IR 05000346/2015502
| ML15161A616 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 06/10/2015 |
| From: | Steven Orth Plant Support Branch II |
| To: | Lieb R FirstEnergy Nuclear Operating Co |
| References | |
| IR 2015502 | |
| Download: ML15161A616 (13) | |
Text
UNITED STATES une 10, 2015
SUBJECT:
DAVIS-BESSE NUCLEAR POWER STATION, UNIT 1 BASELINE EMERGENCY PREPAREDNESS BIENNIAL EXERCISE INSPECTION REPORT 05000346/2015502
Dear Mr. Lieb:
On May 8, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed a baseline emergency preparedness biennial exercise inspection at the Davis-Besse Nuclear Power Station, Unit 1. The enclosed report documents the results of this inspection, which were discussed on May 8, 2015, with you 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. No findings were identified during this inspection.
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 "Rules of Practice," 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 the NRC's Agencywide Documents Access and Management 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 Joseph Maynen Acting for/
Steven K. Orth, Chief Plant Support Branch Division of Reactor Safety Docket No. 50-346 License No. NPF-3
Enclosure:
IR 05000346/2015502 w/Attachment: Supplemental Information
REGION III==
Docket No. 50-346 License No. NPF-3 Report No: 05000346/2015502 Licensee: FirstEnergy Nuclear Operating Co.
Facility: Davis-Besse Nuclear Power Station Location: Oak Harbor, OH Dates: May 4 - May 8, 2015 Inspectors: M. Garza, Emergency Preparedness Inspector J. Beavers, Emergency Preparedness Inspector J. Maynen, Physical Security Inspector D. Kimble, Senior Resident Inspector M. Marshfield, Senior Resident Inspector J. Seymour, Operations Engineer Approved by: S. Orth, Chief Plant Support Branch Division of Reactor Safety Enclosure
SUMMARY OF FINDINGS
IR 05000346/2015502; 05/04/15 - 05/08/15; Davis-Besse Nuclear Power Station, Unit 1;
Baseline Emergency Preparedness Exercise Evaluation - Hostile Action Event; Exercise Evaluation Scenario Review; Performance Indicator Verification.
This report covers a one-week period of announced baseline inspection by three regional inspectors and three resident inspectors. The significance of most findings is indicated by their color (i.e., Green, White, Yellow, and Red) using Inspection Manual Chapter 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after U.S. Nuclear Regulatory Commission (NRC) management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5, dated February 201
NRC-Identified
and Self-Revealed Findings
Cornerstone: Emergency Preparedness
No findings were identified.
Licensee-Identified Violations
The violations of very low safety or security significance or Severity Level IV that were identified by the licensee, have been reviewed by the NRC. Corrective actions taken or planned by the licensee have been entered into the licensees Corrective Action Program. These violations and corrective actions tracking numbers are listed in Section 4OA7 of this report.
REPORT DETAILS
REACTOR SAFETY
Cornerstone: Emergency Preparedness
1EP7 Exercise Evaluation - Hostile Action Event
.1 Exercise Evaluation
a. Inspection Scope
Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Appendix E,Section IV.F.2.j, requires, in part, that nuclear power reactor licensees, in each eight calendar year exercise cycle, provide the opportunity for their Emergency Response Organization (ERO) to demonstrate proficiency in the key skills necessary to respond to a Hostile Action (HA) event directed at the plant site. Davis-Besse Nuclear Power Station staff designed the May 5, 2015, exercise to satisfy this requirement. The U.S. Nuclear Regulatory Commission (NRC) inspected this HA exercise to assess the licensees ability to effectively implement their Emergency Plan during a HA event and adequately protect public health and safety.
The exercise evaluation consisted of the following reviews and assessments:
- The adequacy of the licensees performance in the biennial exercise conducted on May 5, 2015, 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 Emergency Operations Facility, the Alternate Technical Support Center, the Operations Support Center mustering area and the control room simulator.
- A review of other performance areas such as the licensee EROs recognition of abnormal plant conditions; command and control, including interactions with site security staff; intra- and inter-facility communications; prioritization of mitigating activities; utilization of repair and field monitoring teams; interface with offsite agencies, including local law enforcement agencies; staffing and procedure adequacy; and the overall implementation of the Emergency Plan and its implementing procedures.
- Past performance issues from NRC inspection reports to determine the effectiveness of corrective actions, as demonstrated during this exercise, to ensure compliance with 10 CFR 50.47(b)(14).
- The adequacy of the licensees post-exercise critiques, to evaluate the Davis-Besse Nuclear Power Station self-assessment of its ERO performance during the May 5, 2015, exercise, and to ensure compliance with 10 CFR Part 50, Appendix E, Section IV.F.2.g.
The inspectors reviewed various documents that are listed in the Attachment to this report. This inspection activity satisfied one inspection sample for the exercise evaluation on a biennial basis.
This exercise evaluation inspection constituted one sample as defined in Inspection Procedure (IP) 71114.07-06.
b. Findings
No findings were identified.
1EP8 Exercise Evaluation - Scenario Review
a. Inspection Scope
Prior to the exercise, the inspectors conducted an in-office review of the exercise objectives and scenarios 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). This inspection activity represents one sample on a biennial cycle.
The inspectors reviewed various documents that are listed in the Attachment to this report. This inspection activity satisfied one inspection sample for the exercise evaluation on a biennial basis.
This review of the exercise objectives and scenario constituted one sample as defined in IP 71114.08-06.
b. Findings
No findings were identified.
