05000305/FIN-2010502-02
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Finding | |
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| Title | Changes Made to EAL Technical Bases that Decreased the Effectiveness |
| Description | The inspector determined that changes made by the licensee to the EAL Technical Basis document decreased the effectiveness of the Emergency Plan and the change was implemented without prior NRC approval. The issue was determined to be a licensee performance deficiency that impacted the regulatory process and, in accordance with MC 0612 Power Reactor Inspection Reports, was evaluated using the NRCs traditional enforcement policy as well as the Reactor Oversight Process (ROP). Using the NRCs Enforcement Policy, this performance deficiency was considered for escalated enforcement. However, the NRC has classified this violation as a Severity Level IV, after determining that its actual and potential safety significance was very low based on the following considerations: (1) the issue was relatively isolated, in that the decrease in effectiveness resulted from a single mistake; (2) the impact of the issue was confined to two unusual event classifications, not any of the other higher event classifications; and (3) the revision was provided to the NRC for review after implementation, which reduced the impact to the regulatory process. Using MC 0612 Power Reactor Inspection Reports, Appendix B Issue Screening, the performance deficiency was determined to be more than minor and, therefore, a finding, because it is associated with the emergency preparedness cornerstone attribute of procedure quality for EAL and emergency plan changes, and it adversely affected the cornerstone objective of ensuring 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, the licensee made a change to its EAL Technical Basis Document, which was a DIE, because the change eliminated a pathway to get to an Unusual Event by excluding the Charging and Letdown System leakage from consideration as RCS leakage. And, this change was made without prior NRC approval
The inspector determined the finding could be evaluated using the SDP in accordance with IMC 0609, Significance Determination Process, Appendix B, Emergency Preparedness Significance Determination Process. The finding is a failure to comply with 10 CFR 50.54(q) involving the risk significant planning standard 50.47(b)(4), which, in this case, is not considered degraded. This EAL Classification finding is GREEN because it involves two Unusual Event classifications (EAL CU1 and SU5). This finding has a cross-cutting aspect in the area of human performance, decision-making, because the licensee failed to use conservative assumptions when making decisions and did not demonstrate that nuclear safety was an overriding priority. Specifically, the licensee changed its EAL Technical Basis to remove consideration of leakage from the Charging and Letdown system as RCS leakage and eliminated a pathway to declare an Unusual Event for two EALs (CU1 and SU5). This change was screened through the licensees 50.54(q) process and was not identified as a DIE. However, after evaluation by the inspector, this change was determined to be a DIE of the emergency plan and it was not approved by the NRC before the change was implemented. |
| Site: | Kewaunee  |
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| Report | IR 05000305/2010502 Section 1EP4 |
| Date counted | Sep 30, 2010 (2010Q3) |
| Type: | Finding: Green |
| cornerstone | Emergency Prep |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71114.04 |
| Inspectors (proximate) | M Garza H Peterson |
| CCA | H.14, Conservative Bias |
| INPO aspect | DM.2 |
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Finding - Kewaunee - IR 05000305/2010502 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Kewaunee) @ 2010Q3
Self-Identified List (Kewaunee)
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