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:	Kenneth Riemer Plant Support Branch II
To:	Crane C Exelon Generation Co, Exelon Nuclear
References
IR-06-010
Download: ML062400375 (13)

Text

ust 22, 2006

SUBJECT:

BRAIDWOOD STATION, UNITS 1 AND 2 NRC 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 1 and 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 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), 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 Plant Support Branch Division of Reactor Safety Docket Nos. 50-456; 50-457 License Nos. NPF-72; NPF-77 Enclosure: Inspection Report 05000456/2006010(DRS);

05000457/2006010(DRS)

w/Attachment: Supplemental Information cc w/encl: Site Vice President - Braidwood Station Plant 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 preparedness inspectors, 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 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.

Cornerstone: Emergency Preparedness

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

REPORT DETAILS

1EP1 Exercise Evaluation

a. Inspection Scope

The inspectors reviewed the August 8, 2006, 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 records of two emergency preparedness drills, which were conducted in 2005 and 2006, to verify that those drills scenarios were sufficiently different from the scenario used in the August 8, 2006 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 CRS, 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 its exercise performance.

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 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 Drill 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 PIs were reviewed:

Common

• ANS

• ERO Drill Participation

• DEP These activities completed three PI samples.

b. Findings

No findings of significance were identified.

4OA6 Meetings

.1 Exit Meeting

An exit meeting was conducted for:

• Emergency Preparedness with Mr. G. Boerschig and other members of licensee management and staff at the conclusion of the inspection on August 11, 2006.

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

.2 Public and Media Briefing

• On August 11, 2006, an inspector summarized NRCs preliminary exercise inspection conclusions at a public and media briefing hosted by Department of Homeland Security Region V Field Office staff in Joliet, Illinois.

4OA7 Licensee Identified Violations

Cornerstone: Emergency Preparedness

The following violation of very low significance was identified by the licensee and is a violation of NRC requirements which met the criteria of Section VI of the NRC Enforcement 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 effect emergency 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 licensees implementation of the change to EAL HU-5 on January 17, 2006, decreased the effectiveness of the emergency plan without prior NRC approval, and consequently 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 licensees 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 Specialist

Illinois Emergency Management Agency

M. Perry, Engineer

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened, Closed, and Discussed

None.