IR 05000456/2006010

IR 05000456-06-010(DRS); 05000457-06-010(DRS); on 08/07/2006 - 08/11/2006; Braidwood Station; Emergency Preparedness Specialist Report

ML062400375
Person / Time
Site:	Braidwood
Issue date:	08/22/2006
From:	Riemer K R Plant Support Branch II
To:	Crane C M Exelon Generation Co, Exelon Nuclear
References
IR-06-010
Download: ML062400375 (13)

Text

August 22, 2006

Mr. Christopher M. CranePresident and Chief Nuclear Officer Exelon Nuclear Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT: BRAIDWOOD STATION, UNITS 1 AND 2NRC EMERGENCY PREPAREDNESS INSPECTION REPORT 05000456/2006010(DRS); 05000457/2006010(DRS)

Dear Mr. Crane:

On August 11, 2006, the NRC completed an inspection at your Braidwood Station, Units 1and 2. The enclosed report documents the inspection findings, which were discussed on August 11, 2006, with Mr. G. Boerschig and other members of your staff.The inspection examined activities conducted under your license as they relate to safety andcompliance 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. Specifically, this inspection focused on emergency preparedness, including your staff's 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 letterand its enclosure will be available electronically for public inspection in the NRC PublicDocument Room, or from the Publicly Available Records (PARS) component of NRC's C. Crane-2-document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/Kenneth Riemer, ChiefPlant Support Branch Division of Reactor SafetyDocket Nos. 50-456; 50-457License Nos. NPF-72; NPF-77

Enclosure:

Inspection Report 05000456/2006010(DRS); 05000457/2006010(DRS)

w/Attachment:

Supplemental Informationcc w/encl:Site Vice President - Braidwood StationPlant Manager - Braidwood Station Regulatory Assurance Manager - Braidwood Station Chief Operating Officer Senior Vice President - Nuclear Services Vice President - Operations Support Director Licensing Manager Licensing - Braidwood and Byron Senior Counsel, Nuclear, Mid-West Regional Operating Group Document Control Desk - Licensing Assistant Attorney General Illinois Emergency Management Agency State Liaison Officer Chairman, Illinois Commerce Commission W. King, DHS, Region V

SUMMARY OF FINDINGS

IR 05000456/2006010(DRS); 05000457/2006010(DRS); 08/07/2006 - 08/11/2006;Braidwood Station; Emergency Preparedness Specialist Report.The report covers a 1 week baseline inspection by two regional emergency preparednessinspectors, a resident inspector, and a licensed operator examiner. 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 July 1, 2005, through June 30, 2006.The NRC's program for overseeing the safe operation of commercial nuclear power reactors isdescribed in NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000.A.Inspector-Identified and Self-Revealed FindingsNone.

Cornerstone: Emergency Preparedness

One violation of very low safety significance, which was identified by the licensee, wasreviewed by the inspectors. Corrective actions taken by the licensee were entered into the licensee's corrective action program and were adequately completed. This violation is listed in Section 4OA7 of this report.

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REPORT DETAILS

1.REACTOR SAFETYCornerstone: Emergency Preparedness1EP1Exercise Evaluation (71114.01)

a. Inspection Scope

The inspectors reviewed the August 8, 2006, biennial emergency preparednessexercise's objectives and scenario to ensure that the exercise would acceptably test major elements of the licensee's emergency plan and to verify that the exercise's simulated problems provided an acceptable framework to support demonstration of the licensee's capability to implement its plan. The inspectorsalso reviewed records of two emergency preparedness drills, which were conducted in2005 and 2006, to verify that those dr ills' scenarios were sufficiently different from thescenario used in the August 8, 2006 exercise.The inspectors evaluated the licensee's exercise performance, focusing on therisk-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 licensee's recognition of abnormal plant conditions,transfer of responsibilities between facilities, internal communications, interfaces withoffsite officials, readiness of emergency facilities and related equipment, and overallimplementation of the licensee's emergency plan.The inspectors attended post-exercise critiques in the CRS, TSC, OSC, and EOFto evaluate the licensee's initial self-assessment of its exercise performance. The inspectors later met with the licensee's lead exercise evaluators to obtain the licensee's refined assessments of its exercise participants' performances. These self-assessments were then compared with the inspectors' independent observations and assessments to assess the licensee's ability to adequately critique its exerciseperformance.These activities completed one inspection sample.

b. Findings

No findings of significance were identified.

4OA1 Performance Indicator (PI) Verification

Cornerstone: Emergency Preparedness.1Reactor Safety Strategic Area

a. Inspection Scope

The inspectors reviewed the licensee's records associated with each of the threeemergency preparedness PIs to verify that the licensee's program was implemented consistent with the industry guidelines in the applicable revision of Nuclear Energy Institute Publication No. 99-02, "Regulatory Assessment Performance Indicator Guideline," 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 Dr ill and Exercise Performance(DEP) were reviewed to verify the accuracy and completeness of the PI data submitted to NRC for the period from July 1, 2005 through June 30, 2006. The following three PIswere reviewed:Common

• ANS*ERO Drill Participation

• DEPThese activities completed three PI samples.

b. Findings

No findings of significance were identified.4OA6Meetings.1Exit MeetingAn exit meeting was conducted for:

• Emergency Preparedness with Mr. G. Boerschig and other members of licenseemanagement and staff at the conclusion of the inspection on August 11, 2006. The licensee acknowledged the information presented. No proprietary information was identified..2Public and Media Briefing*On August 11, 2006, an inspector summarized NRC's preliminary exerciseinspection conclusions at a public and media briefing hosted by Department of Homeland Security Region V Field Office staff in Joliet, Illinois.

