05000400/FIN-2017003-02
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Finding | |
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| Title | Review of Removal of the Technical Support Center (TSC) Temporary Diesel Generator |
| Description | The inspectors conducted a detailed review of NCR 02123373, Emergency Action Level Document Calculation Assumptions. The inspectors chose the sample because the EAL issue initially appeared to be potentially more significant than finally determined. The inspectors evaluated the following attributes of the licensees actions: complete and accurate identification of the problem in a timely manner evaluation and disposition of operability and reportability issues consideration of extent of condition, generic implications, common cause, and previous occurrences classification and prioritization of the problem identification of root and contributing causes of the problem 19 identification of any additional condition reports completion of corrective actions in a timely manner 2. The inspectors conducted a detailed review of NCR 00520918, Loss of Offsite Power Impact on Technical Support Center (TSC). The inspectors chose the sample because it was discovered that on July 17, 2017, the licensee had removed a temporary diesel generator that was intended to provide a back -up reliable power source to the TSC until a permanent solution was implemented. The inspectors evaluated the following attributes of the licensees actions: complete and accurate identification of the problem in a timely manner evaluation and disposition of operability and reportability issues consideration of extent of condition, generic implications, common cause, and previous occurrences classification and prioritization of the problem identification of root and contributing causes of the problem identification of any additional condition reports completion of corrective actions in a timely manner b. Findings 1. Incomplete and Inaccurate Emergency Action Level Submittals Introduction: The NRC identified a Severity Level IV NCV of 10 CFR 50.9 , Completeness and accuracy of information, for failure to provide complete and accurate information for prior approval of a new EAL scheme. The documents submitted to the NRC were, Shearon Harris Nuclear Power Plant, Unit 1 Changes to the Emergency Action Level Scheme, dated April 25, 2010, and License Amendment Request to Adopt Emergency Action Level Scheme Pursuant to NEI 99- 01, Revision 6, dated April 30, 2015. The first submittal to the NRC in 2010 was not complete and accurate in all material respects , and the submittal in 2015 was a missed opportunity to identify the errors made in the first submittal in 2010. Description : On May 10, 2017, Shearon Harris identified the hot operating mode EAL thresholds were calculated incorrectly using a NUREG -0654 methodology vice the required NEI 99- 01 Rev. 6 method, as specified in the current facility licensing basis. When employing the NUREG -0654 methodology to calculate the EAL threshold values, the reactor coolant system (RCS) inventory was assumed to be released at a 50 gallons per minute (gpm) RCS leak rate and activity of 300 micro -Curies per gram (ci/gm) dose equivalent iodine (DEI), over a six -hour period of time. In comparison, when employing the NEI 99- 01 Rev. 6 methodology, the assumption as part of calculating the EAL threshold values was that the entire RCS inventory was released instantaneously at an activity of 300ci/gm DEI. Both of the licensees submittals to the NRC, specified the licensee s EAL scheme for Category F Fission Product Barrier EAL, contained declaration EAL threshold values for the containment high range radiation monitor for loss of fuel clad barrier and potential loss of containment , that were significantly lower than the correct values , due to use of the improper calculation methodology. The submittal dated April 30, 2015, was submitted to provide a complete change to the EAL scheme. This submittal was a missed opportunity by the licensee to identify that the wrong methodology to calculate the EAL threshold values had been used. 20 These submittals were not correct in material content and impacted the NRC s regulatory processes. The NRC evaluated the licensees failure to provide complete and accurate information to determine if there were any unresolved issues. The inspectors concluded that the incomplete and inaccurate information in the license submittal was material to the NRC because, had the NRC staff known the actual methodology used was inaccurate, the staff would have required the licensee to modify the EAL threshold values . The licensee appropriately revised the EAL threshold values utilizing the correct calculation methodology. The licensee issued NC R 02123373, dated May 10, 2017, for EAL thresholds that were calculated without using the correct methodology described in the facility licensing basis. The licensee implemented compensatory corrective actions by issuing Standing Instruction 2017- 017 to inform operators and emergency response organization decision - makers of the proper application of the EAL scheme and revised threshold values to be implemented until a permanent change is made to the license. Additionally, the licensee issued NCR 02155272, dated October 3, 2017, for the incomplete and inaccurate EAL submittal, specifically addressing and resolving the completeness and accuracy issues identified by the inspectors. The final significance determination of the underlying technical issue for the licensees failure to maintain the effectiveness of its emergency plan was documented in NRC Inspection Report 05000400/2017003, Section 4OA7, as a Green LIV. Analysis : The inspectors evaluated the underlying technical issue and determined that the licensees failure to maintain the effectiveness of its emergency plan was a performance deficiency. The issue was documented as a Green LIV in Section 4OA7 of this report. The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it was necessary to address this violation which impeded the NRCs ability to regulate, using traditional enforcement to adequately deter non- compliance. Using the NRC Enforcement Policy, Section 2.3.11, Inaccurate and Incomplete Information, and Section 6.9, Inaccurate and Incomplete Information or Failure to Make a Required Report , this issue was determined to be a SL IV