IR 05000280/2006502
| ML063490165 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 12/15/2006 |
| From: | Brian Bonser NRC/RGN-II/DRS/PSB1 |
| To: | Christian D Virginia Electric & Power Co (VEPCO) |
| References | |
| EA-06-071 IR-06-502 | |
| Download: ML063490165 (15) | |
Text
December 15, 2006
SUBJECT:
SURRY POWER STATION - NRC SUPPLEMENTAL INSPECTION REPORT Nos. 05000280/2006502 and 05000281/2006502
Dear Mr. Christian:
On November 15, 2006, the U.S. Nuclear Regulatory Commission (NRC) completed a supplemental inspection at your Surry Power Station. The enclosed report documents the inspection results which were discussed on November 15, 2006, with you and members of your staff.
The NRC performed this supplemental inspection to assess your evaluation of a White finding, which was also a violation of 10 CFR 50.47(b)(14) and 10 CFR 50.47(b)(4), in the Emergency Preparedness area of the Reactor Safety cornerstone. This inspection was conducted in accordance with Inspection Procedure 95001, Inspection For One Or Two White Inputs In A Strategic Performance Area, and examined 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.
Based on the results of this inspection, we concluded that you have adequately completed a root cause analysis of the issue, the failure to identify a weakness associated with a risk significant planning standard (RSPS) that was determined to be a drill and exercise performance (DEP) performance indicator (PI) opportunity failure during a full-scale exercise critique on February 9, 2006, and have identified appropriate corrective actions to prevent recurrence of the issue. No findings of significance were identified concerning the root cause evaluation and corrective actions. As a result, the violation is considered closed.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's 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: Heather Gepford for/
Brian R. Bonser, Chief Plant Support Branch 1 Division of Reactor Safety Docket Nos. 50-280, 50-281 License Nos. DPR-32 and DPR-37
Enclosure:
Inspection Report 05000280/2006502, and 05000281/2006502 w/Attachment: Supplemental Information
REGION II==
Docket Nos.:
50-280, 50-281 License Nos.:
05000280/2006502, 05000281/2006502 Licensee:
Virginia Electric and Power Company (VEPCO)
Facility:
Surry Power Station Location:
5850 Hog Island Road Surry, VA 23883 Dates:
November 13-15, 2006 Inspector:
Lee Miller, Senior Emergency Preparedness Inspector Approved by:
Brian Bonser, Chief Plant Support Branch 1 Division of Reactor Safety
SUMMARY OF FINDINGS
IR 05000280/2006502; 05000281/2006502; 11/13/2006 - 11/15/2006; Surry Power Station,
Units 1 and 2; Supplemental Inspection; IP 95001, Inspection For One Or Two White Inputs In A Strategic Performance Area.
This supplemental inspection was performed by a Senior Emergency Preparedness Inspector from Region II. No findings of significance were identified. 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.
Cornerstone: Reactor Safety
The U.S. Nuclear Regulatory Commission (NRC) performed this supplemental inspection to assess the licensees evaluation of a White finding in the Emergency Preparedness area of the Reactor Safety cornerstone. The issue that resulted in a White finding was also a violation of 10 CFR 50.47(b)(14), 10 CFR 50.47(b)(4), and the requirements of 10 CFR 50, Appendix E,
IV.F.2.g. This supplemental inspection was performed in accordance with Inspection Procedure 95001, Inspection For One Or Two White Inputs In A Strategic Performance Area.
The inspector concluded that the licensee performed an adequate evaluation of the root causes of the issue (the failure of the licensees full-scale graded Exercise Critique to identify a weakness associated with a risk significant planning standard (RSPS) that was determined to be a drill and exercise performance (DEP) performance indicator (PI) opportunity failure on February 9, 2006) and had identified appropriate corrective actions. As a result, the violation is considered closed.
The licensees evaluation of the issue identified three root causes. The first identified root cause was inadequate programmatic controls for evaluation of anticipated emergency classifications made during exercises. The second root cause was that Emergency Plan Implementing Procedure (EPIP)-1.01, Emergency Manager Controlling Procedure, Attachment 1 (EAL tabs K-10 and L-1) and associated basis documents contained errors, which affected accurate classification of missile and earthquake events. The third root cause was inadequate administrative controls and supervisory oversight to develop, review, and validate drill/exercise scenarios, including the conditions to support only the predetermined EAL tab(s).
