IR 05000424/2016502

U.S. Nuclear Regulatory Commission Emergency Preparedness Inspection Report 05000424/2016502 and 05000425/2016502

ML16161B004
Person / Time
Site:	Vogtle
Issue date:	06/09/2016
From:	Brian Bonser NRC/RGN-II/DRS/PSB1
To:	Taber K Southern Nuclear Operating Co
References
IR 2016502
Download: ML16161B004 (15)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION une 9, 2016

SUBJECT:

VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 - U.S. NUCLEAR REGULATORY COMMISSION EMERGENCY PREPAREDNESS INSPECTION REPORT 05000424/2016502 AND 05000425/2016502

Dear Mr. Taber:

On May 13, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Vogtle Electric Generating Plant, Units 1 and 2. The enclosed inspection report (IR)

documents the inspection results that were discussed on May 13, 2016, with you and members of your staff.

This report documents one NRC-identified finding of very low safety significance (Green). The finding involved a violation of NRC requirements. Because of the very low safety significance, and because the issue was entered into your corrective action program, the NRC is treating the issue as a non-cited violation (NCV) consistent with Section 2.3.2.a of the NRC Enforcement Policy.

If you contest the violation or significance of the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Vogtle Plant.

If you disagree with the cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region II; and the NRC Resident Inspector at the Vogtle Plant.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public inspections, exemptions, requests for withholding, of the NRC's "Agency Rules of Practice and Procedure," a copy of this letter, its Enclosure, and your response if any, will be available electronically for public inspection in the NRCs Public Document Room, or from the Publicly Available Records (PARS) component of NRC's Agencywide Documents Access and Management System (ADAMS); accessible from the NRC Web site at http://www.nrc.gov/

reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA: Adam D. Nielsen for/

Brian R. Bonser, Chief Plant Support Branch 1 Division of Reactor Safety Docket Nos. 50-424 and 50-425 License Nos. NPF-68 and NPF-81

Enclosure:

NRC IR 05000424 and 425/2016502 w/Attachment: Supplementary Information

REGION II==

Docket Nos: 05000424 and 05000425 License Nos: NPF-68 and NPF-81 Report Nos: 05000424/2016502 and 05000425/2016502 Licensee: Southern Nuclear Operating Company, Inc.

Facility: Vogtle Electric Generating Plant, Units 1 and 2 Location: Waynesboro, GA Dates: May 9-13, 2016 Inspectors: Steven P. Sanchez, Senior Emergency Preparedness Inspector Christopher A. Fontana, Emergency Preparedness Inspector John D. Hickman, Emergency Preparedness Inspector (Trainee)

Wade T. Loo, Senior Health Physicist Thomas A. Stephen, Acting Senior Resident Inspector Approved by: Brian R. Bonser, Chief Plant Support Branch 1 Division of Reactor Safety Enclosure

SUMMARY

Inspection Report (IR) 05000424/2016502 and 05000425/2016502; 5/9/2016 - 5/13/2016;

Vogtle Electric Generating Plant, Units 1 and 2; Exercise and Baseline Inspection This report covers an inspection by three emergency preparedness inspectors, one senior resident inspector, and one senior health physicist. The significance of inspection findings are indicated by their color (i.e., greater than Green, or Green, White, Yellow, or Red) and determined using Inspection Manual Chapter (IMC) 0609, Significance Determination Process, (SDP) dated April 29, 2015. Cross-cutting aspects are determined using IMC 0310, Aspects Within the Cross-Cutting Areas, dated December 4, 2014. All violations of NRC requirements were dispositioned in accordance with the NRCs Enforcement Policy dated February 4, 2015.

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

Cornerstone: Emergency Preparedness

Green: The inspectors identified a non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (CFR), Part 50.54(q)(2), for the licensees failure to maintain the effectiveness of its emergency plan by ensuring that adequate emergency facilities and equipment to support emergency response are provided and maintained as required by 10 CFR 50.47(b)(8).

Specifically, the effectiveness of the emergency plan was reduced by a change to the Technical Support Center (TSC) functionality requirements in Technical Requirements Manual (TRM) TR 13.13.1, Emergency Response Facilities, Revision 1. The requirement to maintain climate control was removed without an adequate basis to support removal. The procedure change had been in place since September 2013, and until a corrected revision is issued, a Standing Order has been put in place. The licensee entered this finding into the corrective action program (CAP) as condition report (CR) 10221041.

