05000341/FIN-2017009-01

Finding

Title

Failure to Maintain the Effectiveness of the Sites Emergency Plan

Description

Preliminary White. An NRC identified finding preliminarily determined to be of low to moderate safety significance (White), and an associated apparent violation of Title 10 of the Code of Federal Regulations (10 CFR) 50.54(q)(2) and 10 CFR 50.47(b)(9) was identified for the licensees failure to maintain the effectiveness of its emergency plan and use adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency. Specifically, the licensee failed to maintain the ability to accurately declare an Emergency Action Level (EAL) classification, RG-1.1, and develop and issue accurate protective action recommendations (PARs) during the implementation of the sites Emergency Plan in response to a rapidly progressing accident. The licensee inaccurately analyzed the effect of increasing background radiation on the sites Standby Gas Treatment System accident range radiation monitor (AXM) indications based on the installed configuration of the AXM. As configured, the AXM could provide inaccurate indications of radioactive releases that are used as the licensees basis for determining EAL classification and development of PARs. The licensee documented the issue in the corrective action program as CR-16-29230, and actions were completed to restore the accuracy of the indications provided by the AXM. The inspectors determined that the licensees failure to maintain the effectiveness of its emergency plan and use adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency was a performance deficiency; the cause was reasonably within the licensees ability to foresee and correct; and should have been prevented. The inspectors determined the issue was more than minor because it adversely affected the emergency preparedness 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, the finding would result in the potential over classification of an emergency event and the potential issuance of unnecessary or early PARs. 3 The inspectors applied Inspection Manual Chapter (IMC) 0609, Appendix B, Section 5.9. to screen this finding, and determined the licensee failed to maintain the risk significant planning standard (RSPS) identified in 10 CFR 50.47(b)(9) by ensuring adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use. Using Table 5.9-1, the inspectors determined the sites dose assessment process was incapable of providing technically adequate estimates of radioactive material releases to the environment or projected offsite doses in some cases (specifically a rapidly progressing accident scenario). This significance example corresponds to a Degraded RSPS Function, which is a finding of low to moderate safety significance (White). The inspectors determined no cross-cutting aspects were associated with the performance deficiency.

01
Site:	Fermi
Report	IR 05000341/2017009 Section 2RS6
Date counted	Mar 31, 2017 (2017Q1)
Type:	Violation: White
cornerstone	Emergency Prep
Identified by:	NRC identified
Inspection Procedure:	IP 71124.06
Inspectors (proximate)	K Polsong Hansens Orth V Myers
Violation of:	10 CFR 50.47(b)(9) 10 CFR 50.54(q)
INPO aspect	CL.1
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Finding - Fermi - IR 05000341/2017009

13(0)11(0)1(3)2(3)3(2)4(3)5(0)6(0)7(1)8(0)9(1)10(4)11(0)12(0)301(0)403(0)404(1)405(1)407(1)502(0)

IR 05000341/2017009: 1

Finding List (Fermi) @ 2017Q1

CCA Matrix: 2017Q1

	Q	CCA	Title
05000341/FIN-2016003-03	2016Q3	H.8	Failure to Follow Procedures During Concrete Placement of Flexible Storage Facility Buildings
05000341/FIN-2016003-02	2016Q3		Fluctuating Background Effect on Accident Range Noble Gas Monitor
05000341/FIN-2016003-01	2016Q3	P.2	Failure to Perform an Operability Determination for Division 1 RPV Reference Leg Backfill System Not Providing Adequate Flow
05000341/FIN-2016007-13	2016Q3	P.2	Failure to Identify a CAQ Associated with Over-Dutied 480V Safety-Related Switchgear Breakers
05000341/FIN-2016007-07	2016Q3	P.6	Failure to Ensure that Protective Devices for the Loads Required at the Beginning of a LOCA Would Not Trip Under Degraded Voltage Conditions
05000341/FIN-2016007-02	2016Q3	P.6	Failure to Verify the Adequacy of the Voltage Supplied to Transformer #64 Load Tap Changer
05000341/FIN-2016007-01	2016Q3		Inadequate Procedure for Addressing Non-Functional MDCT Fan Motor Brake System
05000341/FIN-2016007-16	2016Q3	H.13	Failure to Timely Identify, Document, and Evaluate Conditions that Challenge Operability
05000341/FIN-2016007-15	2016Q3	H.14	Failure to Identify that a Non-Conservative Min-K Insulation Volume Calculation Error Was Nonconforming to the ECCS Suction Strainer Licensing Basis
05000341/FIN-2016007-14	2016Q3		Failure to Identify that an Inadequate Minimum MSIV Accumulator Air Pressure Setpoint Was CAQ
05000341/FIN-2016007-08	2016Q3		Inadequate Containment Debris Inspections Acceptance Criteria
05000341/FIN-2016007-03	2016Q3	H.4	Failure to Verify the Ability to Manually Throttle Safety-Related MOVs during a DBA
05000341/FIN-2016007-04	2016Q3		Failure to Periodically Test the EDG Capability to Start and Accelerate All of the Sequenced Loads Within the Applicable Limits
05000341/FIN-2016007-05	2016Q3		Failure to Leak Test All Division 2 NIAS Boundary Isolation Valves
05000341/FIN-2016007-06	2016Q3		Failure to Ensure that the MSIVs Would Close Within the TS Required Timeframe and as Described in the UFSAR
05000341/FIN-2016007-12	2016Q3	H.4	Failure to Identify an Out-of-Specification Pressure Reading on the Nitrogen Supply to the A MDCT Fan Motor Brake System
05000341/FIN-2016007-09	2016Q3		Failure to Evaluate the Acceptability of Drywell Coatings with Respect to Potential ECCS Suction Strainer Blockage
05000341/FIN-2016007-10	2016Q3		Non Conservative ECCS Suction Strainer Min-K Combined Generation and Transport Factors
05000341/FIN-2016007-11	2016Q3	H.6	Failure to Apply Design Control Measures to a Design Change Associated with NIAS Accumulator Capability
05000341/FIN-2016004-04	2016Q4		Inadequate Testing of SGTS Filters
05000341/FIN-2016004-05	2016Q4	H.12	Failure to Lock an Area Meeting Locked High Radiation Area Conditions
05000341/FIN-2016004-02	2016Q4	H.9	Failure to Correctly Interpret and Implement TS Requirements for LOP Instrumentation and AC Electrical Power Functions
05000341/FIN-2016004-01	2016Q4		Inadequate Work Instructions for Maintenance on Flexible Couplings for EDGs
05000341/FIN-2016004-03	2016Q4		Failure to Satisfy 10 CFR 50.73 Reporting Requirements for Loss of LOP Instrumentation and AC Electrical Power Safety Functions
05000341/FIN-2017009-01	2017Q1		Failure to Maintain the Effectiveness of the Sites Emergency Plan
05000341/FIN-2017001-01	2017Q1	H.7	Inadequate Work Instructions for Maintenance on EDG 14
05000341/FIN-2017001-02	2017Q1	H.1	Failure to Maintain Adequate SLC Storage Tank Boron Concentration

Self-Identified List (Fermi)

	Q	Title
05000341/FIN-2016004-06	2016Q4	Licensee-Identified Violation
05000341/FIN-2017001-03	2017Q1	Licensee-Identified Violation

[Fermi Findings full list]

05000341/FIN-2017009-01

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