05000423/FIN-2016001-03
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Finding | |
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| Title | Licensee-Identified Violation |
| Description | Dominion identified a Severity Level (SL) IV NCV of 10 CFR 50.59(d)(1), Changes, Tests, and Experiments, for the failure to perform an evaluation of a change to the facility as described in the UFSAR which would have required prior approval. During a design basis review of Millstone Unit 3 SW system, Dominion discovered that multiple fittings installed in the system beginning in 1989 were manufactured with Nickel Copper Alloy (UNS N04400) per material specification SB366. Although a material with improved properties, this is not an ASME Boiler Pressure Vessel Code of record Section III (ASME III) permitted material fabrication specification without required additional documentation. The Millstone Unit 3 UFSAR Table 3.2-1, List of QA Category I and Seismic Category I Structures, Systems, and Components, Revision 24.3, requires the SW system to be compliant with ASME III Code Class 3. The inspectors determined that the failure of Dominion to perform written evaluations in accordance with 10 CFR 50.59(d)(1) when installing non-conforming material into Unit 3 beginning in 1989 was a performance deficiency which was within Dominions capability to foresee and prevent. The inspectors identified this condition as more than minor as installation of an ASME III non-conforming material into the Unit 3 SW system would have required prior approval. Because the performance deficiency impacted the ability of the NRC to perform its regulatory function, the inspectors evaluated the issue using the traditional enforcement process. In accordance with the NRC Enforcement Policy, Section 6.1.d.2, this condition screened as SL IV as it was assessed as having very low safety significance (Green) by IMC 0609, Significance Determination Process, when the screening questions were all answered No. 10 CFR 50.59(d)(1), Changes, Tests, and Experiments, states in part, The licensee shall maintain records of changes in the facility, of changes in procedures, and of tests and experiments made pursuant to paragraph (c) of this section. These records must include a written evaluation which provides the bases for the determination that the change, test, or experiment does not require a license amendment pursuant to paragraph (c)(2) of this section. Contrary to the above, from March 1993 through March 29, 2016, Dominion did not perform written evaluations to provide the bases for determining that a change, test, or experiment made pursuant to 10 CFR 50.59(c)(2) did not require a license amendment for installation of SB-366 components into the SW system. Because Dominion identified this issue of very low safety significance (Green) and it has been entered into their CAP (CR1031360), this finding is being treated as a SL IV, licensee-identified NCV consistent with the NRC Enforcement Policy Section 2.3.2. This item was considered licensee identified since Dominion identified this issue during a design basis review. |
| Site: | Millstone  |
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| Report | IR 05000423/2016001 Section 4OA7 |
| Date counted | Mar 31, 2016 (2016Q1) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | Licensee-identified |
| Inspection Procedure: | |
| Inspectors (proximate) | C Highley C Newport G Dentel J Ambrosini K Reid L Mckown |
| Violation of: | 10 CFR 50.59 |
| INPO aspect | |
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Finding - Millstone - IR 05000423/2016001 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Millstone) @ 2016Q1
Self-Identified List (Millstone)
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