ML021210488: Difference between revisions

From kanterella
Jump to navigation Jump to search
(StriderTol Bot insert)
 
(StriderTol Bot change)
 
Line 25: Line 25:
Nuclear Management Company, LLC
Nuclear Management Company, LLC
6610 Nuclear Road
6610 Nuclear Road
Two Rivers, WI 54241
Two Rivers, WI 54241
SUBJECT:       POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2
SUBJECT:
                NRC INSPECTION REPORT 50-266/02-04(DRS); 50-301/02-04(DRS)
POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2  
                PRELIMINARY WHITE FINDING
NRC INSPECTION REPORT 50-266/02-04(DRS); 50-301/02-04(DRS)
PRELIMINARY WHITE FINDING
Dear Mr. Warner:
Dear Mr. Warner:
On April 1, 2002, the NRC completed an inspection of your Point Beach Nuclear Plant, Units 1 and
On April 1, 2002, the NRC completed an inspection of your Point Beach Nuclear Plant, Units 1 and
2. The enclosed report documents the inspection results, which were discussed with Mr. M.
2. The enclosed report documents the inspection results, which were discussed with Mr. M.
Reddemann and members of your staff at an interim exit meeting on February 15, 2002.
Reddemann and members of your staff at an interim exit meeting on February 15, 2002.  
Following the on site inspection, additional information was provided by your staff that was
Following the on site inspection, additional information was provided by your staff that was
reviewed in the Region III office. A final exit meeting was conducted on April 1, 2002, with Mr. A.
reviewed in the Region III office. A final exit meeting was conducted on April 1, 2002, with Mr. A.
Cayia and other members of your staff to discuss the NRCs preliminary significance determination
Cayia and other members of your staff to discuss the NRCs preliminary significance determination
of the inspection results.
of the inspection results.
The inspection examined activities conducted under your license as they relate to safety and
The inspection examined activities conducted under your license as they relate to safety and
compliance with the Commissions rules and regulations and with the conditions of your license.
compliance with the Commissions rules and regulations and with the conditions of your license.  
The inspectors reviewed selected procedures and records, observed activities, and interviewed
The inspectors reviewed selected procedures and records, observed activities, and interviewed
personnel. Specifically, this inspection focused on emergency preparedness, including your
personnel. Specifically, this inspection focused on emergency preparedness, including your
staffs determinations of performance indicators for the Emergency Preparedness Cornerstone.
staffs determinations of performance indicators for the Emergency Preparedness Cornerstone.  
The enclosed report discusses an issue involving your staffs critique of its performance during
The enclosed report discusses an issue involving your staffs critique of its performance during
the biennial emergency preparedness exercise that was conducted on February 12, 2002. The
the biennial emergency preparedness exercise that was conducted on February 12, 2002. The
NRCs preliminary conclusion is that two exercise performance concerns, which are associated
NRCs preliminary conclusion is that two exercise performance concerns, which are associated
with emergency preparedness planning standard 10 CFR 50.47(b)(10), were inadequately
with emergency preparedness planning standard 10 CFR 50.47(b)(10), were inadequately
critiqued by your staff. The first concern was the critique of the initial protective action
critiqued by your staff. The first concern was the critique of the initial protective action
recommendation that your exercise participants communicated to offsite officials. Your
recommendation that your exercise participants communicated to offsite officials. Your
exercise critique concluded that this recommendation was a successful performance indicator
exercise critique concluded that this recommendation was a successful performance indicator
opportunity. However, our inspection identified issues concerning this recommendation that
opportunity. However, our inspection identified issues concerning this recommendation that
were not fully evaluated within your critique. The second concern involved your staffs critique
were not fully evaluated within your critique. The second concern involved your staffs critique
of the exercise participants decision making on the simulated removal from the site of non-
of the exercise participants decision making on the simulated removal from the site of non-
essential personnel, who were not members of the current shift of emergency responders, after
essential personnel, who were not members of the current shift of emergency responders, after
all onsite personnel were accounted for.
all onsite personnel were accounted for.  


M. Warner                                       -2-
M. Warner
-2-
This issue was assessed using the applicable significance determination process as a
This issue was assessed using the applicable significance determination process as a
potentially safety significant finding that was preliminarily determined to be White, i.e. an issue
potentially safety significant finding that was preliminarily determined to be White, i.e. an issue
with some increased importance to safety which may require additional NRC inspection. A
with some increased importance to safety which may require additional NRC inspection. A
basic reason for conducting emergency preparedness drills and exercises is to identify
basic reason for conducting emergency preparedness drills and exercises is to identify
performance and procedure concerns through the critique process so that corrective actions
performance and procedure concerns through the critique process so that corrective actions
can be taken before such concerns might occur during an actual emergency and possibly have
can be taken before such concerns might occur during an actual emergency and possibly have
an adverse impact on health and safety. Therefore, it is important that your staffs critiques of
an adverse impact on health and safety. Therefore, it is important that your staffs critiques of
emergency preparedness drills and exercises be thorough and self-critical whether or not NRC
emergency preparedness drills and exercises be thorough and self-critical whether or not NRC
staff are also present to observe and assess these activities. Since both items are associated
staff are also present to observe and assess these activities. Since both items are associated
with an exercise critique, rather than an actual emergency event, no apparent violation is
with an exercise critique, rather than an actual emergency event, no apparent violation is
associated with the preliminary White finding.
associated with the preliminary White finding.
Before the NRC makes a final decision on this matter, we are providing you an opportunity to
Before the NRC makes a final decision on this matter, we are providing you an opportunity to
request a Regulatory Conference where you would be able to provide your perspectives on the
request a Regulatory Conference where you would be able to provide your perspectives on the
significance of the finding, the bases for your position, and whether you agree with the apparent
significance of the finding, the bases for your position, and whether you agree with the apparent
violations (if applicable). If you choose to request a Regulatory Conference, we encourage you
violations (if applicable). If you choose to request a Regulatory Conference, we encourage you
to submit your evaluation and any differences with the NRC evaluation at least one week prior
to submit your evaluation and any differences with the NRC evaluation at least one week prior
to the conference in an effort to make the conference more efficient and effective. If a
to the conference in an effort to make the conference more efficient and effective. If a
conference is held, it will be open for public observation. The NRC will also issue a press
conference is held, it will be open for public observation. The NRC will also issue a press
release to announce the conference.
release to announce the conference.  
Please contact Mr. Kenneth Riemer at (630) 829-9757 within seven days of the date of this
Please contact Mr. Kenneth Riemer at (630) 829-9757 within seven days of the date of this
letter to inform the NRC of your intentions. If we have not heard from you by telephone or in
letter to inform the NRC of your intentions. If we have not heard from you by telephone or in
writing regarding a conference within 10 days, we will continue with our significance
writing regarding a conference within 10 days, we will continue with our significance
determination and enforcement decision, and you will be advised by separate correspondence
determination and enforcement decision, and you will be advised by separate correspondence
Line 83: Line 85:
and its enclosure will be available electronically for public inspection in the NRC Public
and its enclosure will be available electronically for public inspection in the NRC Public
Document Room or from the Publicly Available Records (PARS) component of NRC's
Document Room or from the Publicly Available Records (PARS) component of NRC's
document system (ADAMS). ADAMS is accessible from the NRC Web site at
document system (ADAMS). ADAMS is accessible from the NRC Web site at
http://www.nrc.gov/NRC/ADAMS/index.html (the Public Electronic Reading Room).
http://www.nrc.gov/NRC/ADAMS/index.html (the Public Electronic Reading Room).
                                                Sincerely,
Sincerely,
                                  /RA by Roy Caniano Acting For/
/RA by Roy Caniano Acting For/  
                                                John A. Grobe, Director
John A. Grobe, Director
                                                Division of Reactor Safety
Division of Reactor Safety
Docket Nos. 50-266; 50-301
Docket Nos. 50-266; 50-301
License Nos. DPR-24; DPR-27
License Nos. DPR-24; DPR-27
Enclosure:       Inspection Report 50-266/02-04(DRS);
Enclosure:
                  50-301/02-04(DRS)
Inspection Report 50-266/02-04(DRS);  
  50-301/02-04(DRS)
See Attached Distribution
See Attached Distribution


