ML102160082

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Annual Assessment Meeting Slides
ML102160082
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Site: Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date: 08/04/2010
From: Diane Jackson
NRC/RGN-I/DRP/PB5
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Download: ML102160082 (30)
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Memorandum to File:

Date: August 4, 2010 Attached are the annual assessment meeting slides from the Annual Assessment Meeting at Vermont Yankee.

1

Vermont Yankee Annual Assessment Meeting 2009 Reactor Oversight Process Nuclear Regulatory Commission - Region I

Agenda / Purpose of Todays Meeting

  • Discuss results of the NRC Groundwater Task Force (Chuck Casto) 3 Force (Chuck Casto)
  • Provide stakeholders the opportunity to engage the NRC staff on plant performance issues and our role in ensuring safe plant operation

Reactor Oversight Process S afety C o rnerstones B aseline In sp ectio n R esu lts P erform an ce Indicator R esu lts S trategic P erform ance Areas S afety C o rnerstones B aseline In sp ectio n R esu lts P erform an ce Indicator R esu lts S trategic P erform ance Areas 4

S ig nificance Threshold Actio n M atrix S ig nificance Threshold R egulato ry R espo nse S ig nificance Threshold Actio n M atrix S ig nificance Threshold R egulato ry R espo nse

Action Matrix Concept Licensee

Response

Regulatory

Response

Degraded Cornerstone Multiple/Rep.

Degraded Cornerstone Unacceptable Performance 5

  • Increasing Safety Significance
  • Increasing NRC Inspection Efforts
  • Increasing NRC/Licensee Management Involvement
  • Increasing Regulatory Actions

NRC Inspection Activities at Vermont Yankee (for CY 2009)

  • 6176 person-hours of inspection and related activities 6
  • 2 resident inspectors on-site
  • 26 regional inspectors
  • 1 major team inspection:

Problem Identification & Resolution

NRC Reactor Oversight Program Deviation Memorandum Vermont Yankee Entergy discovered tritium in a ground water monitoring well at VY in January 2010 S b tl E t di d th t t

di t i l di 7

Subsequently, Entergy discovered that contradictory or misleading information was given to the State of Vermont regarding buried or underground piping.

Consequently, the NRC has deviated from the ROP to provide for:

- additional inspections and stakeholder communications associated with on-site groundwater contamination; and

- assessment, follow-up actions, and stakeholder communications associated with the Demand for Information

NRC Annual Assessment Summary Vermont Yankee Entergy operated the plant safely and in a manner that preserved public health and safety and protected the environment Vermont Yankee was in the Licensee Response column of the NRCs A i M

i f ll f 2009 8

Action Matrix for all of 2009 All cornerstones objectives were fully met The NRC plans baseline inspections at Vermont Yankee for the remainder of 2010. Also, the NRC will continue to perform additional inspections in accordance with the Deviation Memorandum issued for Vermont Yankee.

NRC GROUNDWATER TASK FORCE REPORT

  • Completed review of charter items
  • Determined facts & observations 9
  • Determined facts & observations
  • Developed conclusions & recommendations

- Identified four themes

- Total of 16 specific conclusions

- Identified four key recommendations

NRC GROUNDWATER TASK FORCE REPORT

  • Theme 1 - Reassess NRCs Regulatory Framework for Groundwater Protection 10
  • Theme 2 - Maintain Barriers as Designed to Confine Licensed Material
  • Theme 3 - More Reliable NRC Response
  • Theme 4 - Strengthen Trust

GROUNDWATER TASK FORCE REPORT ANATOMY OF DISTRUST

-Misalignment of Views-Operations Consequence Environmental Protection Action NRC Viewpoint Design Risk Dose Decom 11 Viewpoint Stakeholder Viewpoint Maint Public Health Natural Resource Enf &

Cleanup Resultant Doubt &

Uncertainty Fear &

Anxiety Insult &

Anger Lost Trust

GROUNDWATER TASK FORCE REPORT TASK FORCE RECOMMENDATIONS Operations Consequence Environmental Protection Action Design Risk Dose Decom 12 Maint Public Health Natural Resource Confine, Insp

& Enforce Public Health Communications &

3rd Party Environ Policy, 3rd Party & Better Communications Enforce Design

& Respond Better Resultant Protect Public Health, Safety and the Environment

1.

NRC response to leaks/spills has varied widely and has been case specific.

2.

NRC Event Reports alert the public to leaks but no process exists to update the public on resolution or GROUNDWATER TASK FORCE REPORT CONCLUSIONS 13 process exists to update the public on resolution or consequences.

3.

NRC radiological effluent performance indicator does not provide meaningful data regarding groundwater contamination.

4.

NRC processes do not disseminate low level groundwater experience to inspectors.

5.

NRC findings associated with groundwater contamination that were based solely on public confidence require review.

6.

NRC should consider incorporating the industrys voluntary groundwater protection initiative (NEI 07-07) into the regulatory GROUNDWATER TASK FORCE REPORT CONCLUSIONS 14 framework for groundwater protection.

7.

NRC communication methods do not promptly relay NRC staff assessments of groundwater incidents. Consider using third-party validation methods of groundwater incidents.

8.

NRC regulations do not address the maintenance of non-safety related piping and tanks that contain radioactive fluid.

9.

