05000317/FIN-2014003-03
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Finding | |
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| Title | Inadequate EAL Initiating Condition HA3.1 |
| Description | The inspectors identified a Green NCV of 10 CFR 50.54 (q)(2) and 10 CFR 50.47(b)(4) because Exelon did not maintain the emergency plan to adequately meet the standards in 10 CFR 50.47(b)(4). Specifically, Exelon failed to include Unit 1 and Unit 2 component cooling (CC) rooms under EAL initiating condition HA3.1. As a result, an Alert declaration would have not been made during a hazardous gas event in a vital area. Exelon entered this issue into their CAP as condition report (CR)-2014-004683. Immediate corrective actions included revising EAL initiating condition HA3.1 to include the CC rooms and verify that there are no other areas that need to be included in EAL HA3.1. The failure to update the EAL scheme the site approved emergency plan following a plant modification 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, a plant modification was completed which required operators to be able to enter the CC room in order to bring the plant to cold shutdown and the EAL scheme was not updated to reflect this change. 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 RSPS function. This performance deficiency impacts the following required planning standard and RSPS function: 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. The inspectors determined that the EAL was ineffective because it, in and of itself, no longer resulted in a timely and accurate declaration of an Alert for the initiating condition. Utilizing Figure 5.4.1, an ineffective EAL where an Alert would not be declared when required would screen as a Green finding. This finding has a cross-cutting aspect in the area of Human Performance, Change Management, because Exelon personnel didnt use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority. Specifically, Engineering personnel did not ensure that the impact to the Emergency Plan was adequately evaluated as a result of the permanent plant change engineering change package (ECP)-11-000983 [H.3]. |
| Site: | Calvert Cliffs  |
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| Report | IR 05000317/2014003 Section 1R15 |
| Date counted | Jun 30, 2014 (2014Q2) |
| Type: | NCV: Green |
| cornerstone | Emergency Prep |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.15 |
| Inspectors (proximate) | S Kennedy T O 'Hara A Rosebrook D Orr D Schroeder E Torres H . Anagnostopoulus R Clagg S Bar |
| Violation of: | 10 CFR 50.54 10 CFR 50.47(b)(4) 10 CFR 50.47 10 CFR 50.54(q) |
| CCA | H.3, Change Management |
| INPO aspect | LA.5 |
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Finding - Calvert Cliffs - IR 05000317/2014003 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Calvert Cliffs) @ 2014Q2
Self-Identified List (Calvert Cliffs)
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