2015 Emergency Preparedness Findings
Plant
2015 Emergency Preparedness Findings
Green
White
Green
Green
Green
Type
Green
Green
Green
Green
Short Title
Failure to submit Plan Changes as required by
Appendix E
Inadequate On-Shift Staffing Analysis
Failure to Maintain the Emergency Plan (Incorrect
EAL Values)
Failure to maintain unit 1 condenser vacuum exhaust mid/high range radiation monitors as required by the emergency plan and NRC-approved Emergency
Action Level scheme .
Failure to Correctly Classify an Unusual Event in a
Drill led to determination of a Faulty EAL
Failure to provide a full range of Protective Action
Recommendations (Over water issue)
Failure to Adequately Perform Annual ETE
Evaluation
Failure to Critique a Drill Performance Issue
Failure to Critique a Drill Performance Issue
Date
10/24/14
1/26/15
1/26/15
2/9/15
2/10/15
2/11/15
2/12/15
2/12/15
2/13/15
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2015 Emergency Preparedness Findings
Plant Type Short Title Date
River Bend
Report Date: 10/24/14
Region: IV Severity Level: SL IV
Color: Green
Finding Summary:
At River Bend, Entergy self-identified a Severity Level (SL) IV violation of 10 CFR 50, Appendix E,
Section V, and 10 CFR 50.54(q)(5). These regulations require licensees to submit any changes to the emergency plan or procedures, and a report of changes that includes a summary of its analysis to the
Commission within 30 days of such changes. Entergy revised fleet procedures for emergency plan training and drills and exercises. However, they did not submit the changes to the emergency plan implementing procedures or a summary of the analysis of the changes within 30 days after the changes were put into effect. There was no process in place to ensure fleet procedures necessary to implement the site emergency plan were submitted to the NRC in accordance with the requirements. (IR
05000458/2014004)
Hatch
Report Date: 1/26/15
Region: II Severity Level: NCV
Color: Green
Finding Summary:
On December 24, 2012, the licensee’s detailed analysis of onshift staffing was deficient in that the specific scenario involving a fire in the Main Control Room with dual unit remote shutdown panel operations was evaluated assuming a typical complement of 17 operations personnel vice the 14 specified in the licensee’s Emergency Plan and fire response plan. The licensee subsequently performed a detailed time-motion study and determined that all required functions could have been performed, but individual workload capacity would have been challenged. The NRC determined that with no identified loss or degradation of a planning standard function, the failure to complete the detailed analysis in accordance with 10 CFR Part 50, Appendix E, Section IV.A.9, was a very low safety significance issue (Green) as indicated in Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance
Determination Process, Revision dated September 26, 2014. This violation was documented in CAR
11209. Immediate corrective actions included interim augmentation for on-shift positions and the on-shift staffing analysis was re-performed. Final incorporation into the licensee’s emergency plan is in progress.
Hatch
Report Date: 1/26/15
Region: II Severity Level: NCV
Color: Green
Finding Summary:
From May 2011 to November 2013, the licensee failed to maintain the effectiveness of its emergency plan. The System Malfunction EAL for Fuel Clad Degradation (SU4) listed incorrect reactor coolant sample activity threshold values and the Fission Product Barrier EAL contained an incorrect drywell
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2015 Emergency Preparedness Findings radiation monitor threshold value for reactor coolant system leakage (FA1). These incorrect EAL values were associated with changes to the license technical specifications when incorporating an alternate source term. The licensee implemented immediate compensatory actions by issuing a standing order to include the correct threshold values and informed appropriate operators and decisionmakers. These corrected values were then incorporated into Revision 3 of procedure NMP-EP-110-GL02, HNP EALs –
ICs, Threshold Values and Basis. The issue was placed in their corrective action program as CR732879.
This violation was determined not to be greater than Green as these incorrect EAL threshold values only affected Unusual Event and Alert declarations using Inspection Manual Chapter 0609, Appendix B,
Emergency Preparedness Significance Determination Process, Revision dated September 26, 2014.
Watts Bar
Report Date: 2/9/15
Region: II
Color: Green
Severity Level: NCV
Finding Summary:
A self-revealing Green NCV of 10 CFR 50.54(q)(2) was identified for the failure to follow and maintain the effectiveness of the licensee’s emergency plan. Specifically, from April 2010 until the present, Unit 1
Condenser Vacuum Exhaust (CVE) Mid/High Range Monitors (1-RM-90-404 A&B RMs) were unavailable to perform their EP function to provide EAL inputs to classify emergency action levels,
RG1.1, General Emergency (GE), and RS1.1, Site Area Emergency (SAE). This condition could challenge plant operations when determining emergency classification for gaseous effluent release during a steam generator tube leak or rupture.
