View source for NL-18-0265, Request to Extend Enforcement Discretion Provided in Enforcement Guidance Memorandum 15-002 Concerning Non-Conforming Conditions with Current Licensing Basis for Tornado-Generated Missile Protection

{{Adams
| number = ML18087A386
| issue date = 03/28/2018
| title = Request to Extend Enforcement Discretion Provided in Enforcement Guidance Memorandum 15-002 Concerning Non-Conforming Conditions with Current Licensing Basis for Tornado-Generated Missile Protection
| author name = Gayheart C
| author affiliation = Southern Nuclear Operating Co, Inc
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000348, 05000364
| license number = 
| contact person = 
| case reference number = NL-18-0265, RIS-15-006
| document type = Letter type:NL
| page count = 14
}}

=Text=
{{#Wiki_filter:*     Southern Nuclear                               Regulatory Affairs        40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242 205 992 5000 tel March 28, 2018                                                                  205 992 7601 fax Docket Nos.: 50-348                                                             NL-18-0265 50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant- Unit 1 and 2 Request to Extend Enforcement Discretion Provided in Enforcement Guidance Memorandum 15-002 Concerning Non-Conforming Conditions with Current Licensing Basis for Tornado-Generated Missile Protection Ladies and Gentlemen:
Southern Nuclear Operating Company (SNC) hereby requests that the NRC extend the period of Enforcement Discretion for Farley Nuclear Plant (FNP) Unit 1 and 2 from June 10, 2018, to June 10, 2020, pursuant to Enforcement Discretion Memorandum (EGM) 15-002, Revision 1. FNP has identified two (2) non-conforming conditions (NCCs) regarding Tornado Missile Protection (TMP) requirements affecting structures, systems and components (SSCs) within the scope of the FNP Technical Specifications (TS). The NCCs have been documented in the corrective action process in accordance with station procedures, all required notifications have been made, compensatory measures are in place, and enforcement discretion has been exercised.
* FNP has completed discovery activities in response to Regulatory Issue Summary (RIS) 2015-06. A summary of the discovery methodology, scope and results is provided in the enclosure to this letter. Consistent with the guidance provided in EGM 15-002 and Interim Staff Guidance DSS-ISG-2016-01, compensatory measures have been implemented for the identified NCCs affecting TS SSCs and are described in the enclosure to this letter.
Additionally, a collective review of all compensatory measures currently in place, along with expected operator actions in response to severe weather and a subsequent loss of off-site power (LOSP), has been performed and confirmed that these compensatory measures will be able to be performed in an effective manner.
SNC has concluded that there is no undue risk associated with this requested extension in the enforcement discretion period. We request your approval of this request before June 10,' 2018.                                                   .
This letter contains no NRC commitments. If you have any questions, please contact Ken McElroy at 205.992.7369.

U. S. Nuclear Regulatory Commission NL-18-0265 Page2 Respectfully submitted, CAG/kgl/cg

==Enclosure:==
Justification for Request to Extend the Enforcement Discretion Regarding Tornado Missile Protection Requirements Cc:   Regional Administrator, Region II NRR Project Manager- Farley Nuclear Plant Senior Resident Inspector- Farley Nuclear Plant RTYPE: CFA04.054

Joseph M. Farley Nuclear Plant- Unit 1 and 2 Request to Extend Enforcement Discretion Provided in Enforcement Guidance Memorandum 15-002 Concerning Non-Conforming Conditions with Current Licensing Basis for Tornado-Generated Missile Protection Enclosure Justification for Request to Extend the Enforcement Discretion Regarding Tornado Missile Protection Requirements

Enclosure to NL-18-0265 Justification for Request to Extend the Enforcement Discretion Regarding Tornado Missile Protection Requirements
: 1. Introduction This enclosure provides the justification for the Southern Nuclear Operating Company (SNC) request to extend the expiration date for enforcement discretion regarding tornado missile protection requirements for the Joseph M. Farley Nuclear Plant (FNP).
In Reference 1, the NRC issued Regulatory Issue Summary (RIS) 2015-06, ''Tornado Missile Protection," to, in part, remind licensees of the need to conform with a plant's current, site-specific licensing basis for tornado-generated missile protection.
In Reference 2, the NRC provided, in Enforcement Guidance Memorandum (EGM) 2015-002, guidance to exercise enforcement discretion when a licensee does not comply with a plant's current site-specific licensing basis for tornado-generated missile protection.