The inspectors determined that the performance deficiency was more than minor because it was associated with the procedure quality attribute of the Emergency Preparedness (EP)cornerstone, adversely affected the associated cornerstone objective, and would have affected the emergency response organizations ability to effectively perform their duties had an emergency been declared and TSC climate control non-functional. The finding was evaluated using the EP significance determination process and was identified as having very low safety significance (Green) because it was a failure to comply with NRC requirements and was not a loss of the planning standard function or the overall function of the TSC. The finding was associated with a cross-cutting aspect in the Change Management component of the Human Performance area because the licensee failed to use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority. [H.3] (Section 1EP4)

REPORT DETAILS

REACTOR SAFETY

Cornerstone: Emergency Preparedness

1EP1 Exercise Evaluation

a. Inspection Scope

The onsite inspection consisted of the following review and assessment:

• The adequacy of the licensees performance in the biennial exercise, conducted on May 11, 2016, was reviewed and assessed regarding the implementation of the Risk Significant Planning Standards 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 licensees 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, Technical Support Center, Operations Support Center, and Emergency Operations Facility.

• Other performance areas, such as the emergency response organizations (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 the 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 May 12, 2016, to evaluate the licensees self-assessment of its ERO performance during the exercise, and to ensure compliance with 10 CFR Part 50, Appendix E, Subsection IV.F.2.g.

The inspectors reviewed various documents, which are listed in the Attachment. The inspectors also attended the FEMA-sponsored public meeting on May 13, 2016. This inspection activity satisfied one inspection sample for the exercise evaluation on a biennial basis.

b. Findings

No findings were identified.

1EP4 Emergency Action Level and Emergency Plan Changes

a. Inspection Scope

Since the last NRC inspection of this program area, two revisions to the emergency plan and several revisions to emergency plan implementing procedures had been made. The licensee determined that, in accordance with 10 CFR 50.54(q), the Plan continued to meet the requirements of 10 CFR 50.47(b), and Appendix E to 10 CFR Part 50. The inspectors reviewed the revisions, and sampled implementing procedure changes to evaluate potential reductions in the effectiveness of the Plan. As this review was not documented in a Safety Evaluation Report, and does not constitute formal NRC approval of the changes, these changes remain subject to future NRC inspection in their entirety.

The inspection was conducted in accordance with NRC Inspection Procedure (IP)71114, Attachment 04, Emergency Action Level and Emergency Plan Changes. The applicable planning standards of 10 CFR 50.47(b), and its related requirements in 10 CFR Part 50, Appendix E, were used as reference criteria.

The inspectors reviewed various documents, which are listed in the Attachment to this report. This inspection activity satisfied one inspection sample for the emergency action level and emergency plan changes on an annual basis.

b. Findings

Introduction:

The inspectors identified a green non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (CFR), Part 50.54(q)(2), for the licensees failure to maintain the effectiveness of its emergency plan by ensuring that adequate emergency facilities and equipment to support emergency response are provided and maintained as required by 10 CFR 50.47(b)(8). Specifically, the effectiveness of the emergency plan was reduced by a change to the Technical Support Center (TSC) functionality requirements in Technical Requirements Manual (TRM) TR 13.13.1, Emergency Response Facilities, Revision 1.

Description:

During the performance of the February 17, 2016, quarterly drill, the inspectors noted elevated temperatures in the TSC and questioned the functionality of the TSC. Upon review of TRM TR 13.13.1, Emergency Response Facilities, it was identified that the requirement to maintain climate control was removed in September 2013. One of the TSC functionality requirements was changed from the ventilation system for filtration and climate control to the ventilation system for filtration and radiological control. The goal of the change, annotated in Licensing Document Change Request 2013017, was to provide more definitive guidance with regard to circumstances that require the TSC to be declared non-functional due to loss of any climate control function and thus eliminating the need for an 8-hour report to the NRC. Further inspection of the 10 CFR 50.54

(q) evaluation determined that the removal of the functionality requirement for the TSC to maintain climate control was incompletely considered.

The Vogtle Electric Generating Plant Emergency Plan states that the TSC had been established consistent with NUREG-0696, Functional Criteria for Emergency Response Facilities (ERF), and that the ventilation system provides filtered cooling air during accident conditions. NUREG-0696 further states that ERF ventilation systems shall function in a manner comparable to the control room ventilation system. The Technical Specification Bases states each Control Room Emergency Filtration System train is capable of maintaining control room temperature 85°F. The Final Safety Analysis Report, Section 9.4.1.8, Onsite TSC Heating Ventilation and Air Conditioning (HVAC),states that the HVAC system provides a supply of cooling air sufficient to maintain area temperatures at 75+/-5°F. Additionally, NUREG 0737, Clarifications of Three Mile Island Action Plan Requirements, states that the TSC will be environmentally controlled to provide room air temperature, humidity, and cleanliness appropriate for personnel and equipment. The inspectors reviewed the temperature records of the TSC since May of 2013 and did not identify any prolonged periods (longer than 2 days) of temperatures greater than 85°F.