44OA7Licensee Identified ViolationsCornerstone: Emergency PreparednessThe following violation of very low significance was identified by the licensee and is aviolation of NRC requirements which met the criteria of Section VI of the NRCEnforcement Manual, NUREG-1600, for being dispositioned as a Non-Cited Violation(NCV).Title 10 CFR 50.54(q) requires, in part, that a licensee shall follow and maintain in effectemergency plans which meet the standards in Section 50.47(b) and requirements in Appendix E of this part. The licensee may make changes to these plans without Commission approval only if the changes do not decrease the effectiveness of the plans. Contrary to the above, Emergency Action Level (EAL) HU-5, which addressed natural or destructive phenomenon inside the protected area or switchyard, was revised in a non-conservative manner. The non-conservative Unusual Event revision, which was implemented on January 17, 2006, erroneously referenced a seismic acceleration value for an Alert emergency classification, and was identified by the licensee to be the result of inadequate technical reviews. The licensee identified and restored EAL HU-5 to the correct wording in a revision implemented on March 17, 2006.The licensee's implementation of the change to EAL HU-5 on January 17, 2006,decreased the effectiveness of the emergency plan without prior NRC approval, andconsequently was a violation of 10 CFR 50.54(q). The finding is not suitable for evaluation using the Significance Determination Process, but has been reviewed by

NRC management and is determined to be a finding of very low safety significance. Because the violation was entered into the licensee's corrective action program and adequate corrective action was completed, it is being treated as a Severity Level IV NCV.ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

K. Aleshire, Emergency Preparedness Manager

D. Ambler, Regulatory Assurance Manager

G. Boerschig, Plant Manager

C. Dunn, Training Department Manager

J. Gerrity, Emergency Preparedness Coordinator

D. Gibeaut, Nuclear Oversight Manager

R. Leasure, Radiation Protection Manager

S. McCain, Corporate Emergency Preparedness Manager

W. Waznis, Nuclear Oversight SpecialistIllinois Emergency Management Agency

M. Perry, Engineer

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened, Closed, and

Discussed

None.

LIST OF DOCUMENTS REVIEWED

The following is a list of documents reviewed during the inspection.

Inclusion on this list doesnot imply that the NRC inspectors reviewed the documents in their entirety but rather that selected sections of 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 orany part of it, unless this is stated in the body of the inspection report.

1EP1Exercise EvaluationBraidwood Station August 2006 Exercise Scenario Manual Braidwood Station Draft August 2006 Exercise Findings and Observations Report;

undated Braidwood Station June 2006 Pre-Exercise Findings and Observations Report; datedJuly 28, 2006 Braidwood Station 2005 Off-Year Emergency Plan Drill Scenario SummaryBraidwood Station Annex to the Exelon Standardized Emergency Plan; Section 3;Revision 17

2EP-AA-110; Assessment of Emergencies; Revision 6EP-AA-110-302; Core Damage Assessment - Pressurized Water Reactors; Revision 1

EP-AA-111; Emergency Classification and Protective Action Recommendations;Revision 11EP-AA-112; Emergency Response Organization and Emergency Response FacilityActivation and Operation; Revision 10EP-AA-112-100; Control Room Operation; Revision 7

EP-AA-112-200; TSC Activation and Operation; Revision 5

EP-AA-112-300; OSC Activation and Operation; Revision 5

EP-AA-112-400; EOF Activation and Operation; Revision 6

EP-AA-113; Personnel Protective Actions; Revision 7

EP-AA-114; Notifications; Revision 6

EP-MW-110-200; Dose Assessment; Revision 4

EP-MW-114-100; Midwest Region Offsite Notifications; Revision 5

4OA1 Performance Indicator VerificationBraidwood Station Emergency Planning Zone Sirens' Daily and Monthly OperabilityReports - July 2005 through June 2006

LS-AA-2110; Monthly PI Data Elements for ERO Drill Participation - July 2005 throughJune 2006; Revision 5LS-AA-2120; Monthly PI Data Elements for Drill/Exercise Performance - July

2005through June 2006; Revision 3LS-AA-2130; Monthly PI Data Elements for ANS Reliability - July 2005 throughJune 2006; Revision 4

==4OA7 Licensee Identified ViolationsBraidwood Station Annex to the Exelon Standardized Emergency Plan; Section 3;Category H - Hazards and Other Conditions; Revisions 16 and 17AR

00467017; Discovery of Non-Conservative==

EAL Change; dated March 16, 2006

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LIST OF ACRONYMS

USEDANSAlert and Notification SystemARAction Request

CFRCode of Federal Regulations

CRSControl Room Simulator

DEPDrill and Exercise PerformanceEALEmergency Action Level

EOFEmergency Operations Facility

EROEmergency Response Organization

NCVNon-Cited Violation

NRCUnited States Nuclear Regulatory Commission

NUREGNuclear Regulatory GuideOSCOperations Support Center

PIPerformance Indicator

TSCT echnical Support Center