ML110600903
| ML110600903 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 02/28/2011 |
| From: | Hironori Peterson Division of Reactor Safety III, Operations Branch III |
| To: | Pacilio M Exelon Generation Co |
| References | |
| EA-10-220 IR-10-503 | |
| Download: ML110600903 (16) | |
See also: IR 05000456/2010503
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION III
2443 WARRENVILLE ROAD, SUITE 210
LISLE, IL 60532-4352
February 28, 2011
Mr. Michael J. Pacilio
Senior Vice President, Exelon Generation Company, LLC
President and Chief Nuclear Officer (CNO), Exelon Nuclear
4300 Winfield Road
Warrenville IL 60555
SUBJECT: BRAIDWOOD STATION, UNITS 1 AND 2 FOLLOW-UP INSPECTION OF
EMERGENCY ACTION LEVEL AND EMERGENCY PLAN CHANGE
INSPECTION REPORT 05000456/2010503(DRS); 05000457/2010503(DRS)
AND NOTICE OF VIOLATION
Dear Mr. Pacilio:
On February 10, 2011, the U. S. Nuclear Regulatory Commission (NRC) completed an in-office
inspection of your Braidwood Station, Units 1 and 2. The purpose of the inspection was to
review the facts and circumstances concerning Unresolved Item 05000456/2009005-07;
05000457/2009005-07, Changes to Emergency Action Level HU6 Potentially Decrease the
Effectiveness of the Plans without Prior NRC Approval. The enclosed report documents the
inspection results, which were discussed by telephone on February 10, 2011, with
Mr. D. Enright 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 inspectors reviewed selected procedures and records, observed activities, and interviewed
personnel.
The report documents one NRC-identified finding of very low safety significance (Green). The
finding was determined to involve a violation of NRC requirements. Based on the results of the
inspection and following consultation with the NRC Office of Enforcement staff, we categorized
the violation at Severity Level IV. The violation was evaluated in accordance with the NRC
Enforcement Policy. The current Enforcement Policy is included on the NRC=s Web site at
(http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html).
The violation is cited in the enclosed Notice of Violation (NOV) and the circumstances
surrounding it are described in detail in the subject inspection report. The violation is being
cited in the Notice and a response is required because no corrective action had been taken to
restore compliance since the issue was entered in your corrective action program in
December 2009.
M. Pacilio -2-
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response. The NRC will use your response, in part, to
determine whether further enforcement action is necessary to ensure compliance with
regulatory requirements. In particular, the NRC is interested in any human performance issues
associated with performance of 10 CFR 50.54(q) reviews of Emergency Plan and Emergency
Action Level changes for all Exelon facilities.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter,
its enclosure, and your response, will be available electronically for public inspection in the NRC
Public Document Room or from the Publicly Available Records System (PARS) component of
NRC's Agencywide Documents Access and Management System (ADAMS), accessible from
the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading
Room).
Sincerely,
/RA/
Hironori Peterson, Chief
Operations Branch
Division of Reactor Safety
Docket Nos. 50-456; 50-457
Enclosures:
1. Notice of Violation
2. Inspection Report 05000456/2010503(DRS);
w/Attachment: Supplemental Information
cc w/encls: Distribution via ListServ
NOTICE OF VIOLATION
Exelon Generation Company, LLC Docket Nos. 50-456; 50-457
Braidwood Station, Units 1 and 2 License Nos. NPF-72; NPF-77
During a U. S. Nuclear Regulatory Commission (NRC or Commission) inspection completed on
February 10, 2011, a violation of NRC requirements was identified. In accordance with the NRC
Enforcement Policy, the violation is listed below:
Title 10 CFR 50.54(q) requires, in part, AA licensee authorized to possess and operate a
nuclear power reactor shall follow and maintain in effect emergency plans which meet
the standards in '50.47(b) and the requirements in Appendix E of this part. The
licensee may make changes to these plans without Commission approval only if the
changes do not decrease the effectiveness of the plans and the plans, as changed,
continue to meet the standards of '50.47(b) and the requirements of Appendix E.
Title 10 CFR 50.47(b)(4) requires, in part, A standard emergency classification and
action level scheme, the bases of which include facility system and effluent parameters,
is in use by the nuclear facility licensee, 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, as of March 28, 2008, the licensee made a change to its
emergency plan which decreased the effectiveness of the plan and caused the
emergency plan to no longer meet the standards of 50.47(b) and Appendix E to this part
without Commission approval. Specifically, the licensee modified the Emergency Action
Level (EAL) Basis in EAL HU6, Revision 21, to delay the 15-minute classification time by
the dispatching of personnel, reporting the notification of a fire from the field, and
extinguishing the fire. As a result, this change indefinitely extends the start of the
15-minute emergency classification clock beyond a credible notification that a fire is
occurring or indication of a valid fire detection system alarm. This change decreased the
effectiveness of the emergency plan by reducing the capability to perform a risk
significant planning function in a timely manner.
