IR 05000280/2006010

EA-06-071, Surry, Final Significance Determination for a White Finding & Notice of Violation (Surry Power Station - NRC Inspection Report Nos. 05000280-06-010, 05000281-06-010)

ML062070034
Person / Time
Site:	Surry
Issue date:	07/25/2006
From:	Travers W NRC/RGN-II
To:	Christian D Virginia Electric & Power Co (VEPCO)
References
EA-06-071, IR-06-010
Download: ML062070034 (13)

Text

July 25, 2006EA-06-071 Virginia Electric and Power CompanyATTN: Mr. David Sr. Vice President and Chief Nuclear Officer Innsbrook Technical Center - 2SW 5000 Dominion Boulevard Glen Allen, VA 23060-6711SUBJECT: FINAL SIGNIFICANCE DETERMINATION FOR A WHITE FINDING ANDNOTICE OF VIOLATION (Surry Power Station - NRC Inspection ReportNos. 05000280/2006010 and 05000281/2006010)

Dear Mr. Christian:

The purpose of this letter is to provide you with the Nuclear Regulatory Commission's (NRC)final significance determination for a finding involving the failure of Surry Nuclear Station's full-scale exercise critique to identify a weakness associated with a risk-significant planning standard (RSPS) which was determined to be a drill/exercise performance (DEP) - performanceindicator (PI) opportunity failure. The finding was also determined to be an apparent violation associated with emergency preparedness planning standards 10 CFR 50.47(b)(14) and 10 CFR 50.47(b)(4), and the requirements of 10 CFR Part 50, Appendix E, Section IV.F.2.g.

The finding was documented in NRC Integrated Inspection Report No. 5000280,281/2006008issued on May 5, 2006, and was assessed under the significance determination process as a preliminary White issue (i.e., an issue of low to moderate safety significance which may require additional NRC inspection).The cover letter to the inspection report informed Virginia Electric and Power Company(VEPCO) of the NRC's preliminary conclusion and provided VEPCO an opportunity to request aregulatory conference on this matter. In lieu of a regulatory conference, VEPCO provided a written response dated June 6, 2006.In its written response, VEPCO disagreed with the NRC's conclusion that the issue resulted in apreliminary White finding. VEPCO contended that the NRC's determination did not fullyconsider the information available regarding the Site Area Emergency (SAE) classification made by drill participants during the exercise or subsequent deliberations that formed VEPCO'sbasis for its exercise critique conclusions. VEPCO also noted its differing view regarding compliance with the applicable regulatory requirements that were noted in the NRC's inspectionreport.After carefully considering the information developed during the inspection and the informationprovided in VEPCO's response of June 6, 2006, the NRC has concluded that the finalinspection finding is appropriately characterized as White in the Emergency Preparedness cornerstone. The NRC's response to the points made by VEPCO and the bases for our VEPCO2conclusions are provided in an attachment to this letter. In summary, the NRC concl uded thatVEPCO's SAE event classification during the exercise was an inaccurate classification.

VEPCO's critique failed to identify that the SAE declaration was made using EALs (indications)

that were not exceeded at the time of the declaration. Based on this and in accordance withNRC Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness SignificanceDetermination Process, the NRC has concluded that the significance of the finding isappropriately characterized as White.You have 30 calendar days from the date of this letter to appeal the staff's determination ofsignificance for the identified finding. Such appeals will be considered to have merit only if theymeet the criteria given in NRC Inspection Manual Chapter 0609, Attachment 2.The NRC also has determined that VEPCO's failure to identify the above weakness during itsexercise critique is a violation of 10 CFR 50.47(b)(14), 10 CFR 50.47(b)(4), and the requirements of 10 CFR Part 50, Appendix E, Section IV.F.2.g. The violation is cited in the enclosed Notice of Violation (Notice), and the circumstances surrounding the violation are described in detail in the subject inspection report. In accordance with the NRC EnforcementPolicy, the Notice of Violation is considered escalated enforcement action because it is associated with a White finding.You are required to respond to this letter and should follow the instructions specified in theenclosed Notice when preparing your response. The NRC will use your response, in part, todetermine whether further enforcement action is necessary to ensure compliance with regulatory requirements.For administrative purposes, this letter is issued as a separate NRC Inspection Report,No. 0500280,281/2006010, and the above violation is identified asVIO 0500280,281/2006010-01, White Finding Involving Failure to Identify a Weakness During an Emergency Exercise Critique Associated with an RSPS. Accordingly, Apparent Violation AV 0500280,281/2006008-01 is closed.Because plant performance for this issue has been determined to be in the regulatory responseband, we will use the NRC Action Matrix to determine the most appropriate NRC response forthis event. We will notify you by separate correspondence of that determination.In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, itsenclosures, and your response will be made available electronically for public inspection in theNRC Public Document Room or from the NRC's document system (ADAMS) which is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extentpossible, any response should not include any personal privacy, proprietary, classified, or safeguards information so that it can be made available to the Public without redaction. TheNRC also includes significant enforcement actions on its Web site at www.nrc.gov; select WhatWe Do , Enforcement , then Significant Enforcement Actions

