The inspectors identified a violation of
10 CFR 50.47(b)(2) when the process for timely augmentation of on-shift staff was changed for the station nuclear engineer (
SNE) position without performing a review to determine if the change decreased the effectiveness of the
emergency plan. The inspectors determined this change decreased the effectiveness of the
emergency plan and that the licensee did not obtain prior NRC approval contrary to the requirements of
10 CFR 50.54(q). The primary cause of this finding was related to the cross-cutting area of Human Performance in that changes were made to the emergency response organization augmentation process which were not recognized and corrected by the organization.
Because the issue affected the NRC's ability to perform its regulatory function, it was evaluated with the traditional enforcement process as specified in Section IV.A.3 of the
Enforcement Policy. This issue was determined to be a
Severity Level IV violation because it involved a failure to meet a requirement not directly related to assessment and notification. Further, this problem was isolated to one 30-minute responder position and was not indicative of a functional problem with the emergency response organization augmentation process. Corrective actions included discussions with the
SNEs that it was no longer acceptable to remotely activate the 3-D Monocore program to respond to an emergency at the plant instead of responding to the control room and that response to the control room was required within 30 minutes of the declaration of an emergency at the plant. In addition, the Emergency Call Out System test forms were revised to remove the option for the
SNE to activate the software remotely in lieu of responding to the control room.
