05000440/FIN-2016007-01
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Finding | |
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| Title | Failure to Document 50.59 Evaluation for Replacement of a Manual Action with an Automatic Action |
| Description | The inspectors identified a Severity Level IV, NCV of Title 10 of the Code of Federal Regulations (CFR), Part 50.59, Changes, Tests, and Experiments, having very-low safety significance (Green) for failure to document the basis for performing a plant modification where a manual operator action was replaced with an automatic action. Specifically, the licensee did not evaluate whether adding a safety-related function to a nonsafety-related component was within the licensing basis of the facility. The inspectors determined that the failure to perform a 10 CFR 50.59 evaluation for Plant Modification 11-0794 was contrary to 10 CFR 50.59(d)(1) and was a performance deficiency. The performance deficiency was determined to be more-than-minor and a finding, because the finding impacted mitigating systems cornerstone attribute of Design Control and adversely affected the Cornerstone Objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, this plan modification added a Safety-Related function to a Nonsafety-Related component and, therefore, impacted the availability, reliability, and capability of the Safety-Related Battery Room ventilation system and the Safety-Related Motor Control Center, Switchgear, and Miscellaneous Electrical Equipment Area ventilation system. 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 Mitigating Systems cornerstone. As a result, the inspectors evaluated the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, for the Mitigating Systems cornerstone. The inspectors answered No to question A.4 in Exhibit 2 Mitigating System Screening Questions. Specifically, the inspectors determined the finding did not represent an actual loss of the Battery Room ventilation system or Motor Control Center, Switchgear, and Miscellaneous Electrical Equipment Area ventilation system because the automatic action had not been implemented at the time of the finding. Therefore, the inspectors determined the significance of this finding to be of very-low safety significance (Green). 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). The inspectors determined the finding was associated with the cross-cutting aspect of Procedure Adherence in the area of Human Performance, because the licensee failed to follow the screening criteria in Attachment 2 of Procedure NOBP-LP-4003A, FENOC 10 CFR 50.59 User Guidelines. |
| Site: | Perry  |
|---|---|
| Report | IR 05000440/2016007 Section 1R17 |
| Date counted | Jun 30, 2016 (2016Q2) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.17 |
| Inspectors (proximate) | A Shaikh J Hafeez M Domke R Daley |
| Violation of: | 10 CFR 50.59 |
| CCA | H.8, Procedure Adherence |
| INPO aspect | WP.4 |
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Finding - Perry - IR 05000440/2016007 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Perry) @ 2016Q2
Self-Identified List (Perry)
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