IR 05000324/2010007
| ML102930092 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 10/20/2010 |
| From: | Chris Miller Division of Reactor Safety II |
| To: | Annacone M Progress Energy Carolinas |
| References | |
| EA-10-192 IR-10-007 | |
| Download: ML102930092 (27) | |
Text
October 20, 2010
SUBJECT:
BRUNSWICK STEAM ELECTRIC PLANT - NRC SPECIAL INSPECTION REPORT 05000325/2010007 AND 05000324/2010007; PRELIMINARY WHITE FINDING
Dear Mr. Annacone:
On September 29, 2010, the U. S. Nuclear Regulatory Commission (NRC) completed a Special Inspection at your Brunswick Steam Electric Plant, Units 1 and 2. The purpose of this inspection was to inspect and asses the delay in augmentation of on-shift emergency response staffing for activation of your emergency response facilities following the declaration of an Alert at the Brunswick Steam Electric Plant on June 6, 2010. A Special Inspection was warranted based on the risk and deterministic criteria specified in Management Directive 8.3, NRC Incident Investigation Program.
The enclosed inspection report documents the inspection findings, which were discussed on September 29, 2010, with you and other members of your staff by teleconference. The determination that the inspection would be conducted was made by the NRC on June 7, 2010, and the inspection was started on June 9, 2010.
The inspection was performed in accordance with Inspection Procedure 93812, Special Inspection, and focused on the areas discussed in the inspection charter described in the report. The inspection 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. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
This letter transmits one NRC identified finding that, using the emergency preparedness Significance Determination Process (SDP), has preliminarily been determined to be White, a finding with low to moderate safety significance. The finding is associated with the failure to meet 10 CFR 50.54(q) which requires that a facility follow and maintain in effect Emergency Plans which meet the standards in 10 CFR 50.47(b). Specifically, the requirements of 10 CFR 50.47(b)(2), to provide adequate staffing for initial facility accident response through timely augmentation of on-shift staffing following the declaration of an Alert on June 6, 2010. The
inspectors determined that the failure to provide initial facility accident response through timely augmentation of on-shift staffing uncovered some programmatic weaknesses in the maintenance of the Brunswick emergency plan. The inspectors determined that the implementing procedures for ERO notification, the training of the Control Room Site Emergency Coordinator (CR-SEC), the Control Room Emergency Communicator and Security, and the priorities of the ERO were inadequate to support the required timely augmentation capability of the on-shift personnel after the declaration of an emergency as required by planning standard 10 CFR 50.47(b)(2).
This finding was assessed using Inspection Manual Chapter (IMC) 0609, Appendix B, Emergency Preparedness Significance Determination Process (EP SDP). Section 2.2 describes the EP SDP as having two distinct branches for Failure to Comply (Sheet 1) and for Actual Event Implementation Problem (Sheet 2), that findings should be assessed through both paths and the most significant finding issued. Section 3.1 states in part that a failure to implement is not always a result of a performance problem and may reveal that a program element is not adequate. In that case, inspection should determine whether there is a loss of planning standard (PS) function. Resulting issues would be assessed for significance in accordance with the criteria for a loss of PS function. Section 4.0 states, in part, that a loss of PS function means that program elements are not adequate, not compliant with the planning standards of 10 CFR 50.47(b), or otherwise not functional to such an extent that the function of the planning standard is not available for emergency response. The loss of PS function may be that the Emergency Plan commitments are not met or are inadequate, implementing procedures are inadequate, program design is inadequate, training is inadequate, etc. The result is that if the suspect program element was implemented as designed, or personnel are not capable of implementing the program element, the PS function would not be met. The inspectors determined that the planning standard function failure was a loss of planning standard function, Process for timely augmentation of on-shift staff is established and maintained. Using Sheet 1, Failure to Comply, significance determination process flow chart, the failure to comply, with a planning standard problem, but not a risk significant planning standard problem, with a planning standard function failure, results in a White significance. Additional details associated with this determination are discussed in the enclosed inspection report.
As discussed in the attached inspection report, the finding is also an apparent violation (AV) of NRC requirements, involving 10 CFR 50.54(q) and 10 CFR 50.47(b), and is therefore being considered for escalated enforcement action in accordance with the Enforcement Policy, which can be found on the NRC web site at http://www.nrc.gov/reading-rm/doc-collections/enforcement.
Before we make a final decision on this matter, we are providing you an opportunity to: (1) to attend a Regulatory Conference where you can present to the NRC your perspective on the facts and assumptions, the NRC used to arrive at the finding and determine its significance, or (2) submit your position on the finding to the NRC in writing. If you request a Regulatory Conference, it should be held within 30 days of the receipt of this letter and we encourage you to submit supporting documentation at least one week prior to the conference in an effort to make the conference more efficient and effective. If a Regulatory Conference is held, it will be open for public observation. If you decide to submit only a written response, such a submittal should be sent to the NRC within 30 days of your receipt of this letter. If you decline to request a Regulatory Conference or submit a written response, you relinquish your right to appeal the final SDP determination, in that by not doing either, you fail to meet the appeal requirements
stated in the Prerequisite and Limitation sections of Attachment 2 on IMC 0609. We request that if you decide to attend a Regulatory Conference or provide a written response that you address the apparent violation.
Please contact Mr. Brian Bonser at (404) 997-4653 within 10 business days of the date of your receipt of this letter to notify the NRC of your intentions. If we have not heard from you within 10 days, we will continue with our significance determination decision and you will be advised by separate correspondence of the results of our deliberations on this matter.
