05000244/FIN-2015002-04

Finding

Title

Adequacy of Exelon's Protective Action Recommendation Strategy

Description

Exelons Emergency Plan at Ginna was not in compliance with the regulation at the time the URI was opened. Specifically, as required by 10 CFR 50.47(b)(10), Exelon did not include bodies of water in their PAR scheme for the plume exposure pathway. In December 2014, Exelon worked with the local county OROs and revised the ERPAs at Ginna to include Lake Ontario. Exelon has amended Ginnas Emergency Plan (Revision 03900) and PAR scheme to reflect the change. The NRC concluded that it was not reasonable for Exelon to have been able to foresee and correct the violation caused by not having PARs for Lake Ontario. Specifically, in light of the NRC inspection reports, which approved the licensees Emergency Plan and did not identify this issue, the licensee reasonably concluded that it was in compliance with NRC requirements. Therefore, the NRC did not identify any performance deficiency associated with the violation. IMC 0612, Appendix B, Issue Screening, issued September 7, 2012, directs disposition of this issue in accordance with NRC Enforcement Policy because there was no performance deficiency. Therefore, in accordance with NRC Enforcement Policy, Section 2.2.4.d, which states that a violation involving no performance deficiency is considered an exception to using only the operating reactor assessment program, the inspectors dispositioned this violation using traditional enforcement. The inspectors used NRC Enforcement Policy, Section 6.6, Emergency Preparedness, to evaluate the significance of this violation. The inspectors concluded that the violation is more than minor and best characterized as Severity Level III (low-to-moderate safety significance) because it is similar to Enforcement Policy Example Violation 6.6.c.2. Additionally, the inspectors compared this evaluation to the risk associated with the issue by using IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, issued September 23, 2014. The inspectors screened the issue and evaluated it using Table 5.10-1, Significance Examples 50.47(b)(10), and Section 5.0.2.h, which describes the consideration of compensatory measures when screening for significance. The inspectors concluded that because Exelon provided the wind speed and direction on the notification form to the OROs, and because the counties take action to evacuate Lake Ontario at an Alert level, the planning standard function was not lost and would still be accomplished, albeit in a degraded manner. Based on these reviews, were it to be evaluated under the reactor oversight process, the issue would screen as low-to-moderate safety significance (White). This issue was entered into Exelons CAP as AR 1701509. Because the inspectors determined no performance deficiency existed, the NRC has decided to exercise enforcement discretion in accordance with Section 3.5 of the NRC Enforcement Policy and refrain from issuing enforcement action for the violation (EA-15-025). Further, because Exelons action and/or inaction did not contribute to this violation, it will not be considered in the assessment process, or the NRCs action matrix. This URI is closed.

04
Site:	Ginna
Report	IR 05000244/2015002 Section 1EP5
Date counted	Jun 30, 2015 (2015Q2)
Type:	Violation: Severity level Enforcement Discretion
cornerstone	Emergency Prep
Identified by:	NRC identified
Inspection Procedure:	IP 71114.05
Inspectors (proximate)	A Siwy D Dodson D Render D Schroeder E Burket N Perry S Horvitz
Violation of:	10 CFR 50.47 10 CFR 50.47(b)(10)
INPO aspect
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v • d • e

Finding - Ginna - IR 05000244/2015002

1(3)2(4)3(0)4(0)5(0)6(0)7(0)8(3)403(0)502(0)

IR 05000244/2015002: 1 2 3 4

Finding List (Ginna) @ 2015Q2

CCA Matrix: 2015Q2

	Q	CCA	Title
05000244/FIN-2014405-01	2014Q3	H.4	Security
05000244/FIN-2014007-01	2014Q3		Inadequate Test Control for MSIV Solenoid Operated Valves
05000244/FIN-2014004-01	2014Q3	P.1	Inadequate Work Packages Associated with Maintenance on the Main Generator Exciter Air Cooler Reversing Head
05000244/FIN-2014004-02	2014Q3		Adequacy of Exelons Protective Action Recommendation Strategy
05000244/FIN-2014005-01	2014Q4		Incomplete and Inaccurate Medical Information Provided by Exelon Which Resulted in Issuance of an Initial Senior Operator License without a Required Medical Restriction
05000244/FIN-2014005-02	2014Q4		Failure to Report a Permanent Change in a Licensed Operator's Medical Status and Request a Condition be Placed on the Operator's License
05000244/FIN-2014005-05	2014Q4		A' Emergency Diesel Generator Output Breaker Fails to Close during Routine Surveillance Testing Resulting in a Condition Prohibited by Technical Specifications and a Potential Inability to Fulfill a Safety Function
05000244/FIN-2015001-01	2015Q1		Inadequate Corrective Actions Result in Failure of Bus 18 Undervoltage Solid State Switchboard Card
05000244/FIN-2015001-02	2015Q1	H.3	Inadequate Protective Action Recommendation Flowchart
05000244/FIN-2015002-01	2015Q2	H.1	Failure to Perform 1-Hour Fire Tours as Required By the Technical Requirements Manual
05000244/FIN-2015002-02	2015Q2	H.12	Inadequate Procedure Implementation Results in Inadvertent Entry into 72 Hour Technical Specification Action Statement
05000244/FIN-2015002-03	2015Q2	P.1	Inadequate Preferred Auxiliary Feedwater Protection from Potential Block Wall Failures
05000244/FIN-2015002-04	2015Q2		Adequacy of Exelon's Protective Action Recommendation Strategy

Self-Identified List (Ginna)

	Q	Title
05000244/FIN-2014405-02	2014Q3	Licensee-Identified Violation
05000244/FIN-2014005-03	2014Q4	Licensee-Identified Violation
05000244/FIN-2014005-04	2014Q4	Licensee-Identified Violation
05000244/FIN-2015001-03	2015Q1	Licensee-Identified Violation

[Ginna Findings full list]

05000244/FIN-2015002-04

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