.

VEPCO3Should you have any questions regarding this letter, please contact Mr. Brian Bonser, Chief,Security and Emergency Preparedness Branch, Division of Reactor Safety, at (404)562-4653.

Sincerely,

/RA/William D. Travers Regional AdministratorDocket Nos. 50-280 and 50-281License Nos. DPR-32 and DPR-37Enclosures: 1. Notice of Violation 2. Basis for NRC's Final Significance Determinationcc w/encls:Chris L. Funderburk, DirectorNuclear Licensing and Operations Support Virginia Electric & Power Company Electronic Mail DistributionDonald E. JerniganSite Vice President Surry Power Station Virginia Electric & Power Company Electronic Mail DistributionVirginia State Corporation CommissionDivision of Energy Regulation P. O. Box 1197 Richmond, VA 23209Lillian M. Cuoco, Esq.Senior Counsel Dominion Resources Services, Inc.

Electronic Mail DistributionAttorney GeneralSupreme Court Building 900 East Main Street Richmond, VA 23219

_________________________OFFICEORADRSNRRNSIR/EPOESIGNATURE/RA//HC/ FOR/RA//RA//RA/NAMECEVANSVMCCREERPASCARELLIRKAHLERDSOLORIODATE7/13/067/13/0607/14/0607/18/0607/20/06 E-MAIL COPY? YESNO YESNO YESNO YESNO YESNO YESNO YESNO Enclosure 1NOTICE OF VIOLATIONVirginia Electric and Power Company Docket Nos. 50-280 and 50-281Surry Nuclear Station License Nos. DPR-32 and DPR-37 Units 1 and 2 EA-06-071During an NRC inspection completed on March 29, 2006, a violation of NRC requirements wasidentified. In accordance with the NRC Enforcement Policy, the violation is listed below:10 CFR 50.47(b)(4) requires, in part, that a standard emergency classification andaction level scheme, the bases of which include facility system and effluent parameters,is in use by the nuclear facility licensee, and State and local response plans call forreliance on information provided by facility licensees for determinations of minimuminitial offsite response measures.10 CFR 50.47(b)(14) requires, in part, that periodic exercises be conducted to evaluatemajor portions of emergency response capabilities and deficiencies identified as a resultof exercises be corrected.10 CFR Part 50, Appendix E, Section IV.F.2.g, requires that all training, includingexercises, shall provide for formal critiques in order to identify weak or deficient areas that need correction. Any weaknesses or deficiencies that are identified shall be corrected.Contrary to the above, the licensee's formal critique of an emergency preparednessexercise conducted on February 7, 2006, failed to identify weak or deficient areas.

Specifically, the exercise critique failed to identify that the Station Emergency Manager'sSite Area Emergency event classification was an inaccurate classification.This violation is associated with a White significance determination process finding forUnits 1 and 2 in the Emergency Preparedness cornerstone.Pursuant to the provisions of 10 CFR 2.201, Virginia Electric and Power Company is herebyrequired to submit a written statement or explanation to the U.S. Nuclear RegulatoryCommission, ATTN: Document Control Desk, Washington, DC 20555 with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector at the facility thatis the subject of this Notice within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation; EA-06-071" and should include: (1) the reason for the violation or, if contested, the basis fordisputing the violation or severity level

