05000331/FIN-2009004-02
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Finding | |
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Title | Failure to Maintain EAL Scheme for River Low Level |
Description | A finding of very low safety significance and associated NCV of the emergency planning standard 10 CFR 50.47(b)(4) was identified by the inspectors. The finding involved an inadequate threshold for river water level indentified in the emergency classification scheme. The classification scheme did not provide the threshold values related to specific instruments, parameters, and status indicators for river water low level and low water depth and did not address the effect of sand and silt accumulation on the River Water Supply (RWS) and Ultimate Heat Sink (UHS) systems. The thresholds for the Notification of Unusual Event and Alert were unusable for the condition of low river water level when the river bed elevation becomes greater than the low river water level threshold. The licensee entered the finding into their CAP (CAP 068505 and CE 007573). The inspectors determined the licensees failure to adjust the Emergency Action Level (EAL) threshold criteria for river water low level at the Unusual Event and Alert classification was a performance deficiency. Because the licensee did not recognize the challenge to the RWS and the UHS due to increasing river bed level in the EALs, the EAL thresholds were not adjusted to accommodate for sand accumulation and the river bed rising. The performance deficiency was more than minor since the Emergency Preparedness Cornerstone objective to ensure the licensee is capable of implementing adequate measures to protect the health and safety of the public in a radiological emergency was adversely affected, and the finding involved a risk-significant planning standard. The finding impacted the attribute of procedure quality (emergency planning standard, emergency classification, and action level scheme). The finding was assessed using the emergency preparedness SDP and was determined to be of very low safety significance (Green). The finding was similar to the example given of the emergency classification process would not declare any Alert or Notification of Unusual Event that should be declared, as in the case when the river bed elevation exceeds the river water low level threshold values. The inspectors also determined that this finding has a cross-cutting aspect in the area of Human Performance, Decision-Making, because the licensee did not use conservative assumptions and validate the underlying assumption in the decision to not change the EAL scheme and assumed the technical specifications for the RWS and the UHS systems would address the EAL requirement. H.1(b) |
Site: | Duane Arnold |
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Report | IR 05000331/2009004 Section 1EP5 |
Date counted | Sep 30, 2009 (2009Q3) |
Type: | NCV: Green |
cornerstone | Emergency Prep |
Identified by: | NRC identified |
Inspection Procedure: | IP 71114.05 |
Inspectors (proximate) | K Riemer R Orlikowski R Baker L Haeg T Go R Russell B Cushman C Scott M Audrain |
CCA | H.14, Conservative Bias |
INPO aspect | DM.2 |
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Finding - Duane Arnold - IR 05000331/2009004 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Duane Arnold) @ 2009Q3
Self-Identified List (Duane Arnold)
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