ML16262A213
| ML16262A213 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 09/20/2016 |
| From: | Dan Dorman NRC Region 1 |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| Marjorie McLaughlin | |
| References | |
| EA-16-128 IR 2016009 | |
| Download: ML16262A213 (6) | |
See also: IR 05000244/2016009
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION I
2100 RENAISSANCE BLVD.
KING OF PRUSSIA, PA 19406-2713
September 20, 2016
Mr. Bryan C. Hanson
Senior Vice President, Exelon Generation Company, LLC
President and Chief Nuclear Officer, Exelon Nuclear
4300 Winfield Road
Warrenville, IL 60555
SUBJECT: R.E. GINNA NUCLEAR POWER PLANT, LLC - FINAL SIGNIFICANCE
DETERMINATION FOR A WHITE FINDING WITH ASSESSMENT FOLLOW-UP
AND NOTICE OF VIOLATION - INSPECTION REPORT 05000244/2016009
Dear Mr. Hanson:
This letter provides you the final significance determination for the preliminary White finding
discussed in the U.S. Nuclear Regulatory Commission (NRC) letter dated August 18, 2016,
which included NRC Inspection Report Numbers 05000244/2016002 and 07200067/2016001
(ML16232A051).1 The finding involved an inadvertent change Exelon Generation Company,
LLC (Exelon) made that introduced an error to the R.E. Ginna Nuclear Power Plant, LLC
(Ginna) Emergency Plan. As described in the subject inspection report, the NRC determined
that this finding also involved an apparent violation of Title 10 of the Code of Federal
Regulations (10 CFR) 50.54 (q)(2), Emergency Plans, because Exelon did not maintain the
effectiveness of Ginnas Emergency Plan such that it met the requirements of Appendix E,
Emergency Planning and Preparedness for Production and Utilization Facilities, and the
planning standards of 10 CFR 50.47(b). Specifically, Exelon implemented a revision to the
emergency action level (EAL) table for the fission product barrier matrix that was incorrect with
respect to the EAL threshold associated with potential loss of containment barrier. This could
have resulted in an untimely declaration of a General Emergency or a failure to declare a Site
Area Emergency during an actual event. It should be noted that, upon identification of the
discrepancy, Exelon immediately entered the issue into its corrective action program and issued
a standing order to inform plant personnel. Exelon subsequently revised the EAL table,
correcting the error.
In a telephone conversation with Mr. Anthony Dimitriadis of NRC, Region I, on August 25, 2016,
Mr. Joseph Pacher of your staff indicated that Exelon did not contest the characterization of the
risk significance of this finding and declined the opportunity to discuss this issue at a Regulatory
Conference or to provide a written response. Therefore, after considering the information
developed during the inspection, the NRC has concluded that the finding is appropriately
characterized as White. Note: According to NRC Inspection Manual Chapter (IMC) 0609,
appeal rights only apply to those licensees that have either attended a regulatory conference or
submitted a written response to the preliminary determination letter.
1
Designation in parentheses refers to an Agency-wide Documents Access and Management System
(ADAMS) accession number. Documents referenced in this letter are publicly-available using the
accession number in ADAMS.
B. Hanson -2-
The NRC has also determined that finding involved the violation of 10 CFR 50.54(q)(2), as cited
in the attached Notice of Violation (Notice). In accordance with the NRC Enforcement Policy,
the Notice is considered an escalated enforcement action because it is associated with a White
finding. You are required to respond to this letter and should follow the instructions specified in
the enclosed Notice when preparing your response. If you have additional information that you
believe the NRC should consider, you may provide it in your response to the Notice. The NRC
review of your response to the Notice will also determine whether further enforcement action is
necessary to ensure compliance with regulatory requirements.
As a result of this White finding in the Emergency Preparedness Cornerstone, the NRC has
assessed Ginna to be in the Regulatory Response column of the NRC Action Matrix, retroactive
to the second calendar quarter of 2016. The NRC plans to conduct a separate supplemental
inspection for this finding in accordance with Inspection Procedure (IP) 95001, Supplemental
Inspection Response to Action Matrix Column 2 Inputs, following Exelons notification of
readiness for this inspection. This inspection is conducted to provide assurance that the root
causes and contributing causes of any performance issues are understood, the extent of
condition is identified, and the corrective actions are sufficient to prevent recurrence.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice and Procedure," a copy of
this letter, its enclosure, and your response will be made available electronically for public
inspection in the NRC 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. To the extent
possible, your response should not include any personal privacy, proprietary, or safeguards
information so that it can be made available to the Public without redaction.
Should you have any questions regarding this matter, please contact Mr. Anthony Dimitriadis,
Chief, Projects Branch 1, Division of Reactor Projects in Region I, at (610) 337-6953.