EGM 2015-002 identified FNP as a higher tornado missile risk site (Group A), resulting in an enforcement discretion expiration date of June 10, 2018.
SNC completed a comprehensive tornado missile protection assessment for FNP and has identified non-conforming conditions regarding tornado missile protection requirements.
Compensatory measures were implemented to address the non-conforming conditions.
SNC has confidence in the completeness of the discovery activities conducted by station staff which form the basis for this request.
SNC is requesting an extension to the enforcement discretion expiration date to allow sufficient time to address the non-conforming conditions.
SNC plans to *Submit a license amendment request (LAR) to request approval for the use of the Tornado Missile Risk Evaluator (TMRE) methodology, currently under development by the industry, for evaluating the identified non-conformances.
This reqyest to extend enforcement discretion was prepared in a.ccordance with guidance in Appendix B of Revision 1 of Interim Staff Guidance DSS-ISG-2016-01 (Reference 3).
: 2. RIS 2015-06 Assessment Methodology The methodology followed by SNC for FNP in response to RIS 2015-06 includes the following three objectives:
(1) document the FNP current licensing basis (CLB) for tornados and tornado missile protection, (2) evaluate the site's conformance with the tornado missile protection CLB through a design review and plant walkdowns, and document any non-conforming conditions, and (3) resolve the non-conforming conditions within the SNC corrective action program.
: 3. Summary of CLB for Tornados and Tornado Missile Protection Design The FNP CLB for tornados and tornado missiles pertinent to the RIS 2015-06 assessment are described in the FNP Updated Final Safety Analysis Report (UFSAR), Chapter 3.
Category I Structures are designed to protect safety-related equipment and components from being damaged by tornado missiles. The three types of tornado missiles are as follows:
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Enclosure to NL-18-0265 Justification for Request to Extend the Enforcement Discretion Regarding Tornado Missile Protection Requirements
* A 12-ft-long piece of wood 8 in. in diameter (114 lb.) traveling end-on at a speed of 300 mph and striking the structure at any elevation.
* A 1O-ft-long steel pipe, schedule 40, 3 in. in diameter (75.8 lb.), traveling end-on at a speed of 100 mph and striking the structure at any elevation.
* A 4000-lb automobile, traveling end-on at a speed of 50 mph and striking the structure on an impact area of 20 sq. ft., with any portion of the impact area being not more than 25ft. above grade.
A limited number of unprotected portions of systems and components are analyzed using a probabilistic missile damage analysis computer program (TORMIS), developed by the Electric Power Research Institute (EPRI) and accepted by the NRC.
: 4. Description of the Non-Conformances Where the EGM was Applied FNP completed reviews and walkdowns of structures and components, designed to withstand the tornado missiles specified in the CLB.
The non-conforming conditions, and affected systems, identified during the reviews and walkdowns were documented in the following condition reports (CRs) within the corrective action program:
CR 10306023- Service Water Intake Structure (SWIS) Intake and Exhaust Ventilation H.oods (Compensatory Measures in Place, Enforcement Discretion Invoked)
The 2016 Tornado Missile Protection (TMP) Walkdown identified the Service Water Intake Structure (SWIS) intake and exhaust ventilation hoods as non-conforming to FNP's Licensing Basis with respect to protection from tornado-generated missiles. The ventilation hoods TPNS (total plant numbering system) numbers are: QSW 41 C505A/B/C-B, QSW 41 C505D/E/FA, QSW 41 C506A/B/C-B, QSW41C506D-A, QSW41C508A/B/C/D, and QSW41C510A/B. The TMP walkdown was performed as part of SNC's response to NRC Regulatory Issue Summary 2015-06, Tornado Missile Protection, dated 6/10/15. This item was entered into the Farley Corrective Action Program as Condition Report 10306023.
