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| issue date = 12/18/2014
| issue date = 12/18/2014
| title = IR 05000456/2014502, 05000457/2014502, on 11/17/2014 - 11/21/2014, Braidwood Station, Units 1 and 2, Baseline Emergency Preparedness Exercise Evaluation - Hostile Action Event, Exercise Evaluation Scenario Review; Performance Indicator Veri
| title = IR 05000456/2014502, 05000457/2014502, on 11/17/2014 - 11/21/2014, Braidwood Station, Units 1 and 2, Baseline Emergency Preparedness Exercise Evaluation - Hostile Action Event, Exercise Evaluation Scenario Review; Performance Indicator Veri
| author name = Orth S K
| author name = Orth S
| author affiliation = NRC/RGN-III/DRS/PSB
| author affiliation = NRC/RGN-III/DRS/PSB
| addressee name = Pacilio M J
| addressee name = Pacilio M
| addressee affiliation = Exelon Generation Co, LLC, Exelon Nuclear
| addressee affiliation = Exelon Generation Co, LLC, Exelon Nuclear
| docket = 05000456, 05000457
| docket = 05000456, 05000457
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:
{{#Wiki_filter:UNITED STATES mber 18, 2014
[[Issue date::December 18, 2014]]


Mr. Michael Senior VP, Exelon Generation Co., LLC President and CNO, Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555
==SUBJECT:==
BRAIDWOOD STATION, UNITS 1 AND 2, BASELINE EMERGENCY PREPAREDNESS BIENNIAL EXERCISE INSPECTION REPORT 05000456/2014502; 05000457/2014502


SUBJECT: BRAIDWOOD STATION, UNITS 1 AND 2, BASELINE EMERGENCY PREPAREDNESS BIENNIAL EXERCISE INSPECTION REPORT 05000456/2014502; 05000457/2014502
==Dear Mr. Pacilio:==
On November 21, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Braidwood Station, Units 1 and 2. The enclosed report documents the results of this inspection which were discussed on November 21, 2014, with Mr. M. Kanavos 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. No findings were identified during this inspection.


==Dear Mr. Pacilio:==
In accordance with Title 10, Code of Federal Regulations (CFR), Section 2.390 of the NRC's
On November 21, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Braidwood Station, Units 1 and 2. The enclosed report documents the results of this inspection which were discussed on November 21, 2014, with Mr. M. Kanavos and other members of your staff. The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. No findings were identified during this inspection. In accordance with Title 10, Code of Federal Regulations (CFR), Section 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).
"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/
Sincerely,
Steven K. Orth, Chief Plant Support Branch Division of Reactor Safety Docket Nos. 50-456; 50-457 License Nos. NPF-72; NPF-77  
/RA/
Steven K. Orth, Chief Plant Support Branch Division of Reactor Safety Docket Nos. 50-456; 50-457 License Nos. NPF-72; NPF-77


===Enclosure:===
===Enclosure:===
IR 05000456/2014502; 05000457/2014502  
IR 05000456/2014502; 05000457/2014502 w/Attachment: Supplemental Information


===w/Attachment:===
REGION III==
Supplemental Information cc w/encl: Distribution via LISTSERV Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION III Docket No: 50-456; 50-457 License No: NPF-72; NPF-77 Report No: 05000456/2014502; 05000457/2014502 Licensee: Exelon Generation Company, LLC Facility: Braidwood Station, Units 1 and 2 Location: Braceville, IL Dates: November 17 through 21, 2014 Inspectors: R. Jickling, Senior Emergency Preparedness Inspector J. Benjamin, Senior Resident Inspector J. McGhee, Senior Resident Inspector J. Beavers, Emergency Preparedness Inspector D. Funk, Senior Project Specialist Approved by: S. Orth, Chief Plant Support Branch Division of Reactor Safety 2
Docket No: 50-456; 50-457 License No: NPF-72; NPF-77 Report No: 05000456/2014502; 05000457/2014502 Licensee: Exelon Generation Company, LLC Facility: Braidwood Station, Units 1 and 2 Location: Braceville, IL Dates: November 17 through 21, 2014 Inspectors: R. Jickling, Senior Emergency Preparedness Inspector J. Benjamin, Senior Resident Inspector J. McGhee, Senior Resident Inspector J. Beavers, Emergency Preparedness Inspector D. Funk, Senior Project Specialist Approved by: S. Orth, Chief Plant Support Branch Division of Reactor Safety Enclosure