M. Warner                                                                 -2-
M. Warner
-2-
This issue was assessed using the applicable significance determination process as a
This issue was assessed using the applicable significance determination process as a
potentially safety significant finding that was preliminarily determined to be White, i.e. an issue
potentially safety significant finding that was preliminarily determined to be White, i.e. an issue
with some increased importance to safety which may require additional NRC inspection. A
with some increased importance to safety which may require additional NRC inspection. A
basic reason for conducting emergency preparedness drills and exercises is to identify
basic reason for conducting emergency preparedness drills and exercises is to identify
performance and procedure concerns through the critique process so that corrective actions
performance and procedure concerns through the critique process so that corrective actions
can be taken before such concerns might occur during an actual emergency and possibly have
can be taken before such concerns might occur during an actual emergency and possibly have
an adverse impact on health and safety. Therefore, it is important that your staffs critiques of
an adverse impact on health and safety. Therefore, it is important that your staffs critiques of
emergency preparedness drills and exercises be thorough and self-critical whether or not NRC
emergency preparedness drills and exercises be thorough and self-critical whether or not NRC
staff are also present to observe and assess these activities. Since both items are associated
staff are also present to observe and assess these activities. Since both items are associated
with an exercise critique, rather than an actual emergency event, no apparent violation is
with an exercise critique, rather than an actual emergency event, no apparent violation is
associated with the preliminary White finding.
associated with the preliminary White finding.
Before the NRC makes a final decision on this matter, we are providing you an opportunity to
Before the NRC makes a final decision on this matter, we are providing you an opportunity to
request a Regulatory Conference where you would be able to provide your perspectives on the
request a Regulatory Conference where you would be able to provide your perspectives on the
significance of the finding, the bases for your position, and whether you agree with the apparent
significance of the finding, the bases for your position, and whether you agree with the apparent
violations (if applicable). If you choose to request a Regulatory Conference, we encourage you
violations (if applicable). If you choose to request a Regulatory Conference, we encourage you
to submit your evaluation and any differences with the NRC evaluation at least one week prior
to submit your evaluation and any differences with the NRC evaluation at least one week prior
to the conference in an effort to make the conference more efficient and effective. If a
to the conference in an effort to make the conference more efficient and effective. If a
conference is held, it will be open for public observation. The NRC will also issue a press
conference is held, it will be open for public observation. The NRC will also issue a press
release to announce the conference.
release to announce the conference.  
Please contact Mr. Kenneth Riemer at (630) 829-9757 within seven days of the date of this
Please contact Mr. Kenneth Riemer at (630) 829-9757 within seven days of the date of this
letter to inform the NRC of your intentions. If we have not heard from you by telephone or in
letter to inform the NRC of your intentions. If we have not heard from you by telephone or in
writing regarding a conference within 10 days, we will continue with our significance
writing regarding a conference within 10 days, we will continue with our significance
determination and enforcement decision, and you will be advised by separate correspondence
determination and enforcement decision, and you will be advised by separate correspondence
Line 123: Line 127:
and its enclosure will be available electronically for public inspection in the NRC Public
and its enclosure will be available electronically for public inspection in the NRC Public
Document Room or from the Publicly Available Records (PARS) component of NRC's
Document Room or from the Publicly Available Records (PARS) component of NRC's
document system (ADAMS). ADAMS is accessible from the NRC Web site at
document system (ADAMS). ADAMS is accessible from the NRC Web site at
http://www.nrc.gov/NRC/ADAMS/index.html (the Public Electronic Reading Room).
http://www.nrc.gov/NRC/ADAMS/index.html (the Public Electronic Reading Room).
                                                                          Sincerely,
Sincerely,
                                                              /RA by Roy Caniano Acting For/
/RA by Roy Caniano Acting For/  
                                                                          John A. Grobe, Director
John A. Grobe, Director
                                                                          Division of Reactor Safety
Division of Reactor Safety
Docket Nos. 50-266; 50-301
Docket Nos. 50-266; 50-301
License Nos. DPR-24; DPR-27
License Nos. DPR-24; DPR-27
Enclosure:               Inspection Report 50-266/02-04(DRS);
Enclosure:
                            50-301/02-04(DRS)
Inspection Report 50-266/02-04(DRS);  
  50-301/02-04(DRS)
See Attached Distribution
See Attached Distribution
DOCUMENT NAME: G:DRS\POI02-04DRS.wpd
DOCUMENT NAME: G:DRS\\POI02-04DRS.wpd
To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy
To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy
OFFICE             RIII                         RIII                     RIII                         RIII                       RIII
OFFICE
NAME               TPloski:aa                   KRiemer                 RLanksbury                   KLambert for               RCaniano
RIII
                                                                                                        BClayton                    for JGrobe
RIII
DATE               4/30/02                       4/30/02                 4/30/02                     4/30/02                     4/30/02
RIII
                                                          OFFICIAL RECORD COPY
RIII
RIII
NAME
TPloski:aa
KRiemer
RLanksbury
KLambert for
BClayton
RCaniano
for JGrobe
DATE
4/30/02
4/30/02
4/30/02
4/30/02
4/30/02
OFFICIAL RECORD COPY


