ML071060304
| ML071060304 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 05/03/2007 |
| From: | Reyes L NRC/EDO |
| To: | Gasser J Southern Nuclear Operating Co |
| Campbell, S 415-1730 | |
| Shared Package | |
| ML071060284 | List: |
| References | |
| EA-06-132, EDATS: OEDO-2007-0029, G20070040 | |
| Download: ML071060304 (4) | |
Text
May 3, 2007 EA-06-132 Mr. Jeffrey Gasser Executive Vice President and Chief Nuclear Officer Southern Nuclear Operating Company, Inc.
Post Office Box 1295 Birmingham, AL 35201
Dear Mr. Gasser:
In response to your January 12, 2007, letter, I am providing my determination of Southern Nuclear Operating Companys (SNC) appeal of the Vogtle Electric Generating Plant Emergency Preparedness (EP) Cornerstone White finding that is described in NRC Inspection Report Nos.
05000424/2006009 and 05000425/2006009. After careful consideration of all the available information, I have determined that the NRC staffs White finding regarding the post-exercise critique is appropriate. As reflected in my letter dated March 1, 2007, I considered the following factors in reviewing SNCs appeal:
(1)
Whether the NRC failed to consider, or incorrectly considered, docketed information that is relevant to the appealed significance determination; (2)
Whether the significance determination was inconsistent with the applicable Significance Determination Process (SDP) guidance or lacked justification; and (3)
Whether the SDP provides an inappropriate outcome (e.g., adverse to safety).
SNCs appeal states that given the reactor conditions and procedural guidance available the Site Area Emergency (SAE) declaration made by the Emergency Director (ED) reflected the best information available at the time. It is never the NRCs intention to limit an Emergency Managers ability to assess all available information in an exercise scenario and proceed with the timely completion of appropriate actions. However, in reviewing this issue, I determined that the emphasis placed on the validity of the EDs classification of the event diverted attention from the important issue regarding the adequacy of the critique required by 10 CFR 50.47(b)(14) and Section IV.F.2.g of Appendix E to 10 CFR Part 50.
The NRCs primary concern, as discussed by Region II in its initial finding and subsequent response to the finding appeal, remains the adequacy of the critique following the exercise.
The NRC considers a licensees ability to evaluate knowledge gaps and other deficiencies occurring during an exercise and to take effective corrective actions based on those evaluations to be a crucial component in the safe operation of the plant. This is critical both to ensure that identified problems do not recur during actual events or emergencies and to ensure that the Performance Indicators (PIs) reported by the licensee in the EP Cornerstone are reliable.
J. Gasser In evaluating SNCs appeal, I reviewed SNCs biennial exercise scenario, all docketed correspondence between NRC and SNC and information presented in the March 26, 2007, public meeting on this issue. Based on my review, I have determined that the NRC staff appropriately and correctly considered all relevant information related to the significance determination.
Based on my review, I have determined that the SDP provided an appropriate outcome. The exercise involved some fuel failure and the loss of forced circulation, followed by a drop in pressurizer level due to natural circulation formation. Although these symptoms, early in the exercise, were similar to those that could be expected during a non-isolable reactor coolant system (RCS) leak greater than the capacity of one charging pump, there was additional plant information available that indicated natural circulation formation was occurring. SNCs final critique report dated April 26, 2006, documented that, The SAE was evaluated for PI data
[ability to identify and correctly classify the emergency throughout the exercise as a successful opportunity] because all plant indications at the time were valid and the crew was in compliance with applicable procedures and management expectations. For that reason, SNC stated that it did not consider contrary information available during the critique. Since the necessary information was available to determine that the exercise did not involve a non-isolable RCS leak, the SAE declaration did not reflect all valid and appropriate plant conditions. Had this been an actual event, the SAE declaration could have resulted in unnecessary and inappropriate public protective actions. The NRC expects licensees to fully critique their exercises to identify and reconcile any deficiencies. A proper critique may have identified corrective actions that, in the future, would allow operators to better distinguish between plant conditions indicative of natural circulation formation and a non-isolable RCS leak greater than the capacity of one charging pump.
Regarding whether the significance determination was inconsistent with the applicable SDP guidance, some clarification of the guidance and examples provided in Manual Chapter (MC) 0609, Appendix B, Emergency Preparedness Significance Determination Process, may be appropriate. My staff is currently assessing whether Section 4.14.1 of this MC provides a clear example that a failure to critique an emergency response organizations inappropriate classification of an event is a White finding. As part of the assessment process, we intend to seek input from the industry and other external stakeholders.
As I previously stated, the purpose of this finding is to emphasize the importance of an emergency exercise critique that is capable of identifying and correcting any deficiencies. My decision on this matter is not a reflection on the performance of the operators during the exercise and should not discourage licensees and plant operators from taking the appropriate time to properly diagnose and characterize an emergency.
