05000333/FIN-2013002-03
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Finding | |
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| Title | Failure to Obtain NRC Staff Review and Approval Prior to Changing the TS Definition of a Core Quadrant |
| Description | The inspectors identified a Severity Level (SL) IV non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) 50.59, Changes, Tests, and Experiments, because Entergy personnel implemented a change to the technical specification (TS) definition of core quadrant without prior review and approval by the NRC staff in accordance with 10 CFR 50.59(c)(1)(i). Specifically, Entergy staff changed the definition of core quadrant in Revision 5 of Reactor Analyst procedure RAP-7.1.04C, Neutron Instrumentation Monitoring During In-Core Fuel Handling, which allowed operators to interpret what constitute core quadrant boundaries, such that core alterations could be performed anywhere in the core provided any three source range [neutron] monitors (SRMs) were operable. As immediate corrective action to the task interface agreement (TIA) final response, FitzPatrick staff withdrew RAP-7.1.04C pending revision of the core quadrant definition. The inspectors verified that TS 3.3.1.2.2 had been satisfied during all core alterations that were performed during the 2010 and 2012 refueling outages, using the standard definition of a core quadrant. Entergy staff entered this issue into the corrective action program (CAP) as condition report (CR)-HQN-2013-00034. The inspectors determined that Entergy staffs implementation of a redefinition of core quadrant prior to its review and approval by the NRC staff as specified in 10 CFR 50.59(c)(1)(i) was a performance deficiency that was reasonably within Entergy staffs ability to foresee and correct. Because this was a violation of 10 CFR 50.59, it was considered to be a violation that potentially impedes or impacts the regulatory process. Therefore, this violation was characterized using the traditional enforcement process. The violation was determined to be more than minor in accordance with the NRC Enforcement Manual, Section 7.3.E.6, because there was a reasonable likelihood that the change to the definition of what constituted a core quadrant boundary would require Commission review and approval prior to implementation. Additionally, the inspectors noted that, in accordance with Inspection Manual Chapter (IMC) 0612, Appendix B, Issue Screening, the underlying performance deficiency would screen as more than minor because, if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, potentially inadequate SRM coverage during refueling operations could affect the TS bases function to provide early indication of unexpected subcritical multiplication that could be indicative of an approach to criticality. NRC Enforcement Manual Section 7.3 provides guidance to assess 10 CFR 50.59 violations through the significance determination process (SDP). In this case, the inspectors determined the violation could be evaluated using the SDP in accordance with IMC 0609 Appendix G, Shutdown Operations Significance Determination Process, Checklist 7, BWR Refueling Operation with RCS Level Greater Than 23 Feet. The finding affected the Reactivity Guidelines attribute that assumes existing core alteration TS are being met. Since this attribute does not require quantitative assessment, the finding was screened as Green in accordance with Section 3.3, Mitigation Capability. In accordance with the NRC Enforcement Policy, Section 6.1.d.2, this violation was categorized as SL IV because the issue was evaluated by the SDP as having very low safety significance (Green). The finding did not have a cross-cutting aspect because the performance deficiency did not occur within the past three years and therefore was not reflective of present performance. |
| Site: | FitzPatrick  |
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| Report | IR 05000333/2013002 Section 4OA5 |
| Date counted | Mar 31, 2013 (2013Q1) |
| Type: | TEV: Severity level IV |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | |
| Inspectors (proximate) | S Mccarver J Laughlin E Knutson B Sienel A Burritt E Miller |
| Violation of: | 10 CFR 50.59 Technical Specification - Procedures Technical Specification |
| INPO aspect | |
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Finding - FitzPatrick - IR 05000333/2013002 | |||||||||||||||||||||||||||||||||||
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Finding List (FitzPatrick) @ 2013Q1
Self-Identified List (FitzPatrick)
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