IR 05000443/2012503
| ML12151A036 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/29/2012 |
| From: | Christopher Miller Division of Reactor Safety I |
| To: | Freeman P NextEra Energy Seabrook |
| References | |
| EA 12-093 IR-12-503 | |
| Download: ML12151A036 (14) | |
Text
r;-"wUNITED STATESNUCLEAR REGULATORY COi/I]TIISSIONREGION I21OO RENAISSANCE BOULEVARD, SUITE 1OOKING OF PRUSSIA, PENNSYLVANIA 194@2713May 29,2012EA 12-093Mr. Paul FreemanSite Vice President, North RegionSeabrook Nuclear Power PlantNextEra Energy Seabrook, LLCc/o Mr. Michael O'KeefeP.O. Box 300Seabrook. NH 03874
SUBJECT: SEABROOK STATION, UNIT 1 - NRC EVALUATED EMERGENCYPREPAREDNESS EXERCISE INSPECTION REPORT O5OOO443I2O125O3 .PRELIMINARY WHITE FINDING
Dear Mr. Freeman:
On April 19,2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection atyour Seabrook Station, Unit 1. The enclosed inspection report documents the inspection resultswhich were discussed on April 19, 2012, with you and other members of your staff.The inspection examined activities conducted under your license as they relate to safety andcompliance with the Commission's rules and regulations and with the conditions of your license.The inspectors reviewed selected procedures and records, observed activities, and interviewedpersonnel.The enclosed inspection report discusses a finding that has preliminarily been determined to bea White finding with low to moderate safety significance that may require additional NRCinspections. As described in Section 1EP1 of the enclosed report, the finding is related to yourstaff not identifying a weakness associated with a Risk Significant Planning Standard duringyour April 17,2012, full-scale emergency preparedness exercise critique. Since this finding isassociated with a training exercise critique, it did not present an immediate safety concern. Thisfinding was assessed based on the best available information, using the applicable SignificanceDetermination Process (SDP). The basis for the NRC's preliminary significance determinationis described in the enclosed report. The final resolution of this finding will be conveyed in aseparate correspondence.The finding is also an apparent violation of NRC requirements and is being considered forescalated enforcement action in accordance with the Enforcement Policy, which can be foundon the NRC's Web site at http.//www.nrc.gov/about-nrc/regulatory/enforcemenUenforce-pol.html. ln accordance with the NRC Inspection Manual Chapter (lMC) 0609, we intend to complete ourevaluation, using the best available information, and issue our final determination of safetysignificance within 90 days of the date of this letter. The significance determination processencourages an open dialogue between NRC staff and the licensee; however, the dialogueshould not impact the timeliness of the staff's final determination. Before we make a finaldecision on this matter, we are providing you with an opportunity to: (1) attend a RegulatoryConference where you can present to the NRC your perspective on the facts and assumptionsthe NRC used to arrive at the finding and assess its significance, or (2) submit your position onthe finding to the NRC in writing. lf you request a Regulatory Conference, it should be heldwithin 30 days of the receipt of this letter and we encourage you to submit supportingdocumentation at least one week prior to the conference in an effort to make the conferencemore efficient and effective. lf a Regulatory Conference is held, it wilt be open for publicobservation and, to announce the conference, a public meeting notice and press release will beissued. lf you decide to submit only a written response, such submittal should be sent to theNRC within 30 days of your receipt of this letter. lf you decline to request a RegulatoryConference or submit a written response, you relinquish your right to appeal the final SDPdetermination; in that, by not doing either you fail to meet the appeal requirements stated in thePrerequisite and Limitation Sections of Attachment 2 of IMC 0609.lf you disagree with a cross-cutting aspect assignment in