05000277/FIN-2013004-01
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Finding | |
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| Description | The inspectors identified a Green non-cited violation (NCV) of Title 10 of the Code of Federal Regulation (CFR) 50.54(q)(2) associated with 50.47(b)(4) because PBAPS failed to control emergency planning (EP) procedure changes in a manner that would ensure timely emergency action level (EAL) classification for effluent parameters. On June 27, 2013, PBAPS issued Revision 27 to EP-AA-1007, Exelon Nuclear Radiological Emergency Plan Annex for PBAPS. One of the plan changes involved removal of the \'A\' ventilation and main stack radiation monitors from radiological effluent EAL matrix Table 3-1, and thereby rendered the B ventilation and main stack radiation monitors as the only means of EAL classification for effluent releases. On July 24, 2013, the inspectors questioned shift operations on whether the ability to make timely and accurate EAL classifications was impacted with the B reactor building (RB) ventilation stack radiation monitor inoperable. Shift operations did not have an immediate response, but later in the same shift provided a response to the inspectors that compensatory measures were required for degraded EP equipment, and the \'A\' ventilation stack radiation monitor was established as a compensatory measure for the inoperable \'B\' monitor in response to questions by the inspectors. Following the inspectors questions, PBAPS initiated issue report (IR) 1539674 to capture programmatic deficiencies that were revealed as a result of the inspectors questions. PBAPS corrective actions included a revision to the PBAPS Emergency Plan, a revision to the EP compensatory measure procedure, issuance of Operations Information Update (OIU) 13-10 to the shift managers (SMs) to clarify the purpose of the compensatory measure procedure, and an assignment to incorporate the latest revision of the compensatory measure procedure into licensed operator training program curriculum review committee (CRC). This finding was more than minor because it was associated with the procedure quality attribute of the Emergency Preparedness cornerstone, and adversely affected the associated cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the public health and safety in the event of a radiological emergency. Using IMC 0609, Attachment 4, Phase 1 Initial Screening and Characterization of Findings, and IMC 0609, Appendix B, Emergency Preparedness SDP, the inspectors determined that this finding was of very low safety significance (Green) using Table 5.4.1. Specifically, this finding rendered an EAL ineffective such that an unusual event (UE) declaration could be delayed. The inspectors determined that this finding had a cross-cutting aspect in the area of Human Performance, Work Control, because PBAPS did not appropriately coordinate work activities by incorporating actions to address the impact of work on different job activities, and the need for work groups to communicate, coordinate, and cooperate with each other during activities in which interdepartmental coordination is necessary to assure plant and human performance H.3(b). Specifically, the impact of a PBAPS Emergency Plan Annex revision was not communicated properly or coordinated between the EP department and operations department, to assure that shift operations could implement compensatory measures as necessary for degraded EP equipment. |
| Site: | Peach Bottom  |
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| Report | IR 05000277/2013004 Section 1R22 |
| Date counted | Sep 30, 2013 (2013Q3) |
| Type: | NCV: Green |
| cornerstone | Emergency Prep |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.22 |
| Inspectors (proximate) | J Furia S Hansell J Laughlin F Bower A Ziedonis R Rolph H Gray E Burket J Tomlison |
| Violation of: | 10 CFR 50.54 10 CFR 50.54(q) |
| CCA | H.5, Work Management |
| INPO aspect | WP.1 |
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Finding - Peach Bottom - IR 05000277/2013004 | ||||||||||||||||||||||||||||||||||||
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Finding List (Peach Bottom) @ 2013Q3
Self-Identified List (Peach Bottom)
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