IR 05000461/2017502

Clinton Power Station - Baseline Emergency Preparedness Biennial Exercise Inspection Report 05000461/2017502 (Gph)

ML17317B469
Person / Time
Site:	Clinton
Issue date:	11/13/2017
From:	Orth S K NRC/RGN-III
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
References
IR 2017502
Download: ML17317B469 (11)

Text

November 13, 2017

Mr. Bryan Senior VP, Exelon Generation Company, LLC President and CNO, Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT: CLINTON POWER STATION - BASELINE EMERGENCY PREPAREDNESS BIENNIAL EXERCISE INSPECTION REPORT 05000461/2017502

Dear Mr. Hanson:

On November 2, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed a baseline emergency preparedness biennial exercise inspection at the Clinton Power Station, and the NRC inspectors discussed the results of this inspection with Mr. B. Kapellas and other members of your staff. The results of the inspection are documented in the enclosed report. The NRC inspectors did not identify any finding or violation of more than minor significance. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, "Public Inspections, Exemptions, Requests for Withholding."

Sincerely,/RA/ Steven K. Orth, Chief Plant Support Branch Division of Reactor Safety Docket No. 50-461 License No. NPF-62

Enclosure:

IR 05000461/2017502 cc: Distribution via LISTSERV Letter to Bryan Hanson from Steven Orth dated November 13, 2017

SUBJECT: CLINTON POWER STATION - BASELINE EMERGENCY PREPAREDNESS BIENNIAL EXERCISE INSPECTION REPORT 05000461/2017502 DISTRIBUTION: Jeremy Bowen RidsNrrDorlLpl3 RidsNrrPMClinton Resource RidsNrrDirsIrib Resource Cynthia Pederson Kenneth O'Brien Richard Skokowski Allan Barker Carole Ariano Linda Linn DRSIII DRPIII ROPreports.Resource@nrc.gov

ADAMS Accession Number: ML17317B469 OFFICE RIII RIII RIII RIII NAME GHansen:jw SOrth DATE 11/13/17 11/13/17 OFFICIAL RECORD COPY Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION III Docket No: 50-461 License No: NPF-62 Report No: 05000461/2017502 Licensee: Exelon Generation Company, LLC Facility: Clinton Power Station, Unit 1 Location: Clinton, IL Dates: October 30 - November 2, 2017 Inspectors: G. Hansen, Senior Emergency Preparedness Inspector M. Garza, Emergency Preparedness Inspector W. Schaup, Senior Resident Inspector P. Zurawski, Senior Resident Inspector Approved by: S. Orth, Chief Plant Support Branch Division of Reactor Safety 2

SUMMARY

IR 05000461/2017502; 10/30/2017 - 11/02/2017; Clinton Power Station; Baseline Emergency Preparedness Biennial Exercise Inspection; Exercise Evaluation Scenario Review; Performance Indicator Verification. This report covers a 1-week period of announced baseline inspection by four regional inspectors. The U.S. Nuclear Regulatory Commission's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 6, dated July 2016.

NRC-Identified

and Self-Revealed Findings

===Cornerstone: Emergency Preparedness No findings were identified.

Licensee-Identified Violations

None===

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REPORT DETAILS

REACTOR SAFETY

Cornerstone:

Emergency Preparedness

1EP1 Exercise Evaluation

.1 Exercise Evaluation

a. Inspection Scope

The inspectors reviewed the November 1, 2017, 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 from 2015 through 2017, to verify that those drills' scenarios were sufficiently different from the scenario used in the November 1, 2017, 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; Technical Support Center; Operations Support Center; and Emergency Operations Facility. 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 control room simulator, technical support center, operations support center, and emergency operations facility 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.

b. Findings

No findings were identified.

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1EP8 Exercise Evaluation - Scenario Review

a. Inspection Scope

Prior to the inspection activity on-site, the inspectors conducted an in-office review of the exercise objectives and scenarios submitted to the U.S. Nuclear Regulatory Commission using IP 71114.08, "Exercise Evaluation - Scenario Review," to determine if the exercise would test major elements of the Emergency Plan as required by Title 10 of the Code of Federal Regulations, Part 50.47(b)(14). Documents reviewed are listed in the Attachment to this report. This review of the exercise objectives and scenario constituted one inspection sample as defined in IP 71114.08.

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 third quarter of 2016 through the second quarter of 2017. 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 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, and performance during other drills. Documents reviewed are listed in the Attachment to this report. This inspection constituted one DEP PI verification inspection sample as defined in IP 71151.

b. Findings

No findings were identified.

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.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 third quarter of 2016 through the second quarter of 2017. 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 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 2015, 2016, and 2017 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 PI verification inspection sample as defined in IP 71151.

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 third quarter of 2016 through the second quarter of 2017. 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 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 scheduled ANS operability tests. Documents reviewed are listed in the Attachment to this report. This inspection constituted one ANS PI verification inspection sample as defined in IP 71151.

b. Findings

No findings were identified.