this report, you should provide aresponse within 30 days of the date of this inspection report, with the basis for yourdisagreement, to the RegionalAdministrator, Region l, and the NRC Resident Inspector atSeabrook.Please contact Mr. James Trapp, at (610) 337-5186, within 10 days from the issue date of thisletter to notify the NRC of your intentions. lf we have not heard from you within 10 days, we willcontinue with our significance determination and enforcement decision. Since the NRC has notmade a final determination in this matter, no Notice of Violation is being issue for this inspectionfinding at this time. In addition, please be advised that the number and characterization of theapparent violation may change as the result of further NRC review.ln accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, itsenclosure, and your response (if any) will be available electronically for public inspection in theNRC Public Document Room and from the Publicly Available Records (PARS) component ofNRC's Agencywide Documents Access and Management System (ADAMS). ADAMS isaccessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the PublicElectronic Reading Room).Christopher G. Miller,Docket No. 50-443License No: NPF-86Division of Reactor Safety In accordance with the NRC Inspection Manual Chapter (lMC) 0609, we intend to complete ourevaluation, using the best available information, and issue our final determination of safetysignificance within 90 days of the date of this letter. The significance determination processencourages an open dialogue between NRC staff and the licensee; however, the dialogueshould not impact the timeliness of the staff's final determination. Before we make a finaldecision on this matter, we are providing you with an opportunity to: (1) attend a RegulatoryConference where you can present to the NRC your perspective on the facts and assumptionsthe NRC used to arrive at the finding and assess its significance, or (2) submit your position onthe finding to the NRC in writing. lf you request a Regulatory Conference, it should be heldwithin 30 days of the receipt of this letter and we encourage you to submit supportingdocumentation at least one week prior to the conference in an effort to make the conferencemore efficient and effective. lf a Regulatory Conference is held, it will be open for publicobservation and, to announce the conference, a public meeting notice and press release will beissued. lf you decide to submit only a written response, such submittal should be sent to theNRC within 30 days of your receipt of this letter. lf you decline to request a RegulatoryConference or submit a written response, you relinquish your right to appealthe final SDPdetermination; in that, by not doing either you failto meet the appeal requirements stated in thePrerequisite and Limitation Sections of Attachment 2 of IMC 0609.lf you disagree with a cross-cutting aspect assignment in this report, you should provide aresponse within 30 days of the date of this inspection report, with the basis for yourdisagreement, to the Regional Administrator, Region l, and the NRC Resident Inspector atSeabrook.Please contact Mr. James Trapp, at (610) 337-5186, within 10 days from the issue date of thisletter to notify the NRC of your intentions. lf we have not heard from you within 10 days, we willcontinue with our significance determination and enforcement decision. Since the NRC has notmade a final determination in this matter, no Notice of Violation is being issue for this inspectionfinding at this time. In addition, please be advised that the number and characterization of theapparent violation may change as the result of further NRC review.ln accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, itsenclosure, and your response (if any) will be available electronically for public inspection in theNRC Public Document Room and from the Publicly Available Records (PARS) component ofNRC's Agencyvide Documents Access and Management System (ADAMS). ADAMS isaccessibie from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the PublicElectronic Reading Room).
