IR 05000498/2017010

NRC Radiation Safety and Emergency Preparedness Inspection Report 05000498/2017010 and 05000499/2017010

ML17256A501
Person / Time
Site:	South Texas
Issue date:	09/13/2017
From:	Heather Gepford NRC/RGN-IV/DRS/PSB-2
To:	Gerry Powell South Texas
References
IR 2017010
Download: ML17256A501 (31)

Text

ptember 13, 2017

SUBJECT:

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION - NRC RADIATION SAFETY AND EMERGENCY PREPAREDNESS INSPECTION REPORT 05000498/2017010 AND 05000499/2017010

Dear Mr. Powell:

On August 3, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed a radiation safety inspection at your South Texas Project Electric Generating Station, Units 1 and 2, facility.

On September 7, 2017, the NRC inspectors discussed the results of this inspection with Mr. D. Rencurrel, Senior Vice President of Operations, and other members of your staff. The results of this inspection are documented in the enclosed report.

NRC inspectors documented one finding of very low safety significance (Green) in this report.

This finding involved a violation of NRC requirements. Additionally, NRC inspectors documented one Severity Level IV violation. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violations or significance of the NCVs, 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 copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC resident inspector at the South Texas Project Electric Generating Station.

If you disagree with a cross-cutting aspect assignment 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 U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC resident inspector at the South Texas Project Electric Generating Station. 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.

Sincerely,

/RA/

Heather J. Gepford, Ph.D., CHP, Branch Chief Plant Support Branch 2 Division of Reactor Safety Docket Nos. 50-498 and 50-499 License Nos. NPF-76 and NPF-80

Enclosure:

NRC Inspection Report 05000498/2017010 and 05000499/2017010 w/Attachments:

1. Supplemental Information 2. Request for Information

REGION IV==

Docket: 05000498 and 05000499 License: NPF-76 and NPF-80 Report: 05000498/2017010 and 05000499/2017010 Licensee: STP Nuclear Operating Company Facility: South Texas Project Electric Generating Station, Units 1 and 2 Location: FM 521 - 8 miles west of Wadsworth Wadsworth, Texas 77483 Dates: May 8 through September 7, 2017 Inspectors: L. Carson, Senior Health Physicist S. Money, Health Physicist P. Elkmann, Senior Emergency Preparedness Inspector S. Hedger, Emergency Preparedness Inspector Approved By: Heather J. Gepford, Ph.D., CHP Chief, Plant Support Branch 2 Division of Reactor Safety Enclosure

SUMMARY

IR 05000498/2017010; 05000499/2017010; 05/08/2017 - 08/03/2017; South Texas Project

Electric Generating Station, Units 1 and 2; Emergency Preparedness, Radiation Safety, 71114.05 The report covers an inspection by health physics and emergency preparedness inspectors from Region IV. Two findings, both of which were non-cited violation, were documented. The significance of inspection findings is indicated by their color (i.e., Green, White, Yellow, or Red)and determined using Inspection Manual Chapter 0609, Significance Determination Process, dated April 29, 2015. Cross-cutting aspects are determined using Inspection Manual Chapter 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 NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 6.

NRC-Identified

and Self-Revealed Findings

Cornerstone: Emergency Preparedness

Green.

The inspectors identified a non-cited violation of 10 CFR 50.54(q)(2) associated with the licensees failure to conduct correctly scoped drills as required by the site emergency plan in 2015 and 2016. Annually, the licensee was required to conduct a radiological monitoring drill involving taking samples on-site and offsite of air, vegetation, soil, and water samples. Semiannually, the licensee was required to conduct health physics drills which involved response to and analysis of simulated elevated airborne and liquid samples. During these years, the licensee failed to evaluate emergency response personnel demonstrating abilities addressing all of these criteria. This violation is not an immediate safety concern because drills were conducted involving the site health physics staff during the time period. This issue was entered into the licensees corrective action program in Condition Reports 17-15971 and 17-15974.

