ML11314A255
| ML11314A255 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  (DPR-072) |
| Issue date: | 11/10/2011 |
| From: | Brian Bonser NRC/RGN-II/DRS/PSB1 |
| To: | Franke J Progress Energy Florida |
| References | |
| Download: ML11314A255 (41) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 November 10, 2011 Mr. Jon A. Franke Vice President, Crystal River Nuclear Plant Crystal River Nuclear Plant (NA2C) 15760 W. Power Line Street Crystal River, FL 34428-6708
SUBJECT:
PUBLIC MEETING
SUMMARY
CRYSTAL RIVER NUCLEAR PLANT, DOCKET NO. 50-302
Dear Mr. Franke:
This refers to the Category 1 public meeting which was held on November 7, 2011, in Atlanta, GA. The purpose of this meeting was to discuss a preliminary White finding involving Crystal River Unit 3s emergency plan emergency action level (EAL) 1.4 (General Emergency -
Gaseous Effluents), that contained instrument classification threshold values that were beyond the specified effluent radiation monitors capabilities to accurately indicate. This finding is documented in NRC Inspection Report 05000302/2011501 (ML112660544). A listing of meeting attendees and information presented during the meeting is enclosed.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter will be available electronically for public inspection in the NRC Public Document Room (PDR) or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS).
ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Should you have any questions concerning this meeting, please contact me at (404) 997-4653.
Sincerely,
/ RA / Wade Loo For B. Bonser Brian R. Bonser, Chief Plant Support Branch 1 Division of Reactor Safety Docket No.: 50-302 License No.: DPR-72
Enclosures:
- 1. List of Attendees
- 2. US NRC Slides
- 3. Progress Energy Presentation cc w/encl.: (See page 2)
November 10, 2011 Mr. Jon A. Franke Vice President, Crystal River Nuclear Plant Crystal River Nuclear Plant (NA2C) 15760 W. Power Line Street Crystal River, FL 34428-6708
SUBJECT:
PUBLIC MEETING
SUMMARY
CRYSTAL RIVER NUCLEAR PLANT, DOCKET NO. 50-302
Dear Mr. Franke:
This refers to the Category 1 public meeting which was held on November 7, 2011, in Atlanta, GA. The purpose of this meeting was to discuss a preliminary White finding involving Crystal River Unit 3s emergency plan emergency action level (EAL) 1.4 (General Emergency Gaseous Effluents), that contained instrument classification threshold values that were beyond the specified effluent radiation monitors capabilities to accurately indicate. This finding is documented in NRC Inspection Report 05000302/2011501 (ML112660544). A listing of meeting attendees and information presented during the meeting is enclosed.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter will be available eiectronicaiiy for public inspection in the NRC Public Document Room (PDR) or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/readinq-rm/adams.html (the Public Electronic Reading Room).
Should you have any questions concerning this meeting, please contact me at (404) 997-4653.
Sincerely, IRA! Wade Loo For B. Bonser Brian R. Bonser, Chief Plant Support Branch 1 Division of Reactor Safety Docket No.: 50-302 License No.: DPR-72
Enclosures:
- 1. List of Attendees
- 2. US NRC Slides
- 3. Progress Energy Presentation cc w/encl.: (See page 2)
Distribution w/encl:
PMNS Region II Regional Coordinator, EDO Public Affairs Officer, RII Chief, Resource Management Branch, RIl Region II Administrators Admin DRP Division Admin Region II Division Directors and Deputies Region II Receptionist HQ Operations Officer Public
- See previous concurrence page X PUBLICLY AVAILABLE X NON-PUBLICLY AVAILABLE SENSITIVE X NON-SENSITIVE ADAMS: X Yes ACCESSION NUMBER:
X SUNSI REVIEW COMPLETE X FORM 665 ATTACHED OFFICE RIl: DRS/PSB1 RII: DRS/PSB1 RII: DRS/PSB1 SIGNATURE RA/DB RA/MS RANVLForBB NAME D. BERKSHIRE M. SPECK B. BONSER DATE 11/10/2011 11/10/2011 11/10/2011 E-MAIL COPY?
