05000440/FIN-2016004-02
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Finding | |
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| Title | Modifications to Underdrain and Gravity Discharge System Manhole Covers Without a 10 CFR 50.59 Safety Evaluation |
| Description | Green-Severity Level IV. The inspectors identified a Severity Level IV NCV of 10 CFR 50.59(d)(1), Changes, Test, and Experiments, and an associated finding, for the licensees failure to perform a written evaluation which provided the bases for the determination that a change did not require a license amendment. Specifically, the licensee made a change pursuant to 10 CFR 50.59(c) with the installation of grated manhole covers, replacing the rubber gasket, watertight manhole covers for the underdrain and gravity discharge systems and did not provide a basis for the determination that this change would not result in a more than a minimal increase in the likelihood of occurrence of a malfunction of a system structure or component important to safety. The licensee entered this issue into the CAP as CR 201611864 and performed a prompt operability determination to show that the underdrain and gravity drain systems remained functional while the engineering change package was developed to support the change and bring the underdrain and gravity discharge systems into compliance with the design basis. The performance deficiency was determined to be more than minor in accordance with Inspection Manual Chapter (IMC) 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, dated September 7, 2012, because it was associated with the Mitigating Systems cornerstone attribute of equipment performance and adversely affected the cornerstone attribute of protection against external factors and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Per IMC 0609, Attachment 4, Initial Characterization of Findings, and Appendix A, The Significance Determination Process for Findings at Power, the finding was screened against the Mitigating Systems Screening Questions and determined to be of very low safety significance (Green) because the finding did not cause the underdrain and gravity discharge systems to become inoperable or non-functional. Traditional enforcement applied to this finding because it involved a violation that impacted the regulatory process. The inspectors determined it to be of Severity Level IV because it resulted in a condition evaluated by the SDP as having very low safety significance (Enforcement Policy example 6.1.d.2). The inspectors determined that the finding had a cross-cutting aspect in the area of human performance, procedure adherence, in that individuals did not follow processes, procedures, and work instructions. Specifically, a design engineer authorized the permanent modification to be made without the required 50.59 evaluation being completed [H.8]. |
| Site: | Perry  |
|---|---|
| Report | IR 05000440/2016004 Section 1R18 |
| Date counted | Dec 31, 2016 (2016Q4) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.18 |
| Inspectors (proximate) | A Dahbur G Hansen J Cameron J Nance J Robbins M Bielby M Doyle M Jones M Marshfield N Feliz-Adorno R Baker R Ng S Bell T Briley V Petrella |
| Violation of: | 10 CFR 50.59 |
| CCA | H.8, Procedure Adherence |
| INPO aspect | WP.4 |
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Finding - Perry - IR 05000440/2016004 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Perry) @ 2016Q4
Self-Identified List (Perry)
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