L-07-007, Reply to Notice of Violation - EA-06-215
| ML070160236 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 01/11/2007 |
| From: | Lash J FirstEnergy Nuclear Operating Co |
| To: | Document Control Desk, NRC Region 1 |
| References | |
| EA-06-215, L-07-007 | |
| Download: ML070160236 (6) | |
Text
FENOC FirstEnergyNuclear Operating Company James H. Lash 724-682-5234 Site Vice President Fax: 724-643-8069 January 11, 2007 L-07-007 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555
Subject:
Beaver Valley Power Station, Unit Nos. 1 and 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 Reply to Notice of Violation - EA-06-215 In response to NRC correspondence dated December 12, 2006, and in accordance with 10 CFR 2.201, the attached reply addresses the Notice of Violation transmitted with the letter.
If there are any questions concerning this matter, please contact Mr. Colin P. Keller, Manager, Regulatory Compliance at 724-682-4284.
Sincerely, C~mes H. Lash Attachments: 1. Reply to Notice of Violation - EA-06-215
- 2. Commitment List c: Ms. N. S. Morgan, NRR Project Manager Mr. P. C. Cataldo, NRC Senior Resident Inspector Mr. S. J. Collins, NRC Region I Administrator Mr. D. A. Allard, Director BRP/DEP Mr. L. E. Ryan (BRP/DEP)
ATTACHMENT 1 FIRSTENERGY NUCLEAR OPERATING COMPANY Beaver Valley Power Station Unit Nos. 1 and 2 Reply to Notice of Violation - EA-06-215 Letter dated December 12. 2006 VIOLATION EA-06-215 10 CFR Part 50.47(b)(9), requires, in part, that adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.
Contrary to the above, as of June 27, 2006, the Beaver Valley Power Station (BVPS) method for assessing actual and potential offsite consequences of a radiological emergency condition was inadequate. Specifically, "BVPS Procedure 1/2-EPP-IP-2.6.3, Dose Projection - ARERAS/MIDAS With Real-Time Inputs, revision 13," stated that "IF the duration of a release cannot be estimated, THEN use 1.0 hour0 days <br />0 hours <br />0 weeks <br />0 months <br />, and repeat the projection as better data become available." This is inadequate because the one hour default release duration may not adequately envelope existing plant conditions and, therefore, could lead to untimely protective action recommendations. As an example, during the June 27, 2006, emergency preparedness exercise, the licensee used one hour as a release duration time, even though the release had been occurring for at least 30 minutes and there was no reason to conclude the release would be terminated within one hour of initiation.
This violation is associated with a White Significance Determination Process finding.
Reason for the Violation The Root Cause was determined to be "Rule Based Error" due to a mind set. A rule had been adopted, proceduralized, and taught at Beaver Valley that directed the assignment of a one hour release duration for a radiological release if information was not sufficient to estimate or postulate a more accurate projection. This rule, however, was being generically applied to scenarios where it was very likely the radiological release would be greater than one hour. The mind set had been ingrained into the program, limiting the ability to self-identify the concern. Procedure content reflected the mind-set, further limiting the ability to self-identify the issue, as performance would be deemed as compliant.
to L-07-007 Page 2 Corrective Actions Taken and Results Achieved
- 1. Information was provided to applicable Emergency Response Organization (ERO) personnel in both the Technical Support Center (TSC) and Emergency Operations Facility (EOF) on the need for determining the actual or estimated radioactive release duration during an emergency event. It was stated that it is an expectation that the ERO make a rigorous attempt to determine or estimate the release duration of a potential or ongoing radiological release. Explicit potential questions regarding release origin and ability for isolation were provided as examples of the type of information that should be rigorously sought. It was reinforced that the estimate of release duration is expected to be used and is preferred to the use of a default time that is permitted by current BVPS emergency procedures. Although BVPS is currently pursuing changing this emergency procedure default time to a longer value (e.g., six hours, consistent with evacuation times); it is expected that the ERO will determine a best-estimate release time duration for any radiological release based upon event information.
- 2. The Extent of Condition evaluation was performed by evaluating the default duration values used in BVPS Dose Assessment procedures. These values are based on UFSAR accident types. The durations used as default values along with the technical bases for those values were reviewed. As a result of this review, three issues were found regarding insufficient documentation of the technical basis or references in the procedures. The issues were entered into the Corrective Action Program for resolution. The remaining procedures reviewed were found have a sufficient regulatory basis and/or industry accepted justification.