In addition, the report documents one finding of very low significance (Green). The finding involved a violation of NRC requirements. However, because of the very low safety significance and because it is entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV) consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest the NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at Brunswick.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosures, 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 the 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,
/Harold Christensen RA for/
Christopher G. Miller, Acting Director Division of Reactor Safety
Docket Nos.: 50-325, 50-324 License Nos.: DPR-71 and DPR-62
Enclosure:
Inspection Report 05000325/2010007, and 05000324/2010007 w/Attachment: Supplemental Information, Special Inspection Charter
REGION II==
Docket Nos.:
05000325, 05000324
License Nos.:
Report No.:
05000325/2010007 and 05000324/2010007
Licensee:
Carolina Power and Light Company
Facility:
Brunswick Steam Electric Plant, Units 1 and 2
Location:
Southport, NC
Dates:
June 9, 2010 through September 29, 2010
Inspectors:
Lee Miller, Senior Emergency Preparedness Inspector James Beavers, Emergency Preparedness Inspector
Approved by:
Brian Bonser, Chief Plant Support Branch 1 Division of Reactor Safety
Enclosure SUMMARY OF FINDINGS
IR 05000325/2010007 and 05000324/2010007; 06/09/2010 - 09/29/2010; Brunswick Steam Electric Plant, Units 1 and 2; Special Inspection Report.
The report covered an on-site inspection and related in-office special inspection activities conducted by a senior emergency preparedness inspector and an emergency preparedness inspector. One apparent violation (AV) with potential greater than Green safety significance and one self-revealing Green non-cited violation (NCV) were identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). The cross-cutting aspect was determined using IMC 0310, Components With The Cross-Cutting Areas. Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.
A.
NRC-Identified and Self-Revealing Findings
Cornerstone: Emergency Preparedness
- White: An NRC-identified, low to moderate safety significance (White), apparent violation (AV) of 10 CFR 50.54(q) was identified in that the licensee failed to meet the requirements of 10 CFR 50.47(b)(2). The Technical Support Center (TSC),
Operations Support Center (OSC), and Emergency Operations Facility (EOF) were not activated until approximately two and one-half hours after the Alert declaration due to delays in the notification and response of the Brunswick emergency response organization (ERO).
10 CFR 50.54(q) requires that the facility shall follow and maintain in effect Emergency Plans which meet the standards in 10 CFR 50.47(b). 10 CFR 50.47(b)(2), states, On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support and response activities are specified. Brunswick Plant Emergency Procedures 0PEP-02.6.12, 0PEP-02.6.26, and 0PEP-02.6.27 require activation of the OSC, TSC and EOF respectively within 60 - 75 minutes following the declaration of an ALERT or higher emergency classification. Contrary to the above, on June 6, 2010, the Brunswick Steam Electric Plant ERO failed to provide initial facility accident response through timely augmentation of on-shift staffing after declaration of an alert at Brunswick. This resulted in the delay of OSC, TSC, and EOF activation by 75 minutes.
The licensees failure to maintain its emergency plan in effect is a performance deficiency and an apparent violation (AV) of 10 CFR 50.54(q). The cause of this finding was directly related to the cross-cutting aspect of, The licensee conducts self-assessments at an appropriate frequency; such assessments are of sufficient
Enclosure depth, are comprehensive, are appropriately objective, and are self-critical. The licensee periodically assesses the effectiveness of oversight groups and programs such as CAP, and policies. P.3(a)
- Green: A self-revealing, very low safety significance (Green), non-cited violation (NCV) of 10 CFR 50.72(a)(4) was identified. The Emergency Response Data System (ERDS) was not activated until 80 minutes after the Alert declaration due to a lack of on-shift staffing experience and inadequate procedural guidance.
10 CFR 50.72(a)(4), states, The licensee shall activate the Emergency Response Data System (ERDS) as soon as possible but not later than one hour after declaring an Emergency Class of alert, site area emergency, or general emergency. The ERDS may also be activated by the licensee during emergency drills or exercises if the licensee's computer system has the capability to transmit the exercise data.
Contrary to the above, on June 6, 2010, the Brunswick ERO failed to activate the Emergency Response Data System within one hour after declaring an alert at the Brunswick Steam Electric Plant.
B.
Licensee-Identified Findings
None
Enclosure Report Details
Summary of Plant Event
On June 6, 2010, at 11:37 a.m., an Alert was declared at the Brunswick Steam Electric Plant, Units 1 and 2, due to a discharge of Halon gas into the basement of the emergency diesel generator building. The Halon discharge resulted in the rupture of a blowout panel on the 20 foot elevation and prohibited access to the diesel controls. The Alert declaration was in accordance with requirements of 0PEP-02.1, Initial Emergency Actions. Portions of the ensuing licensee response to the Alert declaration were not in accordance with the Brunswick Nuclear Plant Radiological Response Plan and its implementing procedures. Specifically, all three on-site Emergency Response Facilities (ERFs), the Technical Support Center (TSC), Operations Support Center (OSC), and the Emergency Operations Facilities (EOF), were not activated within 75 minutes of declaration of the Alert. In addition, the emergency response data system (ERDS) was not activated within one hour of the declaration.
