IR 05000282/2012504

IR 05000282-12-504; 12/10/2012 - 12/18/2012; Prairie Island Nuclear Generating Plant, Unit 1; Emergency Preparedness Focused Baseline Inspection

ML13024A420
Person / Time
Site:	Prairie Island
Issue date:	01/24/2013
From:	O'Brien K Division of Reactor Safety III
To:	Jeffery Lynch Northern States Power Co
References
EA-12-273 IR-12-504
Download: ML13024A420 (13)

Text

ary 24, 2013

SUBJECT:

PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 1 -

NRC EMERGENCY PREPAREDNESS INSPECTION REPORT 05000282/2012504; PRELIMINARY WHITE FINDING

Dear Mr. Lynch:

On December 18, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed an Emergency Preparedness inspection at your Prairie Island Nuclear Generating Plant, Unit 1.

The enclosed report documents the inspection findings, which were discussed on December 18, 2012, with Mr. K. Davison 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.

This report documents an NRC-identified finding that has been determined to be preliminarily White, a finding with low to moderate safety significance that may require additional NRC inspections. As described in Section 1EP5.1 of this report, a finding was identified for failure to comply with 10 CFR 50.54(q)(2) and 10 CR 50.47(b)(4). Specifically, from July 24, 2011, until May 18, 2012, Prairie Island Nuclear Generating Plants Unit 1 response to the loss of 1R-50 Shield Building Hi Range Vent Gas Radiation Detector failed to restore the capability to classify emergency action levels, RG1.1, General Emergency, and RS1.1, Site Area Emergency. This finding was assessed based on the best information available, using the Emergency Preparedness Significance Determination Process (SDP). The final resolution of this finding will be conveyed in separate correspondence. The finding is also associated with an apparent violation of NRC requirements and is being considered for escalated enforcement action in accordance with the NRC Enforcement Policy, which can be found on the NRCs Web site at http://www.nrc.gov/about-nrc/regulatory/

enforcement/enforce-pol.html.

In accordance with NRC Inspection Manual Chapter 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. The SDP encourages an open dialogue between the NRC staff and the licensee; however, 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 to either: (1) 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. To announce the conference, a public meeting notice and press release will be issued. 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.

In addition, if you disagree with the cross-cutting aspect assigned to the finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region III, and the NRC Resident Inspector at the Prairie Island Nuclear Generating Plant.

Please contact Donald Funk, Acting Chief, Plant Support Branch, at (630) 829-9822, and in writing within 10 days of the date of this letter to notify the NRC of your intended response. 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.

Since the NRC has not made a final determination in this matter, a Notice of Violation is not being issued for this inspection finding at this time. 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, its enclosure, and your response (if any), 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/

Kenneth G. OBrien, Acting Director Division of Reactor Safety Docket No. 50-282 License No. DPR-42

Enclosure:

Inspection Report 05000282/2012504 w/Attachment: Supplemental Information

REGION III==

Docket No: 50-282 License No: DPR-42 Report No: 05000282/2012504 Licensee: Northern States Power Company, Minnesota Facility: Prairie Island Nuclear Generating Plant, Unit 1 Location: Welch, MN Dates: December 10 - 18, 2012 Inspectors: J. Beavers, Emergency Preparedness Inspector R. Jickling, Senior Emergency Preparedness Inspector K. Stoedter, Senior Resident Inspector K. Barclay, Resident Inspector Approved by: D. Funk, Acting Chief Plant Support Branch Division of Reactor Safety Enclosure

SUMMARY OF FINDINGS

IR 05000282/2012504; 12/10/2012 - 12/18/2012; Prairie Island Nuclear Generating Plant,

Unit 1; Emergency Preparedness Focused Baseline Inspection.

This report covers an announced baseline inspection by two regional inspectors and two resident inspectors. The inspectors identified a finding with a preliminary significance of White and associated apparent violation (AV). The significance of inspection findings are indicated by their color (i.e., Greater Than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process dated June 2, 2011. The cross-cutting aspects are determined using IMC 0310; Components Within the Cross-Cutting Areas dated October 28, 2011. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy dated June 7, 2012. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process Revision 4, dated December 2006.

NRC-Identified

and Self-Revealed Findings

Cornerstone: Emergency Preparedness

• Preliminarily White: A finding having a significance of preliminarily White with one AV of 10 CFR 50.54(q)(2) associated with risk-significant planning standard 10 CFR 50.47(b)(4) was identified by the NRC for the licensee's failure to follow and maintain the effectiveness of its emergency plan. Specifically, from July 24, 2011, until May 18, 2012,

Prairie Island Nuclear Generating Plants Unit 1 response to the loss of 1R-50 Shield Building Hi Range Vent Gas Radiation Detector failed to restore the capability to classify Emergency Action Levels (EALs), RG1.1, General Emergency, and RS1.1, Site Area Emergency. On May 17, 2012, Corrective Action Program entry 01338120 was written and identified the incorrect repair priority on 1R-50. The instrument was repaired and returned to service on May 18, 2012.

