IR 05000395/2011501: Difference between revisions
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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. | 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. | ||
Based on the results of this inspection, no findings of significance were identified. 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 (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). | Based on the results of this inspection, no findings of significance were identified. | ||
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 (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). | |||
Sincerely,/RA/ | Sincerely,/RA/ | ||
| Line 39: | Line 41: | ||
===w/Attachment:=== | ===w/Attachment:=== | ||
Supplemental Information cc w/encl.: (See page 2) | Supplemental Information | ||
cc w/encl.: (See page 2) | |||
ML11314A247 X SUNSI REVIEW COMPLETE X FORM 665 ATTACHED OFFICE RII: DRS/PSB1 RII:DRS/PSB1 RII: DRS/PSB1 RII: DRP/BR5B RIV: DRS/PSB1 RII: DRP/5B SIGNATURE RA/MS RA/MS For WL RA/BB RA VIA EMAIL RA/VIA EMAIL RA/VIA EMAIL NAME M. SPECK W.LOO B. BONSER S. WALKER P. ELKMANN J. REECE DATE 11/09/2011 11/09/2011 11/10/2011 11/09/2011 11/09/2011 11/08/2011 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO SCE&G 2 cc w/encl: J. B. Archie Senior Vice President Nuclear Operations and Chief Nuclear Officer South Carolina Electric & Gas Company Electronic Mail Distribution George A. Lippard, III General Manager Nuclear Plant Operations South Carolina Electric & Gas Company Electronic Mail Distribution Andy T. Barbee Director Nuclear Training South Carolina Electric & Gas Company Electronic Mail Distribution Robert M. Fowlkes General Manager Engineering Services South Carolina Electric & Gas Company Electronic Mail Distribution Robin R. Haselden General Manager Organizational Development & Effectiveness South Carolina Electric & Gas Company Electronic Mail Distribution | |||
Shaun M. Zarandi General Manager Nuclear Support Services South Carolina Electric & Gas Company Electronic Mail Distribution Robert L. Justice Manager Nuclear Operations South Carolina Electric & Gas Company Electronic Mail Distribution | |||
Bruce L. Thompson Manager Nuclear Licensing (Mail Code 830) South Carolina Electric & Gas Company Electronic Mail Distribution Donna W. Railey Licensing Technician Nuclear Licensing South Carolina Electric & Gas Company Electronic Mail Distribution | |||
Robin J. White Nuclear Coordinator S.C. Public Service Authority Mail Code 802 Electronic Mail Distribution | |||
Sandra Threatt, Manager Nuclear Response and Emergency Environmental Surveillance Bureau of Land and Waste Management Department of Health and Environmental Control Electronic Mail Distribution Kathryn M. Sutton, Esq. Morgan, Lewis & Bockius LLP Electronic Mail Distribution | |||
Division of Radiological Health TN Dept. of Environment & Conservation 401 Church Street Nashville, TN 37243-1532 | |||
Richard Haynes Director, Division of Waste Management Bureau of Land and Waste Management S.C. Department of Health and Environmental Control Electronic Mail Distribution Mark Yeager Division of Radioactive Waste Mgmt. | |||
S.C. Department of Health and Environmental Control Electronic Mail Distribution Senior Resident Inspector Virgil C. Summer Nuclear Station U.S. NRC 576 Stairway Road Jenkinsville, SC 29065 | |||
Enclosure U. S. NUCLEAR REGULATORY COMMISSION REGION II | |||
Docket Nos.: 05000395 | |||
License Nos.: NPF-12 | |||
Report No.: 05000395/2011501 | |||
Licensee: South Carolina Gas and Electric | |||
Facility: Virgil C. Summer Nuclear Station, Unit 1 | |||
Location: Jenkinsville, SC | |||
Dates: September 26 - 30, 2011 | |||
Inspectors: M. Speck, Senior Emergency Preparedness Inspector P. Elkmann, Senior Emergency Preparedness Inspector J. Reece, Senior Resident Inspector W. Loo, Senior Health Physics Inspector | |||
Approved by: Brian Bonser, Chief Plant Support Branch 1 Division of Reactor Safety Enclosure | |||
=SUMMARY OF FINDINGS= | =SUMMARY OF FINDINGS= | ||
| Line 50: | Line 89: | ||
===Cornerstone: Emergency Preparedness=== | ===Cornerstone: Emergency Preparedness=== | ||
No findings were identified. | No findings were identified. | ||
| Line 60: | Line 100: | ||
===Cornerstone:=== | ===Cornerstone:=== | ||
Emergency Preparedness | Emergency Preparedness 1EP1 Exercise Evaluation | ||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