The State and local governments were notified at 11:50 a.m., and the NRC at 12:37 p.m. The Control Room Site Emergency Coordinator (CR-SEC) delayed notifying security to activate the emergency response organization (ERO) callout system until 12:02 p.m. Security failed in several attempts to initiate the ERO callout system. Security reported the failure to activate the ERO callout to the control room. At 12:06 p.m. the CR-SEC directed the Control Room Emergency Communicator (CREC) to initiate a manual ERO group page. The CREC failed to successfully initiate an accurate message with three attempts. At 12:37 p.m. an emergency preparedness supervisor successfully initiated a text based page. An emergency preparedness engineer from home initiated the callout system at 12:46 p.m. The ERFs were activated 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 30 minutes after the Alert declaration. The TSC and OSC were activated at 2:05 p.m. and the EOF at 2:07 p.m. The Shift Technical Advisor (STA) was unable to initiate ERDS from the main control. An engineer familiar with ERDS remotely activated the system at 12:57 p.m.
NRC Response
Based on the deterministic criteria in Management Directive 8.3, NRC Incident Investigation Program, that this event involved a significant failure to implement the emergency preparedness program during an actual event, a Special Inspection team was initiated in accordance with Inspection Procedure 93812, Special Inspection. The objectives of the inspection were to assess the circumstances surrounding: (1) the Alert declaration; (2) delayed activation of the ERO facilities; and (3) delayed initiation of ERDS issues. The following ten inspection charter items were inspected to meet these objectives.
- Develop a sequence of events from the Alert declaration to the event termination related to the licensees implementation action of their EP program. Develop a complete description of the problems experienced with the implementation of the EP program during the event.
- Assess the licensees decision process for the events leading up to the event declaration.
- Assess the adequacy of the licensees response to the Alert declaration, activation of the ERO facilities, and initiation of ERDS.
Enclosure
Determine if the ERO callout system responded appropriately.
- Determine if the ERO group page system responded appropriately.
- Determine why the surveillance testing of the ERO callout system and the ERO group page system did not identify the problems experienced with security and operations personnel during attempted activation.
- Determine the scope of the ERO issue involving ERO response with respect to recent event at Brunswick and H.B. Robinson.
- Review the licensees corrective actions (CAs), causal analysis and extent of condition associated with the EP implementation issues.
- Collect data necessary to develop and assess the safety significance of any findings in accordance with IMC 0609, Significance Determination Process.
- Identify any potential generic safety issues and make recommendations for appropriate follow-up actions (e.g., Information Notices, Generic Letters, and Bulletins).
4.
OTHER ACTIVITIES
4OA5 Other Activities - Special Inspection (93812)
.1 Sequence of Events (Charter Item 1.):
Sunday, June 6, 2010
At 11:37 a.m., CR-SEC timely and accurately completes the Alert declaration.
At 11:50 a.m., timely and accurate notification of the State and county agencies was completed in 13 minutes.
At 12:02 p.m., the CR-SEC directed the Secondary Alarm Station (SAS) operator to activate the Brunswick Emergency Notification (BEN) system. The SAS operator failed to activate the system with five attempts. The SAS operator contacted the CR-SEC and informed him the BEN system was not activated.
At 12:06 p.m., the CR-SEC directed the CREC to initiate a manual ERO group page.
The CREC failed to successfully initiate an accurate message with three attempts.
At approximately 12:05 p.m., the CR-SEC directed the STA to activate the ERDS. The STA failed to activate the system with several attempts.
At 12:20 p.m., the STA requested the on-call Nuclear Information Technologist (NIT) for support with the ERDS. The technician was unable to help but determined another staff member may be able to help.
At 12:30 p.m., the on-call NIT contacted another NIT member for support with the ERDS.
(See 12:57 p.m. entry.)
At 12:37 p.m., accurate notification of the NRC was completed in 60 minutes.
Enclosure At 12:37 p.m., the Emergency Preparedness (EP) supervisor initiated a text based group page via the pager vendors website. The EP supervisor successfully initiated an accurate message with one attempt.
At 12:43 p.m., the EP supervisor and EP staff activated the BEN system. The EP organization successfully activated the BEN system with one attempt.
At 12:57 p.m., elapsed time 80 minutes, a NIT successfully activated the ERDS remotely with one attempt, 20 minutes beyond the required time
At 1:58 p.m., the last ERF minimum staffing position arrives.
At 2:05 p.m., the TSC and OSC were activated 73 minutes beyond the time required in the Plant Emergency Procedures.
At 2:07 p.m., the EOF was activated 75 minutes beyond the time required in the Plant Emergency Procedure.
At 4:04 p.m., the emergency event was terminated. ERF staffing remained to investigate and restore from the event.
At 10:09 p.m., the ERF staffing was released. Recovery activities were moved to the Outage Control Center.
.2 Pre-Declaration Decision Assessment (Charter Item 2.):
a.
Inspection Scope
The inspectors reviewed relevant documents and performed interviews associated with the control room response for the Alert declaration.
b.
Findings and Observations
No findings were identified. The inspectors determined that the Alert declaration at 11:37 a.m. on June 6, 2010, was timely and accurate. The licensees notification of the State and county agencies was timely and accurate. The NRC notification was completed in the required hour.
.3 ERO Activation/ERDS Initiation Assessment (Charter Item 3.):
a.
Inspection Scope
The inspectors reviewed relevant documents and performed interviews to assess the adequacy of the licensees response to the Alert declaration with respect to activation of the ERO facilities and initiation of ERDS.
Enclosure b.
Findings and Observations
Failure to Timely Augment the On-shift Staffing
Introduction: The NRC identified an apparent violation (AV) of 10 CFR 50.54(q) for the licensees failure to follow and maintain their emergency plan in effect. The inspectors identified that the licensees ERO failed to provide adequate staffing for initial facility accident response through timely augmentation of on-shift staffing as required by 10 CFR 50.47(b)(2) following the declaration of an Alert at the Brunswick Steam Electric Plant on June 6, 2010.
