An apparent violation associated with
EP planning standard
10 CFR 50.47(b)(15) was identified. This apparent violation, which has low to moderate safety significance, occurred because AmerGen did not conduct annual required radiological response classroom retraining for approximately 50 percent of the
ERO as specified in the
TMI Annex
Emergency Plan (
E-Plan). The finding is more than minor because it is associated with the
EP cornerstone attribute of
ERO readiness (training). It affects the cornerstone objective of ensuring the capability to implement measures to protect the health and safety of the public during an emergency. The
ERO, including several key responders, had not received the training necessary to maintain familiarity with their specific emergency response duties. As a consequence, for an approximate five month period (June-November 2004), those individuals would not have been considered available to respond to a radiological emergency. This resulted in some key
ERO positions not being filled by qualified
ERO members in accordance with AmerGens
TMI E-Plan requirements. (1EP3) Using
Inspection Manual Chapter 0609, Appendix B,
Emergency Preparedness Significance Determination Process, Section 4.15 and Sheet 1, this finding was determined to be of low to moderate safety significance because it was considered to be a loss of an
EP planning standard function because several key responders were not trained as required.