The performance deficiency was more than minor because it was associated with the emergency response organization performance (drills and exercises) cornerstone attribute and adversely affected the Emergency Preparedness cornerstone objective of being capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. The finding was evaluated using Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, dated September 22, 2015. The finding was determined to be of very low safety significance (Green) because it was a failure to comply with NRC requirements, was not associated with the risk-significant planning standards, and was not a loss of a planning standard function. The finding had a cross-cutting aspect in the area of human performance associated with resources because the licensees procedure defining drill objectives and demonstration criteria did not address the entire scope of the drill types in question [H.1]. (Section 1EP5)

• Severity Level IV. The NRC identified a Severity Level IV violation of 10 CFR 50.54(q)(3) for the failure to perform analyses demonstrating that changes to the emergency plan did not reduce the effectiveness of the plan before implementing the changes without prior NRC approval. The failure to perform required evaluations did not have any safety consequences; the inspectors verified that the changes did not reduce the effectiveness of the emergency plan. The issue was entered into the licensees corrective action program as Condition Report 2017-15956.

The failure to perform analyses of the effect of changes in processes supporting emergency preparedness is a performance deficiency. The performance deficiency is more than minor because it affected the procedure quality (plan changes) cornerstone attribute and adversely affected the Emergency Preparedness cornerstone objective of being capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. The performance deficiency was assessed using traditional enforcement because the licensees failure to perform a required analysis impacted the regulatory process. The issue was evaluated using the NRCs Enforcement Policy, dated November 1, 2016, Section 6.6(d), and was determined to be a Severity Level IV violation because the violation did not affect radiological assessment or offsite notification. Traditional enforcement violations are not assessed for cross-cutting aspects. (Section 1EP5)

Licensee-Identified Violations

None

REPORT DETAILS

1EP2 Alert and Notification System Evaluation

a. Inspection Scope

The inspectors verified the adequacy of the licensees methods for testing the primary and backup alert and notification system. The inspectors also reviewed the licensees program for identifying emergency planning zone locations requiring tone alert radios and for distributing the radios, and reviewed audits of distribution records. The inspectors interviewed licensee personnel responsible for the maintenance of the primary and backup alert and notification system and reviewed a sample of corrective action program reports written for alert and notification system problems. The inspectors compared the licensees alert and notification system testing program with criteria in NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1; FEMA Report REP-10, Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants; and the licensees current FEMA-approved alert and notification system design report, Updated Prompt Notification System Design Report, Revisions 1 and 2, dated 2010 and 2013.

These activities constitute completion of one alert and notification system evaluation sample as defined in Inspection Procedure 71114.02.

b. Findings

No findings were identified.

1EP3 Emergency Response Organization Staffing and Augmentation System

a. Inspection Scope

The inspectors verified the licensees emergency response organization on-shift and augmentation staffing levels were in accordance with the licensees emergency plan commitments. The inspectors reviewed documentation and discussed with licensee staff the operability of primary and backup systems for augmenting the on-shift emergency response staff to verify the adequacy of the licensees methods for staffing emergency response facilities, including the licensees ability to staff pre-planned alternate facilities.

The inspectors also reviewed records of emergency response organization augmentation tests and events to determine whether the licensee had maintained a capability to staff emergency response facilities within emergency plan timeliness commitments.

These activities constitute completion of one emergency response organization staffing and augmentation testing sample as defined in Inspection Procedure 71114.03.

b. Findings

No findings were identified.

1EP5 Maintenance of Emergency Preparedness

a. Inspection Scope

The inspectors reviewed the following for the period of November 2015 to April 2017:

• After-action reports for emergency classifications and events

• After-action evaluation reports for licensee drills and exercises

• Independent audits and surveillances of the licensees emergency preparedness program

• Self-assessments of the emergency preparedness program conducted by the licensee

• Licensee evaluations of changes made to the emergency plan and emergency plan implementing procedures

• Drill and exercise performance issues entered into the licensees corrective action program

• Emergency preparedness program issues entered into the licensees corrective action program

• Maintenance records for equipment supporting the emergency preparedness program

• Emergency response organization and emergency planner training records The inspectors reviewed summaries of 154 corrective action program reports associated with emergency preparedness and selected 21 to review against program requirements, to determine the licensees ability to identify, evaluate, and correct problems in accordance with planning standard 10 CFR 50.47(b)(14) and 10 CFR Part 50, Appendix E, IV.F. The inspectors verified that the licensee accurately and appropriately identified and corrected emergency preparedness weaknesses during critiques and assessments.

The inspectors reviewed summaries of 50 licensee evaluations of the impact of changes to the emergency plan and implementing procedures, and selected 10 to review against program requirements to determine the licensees ability to identify reductions in the effectiveness of the emergency plan in accordance with the requirements of 10 CFR 50.54(q)(3) and 50.54(q)(4). The inspectors verified that evaluations of proposed changes to the licensee emergency plan appropriately identified the impact of the changes prior to being implemented.