(2) the corrective steps that have been taken and theresults achieved; (3) the corrective steps that will be taken to avoid further violations; and (4) the date when full compliance will be achieved. Your response may reference or includepreviously docketed correspondence if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

Notice of Violation2If you contest this enforcement action, you should also provide a copy of your response, withthe basis for your denial, to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001. Because your response will be made available electronically for public inspection in the NRCPublic Document Room or from the NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible it shouldnot include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of yourresponse that deletes such information. If you request withholding of such material, you mustspecifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information willcreate an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.In accordance with 10 CFR 19.11, you may be required to post this Notice within 2 workingdays. Dated this 25 th day of July 2006 Enclosure 2NRC'S BASIS FOR FINAL SIGNIFICANCE DETERMINATIONThe NRC's inspection report of May 5, 2006, documented the preliminary significancedetermination for a finding involving the failure of Surry Nuclear Station's full-scale exercise critique to identify a weakness associated with a risk-significant planning standard (RSPS)

which was determined to be a drill/exercise performance (DEP) - performance indicator (PI)opportunity failure. The finding was also determined to be an apparent violation associated with emergency preparedness planning standards 10 CFR 50.47(b)(14) and 10 CFR 50.47(b)(4),

and the requirements of 10 CFR Part 50, Appendix E, Section IV.F.2.g. The finding was assessed under the significance determination process (SDP) as a preliminary White issue (i.e., an issue of low to moderate safety significance which may require additional NRC inspection).In lieu of a regulatory conference, Virginia Electric and Power Company (VEPCO) provided awritten response dated June 6, 2006. VEPCO's written response documented its disagreementwith the NRC's preliminary determination that the finding rises to a level of significance of a White finding. VEPCO concluded that its drill critique correctly determined that drill pers onnelresponded to entry criteria for classifying the event in a reasonable and conservative manner and in accordance with the Emergency Action Level (EAL) procedure in effect. To support its conclusions, VEPCO provided the following four considerations:1.The "failure" determination reached by the NRC appears to be based on an overly narrowconstruct regarding the use and application of EALs for Site Area Emergency (SAE)

classification. This in turn has resulted in an associated overly narrow application of the SDP.2.A "failure" determination is not consistent with NRC regulatory action taken by the NRC inevaluations of other licensees.3.A "failure" determination is not consistent with NRC endorsed guidance.4.A detailed critique that does not find an event classification to be a failure, because theclassification is made conservatively and is consistent with the EAL's entry criteria, is not an indication that a weakness exists in the effective implementation of the Emergency Plan. Such a discrepancy is certainly not a weakness as defined in the SDP; therefore, this issue should not meet the intent nor rise to the level in the SDP process of an actualprogrammatic weakness.The NRC's response to each of the points made by the licensee is provided in the followingparagraphs:Licensee Comment No. 1 - The "failure" determination reached by the NRC appears to bebased on an overly narrow construct regarding the use and application of EALs for SAE classification. This in turn has resulted in an associated overly narrow application of the SDP.

NRC's Basis for Final2Significance DeterminationTo support its view, VEPCO noted that the NRC's inspection report made the following threeinappropriate assumptions/implications after which VEPCO provided its basis for why these assumptions were inappropriate:a.Without a second seismic event of design-basis earthquake (DBE) magnitude, the EAL wasnot usable.b.The earthquake was not validated.

c.Knowledge of the 0.13g acceleration should have caused the Emergency Director to ignoreother EAL entry conditions.NRC Response to Licensee Comment No. 1 - In the NRC's view, a key issue is whether thedamage to the safety-grade auxiliary building emergency ventilati on system (damage to the 1-VS-F-58 A and B fans) was the result of the seismic event that occurred over an hour earlier and had been terminated. VEPCO's position is that the EAL (indication) for the Notification of an Unusual Event (NOUE) could be applied for the determination of the SAE which occurred 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 50 minutes later. The licensee used the transition from the NOUE to the Alert as support for using the initial NOUE EAL as meeting one of the SAE EALs (indications).The NRC's position is that the earthquake was a discrete (discontinuous) event. Thisconclusion is supported by NUMARC/NESP-007, Methodology for Development of Emergency Action Levels, Rev. 2, which provides an earthquake as an example of a discrete (discontinuous) event. In this case, the EAL (indication) used to declare the NOUE did not exist at the time the SAE was declared.Classification of the NOUE was based on meeting the EAL (indication) confirmed earthquakewhich activates the event indicator on the strong motion accelerograph. With the eventindicator , the operators entered Procedure 0-AP-37.00, Seismic Event. When the data fromthe strong motion accelerograph was analyzed