Sincerely,
/RA/
Luis A. Reyes Executive Director for Operations cc: See next page
J. Gasser In evaluating SNCs appeal, I reviewed SNCs biennial exercise scenario, all docketed correspondence between NRC and SNC and information presented in the March 26, 2007, public meeting on this issue. Based on my review, I have determined that the NRC staff appropriately and correctly considered all relevant information related to the significance determination.
Based on my review, I have determined that the SDP provided an appropriate outcome. The exercise involved some fuel failure and the loss of forced circulation, followed by a drop in pressurizer level due to natural circulation formation. Although these symptoms, early in the exercise, were similar to those that could be expected during a non-isolable reactor coolant system (RCS) leak greater than the capacity of one charging pump, there was additional plant information available that indicated natural circulation formation was occurring. SNCs final critique report dated April 26, 2006, documented that, The SAE was evaluated for PI data
[ability to identify and correctly classify the emergency throughout the exercise as a successful opportunity] because all plant indications at the time were valid and the crew was in compliance with applicable procedures and management expectations. For that reason, SNC stated that it did not consider contrary information available during the critique. Since the necessary information was available to determine that the exercise did not involve a non-isolable RCS leak, the SAE declaration did not reflect all valid and appropriate plant conditions. Had this been an actual event, the SAE declaration could have resulted in unnecessary and inappropriate public protective actions. The NRC expects licensees to fully critique their exercises to identify and reconcile any deficiencies A proper critique may have identified corrective actions that, in the future, would allow operators to better distinguish between plant conditions indicative of natural circulation formation and a non-isolable RCS leak greater than the capacity of one charging pump.
Regarding whether the significance determination was inconsistent with the applicable SDP guidance, some clarification of the guidance and examples provided in Manual Chapter (MC) 0609, Appendix B, Emergency Preparedness Significance Determination Process, may be appropriate. My staff is currently assessing whether Section 4.14.1 of this MC provides a clear example that a failure to critique an emergency response organizations inappropriate classification of an event is a White finding. As part of the assessment process, we intend to seek input from the industry and other external stakeholders.
As I previously stated, the purpose of this finding is to emphasize the importance of an emergency exercise critique that is capable of identifying and correcting any deficiencies. My decision on this matter is not a reflection on the performance of the operators during the exercise and should not discourage licensees and plant operators from taking the appropriate time to properly diagnose and characterize an emergency.
Sincerely,
/RA/
Luis A. Reyes Executive Director for Operations cc: See next page DISTRIBUTION: (G20070040)
Public LPL 2-1 R/F RidsNrrDorl (Chaney)
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RidsNrrLAMOBrien Serita Sanders, NRR RidsOpaMail PMNS RidsOgcMailCenter RidsAcrsAcnwMailCenter S Campbell, EDO Kclark, OPA, RgnII DEDR R/f EDO r/f OGC C Carpenter S Bozin, EDO RidsRgn2MailCenter(S. Schaeffer)
ML071060284 OFFICE TRPS TRPS/BC AO/EDO OE OGC DEDR EDO NAME SCampbell:ssb CMiller MJohnson CCarpenter LChandler WKane LReyes DATE 04/17/07 04/19/07
/ /07 04/19/07 04/19/07 04/20/07 05/03/07 OFFICIAL RECORD COPY
Vogtle Electric Generating Plant, Units 1 & 2 cc:
Mr. Tom E. Tynan Vice President - Vogtle Vogtle Electric Generating Plant 7821 River Road Waynesboro, GA 30830 Mr. N.J. Stringfellow Manager, Licensing Southern Nuclear Operating Company, Inc.
P.O. Box 1295 Birmingham, AL 35201-1295 Mr. Steven M. Jackson Senior Engineer - Power Supply Municipal Electric Authority of Georgia 1470 Riveredge Parkway, NW Atlanta, GA 30328-4684 Mr. Reece McAlister Executive Secretary Georgia Public Service Commission 244 Washington St., SW Atlanta, GA 30334 Mr. Harold Reheis, Director Department of Natural Resources 205 Butler Street, SE, Suite 1252 Atlanta, GA 30334 Attorney General Law Department 132 Judicial Building Atlanta, GA 30334 Mr. Laurence Bergen Oglethorpe Power Corporation 2100 East Exchange Place P.O. Box 1349 Tucker, GA 30085-1349 Arthur H. Domby, Esquire Troutman Sanders Nations Bank Plaza 600 Peachtree Street, NE Suite 5200 Atlanta, GA 30308-2216 Resident Inspector Vogtle Plant 8805 River Road Waynesboro, GA 30830 Office of the County Commissioner Burke County Commission Waynesboro, GA 30830