Prior to the inspection activity, the inspectors conducted an in-office review of the exercise objectives and scenario submitted to the NRC 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 onsite inspection consisted of the following review and assessment: $ The adequacy of the licensee's performance in the biennial exercise conducted on September 28, 2011, was reviewed and assessed regarding the implementation of the Risk Significant Planning Standards (RSPS) in 10 CFR 50.47 (b)(4), (5), (9), and (10), which address emergency classification, offsite notification, radiological assessment, and protective action recommendations 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, Operations Support Center (OSC), Technical Support Center (TSC), and Emergency Operations Facility (EOF). $ Other performance areas besides the RSPS, such as the emergency response organization's (ERO) recognition of abnormal plant conditions, command and control, intra- and inter-facility communications, prioritization of mitigation activities, utilization of repair and field monitoring teams, interface with offsite agencies, and the overall implementation of the emergency plan and its implementing procedures. $ Past performance issues from NRC inspection reports and Federal Emergency Management Agency (FEMA)/Department of Homeland Security (DHS) exercise reports to determine effectiveness of corrective actions as demonstrated during this exercise to ensure compliance with 10 CFR 50.47(b)(14). $ The post-exercise critique process and the presentation to the licensee's senior management conducted on September 30, 2011, to evaluate the licensee's self-assessment of its ERO performance during the exercise and to ensure compliance with 10 CFR 50 Appendix E.IV.F.2.g. The inspectors reviewed various documents which are listed in the Attachment. | Prior to the inspection activity, the inspectors conducted an in-office review of the exercise objectives and scenario submitted to the NRC 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 onsite inspection consisted of the following review and assessment: | |||
$ The adequacy of the licensee's performance in the biennial exercise conducted on September 28, 2011, was reviewed and assessed regarding the implementation of the Risk Significant Planning Standards (RSPS) in 10 CFR 50.47 (b)(4), (5), (9), and (10), which address emergency classification, offsite notification, radiological assessment, and protective action recommendations 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, Operations Support Center (OSC), Technical Support Center (TSC), and Emergency Operations Facility (EOF). | |||
$ Other performance areas besides the RSPS, such as the emergency response organization's (ERO) recognition of abnormal plant conditions, command and control, intra- and inter-facility communications, prioritization of mitigation activities, utilization of repair and field monitoring teams, interface with offsite agencies, and the overall implementation of the emergency plan and its implementing procedures. | |||
$ Past performance issues from NRC inspection reports and Federal Emergency Management Agency (FEMA)/Department of Homeland Security (DHS) exercise reports to determine effectiveness of corrective actions as demonstrated during this exercise to ensure compliance with 10 CFR 50.47(b)(14). | |||
$ The post-exercise critique process and the presentation to the licensee's senior management conducted on September 30, 2011, to evaluate the licensee's self-assessment of its ERO performance during the exercise and to ensure compliance with 10 CFR 50 Appendix E.IV.F.2.g. | |||
The inspectors reviewed various documents which are listed in the Attachment. | |||
====b. Findings==== | ====b. Findings==== | ||
=====Introduction:===== | =====Introduction:===== | ||
The team identified an unresolved item (URI) concerning the adequacy of training and procedures to assess and monitor a radiological release using field monitoring teams. | The team identified an unresolved item (URI) concerning the adequacy of training and procedures to assess and monitor a radiological release using field monitoring teams. | ||
=====Description:===== | =====Description:===== | ||
