IR 05000237/2009502

IR 05000237-09-502, 05000249-09-502, on 03/23/2009 - 03/27/2009, Dresden Nuclear Power Station, Units 2 and 3; Baseline Emergency Preparedness Biennial Exercise Inspection

ML091110223
Person / Time
Site:	Dresden
Issue date:	04/15/2009
From:	Hironori Peterson Operations Branch III
To:	Pardee C G Exelon Generation Co, Exelon Nuclear
References
IR-09-502
Download: ML091110223 (13)

Text

April 15, 2009

Mr. Charles Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer (CNO), Exelon Nuclear 4300 Winfield Road Warrenville IL 60555

SUBJECT: DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 BASELINE EMERGENCY PREPAREDNESS BIENNIAL EXERCISE INSPECTION REPORT 05000237/2009502; 05000249/2009502

Dear Mr. Pardee:

On March 27, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed a Baseline Emergency Preparedness Biennial Exercise inspection at your Dresden Nuclear Power Station, Units 2 and 3. The enclosed report documents the inspection findings, which were discussed on March 27, 2009, with Mr. S. Marik 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 NRC-identified and no self-revealed 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 will be made 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/

Hironori Peterson, Chief Operations Branch Division of Reactor Safety Docket Nos. 50-237; 50-249 License Nos. DPR-19; DPR-25

Enclosure:

Inspection Report 05000237/2009502; 05000249/2009502

w/Attachment:

Supplemental Information See Attached Distribution Mr. Charles

SUMMARY OF FINDINGS

IR 05000237/2009502, 05000249/2009502; 03/23/2009 - 03/27/2009; Dresden Nuclear Power Station, Units 2 and 3; Baseline Emergency Preparedness Biennial Exercise Inspection. This report covers a 1 week period of announced baseline inspection by two regional inspectors and one resident inspector. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination

Process" (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. 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.

A. NRC-Identified

and Self-Revealed Findings

Cornerstone: Emergency Preparedness

No findings of significance were identified.

B. Licensee-Identified Violations

No violations of significance were identified.

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REPORT DETAILS

REACTOR SAFETY

Cornerstone:

Emergency Preparedness

1EP1 Exercise Evaluation

.1 Exercise Evaluation

a. Inspection Scope

The inspectors reviewed the March 25, 2009, biennial emergency preparedness exercise's objectives and scenario to ensure that the exercise would acceptably test major elements of the licensee's emergency plan and to verify that the exercise's simulated problems provided an acceptable framework to support demonstration of the licensee's capability to implement its plan. The inspectors also reviewed records of other drills and exercises conducted in 2007, 2008, and 2009, to verify that those drills' scenarios were sufficiently different from the scenario used in the March 25, 2009, exercise. The inspectors evaluated the licensee's exercise performance, focusing on the risk significant activities of emergency classification, notification, and protective action decision making, implementation of accident mitigation strategies, and correction of past exercise weaknesses in the following emergency response facilities:

• Control Room Simulator (CRS);

• Technical Support Center (TSC); and

• Emergency Operations Facility (EOF). The inspectors also assessed the licensee's 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 licensee's emergency plan. The inspectors attended post-exercise critiques in the CRS, TSC, and EOF to evaluate the licensee's initial self-assessment of its exercise performance. The inspectors later met with the licensee's lead exercise evaluators and managers to obtain the licensee's findings and assessments of its exercise participants' performances. These self-assessments were then compared with the inspectors' independent observations and assessments to assess the licensee's ability to adequately critique its exercise performance. Documents reviewed are listed in the Attachment to this report. This exercise evaluation inspection constituted one sample as defined in Inspection Procedure (IP) 71114.01-05.

b. Findings

No findings of significance were identified.

4OA1 Performance Indicator (PI) Verification

.1 Drill/Exercise Performance

a. Inspection Scope

The inspectors sampled licensee submittals for the Drill/Exercise Performance PI for the period from the 4 th quarter 2007 through the 4 th quarter 2008. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the Nuclear Energy Institute (NEI) Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 5, were used. The inspectors reviewed the licensee's 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, performance during the 2008 off-year exercise, and performance during other drills. Documents reviewed are listed in the Attachment to this report.

This inspection constituted one Drill/Exercise Performance sample as defined in IP 71151-05.

b. Findings

No findings of significance were identified.

.2 Emergency Response Organization Drill Participation

a. Inspection Scope

The inspectors sampled licensee submittals for the Emergency Response Organization (ERO) Drill Participation PI for the period from the 4 th quarter 2007 through the 4 th quarter 2008. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 5, were used. The inspectors reviewed the licensee's 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 2008 off-year exercise and other drills; and revisions of the roster of personnel assigned to key emergency response organization 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 of significance were identified.

4.3 Alert and Notification System

a. Inspection Scope

The inspectors sampled licensee submittals for the Alert and Notification System (ANS) performance indicator for the period from the 4 th quarter 2007 through the 4 th quarter 2008. To determine the accuracy of the PI data reported during those periods, PI definitions and guidance contained in the NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 5, were used. The inspectors reviewed the licensee's 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 ANS operability tests.

Documents reviewed are listed in the Attachment to this report. This inspection constituted one alert and notification system sample as defined in IP 71151-05.

b. Findings

No findings of significance were identified.

