IR 05000317/2002010
| ML022240667 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 08/12/2002 |
| From: | Lanning W Division of Reactor Safety III |
| To: | Katz P Calvert Cliffs |
| References | |
| EA-02-159 IR-02-010 | |
| Download: ML022240667 (16) | |
Text
ust 12, 2002
SUBJECT:
CALVERT CLIFFS NUCLEAR POWER PLANT - NRC INSPECTION REPORT 50-317/02-010, 50-318/02-010
Dear Mr. Katz:
On July 19, 2002, the NRC completed an inspection at the Calvert Cliffs Nuclear Power Plant Units 1 & 2. The enclosed report documents inspection findings that were discussed with you and other members of your staff on July 19, 2002.
This inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspection consisted of a review of your emergency preparedness program which included a selected examination of procedures and representative records, observations of activities, and interviews with personnel.
Based on the results of this inspection, we identified one preliminary finding of low to moderate safety significance (White). Specifically, for 84 days, the 49 sirens located in Calvert County, Maryland, which are part of your alert and notification system (ANS), were not capable of being activated in a timely manner due to the removal of a computer icon used for activating the sirens at the 911 Center. This is an apparent violation of 10 CFR 50.54(q), 10 CFR 50.47(b)(5)
and 10 CFR Part 50, Appendix E.IV.D.3 which requires that a capability exist to complete the initial notification of the public within the plume exposure pathway EPZ within about 15 minutes from the time that State and local officials are notified that a situation exists requiring urgent action.
The means to alert and notify the public in a timely manner is a Risk Significant Planning Standard (RSPS), and according to the Emergency Preparedness (EP) Significant Determination Process (SDP), (Manual Chapter 0609, EP Risk Determination Flow Chart, Sheet 1, Third Path, Section 4) failure to meet this RSPS is considered of moderate to high safety significance (Yellow). However, Manual Chapter 0609, Appendix B, Section 1, Failure to Meet a Risk Significant Planning Standard, and the EP SDP recognizes that a finding placed in context through the SDP can potentially result in a color (e.g. Green, White, Yellow, Red) that exceeds the actual impact on public health and safety. In this case, we have concluded that the siren activation problem did not have a substantial impact on the EP Cornerstone Objective,
Mr. Peter and therefore, the finding does not rise to the level of substantial safety significance and is more appropriately characterized as low to moderate safety significance (White).
In making this determination, the NRC considered that (1) the system was capable of sounding and notifying the public within 30 minutes if the system was needed to be activated during the 84-day period (this was based on the time the County identified and fixed the icon problem); (2)
prior to the activation of the sirens, 55 emergency vehicles would be placed in the field to begin automatic route alerting simultaneously with initial siren activation (this activity supplements coverage provided by siren activation); and (3) there were no significant equipment problems found to prevent the actual sounding of the sirens as demonstrated on November 15, 2001, during a retest in which 100% of the sirens sounded. Accordingly, the NRC has determined that the capability of meeting the function of alerting the public was met, but not in a timely manner. The significance of the problem was the length of time the problem was undetected.
Therefore, the finding is considered to be of low to moderate safety significance (White).
At this time, there is no immediate safety concern because interim compensatory measures were taken, including the revision of County procedures which specified that (1) notification be given to the Constellation Generation Group prior to any maintenance performed on the ANS computer software and transmitters; and (2) performance of a siren test whenever maintenance is done to ensure that the system was not compromised in the process.
Since the finding is also an apparent violation of NRC requirements, it is being considered for escalated enforcement action in accordance with the General Statement of Policy and Procedure for NRC Enforcement Actions (Enforcement Policy), NUREG-1600. The current Enforcement Policy is accessible from the NRC Web Site at http://www.nrc.gov.
We believe that we have sufficient information to make our final significance determination for the finding. However, you have the opportunity to either request a regulatory conference to discuss your evaluation and any differences with the NRCs evaluation of this issue or to send us your position in writing regarding your perspectives of the facts and assumptions applied by the NRC to determine this finding and its significance. If you choose to request a regulatory conference, you should be prepared to meet within 30 days of the receipt of this letter. In such case, we encourage you to provide supporting documentation at least one week prior to the conference in order to facilitate effectiveness and efficiency. A Regulatory Conference for a matter of this type would be open for public observation. If you decide to provide a written response, please send your submittal to the NRC within 30 days of the receipt of this letter.