While reviewing procedures used during the biennial emergency preparedness exercise, inspectors questioned the adequacy of licensee procedure EPP-7, Environmental Monitoring, Rev. 11, used to direct deployment of field monitoring teams to effectively locate radioactive release plume boundaries. The licensee initiated corrective action CR-11-04977 to evaluate this issue. Inspectors concluded that further review of information related to the procedure's adequacy, and its interrelationship with other licensee radiological assessment procedures is necessary to determine if the issue constitutes a violation of regulatory requirements. This issue is identified as URI 05000395/2011501-01, "Adequacy of Procedures to Assess and Monitor Emergency Radiological Releases." | While reviewing procedures used during the biennial emergency preparedness exercise, inspectors questioned the adequacy of licensee procedure EPP-7, Environmental Monitoring, Rev. 11, used to direct deployment of field monitoring teams to effectively locate radioactive release plume boundaries. The licensee initiated corrective action CR-11-04977 to evaluate this issue. Inspectors concluded that further review of information related to the procedure's adequacy, and its interrelationship with other licensee radiological assessment procedures is necessary to determine if the issue constitutes a violation of regulatory requirements. This issue is identified as URI 05000395/2011501-01, "Adequacy of Procedures to Assess and Monitor Emergency Radiological Releases." | ||
1EP4 Emergency Action Level (EAL) and Emergency Plan Changes | |||
====a. Inspection Scope==== | ====a. Inspection Scope==== | ||
Since the last NRC inspection of this program area, Revision 59, of the VC Summer Emergency Plan was implemented based on the licensee's determination, in accordance with 10 CFR 50.54(q), that the changes resulted in no decrease in the effectiveness of the Plan, and that the revised Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. The inspector conducted a review of the Plan changes and a sampling review of the implementing procedure changes made between September 1, 2010, and September 1, 2011, to evaluate for potential decreases in effectiveness of the Plan. This review was not documented in a Safety Evaluation Report and does not constitute formal NRC approval of the changes. Therefore, these changes remain subject to future NRC inspection in their entirety. The inspection was conducted in accordance with NRC Inspection Procedure 71114, Attachment 04, "Emergency Action Level and Emergency Plan Changes". The applicable planning standard 10 CFR 50.47(b)(4) and related requirements contained in 10 CFR 50.54(q) and Appendix E to 10 CFR Part 50 were used as reference criteria. | Since the last NRC inspection of this program area, Revision 59, of the VC Summer Emergency Plan was implemented based on the licensee's determination, in accordance with 10 CFR 50.54(q), that the changes resulted in no decrease in the effectiveness of the Plan, and that the revised Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. The inspector conducted a review of the Plan changes and a sampling review of the implementing procedure changes made between September 1, 2010, and September 1, 2011, to evaluate for potential decreases in effectiveness of the Plan. This review was not documented in a Safety Evaluation Report and does not constitute formal NRC approval of the changes. Therefore, these changes remain subject to future NRC inspection in their entirety. | ||
The inspection was conducted in accordance with NRC Inspection Procedure 71114, Attachment 04, "Emergency Action Level and Emergency Plan Changes". The applicable planning standard 10 CFR 50.47(b)(4) and related requirements contained in 10 CFR 50.54(q) and Appendix E to 10 CFR Part 50 were used as reference criteria. | |||
This inspection activity represents one sample on an annual cycle. | |||
The inspector reviewed various documents which are listed in the Attachment. | |||
====b. Findings==== | ====b. Findings==== | ||
| Line 88: | Line 147: | ||