Description: On June 6, 2010, at 1137, an Alert emergency classification was declared at the Brunswick Steam Electric Plant (Brunswick) due to a release of Halon gas in the emergency diesel generator (EDG) building.
The CR-SEC directed the SAS operator to activate the BEN system per 0PEP-04.7, Brunswick Emergency Notification (Automated Telephone) System, 25 minutes after the Alert declaration. However, the SAS operator was unable to successfully activate the BEN system after repeated attempts due to problems entering the system password, scenario code, and being cut-off by an incoming call. The inspectors found the BEN system to be operating as designed. The SAS security officer did not have adequate experience, did not use self-checking, and did not have an adequate understanding of system design or procedural guidance to successfully activate the system. The inspectors also found that the CR-SEC failed to recognize the effect the 25 minute delay in notification of the SAS to activate the BEN system would have on meeting the 75 minute requirement to augment on-shift staffing and activate the emergency response facilities.
The CR-SEC, being notified of the failure to activate the BEN system, directed the Control Room Emergency Communicator (CREC) to initiate a manual ERO group page per 0PEP-02.6.21, Emergency Communicator. Three attempts by the CREC to initiate a manual ERO group page resulted in inaccurate page messages. The pages initiated by the CREC were not performed exactly per the procedure and did not provide a clear message to the ERO. The inspectors found the ERO group page system to be operating as designed; but, the CREC did not have adequate experience, had never actually performed the task, and was unable to follow procedural guidance to successfully activate the system
The Emergency Preparedness supervisor, who was in the control room, realized none of the pages were per procedure and attempted to provide a clear and accurate message to the ERO by initiating a text based group page via the pager vendors website. This resulted in an accurate text page reading, Brunswick Plant is in an Alert - Activate the EOF/TSC/OSC, one hour after the Alert declaration. Minutes later, the Emergency Preparedness group, after determining the BEN system was functional, successfully initiated the BEN system remotely. At this time, the ERO had received three inaccurate manual group pages, one accurate text based group page, and notices from the BEN system advising the ERO of the Brunswicks Alert declaration.
Enclosure The ERO response supported activation of the TSC and OSC activation, 73 minutes after the required activation time, at 2:05 p.m. The Emergency Operations Facility EOF was activated, 75 minutes after the required activation time, at 2:07 p.m. Total time from declaration of the Alert to EOF activation was 150 minutes.
The inspectors found the ERO response and all three ERF activations to be outside the requirements of the respective facility activation procedures and the Brunswick Emergency Plan. Activation of the ERO facilities was required within 75 minutes of the Alert.
Within the first hour following the Alert declaration, the CR-SEC directed the STA to activate ERDS. The STA was unable to successfully activate the ERDS using procedure 0OI-60, ERFIS Data Display System. The ERDS was activated by an off-site nuclear information technician 20 minutes after the 60 minute regulatory requirement had passed. The inspectors found the ERDS to be operating as designed. The STA, however, was unfamiliar with the complete task, did not have adequate experience, system design understanding or procedural guidance to successfully activate the ERDS system.
The inspectors found that most if not all of the aforementioned performance issues had observable, objective performance standards with which actual performance could have been measured. The inspectors also noted that the periodic effectiveness assessment of oversight groups failed to identify the degradation of the emergency preparedness program in general and loss of the ERO augmentation planning standard function specifically.
Analysis: The licensees failure to provide timely augmentation of on-shift staffing and activate the emergency response facilities in timely manner upon declaration of an Alert was a performance deficiency. 10 CFR 50.54(q) and 10 CFR 50.47(b)(2) require the licensee to maintain the ability to provide timely augmentation of on-shift staff. The finding was more than minor because it was associated with the attribute of Emergency Response Organization Performance and affected the cornerstone objective of ensuring that the licensee was capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency.
Inspection Manual Chapter (IMC) 0609, Appendix B, Emergency Preparedness Significance Determination Process (EP SDP), Section 2.2, describes the EP SDP as having two distinct branches for Failure to Comply (Sheet 1) and for Actual Event Implementation Problem (Sheet 2), that findings should be assessed through both paths and the most significant finding issued. Section 3.1 states in part that a failure to implement is not always a result of a performance problem and may reveal that a program element is not adequate. In that case, inspection should determine whether there is a loss of planning standard (PS) function. Resulting issues would be assessed for significance in accordance with the criteria for a loss of PS function. Section 4.0 states in part that a loss of PS function means that program elements are not adequate, not compliant with the planning standards of 10 CFR 50.47(b), or otherwise not functional to such an extent that the function of the planning standard is not available for emergency response. The loss of PS function may be that the Emergency Plan
Enclosure commitments are not met or are inadequate, implementing procedures are inadequate, program design is inadequate, training is inadequate, etc. The result is that if the suspect program element was implemented as designed, or personnel are not capable of implementing the program element, the PS function would not be met. The inspectors determined that the planning standard function failure was a loss of planning standard function, Process for timely augmentation of on-shift staff is established and maintained. Using Sheet 1, Failure to Comply, significance determination process flow chart, the failure to comply, with a planning standard problem, but not a risk significant planning standard problem, with a planning standard function failure, results in a White significance.