=SUMMARY OF FINDINGS=
=SUMMARY OF FINDINGS=
IR 05000456/2014502, 05000457/2014502, 11/17/2014 - 11/21/2014, Braidwood Station, Units 1 and 2, Baseline Emergency Preparedness Exercise Evaluation - Hostile Action Event, Exercise Evaluation Scenario Review; Performance Indicator Verification. This report covers a 1-week period of announced baseline inspection by three regional inspectors and two resident inspectors. The significance of most findings is indicated by their color (i.e., Green, White, Yellow, and Red) using Inspection Manual Chapter 0609, "Significance Determination Process (SDP)."  Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 5, dated February 2014.
IR 05000456/2014502, 05000457/2014502, 11/17/2014 - 11/21/2014, Braidwood Station, Units and 2, Baseline Emergency Preparedness Exercise Evaluation - Hostile Action Event,
Exercise Evaluation Scenario Review; Performance Indicator Verification.


===A. NRC-Identified===
This report covers a 1-week period of announced baseline inspection by three regional inspectors and two resident inspectors. The significance of most findings is indicated by their color (i.e., Green, White, Yellow, and Red) using Inspection Manual Chapter 0609, Significance Determination Process (SDP). Findings for which the SDP 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 5, dated February 2014.
and Self-Revealed Findings


===Cornerstone: Emergency Preparedness No findings were identified.
===NRC-Identified===
and Self-Revealed Findings


===B. Licensee-Identified Violations===
===Cornerstone: Emergency Preparedness===
None===


3
No findings were identified.
 
===Licensee-Identified Violations===
 
None


=REPORT DETAILS=
=REPORT DETAILS=
Line 54: Line 64:
==REACTOR SAFETY==
==REACTOR SAFETY==


===Cornerstone:===
===Cornerstone: Emergency Preparedness===
Emergency Preparedness
{{a|1EP7}}
{{a|1EP7}}
==1EP7 Exercise Evaluation - Hostile Action Event==
==1EP7 Exercise Evaluation - Hostile Action Event==
Line 62: Line 71:


====a. Inspection Scope====
====a. Inspection Scope====
Title 10, Code of Federal Regulations (CFR), Part 50, Appendix E, Section IV.F.2.j, requires, in part, that nuclear power reactor licensees, in each eight calendar year exercise cycle, provide the opportunity for their Emergency Response Organization (ERO) to demonstrate proficiency in the key skills necessary to respond to a Hostile Action (HA) event directed at the plant site. Braidwood Station designed the November 19, 2014, exercise to satisfy this requirement, and the NRC inspected the Braidwood Station HA event exercise to assess the licensee's ability to effectively implement their Emergency Plan during a HA event and adequately protect public health and safety. The exercise evaluation consisted of the following reviews and assessments:  The adequacy of the licensee's performance in the biennial exercise conducted on November 19, 2014, regarding the implementation of the Risk-Significant Planning Standards in 10 CFR 50.47 (b)(4), (5), (9), and (10), which address emergency classification, offsite notification, radiological assessment, and Protective Action Recommendations (PAR), respectively. The overall adequacy of the licensee's emergency response facilities with regard to NUREG-0696, "Functional Criteria for Emergency Response Facilities," and Emergency Plan commitments. The facilities assessed were the Control Room Simulator, Alternative Emergency Response Facility, Incident Command Post, Simulated Central Alarm Station, and the Emergency Operations Facility. A review of other performance areas such as the licensee ERO's recognition of abnormal plant conditions; command and control, including interactions with site security staff; intra and inter-facility communications; prioritization of mitigating activities; utilization of repair and field monitoring teams; interface with offsite agencies, including local law enforcement agencies; staffing and procedure adequacy; and the overall implementation of the Emergency Plan and its implementing procedures. Past performance issues from NRC inspection reports to determine the effectiveness of corrective actions, as demonstrated during this exercise, to ensure compliance with 10 CFR 50.47(b)(14).
Title 10, Code of Federal Regulations (CFR), Part 50, Appendix E, Section IV.F.2.j, requires, in part, that nuclear power reactor licensees, in each eight calendar year exercise cycle, provide the opportunity for their Emergency Response Organization (ERO) to demonstrate proficiency in the key skills necessary to respond to a Hostile Action (HA) event directed at the plant site. Braidwood Station designed the November 19, 2014, exercise to satisfy this requirement, and the NRC inspected the Braidwood Station HA event exercise to assess the licensees ability to effectively implement their Emergency Plan during a HA event and adequately protect public health and safety.


