IR 05000352/2011503
| ML112550468 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 09/12/2011 |
| From: | James Trapp Plant Support Branch 1 |
| To: | Pacilio J Exelon Generation Co, Exelon Nuclear |
| References | |
| EA-11-128 IR-11-503 | |
| Download: ML112550468 (13) | |
Text
ber 12, 2011
SUBJECT:
LIMERICK GENERATING STATION, UNITS 1 AND 2, FOLLOW-UP INSPECTION OF EMERGENCY ACTION LEVEL AND EMERGENCY PLAN CHANGE INSPECTION REPORT 05000352/2011503; 05000353/2011503
Dear Mr. Pacilio:
On August 15, 2011, the U. S. Nuclear Regulatory Commission (NRC) completed an in-office inspection of your Limerick Generating Station Units 1 and 2. The purpose of the inspection was to review the facts and circumstances concerning changes made to Emergency Action Level HU6, which potentially decreased the effectiveness of the Limerick Emergency Plan without prior NRC approval. The enclosed report documents the inspection results, which were discussed by telephone on August 15, 2011, with Mr. V. Cwietniewicz and other members of your staff.
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 inspection was a follow-up to an issue identified during the December 2009 annual inspection of emergency plan and emergency action level changes at Exelons Braidwood Station, Inspection Report 05000456/2010503; 05000457/2010503. The NRC identified a change was made to an emergency action level basis which introduced a decrease in effectiveness to Braidwoods emergency plan. The NRC issued a Severity Level IV Traditional Enforcement violation with a Green finding to Braidwood. Extent of condition inspections were conducted at the other nine Exelon sites where similar violations and findings were identified.
Based on the results of this inspection, the NRC identified one issue that was evaluated under the risk significance determination process as having very low significance (Green). The NRC has also determined that the issue involved a violation of NRC requirements. The violation was evaluated in accordance with the NRC Enforcement Policy, and has been categorized at Severity Level IV. However, because of its very low safety significance, and because the issue was entered into your corrective action program, the NRC is treating the issue as a Non-Cited Violation (NCV) in accordance with Section 2.3.2 of the NRC Enforcement Policy. The current Enforcement Policy is included on the NRCs Web site at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. If you contest the subject or severity of a Non-Cited Violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U. S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, U. S. Nuclear Regulatory Commission, Region I, 475 Allendale Road, King of Prussia, PA 19406; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Limerick Generating Station. In addition, if you disagree with the characterization of any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspector at the Limerick Generating Station. The information that you provide will be considered in accordance with Inspection Manual Chapter 0305.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system, Agencywide Documents Access and Management System (ADAMS),
accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
James M. Trapp, Chief Plant Support Branch 1 Division of Reactor Safety Docket Nos. 50-352; 50-353 License Nos. NPF-39; NPF-85 Enclosure:
Inspection Report No. 05000352/2011503; 05000353/2011503 w/Attachment: Supplemental Information cc w/encl: Distribution via ListServ
SUMMARY OF FINDINGS
IR 05000352/2011503; 05000353/2011503; 07/01/2011 - 08/15/2011; Limerick Generating
Station, Units 1 and 2; Emergency Action Level and Emergency Plan Changes Inspection.
This report covers an approximate 2-month period of follow-up inspection and review of the licensees emergency action level and plan changes. One Severity Level IV Violation and associated Green finding was identified by the inspector. The Severity Level IV Violation was considered a Non-Cited Violation (NCV) of NRC regulations. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC)0609, Significance Determination Process. Findings for which the Significance Determination Process 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.
NRC-Identified
and Self-Revealed Findings
Cornerstone: Emergency Preparedness
- Severity Level IV/Green: The inspector identified a finding of very low safety significance involving a Severity Level IV NCV of 10 CFR 50.54(q) for failing to obtain prior approval for an emergency plan change which decreased the effectiveness of the plan. Specifically, the licensee modified the Emergency Action Level (EAL) Basis in EAL HU6, Revision 13, which indefinitely extended the start of the 15-minute emergency classification clock beyond a credible notification that a fire is occurring or indication of a valid fire detection system alarm. This change decreased the effectiveness of the emergency plan by reducing the capability to perform a risk significant planning function in a timely manner.
The violation affected the NRCs ability to perform its regulatory function because it involved implementing a change that decreased the effectiveness of the emergency plan without NRC approval. Therefore, this issue was evaluated using Traditional Enforcement. The NRC determined that a Severity Level IV violation was appropriate due to the reduction of the capability to perform a risk significant planning standard function in a timely manner. The licensee entered this issue into its corrective action program and revised the EAL basis to restore compliance.
