05000315/FIN-2014007-02
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Finding | |
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| Title | Failure to Evaluate the Adverse Effects of TRM Section Deletion |
| Description | The inspectors identified a Severity Level IV Non-Cited Violation of 10 CFR 50.59(d)(1), Changes, Tests, and Experiments, and an associated finding of very low safety significance (Green) for the licensees failure to perform a written safety evaluation that provided the bases for the determination that the deletion of Technical Requirement Manual, Section 8.4.3, ASME Code Class 1, 2, and 3 Components, did not require a license amendment. Specifically, the licensee did not evaluate the adverse effects of the change. The licensee entered this issue into their Corrective Action Program and initiated corrective actions to implement compensatory measures in accordance with the deleted section of the Technical Requirement Manual. The performance deficiency was determined to be more than minor because, if left uncorrected, it would become a more significant safety concern. In addition, the associated traditional enforcement violation was more than minor because the inspector could not reasonably determine that the changes would not have ultimately required NRC prior approval. The finding was of very low safety significance (Green) based on the inspectors review of corrective action documents associated with non-conforming conditions related to structural integrity of ASME components generated since the TRM removal. Specifically, the inspectors used the two most bounding cases for the evaluation and determined the issues did not result in the loss of operability or functionality, represent a loss of system and/or function, represent an actual loss of function exceeding the Technical Specification allowed outage time, or represent an actual loss of function of non-Technical Specification equipment designated as high safety significant in accordance with the licensees Maintenance Rule Program. This finding had a cross-cutting aspect in the area of problem identification and resolution because the licensee did not take effective corrective actions to address the issue. Specifically, the licensee identified that they had not evaluated the adverse effects of deleting Section 8.4.3 of the Technical Requirement Manual and, as a result, they performed a 50.59 evaluation. However, the evaluation did not address these adverse effects. |
| Site: | Cook  |
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| Report | IR 05000315/2014007 Section 1R17 |
| Date counted | Mar 31, 2014 (2014Q1) |
| Type: | Finding: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.17 |
| Inspectors (proximate) | D Betancourt R Daley |
| CCA | P.3, Resolution |
| INPO aspect | PI.3 |
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Finding - Cook - IR 05000315/2014007 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Cook) @ 2014Q1
Self-Identified List (Cook)
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