During a review of the Integrated Safety Analysis for an additive addition step, it was determined that one of the Items Relied on for Safety (
IROFS), as documented in the
ISA Summary was not reliable. This report is submitted for administrative reporting pursuant to
10CFR7O.50 Appendix A (a)(5). At no time did an unsafe condition exist. The existing criticality safety analysis of the operation bounded the situation, was effective and was not challenged.
The IROFS described for the additive sequence did not prevent incorrect type of additive from being added under all scenarios.
All affected equipment is in the process of being shut down pending revision of the ISA IROFS for this additive addition process. Units will remain shutdown pending final investigation and implementation of additional preventive actions.
Independent controls on moderation remained intact. The as found condition was previously analyzed and demonstrated to be safe. At no time did an unsafe condition exist.
Licensee will notify NRC Region 2,
North Carolina Radiation Protection Agency, and the New Hanover County Emergency Management Agency.