05000255/FIN-2018001-02
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Finding | |
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| Title | Licensee Implementation of Enforcement Guidance Memorandum 15002, Enforcement Discretion for Tornado-Generated Missile Protection Noncompliance |
| Description | On June 10, 2015, the NRC issued Regulatory Issue Summary (RIS) 201506, Tornado Missile Protection (ML15020A419), focusing on the requirements regarding tornado-generated missile protection and required compliance with the facility-specific licensing basis. The RIS also provided examples of noncompliances that had been identified through different mechanisms and referenced Enforcement Guidance Memorandum (EGM) 15002, Enforcement Discretion For Tornado Generated Missile Protection Non-Compliance, which was also issued on June 10, 2015 (ML15111A269) and revised on February 7, 2017 (ML16355A286). The EGM applies specifically to a structure, system, or component (SSC) that is determined to be inoperable for tornado-generated missile protection. The EGM stated that a bounding risk analysis performed for this issue concluded that tornado missile scenarios do not represent an immediate safety concern because their risk is within the LIC504, Integrated Risk-Informed Decision-Making Process for Emergent Issues, risk acceptance guidelines. In the case of Palisades, the EGM provided for enforcement discretion of up to 3 years from the original date of issuance of the EGM. On December 7, 2017, and as supplemented on January 18, 2018, Palisades submitted a request to the NRC to extend the enforcement discretion from June 10, 2018 to June 10, 2020 (ML17341A415 and ML18018A328, respectively). By letter dated February 16, 2018, the NRC granted the request to extend enforcement discretion until June 10, 2020 (ML18046A675). The EGM permitted NRC staff to exercise this enforcement discretion only when a licensee implements, prior to the expiration of the time mandated by the LCO, initial compensatory measures that provide additional protection such that the likelihood of tornado missile effects were lessened. In addition, licensees were expected to follow these initial compensatory measures with more comprehensive compensatory measures within about 60 days of issue discovery. In accordance with the EGM, the comprehensive compensatory measures are toremain in place until permanent repairs are completed, or until the NRC dispositions the non-compliance in accordance with a method acceptable to the NRC such that discretion is no longer needed. Palisades was licensed prior to issuance of Appendix A to 10 CFR Part 50, General Design Criteria for Nuclear Power Plants (GDC). Specifically, GDC 2, Design Bases for Protection Against Natural Phenomena, and GDC 4, Environmental and Dynamic Effects Design Basis, discuss how SSCs important to safety shall be designed to protect against natural phenomena, such as tornadoes and shall be adequately protected against the dynamic effects of tornadoes, including protection against missiles. Palisades site-specific licensing bases compliance with GDC 2 and GDC 4 are described in the Updated Final Safety Analysis Report (UFSAR) Sections 5.1.2.2 and 5.1.2.4. Palisades protection of SSCs against tornado-generated missiles is also discussed in UFSAR Section 5.5, Missile Protection. On January 31, 2018, the licensee initiated condition report (CR) CRPLP201800556, which identified a nonconforming condition in the Palisades licensing basis. Specifically, the surge line from the component cooling water (CCW) surge tank to the CCW suction line was identified to be potentially vulnerable to a tornado missile through a doorway. The licensee previously identified a CCW system-related vulnerability on March 29, 2017. The March 29, 2017 CCW vulnerability and five additional vulnerabilities of other SSCs, which all received enforcement discretion, are documented in NRC Inspection Report 05000255/2017002 (ML17220A349). The licensee assessed this new vulnerability and concluded that previously established compensatory measures for the CCW system were adequate and no additional comprehensive compensatory actions were required. Therefore, the licensee declared the SSC operable, but nonconforming because no additional compensatory measures designed to reduce the likelihood of tornado-generated missile effects were required and the previously implemented compensatory measures were still in place. Corrective Action: The licensee documented the condition of the SSC in the CAP and documented the SSC as operable but nonconforming.Corrective Action Reference: CRPLP201800556 Enforcement: Violation: Enforcement discretion was applied to the required shutdown actions of the following Technical Specification (TS) Limiting Conditions for Operation (LCOs): TS 3.0.3, General Shutdown LCO (cascading or by reference from other LCOs); andTS 3.7.7, Component Cooling Water (CCW) System.Severity/Significance: The subject of this enforcement discretion associated with tornado missile protection deficiencies was determined to be less than red (i.e., high safety significance) based on a generic and bounding risk evaluation performed by the NRC in support of the resolution of tornado-generated missile non-compliances. The bounding risk evaluation is discussed in EGM 15002, Revision 1, Enforcement Discretion for Tornado-Generated Missile Protection Non-Compliance (ML16355A286).
11 Basis for Discretion:The NRC exercised enforcement discretion in accordance with Section 2.3.9 of the Enforcement Policy and EGM 15002 because the licensee initiated initial compensatory measures that provided additional protection such that the likelihood of tornado missile effects were lessened. The licensee implemented more comprehensive compensatory actions to resolve the nonconforming conditions within the required 60 days. These comprehensive measures were to remain in place until permanent repairs were completed, which for Palisades were required to be completed by June 10, 2020, or until the NRC dispositioned the non-compliance in accordance with a method acceptable to the NRC such that discretion was no longer needed.The disposition of this enforcement discretion closes LER 05000255/201700101, Inadequate Protection from Tornado Missiles Identified Due to Nonconforming Design Conditions. |
| Site: | Palisades  |
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| Report | IR 05000255/2018001 Section 1R15 |
| Date counted | Mar 31, 2018 (2018Q1) |
| Type: | Violation: Severity level Enforcement Discretion |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.15 |
| Inspectors (proximate) | A Nguyen J Boettcher R Baker B Bartlett E Fernandez V Myers J Neurauter J Park D Sargis J Seymour E Duncan |
| Violation of: | Technical Specification |
| INPO aspect | |
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Finding - Palisades - IR 05000255/2018001 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Palisades) @ 2018Q1
Self-Identified List (Palisades)
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