05000244/FIN-2016002-01
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Finding | |
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Title | Incorrect Emergency Action Level Table |
Description | Exelon identified that they had inadvertently made a change to the Ginna Emergency Plan. The NRC determined that this error is a preliminary White finding under the Reactor Oversight Process and a violation of Title 10 of the Code of Federal Regulations (10 CFR) 50.54 (q)(2), Emergency Plans, because Exelon did not maintain the effectiveness of Ginnas Emergency Plan such that it met the requirements of Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, and the planning standards of 10 CFR 50.47(b). Specifically, Exelon implemented a revision to the emergency action level (EAL) table for the fission product barrier matrix that was incorrect with respect to the EAL threshold associated with potential loss of containment barrier. This could have resulted in an untimely declaration of a General Emergency or a failure to declare a Site Area Emergency during an actual event. Using IMC 0612, Appendix B, Issue Screening, the performance deficiency was determined to be more than minor because it impacted the procedure quality attribute of the Emergency Preparedness cornerstone and adversely affected the associated cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, Exelons EAL table was revised without adequate technical reviews resulting in a discrepancy between the EAL table and the EAL technical basis. The EAL wording of Table F-1 containment barrier potential loss, block C.6 did not meet the minimum required operable equipment in all situations and could have resulted in a delayed General Emergency declaration or a failure to declare a Site Area Emergency. The inspectors utilized IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process [SDP], to determine the significance of the performance deficiency. The performance deficiency is associated with the emergency classification system planning standard and is considered a risk-significant planning standard function. The inspectors were directed by the SDP to compare the performance deficiency with the examples in Section 5.4, 10 CFR 50.47 (b)(4), Emergency Classification System, to evaluate the significance of this performance deficiency. In accordance with Section 5.4, when an EAL has been rendered ineffective such that any General Emergency declaration would not be declared, but due to other EALs, an appropriate declaration would be made in a degraded manner or any Site Area Emergency would not be declared for a particular off-normal event, a degradation of risk-significant planning standard function (b)(4) is determined; and the finding is White. The finding has a cross-cutting aspect in the area of Human Performance, Change Management, because Exelon did not use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority. Specifically, Exelon did not maintain a clear focus on nuclear safety when implementing changes to the EALs resulting in a significant unintended consequence, the potential to make an untimely emergency declaration. |
Site: | Ginna ![]() |
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Report | IR 05000244/2016002 Section 1EP4 |
Date counted | Jun 30, 2016 (2016Q2) |
Type: | Violation: White |
cornerstone | Emergency Prep |
Identified by: | NRC identified |
Inspection Procedure: | IP 71114.04 |
Inspectors (proximate) | A Dimitriadis A Rosebrook S Barrm Scottd Dormanj Deboerj Furia J Nicholson J Petch M Scott N Perry |
Violation of: | 10 CFR 50.47 10 CFR 50.54(q) |
CCA | H.3, Change Management |
INPO aspect | LA.5 |
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Finding - Ginna - IR 05000244/2016002 | ||||||||||||||||||||||||||||||
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Finding List (Ginna) @ 2016Q2
Self-Identified List (Ginna)
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