05000298/FIN-2016004-02
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Finding | |
|---|---|
| Title | Failure of an Analysis to Demonstrate that Changes Did Not Reduce the Effectiveness of the Emergency Plan |
| Description | The inspectors identified a non-cited violation of 10 CFR 50.54(q)(3) for the licensees failure to perform an analysis demonstrating that proposed emergency plan implementing procedure changes did not reduce the effectiveness of the emergency plan. Specifically, the licensees 50.54(q) evaluation failed to demonstrate that Emergency Plan Implementing Procedure 5.7.1, Emergency Classification, Revision 54, changes, associated with Emergency Action Level SG2.1 and the fission product barrier matrix, did not result in a reduction in effectiveness. The corrective action was to revise 10 CFR 50.54(q) Evaluation 2016-011 to provide additional information about the ability of emergency coordinators in the Technical Support Center and Emergency Operations Facility to classify using the revised emergency action levels. The licensee entered this deficiency into the corrective action program as Condition Report CR-CNS-2016-05697. The licensees failure to perform an analysis demonstrating that proposed changes to Emergency Plan Implementing Procedure 5.7.1 did not reduce the effectiveness of the emergency plan, in violation of 10 CFR 50.54(q)(3), was a performance deficiency. The finding was more than minor, and therefore a finding, because it was associated with the procedure quality attribute (emergency action level changes) of the Emergency Preparedness Cornerstone and adversely affected the 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, the licensees ability to ensure that adequate measures are taken to protect the health and safety of the public is degraded if the licensee performs inadequate analyses of the effects of changes to the emergency plan. Using Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, Attachment 2, dated September 22, 2015, the inspectors determined that the finding was of very low safety significance (Green) because it was not associated with a risk-significant planning standard function or a planning standard function. This finding had a cross-cutting aspect in the area of human performance, associated with change management, because the licensee failed to use a systematic process for evaluating and implementing changes so that nuclear safety remains the overriding priority. Specifically, the licensee did not have an adequate understanding of the licensing basis for making changes to emergency action levels [H.3]. |
| Site: | Cooper  |
|---|---|
| Report | IR 05000298/2016004 Section 1EP4 |
| Date counted | Dec 31, 2016 (2016Q4) |
| Type: | NCV: Green |
| cornerstone | Emergency Prep |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71114.04 |
| Inspectors (proximate) | C Henderson G Warnick J O'Donnell M Phalen P Elkman P Voss |
| Violation of: | 10 CFR 50.54 10 CFR 50.54(q) |
| CCA | H.3, Change Management |
| INPO aspect | LA.5 |
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Finding - Cooper - IR 05000298/2016004 | |||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Cooper) @ 2016Q4
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