Corrective Actions to Prevent Further Violations
- 1. Applicable Emergency Response Organization (ERO) procedures will be revised to provide guidance for the ERO to estimate the anticipated duration of a release, even when specific release information is not readily available. Applicable ERO personnel duties will be revised to emphasize the need to find the source of a leak/release and to provide the best estimate for isolating the leak/release to provide the best data for performing a dose projection. The procedures will include instructions for ERO personnel in both the Technical Support Center and the Emergency Operations Facility to ask specific questions directed at quantifying a projected release duration.
Applicable procedure revisions will be implemented by January 28, 2007.
- 2. Applicable ERO personnel will receive training on the need to determine the source of the leak/release and the best estimate of when the leak/release will be isolated in order to provide the best data to the dose projection process. This training will be completed by June 15, 2007.
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- 3. Applicable ERO personnel will receive training on this Notice of Violation, the results of the FENOC investigation of this issue, including its root cause, and the applicable emergency planning standards in 10 CFR 50.47(b). Emphasis will be placed on the use of a questioning attitude and thorough critiques when assessing emergency preparedness performance with particular emphasis to the risk significant planning standards in 10 CFR 50.47(b). This training will be completed by June 15, 2007.
- 4. The time frame that will be used at BVPS during emergency events when a radiation release duration cannot be reasonably estimated is proposed to be changed from a one-hour release duration to a longer time release in the applicable emergency procedures. Industry benchmarking was performed and the proposed change will align BVPS with the industry and is expected to be submitted to the NRC for approval by January 31, 2007. The applicable BVPS emergency procedures will be revised within 30 days after receiving NRC approval of the requested BVPS emergency procedure changes.
- 5. The effectiveness of the procedures changes and training for applicable ERO personnel on the need to determine the source of the leak/release and the best estimate of when the leak/release will be isolated will be assessed by performing tabletop demonstrations and/or drills. This effectiveness review will be completed by June 15, 2007.
- 6. The effectiveness of the ERO understanding of the proposed change in the default release time (from one hour to a longer time frame) and when to use the default time will also be assessed so that this change can be implemented in a timely manner following NRC approval. This effectiveness review will be completed within 60 days after receiving NRC approval of the requested BVPS emergency procedure changes.
Date when Full Compliance will be Achieved BVPS will be in full compliance within 60 days from NRC approval of the requested BVPS emergency procedure changes described above.
ATTACHMENT 2 Commitment List The following list identifies those actions committed to by FirstEnergy Nuclear Operating Company (FENOC) for Beaver Valley Power Station (BVPS) Unit Nos. 1 and 2 in this document. Any other actions discussed in the submittal represent intended or planned actions by FENOC. They are described only as information and are not regulatory commitments. Please notify Mr. Colin P. Keller, Manager, Regulatory Compliance, at 724-682-4284 of any questions regarding this document or associated regulatory commitments.
Commitment Due Date
- 1. Applicable Emergency Response Organization January 28, 2007 (ERO) procedures will be revised to address the need for the ERO to make specific attempts to estimate the anticipated duration of a release.
- 2. Applicable Emergency Response Organization June 15, 2007 personnel will receive training on the need to determine the source of the leak/release and the best estimate of when the leak/release will be isolated in order to provide the best data to the dose projection process.
- 3. Applicable Emergency Response Organization June 15, 2007 personnel will receive training on this Notice of Violation, its root cause, the results of the FENOC investigation of this issue and the emergency planning standards in 10 CFR 50.47(b). Emphasis will be placed on the use of a questioning attitude and thorough critiques when assessing emergency preparedness performance with particular emphasis to the risk significant planning standards in 10 CFR 50.47(b).
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- 4. The time frame that will be used at BVPS Within 30 days after receiving during emergency events when a radiation NRC approval of the release duration cannot be reasonably estimated requested BVPS emergency is proposed to be changed from a one-hour procedure changes.
release duration to a longer time release in the applicable emergency procedures.
- 5. The effectiveness of the procedures changes June 15, 2007 and training for applicable ERO personnel on the need to determine the source of the leak/release and the best estimate of when the leak/release will be isolated will be assessed by performing tabletop demonstrations and/or drills.