The finding was more than minor using IMC 0612, because it is associated with the emergency preparedness cornerstone attribute of procedure quality for EAL and emergency plan changes, and it adversely affected the cornerstone objective of ensuring 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. Therefore, the performance deficiency was a finding. Using IMC 0609, Appendix B, the inspector determined that the finding had a very low safety significance because the finding is a failure to comply with 10 CFR 50.54(q) involving the risk significant planning standard 50.47(b)(4), which, in this case, met the example of a Green finding because it involved one Unusual Event classification (EAL HU6).
ii
Due to the age of this issue, it was not determined to be reflective of current licensee performance and therefore a cross-cutting aspect was not assigned to this finding.
(Section 1EP4)
Licensee-Identified Violations
No violations of significance were identified.
iii
REPORT DETAILS
REACTOR SAFETY
Cornerstone: Emergency Preparedness
1EP4 Emergency Action Level and Emergency Plan Changes
.1 Emergency Action Level and Emergency Plan Changes
a. Inspection Scope
This inspection was a follow-up review of an issue identified in December 2009 during a NRC Region III routine review of changes implemented to Exelons Braidwood Station Emergency Plan Annex Emergency Action Level (EAL) and EAL Basis. The Region I Emergency Preparedness inspector reviewed the issue for applicability to the Limerick Generating Station Emergency Plan. The Region I inspector reviewed applicable licensee documents and had discussions with licensee personnel. This inspection did not represent an inspection sample.
b. Findings
Introduction:
A Green finding involving a Severity Level IV, Non-Cited Violation (NCV) of 10 CFR 50.54(q) was identified by the inspector for the licensees change to the emergency plan which decreased the effectiveness of the plan without U. S. Nuclear Regulatory Commission (NRC) approval.
Description:
The Radiological Emergency Plan Annex for Limerick Generating Station, Revision 12, EAL HU6 provided the basis for declaring an Unusual Event due to a fire in the protected area not extinguished within 15 minutes of detection. The EAL HU6 Basis, Revision 12, stated, in part, The 15-minute period begins with a credible notification that a fire is occurring or indication of a valid fire detection system alarm. A verified alarm is assumed to be an indication of a fire unless personnel dispatched to the scene disprove the alarm within the 15-minute period. The report, however, shall not be required to verify the alarm.
On November 29, 2007, Limerick Generating Station staff implemented Revision 13 of the EAL HU6 Basis which added the following text: The 15-minute period to extinguish the fire begins with a credible notification that a fire is occurring or indication of a valid fire detection system alarm. If the alarm cannot be verified by redundant Control Room or nearby fire panel indications, notification from the field that a fire exists starts the 15-minute classification and fire extinguishment clocks. The 15-minute period to extinguish the fire does not start until either the fire alarm is verified to be valid by utilization of additional Control Room or nearby fire panel instrumentation, or upon notification of a fire from the field.
Revision 13 of the EAL HU6 Basis allowed delay of the 15-minute classification time by the dispatching of personnel, reporting the notification of a fire from the field, and extinguishing the fire. As a result, this change indefinitely extended the start of the 15-minute emergency classification clock beyond a credible notification that a fire is occurring or indication of a valid fire detection system alarm. This was determined to be a decrease in effectiveness of the licensees emergency plan because the change reduced the capability to perform a risk significant planning standard function in a timely manner. This change was not submitted to the NRC for prior approval.
On May 16, 2011, Exelon implemented Revision 20 of the Limerick Emergency Plan, which restored the EAL HU6 Basis language to the Revision 12 guidance, thereby removing the decrease in effectiveness.
Analysis:
The inspector determined that the change made by the licensee to the EAL HU6 Basis decreased the effectiveness of the Emergency Plan and the change was implemented without prior NRC approval. The issue was determined to be a licensee performance deficiency that impacted the regulatory process and, in accordance with Inspection Manual Chapter (IMC) 0612, Power Reactor Inspection Reports, was evaluated using the NRCs traditional enforcement policy as well as the Reactor Oversight Process (ROP).
Using the NRCs Enforcement Policy, this violation met Example c.2 in Section 6.6: A licensees ability to meet or implement any regulatory requirement related to assessment or notification is degraded such that the effectiveness of the emergency plan decreases.