This is a Severity Level IV Violation (Section 6.6).
This violation is associated with a Green SDP finding.
Pursuant to the provisions of 10 CFR 2.201, Exelon Generation Company, LLC is hereby
required to submit a written statement or explanation to the U. S. Nuclear Regulatory
Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 with a copy to the
Regional Administrator, Region III, and a copy to the NRC Resident Inspector at the Braidwood
facility, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This
reply should be clearly marked as a Reply to a Notice of Violation; EA-10-220 and should
include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing
the violation or severity level; (2) the corrective steps that have been taken and the results
achieved; (3) the corrective steps that will be taken; and (4) the date when full compliance will
be achieved. Your response may reference or include previous docketed correspondence, if
the correspondence adequately addresses the required response. If an adequate reply is not
Enclosure 1
Notice of Violation -2-
received within the time specified in this Notice, an Order or a Demand for Information may be
issued as to why the license should not be modified, suspended, or revoked, or why such other
action as may be proper should not be taken. Where good cause is shown, consideration will
be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response, with
the basis for your denial, to the Director, Office of Enforcement, U. S. Nuclear Regulatory
Commission, Washington, DC 20555-0001.
Because your response will be made available electronically for public inspection in
the NRC Public Document Room or from the NRCs Agencywide Documents Access
and Management System (ADAMS), accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not include
any personal privacy, proprietary, or safeguards information so that it can be made available
to the public without redaction. If personal privacy or proprietary information is necessary to
provide an acceptable response, then please provide a bracketed copy of your response
that identifies the information that should be protected and a redacted copy of your response
that deletes such information. If you request withholding of such material, you must specifically
identify the portions of your response that you seek to have withheld and provide in detail the
bases for your claim of withholding (e.g., explain why the disclosure of information will create
an unwarranted invasion of personal privacy or provide the information required by
10 CFR 2.390(b) to support a request for withholding confidential commercial or financial
information). If safeguards information is necessary to provide an acceptable response, please
provide the level of protection described in 10 CFR 73.21.
In accordance with 10 CFR 19.11, you may be required to post this Notice within two working
days.
Dated this 28th day of February 2011.
Enclosure 1
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Docket Nos: 50-456; 50-457
Report No: 05000456/2010503(DRS); 05000457/2010503(DRS)
Licensee: Exelon Generation Company, LLC
Facility: Braidwood Station, Units 1 and 2
Location: Braceville, Illinois
Dates: June 16, 2010 through February 10, 2011
Inspectors: Robert Jickling, Senior Emergency Preparedness Inspector
Approved by: Hironori Peterson, Chief
Operations Branch
Division of Reactor Safety
Enclosure 2
SUMMARY OF FINDINGS
Inspection Report (IR) 05000456/2010503(DRS), 05000457/2010503(DRS); 06/16/2010 -
02/10/2011; Braidwood Station, Units 1 and 2; results of U. S. Nuclear Regulatory Commission
(NRC) Emergency Action Level and Emergency Plan Changes Inspection and Follow-up of
Unresolved Item (URI)05000456/2009005-07; 05000457/2009005-07.
This report covers an approximate 6-month period of follow-up inspection and review of the
licensees emergency action level and plan changes. One Green finding was identified by the
inspector. The finding involved a Severity Level IV Cited Violation (NOV) of NRC regulations.
The significance of most findings is indicated by their color (Green, White, Yellow, Red) using
Inspection Manual Chapter (IMC) 0609, Significance Determination Process. Findings for
which the Significance Determination Process 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, Revision 4, dated December 2006.
A. NRC-Identified and Self-Revealed Findings
Cornerstone: Emergency Preparedness
- Severity Level IV/Green. A Green finding involving a Severity Level IV, Cited Violation of
10 CFR 50.54(q) was identified by the inspector for the licensees change to the
emergency plan which decreased the effectiveness of the plan without NRC approval.
Specifically, the licensee modified the Emergency Action Level (EAL) Basis in EAL HU6,
Revision 21, to delay the 15-minute classification time by the dispatching of personnel,
reporting the notification of a fire from the field, and extinguishing the fire. As a result,
this change indefinitely extends the start of the 15-minute emergency classification clock
beyond a credible notification that a fire is occurring or indication of a valid fire detection
system alarm. This change decreased the effectiveness of the emergency plan by
reducing the capability to perform a risk significant planning function in a timely manner.