The adequacy of the licensee's post-exercise critiques, to evaluate Braidwood Station's self-assessment of its ERO performance during the November 19, 2014, exercise and to ensure compliance with 10 CFR Part 50, Appendix E, Section IV.F.2.g. The inspectors reviewed various documents that are listed in the Attachment to this report. This inspection activity satisfied one inspection sample for the exercise evaluation on a biennial basis.
The exercise evaluation consisted of the following reviews and assessments:
* The adequacy of the licensees performance in the biennial exercise conducted on November 19, 2014, regarding the implementation of the Risk-Significant Planning Standards in 10 CFR 50.47 (b)(4), (5), (9), and (10), which address emergency classification, offsite notification, radiological assessment, and Protective Action Recommendations (PAR), respectively.
* The overall adequacy of the licensees emergency response facilities with regard to NUREG-0696, Functional Criteria for Emergency Response Facilities, and Emergency Plan commitments. The facilities assessed were the Control Room Simulator, Alternative Emergency Response Facility, Incident Command Post, Simulated Central Alarm Station, and the Emergency Operations Facility.
* A review of other performance areas such as the licensee EROs recognition of abnormal plant conditions; command and control, including interactions with site security staff; intra and inter-facility communications; prioritization of mitigating activities; utilization of repair and field monitoring teams; interface with offsite agencies, including local law enforcement agencies; staffing and procedure adequacy; and the overall implementation of the Emergency Plan and its implementing procedures.
* Past performance issues from NRC inspection reports to determine the effectiveness of corrective actions, as demonstrated during this exercise, to ensure compliance with 10 CFR 50.47(b)(14).
* The adequacy of the licensees post-exercise critiques, to evaluate Braidwood Stations self-assessment of its ERO performance during the November 19, 2014, exercise and to ensure compliance with 10 CFR Part 50, Appendix E, Section IV.F.2.g.
 
The inspectors reviewed various documents that are listed in the Attachment to this report. This inspection activity satisfied one inspection sample for the exercise evaluation on a biennial basis.


This exercise evaluation inspection constituted one sample as defined in Inspection Procedure (IP) 71114.07-06.
This exercise evaluation inspection constituted one sample as defined in Inspection Procedure (IP) 71114.07-06.


====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified. {{a|1EP8}}
{{a|1EP8}}
==1EP8 Exercise Evaluation - Scenario Review==
==1EP8 Exercise Evaluation - Scenario Review==
{{IP sample|IP=IP 71114.08}}
{{IP sample|IP=IP 71114.08}}


====a. Inspection Scope====
====a. Inspection Scope====
Prior to the inspection activity, the inspectors conducted an in-office review of the exercise objectives and scenarios submitted to the NRC using IP 71114.08, "Exercise Evaluation - Scenario Review," to determine if the exercise would test major elements of the Emergency Plan as required by 10 CFR 50.47(b)(14). This inspection activity represents one sample on a biennial cycle. The inspectors reviewed various documents that are listed in the Attachment to this report. This inspection activity satisfied one inspection sample for the exercise evaluation on a biennial basis. This review of the exercise objectives and scenario constituted one sample as defined in IP 71114.08-06.
Prior to the inspection activity, the inspectors conducted an in-office review of the exercise objectives and scenarios submitted to the NRC using IP 71114.08, Exercise Evaluation - Scenario Review, to determine if the exercise would test major elements of the Emergency Plan as required by 10 CFR 50.47(b)(14). This inspection activity represents one sample on a biennial cycle.
 
The inspectors reviewed various documents that are listed in the Attachment to this report. This inspection activity satisfied one inspection sample for the exercise evaluation on a biennial basis.
 
This review of the exercise objectives and scenario constituted one sample as defined in IP 71114.08-06.


====b. Findings====
====b. Findings====
Line 82: Line 101:
==OTHER ACTIVITIES==
==OTHER ACTIVITIES==


===Cornerstone:===
===Cornerstone: Emergency Preparedness===
Emergency Preparedness
{{a|4OA1}}
{{a|4OA1}}
==4OA1 Performance Indicator Verification==
==4OA1 Performance Indicator Verification==
Line 90: Line 108:


