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Failure to Perform a 10 CFR 50.59 Evaluation for a Change to Engineering Safety Features Actuation Periodic Test.
The inspectors identified a Severity Level (SL) IV NCV of 10 CFR 50.59, Changes, Tests, and Experiments, for the licensees failure to perform a written safety evaluation prior to implementing a change to licensee procedure PT/1/A/4200/009 Engineering Safety Features Actuation periodic test (ESFAS). This procedure was last used during refueling outage 22 (November 2015) and resulted in a missed surveillance for TS surveillance requirements (SR) 3 220.127.116.11 and 18.104.22.168. The licensee took corrective actions to revise the ESFAS procedure and complete repairs of the 1A auxiliary shutdown panel supply unit (ASPSU) to allow complete testing of the ESFAS logic circuitry during the next refueling outage in accordance with SR 3.0.3 (November 2018). The licensee entered this issue into the CAP as CR 2124814.The failure to perform a 10 CFR 50.59 safety evaluation for a change to procedure PT/1/A/4200/009, Engineering Safety Features Actuation periodic test (ESFAS) was a performance deficiency. This performance deficiency was determined to be more than minor because there was a reasonable likelihood that the change would have required Commission review and approval prior to implementation in accordance with 10 CFR 50.59(c)(2). Violations of 10 CFR 50.59 are dispositioned using the traditional enforcement process because they are considered to be violations that could potentially impede or impact the regulatory process. However, when possible, the underlying technical issue is evaluated under the SDP to determine the significance of the violation. The performance deficiency impacted the mitigating systems cornerstone. The inspectors determined the issue to be of very low safety significance (Green) because it did not represent an actual loss of function of at least a single train for greater than its technical specification allowed outage time and did not represent an actual loss of function of one or more non-tech spec trains of equipment designated as high safety-significant in accordance with the licensees maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. In accordance with Section 6.1.d the NRC Enforcement Policy, issued November 1, 2016, a traditional enforcement violation of 10 CFR 50.59 that results in conditions evaluated as having very low safety significance (i.e., Green) by the SDP is considered to be a SL IV violation. There was no cross-cutting aspect associated with this violation because cross-cutting aspects are not assigned to traditional enforcement violations.
|Report||IR 05000413/2017004 Section 1R15|
|Date counted||Dec 31, 2017 (2017Q4)|
|Identified by:||NRC identified|
|Inspection Procedure:||IP 71111.15|
|Inspectors (proximate)||J Austin|
|Violation of:||10 CFR 50.59, Changes, tests and experiments|
Finding List (Catawba) @ 2017Q4