YES NO YES NO YES NO YES NO YES NO YES NO YES NO OFFICIAL RECORD COPY DOCUMENT NAME:
G:DRSII\\PSB1EMERGENCY PREPAREDNESS\\CRYSTAL RIVER\\CR3 PUBLIC MEETING
SUMMARY
COVER MEMO REV1.DOCX ML11314A255
PROGRESS ENERGY 2
cc w/encl:
Kelvin Henderson General Manager Nuclear Fleet Operations Progress Energy Electronic Mail Distribution Brian C. McCabe Manager, Nuclear Oversight Shearon Harris Nuclear Power Plant Progress Energy Electronic Mail Distribution Terry D. Hobbs (Acting) Plant General Manager Crystal River Nuclear Plant (NA2C)
Electronic Mail Distribution Stephen J. Cahill Director - Engineering Nuclear Crystal River Nuclear Plant (NA2C)
Electronic Mail Distribution R. Alexander Glenn General Counsel Progress Energy Electronic Mail Distribution Jeffrey R. Swartz Director Site Operations Crystal River Nuclear Plant Electronic Mail Distribution Donna B. Alexander Manager, Nuclear Regulatory Affairs (interim)
Progress Energy Electronic Mail Distribution Thomas Sapporito Consulting Associate (Public Correspondence Only)
Post Office Box 8413 Jupiter, FL 33468 William A. Passetti, Chief Florida Bureau of Radiation Control Department of Health Electronic Mail Distribution Daniel R. Westcott Supervisor Licensing & Regulatory Programs Crystal River Nuclear Plant (NA1B)
Electronic Mail Distribution Joseph W. Donahue Vice President Nuclear Oversight Progress Energy Electronic Mail Distribution Jack E. Huegel Manager, Nuclear Oversight Crystal River Nuclear Plant Electronic Mail Distribution David T. Conley Senior Counsel Legal Department Progress Energy Electronic Mail Distribution Mark Rigsby Manager, Support Services - Nuclear Crystal River Nuclear Plant (NA2C)
Electronic Mail Distribution Senior Resident Inspector U.S. Nuclear Regulatory Commission Crystal River Nuclear Generating Plant U.S. NRC 6745 N Tallahassee Rd Crystal River, FL 34428 Attorney General Department of Legal Affairs The Capitol PL-01 Tallahassee, FL 32399-1050 Bryan Koon, Director Florida Division of Emergency Management Electronic Mail Distribution Chairman Board of County Commissioners Citrus County 110 N. Apopka Avenue Inverness, FL 36250
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List of Attendees Regulatory Conference with Crystal River Nuclear Plant November 7, 2011 Public Participants Telephone M. Hancock, High Risk Organizer, Southern Alliance for Clean Energy M. krekel, Royal Bank of Canada NRC Telephone Participation L. Casey, Office of Enforcement (OE)
C. Murray NSIR Emergency Preparedness (EP)
F. Saba NRR Sr. PM E. Schrader NSIR EP NRC Observers S. LaVie, NSIR M. Donithan, Region Il R. Kellner, Region Il W. Pursley, Region II J. Rivera, Region II
Public Meeting Summary En C 10 S u re 2 Crys ta 1 River Un it 3 Regulatory Conference Nuclear Re gulatory Commis s ion Re gion II November 7,2011 Protecting People and theEnvironment
Purpose of Todays. Meeting Provide Progress Energy an opportunity to explain the details of their position with regard to a preliminary White finding documented in Emergency Preparedness inspection report 05000302/2011501.
