ML082670904
| ML082670904 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 09/23/2008 |
| From: | Stephanie West Division of Reactor Safety III |
| To: | Christian D Dominion Energy Kewaunee |
| References | |
| EA-08-223 IR-08-503 | |
| Download: ML082670904 (13) | |
See also: IR 05000305/2008503
Text
September 23, 2008
Mr. David A. Christian
President and Chief Nuclear Officer
Dominion Energy Kewaunee, Inc.
Innsbrook Technical Center
5000 Dominion Boulevard
Glen Allen, VA 23060-6711
SUBJECT: NRC EMERGENCY PREPAREDNESS INSPECTION REPORT
05000305/2008503; PRELIMINARY WHITE FINDING FOR
KEWAUNEE POWER STATION
Dear Mr. Christian:
On August 29, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an
Emergency Preparedness inspection at your Kewaunee Power Station. The inspection
included on-site inspection on June 16 through 20, 2008, and periodic in-office
inspection through August 29, 2008. The inspection covered one or more of the key
attributes of the emergency preparedness cornerstone of the NRC's Reactor Oversight
Process. The enclosed inspection report documents the inspection results, which were
discussed on August 29, 2008, with Mr. S. Scace 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 inspector reviewed selected procedures and records, observed
activities, and interviewed personnel.
This letter transmits a finding that has preliminarily been determined to be White,
a finding with low to moderate increased importance to safety that may require
additional NRC inspections. As described in Section 1EP4 of this report, a finding
was identified for failure to comply with 10 CFR 50.47(b)(4). Specifically, from
August 2006 to May 2008, the Kewaunee's emergency plan emergency action levels
(EALs) RU1.2, RA1.1 and RA1.2 specified instrument threshold values that were beyond
the limits of the effluent radiation monitors capabilities to accurately measure and
indicate. The inability to classify emergencies with these EALs does not comply with the
requirements in 10 CFR 50.54(q) associated with planning standard 50.47(b)(4).
This finding was assessed based on the best available information, using the
Emergency Preparedness Significance Determination Process (SDP). The final
resolution of this finding will be conveyed in separate correspondence.
D. Christian -2-
The finding is also an apparent violation of NRC requirements and is being
considered for escalated enforcement action in accordance with the
Enforcement Policy, which can be found on the NRCs Web site at
http://www.nrc.gov/reading-rm/doc-collections/enforcement.
In accordance with NRC Inspection Manual Chapter (IMC) 0609, we intend to
complete our evaluation using the best available information and issue our final
determination of safety significance within 90 days of the date of this letter. Although the
SDP encourages an open dialogue between the NRC staff and the licensee, the
dialogue should not impact the timeliness of the staffs final determination.
Before we make a final decision on this matter, we are providing you with an
opportunity: (1) to attend a Regulatory Conference where you can present to the NRC
your perspective on the facts and assumptions the NRC used to arrive at the finding and
assess its significance; or (2) submit your position on the finding to the NRC in writing.
If you request a Regulatory Conference, it should be held within 30 days of the receipt of
this letter and we encourage you to submit supporting documentation at least one week
prior to the conference in an effort to make the conference more efficient and effective.
If a Regulatory Conference is held, it will be open for public observation. If you decide to
submit only a written response, such submittal should be sent to the NRC within 30 days
of your receipt of this letter. If you decline to request a Regulatory Conference or submit
a written response, you relinquish your right to appeal the final SDP determination, in
that by not doing either, you fail to meet the appeal requirements stated in the
Prerequisite and Limitation sections of Attachment 2 of IMC 0609.
Please contact Hironori Peterson, Chief, Operations Branch, at 630-829-9707 and in
writing within 10 days from the issue date of this letter to notify the NRC of your
intentions. If we have not heard from you within 10 days, we will continue with our
significance determination and enforcement decision. The final resolution of this matter
will be conveyed in separate correspondence.