Given this acceptable performance in addressing the condition associated with the White finding, this performance issue will not be held open beyond the normal four quarters provided in Nuclear Regulatory Commission (NRC) Inspection Manual Chapter (IMC) 0305, Operating Reactor Assessment Program.
REPORT DETAILS
INSPECTION SCOPE
The U.S. Nuclear Regulatory Commission (NRC) performed this supplemental inspection to assess the licensees evaluation of a White finding in the Emergency Preparedness area of the Reactor Safety cornerstone. The White finding, which was also a violation of 10 CFR 50.47(b)(14), 50.47(b)(4), and the requirements of 10 CFR 50, Appendix E, IV.F.2.g. was due to the failure of the licensees full-scale graded Exercise Critique to identify a weakness associated with a RSPS that was determined to be a DEP PI opportunity failure on February 9, 2006.
The inspector identified a risk-significant performance deficiency involving a failure of the licensees exercise critique process to identify a weakness associated with an RSPS that was determined to be a DEP PI opportunity failure. In the post exercise critique conducted on February 9, 2006, the licensee failed to identify that the Station Emergency Manager (SEM)declared a Site Area Emergency (SAE) when plant conditions did not support an SAE classification.
02 EVALUATION OF INSPECTION REQUIREMENTS 02.01 Problem Identification a.
Determine that the root cause evaluation identifies who (i.e., licensee, self-revealing, or NRC) identified the issue and under what conditions.
The licensee conducted a full-scale emergency exercise on February 7, 2006. The exercise included elements to test the organizations ability to determine and declare emergency classifications from Notification of Unusual Event (NOUE) through General Emergency. The exercise progressed as expected with classification of a NOUE and the Alert due to an earthquake simulated by a ground vibration message and simulator information. Approximately two hours later a floor vibration message, intended to simulate an unbalanced turbine, was provided. During subsequent evaluation of plant conditions, damage to both trains of auxiliary building exhaust fans (1-VS-F-58 A & B)was reported to the Technical Support Center (TSC). The SEM considered this floor vibration a continuation of the earthquake and declared a SAE. The exercise was continued through declaration of a General Emergency.
The exercise critique identified that classification for a SAE was made under an Emergency Action Level (EAL) tab other than that anticipated by the scenario and initiated Plant Issue S-2006-04565. Exercise participants cited that the damaged auxiliary building exhaust fans (1-VS-F-58 A & B) did not meet the anticipated EAL criteria and therefore the EAL used by the SEM was correct. The Manager, Nuclear Emergency Preparedness, determined, based in part upon guidance contained in NEI 99-02, that the EAL classification was not a DEP PI failure.
After the critique, the NRC notified the station that the declaration of a SAE should have been evaluated as a DEP PI opportunity failure and this was an apparent violation associated with emergency preparedness planning standards 10 CFR 50.47(b)(4) and 10 CFR 50.47(b)(14). The licensee initiated plant issue S-2006-1849 to implement further actions to address the NRC finding.
b.
Determine that the root cause evaluation identifies how long the issue existed, and prior opportunities for identification.
The Root Cause Evaluation S-2006-1849 indicated that the failure was specific to the 2006 Surry Emergency Preparedness Exercise critique and had not previously occurred.
The inspector agreed with the root cause evaluation conclusion that there were no prior instances in recent years at Surry Power Station of difficulties in the licensees exercise critique process to properly identify a weakness associated with a RSPS that was determined to be a DEP PI opportunity failure during a full-scale exercise.
c.
Determine that the evaluation documents the plant-specific risk consequences (as applicable) and compliance concerns associated with the issue.
The root cause demonstrated that the risk consequences associated with a mis-classification of an event is adequately understood. Station management clearly understood and appreciated the need for accurate and timely event classification, and the associated risk commensurate with an event mis-classification.
With respect to compliance concerns, the licensees evaluation acknowledged that Station Management accepted the associated NRC violation, required a root cause evaluation to be completed, and identified corrective actions to be taken.
Based on the above information, the inspector concluded that the licensees evaluations of the risk consequences and compliance concerns associated with the inaccurate SAE declaration were adequate.
02.02 Root Cause and Extent of Condition a.
Determine that the problem was evaluated using a systematic method(s) to identify root cause(s) and contributing cause(s).
