The inspectors documented a licensee-identified apparent violation of Title 10 of the Code of Federal Regulations (10 CFR) 50.54(q)(2), which preliminarily has been determined to be of low to moderate safety significance (White). Specifically, 10
CF
50.54(q)(2) requires a licensee to develop and maintain an emergency plan which meets the requirements of 10 CFR 50.47(b), and 10 CFR 50, Appendix E. Contrary to thi
requirement, from October 11, 2013, through March 4, 2014, CCNPP failed to maintain i
effect an emergency plan that met the standards in 10 CFR 50.47(b)(4) and 10 CFR 50
Appendix E,Section IV.B.1 for Unit 2. CCNPP did not maintain an adequate standar
emergency level scheme because inaccurate effluent radiation monitor thresholds wer
incorporated into Table R-1, Effluent Monitor Classification Threshold. During th
replacement of the Unit 2 main steam line radiation monitors (MSLRMs), CCNPPs staf
inaccurately calculated the associated emergency action levels (EALs) effluent threshol
values for Alert, Site Area Emergency, and General Emergency, and incorporated thes
thresholds into Table R-1. This error could have resulted in an over-classification of a
event and at the general emergency level potentially resulted in an unnecessary protective action recommendation and could cause offsite response organizations to implement unnecessary protective actions. Exelon identified the issue, entered it into their corrective action program (
CAP), implemented appropriate compensatory actions, and initiated corrective actions to revise the
EAL table. The inspectors determined the finding no longer presents an immediate safety concern since appropriate compensatory actions have been implemented. The failure to maintain the
EAL threshold values in Table R-1 of the site approved
emergency plan was a performance deficiency that was within the Exelon staff ability to foresee and correct and should have been prevented. Using
IMC 0612, Appendix B, Issue Screening, the performance deficiency was determined to be more than minor because it impacted the procedure quality attribute of the
Emergency Preparedness cornerstone and adversely impacts the associated cornerstone objective to ensure 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, an
EAL change was improperly implemented, which could result in an over-classification of an event and at the general emergency level potentially result in unnecessary protective action recommendations and movement of the public. The inspectors utilized
IMC 0609, Appendix B,
Emergency Preparedness Significance Determination Process, to determine the significance of the performance deficiency. The performance deficiency is associated with the emergency classification planning standard and is considered a risk significant planning standard (
RSPS) function. This performance deficiency impacts the following required planning standard and
RSPS function:
10 CFR 50.47(b)(4), Emergency Classification System. The inspectors were directed by the
SDP to compare the performance deficiency with the examples in Section 5.4,
10 CFR 50.47(b)(4), Emergency Classification System, to evaluate the significance of this performance deficiency. Using Table 5.4-1, Significance Examples 50.47(b)(4)," the inspectors determined that the performance deficiency matched an example of a degraded
RSPS function, which would be assessed as White. Specifically, the example states, in part, that the performance deficiency would be assessed White if the
EAL classification process would result in an over-classification that would
lead to off-site response organizations implementing, by procedure, unnecessary protective actions for the public. This condition should also be considered met if the licensee would make a protective action recommendation to the off-site response organizations because of the over-classification. The inspectors determined that the cross-cutting aspect that contributed most to the root cause is H.12, Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction techniques. Specifically, Exelon staff did not independently validate the new
EAL threshold values prior to revising and implementing the
EAL scheme change.