The violation affected the NRCs ability to perform its regulatory function because it
involved implementing a change that decreased the effectiveness of the emergency plan
without NRC Commission approval. Therefore, this issue was evaluated using
Traditional Enforcement. The NRC determined that a Severity Level IV violation was
appropriate due to the reduction of the capability to perform a risk significant planning
standard function in a timely manner. The violation is cited because no corrective action
had been taken to restore compliance since the issue was entered in the licensees
corrective action program in December 2009.
The performance deficiency was more than minor and of very low safety-significance
using Manual Chapter (MC) 0612 and MC 0609, Appendix B, because it is associated
with the emergency preparedness cornerstone attribute of procedure quality for EAL and
emergency plan changes, and it adversely affected the cornerstone objective of ensuring
that the licensee is capable of implementing adequate measures to protect the health
and safety of the public in the event of a radiological emergency. Therefore, the
performance deficiency was a finding. Using MC 0609, Appendix B, the inspector
determined that the finding had a very low safety significance. The inspectors also
determined that the finding had a cross-cutting aspect in the area of Human
Performance, decision-making because the licensee did not recognize that the change
1 Enclosure 2
made to the EAL basis document decreased the effectiveness of the emergency plan.
(H.1.(b)) (Section 1EP4)
B. Licensee-Identified Violations
No violations of significance were identified.
2 Enclosure 2
REPORT DETAILS
1. REACTOR SAFETY
Cornerstones: Emergency Preparedness
1EP4 Emergency Action Level and Emergency Plan Changes (71114.04)
.1 Emergency Action Level and Emergency Plan Changes
a. Inspection Scope
This inspection was a follow-up review of Unresolved Item (URI)05000456/2009005-07;
URI 05000457/2009005-07. The issue was identified in December 2009 during a routine
review of changes implemented to the Braidwood Station Emergency Plan Annex
Emergency Action Level (EAL) and EAL Basis. The inspector reviewed applicable
licensee documents and had discussions with licensee personnel.
b. Findings
Introduction:
A Green finding involving a Severity Level IV, Cited Violation of 10 CFR 50.54(q) was
identified by the inspector for the licensees change to the emergency plan which
decreased the effectiveness of the plan without U. S. Nuclear Regulatory Commission
(NRC) approval.
Description:
The Radiological Emergency Plan Annex for Braidwood Station, Revision 20, EAL HU6
provided the basis for declaring an Unusual Event due to a fire in the protected area not
extinguished within 15 minutes of detection. The EAL HU6 Basis, Revision 20, stated in
part: The 15-minute period begins with a credible notification that a fire is occurring or
indication of a valid fire detection system alarm. A verified alarm is assumed to be an
indication of a fire unless personnel dispatched to the scene disprove the alarm within
the 15-minute period. The report, however, shall not be required to verify the alarm.
On March 28, 2008, Braidwood Station staff implemented Revision 21 of the EAL HU6
Basis which added the following text: The 15-minute period to extinguish the fire begins
with a credible notification that a fire is occurring or indication of a valid fire detection
system alarm. If the alarm cannot be verified by redundant Control Room or nearby fire
panel indications, notification from the field that a fire exists starts the 15-minute
classification and fire extinguishment clocks. The 15-minute period to extinguish the fire
does not start until either the fire alarm is verified to be valid by utilization of additional
Control Room or nearby fire panel instrumentation, or upon notification of a fire from the
field.
Revision 21 of the EAL HU6 Basis allowed delay of the 15-minute classification time by
the dispatching of personnel, reporting the notification of a fire from the field, and
extinguishing the fire. As a result, this change indefinitely extended the start of the
15-minute emergency classification clock beyond a credible notification that a fire is
3 Enclosure 2
occurring or indication of a valid fire detection system alarm. This was determined to be
a decrease in effectiveness of the licensees emergency plan because the change
reduced the capability to perform a risk significant planning standard function in a timely
manner. This change was not submitted to the NRC for prior approval.
Analysis:
The inspector determined that the change made by the licensee to the EAL HU6 Basis
decreased the effectiveness of the Emergency Plan and the change was implemented
without prior NRC approval. The issue was determined to be a licensee performance
deficiency that impacted the regulatory process and, in accordance with Manual Chapter
(MC) 0612 Power Reactor Inspection Reports, was evaluated using the NRCs
traditional enforcement policy as well as the Reactor Oversight Process (ROP).
Using the NRCs Enforcement Policy, this violation met Example c.2 in Section 6.6: A
licensees ability to meet or implement any regulatory requirement related to assessment
or notification is degraded such that the effectiveness of the emergency plan decreases.
