IR 05000341/2017009

NRC Inspection Report 05000341/2017009 and Preliminary White Finding

ML17055C090
Person / Time
Site:	Fermi
Issue date:	02/24/2017
From:	O'Brien K Division of Reactor Safety III
To:	Fessler P DTE Electric Company
References
EA-17-012 IR 2017009
Download: ML17055C090 (14)

Text

UNITED STATES uary 24, 2017

SUBJECT:

FERMI POWER PLANT, UNIT 2 - NRC INSPECTION REPORT 05000341/2017009 AND PRELIMINARY WHITE FINDING

Dear Mr. Fessler:

On January 25, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Fermi Power Plant, Unit 2, and the NRC inspectors discussed the results of this inspection with Mr. K. Polson and other members of your staff. The results of this inspection are documented in the enclosed report.

Section 2RS6 of the enclosed report documents a finding with an associated apparent violation that the NRC has preliminarily determined to be White, with low-to-moderate safety significance.

This finding involved the licensees failure to maintain the effectiveness of the Fermi 2 Emergency Plan and use adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency. Specifically, due to the configuration of the sites standby gas treatment system accident range radiation monitor, the licensee failed to maintain the ability to accurately assess the condition of the plant and offsite radiological consequences, to accurately declare an Emergency Action Level classification, and to develop and issue accurate protective action recommendations (PARs)

for the public during the implementation of the sites Emergency Plan in response to a rapidly progressing accident. We assessed the significance of the finding using the significance determination process (SDP) and readily available information. We are considering escalated enforcement for the apparent violation consistent with our Enforcement Policy, which can be found at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. Because we have not made a final determination, no notice of violation is being issued at this time. Please be aware that further NRC review may prompt us to modify the number and characterization of the apparent violation(s).

We intend to issue our final significance determination and enforcement decision, in writing, within 90 days from the date of this letter. The NRCs SDP is designed to encourage an open dialogue between your staff and the NRC; however, neither the dialogue nor the written information you provide should affect the timeliness of our final determination. Before we make a final decision, you may choose to communicate your position on the facts and assumptions used to arrive at the finding and assess its significance by either:

(1) attending and presenting at a regulatory conference, or (2) submitting your position in writing. The focus of a regulatory conference is to discuss the significance of the finding.

Written responses should reference the inspection report number and enforcement action number associated with this letter in the subject line. Your written response should be sent to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Center, Washington, DC, 20555-001, with a copy to Mr. Steven K. Orth, Plant Support Branch, Branch Chief, U.S. Nuclear Regulatory Commission, Region III, 2443 Warrenville Road, Lisle, IL 60532.

If you request a regulatory conference, it should be held within 40 days of your receipt of this letter. Please provide information you would like us to consider or discuss with you at least 10 days prior to any scheduled conference. If you choose to attend a regulatory conference, it will be open for public observation. If you decide to submit only a written response, it should be sent to the NRC within 40 days of your receipt of this letter. If you choose not to request a regulatory conference or to submit a written response, you will not be allowed to appeal the NRCs final significance determination.

Please contact Mr. Steven K. Orth at (630) 829-9757, and in writing, within 7 days from the issue date of this letter to notify the NRC of your intentions. If we have not heard from you within 7 days, we will continue with our significance determination and enforcement decision.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding Electronic Reading Room).

Sincerely,

/RA/

Kenneth G. O Brien, Director Division of Reactor Safety Docket No. 50-341 License No. NPF-43

Enclosure:

Inspection Report 05000341/2017009

REGION III==

Docket No: 50-341 License No: NPF-43 Report No: 05000341/2017009 Licensee: DTE Energy Company Facility: Fermi Power Plant, Unit 2 Location: Newport, MI Dates: September 30, 2016, through January 25, 2017 Inspectors: V. Myers, Senior Health Physics Inspector G. Hansen, Senior Emergency Preparedness Inspector Approved by: S. Orth, Chief Plant Support Branch Division of Reactor Safety Enclosure

SUMMARY

Inspection Report 05000341/2017009; Fermi Power Plant, Unit 2; Radioactive Gaseous and

Liquid Effluent Treatment.

The enclosed inspection report documents a finding that has preliminarily been determined to be White, a finding with low to moderate safety significance, that may require additional U.S. Nuclear Regulatory Commission (NRC) inspections, regulatory actions, and oversight.

The significance of inspection findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609,

"Significance Determination Process," dated April 29, 2015. Cross-cutting aspects are determined using IMC 0310, "Aspects Within the Cross-Cutting Areas," dated December 4, 2014. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated November 1, 2016. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649,

"Reactor Oversight Process," dated July 201

NRC-Identified

and Self-Revealed Findings

Cornerstone: Emergency Preparedness

Preliminary

White.