The inspectors reviewed summaries of 200 records pertaining to the maintenance of equipment and facilities used to implement the emergency plan, and selected 11 to review against program requirements to determine the licensees ability to maintain equipment in accordance with the requirements of 10 CFR 50.47(b)(8) and 10 CFR Part 50, Appendix E, IV.E. The inspectors verified that equipment and facilities were maintained in accordance with the commitments of the licensees emergency plan.

These activities constitute completion of one sample of the maintenance of the licensees emergency preparedness program as defined in Inspection Procedure 71114.05.

1. Failure to Conduct Drills in Accordance with the Site Emergency Plan

Introduction.

The inspectors identified a Green non-cited violation of 10 CFR 50.54(q)(2)associated with the licensees failure to follow their emergency plan. Specifically, the licensee failed to follow South Texas Project Electric Generating Station Emergency Plan, ICN 20-18, Section N, Addendum N-1, which requires that drills involving radiological monitoring and health physics be conducted on an annual and semi-annual basis, respectively, covering a specified scope of evaluations. The licensee failed to conduct a correctly scoped radiological drill in 2015 and 2016, and one of the health physics drills in 2016.

Description.

The inspectors reviewed drills and exercises conducted by the licensee between November 2015 and May 2017, and compared the drill and exercise evaluation reports to the requirements of the licensee emergency plan.

The inspectors determined that South Texas Project Electric Generating Station Emergency Plan, ICN 20-18, Section N, Addendum N-1, Sections 6.0 and 7.0, required the following for radiological monitoring and health physics drills:

• Radiological monitoring drills shall be conducted at the station annually. These drills shall provide for the monitoring of plant environs and radiological monitoring on-site and offsite. At least once every year collection and analysis will also include air, vegetation, soil, and water.

• Health physics drills shall be conducted semiannually, which involve response to and analysis of simulated elevated airborne and liquid samples and direct radiation measurements in the environment.

The inspectors evaluated drill reports for environmental monitoring drills held on March 16, 2015, and February 9, 2016. For the semi-annual health physics drill requirement, combined functional drill reports from 2015 and 2016 were reviewed.

Based on this review, the inspectors determined that the following drill requirements were not met:

• For the years 2015 and 2016, environmental monitoring was evaluated at only one location. Therefore, the scope of the evaluation did not provide for the requirement to monitor on-site and offsite.

• The 2015 and 2016 environmental monitoring drills included evaluating collection and analysis of a vegetation sample. However, collection and analysis of soil and water samples were not evaluated.

• One of the two semiannual health physics drills, held on August 17, 2016, did not include situational analysis and response actions by health physics staff as part of the demonstration criteria.

The inspectors reviewed the licensees documentation describing how emergency preparedness drills were developed, and what demonstration criteria were used to evaluate the emergency response staffs proficiency. Licensee document ZV-0027, Drill and Exercise Performance Objectives and Demonstration Criteria, Revision 3, stated the demonstration criteria for drill objectives related to these two drills. However, it did not capture all of the requirements of the emergency plan. Examples included:

• The drill objective for the environmental monitoring drill (HP Environmental Release Monitoring, OBJ-I-6) did not include demonstration criteria to evaluate the taking of both on-site and offsite samples.

• The same environmental monitoring drill objective did not specify the specific samples that were necessary.

• The drill objective for the health physics drill (HP In Plant Monitoring, OB-J-I-5)did not state that response actions based on the analysis of presented radiological conditions needed to be demonstrated.

The inspectors determined that the licensee did not conduct these drills in a manner that ensured that all of the required demonstration criteria were evaluated at the specified frequency. Therefore, the inspectors concluded that the licensee did not follow the requirements of the site emergency plan. The inspectors determined that all other drills required by the emergency plan were conducted in 2015 and 2016.

Analysis.

The failure to conduct drills required by the emergency plan is a performance deficiency within the licensees ability to foresee and correct. The performance deficiency was more than minor because it was associated with the emergency response organization performance (drills and exercises) cornerstone attribute and adversely affected the Emergency Preparedness Cornerstone objective of being capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. The licensees ability to take adequate measures to protect the health and safety of the public is degraded when the licensee does not perform drills and exercises to ensure emergency response organization proficiency.

The finding was evaluated using Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, dated September 22, 2015. The finding was determined to be of very low safety significance (Green) because it was a failure to comply with NRC requirements, was not associated with the risk significant planning standards, and was not a loss of planning standard function. The planning standard function was not lost because the licensee did conduct drills that addressed portions of the related emergency plan commitments.