Although the regulatory requirement could be implemented during the response to an
actual emergency, the implementation would be degraded (e.g., not fully effective,
inappropriately delayed). Specifically, the change made to the EAL Basis directly
affected the Risk Significant Planning Standard Classification, which affected
assessment of event conditions. Therefore, this violation met the example for Severity
Level III. However, the NRC has classified this violation as a Severity Level IV, after
determining that its actual and potential safety significance was very low based on the
following considerations: (1) the issue involved only one Unusual Event EAL, and not
any of the other higher event classifications; and (2) the issue could delay classification
but would not prevent classification.
Using MC 0612 Power Reactor Inspection Reports, Appendix B, Issue Screening, the
performance deficiency was determined to be more than minor and, therefore, a finding,
because it is associated with the emergency preparedness cornerstone attribute of
procedure quality for EAL and emergency plan changes, and it adversely affected the
cornerstone objective of ensuring that the licensee is capable of implementing adequate
measures to protect the health and safety of the public in the event of a radiological
emergency. Specifically, the licensee made a change to its EAL Basis, which was a
decrease in effectiveness, because the change indefinitely extended the start of the
15-minute emergency classification clock beyond a credible notification that a fire is
occurring or indication of a valid fire detection system alarm. Also, this change was
made without prior NRC approval.
The inspector determined the finding could be evaluated using the Significance
Determination Process (SDP) in accordance with Inspection Manual Chapter (IMC) 0609, Significance Determination Process, Appendix B, Emergency Preparedness
Significance Determination Process. The finding is a failure to comply with
10 CFR 50.54(q) involving the risk significant planning standard 50.47(b)(4), which, in
this case, is not considered degraded. This EAL Classification finding is Green because
it involved one Unusual Event classifications (EAL HU6).
This finding has a cross-cutting aspect in the area of human performance,
decision-making, because the licensee failed to use conservative assumptions when
making decisions and did not demonstrate that nuclear safety was an overriding priority.
4 Enclosure 2
Specifically, the licensee changed its EAL Basis to indefinitely extend the start of the
15-minute emergency classification clock beyond a credible notification that a fire is
occurring or indication of a valid fire detection system alarm for one EAL HU6. This
change was screened through the licensees 50.54(q) process and was not identified as
a decrease in effectiveness. However, after evaluation by the inspector, this change
was determined to be a decrease in effectiveness of the emergency plan which was not
approved by the NRC before the change was implemented.
Enforcement:
Title 10 of the CFR 50.54(q) states, in part, AA licensee authorized to possess and
operate a nuclear power reactor shall follow and maintain in effect emergency plans
which meet the standards in '50.47(b) and the requirements in Appendix E of this part.
The nuclear power reactor licensee may make changes to these plans without
Commission approval only if the changes do not decrease the effectiveness of the plans
and the plans, as changed, continue to meet the standards of '50.47(b) and the
requirements of Appendix E to this part.
Title 10 CFR 50.47(b)(4) states, in part, A standard emergency classification and action
level scheme, the bases of which include facility system and effluent parameters, is in
use by the nuclear facility licensee, 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, as of March 28, 2008, the licensee made a change to the
emergency classification process which decreased the effectiveness of their emergency
plan and caused the emergency plan to no longer meet the standards of 50.47(b) and
Appendix E to this part without Commission approval. Specifically, the licensee modified
the EAL Basis in EAL HU6, Revision 21, to delay the 15-minute classification time by the
dispatching of personnel, reporting the notification of a fire from the field, and
extinguishing the fire. As a result, this change indefinitely extended the start of the
15-minute emergency classification clock beyond a credible notification that a fire is
occurring or indication of a valid fire detection system alarm. This change decreased the
effectiveness of the emergency plan by reducing the capability to perform a risk
significant planning function in a timely manner.
This violation impacted the regulatory process, was of very low safety significance and
was also entered into the licensees corrective action program as IR 01008718 dated
December 22, 2009. The violation is being cited in the Notice and a response is
required because no corrective action had been taken to restore compliance since the
issue was entered in your corrective action program in December 2009. This violation is
determined to be a Severity Level IV Cited Violation, consistent with Section 2.3.3 of the
NRC Enforcement Policy (NOV 05000456/2010503-01; NOV 05000457/2010503-01).
This issue has also been dispositioned as a Finding of very low safety significance
(Green) (FIN 05000456/2010503-01, FIN 05000457/2010503-01).
The URI 05000456/2009005-07; URI 05000457/2009503-07, Changes to EAL HU6
Potentially Decreased the Effectiveness of the Plans without Prior NRC Approval is
closed.
