IR 05000293/2008502
Download: ML081350151
Text
May 13, 2008
Mr. Kevin Bronson Site Vice President Entergy Nuclear Operations, Inc. Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508
SUBJECT: PILGRIM NUCLEAR POWER STATION - NRC EVALUATED EMERGENCY PREPAREDNESS EXERCISE - INSPECTION REPORT NO. 05000293/2008502
Dear Mr. Bronson:
On April 4, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection of the 2008 evaluated emergency preparedness exercise at your Pilgrim Nuclear Power Station. The enclosed inspection report documents the inspection results, which were discussed on April 4, 2008, 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 Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. Based on the results of this inspection, no findings of significance were identified. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document 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/ James A. Trapp, Chief Plant Support Branch 1 Division of Reactor Safety Docket Nos. 50-293 License Nos. DPR-35
Enclosure:
NRC Inspection Report 05000293/2008502 May 13, 2008 Mr. Kevin Bronson Site Vice President Entergy Nuclear Operations, Inc. Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508 SUBJECT: PILGRIM NUCLEAR POWER STATION - NRC EVALUATED EMERGENCY PREPAREDNESS EXERCISE - INSPECTION REPORT NO. 05000293/2008502 Dear M
SUMMARY OF FINDINGS
IR 05000293/2008502; 04/01-04/2008; Pilgrim Nuclear Power Station; Exercise Evaluation; Emergency Action Level and Emergency Plan Changes; Emergency Preparedness Performance Indicators.
This was an announced inspection conducted by five region-based inspectors. No findings of significance were identified. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.
Cornerstone: Emergency Preparedness
A. NRC-Identified and Self-Revealing Findings
No findings of significance were identified. B. Licensee-Identified Findings None.
1
REPORT DETAILS
REACTOR SAFETY
Cornerstone:
Emergency Preparedness (EP) 1EP1 Exercise Evaluation (71114.01 - 1 Sample)
a. Inspection Scope
Prior to the April 2, 2008, emergency preparedness exercise, the NRC inspectors conducted an in-office review of the exercise objectives and scenario, which Entergy had submitted to the NRC, to determine if the exercise would test major elements of the Pilgrim emergency plan as required by 10 CFR 50.47(b)(14). This overall exercise inspection activity represented the completion of one sample on a biennial cycle. The exercise evaluation consisted of the following review and assessment:
- The adequacy of Pilgrim's performance in the biennial full-participation exercise regarding the implementation of the risk-significant planning standards (RSPS) described in 10 CFR 50.47(b)(4), (5), (9), and (10), which are: emergency classification; offsite notification; radiological assessment; and, protective action recommendations, respectively.
- The overall adequacy of Pilgrim's 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 (TSC), Operations Support Center (OSC), and Emergency Operations Facility (EOF).
- A review of other performance areas, such as: the emergency response organization's (ERO's) recognition of abnormal plant conditions; command and control; intra- and inter-facility communications; prioritization of mitigating activities; utilization of repair and field monitoring teams; interface with offsite agencies; staffing and procedure adequacy; and, the overall implementation of the emergency plan and its implementing procedures.
- A review of past performance issues from the last NRC exercise inspection report and Pilgrim's EP drill reports, to determine the effectiveness of licensee corrective actions as demonstrated during the April 2 exercise and to ensure compliance with 10 CFR 50.47(b)(14).
- The licensee's post-exercise critiques, to evaluate Pilgrim's self-assessment of its ERO performance during the April 2 exercise and to ensure compliance with 10 CFR 50, Appendix E, Section IV.F.2.g. The inspectors reviewed the documents listed in the attachment to this report.
b. Findings
No findings of significance were identified. 1EP4 Emergency Action Level (EAL) and Emergency Plan Changes (71114.04 - 1 Sample)
a. Inspection Scope
Since the last NRC inspection of this program area, Revision 33 of the Pilgrim Nuclear Power Station Emergency Plan was implemented by Entergy. Entergy determined that in accordance with 10 CFR 50.54(q), the changes resulted in no decrease in effectiveness of the Plan, and that the revised Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR 50. The inspectors reviewed all EAL changes made since June 2007, and conducted a sampling review of other Emergency Plan changes, including changes to lower-tier emergency plan implementing procedures, to evaluate for any potential decreases in effectiveness of the Emergency Plan. However, this review was not documented in a Safety Evaluation Report and does not constitute formal NRC approval of the changes. Therefore, these changes remain subject to future NRC inspection in their entirety.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES (OA)
4OA1 Performance Indicator (PI) Verification (71151 - 3 Samples)
a. Inspection Scope
The inspectors reviewed data for the Pilgrim EP PIs, which are: (1) Drill and Exercise Performance (DEP); (2) Emergency Response Organization (ERO) Drill Participation; and, (3) Alert and Notification System (ANS) Reliability. The last EP inspection at Pilgrim was conducted in the second quarter of 2007, so the inspectors reviewed supporting documentation from EP drills and tests from the second, third, and fourth calendar quarters of 2007 to verify the accuracy of the reported PI data. The review of these PIs was conducted in accordance with NRC Inspection Procedure 71151, using the acceptance criteria documented in NEI 99-02, "Regulatory Assessment Performance Indicator Guidelines," Revision 5. This inspection activity represented the completion of three samples on an annual cycle.
b. Findings
No findings of significance were identified.
4OA6 Meetings, Including Exit
On April 4, 2008, the inspectors presented the results of this inspection to Mr. K. Bronson, the Pilgrim Site Vice President, and other members of the Pilgrim staff. No proprietary information was provided to the inspectors during this inspection.
ATTACHMENT
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- T. Sowdon, Pilgrim Emergency Preparedness Manager
- N. Avrakotos, Entergy Emergency Planning Senior Manager
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
None
LIST OF DOCUMENTS REVIEWED
Section 1EP1: Exercise Evaluation Pilgrim Nuclear Power Station Emergency Plan (Revision 33) Pilgrim Nuclear Power Station Emergency Plan Implementing Procedures Pilgrim Nuclear Power Station April 2, 2008, Emergency Exercise Scenario Package Pilgrim Nuclear Power Station Emergency Preparedness Drill Reports, January 2007 - March 2008
Condition Reports
written for the April 2, 2008, exercise:
- CR-PNP-2008-0796, -1080, 1084, 1093, 1105, 1107, 1108, 1109, 1111, 1200, 1215, 1216,
- 1218, 1219, 1220, 1222, 1234, 1235, 1236, 1238, 1241, 1344
Section 1EP4: Emergency Action Level and Emergency Plan Changes Procedure
- EN-LI-100, Process Applicability Determination (Rev. 6)
Procedure
- EN-LI-113, Licensing Basis Document Change Process (Rev. 2) Procedure
- EN-EP-305, Emergency Planning 10CFR50.54(q) Review Process (Rev. 1) 10
- CFR 50.54(q) Reviews, Performed June 2007 - March 2008
Section 4OA1: Performance Indicator Verification Procedure
- EN-LI-114, Performance Indicator Process (Rev. 3) Procedure
- EN-EP-201, Performance Indicators (Rev. 6) ERO Drill Participation PI data, April 2007 - December 2007 Public Notification System PI data, April 2007 - December 2007
LIST OF ACRONYMS
- RS [[]]
PS Risk Significant Planning Standard