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05000261/FIN-2017001-0231 March 2017 23:59:59RobinsonNRC identifiedFailure to Submit Complete and Accurate Information for a Requested License AmendmentSeverity Level IV. An NRC -identified severity level IV (SL IV) NCV of 10 CFR 50.9(a), Completeness and Accuracy of Information, was identified for the licensees failure to provide complete and accurate information in a license amendment request (LAR), dated November 19, 2015, requesting extension of the containment leak rate test frequencies required by various containment technical specifications (TS s). In this LAR, the licensee incorrectly stated that they had revised their ASME BPVC, Section XI, Subsection IWE program to include visual examinations of the test connections in the leak -chase channel penetration pressurization system ( PPS) , when in fact, the program had not been revised and the examinations had not been performed . This information was material to the NRC because it was used, in part, as the basis for the approval and issuance of License Amendment 247, dated October 11, 2016, extending the TS containment leak rate test frequencies. The licensees corrective actions included conducting the visual examinations of the test connections in the leak -chase channel PPS during the ongoing refueling outage in March 2017 and initiating actions to add the visual examination requirements to their Subsection IWE program. This issue was entered into the licensees CAP as NCR 02110516. The failure to provide complete and accurate information in accordance with 10 CFR 50.9(a) for the LAR associated with License Amendment 247 is a violation of NRC requirements . This violation was screened against the ROP guidance in IMC 0612, Appendix B, Issue Screening, and no associated ROP finding was identified. The inspectors evaluated this issue using the Traditional Enforcement process because it had the potential to impact the NRCs ability to perform its regulatory function. Specifically, the violation impacted the regulatory process, in that the inaccurate information was material to the NRCs review and acceptance of licensee actions to address the industry -wide operating experience discussed in NRC IN 2014- 07. Based on licensee inaccurate information that they had addressed IN 2014 -07 by revising their containment ISI program to perform visual inspections of accessible tubing in the containment leak -chase channel PPS system, the NRC staff concluded that the licensee was properly implementing the ASME BPVC, Section XI, Subsection IWE program. In accordance with the guidance in Sections 2.2 and 6.9 of the NRC Enforcement Policy, the inspectors determined this is an SL IV violation, because had the information been complete and accurate at the time provided, it likely would have resulted in the need for further clarification of the licensees actions to address NRC IN 2014- 07 , but would not have caused the NRC to change its decision to issue the license amendment or resulted in substantial further inquiry . Also, on March 23, 2017, the licensee completed the visual examinations of the subject tubing in the leak -chase channel system and did not identify any significant degradation. In accordance with IMC 0612, Appendix B, traditional enforcement issues are not assigned a cross -cutting aspect.
05000261/FIN-2015404-0130 September 2015 23:59:59RobinsonNRC identifiedSecurity
05000261/FIN-2015002-0130 June 2015 23:59:59RobinsonNRC identifiedFailure to Timely Report Required Information as Required by 10 CFR 50.73An NRC-identified Severity Level IV NCV of 10 CFR 50.73, Licensee Event Report System, was identified for the licensees failure to submit a licensee event report (LER) within 60 days after discovery of a condition which was prohibited by the plants Technical Specifications (TS). The issue was entered into the licensees CAP as condition report (CR) 743653. The licensee submitted the LER to restore compliance. The licensees failure perform an adequate reportability evaluation and subsequently submit an LER within 60 days after discovery of a condition which was prohibited by the plant TSs as required by 10 CFR 50.73 was a performance deficiency. This performance deficiency was assessed using traditional enforcement because it had the potential for impacting the NRCs ability to perform its regulatory function. The inspectors determined the significance of this violation was a Severity Level IV NCV using Section 6.9.d.9 of the NRCs Enforcement Policy. Cross cutting aspects are not assigned to traditional enforcement violations.
