The inspector identified an noncited violation of
10 CFR 50.9 because Pacific Gas and Electric Company failed to provide complete and accurate information in a submittal of data for the
emergency preparedness drill and exercise performance indicator. Specifically, Pacific Gas and Electric Company staff failed to identify three missed opportunities for emergency notification accuracy during the second calendar quarter of 2005. Pacific Gas and Electric Company took prompt action to correct the second quarter data, which resulted in the drill and exercise performance indicator color to cross from GREEN to WHITE. Pacific Gas and Electric Company also initiated a 100 percent review of the second and third quarter drill and exercise performance indicator data and discovered one additional administrative error in the third quarter performance indicator data, which had been previously evaluated, but not yet reported to the NRC. Pacific Gas and Electric Company had previously initiated a root cause evaluation in its corrective action program to determine the reason for the declining indicator and, subsequently, initiated another root cause evaluation to determine the reason for the failure to adequately evaluate and report the performance indicator data. The finding also had human performance crosscutting aspects in that the reviews that were performed were not adequate to identify the actual failures that had occurred
Because this issue affected the NRC's ability to perform its regulatory function, it was evaluated using the traditional enforcement process. Supplement 7, Section D.3, of the
NRC Enforcement Policy describes this finding as a
Severity Level IV violation. The issue is significant because it indicates a declining trend in the attention to detail shown by senior licensed operators in performing emergency notifications to the state and local authorities. This issue is documented in Pacific Gas and Electric Company's corrective action program as Nonconformance Report NO002200.