This finding was determined to be more than minor because it was associated with the Emergency Response Organization performance attribute of the Reactor Safety -

Emergency Preparedness Cornerstone. This finding 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. This finding was evaluated in accordance with IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process. As Appendix B was revised in February 2012, the finding was evaluated using both the version in effect at the time of the violation and the current version. Under both versions, other than changing the names of the involved Section and Sheet/Attachment, there was no effect on the final outcome. The issue was determined to be a Failure to Comply. The risk was evaluated using Section 4.0 of IMC 0609 and Sheet 1, Failure to Comply, in the previous revision, and Section 5.0 and Attachment 2, Failure to Comply Significance Logic, in the current revision, along with their associated narratives. With EALs, RG1.1 and RS1.1, ineffective, the inspectors considered mitigating factors, such as alternative EALs, within the same initiating condition and determined the alternative EALs were such that an accurate declaration of the initiating condition would have been made. Therefore, the inspectors determined that no loss of Risk-Significant Planning Standard (RSPS)function existed. However, the alternative EAL classifications would have been delayed, and, therefore, the event would have been declared in a degraded manner. The finding was preliminarily determined to be of low to moderate safety significance (White) in that ineffective EALs, RG1.1, and RS1.1 existed, degraded an RSPS function, and affected the ability of the licensee to properly classify events involving a radiological release.

A cross-cutting aspect (H.1(a)) was identified within the decision making component.

The licensees risk-significant decision concerning the timely corrective actions to restore the failed 1R-50 Shield Building Hi Range Vent Gas Radiation Detector did not use a systematic process to ensure safety was maintained. A lack of formally defined authority and roles for decisions and communications precluded the appropriate interdisciplinary input, evaluation, and repair of this equipment. (Section 1EP5.1)

Licensee-Identified Violations

No violations were identified.

REPORT DETAILS

1EP5 Maintenance of Emergency Preparedness

.1 Maintenance of Emergency Preparedness

a. Inspection Scope

The inspectors performed in-office and on-site reviews of site procedures, documents and corrective actions related to the extended loss of one Prairie Island Nuclear Power Plants R-50 Shield Building Hi Range Vent Gas Radiation Detector to determine compliance with the regulations 10 CFR 50.54(q)(2). Processes describing the identification, compensatory measures, and repair of Emergency Action Level (EAL)-related equipment were discussed with emergency preparedness and Emergency Response Organization (ERO) personnel. Documents reviewed are listed in the to this report.

This maintenance of emergency preparedness inspection constituted zero samples as defined in Inspection Procedure 71114.05-06.

b. Findings

Introduction:

A finding having a significance of preliminarily White with one apparent violation of 10 CFR 50.54(q)(2) associated with risk-significant planning standard 10 CFR 50.47(b)(4) was identified by the NRC for the licensee's failure to follow and maintain the effectiveness of its emergency plan. Specifically, from July 24, 2011, until May 18, 2012, Prairie Island Nuclear Generating Plants Unit 1 response to the loss of 1R-50 Shield Building Hi Range Vent Gas Radiation Detector failed to restore the capability to classify EALs, RG1.1, General Emergency, and RS1.1, Site Area Emergency.

Description:

On July 24, 2011, the Unit 1 Prairie Island Nuclear Power Plant 1R-50, Shield Building Hi Range Vent Gas Radiation Detector failed and was taken out of service. The compensatory measure of using the 1R-22 Shield Building Vent Stack Monitor for tracking effluent radiation was immediately enacted. Troubleshooting was performed on August 10, 2011, and corrective actions to restore the failed 1R-50 Shield Building Hi Range Vent Gas Radiation Detector instrument were scheduled for June 2012. On February 9, 2012, FP-EP-EQP-01, Fleet Procedure of Equipment Important to EP, was issued. Operations identified an equipment issue with 1R-50 using the new procedure and Action Request (AR) 01325419 was initiated on February 17, 2012. On May 17, 2012, Corrective Action Program entry 01338120 was written and identified the priority on 1R-50 to be incorrect. The instrument was repaired and returned to service on May 18, 2012.

From December 10, 2012, to December 18, 2012, the NRC performed in-office and on-site reviews of site procedures, documents, and corrective actions related to the loss of 1R-50 Shield Building Hi Range Vent Gas Radiation Detector to determine compliance with the regulations 10 CFR 50.54(q)(2). The inspectors determined that the compensatory measure put into place by the licensee, namely the use of the 1R-22 Shield Building Vent Stack Monitor, was not capable of providing a valid reading for EAL, RG1.1, General Emergency, or EAL RS1.1, Site Area Emergency, because the instrument range limitations affected the licensees ability to determine the magnitude of, and continually assess the impact of, the release of radioactive materials for the Site Area and General Emergency events.