2 Protecting People and the Environment
Opening Remarks and Introduction
- NRC Regulatory and Enforcement Policy Statement of Issue and Apparent Violation
- Progress Energy
- Break/NRC Caucus
- NRC Follow Up Questions
- Closing Remarks
- NRC available to address public questions 3
Protecting People and the Environment
Pb1ic Meeting Summary C
Crystal River Unit 3 Regulatory Conference Nuclear Regulatory Commission Region II November 7, 2011 Protecting People and the Environment
Crystal River Unit 3 Nuclear Plant Emergency Preparedness Regulatory Conference Nuclear Regulatory Commission Region II November 7, 2011 nkF/eet
&. Progress Energy
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Agenda
- Apparent Violation
- Background Immediate Corrective Actions
- Extent of Condition
- Evaluation Results
- Completed Actions
- Actions Remaining
- Significance
- Closing Remarks 3
Think Fleet Progress Energy
Apparent Violation Requirements Apparent Violation September 23, 2011 License Condition 10 CFR 50.54(q) requires operating license holders to follow and maintain in effect emergency plans which meet the standards in 10 CFR 50.47(b) and Appendix E 10 CFR 50.47(b)(4) requres 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 kFcc.
Emergency plan emergency action level (EAL) 1.4 (General Emergency
Gaseous Effluents) contained instrument classification threshold values that were beyond the specified effluent radiation monitors capabilities to accurately measure 4
Progress Energy
=
Background===
- 06/24/11: Reviewed Industry Operating Experience on EAL threshold above instrument/monitor range
- 06/27/11: Licensee identified OE applicability at CR3, i.e. EAL 1.4 setpoints exceeded the instrument range of RM-A1/RM-A2 instrumentation Think Fleet Progress Energy
Immediate Corrective Actions
- Immediately returned Radiation Monitor Mid-Range setpoints to the previous EAL 1.4 value
- Completed an evaluation of the monitors capabilities and function:
- Established EAL 1.4 threshold at 3 mR/hr on the high-range scale for RM-A1/RM-A2
- Completed Fleet EAL review to determine if similar vulnerabilities existed Fleet 6
Progress Energy
Immediate çorrectiveActions
- Implemented Interim Guidance for EAL Changes
- Field walk-downs for process monitor changes
- Clear expectations for more rigorous reviews
- Senior Reactor Operator (SRO)
- EP Functional Area Manager
- System Engineer (EALs relating to process equipment such as radiological instruments or environmental monitoring)
- Change Log to include check-off list to aid in the updating of RERP
- Validation review by an Emergency Coordinator
- Review/Approval by Plant Nuclear Safety Committee
- Guidance/expectations provided to NGG Fleet/Site ocedure writers for EAL changes Progress Energy
Extent of Condition
- Verified EP related instruments/equipment are capable of performing their intended function
- Reviewed Emergency Preparedness Implementing Procedures (EPIPs)
- EAL-Bases Manual
- EM-202, Duties of the Emergency Coordinator
- EM-.21 9, Duties of the Dose Assessment Team
- EM-400, Operation of the Emergency Operations Facility (EOF)
- EM-402, EOF Technical Support Team
- EM-91 1, Security Threats
- EMG-NGGC-0002, Off-Site Dose Assessment
- CH-631, Post Accident Sampling and Analysis of Reactor Building Vent, Auxiliary Building Vent and Reactor Building Atmosphere 8
Progress Energy
Evaluation Results
- Root Cause
- Insufficient procedure detail/guidance for the EAL change process
- Key Contributing Causes
- Assumptions were made and not validated
- Reviews not adequate or not conducted kFIecf Progress Energy
Completed Actions
- Nuclear Safety Review Committee review of Root Cause Evaluation
- Independent (outside PGN) consultant review of EAL scheme and EEP program
- EP Staff task analysis review
- Reviewed change process for other non-plant operating manual documents
- Shared OE with Fleet and Industry 10 Progress Energy
Actions Remaining
- Corrective Action To Prevent Recurrence (CAPR)
Codify the interim guidance requiring a more rigorous process with specific guidance on the development, validation and implementation of EALs