The inspectors determined that the finding had a resources cross-cutting aspect in the human performance area because the licensees organization failed to ensure that procedures were adequate to support nuclear safety. Specifically, licensee procedures on drill objectives and demonstration criteria failed to cover the full scope of these drills as described in the emergency plan [H.1].

Enforcement.

Title 10 CFR 50.54(q)(2) requires, in part, that a power reactor licensee follow an emergency plan which meets the requirements of Appendix E to 10 CFR Part 50 and the standards of 10 CFR 50.47(b). Planning standard 10 CFR 50.47(b)(14) requires, in part, that the licensee conduct periodic drills to maintain key skills. South Texas Project Electric Generating Station Emergency Plan, ICN 20-18, Section N, Addendum N-1, Sections 6.0 and 7.0, requires, in part, that:

• Radiological monitoring drills shall provide for the monitoring of plant environs and radiological monitoring on-site and offsite. At least once every year collection and analysis will also include vegetation, soil, and water.

• Health physics drills shall involve response to and analysis of simulated elevated airborne and liquid samples and direct radiation measurements in the environment.

Contrary to the above, between January 1, 2016, and May 10, 2017, South Texas Project Electric Generating Station failed to follow an emergency plan which met the requirements of Appendix E and the Standards of 10 CFR 50.47(b). Specifically, the licensee failed to conduct annual and semi-annual drills involving the radiological monitoring and health physics respectively with the scope of evaluation required by the South Texas Project Electric Generating Station Emergency Plan, ICN 20-18, Section N, Addendum N-1, to maintain key emergency response organization skills. The inspectors determined that all other drills required to be conducted by the emergency plan were conducted in 2015 and 2016. This issue was entered into the licensees corrective action program as Condition Reports 17-15971 and 17-15974. Because this violation was determined to be of very low safety significance and was entered into the licensees corrective action program, this violation is being treated as an NCV, consistent with Section 2.3.2.a of the Enforcement Policy: NCV 05000498,05000499/2017010-01, Failure to Conduct Drills In Accordance With the Site Emergency Plan.

2. Failure to Perform Required 50.54(q) Evaluations Prior to Implementing Changes to the

Emergency Plan

Introduction.

The inspectors identified a Severity Level IV non-cited violation of 10 CFR 50.54(q)(3) for the failure to perform analyses demonstrating that changes to the emergency plan did not reduce the effectiveness of the emergency plan before implementing those changes without prior NRC approval.

Description.

The inspectors identified four licensee 50.54(q) screenings performed between November 2, 2015, and September 7, 2016, which did not result in the licensee performing an evaluation against the requirements of 10 CFR 50.54(q)(3) as required by Procedure 0PGP05-ZV-0010, Emergency Plan Change. The licensee concluded in the initial screening that a full analysis was not required when the procedure required the analysis. The proposed changes were subsequently implemented without the prior approval of the NRC.

The inspectors reviewed the 0PGP05-ZV-0010, Emergency Plan Change, Screen Evaluation Form, prepared for:

• 0ERP01-ZV-EF02, Deputy EOF Director, Revision 15, dated November 2, 2015

• 0ERP01-ZV-EF08, Licensing Director, Revision 9, dated May 9, 2016

• 0ERP01-ZV-IN07, Protective Action Recommendations, Revision 17, dated August 8, 2016

• 0ERP01-ZV-SH01, Shift Manager, Revision 31, dated September 7, 2016 The inspectors compared the 50.54(q) screening evaluations for 0ERP01-ZV-EF02, 0ERP01-ZV-EF08, 0ERP01-ZV-IN07, and 0ERP01-ZV-SH01 against the requirements of Procedure 0PGP05-ZV-0010, Revisions 16 and 17. In each screening, the licensee concluded in Block 3 that The change is not editorial or typographical, and in Block 4 that The change does not conform to an activity that has prior approval, and concluded that the change affected at least one 10 CFR 50.47(b) planning standard.

The inspectors determined that Procedure 0PGP05-ZV-0010, Addendum 1, Section 7.0, provided criteria for concluding that a proposed change did not require a full evaluation and could be implemented without the prior approval of the NRC. Specifically, Section 7.0 permitted implementation without an evaluation only if it affected one or more 10 CFR 50.47(b) planning standards or a plant commitment and either the proposed change was editorial, corrected typographical errors, or was bounded by an existing NRC approval. The inspectors concluded that the four screening evaluations did require full 50.54(q) evaluations according to the requirements of Procedure 0PGP05-ZV-0010 because the screenings identified the changes as not editorial or typographical, and not conforming to an activity that has prior NRC approval.