05000261/FIN-2015001-0131 March 2015 23:59:59RobinsonNRC identifiedInadequate 10 CFR 50.59 Evaluation Results in RPI System InoperabilityThe inspectors identified a severity level IV (SLIV) non-cited violation (NCV) of 10 CFR 50.59, Changes, Tests, and Experiments, for the licensees failure to obtain a license amendment prior to implementing a change to licensee procedure OST-20, Shiftly Surveillances. Specifically, a note was added to procedure OST-20 to allow the use of the Emergency Response Facility Information System (ERFIS) as an acceptable alternate method to determine Analog Rod Positon Indication (ARPI) System operability if the position indicators were not indicating properly. This change resulted in an associated Green NCV of Technical Specification (TS) 3.1.7, Rod Position Indication, for failing to shut down the reactor or follow remedial actions permitted by a TS action requirement when a Limiting Condition for Operation (LCO) was not met. Upon determination that the practice of crediting ERFIS for rod position indication (RPI) operability was not allowed by the current licensing basis (CLB), Standing Instruction 14-023 was issued to suspend the practice and condition report (CR) 720726 was written to document the issue. The licensees failure to obtain a license amendment for a change that resulted in a change to technical specifications incorporated in the license was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the mitigating systems cornerstone attribute of procedure quality and adversely affected the objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the procedure change adversely impacted the availability and capability of systems to respond to a design basis event because it allowed the use of a non CLB method for determining rod position after failure of the ARPI system. Rod position indication is required to determine maximum rod misalignment which is an initial assumption in the safety analysis that directly affects core power distributions and assumptions of available shutdown margin. The finding was screened using IMC 0609 Appendix A Exhibit 2.C, Reactivity Control Systems, dated June 19, 2012, and was determined to be of very low safety significance (Green) because the finding did not result in a mismanagement of reactivity by operators. The violation was determined to be a SLIV violation using the Enforcement Policy example 6.1.d.2, because it resulted in a condition having very low safety significance. No cross-cutting aspect was assigned in association with the ROP finding because the change to the procedure was performed greater than three years ago and did not reflect current licensee performance.
05000261/FIN-2007501-0130 June 2007 23:59:59RobinsonNRC identifiedImplementation of a Change in Rev. 8 of the EAL-1 Flow Chart which Decreased the Effectiveness of the Emergency PlanA non-cited violation (NCV) was identified for implementing a change which decreased the effectiveness of the Emergency Plan without prior NRC approval, contrary to the requirements of 10 CFR 50.54(q). The change concerned an emergency action level applicable to the inability to monitor a significant transient in progress. The licensee entered this issue into its corrective action program for resolution. The finding was evaluated under the NRCs Enforcement Policy using the traditional enforcement process because licensee reductions in the effectiveness of its emergency plan impact the regulatory process. This finding is more than minor because it could have resulted in failure to accurately declare a Site Area Emergency under certain conditions. The finding was determined to be a Severity Level IV NCV because it involved licensee failure to meet an emergency planning requirement (i.e., 10 CFR 50.54(q)) not directly related to assessment or notification (Section 1EP4)
05000261/FIN-2006005-0231 December 2006 23:59:59RobinsonNRC identifiedInadequate 10 CFR 50.54(Q) Evaluation for Emergency Plan Rev. 33No Color. A Severity Level IV non-cited violation was identified for implementing a change to the emergency plan without appropriate justification, contrary to the requirements of 10 CFR 50.54(q). The finding was evaluated under the NRCs Enforcement Policy using the traditional enforcement process because licensee reductions in the effectiveness of its emergency plan impact the regulatory process. The finding was determined to be a noncited Severity Level IV violation because it involved licensee failure to meet an emergency planning requirement not directly related to assessment or notification
05000261/FIN-2005006-0131 March 2005 23:59:59RobinsonNRC identifiedFailure to Fully Evaluate a Change to the Discharge Path of Relief Valve SI-857A Which Potentially Involves an Unreviewed Safety QuestionThe inspectors identified a Severity Level IV (SL IV) non-cited violation (NCV) of 10 CFR 50.59 requirements for the licensee's failure to fully evaluate a change to the plant which potentially involved an unreviewed safety question (USQ). Specifically, the licensee implemented a plant change in 1992 which directed the discharge of safety injection system (SIS) relief valve SI-857A to an open floor drain in the auxiliary building (contrary to the Updated Final Safety Analysis Report), without evaluating the effects on dose consequences. The potential USQ was related to an increase in the dose consequences, if valve SI-857A, which is located outside containment, were to lift (and potentially fail to reseat) during post-LOCA recirculation conditions. This finding was evaluated using traditional enforcement and is more than minor because it was a change to the facility which would require NRC review and approval prior to implementation. This finding affected the mitigating systems cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to preclude undesirable consequences. However, the technical issue was determined to be of very low safety significance, given the low likelihood of a scenario involving a loss of coolant accident and actuation of SI-857A. The licensee entered this issue into the corrective action program as Action Request 151238.
05000261/FIN-2004005-0131 December 2004 23:59:59RobinsonNRC identifiedImplementation of a Change to EAL-2 Which Decreased the Effectiveness of the Emergency Plan, Rev. 54No Color. A severity level IV non-cited violation was identified for failure to meet the Emergency Plan change requirements of 10 CFR 50.54 (q). A change involving emergency classification of a seismic event, which decreased the effectiveness of the Emergency Plan, Revision 54, was implemented without prior NRC approval. The finding was evaluated using the NRC's Enforcement Policy because licensee reductions in the effectiveness of its emergency plan impact the regulatory process. This finding is more than minor because extending the time period required for appropriate emergency classification of a seismic event could adversely affect the performance of both onsite and offsite emergency actions. The finding was determined to be a severity level IV violation because it involved licensee failure to meet an emergency planning requirement not directly related to assessment and notification.