- Revise EAL Basis Manual and related training materials to more clearly define the RM-A1/RM-A2 mid-range and high range monitor responses and different calibration and response factors
- Provide Operator training on the Low Medium High Valve Controllers (LMHVC) and the range of operation for RM-A1/RM-A2 mid and high range monitors kF1 11 Progress Energy
Significanc CR-3 EAL Scieme
- EAL 1.4 can be entered by three options:
1)
RM-A1 or RM-A2 mid-range thresholds exceeded for
>15 mm 2)
Dose Assessment results indicate SITE BOUNDARY dose >1000 mR TEDE or >5000 mR thyroid ODE for the actual or projected duration of the release AND core damage is suspected or has occurred 3)
Field survey results indicate closed window dose rates
>1000 mR/hr expected to continue for more than one hour; or analyses of field survey samples indicate thyroid ODE of 5000 mR for one hour of inhalation at or beyond SITE BOUNDARY 12 Progress Energy
Significance General Emergency Declaration Remained Timely and Accurate NRCs White Finding significance determination based on Manual Chapter (MC) 0609 Appendix B, page B-34 (Sheet 1, Failure to Comply)
Per MC 0609 Appendix B, EAL 1.4 was not degraded General Emergency Declaration and Notification Other EALs would be met to declare a General Emergency before EAL 1.4 dose thresholds were met EAL 1.4 Option 2, Release Significance Category Determination would be conducted also supporting timely classification EAL 1.4 Option I with the threshold error, would still contribute to a General Emergency Declaration Postulated accidents involving site boundary dose rates at PAG levels would result in a timely General Emergency declaration that would not be delayed (<15 minutes)
Clarification in the Draft Predecisional MC 0609, Appendix B also supports EAL I.4 was not degraded Fleet 13 Progress Energy
Significance CR-3 EAL Scheme Diverse and Redundant Category Abnormal Radiation Levels/Effluents EAL 1.1-1.4 Natural/Manmade Hazards and EC Judgment System Malfunction Loss of Power Loss/Potential Loss Fuel Clad Loss/Potential Loss RCS Loss/Potential Loss Containment Alert x
,,kF1ce.
14 Progress Energy x
x x
x x
x x
x x
x x
x x
x x
x x
x x
x x
x x
x x
x x
Significance Mitigating Factors/Alternative EALs: RERP Multiple alternative EALs would be met to declare a General Emergency well BEFORE EAL 1.4 dose thresholds would be reached Fission Product Barrier EALs would be used to declare a General Emergency well before site boundary doses would exceed EPA PAG limits Loss of 2 of 3 barriers with potential loss of third = General Emergency Containment Radiation Monitors would provide indication of General Emergency condition ahead of RM-A1/RM-A2 15 Progress Energy
Significance Mitigating Factors/Alternative EALs RERP Fission Product: Barrier Matrix: Potential Loss Potential Loss of Fuel Potential Loss of RCS Potential Loss of Clad Containment Entry into EOP RCS Leak one or more RB Pressure >54 psig Injection Valves Core Exit Thermocouples RCS Leak resulting in ES RB Hydrogen >4%
Actuation EC Deems Barrier in RCS Pressure/Temperature RB Pressure >30 psig with no Jeopardy Building Spray available HPI/PORV Cooling in RB High Rad Monitors Progress
>25,000 R/hr EC Deems Barrier in Core Conditions in Severe Jeopardy Accident Region of ICC Curves EC Deems Barrier in Jeopardy ThinkF/
16 Progress Energy
Significance Mitigating Factors/Alternative EALs RERP Fission Product Barrier Matrix: Loss Loss of Fuel Clad Loss of RCS Loss of Containment Core Condition in RCS Leak Resulting in Loss Rapid Unexplained RB Region 3 of ICC Curves of Adequate Subcooling Pressure Decrease Margin RCS Activity >300 pCi/gm RB High Rad Monitors RB Pressure or Sump Level 1-131 DE
>100 RIhr for 15 minutes not consistent with LOCA Conditions RB High Rad Monitors EC Deems Barrier is Lost OTSG Leak >10 gpm with
>100 RIhr for 15 minutes Prolonged Steaming EC Deems Barrier is Lost RB Isolation incomplete and Release Path Exists EC Deems Barrier is Lost Think F/oct 17 Progress Energy
Significance Mitigating Factors/Alternative EALs RERP Simplified Block Diagram Illustrating Relationship of the Fission Product Barrier EALs and EAL 1.4 Fuel Clad Potential Loss EAL5.2 Loss EAL5.1
,kFloo.
