IR 05000247/2004007

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NRC Evaluated Emergency Preparedness Exercise - Inspection Report No. 05000247/2004007 and 05000286/2004004
ML042050026
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 07/23/2004
From: Conte R
NRC/RGN-I/DRS/OSB
To: Dacimo F
Entergy Nuclear Operations
Silk D, RGN-I/DRS/OSB, 610-337-5372
References
FOIA/PA-2006-0299 IR-04-004, IR-04-007
Download: ML042050026 (11)


Text

July 23, 2004

SUBJECT:

INDIAN POINT NUCLEAR GENERATING UNITS 2 AND 3 - NRC EVALUATED EMERGENCY PREPAREDNESS EXERCISE - INSPECTION REPORT NO.

05000247/2004007 AND 05000286/2004004

Dear Mr. Dacimo:

On June 11, 2004, the US Nuclear Regulatory Commission (NRC) completed an inspection at your Indian Point Energy Center. The enclosed inspection report documents the inspection findings, which were discussed on June 11, 2004, with yourself and other members of your staff.

The inspection examined the emergency preparedness exercise conducted on June 8, 2004, and the related activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, no findings of significance were identified.

In accordance with 10CFR2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Richard J. Conte, Chief Operational Safety Branch Division of Reactor Safety Docket Nos.

50-247, 50-286 License Nos. DPR-26, DPR-64

Enclosure:

Inspection Report No. 05000247/2004007 and 05000286/2004004 w/Attachment: Supplemental Information

REGION I

REGION I

Docket Nos:

50-247, 50-286 License Nos:

DPR-26, DPR-64 Report No:

05000247/2004007 and 05000286/2004004 Licensee:

Entergy Nuclear Northeast Facility:

Indian Point Energy Center Location:

Buchanan, New York Dates:

June 7 - 11, 2004 Inspectors:

D. Silk, Sr. Emergency Preparedness Inspector Division of Reactor Safety (DRS), (Lead)

M. Buckley, Security Risk Analyst, Office of Nuclear Security and Incident Response G. Hunegs, Sr. Resident Inspector, Nine Mile Point, Division of Reactor Projects (DRP)

L. James, Reactor Operations Engineer, Office of Nuclear Reactor Regulation (NRR)

R. Kahler, Emergency Preparedness Specialist, Emergency Preparedness Project Office, NRR J. Noggle, Health Physicist, DRS B. Norris, Sr. Reactor Engineer, DRS W. Raymond, Sr. Resident Inspector, Pilgrim, DRP D. Schneck, Emergency Preparedness Specialist, Emergency Preparedness Project Office, NRR Approved by:

Richard J. Conte, Chief Operational Safety Branch Division of Reactor Safety

Enclosure ii SUMMARY OF FINDINGS IR 05000247/2004007 and 05000286/2004004; 06/07-06/11/2004; Indian Point Nuclear Generating Units 2 and 3; Emergency Preparedness Exercise.

This inspection was conducted by region-based inspectors, resident inspectors from other Region I sites, and specialists from NRC headquarters. No findings of significance were identified using IMC 0609, Significance Determination Process (SDP). The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.

A.

NRC-Identified Findings Cornerstone: Emergency Preparedness None.

B.

Licensee-Identified Findings None.

Enclosure Report Details 1.

REACTOR SAFETY Cornerstone: Emergency Preparedness (EP)

1EP1 Exercise Evaluation (71114.01)

a.

Inspection Scope This inspection activity represents the completion of one sample on a biennial cycle.

Prior to the exercise, an in-office review was conducted of the exercise objectives and scenario submitted to the NRC to determine if the exercise would test major elements of the emergency plan as required by 10 CFR 50.47(b)(14). The inspectors reviewed various opportunities for aspects of dose assessment functions to be demonstrated, such as performing what if calculations, assessing radiation monitor readings, and deploying and coordinating field monitoring teams. Furthermore, the inspectors reviewed licensee drill reports since the last biennial exercise on September 24, 2002 which documented five drills or exercises in which radiological releases were simulated.

(In two cases offsite agencies participated, the most recent case being on May 12, 2004).