Sincerely,/RNChristopher G. Miller, DirectorDivision of Reactor SafetyDocket No. 50-443License No: NPF-86DOCUMENT NAME: G:\DRS\Plant Support Branch 1\BarAEP Ex12 Seabrook\Seabrook EP EX 2012 Report.docxADAMS ACCESSION NUMBER: M112151,4036V suNstReviewg Non-Sensitive! SensitiveVtrPublicly AvailableNon-Publicly AvailableOFFICERI/DRSRI/DRSRI/ORARI/DRSRI/DRSNAMESBarrABurrittMMcLaughlinJTrappCMillerDATE51231125t2sl125t29t125t251125t29t12COPY
Enclosure:
NRC lnspection Report No. 05000443/2012593
w/Attachment:
Supplemental Informationcc w/encl:S. Coleman, RAC, FEMA Region Icc Mencl: Distribution via ListServ Distribution w/encl: (via E-mail)W. Dean, RA (RIORAMAlL Resource)D. Lew, DRA (RIORAMAlL Resource)D. Roberts, DRP (RI DRPMAIL Resource)J. Clifford, DRP (RlDRPMail Resource)C. Miller, DRS (Rl DRSMail Resource)P. Wilson, DRS (Rl DRSMail Resource)A. Burritt, DRPL. Cline, DRPA. Turilin, DRPR. Montgomery, DRPW. Raymond, DRP, SRIM. Jennerich, DRP, RlJ. DeBoer, Acting RlA. Cass, DRP, Resident AAM. McCoppin, Rl, OEDORidsNrrPMSeabrook ResourceRid s N rrDorlLpll -2 Resou rceROPreports ResourceD. Bearde, DRSS. Barr, DRSJ. Trapp, DRSR. Kahler, NSIRYEPDS. LaVie, NSIRYEPDM. McLaughlin, ORAD. Holody, ORAR. Eul, OEJ. Bowen, NRRS. Coker, NSIR U.S. NUCLEAR REGULATORY COMMISSIONREGION IDocket No.: 50-443License No.: NPF-86Report No.: 05000443/2012503Licensee: NextEra Energy Seabrook, LLCFacility: Seabrook Station, Unit 1Location: Seabrook. NH 03874April 16-19,2012lnspectors: S. Barr, Senior Emergency Preparedness Inspector, DRS, Region I (Lead)W. Raymond, Senior Resident lnspector, DRP, Region IR. Rolph, Health Physicist, DRS, Region IC. Crisden, Emergency Preparedness Inspector, DRS, Region IR. Montgomery, Acting Resident lnspector, DRP, Region IApproved by: James M. Trapp, ChiefPlant Support Branch 1Division of Reactor SafetyEnclosure SUMMARY OF FINDINGSlR 0500044312012503; 411612012-411912012; Seabrook Station, Unit 1; Exercise Evaluation.This was an announced inspection conducted by four region-based inspectors and one residentinspector. One finding with the potential for greater than Green safety significance wasidentified. The significance of most findings is indicated by their color (Green, White, Yellow,Red) using Inspection Manual Chapter (lMC) 0609, "significance Determination Process"(SDP). The cross-cutting aspect was determined using IMC 0310, "Components Within theCross Cutting Areas." Findings for which the SDP does not apply maybe Green or be assigneda severity level after NRC management review. The NRC's program for overseeing the safeoperation of commercial nuclear power reactors is described in NUREG-1649, "ReactorOversight Process," Revision 4, dated December 2006.Cornerstone: Emergency Preparedness. &lilqi!gg[h!!9. The NRC identified an apparent violation (AV) for the licensee'sexercise critique process not properly identifying a weakness associated with a risk-significant planning standard (RSPS) that was determined to be a Drill/ExercisePerformance (DEP) Performance Indicator (Pl) opportunity failure during a full-scaleexercise. The AV is associated with emergency preparedness planning standards 10CFR 50.47(bX14) and 10 CFR 50.47(bX5) and the requirements of Section lV.F.2.g ofAppendix E to 10 CFR Part 50. This finding was entered into the licensee's correctiveaction program.The failure of NextEra to identify the exercise weakness related to an incorrect protectiveaction recommendation (PAR) notification during their exercise critique was aperformance deficiency that was reasonably within NextEra's ability to foresee andprevent. The finding is more than minor because it is associated with the emergencyresponse organization attribute of the Emergency Preparedness Cornerstone andaffected the cornerstone objective to ensure that the licensee is capable of implementingadequate measures to protect the health and safety of the public in the event of aradiological emergency. This finding was determined to potentially have greaterthan-Green safety significance because the licensee's exercise critique process did notproperly identify a weakness associated with a RSPS that was determined to be a DEPPl opportunity failure during a biennial full-participation exercise. The finding is relatedto the cross-cutting area of Problem ldentification and Resolution, Corrective ActionProgram, in that NextEra personnel did not identify a RSPS issue completely,accurately, and in a timely manner commensurate with the safety significance P.1(a).Specifically, during