05000220/FIN-2013002-05
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Finding | |
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| Title | Failure to Perform a 50.59 Evaluation for a Procedure Change |
| Description | The inspectors identified a Severity Level IV NCV and associated Green finding (FIN) of Title 10 of the Code of Federal Regulations (10 CFR) 50.59, Changes, Tests and Experiments, because Unit 1 failed to perform a written 50.59 evaluation for changes to the operating procedure for the shutdown cooling system (SDCS) isolation valves. Specifically, Constellation added steps to the procedure to defeat the design basis safety function of the SDCS isolation valves to automatically isolate on a RPV low-low water level signal without performing a written 50.59 evaluation. Constellation entered this issue into their CAP as CR-2012-009540. The inspectors determined that Constellations failure to perform a written 50.59 evaluation for changes to N1-OP-4, Shutdown Cooling System, Revision 03701, as required by 10 CFR 50.59 was a performance deficiency that was reasonably within Constellations ability to foresee and correct and should have been prevented. Because this issue had the potential to affect the NRCs ability to perform its regulatory function, the inspectors evaluated the performance deficiency in accordance with the traditional enforcement process. The violation was determined to be more than minor because the inspectors could not reasonably determine that the changes would not have ultimately required NRC prior approval, because the change resulted in a more than minimal change in the frequency of occurrence of a previously evaluated accident (LOCA). However, both the NRC Enforcement Policy and NRC IMC 0612 Appendix B, Issue Screening, direct the inspector to evaluate the finding under the SDP as well. Under the SDP, this finding is more than minor because it is associated with the equipment performance attribute of the Initiating Events cornerstone and affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, by failing to maintain the safety function of the SDCS isolation valves to automatically isolate on low-low RPV water level, Unit 1 increased the likelihood of a loss-of-coolant accident (LOCA). In accordance with IMC 0609.04, Initial Characterization of Findings, IMC 0609 Appendix G, Shutdown Operations Significance Determination Process, and Checklist 6 of IMC 0609 Appendix G, Attachment 1, BWR Cold Shutdown or Refueling Operation, Time to Boil <2 hours: RCS Level <23 feet Above Top of Flange, the inspectors determined this finding to be of very low safety significance (Green) because this finding was not a loss of control and did not impact checklist attributes requiring a Phase 2 or Phase 3 analysis. Therefore, in accordance with Section 6.1.d.2 of the NRC Enforcement Policy, this violation is also categorized as a Severity Level IV (more than minor concern that resulted in no or relatively inappreciable potential safety or security consequence) violation because the resulting conditions were evaluated as having very low safety significance (Green) by the SDP. The inspectors did not assign a cross-cutting aspect to this finding because the performance deficiency is not indicative of present performance because it did not occur within the last 3 years. |
| Site: | Nine Mile Point  |
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| Report | IR 05000220/2013002 Section 4OA3 |
| Date counted | Mar 31, 2013 (2013Q1) |
| Type: | NCV: Green |
| cornerstone | Initiating Events |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71153 |
| Inspectors (proximate) | D Schroeder K Kolaczyk B Haagensen J Laughlin T Ziev B Dionne E Miller |
| Violation of: | 10 CFR 50.59 |
| INPO aspect | |
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Finding - Nine Mile Point - IR 05000220/2013002 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Nine Mile Point) @ 2013Q1
Self-Identified List (Nine Mile Point)
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