The inspectors determined that the licensees failure to provide initial facility accident response through timely augmentation of on-shift staffing revealed programmatic weaknesses in the licensees maintenance of its emergency plan. The inspectors determined that the implementing procedures for ERO notification, the training of the Control Room Site Emergency Coordinator (CR-SEC), the Control Room Emergency Communicator and Security, and the priorities of the ERO were inadequate to support the required timely augmentation capability of the on-shift personnel after the declaration of an emergency as required by planning standard 10 CFR 50.47(b)(2). The inability to meet these key program elements resulted in the inability to meet the planning standard function as described in Section 4.0, Failure to Comply, of Manual Chapter 0609, Appendix B. The inspectors determined that the planning standard function failure was a loss of planning standard function, Process for timely augmentation of on-shift staff is established and maintained. Using Sheet 1, Failure to Comply, significance determination process flow chart, the failure to comply, with a planning standard problem, but not a risk significant planning standard problem, with a planning standard function failure, results in a White significance. The licensees failure to maintain its emergency plan in effect is a performance deficiency and an apparent violation (AV) of 10 CFR 50.54(q). The cause of this finding was directly related to the cross-cutting aspect of aspect of, The licensee conducts self-assessments at an appropriate frequency; such assessments are of sufficient depth, are comprehensive, are appropriately objective, and are self-critical. The licensee periodically assesses the effectiveness of oversight groups and programs such as CAP, and policies. P.3(a)
Enforcement: 10 CFR 50.54(q) requires that the facility shall follow and maintain in effect Emergency Plans which meet the standards in 10 CFR 50.47(b). 10 CFR 50.47(b)(2), states, On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support and response activities are specified. Brunswick Plant Emergency Procedures 0PEP-02.6.12, 0PEP-02.6.26, and 0PEP-02.6.27 require activation of the OSC, TSC and EOF respectively within 60 - 75 minutes following the declaration of an ALERT or higher emergency classification. Contrary to the above, on June 6, 2010, the Brunswick Steam Electric Plant ERO failed to provide initial facility accident response through timely augmentation of on-shift staffing after declaration of an alert at Brunswick.
This resulted in the delay of OSC, TSC, and EOF activation by 75 minutes. This finding is identified as Apparent Violation (AV) 50-325, 50-324/2010007-001, Failure to Timely
Enclosure Augment On-shift Staff. This issue has been entered into the licensee's corrective action system (NCR 403477).
Failure To Timely Activate ERDS
Introduction: A self-revealing, very low safety significance (Green), non-cited violation (NCV) of 10 CFR 50.72(a)(4) was identified for the licensees failure to activate the Emergency Response Data System (ERDS) within one hour of the Alert declaration.
Description: Concurrently with the ERO notification and within the first hour following the Alert declaration, the CR-SEC directed the ERDS activation by the STA. The STA was unable to successfully activate the ERDS using 0OI-60, Data Display System. The ERDS was eventually activated by an off-site nuclear information technician 20 minutes after the one hour specified in 10 CFR 50.72(a)(4). The inspectors found the ERDS to be operating as designed; however, the STA, unfamiliar with the complete task, did not have adequate experience, system design understanding or procedural guidance to successfully activate the ERDS system.
Analysis: A self-revealing non-cited violation of 10 CFR 50.72(a)(4) was identified.
During the June 6, 2010, discharge of Halon gas Alert declaration event, the licensee failed to activate the Emergency Response Data System (ERDS) within one hour of the Alert declaration. The ERDS was not made operable until 80 minutes after the Alert declaration due to task unfamiliarity by the Shift Technical Advisor (STA).
The inspectors determined that the licensees failure to activate the ERDS within one hour of the Alert declaration was a performance deficiency because the licensee is expected to comply with 10 CFR 50.72(a)(4).
The finding was more than minor because it was associated with the attribute of Emergency Response Organization Performance and affected the cornerstone objective of ensuring that the licensee was capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency.
This finding was evaluated in accordance with Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, and was determined to be a finding of very low safety significance (Green) because there was no loss of planning standard function.
Enforcement: 10 CFR 50.72(a)(4), states, The licensee shall activate the Emergency Response Data System (ERDS) as soon as possible but not later than one hour after declaring an Emergency Class of alert, site area emergency, or general emergency.
The ERDS may also be activated by the licensee during emergency drills or exercises if the licensee's computer system has the capability to transmit the exercise data.
Contrary to the above, on June 6, 2010, the Brunswick ERO failed to activate the Emergency Response Data System within one hour after declaring an alert at the Brunswick Steam Electric Plant. Because this violation was of very low safety significance (Green) and it was entered into the licensees CAP (NCR 403477), this violation is being treated as an NCV, consistent with the NRC Enforcement Policy. This
Enclosure finding is identified as NCV 50-325, 50-324/2010007-002, Failure to Timely Activate ERDS.
.4 ERO Callout System Assessment (Charter Item 4):
a.
Inspection Scope
The inspectors reviewed relevant documents and performed interviews to assess the adequacy of the licensees response to determine if the ERO callout system responded appropriately.
b.
Findings and Observations
No findings were identified. The CR-SEC directed the SAS operator to activate the BEN system per 0PEP-04.7, Brunswick Emergency Notification (Automated Telephone)
System. However, the SAS operator was unable to successfully activate the BEN system in five attempts. Problems were encountered entering the system password and scenario code. The SAS operator also uncovered a latent hardware issue with the phone activation system which allowed any incoming call to terminate the BEN system activation process. The inspectors found the BEN system to be operating as designed, however, the security officer did not have adequate experience, system design understanding or procedural guidance to successfully activate the system.
.5 ERO Group Page System Assessment (Charter Item 5):
a.
