05000387/FIN-2015001-04
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Finding | |
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| Title | Effectiveness of Declaration Capability of Abnormal Radiation Level EAL |
| Description | An unresolved item (URI) was identified because inspectors could not obtain enough information from PPL to determine whether two issues identified by PPL, related to the ability to declare emergencies RG1 and RS1 under the Abnormal Radiation Levels/Radiological Effluents emergency action level (EAL), constituted a violation of regulatory requirement. During a full-scale emergency preparedness (EP) drill, PPL identified during their drill critique that various dose assessment methods are only procedurally directed to be performed by the emergency operations facility (EOF) dose assessment staff. Specifically, procedures for the technical support center (TSC) dose assessment staff would not allow assessment of offsite consequences from an unfiltered and unmonitored release unless field monitoring was available. Additionally, PPLs Nuclear Oversight (NOS) documented that the remote monitoring system (RMS), which consists of 16 fixed radiation monitors at the site boundary that are activated and monitored by TSC/EOF staff, was in a condition that could impact the ability to assess the EAL thresholds. The Abnormal Radiation Level EAL, as presented in EP-RM-004, EAL Classification Bases, Revision 3, includes five dose threshold values for each of the initiating conditions (ICs) RG1 and RS1. One such threshold requires a valid dose assessment using actual meteorology in excess of the limit specified in the EALs. During a full-scale drill on February 17, 2015, PPL identified during their post-drill critique that the TSC and on-shift dose assessors were unable to perform a valid dose assessment for an unmonitored and unfiltered release. In the drill scenario, an airborne release occurred from a blowout panel due to an unisolable leak in the HPCI system. This leak, in conjunction with approximately 1% cladding damage that had occurred due to the initiating event, resulted in dose projections in excess of the RG1 threshold. The TSC staff was not able to perform a valid blowout panel calculation because their procedures and training do not direct them to perform this action. In accordance with EP-PS-105, TSC Dose Calculator, Revision 23, TSC dose assessors are only procedurally directed to perform forward calculations using release data from the vent stack monitors and back calculations using field monitoring data. PPL entered the issue into the CAP as CR-2015-04701. Inspectors questioned whether any compensatory measures would be implemented to address the potential issue. PPLs initial response determined that the current revision to the emergency plan indicates that only forward and back calculations are required for all emergency facilities. Though PPL acknowledges that the EOF has the ability to perform several other types of calculations (i.e. Default Accident, Event Tree NUREG-1228, Blowout Panel, and Isotopic Entry Calculations), PPL indicated that these types of calculations would require additional information that requires EOF staffing to perform. PPL staff indicated that this conclusion would be formally documented in an evaluation. Inspectors reviewed the issue and questioned the adequacy of PPLs response. PPLs Emergency Plan describes that data from vent effluent monitors serve as inputs for the off-site dose calculation methods and that field team surveys are used to update projected dose. Section 7.1.1.3 of the plan describes PPLs dose calculation model, MIDAS, which complies with the U. S. Environmental Protection Agency Protective Action Guide Manual (EPA-400). This program provides multiple methods to perform valid dose assessments including those described above. Inspectors reviewed what additional information would be required from EOF staff to perform, in particular, the blowout panel calculation method. EP-RM-004, MIDAS-NU Users Manual, Revision 1, is the procedure for performing dose assessment using PPLs dose assessment model. Section H provides directions for performing a blowout panel calculation and lists the required inputs. All inputs would be available to TSC personnel. The only engineering information needed would be the estimated percent fuel cladding failure which is determined by the Fuels Lead Engineer in the EOF or the Core Thermal Hydraulics Engineer in the TSC in accordance with EP-PS-324, Fuels Lead Engineer/Core Thermal Hydraulics Engineer, Revision 17. Of these two positions, the Fuels Lead Engineer is not designated as minimum staffing in accordance with PPLs emergency plan and therefore the primary responsibility for core damage assessment lies with the TSC staff. Overall, the inspectors issue of concern regarded whether the effectiveness of PPLs emergency plan to meet the planning standards in 10 CFR 50.47 had been maintained by limiting procedural direction and training for forward and back calculations to TSC dose assessment staff or whether the TSC staff should have been capable of performing all MIDAS calculations. A second dose threshold value listed