Please contact Mr. Richard Conte at (610) 337-5183 within 10 days of the date of this letter to inform the NRC of your intentions. If we have not heard from you within 10 days, we will continue with our significance determination and enforcement decision, and you will be advised by separate correspondence of the results. Since the NRC has not made a final determination in these matters, no Notice of Violation is being issued at this time. In addition, please be advised that the characterization of the apparent violation described in the enclosed report may change as a result of further review.
In accordance with 10 CFR 2.790 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room for from the Publically Available Records (PARS) component of the NRCs document
Mr. Peter system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (The Public Electronic Reading Room).
If you have any questions please contact me at 610-337-5126.
Sincerely,
/RA/
Wayne D. Lanning, Director Division of Reactor Safety Docket Nos. 50-317, 50-318 License Nos. DRP-53, DRP-69
Enclosures:
Inspection Report 50-317/02-010, 50-318/02-010 Attachment 1 - Supplemental Information
REGION I==
Docket Nos: 50-317, 50-318 License Nos: DPR-53, DPR-69 Report Nos: 50-317/02-010, 50-318/02-010 Licensee: Constellation Generation Group Facility: Calvert Cliffs Nuclear Power Plant Units 1 and 2 Location: 1650 Calvert Cliffs Parkway Lusby, MD 20657-4702 Dates: July 15, 2002 through July 19, 2002 Inspector: N. McNamara, Emergency Preparedness Inspector Approved by: Richard J. Conte, Chief Operations Safety Branch Division of Reactor Safety
SUMMARY OF FINDINGS IR05000317/02-010, IR05000318/02-010; On 07/15-19/2002; Calvert Cliffs Nuclear Power Plant; Units 1 and 2. Emergency Preparedness Report. Alert and Notification System, Performance Indicator Verification.
The report covered an inspection by a regional emergency preparedness inspector. This inspection identified a Preliminary White finding that is an apparent violation. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter 0609 Significant Determination Process. Findings for which the SDP does not apply may be Green or assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversite Process, Revision 3, dated July 2000.
A. Inspector Identified Findings (EP)
Cornerstone: Emergency Preparedness
Preliminary White. The inspector identified an apparent violation of 10 CFR 50.54(q), 10 CFR 50.47(b)(5) and Appendix E.IV.D.3. The Calvert County offsite ANS (49 sirens) was not capable of being activated in a timely manner for 84 days due to the removal of a computer icon used for activating the sirens at the Calvert County, Maryland, 911 Center.
The means to alert and notify the public in a timely manner is a Risk Significant Planning Standard (RSPS), and according to the Emergency Preparedness (EP)
Significant Determination Process (SDP), (Manual Chapter 0609, EP Risk Determination Flow Chart, Sheet 1, Third Path, Section 4) failure to meet this RSPS is considered of moderate to high safety significance (Yellow). However, using Manual Chapter 0609, Appendix B, Section 1, Failure to Meet a Risk Significant Planning Standard, and the EP SDP it recognizes that a finding placed in context through the SDP can potentially result in a color (e.g. Green, White, Yellow, Red) that exceeds the actual impact on public health and safety.
The NRC concluded that the siren activation problem did not have a substantial impact on the EP Cornerstone Objective, and therefore, the finding does not rise to the level of substantial safety significance and is more appropriately characterized as low to moderate safety significance (White).
In making this determination, the NRC considered that: (1) the system was capable of sounding and notifying the public within 30 minutes if the system was needed to be activated during the 84-day period (this was based on the time the County identified and fixed the icon problem); (2) prior to the activation of the sirens, 55 emergency vehicles would be placed in the field to begin automatic route alerting simultaneously with initial siren activation (this activity supplements coverage provided by siren activation); and (3) there were no significant equipment problems found to prevent the actual sounding of the sirens as demonstrated on November 15, 2001, during a retest in which 100% of the sirens sounded. Accordingly, the NRC considers the significance of the problem to be the length of time the problem was undetected which is considered a low to moderate safety significance (White). Accordingly, the NRC has determined that the capability of meeting the function of alerting the public was met, but not in a ii
timely manner. The NRC considers the true significance of the problem to be in the length of time the problem was undetected. Therefore, the finding is considered to be of low to moderate safety significance (White). (Section1EP2 ).
