05000424/FIN-2017503-01
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Finding | |
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Title | Transposition Results in Significantly Different EAL Threshold Values |
Description | TBD: The inspectors identified an apparent violation (AV) of Title 10 CFR Part 50.54(q)(2) for failure to follow and maintain the effectiveness of emergency plans which met the requirements of 10 CFR Part 50.47(b)(4) and Part 50 Appendix E, to have a standardized emergency action levels (EAL) scheme in use based on facility system and effluent parameters. Specifically, the licensee's emergency classification scheme for Radiological Effluent EAL RG1 (General Emergency) and RS1 (Site Area Emergency), contained radiation monitor threshold values which were significantly different (forty-two times different) due to a transposition of the threshold values. The licensee took immediate corrective actions by entering the issue into the corrective action program as condition report (CR) 10283097 and providing corrected EAL declaration threshold values to appropriate management and decision-makers (shift managers/emergency directors) via Standing Order C-2016-008. The performance deficiency was determined to be more than minor because it was associated with the Emergency Preparedness cornerstone attribute of Procedure Quality and adversely affected the cornerstone objective of ensuring 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 declare a Site Area Emergency (SAE) and General Emergency (GE) based on effluent radiation monitor values was degraded in that event classification could be delayed and unnecessary Protective Action Recommendations could be provided to the public. The finding was assessed for significance in accordance with NRC Inspection Manual Chapter (IMC) 0609, Appendix B, Emergency Preparedness Significance Determination Process. The inspectors determined that the finding constituted a degraded rather than lost risk significant planning standard function and accordingly is assigned White significance. Additionally, the overconservative threshold values could result in an over classification and unnecessary PARs to the public. In accordance with IMC 0609, Appendix B, an EAL over-classification that would result in unnecessary PARs for the public is assigned White Significance. Because these two findings resulted from the same performance deficiency, one White finding with two examples will be cited. The cause of the finding was determined to be associated with a cross-cutting aspect in the change management component of the human performance area because the licensee failed to use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority [H.3]. |
Site: | Vogtle |
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Report | IR 05000424/2017503 Section 4OA2 |
Date counted | Dec 31, 2016 (2016Q4) |
Type: | Violation: White |
cornerstone | Emergency Prep |
Identified by: | NRC identified |
Inspection Procedure: | IP 71152 |
Inspectors (proximate) | A Gody S Sancheza Alena Gody S Sanchez |
Violation of: | 10 CFR 50 Appendix E 10 CFR 50.47(b)(4) 10 CFR 50.54(q) |
CCA | H.3, Change Management |
INPO aspect | LA.5 |
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Finding - Vogtle - IR 05000424/2017503 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Vogtle) @ 2016Q4
Self-Identified List (Vogtle)
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