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05000400/FIN-2018002-0330 June 2018 23:59:59HarrisNRC identifiedFailure to Adequately Document Changes to the Emergency PlanThe inspectors identified multiple examples of a Severity Level IV (SL-IV) NCV of 10 CFR 50.54(q)(3), for changes to the licensees radiological emergency plan (E-Plan) associated with protective action recommendation (PAR) procedures and emergency response equipment that failed to demonstrate that the changes would not reduce the effectiveness of the E-Plan. Specifically, the licensee did not provide an adequate analysis to demonstrate that the removal of the sheltering in-place PARs was not a reduction in effectiveness of the E-Plan. Additionally, the licensee did not perform an analysis demonstrating that the removal of a temporary diesel generator providing a backup source of power to the Technical Support Center (TSC) did not reduce the effectiveness of the E-Plan.
05000400/FIN-2017003-0130 September 2017 23:59:59HarrisNRC identifiedIncomplete and Inaccurate Emergency Action Level SubmittalsThe NRC identified a Severity Level (SL ) IV non- cited violation (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 emergency action level (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 submit ted documents specified the licensee s EAL scheme for Category F Fission Product Barrier EAL, which contained declaration EAL threshold values for the containment high range radiation monitor that were lower than the correct values due to use of a n improper calculation methodology. The calculation methodology that was used was not in accordance with the license. It was used to calculate the loss of fuel clad barrier and potential loss of containment threshold 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 EAL scheme. The licensee entered this violation into their corrective action program (CAP) as nuclear condition report (NCR) 02155272. 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 licensee- identified violation (LIV) in Section 4OA7 of this report. The reactor oversight process (ROP) , 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. 3 Additionally, the associated technical violation was determined to be of very low safety significance. Traditional enforcement violations are not assessed for cross -cutting aspects
05000400/FIN-2015008-0131 December 2015 23:59:59HarrisNRC identifiedUntimely 10 CFR 50.73 Notification of an Inoperable CIVAn NRC-identified Severity Level IV violation of 10 CFR 50.73 was identified for the licensees failure to provide a written report to the NRC within 60 days after discovery of a condition prohibited by Technical Specification (TS) Limited Condition for Operation (LCO) 3.6.3, "Containment Isolation Valves."The issue was placed in the licensees corrective action program as CR 01958628.The inspectors determined that the failure to provide a written report to the NRC within the time limits specified in regulations was a violation 10 CFR 50.73. The violation was evaluated using Section 6.9 of the NRC Enforcement Policy, because the failure to submit a required licensee event report may impact the ability of the NRC to perform its regulatory oversight function. As a result, this violation was evaluated using traditional enforcement. In accordance with Section 6.9.d.9of the NRC Enforcement Policy, this violation was determined to be a Severity Level IV, non-cited violation. The inspectors determined that a cross-cutting aspect was not applicable because the issue involving untimely reports to the NRC was strictly associated with a traditional enforcement violation.
05000400/FIN-2015003-0630 September 2015 23:59:59HarrisNRC identifiedFailure to Report the Loss of Emergency Assessment CapabilityThe inspectors identified a severity level (SL) IV NCV of 10 CFR 50.72(b)(3)(xiii) for the failure to report to the NRC within 8 hours the major loss of emergency assessment capability of the Technical Support Center (TSC). Specifically, on multiple occasions between January 2015 and July 2015, there were unplanned losses of emergency response facility (ERF) function, which resulted in the loss of emergency assessment capability, which the licensee failed to report the condition within the 8-hour time requirement. Subsequently, the licensee notified the NRC once it was realized a report was required and entered the issue in the CAP as AR 757885. The failure to report the loss of emergency assessment capability in the TSC as required by 10 CFR Part 50.72(b)(3)(xiii) was a performance deficiency. The licensees failure to notify the NRC was determined to impact the regulatory process, which requires evaluation through the traditional enforcement process. Based on the examples provided in Section 6.9 of the Enforcement Policy, dated February 4, 2015, Inaccurate and Incomplete Information or Failure to Make a Required Report, the performance deficiency was determined to be a SL IV violation. Specifically, example d.9 states that a SL IV violation involves a failure to make a report required by 10 CFR 50.72 or 10 CFR 50.73. Because the violation was processed as a traditional enforcement violation, no cross-cutting aspect is assigned.
