05000461/FIN-2010003-02
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Finding | |
|---|---|
| Title | Failure to Perform an Adequate 10 CFR 50.59 Evaluation for CPS Procedure 3711.01 |
| Description | The inspectors identified a finding of very low safety significance with an associated NCV of 10 CFR 50.59, Changes, Tests and Experiments. The licensee failed to perform an adequate 10 CFR 50.59 evaluation and obtain a license amendment prior to implementing CPS 3711.01, CPS [Clinton Power Station] Operations with the Potential to Drain the Reactor Vessel [OPDRV], Revision 0 on January 11, 2010. The procedure established a definition of an OPDRV for use in determining the applicability of several TS requirements while in Modes 4 and 5. The licensee failed to recognize that implementing this new procedure, in effect, constituted a change to the TS incorporated into its licensing basis, which would, therefore, require a license amendment pursuant to 10 CFR 50.59(c)(1)(i) and 10 CFR 50.90. No immediate corrective actions were taken to address this finding; however, the licensee entered this issue into its corrective action program for evaluation. The finding was of more than minor significance because there was a reasonable likelihood that the change requiring a 10 CFR 50.59 evaluation would require NRC review and approval prior to implementation. Because this issue affected the 3 Enclosure NRC\'s ability to perform its regulatory function, the inspectors evaluated it using the traditional enforcement process and assessed the significance of the underlying issue using the SDP. Based on the results of a modified Phase 2 SDP evaluation, this finding was determined to be of very low safety significance. Consistent with the guidance in Supplement I, Paragraph D.5, of the NRC Enforcement Policy, the violation associated with this finding was determined to be a Severity Level IV Violation. The inspectors concluded that this finding affected the cross-cutting area of human performance. Specifically, the licensee did not use conservative decision making to demonstrate that the proposed action did not require prior NRC approval. The inspectors noted that the licensee was aware of potential concerns regarding the new procedure prior to completing the initial 10 CFR 50.59 evaluation and again prior to revising the evaluation in response to concerns raised by the inspectors; however, the incorrect conclusion was reached in both revisions of the evaluation that the new procedure was not a change to the TS and that a license amendment was not necessary. (IMC 0310 H.1(b)) |
| Site: | Clinton  |
|---|---|
| Report | IR 05000461/2010003 Section 1R13 |
| Date counted | Jun 30, 2010 (2010Q2) |
| Type: | TEV: Severity level IV |
| cornerstone | Barrier Integrity |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.13 |
| Inspectors (proximate) | B Kemker D Lords D Melendez Colon E Coffman J Cassidy M Mitchell M Ring R Russell S Mischke |
| CCA | H.14, Conservative Bias |
| INPO aspect | DM.2 |
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Finding - Clinton - IR 05000461/2010003 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Clinton) @ 2010Q2
Self-Identified List (Clinton)
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