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).