During this inspection, the adequacy of Entergys performance in the biennial full-participation exercise was reviewed and assessed regarding the implementation of the risk-significant planning standards (RSPS) in 10 CFR 50.47 (b) (4), (5), (9) & (10), which are emergency classification, offsite notification, radiological assessment, and protective action recommendations, respectively. Other performance areas besides the RSPS were evaluated, such as the emergency response organizations (ERO) recognition of abnormal plant conditions and indications, command and control, intra-and inter-facility communications, prioritization of mitigation activities, utilization of repair and field monitoring teams, interface with offsite agencies, and the overall implementation of the emergency plan and its implementing procedures.

The overall adequacy of Entergys emergency response facilities were compared to NUREG-0696, Functional Criteria for Emergency Response Facilities and Emergency Plan commitments. The facilities assessed were the: simulator (SCR); Technical Support Center (TSC); Operations Support Center (OSC); Emergency Operations Facility (EOF); and Joint News Center (JNC). Other facilities that were observed with respect to integration with the emergency response facilities were the Central Alarm Station (CAS) and Incident Command Post (ICP).

Because Entergy now has a common TSC/OSC (located in Unit 2's TSC/OSC area),

additional inspection effort focused on this change. Inspectors assessed an emergency planning 50.54(q) review document titled "Integrated TSC/OSC" and Engineering Report No. Indian Point 3 - RPT-04-00023, Integration of Indian Point 2 & 3 Technical Support Centers. Inspectors also reviewed the portions of the May 12, 2004, drill report pertaining to the common TSC/OSC. These facilities were compared with NUREG 0696.

Enclosure The inspectors verified that the walking time from Unit 3 to the common TSC/OSC was approximately two minutes. Inspectors observed this exercise to note challenges with the conduct of performance in the integrated TSC/OSC.

An inspector observed and assessed the CAS and the ICP communications with on-site emergency response facilities and off-site federal, state, and local agencies with attention to communication techniques, protocols, procedure use, and equipment operation and reliability. Also, licensee securitys response to the exercise information was observed and Entergys control of distractions imposed on the security force, particularly the CAS personnel, during the exercise activities was evaluated to verify that the security force maintained site physical protection and access control throughout the exercise. Emergency procedures were reviewed for actions expected to be accomplished or simulated by the security force during the exercise. These activities were compared to the security performance objectives for the exercise.

Activities in the JNC located at Westchester County Airport were observed and evaluated during the exercise. In particular, the NRC observed the licensees ability to obtain and prioritize accurate, timely information for inclusion in upcoming news releases and briefings while being sensitive to the needs of the public. The NRC observed the pre-briefings (to ensure prioritization of matters affecting public health and safety) as well as the coordination of news briefings. The licensees ability to disseminate timely and accurate information from the JNC was previously identified as a finding during an actual event in 2000 and in the September 2002 biennial evaluated exercise. The NRC focused on licensee corrective action in this area. Specifically, a revised process was in place to immediately notify the spokespersons of significant changes in issues affecting public health and safety during the conduct of the news briefings. (The news briefing coordinator was in contact with the licensees JNC staff in the working room via headset and was to be immediately informed if a significant event occurred.) Overall, the NRC observed and evaluated the ability of the licensee to disseminate timely and accurate information from the JNC.

The activities at the main control cell (located at the Alternate EOF) were monitored which included the coordination of cues to the players for the ERO, the state and counties, and the federal agencies. Also monitored were the timelines between the facilities, especially after a time-advance was used in the scenario, and the general information that was being given to the individual controllers in the field and any information that was passed to the players as part of the scenario. To enhance the evaluation teams ability to monitor key events and player actions, NRC evaluators in the SCR, TSC, EOF and AEOF were in communication via a phone bridge.

Past performance issues from NRC inspection reports and Entergys drill reports were reviewed to determine the effectiveness of corrective actions as demonstrated during this exercise to ensure compliance with 10CFR50.47(b)(14). Also, the immediate post-exercise facility debriefs and final critique was observed to evaluate Entergys self-assessment of its EROs performance during the exercise and to ensure compliance with 10CFR50 Appendix E.IV.F.2.g.

b.

Findings

Enclosure No findings of significance were identified.

4.

