IR 05000245/2012503
| ML12324A008 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 11/16/2012 |
| From: | Anthony Dimitriadis Plant Support Branch 1 |
| To: | Heacock D A Dominion Resources |
| References | |
| IR-12-503 | |
| Download: ML12324A008 (12) | |
Text
November L6, 28LZMr. David A. HeacockPresident and Chief Nuclear OfficerDominion Resources5000 Dominion Blvd.Glen Allen, VA 23060-6711
SUBJECT: MILLSTONE POWER STATION, UNITS 2 AND 3 - NRC EVALUATEDEMERGENCY PREPAREDNESS EXERCISE - INSPECTION REPORT NOS.05000336/2012503 AN D 05000 423t201 2503
Dear Mr. Heacock:
On October 4,2012,the U.S. Nuclear Regulatory Commission (NRC) completed an inspectionat your Millstone Power Station, Units 2 and 3. The enclosed inspection report documents theinspection results, which were discussed in a debrief meeting on August 24, 2012, withStephen E. Scace, Site Vice President, and other members of your stafl A final exit meetingwas conducted via a telephone conference on October 4,2012, also with Mr. Scace and othermembers of your staff.The inspection examined activities conducted under your license as they relate to safety andcompliance with the Commission's rules and regulations and with the conditions of your license.The inspectors reviewed selected procedures and records, observed activities, and interviewedpersonnel.The enclosed inspection report documents one NRC-identified finding of very low safetysignificance (Green). This finding was determined to involve a violation of NRC requirements.However, because of the very low safety significance and because it has been entered into thecorrective action program (CAP), the NRC is treating this violation as a non-cited violation(NCV) consistent with Section 2.3.2 of the Enforcement Policy. lf you contest the finding in thisieport, you should provide a response within 30 days of the date of this inspection report, withtfrb basls for your denial, to the U.S. Nuclear Regulatory Commission, ATTN.: DocumentControl Deskl Washington, DC 20555-0001; with copies to the Regional Administrator, Region l;the Director, Office of Enforcement, United States Nuclear Regulatory Commission,Washington, DC 20555-0001; and the NRC Resident lnspector at Millstone. Additionally, if youdisagree with the cross-cutting aspect assignment in this report, you should provide a responsewithin 30 days of the date of this inspection report, with the basis for your disagreement, to theRegionalAdministrator, Region l, and the Millstone NRC Resident Inspector. ln accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, itsenclosure, and your response (if any) will be available electronically for public inspection in theNRC Public Document Room and from the Publicly Available Records (PARS) component ofNRC's Agencywide Documents Access and Management System (ADAMS). ADAMS isaccessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the PublicElectronic Reading Room).Plant Support Branch 1Division of Reactor SafetyDocket Nos. 50-336, 50423License Nos. DPR-65, NPF-49
Enclosure:
NRC lnspection Report Nos. 05000336/2012503 and 0500042312012503
w/Attachment:
Supplemental Informationcc w/encl:S. Coleman, RAC, FEMA Region Icc w/encl: Distribution via ListServ ln accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, itsenclosure, and your response (if any) will be available electronically for public inspection in theNRC Public Document Room and from the Publicly Available Records (PARS) component ofNRC's Agencywide Documents Access and Management System (ADAMS). ADAMS isaccessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the PublicElectronic Reading Room).