An NRC identified finding preliminarily determined to be of low to moderate safety significance (White), and an associated apparent violation of Title 10 of the Code of Federal Regulations (10 CFR) 50.54(q)(2) and 10 CFR 50.47(b)(9) was identified for the licensees failure to maintain the effectiveness of its emergency plan and use adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency. Specifically, the licensee failed to maintain the ability to accurately declare an Emergency Action Level (EAL) classification, RG-1.1, and develop and issue accurate protective action recommendations (PARs) during the implementation of the sites Emergency Plan in response to a rapidly progressing accident. The licensee inaccurately analyzed the effect of increasing background radiation on the sites Standby Gas Treatment System accident range radiation monitor (AXM) indications based on the installed configuration of the AXM. As configured, the AXM could provide inaccurate indications of radioactive releases that are used as the licensees basis for determining EAL classification and development of PARs.

The licensee documented the issue in the corrective action program as CR-16-29230, and actions were completed to restore the accuracy of the indications provided by the AXM.

The inspectors determined that the licensees failure to maintain the effectiveness of its emergency plan and use adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency was a performance deficiency; the cause was reasonably within the licensees ability to foresee and correct; and should have been prevented. The inspectors determined the issue was more than minor because it adversely affected the emergency preparedness cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, the finding would result in the potential over classification of an emergency event and the potential issuance of unnecessary or early PARs.

The inspectors applied Inspection Manual Chapter (IMC) 0609, Appendix B,

Section 5.9. to screen this finding, and determined the licensee failed to maintain the risk significant planning standard (RSPS) identified in 10 CFR 50.47(b)(9) by ensuring adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use. Using Table 5.9-1, the inspectors determined the sites dose assessment process was incapable of providing technically adequate estimates of radioactive material releases to the environment or projected offsite doses in some cases (specifically a rapidly progressing accident scenario). This significance example corresponds to a Degraded RSPS Function, which is a finding of low to moderate safety significance (White).

The inspectors determined no cross-cutting aspects were associated with the performance deficiency. (Section 2RS6.1)

Licensee Identified Findings None

REPORT DETAILS

2RS6 Radioactive Gaseous and Liquid Effluent Treatment

.1 Instrumentation and Equipment (02.05)

a. Inspection Scope

The inspectors assessed calibration and availability for select effluent monitors used for triggering emergency action levels or for determining protective action recommendations.

b. Findings

Failure to Maintain the Effectiveness of the Sites Emergency Plan.

Introduction An U.S. Nuclear Regulatory Commission (NRC)-identified, preliminary White finding, associated with an Apparent Violation (AV) of Title 10 of the Code of Federal Regulations (10 CFR) 50.54(q)(2), and 10 CFR 50.47(b)(9) was identified for the licensees failure to maintain the effectiveness of its emergency plan and use adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency. Specifically, the licensee failed to maintain the ability to accurately declare an Emergency Action Level (EAL) for a General Emergency classification (RG-1.1) and to develop and issue accurate protective action recommendations (PARs) for the public during the implementation of the sites Emergency Plan in response to a rapidly progressing accident. The licensee inaccurately analyzed the effect of increasing background radiation on the sites Standby Gas Treatment System (SGTS) accident range radiation monitor (AXM) indications based on the installed configuration of the AXM. As configured, the AXM would provide inaccurate indications of radioactive releases that are used as the licensees basis for determining EAL classification and development of PARs.

Description During accident conditions, the licensees plant exhaust systems will redirect exhaust through the SGTS, which includes filters designed to remove radioactive material prior to release offsite. The SGTS AXM noble gas monitors function is to quantify offsite radioactive releases through the SGTS during accident conditions. This data is then used in accordance with the licensees emergency plan to determine emergency classification levels and PARs, based on the sites EAL schemes and offsite dose assessment programs. The PARs are then reviewed by State and Local officials to determine what protective actions may be initiated.

