IR 05000237/2005006

IR 05000237-05-006 (Drs); IR 05000249-05-006 (DRS) on 03/07/2005 - 03/11/2005 for Dresden Nuclear Power Station, Units 2 & 3; Emergency Preparedness Specialist Report

ML050800284
Person / Time
Site:	Dresden
Issue date:	03/21/2005
From:	Kenneth Riemer Division of Reactor Safety III
To:	Crane C Exelon Generation Co, Exelon Nuclear
References
IR-05-006
Download: ML050800284 (13)

Text

rch 21, 2005

SUBJECT:

DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 NRC EMERGENCY PREPAREDNESS INSPECTION REPORT NO. 05000237/2005006(DRS); 05000249/2005006(DRS)

Dear Mr. Crane:

On March 11, 2005, the NRC completed an inspection at your Dresden Nuclear Power Station.

The enclosed report documents the inspection findings, which were discussed on March 11, 2005, with Mr. D. Bost 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. Specifically, this inspection focused on emergency preparedness, including your staffs determinations of performance indicators for the Emergency Preparedness Cornerstone.

On the basis of the results of this inspection, no findings of significance were identified.

In accordance with 10 CFR Part 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure 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 Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Kenneth Riemer, Chief Security and Preparedness Branch Division of Reactor Safety Docket Nos. 50-237; 50-249 License Nos. DPR-19; DPR-25 Enclosure: Inspection Report 05000237/2005006(DRS);

05000249/2005006(DRS)

See Attached Distribution

SUMMARY OF FINDINGS

IR 05000237/2005006(DRS); 05000249/2005006(DRS); 03/07/2005 - 03/11/2005;

Dresden Nuclear Power Station, Units 2 & 3; Emergency Preparedness Specialist Report.

The report covers a one-week baseline inspection by two regional emergency preparedness inspectors and a senior resident inspector. The inspection focused on the Emergency Preparedness Cornerstone in the Reactor Safety strategic performance area during the biennial emergency preparedness exercise. This inspection also included a review of records related to the three emergency preparedness performance indicators for the period October 1, 2003, through December 31, 2004. One Green Non-Cited Violation was identified.

The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.

A. Inspector-Identified and Self-Revealed Findings None.

Licensee-Identified Violations

Green.

Title 10 CFR 50.47 (b) (15) requires, in part, that radiological emergency response training is provided to those who may be called on to assist in an emergency.

Table B-1 of the licensees Standardized Emergency Plan required that the minimum on-shift staffing included two Radiation Protection (RP) personnel for in-plant protective actions. In September 2004, the licensee identified that this commitment was met by one on-shift RP technician and one on-shift chemistry technician that had been trained and qualified to perform in-plant protective actions. However, the licensee also determined that chemistry technicians training had evolved such that this training no longer met all requirements to provide in-plant protection actions.

Timely corrective actions included assigning two RP technicians on all back shifts, initiating revision of the standardized ERO training procedure, and initiating an assessment of ERO position qualifications in cases where some ERO training was being performed by other departments. Because no emergencies had occurred that required in-plant protective actions and the licensees timely corrective actions included staffing a minimum of two RP technicians on-shift, this violation is not more than of very low significance, and is being treated as a Non-Cited Violation. (Section 4OA7)

REPORT DETAILS

1EP1 Exercise Evaluation

a. Inspection Scope

The inspectors reviewed the March 2005 biennial emergency preparedness exercises objectives and scenario to ensure that the exercise would acceptably test major elements of the licensees emergency plan and to verify that the exercises simulated problems provided an acceptable framework to support demonstration of the licensees capability to implement its plan. The inspectors also reviewed excerpts of records of two emergency preparedness drills, which were conducted on April 21, 2004, and February 16, 2005, to determine whether those drills scenarios were sufficiently different from the scenario used in the March 9, 2005, exercise.

The inspectors evaluated the licensees exercise performance, focusing on the risk-significant activities of emergency classification, notification, and protective action decision making, as well as implementation of accident mitigation strategies in the following emergency response facilities:

• Control Room Simulator (CRS);

• Technical Support Center (TSC);

• Operations Support Center (OSC); and

• Emergency Operations Facility (EOF).

The inspectors also assessed the licensees recognition of abnormal plant conditions, transfer of responsibilities between facilities, internal communications, interfaces with offsite officials, readiness of emergency facilities and related equipment, and overall implementation of the licensees emergency plan.

The inspectors attended post-exercise critiques in the TSC, OSC, and EOF to evaluate the licensees initial self-assessment of its exercise performance. The inspectors later met with the licensees lead exercise evaluators to obtain the licensees refined assessments of its exercise participants performances. These self-assessments were then compared with the inspectors independent observations and assessments to assess the licensees ability to adequately critique station performance during the exercise.

