05000323/FIN-2009009-03

Finding

Title

Failure to Evaluate a Change to the Facility as Described in the Final Safety Analysis Report Update Associated with the Addition of Manual Actions in the Safety Analysis

Description

The inspection team identified a noncited violation of 10 CFR 50.59, which states that a licensee may make changes to the facility as described in the final safety analysis report without obtaining a license amendment if the change does not result in a departure from a method of evaluation described in the final safety analysis report used in establishing the design bases or in the safety analyses. This regulation further requires the licensee to include a written evaluation providing the basis for concluding that a license amendment is not required. On November 21,2005, the licensee failed to provide a written evaluation concluding that a license amendment was not required for a change to the facility as described in the final safety analysis report. Specifically, the licensee identified a condition where large differential pressure across the residual heat removal suction containment sump valves could cause them to fail to open during certain small break loss of coolant accidents. On October 5, 2005, the licensee revised Emergency Operating Procedure E-1, Loss of Reactor or Secondary Coolant, to add an operator action to align component cooling water to the residual heat removal heat exchanger. On June 16, 2009, the licensee again revised Emergency Operating Procedure E-1 to specify that operator action to align component cooling water within 30 minutes was a time critical operator action. The licensee did not evaluate either change to determine if prior NRC approval was required for the new manual actions. The licensee entered this issue into their corrective action program as Notification 50276288. The failure of the licensee to perform a 10 CFR 50.59 evaluation of a new manual action supporting the plants design basis was a performance deficiency within the licensees ability to foresee and correct. The inspectors evaluated this issue using the traditional enforcement process because the performance deficiency had the potential for impacting the NRCs ability to perform its regulatory function. The inspectors concluded that the issue was more than minor because of a reasonable likelihood that the change to the facility would require Commission review and approval prior to implementation. The inspectors also evaluated the significance of this issue under the Significance Determination Process using Inspection Manual Chapter 0609.04, Phase 1 - Initial Screening and Characterization of Findings. The inspectors concluded that the issue affected the Mitigating Systems Cornerstone and screened Green because the finding was a design or qualification deficiency confirmed not to result in loss of operability. The issue was classified as Severity Level IV because the violation of 10 CFR 50.59 involved conditions resulting in very low safety significance by the significance determination process. This finding had a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program component because the licensee did not thoroughly evaluate the change to the facility as described in the Final Safety Analysis Report Update to determine if prior NRC approval was required [P.1 (c)

03
Site:	Diablo Canyon
Report	IR 05000323/2009009 Section 1R02
Date counted	Mar 31, 2010 (2010Q1)
Type:	TEV: Severity level IV
cornerstone	Mitigating Systems
Identified by:	NRC identified
Inspection Procedure:	IP 71111.02
Inspectors (proximate)	M Peck P Elkmann M Runyan R Caniano M Williams
CCA	P.2, Evaluation
INPO aspect	PI.2
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Finding - Diablo Canyon - IR 05000323/2009009

1(0)2(6)3(4)4(5)5(12)6(5)7(11)8(0)201(7)301(0)402(2)403(2)501(0)

IR 05000323/2009009: 1 2 3

Finding List (Diablo Canyon) @ 2010Q1

CCA Matrix: 2010Q1

	Q	CCA	Title
05000275/FIN-2009004-04	2009Q3	P.1 P.1(a)	Failure to Update the Final Safety Analysis Report Update with Current Accident Analysis
05000275/FIN-2009004-03	2009Q3	H.7	Failure to Follow Emergency Operating Procedures Following a Reactor Trip
05000275/FIN-2009004-02	2009Q3	P.5 P.2(a)	Failure to Perform Corrective Actions Resulted in an Unplanned Trip
05000275/FIN-2009004-01	2009Q3	P.2	Failure to Identify and Correct a Degraded Fire Barrier
05000275/FIN-2009008-01	2009Q3	H.7	Safe Shutdown Procedure Not Consistent With Safe Shutdown Analysis
05000275/FIN-2009005-04	2009Q4	P.1 P.1(a)	Less than Adequate Replacement Reactor Head Modification Design Control
05000275/FIN-2009005-01	2009Q4	H.4 H.9	Less Than Adequate Work Planning Resulted in the Release of Two Gas Decay Tanks
05000275/FIN-2009005-02	2009Q4	H.5	Failure to Properly Plan a Maintenance Activity
05000275/FIN-2009005-05	2009Q4	P.2	Less than Adequate Change Evaluation to the Facility as Described in the Final Safety Analysis Report Update
05000275/FIN-2009005-03	2009Q4	P.2	Inadequate 50.59 Evaluation for Steam Generator Tube Rupture Analysis
05000275/FIN-2010002-05	2010Q1	P.2	Failure to Submit a LERE for a Common-Cause Inoperability of Independent Trains or Channels
05000275/FIN-2010002-04	2010Q1	P.2	Less Than Adequate Evaluation Following a Failure of Both Motor Driven Auxiliary Feedwater Trains
05000275/FIN-2010002-03	2010Q1		Failure to Report a Condition That Could Have Prevented the Fulfillment of a Safety Function
05000275/FIN-2010002-02	2010Q1	P.2	Failure to Update the Final Safety Analysis Report with the Current Plant Design Bases
05000323/FIN-2009009-03	2010Q1	P.2	Failure to Evaluate a Change to the Facility as Described in the Final Safety Analysis Report Update Associated with the Addition of Manual Actions in the Safety Analysis
05000275/FIN-2010002-01	2010Q1	P.3	Failure to Effectively Implement the Seismically-Induced Systems Interaction Program
05000275/FIN-2010402-01	2010Q1		Security
05000275/FIN-2010402-02	2010Q1		Security
05000323/FIN-2009009-02	2010Q1	P.2 P.1(a)	Failure to Conduct an Adequate Post-Modification Test
05000323/FIN-2009009-01	2010Q1	P.2	Failure to Follow Design and Configuration Control Requirements

Self-Identified List (Diablo Canyon)

	Q	Title
05000275/FIN-2009403-01	2009Q4	Licensee-Identified Violation
05000275/FIN-2009005-06	2009Q4	Licensee-Identified Violation
05000275/FIN-2010002-06	2010Q1	Licensee-Identified Violation

[Diablo Canyon Findings full list]

05000323/FIN-2009009-03

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