The licensees screening evaluations inappropriately concluded for these four changes that a full evaluation was not required and thus the evaluations were not performed.

Therefore, the inspectors concluded the licensee did not comply with the requirements of 10 CFR 50.54(q)(3) in implementing the four changes to the emergency plan because they did not perform an analysis demonstrating that the changes did not reduce the effectiveness of the emergency plan.

Analysis.

The licensees failure to perform required 50.54(q) evaluations is a performance deficiency within the licensees ability to foresee and correct. The performance deficiency is more than minor because it affected the procedure quality (plan changes) cornerstone attribute and adversely affected the cornerstone objective.

The ability of the licensee to ensure that adequate measures are taken to protect the health and safety of the public may be degraded when evaluations are not performed to ensure that changes made to the emergency plan do not reduce the plans effectiveness. The performance deficiency was assessed using traditional enforcement because the licensees failure to perform a required analysis impacted the regulatory process because a licensee evaluates changes affecting emergency preparedness to determine whether those changes require NRC approval before being implemented.

The performance deficiency was evaluated using the NRCs Enforcement Policy, dated November 1, 2016, Section 6.6(d). The issue was determined to be a Severity Level IV violation of NRC requirements because the licensees ability to implement regulatory requirements related to radiological assessment and offsite notification were not affected by the violation. Traditional enforcement violations are not assessed for cross-cutting aspects.

Enforcement.

Title 10 CFR 50.54(q)(3) states, in part, that a licensee may make changes to its emergency plan without NRC approval only if the licensee performs and retains an analysis demonstrating that the changes do not reduce the effectiveness of the plan. Contrary to the above, between November 2, 2015, and September 7, 2016, South Texas Project made changes to its emergency plan without NRC approval and did not perform and retain an analysis demonstrating that the changes did not reduce the effectiveness of the plan. Specifically, on November 2, 2015; May 9, 2016; August 8, 2016; and September 7, 2016, the licensee determined that proposed changes to the emergency plan did not require a 50.54(q) evaluation and could be implemented without NRC approval. The failure to perform required evaluations did not have any safety consequences; the inspectors verified that the changes did not reduce the effectiveness of the emergency plan. The issue was entered into the licensees corrective action program as Condition Report 2017-15956. This violation is being treated as an NCV, consistent with Section 2.3.2.a of the Enforcement Policy: NCV 05000498,05000499/2017010-02, Failure to Perform Required 50.54(q) Evaluations prior to Implementing Changes to the Emergency Plan.

RADIATION SAFETY

Cornerstones: Public Radiation Safety and Occupational Radiation Safety

2RS2 Occupational ALARA Planning and Controls

a. Inspection Scope

The inspectors assessed licensee performance with respect to maintaining individual and collective radiation exposures as low as is reasonably achievable (ALARA). The inspectors performed this portion of the attachment as a post-outage review. During the inspection, the inspectors interviewed licensee personnel, reviewed licensee documents, and evaluated licensee performance in the following areas:

• Radiological work planning, including work activities of exposure significance, and radiological work planning ALARA evaluations, initial and revised exposure estimates, and exposure mitigation requirements. The inspectors also verified that the licensees planning identified appropriate dose reduction techniques, reviewed any inconsistencies between intended and actual work activity doses, and determined if post-job (work activity) reviews were conducted to identify lessons learned.

• Verification of dose estimates and exposure tracking systems, including the basis for exposure estimates, and measures to track, trend, and if necessary reduce occupational doses for ongoing work activities. The inspectors evaluated the licensees method for adjusting exposure estimates and reviewed the licensees evaluations of inconsistent or incongruent results from the licensees intended radiological outcomes.

• Problem identification and resolution for ALARA planning. The inspectors reviewed audits, self-assessments, and corrective action program documents to verify problems were being identified and properly addressed for resolution.

These activities constitute completion of three samples of the five required samples of occupational ALARA planning and controls program, as defined in Inspection Procedure 71124.02, and completes the inspection.

b. Findings

No findings were identified.

2RS4 Occupational Dose Assessment

a. Inspection Scope

The inspectors evaluated the accuracy and operability of the licensees personnel monitoring equipment, verified the accuracy and effectiveness of the licensees methods for determining total effective dose equivalent, and verified that the licensee was appropriately monitoring occupational dose. The inspectors interviewed licensee personnel, walked down various portions of the plant, and reviewed licensee performance in the following areas:

• Source term characterization, including characterization of radiation types and energies, hard-to-detect isotopes, and scaling factors.

