05000440/FIN-2016004-02

Finding

Title

Modifications to Underdrain and Gravity Discharge System Manhole Covers Without a 10 CFR 50.59 Safety Evaluation

Description

Green-Severity Level IV. The inspectors identified a Severity Level IV NCV of 10 CFR 50.59(d)(1), Changes, Test, and Experiments, and an associated finding, for the licensees failure to perform a written evaluation which provided the bases for the determination that a change did not require a license amendment. Specifically, the licensee made a change pursuant to 10 CFR 50.59(c) with the installation of grated manhole covers, replacing the rubber gasket, watertight manhole covers for the underdrain and gravity discharge systems and did not provide a basis for the determination that this change would not result in a more than a minimal increase in the likelihood of occurrence of a malfunction of a system structure or component important to safety. The licensee entered this issue into the CAP as CR 201611864 and performed a prompt operability determination to show that the underdrain and gravity drain systems remained functional while the engineering change package was developed to support the change and bring the underdrain and gravity discharge systems into compliance with the design basis. The performance deficiency was determined to be more than minor in accordance with Inspection Manual Chapter (IMC) 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated September 7, 2012, because it was associated with the Mitigating Systems cornerstone attribute of equipment performance and adversely affected the cornerstone attribute of protection against external factors and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Per IMC 0609, Attachment 4, Initial Characterization of Findings, and Appendix A, The Significance Determination Process for Findings at Power, the finding was screened against the Mitigating Systems Screening Questions and determined to be of very low safety significance (Green) because the finding did not cause the underdrain and gravity discharge systems to become inoperable or non-functional. Traditional enforcement applied to this finding because it involved a violation that impacted the regulatory process. The inspectors determined it to be of Severity Level IV because it resulted in a condition evaluated by the SDP as having very low safety significance (Enforcement Policy example 6.1.d.2). The inspectors determined that the finding had a cross-cutting aspect in the area of human performance, procedure adherence, in that individuals did not follow processes, procedures, and work instructions. Specifically, a design engineer authorized the permanent modification to be made without the required 50.59 evaluation being completed [H.8].

02
Site:	Perry
Report	IR 05000440/2016004 Section 1R18
Date counted	Dec 31, 2016 (2016Q4)
Type:	NCV: Green
cornerstone	Mitigating Systems
Identified by:	NRC identified
Inspection Procedure:	IP 71111.18
Inspectors (proximate)	A Dahbur G Hansen J Cameron J Nance J Robbins M Bielby M Doyle M Jones M Marshfield N Feliz-Adorno R Baker R Ng S Bell T Briley V Petrella
Violation of:	10 CFR 50.59
CCA	H.8, Procedure Adherence
INPO aspect	WP.4
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v • d • e

Finding - Perry - IR 05000440/2016004

1(4)2(3)3(0)4(4)5(0)6(0)7(3)8(4)9(2)201(0)403(1)404(0)406(2)407(1)502(0)

IR 05000440/2016004: 1 2 3 4

Finding List (Perry) @ 2016Q4

CCA Matrix: 2016Q4

	Q	CCA	Title
05000440/FIN-2016008-01	2016Q1		Coincidence Logic to Preclude Spurious Trips of the Offsite Power Source
05000440/FIN-2016403-01	2016Q1	H.4	Security
05000440/FIN-2016001-01	2016Q1	H.1	Failure to Properly Implement System Operating Instructions to Maintain Control of Reactor Pressure Vessel Level
05000440/FIN-2016001-02	2016Q1	H.1	Failure to Control Welding and Inspection Activities to Maintain Reactor Coolant System Integrity
05000440/FIN-2016001-03	2016Q1	H.12	Failure to Take Actions to Prevent a Loss of Safety Function during Reactor Recirculation Pump Downshift
05000440/FIN-2016008-02	2016Q1	H.14	Failure to Provide Instructions to Completely Vent Reference Legs
05000440/FIN-2016008-03	2016Q1	H.11	Hardcard Development Failed to Follow Procedure Change Process
05000440/FIN-2016008-04	2016Q1	H.7	Failure to Maintain Traceability of Safety Related Fuses
05000440/FIN-2016007-02	2016Q2	P.1	Use of Unapproved Standard for Site Flooding Modifications and Analysis
05000440/FIN-2016002-01	2016Q2	H.8	Failure to Comply with ODCM During Liquid Effluent Discharge
05000440/FIN-2016007-03	2016Q2	H.6	Failure to Comply With ASME Code Requirements for Repair on Code Class 1 Component
05000440/FIN-2016007-01	2016Q2	H.8	Failure to Document 50.59 Evaluation for Replacement of a Manual Action with an Automatic Action
05000440/FIN-2016009-01	2016Q3	H.8	Failure to Implement a Periodic Replacement Program for FLEX Hoses
05000440/FIN-2016009-02	2016Q3	H.5	Failure to Establish a Periodic Maintenance Program for Communications Equipment Associated with FLEX
05000440/FIN-2016004-02	2016Q4	H.8	Modifications to Underdrain and Gravity Discharge System Manhole Covers Without a 10 CFR 50.59 Safety Evaluation
05000440/FIN-2016004-01	2016Q4	H.12	ECC B Heat Exchanger Flow Root Valves Out of Position
05000440/FIN-2016407-01	2016Q4	H.13	Security
05000440/FIN-2016406-01	2016Q4		Security
05000440/FIN-2016004-04	2016Q4		Failure to Notify the NRC within Eight Hours of a Non-Emergency Event that Could Have Prevented the Fulfillment of a Safety Function
05000440/FIN-2016004-03	2016Q4		RCS Pressure Boundary Leakage Operation Prohibited by TSs

Self-Identified List (Perry)

	Q	Title
05000440/FIN-2016002-02	2016Q2	Licensee-Identified Violation
05000440/FIN-2016002-03	2016Q2	Licensee-Identified Violation
05000440/FIN-2016406-02	2016Q4	Licensee-Identified Violation

[Perry Findings full list]

05000440/FIN-2016004-02

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