NRC regulations regarding radiological impacts of facility operations vary for different types of facilities (e.g., power and research reactors, fuel cycle, in-situ recovery).

10. The final decommissioning rule now before the Commission (SECY 09 0042) ill t

i l

di ti if GROUNDWATER TASK FORCE REPORT CONCLUSIONS 15 (SECY-09-0042) will not require early remediation even if potential contamination of drinking water aquifers or subsurface-water bodies exists.

11. NRC staff should develop methods to more effectively communicate information on incidents involving a loss of confinement to the public.
12. The NRC public website information is fragmented and, in some cases, out of date.
13. International regulators effectively communicate radiological monitoring results annually in a public report to their legislatures.
14. Over 65 countries use IAEAs International Nuclear & Radiological Event Scale (INES) to explain significance of events associated with radiation GROUNDWATER TASK FORCE REPORT CONCLUSIONS 16 with radiation.
15. Timely information exchange & cooperation regarding operational events below regulatory limits will help regulatory authorities respond to emergent issues such as buried piping tritium leaks.
16. International regulators should cooperatively develop technical understanding of radionuclide transport by environmental paths.

Identify the policy issues associated with an assessment of the NRCs groundwater protection regulatory framework Once the policy issues are addressed, implement conforming changes to incorporate appropriate enhancements in the Reactor Oversight Program GROUNDWATER TASK FORCE REPORT KEY RECOMMENDATIONS 17 Program Consider development of specific actions to address the key themes and conclusions in this report Conduct a focused dialogue with EPA, States and international regulators to develop a collaborative approach for an enhanced groundwater protection strategy

NRC GROUNDWATER TASK FORCE REPORT

  • After a thorough review, the GTF determined that NRC is accomplishing its stated mission of protecting public health, safety, and protection of the environment through its response to 18 the environment through its response to groundwater leaks/spills.
  • Within the current regulatory structure, NRC is correctly applying requirements and properly characterizing the relevant issues.

Demand for Information (DFI)

Inspection

  • Background
  • Team Composition & Methodology

- 19 NRC technical staff 19 Region I and NRC Headquarters

- Plant Component Walk-downs & Inspections

>115 plant components

- Personnel Interviews

>75 Entergy staff & contractors

- Document Reviews

>250 Entergy communications

Completeness and accuracy of material communications to the NRC &

corrective actions

  • Document Review

- Considered Entergy employees involvement, technical content, NRC review and verification DFI INSPECTION Inspection Scope & Results: DFI Items 1 & 2 20

- Selected statistical samples of plant components to verify whether:

- Independently identified buried/underground piping on-site, to determine whether:

Completeness and accuracy of material communications to the NRC &

corrective actions

  • Results

- Material information provided to the NRC was complete and accurate DFI INSPECTION Inspection Scope & Results: DFI Items 1 & 2 21

- No corrective actions required

  • Observation: Entergy identified 1 instance in which inaccurate information, which the NRC verified was not material, was provided to the NRC

- Plant components properly scoped/described in license renewal application

- Buried/Underground piping properly identified and scoped with appropriate aging management programs

  • Recommendation: Revise license renewal application to account for lessons learned from leaks & clarify inspection plans for inaccessible components

Inspection Scope & Results: DFI Items 3 & 4 Organizational Impacts to Implementation of NRC-regulated programs &

Safety Culture

  • Program Implementation

- Reviewed staff qualifications against standards

- Conducted staff interviews DFI INSPECTION 22

  • Safety Culture

- Reviewed Entergys site safety culture surveys

  • Interviewed assessors and Entergy

- Conducted an independent inspection of safety conscious work environment (SCWE)

  • Individual and Focus Group interviews
  • Staff and process observations
  • Document review

Inspection Scope & Results: DFI Items 3 & 4 Organizational Impacts to Implementation of NRC-regulated programs &

Safety Culture

  • Results

- Organizational changes have not negatively impacted Entergys implementation of NRC-regulated programs DFI INSPECTION 23

- Entergys investigation did not negatively impact site SCWE

- NRC inspection results are consistent with Entergys safety culture surveys

- Observation: One instance identified in which Entergys initial follow-up of a potential SCWE concern was not appropriate.

Subsequent licensee follow-up indicated that there were no SCWE-related concerns.

Inspection Scope & Results: DFI Item 5 Review results of Entergy investigation

  • Document Review

- Reviewed investigation report for any impact on NRC-regulated activities DFI INSPECTION 24

  • Results

- No safety issues, allegation issues, or NRC regulatory impacts were identified

Contacting the NRC

  • Report a safety concern:

3/4(800) 695-7403 3/4Allegation@nrc.gov 25 g

g

  • General information or questions:

3/4www.nrc.gov 3/4Public Affairs Officers:

3/4Diane Screnci 610-337-5330 3/4Neil Sheehan 610-337-5331

End of the Presentation Nuclear Regulatory Commission Nuclear Regulatory Commission Region I King of Prussia, Pennsylvania June 22, 2010

Q&A Ground Rules

  • Please be respectful of the speaker
  • Only one speaker at a time
  • To be fair to the other questioners, please limit your remarks to 5 minutes (We will come back to you as 27 time allows)
  • We will alternate between elected officials and the public at the beginning
  • Speakers will be called to a microphone.
  • Order called may vary from the sign-up order to ensure all groups are heard from
  • See Karl or Bill if you have procedural questions
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