Inspection Scope
The inspectors reviewed relevant documents and performed interviews to assess the adequacy of the licensees response to determine if the ERO group page system responded appropriately.
b.
Findings and Observations
No findings were identified. The CR-SEC, being notified of the failure to activate BEN, directed the Control Room Emergency Communicator (CREC) to initiate a manual ERO group page per 0PEP-02.6.21, Emergency Communicator. Three attempts by the CREC to initiate a manual ERO group page resulted in inaccurate page messages. The inspectors found the ERO group page system to be operating as designed. The inspectors found that the CREC did not have adequate experience, had never actually performed the task and was unable to follow the procedural guidance to successfully activate the system
.6 Surveillance Testing Failure to Identify (Charter Item 6):
a.
Inspection Scope
The inspectors reviewed relevant documents and performed interviews to assess the adequacy of the licensees response to determine why the surveillance testing of the
Enclosure ERO callout system and the ERO group page system did not identify the problems experienced with security and operations personnel during attempted activation.
b.
Findings and Observations
No findings were identified. As discussed above, the ERO callout system and the ERO group page system operated as designed. The inspectors found the personnel performing periodic surveillances to be experienced and fully knowledgeable of the systems. The ERO members that attempted to initiate these systems on the day of the Alert were neither experienced nor knowledgeable. Neither Operations nor Security personnel were required to demonstrate task proficiency for ERO positional qualification.
.7 Scope of ERO Response Issues (Charter Item 7):
a.
Inspection Scope
The inspectors reviewed relevant documents and performed interviews to assess the adequacy of the licensees response to determine the scope of the ERO issue involving ERO response with respect to recent events at Brunswick and H.B. Robinson.
b.
Findings and Observations
No findings were identified. ERO response to the ERFs was not timely regardless of the notification issues. The three onsite facilities required approximately two and one half hours to activate from the time of the Alert declaration. ERO members reported the following: confusion over the initial pages, not recognizing the number displayed on the manual group pages as an ERO related number, garbled pager messages, misinterpretation of plant status (if both units were at 100%, then no emergency), busy signals, BEN system messages as scam calls, being outside of the 60 minute response time to the site, having to take family members home before reporting to the sight, and misinterpretation of minimum staffing time starting with their personal notification.
Administrative control issues (quarterly requests for ERO information) failed to identify some minimum staffing personnel living outside a 60 minute response time and incorrect for contact numbers.
.8 Corrective Action, Causal Analysis and Extent of Condition Assessment (Charter Item 8):
a.
Inspection Scope
The inspectors reviewed the licensees corrective actions (CAs), causal analysis and extent of condition associated with the event.
b.
Findings and Observations
No findings were identified. As described in the licensees Significant Adverse Condition Investigation Report, CAP-NGGC-0205-16-11, Line management does not display an urgency or importance of the ERO which leads to the lack of sense of importance by the
Enclosure workforce. Some examples of this are by allowing vacancies in the minimum staffing positions for long periods of times, allowing candidates to remain unqualified for long periods of time, lack of support for drills, placing an emphasis on providing update information to EP, and for managers themselves not qualifying for an ERO position in a timely manner. The inspectors also noted that the periodic effectiveness assessment of oversight groups failed to identify the degradation of the emergency preparedness program in general and loss of the ERO augmentation planning standard function specifically.
In the interim, Brunswick Nuclear Plant has implemented a number of corrective actions.
A standing instruction for the Shift Managers directing timely BEN system activation (five minutes), hard copy initial notification for state and local agencies and observation of communication proficiencies was instituted. SAS operators were required to demonstrate proficiency prior to assuming shift to ensure their experience level was on par with the procedural guidance. A single use telephone exchange was assigned for the BEN system activation. STAs were required to demonstrate proficiency prior to assuming shift to ensure their experience level was on par with the procedural guidance.
The plant general manager addressed all ERO members emphasizing the significance of the event and ERO member responsibilities. Qualifications of some ERO members were removed as a result of performance, experience and logistical insufficiencies. The inspectors found these actions adequate to restore the loss of planning standard function with respect to timely ERO augmentation of on-site staffing.
.9 Significance Determination (Charter Item 9):
a.
Inspection Scope
The inspectors collected data necessary to develop and assess the safety significance of any findings in accordance with IMC 0609, Significance Determination Process.
b.
Findings and Observations
No findings were identified. See section.3 above for the assessment of significance determination.
.10 Generic Safety Issues and Follow Up Actions (Charter Item 10):
a.
Inspection Scope
The inspectors reviewed relevant documents and performed interviews to assess the adequacy of the licensees response to determine the scope of the ERO issue involving ERO response with respect to recent events at Brunswick and H.B. Robinson.
b.
Findings and Observations
No findings were identified. The periodic demonstration of a facilities ability to provide accident response in key functional areas through the timely augmentation of on shift staffing is a function of planning standard 10 CFR 50.47(b)(2). Task elements of this
Enclosure function should include the decision time required to call in the ERO, the demonstrated ability to initiate the call out equipment, the demonstrated ability of the ERO to respond to the site, and the demonstrated ability of the ERO to activate the ERFs within the required time limits. Simulated portions of these elements prevent objective evaluation of these tasks and ultimately the objective evaluation of the augmentation function.
The licensees investigation of the Brunswick ERO response concluded that similar problems with ERO response may exist at all four Progress Energy nuclear sites. ERO response is required at all sites but has differing call out methodologies to activate the ERO at each site. One of the corrective actions from the licensees investigation was to share the results of their investigation with other sites as internal operating experience (OE). The licensee also plans to share the results industry wide as external OE.