the biennialfull-participation exercise evaluation Next Era failed toidentify a weakness. (Section 1EP1)Enclosure REPORT DETAILS1. REACTORSAFETYCornerstone: Emergency Preparedness (EP)1EP1 Exercise Evaluation (71114.01- 1 Sample)a. lnspection ScopePrior to the April 17,2012, emergency preparedness exercise, the NRC inspectorsconducted an in-office review of the exercise objectives and scenario, which NextErahad submitted to the NRC, to determine if the exercise would test major elements of theSeabrook Emergency Plan as required by 10 CFR 50.47(bX14). This overall exerciseinspection activity represented the completion of one sample on a biennial cycle.The exercise evaluation consisted of the following review and assessment:o The adequacy of NextEra's performance in the biennial full-participation exerciseregarding the implementation of the risk-significant planning standards (RSPS)described in 10 CFR 50.47(bX4), (5), (9), and (10), which are: emergencyclassification; offsite notification; radiological assessment; and protective actionrecom mendations, respectively.o The overall adequacy of NextEra's Seabrook emergency response facilities withregard to NUREG-0696, "Functional Criteria for Emergency Response Facilities,"and Emergency Plan commitments. The facilities assessed were the Control RoomSimulator, Operations Support Center (OSC), Technical Support Center (TSC), andEmergency Operations Facility (EOF).o fl review of other performance areas, such as: the Seabrook emergency responseorganization's (ERO's) recognition of abnormal plant conditions; command andcontrol; 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 emergencyplan and its implementing procedures.o A review of past performance issues from the last NRC Seabrook exerciseinspection report and NextEra's Seabrook EP drill reports, to determine theeffectiveness of licensee corrective actions as demonstrated during the April 17,2012, exercise and to ensure compliance with 10 CFR 50.47(b)(14).e The licensee's post-exercise critiques, to evaluate NextEra's self-assessment of itsERO performance during the April 17 , 2012, exercise and to ensure compliancewith 10 CFR 50, Appendix E, Section lV.F.2.g.Enclosure 2The inspectors reviewed the documents listed in the attachment to this report.Findinqslntroduction. The NRC identified a preliminary white significance apparent violationassociated with emergency preparedness planning standards 10 CFR 50.47(bX14)and10 CFR 50.47(bX5) and the requirements of Section lV. F.2.9 of Appendix E to 1 0 CFRPart 50. Specifically, NextEra staff did not identify a deficiency related to a risksignificant planning standard (RSPS) during their critique following the full-participationemergency preparedness exercise.Description. On April 17,2012, the NRC inspection team observed the NextEraSeabrook full scale emergency planning exercise. For the exercise, the EmergencyOperating Facility (EOF) Coordinator held the dual responsibility as the lead doseassessor for PAR preparation and as the offsite notification communicator. At 1 1 15, thelicensee declared a General Emergency (GE) in the exercise due to a simulated largebreak loss of coolant accident. The EOF Coordinator initiated action to develop therequired PAR and associated offsite notification form. This included verification of thestatus of any radiological release that might be occurring from the site. As part of thatprocess, he requested the meteorological tower lower elevation wind direction from thedose assessment team. Station procedures required that the lower elevation winddirection be used for no-release conditions, which the EOF Coordinator believed was thecase. lf the licensee had been aware that a release was in progress, the procedurewould have directed the EOF Coordinator to use the upper elevation wind direction todevelop the PAR. In response to the EOF Coordinator request, the EOF doseassessment staff, which also did not recognize a release was in progress, incorrectlyprovided the upper elevation wind direction (81-degrees) instead of the lower elevationwind direction (146-degrees). The EOF Coordinator used the upper elevation winddirection to develop the PAR, thinking he was using the lower wind direction. At 1128,the EOF Coordinator notified the State Emergency Operation Centers of the GE and thePAR. The EOF Coordinator believed he was notifying the States of a PAR for norelease in progress, but because of the EOF dose assessment error of providing thewind direction used for