1 RCS Potential Loss EAL6.2 Loss EAL6.1 1
Containment Potential Loss EAL7.2 Loss EAL7.1 18 I
Progress Energy EAL 1.4
Significance CR-3_EAL_Scheme
- EAL 1.4 can be entered by three options:
1)
RM-A1 or RM-A2 mid-range thresholds exceeded for
>15 mm 2)
Dose Assessment results indicate SITE BOUNDARY dose >1000 mR TEDE or >5000 mR thyroid ODE for the actual or projected duration of the release AND core damage is suspected or has occurred 3)
Field survey results indicate closed windows dose rates >1000 mR/hr expected to continue for more than one hour; or analyses of field survey samples indicate thyroid CDE of 5000 mR for one hour of inhalation at or beyond SITE BOUNDARY 19 Progress Energy
Significance EAL 1.4 Option I Option 1: RM-A1 & RM-A2 At some General Emergency levels, mid-range for RM-A1/RM-A2 is beyond usable scale Operator would recognize monitor had transitioned to the high range scale Plant computer points (W330, W331, W335, & W336) provide continuous data of RM-A1 and RM-A2 mid range and high-range readings Plant computer data would clearly indicate a mid range purge and high-range output would be available for EC and Dose Assessment Team evaluation Guidance contained in EAL would still contribute to a
,,General Emergency Declaration 20 Progress Energy
Significance EALI.4Option2
- Option 2: Dose Assessment Methods
- Primary Method Used by Dose Assessment Team at EOF for Alert or Higher
- EM-204a
- Control Room Method
- Uses Low and Mid Range Monitors Limited for Hugh Wind Speeds and Short Durations
- Release Significance Category Determination
- Core Damage plus Release in Progress would support General Emergency Classification in <15 minutes
,ikFIeot 21 Progress Energy
Significance EALI.4Option3
- Option 3: Field Monitoring Team Results
- Field Monitoring Teams available at an Alert or Higher
- Teams are dispatched from the TSC/OSC and/or by Shift Manager from the Control Room (on-shift RP)
- Provides necessary information for General Emergency declaration using EAL I.4 Think Fleet 22 Progress Energy
Simplified Block Diagram Illustrating Relationship of the Fission Product Barrier EALs and EAL 1.4 RCS Potential Loss Potential Loss Potential Loss EAL5.2 EAL6.2 EAL7.2 Loss Loss Loss EAL 5i EAL 6.1 EAL 7.1 I
I I
nkF,ce Progress Energy Significance Mitigating Factors/Alternative EALs RERP Fuel Clad Containment EAL 1.4 23
Significance Mitigating Factors/Alternative EALs RERP
- Spent Fuel Pool Accident
- Only other postulated event beyond fission product barrier loss resulting in PAG level site boundary doses
- A catastrophic failure (pool containing fuel and quickly drained) would be declared by EAL 2.27 based on:
The potential for uncontrolled radionuclide releases that can be expected to exceed EPA Protective Action Guidelines Plume Exposure Levels beyond the site boundary
- Spent fuel pool failure over time would result in an Alert when leakage exceeds makeup capacity
- Dose assessment and field teams would be staffed
- EAL 1.4 Options 2 & 3 would be used to escalate to General Emergency in a timely manner 24 Progress Energy
Significance Mitigating FactorslAlternatiVe EALs RERP
- Actual Experience
- Reviewed Exercises and Drills conducted since 1983
- Scenarios involving PAG level site boundary doses routinely used
- EAL 1.4 has not been used to declare a General Emergencies (GE) since implemented in June 2000 due to the multiple alternative EAL thresholds that are met well before site boundary doses reach PAG levels
- The Dose Projection EAL was used prior to 2000 to declare a GE in some drills (prior to Fission Product Barrier EALs)
- Supports the effectiveness of the alternative EALs as Mitigating Factors 25 Progress Energy
SREEN Significance Manual Chaflter 0609, Appendix B Failure to Comply PS NO Problem?