The licensee's root cause evaluation utilized event and causal factors charting, barrier analysis, and change analysis. Three root causes and one contributing cause were identified. The first identified root cause was inadequate programmatic controls for evaluation of anticipated emergency classifications made during exercises. The second root cause was that Emergency Plan Implementing Procedure (EPIP)-1.01, Emergency Manager Controlling Procedure, Attachment 1 (EAL tabs K-10 and L-1) and associated basis documents contained errors, which affected accurate classification of missile and earthquake events. The third root cause was inadequate administrative controls and supervisory oversight to develop, review, and validate drill/exercise scenarios, including the conditions to support only the predetermined EAL tab(s). The contributing cause was a knowledge deficiency related to recognition of an earthquake as a discrete event.
The inspector reviewed the root cause analysis methods employed by the licensee and concluded that an adequate, formal, structured approach was utilized to identify the root and contributing causes.
b.
Determine that the root cause evaluation was conducted to a level of detail commensurate with the significance of the problem.
The licensee's root cause evaluation identified three root causes and one contributing cause. The inspector determined that the root cause evaluation was conducted to a sufficient level of detail for the issue and sufficient corrective actions were identified commensurate with the significance of the issue.
c.
Determine that the root cause evaluation included consideration of prior occurrences of the problem and knowledge of prior operating experience.
Root Cause Evaluation S-2006-1849 evaluated industry operating experience, as well as internal records to determine if similar failure of an exercise critique to identify an emergency event classification as inaccurate had occurred previously. Based on a records review of past Condition Reports or Plant Issues, the licensee did not identify prior instances.
Based upon the reviews summarized in Subsections 02.01.b and 02.02.c of this inspection report, the inspector concluded that the licensee had adequately searched for prior occurrences of the issue.
d.
Determine that the root cause evaluation addresses the extent of condition and the extent of cause of the problem.
Root Cause Evaluation S-2006-1849 included extent of condition evaluations of the issue. The licensees extent of condition considered an improper evaluation of station performance regarding EAL classification. This improper classification occurred following an exercise on February 7, 2006, in which the SEM selected an EAL tab that was different from that which was planned. An extent of condition review was performed on all Surry EP exercises for the previous five years to determine if any other drills/exercises had different than planned EAL tabs selected and were evaluated as a DEP/PI pass. There were no other cases in which other than planned EAL tab selections were made.
The Root Cause Evaluation S-2006-1849 adequately encompassed the following topics:
- (1) Inadequate programmatic controls for evaluation of incorrect EAL tab selections;
- (2) EPIP-1.01, Emergency Manager Controlling procedure errors;
- (3) Inadequate administrative controls to develop, review and validate drill/exercise scenarios. None of these evaluations resulted in the identification of prior occurrences of the issue at Surry Nuclear Power Station.
Review of EPIP-1.01 revealed a problem in EAL tab A.3. Under 'indications' states 'loss of any of the following systems:' is interpreted to mean any one of the listed systems.
The systems on the list are bulleted, which by convention would indicate that all three systems are required to be lost before the condition is satisfied. A corrective action (CA001940) to perform a complete review to address this deficiency as well as review of the remaining EAL tabs and bases was initiated.
Areas considered for extent of cause included Operations training (simulator scenario),
Security and Fire/Medical. Operations training had adequate guidance for the evaluation of the EAL tab selection with the specific criteria for past/fail. Security had controls similar to Emergency Preparedness and has a corrective action to address this issue (CA001941). Safety/Loss prevention does not have adequate guidance for evaluation of exercises and drills. This condition was addressed by corrective action CA001943.
The inspector concluded that the licensees extent of condition and extent of cause evaluations were adequate.
e.
Determine that the root cause evaluation, extent of condition, and the extent of cause appropriately considered the safety culture components has described in Inspection Manual Chapter (IMC) 0305.
The causes of this event could relate to three safety culture component areas: decision-making, resources, and work practices.
Decision-making: the SEM is responsible for making proper classification within 15 minutes following the existence of plant conditions requiring classification. This places the SEM under significant time pressure. The SEM considered the earthquake a continuous event and therefore did not reverify the indications of 'earthquake which activates the event indicator on the Strong Motion Accelerograph' by communicating with the control room prior to making the decision the indications for and SAE, and L-1 were met. The Emergency Preparedness manager made the decision that the SAE declaration based on an earthquake was not a DEP PI opportunity failure. This decision was based on his evaluation made while functioning in a knowledge-based mode. He did not have the benefit of an interdisciplinary review, and there was no procedural requirement for an independent assessment of his evaluation.
