05000315/FIN-2015003-04
Finding | |
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Title | Changes to Minimum 60-Minute Emergency Responder Staffing Without Prior Approval |
Description | The inspectors identified a finding of very-low safety significance with an associated Severity Level IV (SL-IV) NCV of Title 10, Code of Federa
Regulations (CFR) 50.54(q)(3) and 10 CFR 50.54(q)(4) related to a staffing change in the licensees Emergency Plan that reduced the effectiveness of the Plan, which was made without prior NRC approval. Specifically, in March 2004, the licensee made changes to wording in the Donald C. Cook Emergency Plan that allowed two Radiation Protection (RP) Technician positions to be augmented by staff that were not qualified RP Technicians. This issue was placed in the licensees CAP and was corrected by revising the Emergency Plan to the approved augmented staffing minimum. The finding was of more than minor significance because it was associated with the Emergency Preparedness Cornerstone attribute of Procedure Quality, and affected the cornerstone objective of ensuring the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, a failure to evaluate changes to the Emergency Plan as required by 10 CFR 50.54(q)(3) resulted in unacceptable changes made to the plan that decreased its effectiveness without prior NRC approval as required by 10 CFR 50.54(q)(4) and reduced the licensees capability to perform an emergency planning function in the event of a radiological emergency. The finding was of very low safety significance because it was a failure to comply that did not result in a loss of the planning standard function. In accordance with Section 6.6.d of the NRC Enforcemen Policy, this violation was categorized as SL-IV because it involved the licensees ability to meet or implement a regulatory requirement not related to assessment or notification such that the effectiveness of the Emergency Plan decreases. The inspectors concluded that because the performance deficiency involved a change to the licensees Emergency Plan in March 2004, this issue would not be reflective of current licensee performance and no cross-cutting aspect was identified. (Section 1EP4.b.1) Violations of very low safety or security significance or SL-IV that were identified by th licensee have been reviewed by the NRC. Corrective actions taken or planned by the licensee have been entered into the licensees CAP. These violations and CAP tracking numbers are listed in Section 4OA7 of this report. |
Site: | Cook |
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Report | IR 05000315/2015003 Section 1EP4 |
Date counted | Sep 30, 2015 (2015Q3) |
Type: | TEV: Severity level IV |
cornerstone | Emergency Prep |
Identified by: | NRC identified |
Inspection Procedure: | IP 71114.04 |
Inspectors (proximate) | J Ellegood J Lennartz J Mancuso K Riemer M Garza M Learn R Edwards R Elliott T Taylor |
Violation of: | 10 CFR 50.54 10 CFR 50.54(q) |
INPO aspect | |
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Finding - Cook - IR 05000315/2015003 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Cook) @ 2015Q3
Self-Identified List (Cook)
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