05000305/FIN-2012005-03
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Finding | |
|---|---|
| Title | Removal of Refueling Procedure Requirement For Spent Fuel Pool Cooling Without Prior NRC Approval |
| Description | The inspectors identified a Severity Level (SL) IV NCV of 10 CFR 50.59(d)(1), Changes, Tests, and Experiments, and associated finding of very low safety significance for the failure to document an evaluation that provided a basis for the determination that the changes implemented in Procedure RF-01.00, KNPP [Kewaunee Nuclear Power Plant] Refueling Procedure, Revision I, did not require a license amendment in 2001. Specifically, the licensee failed to include, in the written evaluation, a basis as to why the change did not create a possibility for a malfunction of an structure, system or component (SSC) important to safety with a different result than any previously evaluated in the Updated Safety Analysis Report (USAR) and did not result in a departure from a method of evaluation described in the USAR used in establishing the design bases. The changes to procedure RF-01.00 removed a requirement to place the residual heat removal (RHR) A heat exchanger in parallel with the spent fuel pool (SFP) heat exchanger, when a full core offload took place with service water temperatures greater than or equal to 60 degrees Fahrenheit (◦F). The licensee initiated condition report (CR) 493206, and at the end of the inspection period, was conducting a causal evaluation and developing corrective actions to restore the required actions to the refueling procedure. The violation was determined to be more than minor in accordance with IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated September 7, 2012, because the performance deficiency adversely affected the Barrier Integrity Cornerstone objective to maintain functionality of the SFP cooling system. Specifically, the configuration control and design control attributes, related to the design margins for the SFP, increase in allowable fuel assemblies as documented in License Amendment No. 150. 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, Initial Characterization of Findings, dated June 19, 2012 and Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 3, Barrier Integrity Screening Questions, dated June 19, 2012. The inspectors answered No to questions 1 through 4 in Section D, Spent Fuel Pool, and screened the finding as having very low safety significance (Green). In accordance with Section 6.1.d.2 of the NRC Enforcement Policy, this violation is categorized as SL 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 05000305/2012005 Section 1R04 |
| Date counted | Dec 31, 2012 (2012Q4) |
| Type: | TEV: Severity level IV |
| cornerstone | Barrier Integrity |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.04 |
| Inspectors (proximate) | J Beavers V Myers K Carrington D Mcneil R Winter K Riemer J Jandovitz C Moore J Laughlin R Krsek K Barclay |
| INPO aspect | |
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Finding - Kewaunee - IR 05000305/2012005 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Kewaunee) @ 2012Q4
Self-Identified List (Kewaunee)
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