Because the NRC has not made a final determination in this matter, no Notice of
Violation is being issued for these inspection findings at this time. In addition, please be
advised that the number and characterization of the apparent violation described in the
enclosed inspection report may change as a result of further NRC review.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter
and its enclosure will be made available electronically for public inspection in the NRC
D. Christian -3-
Public Document Room or from the NRCs document system (ADAMS), accessible from
the NRC Web site at http://www.nrc.gov/reading-rm/adams.html
Sincerely,
/RA/
Steven West, Director
Division of Reactor Safety
Docket No. 50-305
License No. DPR-43
Enclosure: Inspection Report No. 05000305/2008503(DRS)
w/Attachment: Supplemental Information
cc w/encl: S. Scace, Site Vice President
M. Wilson, Director, Nuclear Safety and Licensing
C. Funderburk, Director, Nuclear Licensing and
Operations Support
T. Breene, Manager, Nuclear Licensing
L. Cuoco, Senior Counsel
D. Zellner, Chairman, Town of Carlton
J. Kitsembel, Public Service Commission of Wisconsin
P. Schmidt, State Liaison Officer
D. Christian -3-
Public Document Room or from the NRCs document system (ADAMS), accessible from
the NRC Web site at http://www.nrc.gov/reading-rm/adams.html
Sincerely,
/RA/
Steven West, Director
Division of Reactor Safety
Docket No. 50-305
License No. DPR-43
Enclosure: Inspection Report No. 05000305/2008503(DRS)
w/Attachment: Supplemental Information
cc w/encl: S. Scace, Site Vice President
M. Wilson, Director, Nuclear Safety and Licensing
C. Funderburk, Director, Nuclear Licensing and
Operations Support
T. Breene, Manager, Nuclear Licensing
L. Cuoco, Senior Counsel
D. Zellner, Chairman, Town of Carlton
J. Kitsembel, Public Service Commission of Wisconsin
P. Schmidt, State Liaison Officer
DISTRIBUTION
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DOCUMENT NAME: G:\DRS\Work in Progress\KEW 2008 503 DRS.doc
9 Publicly Available 9 Non-Publicly Available 9 Sensitive 9 Non-Sensitive
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OFFICE RIII RIII RIII RIII
NAME RJickling:co HPeterson MKunowski KO'Brien VL for
DATE 09/04/08 09/15/08 09/19/08 09/19/08
OFFICE RIII RIII
NAME JHeck SWest
DATE 09/22/08 09/23/08
OFFICIAL RECORD COPY
Letter to David A. Christian from Steven West dated September 23, 2008.
SUBJECT: NRC EMERGENCY PREPAREDNESS INSPECTION REPORT
05000305/2008503; PRELIMINARY WHITE FINDING FOR
KEWAUNEE POWER STATION
DISTRIBUTION:
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Docket No: 50-305
License No: DPR-43
Report No: 05000305/2008503
Licensee: Dominion Energy Kewaunee, Inc.
Facility: Kewaunee Power Station
Location: Kewaunee, WI
Dates: June 16 through July 30, 2008
Inspector: Robert Jickling, Sr. Emergency Preparedness Inspector
Approved by: Steven West, Director
Division of Reactor Safety
Enclosure
SUMMARY OF FINDINGS
IR 05000305/2008; 06/16/2008 - 08/29/2008; Kewaunee Power Station; Emergency Action
Level and Plan Changes
This report covered a 2-month period of inspection by a regional emergency preparedness
inspector. One Apparent Violation (AV) item with potential White safety significance was
identified. The significance of most findings is indicated by their color (Green, White, Yellow,
Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process
(SDP). Findings for which the SDP 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.
A. NRC-Identified and Self-Revealed Findings
Cornerstone: Emergency Preparedness
emergency plans which use a standard emergency classification and action level
scheme. Specifically, the licensee's emergency plan Alert emergency action levels
(EALs) RA1.1 and RA1.2 specified instrument setpoints that were beyond the limits of
the effluent radiation monitors capabilities.