iii
Report Details 1. REACTOR SAFETY Emergency Preparedness 1EP2 Alert and Notification System (ANS) Testing a. Inspection Scope An onsite review of the licensees ANS was conducted to ensure prompt notification of the public to take protective actions. The inspector reviewed: (1) the licensees design basis document submitted to the Federal Emergency Management Agency in 1986; (2) siren testing data; (3) maintenance records for correcting siren failures; and (4)
several incident reports relating to siren failures. In addition, the inspector visited the Calvert County, Maryland, 911 Center and observed a weekly ANS silent test. The review was conducted in accordance with NRC Inspection Procedure 71114, Attachment 02, and the applicable planning standard, 10 CFR 50.47(b)(5) and its related 10 CFR 50, Appendix E requirements were used as reference criteria.
The inspector also conducted a review of a failed ANS full cycle test in Calvert County that was conducted by Constellation Generation Group on November 5, 2001. The licensee found that all 49 sirens were not capable of being activated in a timely manner for 84 days. The review included: (1) interviews with both the licensee and officials from the Calvert County 911 Center; (2) associated Incident Reports; (3) corrective actions to date; and (4) Root Cause Report No. IR3-053-295.
b. Findings
.1 ANS Program Review No findings of significance were identified.
.2 November 5, 2001 Full-cycle ANS Test Failure Introduction:
The inspector identified a finding that is preliminarily determined to be of low to moderate safety significance (White), involving a violation of 10 CFR 50.54(q), 10 CFR 50.47(b)(5) and 10 CFR Part 50, Appendix E.IV.D.3. The Calvert County ANS (49 sirens) was not capable of being activated in a timely manner for 84 days due to the removal of a computer icon used for activating the sirens at the Calvert County 911 Center.
Description:
On November 5, 2001, the licensee made a 10 CFR 50.72 notification report that all 49 offsite sirens located in Calvert County failed to activate during an annual full-cycle public ANS test. A subsequent investigation by the licensee found that the system was not capable of being activated in a prompt manner for 84 days because there was an
incorrect computer icon for activating the sirens on the computer screen located at the Calvert County 911 Center.
In August 2001, a computer contractor hired by the County to simplify the 911 computer screens, removed the correct icon and incorrectly programmed the icon left on the screen. Following the November test failure, County officials found the cause of the siren failures and the system was restored to available status within 30 minutes. The licensee conducted a subsequent Calvert County annual full cycle activation test on November 15, 2001 and 100% of the sirens activated.
An initial review of the issue by the NRC determined that at an Alert Emergency Declaration, the County would automatically dispatch 55 emergency vehicles to pre-designated routes to initiate route alerting immediately following the activation of the sirens during a radiological event. This was a precaution put in place due to the ANS not having an activation feedback system and supplements coverage provided by siren activation. County officials believe the entire 10 mile Emergency Planning Zone can be covered within 30-45 minutes of activation.
The NRC initially treated this issue as an Unresolved Item (NRC Inspection Report No.
50-317/01-012, 50-318/01-012, dated January 28, 2002) because additional guidance was needed from the Federal Emergency Management Agency (FEMA) regarding if the licensees automatic backup route alerting could reasonably fulfill the function of the planning standard (10 CFR 50.47.(b)(5)) to provide early notification to the entire EPZ within 15 minutes. FEMA responded to the NRC on May 15, 2002 (ADAMS Accession No. ML021510365) and based on that response, the NRC determined that the automatic backup route alerting is designed for 45 minutes and should not be considered a primary special alerting method capable of being completed in 15 minutes.
Therefore, the licensees primary system would not have been able to meet the 15 minute notification function during that 84-day period.
The inspector reviewed the ANS weekly silent tests and post maintenance test records and determined that there were no significant equipment problems with the ANS transmission system, the sirens themselves, or any of their related equipment that would have prevented most of the sirens from activating during the November 2001 test. Also, the icon problem was not detected during the weekly silent tests because a different icon was used to perform those tests.
Analysis:
The failure of the sirens to activate in a timely manner for 84 days is considered a performance deficiency and constitutes a violation of 10 CFR 50.54(q), 10 CFR 50.47(b)(5) and 10 CFR Part 50, Appendix E.IV.D.3. Traditional enforcement does not apply because the issue did not have any actual safety consequences or potential for impacting the NRCs regulatory function and was not the result of any willful violation of NRC requirements. Constellation Generation Groups failure to detect an ANS problem for 84 days was considered more than minor since it was associated with an attribute and affected the objective of the Emergency Preparedness Cornerstone. The applicable attribute was the ANS not capable of being activated in a prompt manner for
notifying the public within 15 minutes of the time that State and local officials make the decision that a situation exists requiring urgent action by the general public.
