05000528/FIN-2009003-03
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Finding | |
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| Title | Failure to Perform Written Safety Evaluation in Accordance with 10 CFR 50.59 for Refueling Water Tank Full Flow Recirculation |
| Description | The inspectors identified a noncited Severity Level IV violation of 10 CFR 50.59 requirements for the failure of engineering personnel to perform adequate written safety evaluations prior to implementing changes to the emergency core cooling system. Specifically, between 1987 and February 2009, engineering personnel failed to obtained prior NRC approval for a change that involved two unreviewed safety questions involving emergency core cooling system operability and containment bypass leakage during an accident. The first example involved a change in an emergency core cooling system lineup that could have prevented the fulfillment of the safety functions of the safety injection system to remove residual heat and mitigate the consequences of an accident. The second example involved opening normally locked close valves, while the plant is operating, that could result in the loss of a safety function to control the release of radioactive material as a result of the containment bypass path. This issue was entered into the licensee\'s corrective action program as Condition Report / Disposition Request 3287805.This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems Cornerstone and adversely affects the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events. This finding is also more than minor because it is associated with the configuration control attribute of the Barrier Integrity Cornerstone and adversely affects the cornerstone objective of providing 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 accordance with Inspection Manual Chapter 0612, Appendix B, Issue Disposition Screening, the inspectors determined that traditional enforcement applied because this issue may have impacted the NRCs ability to perform its regulatory function, and should be evaluated using the traditional enforcement process. The issue was classified as Severity Level IV because the violation of 10 CFR 50.59 involved conditions evaluated as having very low safety significance by the Significance Determination Process. Using Manual Chapter 0609.04, Phase 1 Initial Screening and Characterization of Findings, the finding required a Phase 2analysis because the finding represented a loss of safety system function of the safety injection system. The Phase 2 analysis determined that this finding was potentially greater than Green; therefore, a Phase 3 analysis was completed by a regional senior reactor analyst. The Phase 3 analysis determined that this issue was of very low safety significance based on the senior reactor analyst reviewing the licensee\'s risk estimate of the condition which concluded that the incremental conditional core damage probability was much less than 1.0E-7. The analyst checked portions of the licensee\'s analysis using the Palo Verde SPAR model, and found the licensee results to be acceptable. Therefore, the significance of the finding was determined to be very low (Green). This finding was evaluated as not having a crosscutting aspect because the performance deficiency is not indicative of current performance |
| Site: | Palo Verde  |
|---|---|
| Report | IR 05000528/2009003 Section 1R15 |
| Date counted | Jun 30, 2009 (2009Q2) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.15 |
| Inspectors (proximate) | R Treadway L Carson J Adams J Melfi S Alferink M Young M Hay J Bashore M Catts P Jayroe S Hedger |
| INPO aspect | |
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Finding - Palo Verde - IR 05000528/2009003 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Palo Verde) @ 2009Q2
Self-Identified List (Palo Verde)
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