These activities completed one inspection sample.

b. Findings

No findings of significance were identified.

1EP4 Emergency Action Level and Emergency Plan Changes

a. Inspection Scope

The inspectors performed a screening review of Revision 18 of the Dresden Stations Annex to the Exelon Standardized Emergency Plan, as well as the licensees associated 50.54(q) evaluation of the changes incorporated in Revision 18, to determine whether changes in Revision 18 decreased the effectiveness of the licensees emergency planning for the Dresden Station. The inspectors also reviewed seven letters of agreement with offsite support organizations to determine whether these agreements were current and whether the types of support to be provided were consistent with statements in the Dresden Annex. The screening review did not constitute an approval of Revision 18 of the Dresden Annex and, as such, the changes are subject to future NRC inspection to ensure that the Dresden Annex of the standardized plan continues to meet NRC regulations.

These activities completed one inspection sample.

b. Findings

No findings of significance were identified.

4OA1 Performance Indicator (PI) Verification

.1 Reactor Safety Strategic Area

a. Inspection Scope

The inspectors reviewed the licensees records associated with each of the three emergency preparedness PIs to verify that the licensees program was implemented consistent with the industry guidelines in Nuclear Energy Institute Publication No. 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 2, and related licensee procedures. Specifically, licensee records related to the performance of the Alert and Notification System (ANS), key Emergency Response Organization (ERO)members drill participation, and Drill and Exercise Performance (DEP) were reviewed to verify the accuracy and completeness of the PI data submitted to NRC for the period from October 1, 2003 through December 31, 2004. The following three PIs were reviewed:

Common

• ANS;

• ERO Drill Participation; and

• Drill and Exercise Performance.

These activities completed thee PI samples.

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems

The following performance concerns, which could have adversely impacted emergency response activities if events had been real, were independently identified by the licensee and by the inspectors during the March 2005 exercise:

• The licensee did not initially notify the simulated NRC Headquarters Operations Officer within 60 minutes of the first emergency declaration.

• The responsible licensee decision maker incorrectly declared a General Emergency roughly 70 minutes before simulated plant conditions had degraded enough to warrant this emergency reclassification.

4OA6 Meetings

.1 Exit Meeting

An exit meeting was conducted for:

• Emergency Preparedness with Mr. D. Bost and other members of licensee management and staff at the conclusion of the inspection on March 11, 2005.

The licensee acknowledged the information presented. No proprietary information was identified.

4OA7 Licensee Identified Violations

The following violation of very low significance (Green) was identified by the licensee and is a violation of NRC requirements which met the criteria of Section VI of the NRC Enforcement Manual, Nuclear Regulatory Guide (NUREG)-1600, for being dispositioned as a Non-Cited Violation (NCV).

Cornerstone: Emergency Preparedness

Title 10 CFR 50.47 (b)

(15) requires, in part, that radiological emergency response training is provided to those who may be called on to assist in an emergency. Table B-1 of the licensees Standardized Emergency Plan required that the minimum on-shift staffing included two Radiation Protection (RP) personnel for in-plant protective actions.

In September 2004, EP staff based at another of the licensees Illinois nuclear stations identified that this emergency plan commitment was met by one on-shift RP technician and one on-shift chemistry technician that had been trained and qualified to perform in-plant protective actions. However, the licensee also determined that chemistry technicians training had evolved such that it no longer met all requirements to provide in-plant protection actions.

In early December, the licensee completed an adequate root cause investigation of this concerns possible impact at each of its Illinois nuclear stations. Timely corrective actions included assigning two RP technicians on all back shifts, initiating revision of the standardized ERO training procedure, and initiating an assessment of ERO position qualifications in cases where some ERO training was being performed by other departments. Longer-term actions included provisions for an effectiveness review of measures taken to ensure that two qualified RP technicians were always on-shift.

Because no emergencies had occurred that required in-plant protective actions and the licensees timely corrective actions included staffing a minimum of two RP technicians on-shift, this violation is not more than of very low significance, and is being treated as an NCV.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

G. Bockholdt, Maintenance Director

D. Bost, Site Vice President

S. Erickson, Corporate Emergency Planning Specialist

R. Gadbois, Operations Director

J. Griffin, NRC Coordinator

A. Khanifar, Nuclear Oversight Manager

S. McCain, Corporate Emergency Preparedness Manager

P. Salas, Regulatory Assurance Manager

C. Symonds, Training Director

D. Wozniak, Plant Manager

LIST OF ITEMS

Opened and Closed

None.

Discussed

None.