05000266/FIN-2018002-02
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Finding | |
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| 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 noncompliance 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 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 Point Beach, the EGM provided for enforcement discretion of up to three years from the original date of issuance of the EGM. The EGM allowed 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 provided 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 approximately 60 days of issue discovery. The comprehensive measures should remain 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. Table 1.31 of the Point Beach Final Safety Analysis Report (FSAR) states, in part, that SSCs, which are essential to the prevention and mitigation of nuclear accidents, shall be designed, fabricated, and erected to withstand the forces that might reasonably be imposed by the occurrence of an extraordinary natural phenomenon, such as a tornado. On March 1, 2018, the licensee initiated AR 02252240, identifying a nonconforming condition of Table 1.31. Specifically, on both units 1 and 2, the steam supply lines and exhaust stacks for the turbine-driven auxiliary feedwater pumps, the main steam isolation valves, the atmospheric steam dumps, the main steam safety valves, and the vents for T175B bulk fuel oil storage tank were not adequately protected from tornado-generated missiles. The licensee declared the affected SSCs inoperable and promptly implemented compensatory measures designed to reduce the likelihood of tornado-generated missile effects. The condition was reported to the NRC as Event Notice 53239 as an unanalyzed condition and potential loss of safety function. Enforcement discretion was previously authorized and documented in Inspection Report 05000266/2018001 (ADAMS Accession Number ML18128A229). Corrective Actions: The licensee documented the inoperability of the SSCs and the affected TS LCO conditions in the CAP and in the control room operating log. The shift manager notified the NRC resident inspector of implementation of EGM 15002, and documented the implementation of the compensatory measures to establish the SSCs operable but nonconforming prior to expiration of the LCO required action. The licensees immediate compensatory measures included: review and revision of procedures for a tornado watch and a tornado warning to provide additional instructions for operators preparing for tornados and/or high winds, and a potential loss of SSCs vulnerable to the tornado missiles; confirmation of readiness of equipment and procedures dedicated to the Diverse and Flexible Coping Strategy (FLEX); verification that training was up to date for individuals responsible for implementing preparation and response procedures; and establishment of a heightened station awareness and preparedness relative to identified tornado missile vulnerabilities. The licensees longer term compensatory measure was to modify AOP13C, Severe Weather Conditions procedure, to include actions for removing potential airborne hazards and damage assessments for systems with a vulnerability to damage from tornado missiles. Corrective Action Reference: AR 2252240 Enforcement: Violation: The enforcement discretion was applied to the required shutdown actions of the following TS LCOs for both units: TS 3.0.3, General Shutdown LCO (cascading or by reference from other LCOs); TS 3.7.1, Main Steam Safety Valves (MSSVs); TS 3.7.2, Main Steam Isolation Valves (MSIVs) and Non-Return Check Valves; TS 3.7.4, Atmospheric Dump Valve (ADV) Flowpaths; TS 3.7.5, Auxiliary Feedwater (AFW); TS 3.8.1; AC Sources Operating; and TS 3.8.3, Diesel Fuel Oil and Starting Air. 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 Enforcement Guidance Memorandum 15002, Revision 1, Enforcement Discretion for Tornado-Generated Missile Protection Non-Compliance, and can be found in ADAMS Accession Number ML16355A286. 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 measures to address the nonconforming conditions within the required 60 days. These comprehensive actions are to remain in place until permanent repairs are completed, which, for Point Beach, were required to be completed by June 10, 2018, or until the NRC dispositioned the non-compliance in accordance with a method acceptable to the NRC, such that discretion was no longer needed.On April 26, 2018, the licensee submitted a request to extend the enforcement discretion in letter titled Request to Extend Enforcement Discretion Provided in Enforcement Guidance Memorandum 15002 for Tornado-Generated Missile Protection Non-conformances Identified in Response to Regulatory Issues Summary 201506, Tornado Missile Protection. On May 21, 2018, the NRC approved this request and extended the enforcement discretion until June 10, 2020. The disposition of this enforcement discretion closes LER 201800100. |
| Site: | Point Beach  |
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| Report | IR 05000266/2018002 Section 1R15 |
| Date counted | Jun 30, 2018 (2018Q2) |
| Type: | Violation: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.15 |
| Inspectors (proximate) | T Hartman K Barclay C Hunt S Bell J Cameron |
| Violation of: | Technical Specification |
| INPO aspect | |
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Finding - Point Beach - IR 05000266/2018002 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Point Beach) @ 2018Q2
Self-Identified List (Point Beach)
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