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Quarter | Site | Title | Description | |
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05000289/FIN-2004005-01 | 2004Q4 | Three Mile Island | Plant Modification Decreased Effectiveness of Emergency Plan Without Prior NRC Approval, Deficient 10 CFR 50.54(Q) Evaluation | A non-cited violation of 10 CFR 50.54(q) was identified for not properly maintaining the TMI Radiological Emergency Plan (the Plan) up-to-date to address a modification made within the owner controlled area. Specifically, plant modifications which blocked the south gate access bridge resulted in a decrease in effectiveness in the Plan without prior NRC approval. Corrective actions included discussions with the local railroad company to establish a memorandum of understanding, establishment of a shift night order, training for emergency directors, reassessment of south gate accessibility, and entry of the issue into the licensee's corrective action program as issue reports 260849, 260697, 266937, 269032, 282239 and 282851 A contributing cause of this finding is related to the cross-cutting area of problem identification and resolution, because (1) the 10 CFR 50.54(q) evaluation did not identify the potential that a train (or crossing gate) malfunction could occur and cause delays in accessing or leaving the site, despite several such occurrences; (2) evaluation of the issue following three train (or crossing gate) malfunctions in October 2004 was cursory in that it did not take positive actions to verify contingency actions were identified, understood, and trained upon; and (3) substantive corrective actions such as establishing a memorandum of understanding with the railroad and establishing written guidance shift manager/emergency director guidance for this contingency were not developed until repeatedly questioned by the inspectors. This finding was of very low safety significance, because it did not constitute a loss of a planning standard function required by 10 CFR 50.47(b)(2) or (b)(3). |
05000289/FIN-2004005-03 | 2004Q4 | Three Mile Island | Untimely Licensee Event Report for Both Trains of High Pressure Injection Being Inoperable | A non-cited violation of 10 CFR 50.73 was identified for untimely submittal of a licensee event report (LER). In March 2004, station personnel had all necessary information available to identify that both trains of high pressure injection (HPI) had been inoperable for a brief period in 2003. The issue was not reported until December 2004, following identification by the inspectors. A contributing cause of this finding is a shortcoming in problem identification in the cross-cutting area of PI&R in that station personnel did not consider unavailability of the emergency power supply to the second HPI train and associated technical specification requirements when determining reportability of this condition. Additionally, the original operability determination did not correctly address seismic qualification of HPI support systems until identified by the inspectors. Corrective actions included submittal of the condition report, training for station personnel, and entering the issue into the corrective action program as issue report 267630. |
05000352/FIN-2003004-03 | 2003Q3 | Limerick | DID Not Perform a 10 CFR 50.54(Q) Review Resulting in Removal of a Provision Without Prior NRC Approval | The inspector identified a SL IV NCV of 10 CFR 50.54(q) because the licensee decreased the effectiveness of its emergency plan in one area by removing a provision to provide volunteer bus drivers to two school districts within the 10 mile Emergency Planning Zone for evacuating students during a radiological event. The change was implemented without NRC approval Changing emergency plan provisions without prior NRC approval impacts the NRC's ability to perform its regulatory function and is therefore processed through traditional enforcement as specified in Section IV.A.3 of the Enforcement Policy, issued May 1, 2000 (65 FR 25388). According to Supplement VIII of the Enforcement Policy, this finding was determined to be a SL IV violation because it involved a failure to meet a requirement not directly related to assessment and notification. This NCV was also determined to have very low safety significance since Exelon had maintained a list of volunteers that would have been able to perform the function if needed. |
05000352/FIN-2003004-04 | 2003Q3 | Limerick | DID Not Retain a Record of the 10 CFR 50.54(Q) Review of the Deleted Portions of the Emergency Plan | The inspector identified a SL IV non-cited violation of 10 CFR 50.54(q). During the implementation of a new Standard Emergency Plan, Exelon did not retain a record that determined whether a decrease-in-effectiveness had or had not occurred when Exelon generated the new Standard Emergency Plan that deleted portions of the previous Combined Limerick/Peach Bottom Emergency Plan Changing emergency plan provisions without documentation impacts the NRC's ability to perform its regulatory function and is therefore processed through traditional enforcement as specified in Section IV.A.3 of the Enforcement Policy, issued May 1, 2000 (65 FR 25388). According to Supplement VIII of the Enforcement Policy, this finding was determined to be a SLl IV because it involved a failure to meet a requirement not directly related to assessment and notification. |
05000277/FIN-2003004-04 | 2003Q3 | Peach Bottom | Inadequate Emergency Plan Change Documentation, 10 CFR 50.54(Q) | The inspector identified a Severity Level IV non-cited violation of 10 CFR 50.54(q). During the implementation of a new Standard Emergency Plan, Exelon did not retain a record that determined whether a decrease-in-effectiveness had or had not occurred when Exelon generated the new Standard Emergency Plan that deleted portions of the previous Combined Limerick/Peach Bottom Emergency Plan. Changing emergency plan commitments without documentation impacts the NRC's ability to perform its regulatory function and is, therefore, processed through traditional enforcement as specified in Section IV.A.3 of the Enforcement Policy, issued May 1, 2000 (65 CFR 25388). According to Supplement VIII of the Enforcement Policy, this finding was determined to be a Severity Level IV because it involved a failure to meet a requirement not directly related to assessment and notification. |