05000263/FIN-2014009-04
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Finding | |
|---|---|
| Title | Safety/Security Interface Assessment Failure |
| Description | The inspectors identified a finding of very low security significance for the licensees failure to adequately assess and manage the potential for adverse effects on safety and security associated with the development and planned implementation of its external flooding mitigation plan. Specifically, 10 CFR 73.58(b)(3)(i) requires the licensee to have the capabilities to detect, assess, interdict and neutralize threats up to and including the design basis threat of radiological sabotage at all times. The failure to adequately review and evaluate the security measures and changes that would be implemented in response to a flooding event would have resulted in the requirements of 10 CFR 73.58(b)(3)(i) not being adequately maintained. This finding is not a violation of the regulatory requirements since the licensee had not actually implemented the changes that could have adversely impacted the sites security equipment, systems, and protective measures. The licensee entered the issue into its CAP to perform and document the assessments required to manage the planned changes, and to evaluate and develop potential corrective actions. The finding was of more than minor significance because it adversely affected the Security Cornerstone objective to provide high assurance that the licensee's security system uses a defense-in-depth approach and can protect against the design basis threat of radiological sabotage from external and internal threats. Specifically, the licensee failed to assess and manage changes to security equipment, systems, and protective measures that would be required in the event of the implementation of its external flooding mitigation plan to determine whether these changes could adversely impact its ability to implement the sites protective plan, which could potentially lead to a loss of defense-in-depth. The finding was of very low security significance because the total point value of this performance issue was determined to be one (1) when it was screened using the guidance provided in IMC 0609, Significance Determination Process, Appendix E, Part 1, Baseline Security Significance Determination Process (SDP) for Power Reactors, dated January 15, 2014. The inspectors determined this finding affected the cross-cutting area of human performance with a cross-cutting aspect of change management due to the licensees failure to use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority. Specifically, the licensee did not provide validation of the security plan by conducting integrated tabletops and reviews and perform additional assessment based on feedback from its external reviewers to determine whether these changes could adversely impact its ability to implement the sites protective plan. |
| Site: | Monticello  |
|---|---|
| Report | IR 05000263/2014009 Section 4OA4 |
| Date counted | Dec 31, 2014 (2014Q4) |
| Type: | Finding: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 95002 |
| Inspectors (proximate) | B Kemker G Hansen J Corujo -Sandin J Rutkowski K Riemer M Ziolkowski P Voss R Edwards P Chaput W Wan |
| CCA | H.3, Change Management |
| INPO aspect | LA.5 |
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Finding - Monticello - IR 05000263/2014009 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Monticello) @ 2014Q4
Self-Identified List (Monticello)
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