The inspectors sampled licensee submittals for the three performance indicators (PI) listed below. For each of the submittals, the inspectors reviewed the period from July 1, 2010, through June 30, 2011. To verify the accuracy of the PI data reported during that period, PI definitions and guidance contained in Nuclear Energy Institute (NEI) 99-02, Regulatory Assessment Indicator Guideline, Revision 6, were used to verify the basis in reporting for each data element. | The inspectors sampled licensee submittals for the three performance indicators (PI) listed below. For each of the submittals, the inspectors reviewed the period from July 1, 2010, through June 30, 2011. To verify the accuracy of the PI data reported during that period, PI definitions and guidance contained in Nuclear Energy Institute (NEI) 99-02, Regulatory Assessment Indicator Guideline, Revision 6, were used to verify the basis in reporting for each data element. | ||
$ Emergency Response Organization Drill/Exercise Performance (DEP) $ Emergency Response Organization Readiness (ERO) $ Alert and Notification System Reliability (ANS) | $ Emergency Response Organization Drill/Exercise Performance (DEP) | ||
$ Emergency Response Organization Readiness (ERO) | |||
$ Alert and Notification System Reliability (ANS) | |||
The inspectors reviewed portions of the raw PI data developed from monthly performance indicator reports, and discussed the methods for compiling and reporting the PIs with the responsible emergency preparedness personnel. The inspectors also independently screened drill and exercise opportunity evaluations, drill participation reports, and drill evaluations. Selected reported values were calculated to verify their accuracy. The inspectors compared graphical representations from the most recent PI report to the raw data to verify that the data was correctly reflected in the report. Reviewed documents are listed in the Attachment. | |||
The inspection was conducted in accordance with NRC Inspection Procedure 71151, "Performance Indicator Verification." This inspection activity represents three samples on an annual cycle. | |||
The inspectors reviewed various documents which are listed in the Attachment. | |||
====b. Findings==== | ====b. Findings==== | ||
No findings were identified. | No findings were identified. | ||
{{a|4OA6}} | {{a|4OA6}} | ||
==4OA6 Meetings, Including Exit== | ==4OA6 Meetings, Including Exit== | ||
On September 30, 2011, the lead inspector presented the inspection results to Mr. J. Archie and members of the onsite management staff. The inspectors confirmed that proprietary information was not provided or taken during the inspection. | On September 30, 2011, the lead inspector presented the inspection results to Mr. J. Archie and members of the onsite management staff. The inspectors confirmed that proprietary information was not provided or taken during the inspection. | ||
| Line 124: | Line 190: | ||
===Opened=== | ===Opened=== | ||
: 05000395/2011501-01 URI Adequacy of Procedures to Assess and Monitor Emergency Radiological Releases | : 05000395/2011501-01 URI Adequacy of Procedures to Assess and Monitor Emergency Radiological | ||
Attachment | Releases | ||
Attachment | |||
==LIST OF DOCUMENTS REVIEWED== | ==LIST OF DOCUMENTS REVIEWED== | ||
1EP1 Exercise Evaluation | 1EP1 Exercise Evaluation | ||
| Line 143: | Line 211: | ||
: EPP-105 Conduct of Drills and Exercises, Rev. 9 | : EPP-105 Conduct of Drills and Exercises, Rev. 9 | ||
: EPP-108.00 Emergency Action Level Technical Basis Document, Rev. 0 Management Directive 11, Shift Supervisor Duties and Responsibilities, Rev. 29 | : EPP-108.00 Emergency Action Level Technical Basis Document, Rev. 0 Management Directive 11, Shift Supervisor Duties and Responsibilities, Rev. 29 | ||
: SAP-0127, Emergency Preparedness, Rev. 2 | : SAP-0127, Emergency Preparedness, Rev. 2 | ||
: Records and Data | : Records and Data Control Room, Technical Support Center, Operations Support Center, Emergency Operations Facility, Joint Information Center - Documentation packages (logs, event notification forms), Protective Action Recommendations, Media releases, and Radiological Dose Assessment 2009 Graded Exercise drill package Drill reports: | ||
: 3/24/2010, 5/26/2010, 7/21/2010, 10/27/2010, 12/1/2010, 3/23/2011, 6/22/2011, and 8/31/2011 | : 3/24/2010, 5/26/2010, 7/21/2010, 10/27/2010, 12/1/2010, 3/23/2011, 6/22/2011, and 8/31/2011 | ||
: Corrective Action Program | : Corrective Action Program | ||
| Line 164: | Line 231: | ||
==Section 1EP4: Emergency Action Level and Emergency Plan Changes== | ==Section 1EP4: Emergency Action Level and Emergency Plan Changes== | ||
: EP-100, Radiation Emergency Plan, Rev. 59 | : EP-100, Radiation Emergency Plan, Rev. 59 | ||
: Attachment | : Attachment Changes packages | ||