The means to alert and notify the public in a timely manner is a Risk Significant Planning Standard (RSPS), and according to the Emergency Preparedness (EP) Significant Determination Process (SDP), (Manual Chapter 0609, EP Risk Determination Flow Chart, Sheet 1, Third Path, Section 4) failure to meet this RSPS is considered of moderate to high safety significance (Yellow). However, using Manual Chapter 0609, Appendix B, Section 1, Failure to Meet a Risk Significant Planning Standard, and the EP SDP it recognizes that a finding placed in context through the SDP can potentially result in a color (e.g. Green, White, Yellow, Red) that exceeds the actual impact on public health and safety. The NRC concluded that the siren activation problem did not have a substantial impact on the EP Cornerstone Objective, and therefore, the finding does not rise to the level of substantial safety significance and is more appropriately characterized as low to moderate safety significance (White).
Although the NRC recognizes that the notification of the public would not have been completed within 15 minutes, the NRC concluded it does not rise to the level of a Yellow finding because: (1) the system was capable of sounding and notifying the public within 30 minutes if the system needed to be activated during the 84-day period (this was based on the time the County identified and fixed the icon problem); (2) 55 emergency vehicles would be placed in the field, prior to the activation of the sirens, to begin automatic route alerting simultaneously with initial siren activation; and (3) there were no significant equipment problems found to prevent the actual sounding of the sirens as demonstrated on November 15, 2001, during a retest in which 100% of the sirens sounded. Accordingly, the NRC has determined that Constellation Generation Group was capable of meeting the function of alerting the public, although not within the required 15 minutes.
The NRC considers the significance of this issue to be more than green because for 84 days the problem went undetected and would have continued to go undetected had the licensee not performed the annual full cycle test. In addition, the annual test was conducted with individuals pre-staged in the field for listening to the actual sounding of the siren. Had this been a real event during late evening hours, County officials may not have been immediately aware that the sirens had not sounded. This could have delayed their troubleshooting efforts which may have resulted in the sirens not being sounded for greater than 30 minutes.
Enforcement:
10 CFR 50.54(q) requires, in part, that a licensee shall follow and maintain in effect emergency plans which meet the standards of 10 CFR 50.47(b) and requirements in 10 CFR Part 50, Appendix E. 10 CFR 50.47(b)(5) and 10 CFR Part 50, Appendix E.IV.D.3 require, in part, that procedures have been established for notification and means to provide early notification to the populace within 15 minutes of the time that State and local officials are notified that a situation exists requiring urgent action. Calvert Cliffs Emergency Plan Section 4.II.D, Prompt Notification requires, in part, that the prompt notification using sirens or backup methods facilitate public awareness for information or instructions for broadcast by state or local government authorities on the Emergency
Alert System. Contrary to the above, for 84 days prior to November 5, 2002, the licensee was not capable of immediately activating the ANS in Calvert County for notifying the general populace within 15 minutes of State and local officials decision to promptly provide instructions to the public within the plume exposure pathway EPZ during a radiological event. This is considered an apparent violation. (AV 50-317;50-318/02-010-01)
The following contributed to the sirens not being activated in a timely manner for 84 days: (1) no formal process in place to ensure that the County informs Constellation Generation Group of any changes made to the software system; and (2) no post-maintenance testing was performed following any repair or improvement generated by the County. Interim compensatory measures were taken to revised the County procedures to include: (1) notification be given to the Constellation Generation Group prior to any maintenance performed on the ANS computer software and transmitters; and (2) performance of a siren test whenever maintenance is done to ensure that the system was not compromised in the process. (IR No. IR3-053-295)
1EP3 Emergency Response Organization (ERO) Augmentation Testing a. Inspection Scope An onsite review for the period of 2001-2002 of the licensees ERO augmentation staffing requirements and the process for notifying the ERO was conducted to ensure the readiness of key staff for responding to an event and timely facility activation. In addition to conducting interviews, the inspector reviewed the licensees Emergency Plan qualification records for key ERO positions, quarterly communication pager test records, applicable procedures and trending of test data. The review was conducted in accordance with NRC Inspection Procedure 71114, Attachment 03, and the applicable planning standard, 10 CFR 50.47(b)(2) and its related 10 CFR 50, Appendix E requirements were used as reference criteria.
b. Findings No findings of significance were identified.
