply as the violation impacted the regulatory process. Using 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 that did not represent a loss of operability or functionality; 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. The team assessed the violation in accordance with the Enforcement Policy, and determined it to be a Severity Level IV violation because it resulted in a condition evaluated by the Significance Determination Process as having very low safety significance (Enforcement Policy example 6.1.d.2). This finding did not have a cross-cutting aspect because cross-cutting aspects are not assigned to traditional enforcement violations. |
| Site: | Callaway  |
|---|---|
| Report | IR 05000483/2014007 Section 1R21 |
| Date counted | Jun 30, 2014 (2014Q2) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.21 |
| Inspectors (proximate) | B Correll C Baron C Hale G Nicely J Braisted R Kopriva S Hedger T Farnholtz |
| Violation of: | 10 CFR 50.59 |
| INPO aspect | |
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Finding - Callaway - IR 05000483/2014007 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Callaway) @ 2014Q2
Self-Identified List (Callaway)
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