====a. Inspection Scope====
====a. Inspection Scope====
The inspectors sampled licensee submittals for the Drill/Exercise Performance (DEP) Performance Indicator (PI) for the period from the first quarter 2013 through the third quarter 2014. To determine the accuracy of the DEP data reported during those periods, PI definitions and guidance contained in the Nuclear Energy Institute (NEI) document NEI 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, was used. The inspectors reviewed the licensee's records associated with 5 the PI to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the NEI guidance. Specifically, the inspectors reviewed licensee records and processes, including procedural guidance on assessing opportunities for the PI, assessments of PI opportunities during pre-designated control room simulator training sessions, and performance during other drills. Documents reviewed are listed in the Attachment to this report. This inspection constituted one DEP sample as defined in IP 71151-05.
The inspectors sampled licensee submittals for the Drill/Exercise Performance (DEP)
Performance Indicator (PI) for the period from the first quarter 2013 through the third quarter 2014. To determine the accuracy of the DEP data reported during those periods, PI definitions and guidance contained in the Nuclear Energy Institute (NEI)document NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, was used. The inspectors reviewed the licensees records associated with the PI to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the NEI guidance. Specifically, the inspectors reviewed licensee records and processes, including procedural guidance on assessing opportunities for the PI, assessments of PI opportunities during pre-designated control room simulator training sessions, and performance during other drills. Documents reviewed are listed in the Attachment to this report.
 
This inspection constituted one DEP sample as defined in IP 71151-05.


====b. Findings====
====b. Findings====
Line 98: Line 119:


====a. Inspection Scope====
====a. Inspection Scope====
The inspectors sampled licensee submittals for the ERO Drill Participation PI for the period from the first quarter 2013 through the third quarter 2014. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in NEI 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, was used. The inspectors reviewed the licensee's records associated with the PI to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the NEI guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the PI, performance during the 2013 and 2014 drills, and revisions of the roster of personnel assigned to key ERO positions. Documents reviewed are listed in the Attachment to this report.
The inspectors sampled licensee submittals for the ERO Drill Participation PI for the period from the first quarter 2013 through the third quarter 2014. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, was used. The inspectors reviewed the licensees records associated with the PI to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the NEI guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the PI, performance during the 2013 and 2014 drills, and revisions of the roster of personnel assigned to key ERO positions. Documents reviewed are listed in the Attachment to this report.


This inspection constituted one ERO Drill Participation sample as defined in IP 71151-05.
This inspection constituted one ERO Drill Participation sample as defined in IP 71151-05.
Line 108: Line 129:


====a. Inspection Scope====
====a. Inspection Scope====
The inspectors sampled licensee submittals for the Alert and Notification System (ANS) PI for the period from the first quarter 2013 through the third quarter 2014. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in NEI 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, was used. The inspectors reviewed the licensee's records associated with the PI to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the NEI guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the PI and results of periodic scheduled ANS operability tests. Documents reviewed are listed in the Attachment to this report.
The inspectors sampled licensee submittals for the Alert and Notification System (ANS)
PI for the period from the first quarter 2013 through the third quarter 2014. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, was used. The inspectors reviewed the licensees records associated with the PI to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the NEI guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the PI and results of periodic scheduled ANS operability tests.
 
Documents reviewed are listed in the Attachment to this report.


This inspection constituted one ANS sample as defined in IP 71151-05.
This inspection constituted one ANS sample as defined in IP 71151-05.
6


====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified.
{{a|4OA6}}
{{a|4OA6}}
==4OA6 Management Meetings==
==4OA6 Management Meetings==


===.1 Exit Meeting Summary On November 21, 2014, the inspectors presented the biennial exercise inspection results to Mr. M. Kanavos and other members of the licensee's staff.===
===.1 Exit Meeting Summary===
The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary. ATTACHMENT:
 
On November 21, 2014, the inspectors presented the biennial exercise inspection results to Mr. M. Kanavos and other members of the licensees staff. The licensee acknowledged the issues presented.
 
The inspectors confirmed that none of the potential report input discussed was considered proprietary.
 
ATTACHMENT:  


