05000298/FIN-2011005-07
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Finding | |
|---|---|
| Title | Failure to Perform Required 10 CFR 50.59 Evaluations for Changes |
| Description | The inspectors identified a non-cited violation of 10 CFR 50.59, Changes, Test, and Experiments, associated with the licensees failure to adequately evaluate changes in order to ensure that they did not require prior NRC approval. Specifically, the inspectors determined that the re-analysis of the turbine building peak pressure in response to a high energy line break event that the licensee had performed used a different calculation method than what had originally been used to support the stations licensing basis. This re-analysis was performed for the purpose of gaining margin on the station doors credited with protecting safety-related equipment from the line break event. This new method resulted in a lower peak turbine building pressure. This issue was entered into the licensees corrective action program as Condition Reports CR-CNS-2011-10391 and CR-CNS-2011-11861. The licensees failure to implement the requirements of 10 CFR 50.59 and adequately evaluate changes was a performance deficiency. The performance deficiency is greater than minor because the failure to follow the requirements of 10 CFR 50.59 and receive prior NRC approval for changes in licensed actions impacted the NRCs regulatory ability, and is, therefore, a finding. Since violations of 10 CFR 50.59 are considered to impede or impact the regulatory process they are dispositioned using the traditional enforcement process. The enforcement manual specifies that the severity level is determined in parallel with the Significance Determination Process. As such, the inspectors concluded that this issue also represented a performance deficiency under the Reactor Oversight Process because the licensee failed to appropriately evaluate the proposed change in accordance with the requirements of Station Procedure 0.8, 10CFR50.59 and 10CFR72.48 Reviews. The performance deficiency was determined to be more than minor because it was associated with the design control attribute of the Mitigating Systems Cornerstone, and affected the associated cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences, and is therefore a finding. Using Manual Chapter 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings, the finding was determined to have very low safety significance because the finding: (1) was not a design or qualification issue confirmed not to result in a loss of operability or functionality; (2) did not represent an actual loss of safety function of the system or train; (3) did not result in the loss of one or more trains of nontechnical specification equipment; and (4) did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The inspectors reviewed this issue in accordance with NRC Inspection Manual Chapter 0612 and the NRC Enforcement Manual and Enforcement Policy and concluded that because the violation was determined to be of very low safety significance, was not repetitive or willful, and was entered into the corrective action program, this violation is being treated as a Severity Level IV non-cited violation consistent with the NRC Enforcement Policy. The finding was determined to have a cross-cutting aspect in the area of human performance, associated with the decision-making component in that the licensee failed to use conservative assumptions in decision making when they failed to recognize that the new calculation methodology was a change to a previously approved methodology |
| Site: | Cooper  |
|---|---|
| Report | IR 05000298/2011005 Section 4OA2 |
| Date counted | Dec 31, 2011 (2011Q4) |
| Type: | TEV: Severity level IV |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71152 |
| Inspectors (proximate) | P Elkmann R Hagar V Gaddy C Graves J Josey L Carson L Ricketson M Chambers N Greenec Gravesj Josey L Carson L Ricketson M Chambers N Greene P Elkmann R Hagar V Gaddy |
| CCA | H.14, Conservative Bias |
| INPO aspect | DM.2 |
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Finding - Cooper - IR 05000298/2011005 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Cooper) @ 2011Q4
Self-Identified List (Cooper)
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