The inspectors identified an
URI concerning the licensees failure to perform a
10 CFR 50.59 Safety Evaluation for the facility change involving the relocation of the portable pumps used to replenish the
UHS. In April 2001, the licensee completed a
10 CFR 50.59 Safety Evaluation Screening, QC-S-2001-0026, to assess removal of the portable pumps from onsite and relocating the pumps to an offsite leasing facility located a few hours away. The licensee justified the change by stating the pumps were not needed for about 2 days and to reduce costs, were not needed to be maintained on site. The licensee reasoned that leasing pumps would result in more reliable and an increased number of pumps for the event. The licensee implemented UFSAR-99-R6-165 to revise the
UFSAR wording regarding the availability of the portable pumps. Specifically, the licensee revised, Portable pumps of sufficient capacity are onsite, backup pump(s) would be available from another station or leasing facility and changed to Portable pumps of sufficient capacity are available from a leasing facility. The inspectors noted
Regulatory Guide 1.187, Guidance for Implementation of
10 CFR 50.59, Changes, Test, and Experiments, endorsed
NEI 96-07 Revision 1, Guidelines for
10 CFR 50.59 Evaluations. Section 4.2.1 of
NEI 96-07 describes how to determine whether an activity was a change to the facility or procedure as described in the
UFSAR. The guidance provides a series of questions including does the activity reduce existing redundancy, diversity, or defense in depth? In the screening, the licensee stated the proposed change did not have a negative impact, in fact, it was portrayed as a positive impact. The inspectors disagreed. Removing the pumps from on site decreased the existing redundancy, diversity and defense in depth because the site was no longer relying on onsite pumps with [emphasis added] backup capabilities and now solely relied on the backup pumps. The licensee did not consider the increased likelihood of failure due to (1) potential unavailability from the vendor due to other external events or competing interests; or (2) an accident occurring during transport which may prevent or significantly delay delivery. In addition, the inspectors determined the licensee had not completed or initiated the actions stated in the screening to support the conclusions of no negative impact. Specifically, the licensee stated a predefined would be established to periodically verify the availability of pumps. This predefine was not created. In addition, the licensee stated an actual demonstration including delivery and setup would be accomplished on a routine basis. No such activities were completed. To address the inspectors concerns, the licensee initiated
AR 01418982, Godwin Pump Relocation to perform the
10 CFR 50.59 Safety Evaluation and
AR 01416480, Godwin Pump Performance Not Routinely Checked to create a periodic surveillance to demonstrate performance of Godwin pumps including the physical delivery of pumps. As described in Section 1R07.1b.(2), additional information is necessary to determine the assumed failure mechanism of Lock and Dam No. 14. This will result in a determination of whether the portable pumps were required to remain onsite or be relocated. Therefore, this issue is considered an Unresolved Item (
URI 5000254/2013003-03;
05000265/2013003-03, Failure to Assess Impact of Relocating Portable Pumps Offsite) pending further consultation with the Office of Nuclear Reactor Regulation.