M. Warner                                 -3-
M. Warner
cc w/encl: R. Grigg, President and Chief
-3-
            Operating Officer, WEPCo
cc w/encl:
          R. Anderson, Executive Vice President
R. Grigg, President and Chief
            and Chief Nuclear Officer
  Operating Officer, WEPCo
          T. Webb, Licensing Manager
R. Anderson, Executive Vice President
          D. Weaver, Nuclear Asset Manager
  and Chief Nuclear Officer
          T. Taylor, Plant Manager
T. Webb, Licensing Manager
          A. Cayia, Site Director
D. Weaver, Nuclear Asset Manager
          J. ONeill, Jr., Shaw, Pittman,
T. Taylor, Plant Manager
            Potts & Trowbridge
A. Cayia, Site Director
          K. Duveneck, Town Chairman
J. ONeill, Jr., Shaw, Pittman,  
            Town of Two Creeks
  Potts & Trowbridge
          D. Graham, Director
K. Duveneck, Town Chairman
            Bureau of Field Operations
  Town of Two Creeks
          A. Bie, Chairperson, Wisconsin
D. Graham, Director
            Public Service Commission
  Bureau of Field Operations
          S. Jenkins, Electric Division
A. Bie, Chairperson, Wisconsin
            Wisconsin Public Service Commission
  Public Service Commission
          State Liaison Officer
S. Jenkins, Electric Division
          W. Curtis, FEMA, Region V
  Wisconsin Public Service Commission
State Liaison Officer
W. Curtis, FEMA, Region V


M. Warner                                     -3-
M. Warner
cc w/encl:     R. Grigg, President and Chief
-3-
                Operating Officer, WEPCo
cc w/encl:
              R. Anderson, Executive Vice President
R. Grigg, President and Chief
                and Chief Nuclear Officer
  Operating Officer, WEPCo
              T. Webb, Licensing Manager
R. Anderson, Executive Vice President
              D. Weaver, Nuclear Asset Manager
  and Chief Nuclear Officer
              T. Taylor, Plant Manager
T. Webb, Licensing Manager
              A. Cayia, Site Director
D. Weaver, Nuclear Asset Manager
              J. ONeill, Jr., Shaw, Pittman,
T. Taylor, Plant Manager
                Potts & Trowbridge
A. Cayia, Site Director
              K. Duveneck, Town Chairman
J. ONeill, Jr., Shaw, Pittman,  
                Town of Two Creeks
  Potts & Trowbridge
              D. Graham, Director
K. Duveneck, Town Chairman
                Bureau of Field Operations
  Town of Two Creeks
              A. Bie, Chairperson, Wisconsin
D. Graham, Director
                Public Service Commission
  Bureau of Field Operations
              S. Jenkins, Electric Division
A. Bie, Chairperson, Wisconsin
                Wisconsin Public Service Commission
  Public Service Commission
              State Liaison Officer
S. Jenkins, Electric Division
              W. Curtis, FEMA, Region V
  Wisconsin Public Service Commission
State Liaison Officer
W. Curtis, FEMA, Region V
ADAMS Distribution:
ADAMS Distribution:
WDR
WDR  
DFT
DFT  
BAW
BAW
RidsNrrDipmIipb
RidsNrrDipmIipb
Line 202: Line 227:
JRK1
JRK1


          U.S. NUCLEAR REGULATORY COMMISSION
U.S. NUCLEAR REGULATORY COMMISSION
                          REGION III
REGION III
Docket Nos:         50-266; 50-301
Docket Nos:
License Nos:       DPR-24; DPR-27
50-266; 50-301
Report No:         50-266/02-04(DRS); 50-301/02-04(DRS)
License Nos:  
Licensee:           Nuclear Management Company, LLC
DPR-24; DPR-27
Facility:           Point Beach Nuclear Plant, Units 1 and 2
Report No:
Location:           6610 Nuclear Road
50-266/02-04(DRS); 50-301/02-04(DRS)
                    Two Rivers, WI 54241
Licensee:
Dates:             February 11 through February 15, 2002; and
Nuclear Management Company, LLC
                    April 1, 2002
Facility:
Inspectors:         T. Ploski, Senior Emergency Preparedness Inspector
Point Beach Nuclear Plant, Units 1 and 2
                    R. Jickling, Emergency Preparedness Inspector
Location:
                    S. Orth, Senior Radiation Specialist
6610 Nuclear Road
                    P. Krohn, Senior Resident Inspector
Two Rivers, WI 54241  
Approved by:       Kenneth Riemer, Chief
Dates:
                    Plant Support Branch
February 11 through February 15, 2002; and
April 1, 2002
Inspectors:
T. Ploski, Senior Emergency Preparedness Inspector
R. Jickling, Emergency Preparedness Inspector
S. Orth, Senior Radiation Specialist
P. Krohn, Senior Resident Inspector
Approved by:
Kenneth Riemer, Chief
Plant Support Branch