4OA5 Other Activities

.1 (Closed) NRC Temporary Instruction (TI) 2515/175 "Emergency Response Organization, Drill/Exercise Performance Indicator, Program Review

" The inspector performed TI 2515/175, ensured the completeness of the TI's Attachment 1 and then forwarded the data to NRC, Headquarters

4OA6 Management Meetings

.1 Exit Meeting Summary

On March 27, 2009, the inspectors presented the inspection results to Mr. S. Marik, 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. The inspectors confirmed that none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

S. Merik, Plant Manger

K. Appel, Corporate Emergency Preparedness Manager

D. Leggett, Nuclear Oversight Manger

R. Luburn, Radiation Protection

T. Mohr, Engineering

P. Quealy, Emergency Preparedness Manager

S. Taylor, Regulatory Assurance Manager

S. Vercelli, Acting Work Management Director Nuclear Regulatory Commission

D. Meléndez-Colón, Resident Inspector

LIST OF ITEMS

OPENED, CLOSED AND DISCUSSED

Opened, Closed, and Discussed

None

LIST OF DOCUMENTS REVIEWED

The following is a list of documents reviewed during the inspection.

Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that selected sections of portions of the documents were evaluated as part of the overall inspection effort.

Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report.

EMERGENCY PLAN AND PROCEDURES Number Description or Title Date or RevisionEP-AA-1000 Exelon Nuclear Standardized Radiological Emergency Plan

EP-AA-1004 Exelon Nuclear Radiological Emergency Plan Annex for Dresden Station

EP-MW-110-200 Dose Assessment 7

EP-AA-111 Emergency Classification and Protective Action Recommendations

EP-AA-111-F-04 Dresden Plant Based PAR Flowchart C

EP-AA-112-400 Emergency Operations Facility Activation and Operation

EP-AA-113 Personnel Protective Action 9

2EXERCISE RECORDS Number Description or TitleDate or Revision Dresden Station 2009 NRC Graded Exercise Scenario Manual

February 25, 2009 Drill and Exercise Scenario Timelines March 21, 2007 - March 27, 2009

Corrective Action Program Items Identified during Drills and Exercises June 28, 2006 - October 8, 2008 Self-Assessment Report

862747 NRC EP Exercise Inspection Readiness February 17, 2009

CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED Number Description or TitleDate or Revision

AR 00618849 2007 Exercise EOF Unable to Establish Correct Release Path April 18, 2007

AR 00611051 2007 Exercise TSC Team Classification and Delays March 30, 2007

AR 00611004 2007 Exercise Scenario Improvement Items March 31, 2007

AR 00607981 2007 Exercise Management and Scenario Control Weakness March 21, 2007

AR 00607546 2007 Exercise NOS OSC Critique Issues March 21, 2007

AR 00607089 2007 Exercise Simulator Failure March 21, 2007

AR 00607079 2007 Exercise NOS TSC Problem Observations March 21, 2007

PERFORMANCE INDICATOR RECORDS AND DOCUMENTS Number Description or TitleDate or Revision

LS-AA-2110 Monthly Data Elements for NRC Emergency Response Organization Drill Participation Records December 2007 - December 2008

LS-AA-2120 Monthly Data Elements for NRC Drill/Exercise Performance Records October 2007 - December 2008

LS-AA-2130 Monthly Data Elements for NRC Alert and Notification System (ANS) Reliability Records October 2007 - December 2008

CORRECTIVE ACTION PROGRAM REPORTS GENERATED DURING INSPECTION Number Description or TitleDate or Revision

AR 00905174

2009 Exercise EOF Dose Assessment Variations Identified by NRC April 9, 2009

AR 00903654

2009 Exercise EOF Dose Assessment Communications and Information Issues April 6, 2009

3CORRECTIVE ACTION PROGRAM REPORTS GENERATED DURING INSPECTION Number Description or TitleDate or Revision

AR 00903566 2009 Exercise Training Needed on Control Room Communicator Roles April 6, 2009

AR 00903559 2009 Exercise Information Not Relayed to Station Security from TSC

April 6, 2009

AR 00903514 2009 Exercise Scenario Radiation Data Provided Incorrect Units for Field Meters April 4, 2009

AR 00903499 2009 Exercise Performance Item for TSC Habitability and Slow Updating on Team Status Board April 4, 2009

AR 00900365 2009 Exercise Unsatisfactory Demonstration Criteria for Simulated Site Evacuation

March 31, 2009

AR 00900346 2009 Exercise Unsatisfactory Demonstration Criteria for CRS Habitability

March 31, 2009

AR 00898171 2009 Exercise Nuclear Oversight OSC Team Briefing Form Completion Observation March 26, 2009

AR 00898136 2009 Exercise Nuclear Oversight Concern Regarding the Early Issuance of Potassium Iodide March 26, 2009

AR 00897914 2009 Exercise Nuclear Oversight Concerns Regarding the Use of Acronyms and Early Dispatch of Field Teams March 26, 2009

4

LIST OF ACRONYMS

USED [[]]

ADAMS Agencywide Documents Access and Management System

ANS Alert and Notification System

CFR Code of Federal Regulations

CRS Control Room Simulator

EOF Emergency Operations Facility

EP Emergency Preparedness

ERO Emergency Response Organization

IMC Inspection Manual Chapter

IP Inspection Procedure

KI Potassium Iodide

NARS Nuclear Accident Reporting System

NEI Nuclear Energy Institute

NOS Nuclear Oversight

NRC Nuclear Regulatory Commission

OSC Operations Support Center

PAR Protective Action Recommendation

PARS Publicly Available Records

PI Performance Indicator

SDP Significance Determination Process

TI Temporary Instruction

TSC Technical Support Center