05000528/FIN-2007012-18
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Finding | |
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| Title | Failure to Periodically Update the Updated Final Safety Analysis Report |
| Description | The team identified a Severity Level IV NCV of 10 CFR 50.71(e) for the failure of the licensee to periodically update the UFSAR with all changes made in the facility or procedures. While conducting a review of the Unit 2 liquid radiological waste system, the team found that the system was not being operated in accordance with the description provided in the UFSAR. Specifically, evaporator concentrate was being pumped to one of the high total dissolved solids (TDS) holdup tanks rather than the concentrate monitor tanks as specified in Section 11.2.2 of the UFSAR. The licensee stated that the Unit 2 concentrate monitor system had been out of service since 2002. The teams review of corrective action documents related to the system determined that the concentrate monitor tanks were not being used because of equipment/maintenance issues with the concentrate monitor system. The UFSAR stated in Section 11.2.2.4.1.2, that flow from the high TDS holdup tank can be terminated or diverted to an alternate path by operator action based on evaporator or holdup pump malfunction, high-pressure drop across the adsorption bed or ion exchangers, an exhausted resin bed, or when the radiological waste section leader determines it is necessary. The UFSAR did not specify the alternate flow path nor the allowed duration. The team concluded that operating outside of the UFSAR design basis for approximately 5 years was not the intent of UFSAR Section 11.2.2.4.1.2. Analysis: The team determined that the failure to update the UFSAR to reflect changes made to the facility was a performance deficiency. This issue was subject to traditional enforcement because it had the potential for impacting the NRCs ability to perform its regulatory function. The finding is characterized as a Severity Level IV violation because the erroneous information in the UFSAR was not used to make an unacceptable change to the facility or procedures. The cause of this finding had a crosscutting aspect associated with resources of the human performance area in that the licensee failed to ensure that personnel and equipment were available and adequate to maintain radiological safety by minimization of long-standing equipment issues (H.2.(a)). Enforcement: 10 CFR 50.71(e) requires that the licensee periodically update the USFAR with all changes made in the facility or procedures. Contrary to the above, in 2002 the licensee made a change to the facility and procedures as described in the UFSAR and failed to update the UFSAR. Specifically, the licensee began operating the Unit 2 liquid radiological waste system in a manner different than that specified by UFSAR when they commenced pumping evaporator concentrate to the high TDS holdup tanks rather than the concentrate monitor tanks as specified in UFSAR Section 11.2.2. The failure to update the UFSAR was characterized as a Severity Level IV violation. The finding was of very low safety significance because the change in operation of the total dissolved solids holdup tanks did not result in an increase in the likelihood of a release of radioactive material. This issue was entered in the licensees CAP as PVAR 3075089. This violation was treated as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy: NCV 05000529/2007012-18, Failure to Periodically Update the Updated Final Safety Analysis Report |
| Site: | Palo Verde  |
|---|---|
| Report | IR 05000528/2007012 Section 4OA4 |
| Date counted | Dec 31, 2007 (2007Q4) |
| Type: | TEV: Severity level IV |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 95003 |
| Inspectors (proximate) | G Werner H Gepford J Drake M Schneider M Wilk P Elkmann R Kahler R Smith S Gillum T Pruett |
| CCA | H.6, Design Margins |
| INPO aspect | WP.2 |
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Finding - Palo Verde - IR 05000528/2007012 | |||||||||||||||||||
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Finding List (Palo Verde) @ 2007Q4
Self-Identified List (Palo Verde)
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