: EPP-001.1, Unusual Event, Revision 8 | : EPP-001.1, Unusual Event, Revision 8 | ||
: EPP-001, Activation and Implementation of Emergency Plan, Revision 30, Change A | : EPP-001, Activation and Implementation of Emergency Plan, Revision 30, Change A | ||
| Line 187: | Line 253: | ||
: EPP-105, Conduct of Drills and Exercises, Rev. 9 | : EPP-105, Conduct of Drills and Exercises, Rev. 9 | ||
: EPP-106, Emergency Preparedness Performance Indicator Procedure, Rev. 2 | : EPP-106, Emergency Preparedness Performance Indicator Procedure, Rev. 2 | ||
: EPP-021, Activation of the Early Warning Siren System (EWSS), Rev. 22 | : EPP-021, Activation of the Early Warning Siren System (EWSS), Rev. 22 | ||
: Records and Data | : Records and Data | ||
: DEP documentation for July 1, 2010, through June 30, 2011 | : DEP documentation for July 1, 2010, through June 30, 2011 | ||
Revision as of 14:50, 31 July 2018
| ML11314A247 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 11/10/2011 |
| From: | Bonser B R NRC/RGN-II/DRS/PSB1 |
| To: | Gatlin T D South Carolina Electric & Gas Co |
| M. SPECK | |
| References | |
| IR-11-501 | |
| Download: ML11314A247 (11) | |
Text
November 10, 2011
Mr. Thomas Vice President - Nuclear Operations South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station P.O. Box 88 Jenkinsville, SC 29065
SUBJECT: VIRGIL C. SUMMER NUCLEAR STATION - NRC EMERGENCY PREPAREDNESS INSPECTION REPORT 05000395/2011501
Dear Mr. Gatlin:
On September 30, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your V. C. Summer Nuclear Station. The enclosed inspection report documents the inspection results, which were discussed on September 30, 2011, with Mr. J. Archie and 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.
Based on the results of this inspection, no findings of significance were identified.
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 (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,/RA/
Brian Bonser, Chief Plant Support Branch 1 Division of Reactor Safety Docket No.: 50-395 License No.: NPF-12
Enclosure:
Inspection Report 05000395/2011501
w/Attachment:
Supplemental Information
cc w/encl.: (See page 2)
ML11314A247 X SUNSI REVIEW COMPLETE X FORM 665 ATTACHED OFFICE RII: DRS/PSB1 RII:DRS/PSB1 RII: DRS/PSB1 RII: DRP/BR5B RIV: DRS/PSB1 RII: DRP/5B SIGNATURE RA/MS RA/MS For WL RA/BB RA VIA EMAIL RA/VIA EMAIL RA/VIA EMAIL NAME M. SPECK W.LOO B. BONSER S. WALKER P. ELKMANN J. REECE DATE 11/09/2011 11/09/2011 11/10/2011 11/09/2011 11/09/2011 11/08/2011 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO SCE&G 2 cc w/encl: J. B. Archie Senior Vice President Nuclear Operations and Chief Nuclear Officer South Carolina Electric & Gas Company Electronic Mail Distribution George A. Lippard, III General Manager Nuclear Plant Operations South Carolina Electric & Gas Company Electronic Mail Distribution Andy T. Barbee Director Nuclear Training South Carolina Electric & Gas Company Electronic Mail Distribution Robert M. Fowlkes General Manager Engineering Services South Carolina Electric & Gas Company Electronic Mail Distribution Robin R. Haselden General Manager Organizational Development & Effectiveness South Carolina Electric & Gas Company Electronic Mail Distribution
Shaun M. Zarandi General Manager Nuclear Support Services South Carolina Electric & Gas Company Electronic Mail Distribution Robert L. Justice Manager Nuclear Operations South Carolina Electric & Gas Company Electronic Mail Distribution
Bruce L. Thompson Manager Nuclear Licensing (Mail Code 830) South Carolina Electric & Gas Company Electronic Mail Distribution Donna W. Railey Licensing Technician Nuclear Licensing South Carolina Electric & Gas Company Electronic Mail Distribution
Robin J. White Nuclear Coordinator S.C. Public Service Authority Mail Code 802 Electronic Mail Distribution
Sandra Threatt, Manager Nuclear Response and Emergency Environmental Surveillance Bureau of Land and Waste Management Department of Health and Environmental Control Electronic Mail Distribution Kathryn M. Sutton, Esq. Morgan, Lewis & Bockius LLP Electronic Mail Distribution
Division of Radiological Health TN Dept. of Environment & Conservation 401 Church Street Nashville, TN 37243-1532
Richard Haynes Director, Division of Waste Management Bureau of Land and Waste Management S.C. Department of Health and Environmental Control Electronic Mail Distribution Mark Yeager Division of Radioactive Waste Mgmt.
