05000315/FIN-2016003-04
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Finding | |
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| Title | Licensee-Identified Violation |
| Description | The following violation of very low significance (Green) or Severity Level IV was identified by the licensee and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as an NCV. The licensee identified a finding and NCV of 10 CFR 50.59 for the failure to properly evaluate modifications to the facility. Specifically, Evaluation 2010001600 failed to addresses each of the changes associated with proposed changes to the UFSAR to incorporate revised analysis to control room and offsite radiological dose consequences for the design bases accident. While preparing a revision to evaluation 2010001600, the preparer noted numerous discrepancies which were documented in AR 201214068. Because of the complex nature of the revisions and licensing history of Cooks dose consequence analysis, the licensee determined use of the 50.59 process would not resolve the discrepancies in the current license bases and concluded the appropriate corrective action would be preparation and submittal of a license amendment to fully implement alternate source term as part of the D. C. Cook license. The licensee has submitted the license amendment request and it is now approved. The inspectors determined that the failure of the licensee to demonstrate via the 50.59 process that the change to the licensee could be made without prior NRC approval was a performance deficiency. In accordance with the NRC Enforcement Policy, August 2016, changes made contrary to 10 CFR 50.59 impact the agencys ability to regulate and warrant enforcement. Examples provided in this Enforcement Policy stipulate that an associated SDP finding of very low safety significance would result in a Severity Level IV finding. The inspectors did not identify any physical changes to the facility based on the changes made to the UFSAR nor any other changes suitable for review in the SDP. Therefore, the inspectors determined there was no associated ROP finding and the issue was a Severity Level IV violation of 50.59. 10 CFR 50.59 requires in part, that a licensee must obtain a license amendment prior to implementing a change if it would result in a departure from a method described in the UFSAR used in establishing the design bases or in the safety analysis. Contrary to this requirement on February 25, 2010, evaluation 20100016 accepted changes to the UFSAR that affected methodologies for control room and offsite dose that departed from methods described in the UFSAR. Because the licensee identified this issue in AR 201214068 and took corrective actions to submit a license amendment and is Severity Level IV, the inspectors conclude that this issue may be disposed as a licensee identified NCV. |
| Site: | Cook  |
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| Report | IR 05000315/2016003 Section 4OA7 |
| Date counted | Sep 30, 2016 (2016Q3) |
| Type: | TEV: Severity level IV |
| cornerstone | Mitigating Systems |
| Identified by: | Licensee-identified |
| Inspection Procedure: | |
| Inspectors (proximate) | J Bozga J Ellegood K Riemer T Go T Taylor |
| Violation of: | 10 CFR 50.59 |
| INPO aspect | |
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Finding - Cook - IR 05000315/2016003 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Cook) @ 2016Q3
Self-Identified List (Cook)
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