05000255/LER-1917-001, Regarding Inadequate Protection from Tornado Missiles Identified Due to Nonconforming Design Conditions
| ML17144A289 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/24/2017 |
| From: | Arnone C Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| PNP 2017-024 LER 17-001-00 | |
| Download: ML17144A289 (5) | |
| Event date: | |
|---|---|
| Report date: | |
| Reporting criterion: | 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(viii)(B) 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(ix)(A) 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(v)(A), Loss of Safety Function - Shutdown the Reactor 10 CFR 50.73(a)(2)(v)(B), Loss of Safety Function - Remove Residual Heat 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(i) |
| 2551917001R00 - NRC Website | |
text
.===-Entergy PNP 2017-024 May 24,2017 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043 Tel 269 7642000 Charles F. Arnone Site Vice President 10 CFR 50.73
SUBJECT:
Inadequate Protection from Tornado Missiles Identified Due to Nonconforming Design Conditions Palisades Nuclear Plant Docket 50-255 License No. DPR-20
Dear Sir or Madam:
Entergy Nuclear Operations, Inc., submits the enclosed Licensee Event Report, 2017-001-00, in accordance with 10 CFR 50.73 for the Palisades Nuclear Plant. This report details nonconforming design conditions associated with protection against potential tornado missile impact.
This letter contains no new commitments and no revisions to existing commitments.
CFAltad Attachment: LER 2017-001-00, Inadequate Protection from Tornado Missiles Identified Due to Nonconforming Design Conditions CC Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC
ATTACHMENT LER 2017-001-00 INADEQUATE PROTECTION FROM TORNADO MISSILES IDENTIFIED DUE TO NONCONFORMING DESIGN CONDITIONS 3 Pages Follow
NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 03/31/2020 (04-2017) httD:/lwww.nrc.gov/reading*rm/doc-coliectionslnur§gs/staff/sr10221r3D the NRC may not conduct or sponsor, and a person is not required to respond to, the infonnation collection.
- 3. PAGE PALISADES NUCLEAR PLANT 05000255 10F3
- 4. nTLE Inadequate Protection from Tornado Missiles Identified Due to Nonconforming Design Conditions
- 5. EVENT DATE
- 6. LER NUMBER
- 7. REPORT DATE
- 8. OTHER FAclLinES INVOLVED SEQUENTIAL FACILITY NAME DOCKET NUMBER MONTH DAY YEAR YEAR REV MONTH DAY YEAR NUMBER NO.
05000 03 29 2017 2017 001 00 05 24 2017 FACILITY NAME DOCKET NUMBER 05000 9.OPERAllNGMODE
- 11. THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR §: Check all that apply) 1 o 20.2201(b) o 20.2203(a)(3)(i) o 50.73(a)(2)(ii)(A) o 50.73(a)(2)(viii)(A) o 20.2201(d) o 20.2203(a)(3)(ii) 18150.73(a)(2)(ii)(B) o 50.73(a)(2)(viii)(B) o 20.2203(a)(1) o 20.2203(a)(4) o 50.73(a)(2)(iii) 181 50.73(a)(2)(ix)(A) o 20.2203(a)(2)(i) o 50.36(c)(1)(i)(A) o 50.73(a)(2)(iv)(A) o 50.73(a)(2)(x)
- 10. POWER LEVEL o 20.2203(a)(2)(ii) o 50.36(c)(1)(ii)(A) 181 50.73(a)(2)(v)(A) o 73.71(a)(4) o 20.2203(a)(2)(iii) o 50.36(c)(2) 181 50.73(a)(2)(v)(B) o 73.71(a)(5) 70%
o 20.2203(a)(2)(iv) o 50.46(a)(3)(ii) o 50.73(a)(2)(v)(C) o 73.77(a)(1) o 20.2203(a)(2)(v) o 50.73(a)(2)(i)(A) 18150.73(a)(2)(v)(D) o 73.77(a)(2)(i) o 20.2203(a)(2)(vi) 18150.73(a)(2)(i)(B) 181 50.73(a)(2)(vii) o 73.77(a)(2)(ii) o 50.73(a)(2)(i)(C) o OTHER Specify in Abstract below or in
CAUSE OF THE EVENT
YEAR 2017 SEQUENTIAL NUMBER
- - 001 Due to the historical nature of the issue, a speCific cause for the identified vulnerabilities was not determined.
ASSESSMENT OF SAFETY CONSEQUENCES
REV NO.
- - 00 No actual safety consequence occurred, as Palisades did not experience an actual tomado missile event. As stated in the NRC Enforcement Guidance Memorandum,15-002, the basis for exercising enforcement discretion is a result of a generic risk analysis performed by the Office of Nuclear Reactor Regulation (NRR), Division of Risk Assessment (ORA). The assessment documents a conservative, bounding-type analysis of the risk Significance for plant facilities that may not be in compliance with their tomado missile protection licensing basis. The generic analysis assumed that core damage would occur if a tomado hit a plant located in the most active tomado region in the country and that it caused a tomado-generated missile to fail all emergency core cooling equipment at the plant with no ability to recover.
Given this conservative assumption, the core-damage frequency (COF) associated with tomado missile related to the non-compliances are well below CDFs requiring immediate regulatory action. Some tomado generated missiles may not cause system failures at all or may cause failures that are repairable or recoverable within a reasonable time frame.
In summary, the generic bounding risk analysis performed by NRR ORA has concluded that this issue is of low risk Significance. Therefore, enforcement discretion will not impose significant additional risk to public health and safety.
CORRECTIVE ACTIONS
Corrective Actions Completed:
All applicable TS equipment and systems were declared inoperable. Initial compensatory measures were implemented, per the guidance of DSS-ISG-2016-01 Appendix A, within the time allowed by the applicable LCOs.
Subsequently, the affected TS equipment and systems were declared operable but nonconforming.
To establish a heightened level of station awareness and preparedness relative to identified tomado missile vulnerabilities, a description of the nonconforming SSCs and the associated compensatory measures were documented in operations standing orders log.
Corrective Actions Planned:
Establish comprehensive compensatory measures in approximately 60 days of discovery, per the guidance of NRC Interim Staff Guidance DSS-ISG-2016-01 Appendix A.
PREVIOUS SIMILAR EVENTS
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