IR 05000334/2010502

IR 05000334-10-502, 05000412-10-502, on 04/19/2010-04/23/2010, Beaver Valley Power Station, Exercise Evaluation, Emergency Action Level and Emergency Plan Changes, Emergency Preparedness Performance Indicators

ML101520199
Person / Time
Site:	Beaver Valley
Issue date:	06/01/2010
From:	James Trapp Plant Support Branch 1
To:	Harden P FirstEnergy Nuclear Operating Co
References
IR-10-502
Download: ML101520199 (11)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION une 1, 2010

SUBJECT:

BEAVER VALLEY POWER STATION - NRC EVALUATED EMERGENCY PREPAREDNESS EXERCISE - INSPECTION REPORT NO.

05000334/2010502 AND 05000412/2010502

Dear Mr. Harden:

On April 2:3, 2010, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection of the April 20, 2010, evaluated emergency preparedness exercise at your Beaver Valley Power Station. The enclosed inspection report documents the inspection results, which were discussed on April 23, 2010, 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. However, a licensee-identified violation which was determined to be of very low safety significance is listed in this report. NRC is treating this violation as a non-cited violation (NCV) consistent with Section VI.A.1 of the NRC Enforcement Policy because of the very low safety significance of the violation and because it is entered into your corrective action program. If you contest this non cited violation, 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 I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Beaver Valley Power Station. 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, James A. Trapp, Chief Plant Support Branch 1 Division of Reactor Safety Docket Nos. 50-334, 50-412 License Nos. DPR-66, NPF-73

Enclosure:

NRC Inspection Report Nos. 05000334/2010502 and 05000412/2010502

REGION I==

Docket Nos: 50-334,50-412 License Nos: DPR-66, NPF-73 Report Nos: 05000334/2010502, 05000412/2010502 Licensee: FirstEnergy Nuclear Operating Company (FENOC)

Facility: Beaver Valley Power Station Units 1 and 2 Location: Post Office Box 4 Shippingport, PA 15077 Dates: April 19 - 23, 2010 Inspectors: S. Barr, Sr. Emergency Preparedness Inspector, DRS, Region I (Lead)

D. Kern, Sr. Resident Inspector - Three Mile Island, DRP, Region I D. Everhart, Physical Security Inspector, DRS, Region I J. Laughlin, Emergency Preparedness SpeCialist, NSIR E. Keighley, Reactor Engineer, DRP, Region I (Observer)

L. Kern, Reactor Engineer, DRP, Region I (Observer)

G. Gwiazdowski, Security Specialist, NSIR (Observer)

Approved By: James A. Trapp, Chief Plant Support Branch 1 Division of Reactor Safety

SUMMARY OF FINDINGS

IR 05000334/2010502, 0500041212010502; 04/19/2010-04/23/2010; Beaver Valley Power

Station; Exercise Evaluation; Emergency Action Level and Emergency Plan Changes;

Emergency Preparedness Performance Indicators.

This was an announced inspection conducted by two region-based inspectors, one resident inspector and one headquarter-based inspector. 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.

NRC-Identified and Self-Revealing Findings

No findings of significance were identified.

B. Licensee-Identified Findings A violation of very low safety significance, which was identified by the licensee, has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensee's corrective action program. This violation and corrective actions are listed in Section 40A7 of this report.

ii

REPORT DETAILS

REACTOR SAFETY

Cornerstone: Emergency Preparedness (EP)

1EP1 Exercise Evaluation (71114.01-1 Sample)

a. Inspection Scope

Prior to the April 20, 2010, emergency preparedness exercise, the NRC inspectors conducted an in-office review of the exercise objectives and scenario, which FENOC had submitted to the NRC, to determine if the exercise would test major elements of the Beaver Valley 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 FENOC'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 FENOC's Beaver Valley 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, Operations Support Center (OSC), Technical Support Center (TSC). Emergency Operations Facility (EOF), and Joint Information Center (JIC).

II A review of other performance areas, such as: the Beaver Valley 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 Beaver Valley exercise inspection report and FENOC's Beaver Valley EP drill reports, to determine the effectiveness of licensee corrective actions as demonstrated during the April 20, 2010, exercise and to ensure compliance with 10 CFR 50.47(b)(14).

• The licensee's post-exercise critiques, to evaluate FENOC's self-assessment of its

• ERO performance during the April 20, 2010, 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, in September 2009, FENOC implemented various revisions of the different sections of the Beaver Valley Emergency Plan. FENOC had determined that, in accordance with 10 CFR 50.54(q), any change made to the Plan, and its lower-tier implementing procedures, had not resulted in any 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 confirmed no EAL changes had been made'since September 2009, and conducted a sampling review of other Emergency Plan changes, including the changes to lower-tier emergency plan implementil)g procedures, to evaluate for any potential decreases in effectiveness of the Emergency Plan. However, this review was not documented in an NRC 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)

40A1 Performance Indicator (PI) Verification (71151 - 3 Samples)

a. Inspection Scope

The inspectors reviewed data for the Beaver Valley 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 NRC EP inspection at Beaver Valley was conducted in the third quarter of 2009, so the inspectors reviewed supporting documentation from EP drills, training records, and eqUipment tests from the third calendar quarter of 2009 through the first quarter of 201 0, 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.

b. Findings

No findings of significance were identified.

40A6 Meetings. Including Exit On April 23, 2010, the inspectors presented the results of this inspection to Mr. Paul Harden, Site Vice President, and other members of the FENOC staff. No proprietary information was provided to the inspectors during this inspection.

40A7 Licensee-Identified Violations The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meet the criteria of Section VI of the NRC Enforcement Policy, NUREG-1600, for being dispositioned as a non-cited violation (NCV).

10 CFR 50.54(q) requires that a nuclear power reactor licensee shall follow and maintain in effect emergency plans that meet the standards in 10 CFR 50.47(b). Contrary to this requirement, FENOC failed to maintain their described method of notifying State and local organizations of emergency events. Specifically, for the time period between February 8 and February 16, 2010, the Beaver Valley control room staff did not possess the newly-issued code word for verifying notification communications between the site and local officials. The control room staff's inability to use the proper code word would have unnecessarily delayed the required notification of those local officials, as required by 10 CFR 50.47(b)(5). Once discovered by FENOC on February 16,2010, the condition was immediately corrected. FENOC further performed a Cause Analysis in conjunction with CR 10-71680 and initiated programmatic corrective actions to assure

. the control room is properly informed when a new code word is assigned. The finding was more than minor because it is associated with the emergency preparedness cornerstone and affected the cornerstone objective of ensuring proper offsite not,ification of an emergency event at the Beaver Valley Nuclear Power Station. The inspectors determined that the finding was of very low safety significance (Green), based on IMC 0609, Appendix B, because, while not having the proper code word could have delayed theoffsite notification, alternate means of establishing offsite notifications were available and would have accomplished the notification objective.

ATTACHMENT

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

G. Cramer, Emergency Planning Manager

B. Tuite, Regulatory Compliance Manager

R. Lieb, Site Operations Director

P. Harden, Site Vice President

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

None