05000528/FIN-2005002-06
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Finding | |
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| Title | Failure to Obtain Prior NRC Approval for a Design Change to the Facility |
| Description | A Severity Level IV non-cited violation of 10 CFR 50.59 requirements was identified for the failure to obtain a license amendment for a permanent modification to all six station emergency diesel generators. The inspectors determined that there were two modifications performed on the jacket water system of each emergency diesel generator. Condition Report/Disposition Request (CRDR) 130208, in 1993, directed the abandonment of the jacket water surge tank makeup valves on both emergency diesel generators of all three units. A recent modification, Design Modification Work Order 220055 in 2003, removed the surge tank low level alarm on both emergency diesel generators of all three units. The licensee replaced these two automatic actions (automatic makeup and low level alarm) with a manual operator action to fill, as necessary, every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during rounds. The inspectors reviewed the updated final safety analysis report (UFSAR) and design basis documents, and found that the automatic jacket water surge tank makeup, and the low level alarm, were both shown in UFSAR descriptions, drawings, and design value tables.
The issue was determined to be more than minor, through Inspection Manual Chapter 0612, Appendix B, in that it affected the mitigating systems cornerstone attribute of equipment performance, and was repeated for all of the station emergency diesel generators. The issue was determined to result in more than a minimal increase in the consequences of a malfunction of an structure, system, or component important to safety evaluated in the UFSAR, since jacket water leakage could go undetected for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and affect diesel operability. Thus, a license amendment was required. In accordance with the NRC Enforcement Manual, violations of 10 CFR 50.59 are not processed through the significance determination process. Therefore, this issue was considered applicable to traditional enforcement. Although the significance determination process is not designed to assess significance of violations that potentially impact or impede the regulatory process, the result of a 10 CFR 50.59 violation can be assessed significance through the significance determination process. The lead inspector and the Region IV senior reactor analyst discussed the significance of this finding. An SDP Phase 1 screening was performed and the finding was determined to have very low safety significance because there was no actual loss of the mitigating system safety function. The licensee entered this issue into its corrective action program as CRDR 2711244. |
| Site: | Palo Verde  |
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| Report | IR 05000528/2005002 Section 4OA5 |
| Date counted | Mar 31, 2005 (2005Q1) |
| Type: | TEV: Severity level IV |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | |
| Inspectors (proximate) | R Lantz T Stetka B Tharakan G George J Melfi T Mcconnell W Sifre C Paulk G Warnick T Pruett J Kramer P Denvenuto |
| INPO aspect | |
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Finding - Palo Verde - IR 05000528/2005002 | |||||||||||||||||||||
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Finding List (Palo Verde) @ 2005Q1
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