05000280/FIN-2016001-01
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Finding | |
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| Title | Failure to Perform a 10 CFR 50.59 Evaluation for Blocking Ventilation to Main Steam Valve Houses |
| Description | An NRC-identified finding of very low safety significance and an associated Severity Level IV NCV of 10 CFR 50.59, Changes, Tests, and Experiments, was identified when the licensee failed to perform and maintain a written evaluation to demonstrate that a procedure change did not require a license amendment. Specifically, the licensee implemented a change to procedure 0-OP-ZZ-021, Severe Weather Preparation, Revision 12, to allow installation of tarpaulins over the main steam valve house (MSVH) ventilation louvers thereby changing the Updated Final Safety Analysis Report (UFSAR) facility design without maintaining supporting calculations. The licensees failure to perform a 10 CFR 50.59 evaluation was a performance deficiency (PD). The inspectors determined that the PD was more than minor because it was associated with the design control attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the change allowed the ventilation of the MSVH to be blocked and the lack of engineering calculations resulted in a condition where there was a reasonable doubt about the operability of the auxiliary feedwater (AFW) pumps for their required mission time. Using Manual Chapter 0609.04, Initial Characterization of Findings, Table 2, dated June 19, 2012; the finding was determined to adversely affect the Mitigating Systems Cornerstone. The inspectors screened the finding using Inspection Manual Chapter (IMC) 0609, Appendix A, Significance Determination Process (SDP) for Findings at-Power, dated June 19, 2012, and determined that it screened as Green because the PD did not affect the design or qualification of the AFW system and it did not represent an actual loss of system safety function. Using IMC 0310, Aspects within the Cross-Cutting Areas, dated December 4, 2014, the inspectors determined that the finding had a cross-cutting aspect in the procedure adherence component of the human performance area, H.8, because the licensee failed to follow processes, procedures and work instructions for the 50.59 applicability review when changing the severe weather preparation procedure. Additionally, the failure to perform a 10 CFR 50.59 evaluation was determined to be more-than-minor in accordance with the guidance in the NRC Enforcement Manual for traditional enforcement violations, because the MSVH louvers were actually covered and there was a reasonable likelihood that the lack of MSVH ventilation could affect the operability of the AFW pumps for their required mission time. The failure constitutes a violation of 10 CFR 50.59, which impacts the regulatory process and therefore, was evaluated through the traditional enforcement process. The SDP, which was used to evaluate this performance deficiency, does not specifically consider the impact on the regulatory process. Thus, although related to a common regulatory concern, it is necessary to address both the violation and finding using different processes to correctly reflect both the regulatory importance of the violation and the safety significance of the associated performance deficiency. |
| Site: | Surry  |
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| Report | IR 05000280/2016001 Section 1R01 |
| Date counted | Mar 31, 2016 (2016Q1) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.01 |
| Inspectors (proximate) | C Jones G Eatmon P Mckenna S Rose |
| Violation of: | 10 CFR 50.59 |
| INPO aspect | |
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Finding - Surry - IR 05000280/2016001 | |||||||||||||||||||||||||||||||||||||||||||
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Finding List (Surry) @ 2016Q1
Self-Identified List (Surry)
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