S.C. Department of Health and Environmental Control Electronic Mail Distribution Senior Resident Inspector Virgil C. Summer Nuclear Station U.S. NRC 576 Stairway Road Jenkinsville, SC 29065
Enclosure U. S. NUCLEAR REGULATORY COMMISSION REGION II
Docket Nos.: 05000395
License Nos.: NPF-12
Report No.: 05000395/2011501
Licensee: South Carolina Gas and Electric
Facility: Virgil C. Summer Nuclear Station, Unit 1
Location: Jenkinsville, SC
Dates: September 26 - 30, 2011
Inspectors: M. Speck, Senior Emergency Preparedness Inspector P. Elkmann, Senior Emergency Preparedness Inspector J. Reece, Senior Resident Inspector W. Loo, Senior Health Physics Inspector
Approved by: Brian Bonser, Chief Plant Support Branch 1 Division of Reactor Safety Enclosure
SUMMARY OF FINDINGS
IR 05000395/2011501; 09/26/2011 - 09/30/2011; Virgil C. Summer Nuclear Station, Unit 1; Emergency Preparedness Baseline Inspection.
The report covered an announced inspection by two Emergency Preparedness Inspectors, one Senior Resident Inspector, and one Health Physics Inspector. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process."
A. NRC-Identified and Self-Revealing Findings
Cornerstone: Emergency Preparedness
No findings were identified.
B. Licensee-Identified Violations
None.
REPORT DETAILS
REACTOR SAFETY
Cornerstone:
Emergency Preparedness 1EP1 Exercise Evaluation
a. Inspection Scope
Prior to the inspection activity, the inspectors conducted an in-office review of the exercise objectives and scenario submitted to the NRC 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 onsite inspection consisted of the following review and assessment:
$ The adequacy of the licensee's performance in the biennial exercise conducted on September 28, 2011, was reviewed and assessed regarding the implementation of the Risk Significant Planning Standards (RSPS) in 10 CFR 50.47 (b)(4), (5), (9), and (10), which address emergency classification, offsite notification, radiological assessment, and protective action recommendations 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, Operations Support Center (OSC), Technical Support Center (TSC), and Emergency Operations Facility (EOF).
$ Other performance areas besides the RSPS, such as the emergency response organization's (ERO) recognition of abnormal plant conditions, command and control, intra- and inter-facility communications, prioritization of mitigation activities, utilization of repair and field monitoring teams, interface with offsite agencies, and the overall implementation of the emergency plan and its implementing procedures.
$ Past performance issues from NRC inspection reports and Federal Emergency Management Agency (FEMA)/Department of Homeland Security (DHS) exercise reports to determine effectiveness of corrective actions as demonstrated during this exercise to ensure compliance with 10 CFR 50.47(b)(14).
$ The post-exercise critique process and the presentation to the licensee's senior management conducted on September 30, 2011, to evaluate the licensee's self-assessment of its ERO performance during the exercise and to ensure compliance with 10 CFR 50 Appendix E.IV.F.2.g.