YES PS Problem?
Function GREEN Failure?
I YES YES WHITE (ES RSPS Function NO Failure?
Function?
YES YELLOW kF/oet.
26
!4 Progress Energy
Significance Mitigating Factors I
- Excerpts
- As used herein, an EAL is ineffective when it no longer results in a timely and accurate declaration for the initiating condition.
- An EAL may be rendered ineffective by changes to facility procedures, systems, or equipment, errors in numeric thresholds; or any other cause that could result in an initialing condition, which should be declared, riot being declared in a timely and accurate manner following the change(s) 1 Draft Predecisional Manual Chapter 0609, App. B 27 Progress Energy
EAL schemes often have either redundant or diverse indications for the same Initiating Condition. Credit is to be given to these alternative EALs as MITIGATING FACTORS if they were part of the licensees approved emergency classification scheme before the ineffective EAL was identified.
One of the following two significance situations may exist:
1) 2)
If the aIterntive EALs are such that an accurate and timely declaration of the initiating condition would still be made, the classification function is neither lost nor degraded. In this context, timely means within the 15-minute timeliness capability requirement. For example, loss or potential loss of the fuel barrier EAL may include thresholds such as reactor pressure vessel (RPV) level and drywell radiation monitor. An RPV level threshold is a precursor to core damage and can adequately compensate for an ineffective drywell radiation monitor threshold because the declaration will still be timely and accurate. However, a classification based on drywell radiation monitor threshold rather than an ineffective RPV level would likely be delayed (as the core damage must first occur for the radiation monitor to indicate).
28 Progress Energy
Significance Draft Manual Chapter 0609, Appendix B Event would not be declared Yellow Event would be declared in a dec raded manner 1
Event would be declared in a timely arid accurate manner 1
Event would not be deals red I
Event would be dedared in a degraded manner 1
Event would be declared in atirnely and accurate manner 1
I Finding Event would riot be declared I
careen EAL Oiterc lass iflcntion Would result in unnecessary PARs for the public 3
Would result in unnecessa, classification White Green Frnercjency oriclrtion wcruM be declared because of unaffected redundant or diverse tEAl fl-irhokis, An EAL s inettectiue when it in of itself, no longer results in a timety and accurate declaration foe the initiating condition.
hi making this detarrhnation. consider only those public protective act,ons that would be triggered byan ORO receving notification of a parbcuiar emergency classificaton (e.g., an invalid General emergency deciarat4on). This signicance loglo does not apply to over classifications during an actual event.
fleet.
29 Progress Energy EALDefidency I
Classification Level lmnpac-tof Deficient EAL Finding General Emnen?encvj I Inafferkiua FAI 2
I I
I Ftlt A ran F nrnancsi rjnr IF nr AIa.fr 2
S Event would bededared ma degraded manner 1
N Finding Event would be declared mnatimnely and accurate manner 1
No Finding
Closing Remarks
- Progress Energy concurs with the Apparent Violation
- Immediate actions taken to restore compliance
- Prompt extensive and comprehensive Extent of Condition completed
- Corrective actions ensure increased rigor in Emergency Plan changes
- EAL Structure and Accident Scenario EALs FPB loss or SFP accidents are precursors to PAG level site boundary doses
- Ensure timely and accurate classification and notification of General Emergency
- Ensure Protective Action Guides are followed
- Protect Public Health and Safety
- Progress Energys conclusion, based on MC 0609 gjppendix B, is the significance of this Finding Green 30 Progress Energy
Questions?
,ikFlee.
31 Progress Energy