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05000282/FIN-2018002-012018Q2Prairie IslandResults of ISFSICask Array Dose Calculation Not Incorporated into FSARPrairie Island ISFSI FSAR, as updated, Revision 18, Section A7A.7 evaluates off-site dose rates for an array of ISFSI casks. In this dose rate calculation, explicit modeling credit is given to the earthen berm that surrounds the Prairie Island ISFSI as discussed in Section A7A.7.1. The earthen berm provides radiation shielding for the ISFSI. This calculation allows the licensee to demonstrate, in part, compliance with Title 10 of the Code of Federal Regulations (CFR) 72.104(a) which requires, in part, that, During normal operations and anticipated occurrences, the annual dose equivalent to any real individual who is located beyond the controlled area must not exceed 0.25 mSv (25 mrem) to the whole body, 0.75 mSv (75 mrem) to the thyroid and 0.25 mSv (25 mrem) to any other critical organ. Calculation TN40HT0502, TN40HT Far Field Shielding Calculations, Revision 0, was performed by the licensee in support of a License Amendment Request (LAR) to modify the Prairie Island ISFSI TN40 cask design (designated as TN40HT casks). The TN40HT LAR was submitted to the NRC by the licensee on March 28, 2008. This dose rate calculation does not credit the earthen berm and, in part, also allows the licensee to demonstrate, in part, compliance with 10 CFR 72.104(a). The licensee also provided this calculation directly to the NRC in a February 29, 2012, letter in response to a Request for Supplemental Information (RSI) from the NRC associated with the license renewal application for the Prairie Island ISFSI. Although the results from calculation TN40HT0502 for a single cask was incorporated into the Prairie Island ISFSI FSAR, Revision 18, in Tables A7A.22 and A7A.61, the results from TN40HT0502 for an array of casks which, in part, allows the licensee to demonstrate, in part, compliance with 10 CFR 72.104(a), has not been incorporated into the ISFSI FSAR, Revision 18.Title 10 CFR 72.70, Safety analysis report updating requires, in part, that (a) Each specific licensee for an ISFSI shall update periodically, as provided in paragraphs (b) and (c) of this section, the FSAR to assure that the information included in the report contains the latest information developed (b) Each update shall contain all the changes necessary to reflect information and analyses submitted to the Commission by the licensee or prepared by the licensee pursuant to Commission requirement since the submission of the original FSAR or, as appropriate, the last update to the FSAR under this section. The update shall include the effects of: (2) All safety analyses and evaluations performed by the licensee in support of approved license amendments.This Unresolved Item is being opened to determine whether or not the licensee is required to update the ISFSI FSAR with the results of calculation TN40HT0502 for an array of casks in accordance with 10 CFR 72.70.Planned Closure Action: Region III will coordinate with the Division of Spent Fuel Management in the NRC Office of Nuclear Material Safety and Safeguards to determine whether or not calculation TN40HT0502 is subject to the FSAR updating requirements of 10 CFR 72.70 for the Prairie Island ISFSI.
05000387/FIN-2008005-012008Q4SusquehannaIneffective Evaluation and Incorporation of Operating Experience into the Corrective Action ProgramA self-revealing finding was identified for failing to properly implement PPL procedure NDAP-QA-0725 regarding the incorporation and evaluation of operating experience (OE) into the corrective action program and control of field work. Specifically, in December 2007 an industry operating experience report regarding the control of field work for nitrogen freeze seals in plant vital areas was entered into Susquehannas corrective action program. However, the inspectors identified that PPLs review and evaluation of this OE resulted in no corrective actions taken or planned and that the relevant information was not communicated to the affected station groups as required by NDAP-QA-0725, Appendix D. Inspectors determined that the lack of corrective actions and inadequate communication of industry OE were primary contributors to the Susquehanna Unit 2 Alert declaration on October 27, 2008. This emergency declaration was required when the oxygen level in the 2B residual heat removal (RHR) pump room, which is a plant vital area, dropped below the minimum allowable threshold of 19.5 percent, which is the Immediately-Dangerous-to-Life-and- Health (IDLH) limit. This finding was more than minor because the failure to properly implement NDAP-QA- 0725, Appendix D, to evaluate external industry OE, implement corrective actions, and communicate the OE information to those who performed the relevant tasks at Susquehanna resulted in prohibiting access to safety-related equipment in the RHR room, resulted in the declaration of an emergency event (Alert), and increased the Technical Specification (TS) out-of-service (OOS) time for the 2B RHR pump. This finding affected the equipment performance attribute of the Mitigating Systems cornerstone and was of very low safety significance (Green) because it was not a design or qualification deficiency, there was no loss of safety function, and it was not potentially risk significant due to external events. The finding was not a violation of regulatory requirements but represented a failure to properly implement NDAP-QA- 0725, Appendix D, in that external OE was not correctly evaluated and as a result, relevant information was not communicated to the affected work groups. PPL entered this issue into their corrective action program (CR # 1086125) and implemented corrective actions that included procedure revisions, reinforcement of procedure adherence, and training and qualification revisions. The inspectors determined that this finding has a cross-cutting aspect in the area of Problem Identification and Resolution (operating experience component) because PPL did not systematically or effectively evaluate and communicate industry OE to affected internal stakeholders in a timely manner. (IMC 0305 aspect: P.2(a)). (Section 4OA3
05000387/FIN-2008005-022008Q4SusquehannaLicensee-Identified Violation10 CFR Part 50, Appendix B, Criterion VIII, \\\"Identification and Control of Materials, Parts and Components,\\\" requires measures be established for the identification and control of material parts and components. These measures shall assure that identification of the item is maintained by part number, serial number or other appropriate means, traceable to the item throughout fabrication, installation, and use of the item. These control measures shall be designed to prevent the use of incorrect or defective parts or components. Contrary to this requirement, on December 16, 2008, PPL identified that the safety-related, 480 volt motor control center 1B217 supply breaker installed in the safety-related, 480 volt bus 1B 210 was not an Appendix B, Quality Controlled component. This issue was entered into PPLs CAP (CR 1101415). This violation is of very low safety significance (Green) because it resulted in a qualification deficiency that reduced component reliability but was confirmed not to result in the loss of component or safety system function
05000387/FIN-2008005-032008Q4SusquehannaLicensee-Identified ViolationTechnical Specifications 6.12.2 require that the areas where the radiation level exceeds 1000 mrem per hour be provided with locked doors, and that the keys shall be maintained under the administrative control of the shift foreman. Administrative control for these keys is that they be in the physical possession of a health physics technician. Contrary to this requirement, on October 23, 2008, the key to a posted locked high radiation area was left unattended and not in the possession of a health physics technician, for approximately 15 minutes. This was identified in the licensee=s CAP as CR 1085400. This finding is of very low safety significance (Green) because while the key was not in the physical possession of a health physics technician, the door to the area remained locked, and no unauthorized entry to the area was made