05000454/FIN-2016002-05
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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, 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 which was also issued on June 10, 2015. The EGM provided guidance to allow the NRC staff to exercise enforcement discretion when an operating power plant licensee did not comply with the current licensing basis for tornado-generated missile protection. Specifically, the discretion applied to SSCs declared inoperable resulting in TS LCOs that would require a reactor shutdown or mode change if the licensee could not meet the required actions within the TS completion time. The discretion allowed the licensee to re-establish operability through compensatory measures and established criteria for continued operation of the facility as longer term corrective actions were implemented. The EGM stated that the bounding risk analysis performed for this issue concluded that this issue was of low risk significance and, in Byrons case, provided for enforcement discretion of up to three years from the date of issuance of the EGM. However, the EGM did not provide licensees with enforcement discretion for any related underlying technical violations; and moreover, the EGM specifically requires that any associated underlying technical violation(s) be assessed through the enforcement process. Appendix A to 10 CFR Part 50, General Design Criteria for Nuclear Power Plants (GDC), Criterion 4, Environmental and Dynamic Effects Design Basis, stated in part that SSCs important to safety shall be adequately protected against dynamic effects including missiles. On May 25, 2016, the licensee initiated IR 02673848, identifying a nonconforming condition of Criterion 4. Specifically, multiple locations were identified in the refueling water storage tank (RWST) roof hatches and in the L-line wall above the 451 elevation (separating the turbine building from the Class I auxiliary building) where SSCs were not adequately protected from tornado-generated missiles. The licensee declared multiple SSCs inoperable and promptly implemented compensatory measures designed to reduce the likelihood of tornado-generated missile effects. The inspectors reviewed the licensees compensatory measures that 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 condition was reported to the NRC as Event Notice (EN) 51958 as an unanalyzed condition and potential loss of safety function. 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 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 3.3.7, Control Room Ventilation (VC) Filtration System Actuation Instrumentation; TS 3.5.2, ECCS Operating; TS 3.5.4, Refueling Water Storage Tank (RWST); TS 3.6.6, Containment Spray and Cooling Systems; TS 3.7.9; Ultimate Heat Sink; TS 3.7.10, Control Room Ventilation (VC) Filtration System; TS 3.7.11, Control Room Ventilation (VC) Temperature Control System; TS 3.8.4, DC Sources Operating; TS 3.8.7, Inverters Operating; and TS 3.8.9, Distribution Systems Operating. The inspectors review addressed the material issues in the plant, and whether the measures were implemented in accordance with the guidance documentation for the EGM. The inspectors also evaluated whether the measures as implemented would function as intended and were properly controlled. The licensee implemented actions to track the more comprehensive actions to resolve the nonconforming conditions within the required 60 days. These comprehensive actions were to remain in place until permanent repairs were completed, which for Byron were required to be completed in three years, 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 inspectors did not review the underlying circumstances that resulted in the TS violations. As stated in the EGM guidance, violations of other requirements, including 10 CFR 50 Appendix A, Criterion 4, which may have contributed to the TS violations, would be evaluated independently of the EGM implementation. This operability inspection constituted a partial sample as defined in IP 71111.1505 since all corrective actions to support continued operability and resolution of the nonconforming conditions had not been identified. These actions and any underlying technical violations will be addressed with the completion of this inspection sample and documented in a future NRC Inspection Report. |
| Site: | Byron  |
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| Report | IR 05000454/2016002 Section 1R15 |
| Date counted | Jun 30, 2016 (2016Q2) |
| Type: | Violation: Severity level Enforcement Discretion |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.15 |
| Inspectors (proximate) | C Hunt C Thompson E Duncan G Edwards J Draper J Mcghee L Smith M Holmberg S Bell |
| Violation of: | 10 CFR 50 Appendix A GDC 4 |
| INPO aspect | |
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Finding - Byron - IR 05000454/2016002 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Byron) @ 2016Q2
Self-Identified List (Byron)
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