05000424/FIN-2016007-08
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Finding | |
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| Title | Failure to Promptly Identify Nonconformances with Tornado Missile Protection |
| Description | Enforcement Guidance Memorandum (EGM) 15-002 dated 6/10/2015, (ADAMS Accession No. ML15111A269) provided guidance to exercise enforcement discretion when an operating power reactor licensee does not comply with the plants current site-specific licensing basis for tornado-generated missile protection. Specifically, discretion would apply to the TS limiting conditions for operation (LCO) which would require a reactor shutdown or mode change, if a licensee could not meet TS LCO required action(s) within the TS completion time. The EGM background discussed Regulatory Issue Summary (RIS) 2015-06, Tornado Missile Protection, dated 6/10/2015, (ADAMS Accession No. ML15020A419) to remind licensees of the need to conform their facility to the current, site-specific licensing basis for tornado-generated missile protection. In addition the EGM stated, that upon reviewing the above-noted RIS, some licensees may discover that a TS-controlled SSC at their facility does not comply with the plants current licensing basis (CLB) and that an operability determination (or functional assessment) will be necessary. The EGM actions section specified that the NRC would exercise this enforcement discretion only when a licensee implements initial compensatory measures prior to the expiration of the time allowed by the LCO that provide additional protection such that the likelihood of tornado missile effects are lessened. The licensee initiated CR10087558 on 06/23/2015, to evaluate the RIS and conducted at least two walk-downs to identify tornado missile nonconformances. The licensee discovered potential nonconformances during these walk-downs and itemized them in a list. However, the licensee failed to identify all of these items as conditions adverse to quality (CAQs), in accordance with Appendix B, Criterion XVI. The team determined that the CAP required the evaluation of these items, CRs to document the nonconformances, and operability determinations for items affecting TS. Procedure NMP-GM-002, Corrective Action Program, Section 2, defined a condition adverse to quality in part, as an all-inclusive term used in reference to any of the following: ..., deficiencies, ..., and nonconformances potentially impacting Nuclear Safety. Nonconformances are deficiencies in characteristic, documentation, or procedure that renders the quality of an item or activity unacceptable or indeterminate. The team determined that, at the time of discovery, the itemized tornado missile vulnerabilities rendered the quality of SSCs indeterminate and thus a nonconformance in accordance with the definition in the procedure. Procedure NMP-GM-002-001, Corrective Action Program Instructions Section 4 specified that personnel should initiate a CR to identify an event, condition, problem, or process that needs correcting. [This included] nonconforming items. In addition, Section 4 specified to immediately contact the Shift Support Supervisor or Work Week Coordinator (Dispatcher) when a condition is discovered that has the potential to impact plant operation or reportability. [This included] equipment or process issues related to Technical Specifications (tech specs). The team noted that the licensee did not create any additional CRs for the itemized potential vulnerabilities as required by their corrective action instructions procedure. On October 4, 2016, the inspectors conducted plant walk downs of the SSCs selected in the CDBI inspection plan and identified potential tornado missile issues. These issues were previously highlighted as potential nonconformances by the licensee, but not identified as CAQs. As a result of these observations, the licensee initiated CRs: CR10291142, Unit 1 TDAFW Exhaust nonconformance CR10291143, Unit 2 TDAFW Exhaust nonconformance CR10291144, Unit 1 Condensate Storage Tanks nonconformance CR10291145, Unit 2 Condensate Storage Tanks nonconformance CR10291146, Unit 1 Main Steam Safety Valve Exhaust nonconformance CR10291148, Unit 2 Main Steam Safety Valves Exhaust nonconformance The licensee determined that the TDAFW Exhaust and Condensate Storage Tanks were not operable because of nonconformances with these components tornado missile protection design bases. Additionally, the licensee submitted a 10 CFR 50.72 notification report (52319) to the NRC in accordance with plant procedures and NRC requirements. |
| Site: | Vogtle  |
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| Report | IR 05000424/2016007 Section 1R21 |
| Date counted | Dec 31, 2016 (2016Q4) |
| Type: | Violation: Severity level Enforcement Discretion |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.21 |
| Inspectors (proximate) | A Della Greca A Ruh J Bartley J Eargle T Fanelli T Su W Sherbi |
| Violation of: | Technical Specification |
| INPO aspect | |
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Finding - Vogtle - IR 05000424/2016007 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Vogtle) @ 2016Q4
Self-Identified List (Vogtle)
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