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The inspectors identified a Severity Level … The inspectors identified a Severity Level IV noncited violation of 10 CFR 50.59 for the failure to obtain NRC approval prior to implementing a change to the facility that resulted in a departure from a method of evaluation described in the final safety analysis report used in establishing the design bases. Specifically, the licensee implemented a change that assumed the unprotected dry cooling towers would not be impacted during a tornado event. This change was implemented based on the inappropriate use of a Tornado Missile Risk Evaluation method of evaluation not previously approved by the NRC. The licensee implemented this change to compensate for a licensee identified analysis error that adversely affected the ultimate heat sink capability following a tornado event. The licensee entered this deficiency into their corrective action program for resolution. The cause of this finding is related to the crosscutting element of human performance</br>The finding is greater than minor in that it affected the mitigating systems cornerstone attribute of equipment availability and function during a design bases tornado event. Regional and NRR staff determined that the change made by the licensee resulted in a departure from a method of evaluation described in the final safety analysis report used in establishing the design bases and that the change would require NRC approval under 10 CFR 50.59 guidance. In accordance with the NRC Enforcement Manual, violations of 10 CFR 50.59 are not processed directly through the significance determination process. Therefore, this issue was considered applicable as traditional enforcement. Although the significance determination process is not designed to assess significance of violations that potentially impact or impede the regulatory process, the technical result or condition of a 10 CFR 50.59 violation can be assessed through the significance determination process. The inspectors and the Region IV reactor analyst discussed the significance of this finding. A significance Determination Process Phase 1 screening was performed and the finding was determined to have very low safety significance because there was no actual loss of mitigating system safety function per Generic Letter 91-18 guidance.unction per Generic Letter 91-18 guidance.

Discovered date

23:59:59, 30 September 2005 +

Docket

05000382 +

Event date

23:59:59, 30 September 2005 +

Finding integer

3 +

Finding type

Traditional Enforcement Violation +

Generic letter

NRC Generic Letter 91-18, Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability +

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Identified by

NRC identified +

Inspection procedure

IP 71152, Problem Identification and Resolution (PI&R) +

Inspection report

IR 05000382/2005004 +

Inspector

Gerond George +, Vincent Gaddy +, Thomas Farnholtz +, M Hay +, R Barkley +, P Elkman +, T Hoeg +, S Garchow +, G Larkin +, D Overland +, John Kirkland +, Robert Kahler + and Michael Brown +

Modification date"Modification date" is a predefined property that corresponds to the date of the last modification of a subject and is provided by <a rel="nofollow" class="external text" href="https://www.semantic-mediawiki.org/wiki/Help:Special_properties">Semantic MediaWiki</a>.

00:31:41, 21 February 2018 +

Person