                                    SUMMARY OF FINDINGS
2
SUMMARY OF FINDINGS
IR 05000266-02-04(DRS), 05000301-02-04(DRS), on 02/11-04/1/2002, Nuclear Management
IR 05000266-02-04(DRS), 05000301-02-04(DRS), on 02/11-04/1/2002, Nuclear Management
Company, LLC, Point Beach Nuclear Plant, Units 1 and 2. Exercise Evaluation.
Company, LLC, Point Beach Nuclear Plant, Units 1 and 2.   Exercise Evaluation.
The report covers a baseline inspection by two regional emergency preparedness
The report covers a baseline inspection by two regional emergency preparedness
inspectors, one regional radiation protection inspector, and a senior resident inspector.
inspectors, one regional radiation protection inspector, and a senior resident inspector.  
The inspection focused on the Reactor Safety, Emergency Preparedness Cornerstone,
The inspection focused on the Reactor Safety, Emergency Preparedness Cornerstone,
during the biennial emergency preparedness exercise, and included a review of
during the biennial emergency preparedness exercise, and included a review of
records related to the three emergency preparedness performance indicators for the
records related to the three emergency preparedness performance indicators for the
period ending December 31, 2001. One preliminary White finding was identified
period ending December 31, 2001. One preliminary White finding was identified
during the inspection.
during the inspection.
The significance of most findings is indicated by their color (Green, White, Yellow, Red)
The significance of most findings is indicated by their color (Green, White, Yellow, Red)
using IMC 0609 Significance Determination Process (SDP). The NRCs program for
using IMC 0609 Significance Determination Process (SDP). The NRCs program for
overseeing the safe operation of commercial nuclear power reactors is described at its
overseeing the safe operation of commercial nuclear power reactors is described at its
Reactor Oversight Process website at http://www/nrc.gov/NRR/OVERSIGHT/index.html.
Reactor Oversight Process website at http://www/nrc.gov/NRR/OVERSIGHT/index.html.  
Findings for which the SDP does not apply are indicated by No Color or by the severity
Findings for which the SDP does not apply are indicated by No Color or by the severity
level of the applicable violations.
level of the applicable violations.
A.     Inspector Identified Findings
A.
Cornerstone: Emergency Preparedness
Inspector Identified Findings
TBD. Two exercise performance issues, which are associated with emergency preparedness
Cornerstone: Emergency Preparedness
planning standard 10 CFR 50.47(b)(10), were inadequately critiqued by licensee staff. The first
TBD. Two exercise performance issues, which are associated with emergency preparedness
planning standard 10 CFR 50.47(b)(10), were inadequately critiqued by licensee staff. The first
issue was associated with the licensees critique of the initial offsite Protective Action
issue was associated with the licensees critique of the initial offsite Protective Action
Recommendation (PAR) that its exercise participants communicated to offsite officials. The
Recommendation (PAR) that its exercise participants communicated to offsite officials. The
NRC identified issues that contradicted the licensees critique conclusion that the initial PAR
NRC identified issues that contradicted the licensees critique conclusion that the initial PAR
was a successful performance indicator opportunity with respect to its content. The second
was a successful performance indicator opportunity with respect to its content. The second
issue was the licensees critique of its participants decision making process on the simulated
issue was the licensees critique of its participants decision making process on the simulated
removal from the site of non-essential personnel, who were not members of the current shift of
removal from the site of non-essential personnel, who were not members of the current shift of
emergency responders, once all onsite personnel were accounted for.
emergency responders, once all onsite personnel were accounted for.
Using the Emergency Preparedness Significance Determination Process, the NRC has made a
Using the Emergency Preparedness Significance Determination Process, the NRC has made a
preliminary determination that the finding was of low to moderate risk significance (White). In
preliminary determination that the finding was of low to moderate risk significance (White). In
accordance with NRCs Enforcement Policy, as published in NUREG 1600, it was determined
accordance with NRCs Enforcement Policy, as published in NUREG 1600, it was determined
that there is no apparent violation of NRC requirements since the critique issues were related to
that there is no apparent violation of NRC requirements since the critique issues were related to
an exercise, rather than to an actual emergency. (Section 1EP1.b)
an exercise, rather than to an actual emergency. (Section 1EP1.b)
                                                  2


                                          Report Details
3
Report Details
Summary of Plant Status
Summary of Plant Status
The plant operated at approximately 100 percent power throughout the inspection period.
The plant operated at approximately 100 percent power throughout the inspection period.
1.     REACTOR SAFETY
1.
      Cornerstone: Emergency Preparedness
REACTOR SAFETY
1EP1 Exercise Evaluation (71114.01)
Cornerstone: Emergency Preparedness
a.   Inspection Scope
1EP1
      The inspectors reviewed the February 2002 exercises objectives and scenario to
Exercise Evaluation (71114.01)
      ensure that the exercise would acceptably test major elements of the licensees
  a.
      emergency plan and to verify that the exercises simulated problems provided an
Inspection Scope
      acceptable framework to support demonstration of the licensees capability to
The inspectors reviewed the February 2002 exercises objectives and scenario to
      implement its plan. The inspectors also reviewed records of a pre-exercise practice
ensure that the exercise would acceptably test major elements of the licensees
      drill, which was conducted in January 2002, to determine whether the associated
emergency plan and to verify that the exercises simulated problems provided an
      accident scenario was sufficiently different from the scenario used in the
acceptable framework to support demonstration of the licensees capability to
      February 12, 2002 exercise.
implement its plan. The inspectors also reviewed records of a pre-exercise practice
      The inspectors evaluated the licensees exercise performance, focusing on the
drill, which was conducted in January 2002, to determine whether the associated
      risk-significant activities of emergency classification, notification, and protective action
accident scenario was sufficiently different from the scenario used in the  
      decision making, as well as implementation of accident mitigation strategies in the
February 12, 2002 exercise.  
      following emergency response facilities:
The inspectors evaluated the licensees exercise performance, focusing on the
      *       Control Room Simulator (CRS)
risk-significant activities of emergency classification, notification, and protective action
      *       Technical Support Center (TSC)
decision making, as well as implementation of accident mitigation strategies in the
      *       Operations Support Center (OSC)
following emergency response facilities:
      *       Emergency Operations Facility (EOF)
*
      The inspectors also assessed the licensees recognition of abnormal plant conditions,
Control Room Simulator (CRS)
      transfer of responsibilities between facilities, internal communications, interfaces with
*
      offsite officials, readiness of emergency facilities and related equipment, and overall
Technical Support Center (TSC)
      implementation of the licensees emergency plan.
*
      The inspectors attended the initial post-exercise critiques in the CRS, OSC, TSC, and
Operations Support Center (OSC)
      EOF to evaluate the licensees initial self-assessment of its exercise performance. The
*
      inspectors later met with the licensees lead exercise evaluators to assess the licensees
Emergency Operations Facility (EOF)
      refined critique of its exercise participants performances. The licensees refined
The inspectors also assessed the licensees recognition of abnormal plant conditions,
      critiques results were then compared with the inspectors independent observations and
transfer of responsibilities between facilities, internal communications, interfaces with
      assessments.
offsite officials, readiness of emergency facilities and related equipment, and overall
                                                  3
implementation of the licensees emergency plan.
The inspectors attended the initial post-exercise critiques in the CRS, OSC, TSC, and
EOF to evaluate the licensees initial self-assessment of its exercise performance. The
inspectors later met with the licensees lead exercise evaluators to assess the licensees
refined critique of its exercise participants performances. The licensees refined
critiques results were then compared with the inspectors independent observations and
assessments.