• External dosimetry including National Voluntary Laboratory Accreditation Program (NVLAP) accreditation, storage, issue, use, and processing of active and passive dosimeters.

• Internal dosimetry, including the licensees use of whole body counting, use of in vitro bioassay methods, dose assessments based on airborne monitoring, and the adequacy of internal dose assessments.

• Special dosimetric situations, including declared pregnant workers, dosimeter placement and assessment of effective dose equivalent for external exposures (EDEX), shallow dose equivalent, and neutron dose assessment.

• Problem identification and resolution for occupational dose assessment. The inspectors reviewed audits, self-assessments, and corrective action program documents to verify problems were being identified and properly addressed for resolution.

These activities constitute completion of the five required samples of occupational dose assessment program, as defined in Inspection Procedure 71124.04.

b. Findings

No findings were identified.

4OA1 Performance Indicator Verification

.1 Drill/Exercise Performance (EP01)

a. Inspection Scope

The inspectors reviewed the licensees evaluated exercises, emergency plan implementation, and selected drill and training evolutions that occurred between July 2016 and March 2017 to verify the accuracy of the licensees data for classification, notification, and protective action recommendation (PAR) opportunities. The inspectors reviewed a sample of the licensees completed classifications, notifications, and PARs to verify their timeliness and accuracy. The inspectors used Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data. The specific documents reviewed are described in the attachment to this report.

These activities constitute verification of the drill/exercise performance indicator as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.2 Emergency Response Organization Drill Participation (EP02)

a. Inspection Scope

The inspectors reviewed the licensees records for participation in drill and training evolutions between July 2016 and March 2017 to verify the accuracy of the licensees data for drill participation opportunities. The inspectors verified that all members of the licensees emergency response organization (ERO) in the identified key positions had been counted in the reported performance indicator data. The inspectors reviewed the licensees basis for reporting the percentage of ERO members who participated in a drill.

The inspectors reviewed drill attendance records and verified a sample of those reported as participating. The inspectors used Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data. The specific documents reviewed are described in the attachment to this report.

These activities constitute verification of the emergency response organization drill participation performance indicator as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.3 Alert and Notification System Reliability (EP03)

a. Inspection Scope

The inspectors reviewed the licensees records of alert and notification system tests conducted between July 2016 and March 2017 to verify the accuracy of the licensees data for siren system testing opportunities. The inspectors reviewed procedural guidance on assessing alert and notification system opportunities and the results of periodic alert and notification system operability tests. The inspectors used Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the reported data. The specific documents reviewed are described in the attachment to this report.

These activities constitute verification of the alert and notification system reliability performance indicator as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On May 12, 2017, the emergency preparedness inspectors presented the results of the inspection of the licensees emergency preparedness program to Mr. A. Capristo, Executive Vice President and Chief Administrative Officer, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

On August 3, 2017, the health physics inspectors presented the radiation safety inspection results to Mr. D. Koehl, President and Chief Executive Officer, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

On September 7, 2017, the inspectors presented the results of the inspection to Mr. D. Rencurrel, Senior Vice President of Operations, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

R. Aguilera, Manager, Plant Protection/Emergency Response

A. Capristo, Executive Vice President and Chief Administrative Officer

R. Gonzales, Staff Engineer, Licensing

D. Koehl, President and Chief Executive Officer

D. Rencurrel, Senior Vice President, Operations

J. Connolly, Vice President, Site

D. Hubernak, Supervisor, General Health Physics

K. Kawabata, Health Physicist

J. Pointon, Supervisor, ALARA

B. Scarborough, Manager, Nuclear Oversight

C. Stone, Manager, Radiation Protection/Health Physics

M. Pilgreen, Supervisor, Technical Support

L. Kauffman, RPT Outage Planner

M. Murray, Manager, Regulatory Affairs/Licensing

J. Enoch, Supervisor, Emergency Response

D. Rencurrel, Senior Vice President of Operations

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000498/2017010-01, NCV Failure to Conduct Drills In Accordance with the Site

05000499/2017010-01 Emergency Plan (Section 1EP5)

05000498/2017010-02, NCV Failure to Perform Required 50.54(q) Evaluations prior to

05000499/2017010-02 Implementing Changes to the Emergency Plan (Section 1EP5)