05000387/FIN-2014004-01
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Finding | |
|---|---|
| Title | Adequacy of Guidance to an Emergency Plan Procedure Change |
| Description | An Unresolved Item (URI) was identified because additional information is needed to determine whether a performance deficiency exists and if a violation of 10 CFR 50.54(q)(2) occurred. The inspectors identified an issue of concern when multiple instances were noted during emergency plan (EP) drills and exercises where emergency response organization (ERO) members reached different conclusions about the status of a release when presented with the same set of plant conditions and indications. On July 24, 2014, inspectors observed a full-scale emergency preparedness (EP) drill at PPLs Susquehanna Steam Electric Station (SSES). During the drill, the inspectors observed that the staff in the Susquehanna control room (CR), the Technical Support Center (TSC), and the Emergency Operating Facility (EOF) utilized Attachment QQ of EP-PS-001, Radiological Release in Progress Guidance, Revision 3 to determine whether or not a radioactive release was occurring due to the event. The inspectors identified that, when presented with the same set of plant conditions and indications, different emergency facilities made different notifications to the offsite response organization (ORO). Specifically, the notifications pertaining to the declaration of an Unusual Event by the CR, an Alert by the TSC, the CR and TSC Emergency Directors (EDs) communicated their determinations that there was no release in progress. Conversely, in a periodic update at the Alert level by the EOF staff, the EOF Recovery Manager (RM) communicated a determination that a release was occurring. The plant conditions for all three of these notifications involved a fuel failure with an unmonitored release path to the environment because the Turbine Building ventilation was inoperable due to a loss of offsite power. However, all main steam isolation valves (MSIVs) were closed in response to the event and the only unmonitored path for radioactive material was through MSIV seat leakage assumed in the design bases. As the drill progressed, plant conditions changed and a site area emergency (SAE) was declared due to a steam leak on the RCIC system in the reactor building. A fourth notification was made, by the EOF, and the RM again stated that there was a release in progress. On July 25, 2014, the inspectors observed the post-drill critique, and noted that PPL determined that all four of these notifications were accurate thereby raising questions for the inspectors. Subsequently, in response to questions by the inspectors, PPL determined that there was initially no release in progress due to the event and that the EOF RM had communicated incorrect information during the periodic (third) update notification. The inspectors then questioned whether the subsequent (fourth) notification pertaining to the SAE was accurate. The inspectors also questioned PPL on the potential inconsistent outcomes that can arise from using the flowchart in Attachment QQ, Radiological Release in Progress Guidance, Revision 3 of EP-PS-001). The inspectors also noted that, since 2005, two changes had been made to the release progress flowchart. These two changes appeared to have the potential to change the outcome of the release in progress determinations. While reviewing the inspectors concerns, PPL identified that, in recent licensed operator requalification training cycles, crews using the Attachment QQ flowchart had reached different conclusions on whether there was a release in progress for the same set of conditions and indications as provided for the SAE declaration in the July 24th full-scale drill. PPL found that, despite this disparity, the EP organization evaluated each opportunity as having appropriately assessed the status of the release, and reported them all as drill and exercise performance (DEP) performance indicator (PI) successes to the NRC. Inspectors noted that at the time of drill performance, the EP organization did not review and did not critique whether judgment was appropriately applied, nor did they retain sufficient documentation to allow inspectors to independently inspect and assess the outcome. Therefore, the inspectors determined that additional inspection and information regarding these questions are required. The inspectors could not conclude whether each of the release determinations were accurate or whether the guidance provided to implement EPIP changes regarding release in progress determinations allowed PPLs ERO to come to disparate conclusions when presented with the same plant conditions and indications. Therefore, an Unresolved Item (URI) was identified because additional information is needed for the inspectors to determine whether a performance deficiency existed and if a violation of 10 CFR 50.54(q)(2) occurred when changes were implemented to the emergency plan implementing procedure (EPIP) for determining whether an event-based release is in progress. |
| Site: | Susquehanna  |
|---|---|
| Report | IR 05000387/2014004 Section 1EP6 |
| Date counted | Sep 30, 2014 (2014Q3) |
| Type: | URI: |
| cornerstone | Emergency Prep |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71114.06 |
| Inspectors (proximate) | C Graves E Burket F Bower J Cherubini J Greives T Daund Lawyerf Arner F Bower H Gray J Brand J Furia J Grieves J Heinly J Nicholson M Patel O Masnyk-Bailey S Pindale T Daun C Graves |
| INPO aspect | |
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Finding - Susquehanna - IR 05000387/2014004 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Susquehanna) @ 2014Q3
Self-Identified List (Susquehanna)
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