b. Findings
4
  One preliminary White finding was identified for the licensees inadequate critique of two
  b.
  exercise performance issues associated with emergency planning standard 10 CFR
Findings
  50.47(b)(10). Per Supplement VIII of NRCs Enforcement Policy, as published in
One preliminary White finding was identified for the licensees inadequate critique of two
  Nuclear Regulatory Guide (NUREG) 1600, no associated violation of NRC requirements
exercise performance issues associated with emergency planning standard 10 CFR
  was identified since the finding was associated with an exercise rather than an actual
50.47(b)(10). Per Supplement VIII of NRCs Enforcement Policy, as published in
  emergency event.
Nuclear Regulatory Guide (NUREG) 1600, no associated violation of NRC requirements
  This planning standard encompasses protective actions for the general public and
was identified since the finding was associated with an exercise rather than an actual
  onsite personnel. As demonstrated by the licensees exercise performance, the
emergency event.
  inspectors identified two issues associated with the planning standard that were not
This planning standard encompasses protective actions for the general public and
  adequately critiqued by the licensee. The first issue was that the licensee failed to
onsite personnel. As demonstrated by the licensees exercise performance, the
  adequately critique exercise participants initial Protective Action Recommendation
inspectors identified two issues associated with the planning standard that were not
  (PAR) that was communicated to offsite officials. The second issue was that the
adequately critiqued by the licensee. The first issue was that the licensee failed to
  licensee failed to adequately critique exercise participants decision making on the
adequately critique exercise participants initial Protective Action Recommendation
  simulated removal of non-essential onsite personnel, who were not members of the
(PAR) that was communicated to offsite officials. The second issue was that the
  current shift of emergency responders, from the site after all onsite personnel had been
licensee failed to adequately critique exercise participants decision making on the
  accounted for.
simulated removal of non-essential onsite personnel, who were not members of the
  The NRC Manual Chapter (MC) 0609 divides the sixteen emergency planning standards
current shift of emergency responders, from the site after all onsite personnel had been
  of 10 CFR 50.47(b) into two categories, namely risk significant planning standards and
accounted for.
  other planning standards. With respect to the two aforementioned issues, MC 0609
The NRC Manual Chapter (MC) 0609 divides the sixteen emergency planning standards
  states that 10 CFR 50.47(b)(10) is risk significant for offsite PARs but not also for onsite
of 10 CFR 50.47(b) into two categories, namely risk significant planning standards and
  protective actions.
other planning standards. With respect to the two aforementioned issues, MC 0609
  Protective Action Recommendation
states that 10 CFR 50.47(b)(10) is risk significant for offsite PARs but not also for onsite
  The first issue associated with the preliminary White finding was that the licensee did
protective actions.
  not adequately critique the initial PAR. Based on a review of the licensees exercise
Protective Action Recommendation
  scenario manual, Section 6 of the licensees emergency plan, Emergency Plan
The first issue associated with the preliminary White finding was that the licensee did
  Implementing Procedure (EPIP) 1.3, relevant guidance in Nuclear Regulatory Guide
not adequately critique the initial PAR. Based on a review of the licensees exercise
  NUREG 0654 and Supplement 3 of this NUREG, the Environmental Protection Agencys
scenario manual, Section 6 of the licensees emergency plan, Emergency Plan
  protective action guides, and the criteria in Nuclear Energy Institute (NEI) publication 99-
Implementing Procedure (EPIP) 1.3, relevant guidance in Nuclear Regulatory Guide
  02, Revision 2, the inspectors determined that the licensees initial PAR was incorrect
NUREG 0654 and Supplement 3 of this NUREG, the Environmental Protection Agencys
  and unanticipated per the scenario and should not be considered as a successful
protective action guides, and the criteria in Nuclear Energy Institute (NEI) publication 99-
  Performance Indicator (PI) opportunity. In contrast, the licensees critique conclusion
02, Revision 2, the inspectors determined that the licensees initial PAR was incorrect
  was that this initial PAR was a successful Performance Indicator PI opportunity.
and unanticipated per the scenario and should not be considered as a successful
  In accordance with the exercise scenario, the licensees decision maker correctly
Performance Indicator (PI) opportunity. In contrast, the licensees critique conclusion
  declared a General Emergency at about 10:48 a.m. Licensee staff then formulated an
was that this initial PAR was a successful Performance Indicator PI opportunity.
  initial PAR that was communicated to offsite officials within 15 minutes of the General
In accordance with the exercise scenario, the licensees decision maker correctly  
  Emergency declaration. The initial PAR included a correct recommendation to evacuate
declared a General Emergency at about 10:48 a.m. Licensee staff then formulated an
  the public within a two mile radius of the site. However, the inspectors specific concern
initial PAR that was communicated to offsite officials within 15 minutes of the General
  was that this initial PAR also included an unexpected recommendation to evacuate
Emergency declaration. The initial PAR included a correct recommendation to evacuate
  persons within five sectors (L, M, N, P, and Q) between two and five miles from the site,
the public within a two mile radius of the site. However, the inspectors specific concern
  rather than evacuation of persons within three or possibly four of these sectors between
was that this initial PAR also included an unexpected recommendation to evacuate
  two and five miles from the site, which was predicted by the scenario and which would
persons within five sectors (L, M, N, P, and Q) between two and five miles from the site,
  be consistent with the emergency plan and implementing procedures. The inspectors
rather than evacuation of persons within three or possibly four of these sectors between
                                            4
two and five miles from the site, which was predicted by the scenario and which would
be consistent with the emergency plan and implementing procedures. The inspectors