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4OA6 Management Meetings

.1 Exit Meeting Summary On November 2, 2017, the inspectors presented the biennial exercise inspection results to Mr. B. Kapellas, 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. ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

B. Kapellas, Plant Manager

M. Friedmann, Emergency Preparedness Manager

D. Shelton, Regulatory Assurance Manager

S. O'Riley, Engineering Programs Manager

K. Aleshire, Director EP (Corporate)

A. Daniels, Midwest Emergency Preparedness Manager (Corporate)

R. Mika, Midwest Drill and Exercise Coordinator (Corporate)

U.S. Nuclear Regulatory Commission W. Schaup, Senior Resident Inspector

E. Sanchez, Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened, Closed, and Discussed

None LIST OF ACRONYMS USED ANS Alert and Notification System DEP Drill / Exercise Performance ERO Emergency Response Organization IP Inspection Procedure NEI Nuclear Energy Institute NRC U.S. Nuclear Regulatory Commission PI Performance Indicator

LIST OF DOCUMENTS REVIEWED

The following is a partial 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 or 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. 1EP1 Exercise Evaluation (71114.01) -

EP-AA-1000; Exelon Nuclear Standardized Radiological Emergency Plan; Revision 28 -

EP-AA-1003; Exelon Nuclear Radiological Emergency Plan Annex for Clinton Station; Revision 27 -

EP-AA-1003, Addendum 1; Clinton Station On-Shift Staffing Technical Basis; Revision 1 -

EP-AA-1003, Addendum 3; Exelon Nuclear Emergency Action Levels for Clinton Station; Revision 2 -

EP-AA-110-200; Dose Assessment; Revision 8 -

EP-AA-110-301; Core Damage Assessment (BWR); Revision 10 -

EP-AA-111; Emergency Classification and Protective Action Recommendations; Revision 19 -

EP-AA-111-F-07; Clinton PAR Flowchart; Revision E -

EP-AA-112; Emergency Response Organization (ERO)/Emergency Response Facility Activation and Operation; Revision 18 -

EP-AA-113; Personnel Protective Actions; Revision 13 -

EP-AA-113-F-22; Clinton Assembly, Accountability, and Evacuation Guidelines; Revision B -

EP-AA-114; Notifications; Revision 13 -

EP-MW-114-100; Midwest Region Offsite Notifications; Revision 16 -

EP-AA-115; Termination and Recovery; Revision 9 -

EP-AA-121; Emergency Response Facilities and Equipment Readiness; Revision 15 - Clinton 2015 Hostile Action Based NRC Graded Exercise Evaluation Report; Dated

November 18, 2015 - Clinton 2016 Off-Year Exercise Evaluation Report; Dated December 1, 2016 - Clinton 2017 Pre-Exercise Evaluation Report; Dated September 20, 2017 - PowerPoint Presentation; Clinton Biennial Exercise - Exercise Evaluation Results;

Dated November 2, 2017 - Two-Year List of Drill and Exercise Condition Reports; October 2015 - October 2017 - Two Years of Drill and Exercise Timelines; October 2015 - October 2017 -

AR 02589299; Certain Clinton EAL Radiation Monitors not in PPDS;

Dated November 18, 2015 -

AR 02590313; Corporate EP to review issues identified and create additional AC;

Dated November 20, 2015 -

AR 02664254; EP Focus Area Drill Critique Issues; Dated May 02, 2016 -

AR 02720307; EP OYE Simulator Failed Demonstration Criteria; Dated September 26, 2016 -

AR 02720309; EP OYE OSC Failed Demonstration

Criteria; Dated September 26, 2016 -

AR 02726456; EP Full Scale Drill Issues; Dated October 10, 2016 -

AR 03962438; EP Drill Evaluation and Critique Items; Dated January 12, 2017 -

AR 04007063; EP Drill Evaluation Results; Dated May 5, 2017 -

AR 04054678; Untimely EAL

Declaration During Drill, DEP Failure;

Dated September 21, 2017 - AR

0408758; Previously Conducted Drill

Scenario Found in Recycle Bin;

Dated October 30, 2017 -

AR 04062838; CPR

PEX 2017 - EOF ERO Performance Issues; Dated October 13, 2017

1EP8 Exercise Evaluation - Scenario Review (71114.08) - Clinton Station 2017 NRC Graded Exercise 60 Day Manual; Dated

August 29, 2017 4OA1 Performance Indicator Verification (71151) -

NEI 99-02; Regulatory Assessment Performance Indicator Guideline; Revision 7 - NRC PI Data Sheets; NRC Indicator ANS Reliability; October 2016 - June 2017 - NRC PI Data Sheets; ERO Readiness; October 2016 - June 2017 - NRC PI Data Sheets; Drill/Exercise Performance; October 2016 - June 2017