During a walkdown of the facility and discussion with staff, inspectors identified that the licensee used a fixed background subtract function for the AXM, which is located in close proximity to the SGTS filters. Although the function of the AXM is to quantify radioactive effluent releases through the SGTS, the detector will also respond to radiation from other external sources in the vicinity of the detector. Radiation from these other external sources is known as background radiation and may need to be subtracted from the total radiation that the detector is sensing in order to determine what is actually being released through the SGTS. The use of a fixed background subtraction means that a predetermined value for background radiation is subtracted from the detector reading. In this case, that predetermined value was based on background radiation during normal operation. The inspectors questioned this method because of the close proximity of the SGTS filters to the AXM. During an accident, the filters would collect radioactive material, significantly increasing the general area background radiation in the vicinity of the AXM. Upon further investigation, the inspectors determined that this AXM model had an additional detector that was designed to detect fluctuating background radiation and subtract that real time value from the detector sampling the SGTS (fluctuating background subtract). This fluctuating background subtract detector was not in use at the time of the inspection and an investigation by the licensee indicated that it had not been in use since the plant started operation. A preliminary evaluation conducted by the licensee concluded that the background radiation from the filters could result in AXM readings 100 to 1000 times greater than what would actually be released from the SGTS during accident conditions. In response to this evaluation, on November 16, 2016, the licensee declared both AXMs (Division 1 and Division 2) inoperable. An independent evaluation by the inspectors also concluded that the radiation from the SGTS filters would be sufficient enough to compromise the licensees ability to quantify radioactive releases during accident conditions. Specifically, this issue could lead the licensee to declare emergency classification levels based on the sites EAL schemes prior to the actual EAL initiating conditions being met and/or result in dose projections prompting the issuance of PARs without the actual conditions being present.

In response to the initial evaluation, the licensee performed a more detailed evaluation of the AXM. This evaluation determined that even with the fluctuating background subtract detector functioning, the background radiation levels could be high enough that the AXM would not provide accurate readings. This evaluation also determined that, in 1996, the licensee identified that although the Final Safety Analysis Report (FSAR) indicated that the AXM utilized a fluctuating background subtract function, this function was not in use at the time. The licensee failed to recognize the impact of the radiation fields in accident conditions. Instead, the licensee updated the FSAR to reflect that only fixed background subtract would be used with the justification that the AXM was in an area with relatively fixed radiation levels. Although radiation levels do remain relatively fixed during normal operations, the licensee failed to identify that during accident conditions, radiation levels would increase substantially.

Additionally, the inspectors reviewed and evaluated information provided by the licensee in which the licensee asserted they would be able to effectively implement the emergency plan. Specifically, the licensee would use indications from the sites containment high range radiation monitors (CHRRMS) to assess the potential off-site radioactive release and would be able to identify that the indications provided by the AXM were inaccurate. The sites implementing procedure EP-101, Classification of Emergencies, Revision 41, states, in part, the indications for declaring EAL RG 1.1 are in the absence of real time dose assessment, reading on any Table R-1 effluent radiation monitor greater than column GE for greater than or equal to 15 minutes.

Included in Table R-1 Effluent Monitor Classification Thresholds are the readings for the SBGTS AXM. The CHRRMS are not credited for classifying the emergency condition under this EAL initiating condition. The inspectors evaluated the information provided by the licensee and concluded that, while the licensee would likely recognize the difference between the CHRRMS indications and the AXM indications, absent any real time dose assessment information, the site would likely rely on the AXM indications for declaration of EAL RG 1.1 and subsequent determination of PARs, as directed by its procedures.

The time that it would take to determine the accuracy of the AXM readings would result in the failure to accurately declare the EAL classification and determine PARs.

Overall, the inspectors concluded that the licensee failed to maintain the effectiveness of its emergency plan and use adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency.

Specifically, the licensee failed to maintain the ability to accurately declare an EAL classification RG-1.1, and develop and issue accurate PARs during the implementation of the sites Emergency Plan in response to a rapidly progressing accident.

Analysis The inspectors determined that the licensees failure to maintain the effectiveness of its emergency plan and use adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency was a performance deficiency; the cause of which was reasonably within the licensees ability to foresee and correct, and should have been prevented. The inspectors determined the issue was more than minor because it adversely affected the EP cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, the finding would result in the potential over classification of an emergency event and the potential issuance of unnecessary or early PARs.

The finding is associated with a Failure to Comply, in that, the sites EP program was non-compliant with the EP regulatory requirement of 10 CFR 50.47(b)(9). The inspectors screened the finding using IMC 0609, Appendix B, Section 5.9. Specifically, the licensee failed to maintain the risk significant planning standard (RSPS) identified in 10 CFR 50.47(b)(9) by ensuring adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use. Using Table 5.9-1, the inspectors determined the sites dose assessment process is incapable of providing technically adequate estimates of radioactive material releases to the environment or projected offsite doses in some cases (specifically a rapidly progressing accident scenario). This significance example corresponds to a Degraded RSPS Function (Preliminary White Finding).

