05000315/FIN-2014005-05
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Finding | |
|---|---|
| Title | Changes to Minimum 60-Minute Emergency Responder Staffing Without Prior Approval |
| Description | An Unresolved Item (URI) was identified because additional information is required to determine whether a performance deficiency that is more than minor exists and if a violation of 10 CFR 50.54(q)(3) occurred. The inspectors identified an issue of concern for a change to the Donald C. Cook Emergency Plan, Table 1, that reduced the number of Radiation Protection Technicians (RPTs) required to augment the on-shift emergency response organization in 60 minutes of a declared emergency and replaced them with a Radiological Assessment Coordinator (RAC) and an Environmental Assessment Coordinator (EAC). Description. During the review, the inspectors identified a change made in Table 1 of Revision 35 to the Emergency-Plan (E-Plan), dated June 3, 2014. The change reduced the number of 60-minute response RPTs tasked with conducting offsite surveys from three RPTs to two RPTs and one EAC. The second change reduced the number of 60-minute response RPTs tasked with conducting in-plant surveys from two RPTs to one RPT and one RAC. According the licensees 10 CFR 2014 50.54(q) screening evaluation, this change was to align the wording in Table 1 with Sections B.5.a.4 and B.5.c.4 of the E-Plan. The inspectors identified that the wording in Section B.5.a.4 and B.5.c.4 of the E-Plan had been changed to include the EAC and the RAC as 60-minute responders in Revision 19 of the plan in March of 2004. Inspectors review of the 10 CFR 50.54(q) screening for the changes in Revision 19, identified no evaluations had been done for this change. The inspectors reviewed Revision 18 of the E-Plan and the associated March 21, 2003 licensee request for prior approval for changes to the E-plan that was conducted, approved by the NRC, and implemented in this revision. The NRC approved change request included specific numbers of RPTs for 60-minute response tasks of three RPTs for offsite surveys and 2 RPTs for onsite surveys. The licensee indicated that the EAC and RAC were not currently qualified RPTs. This suggests a performance deficiency, due to the appearance of a reduction in effectiveness to the licensees E-plan, without prior NRC approval. However, in order to determine if this is a performance deficiency of more than minor significance, additional information is required to understand if the RAC and EAC positions had equivalent capabilities as the qualified RPTs. The licensee has entered this issue in their Corrective Action Program as AR 2014-15685, Potential EP Finding. Compensatory actions were taken while their staff gathers additional information, which included requiring two additional qualified RPTs to respond to the Operations Support Center within 60 minutes prior to activating the facility in the event of a declared emergency. The licensee stated that it will provide the inspectors with additional information within 30 days of the exit meeting. Therefore, a URI was identified pending additional information. Specifically, documentation demonstrating the knowledge, skills, and abilities of the EAC and RAC are equivalent to the RPTs is necessary for the inspectors to determine whether the performance deficiency is more than minor and if a violation of 10 CFR 50.54(q) occurred. (URI 05000315/201400505; Changes to Minimum 60-Minute Emergency Responder Staffing Without Prior Approval) |
| Site: | Cook  |
|---|---|
| Report | IR 05000315/2014005 Section 1EP4 |
| Date counted | Dec 31, 2014 (2014Q4) |
| Type: | URI: |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71114.04 |
| Inspectors (proximate) | J Ellegood J Lennartz J Mancuso K Riemer M Garza M Learn R Edwards R Elliott T Taylore Sanchezj Cassidy J Ellegood J Lennartz K Riemer M Garza M Mitchell M Phalen T Go T Taylor |
| INPO aspect | |
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Finding - Cook - IR 05000315/2014005 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Cook) @ 2014Q4
Self-Identified List (Cook)
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