5 Enclosure 2
4OA6 Management Meetings
.1 Exit Meetings
On February 10, 2011, the inspectors discussed the inspection results by telephone with
Mr. D. Enright, and other members of the licensee staff. The licensee acknowledged the
issue presented. The inspectors confirmed that none of the potential report input
discussed was considered proprietary.
ATTACHMENT: SUPPLEMENTAL INFORMATION
6 Enclosure 2
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
D. Enright, Site Vice President
K. Aleshire, Corporate Emergency Preparedness Manager
S. Butler, Emergency Preparedness Manager
V. Cwietniewicz, Corporate Emergency Preparedness Manager
A. Daniels, Corporate Emergency Preparedness Manager
D. Drawbaugh, Byron Emergency Preparedness Manager
R. Gaston, Regulatory Assurance Manager
J. Gerrity, Regulatory Assurance
K. Kemper, Corporate Emergency Preparedness Director
U. S. Nuclear Regulatory Commission
H. Peterson, Chief, Operations Branch, Division Reactor Safety
E. Duncan, Chief, Branch 3, Division of Reactor Projects
J. Beavers, Emergency Preparedness Inspector
LIST OF ITEMS OPENED, CLOSED AND DISCUSSED
Opened
05000456/2010503-01 VIO (Traditional Enforcement) Changes to EAL Basis05000457/2010503-01 Decreases the Effectiveness of the Plan without Prior
NRC Approval (1EP4.1)05000456/2010503-01 FIN Changes Made to EAL Basis that Decreased the
05000457/2010503-01 Effectiveness (1EP4.1)
Closed
05000456/2009005-07 URI Changes to EAL HU6 Potentially Decreased the
05000457/2009005-07 Effectiveness of the Plans without Prior NRC Approval
(1EP4.1)
Discussed
None
1 Attachment
LIST OF DOCUMENTS REVIEWED
The following is a partial 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 or 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.
1EP4 Emergency Action Level and Emergency Plan Changes
EP-AA-1001; Radiological Emergency Plan Annex for Braidwood Station; Revisions 19,
20, and 21
IR 01173606; Braidwood URI on EAL HU6 Classified as Violation; February 10, 2011
IR 01012197; NRC URI for Changes Made to EAL HU6 for a Fire; January 4, 2010
IR 01008718; EP Notified of URI Issued at MidWest Sites for EAL Bases Change;
December 22, 2009
2 Attachment
LIST OF ACRONYMS USED
ADAMS Agencywide Document Access Management System
CAP Corrective Action Program
CFR Code of Federal Regulations
DRP Division of Reactor Projects
DRS Division of Reactor Safety
EAL Emergency Action Level
FIN Finding
IMC Inspection Manual Chapter
IP Inspection Procedure
IR Issue Report
MC Manual Chapter
NEI Nuclear Energy Institute
NOV Notice of Violation
NRC U. S. Nuclear Regulatory Commission
PARS Publicly Available Records System
ROP Reactor Oversight Process
SDP Significance Determination Process
URI Unresolved Item
3 Attachment
M. Pacilio -2-
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response. The NRC will use your response, in part, to
determine whether further enforcement action is necessary to ensure compliance with
regulatory requirements. In particular, the NRC is interested in any human performance issues
associated with performance of 10 CFR 50.54(q) reviews of Emergency Plan and Emergency
Action Level changes for all Exelon facilities.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter,
its enclosure, and your response, will be available electronically for public inspection in the NRC
Public Document Room or from the Publicly Available Records System (PARS) component of
NRC's Agencywide Documents Access and Management System (ADAMS), accessible from
the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading
Room).
Sincerely,
Hironori Peterson, Chief
Operations Branch
Division of Reactor Safety
Docket Nos. 50-456; 50-457
Enclosures:
1. Notice of Violation
2. Inspection Report 05000456/2010503(DRS);
w/Attachment: Supplemental Information
cc w/encls: Distribution via ListServ
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OFFICE RIII RIII RIII
NAME RJickling:co BP for SOrth HPeterson
DATE 02/25/2011 02/28/2011 02/28/2011
OFFICIAL RECORD COPY
Letter to Michael J. Pacilio from Hironori Peterson dated February 28, 2011.
SUBJECT: BRAIDWOOD STATION, UNITS 1 AND 2 FOLLOW-UP INSPECTION OF
EMERGENCY ACTION LEVEL AND EMERGENCY PLAN CHANGE
INSPECTION REPORT 05000456/2010503(DRS); 05000457/2010503(DRS)
AND NOTICE OF VIOLATION
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