05000305/FIN-2010004-03
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Finding | |
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| Title | Replacement of Automatic Action with an Operator Manual Action Without Prior NRC Approval |
| Description | A Severity Level IV NCV of 10 CFR 50.59(d)(1), Changes, Tests, and Experiments, was identified by the inspectors for the failure to document an evaluation that provided a basis for the determination that the changes implemented in DCR 3163 and Emergency Operating Procedure ES-1.3, Transfer to Sump Recirculation, in 2001 did not require a license amendment. Specifically, the licensee failed to provide an evaluation that adequately documented why replacing the automatic opening of the service water (SW) valves SW-1300A and SW-1300B upon a safety injection signal (to support the service water safety function of loss of coolant accident (LOCA) recirculation operation) with a manual action to open the valves in Emergency Operating Procedure ES 1.3, did not present more than a minimal increase in the likelihood of occurrence of a malfunction of a structure, system, or component (SSC) important to safety previously evaluated in the updated safety analysis report. The licensee initiated CR389330 and, at the end of the inspection period, planned to submit a license amendment request to the NRC for this design change. The violation was determined to be more than minor because the inspectors could not reasonably determine that the changes would not have ultimately required prior NRC approval. Violations of 10 CFR 50.59 are dispositioned using the traditional enforcement process instead of the SDP because they are considered to be violations that potentially impede or impact the regulatory process. However, if possible, the underlying technical issue is evaluated under the SDP to determine the severity of the violation. In this case, the inspectors determined the finding could be evaluated using the SDP in accordance with IMC 0609, Significance Determination Process, Attachment 0609.04, Phase 1 - Initial Screening and Characterization of Findings, Tables 3b and 4a, for the Mitigating Systems Cornerstone. The inspectors answered yes to question 1 of the Mitigating Systems Cornerstone column of the Phase 1 worksheet because the inspectors concluded that this was a design basis deficiency confirmed not to result in the loss of operability. Based upon this Phase 1 screening, the inspectors concluded that the issue was of very low safety significance (Green). In accordance with Section 6.1.d.2 of the NRC Enforcement Policy this violation is categorized as Severity Level IV because the resulting changes were evaluated by the SDP as having very low safety significance. The inspectors determined that this finding did not reflect present performance since the error was introduced in a design change that was greater than three years old; therefore, there was no cross-cutting aspect associated with this finding. |
| Site: | Kewaunee  |
|---|---|
| Report | IR 05000305/2010004 Section 1R18 |
| Date counted | Sep 30, 2010 (2010Q3) |
| Type: | TEV: Severity level IV |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.18 |
| Inspectors (proximate) | R Winter J Jandovitz J Cassidy M Kunowski R Krsek K Barclay P Cardona-Morales |
| INPO aspect | |
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Finding - Kewaunee - IR 05000305/2010004 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Kewaunee) @ 2010Q3
Self-Identified List (Kewaunee)
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