This finding was considered more than minor because the licensee is required to be
capable to implement adequate measures to protect public health and safety in the
event of a radiological emergency. Regulations require a standard emergency
classification and action level scheme, the bases which included facility system and
effluent parameters, in use by the licensee and State and local response plans call for
reliance on information provided by the licensee for determination of minimum initial
offsite response measures. As a result of having Alert EAL threshold values that were
beyond the range of the associated effluent radiation monitors, Kewaunee personnel
would not have been able to classify an emergency based upon an effluent radioactive
material release in a timely manner. Emergency response actions directed by the
State and local emergency response plans, which rely on information provided by the
licensee, could have potentially been delayed.
The cause of the finding is related to the human performance cross-cutting element of
H.2(c) for ensuring that personnel, equipment, and procedures are available and
adequate to assure nuclear safety. Specifically, those necessary for complete,
accurate, and up-to-date design documentation, procedures, and work packages.
(Section 1EP4)
B. Licensee-Identified Violations
No violations of significance were identified.
1 Enclosure
REPORT DETAILS
1. REACTOR SAFETY
Cornerstone: Emergency Preparedness
1EP4 Emergency Action Level and Emergency Plan Changes (71114.04)
.1 Emergency Action Level and Emergency Plan Changes
a. Inspection Scope
The inspector completed a screening review of revisions made to the licensees
emergency plan to determine whether the changes identified in those revisions may
have reduced the effectiveness of the licensees emergency plan. The screening
review of these revisions does not constitute approval of the changes and, as such,
the changes are subject to future NRC inspection to ensure the emergency plan
continues to meet NRC regulations. Documents reviewed are listed in the Attachment
to this report.
The inspector also reviewed licensee actions to resolve identified problems with
effluent radiation monitors, starting in April 2006, and emergency plan emergency
action levels (EALs), starting in November 2006.
This emergency action level and emergency plan changes inspection constituted one
sample as defined in IP 71114.04-05.
b. Findings
Introduction: The inspector identified an apparent violation (AV) for failure to promptly
identify and correct problems with the licensee's emergency plan Alert EALs RA1.1
and RA1.2 specified instrument setpoints that were beyond the limits of the effluent
radiation monitors capabilities. This has potential safety significance greater than very
low safety significance and will remain unresolved pending completion of the
Significance Determination Process (SDP).
Description: On April 28, 2006, the licensee initiated a corrective action program
(CAP) to document questions asked by a NRC inspector regarding whether the
technical specification definition for channel calibration was met for R-18
(Monitor-R18/Waste Disposal Liquid) and R-19 (Monitor-R19/Steam Generator
Blowdown Liquid) calibrations. In an unrelated action in April of 2006, the NRC
approved a Dominion request to upgrade the Kewuanee EAL scheme based on the
NRC-endorsed NEI 99-01 guidance. These EAL changes were subsequently
implemented in August of 2006. On September 16, 2006, the licensee initiated a CAP
documenting calibration results that indicated that monitors R-18 and R-19 responded
non-linearly above approximately 1E+6 counts per minute (cpm). As a result, the
monitors were taken out of service and a grab sampling program initiated to meet
conditions of the Offsite Dose Calculation Manual (ODCM). On November 6, 2006,
emergency preparedness personnel initiated a CAP to evaluate the capability to read
the threshold values for EALs RU1.2, RA1.1, and RA1.2 on radiation monitors R-16,
18, 19, and 20. In addition to the questionable R-16, 18, 19, and 20 readings above
2 Enclosure
1E+6 cpm, this CAP also identified that EALs RU1.2, RA1.1 and, RA1.2 threshold
values would be well beyond the linear range and in some cases beyond the
measurement and display range of the instruments. With EALs RU1.2, RA1.1, and
RA1.2 rendered ineffective, Kewuanee personnel would have had to rely on the
analysis of samples taken from these effluent release pathways, a condition that would
have resulted in delays and significantly less timely emergency classifications. On
February 21, 2007, a Design Change Request was initiated to modify R-18 and 19
monitors to accommodate Kewaunee's EALs and to consider pursuit of higher range
detectors for R-18 and 19.
