The inspectors identified an
NCV of
10 CFR 50.47(b)(4) and Appendix E to
10 CFR 50, Sections IV.B and IV.C because Constellation did not have a clear method to assess and determine the bay water level such that the emergency action level (
EAL) classification process would declare an Unusual Event (UE) or Alert in a timely manner. Following a lower than normal tide event which caused high debris loading across the trash racks, the inspectors determined that operators did not have adequate procedure guidance in place and readily available indication to determine actual bay water level. Constellation entered this issue into their
CAP for resolution and took actions to establish compensatory measures to monitor the bay water level pending the development of permanent corrective actions. The inspectors determined that this finding is more than minor because it is associated with the
Emergency Preparedness cornerstone attributes of procedure quality and equipment, and affects the cornerstone objective to ensure that Constellation is capable of implementing adequate measures to protect the health and safety of the public in the event of an emergency. Specifically, the lack of procedural guidance and readily available indication increases the likelihood of Constellation not being able to make an
EAL classification in a timely manner based on bay water level to protect the saltwater pumps and other equipment needed for
safe shutdown. The finding is of very low safety significance because the finding did not result in a loss or degraded Risk-Significant Planning Standard (
RSPS) Function. It is also similar to examples of green findings in Appendix B of section 4.4 in
IMC 0609 in that the
EAL classification process would not declare any Alert or Notification of UE that should be declared. This finding has a cross-cutting aspect in the area of problem identification and resolution because Constellation did not thoroughly evaluate problems associated with bay water level measurement such that the resolution addresses causes and extent of conditions, as necessary (
P.1.c per
IMC 0305