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05000305/FIN-2003008-012003Q4KewauneeNON-CITED Violation of 10 CFR 50.59, for the Failure to Perform a Written Evaluation, as Required, for a Modification to the Component Cooling Water System

The inspectors identified a finding of very low safety significance associated with a Non-Cited Violation of 10 CFR 50.59(d)(1) for the licensee's failure to perform a safety evaluation for changes made to the facility. Specifically, the licensee screened out' of the 10 CFR 50.59 process a modification that included the addition of a minimum flow recirculation line to the component cooling water pumps. This modification further cross-connected the suction and discharge piping of both component cooling water pump trains. Subsequently, the inspectors identified and the licensee concurred that a safety evaluation was required for this modification.

Because the Significance Determination Process is not designed to assess the significance of violations that potentially impact or impeded the regulatory process, this issue was dispositioned using the traditional enforcement process in accordance with Section IV of the NRC Enforcement Policy. However, the results of this violation were assessed using the Significance Determination Process. In this case, the licensee failed to perform a safety evaluation in accordance with 10 CFR 50.59 and had placed the new system in service for testing prior to the completion of the required safety evaluation.

The inspectors considered this issue to be of more than minor significance because, if left uncorrected, the issue could become a more significant safety concern. Specifically, the inspectors noted that the licensee's processes for permanent modifications failed to identify this issue at several review levels. The inspectors determined that the issue was of very low significance because the new system was placed in service for a short period of time for testing prior to the completion of the required safety evaluation. In addition, the final safety evaluation completed by the licensee in October 2003 determined that the modification did not require prior NRC approval. The inspectors determined this finding was a Severity Level IV Non-Cited Violation of 10 CFR 50.59. The inspectors also determined that the finding had, as a primary cause, a human performance deficiency which affected the cross-cutting are of Human Performance.

05000456/FIN-2003006-012003Q3BraidwoodFailure to Provide Accurate Performance Indicator Data to the NRCA self-revealing issue was identified when licensee engineers noted, during a review, that they had miscalculated and therefore misreported in July 2001, the fault exposure time for a 1B auxiliary feedwater pump failure. The issue was more than minor because it caused the performance indicator to cross the Green-to-White threshold during later quarters. The licensee submitted the corrected data to the NRC in a special mid-quarter data submittal in August 2003 and the issue was entered into the licensee's corrective action system. Because this issue affected the NRC's ability to perform its regulatory function, it was evaluated with the traditional enforcement process. The issue was determined to be a Severity Level IV Non-Cited Violation of 10 CFR 50.9. (4OA1.1)