=SUPPLEMENTAL INFORMATION=
=SUPPLEMENTAL INFORMATION=


==KEY POINTS OF CONTACT==
==KEY POINTS OF CONTACT==
Licensee  
 
: [[contact::M. Kanavos]], Site Vice President  
Licensee
: [[contact::M. Marchionda]], Plant Manager  
: [[contact::M. Kanavos]], Site Vice President
: [[contact::J. Bashor]], Engineering Manager  
: [[contact::M. Marchionda]], Plant Manager
: [[contact::B. Bergman]], Outage Manager  
: [[contact::J. Bashor]], Engineering Manager
: [[contact::J. Cady]], Radiation Protection Manager  
: [[contact::B. Bergman]], Outage Manager
: [[contact::A. Daniels]], MidWest Emergency Preparedness Manager  
: [[contact::J. Cady]], Radiation Protection Manager
: [[contact::T. Elam]], Projects  
: [[contact::A. Daniels]], MidWest Emergency Preparedness Manager
: [[contact::A. Ferko]], Operations Manager  
: [[contact::T. Elam]], Projects
: [[contact::T. Fisk]], Nuclear Oversight  
: [[contact::A. Ferko]], Operations Manager
: [[contact::T. Gardner]], Nuclear Oversight Assessor  
: [[contact::T. Fisk]], Nuclear Oversight
: [[contact::C. Ingold]], Site Chemical Environment & Radwaste Manager  
: [[contact::T. Gardner]], Nuclear Oversight Assessor
: [[contact::J. Lizalek]], Security  
: [[contact::C. Ingold]], Site Chemical Environment & Radwaste Manager
: [[contact::S. McKinney]], Emergency Preparedness Coordinator  
: [[contact::J. Lizalek]], Security
: [[contact::D. Poi]], Emergency Preparedness Manager  
: [[contact::S. McKinney]], Emergency Preparedness Coordinator
: [[contact::P. Raush]], Regulatory Assurance Manager  
: [[contact::D. Poi]], Emergency Preparedness Manager
: [[contact::R. Schlessmann]], Regulatory Assurance  
: [[contact::P. Raush]], Regulatory Assurance Manager
: [[contact::B. Sparr]], Maintenance Director  
: [[contact::R. Schlessmann]], Regulatory Assurance
: [[contact::D. Stiles]], Site Training Director Nuclear Regulatory Commission  
: [[contact::B. Sparr]], Maintenance Director
: [[contact::J. Benjamin]], Senior Resident Inspector  
: [[contact::D. Stiles]], Site Training Director
: [[contact::B. Boston]], Acting Resident Inspector  
Nuclear Regulatory Commission
: [[contact::J. Benjamin]], Senior Resident Inspector
: [[contact::B. Boston]], Acting Resident Inspector
 
==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==
==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==


