05000331/FIN-2016007-02
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Finding | |
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| Title | Failure to Document 50.59 Evaluation for UFSAR Change Concerning Radiological Dose Consequence Analysis Methodology |
| Description | The inspectors identified a Severity Level IV, NCV of 10 CFR 50.59, Changes, Tests, and Experiments, having very-low safety significance (Green) for the licensees failure to document the basis for making a change to Updated Final Safety Analysis Report (UFSAR) Table 15.0-2 to allow the use of RADTRAD Version 3.03 for all Chapter 15 Accidents. Specifically, the licensee failed to demonstrate that the change to UFSAR Table 15.0-2 did not constitute a Departure from a Method of Evaluation described in the UFSAR and would have never required prior NRC review and approval. The inspectors determined that the failure to evaluate whether the change to UFSAR Table 15-0.2 constituted a Departure from a Method of Evaluation was contrary to 10 CFR 50.59(d)(1) and was a PD. The PD was determined to be more than minor, and a finding, because if left uncorrected, the PD had the potential to become a more significant safety concern. Specifically, the inspectors could not reasonably determine that use of RADTRAD version 3.03 for all UFSAR Chapter 15 Accidents would not have increased the control room dose value during accidents. In addition, the associated violation was determined to be more than minor because the inspectors could not reasonably determine that the changes would not have ultimately required NRC prior approval. The inspectors determined that finding could be evaluated using the SDP in accordance with IMC 0609, Significance Determination Process. Using Attachment 0609.04, Initial Characterization of Findings, Table 2 the inspectors determined that the finding affected the Barrier Integrity cornerstone. As a result, the inspectors evaluated the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 3 for the Barrier Integrity cornerstone. The inspectors answered Yes to question C.1 in Exhibit 3 Barrier Integrity Screening Questions. Specifically, the inspectors determined the finding only represented a degradation of the radiological barrier function provided for the control room. In accordance with Section 6.1.d 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 (i.e., green finding). In accordance with IMC 0612, Power Reactor Inspection Reports, Section 07.03.c, the inspectors did not assign a cross-cutting aspect to this violation because the violation and underlying technical finding was not indicative of current plant performance. |
| Site: | Duane Arnold  |
|---|---|
| Report | IR 05000331/2016007 Section 1R17 |
| Date counted | Mar 31, 2016 (2016Q1) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.17 |
| Inspectors (proximate) | A Shaikh I Khan J Bozga R Daley |
| Violation of: | 10 CFR 50.59 |
| INPO aspect | |
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Finding - Duane Arnold - IR 05000331/2016007 | |||||||||||||||||||||||||||||
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Finding List (Duane Arnold) @ 2016Q1
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