, the classification was upgraded to an Alert. The earthquake confirmation and data collection occurred at the same time, and only theanalysis of the data delayed the declaration of the Alert.After entry into Emergency Plan Implementing Procedure (EPIP)-1.01, Emergency ManagerControlling Procedure, the applicable procedures in effect included EPIP-1.02, Response to Notification of Unusual Event; EPIP-1.03, Response to Alert; EPIP-1.04, Response to Site Area Emergency; and EPIP-1.05, Response to General Emergency. The Station Emergency Director is directed to review the EAL table and determine if the current classification is correct and to return to EPIP-1.01 for escalation and de-escalation of the emergency classification as required.EPIP-1.01, Step 1, directs the user to evaluate EALs in the following manner:a.Determine event category using Attachment 1, Emergency Action Level Table 1 Index.

b.Review EAL tab associated with event category.

NRC's Basis for Final3Significance Determinationc.Use control room monitors, process computer system (PCS), and outside reports to getindications of emergency conditions listed in the EAL table.d.Verify EAL - CURRENTLY EXCEEDED.

Each evaluation for emergency classification takes into account the classification considered,the conditions/applicability, and the existing indications for that classification at the time of theclassification. If the indications for the classification are not met at that time, then the classification or change in classification cannot be made. Based on the procedures in effect and the fact that indications for an SAE were not met at the time, the NRC concl uded thatVEPCO's change in classification to an SAE was inaccurate.Regarding the inspection report assumptions, two of the three statements the licenseeidentified as NRC assumptions are properly referenced in the following statements taken fromthe NRC report:a.Without a second seismic event of DBE magnitude, the correct classification of the turbineblading failure and damage to safety-related structures and equipment would have been at the Alert level. Since the facility was already in an Alert status, no change in the emergencyresponse level was necessary. The inspectors determined that the EAL used to make the classification by the exercise participants for SAE was an incorrect EAL classification based on the event conditions and the indications available.The licensee's analysis of the first assumption states that ...This assertion implies that the only correct way to use an EAL is for a unique event thatwould be classifiable at the moment the event occurs. This perspective is employing an event evaluation method where all of the information is revealed at the same time; however, the evaluation of a flow of events that are revealed over time is also an appropriate method for event classification.In response, the NRC notes that both EPIP-1.01 and NEI 99-02, Regulatory AssessmentPerformance Indicator Guideline, Rev. 3, clearly state that to make an event classification, the EAL (indications) must currently be exceeded for that classification. NEI 99-02 also provides guidance on actions that must be taken if the licensee discovers an event or condition had existed that exceeded an EAL, but no classification had been made, and the EAL is no longer exceeded at the time of discovery. Based on this, the NRC concluded that the earthquake wasa discrete (discontinuous) event and that the EAL (indication) used to declare the NOUE did notexist at the time the SAE was declared, approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 50 minutes later.Regarding the assumption that the earthquake was not validated, VEPCO properly referencedthis assumption as indicated by the following statement from the NRC inspection report:b.The Station Emergency Manager (SEM) assumed that a second seismic event occurredwithout validating the information from the control room alarms. The inspectors based the SEM assumption on hearing the SEM's statement during the exercise prior to the SAE declaration. The SEM made the statement after receiving reports that vibrations were felt coming from the floor/ground. Significant floor vibration is expected in the event of a turbine NRC's Basis for Final4Significance Determinationblading failure that penetrates the turbine casing. As event conditions changed that couldmeet emergency classification escalation criteria, the SEM should have evaluated the event category and selected the proper EAL tab associated with the event category.The licensee's written response stated that ...Furthermore, the EAL construction for the SAE did not require another earthquake to occureven though the SEM thought one had occurred. This action would only serve as a replication of the action that was taken to transition from the NOUE to the Alert classification.The NRC notes that the crew had received information that no damage and no flooding in theUnit 1 and 2 turbine buildings occurred as a result of the earthquake. The report of no damage detected was consistent with the facilitator interface for mini-scenario No. 1. Procedure 0-AP-37.00, Seismic Event, had been exited, and the event indicator on the strong motion accelerograph had been reset. Both actions were completed prior to the SAE declaration.Classification of the NOUE was based on meeting the EAL (indication) (confirmed earthquake)which activates the event indicator on the strong motion accelerograph. With the event indicator, the operators entered Procedure 0-AP-37.00, Seismic Event. When the data fromthe strong motion accelerograph was analyzed, the classification was upgraded to an Alert.