Sincerely,/RNAnthony Dimitriadis, ChiefPlant Support Branch 1Division of Reactor SafetyDocket Nos. 50-336, 50-423License Nos. DPR-65, NPF-49
Enclosure:
NRC lnspection Report Nos. 05000336/2012503 and 0500042312012503
w/Attachment:
Supplemental Informationcc w/encl:S. Coleman, RAC, FEMA Region Icc w/encl: Distribution via ListServDOCUMENT NAME: GIDRS\Plant Support Branch 1\Barr\EP Ex12 Millstone\Millstone EP EX 2012 Report.docxADAMS ACCESSI()N NUMBER: ML123241\UUUV suNslReviewg Non-Sensitive! SensitiveV Publicly Available! Non-PubliclyAvailableOFFICERI/DRSRI/DRPRI/DRSNAMESBarr/KH forRBellamy/TCS forADimitriadisDATE11t16t1211t16t1211t16t12FOFFICIAL Distribution w/encl: (via E-mail)W. Dean, RA (RIORAMAIL RESOURCE)D. Lew, DRA (RIORAMAIL RESOURCE)D. Roberts, DRP (RIDRPMAIL Resource)P. Wilson, DRP (RIDRPMAIL Resource)C. Miller, DRS (RIDRSMAIL RESOURCE)J. Clifford, DRS (RIDRSMAIL RESOURCE)C. Santos, Rl OEDOR. Bellamy, DRPT. Setzer, DRPE. Keighley, DRPJ. DeBoer, DRPJ. Ambrosini, DRP, SRIB. Haagensen, DRP, RlJ. Krafty, DRP, RlC. Kowalyshyn, MRidsNrrPMMillstone ResourceRidsNrrDorlLpl 1 -1 ResourceROPreports ResourceR. Kahler, NSIRYEPDS. LaVie, NSIRYEPDD. Bearde, DRSS. Barr, DRSA. Dimitriadis, DRS Docket No.:License No.:Report No.:Licensee:Facility:Location:Dates:Inspectors:Approved by:U.S. NUCLEAR REGULATORY COMMISSIONREGION I50-336, 50-423DPR-65, NPF-4905000336/201 2503 and 05000 423 1201 2503Dominion Nuclear Connecticut, Inc.Millstone Nuclear Power Station, Units 2 and 3Waterford, CT 06385August 2A,2012 - October 4,2012S. Barr, Senior Emergency Preparedness Inspector, DRS, Region I (Lead)J. Ambrosini, Senior Resident lnspector, DRP, Region IB. Haagensen, Resident Inspector, DRP, Region IS. LaVie, Senior Emergency Preparedness Specialist, NSIRW. Lange, Emergency Preparedness Specialist, NSIR (Observer)Anthony Dimitriadis, ChiefPlant Support Branch 1Division of Reactor SafetyEnclosure
SUMMARY OF FINDINGS
lR 0500033612012503, 05000423120125A3;812012012-101412012; Millstone Power Station,Units 2 and 3; Emergency Preparedness Exercise Evaluation.This was an announced inspection conducted by one region-based inspector, two residentinspectors, and one headquarters-based inspector. One finding of very low safety significance(Green) was identified. The significance of most findings is indicated by their color (Green,White, Yellow, Red) using Inspection Manual Chapter (lMC) 0609, "Significance DeterminationProcess" (SDP). The cross-cutting aspect was determined using IMC 0310, "ComponentsWithin the Cross Cutting Areas." Findings for which the SDP does not apply may be Green orbe assigned a severity level after NRC management review. The NRC's program foroverseeing the safe operation of commercial nuclear power reactors is described inNUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.Gornerstone: Emergency Preparedness. @. The NRC identified a non-cited violation (NCV) associated with emergencypreparedness planning standard 10 CFR 50.47(b)(4), and the requirements ofSections lV.B and lV.C of Appendix E to 10 CFR Part 50. Specifically, Dominion did notmaintain in effect the Millstone Units 2 and 3 emergency action level (EAL) schemes bynot providing operations procedures for obtaining reactor coolant samples once a safetyinjection signal has occurred. These deficiencies adversely affected the ability of thelicensee to properly classify events involving the loss of the fuel clad fission productbarrier.The inspection team determined that the failure by Dominion to provide the properoperating procedures for operators to adequately implement their respective unit's EALswas a performance deficiency that was reasonably within their ability to foresee andprevent. The finding is more than minor because it is associated with the emergencyresponse organization (ERO) attribute of the Emergency Preparedness Cornerstone andaffected the cornerstone objective to ensure that the licensee is capable of implementingadequate measures to protect the health and safety of the public in the event of aradiological emergency. The inspectors evaluated this finding using the EmergencyPreparedness Significance Determination Process (Appendix B to IMC 0609) anddetermined the finding to be of very low safety significance (Green). Appendix B toIMC 0609, Section 5.4, and Table 5.4-1, were used to reach this determination. Theinspector determined that this finding involved an example where an EAL has beenrendered ineffective such that any