===Opened, Closed, and Discussed===
===Opened, Closed, and Discussed===
None
 
None


==LIST OF DOCUMENTS REVIEWED==
==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 inspectors 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.
: 1EP7 Exercise Evaluation (71114.07)
: EP-AA-1000; Exelon Nuclear Standardized Radiological Emergency Plan; Revision 25
: EP-AA-1001; Radiological Emergency Plan Annex for Braidwood Station; Revision 32
: EP-AA-110; Assessment of Emergencies; Revision 9
: EP-AA-111; Emergency Classification and PARs; Revision 18
: EP-AA-112; ERO/ERF Activation and Operation; Revision 16
: EP-AA-113; Personnel Protective Action; Revision 11
: EP-AA-114-100; Midwest Region Offsite Notifications; Revision 14
: EP-AA-122; Drills and Exercise Program; Revision 15 0Bw0A; Security Threat; Revision 17 Two Year List of Drill and Exercise Corrective Action Program Issues; December 5, 2012 - August 29, 2014 Two Years of Drill and Exercise Timelines; December 5, 2012 - August 27, 2014
: IR 2416846.2; Exercise-Alternate ERF Confusion Regarding Multiple Priority Ones; November 24, 2014
: IR 2416846.4; Exercise-Alternative ERF Determined Cell Phone Communications With Mitigation Teams Was Not Adequate In the Plant; November 24, 2014
: IR 2416839; Exercise-Alternative ERF Mitigation Team Movement On-Site Did Not Adhere to Restrictions; November 24, 2014
: IR 2415811; Exercise-Over-Simulation Contributed to Confusion With Mitigation Team Status Communications; November 21, 2014
: IR 2415803; Exercise-Mitigative Action Planning at the ICP and Alternative ERF Needs to be Improved and Alternative ERF Communications With ICP and Mitigation Teams Needs to be Improved; November 21, 2014
: IR 2415733.1; Exercise-EOF Failed to Notify the NRC Within One Hour of the Emergency Classification; November 21, 2014
: IR 2415733.2; Exercise-EOF Significant Events Log Lacked Information and Contained Errors; November 21, 2014
: IR 2415733.3; Exercise-EOF Top Priorities Not Established But Had Three Priority Ones; November 21, 2014 
: 1EP8 Exercise Evaluation - Scenario Review (71114.08) Braidwood Station 2014 HAB Exercise 60 Day Submittal; September 15, 2014 4OA1 Performance Indicator Verification (71151)
: LS-AA-2110; Monthly Data Elements for NRC ERO Drill Participation; January 2013 - September 2014
: LS-AA-2120; Monthly Data Elements for NRC Drill/Exercise Performance; March 2013 - September 2014
: LS-AA-2130; Monthly Data Elements for NRC ANS Reliability; January 2013 - September 2014
: AR 01678496; Siren Failure; July 3, 2014
: AR 01678295; Siren Failures; July 2, 2014
: AR 01677436; Siren Outage; July 1, 2014
==LIST OF ACRONYMS==
: [[USED]] [[]]
: [[ADAMS]] [[Agencywide Documents Access and Management System]]
: [[ANS]] [[Alert and Notification System]]
: [[CFR]] [[Code of Federal Regulations]]
: [[DEP]] [[Drill and Exercise Performance]]
: [[DRS]] [[Division of Reactor Safety]]
: [[ERO]] [[Emergency Response Organization]]
: [[HA]] [[Hostile Action]]
: [[IP]] [[Inspection Procedure]]
: [[NEI]] [[Nuclear Energy Institute]]
: [[NRC]] [[U.S. Nuclear Regulatory Commission]]
: [[PAR]] [[Protective Action Recommendation]]
: [[PARS]] [[Publicly Available Records System]]
PI Performance Indicator SDP Significance Determination Process
Mr. Michael
: [[J.]] [[Pacilio Senior]]
: [[VP]] [[, Exelon Generation Co.,]]
: [[LLC]] [[President and]]
: [[CNO]] [[, Exelon Nuclear 4300 Winfield Road Warrenville,]]
: [[IL]] [[60555]]
: [[SUBJEC]] [[T:  BRAIDWOOD STATION,]]
: [[UNITS]] [[1]]
: [[AND]] [[2, BASELINE EMERGENCY PREPAREDNESS BIENNIAL EXERCISE INSPECTION]]
: [[REPORT]] [[05000456/2014502; 05000457/2014502  Dear Mr. Pacilio: On November 21, 2014, the U.S. Nuclear Regulatory Commission (]]
: [[NRC]] [[) completed an inspection at your Braidwood Station, Units 1 and 2. The enclosed report documents the results of this inspection which were discussed on November 21, 2014, with Mr.]]
: [[M.]] [[Kanavos and other members of your staff. The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. No findings were identified during this inspection. In accordance with Title 10, Code of Federal Regulations (]]
: [[CFR]] [[), Section 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]] [[/  Steven]]
: [[K.]] [[Orth, Chief Plant Support Branch Division of Reactor Safety Docket Nos. 50-456; 50-457 License Nos.]]
: [[NPF]] [[-72; NPF-77 Enclosure:]]
: [[IR]] [[05000456/2014502; 05000457/2014502  w/Attachment:  Supplemental Information cc w/encl:  Distribution via]]
: [[LISTSE]] [[RV    DOCUMENT NAME:]]
: [[BRA]] [[2014 502 (]]
: [[RDJ]] [[).docx  Publicly Available  Non-Publicly Available  Sensitive  Non-Sensitive To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy]]
: [[OFFICE]] [[]]
: [[RIII]] [[]]
: [[RIII]] [[]]
: [[RIII]] [[]]
: [[RIII]] [[]]
: [[NAME]] [[RJickling:ls DFunk SOrth]]
: [[DATE]] [[12/17/14 12/18/14 12/18/14]]
: [[OFFICI]] [[AL]]
: [[RECORD]] [[]]
: [[COPY]] [[Letter to Michael]]
: [[J.]] [[Pacilio from Steven K. Orth dated December 18, 2014.]]
: [[SUBJEC]] [[T: BRAIDWOOD STATION,]]
: [[UNITS]] [[1]]
: [[AND]] [[2,]]
: [[UNITS]] [[1]]
: [[AND]] [[2  BASELINE EMERGENCY PREPAREDNESS BIENNIAL EXERCISE INSPECTION REPORT 05000456/2014502; 05000457/2014502]]
}}
}}

Latest revision as of 07:56, 20 December 2019

IR 05000456/2014502, 05000457/2014502, on 11/17/2014 - 11/21/2014, Braidwood Station, Units 1 and 2, Baseline Emergency Preparedness Exercise Evaluation - Hostile Action Event, Exercise Evaluation Scenario Review; Performance Indicator Veri
ML14356A134
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 12/18/2014
From: Steven Orth
Plant Support Branch II
To: Pacilio M
Exelon Generation Co, Exelon Nuclear
Robert Jickling
References
IR 2014502
Download: ML14356A134 (13)
v • d • e


Text

UNITED STATES mber 18, 2014

SUBJECT:

BRAIDWOOD STATION, UNITS 1 AND 2, BASELINE EMERGENCY PREPAREDNESS BIENNIAL EXERCISE INSPECTION REPORT 05000456/2014502; 05000457/2014502

Dear Mr. Pacilio:

On November 21, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Braidwood Station, Units 1 and 2. The enclosed report documents the results of this inspection which were discussed on November 21, 2014, with Mr. M. Kanavos 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. No findings were identified during this inspection.

