The inspector identified an apparent violation for the licensees failure to provide adequate corrective actions to a previously-identified
emergency preparedness exercise weakness.
10 CFR 50, Appendix E, Section IV.F.2.g, requires that any
emergency preparedness weakness or deficiency that is identified shall be corrected. An apparent violation of that requirement was identified involving the licensees failure to adequately correct a performance deficiency in the area of Protective Action Recommendation development identified by the NRC in the May 2004 evaluated exercise. Specifically, in the 2006 exercise, the licensee dose assessment team did not adequately consider plant-specific situational information to develop the best dose projection estimate achievable at the time, which was an apparent repeat of a problem exhibited in the 2004 exercise. The licensees 2006 performance regarding the development of a dose projection without a sound technical basis demonstrated that the licensee had implemented ineffective corrective actions for the 2004 inspection finding. This finding is greater than minor because it is associated with the Emergency Response Organization Performance attribute and affected the objective of the
Emergency Preparedness Cornerstone 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. The
Emergency Preparedness SDP, Section 5.3, Failure to Correct Drill or Exercise Weaknesses, was used to evaluate the significance of this finding. Because the licensees corrective actions were not adequate and the weakness involved a Risk Significant Planning Standard area that is not covered by performance indicators (i.e.,
10 CFR 50.47(b)(9)), a loss of planning standard function was assessed, resulting in a White finding.