release conditions, the PAR was actually correct per the exercisescenario (i.e., a release was occurring). The radiological release condition was,however, inaccurately reported on the notification form as "A radiological release has notoccurred."The licensee's critique, conducted on April 17-19, 2012, determined that the notificationof the GE and the initial PAR was successful due to the notified PAR being the PARanticipated by the scenario. The critique did not identify the error in the description ofrelease status contained on the notification form or the error made by the EOFCoordinator and the dose assessment staff in assessing the meteorological conditionsthat existed when the initial PAR was developed. NextEra counted the offsite notificationassociated with the initial GE declaration as a successful Drill and Exercise Performance( DEP) performance ind icator ( Pl ) opportunity.The inspectors identified a performance deficiency involving the failure by the licensee toidentify a RSPS weakness associated with the errors on the offsite notification form andEnclosure 3the errors involved in the development of the PAR, which was determined to be a DEPPl opportunity failure. A weakness, as defined by the NRC in the EmergencyPreparedness Significance Determination Process (Appendix B to IMC 0609), is a levelof ERO performance demonstrated during an exercise that would preclude effectiveimplementation of the Emergency Plan, if the weakness were to occur during an actualemergency. Nuclear Energy lnstitute (NEl) 99-02, "Regulatory AssessmentPerformance Guideline," states that for a DEP Pl opportunity to be successful, therelease status must be correctly indicated on the notification form, which was not thecase for this notification.When the inspector described the observed performance deficiencies at the exit meetingfollowing the licensee's critique, NextEra initiated Action Report (AR) 01766946 toinvestigate the discrepancies and place the NRC's findings in the Seabrook correctiveaction programAnalysis. The inspection team determined that the failure by NextEra to identify theexercise weakness related to the PAR notification during their exercise critique was aperformance deficiency that was reasonably within their ability to foresee and prevent.The finding is more than minor because it is associated with the emergency responseorganization (ERO) attribute of the Emergency Preparedness Cornerstone and affectedthe cornerstone objective to ensure that the licensee is capable of implementingadequate measures to protect the health and safety of the public in the event of aradiological emergency. Specifically, the failure of NextEra personnel to effectivelyidentify an exercise weakness associated with a RSPS caused a missed opportunity toidentify and correct an exercise-related performance deficiency.The inspectors assessed the more significant issue, related to the failure to accuratelycommunicate the radiological release status on the notification form, using theEmergency Preparedness Significance Determination Process (Appendix B to IMC0609) and preliminarily determined the finding to be of low to moderate safetysignificance (White). A loss of planning standard (PS) function occurred when theexercise critique process failed to identify a weakness associated with a RSPS that isdetermined by the NRC to be a DEP Pl opportunity failure during a full-participationexercise" NextEra's failure to critique the inaccurate notification met the NRC's definitionof a weakness that was a DEP Pl opportunity failure in a full-participation exercise and isconsidered a loss of PS function and a white finding. Appendix B to IMC 0609, Section5.14, Figure 5.14-1and Table 5.14-2, was used to reach this preliminary determination.The finding is related to the cross-cutting area of Problem ldentification and Resolution,Corrective Action Program, in that NextEra personnel did not identify a RSPS issuecompletely, accurately, and in a timely manner commensurate with the safetysignificance P.1(a). Specifically, during the biennial exercise evaluation, Next Erafailed to recognize and critique that a RSPS was not met and did not place this issue intothe corrective action program until prompted by the NRC team's findings.Enclosure 4Enforcement. Title 10 of the Code of Federal Regulations (CFR), Section 50.54(q)(2)requires, in part, that a licensee shall follow and maintain the effectiveness of anemergency plan that meets the requirements in appendix E to this part and, for