Site Area Emergency would not be declared for aparticular off-normal event, but because of other EALs, an appropriate declaration couldbe made in a degraded manner (e.9., delayed). The finding is related to the cross-cutting area of Problem ldentification and Resolution, Corrective Action Program, in thatDominion personnel did not take appropriate corrective actions to address a Risk-Significant Planning Standard (RSPS) issue completely, accurately, and in a timelymanner commensurate with the safety significance P.1(d). Specifically, Dominion didnot place this issue into the corrective action program and take appropriate action untilprompted by the NRC team's findings.(Section 1EP1) iiEnclosure
REPORT DETAILS
1. REACTORSAFETYCornerstone: Emergency Preparedness (EP)1EP1 Exercise Evaluation (71114.01- 1 sample)a. Inspection ScopePrior to the August 21,2012, emergency preparedness exercise, the NRC inspectorsconducted an in-office review of the exercise objectives and scenario, which Dominionhad submitted to the NRC, to determine if the exercise would test major elements of theMillstone Power Station Emergency Plan as required by 10 CFR 50.47(bX1a). Thisoverall exercise inspection activity represented the completion of one sample on abiennial cycle.The exercise evaluation consisted of the following review and assessment:. The adequacy of Dominion's performance in the biennial full-participation exerciseregarding the implementation of the risk-significant planning standards (RSPS)described in 10 CFR 50.47(bX4), (5), (9), and (10), which are: emergencyclassification; offsite notification; radiological assessment; and protective actionrecommendations, respectively.. The overall adequacy of Dominion's Millstone emergency response facilities withregard to NUREG-0696, "Functional Criteria for Emergency Response Facilities,"and Emergency Plan commitments. The facilities assessed were the Control RoomSimulator, Operations Support Center (OSC), Technical Support Center (TSC), andEmergency Operations Facility (EOF).r A review of other performance areas, such as: the Millstone emergency responseorganization's (ERO's) recognition of abnormal plant conditions; command andcontrol; intra- and inter-facility communications; prioritization of mitigating activities;utilization of repair and field monitoring teams; interface with offsite agencies;staffing and procedure adequacy; and the overall implementation of the emergencyplan and its implementing procedures.o fi review of past performance issues from the last NRC Millstone exerciseinspection report and Dominion's Millstone EP drill reports, to determine theeffectiveness of licensee corective actions as demonstrated during the August 21,2012, exercise and to ensure compliance with 10 CFR 50.47(bX14).. The licensee's post-exercise critiques, to evaluate Dominion's self-assessment ofits ERO performance during the August 21,2012, exercise and to ensurecompliance with 10 CFR 50, Appendix E, Section lV.F.2.g.Enclosure b.2The inspectors reviewed the documents listed in the attachment to this report.FindinosIntroduction. The NRC identified an NCV associated with emergency preparednessplanning standard 10 CFR 50.47(bX4), and the requirements of Sections lV.B and lV.Cof Appendix E to 10 CFR Part 50. Specifically, Dominion did not maintain in effect theMillstone Units 2 and 3 emergency action level (EAL) schemes for assessing the loss ofthe fuel clad barrier.Description. On August 21,2012, the NRC inspection team observed the DominionMillstone Unit 3 full scale emergency planning exercise. The exercise scenario includedthe failure of a reactor coolant pump, which discharged a loose part into the reactorcoolant system (RCS). The loose part, in turn, damaged the reactor fuel and a steamgenerator tube. Per the scenario, the damage to the fuel was intended for the ERO todiagnose a loss of the fuel clad barrier, and the damage to the steam generator tube aloss of the RCS. The basis for the ERO's conclusion that the fuel clad barrier was lostwas a dose rate at one foot from an unpressurized RCS sample. The obtaining of theRCS sample during the exercise was simulated, and the sample results were provided tothe ERO by a licensee drill controller.The NRC inspector in the control room simulator identified a discrepancy with theexercise scenario and the actions of the drill controller. During the scenario, anexpected safety injection signal had occurred, and one of the automatic