OTHER ACTIVITIES (OA)

4OA1 Performance Indicator (PI) Verification (71151)

a.

Inspection Scope The inspectors reviewed the licensees procedure for developing the data for the EP PIs which are: (1) Drill and Exercise Performance (DEP); (2) ERO Drill Participation; and (3) ANS Reliability. The inspector reviewed documentation from drills in 2003 and 2004 and ANS testing results to verify the accuracy of the reported data. Data generated since the July 2003 EP PI verification was reviewed during this inspection. The review of these performance indicators was conducted in accordance with NRC Inspection Procedure 71151. The acceptance criteria used for the review were 10 CFR 50.9 and NEI 99-02, Revision 2, Regulatory Assessment Performance Indicator Guidelines.

b.

Findings No findings of significance were identified.

4OA2 Identification and Resolution of Problems (71152: PI&R Sample)

a.

Inspection Scope The inspectors reviewed Entergys critique findings as documented in condition reports and drill reports from 2002 through 2004. This review was conducted to determine if significant performance trends exist and to determine the effectiveness of licensee corrective actions based upon ERO performance during this exercise. The inspectors verified that issues identified during this exercise were entered into Entergys corrective action program. These items are listed in the attachment to this report. NRC Inspection Procedure 71114, Attachment 01; 10 CFR 50.47(b)(14); and Appendix E IV.F.2.g were used as reference criteria.

b.

Findings and Observations No findings of significance were identified.

40A6 Meetings, Including Exit The inspectors presented the inspection results to Mr. F. Dacimo, Site Vice President, and other members of the licensees staff at the conclusion of the inspection on June 11, 2004. The licensee had no objections to the NRC observations. No proprietary information was provided to the inspectors during this inspection.

Attachment A-1 SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT Licensee Personnel F. Inzirillo, Emergency Preparedness Manager LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened, Closed, Discussed None LIST OF DOCUMENTS REVIEWED Section 1EP1: Exercise Evaluation NUREG-0696, Functional Criteria for Emergency Response Facilities Emergency Plan Section B: Station Emergency Response Organization Emergency Plan Section E: Notification Methods and Procedures Emergency Plan Section F: Emergency Communications Emergency Plan Section G: Public Education and Information Emergency Plan Section H: Emergency Facilities and Equipment Emergency Plan Section J: Protective Response IP-EP-120, Emergency Classification IP-EP-130, Emergency Notification and Mobilization IP-EP-213, Unit 3 Control Room IP-EP-222, Technical Support Center IP-EP-232, Operations Support Center IP-EP-250, Emergency Operations Facility IP-EP-410, Protective Action Recommendations IP-1055, Fire Emergency Response ONOP-SEC-1, Response to Security Compromise Emergency Preparedness FEMA Exercise Unit 2 September 24, 2002 IPEC 2004 IPEC Full Participation Exercise Scenario Section 4OA1:Performance Indicator Verification IP-EP-AD5, Emergency Preparedness Performance Indicator Program, Rev 1

A-2 Attachment Section 40A2: Identification and Resolution of Problems Condition Reports IP2-2004-02664 Siren sound unfamiliar associated with announcement of incoming plane IP2-2004-02669 Plant page could not be heard in OSC, TSC, and EOF IP2-2004-02694 Plant page could not be heard at Unit 2 dock near the cafeteria IP3-2004-02082 10CFR50.54(x) should have been implemented during the exercise IP3-2004-02083 Protocol for bringing in fire fight assistance - control room or ICP IP3-2004-02084 Develop pre-planned activities to cross-tie power from other unit IP3-2004-02086 Communication of upgrade security classification was not timely IP3-2004-02116 Drill report for exercise is to be developed IP3-2004-02403 Consider more realism in drill regarding fire fighting activities LIST OF ACRONYMS AEOF Alternate Emergency Operations Facility ANS Alert and Notification System CAS Central Alarm Station CFR Code of Federal Regulations EAL Emergency Action Level ERO Emergency Response Organization EOF Emergency Operations Facility EP Emergency Preparedness ERO Emergency Response Organization ICP Incident Command Post JNC Joint News Center OSC Operations Support Center PI Performance Indicator RSPS Risk Significant Planning Standard SCR Simulator TSC Technical Support Center