05000456/FIN-2015002-01
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Finding | |
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Title | Failure to Update the Final Safety Analysis Report-Thimble Tube Inspection Program |
Description | The inspectors identified a Severity Level IV NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50.71(e), Periodic Update of the Updated Final Safety Analysis Report (UFSAR), and an associated Green finding for the licensees failure to update the UFSAR with a description of the Thimble Tube Inspection Program to reflect information submitted to the NRC in response to NRC Bulletin 88-09. Specifically, the licensee did not update Section 5.2.4, Inservice Inspection and Testing of Reactor Coolant Pressure Boundary, of the UFSAR to include the Incore Thimble Tube Inspection Program, which provided the basis for leakage integrity for this portion of the reactor coolant pressure boundary. The licensee entered this issue into their Corrective Action Program (CAP) and identified a recommended action to incorporate the Incore Thimble Tube Inspection Program into the UFSAR. The performance deficiency 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, if left uncorrected, the performance deficiency would have the potential to lead to a more significant safety concern. Specifically, the failure to update the UFSAR with the Thimble Tube Inspection Program could result in reductions or elimination of the program without seeking prior NRC approval and insufficient thimble tube inspections could also result in the failure to detect thimble tube wear prior to an un-isolable leak in the reactor coolant pressure boundary. Additionally, the failure to update the UFSAR was more than minor because it was associated with the Initiating Events Cornerstone attribute of Equipment Performance and adversely affected the Cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions. The finding screened as having very low safety significance (Green), because the licensees failure to update the UFSAR with a description of the Thimble Tube Inspection Program had not resulted in degradation of a thimble tube such that the reactor coolant system leak rate for a small break loss of coolant accident was exceeded and did not affect systems used to mitigate a loss of coolant accident. Therefore, the inspectors answered No to Questions A.1 and A.2, of Exhibit 1, Initiating Events Screening Questions, identified in Appendix A of IMC 0609 and the finding screened as having very low safety significance. Violations of 10 CFR 50.71(e) are dispositioned using the traditional enforcement process, because they are considered to be violations that potentially impede or impact the regulatory process. In accordance with Sections 6.1.c.7 and 6.1.d.3 of the NRC Enforcement Policy, this violation was categorized as Severity Level IV because the licensees failure to update the UFSAR as required by 10 CFR 50.71(e) had not yet resulted in an unacceptable change to the facility (e.g. thimble tube structural integrity was maintained) or procedures and the associated finding was of very low risk significance. The finding was the result of an error made in excess of 10 years ago, and thus was not indicative of current licensee performance. Therefore, no cross-cutting aspect was identified. |
Site: | Braidwood |
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Report | IR 05000456/2015002 Section 1R08 |
Date counted | Jun 30, 2015 (2015Q2) |
Type: | NCV: Green |
cornerstone | Initiating Events |
Identified by: | NRC identified |
Inspection Procedure: | IP 71111.08 |
Inspectors (proximate) | B Metrow D Betancourt E Duncan J Benjamin J Mancuso M Holmberg N Mcmurray T Go |
Violation of: | 10 CFR 50.71(e) 10 CFR 50.71 |
INPO aspect | |
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Finding - Braidwood - IR 05000456/2015002 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Braidwood) @ 2015Q2
Self-Identified List (Braidwood)
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