05000317/FIN-2009005-03
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Finding | |
|---|---|
| Title | Failure to Provide for Adequate Compensatory Measures with the Wide Range Noble Gas Monitor Out of Service |
| Description | The inspectors identified a Green NCV of 10 CFR 50.54(q), Conditions of Licenses, because Constellation did not properly maintain the conditions of the CCNPP Emergency Plan. Specifically, Constellation did not implement timely changes to the Emergency Plan and its dose assessment implementing procedures when CCNPP transitioned from the NUREG-0654 emergency action level (EAL) scheme to the NUMARC NESP-007 EAL scheme in 1993. The change in the EAL schemes resulted in additional site area emergency (SAE) and general emergency (GE) classification levels based on effluent monitor radiation levels. When these new EALs were added, Constellation did not revise their Emergency Response Plan Implementing Procedure (ERPIP)-821 to consider the radiation levels, which would exist at the SAE and GE thresholds. The specific concern involved the inability to take the compensatory measures when the wide range noble gas monitor (WRNGM) was out of service; manual radiation readings could not be taken near the WRNGM due to the radiation levels which could exist at the SAE and GE conditions. Constellation entered this issue into their corrective action program (CAP) for resolution as condition report (CR)-2009-003720. Constellations corrective actions included: the installation of a radiation meter at the 10- meter distance from the main stack that was remotely readable; revision of emergency Response Plan Implementing Procedure (ERPIP)-821 to account for the current Calvert Cliffs EAL thresholds; and the performance of a human performance investigation to provide for additional corrective actions to assure that plant changes are evaluated for impact and necessary changes to the emergency plan and its implementing procedures. The finding is more than minor because it affected the Emergency Response Organization (ERO) performance and procedure quality attributes of the Emergency Preparedness (EP) Cornerstone to ensure that Constellation is capable of implementing adequate measures to protect the public health and safety in the event of a radiological emergency. In accordance with IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, the inspectors determined that the finding is of very low safety significance (Green). Specifically, the inspectors utilized IMC 0609, Appendix B, Section 4.9 and Sheet 1, Failure to Comply, and determined that the failure to comply with an aspect of the Emergency Plan related to dose assessment (10 CFR 50.47(b)(9)) was an RSPS problem; but it was not a RSPS functional failure of the CCNPP dose assessment process. This was not a degraded RSPS function because Calvert Cliffs EAL scheme has redundant EALs that provided assurance that this performance deficiency ultimately would not have affected the outcome of protecting the health and safety of the public or of station personnel. This finding has a cross-cutting aspect in the area of identification and resolution of problems because the WRNGM has failed in the past (including as recently as December 2008 and May 2009), yet Constellation did not appropriately evaluate the proposed compensatory actions in a manner to assure the dose assessment function was not negatively affected. Specifically, the provisions of the ERPIP-821 sampling procedure had repeatedly been relied upon, but in fact were not able to satisfy the dose assessment functions required by the CCNPP Emergency Plan (P.1.c of IMC 0305) |
| Site: | Calvert Cliffs  |
|---|---|
| Report | IR 05000317/2009005 Section 4OA2 |
| Date counted | Dec 31, 2009 (2009Q4) |
| Type: | NCV: Green |
| cornerstone | Emergency Prep |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71152 |
| Inspectors (proximate) | D Silk M Davis K Young D Johnson S Barr G Dentel N Perry R Rolph J Hawkins |
| CCA | P.2, Evaluation |
| INPO aspect | PI.2 |
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Finding - Calvert Cliffs - IR 05000317/2009005 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Calvert Cliffs) @ 2009Q4
Self-Identified List (Calvert Cliffs)
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