4OA6 Meetings, Including Exit
On June 6, 2010, the special inspection team leader presented preliminary inspection results to Mr. and other members of his staff. Licensee acknowledged the preliminary findings and the inspectors stated they received no proprietary information.
On September 29, 2010, the special inspection team leader re-exited with Mr. M.
Annacone and other members of the Brunswick staff via teleconference. The final inspection results were discussed. Licensee acknowledged the preliminary findings and the inspectors stated they received no proprietary information.
ATTACHMENT: SUPPLEMENTAL INFORMTION BRUNSWICK SPECIAL INSPECTION CHARTER
Attachment 1 SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel:
M. Annacone, Vice President - Brunswick Steam Electric Plant B. Brewer, Manager Maintenance J. Burke, Manager Shift Operations K. Crocker, Supervisor Emergency Preparedness B. Davis, Manger Engineering S. Gordy, Manager Operations R. Ivey, Manager NOS J. Johnson, Manager E&RC P. Mentel, Manager Support Services A. Pope, Supervisor Licensing/Regulatory Programs J. Stephenson, Corporate Emergency Preparedness M. Williams, Manager Training
ITEMS OPENED AND CLOSED
Opened 50-325, 50-324/2010007-01 AV Failure to Timely Augment On-shift Staffing 50-325, 50-324/2010007-02 NCV Failure to Timely Activate ERDS
LIST OF DOCUMENTS REVIEWED
Procedures and Documents 0ERP, Radiological Emergency Response Plan, Rev. 74 0PEP-02.1, Initial Emergency Actions 0PEP-02.1.1, Emergency Control - Notification of Unusual Event, Alert, Site Area Emergency, and General Emergency, Rev. 13 0PEP-02.6.12, Activation and Operation of the Operational Support Center (OSC), Rev. 34 0PEP-02.6.21, Emergency Communicator, Rev. 52 0PEP-02.6.26, Activation and Operation of the Technical support Center (TSC), Rev. 22 0PEP-02.6.27, Activation and Operation of the Emergency Operations Facility (EOF), Rev. 24 0PEP-04.2, Emergency Facilities and Equipment, Rev. 34 0PEP-04.7, Brunswick Emergency Notification (Automated Telephone) System, Rev. 6 0OI-60, ERFIS Data Display System, Rev. 31
Condition Reports (CR)
NCR 00403461 - Delays encountered logging into Web-EOC. Delays were encountered during an actual event with logging into Web-EOC in the Control Room because there is not a dedicated computer in the Control Room for using Web-EOC. This delay resulted in delays notifying Security to activate BEN.
Attachment 1 NCR 00403465 - Latest procedure revision not available-ERO Dose Projection. EMG-NGGC-0002 Revision 0 was posted in the Dose Projection Coordinators procedure book; the correct Revision is #1. This was noted previously during the last ERO drill, but document services was not able to access the book due to the cabinet being locked.
NCR 00403466 - EOF activation time did not meet requirements. The EOF activated at 1407.
The Alert was declared at 11:37. Facilities were required to be activated by 12:52.
NCR 00403468 - Security had issues activating BEN during 06/06/10 Alert. Security had issues activating the Brunswick Emergency Notification System during the 6/6/10 event.
Control Room Emergency Communicators were successful setting off the ERO pagers using the group number. BEN was later successfully activated by a responding EP Rep.
NCR 00403469 - Incorrect Notification Time on Message 1 during Alert 6/6/10. The Notification Time entered on the Emergency Notification Form for Message 1 during the Alert event on 6/6/10 was incorrect. The Notification Time was entered as 1200 pm. The correct Notification Time was actually 11:50 and logged as such in both the manual logs and WebEOC Notification Page.
NCR 00403470 - Security was notified to activate BEN 25 mins after. Security was notified to activate the Brunswick Emergency Notification (BEN) system 25 minutes after declaration of the event. Activating BEN alerts the ERO to staff and activate the Emergency Facilities.
NCR 00403477 - Emergency Facilities late to activate (TSC and OSC). Alert was declared by the SEC at 11:37 on June 6, 2010. The TSC and OSC did not activate by the required time 12:52. Activation time was 14:05.
NCR 00403624 - Team 5 EP Drill - WebEOC dual commit for electronic. The WebEOC dual commit function used to electronically transmit Emergency Notification Forms (ENF'S) to the State EOC was not working during the June 01Team 5 EP Drill. This did not affect transmittal of the ENF, only electronic display of the form by the State. This NCR is a duplicate of NCR 403087 which has been canceled.
NCR 00403656 - Two Instructors did not meet EP expectations and standards. Two training Instructors assigned to EP Minimum Staffing Positions did not meet the expectations for reporting to the ERO Facilities within 60 minutes of an actual Alert declaration. One Instructor was 84 minutes and one was 90 minutes. This AR will document the human performance clock reset for Brunswick Training Section. NCR 403466 will track actions for ERO response.
NCR 00403850 - Discrepancy between the 0PEP-02.2.1 and 0PEP-02.1.1. During the investigation of the June 06, 2010 Halon discharge event a discrepancy was found between the 0PEP-02.2.1 Emergency Action Level Technical Bases and 0PEP-02.1.1 EAL Table wording for EAL HA3.1.