CR 10322897 - Diesel Fuel Oil Storage Tank Vents (Compensatory Measures in Place, Enforcement Discretion Invoked)
The Tornado Missile Protection (TMP) project team identified the diesel generator (DG) fuel oil storage tank (FOST) vents as non-conforming to FNP's Licensing Basis with respect to protection from tornado-generated missiles. Each DG FOST is provided with a 1" vent pipe that extends above the ground and is exposed to tornado missiles. The FOST vents are required to transfer fuel oil to support the emergency diesel generators (EDG) to meet the FSAR Chapter 15 accident analyses requirements involving loss of offsite power (LOSP). LOSP is considered a credible event concurrent with a design basis tornado (REA 97-1409). If the 1-inch vent pipes were hit by a tornado missile they could become crimped and impede the transfer of fuel oil thereby resulting in failure of the associated EDGs to perform their safety functions. The DG FOST TPNS numbers are: Q1Y52T502, QSY52T501, QSY52T503, Q2Y52T503, and QSY52T504. The TMP project was initiated in response to NRC Regulatory Issue Summary 2015-06, Tornado Missile E-2

Enclosure to N L-18-0265 Justification for Request to Extend the Enforcement Discretion Regarding Tornado Missile Protection Requirements Protection, dated 6/10/15. This item was entered into the Farley Corrective Action Program as Condition Report 10322897.
These non-conforming conditions were reported by SNC as an eight-hour notification on December 7, 2016, (Event Number 52414) under the following regulations:
* 10 CFR 50.72(b)(3)(ii)(B), ''The nuclear power plant being in an unanalyzed condition that significantly degrades plant safety."
* 10 CFR 50.72(b)(3)(v)(D), "Mitigate the consequences of an accident."
The NRC resident inspector was also notified.
Operability determinations were completed and documented in the corrective action program. The non-conforming equipment was declared inoperable. Guidance in Revision 1 of EGM 15-002 (Reference 4) was used to declare the equipment operable but non-conforming and to implement enforcement discretion.
Licensee Event Report (LEA) 2016-009-00 (Reference 5) was submitted in accordance with 10 CFR 50.73 due to Technical Specification-required equipment that did not meet CLB requirements for protection against tornado missiles.
: 5. Description of the Prompt and Long-Term Compensatory Measures Prior to the initial FNP walkdowns, generic compensatory measures were developed and proceduralized to meet the intent of Appendix A of the Interim Staff Guidance DSS-ISG-2016-01. These generic compensatory measures were developed to act as the required prompt compensatory measures prior to the expiration of the time allowed by the LCO as described in the Enforcement Guidance Memorandum (EGM) 15-002 for use of the enforcement discretion. Generic measures were also developed for the long-term comprehensive compensatory measures. These comprehensive compensatory measures were put into place within 60 days of identification of the nonconformance as described in DSS-ISG-2016-01 Interim Staff Guidance.
The following describes these prompt and long-term compensatory measures taken in response to the identified non-conforming conditions:
The site specific severe weather procedure, FNP-0-AOP-21.0, and fleet procedure, NMP-OS-017, were updated and provide guidance for responding to tornado warnings and watches.
Appendix II of FNP-0-AOP-21.0 provides site-specific potential contingency actions for tornado warnings and watches. Appendix Ill of FNP-0-AOP-21.0 provides guidance for sustained high winds. Step 1.4 and Step 6 of Appendix II of FNP-0-AOP-21.0 were revised. This revision has the Operations crew evaluate any standing action items related to the Tornado Missile Project (TMP). This was done to encompass any future findings by the TMP team until each finding is mitigated. Step 6.2 of Appendix II was revised to address the DG FOST vents. This step was moved up in priority to be the first mitigating action following an actual tornado hit. Each tank vent is required to be inspected to ensure tanks can provide their vent function. FNP-0-AOP-21 was also revised to provide additional guidance on the obstruction or pipe collapse. The operator would be directed to notify Maintenance for immediate repair and to secure any running transfer pump on a non-vented tank. Additionally, a caution was applied to state that any running transfer E-3

Enclosure to NL-18-0265 Justification for Request to Extend the Enforcement Discretion Regarding Tornado Missile Protection Requirements pump should be secured within 40 minutes due to vacuum concerns on the tank. The 40-minute time would assume continuous operation. These specific pumps would cycle on level of their associated day tank if in auto thus extending the total time to address this issue.
Additionally, if any pump was in manual operation, this would be performed by a locally stationed operator. In the event of severe weather, plant personnel would be putting their task in a safe condition thus the operator would be securing the evolution. If not, the operator would still be there on station to address any diesel concerns during the evolution. Based on a walk down from the control room, it would take approximately 11 minutes to evaluate the vent lines and secure any running fuel pumps (on either train) assuming safe weather conditions.