On October 11, 2007, a corrective action (CA) was initiated by the licensee identifying
that in addition to EALs RA1.1 and RA1.2 threshold values not falling within the
range of monitors R-16, 19, and 20 to classifying Alert conditions, the EAL threshold
values were also outside the operating range for monitors R-12, 13, 14, and 21. On
April 7, 2008, a NRC resident inspector questioned the adequacy and timeliness of
manually sampling the effluent streams. On May 2, 2008, the licensee completed a
root cause evaluation which identified that the EALs implemented on August 24, 2006,
contained effluent radiation monitor threshold values for Alert classifications that were
outside the display range of the specified effluent radiation monitors. The root cause
evaluation identified the cause as revision and control of the emergency plan and
EALs did not contain sufficient guidance for development, validation, and approval of
EAL threshold values. On May 29, 2008, the EAL threshold values in RU1.2, RA1.1,
and RA1.2 were lowered in Revision 4 to the EALs.
From this information, the inspector determined the problem that led to implementing
EALs threshold values higher than the capabilities of the effluent radiation monitors
occurred because the calculated values were not verified prior to implementation in
August of 2006. Because the problem with EAL threshold values for RU1.2, RA1.1,
and RA1.2 existed from August 24, 2006 until May 29, 2008, the inspector concluded
that the licensee failed to, in a timely manner, identify and correct a problem that
resulted in the failure to maintain a standard emergency classification scheme, which
included facility system and effluent parameters. The inspector's determination was in
alignment with the licensee's detailed root cause evaluation.
Analysis: The inspector determined that the failure to verify that threshold values
specified in the EALs were compatible with the installed plant equipment was contrary
to 10 CFR 50.47(b)(4) and was a performance deficiency. This finding was considered
more than minor because the finding, if left uncorrected, would become a more
significant safety concern. Specifically, in the event of a radiological emergency, the
deficiency could lead to the failure to declare two Alert conditions in a timely manner.
The inspector determined the finding could be evaluated using the SDP in accordance
with IMC 0609, "Significance Determination Process," Appendix B, "Emergency
Preparedness Significance Determination Process." Using the "Failure to Comply"
flowchart, the first decision box asks if it is a planning standard problem. Following the
yes path to the second decision asks if it is a risk significant planning standard. Again,
follow the yes path to the decision which asks if it is a risk significant planning standard
failure. The no path leads to the decision which asks if it was a risk significant
planning standard degraded function. Answering yes results in a White finding. The
inspector determined this was a degraded risk significant planning standard, rather
than failed, because even though the two Alerts (RA1.1 and RA1.2) would not be able
3 Enclosure
to be declared due to the EAL threshold values being beyond the range of the
associated instruments, an Alert could be declared, although in a delayed manner,
using RA1.3 which is based on grab sample and analysis results obtained by a
chemistry technician and reported to the shift manager.
This finding has a cross-cutting aspect in the area human performance, resources,
because the licensee did not ensure adequate procedures to assure nuclear safety
H.2(c). Specifically, processes for revision and control of emergency plan EALs did
not contain adequate guidance for development, validation, and approval. Kewaunee
processes were such that changes were made, without verification, to EAL setpoint
values which were beyond the range of the instruments.
Enforcement: Title 10 of the Code of Federal Regulations, Part 50.54(q) requires that
licensees follow and maintain in effect emergency plans which meet the standards in
50.47(b) and requirements in Appendix E. The requirements of 10 CFR 50.47(b)(4)
state, in part, that the emergency plans must have a standard emergency classification
and action level scheme, the bases which include facility system and effluent
parameters, in use by the licensee and that State and local response plans call for
reliance on information provided by the licensee for determination of minimum initial
offsite response measures.
Contrary to the above, Kewaunee failed to maintain a standard emergency
classification scheme, which included facility system and effluent parameters, that
the State and local response plans can rely on for information to determine minimum
initial offsite response measures. This is a degraded, rather than a failed, risk
significant planning standard function. Even though the two Alerts (RA1.1 and RA1.2)
would not be able to be declared due to the EAL threshold values being beyond the
range of the instruments, an Alert could be declared, although in a delayed manner,
using RA1.3 which is based on grab sample and analysis results obtained by a
chemistry technician to sample and reported to the shift manager. Pending
determination of safety significance, this finding is identified as an apparent violation
(AV)05000305/2008503-01, Failure to Maintain a Standard Emergency Action Level
Scheme.
