Title 10 of the Code of Federal Regulations 50.54(q)(2) requires, in part, that a holder of a license under this part shall follow and maintain the effectiveness of an
emergency plan that meets the requirements in
10 CFR Part 50, Appendix E, and the planning standards of
10 CFR 50.47(b). Title
10 CFR Part 50, Appendix E, Section IV.A.9 states, By December 24, 2012, for nuclear power reactor licensees, a detailed analysis demonstrating that on-shift personnel assigned
emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the
emergency plan, shall be included. Contrary to the above, on December 24, 2012, the licensees detailed analysis of on-shift staffing was deficient in that all assigned functions for on-site personnel were not evaluated. Specifically, the augmentation tasks identified in the licensees
emergency plan assigned to on-shift personnel were not considered when performing A.2002, Monticello On-Shift Staffing Analysis, for the Core/Thermal Hydraulics and Radiation Waste Operator positions. The NRC determined that with no identified loss or degradation of a planning standard function, the failure to complete the detailed analysis in accordance with
10 CFR Part 50, Appendix E, Section IV.A.9 was a very low safety significance issue (Green) as indicated in
IMC 0609, Appendix B,
Emergency Preparedness Significance Determination Process, Revision February 24, 2012. This issue was identified in a self-assessment process on May 13, 2014, and documented in corrective action entries as action requests 01430607 and 0101437840. Immediate corrective actions included interim augmentation for both on-shift positions fully analyzing and updating the on-shift staffing analysis. As such, the NRC determined this to be an
NCV in accordance with Section 2.3.2 of the
Enforcement Policy.
