05000354/FIN-2015003-01
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Finding | |
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| Title | Inaccurate Information Provided to the NRC in License Amendment Request for Service Water Bay Watertight Doors |
| Description | The inspectors identified a severity level IV (SL IV) NCV of Title 10 of the Code of Federal Regulations (10 CFR) 10.50.9(a), Completeness and Accuracy of Information, for PSEGs failure to provide accurate and complete information in a license amendment request regarding technical specification (TS) 3.7.3 Flood Protection. This information was material to NRC because it was used, in part, as the basis for the approval and issuance of a license amendment to remove the Unit 2 service water intake structure (SWIS) watertight doors from TS flood protection requirements. PSEGs corrective actions include reinstatement of the Unit 2 watertight doors in the technical requirements manual (TRM) flood protection requirements. Additionally, since the inaccurate license change request submittal in 1998, PSEG implemented LS-AA-117, Written Communications, which requires that all license amendment requests and documents submitted to the NRC under oath and affirmation shall receive a Technical Verification Team review. The Technical Verification Team review consists of a page-by-page review of the subject document that identifies and validates all statements of fact, assumptions, data inputs and calculations which could alter the conclusions reached in the document. The inspectors evaluated this issue using the traditional enforcement process because the performance deficiency had the potential to impact the NRCs ability to perform its regulatory function. Specifically, this violation impacted the regulatory process in that the inaccurate information was material to the NRCs determination that there was reasonable assurance the proposed removal of the Unit 2 SWIS bay watertight doors from the Hope Creek TSs would not result in plant operations that would endanger the health and safety of the public. The inspectors concluded that had the information been complete and accurate at the time provided, it likely would have resulted in a reconsideration of this regulatory position. The inspectors determined that the performance deficiency identified is a Severity Level IV violation, because: the risk associated with an external flooding event at Hope Creek is very low (less than 10-8 per year), the flood protection TS requirement has been changed to a TRM requirement, and the procedure revision to HC.OP-AB.MISC-0001, Acts of Nature, ensured that all of the SWIS exterior doors would be closed during high river water level conditions. The performance deficiency was screened against the Reactor Oversight Process (ROP) per the guidance of IMC 0612, Appendix B, Issue Screening, and no 4 associated ROP finding was identified. In accordance with IMC 0612, Appendix B, this traditional enforcement issue is not assigned a cross-cutting aspect. |
| Site: | Hope Creek  |
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| Report | IR 05000354/2015003 Section 1R01 |
| Date counted | Sep 30, 2015 (2015Q3) |
| Type: | TEV: Severity level IV |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.01 |
| Inspectors (proximate) | A Turilin J Brand J Hawkins L Dumont R Nimitz S Barr S Haney |
| Violation of: | Technical Specification - Procedures Technical Specification 10 CFR 50.9 |
| INPO aspect | |
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Finding - Hope Creek - IR 05000354/2015003 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Hope Creek) @ 2015Q3
Self-Identified List (Hope Creek)
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