Resources: This component requires that personnel, equipment, procedures, and other resources are available and adequate to assure nuclear safety. In this case, procedures for the critique were not specific enough to cause the evaluator to arrive at a DEP PI opportunity failure. The Evaluator conducted the evaluation alone, under time pressure and without the benefit of procedurally directed evaluation criteria. The scenario developer did use a checklist for scenario development but this checklist did not contain specific guidance regarding a congruency check between indications, bases, and exercise message injects that may be interpreted to satisfy more than one indication.
The normal peer check of the scenario was not performed due to an extended illness.
Work Practices: This component requires that human error prevention techniques be communicated. In this case, a human error trap for EAL escalation based on time elapsed since the exercise start was not discussed. Therefore, when the equipment damaged was presented, this was believed by the procedure reader and SEM to be the trigger for the next EAL escalation. The scenario itself presented a human error trap by allowing a transition between two events, which while different had very similar indications.
The inspector concluded that the root cause evaluation, extent of condition, and the extent of cause appropriately considered the safety culture components.
02.03 Corrective Actions a.
Determine that appropriate corrective action(s) are specified for each root/contributing cause or that there is an evaluation that no actions are necessary.
The Root Cause Evaluation S-2006-1849 resulted in seven corrective actions that were relevant to the three root causes. The root cause evaluation identified one contributing cause and one associated corrective action. Five compensatory or short term corrective actions were identified to be completed prior to the conduct of the next drill/exercise at Surry Power Station. Five other corrective actions were identified during the extent of cause consideration.
The corrective actions provide for development of a drill and exercise critique process that ensures a thorough, documented evaluation of unanticipated emergency classifications. The evaluation will be conducted by a team consisting of members from Emergency Preparedness and SEM position qualified personnel. The evaluation results shall be reviewed and approved by Emergency Preparedness and station management.
EPIP-1.
and associated basis documents will have changes prepared and submitted, as required, to the NRC for approval proposed revisions of EALs. Both Security and Safety and Loss Prevention will revise drill development and critique evaluation critieria to ensure drill development adequacy and critique objective satisfaction. Pre-exercise briefings will emphasize the requirement for exercise facilitators to ensure accuracy in relating drill messages.
The inspector concluded that all of the corrective actions were appropriate and should be adequate to prevent recurrence of the issue.
b.
Determine that the corrective actions have been prioritized with consideration of the risk significance and regulatory compliance.
The inspector determined that the corrective action programs records contained accurate information regarding what corrective actions were completed and what other actions were ongoing. Uncompleted corrective actions were prioritized with consideration of risk significance. The inspector discussed corrective actions associated with planned changes to several EALs with the licensees emergency planning staff. The inspector was satisfied that the licensee adequately understood the need to avoid making EAL changes that could be perceived as decreasing the emergency plans effectiveness without prior NRC approval.
c.
Determine that a schedule has been established for implementing and completing the corrective actions.
The inspector determined that corrective actions should be completed on schedule, as documented in corrective action program records. The inspector discussed the status of ongoing corrective actions with the licensee. The licensee did not identify concerns that planned corrective actions would not be completed by their currently scheduled due dates. The inspector concluded that the overall schedule for completion of corrective actions was reasonable.
d.
Determine that quantitative or qualitative measures of success have been developed for determining the effectiveness of the corrective actions to prevent recurrence.
An assignment for the performance of a corrective action effectiveness review in accordance with VPAP-1601, Corrective Action, has been entered into the corrective action system (S-2006-1849-R16 and ERF 000013).
The inspector concluded that the Root Cause Evaluation S-2006-1849 included adequate provisions for an effectiveness review. The timing of this review was reasonable and is currently planned to occur in fall of 2007.
MANAGEMENT MEETINGS
Exit Meeting Summary
The inspector presented the inspection results to Mr. D. Jernigan, Surry Site Vice President, and other members of licensee management and staff at the conclusion of the inspection on November 15, 2006. The licensee acknowledged the information presented. No proprietary information was discussed.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- D. Jernigan, Site Vice President
- M. Adams, Director Nuclear Safety and Licensing
- W. Renz, Director Nuclear Protection Services & Emergency Preparedness
- J. Gram, Manager Nuclear Oversight
- B. McBride, Manager Emergency Preparedness
- B. Garber, Licensing Supervisor
- W. Matthews, Supervisor Nuclear Operations
- J. Costello, Supervisor Nuclear Emergency Preparedness
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
Opened
None.
Closed
- 05000280, 281/2006010-01 VIO White Finding Involving Failure to Identify a Weakness During an Emergency Exercise Critique Associated with an RSPS.
Discussed
None.