in the Abnormal Radiation Level EAL requires assessment of the RMS. RMS readings can serve as an alternate input to dose assessment in lieu of field monitoring data. Inspectors reviewed CR-2015-06706 in which NOS identified a programmatic deficiency associated with the system. Specifically, the CR documented that PPL did not maintain the Emergency Plan consistent with the approved EALs. The RMS perimeter radiation monitoring system was initially added to the Emergency Plan in Revision 28 and was considered an enhancement. In revision 56 of the Emergency Plan, the RMS perimeter radiation monitoring system was added as an initiating condition for EALs RG1 and RS1. Despite this, the equipment is still described in the emergency plan as not being required. Additionally, the CR documented that the RMS is not maintained as required by EP-115, Equipment Important to Emergency Response, Revision 2. Specifically, NOS documented that 4 of the 16 fixed radiation monitors in the RMS had been out of service since 2013 and the software that displays the RMS does not consistently run in computers in the EOF and TSC. Finally, the CR documented that PPLs CAP has failed to take adequate corrective actions with regards the RMS system. Specifically, CR-2013-04635, written by PPL in November 2013, identified stated that the RMS system is unreliable and cannot be maintained due to a number of hardware and software issues. Despite this, no action had been taken to correct the identified equipment issues. Overall, PPLs NOS concluded that the systematic breakdown in maintaining the Emergency Plan and associated equipment has led to the RMS perimeter radiation monitoring system not being maintained in a functional state to support RG1 and RS1 classification under IC-3. At the end of this inspection, PPL was performing a level 2 apparent cause evaluation for the NOS identified issue. The inspectors issue of concern regarded whether the emergency planning standard in 10 CFR 50.47 had been maintained with the identified RMS equipment deficiencies. 10 CFR 50.54(q)(2) requires that a licensee follow and maintain the effectiveness of an emergency plan that meets the requirements of appendix E to this part and the planning standards of 10 CFR 50.47(b). 10 CFR 50.47(b)(4), Emergency Classification System, requires a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, to be in use by the nuclear facility licensee. Appendix E,Section IV.C.2 requires that licensees establish and maintain the capability to assess, classify and declare an emergency condition within 15-minutes after the availability of indications to plant operators that an emergency action level has been exceeded. Additionally, 10 CFR 50.47(b)(9), Emergency Assessment Capabilities, requires that adequate methods, systems and equipment for assessing and monitoring offsite consequences of a radiological emergency to be in use. 10 CFR 50.47(b)(2) states, in part, that on-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support and response activities are specified. Section 2 of NUREG-0696, Functional Criteria for Emergency Response Facilities, states, in part, that the on-site TSC will perform the EOF functions for the Alert Emergency classification and for the Site Area and General Emergency classifications until the EOF is functional. At the completion of the inspection, inspectors did not have enough information to determine whether either of the two issues resulted in PPL failing to maintain the effectiveness of their emergency plan and therefore could not determine whether a violation of regulatory requirements existed. PPLs evaluations under CR-2015-04701 and CR-2015-04635 should document PPLs determination of whether each constituted a violation of regulatory requirements, to include: 1) whether the effectiveness of the emergency plan was maintained with the identified issues of concern and 2) whether corrective actions to address the identified issues of concern were adequate to maintain the effectiveness of the emergency plan pending future actions and 3) the timeline of events regarding the reliability of the RMS system. This issue will be tracked as an unresolved item (URI) pending further NRC review of PPLs evaluation of the two issues documented under CR-2015-04701 and CR-2015-04635, to include consultation with regional EP specialists and the Office of Nuclear Security and Incident Response (NSIR). (URI 05000387;388/2015001-04, Effectiveness of Declaration Capability of Abnormal Radiation Level EAL) |
| Site: | Susquehanna  |
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| Report | IR 05000387/2015001 Section 1EP6 |
| Date counted | Mar 31, 2015 (2015Q1) |
| Type: | URI: |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71114.06 |
| Inspectors (proximate) | C Graves D Schroeder E Gray J Deboer J Grieves N Embert S Barr T Daun T Fish P Meiera Turilin F Bower J Grieves N Graneto T Daun T O'Har |
| INPO aspect | |
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Finding - Susquehanna - IR 05000387/2015001 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Susquehanna) @ 2015Q1
Self-Identified List (Susquehanna)
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