Additionally, the actions for severe weather described in NMP-OS-017 would be performed concurrently. NMP-OS-017, Severe Weather, is directed to be performed by Step 3 of FNP-0-AOP-21.0. In the event of actual damage to the DG FOST vents, Step 6.2.2 of Appendix II directs the operator to immediately notify Maintenance to correct the issue. As discussed above, Step 6.2 of Appendix II provides the operator with a caution of securing any running fuel transfer pump within 40 minutes on a fuel tank that is not properly vented. This number is conservative since when operating in auto, the fuel transfer pump would cycle based on day tank level.
FNP-0-AOP-21.0 Step 6.7 of Appendix II was also revised to ensure the SWIS ventilation hoods are inspected in the event of a tornado strike. Additionally, the crew should refer to FNP-0-SOP-0.22 to account for water accumulation. SWIS Building temperature alarms in the main control room (MCR). FNP-0-ARP-8.0 provides guidance to restore temperature including manual operation of the damp'ers, blocking open dampers and opening fire doors to reduce temperature.
Symptoms and Entry Conditions for Abnormal Operating Procedure for Severe Weather FNP-0-AOP-21.0 are if severe weather conditions are experienced or anticipated from any of the following:
* TORNADO WARNING This is issued when a tornado is indicated by the WSR-88D radar or sighted by spotters; therefore, people in the affected area should seek safe shelter immediately. They can be issued without a tornado watch being already in effect. They are usually issued for a duration of around 30 minutes. A tornado warning is issued by your local National Weather Service office (NWFO). It will include where the tornado was located and what towns will be in its path.
* TORNADO WATCH This is issued by the National Weather Service when*
conditions are favorable for the development of tornadoes in and close to the watch area. The watch area can vary depending on the weather situation. They are usually issued for a duration of 4 to 8 hours. They normally are issued well in E-4

Enclosure to NL-18-0265 Justification for Request to Extend the Enforcement Discretion Regarding Tornado Missile Protection Requirements advance of the actual occurrence of severe weather. During the watch, people should be prepared to move to a place of safety.
* Visual report of a tornado in the vicinity of or on the plant site, a tornado warning that could affect the plant site or a tornado watch that has been issued and determined to be a threat to the plant site.
If any immediate weather hazards exist, such as a tornado sighting, tornado warning imminently affecting the plant, a high wind condition or a severe thunderstorm is imminent Step 1.4 of FNP-AOP-21.0 requires review of any open tornado missile contingency action plans. In the event of a tornado striking the plant Step 1.5 directs implementation of Appendix II, Potential Tornado Contingencies while continuing with FNP-0-AOP-21.0.
Appendix II Potential Tornado Contingencies FNP-0-AOP-21.0 Steps 1 through 4 apply when a tornado watch that may affect the plant site is in effect and time to take precautionary measures exists.
Step 1.3: Begin monitoring of the National Weather Service to keep informed of the latest tornado warnings or watches at www.weather.gov. Refer to APPENDIX Ill, SUSTAINED HIGH WIND CONTINGENCIES, Step 1 weather source information.
Step 1.5: Inspect the plant site for loose or unsecured material.
[] Protected Area
[]High Voltage Switchyard
[] Turbine buildir.tg and transformer areas
[] SWIS
[] RWIS
[]Cooling Towers and outside areas
[]Water Treatment plant outside areas
[] Training Center
[]Warehouse, West Office Building and adjacent areas
[]Underground Diesel Fuel Oil Storage Tank area
[] Flex Storage Building Step 1.6: Carefully inspect plant building roofs for loose or unsecured material, being cognizant that some items may blend in with the roofing.
Step 1.7: Secure all items which may become missiles during high winds.
Step 3 of FNP-0-AOP-21.0: Perform the actions of NMP-OS-017, Severe Weather, as deemed appropriate, while continuing with the performance of FNP-0-AOP-21.0.
Step 6 of Appendix II applies if a tornado strikes the plant site, requiring the performance and action of the following:
Step 6.1: Implement any previously identified Tornado Missile Contingency Action Tracking Items.
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Enclosure to NL-18-0265 Justification for Request to Extend the Enforcement Discretion Regarding Tornado Missile Protection Requirements Step 6.2: Check the five underground Diesel Fuel Oil Tank Vents.
Step 6.2.1: Ensure vents are clear of debris and are capable of venting.
Step 6.2.2: If any Diesel Fuel Oil Tank Vent is obstructed/pinched (Inadequate Vent Path), Then immediately direct Maintenance to correct condition (Crash Cart WO is available)
Step 6.2.3: Ensure Diesel Fuel Transfer system is operating properly based on system status.