Although the regulatory requirement could be implemented during the response to an actual emergency, the implementation would be degraded (e.g., not fully effective, inappropriately delayed). Specifically, the change made to the EAL Basis directly affected the Risk Significant Planning Standard Classification, which affected assessment of event conditions. Therefore, this violation met the example for Severity Level III. However, the NRC has classified this violation as a Severity Level IV, after determining that its actual and potential safety significance was very low based on the following considerations:
- (1) the issue involved only one Unusual Event EAL, and not any of the other higher event classifications; and
- (2) the issue could delay classification but would not prevent classification.
Using IMC 0612, Power Reactor Inspection Reports, Appendix B, Issue Screening, the performance deficiency was determined to be more than minor and, therefore, a finding, because it is associated with the emergency preparedness cornerstone attribute of procedure quality for EAL and emergency plan changes, and it adversely affected the cornerstone objective of ensuring 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 licensee made a change to its EAL Basis, which was a decrease in effectiveness, because the change indefinitely extended the start of the 15-minute emergency classification clock beyond a credible notification that a fire is occurring or indication of a valid fire detection system alarm. Also, this change was made without prior NRC approval.
The inspector determined the finding could be evaluated using the Significance Determination Process (SDP) in accordance with IMC 0609, Significance Determination Process, Appendix B, Emergency Preparedness Significance Determination Process.
The finding is a failure to comply with 10 CFR 50.54(q) involving the risk significant planning standard 50.47(b)(4), which, in this case, met the example of a Green finding because it involved one Unusual Event classification (EAL HU6).
Due to the age of this issue, greater than three years, it was not determined to be reflective of current licensee performance and therefore a cross-cutting aspect was not assigned to this finding. This change was screened through the licensees 50.54(q)process and was not identified as a decrease in effectiveness.
Enforcement:
10 CFR 50.54(q) states, in part, that a holder of a nuclear power reactor operating license shall follow and maintain in effect emergency plans which meet the standards in 50.47(b) and the requirements in appendix E of this part. The nuclear power reactor licensee may make changes to these plans without Commission approval only if the changes do not decrease the effectiveness of the plans and the plans, as changed, continue to meet the standards of 50.47(b) and the requirements of appendix E to this part.
10 CFR 50.47(b) provides specific standards that offsite emergency response plans for nuclear power reactors must meet. One such standard, 10 CFR 50.47(b)(4), is that a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.
Contrary to the above, on November 29, 2007, the licensee made a change to its emergency plan without Commission approval, and that change decreased the effectiveness of the plan and caused the plan to no longer meet the standards of 50.47(b) and appendix E to this part. Specifically, the licensee modified the EAL basis in EAL HU6, Revision 0, to delay the 15-minute classification time by waiting for the dispatch of personnel and the notification of a fire from the field. This change indefinitely extended the start of the 15-minute emergency classification clock beyond a credible notification that a fire is occurring or indication of a valid fire detection system alarm.
This change decreased the effectiveness of the emergency plan by reducing the capability to perform a risk significant planning function in a timely manner.
This violation impacted the regulatory process, was of very low safety significance and was also entered into the licensees corrective action program as IR 01184333, dated March 7, 2011. Because of its very low safety significance and because the issue was entered into the licensees corrective action program, the violation is being treated as a Severity Level IV Non-Cited Violation (NCV), consistent with Section 2.3.2 of the NRC Enforcement Policy (NCV 05000352/2011503-01; NCV 05000353/2011503-01, Changes Made to EAL HU6 Which Decreased the Effectiveness of the Plans Without Prior NRC Approval).
The underlying finding aspect of a violation is evaluated separately from the traditional enforcement violation and therefore the underlying finding is being assigned a separate tracking number (FIN 05000352/2011503-02; FIN 05000353/2011503-02, Changes Made to EAL HU6 Which Decreased the Effectiveness of the Plans Without Prior NRC Approval).
4OA6 Management Meetings
.1 Exit Meetings
On August 15, 2011, the inspector discussed the inspection results by telephone with Mr. V. Cwietniewicz and other members of the licensee staff. The licensee acknowledged the issue presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- V. Cwietniewicz, Corporate Emergency Preparedness Manager
- M. Jesse, Regulatory Assurance Manager
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
Opened
- 05000352/2011503-01 NCV (Traditional Enforcement) Changes to EAL Basis
- 05000352/2011503-01 Decreased the Effectiveness of the Plan without Prior NRC Approval (1EP4.1)
- 05000353/2011503-02 FIN Changes to EAL Basis Decreased the Effectiveness of the
- 05000353/2011503-02 Plan without Prior NRC Approval (1EP4.1)