The NRC determined the response failed to restore the capability to classify EALs, RG1.1 and RS1.1, and rendered them ineffective. Additionally, the instrument failure would also inhibit the licensees ability to continually assess the magnitude of a radioactive material release.

Analysis:

The inspectors determined that the extended loss of the Prairie Island 1R-50 Shield Building Hi Range Vent Gas Radiation Detector involved a failure to meet a requirement and was within the licensees ability to foresee and correct. Therefore, it met the definition of a performance deficiency. This finding was determined to be more than minor because it was associated with the ERO performance attribute of the Reactor Safety - Emergency Preparedness Cornerstone. This finding 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.

This finding was evaluated in accordance with Inspection Manual Chapter (IMC) 0609, Appendix B, Emergency Preparedness Significance Determination Process. As Appendix B was revised in February 2012, the finding was evaluated using both the version in effect at the time of the violation and the current version. Under both versions, other than changing the names of the involved Section and Sheet/Attachment, there was no effect on the final outcome. The issue was determined to be a Failure to Comply.

The risk was evaluated using Section 4.0 of IMC 0609 and Sheet 1, Failure to Comply, in the previous revision, and Section 5.0 and Attachment 2, Failure to Comply Significance Logic, in the current revision, along with their associated narratives. With EALs, RG1.1 and RS1.1 ineffective, the inspectors considered mitigating factors, such as alternative EALs within the same initiating condition, and determined the alternative EALs were such that an accurate declaration of the initiating condition would have been made. Therefore, the inspectors determined that no loss of Risk-Significant Planning Standard (RSPS) function existed. However, the alternative EAL classifications would have been delayed, and, therefore, the event would have been declared in a degraded manner. The finding was preliminarily determined to be of low to moderate safety significance (White) in that ineffective EALs, RG1.1, and RS1.1 existed, degraded an RSPS function, and affected the ability of the licensee to properly classify events involving a radiological release.

A cross-cutting aspect (H.1(a)) was identified within the decision making component.

The licensees risk-significant decision concerning the timely corrective actions to restore the failed 1R-50 Shield Building Hi Range Vent Gas Radiation Detector did not use a systematic process to ensure safety was maintained. A lack of formally defined authority and roles for decisions and communications precluded the appropriate interdisciplinary input, evaluation, and repair of this equipment. (Section 1EP5.1)

Enforcement:

Title 10 CFR 50.54(q)(2) requires that a holder of a nuclear power reactor operating license follow and maintain the effectiveness of an emergency plan that meets the requirements in Appendix E to this part and the risk-significant planning standard of 10 CFR 50.47(b). Title 10 CFR 50.47(b)(4), states, 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.

An AV of 10 CFR 50.54(q)(2) associated with risk-significant planning standard 10 CFR 50.47(b)(4) was identified by the NRC for the failure to follow and maintain the effectiveness of its emergency plan. Specifically, from July 24, 2011, until May 18, 2012, Prairie Island Nuclear Generating Plants Unit 1 response to the loss of 1R-50 Shield Building Hi Range Vent Gas Radiation Detector failed to restore the capability to classify EALs, RG1.1, General Emergency, and RS1.1, Site Area Emergency.

The 1R-50 Shield Building Hi Range Vent Gas Radiation Detector was restored on May 18, 2012, as described in Corrective Action Program entry. The finding and associated AV of 10 CFR 50.54(q)(2) and risk-significant planning standard 10 CFR 47(b)(4), is of preliminarily White significance pending completion of the final significance determination (AV 05000282/2012504-01, Degraded Emergency Action Level Scheme).

4OA6 Management Meetings

.1 Interim Exit Meetings

On December 18, 2012, the inspectors presented the focused baseline inspection results to Mr. K. Davison and other members of your staff. The inspectors confirmed that none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

J. Anderson, Regulatory Affairs

T. Borlen, Training Manager

J. Callahan, Corporate Emergency Preparedness

K. DeFusco, Emergency Preparedness

K. Davison, Director Site Operations

P. Huffman, Director Site Engineering

B. Kappes, Nuclear Oversight

J. Nemcek, Emergency Preparedness Coordinator

I. Nordby, Regulatory Affairs

J. Sternishe, Training

E. Weinkam, Corporate Emergency Preparedness

Nuclear Regulatory Commission

J. Beavers, Emergency Preparedness Inspector

B. Jickling, Senior Emergency Preparedness Inspector

K. OBrien, Acting Director, Division of Reactor Safety

K. Stoedter, Senior Resident Inspector

LIST OF ITEMS

Opened

05000282/2012504-01 AV Degraded Emergency Action Level Scheme (Section 1EP5.1)

Closed/Discussed None Attachment