05000400/FIN-2017003-01
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Finding | |
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| Title | Incomplete and Inaccurate Emergency Action Level Submittals |
| Description | The NRC identified a Severity Level (SL ) IV non- cited violation (NCV) of 10 CFR 50.9, Completeness and accuracy of information, for failure to provide complete and accurate information for prior approval of a new emergency action level (EAL) scheme. The documents submitted to the NRC were, Shearon Harris Nuclear Power Plant, Unit 1 Changes to the Emergency Action Level Scheme, dated April 25, 2010, and License Amendment Request to Adopt Emergency Action Level Scheme Pursuant to NEI 99- 01, Revision 6, dated April 30, 2015. The submit ted documents specified the licensee s EAL scheme for Category F Fission Product Barrier EAL, which contained declaration EAL threshold values for the containment high range radiation monitor that were lower than the correct values due to use of a n improper calculation methodology. The calculation methodology that was used was not in accordance with the license. It was used to calculate the loss of fuel clad barrier and potential loss of containment threshold values. The licensee implemented compensatory corrective actions by issuing Standing Instruction 2017 -017 to inform operators and emergency response organization decision- makers of the proper application of the EAL scheme and appropriate threshold values to be implemented. Additionally, the licensee plans to submit a license amendment request to update the EAL scheme. The licensee entered this violation into their corrective action program (CAP) as nuclear condition report (NCR) 02155272. The inspectors evaluated the underlying technical issue and determined that the licensees failure to maintain the effectiveness of its emergency plan was a performance deficiency. The issue was documented as a Green licensee- identified violation (LIV) in Section 4OA7 of this report. The reactor oversight process (ROP) , significance determination process , does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it was necessary to address this violation which impeded the NRCs ability to regulate, using traditional enforcement to adequately deter non- compliance. Using the NRC Enforcement Policy, Section 2.3.11, Inaccurate and Incomplete Information, and Section 6.9, Inaccurate and Incomplete Information or Failure to Make a Required Report, this issue was determined to be a SL IV violation. Though the NRC would have questioned the issue with a request for additional information, it would not have resulted in substantial further inquiry. 3 Additionally, the associated technical violation was determined to be of very low safety significance. Traditional enforcement violations are not assessed for cross -cutting aspects |
| Site: | Harris  |
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| Report | IR 05000400/2017003 Section 4OA2 |
| Date counted | Sep 30, 2017 (2017Q3) |
| Type: | TEV: Severity level IV |
| cornerstone | Emergency Prep |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71152 |
| Inspectors (proximate) | J Zeiler A Patz M Donithan S Shah R Kellner J Panfel W Pursley J Rivera S Sanchez J Hickman S Rose |
| Violation of: | 10 CFR 50.9 |
| INPO aspect | |
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Finding - Harris - IR 05000400/2017003 | |||||||||||||||||||||||||||||||||
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Finding List (Harris) @ 2017Q3
Self-Identified List (Harris)
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