1EP4 Emergency Action Level (EAL) Revision Review a. Inspection Scope A regional in-office review of revisions to the Emergency Plan, implementing procedures and EAL changes was performed to determine that changes didnt decrease the effectiveness of the Plan. The revisions covered the period from March through July 2002. Onsite, the inspector reviewed the associated 10 CFR 50.54(q) reviews and discussed selected changes to understand the basis for the change to determine if a decrease in the effectiveness had occurred. The review was conducted in accordance with NRC Inspection Procedure 71114, Attachment 04, and the applicable requirements in 10 CFR 50.54(q) were used as reference criteria.
b. Findings No findings of significance were identified.
1EP5 Correction of Emergency Preparedness Weaknesses and Deficiencies a. Inspection Scope The inspector reviewed corrective actions identified by the licensee pertaining to findings from drill/exercise reports from 2000 - 2002, self-assessment reports from 2000-2002 and from problems resulting from surveillances and actual events. Incident reports assigned to the EP Department were also reviewed to determine the significance of the issues and to determine if repeat problems were occurring. In addition, the inspector reviewed the 2001 and 2002 Quality Assessment audit reports and the associated audit checklists to determine if the licensee had met the 10 CFR 50.54(t) requirements and if any repeat issues were identified. This review was conducted according to NRC Inspection Procedure 71114, Attachment 05, and the applicable planning standard, 10 CFR 50.47(b)(14) and its related 10 CFR 50, Appendix E requirements were used as reference criteria.
b. Findings No findings of significance were identified.
4. OTHER ACTIVITIES [OA]
4OA1 Performance Indicator (PI) Verification a. Inspection Scope The inspector reviewed the licensees procedure for developing the data for the EP PIs which are: (1) Drill and Exercise Performance (DEP), (2) Emergency Response Organization (ERO) Drill Participation, and (3) Alert and Notification System (ANS)
Reliability. The inspector also reviewed the licensees drill/exercise reports, training records and ANS testing data since the last NRC PI inspection, conducted in September 2001, to verify the accuracy of the reported data. The review was conducted in accordance with NRC Inspection Procedure 71151. The acceptance criteria are 10 CFR 50.9 and NEI 99-02, Revision 1, Regulation Assessment Performance Indicator Guideline.
b. Findings
.1 Alert and Notification System (ANS)
Due to the age of the ANS, Calvert Cliffs sirens have significantly degraded in the past five years. Beginning in June 2001, in order to have confidence in the operability of the system, the licensee tripled their weekly siren tests, immediately verified the activation results, conducted quarterly growl tests and routinely reviewed the test data for any identifiable trends. They have committed to a new siren system by the end of 2003.
While reviewing the ANS PI data, the inspector noted that the increased testing consisted of performing three successive complete silent tests during the same time period. Constellation Generation Group found that because of intermittent failures, there were times that not all three tests were successful. However, they determined at least one of the three tests most times was successful unless there was a complete system failure. Troubleshooting efforts have not determined the exact reasons for the intermittent failures.
When reporting the PI data, the licensee considered the three silent tests as one test but was reporting successes on any of the three tests. For example, if two tests were successful and one was a failure, the licensee considered the one failure as a success.
The only time they counted a failure was if all three tests were unsuccessful. The inspector determined that by not counting all the tests, the licensee could be unintentionally masking failures which may provide a false impression that the system was operating at a high performance level. The licensee recalculated their data by counting all the tests conducted since June 2001 as single tests and counted all the failures. In the third and fourth quarters of 2001, the PI data went into the White response band which was consistent with the number of siren problems the licensee had in those quarters.
Constellation Generation Group believed the calculation of the data was correct because it mimics how they would activate the sirens during an actual event (three consecutive pushes) and they revised their full activation and weekly test procedures to reflect the new testing method. However, the current testing and activation process is an interim action, the change in testing methodology was not submitted to FEMA for approval prior to use, and it appears it may not be meeting the intent of the PI for providing the NRC a true indicator of the reliability of the system and for identifying routine performance problems. Constellation Generation Group stated they would submit a Frequently Asked Question (FAQ) to the Nuclear Energy Institute (NEI)
Working Group to determine if their interpretation of the guidance set forth in NEI 99-02, Revision 2 is correct and entered the issue in their corrective action system (No. IR3-021-087). This issue is being treated as an Unresolved Item (URI 50-317/02-010-02, 50-318/02-010-02) and the NRC will disposition the final significance of this issue following the response to the FAQ.
