05000482/FIN-2009005-15
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Finding | |
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Title | Failure to Report a Condition that Could Have Prevented Fulfillment of a Safety Function |
Description | The inspectors identified a Severity Level IV noncited violation of 10 CFR 50.73 in which the licensee failed to submit a licensee event report within 60 days following discovery of events or conditions meeting the reportability criteria. On December 31, 2009, the inspectors identified a licensee event report that was no timely. Licensee Event Report 2009-009-00 was not issued within 60 days for a condition prohibited by technical specifications, and the event report did not identify that the disabling of both trains of the P-4 interlock on August 22, 2009 was also reportable per 10 CFR 50.73(a)(2)(v). The P-4 interlock was required by Technical Specification 3.3.2, function 8.a, and is discussed in USAR, Section 7.3.8, NSSS Engineered Safety Feature Actuation System. Wolf Creek licensee event report 2009-009 was correct in that the interlock is not credited in accident analysis. However, NUREG 1022, Section 3.2.6, specifies that inoperable systems required by the technical specifications be reported, even if there are other diverse operable means of accomplishing the safety function. The inspectors reviewed this issue in accordance with Inspection Manual Chapter 0612 and the NRC Enforcement Manual. Through this review, the inspectors determined that traditional enforcement was applicable to this issue because the NRC\'s regulatory ability was affected. Specifically, the NRC relies on the licensee to identify and report conditions or events meeting the criteria specified in regulations in order to perform its regulatory function, and when this is not done, the regulatory function is impacted. The inspectors determined that this finding was not suitable for evaluation using the significance determination process, and as such, was evaluated in accordance with the NRC Enforcement Policy. The finding was reviewed by NRC management, and because the violation was determined to be of very low safety significance, was not repetitive or willful, and was entered into the corrective action program, this violation is being treated as a Severity Level IV noncited violation consistent with the NRC Enforcement Policy. This finding was determined to have a crosscutting aspect in the area of problem identification and resolution associated with the corrective action program in that the licensee failed to appropriately and thoroughly evaluate for reportability aspects all factors and time frames associated with the inoperability of the engineered safety features actuation system P.1(c) (Section 4OA3) |
Site: | Wolf Creek |
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Report | IR 05000482/2009005 Section 4OA3 |
Date counted | Dec 31, 2009 (2009Q4) |
Type: | TEV: Severity level IV |
cornerstone | Miscellaneous |
Identified by: | NRC identified |
Inspection Procedure: | IP 71153 |
Inspectors (proximate) | G Vasquez J Drake P Jayroe R Kopriva S Alferink A Fairbanks C Alldredge C Cauffman C Long C Peabody D Graves D Loveless G Miller |
CCA | P.2, Evaluation |
INPO aspect | PI.2 |
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Finding - Wolf Creek - IR 05000482/2009005 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Wolf Creek) @ 2009Q4
Self-Identified List (Wolf Creek)
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