4OA6 Management Meetings
.1 Exit Meeting Summary
On August 29, 2008, the inspector presented the inspection results to Mr. S. Scace,
and other members of the licensee staff by teleconference. The licensee
acknowledged the issues presented. The inspector confirmed that none of the
potential report input discussed was considered proprietary.
The inspector confirmed that none of the potential report input discussed was
considered proprietary.
ATTACHMENT: SUPPLEMENTAL INFORMATION
4 Enclosure
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
S. Scace, Site Vice President
P. Blasioli, Nuclear Protective Services and Emergency Preparedness Director, Innsbrook
T. Breene, Licensing Manager
J. Costello, Emergency Preparedness Supervisor, Innsbrook
J. Egdorf, Emergency Preparedness Supervisor
R. Repshas, Licensing Engineer
P. Serra, Nuclear Fleet Emergency Preparedness Manager, Innsbrook
C. Sly, Licensing Engineer, Innsbrook
M. Wilson, Nuclear Station Safety and Licensing Director
S. Wood, Emergency Preparedness Manager
Nuclear Regulatory Commission
S. Burton, Senior Resident Inspector
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
05000305/2008503-01 AV Failure to Maintain a Standard EAL Scheme
Closed and Discussed
None
5 Enclosure
LIST OF DOCUMENTS REVIEWED
The following is a list of documents reviewed during the inspection. Inclusion on this list does
not imply that the NRC inspector reviewed the documents in their entirety, but rather, that
selected sections of portions of the documents were evaluated as part of the overall
inspection effort. Inclusion of a document on this list does not imply NRC acceptance of the
document or any part of it, unless this is stated in the body of the inspection report.
Section 1EP4 Emergency Action Level and Emergency Plan Changes
PLANT PROCEDURES
Number Title Revision or Date
Kewaunee Power Station Emergency Plan May 22, 2008
Kewaunee Power Station Emergency Plan August 24, 2006
EAL Technical Bases Document May 29, 2008
EPIP-AD-02 Emergency Class Determination August 24, 2006
EPIP-AD-02 Emergency Class Determination May 15, 2006
EPIP-AD-02 Emergency Class Determination December 20, 2005
REPORTS
Number Title Date
RCE-2008-221 Evaluate EAL Setpoint Issues Root Cause May 2, 2008
CONDITION REPORTS
Number Issue Date Originated
CR090741 Identified UE and Alert EAL Setpoint Issues February 8, 2008
with Plant Effluent Monitors
CA019123 Track Implementation of EAL Calculation
CA028726 Evaluate EAL ICs Based on R-16/18/19/20 December 18, 2006
CA026592 Non-Linear Response for R-18 and R-19 September 27, 2006
Detectors
CE018812 Non-Linear Response for R-18 and R-19 September 17, 2006
Detectors
CE0176641 NRC Question about R-18 and R-19 May 3, 2006
Calibration
CAP039122 Evaluate EAL ICs Based on R-16/18/19/20 November 6, 2006
CAP037265 Non-Linear Response for R-18 and R-19 September 16, 2006
Detectors
CAP033340 NRC Question about R-18 and R-19 April 28, 2006
Calibration
DCR029923 Non-Linear Response for R-18 and R-19 February 21, 2007
Detectors
DCR026981 Non-Linear Response for R-18 and R-19 October 4, 2006
Detectors
OTH014874 R-18 is Out of Service for Liquid RadWaste August 24, 2006
Discharge
6 Enclosure
LIST OF ACRONYMS USED
ADAMS NRC's Document System
AR Action Request
AV Apparent Violation
CA Corrective Action
CAP Corrective Action Program
CE Condition Evaluation
CFR Code of Federal Regulations
cpm counts per minute
EALs Emergency Action Levels
IMC Inspection Manual Chapter
NEI Nuclear Energy Institute
NRC Nuclear Regulatory Commission
ODCM Off-Site Dose Calculation Manual
SDP Significance Determination Process
7 Enclosure