05000293/FIN-2015007-06
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Finding | |
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| Title | Failure to Implement Compensatory Measures for Out-of-Service EAL Instrumentation |
| Description | The inspectors identified a Green NCV of 10 CFR 50.54(q)(2) for failing to follow and maintain an emergency plan that meets the requirements of planning standards 10 CFR 50.47(b) and Appendix E. Specifically, on January 27, 2015, following a loss of instrument air, the indications in the Control Room for Sea Water Bay level were lost, and Entergy did not implement compensatory measures, as directed by an Emergency Plan Implementing Procedure, to determine whether a Sea Water Bay level emergency action level (EAL) threshold had been exceeded. Entergy entered this issue into the CAP as CR-PNP-2015- 00948 and initiated corrective actions to identify alternative means for assessing this EAL in the event of a loss of Sea Water Bay level instruments. The inspectors determined that Entergys failure to implement compensatory measures for out-of-service EAL instrumentation was a performance deficiency that was within Entergys ability to foresee and correct and should have been prevented. Specifically, Entergy did not implement the compensatory measure listed in Attachment 9.2 of EP-IP-100.1, Emergency Action Levels, Revision 10. The inspectors determined that following a loss of instrument air, the indications for Sea Water Bay level EAL were lost, rendering those EALs ineffective such that Entergy was not able to determine whether a Sea Water Bay level EAL threshold had been exceeded and to declare an emergency based on the Sea Water Bay level. This NRC-identified performance deficiency was more than minor because it was associated with the emergency response organization performance (program elements not meeting 50.47(b) planning standards) attribute of the Emergency Preparedness cornerstone and affected the cornerstone objective of ensuring 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, the out-of-service Sea Water Bay level instrumentation could have led to an emergency not being declared in a timely manner. The inspectors evaluated the finding using IMC 0609, Attachment 4, Initial Characterization of Findings, issued June 19, 2012. The attachment instructs the inspectors to utilize IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, issued September 23, 2014, when the finding is in the licensees Emergency Preparedness cornerstone. The inspectors determined the finding was associated with risk significant planning standard 10 CFR 50.47(b)(4), Emergency Classification System, and corresponded to the following Green Finding example in Table 5.4-1: an EAL has been rendered ineffective such that any Alert or Unusual Event would not be declared, or declared in a degraded manner for a particular off-normal event. Therefore, using Figure 5.4-1, Significance Determination for Ineffective EALs and Overclassification, and the example in Table 5.4-1, the inspectors determined the finding was of very low safety significance (Green). The finding had a cross-cutting aspect in the area of Human Performance, Documentation, because Entergy did not maintain complete and accurate documentation. Specifically, compensatory measures associated with out-of-service EAL instrumentation are not governed by comprehensive and high-quality programs, processes, and procedures. |
| Site: | Pilgrim |
|---|---|
| Report | IR 05000293/2015007 Section 4OA5 |
| Date counted | Mar 31, 2015 (2015Q1) |
| Type: | NCV: Green |
| cornerstone | Emergency Prep |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 93812 |
| Inspectors (proximate) | C Cahill D Schroeder E Burket E Dipaolo H Nieh J Lilliendahl S Pindale T Dunn |
| Violation of: | 10 CFR 50.47 10 CFR 50.47(b)(4) 10 CFR 50.54 10 CFR 50.54(q) |
| CCA | H.7, Documentation |
| INPO aspect | WP.3 |
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Finding - Pilgrim - IR 05000293/2015007 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Pilgrim) @ 2015Q1
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