05000285/FIN-2016008-01
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Finding | |
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| Title | Failure to Obtain Prior NRC Approval for a Change When Required |
| Description | The inspectors identified a Severity Level IV, Green, non-cited violation of 10 CFR 50.59, Changes, Tests, and Experiments, Section (c)(1), which states, in part, that a licensee may make changes in the facility as described in the final safety analysis report (as updated) without obtaining a license amendment pursuant to 10 CFR 50.90 only if: (i) a change to the technical specifications incorporated in the license is not required, and (ii) the change, test, or experiment does not meet any of the criteria in paragraph (c)(2). Title 10 CFR 50.59, Section (c)(2), states, in part, that a licensee shall obtain a license amendment pursuant to Section 50.90 prior to implementing a proposed change, test, or experiment if the change, test, or experiment would result in more than a minimal increase in the likelihood of occurrence of a malfunction of a structure, system, or component important to safety previously evaluated in the final safety analysis report (as updated). Specifically, from June 9, 2015 through August 11, 2016, the licensee implemented a change to Operating Instruction OI-VA-2, Auxiliary Building Ventilation System Normal Operation, Attachment 11, Revision 47, after incorrectly concluding that the opening of certain high-energy line break barriers and selected fire barrier doors to allow supplemental cooling of both safety-related switchgear rooms did not increase the likelihood of occurrence of a malfunction of a structure, system, or component important to safety previously evaluated in the final safety analysis report. In response to this issue, the licensee revised entry conditions to Operating Instruction OI-VA-2, Attachment II, to ensure that high energy line break barriers are not impaired prematurely. This finding was entered into the licensees corrective action program as Condition Report CR-2016-06667. The licensees failure to implement the requirements of 10 CFR 50.59 and adequately evaluate the disabling of certain high-energy line break barriers to facilitate supplemental cooling of both safety-related switchgear rooms was a performance deficiency. This finding was evaluated using traditional enforcement because it had the potential for impacting the NRCs ability to perform its regulatory function. In accordance with Section 2.1.3.E.6 of the NRC Enforcement Manual, the inspectors used Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process For Findings At-Power, dated June 19, 2012, to determine that this performance deficiency was of very low safety significance (Green) because it (1) was not a deficiency affecting the design or qualification of a mitigating structure, system, or component and did not result in a loss of operability or functionality; (2) did not represent a loss of system and/or function; (3) did not represent an actual loss of function of at least a single train for longer than its technical specification allowed outage time, or two separate safety systems out-ofservice for longer than its technical specification allowed outage time; and (4) did not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety significance in accordance with the licensees maintenance rule program. Therefore, in accordance with Section 6.1.d.2 of the NRC Enforcement Policy, the inspectors characterized this performance deficiency as a Severity Level IV violation. As described in Inspection Manual Chapter 0612, Power Reactor Inspection Reports, no cross-cutting aspect was assigned to this violation because traditional enforcement violations are not assessed for cross-cutting aspects. |
| Site: | Fort Calhoun  |
|---|---|
| Report | IR 05000285/2016008 Section 1R17 |
| Date counted | Sep 30, 2016 (2016Q3) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.17 |
| Inspectors (proximate) | J Braisted R Latta S Graves T Farnholtz |
| Violation of: | 10 CFR 50.59 |
| INPO aspect | |
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Finding - Fort Calhoun - IR 05000285/2016008 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Fort Calhoun) @ 2016Q3
Self-Identified List (Fort Calhoun)
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