Attachment 1 LIST OF ACRONYMS
ANS Alert and Notification System BEN
Brunswick Emergency Notification CREC Control Room Emergency Coordinator CR-SEC Control Room Site Emergency Coordinator DEP Drill Exercise Performance EAL
Emergency Action Level EOF
Emergency Operations Facility ERDS Emergency Response Data System ERF
Emergency Response Facility ERO Emergency Response Organization IMC
Inspection Manual Chapter NEI
Nuclear Energy Institute NIT
Nuclear Information Technologist OSC
Operations Support Center PI
Performance Indicator SAS
Secondary Alarm Station SDP
Significance Determination Process STA
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257
Attachment 2 June 9, 2010
MEMORANDUM TO: Lee R. Miller Senior Emergency Preparedness Inspector
FROM:
Luis A. Reyes /RA/
Regional Administrator
SUBJECT:
SPECIAL INSPECTION CHARTER TO EVALUATE BRUNSWICK ALERT DECLARATION FOR DISCHARGE OF HALON GAS INTO THE EMERGENCY DIESEL GENERATOR BUILDING, DELAYED ACTIVATION OF THE ERO FACILITIES, AND DELAYED INITIATION OF ERDS ISSUES
You have been selected to lead a Special Inspection (SI) to assess the circumstances surrounding the Alert declaration, delayed activation of the ERO facilities, and delayed initiation of ERDS issues at Brunswick Steam Electric Plant. Your onsite inspection should begin on June 9, 2010. James Beavers will be assisting you in this inspection.
A.
Basis
On June 6, 2010, at 1137, Brunswick Steam Electric Plant, Unit 1 and 2, declared an Alert condition due to a discharge of Halon gas into the basement of the emergency diesel generator building that resulted in rupture of a blowout panel on the 20 foot elevation which prohibited access to the diesel controls. The State and local governments were notified at 1200 and the NRC at 1237. The ERO facilities were activated approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 28 minutes after the Alert declaration. The TSC and OSC were activated at 1405 and the EOF at 1407. The shift manager delayed notifying security to activate the ERO callout system until 1202. Security failed in several attempts to initiate the ERO callout system. Security reported to the control room of the failure to activate the ERO callout. The control room emergency communicator also tried and failed to initiate the ERO callout. An ERO group page was initiated at 1215 and did not get the desired ERO response. The callout system was initiated by an EP engineer from home at 1246. ERDS could not be initiated from the main control room. An engineer familiar with ERDS activated the system at 1257.
In accordance with Management Directive 8.3, NRC Incident Investigation Program, deterministic criteria were used to evaluate the level of NRC response for this operational event.
CONTACT:
Brian Bonser, RII/DRP (404)997-4653
L. Miller
Attachment 2 Based on the deterministic criteria that this issue involved a significant failure to implement the emergency preparedness program during an actual event, including the failure to augment onsite personnel for the event met criterion, for a Special Inspection, Region II determined that the appropriate level of NRC response was to conduct a Special Inspection. This Special Inspection is chartered to identify the circumstances surrounding this event, review the licensees actions following discovery of the conditions, and evaluate the licensees response to the event.
B.
Scope
The inspection team is expected to perform data gathering and fact-finding in order to address the following:
1. Develop a sequence of events from the Alert declaration to the event termination.
Develop a complete description of the problems experienced during the event.
2. Assess the licensees decision process for the events leading up to the event declaration.
3. Assess the adequacy of the licensees response to the Alert declaration, activation of the ERO facilities, and initiation of ERDS.
4. Determine if the ERO callout system responded appropriately.
5. Determine if the ERO group page system responded appropriately.
6. Determine why the surveillance testing of the ERO callout system and the ERO group page system did not identify the problems experienced with security and operations personnel during attempted activation.
7. Determine the scope of the ERO issue involving ERO response with respect to recent event at Brunswick and H.B. Robinson.
8. Review the licensees corrective actions (CAs), causal analysis and extent of condition associated with the event.
9. Collect data necessary to develop and assess the safety significance of any findings in accordance with IMC 0609, Significance Determination Process.
10. Identify any potential generic safety issues and make recommendations for appropriate follow-up actions (e.g., Information Notices, Generic Letters, and Bulletins).
L. Miller
Attachment 2 C.
Guidance
Inspection Procedure 93812, "Special Inspection," provides additional guidance to be used during the conduct of the Special Inspection. Your duties will be as described in Inspection Procedure 93812. The inspection should emphasize fact-finding in its review are not directly related to the event should be reported to the Region II office for appropriate action.
You will report to the site, conduct an entrance, and begin inspection no later than June 9, 2010.
It is anticipated that the on-site portion of the inspection will be completed during this week. A status briefing of Region II management will be provided the second day on-site at approximately 4:00 p.m. In accordance with IP 93812, you should promptly recommend a change in inspection scope or escalation if information indicates that the assumptions utilized in the MD 8.3 risk analysis were not accurate. A report documenting the results of the inspection should be issued within 45 days of the completion of the inspection. The report should address all applicable areas specified in section 3.02 of Inspection Procedure 93812. At the completion of the inspection you should provide recommendations for improving the Reactor Oversight Process baseline inspection procedures and the Special Inspection process based on any lessons learned.
This charter may be modified should you develop significant new information that warrants review. Should you have any questions concerning this charter, contact Brian Bonser at (404) 997-4653.
Docket Nos.: 50-325, 50-324 License Nos.: DPR-71, DPR-62
cc:
R. W. Borchardt, EDO B. Mallett, DEDR L. Reyes, RII V. McCree, RII K. Kennedy, RII H. Christensen, RII B. Bonser, RII J. Munday, RII L. Wert, RII F. Saba, NRR C. Miller, NSIR R. Kahler, NSIR