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05000483/FIN-2014004-032014Q3CallawayLicensee-Identified ViolationThe licensee dose assessment methods are inaccurate under some circumstances. Title 10 of the Code of Federal Regulations, Section 50.54(q)(2) requires, in part, that power reactor licensees follow and maintain the effectiveness of an emergency plan that meets the requirements of Appendix E to Part 50 and the standards of 10 CFR 50.47(b). Section 50.47(b)(9) requires that adequate systems, methods, and equipment for assessing the actual and potential offsite consequences of a radiological emergency condition are in use. Contrary to the above, between December 5, 2009, and April 23, 2014, Callaway Plant did not maintain the effectiveness of an emergency plan that fully met the standards of 10 CFR 50.47(b). Specifically, the licensee failed to maintain adequate systems, methods, and equipment for assessing the actual and potential offsite consequences of a radiological release to the environment. The licensee identified circumstances which could cause their dose assessment program to overestimate offsite doses by a factor of 24. This finding was assessed using Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, and was determined to be of very low safety significance (Green). The finding was a failure to comply with NRC requirements, was not a loss of risk significant planning standard function, and was not a degraded planning standard function. The finding was determined not to degrade the planning standard function because the calculation was not inaccurate in its normal operating configuration, the circumstances in which the inaccurate calculation would be used were rare, a method existed for the operator to correct the error, and because the error could be readily detected from examination of the dose assessment report. The issue was entered into the licensees corrective action program as Corrective Action Request 201402814.
05000528/FIN-2015301-012015Q2Palo VerdeLicensee-Identified ViolationThe following violation of very low safety significance (Green) and Severity Level IV was identified by the licensee and is a violation of NRC requirements, which meets the criteria of the NRC Enforcement Policy, for being dispositioned as a Non-Cited Violation. Title 10 CFR 55.49, Integrity of Examinations and Tests, requires, in part, that facility licensees shall not engage in any activity that compromises the integrity of any application, test, or examination required by this part. Contrary to the above, on April 14, 2015, the licensee engaged in an activity that compromised the integrity of the examination. Specifically after administrative JPMs had been administered to the applicants by the examination team, the licensee, upon performing their examination security walk-down, neglected to secure a three-ring binder that contained two reactor operator and two senior reactor operator administrative JPMs that were to be performed the next day. All four JPMs were left unattended and unsecured until 5:00 a.m. on April 15, 2015, when they were discovered as part of the licensee examination security preparation procedure. The four compromised JPMs were replaced by new administrative JPMs as required by NUREG-1021. The failure to meet 10 CFR 55.49 was evaluated through the traditional enforcement process because it impacted the ability of the NRC to perform its regulatory oversight function. This resulted in assignment of a Severity Level IV violation because it involved a non-willful compromise of examination integrity and is consistent with Section 6.4.d of the NRC Enforcement Policy. The associated performance deficiency was screened as Green because there was not an actual effect on the equitable and consistent administration of any examination required by 10 CFR 55.59, Integrity of Examinations and Tests. The licensee entered this issue into their corrective action program as PVAR 4645293.