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05000338/FIN-2017007-0330 June 2017 23:59:59North AnnaNRC identifiedFailure to Obtain NRC Review and Approval for Changes to Safety-Related Dike West of Unit 2 Turbine BuildingThe team identified a Severity Level IV non-cited violation of 10 CFR 50.59(c)(2), Changes, Tests, and Experiments, for the licensees failure to obtain a license amendment, as specified by Nuclear Energy Institute (NEI) 96-07 Section, 4.3.2, prior to implementing a change that increased the likelihood of a malfunction of a safety-related dike. This has been entered into the licensee corrective action program as condition report 1065945. The violation was dispositioned using the traditional enforcement process in accordance with the NRC Enforcement Policy, Subsection 2.2.2 Revised August 1, 2016, because the issue affected the NRCs ability to perform its regulatory oversight function. The NRC Enforcement Policy, Section 6.1, Violation Examples for Reactor Operations, Subsection 6.1.d.2 specified that violations of 10 CFR 50.59 which resulted in conditions that were evaluated by the Significance Determination Process (SDP) as being of very low safety significance represented a severity level IV violation. The regional senior reactor analyst performed a screening analysis to determine the significance of the violation. Using very conservative failure frequencies for ductile iron pipe used in water systems, and a conservative initiating event frequency for an independent simultaneous rainfall capable of filling the dike, the finding was determined to be of very low safety significance. The inspector determined that the detailed risk evaluation confirmed that a severity level IV violation was appropriate. Crosscutting aspects are not assigned to traditional enforcement violations.
05000338/FIN-2011003-0730 June 2011 23:59:59North AnnaLicensee-identifiedLicensee-Identified ViolationNUHOMS Certificate of Compliance 1030, Amendment 0, Technical Specifications 2.1.c, Functional and Operating Limits, requires, in part, that the spent nuclear fuel stored in each 32PTH DSC/HSM-H at the Independent Spent Fuel Storage Installation (ISFSI) is to be qualified for four (4) heat load zones designated as Zones 1a, 1b, 2 and 3. Contrary to this requirement, the licensee identified that it failed to properly load fuel assemblies into seven NUHOMS Dry Shielded Canisters (DSCs) resulting in the fuel assemblies exceeding the decay heat limit for the loading zones in two of the four center zones. Specifically, the Zone 1a and Zone 1b locations were reversed, resulting in the DSC Zone 1b heat load limits being exceeded (by less than 7.5 per cent in the worst case) at the time of loading. An evaluation performed by the licensee showed that all of the affected DSCs are currently in a safe condition as loaded in the HSMs. This issue is in the licensees CAP as CR419242, NUHOMS DSCs Loaded to Incorrect Heat Load Limits for Specific Orientation. This Severity Level IV violation is being treated as a non-cited violation (NCV), consistent with Section 2.3.2.b of the NRC Enforcement Policy; specifically, the violation was identified by the licensee, the issue was placed into the licensees CAP, the violation was not repetitive as a result of inadequate corrective action, and the violation was not willful. Documents reviewed are listed in the Attachment to this report
05000338/FIN-2006501-0131 December 2006 23:59:59North AnnaLicensee-identifiedLicensee-Identified ViolationThe following violation of very low concern was identified (Severity Level IV) by the licensee and is a violation of NRC requirements which meets the criteria of Section VI of the NRC Enforcement Policy, NUREG-1600, for being dispositioned as an NCV. 10 CFR 50.54(q) states in part that the licensee may make changes to these plans without Commission approval only if the changes do not decrease the effectiveness of the plans. Proposed changes that decrease the effectiveness of the approved emergency plans may not be implemented without application to and approval by the Commission. Contrary to the above, on October 06, 2000, the licensee made changes to their Emergency Plan with Revision 23, which resulted a decrease in effectiveness (DIE) of the emergency plan. The change replaced the licensees previous standard minimum Protective Action Recommendation (PAR) based on NRC and FEMA guidance, which used the keyhole approach (i.e., evacuate all sectors to 2 miles and downwind sectors 2- 5 miles) with an evacuation to 5 miles in all directions. The change may be overly conservative in such a way as to place members of the public at unnecessary risk during evacuation of an area unaffected by a radiological release which would be more appropriately recommended for sheltering. These changes were not submitted to the NRC for approval prior to implementation. This finding is documented in the licensee's corrective action program as N2006-0568.