The inspectors reviewed various documents which are listed in the Attachment.
b. Findings
Introduction:
The team identified an unresolved item (URI) concerning the adequacy of training and procedures to assess and monitor a radiological release using field monitoring teams.
Description:
While reviewing procedures used during the biennial emergency preparedness exercise, inspectors questioned the adequacy of licensee procedure EPP-7, Environmental Monitoring, Rev. 11, used to direct deployment of field monitoring teams to effectively locate radioactive release plume boundaries. The licensee initiated corrective action CR-11-04977 to evaluate this issue. Inspectors concluded that further review of information related to the procedure's adequacy, and its interrelationship with other licensee radiological assessment procedures is necessary to determine if the issue constitutes a violation of regulatory requirements. This issue is identified as URI 05000395/2011501-01, "Adequacy of Procedures to Assess and Monitor Emergency Radiological Releases."
1EP4 Emergency Action Level (EAL) and Emergency Plan Changes
a. Inspection Scope
Since the last NRC inspection of this program area, Revision 59, of the VC Summer Emergency Plan was implemented based on the licensee's determination, in accordance with 10 CFR 50.54(q), that the changes resulted in no decrease in the effectiveness of the Plan, and that the revised Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. The inspector conducted a review of the Plan changes and a sampling review of the implementing procedure changes made between September 1, 2010, and September 1, 2011, to evaluate for potential decreases in effectiveness of the Plan. This review was not documented in a Safety Evaluation Report and does not constitute formal NRC approval of the changes. Therefore, these changes remain subject to future NRC inspection in their entirety.
The inspection was conducted in accordance with NRC Inspection Procedure 71114, Attachment 04, "Emergency Action Level and Emergency Plan Changes". The applicable planning standard 10 CFR 50.47(b)(4) and related requirements contained in 10 CFR 50.54(q) and Appendix E to 10 CFR Part 50 were used as reference criteria.
This inspection activity represents one sample on an annual cycle.
The inspector reviewed various documents which are listed in the Attachment.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator (PI) Verification
a. Inspection Scope
The inspectors sampled licensee submittals for the three performance indicators (PI) listed below. For each of the submittals, the inspectors reviewed the period from July 1, 2010, through June 30, 2011. To verify the accuracy of the PI data reported during that period, PI definitions and guidance contained in Nuclear Energy Institute (NEI) 99-02, Regulatory Assessment Indicator Guideline, Revision 6, were used to verify the basis in reporting for each data element.
$ Emergency Response Organization Drill/Exercise Performance (DEP)
$ Emergency Response Organization Readiness (ERO)
$ Alert and Notification System Reliability (ANS)
The inspectors reviewed portions of the raw PI data developed from monthly performance indicator reports, and discussed the methods for compiling and reporting the PIs with the responsible emergency preparedness personnel. The inspectors also independently screened drill and exercise opportunity evaluations, drill participation reports, and drill evaluations. Selected reported values were calculated to verify their accuracy. The inspectors compared graphical representations from the most recent PI report to the raw data to verify that the data was correctly reflected in the report. Reviewed documents are listed in the Attachment.
The inspection was conducted in accordance with NRC Inspection Procedure 71151, "Performance Indicator Verification." This inspection activity represents three samples on an annual cycle.
The inspectors reviewed various documents which are listed in the Attachment.
b. Findings
No findings were identified.
