05000263/FIN-2018002-01
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Finding | |
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| Title | Licensee-Identified Violation |
| Description | This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a Non-Cited Violation, consistent with Section2.3.2 of the Enforcement Policy.Enforcement: Violation: Title 10 CFR 50.54(q)(2) requires that a holder of a nuclear power reactor operating license follow and maintain the effectiveness of an emergency plan that meets the requirements of 10 CFR Part 50, Appendix E and the planning standards of 10 CFR 50.47(b). Title 10 CFR Part 50.47(b)(8) requires, in part, that a licensee must provide and maintain adequate emergency facilities and equipment to support the emergency response plan.Contrary to the above requirements, on March 23, 2018, the licensee identified the site failed to maintain the effectiveness of the emergency plan by not providing and/or maintaining equipment capable of measuring the Immediately Dangerous to Life and Health (IDLH) concentrations for several toxic chemicals as required to properly classify an Alert Emergency Action Level (EAL). Specifically, while performing an emergency equipment inventory, the licensee identified that detector tubes (Draeger tubes) available to measure chlorine gas concentrations were not capable of measuring the IDLH concentration of 10 ppm required to identify the threshold level for classifying an Alert EAL (HA 3.1) since the measurement range of the available sample tubes was 50500 ppm.The inability to properly classify the Alert EAL represented a Loss of Emergency Assessment Capability and resulted in the licensees submission of Event Notification Report # 53298 in accordance with the requirements of 10 CFR 50.72(b)(3)(xiii). An immediate extent of condition review performed by the licensee identified additional deficiencies in adequate sampling methods for determining IDLH concentrations for Butadiene, Ethylene Dichloride, and Gasoline. Additionally, the licensee identified that in April 2015 there was missed opportunity to correct this deficiency when an Emergency Preparedness (EP) Coordinator, performing a Control Room Emergency Equipment Inventory, identified the need to order and replace the existing chlorine detector tubes. The EP Coordinator added the incorrect detector tubes to the existing inventory form without validating the tubes detection range and accuracy to ensure it was capable of detecting the IDLH threshold concentration level of 10 ppm.Upon identification of the issue, the licensee implemented compensatory measures for determining the EAL classification and entered the issue into the corrective action program (CR 501000009876). On May 08, 2018, the licensee implemented the sites new EAL classification procedure that was developed using NEI 9901, Revision 6, which does not require atmospheric sampling (use of detection tubes) for classification of EAL HA 3.1.Significance/Severity Level: Using IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, Table 5.81, the inspectors determined this finding was
10 of very low safety significance (Green) because a significant amount of equipment necessary to implement the E-plan was not available or functional to the extent that any key ERO member could not perform his/her assigned functions, in the absence of compensatory measures (Degraded Planning Standard), specifically the ability to accurately classify the Alert EAL. Determining the finding significance using IMC 0609, Appendix B, Table 5.41, results in the same finding significance (very low significance) since the performance deficiency would have rendered an EAL initiating condition ineffective such that the Alert would have been declared in a degraded manner.Corrective Action Reference: 501000009876, CR Toxic Gas Detector Tube. |
| Site: | Monticello  |
|---|---|
| Report | IR 05000263/2018002 Section 4OA7 |
| Date counted | Jun 30, 2018 (2018Q2) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | Licensee-identified |
| Inspection Procedure: | |
| Inspectors (proximate) | P Zurawski D Krause T Go G Hanson K Riemer |
| Violation of: | 10 CFR 50 Appendix E 10 CFR 50.47 10 CFR 50.47(b)(8) 10 CFR 50.54 10 CFR 50.54(q) 10 CFR 50.72 10 CFR 50.72(b)(3)(xiii), Loss of Emergency Preparedness |
| INPO aspect | |
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Finding - Monticello - IR 05000263/2018002 | ||||||||||||||||||||||||||||||||||||||||
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Finding List (Monticello) @ 2018Q2
Self-Identified List (Monticello)
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