ML051580171
| ML051580171 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 05/28/2005 |
| From: | Swenson C AmerGen Energy Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation, NRC/OE |
| References | |
| 2130-05-20103, EA-04-213 | |
| Download: ML051580171 (5) | |
Text
AmerGen Energy Company, LLC www.exeloncorp.com AmerGen.. An Exelon Company Oyster Creek US Route g South, PO. Box 388 Forked River, NJ 08731.0388 10CFR 2.201 May 28, 2005 2130-05-20103 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Oyster Creek Generating Station Facility Operating License No. DPR-16 NRC Docket No. 50-219
Subject:
Supplemental to Reply to Notice of Violation EA-04-213
Reference:
(1) Replyto Notice of Violation EA-04-213, AmerGen Energy Company LLC, Oyster Creek Generating Station, to U.S. Nuclear Regulatory Commission, dated March 31, 2005 (2) FINAL SIGNIFICANCE DETERMINATION FOR A WHITE FINDING AND NOTICE OF VIOLATION (NRC Inspection Report 05000219/2004009) Oyster Creek Generating Station, dated March 1, 2005 This letter is to supplement our Reply to Notice of Violation EA-04-213 (Reference 1) submitted on March 31, 2005 as directed by the NRC letter dated March 1, 2005, Final Significance Determination for a White Finding and Notice of Violation (NRC Inspection Report 05000219/2004009) for the Oyster Creek Generating Station (Reference 2). Attachment 1 to this cover letter provides the revised reply to the Notice of Violation based upon further review of the original root cause evaluation. Attachment 2 lists the revised regulatory commitments made in this reply.
If any further information or assistance is needed, please contact David Fawcett at 609-971-4284.
Sincerely, C. Swen o Vice President, Oyster Creek Generating Station CNS/DIF - Revised Reply to the Notice of Violation - Revised Summary of Regulatory Commitments cc: S. J. Collins, Administrator, USNRC Region I P. S. Tam, USNRC Senior Project Manager, Oyster Creek R. J. Summers, USNRC Senior Resident Inspector, Oyster Creek File No. 05012 I.
Revised Reply to Notice of Violation EAT04-213 ATTACHMENT 1 AmerGen Energy Company, LLC Docket No. 50-219 Oyster Creek Generating Station License No. DPR-16 Restatement of Violation EA-04-213 During an NRC inspection conducted between August 23 - November 29, 2004, for which exit meetings were held on August 26 and November 29, 2004, violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1 600, the violation is listed below:
A. 10 CFR 50.54(q) requires a licensee authorized to possess and operate a nuclear power reactor to follow and maintain in effect emergency plans which meet the standards in 10 CFR 50.47(b).
10 CFR 50.47(b)(4) requires the facility licensee to have a standard emergency classification and action level scheme in use, 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, for the period between July 23- 31, 2004, the licensee had a degraded emergency classification and action level scheme in use because the Fission Product Barrier Matrix Emergency Action Level contained an incorrect threshold value, which could have delayed a General Emergency declaration and subsequent minimum initial offsite response actions directed by state and local response plans. Specifically, a threshold value (reactor water level) used to make a General Emergency declaration (in conjunction with other factors), was incorrectly listed as "less than minus 30" top of active fuel" when it should have been "less than minus 20" top of active fuel."
B. Technical Specification 6.8.1 requires written procedures covering the applicable procedures in Appendix "A" of Regulatory Guide 1.33, as referenced in the Quality Assurance Topical Report (QATR). Chapter 6 of the Exelon Quality Assurance Topical Report, NO-AA-1 0, Revision 72, dated March 8,2004, describes that the Company has in place programmatic controls, which ensure that procedures are technically correct before use and that procedures are reviewed and revised as needed, when pertinent source material is changed, when the plant design is changed, or when deficiencies are identified and corrected.
Procedure CC-AA-102, "Design Input and Configuration Change Impact Screening,"
requires responsible departments to identify the procedures within their scope of responsibility that are affected by the configuration change and to create action requests to track the procedure changes, and requires the responsible engineer to determine the effect of the configuration change on the general station emergency response plans or scenarios.
Contrary to the above, on July 23, 2004, the licensee did not follow the configuration control process for implementing the necessary changes to station procedures when pertinent source material changed (reactor water level threshold value). As a result, necessary changes were not made to the Fission Product Barrier Matrix Emergency I
Revised Reply to Notice of Violation EA-04-213 Action Level, as well as to Emergency Operating Procedure flow chart 2000-EMG-3200.12, "Secondary Containment and Reactivity Release Control," Table 14, and to Emergency Plan Implementing Procedure, EP-OC-123-1006, "Radiological Assessment Computer Program Technical Basis."
These violations are associated with a WHITE significance determination process finding.
AmerGen Reply to Notice of Violation EA-04-213 AmerGen concurs with the violations as written.
Reason for the Violations This finding involved untimely actions to change an Emergency Action Level (EAL), namely a Fission Product Barrier Matrix threshold value used for making a General Emergency (GE) declaration.
Program implementation and human performance deficiencies were contributing factors to this finding. More specifically, a configuration change process was not used to ensure that the Emergency Preparedness department was aware of a plant configuration change that would require a simultaneous change to an affected EAL related to the emergency declaration.