5
based their conclusion that the initial PAR was not a successful PI opportunity on a
based their conclusion that the initial PAR was not a successful PI opportunity on a
number of factors, including:
number of factors, including:
*     Licensee participants were presented with plant conditions, which were correctly
*
      recognized by those tasked with developing and approving the initial PAR, that
Licensee participants were presented with plant conditions, which were correctly
      included a gap release from containment. The scenario also postulated a wind
recognized by those tasked with developing and approving the initial PAR, that
      direction from 90 degrees +/- five degrees, a forecast wind direction shift that
included a gap release from containment. The scenario also postulated a wind
      might occur, and a B atmospheric stability class before and after this possible
direction from 90 degrees +/- five degrees, a forecast wind direction shift that
      wind direction shift.
might occur, and a B atmospheric stability class before and after this possible
*     Per Attachment A to EPIP 1.3 and the output from the licensees offsite dose
wind direction shift.
      projection software, which was used by participants during the exercise and
*
      included atmospheric stability class as an input, a wind direction from 90 degrees
Per Attachment A to EPIP 1.3 and the output from the licensees offsite dose
      +/- five degrees translated into the three downwind sectors (each having a width
projection software, which was used by participants during the exercise and
      of 22.5 degrees) of M, N, and P.
included atmospheric stability class as an input, a wind direction from 90 degrees
*     Per Step 3.3 of EPIP 1.3 and Subsection 5.1.2 of Section 6 of the licensees
+/- five degrees translated into the three downwind sectors (each having a width
      emergency plan, an offsite PAR would include evacuation of a two mile radius
of 22.5 degrees) of M, N, and P.
      from the site and typically (per EPIP 1.3) or in many cases (per the
*
      emergency plan) three or four sectors between two and five miles downwind.
Per Step 3.3 of EPIP 1.3 and Subsection 5.1.2 of Section 6 of the licensees
      However, neither EPIP 1.3 nor the emergency plan specified what circumstances
emergency plan, an offsite PAR would include evacuation of a two mile radius
      might warrant a PAR having more than three or four downwind sectors with the
from the site and typically (per EPIP 1.3) or in many cases (per the
      following possible exception. Step 3.4 of EPIP 1.3 stated that a PAR to evacuate
emergency plan) three or four sectors between two and five miles downwind.  
      all sectors within a five mile radius of the site should be considered if either the
However, neither EPIP 1.3 nor the emergency plan specified what circumstances
      wind speed was less than three miles per hour or if a lake breeze effect was
might warrant a PAR having more than three or four downwind sectors with the
      identified. In contrast, the scenario postulated a wind speed remaining above
following possible exception. Step 3.4 of EPIP 1.3 stated that a PAR to evacuate
      five miles per hour and no lake breeze effect.
all sectors within a five mile radius of the site should be considered if either the
*     As noted by the inspectors and as documented in a few records generated by
wind speed was less than three miles per hour or if a lake breeze effect was
      licensee participants during the exercise, State officials modified the licensees
identified. In contrast, the scenario postulated a wind speed remaining above
      initial PAR to include evacuation of only three downwind sectors (M, N, and P)
five miles per hour and no lake breeze effect.
      between two and five miles from the site.
*
*     The scenario manual indicated that a wind direction shift from about 90 degrees
As noted by the inspectors and as documented in a few records generated by
      to about 115 to 120 degrees would be issued to participants around noontime in
licensee participants during the exercise, State officials modified the licensees
      order to support an exercise objective of having licensee, State, and county
initial PAR to include evacuation of only three downwind sectors (M, N, and P)
      staffs demonstrate their capabilities to deal with changing meteorological
between two and five miles from the site.
      conditions warranting two PARs. During the exercise, the licensees exercise
*
      controllers modified the scenarios postulated wind direction shift such that the
The scenario manual indicated that a wind direction shift from about 90 degrees
      revised wind direction was from about 130 degrees. The inspectors interpreted
to about 115 to 120 degrees would be issued to participants around noontime in
      this controller action to mean that the initial PARs inclusion of five sectors
order to support an exercise objective of having licensee, State, and county
      beyond two miles from the site was not forecast by the scenario and was,
staffs demonstrate their capabilities to deal with changing meteorological
      therefore, unexpected by the scenario and the licensees exercise controllers.
conditions warranting two PARs. During the exercise, the licensees exercise
*     The licensees exercise participants quickly recognized the wind direction shift to
controllers modified the scenarios postulated wind direction shift such that the
      be from 130 degrees. They developed a revised PAR that included the three
revised wind direction was from about 130 degrees. The inspectors interpreted
      downwind sectors between two and five miles from the site that were consistent
this controller action to mean that the initial PARs inclusion of five sectors
      with Attachment A to EPIP 1.3 and the output from the licensees offsite dose
beyond two miles from the site was not forecast by the scenario and was,
      projection software. The inspectors agreed with the licensees critique that the
therefore, unexpected by the scenario and the licensees exercise controllers.
                                          5
*
The licensees exercise participants quickly recognized the wind direction shift to
be from 130 degrees. They developed a revised PAR that included the three
downwind sectors between two and five miles from the site that were consistent
with Attachment A to EPIP 1.3 and the output from the licensees offsite dose
projection software. The inspectors agreed with the licensees critique that the