actions of thissignal is the isolation of the non-safety header of the reactor plant closed cooling water(RPCCW) system. The non-safety header of RPCCW provides the cooling water to theRCS sample sink, which is required to obtain an RCS sample. The inspector identifiedthat without the RCS sample, the ERO would not have been able to diagnose the loss ofthe fuel clad barrier as provided in the scenario.Further investigation by the inspector determined that the Unit 3 emergency operatingprocedures (EOPs) do not provide direction in a timely manner to un-isolate the RPCCWto the RCS sample cooler or the post accident sampling system. The inspector alsodetermined that a similar situation existed with the Millstone Unit 2 EALs, in that Unit 2'sreactor building component cooling water isolates in a similar manner and would preventthe timely gathering and assessment of a RCS sample for EAL purposes. The licenseehad earlier opportunities to identify this discrepancy with both units. In 2004, thelicensee initiated CR-04-08128, which identified that the Unit 2 RBCCW would isolate ona safety injection signal. In 2008, Dominion staff initiated CR-08-06929, which identifiedthat RPCCW isolates on a safety injection signal and sampling would not be possible.Dominion responded to the inspector's concerns by stating that, for Unit 3, EOP 35 E-3,Steam Generator Tube Rupture, Step 33, has steps to un-isolate RPCCW for samplingpurposes. For Unit 2, chemistry procedure CP 2802N, Primary Systems Sampling andAnalysis, provides guidance for a chemistry technician to contact the control room ifsampling is required when RBCCW has isolated. The inspector determined that whilethese procedures may provide guidance on how to correct the EAL deficiency, neitherprocedure would be readily referred to by operators involved in mitigating an emergencyEnclosure 3event. The inspector did determine, however, that other thresholds in the Fuel CladBarrier EAL would eventually allow the operators to determine that barrier had failed.The NRC identified during this inspection that Dominion had failed to properly recognizeand correct the deficiencies in both units' operating procedures that rendered the "doserate at one foot from an unpressurized RCS sample" EAL impracticable for a scenariosuch as that presented in the Unit 3 EP exercise scenario. This type of scenario, inwhich one initiating event could reasonably cause the loss of two fission productbarriers, could result in the declaration of a Site Area Emergency (SAE).In response to the issues identified by the inspector, Dominion entered this issue intotheir corrective action plan and initiated CR-12-485651 to address the deficienciesidentified by the inspector.Analvsis. The inspection team determined that the failure by Dominion to provide theproper operating procedures for operators to adequately implement their respectiveunit's EALs was a performance deficiency that was reasonably within their ability toforesee and prevent. The finding is more than minor because it is associated with theEmergency Response Organization (ERO) attribute of the Emergency Preparednesscornerstone and affected the cornerstone objective to ensure that the licensee iscapable of implementing adequate measures to protect the health and safety of thepublic in the event of a radiological emergency.The inspectors evaluated this finding using the Emergency Preparedness SignificanceDetermination Process (Appendix B to IMC 0609) and determined the finding to be ofvery low safety significance (Green). Appendix B to IMC 0609, Section 5.4, andTable 5.4-1, were used to reach this determination. The inspector determined that thisfinding involved an example where an EAL has been rendered ineffective such that anySAE would not be declared for a particular off-normal event, but because of other EALs,an appropriate declaration could be made in a degraded manner (e.9., delayed), aGreen finding per Table 5.4-1.The finding is related to the cross-cutting area of Problem ldentification and Resolution,Corrective Action Program, in that Dominion personnel did not take appropriatecorrective actions to address the RSPS issue completely, accurately, and in a timelymanner commensurate with the safety significance P.1(d). Specifically, Dominion didnot place this issue into the corrective action program and take appropriate action untilprompted by the NRC team's findings.Enforcement. Title 10 of the Code of Federal Regulations (CFR), Section 50.54(q)(2)requires, in part, that a licensee shallfollow and maintain the effectiveness of anemergency plan that meets the requirements in Appendix E to this Part and, for nuclearpower reactor licensees, the planning standards of $ 50.47(b).10 CFR 50.47(bX4) requires, in part, that a standard emergency classification and actionlevel scheme is in use by the licensee, the bases of which include facility system andeffluent parameters.Enclosure 4Contrary to the above, Dominion did not follow and maintain an emergency plan using astandard emergency classification and action level scheme. Specifically, Dominion didnot provide adequate operating procedures to adequately implement the Fuel CladdingBarrier of the Unit 2 and Unit 3 EAL tables. As a result, this deficiency adverselyaffected licensee's ability to classify an emergency event involving failures of fissionproduct barriers. Because this issue was of very low safety significance (Green) andhas been entered into the CAP (CR-12-485651), this issue is being treated as an NCV,consistent with the NRC's Enforcement policy. (NCV 05000336/2012503-001 and05000423/2012503-001, Failure to Adequately lmplement Fuel Glad Barrier EALs)4. OTHER ACTTVTTlES (OA)4OA1 Performance Indicator (Pl) Verification (71151- 3 samples)a. Inspection ScopeThe inspectors reviewed data for the Millstone EP Pls, which are: (1) Drill and ExercisePerformance (DEP); (2) Emergency Response Organization (ERO) Drill Participation;and, (3) Alert and Notification System (ANS) Reliability. The last NRC EP inspection atMillstone was conducted in August 2011, so the inspectors reviewed supportingdocumentation from EP drills, training records, and equipment tests from the thirdcalendar quarter of 2011 through the second quarter of 2Q12, to verify the accuracy ofthe reported Pl data. The review of these Pls was conducted in accordance with NRCInspection Procedure 71151, using the acceptance criteria documented in NEI 99-02,"Regulatory Assessment Performance lndicator Guidelines," Revision 6. This inspectionactivity represented the completion of three samples.b. FindinosNo findings were identified.4OAO Meetinos. includinq ExitOn August 24,2012, the inspectors presented the preliminary results of this inspectionto Mr. S. Scace, Millstone Site Vice President, and other members of the Dominion staff.On October 4,2012, the inspectors conducted a phone teleconference exit meeting, alsowith Mr. Scace and other members of the Dominion staff. No proprietary informationwas provided to the inspectors during this inspection.Enclosure A-1ATTACHMENT
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- S. Scace, Site Vice President
- D. Smith, Emergency Preparedness Manager
LIST OF ITEMS
OPENED, GLOSED, AND DISCUSSEDOpened05000336 and 05000 42312012503-00 1
LIST OF DOCUMENTS REVIEWED
Section 1EPl: Exercise EvaluationMillstone August 21,2012, Emergency Exercise Data PackageMillstone Power Station Emergency Plan, Revision 44Millstone Emergency Response Drill Reports, January 2011 - August 2012Millstone Power Station Emergency Plan lmplementing ProceduresMillstone Power Station Emergency Plan Administrative ProceduresEOP 35
- E-3, Steam Generator Tube Rupture, Revision 23CP 2802N, Primary Systems Sampling and Analysis, Revision 001-04Condition Reports:
- CR-04-081 28;
- CR-08-06929;
- CR-12-485651Section 4OA{ : Performance Indicator VerificationEP-AA-1 03, Emergency Preparedness Performance lndicators, Revision 2ERO Drill Participation Pl data, July 2011 - June 2012Alert Notification System Pl data, July 2011 - June 2012DEP Pl data, July 2011 - June 2012NCV Failure to Adequately lmplement Fuel CladBarrier EALsAttachment
- ADAMSANSCFRCRDEPDRPDRSEALEOFEOPEPEROtMcNCVNEINRCoscPARSPIRCSRPCCWRSPSSAESDPTSCA-2
LIST OF ACRONYMS
Agencywide Documents Access and Management SystemAlert and Notification SystemCode of Federal RegulationsCondition ReportDrill and Exercise PerformanceDivision of Reactor ProjectsDivision of Reactor SafetyEmergency Action LevelEmergency Operations FacilityEmergency Operating ProceduresEmergency PreparednessEmergency Response Organizationlnspection Manual ChapterNon-Cited ViolationNuclear Energy InstituteNuclear Regulatory CommissionOperations Support CenterPublicly Available RecordsPerformance lndicatorReactor Coolant SystemReactor Plant Closed Cooling WaterRisk Significant Planning StandardSight Area EmergencySignificance Determination ProcessTechnical Support CenterAttachment