05000400/FIN-2013010-0130 June 2013 23:59:59HarrisNRC identifiedFailure to Report a Degraded Primary Safety Barrier Per 10 CFR 50.73(A)(2)(II)(A)The inspectors identified a non-cited violation of Title 10 of the Code of Federal Regulations (10 CFR) Part 50.73(a)(2)(ii)(A) for the licensees failure to submit a 60-day Licensee Event Report (LER) for a condition in which one of the plants principal safety barriers was seriously degraded. The licensee generated Action Request 00606893 to document the failure to provide the required 60-day LER. The inspectors determined that the failure to report a seriously degraded principal safety barrier as required by 10 CFR 50.73(a)(2)(ii)(A) was a performance deficiency. Using the guidance of Inspection Manual Chapter 0612, Appendix B, Issue Screening, the team determined the performance deficiency involved a violation that could have impacted the regulatory process, therefore, it was dispositioned using the traditional enforcement process. In accordance with Section 6.9.d.9 of the NRC Enforcement Policy, a failure to make a report required by 10 CFR 50.73 is a Severity Level IV violation. Cross-cutting aspects are not assigned to traditional enforcement violations.
05000400/FIN-2011008-0130 June 2011 23:59:59HarrisNRC identifiedFailure to Report Required Information Related to MSIV FailureThe team identified a Severity Level IV violation of 10 CFR 50.73 for the licensees failure to include all required information in licensing event report (LER) 2010-002-00. The licensee submitted a supplemental LER to include all required information. The licensee entered this issue into the CAP as NCR 458636. The licensees failure to include all pertinent information in LER 2010-002-00 was a performance deficiency. This finding was considered a severity level IV violation in accordance with traditional enforcement as outlined in the NRC enforcement policy. 10 CFR Part 50.73, states in part that the LER shall contain the failure mode, mechanism, and effect of each failed component, if known. Contrary to this, the licensee failed to include specific information related to the main steam isolation valve failure in the LER. The finding was considered to be of low safety significance because it was not repetitive or willful, and was entered into the licensees corrective action program. The team determined that no cross cutting aspect was applicable to this performance deficiency because traditional enforcement violations are not screened for cross cutting attributes.
05000400/FIN-2010002-0131 March 2010 23:59:59HarrisNRC identifiedFailure to Submit a Licensee Event Report for a Condition Prohibited by Technical Specifications Associated with the B Emergency Service Water Discharge ValveThe inspectors identified a Severity Level IV, non-cited violation (NCV) of 10CFR 50.73(a)(2)(i)(B) due to the licensees failure to recognize that the inability of the B Emergency Service Water (ESW) Discharge Valve (1SW-271) to open on the start of B ESW pump caused a reportable condition. Consequently, the licensee failed to submit a licensee event report (LER) within 60 days as required by 10 CFR50.73. The licensee entered this issue into the corrective action program (CAP) as Action Request (AR) #361821 and AR #358062. The licensee took corrective action by reporting this event in LER 05000400/2010-001, Clearance Error Results in Equipment Becoming Inoperable. The licensees failure to recognize that the inability of 1SW-271 to open caused a reportable condition and submit an LER as required by 10 CFR 50.73 was a performance deficiency. This issue was dispositioned as traditional enforcement, instead of the Significance Determination Process, because it had the potential for impacting the NRCs ability to perform its regulatory function. However, because this violation was of very low safety significance, was not repetitive or willful, and was entered into the licensees CAP as AR #361821 and AR #358062, the NRC has characterized the significance of this violation as a Severity Level IV NCV in accordance with section IV.A.3 and supplement I of the NRC Enforcement Policy. The cause of this event was directly related to the cross-cutting aspect in the area of problem identification and resolution within the CAP component because the licensee did not adequately evaluate the need to submit an LER per the requirements of 10 CFR 50.73.