AmerGen used the procedure revision process rather than the configuration control process for implementing the necessary changes to station procedures when the Minimum Steam Cooling Reactor Water Level (MSCRWL) value was revised, resulting in the failure to make the necessary changes to the EALs, as well as to emergency operating procedures (EOP) flow chart procedure, 2000-EMG-3200.12, "Radioactivity Release Control," Table 14, and to the Emergency Plan Implementing Procedure, EP-OC-123-1006, "Radiological Assessment Computer Program Technical Basis."
A revised root cause analysis was completed that determined the following:
The first root cause was determined to be that the individuals involved in the fuel EPG parameter change and subsequent EOP procedure changes did not use the configuration control process requirements due to knowledge deficiencies.
The second root cause was that insufficient technical rigor was applied during resolution of a design input error associated with ECR OC 02-00789 for use of GE-1 1 fuel because a formal technical human performance process and procedure was not in place.
Corrective Steps that Have Been Taken and the Results Achieved Following self identification of this issue, AmerGen took immediate corrective actions that included: (1) the reactor power was reduced in order to support the rod pattern change to satisfy the previous MSCRWL limit of minus 30" TAF; (2) a 10 CFR 50.54(q) review was conducted to ensure the change would not decrease the effectiveness of the plan; and (3) the EAL change was reviewed by the Plant Operations Review Committee (PORC) and approval was obtained from the State of New Jersey, Bureau of Nuclear Engineering prior to implementation.
The EAL revision to correct the value for MSCRWL was completed on 07/31/2004.
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Revised Reply to Notice of Violation EA 213 Corrective Steps that Have Been Taken and the Results Achieved (cont'd)
Emergency Operating Procedures (EOP) flow chart procedure,2000-EMG-3200.12, Radioactivity Release Control, Table 14, has been revised to reflect the new value for MSCRWL.
Emergency Plan Implementing Procedure, EP-OC-123-1006, Radiological Assessment Computer Program Technical Basis has been revised with a target implementation date of 5/31/2005 to incorporate the replacement of the RAC program with the Exelon standard dose assessment program. EP-OC-123-1006, Rev. 1 is now titled, Dose Assessment and Protective Action Recommendation (DAPAR) Technical Basis for Oyster Creek Generating Station.
Corrective Steps that Were or Will Be Taken to Avoid Further Violations CAPR 1. Conduct the following topics as part of Engineering Support Program (ESP) training;
- 1) Emergency Plan revision process and; 2) How to recognize when the configuration change process should be invoked and the proper organizations to involve in the task. These topics are to be added to the list of engineering recurring training topics. Action - CAP 02004-1986-11.
Due 7/30/2005.
CAPR 2. Revise the administrative procedure for control of EOP documents (AD-OC-103, EOP/SAM Program Control) to include instructions to use the appropriate configuration control process to revise the plant specific technical guidelines (PSTG) Appendix C criteria. Action -
CAP 02004-1986-12. Completed 12/02/2004.
CAPR 3. Provide training and qualification to perform and review configuration changes per Exelon processes to the appropriate level of personnel in the Exelon Fuels organization. CAP 02004-1986-21 Completed 12/03/2004.
CAPR 4. Fully implement and provide training on Technical Task Risk/Rigor Assessment Procedure HU-AA-1212, with all OC Engineering department personnel. Action - CAP 02004-1986-13. Completed 12/06/2004.
Date When Full Compliance Will Be Achieved The Oyster Creek Emergency Plan was brought into Full Compliance on July 31, 2004 when the Emergency Plan EALs were revised to the new value for MSCRWL.
Emergency Operating Procedures (EOP) flow chart procedure, 2000-EMG-3200.12, Radioactivity Release Control, Table 14, was revised on May 26, 2005 to reflect the new value for MSCRWL An additional action to implement a revised EP-OC-123-1006, Radiological Assessment Computer Program Technical Basis will be completed no later than June 3, 2005 with the implementation of EP-OC-123-1006, Rev. 1., Dose Assessment and Protective Action Recommendation (DAPAR) Technical Basis for Oyster Creek.
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Revised Reply to Notice of Violation EA-04-213 ATTACHMENT 2 REVISED
SUMMARY
OF COMMITMENTS The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.)
COMMITTED COMMITMENT TYPE COMMITMENT DATE OR "OUTAGE" ONE-TIME ACTION PROGRAMMATIC Conduct the following topics as part of Engineering Support Program (ESP) training; 1)
Emergency Plan revision process and; 2) How 7/30/2005 YES to recognize when the configuration change process should be invoked and the proper organizations to involve in the task. These topics are to be added to the list of engineering recurring training topics.
Revise the administrative procedure for control of EOP documents (AD-OC-1 03, EOP/SAM Program Control) to include instructions to use 12/02/2004 YES the appropriate configuration control process to revise the plant specific technical guidelines (PSTG) Appendix C criteria.
Provide training and qualification to perform and review configuration changes per Exelon processes to the appropriate level of personnel 12/03/2004 YES in the Exelon Fuels organization.
Fully implement the Technical Task Risk/Rigor Assessment Procedure HU-AA-1212 with OC Engineering department personnel. 12/06/2004 YES 4