05000336/FIN-2015201-02
From kanterella
Jump to navigation
Jump to search
Finding | |
|---|---|
| Title | Failure to Provide Complete and Accurate Information in Charging Pump License Amendment Requests |
| Description | 10 CFR 50.9(a), Completeness and Accuracy of Information, states, in part, that information provided to the Commission by a licensee or information required by statute or by the Commission's regulations to be maintained by the licensee shall be complete and accurate in all material respects. 10 CFR 50.9(b) states, in part, that a licensee shall notify the Commission of information identified by a licensee as having a significant implication for public health and safety and that a licensee is only in violation of this if the licensee fails to notify the Commission of this information, via the Administrator of the appropriate Regional Office, within two working days of identification. Contrary to the above, on multiple occasions DNC provided information to the Commission that was not complete and accurate in all material respects, as illustrated in the examples (a) and (b) below, and failed to notify the Commission of information having a significant implication for public health and safety, as illustrated by example (c) below: a. On June 30, 2010, DNC provided its biennial 10 CFR 50.59 change report for 2008 and 2009, as required by 10 CFR 50.59(d)(2), to the NRC. This report contained a summary of the 10 CFR 50.59 evaluation for the removal of charging pumps from the analysis of inadvertent opening of the PORVs in Chapter 14 of the Millstone, Unit 2 UFSAR that was not complete and accurate. Specifically, DNC described the change as being more conservative (i.e., less inventory is available to mitigate the consequences of the inadvertent opening of the PORVs), when in fact the revised analysis appears to be less conservative (more inventory is available to mitigate the consequences of the inadvertent opening of the PORVs).1 DNC's summary of this 10 CFR 50.59 evaluation was also incomplete because it failed to state that the revised analysis did not apply the single failure assumption stated in the UFSAR. This prevented the NRC from fully understanding the nature of the change in the analysis of the PORV event. b. On two occasions, DNC provided NRC with information associated with license amendment requests that was not accurate. On July 19, 2004, the licensee submitted responses to requests for additional information associated with a 2002 license amendment request which stated that flow from the charging pumps was no longer required for design basis accident mitigation, and, therefore, the charging pumps were no longer required to be controlled by technical specifications. On February 20, 2007, the licensee submitted a different license amendment request which stated that charging pump flow is no longer credited in any design basis accident analysis described in Chapter 14 of the Millstone, Unit 2 UFSAR. At the time of each of these submittals, UFSAR Section 14.6.1 and Table 14.0.9-1 described the charging pumps as mitigating equipment for a design basis accident (i.e., inadvertent opening of the PORVs). c. On September 25, 2007, DNC staff identified information having significant implication for public health and safety and did not notify the Commission of this information. Specifically, in the investigation of Condition Report CR-07 -08295, dated August 7, 2007, DNC staff identified that the charging pumps were credited for mitigating a design basis accident (i.e., the inadvertent opening of the PORVs) in Chapter 14 of the Millstone, Unit 2 UFSAR, contrary to the information submitted to the NRC in license amendment requests (LARs) on May 7, 2002, and February 20, 2007. On September 9, 2004, the NRC approved the removal of the automatic safety function for the charging pumps, based, in part, on DNC's submittal of inaccurate information in the May 2002 LAR stating that flow from the charging pumps was no longer required for design basis accident mitigation. The information documented in CR-07 -08295 invalidated the basis for the previously approved amendment. Additionally, because the NRC was in the process of reviewing DNC's February 20, 2007, LAR to eliminate the TS surveillance requirement for the charging pumps, DNC's failure to notify the NRC of this information could have resulted in the NRC staff approving removal of the charging pumps from the Millstone, Unit 2 TS, which were credited for design basis accident mitigation during inadvertent opening of the PORVs, had the NRC not become aware of this information on its own. |
| Site: | Millstone  |
|---|---|
| Report | IR 05000336/2015201 Section 1R17 |
| Date counted | Jun 30, 2013 (2013Q2) |
| Type: | Violation: Severity level Enforcement Discretion |
| cornerstone | No Cornerstone |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.17 |
| Inspectors (proximate) | B Bickett D Willis G Carpenter L Casey M Parker R Morris |
| Violation of: | 10 CFR 50.59 10 CFR 50.9 Technical Specification |
| INPO aspect | |
| ' | |
Finding - Millstone - IR 05000336/2015201 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
Finding List (Millstone) @ 2013Q2
Self-Identified List (Millstone)
| ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||