The earthquake confirmation and data collection occurred at the same time, and only the analysis of the data delayed the declaration of the Alert.When the turbine failure occurred, there was no earthquake that activated the event indicatoron the strong motion accelerograph, and there was no safety-related system significantlydegraded by the earthquake. Procedure 0-AP-37.00 was not entered, and the required EALs(indications) for L-1, Earthquake Greater than DBE Levels, were not met. NEI 99-02 states that if an event has occurred that resulted in an emergency classification where no EAL was exceeded, the incorrect classification should be considered a missed opportunity. EPIP-1.01, step 1.c, stated, "Use control room monitors, PCS, and outside reports to get indications of emergency conditions listed in the EAL table." Based on this, the NRC concl uded that the SAEdeclaration was made using EALs (indications for L-1) that were not exceeded.The third assumption identified in the licensee's written response of June 6, 2006, has nospecific tie to the NRC inspection report that can be found.c.The assumption that knowledge of one indication should shade or influence the use ofanother indication in the EAL structure; however, this is not the logic of many of the EAL classification schemes.Licensee Procedure DNOS-0101, Nuclear Safety and Conservative Decision Making, providesat least four standards that address this concern:*Human performance tools and group input shall be utilized to avoid inappropriate actionsand unexpected responses when reaching operating decisions.

NRC's Basis for Final5Significance Determination*Operators shall recognize when degraded conditions exist that could challenge plant safetyor reliability.*Information shall be gathered and analyzed from relevant sources and appropriatepersonnel in order to clearly define and provide options for resolution of operational concerns.*When faced with time-critical decisions, operators:*Question and validate available information.

• Utilize available alternate indications to validate information.

• Assume the available indications are valid until proven otherwise.