Step 6.2.4: Secure any Fuel Transfer Pump running on a non-vented tank.
Step 6. 7.1: Perform general plant inspection for damage including siding and roof damage. (Refer to FNP-0-SOP-0.22)
[] Protected Area
[]High Voltage Switchyard
[] Turbine building and transformer areas
[] SWIS (Including Roof Vent and Exhaust Hoods)
[] RWIS
[]Cooling Towers and outside areas
[] Water Treatment plant outside areas
[] Training Center
[]Warehouse, West Office Building and adjacent areas
{] Underground Diesel Fuel Step 6.7.2- IF in-leakage is identified, take immediate measures to temporarily protect electrical equipment by containing or deflecting leakage (e.g. install catch devices or containment rigs). This is also covered in Farley Water Intrusion Monitoring procedure FNP-0-SOP-0.22 Severe Weather NMP-OS-017 This procedure provides minimum requirements to site personnel for preparations, staff augmentation, and compensatory measures necessary should a severe weather pattern be projected to, or actually, affect the site. This procedure applies to all site personnel assigned to perform duties during the initial notifications of approach, preparations, and actual impact of a severe weather pattern. Once the site is notified of a warning for high winds, severe storm, or tornado by the Control Room or National Weather Service AND, time permitting, the site Duty Manager shall notify site supervision to take the appropriate actions per the applicable station procedures and Severe Weather Preparation Checklists, Attachments 1 through 9, of NMP-OS-017. In addition, personnel should be directed to:
Inspect the site for potential missiles.
AND Secure equipment that could become a missile.
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Enclosure to NL-18-0265 Justification for Request to Extend the Enforcement Discretion Regarding Tornado Missile Protection Requirements Site supervision shall notify the Work Week Manager once their respective checklist has been completed. The Work Week Manager shall provide status updates and notification when all checklists have been completed to the Site Duty Manager.
Attachments 1 through 9 provide checklists for severe weather preparations.
Maintenance checklist includes but not limited to:
* Perform walk-downs of outside areas.
* Evaluate sandbags usage for expected water and flooding boundaries, especially for plant intake structure.
* Use booms around grating, to avoid water flow on top of critical components.
Chemistry and the contractor equipment cleaners, maintain an ample supply of booms.
* Fill vehicles, tractors, bucket truck and equipment with fuel.
* Contact list developed, published and posted:
o Maintenance crew 24-hour coverage o Tool Room o Facilities Operations & Maintenance o Electricians to support temp power o Labor Support o Scaffold Support o Forklift Operations checklist includes but not limited to:
* Increase rounds/logs for cooling water system intakes and structures for early identification of adverse trends. If any work is required at the intake/cooling structures (that is, continuous manning of the traveling screens for flushing), then ensure plant operators are equipped with the foul weather gear (including life vests).
* Ensure adequate resources (including use of maintenance personnel, if necessary) are available to conduct hourly inspections of operating spaces as compensatory measures. Ensure adequate high intensity lights available to support the additional inspections.
* Brief crews on applicable Abnormal Operating Procedure as applicable. Evaluate conducting just-in-time training for the Operations staff to prepare for potential storm-induced casualties, including a station blackout, loss of off-site power, load rejection casualty, single-loop service water operations, and rapid shutdown.
* Anticipate falling barometric pressure and high winds that may cause a reduction in main condenser vacuum and drywell pressure. Makeup to the drywell should be planned accordingly.
* Consider staging personnel in key locations (intakes, emergency diesel generator buildings, and so forth), if safe, that may be difficult to reach during storm conditions.
* All sumps/pits should be drained to lowest levels.
* If the OCC is manned, announce via plant page that the Outage Control Center (OCC) is the point of contact for all water-related problems in the field. This will E-7

Enclosure to NL-18-0265 Justification for Request to Extend the Enforcement Discretion Regarding Tornado Missile Protection Requirements free up the Control Room staff from unnecessary phone calls and allow the OCC to set priorities for addressing problem and staffing.
* Consider staging portable dewatering pumps and portable electric generators with fuel supplies for sumps and possible flooding.
* Inspect areas surrounding operating equipment for loose objects.