        development of this revised PAR was a successful PI opportunity.
6
*       The licensee generated a number of Action Requests-Corrective Action Program
development of this revised PAR was a successful PI opportunity.
        (AR-CAP) documents as a result of its exercise critique. The inspectors noted
*
        that only AR-CAP002169 addressed PARs developed during the exercise.
The licensee generated a number of Action Requests-Corrective Action Program
        However, this AR addressed a concern of how to document a PAR change due
(AR-CAP) documents as a result of its exercise critique. The inspectors noted
        to a wind shift. Specifically, this AR-CAPs concern was whether accumulated
that only AR-CAP002169 addressed PARs developed during the exercise.  
        sectors should be documented on the form or only the newly affected downwind
However, this AR addressed a concern of how to document a PAR change due
        sectors. Therefore, the inspectors concluded that the licensee had not
to a wind shift. Specifically, this AR-CAPs concern was whether accumulated
        adequately critiqued its initial PAR.
sectors should be documented on the form or only the newly affected downwind
sectors. Therefore, the inspectors concluded that the licensee had not
adequately critiqued its initial PAR.
Removal of Non-Essential Personnel
Removal of Non-Essential Personnel
The second issue associated with the preliminary White finding was that the licensee did
The second issue associated with the preliminary White finding was that the licensee did
Line 395: Line 446:
An actual assembly and accountability of onsite personnel was performed during the
An actual assembly and accountability of onsite personnel was performed during the
exercise and was successfully completed at about 10:05 a.m., which was after the Site
exercise and was successfully completed at about 10:05 a.m., which was after the Site
Area Emergency declaration and prior to the General Emergency declaration. The
Area Emergency declaration and prior to the General Emergency declaration. The
subsequent removal of non-essential personnel from the site was simulated in order to
subsequent removal of non-essential personnel from the site was simulated in order to
avoid further disrupting the normal work activities of personnel who were not chosen to
avoid further disrupting the normal work activities of personnel who were not chosen to
be otherwise involved in the exercise.
be otherwise involved in the exercise.  
During the exercise, inspectors noted that the decision to begin the simulated removal of
During the exercise, inspectors noted that the decision to begin the simulated removal of
non-essential personnel from the site was not made until about 12:50 p.m. The decision
non-essential personnel from the site was not made until about 12:50 p.m. The decision
occurred over 2.5 hours after all onsite personnel were accounted for and about two
occurred over 2.5 hours after all onsite personnel were accounted for and about two
hours after the licensee issued its initial PAR to offsite officials that included evacuation
hours after the licensee issued its initial PAR to offsite officials that included evacuation
of the public. The decision was to release non-essential personnel and to allow them
of the public. The decision was to release non-essential personnel and to allow them
to leave the site using their own vehicles, although the use of buses to be provided by a
to leave the site using their own vehicles, although the use of buses to be provided by a
local company was discussed.
local company was discussed.
The inspectors reviewed the following documents: Sections 5 and 6 and Appendix D of
The inspectors reviewed the following documents: Sections 5 and 6 and Appendix D of
the licensees emergency plan and EPIP 6.1, which was titled Assembly, Accountability,
the licensees emergency plan and EPIP 6.1, which was titled Assembly, Accountability,
Release, and Evacuation of Personnel. The inspectors also reviewed AR-CAP002156
Release, and Evacuation of Personnel. The inspectors also reviewed AR-CAP002156
and AR-CAP002170 that were generated as a result of the licensees exercise critique,
and AR-CAP002170 that were generated as a result of the licensees exercise critique,
as well as log entries made by several participants who were involved in the decision
as well as log entries made by several participants who were involved in the decision
making process. Based on the inspectors exercise observations, review of the
making process. Based on the inspectors exercise observations, review of the
aforementioned documents, and assessment of the licensees February 14 and 15
aforementioned documents, and assessment of the licensees February 14 and 15
critique presentations, inspectors concluded that the licensee had not adequately
critique presentations, inspectors concluded that the licensee had not adequately
critiqued exercise performance regarding participants decision making to simulate
critiqued exercise performance regarding participants decision making to simulate
removing non-essential personnel from the site. In contrast, the licensees position was
removing non-essential personnel from the site. In contrast, the licensees position was
that its staff had adequately critiqued this decision making and that participants use of
that its staff had adequately critiqued this decision making and that participants use of
EPIP 6.1 was acceptable.
EPIP 6.1 was acceptable.
                                            6


7
The inspectors conclusion was based on a number of factors, including:
The inspectors conclusion was based on a number of factors, including:
*       Subsection 5.1.1.d.2 of Section 6 of the emergency plan stated that an assembly
*
        and release or evacuation will be ordered upon the classification of a Site or
Subsection 5.1.1.d.2 of Section 6 of the emergency plan stated that an assembly
        General Emergency. This subsection and EPIP 6.1 stated that assembled, non-
and release or evacuation will be ordered upon the classification of a Site or
        essential personnel would either be released from the site when no radiological
General Emergency. This subsection and EPIP 6.1 stated that assembled, non-
        conditions were present, or be evacuated from the site when radiological
essential personnel would either be released from the site when no radiological
        conditions were present and additional actions, such as radiological monitoring
conditions were present, or be evacuated from the site when radiological
        and relocation, were required.
conditions were present and additional actions, such as radiological monitoring
*       Subsection 3.2.3 of Section 5 of the emergency plan stated that non-essential
and relocation, were required.
        personnel will be released if conditions allow; however, these conditions were
*
        not specified. Step 4.4 of EPIP 6.1 stated that an evacuation of non-essential
Subsection 3.2.3 of Section 5 of the emergency plan stated that non-essential
        personnel to an offsite assembly area shall be considered under certain
personnel will be released if conditions allow; however, these conditions were
        projected or measured radiological conditions, or other hazards.
not specified. Step 4.4 of EPIP 6.1 stated that an evacuation of non-essential
*       Following the licensees critique presentation on February 14, the inspectors
personnel to an offsite assembly area shall be considered under certain
        asked the licensees exercise controllers about the acceptability of the
projected or measured radiological conditions, or other hazards.
        participants considering the use of buses from a local company to transport non-
*
        essential personnel from the site. The licensee indicated that it believed that an
Following the licensees critique presentation on February 14, the inspectors
        agreement existed with a local company to provide such a support. In contrast,
asked the licensees exercise controllers about the acceptability of the
        the inspectors did not identify evidence of pre-planning, either in the emergency
participants considering the use of buses from a local company to transport non-
        plan or in EPIP 6.1, to use a local company to provide buses to remove non-
essential personnel from the site. The licensee indicated that it believed that an
        essential personnel from the site during an emergency.
agreement existed with a local company to provide such a support. In contrast,
*       At its February 14 critique presentation, the licensee gave the inspectors copies
the inspectors did not identify evidence of pre-planning, either in the emergency
        of two AR associated with its exercise critique of the implementation of EPIP 6.1.
plan or in EPIP 6.1, to use a local company to provide buses to remove non-
        Eight concerns associated with the assembly and accountability processes in
essential personnel from the site during an emergency.
        one onsite building were summarized in AR-CAP002156. Assembly and
*
        Accountability Process was the title of AR-CAP002170, which also listed eight
At its February 14 critique presentation, the licensee gave the inspectors copies
        concerns. Although one of these eight concerns was when to evacuate
of two AR associated with its exercise critique of the implementation of EPIP 6.1.  
        assembled personnel, the AR did not also list a concern about when to release
Eight concerns associated with the assembly and accountability processes in
        assembled personnel consistent with the emergency plans and EPIP 6.1's
one onsite building were summarized in AR-CAP002156. Assembly and
        different meanings of the words release and evacuate.
Accountability Process was the title of AR-CAP002170, which also listed eight
*       After the licensees February 14 critique presentation, the inspectors asked other
concerns. Although one of these eight concerns was when to evacuate
        questions about the participants decision making on removing non-essential
assembled personnel, the AR did not also list a concern about when to release
        personnel from the site, such as whether the decision to begin removing non-
assembled personnel consistent with the emergency plans and EPIP 6.1's
        essential personnel was considered to be timely and what road was eventually
different meanings of the words release and evacuate.
        chosen to reach the Site Boundary Control Center (SBCC). The inspectors
*
        concluded that the licensee did not have sufficient information available to
After the licensees February 14 critique presentation, the inspectors asked other
        respond to these questions.
questions about the participants decision making on removing non-essential
personnel from the site, such as whether the decision to begin removing non-
essential personnel was considered to be timely and what road was eventually
chosen to reach the Site Boundary Control Center (SBCC).   The inspectors
concluded that the licensee did not have sufficient information available to
respond to these questions.
Significance Determination
Significance Determination
Appendix B to NRC Manual Chapter (MC) 0610* includes criteria for determining
Appendix B to NRC Manual Chapter (MC) 0610* includes criteria for determining
whether an issue warrants further analysis and documentation in an inspection report as
whether an issue warrants further analysis and documentation in an inspection report as
a finding. Using these criteria, the inspectors determined that the issues of the
a finding. Using these criteria, the inspectors determined that the issues of the
licensees failure to adequately critique: (1) its participants initial PAR and (2) its
licensees failure to adequately critique: (1) its participants initial PAR and (2) its
participants decision making on the simulated removal of non-essential personnel from
participants decision making on the simulated removal of non-essential personnel from
                                          7


