05000424/FIN-2010007-01
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Finding | |
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| Title | Violation of 10 CFR 50.71(e)(4) for Failure to Reflect Changes to Facility and Procedures in Final Safety Analysis Report Periodic Revisions |
| Description | The inspectors identified a Severity Level (SL) IV non-cited violation (NCV) of 10 CFR 50.71(e)(4) for the failure to reflect all changes made in the facility or procedures as described in the updated final safety analysis report (UFSAR) up to a maximum of six months prior to the date of filing of periodic updates to the UFSAR with the NRC. Licensee procedure NMP-ES-022, DCP Site Approval, Implementation and Closure, Ver. 7.0 addressed the processing of documentation regarding design change packages (DCPs). Step 6.7.2.3 of this procedure required the modification engineer to assign an action item to the licensing document owner identified in the licensing document change request (LDCR). Licensee procedure NMP-AD-009, Licensing Document Change Requests, Ver. 8.0 addressed the processing of LDCRs. NMP-AD-009 included updates to the UFSAR in the scope of LDCRs. This procedure did not contain any timeliness guidance regarding the completion of LDCRs which impacted the UFSAR to ensure compliance with the requirements of 10 CFR 50.71(e)(4). The licensee submitted Revision 15 of the UFSAR to the NRC on April 16, 2009. The inspectors identified five instances where DCPs were implemented which made changes to the facility or procedures as described in the UFSAR more than six months prior to the April 16, 2009 submittal. This finding was entered into the licensees corrective action program as condition report (CR) 2010109181. The failure to reflect all changes made in the facility or procedures as described in the UFSAR up to a maximum of six months prior to the date of filing of periodic updates to the UFSAR with the NRC is a performance deficiency. Traditional enforcement applies since this finding reflects an impact on the regulatory process in the form of timely and accurate reports to the NRC. This finding is more than minor consistent with Section XIII, Supplement I, D.6 of the NRC Enforcement Policy. This section of the enforcement policy states, in part, that a failure to update the FSAR as required by 10 CFR 50.71(e) in cases where the information is not used to make an unacceptable change to the facility or procedures is a SL IV violation. The team reviewed the five DCPs which were implemented greater than six months prior to the submission of Revision 15 of the UFSAR to the NRC and conducted focused queries of licensee CRs dating back to the implementation of the oldest of the five affected DCPs. The team was not able to find any occurrences where the lack of timely updates to the UFSAR resulted in an unacceptable change to the facility or procedures. The inspectors determined that the thorough evaluation of problems such that resolutions address causes and extent of conditions, as necessary was a significant cause of this performance deficiency. The licensee generated CR 2007107068 in June 2007 in response to a discovery that the FSAR did not reflect the changes associated with a DCP. The extent of condition of the corrective actions associated with this failed to identify that the LDCR procedure did not contain any timeliness guidance to ensure compliance with 10 CFR 50.71(e)(4). This is directly related to the Corrective Action Program component of the cross-cutting area of Problem Identification and Resolution. |
| Site: | Vogtle  |
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| Report | IR 05000424/2010007 Section 1R21 |
| Date counted | Sep 30, 2010 (2010Q3) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.21 |
| Inspectors (proximate) | D Mas-Penaranda S Kobylarz R Berryman S Spiegelman B Desai J Eargle S Walker M King |
| CCA | P.2, Evaluation |
| INPO aspect | PI.2 |
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Finding - Vogtle - IR 05000424/2010007 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Vogtle) @ 2010Q3
Self-Identified List (Vogtle)
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