The inspectors identified a Green
NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50.54(q)(2) for Exelons failure to maintain an
emergency plan that meets the requirements in Appendix E, Content of
Emergency Plans, to Part 50 and the planning standards of 50.47(b). Specifically, Exelon did not perform a drive-in augmentation drill during the required 3-year cycle nor did they perform a health physics drill semi-annually as required by Ginnas
Emergency Plan Implementing Procedure
EP-AA-122-100, Drill and Exercise Planning and Scheduling. Immediate corrective actions included entering this issue into their corrective action program (
CAP). This finding is more than minor because it is associated with the emergency response organization (
ERO) readiness attribute of the
Emergency Preparedness cornerstone and adversely affected the cornerstone objective to ensure that Exelon is capable of maintaining adequate measures to protect the health and safety of the public in the event of a radiological emergency. In accordance with
IMC 0609, Appendix B,
Emergency Preparedness Significance Determination Process, Attachment 2, Failure to Comply Significance Logic, the inspectors determined that the performance deficiency affected planning standard
10 CFR 50.47(b)(14). The inspectors concluded that this performance deficiency matched an example on Table 5.14-1 Significance Examples 50.47(b)(14), for a Degraded Planning Standard Function. Specifically, two drills had not been conducted during a 2year (calendar) period in accordance with the
emergency plan, thus constituting a degraded planning standard function which corresponds to a very low safety significance (Green) finding. The cause of the finding has a cross-cutting aspect in the area of Human Performance, Procedure Adherence, because Exelon did not schedule or plan for a drive-in augmentation drill or health physics drills in accordance with procedure
EP-AA-122-100. [H.8]
