The team identified a finding of very low safety significance and a Non-Cited Violation of
10 CFR 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, for the licensees failure to ensure that Revision 54 of the Technical Requirements Manual was appropriate to the circumstances. Revision 54 of the Technical Requirements Manual was not appropriate to the circumstances, because it allowed deviations from the Technical Requirement Manual requirements without following the procedure change process and
10 CFR 50.59 review process. The cause of this finding was related to the Decision Making Component (Item
H.1(b) of
IMC 305) for the cross-cutting area of Human Performance, because the licensee failed to make conservative assumptions in decisions affecting the procedure adherence for safety related systems. Specifically, the licensees assumptions for implementing Revision 54 were not based on a comprehensive review of system alignments for all possible Technical Requirements Manual deviations, and thus did not demonstrate that the proposed deviations allowed would be safe. The licensee subsequently removed the option to deviate from the Technical Requirements Manual and entered this issue into the corrective action program. This finding was determined to be more than minor in accordance with
IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, because the finding was associated with the Equipment Performance attribute of the
Mitigating Systems Cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to
initiating events to prevent undesirable consequences (i.e., core damage). Absent NRC intervention, the licensees procedure option could have allowed unsafe deviations from the Technical Requirements Manual or allowed actions which would have required prior NRC approval (e.g., license amendment). The team evaluated the finding in accordance with
IMC 0609.04 Phase 1 Initial Screening and Characterization of Findings. Under the
Mitigating Systems Cornerstone Column of Table 4a, the team answered No to each of the screening questions, because the NRC identified this deficient change prior to the licensee implementing any actions which adversely affected the structural integrity or operability of
mitigating systems. Therefore, the finding screened as having very low safety significance.