4OA6 Meetings, Including Exit
On September 30, 2011, the lead inspector presented the inspection results to Mr. J. Archie and members of the onsite management staff. The inspectors confirmed that proprietary information was not provided or taken during the inspection.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- J. Archie, Senior Vice President, Chief Nuclear Officer
- E. Bonnette, EP Specialist
- L. Bouknight, EP Specialist
- T. Gatlin, Vice President Nuclear Operations
- R. Haselden, General Manager Organizational Effectiveness
- J. Knox, Emergency Planning Specialist
- C. Lasseigne, Licensing Specialist
- G. Lippard, General Manager Nuclear Power Operations
- T. McCullough, EP Supervisor
- S. Reese, Licensing Specialist
- E. Rumfelt, Licensing Supervisor
- B. Thompson, Manager Nuclear Licensing
- R. Williamson, Manager Emergency Services
- S. Zarandi, General Manager Nuclear Support Services
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
- 05000395/2011501-01 URI Adequacy of Procedures to Assess and Monitor Emergency Radiological
Releases
Attachment
LIST OF DOCUMENTS REVIEWED
1EP1 Exercise Evaluation
Procedures
- EPP-001.2 Alert, Rev. 8
- EPP-001.3 Site Area Emergency, Rev. 8
- EPP-001.4 General Emergency, Rev. 8
- EPP-001 Activation and Implementation of Emergency Plan, Rev. 30
- EPP-002 Communication and Notification, Rev. 35
- EPP-005 Offsite dose Calculation, Rev. 20
- EPP-007, Environmental Monitoring, Rev. 11
- EPP-012, Onsite Personnel Accountability and Evacuation, Rev. 12
- EPP-021 Activation of the Early Warning Siren System (EWSS), Rev. 22
- EPP-023 Technical Support Center, Rev. 17
- EPP-028 Operations Support Center, Rev. 1
- EPP-051 Emergency Operations Facility, Rev. 8
- EPP-105 Conduct of Drills and Exercises, Rev. 9
- EPP-108.00 Emergency Action Level Technical Basis Document, Rev. 0 Management Directive 11, Shift Supervisor Duties and Responsibilities, Rev. 29
- SAP-0127, Emergency Preparedness, Rev. 2
- Records and Data Control Room, Technical Support Center, Operations Support Center, Emergency Operations Facility, Joint Information Center - Documentation packages (logs, event notification forms), Protective Action Recommendations, Media releases, and Radiological Dose Assessment 2009 Graded Exercise drill package Drill reports:
- 3/24/2010, 5/26/2010, 7/21/2010, 10/27/2010, 12/1/2010, 3/23/2011, 6/22/2011, and 8/31/2011
- Corrective Action Program
- CR-11-04947, Notification timeliness
- CR-11-04944, Dose assessment errors
- CR-11-04950, Procedure deficiencies
- CR-11-04945, Evaluate RHR temperature limit
- CR-11-04955, OSC repair team accountability
- CR-11-04943, PAR issue
- CR-11-04944, KI issuance
- CR-11-04946, Inaccurate press releases
- CR-11-04948, Briefing area postings
- CR-11-04948, Stage controllers in shops
- CR-11-04977,
- EPP-7 adequacy
- CR-11-04983, NRC comment roll-up
Section 1EP4: Emergency Action Level and Emergency Plan Changes
- EP-100, Radiation Emergency Plan, Rev. 59
- Attachment Changes packages
- EPP-001.1, Unusual Event, Revision 8
- EPP-001, Activation and Implementation of Emergency Plan, Revision 30, Change A
- EPP-002, Communication and Notification, Revision 35
- EPP-007, Environmental Monitoring, Revision 11
- EPP-027, Hostile Action, Rev. 4
- EPP-051, Emergency Operations Facility, Revision 8
- EPP-100, Radiation Emergency Plan, Revision 59
- EPP-105, Conduct Of Drills And Exercises, Rev.
- 9
- EPP-108, Emergency Action Level Technical Basis Document, Revision 0, Change A
- EPP-109, Equipment related to Emergency Preparedness, Revision 0
- SAP-0127, Emergency Preparedness, Revision 2
- EPMP-102,
- EOF-JIC Handbook, Revision 0
Section 4OA1: Performance Indicator Verification
Procedures
- EPP-104, Verification of Communications Operability, Rev. 9
- EPP-105, Conduct of Drills and Exercises, Rev. 9
- EPP-106, Emergency Preparedness Performance Indicator Procedure, Rev. 2
- EPP-021, Activation of the Early Warning Siren System (EWSS), Rev. 22
- Records and Data
- DEP documentation for July 1, 2010, through June 30, 2011
- Siren test data for July 1, 2010, through June 30, 2011