Crash cart work orders have been planned and developed in the event immediate repair is required due to tornado missile damage to the SWIS Ventilation Hoods and the Diesel Fuel Oil Storage Tank Vents. A crash cart work order is a planned, packaged, and staged for implementation in the event damage to the Diesel Fuel Oil Storage Tank Vents and SWIS roof vents is identified. Tools are available in the cold tool room located in the maintenance shop and are easily accessible if necessary. The list below identifies the crash cart work orders that are also staged in a crash cart work order cabinet located in the maintenance shop.
SWIS Roof Vents
* SNC832554      Service Water Pump Room Exhaust Ventilator B
* SNC832555       SWIS PUMP ROOM B- EXHAUST FAN C
* SNC832556       SERVICE WTR B TAN BATI CHGR RM INTAKE VENT
* SNC832557       SERVICE WTR A TAN BATI CHGR RM INTAKE VENT.
* SNC832558       SW PUMP ROOM EXHAUST VENTILATOR E
* SNC832559       SW A TRAIN SWITCHGEAR ROOM INTAKE VENT. FAN
* SNC832560      SW A TRAIN SWITCHGEAR ROOM STANDBY EXHAUST FAN
* SNC832561      SW PUMP ROOM EXHAUST VENTILATOR D
* SNC832562       SW TRAIN B SWITCHGEAR ROOM INTAKE VENT. FAN
* SNCB32563      SW B TRAIN SWITCHGEAR ROOM EXHAUST FAN
* SNC832564       SW PUMP ROOM EXHAUST VENTILATOR F
* SNC832565       SW PUMP ROOM B EXHAUST FAN A Diesel FOST
* SNC840976 18 DG FUEL STORAGE TANK
* SNC8409771-2A DG FUEL OIL STORAGE TANK
* SNC840978 1C DG FUEL OIL STORAGE TANK
* SNC840979 28 DG FUEL OIL STORAGE TANK
* SNC840980 2C DG FUEL OIL STORAGE TANK
: 6. Comprehensive Assessment of All Compensatory Measures The above long-term compensatory measures and other expected operator actions in response to severe weather and a subsequent loss of off-site power (LOSP) were collectively assessed. The assessment concluded that the implemented long-term compensatory measures along with other required actions in a severe weather LOSP event can be completed without putting unnecessary burden on the operators.
An assessment of time-critical actions/time-sensitive actions (TCAs/TSAs) was also performed. Time-critical actions that occur outside of the control room and that are plausibly necessary concurrent with a high winds/tornado event include isolating CST E-8

Enclosure to NL-18-0265 Justification for Request to Extend the Enforcement Discretion Regarding Tornado Missile Protection Requirements suction line to AFW and response to Extended Loss of AC Power (ELAP). These actions are not specifically required following a LOSP or tornado event; however, they were reviewed to provide additional assurance that the added compensatory measures will not hinder control room operator actions for any plausible scenarios. The time-sensitive actions that occur (at least in part) outside of the control room and that are relevant to a LOSP or consequential LOSP from a tornado or high wind event include the reestablishment of un-sequenced loads following loss of offsite power, stage and connect portable SG Flex Pump for steam generator makeup in the event of TDAFWP failure and ELAP response.
: 7. Basis for Need for Additional Enforcement Discretion Time In EGM 2015-002 (Reference 2), the NRC provided guidance to exercise enforcement discretion when an operating power reactor licensee does not comply with a plant's current site-specific licensing basis for tornado-generated missile protection. The NRC would exercise this enforcement discretion only when a licensee implements initial compensatory measures to provide additional protection, followed by more comprehensive, long-term compensatory measures implemented within 60 days of issue discovery. The enforcement discretion would expire three years after issuance of RIS 2015-06, dated June 10, 2015, for plants of a higher tornado missile risk (Group A Plants),
and five years after RIS issuance for plants of a lower tornado missile risk (Group B Plants). EGM 2015-002 identified FNP as a plant of a higher tornado missile risk; therefore, its enforcement discretion would expire on June 10, 2018.
In Reference 4, the NRC issued Revision 1 of EGM 2015-002, which stated that licensees may request an extension to their enforcement discretion expiration date if proper justification is provided. This extension would be granted on a ~ase-by-case basis.
In accordance with the revised EGM 15-002, SNC is requesting an extension of the expiration date for enforcement discretion at FNP from June 10, 2018, to June 10, 2020.
There is no undue risk associated with this requested extension of the enforcement discretion due date. The identified non-conformances involve limited exposure of equipment to tornado missiles, and, in many of the non-conformances, the equipment is partially protected or has redundancy.
