05000318/FIN-2014002-02
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Finding | |
|---|---|
| Title | Inadequate Compensatory Actions for Out of Service Letdown Radiation Monitor |
| Description | The inspectors identified an NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50.54, Conditions of Licenses, paragraph (q)(2), because CENG did not maintain the Emergency Plan to adequately meet the standards in 50.47(b)(4). Specifically, following the removal of the Unit 2 letdown radiation monitor for maintenance on October 28, 2013, CENG did not establish adequate compensatory measures to ensure that a fuel clad degradation emergency action level (EAL) could be assessed in a timely manner as discussed in the Emergency Plan. This could have resulted in an unnecessary delay in the recognition of a Notice of an Unusual Event (NOUE) EAL declaration for elevated coolant reactivity. Immediate corrective actions included restoring the proper valve lineup, entering this issue into their CAP, and implementing compensatory actions, which included the use of a portable radiation monitor with appropriate alarm setpoints to initiate action to sample the RCS to determine if the specified reactor coolant activity limits are exceeded. Planned corrective actions include restoration of the Unit 2 letdown radiation monitor. This finding is more than minor because it was associated with the emergency response organization performance attribute of the Emergency Preparedness (EP) cornerstone and affected the cornerstones objective to ensure that CENG is capable of implementing adequate measures to protect public health and safety in the event of a radiological emergency. Specifically, the failure to establish compensatory actions beyond the normal RCS sampling frequency could have resulted in exceeding an NOUE EAL threshold for a degraded fuel clad and the condition not becoming known until the next normal RCS sample or upon further fuel clad degradation requiring escalation under other EALs. In accordance with IMC 0609.04, Initial Characterization of Findings, issued June 19, 2012, and IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, issued February 24, 2012, the inspectors determined the finding is of very low safety significance (Green). Utilizing IMC 0609, Appendix B, the inspectors determined that the finding is associated with an aspect of the Emergency Plan related to the EAL Classification Scheme 10 CFR 50.47(b)(4). The inspectors determined that the EAL was ineffective because it, in and of itself, no longer resulted in a timely and accurate declaration for the initiating condition. Utilizing Figure 5.4.1, the impact of the ineffective EAL is that a NOUE would be declared in a timely manner, which screens as a Green finding. In addition, the finding is similar to a Green finding in Table 5.4.1, Significance Examples 50.47(b)(4), in that the EAL classification process is not capable of classifying an Alert or NOUE in a timely and accurate manner. This finding has a cross-cutting aspect in the area of Human Performance, Work Management, because CENG personnel adequately implement a work process that included the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. Specifically, Operations and Chemistry personnel did not ensure that the assigned tasks were adequate to compensate for the increased in nuclear risk associated with having the letdown radiation monitor out of service [H.5]. |
| Site: | Calvert Cliffs  |
|---|---|
| Report | IR 05000318/2014002 Section 1R15 |
| Date counted | Mar 31, 2014 (2014Q1) |
| Type: | NCV: Green |
| cornerstone | Emergency Prep |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.15 |
| Inspectors (proximate) | N Floyd P Kaufman S Kennedy T Burns A Bolger A Rosebrook D Schroeder E Torres H. Anagnostopoulus |
| Violation of: | 10 CFR 50.54 10 CFR 50.47(b)(4) 10 CFR 50.47 |
| CCA | H.5, Work Management |
| INPO aspect | WP.1 |
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Finding - Calvert Cliffs - IR 05000318/2014002 | ||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Calvert Cliffs) @ 2014Q1
Self-Identified List (Calvert Cliffs)
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