The inspectors determined that the failure to identify the extended loss of the Unit 1 Watts Bar Nuclear
Power Plant’s 1-RM-90-404 A&B CVE Radiation Monitors was not compliant with their approved emergency plan and was a failure to comply with 10 CFR 50.54(q)(2), was within the licensee’s ability to foresee and correct, and therefore constituted a performance deficiency. This finding was determined to be more than minor because it was associated with the Facilities and Equipment attribute of the Reactor
Safety – Emergency Preparedness Cornerstone. This finding adversely affected the cornerstone objective of ensuring that the licensee was capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency in that equipment relied upon to prompt decision-makers to declare emergencies was not available.
This finding was evaluated in accordance with Inspection Manual Chapter (IMC) 0609, Appendix B,
“Emergency Preparedness Significance Determination Process.” The issue was determined to be a Failure to Comply and was evaluated using Section 5.0 and Attachment 2, “Failure to Comply Significance
Logic,” With regards to EALs, RG1.1 and RS1.1, the inspectors considered mitigating factors, and determined that alternative EALs within the radiological effluent initiating condition, facility design as documented in their UFSAR, and the licensee’s declaration processes, were such that an accurate and timely declaration would have been made. Therefore, the inspectors determined that the Risk-Significant
Planning Standard (RSPS) function was neither lost nor degraded and determined to be of low safety significance (Green).
Vermont Yankee Region: I Severity Level: NCV
Report Date: 2/10/15 Color: Green
Finding Summary:
The inspectors identified a Green NCV of 10 CFR 50.54(q), “Emergency Plans,” because Entergy’s emergency action level (EAL) classification process could result in a misclassification, a deficiency related to a risk significant planning standard. Specifically, Entergy personnel failed to correctly classify emergency conditions during an emergency preparedness drill using the applicable EAL criteria. Entergy initiated CR-VTY-2014-3990 for not recognizing the proper application of Note 1 contained in EAL
AG1.1, and subsequently trained operating crews and emergency response organization (ERO) decision makers on the basis and intent of Note 1. Entergy reviewed the implementing procedures and associated
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2015 Emergency Preparedness Findings basis documents and determined that applicable procedures and guidance properly described and implemented the required hierarchy of EAL AG1.1 and EAL AG1.2.
This finding is more than minor because it is associated with the ERO attribute of the Emergency
Preparedness cornerstone and adversely affected the cornerstone objective of ensuring that Entergy is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, the failure to establish an adequate EAL classification process could result in a general emergency (GE) declaration when a GE is not warranted. The inspectors determined the significance of the finding using IMC 0609, Appendix B, "Emergency Preparedness Significance
Determination Process." The finding was determined to be of very low safety significance (Green).
Specifically, the inspectors considered the above extenuating circumstances and evaluated the finding in accordance with IMC 0609, Appendix B, Section 5.4, "10 CFR 50.47(b)(4), Emergency Classification
System," and concluded that the EAL issue could result in an early GE declaration, but the finding more closely fit the "would result in unnecessary classification" significance category rather than the "would result in unnecessary [protective action recommendations] PARS for the public" significance category.
The inspectors determined that the finding has a cross-cutting aspect in the area of Human Performance,
Training, because Entergy did not ensure the knowledge and training of the trainers and ERO personnel sufficiently conveyed realistic application of radiological based
EAL criteria which properly balanced the risks of radiological dose consequences with the risks associated with unnecessary protective action recommendations.
Diablo Canyon
Report Date: 2/11/15
Region: IV Severity Level: III
Color: White
Finding Summary:
During an NRC inspection conducted from November 21, 2013, through October 17, 2014, a violation of
NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:
10 CFR 50.54(q) [2005 version] requires, in part, that a nuclear power reactor licensee shall follow and maintain in effect emergency plans which meet the standards in 10 CFR 50.47(b) and that proposed changes that decrease the effectiveness of the approved emergency plans may not be implemented without application to and approval by the Commission. 10 CFR 50.47(b)(10) requires that a range of protective actions be developed for the plume exposure pathway emergency planning zone for emergency workers and the public. Contrary to the above, on November 4, 2005, the licensee implemented a change that decreased the effectiveness of the approved emergency plan without application to and approval by the Commission, which resulted in the licensee failing to follow and maintain in effect an emergency plan meeting the standards in 10 CFR 50.47(b). Specifically, without approval from the NRC, the licensee decreased its emergency plan’s effectiveness by removing instructions from its emergency plan implementing procedures for making protective action recommendations for affected areas over the ocean within the 10-mile emergency planning zone.
Fort Calhoun
Report Date: 2/12/15
Region: IV
Color: Green
Severity Level: NCV
Finding Summary:
The NRC identified a Green non-cited violation for the licensee’s failure to determine the availability of year 2013 state and local population data in estimating annual changes in the plume exposure emergency planning zone population. The failure to determine whether State and/or local population data was available for 2013 was a performance deficiency within the licensee’s ability to forsee and correct.
Appendix E to 10 CFR Part 50, Section IV.5, states, in part, that during the years between decennial censuses, nuclear power reactor licensees shall estimate emergency planning zone permanent resident population changes once a year using the most recent U.S. Census Bureau annual resident population estimate and State/local government population data, if available. Contrary to the above, Fort Calhoun
Station failed in 2013 to estimate emergency planning zone permanent resident population changes using
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2015 Emergency Preparedness Findings the most recent U.S. Census Bureau annual resident population estimate and State/local government population data, if available. Specifically, Fort Calhoun Station failed to determine whether State and local government population data was available prior to performing the analysis.
