05000313/FIN-2016003-04: Difference between revisions
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| identified by = NRC | | identified by = NRC | ||
| Inspection procedure = IP 71111.15 | | Inspection procedure = IP 71111.15 | ||
| Inspector = A Barrett, B Baca, B Correll, B Tindell, C Osterholtz, C Steely, G Guerra, J Choate, J Dixon, J O, | | Inspector = A Barrett, B Baca, B Correll, B Tindell, C Osterholtz, C Steely, G Guerra, J Choate, J Dixon, J O'Donnell, L Carson, M Bloodgood, M Phalen, M Tobin, N Greene, N O'Keefe, N Okonkwo, P Elkmann, R Alexander, S Hedger | ||
| CCA = N/A for ROP | | CCA = N/A for ROP | ||
| INPO aspect = | | INPO aspect = | ||
| description = Appendix A to 10 CFR 50, General Design Criteria for Nuclear Power Plants, Criterion 2, Design Bases for Protection Against Natural Phenomena, states, in part, that SSCs important to safety shall be designed to withstand the effects of natural phenomena, such as tornadoes. Criterion 4, Environmental and Dynamic Effects Design Basis, states, in part, that SSCs important to safety shall be appropriately protected against dynamic effects including missiles which may result from events and conditions outside the nuclear power unit. As part of their response to external flood boundary degradation, the licensee performed a review of external hazard protection at the site, which included protection against tornado-generated missiles required by the current licensing basis for each unit. During the review, on four separate occasions, the licensee identified plant areas containing safety-related SSCs that could be susceptible to tornado missiles: Unit 1 Upper South Electrical Penetration Room Unit 1 Cable Spreading Room Unit 1 Controlled Access Area Unit 1 Vital Switchgear In each case, the licensee identified low-probability scenarios where one or more tornado-generated missiles could penetrate doors, walls, and other building features that were not fully qualified, and subsequently damage equipment that was important to safety inside the affected rooms. Details about the date of discovery, affected SSCs, condition report numbers, compensatory actions taken by the licensee, notifications made to the NRC, and affected technical specification actions for each susceptible area are listed in Attachment 3 of this report. Relevant Enforcement Discretion Policy On June 10, 2015, the NRC issued Enforcement Guidance Memorandum (EGM) 15-002, Enforcement Discretion for Tornado-Generated Missile Protection Noncompliance. (ML15111A269) The EGM referenced a bounding generic risk analysis performed by the NRC staff that concluded that tornado missile vulnerabilities pose a low risk significance to operating nuclear plants. Because of this, the EGM described the conditions under which the NRC staff may exercise enforcement discretion for noncompliances with the current licensing basis for tornado-generated missile protection. Specifically, if the licensee could not meet the technical specification required actions within the required completion time, the EGM allows the staff to exercise enforcement discretion provided the licensee implements initial compensatory measures prior to the expiration of the time allowed by the limiting condition for operation. The compensatory actions should provide additional protection such that the likelihood of tornado missile effects are lessened. The EGM then requires the licensee to implement more comprehensive compensatory measures within approximately 60 days of issue discovery. The compensatory measures must remain in place until permanent repairs are completed, or until the NRC dispositions the non-compliance in accordance with a method acceptable to the NRC such that discretion is no longer needed. In addition, the issue must be entered into the licensees corrective action program. Because EGM 15-002 listed Arkansas Nuclear One as a Group A plant, enforcement discretion will expire on June 10, 2018. However, the EGM did not provide for enforcement discretion for any related underlying technical violations; the EGM specifically requires that any associated underlying technical violations be assessed through the enforcement process. Licensee Actions For each of the examples listed above, the licensee declared the affected systems inoperable and complied with the applicable technical specification action statement(s), initiated a condition report, invoked the enforcement discretion guidance, implemented prompt compensatory measures, and returned the SSCs to an operable status. The licensee instituted compensatory measures intended to reduce the likelihood of tornado missile effects that included developing actions to be taken if a tornado watch is predicted or issued for the area to ensure the operability or restore redundant equipment during severe weather, and actions to be taken if a tornado warning is issued, including pre-staging operators in safe, strategic locations to promptly implement mitigative actions, and verifying the readiness of equipment and procedures dedicated to the Diverse and Flexible Coping Strategy (FLEX). Other specific compensatory actions for the individual areas are listed in Attachment 3. NRC Actions The inspectors review addressed the material issues in the plant, and whether the measures were implemented in accordance with the guidance in EGM 15-002. The inspectors also evaluated whether the measures would function as intended and were properly controlled. The inspectors verified through inspection that the EGM 15-002 criteria were met in each case. Therefore, the staff determined that it was appropriate to exercise enforcement discretion and not take enforcement action for the technical specification requirements listed in Attachment 3 of this report, provided the noncompliances are resolved by June 10, 2018 (EA-16-143). The inspectors did not fully review the underlying circumstances that resulted in the technical specification violations. As stated in EGM 15-002, violations of other requirements which may have contributed to the technical specification violations will be evaluated independently of EGM implementation. The inspectors will verify restoration of compliance and assess the underlying circumstances in a follow-up inspection tracked under Licensee Event Reports 05000313/2016-002-00 and 05000313/2016-003-00, and any updates or additional licensee event reports that the licensee