OTHER ACTIVITIES
Cornerstone: Emergency Preparedness
4OA1 Performance Indicator Verification
.1 Drill/Exercise Performance
a. Inspection Scope
The inspectors sampled licensee submittals for the Drill/Exercise Performance (DEP)
Performance Indicator (PI) for the period from the third quarter of 2014 through the first quarter of 2015. To determine the accuracy of the DEP data reported during those periods, PI definitions and guidance contained in the Nuclear Energy Institute (NEI)document NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, was used. The inspectors reviewed the licensees records associated with the PI to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the NEI guidance. Specifically, the inspectors reviewed licensee records and processes, including procedural guidance on assessing opportunities for the PI, assessments of PI opportunities during pre-designated control room simulator training sessions, and performance during other drills. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one DEP sample as defined in IP 71151-05.
b. Findings
No findings were identified.
.2 Emergency Response Organization Drill Participation
a. Inspection Scope
The inspectors sampled licensee submittals for the ERO Drill Participation PI for the period from the third quarter of 2014 through the first quarter of 2015. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, was used. The inspectors reviewed the licensees records associated with the PI to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the NEI guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the PI, performance during the 2013 and 2014 drills, and revisions of the roster of personnel assigned to key ERO positions. Documents reviewed are listed in the Attachment to this report.
This inspection constituted one ERO Drill Participation sample as defined in IP 71151-05.
b. Findings
No findings were identified.
.3 Alert and Notification System
a. Inspection Scope
The inspectors sampled licensee submittals for the Alert and Notification System (ANS)
PI for the period from the third quarter of 2014 through the first quarter of 2015. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, was used. The inspectors reviewed the licensees records associated with the PI to verify that the licensee accurately reported the indicator in accordance with relevant procedures and the NEI guidance. Specifically, the inspectors reviewed licensee records and processes including procedural guidance on assessing opportunities for the PI and results of periodic scheduled ANS operability tests.
Documents reviewed are listed in the Attachment to this report.
This inspection constituted one ANS sample as defined in IP 71151-05.
b. Findings
No findings were identified.
4OA6 Management Meetings
.1 Exit Meeting Summary
On May 8, 2015, the inspectors presented the biennial exercise inspection results to Mr. Raymond Lieb, Site Vice President, and other members of the licensee staff.
The licensee acknowledged the issues presented.
The inspectors confirmed that none of the potential report input discussed was considered proprietary.
.2 Public and Media Briefing
On May 8, 2015, the inspectors summarized the NRCs preliminary exercise inspection conclusions at a public and media briefing hosted by Department of Homeland Security/Federal Emergency Management Agency, Region V, Field Office staff, at the Ottawa County Emergency Operations Center, in Port Clinton, Ohio.
4OA7 Licensee-Identified Violations
The licensee-identified a finding of very low safety significance (Green) and an associated violation of 10 CFR 50.54 (q)(2) and 10 CFR Part 50.47(b)(14).
Title 10 CFR 50.54(q)(2), requires, in part, that a holder of a license under this part, shall follow and maintain the effectiveness of an emergency plan that meets the requirements of Appendix E, of Part 50, and for nuclear power reactor licensees, the planning standards of 10 CFR 50.47(b). Title 10 CFR 50.47(b)(14) requires, in part, that Periodic Exercises are (will be) conducted to evaluate major portions of emergency response capabilities, periodic drills are (will be) conducted to develop and maintain key skills, and deficiencies identified as a result of exercises or drills are (will be) corrected.
Section 8.1.2.c.6 of the Davis-Besse Nuclear Power Station Emergency Plan, Revision 30, states, Semiannual Health Physics drills will be conducted which involve response to, and analysis of, simulated elevated airborne and liquid samples and direct radiation measurements in the environment. Contrary to the above, from mid-2013 to the end of 2014, the licensee failed to comply with the established drill and exercise program. Specifically, the health physics drill objectives were only being partially met during this time period. The drill scenarios were limited and did not provide an opportunity for the participants to complete sampling/analysis of liquid samples. As part of the corrective actions after the discovery of this issue, the licensees Emergency Response Staff conducted a drill on December 11, 2014, to ensure that all aspects of the Health Physics drill objectives were met.
The performance deficiency was more than minor because the issue was associated with the Emergency Preparedness cornerstone and adversely affected the associated cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Specifically, the drill scenarios were limited in scope and health physics objectives specified in the emergency plan, were not carried out fully during exercises and drills, that were conducted in the middle of 2013 through the end of 2014. The NRC determined that this was a failure to comply with the licensees emergency plan and a degradation of a planning standard function in accordance with 10 CFR, Part 50.47(b)(14), and was a very low safety significance issue (Green) as indicated in Inspection Manuel Chapter 0609, Emergency Preparedness SDP, Appendix B, 2, Failure to Comply Significance Logic. Because the finding is of very low safety significance (Green) and it was entered into the licensees Corrective Action Program as Condition Report, CR-2014-16715, this violation is being treated as an non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- R. Lieb, Site Vice President
- T. Summers, Plant Manager
- J. Vetter, Emergency Response Manager
- V. Wadsworth, Senior Nuclear Engineering Specialist
- D. Imlay, Performance Improvement Director
- D. Hartuett, Operations Training Superintendent
- G. Laird, Technical Services Manager
- G. Wolf, Regulatory Compliance Supervisor
- B. Jackway, Site Protection Training Supervisor
- G. Cramer, Security Manager
- B. Mady, Plant Engineering Manager
- J. Phillips, Operations Services Superintendent
- D. Saltz, Maintenance Director
- P. McCluskey, Regulatory Compliance Manager
- A. Dawson, Chemistry Manager
- D. Noble, Radiation Protection Manager
- S. Hower, Senior Safety Representative
U.S. Nuclear Regulatory Commission
- D. Kimble, Senior Resident Inspector
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened, Closed, and Discussed
None