violation. Though the NRC would have questioned the issue with a request for additional information, it would not have resulted in substantial further inquiry. Additionally, the associated technical violation was determined to be of very low safety significance. Traditional enforcement violations are not assessed for cross -cutting aspects . Enforcement : Section 50.9 of 10 CFR states, in part, that, information provided to the Commission by a licensee shall be complete and accurate in all material respects. Contrary to the above, on April 25, 2010, and on April 30, 2015 , information was submitted by the licensee to the NRC that was not complete and accurate in all material respects. Specifically, the submitted documents specified the licensee s EAL scheme for Category F Fission Product Barrier EAL, contained EAL declaration threshold values for the containment high range radiation monitor , that were lower than the actual correct values , due to use of an improper calculation methodology. This was not in accordance with the license. It was used to calculate the loss of fuel clad barrier and potential loss of containment thresholds values. The licensee implemented compensatory corrective actions by issuing Standing Instruction 2017 -017 to inform operators and emergency response organization decision -makers of the proper application of the EAL scheme and appropriate threshold values to be implemented. Additionally, the licensee plans to submit a license amendment request to update the 21 EAL scheme. Because this violation was not repetitive or willful, and was entered into the licensees CAP as NC R 02155272, it is being treated as a SL IV NCV, consistent with Section 2.3.2 .a of the NRC Enforcement Policy. ( NCV 05000400/2017003- 01, Incomplete and Inaccurate Emergency Action Level Submittal s) 2. Adequacy of Process for Removal of the TSC Temporary Diesel Generator Introduction: The inspectors opened an Unresolved Item (URI) to complete a review of the licensees removal of a temporary diesel generator on July 17, 2017, that was previously installed to provide reliable backup power to the TSC in the event of a Loss of Offsite Power (LOOP) coincident with a Loss of Coolant Accident (LOCA) event. This temporary diesel generator was originally intended to be installed until a reliable backup power source could be implemented under a permanent modification. Description : The licensee initiated NCR 00520918 on March 1, 2012, to address the consequences of a LOOP/LOCA event on the T SC functionality. Since the TSC is designed with two sources of electrical power, both from offsite power sources, it was recognized that a complete loss of offsite power to the TSC could result in long term TSC operational concerns. Specifically, with t he loss of both offsite power sources, the TSC emergency ventilation system, which provides required radiation protection for event response personnel, would be non- functional, as well as other critical TSC equipment following the loss of short -term (~1 -2 hour s) back -up battery power supplies. The inspectors noted that the operability/functionality section of NCR 00520918 stated that the TSC was functional based on the (current) availability of both of the offsite power sources; however, should a LOOP event occur, then the TSC would be considered non -functional since offsite power would be rendered non -functional. This statement demonstrated the licensees understanding of the vulnerability of continued TSC functionality during a LOOP event. In recognition of this vulnerability, the NCR implemented a short -term solution for procuring and installing a temporary diesel generator in late 2012 under modification EC 85350. The inspectors noted that an emergency preparedness change review evaluation was conducted in accordance with 10 CFR 50.54(q) under action request 00568695. This change request stated that it was necessary to provide the infrastructure for an additional reliable power source for the TSC habitability systems. NCR 00520918 stated that the long- term solution was to provide a permanent backup power supply to the TSC , at which time the temporary diesel generator would be removed. While an action item was initiated to install this TSC permanent backup power source under modification EC 85145, the modification was later revised, removing the intended implementation of a permanent backup power source to the TSC. The inspectors were concerned that the TSC could have equipment and habitability issues during design basis LOOP/LOCA events when the normal TSC offsite power would be non- functional. In addition, the inspectors determined that the TSC temporary diesel generator was removed from the site on July 17, 2017, without implementing the originally intended reliable permanent backup power to the TSC and without conducting a 10 CFR 50.54(q) evaluation specific to its removal to demonstrate that this action did not reduce the effectiveness of implementing the emergency plan. The inspectors requested additional information from the licensee related to the documentation, basis, and process used for the removal of the TSC temporary diesel generator, and evidence that the TSC facility would still be capable of performing all of its intended functions during a LOOP/LOCA event. This issue of concern requires more information to 22 determine if a performance deficiency exists, and if the performance deficiency potentially constitutes a violation of regulatory requirements . Pending review of additional information from the licensee, this issue is identified a s URI 05000400/2017003 -02, Review of Removal of the Technical Support Center ( TSC ) Temporary Diesel Generator. |
| Site: | Harris  |
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| Report | IR 05000400/2017003 Section 4OA2 |
| Date counted | Sep 30, 2017 (2017Q3) |
| Type: | URI: |
| cornerstone | Emergency Prep |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71152 |
| Inspectors (proximate) | J Zeiler A Patz M Donithan S Shah R Kellner J Panfel W Pursley J Rivera S Sanchez J Hickman S Rose |
| INPO aspect | |
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Finding - Harris - IR 05000400/2017003 | |||||||||||||||||||||||||||||||||
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Finding List (Harris) @ 2017Q3
Self-Identified List (Harris)
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