This finding is more than minor because the issue is associated with procedure quality and offsite
Emergency Preparedness cornerstone attributes and adversely affected the Emergency Preparedness cornerstone objective. The finding was evaluated using Manual Chapter 0609, Appendix B, “Emergency
Preparedness Significance Determination Process,” dated February 24, 2014, and was determined to be of very low safety significance (Green) because it was a failure to comply with NRC requirements, was not a loss of planning standard function, and was not a degraded planning standard function. The planning standard function was not degraded because including state and local 2013 data would not have required the current emergency planning zone time estimate to be updated. There are no immediate safety or security concerns associated with this finding. This finding was assigned a cross-cutting aspect in the area of human performance associated with work management because the licensee failed to understand the scope of work performed by a contractor on their behalf, and failed to ensure the contractor fully complied with regulatory requirements.
Susquehanna
Report Date: 2/12/15
Region: I
Color: Green
Severity Level: NCV
Finding Summary:
The inspectors identified a Green non-cited violation (NCV) of 10 CFR 50.54(q)(2) for failing to follow and maintain an emergency plan that meets the requirements of appendix E and the planning standards of
10 CFR 50.47(b). Specifically, PPL did not identify and critique a weakness related to a risk significant planning standard during their critique following the
July 24, 2014, emergency preparedness drill, as required by 10 CFR 50.47(b)(14) and Appendix E,
Section IV(F)(2)(g). The inspectors determined that PPL did not identify and critique an emergency preparedness drill performance weakness in the formal critique was a performance deficiency that was within PPL’s ability to foresee and correct and should have been prevented. Specifically, PPL did not identify that a periodic update notification provided to the offsite response organizations (OROs) weakness caused a missed opportunity to identify and correct a drill-related performance deficiency. 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 26, 2014, when the finding is in the licensee’s Emergency Preparedness cornerstone. The inspectors determined this finding was a critique finding, the drill scope was full scale, the planning standard was a risk-significant planning standard, and the performance indicator opportunity was a success because periodic update notifications to the OROs are not credited as performance indicator (PI) opportunities using the guidance provided in
Nuclear Energy Institute (NEI) 99-02, “Regulatory Assessment Performance Indicator Guideline,”
Revision 7. Therefore, using Figure 5.14-1, “Significance Determination for Critique Findings,” the inspectors determined the finding was of very low safety significance (Green).
The cause of the finding has a cross-cutting aspect in the area of Human Performance, Consistent Process, because PPL did not use a consistent, systematic approach when making decisions. Specifically, PPL personnel did not use a consistent approach when evaluating and critiquing the accuracy of all notifications provided to the OROs
Arkansas Nuclear One
Report Date: 2/13/15
Region: IV Severity Level: NCV
Color: Green
Finding Summary:
The inspectors identified a non-cited violation of 10 CFR Part 50.47(b)(14) for the failure to correct a deficiency identified in a 2013 simulator drill. Specifically, control room operators did not implement the procedure that describes how the site will maintain continuous communication with threat notification sources during a drill conducted August 7, 2013, and also during the September 16, 2014, biennial
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2015 Emergency Preparedness Findings exercise. The inspectors determined that the licensee’s corrective actions for this issue were incomplete and did not address the extent of condition. The licensee has entered the issue into the corrective action program in corrective action documents WT-WTANO-2014-00189 and Condition Report CR-ANO-C-
2014-02478.
The failure to correct weaknesses occurring in drills and exercises is a performance deficiency within the licensee’s ability to foresee and correct. The performance deficiency is more than minor because it is associated with the emergency response organization performance attribute of the Emergency
Preparedness Cornerstone and it adversely impacted the cornerstone objective. The licensee’s ability to implement adequate measures to protect the health and safety of the public in the event of hostile action and a radiological emergency is degraded when it fails to correct performance that precludes the effective implementation of the emergency plan. This finding was evaluated using Manual Chapter 0609,
Appendix B, “Emergency Preparedness Significance Determination Process (SDP),” Attachment 2, dated
February 24, 2012, and was determined to be of very low safety significance (Green) because it was a failure to comply with NRC requirements, was not associated with a risk-significant planning standard, and was not a loss of planning standard function. The finding was not a loss of function because the deficiency that was identified was not associated with classification, notifications to state and local agencies, or the development of protective action recommendations.
The finding was assigned a cross-cutting aspect in the area of problem identification and resolution, associated with the resolution of issues because the licensee failed to evaluate the initial performance issues to ensure that resolutions adequately addressed the extent of condition commensurate with their safety significance. The licensee failed to recognize in August 2013 that continuous communications with threat notification sources is required by regulation and that performance issues with the implementing procedure should be communicated to the entire control room staff population
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