In accordance with Title 10, Code of Federal Regulations (CFR), Section 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/

Steven K. Orth, Chief Plant Support Branch Division of Reactor Safety Docket Nos. 50-456; 50-457 License Nos. NPF-72; NPF-77

Enclosure:

IR 05000456/2014502; 05000457/2014502 w/Attachment: Supplemental Information

REGION III==

Docket No: 50-456; 50-457 License No: NPF-72; NPF-77 Report No: 05000456/2014502; 05000457/2014502 Licensee: Exelon Generation Company, LLC Facility: Braidwood Station, Units 1 and 2 Location: Braceville, IL Dates: November 17 through 21, 2014 Inspectors: R. Jickling, Senior Emergency Preparedness Inspector J. Benjamin, Senior Resident Inspector J. McGhee, Senior Resident Inspector J. Beavers, Emergency Preparedness Inspector D. Funk, Senior Project Specialist Approved by: S. Orth, Chief Plant Support Branch Division of Reactor Safety Enclosure

SUMMARY OF FINDINGS

IR 05000456/2014502, 05000457/2014502, 11/17/2014 - 11/21/2014, Braidwood Station, Units and 2, Baseline Emergency Preparedness Exercise Evaluation - Hostile Action Event,

Exercise Evaluation Scenario Review; Performance Indicator Verification.

This report covers a 1-week period of announced baseline inspection by three regional inspectors and two resident inspectors. The significance of most findings is indicated by their color (i.e., Green, White, Yellow, and Red) using Inspection Manual Chapter 0609, Significance Determination Process (SDP). Findings for which the SDP 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 5, dated February 2014.

NRC-Identified

and Self-Revealed Findings

Cornerstone: Emergency Preparedness

No findings were identified.

Licensee-Identified Violations

None

REPORT DETAILS

REACTOR SAFETY

Cornerstone: Emergency Preparedness

1EP7 Exercise Evaluation - Hostile Action Event

Main article: IP 71114.07

.1 Exercise Evaluation

a. Inspection Scope

Title 10, Code of Federal Regulations (CFR), Part 50, Appendix E,Section IV.F.2.j, requires, in part, that nuclear power reactor licensees, in each eight calendar year exercise cycle, provide the opportunity for their Emergency Response Organization (ERO) to demonstrate proficiency in the key skills necessary to respond to a Hostile Action (HA) event directed at the plant site. Braidwood Station designed the November 19, 2014, exercise to satisfy this requirement, and the NRC inspected the Braidwood Station HA event exercise to assess the licensees ability to effectively implement their Emergency Plan during a HA event and adequately protect public health and safety.

The exercise evaluation consisted of the following reviews and assessments:

  • The adequacy of the licensees performance in the biennial exercise conducted on November 19, 2014, regarding the implementation of the Risk-Significant Planning Standards in 10 CFR 50.47 (b)(4), (5), (9), and (10), which address emergency classification, offsite notification, radiological assessment, and Protective Action Recommendations (PAR), respectively.
  • The overall adequacy of the licensees emergency response facilities with regard to NUREG-0696, Functional Criteria for Emergency Response Facilities, and Emergency Plan commitments. The facilities assessed were the Control Room Simulator, Alternative Emergency Response Facility, Incident Command Post, Simulated Central Alarm Station, and the Emergency Operations Facility.
  • A review of other performance areas such as the licensee EROs recognition of abnormal plant conditions; command and control, including interactions with site security staff; intra and inter-facility communications; prioritization of mitigating activities; utilization of repair and field monitoring teams; interface with offsite agencies, including local law enforcement agencies; staffing and procedure adequacy; and the overall implementation of the Emergency Plan and its implementing procedures.
  • Past performance issues from NRC inspection reports to determine the effectiveness of corrective actions, as demonstrated during this exercise, to ensure compliance with 10 CFR 50.47(b)(14).
  • The adequacy of the licensees post-exercise critiques, to evaluate Braidwood Stations self-assessment of its ERO performance during the November 19, 2014, exercise and to ensure compliance with 10 CFR Part 50, Appendix E, Section IV.F.2.g.