• Use all available resources, including people offsite, if necessary.Both EPIP-1.01 and NEI 99-02 state that to make an event classification, the EAL (indications)must currently be exceeded for that classification. Each evaluation for emergency classification takes into account the classification considered, the conditions/applicability, and the existingindications for that classification. If the EALs (indications) for the classification are not met, then the classification or change in classification cannot be made.Licensee Comment No. 2 - A "failure" determination is not consistent with NRC regulatoryaction taken by the NRC in evaluations of other licensees.The licensee provided descriptions of two events which were classified as emergencies thatwere later found to have used entry criteria to classify an event that led to an overly conservative classification. NRC Response to Licensee Comment No. 2 - Based on the NRC's followup review of the twoevents in question and the information provided by VEPCO, the NRC has concl uded thatregulatory action in these cases was in accordance with Inspection Manual Chapter (IMC) 0609, Appendix B, Emergency Preparedness Significance Determination Process. The information provided by VEPCO was not sufficient to warrant a reconsideration of the NRC'sconclusions in these two previous matters. Should additional or new information become available, the NRC would be amenable to reconsideration of these matters within the context ofthe criteria provided in NRC ICM 0609, Attachment 2.The NRC notes that the conclusions in the instant VEPCO matter are consistent with a recentenforcement action involving a White finding and associated NOV that was issued to another utility on December 16, 2005 (EA-05-192, ADAMS Accession No. ML053530049).Licensee Comment No. 3 - A "failure" determination is not consistent with NRC endorsedguidance.Based on NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Rev. 3, thelicensee stated that they reevaluated indications provided to the participants and the method of NRC's Basis for Final6Significance Determinationinterpretation and implementation of the EALs that was used. The determination of PIopportunity success was based on the fact that the indications provided were usable as supportive of an escalation to an SAE classification in this scenario.NRC Response to Licensee Comment No. 3 - NEI 99-02, Regulatory Assessment PerformanceIndicator Guideline, Rev. 3, states that ...During drill performance, the emergency response organization may not always classify anevent exactly the way that the scenario specifies. This could be due to conservative decision making, Emergency Director judgment call, or a simulator driven scenario that has the potential for multiple "forks." Situations can arise in which assessment of classification opportunities is subjective due to deviation from the expected scenario path. In such cases, evaluators should document the rationale supporting their decision for eventual NRC inspection. Evaluators must determine if the classification was appropriate to the event as presented to the participants and in accordance with the approved emergency plan and implementing procedures.The NRC observed the deviation during the graded exercise and was knowledgeable of theevents leading to the deviation. The NRC reviewed the deviation from the expected scenariopath and the licensee's rationale used to reach their decision. Additional information provided by the licensee was reviewed and incorporated into the inspection report. The NRC disagreeswith the licensee's conclusion that the classification was appropriate and in accordance with the approved emergency plan and implementing procedures, as noted previously.Licensee Comment No. 4 - A detailed critique that does not find an event classification to be afailure, because the classification is made conservatively and is consistent with the EAL's entry criteria, is not an indication that a weakness exists in the effective implementation of the Emergency Plan. Such a discrepancy is certainly not a weakness as defined in the SDP; therefore, this issue should not meet the intent nor rise to the level in the SDP process of anactual programmatic weakness.NRC Response to Licensee Comment No. 4 - IMC 0609 states, in part, that ...As applied to emergency preparedness, a weakness is a level of performancedemonstrated during a drill or exercise that could have precluded effective implementationof the Emergency Plan in the event of an actual emergency. Weaknesses are not confined to performance problems that result in a loss of planning standard (PS) function. For example, an inaccurate or untimely classification, notification, or Protective Action Recommendation (PAR) development is a weakness associated with an RSPS (i.e., a DEP PI opportunity failure) ... The NRC staff expects licensees to identify and critique thisperformance problem as a weakness associated with an RSPS. Failure to correct a weakness should be analyzed against the compliance criteria in planning standard 10 CFR 50.47(b)(14) and the Emergency Plan. A failure to identify and/or correct a weakness associated with an RSPS function represents a loss of PS function10 CFR 50.47(b)(14) for which Section 5.0 of IMC 0609, Appendix B, provides guidanceregarding the correction of weaknesses. For purposes of this SDP, this includes a deficiency, as the term is used in planning standard 10CFR 50.47(b)(14) and Section IV.F.2.g of Appendix E to 10 CFR Part 50.

NRC's Basis for Final7Significance DeterminationIf the licensee's critique fails to identify an inaccurate or untimely classification, notification,or PAR development (i.e., a DEP PI opportunity failure), it is considered a loss of PS function (white finding). This is because the licensee's capability to observe and evaluatethe process associated with an RSPS is questionable.It is the NRC's conclusion that the SAE event classification was an inaccurate classification. The licensee's critique failed to identify that the SAE declaration was made using EALs (indications) that were not exceeded at the time of the declaration. This determination isconsistent with IMC 0609.The response of the offsite response organizations (ORO) to a radiological emergency is highlydependent on the quality of the information that the licensee provides the OROs in emergencyclassification, PARs, and notifications. Conservative decision-making is highly encouraged but not when the decision may result in the public being placed at unnecessary risk due to over-conservative classifications or PARs. As such, the NRC expects licensee emergencyclassifications, PARs, and notifications to be accurate and timely. NEI 99-02 defines accurate as: "Classification and PARs appropriate to the event as specified by the approved plan and implementing procedures ..."The exercise scenario provided no valid bases for plant personnel to conclude that the turbinefailure and the consequential safety-grade ventilation system damage was the result of theseismic event which had occurred and terminated over an hour earlier. This conclusion is confirmed by the facts that the scenario developers did not envision the SAE being called underEAL L-1 and that the operators exited the seismic abnormal procedure before the SAE wasdeclared. The turbine failure was not a progression from the earlier seismic event but rather a new discrete event. As such, the NRC continues to believe that the SAE classification wasinaccurate and, therefore, a PI opportunity failure, a deficiency that was not identified in thecritique.