Analysis:

The licensees failure to adequately maintain their emergency plan was a performance deficiency. Specifically, the effectiveness of the emergency plan was reduced by a change to the TSC functionality requirements in TRM TR 13.13.1, Emergency Response Facilities, Revision 1, when the requirement to maintain climate control was removed without an adequate basis to support removal. The inspectors determined that the performance deficiency was more than minor using NRC Inspection Manual Chapter (IMC) 0612, Appendix B, Issue Screening, because the performance deficiency was associated with the procedure quality attribute of the Emergency Preparedness (EP) cornerstone, adversely affected the associated cornerstone objective, and would have affected the emergency response organizations ability to effectively perform their duties had an emergency been declared and TSC climate control non-functional. The finding was evaluated using the EP significance determination process and was identified as having very low safety significance (Green)because it was a failure to comply with NRC requirements and was not a loss of the planning standard function or the overall function of the TSC. The finding was associated with a cross-cutting aspect in the Change Management component of the Human Performance area because the licensee failed to use a systematic process for evaluating and implementing change so that nuclear safety remains the overriding priority. [H.3]

Enforcement:

Title 10 CFR 50.54(q)(2) requires, in part, that a licensee authorized to possess and operate a nuclear power reactor shall follow and maintain the effectiveness of an emergency plan which meets the requirements in Appendix E to this part and the Planning Standards of 50.47(b). Title 10 CFR 50.47(b)(8) requires, in part, that adequate emergency facilities and equipment to support emergency response are provided and maintained. Contrary to the above, the licensee potentially reduced the ability of the TSC staff to adequately respond to an emergency condition by removing the climate control requirements for the TSC. Specifically, the effectiveness of the emergency plan was reduced by a change to the TSC functionality requirements in TRM TR 13.13.1, Emergency Response Facilities, Revision 1, when the requirement to maintain climate control was removed without an adequate basis to support removal.

The procedure change had been in place since September 2013, and until a corrected revision is issued, a Standing Order has been put in place. The licensee entered the issue into their Corrective Action Program (CAP) as CR 10221041. Because this failure is of very low safety significance (Green) and has been entered into the licensees CAP, this violation is being treated as a NCV, consistent with Section 2.3.2.a of the NRC Enforcement Policy: NCV 05000424/2016502-01, 05000425/2016502-01, Failure to Adequately Maintain Emergency Response Facilities.

1EP8 Exercise Evaluation - Scenario Review

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 using IP 71114.08, Exercise Evaluation - Scenario Review, to determine if the exercise would test major elements of the emergency plan as required by 10 CFR 50.47(b)(14).

The inspectors reviewed various documents, which are listed in the Attachment to this report. This inspection activity satisfied one inspection sample for the exercise evaluation on a biennial basis.

b. Findings

No findings were identified.

4OA1 Performance Indicator Verification

a. Inspection Scope

The inspectors sampled licensee submittals relative to the performance indicators (PIs)listed below for the period April 1, 2015, through March 31, 2016. To verify the accuracy of the PI data reported during that period, PI definitions and guidance contained in Nuclear Energy Institute 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, was used to confirm the reporting basis for each data element.

Emergency Preparedness Cornerstone

• Drill/Exercise Performance (DEP)

• Emergency Response Organization (ERO) Readiness

• Alert and Notification System (ANS) Reliability For the specified review period, the inspectors examined data reported to the NRC, procedural guidance for reporting PI information, and records used by the licensee to identify potential PI occurrences. The inspectors verified the accuracy of the PIs for ERO and DEP through review of a sample of drill and event records. The inspectors reviewed selected training records to verify the accuracy of the PI for ERO drill participation for personnel assigned to key positions in the ERO. The inspectors verified the accuracy of the PI for ANS reliability through review of a sample of the licensees records of periodic system tests. The inspectors also interviewed the licensee personnel who were responsible for collecting and evaluating the PI data. Licensee procedures, records, and other documents reviewed within this inspection area, are listed in the

.

This inspection satisfied three inspection samples for PI verification on an annual basis.

b. Findings

No findings were identified.

4OA6 Meetings

On May 13, 2016, the inspection team presented the inspection results to Mr. K. Taber and other members of the plant staff. The inspectors confirmed that no proprietary information was provided during the inspection.

ATTACHMENT: Supplementary Information

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

S. Briggs, Operations Director

M. Brett, Emergency Preparedness Specialist

G. Gunn, Regulatory Affairs Manager

J. Hall, Emergency Preparedness Supervisor (Units 3 and 4)

M. Hayden, Emergency Preparedness Supervisor

M. Johnson, Radiation Protection Manager

L. Mansfield, Fleet Emergency Preparedness Manager

M. Redden, Emergency Preparedness Specialist

K. Taber, Site Vice President

K. Walden, Licensing Engineer

J. Williams, Site Integration Director

LIST OF ITEMS

Opened and Closed

05000424/2016502-01,

05000425/2016502-01 NCV Failure to Adequately Maintain Emergency Response Facilities (Section 1EP4)