The inspectors reviewed various documents that are listed in the Attachment to this report. This inspection activity satisfied one inspection sample for the exercise evaluation on a biennial basis.

This exercise evaluation inspection constituted one sample as defined in Inspection Procedure (IP) 71114.07-06.

b. Findings

No findings were identified.

1EP8 Exercise Evaluation - Scenario Review

Main article: IP 71114.08

a. Inspection Scope

Prior to the inspection activity, the inspectors conducted an in-office review of the exercise objectives and scenarios submitted to the NRC using IP 71114.08, Exercise Evaluation - Scenario Review, to determine if the exercise would test major elements of the Emergency Plan as required by 10 CFR 50.47(b)(14). This inspection activity represents one sample on a biennial cycle.

The inspectors reviewed various documents that are listed in the Attachment to this report. This inspection activity satisfied one inspection sample for the exercise evaluation on a biennial basis.

This review of the exercise objectives and scenario constituted one sample as defined in IP 71114.08-06.

b. Findings

No findings were identified.

OTHER ACTIVITIES

Cornerstone: Emergency Preparedness

4OA1 Performance Indicator Verification

Main article: IP 71151

.1 Drill/Exercise Performance

a. Inspection Scope

The inspectors sampled licensee submittals for the Drill/Exercise Performance (DEP)

Performance Indicator (PI) for the period from the first quarter 2013 through the third quarter 2014. To determine the accuracy of the DEP data reported during those periods, PI definitions and guidance contained in the Nuclear Energy Institute (NEI)document NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, was used. The inspectors reviewed the licensees records associated with the PI to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the NEI guidance. Specifically, the inspectors reviewed licensee records and processes, including procedural guidance on assessing opportunities for the PI, assessments of PI opportunities during pre-designated control room simulator training sessions, and performance during other drills. Documents reviewed are listed in the Attachment to this report.

This inspection constituted one DEP sample as defined in IP 71151-05.

b. Findings

No findings were identified.

.2 Emergency Response Organization Drill Participation

a. Inspection Scope

The inspectors sampled licensee submittals for the ERO Drill Participation PI for the period from the first quarter 2013 through the third quarter 2014. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, was used. The inspectors reviewed the licensees records associated with the PI to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the NEI guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the PI, performance during the 2013 and 2014 drills, and revisions of the roster of personnel assigned to key ERO positions. Documents reviewed are listed in the Attachment to this report.

This inspection constituted one ERO Drill Participation sample as defined in IP 71151-05.

b. Findings

No findings were identified.

.3 Alert and Notification System

a. Inspection Scope

The inspectors sampled licensee submittals for the Alert and Notification System (ANS)

PI for the period from the first quarter 2013 through the third quarter 2014. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, was used. The inspectors reviewed the licensees records associated with the PI to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the NEI guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the PI and results of periodic scheduled ANS operability tests.

Documents reviewed are listed in the Attachment to this report.

This inspection constituted one ANS sample as defined in IP 71151-05.

b. Findings

No findings were identified.

4OA6 Management Meetings

.1 Exit Meeting Summary

On November 21, 2014, the inspectors presented the biennial exercise inspection results to Mr. M. Kanavos and other members of the licensees staff. The licensee acknowledged the issues presented.

The inspectors confirmed that none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

M. Kanavos, Site Vice President
M. Marchionda, Plant Manager
J. Bashor, Engineering Manager
B. Bergman, Outage Manager
J. Cady, Radiation Protection Manager
A. Daniels, MidWest Emergency Preparedness Manager
T. Elam, Projects
A. Ferko, Operations Manager
T. Fisk, Nuclear Oversight
T. Gardner, Nuclear Oversight Assessor
C. Ingold, Site Chemical Environment & Radwaste Manager
J. Lizalek, Security
S. McKinney, Emergency Preparedness Coordinator
D. Poi, Emergency Preparedness Manager
P. Raush, Regulatory Assurance Manager
R. Schlessmann, Regulatory Assurance
B. Sparr, Maintenance Director
D. Stiles, Site Training Director

Nuclear Regulatory Commission

J. Benjamin, Senior Resident Inspector
B. Boston, Acting Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened, Closed, and Discussed

None

LIST OF DOCUMENTS REVIEWED

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