Sincerely,
/RA David C. Lew for:/
Daniel H. Dorman
Regional Administrator
Docket No. 50-244
License No. DPR-18
Enclosure:
Notice of Violation
cc w/encl: Distribution via ListServ
SUNSI Review/ X Non-Sensitive X Publicly Available
X
MMM* Sensitive Non-Publicly Available
OFFICE RI/ORA RI/DRP RI/DRS RI/DRP RI/DRS RI/ ORA
M McLaughlin/ M Scott/ D Pelton
NAME A Dimitriadis/ AD* R McKinley/ RRM* R Lorson/ RKL* B Klukan/ BMK*
MMM* for*
DATE 8/26/16 8/26/16 8/29/16 9/01/16 9/01/16 9/01/16
OFFICE RI/ ORA OE NSIR/ NRR/ RI/DRA
T Marenchin via
NAME B Bickett/ BAB* R Kahler via email L Casey via email D Dorman/ DCL
DATE 9/06/16 9/14/16 9/07/16 9/07/16 DCL for 9/19/16
Letter to Bryan Hanson from Daniel Dorman dated September 20, 2016
Distribution w/encl: (via E-mail)
SECY RidsSecyMailCenter
OEMAIL OEMAIL Resource
OEWEB OEWEB Resource
V McCree, EDO RidsEdoMailCenter
M Johnson, DEDR
P Holahan, OE RidsOeMailCenter
N Hilton, OE
R Fretz, OE
N Hasan, OE
T Marenchin, OE
W Dean, NRR RidsNrrOd Resource
M Evans, NRR
B McDermott, NRR
C Miller, NRR
L Casey, NRR
B Holian, NSIR
S Coker, NSIR
R Khaler, NSIR
S LaVie, NSIR
ROPassessment Resource
Enforcement Coordinators RII, RIII, RIV
(D Gamberoni, R Skokowski, M Hay)
J Martin, OGC RidsOgcMailCenter
H Harrington, OPA RidsOpaMail Resource
H Bell, OIG RidsOigMailCenter
K Fowler, OI RidsOiMailCenter
L Bates, OCFO RIDSOcfoMailCenter
M Williams, OCFO
D Dorman, RA/RI R1ORAMail Resource
D Lew, DRA/RI
D Screnci, PAO-RI / N Sheehan, PAO-RI
D Tifft, ORA / C Crisden, ORA
M Scott, DRP R1DRPMail Resource
D Pelton, DRP
R Lorson, DRS R1DRSMail Resource
A Dimitriadis, DRP
A Rosebrook, DRP
J Bowen, RI OEDO
RidsNrrPMREGinna Resource
RidsNrrDorlLpl1-1 Resource
ROPReports Resource
B Klukan, ORA
B Bickett, ORA
M McLaughlin, ORA
D Bearde, ORA
Region I OE Files (with concurrences)
Enclosure
NOTICE OF VIOLATION
Exelon Generation Company, LLC Docket No. 50-244
R.E. Ginna Nuclear Power Plant License No. DPR-18
During an NRC inspection conducted from April 1, 2016 through June 30, 2016, and for which
an inspection exit meeting was conducted on July 12, 2016, a violation of NRC requirements
was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:
10 CFR 50.54(q)(2) requires that a holder of a license under this part shall follow and
maintain the effectiveness of an emergency plan that meets the requirements in
Appendix E to this part; and for nuclear power reactor licensees, the planning standards
of § 50.47(b).
10 CFR 50.47(b)(4) requires that 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.
Appendix E,Section IV.C.2, requires that nuclear reactor licensees shall establish and
maintain the capability to assess, classify, and declare an emergency condition within
15 minutes after the availability of indications to plant operators that an EAL has been
exceeded and shall promptly declare the emergency condition as soon as possible
following indication of the appropriate emergency classification level.
Contrary to the above, from December 23, 2013, until April 22, 2016, Exelon did not
maintain the effectiveness of Ginnas Emergency Plan such that it met the requirements
of Appendix E and the planning standards of 10 CFR 50.47(b). Specifically, Exelon did
not use an emergency classification and action level scheme that maintained the
licensees capability to assess, classify, and declare an emergency condition within 15
minutes after the availability of indications to plant operators that an EAL had been
exceeded. This could have resulted in an untimely declaration of a General Emergency
or a failure to declare a Site Area Emergency during an actual event. Specifically,
Exelon had implemented a revision to the EAL table for the fission product barrier matrix
that was incorrect with respect to the EAL threshold associated with potential loss of
containment barrier.
This violation is associated with a White Significance Determination Process finding.
Pursuant to the provisions of 10 CFR 2.201, Exelon Generation Company, LLC (Exelon) 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 I, and a copy to the NRC Resident Inspector at R.E. Ginna
Nuclear Power Plant, 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-16-128"
and should include for the 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
Notice of Violation -2-
correspondence, if the correspondence adequately addresses the required response. If an
adequate reply is not 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, United States 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 document 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, Exelon may be required to post this Notice within two
working days of receipt.
Dated this 20th day of September, 2016.