05000387/FIN-2015503-01
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Finding | |
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| Title | Failure to Maintain a Standard EAL Scheme |
| Description | The inspectors identified an 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 CFR 50.54(q)(2) requires a licensee to follow and maintain an emergency plan which meets the requirements of 10 CFR 50.47(b), and 10 CFR Part 50, Appendix E. Contrary to this requirement, as of June 20, 2012, PPL Susquehanna (PPL) failed to establish an effective Susquehanna Steam Electric Station (Susquehanna) Emergency Plan to ensure that a timely event declaration would be made for an unisolable primary system leak outside of primary containment. Specifically, PPLs interpretation of the 15-minute assessment and classification period degraded their ability to make timely Alert or Site Area Emergency declarations in certain cases. This potential delay in declaration of an Alert or Site Area Emergency could have impacted the ability of off-site response organizations to implement timely actions to protect the public during a radiological emergency. The inspectors determined the incorrect interpretation of the 15-minute assessment and declaration period was a performance deficiency that was within PPLs 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 was associated with the ERO performance attribute of the emergency preparedness (EP) Cornerstone and affected the cornerstone objective to ensure that the licensee was capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, the finding could impact the declaration timeliness of an emergency associated with a degraded fission product barrier. The inspectors utilized IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, to determine the significance of the finding. The finding is associated with the emergency classification planning standard and is considered a risk significant planning standard (RSPS) function. This finding impacts the following required RSPS function: 10 CFR 50.47(b)(4), Emergency Classification System. The inspectors utilized the SDP to compare the finding with the examples in Section 5.4, 10 CFR 50.47(b)(4), Emergency Classification System, to evaluate the significance of this finding. Using Table 5.4-1, Significance Examples 50.47(b)(4)," the inspectors determined that the finding matched an example of a degraded RSPS function, which would be assessed as White. Specifically, the example states that the finding would be assessed as White if the emergency action level (EAL) classification process is not capable of classifying a general emergency or a Site Area Emergency within 15-minutes or declaring the emergency promptly once the appropriate classification level is determined. The inspectors determined that the cross-cutting aspect that contributed most to the root cause is P.5, Operating Experience: The organization systematically and effectively collects, evaluates, and implements relevant internal and external operating experience in a timely manner. Specifically, PPL did not perform a thorough review of operating experience during and after implementing the new EP rule to ensure all Susquehanna EAL thresholds were being evaluated in accordance with the NRCs emergency declaration timeliness requirement in the regulation. |
| Site: | Susquehanna  |
|---|---|
| Report | IR 05000387/2015503 Section 4OA2 |
| Date counted | Mar 31, 2015 (2015Q1) |
| Type: | Violation: White |
| cornerstone | Emergency Prep |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71152 |
| Inspectors (proximate) | A Dimitriadis E Burket J Grievesa Alen A Dimitriadis E Burket J Grievesa Bolger R Mckinley S Barr |
| Violation of: | 10 CFR 50.54 10 CFR 50.47(b)(4) 10 CFR 50 Appendix E 10 CFR 50.47 10 CFR 50.54(q) |
| CCA | P.5, Operating Experience |
| INPO aspect | CL.1 |
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Finding - Susquehanna - IR 05000387/2015503 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Susquehanna) @ 2015Q1
Self-Identified List (Susquehanna)
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