05000271/FIN-2014005-02
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Finding | |
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| Title | Misclassification of Emergency Conditions Based on Radiological Criteria |
| Description | The inspectors identified a Green NCV of 10 CFR 50.54(q), Emergency Plans, because Entergys emergency action level (EAL) classification process could result in a misclassification, a deficiency related to a risk significant planning standard. Specifically, Entergy personnel failed to correctly classify emergency conditions during an emergency preparedness drill using the applicable EAL criteria. Entergy initiated CR-VTY-2014-3990 for not recognizing the proper application of Note 1 contained in EAL AG1.1, and subsequently trained operating crews and emergency response organization (ERO) decision makers on the basis and intent of Note 1. Entergy reviewed the implementing procedures and associated basis documents and determined that applicable procedures and guidance properly described and implemented the required hierarchy of EAL AG1.1 and EAL AG1.2. This finding is more than minor because it is associated with the ERO attribute of the Emergency Preparedness cornerstone and adversely affected the cornerstone objective of ensuring that Entergy is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, the failure to establish an adequate EAL classification process could result in a general emergency (GE) declaration when a GE is not warranted. The inspectors determined the significance of the finding using IMC 0609, Appendix B, "Emergency Preparedness Significance Determination Process." The finding was determined to be of very low safety significance (Green) because of the following: the drill scenario and applicable sequence of EALs applied solely to damage to spent fuel which has a lower volatile radiological inventory than fuel in the reactor, the language in EAL AG 1.1 Note 1 uses the word "should" rather than "shall," and the EAL scheme provides for the use of judgment when meeting an EAL threshold is believed to be imminent, and the likelihood of actual emergency conditions reaching EAL AG1.1 and not reaching EAL AG1.2 is considered very low. Specifically, the inspectors considered the above extenuating circumstances and evaluated the finding in accordance with IMC 0609, Appendix B, Section 5.4, "10 CFR 50.47(b)(4), Emergency Classification System," and concluded that the EAL issue could result in an early GE declaration, but the finding more closely fit the "would result in unnecessary classification" significance category rather than the "would result in unnecessary [protective action recommendations] PARS for the public" significance category. The inspectors determined that the finding has a cross-cutting aspect in the area of Human Performance, Training, because Entergy did not ensure the knowledge and training of the trainers and ERO personnel sufficiently conveyed realistic application of radiological based EAL criteria which properly balanced the risks of radiological dose consequences with the risks associated with unnecessary protective action recommendations. |
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
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| Report | IR 05000271/2014005 Section 1EP6 |
| Date counted | Dec 31, 2014 (2014Q4) |
| Type: | NCV: Green |
| cornerstone | Emergency Prep |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71114.06 |
| Inspectors (proximate) | B Scrabeck J Brand J Furia N Day R Mckinley S Rich S Rutenkroger |
| Violation of: | 10 CFR 50.54 10 CFR 50.54(q) |
| CCA | H.9, Training |
| INPO aspect | CL.4 |
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Finding - Vermont Yankee - IR 05000271/2014005 | |||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Vermont Yankee) @ 2014Q4
Self-Identified List (Vermont Yankee)
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