nuclearpower reactor licensees, the planning standards of $ 50.47(b).10 CFR 50.47(bX14) requires, in part, that periodic exercises be conducted to evaluatemajor portions of emergency response capabilities and that deficiencies identified as aresult of exercises are corrected.Section lV.F.2.g of Appendix E to 10 CFR Part 50 requires that all training, includingexercises, shall provide for formal critiques in order to identify weak or deficient areasthat need correction. Any weaknesses or deficiencies that are identified shall becorrected.Contrary to the above, during the April 19, 2012, critique of the April 17 , 2012, SeabrookStation biennial emergency preparedness exercise, NextEra did not identify aperformance weakness. Specifically, NextEra did not identify as a weakness that: 1) aninaccurate notification concerning the status of radiological releases from the site hadbeen made to the required State response organizations; and, 2) an incorrect winddirection indication had been requested for determining the appropriate PAR.Pending determination of the final safety significance, this finding with the associatedapparent violation will be tracked as AV 05000443/2012503-001, Failure of ExerciseGritique to identify a RSPS Weakness as a DEP Pl Opportunity Failure.4. OTHER ACTIVITTES (OA)4OA1 Performance lndicator (Pl) Verification (71151- 3 Samples)a. lnspection ScopeThe inspectors reviewed data for the Seabrook EP Pls, which are: (1) Drill and ExercisePerformance (DEP); (2) Emergency Response Organization (ERO) Drill Participation;and, (3) Alert and Notification System (ANS) Reliability. The last NRC EP inspection atSeabrook was conducted in the fourth calendar quarter of 2011, so the inspectorsreviewed supporting documentation from EP drills, training records, and equipment testsfrom the fourth calendar quarter of 2011 through the first quarter of 2012, to verify theaccuracy of the reported Pl data. The review of these Pls was conducted in accordancewith NRC Inspection Procedure 71151, using the acceptance criteria documented in NEI99-02, "Regulatory Assessment Performance Indicator Guidelines," Revision 6.This inspection activity represented the completion of three samples.b. FindinqsNo findings were identified.Enclosure 54OAO Meetinos, includinq ExitOn April 19,2012, the inspectors presented the results of this inspection toMr. P. Freeman, Seabrook Site Vice President, and other members of the NextEra staff.No proprietary information was provided to the inspectors during this inspection.Enclosure A-1ATTACHMENTSUPPLEMENTAL I N FORMATIONKEY POINTS OF GONTACTLicensee PersonnelP. Freeman, Site Vice PresidentD. Currier, Emergency Preparedness ManagerLIST OF ITEMS OPENED, GLOSED, AND DISCUSSEDOpened05000443/2012503-001 AV Failure of Exercise Critique to ldentify an RSPSWeakness as a DEP Pl Opportunity FailureLIST OF DOCUMENTS REVIEWEDSection 1EP1: Exercise EvaluationSeabrook April 17, 2012, Emergency Exercise Data PackageSeabrook Station Radiological Emergency Plan, Revision 59Seabrook Station Emergency Response Manual, Revision 120Seabrook Emergency Response Drill Reports, January 2011 - Aprll2012ER 1.1, Classification of Emergencies, Revision 50ER 1.2, Emergency Plan Activation, Revision 57ER 2.0, Emergency Notification Documentation Forms Procedure, Revision 34ER 3.1, Technical Support Center Operations, Revision 52ER 3.2, Operations Support Center Operations, Revision 45ER 3.3, Emergency Operations Facility Operations, Revision 48ER 4.3, Radiation Protection During Emergency Conditions, Revision 29ER 5.4, Protective Action Recommendations, Revision 32ER 5.7, lnitial Offsite Dose Projection, Revision 33Action Report 01766946Section 4OAl : Performance Indicator VerificationEPDP-03, Emergency Preparedness Performance I ndicators, Revision 21ERO Drill Participation Pl data, October 2011 -March2012Alert Notification System Pl data, October 2011 -March2012DEP Pl data, October 2011 - March 2012 A-2LIST OF ACRONYMSAR Action RequestANS Alert and Notification SystemAV Apparent ViolationCFR Code of Federal RegulationsDEP Drill and Exercise PerformanceEAL Emergency Action LevelEOF Emergency Operations FacilityEP Emergency PreparednessERO Emergency Response OrganizationGE General EmergencyIMC Inspection Manual ChapterNEI Nuclear Energy lnstituteNRC Nuclear Regulatory CommissionOSC Operations Support CenterPl Performance IndicatorPS Planning StandardRSPS Risk Significant Planning StandardSDP Significance Determination ProcessTSC Technical Support Center