05000244/FIN-2015001-02
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Finding | |
|---|---|
| Title | Inadequate Protective Action Recommendation Flowchart |
| Description | A self-revealing Green NCV of 10 CFR 50.54(q)(2), 10 CFR 50.47(b)(10), and 10 CFR 50, Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, Section IV.B.1, was identified for Exelon inadequately maintaining the effectiveness of its Emergency Plan. Specifically, 10 CFR 50.54(q)(2) requires reactor licensees to follow and maintain the effectiveness of an emergency plan that meets the requirements in 10 CFR 50, Appendix E and the planning standards of 50.47(b), and Exelon did not adequately maintain the effectiveness of its Emergency Plan when Exelon implemented changes to the protective action recommendation (PAR) flowchart that would have resulted in Exelon inappropriately recommending evacuation of downwind areas and many more emergency response planning areas (ERPAs) than intended. The inspectors determined that Exelon did not adequately maintain the effectiveness of its Emergency Plan in accordance with 10 CFR 50.54(q)(2), 10 CFR 50.47(b), and 10 CFR 50, Appendix E, when Exelon implemented changes to the PAR flowchart. Specifically, Exelon implemented Figure 5.3, Scheme for Protective Action Recommendations, of the Nuclear Emergency Response Plan (NERP), and Attachment 3, Ginna PAR Determination Instructions, of CNG-EP-1.01-1013, Emergency Classification and PAR, Revision 00100, and the flowchart for Initial Protective Action Recommendation ONLY, with an unintentional error. Incorrectly revising and incorporating an inaccurate value in the implementing procedures for the NERP is considered a performance deficiency that was within Exelons ability to foresee and prevent. The inspectors determined that the inadequate maintenance of the Emergency Plan was more than minor because it was associated with the procedure quality attribute of the Emergency Preparedness cornerstone and affected the cornerstone objective to ensure 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, Exelons PAR implementation procedure was revised and contained containment radiation level set points that would potentially result in an inappropriate recommendation to evacuate downwind areas and many more ERPAs than intended when fewer or no evacuations should have been recommended. The inspectors evaluated the finding using IMC 0609.04, Initial Characterization of Findings. The attachment instructs the inspectors to utilize IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, when the finding impacts the licensees Emergency Preparedness cornerstone. The performance deficiency is associated with the emergency protective actions planning standard and is considered a risk-significant planning standard function. The inspectors were directed by the SDP to compare the performance deficiency with the examples in Section 5.10, 10 CFR 50.47(b)(10), Emergency Protective Actions, to evaluate the significance of this performance deficiency. However, the examples in Table 5.10-1, Significance Examples 50.47(b)(10), address failure to make a PAR, but the examples do not specifically address unnecessary evacuations of ERPAs. Therefore, in accordance with the guidance in Section 5.0.3 of IMC 0609, Appendix B, the issue was evaluated using the Attachment 2 flowchart and informed by the examples provided in other sections of the Emergency Preparedness SDP as described below. In the subject scenario, the licensee will have already accurately made a General Emergency declaration prior to determining an initial PAR. At the General Emergency level, there is at least a loss of two fission product barriers and a potential or full loss of a third, and a release is either in progress or imminent at levels that are likely to exceed Environmental Protection Agency protective action guidelines (PAGs) at and beyond the site boundary. As such, there is potentially a dose avoidance benefit for the public even when a PAG has not been reached due to a General Emergency condition actually existing. Therefore, an inadequate PAR resulting in evacuations of ERPAs when no evacuations are otherwise called for is less significant than an emergency action level overclassification resulting in an unnecessary PAR, because there is a potential dose avoidance benefit to the public at the General Emergency level. In this instance, a PAR is made, which is sufficient to ensure public health and safety, although some additional risk will be incurred. The (b)(10) risk-significant planning standard functions are still met, although Exelon did fail to comply with the planning standard. Therefore, the inspectors determined the finding was of very low safety significance (Green). Exelon corrective actions included issuing NERP, Revision 04000, and CNG-EP-1.01-1013, Revision 00200, which corrected the PAR flowchart text ensuring all emergency directors were adequately trained and aware of the NERP and CNG-EP-1.01-1013 revisions. The finding has a cross-cutting aspect in the area of Human Performance, Change Management, because Exelon did not use a systematic process for evaluating and implementing change so that nuclear safety remained the overriding priority. Specifically, changes to the NERP were made, and the inadequate change and the importance of the changes were not recognized by Exelon corporate, the department review, or the plant operations review committee review. Managers did not ensure individuals understood the importance of, and their role in, the change management process, and managers did not maintain a clear focus on nuclear safety when implementing the change management process to ensure that significant unintended consequences were avoided [H.3]. |
| Site: | Ginna  |
|---|---|
| Report | IR 05000244/2015001 Section 1EP4 |
| Date counted | Mar 31, 2015 (2015Q1) |
| Type: | NCV: Green |
| cornerstone | Emergency Prep |
| Identified by: | Self-revealing |
| Inspection Procedure: | IP 71114.04 |
| Inspectors (proximate) | D Dodson D Schroeder E Burket H. Anagnostopoulus N Perry S Horvitz T Fish |
| Violation of: | 10 CFR 50.47(b)(10) 10 CFR 50 Appendix E 10 CFR 50.47 10 CFR 50.54(q) 10 CFR 50.54 |
| CCA | H.3, Change Management |
| INPO aspect | LA.5 |
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Finding - Ginna - IR 05000244/2015001 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Ginna) @ 2015Q1
Self-Identified List (Ginna)
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