The inspectors determined that the performance deficiency was not indicative of current plant performance and therefore, no cross-cutting aspect was assigned. The inspectors recognized that the licensee missed an opportunity to identity and correct the issue as part of the FSAR evaluation in 1996.

Enforcement Title 10 CFR 50.54(q)(2) requires, in part, a licensee authorized to possess and operate a nuclear power reactor shall follow and maintain the effectiveness of an emergency plan which meets the requirements in Appendix E to this part and the planning standards of 10 CFR 50.47(b). Title 10 CFR 50.47(b)(9) requires, in part, adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.

As of September 30, 2016, the licensee failed to maintain the effectiveness of its emergency plan and use adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency.

Specifically, the licensee failed to maintain the ability to accurately declare an EAL classification RG-1.1, and develop and issue accurate PARs during the implementation of the sites Emergency Plan in response to a rapidly progressing accident. The licensee failed to analyze the effect of increasing background radiation on the sites SGTS AXM indications based on the installed configuration of the AXM. As configured, the AXM would provide inaccurate indications of radioactive releases that are used as the licensees basis for determining EAL classification and development of PARs.

This is an apparent violation of NRC requirements.

The licensee documented the issue in the corrective action program as CR-16-29230.

Corrective actions for this issue included immediate actions to notify the Shift Manger, Emergency Response Organization personnel, and other appropriate plant staff on the status of the AXM and the use of alternate sampling capabilities. Additionally, the licensee has completed the installation of lead shielding around the AXM to ensure the accuracy of the AXM indications during accident conditions. AV 05000341/2017009-01 (Failure to Maintain the Effectiveness of the Sites Emergency Plan).

4OA5 Other Activities

.1 (Closed) Unresolved Item 05000341/2016003-02: Fluctuating Background Effect on

Accident Range Noble Gas Monitor

Introduction:

The inspectors closed an unresolved item (URI), which was discussed in NRC inspection report 05000341/2016003, and was related to the licensees ability, during an accident, to accurately quantify radioactive releases, potentially having an adverse impact on the licensees ability to effectively implement its Emergency Plan.

The inspectors determined that this issue represented a URI because more information was required to determine whether a performance deficiency existed associated with the licensees ability to effectively implement the sites Emergency Plan during a rapidly progressing accident scenario based on the existing configuration and location of the SGTS AXM.

Description:

During a walkdown of the facility and discussions with licensee staff, the inspectors identified that the SGTS AXM noble gas detector did not utilize the fluctuating background subtraction feature of the unit and only subtracted a fixed background rate.

The inspectors questioned this configuration because the physical location of the monitor was in close proximity to the SGTS filtration system, which could significantly change radiation levels in the area during an accident. The function of the AXM is to assess radioactivity being released from the plant during accident conditions. These readings are used for various purposes, including accident classification and off-site dose assessment, both of which can affect the protective action recommendations made by the licensee. On September 29, 2016, the licensee provided the inspectors an assessment of the potential impact of fluctuating background from the filtration system on the AXM noble gas detector. The licensee continued the assessment of the AXM configuration and the impact on the sites ability to effectively implement the Emergency Plan. On November 16, 2016, as documented in CR 16-23920, the licensee declared the AXM inoperable due to evidence the AXM could read radioactive releases approximately 1000 times greater than what is actually exiting the filter train and being released to the environment. This could lead to inaccurate EAL declarations and inaccurate dose assessments in an accident. Based on the additional information documented in CR-16-23290, the inspectors identified a potential finding and an apparent violation of regulatory requirements. Therefore, this URI is closed to the finding documented in section 2RS6.1 of this inspection report. AV 05000341/

2017009-01 (Failure to Maintain the Effectiveness of the Sites Emergency Plan).

4OA6 Management Meetings

.1 Exit Meeting Summary

On January 25, 2017, the inspectors presented the inspection results to Mr. K. Polson, Site Vice President, and other members of the licensee staff.

The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

K. Polson, Site Vice President

M. Caragher, Plant Manager

E. Kokosky, Director-Organizational Effectiveness

S. Maglio, Licensing Manager

N. Avrakatos, Emergency Preparedness Manager

K. Mann, Compliance Supervisor

S. Ward, Senior Licensing Engineer

R. LaBurn, Radiation Protection Manager

U.S. Nuclear Regulatory Commission

B. Kemker, Senior Resident Inspector

P. Smagacz, Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000341/2017009-01 AV Failure to Maintain the Effectiveness of the Sites Emergency Plan (Section 2RS6.1)

Closed

05000341/2016003-02 URI Fluctuating Background Effect on Accident Range Noble Gas Monitor (Section 4OA5)

Discussed

None