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The inspectors identified a noncited violaThe inspectors identified a noncited violation of 10 CFR 50.71 after Pacific Gas and Electric failed to update the Final Safety Analysis Report Update with a critical operator action assumed in the plant steam generator tube rupture accident analysis. The steam generator tube rupture accident analysis assumed that the ruptured steam generator will not overfill with water during the accident. To ensure a margin to overfill, the accident analysis included a critical assumption that plant operators would manually trip the turbine-driven auxiliary feedwater pump within 5.54 minutes following the reactor trip. Final Safety Analysis Report Update Section 15.4.3.1, Identification of Causes and Accident Description, and Final Safety Analysis Report Update Table 15.4-12, Operator Action Times for Design Basis SGTR Analysis, provided a detailed description of the time dependant operator actions assumed in the accident analysis. The inspectors identified that neither section included the critical assumed operator action to trip the turbine-driven auxiliary feedwater pump. The inspectors concluded that the licensee had a reasonable opportunity to identify and correct the problem when the results of the revised steam generator tube rupture accident, supporting steam generator replacement, was updated in the Final Safety Analysis Report Update in October 2008. The licensee entered this violation into the corrective action program as Notification 50269753. The inspectors evaluated this finding with the traditional enforcement process because the issue affected the NRCs ability to perform its regulatory function. The inspectors concluded that the finding is greater than minor because the failure to update the required critical operator action assumed in the accident analysis could have a material impact on safety or licensed activities. The inspectors concluded that the violation is Severity Level IV because the erroneous information was not used to make an unacceptable change to the facility or procedures. The inspectors concluded that this finding had a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program component because the licensee failed to implement a corrective action program with a low threshold for identifying issues and failed to identify the inaccuracies in the accident analysis as described in the Final Safety Analysis Report Update (P.1(a)inal Safety Analysis Report Update (P.1(a)  
23:59:59, 30 September 2009  +
05000275  +  and 05000323  +
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23:48:10, 20 February 2018  +
23:59:59, 30 September 2009  +
Failure to Update the Final Safety Analysis Report Update with Current Accident Analysis  +