05000373/FIN-2018001-03
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| Title | Enforcement Action (EA) 18035: Licensee Implementation of Enforcement Guidance Memorandum 15002, Enforcement Discretion for Tornado-Generated Missile Protection Noncompliance |
| Description | On June 10, 2015, the NRC issued Regulatory Issue Summary (RIS) 201506, Tornado Missile Protection (ML15020A419), focusing on the requirements regarding tornado-generated missile protection and required compliance with the facility-specific licensing basis. The RIS also provided examples of noncompliance that had been identified through different mechanisms and referenced Enforcement Guidance Memorandum (EGM) 15002, Enforcement Discretion For Tornado Generated Missile Protection Non-Compliance, which was also issued on June 10, 2015 (ML15111A269) and revised on February 7, 2017 (ML16355A286). The EGM applies specifically to an SSC that is determined to be inoperable for tornado generated missile protection. The EGM stated that a bounding risk analysis performed for this issue concluded that tornado missile scenarios do not represent an immediate safety concern because their risk is within the LIC504, Integrated Risk-Informed Decision-Making Process for Emergent Issues, risk acceptance guidelines. The EGM provided for enforcement discretion of up to three years from the original date of issuance of the EGM. The EGM allowed NRC staff to exercise this enforcement discretion only when a licensee implements, prior to the expiration of the time mandated by the LCO, initial compensatory measures that provided additional protection such that the likelihood of tornado missile effects were lessened. In addition, licensees were expected to follow these initial compensatory measures with more comprehensive compensatory measures within approximately 60 days of issue discovery. The comprehensive measures should remain in place until permanent repairs are completed, or until the NRC dispositions the non-compliance in accordance with a method acceptable to the NRC such that discretion is no longer needed. Appendix A to 10 CFR 50, General Design Criteria for Nuclear Power Plants (GDC), Criterion 4, Environmental and Dynamic Effects Design Basis, states in part that SSCs important to safety shall be adequately protected against dynamic effects including missiles. On February 15, 2018, during evaluation of protection for Technical Specifications (TS) equipment from the damaging effects of tornado generated missiles, LaSalle County Station identified a non-conforming condition in the plant design such that specific TS equipment is considered to not be adequately protected from tornado generated missiles. Specifically, tornado generated missiles could strike the components supporting the operation of Control Room (VC) and Auxiliary Electric Room (VE) ventilation. This could result in inoperable VC/VE systems, which provide a protected environment for occupants to control the unit following an uncontrolled release of radioactivity, hazardous chemicals, or smoke if a tornado were to occur. In addition, the Unit 2 Division 2 motor control center (MCC) 236X1 was affected, which impacted various loads on Unit 2 including the Unit 2 standby gas treatment, Unit 2 Division 2 post LOCA system, B main control room area filtration system supply and exhaust fan, reactor building Division 2 isolation damper control logic, Unit 2 Division 2 battery room exhaust fan and Unit 2 24/48 Volt battery rooms exhaust fans. This would result in a loss of power to components and systems rendering them inoperable. The condition was reported to the NRC in Event Notice (EN) 53213 as an unanalyzed condition and potential loss of safety function. Corrective Actions: The licensee documented the inoperability of the SSCs and the affected TS Limiting Conditions for Operation (LCOs) in the CAP and in the control room operating log. The shift manager notified the NRC resident inspector of the implementation of EGM 15002, and documented the implementation of the compensatory measures to establish the SSCs operable but nonconforming prior to expiration of the LCO required action. Initial (immediate) compensatory measures were established by an operations standing order that included: Procedures were verified to be put in place, with associated current training, for performing actions in response to a tornado. Procedures were verified to be put in place, with associated current training, for actions to be taken if a tornado watch is issued for the area. Procedures were verified to be put in place, with associated current training, for actions to be taken if a tornado warning is issued for the area. Verification that training was up to date for individuals responsible for implementing preparation and response procedures; and Established a heightened station awareness and preparedness level relative to identified tornado missile vulnerabilities. The comprehensive (60 day) compensatory measures were established by incorporating the standing order actions and adding additional detail to operating procedure LOATORN001, High Winds/Tornado, Revision 22, for completing additional inspections and restoration actions on equipment vulnerable to tornado missile damage. Corrective Action Program References: AR 4104401; AR 4104391; AR 4104393; AR 4104396; AR 4104397. Enforcement: Violation: The enforcement discretion was applied to the required shutdown actions of the following TS LCOs for both units: TS 3.7.4, Control Room Area Filtration (CRAF) System; TS 3.7.5, Control Room Area Ventilation Air Conditioning (AC); TS 3.6.4.2, Secondary Containment Isolation Valves (SCIVs); TS 3.6.4.3; Standby Gas Treatment (SGT) System; and TS 3.8.7, Distribution SystemsOperating. Severity/Significance: The subject of this enforcement discretion, associated with tornado missile protection deficiencies was determined to be less than red (i.e., high safety significance) based on a generic and bounding risk evaluation performed by the NRC in support of the resolution of tornado-generated missile non-compliances. The bounding risk evaluation is discussed in Enforcement Guidance Memorandum 15002, Revision 1, Enforcement Discretion for Tornado-Generated Missile Protection Non-Compliance, and can be found in ADAMS, Accession No. ML16355A286. Basis for Discretion: The NRC exercised enforcement discretion in accordance with Section 2.3.9 of the Enforcement Policy and EGM 15002 because the licensee initiated initial compensatory measures that provided additional protection such that the likelihood of tornado missile effects were lessened. The licensee implemented actions to track the more comprehensive actions to resolve the nonconforming conditions within the required 60 days. These comprehensive actions were to remain in place until permanent repairs were completed, which for LaSalle were required to be completed by June 10, 2018, or until the NRC dispositioned the non-compliance in accordance with a method acceptable to the NRC such that discretion was no longer needed |
| Site: | LaSalle  |
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| Report | IR 05000373/2018001 Section 1R15 |
| Date counted | Mar 31, 2018 (2018Q1) |
| Type: | Violation: Severity level Enforcement Discretion |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.15 |
| Inspectors (proximate) | R Ruiz J Havertape W Schaup C Zoia B Dickson |
| Violation of: | Technical Specification |
| INPO aspect | |
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Finding - LaSalle - IR 05000373/2018001 | |||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (LaSalle) @ 2018Q1
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