05000263/FIN-2014005-02
Finding | |
|---|---|
| Title | Incorrect Emergency Action Level Threshold |
| Description | An Unresolved Item (URI) was identified because additional information is needed to determine whether a performance deficiency exists and if a violation of 10 CFR 50.54(q)(2) occurred. The inspectors identified an issue of concern associated with the licensees changing of the High River Level EAL threshold from 921 to 920 for the alert classification EAL HA1.6. Description. During the first quarter of 2014, the licensee made a change to EAL HA1.6
for High River Level. Specifically, the licensee changed the threshold for the Alert classification from 921 to 920. On November 4, 2014, the NRC questioned the reason for the EAL threshold change, noting that the change may be in conflict with the EAL basis for HA1.6. These questions prompted licensee discovery that the EAL threshold basis was associated with flooding impacts on plant equipment, rather than river level historical data, as the licensee originally believed. The inspectors observed that the basis for EAL HA1.6 was linked to the river level where flood waters would reach the top of the retention basin. The inspectors also noted that although the licensee had changed the EAL threshold, the actual level of the basin was not altered. The licensee then questioned if the known level of the retention basin was a legacy error and what the correct level was for this EAL threshold. To address these questions, the licensee requested input from engineering and documented these issues in Action Request (AR) 01454593 on that same date. As an interim action, AR 01454593 documented that the current river level was 906, and if flooding were to occur, the licensee would rely on Procedure A.6, Acts of Nature, and an event response team would be formed in accordance with the procedure to monitor river level during the duration of a flood event. The licensee noted that at a river level of 918, a Notification of Unusual Event would be declared. In addition, the licensee concluded that the shift manager, event response team, and plant management would monitor for indication of degraded performance of equipment or structures necessary for safe shutdown for event classification escalation to the Alert level. The inspectors evaluated these interim compensatory measures and found them adequate as no additional reasonable risk existed as a result of this issue. On December 3, 2014, NRC questions regarding the progress of the previous AR led to the licensees statement that the 920 level also may not be correct. Because the licensee had not yet determined the appropriate High River Level EAL threshold for the alert classification EAL HA1.6, the inspectors could not readily determine whether the error was a legacy issue with the old threshold value, a current performance issue with the new threshold value and EAL change process, or both. The interim compensatory measures identified in the previous AR remained in effect at the conclusion of this inspection and the December 3, 2014 discussions and URI determination resulted in the generation of AR 01458209 by the licensee on that same date Therefore, a URI was identified because additional information on the correct High River Level EAL threshold is needed for the inspectors to determine whether a performance deficiency existed and if a violation of 10 CFR 50.54(q)(2) occurred. (URI 05000263/201400501; Incorrect Emergency Action Level Threshold) |
| Site: | Monticello  |
|---|---|
| Report | IR 05000263/2014005 Section 1EP4 |
| Date counted | Dec 31, 2014 (2014Q4) |
| Type: | URI: |
| cornerstone | Barrier Integrity |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71114.04 |
| Inspectors (proximate) | I Hafeez J Beavers J Neurauter K Riemer M Davis M Learn M Mitchell M Ziolkowski P Voss P Zurawski S Bell T Bilikd Mcneil J Beavers K Riemer M Phalen P Voss P Zurawski S Bel |
| INPO aspect | |
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Finding - Monticello - IR 05000263/2014005 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Monticello) @ 2014Q4
Self-Identified List (Monticello)
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