issues. | | description = Appendix A to 10 CFR 50, General Design Criteria for Nuclear Power Plants, Criterion 2, Design Bases for Protection Against Natural Phenomena, states, in part, that SSCs important to safety shall be designed to withstand the effects of natural phenomena, such as tornadoes. Criterion 4, Environmental and Dynamic Effects Design Basis, states, in part, that SSCs important to safety shall be appropriately protected against dynamic effects including missiles which may result from events and conditions outside the nuclear power unit. As part of their response to external flood boundary degradation, the licensee performed a review of external hazard protection at the site, which included protection against tornado-generated missiles required by the current licensing basis for each unit. During the review, on four separate occasions, the licensee identified plant areas containing safety-related SSCs that could be susceptible to tornado missiles: Unit 1 Upper South Electrical Penetration Room Unit 1 Cable Spreading Room Unit 1 Controlled Access Area Unit 1 Vital Switchgear In each case, the licensee identified low-probability scenarios where one or more tornado-generated missiles could penetrate doors, walls, and other building features that were not fully qualified, and subsequently damage equipment that was important to safety inside the affected rooms. Details about the date of discovery, affected SSCs, condition report numbers, compensatory actions taken by the licensee, notifications made to the NRC, and affected technical specification actions for each susceptible area are listed in Attachment 3 of this report. Relevant Enforcement Discretion Policy On June 10, 2015, the NRC issued Enforcement Guidance Memorandum (EGM) 15-002, Enforcement Discretion for Tornado-Generated Missile Protection Noncompliance. (ML15111A269) The EGM referenced a bounding generic risk analysis performed by the NRC staff that concluded that tornado missile vulnerabilities pose a low risk significance to operating nuclear plants. Because of this, the EGM described the conditions under which the NRC staff may exercise enforcement discretion for noncompliances with the current licensing basis for tornado-generated missile protection. Specifically, if the licensee could not meet the technical specification required actions within the required completion time, the EGM allows the staff to exercise enforcement discretion provided the licensee implements initial compensatory measures prior to the expiration of the time allowed by the limiting condition for operation. The compensatory actions should provide additional protection such that the likelihood of tornado missile effects are lessened. The EGM then requires the licensee to implement more comprehensive compensatory measures within approximately 60 days of issue discovery. The compensatory measures must remain in place until permanent repairs are completed, or until the NRC dispositions the non-compliance in accordance with a method acceptable to the NRC such that discretion is no longer needed. In addition, the issue must be entered into the licensees corrective action program. Because EGM 15-002 listed Arkansas Nuclear One as a Group A plant, enforcement discretion will expire on June 10, 2018. However, the EGM did not provide for enforcement discretion for any related underlying technical violations; the EGM specifically requires that any associated underlying technical violations be assessed through the enforcement process. Licensee Actions For each of the examples listed above, the licensee declared the affected systems inoperable and complied with the applicable technical specification action statement(s), initiated a condition report, invoked the enforcement discretion guidance, implemented prompt compensatory measures, and returned the SSCs to an operable status. The licensee instituted compensatory measures intended to reduce the likelihood of tornado missile effects that included developing actions to be taken if a tornado watch is predicted or issued for the area to ensure the operability or restore redundant equipment during severe weather, and actions to be taken if a tornado warning is issued, including pre-staging operators in safe, strategic locations to promptly implement mitigative actions, and verifying the readiness of equipment and procedures dedicated to the Diverse and Flexible Coping Strategy (FLEX). Other specific compensatory actions for the individual areas are listed in Attachment 3. NRC Actions The inspectors review addressed the material issues in the plant, and whether the measures were implemented in accordance with the guidance in EGM 15-002. The inspectors also evaluated whether the measures would function as intended and were properly controlled. The inspectors verified through inspection that the EGM 15-002 criteria were met in each case. Therefore, the staff determined that it was appropriate to exercise enforcement discretion and not take enforcement action for the technical specification requirements listed in Attachment 3 of this report, provided the noncompliances are resolved by June 10, 2018 (EA-16-143). The inspectors did not fully review the underlying circumstances that resulted in the technical specification violations. As stated in EGM 15-002, violations of other requirements which may have contributed to the technical specification violations will be evaluated independently of EGM implementation. The inspectors will verify restoration of compliance and assess the underlying circumstances in a follow-up inspection tracked under Licensee Event Reports 05000313/2016-002-00 and 05000313/2016-003-00, and any updates or additional licensee event reports that the licensee issues. | ||
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Latest revision as of 23:24, 21 February 2018
| Site: | Arkansas Nuclear  |
|---|---|
| Report | IR 05000313/2016003 Section 1R15 |
| Date counted | Sep 30, 2016 (2016Q3) |
| Type: | Violation: Severity level Enforcement Discretion |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.15 |
| Inspectors (proximate) | A Barrett B Baca B Correll B Tindell C Osterholtz C Steely G Guerra J Choate J Dixon J O'Donnell L Carson M Bloodgood M Phalen M Tobin N Greene N O'Keefe N Okonkwo P Elkmann R Alexander S Hedger |
| Violation of: | 10 CFR 50 Appendix A GDC 2 10 CFR 50 Appendix A GDC 4 |
| INPO aspect | |
| ' | |