.2 Drill exercise Performance (DEP)
The DEP PI could not be completed due to the unavailability of the actual PI data.
Licensed Operator Requalification Training (LORT), conducted by the Training Department staff, makes up approximately 80% of the DEP Performance Indicator data.
However, the Training Department discards the original paperwork (notes, classifications, notification forms, etc) that supports the reported data. The inspector determined that on numerous occasions, the EP staff attempted to have Training send the information to them but an agreement could not be reached with the Training Department. The inspector discussed the issue with the training departments senior manager who was not aware of the problem and committed to cooperate with the EP staff in providing all information necessary for them to support the reported data. This issue was entered into the licensees corrective action system (IR No. IR3-083-794) and is being treated as an Unresolved Item (URI 50-217;218/02-010-03). This issue will be reviewed again prior to the end of 2002 by the NRC resident inspection staff to verify the actual data from the LORT drills. The inspector verified that the data submitted as a result of drills and exercises was correct.
40A6 Meetings
.1 Exit Meeting Summary The inspector presented the inspection results to the licensee at the conclusion of the inspection on July 19, 2002. The licensee did not dispute the facts presented by the inspector.
Attachment 1 Supplemental Information a. Key Points of Contact Constellation Generation Group C. J. Andrews, Lead Assessor, Quality Assurance T. Grover, Regulatory Matters E. P. Gwiazdowski, NuclearSecurity/Emergency Planning Director A. J. ODonnell, Emergency Planning Director B. C. Scotland, Performance Management Analyst M. V. Seckens, Operations Training General Supervisor R. R. Woods, Sr. Emergency Planning Analyst Nuclear Regulatory Commission R. J. Conte, Chief, Operations Safety Branch, Region I K. Smith, Intern, Region I b. List of Items Opened, Closed, and Discussed Opened AV 50-317;318/02-010-01 ANS was not capable of activating for 84 days in a timely manner.
URI 50-317;318/02-010-02 ANS PI Data potentially not being calculated properly.
URI 50-317;318/02-010-03 Not verifying the DEP PI due to the actual supporting documentation not being available.
Closed URI 50-317;318/01-012-02 ANS was not capable of activating for 84 days in a timely manner c. List of Documents Reviewed Calvert Cliffs Nuclear Response Emergency Plan Calvert Cliffs Nuclear Response Implementing Procedures Calvert County Siren Activation and Testing Procedure Dorchester County Emergency Management Agency Siren Activation Procedure, Rev. 5 Calvert Cliffs Nuclear Power Plant Alert and Notification System Design and Support Documents in Response to FEMA-43, September 1984 ERO Notification Procedures, ERPIP-105
Control Room Communicator, Personnel Notification, ERPIP-105, Rev. 9 Self Assessment 200100248, Public Alert and Notification System, dated 8/27/01 Self Assessment 200000017, Participation in the ERO, dated 12/28/01 Self Assessment 200100008, Effectiveness of the ANS Growl Testing, dated 2/5/01 Self Assessment 200100243, Radiological Emergency Response Drill, dated 7/5/01 Self Assessment 200000011, Emergency Public Information Action Item Subsystem, QL-2-102 Nuclear Assessment Department Audit Report No. 2001-01, dated 8/30/01 Nuclear Assessment Department Audit Report No. 2002-01, dated 1/01 Drill/Exercise Evaluation Report, 8/25/2000 Drill/Exercise Evaluation Report, 5/24/01 Drill/Exercise Evaluation Report, 9/12/01 d. List of Acronyms ANS Alert Notification System AV Apparent Violation CFR Code of Federal Regulations DEP Drill and Exercise Performance EP Emergency Preparedness ERO Emergency Response Organization EPZ Emergency Planning Zone FAQ Frequently Asked Question FEMA Federal Emergency Management Agency LORT Licensed Operator Requalification Training NEI Nuclear Energy Institute NRC Nuclear Regulatory Commission PI Performance Indicator SDP Significance Determination Process URI Unresolved Item