A comprehensive assessment of the site regarding tornado missile protection against the current licensing basis has been completed, revealing the non-conformances discussed above. The compensatory actions implemented for the non-conformances are consistent with the guidance in EGM 15-002 and NRC Interim Staff Guidance DSS-ISG-2016-01, and provide assurance that the consequences of the identified non-conformances are minimized until permanently resolved. Additionally, a collective review was performed to confirm that the site operators can perform the long-term compensatory measures coincident with other standard required actions in a severe weather LOSP event without putting unnecessary burden on the operators. These compensatory measures would remain in-place throughout the period of extended enforcement discretion, until the non-conformances are resolved.
The TMRE methodology is being developed by the industry to evaluate tornado missile protection non-conforming conditions. LARs for implementation of the TMRE methodology at several pilot sites have been submitted and accepted by the NRC.
Approval of the pilot site LARs by the NRC is not expected until mid-year 2018. Once the E-9

Enclosure to NL-18-0265 Justification for Request to Extend the Enforcement Discretion Regarding Tornado Missile Protection Requirements pilot site LARs have been approved, then other licensees with identified tornado missile protection non-conformances would submit LARs, based on the approved pilot LARs, for implementation of the TMRE methodology to address the non-conformances at their sites.
To address the tornado missile protection non-conformances identified at FNP, SNC would need to perform a TMRE analysis for the non-conformances, prepare and submit a LAR for use of the TMRE methodology to evaluate the non-conformances, and obtain NRC approval of the LAR. The FNP LAR would be submitted after the LARs for the pilot sites have been approved. If the TMRE methodology did not resolve all of the non-conformances at FNP, then the installation of plant modifications would need to be pursued. This would need to be completed by the current enforcement discretion expiration date of June 10, 2018. Since NRC approvals of the pilot site LARs are not expected until sometime in 2018, SNC actions to resolve the non-conformances at FNP cannot be reasonably implemented in an orderly and cost-effective manner in the time remaining under the existing enforcement discretion.
The requested enforcement discretion expiration date of June 10, 2020, would allow SNC sufficient time to resolve the tornado missile protection non-conformances and restore the site to compliance.
If conditions arise such that achieving tornado missile protection compliance at FNP within the requested extended period of enforcement discretion is not possible, the NRC would be promptly notified.
: 8. Restoration of Licensing Basis Compliance SNC plans to submit a LAR for the use of the TMRE methodology, currently in
  . development by the industry. The TMRE methodology would be used to evaluate the identified non-conformances.
If an approved TMRE methodology is not available for use, SNC would consider performing plant modifications to eliminate the non-conformances.
: 9. References
: 1. NRC Regulatory Issue Summary 2015-06, Tornado Missile Protection, dated June 10, 2015 (ADAMS Accession Number ML15020A419)
: 2. NRC memorandum, Enforcement Guidance Memorandum 15-002, Enforcement Discretion for Tornado Generated Missile Protection Non-Compliance, dated June 10, 2015 (ADAMS Accession Number ML15111A269)
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Enclosure to NL-18-0265 Justification for Request to Extend the Enforcement Discretion Regarding Tornado Missile Protection Requirements
: 3. NRC Interim Staff Guidance, DSS-ISG-2016-01, "Clarification of Licensee Actions in Receipt of Enforcement Discretion Per Enforcement Guidance Memorandum EGM 15-002, Enforcement Discretion for Tornado-Generated Missile Protection Noncompliance," Revision 1, dated November 2017 (ADAMS Accession Number ML17128A344)
: 4. NRC memorandum, Enforcement Guidance Memorandum 15-002, Revision 1:
Enforcement Discretion for Tornado-Generated Missile Protection Noncompliance, dated February 7, 2017 (ADAMS Accession Number ML16355A286)
: 5. License Event Report 2016-009-00, Tornado Missile Vulnerabilities Result in Condition Prohibited by Technical Specifications, dated February 2, 2017 (ADAMS Accession Number ML170338232)
: 6. NRC Interim Staff Guidance, DSS-ISG-2016-01, "Clarification of Licensee Actions in Receipt of Enforcement Discretion Per Enforcement Guidance Memorandum EGM 15-002, Enforcement Discretion for Tornado-Generated Missile Protection Noncompliance," dated February 2016 (ADAMS Accession Number ML15348A202)
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