    the site were issues that had a credible impact on safety. Each issue could also be
8
    viewed as a precursor to a significant event and would, if left uncorrected, under the
the site were issues that had a credible impact on safety. Each issue could also be
    same conditions become a more significant safety concern. Both critique issues were
viewed as a precursor to a significant event and would, if left uncorrected, under the
    evaluated as such because a basic reason for conducting Emergency Preparedness
same conditions become a more significant safety concern. Both critique issues were
    drills and exercises is to identify performance and procedure concerns so that corrective
evaluated as such because a basic reason for conducting Emergency Preparedness  
    actions on such concerns can be taken before these concerns may occur during an
drills and exercises is to identify performance and procedure concerns so that corrective
    actual emergency and have an adverse impact on health and safety.
actions on such concerns can be taken before these concerns may occur during an
    Appendix B to MC 0609 divides the 16 emergency planning standards of 10 CFR
actual emergency and have an adverse impact on health and safety.
    50.47(b) into two categories, specifically risk significant and other planning
Appendix B to MC 0609 divides the 16 emergency planning standards of 10 CFR
    standards. With respect to the two aforementioned issues, Subsection 5.10 of Appendix
50.47(b) into two categories, specifically risk significant and other planning
    B states that 10 CFR 50.47(b)(10) is risk significant for offsite PARs, but not for onsite
standards. With respect to the two aforementioned issues, Subsection 5.10 of Appendix
    protective actions.
B states that 10 CFR 50.47(b)(10) is risk significant for offsite PARs, but not for onsite
    Rather than have a separate finding for each critique issue, it is appropriate to identify
protective actions.
    one preliminary finding to encompass both issues and to focus on their common factor,
Rather than have a separate finding for each critique issue, it is appropriate to identify
    specifically that both issues were inadequately critiqued by licensee staff. It is then
one preliminary finding to encompass both issues and to focus on their common factor,
    appropriate to assign a preliminary significance to the evaluation of the licensees
specifically that both issues were inadequately critiqued by licensee staff. It is then
    critique that is associated with the more risk significant of the two critique issues (White)
appropriate to assign a preliminary significance to the evaluation of the licensees
    (Unresolved Item No. 50-266/02-04-01 and 50-301/02-04-01).
critique that is associated with the more risk significant of the two critique issues (White)
4.   OTHER ACTIVITIES
(Unresolved Item No. 50-266/02-04-01 and 50-301/02-04-01).
4.
OTHER ACTIVITIES
4OA1 Performance Indicator (PI) Verification (71151)
4OA1 Performance Indicator (PI) Verification (71151)
a. Inspection Scope
  a.
    The inspectors reviewed the licensees records related to each of the three emergency
Inspection Scope
    preparedness PIs to verify that the licensees program was implemented consistent with
The inspectors reviewed the licensees records related to each of the three emergency
    the industry guidelines in Nuclear Energy Institute publication No. 99-02 and related
preparedness PIs to verify that the licensees program was implemented consistent with
    licensee procedures. Specifically, licensee records related to the performance of the
the industry guidelines in Nuclear Energy Institute publication No. 99-02 and related
    Alert and Notification System (ANS), key Emergency Response Organization (ERO)
licensee procedures. Specifically, licensee records related to the performance of the
    members drill participation, and Drill and Exercise Performance (DEP) were reviewed to
Alert and Notification System (ANS), key Emergency Response Organization (ERO)
    verify the accuracy and completeness of the data submitted to NRC for the period
members drill participation, and Drill and Exercise Performance (DEP) were reviewed to
    October 2001 through December 2001.
verify the accuracy and completeness of the data submitted to NRC for the period
b. Findings
October 2001 through December 2001.
    No findings of significance were identified.
  b.
Findings
No findings of significance were identified.  
4OA6 Meetings
4OA6 Meetings
a   Exit Meeting
  a
    The inspectors presented the preliminary inspection results to Mr. M. Reddemann and
Exit Meeting
    other members of licensee management and staff at an interim exit meeting on
The inspectors presented the preliminary inspection results to Mr. M. Reddemann and
    February 15, 2002. The licensee acknowledged the information presented. No
other members of licensee management and staff at an interim exit meeting on
    proprietary information was identified. On April 1, 2002, a final exit meeting was held
February 15, 2002. The licensee acknowledged the information presented. No
    with Mr. F. Cayia and other members of licensee management and staff.
proprietary information was identified. On April 1, 2002, a final exit meeting was held
                                                8
with Mr. F. Cayia and other members of licensee management and staff.


b. Other Meeting
9
  On February 15, 2002, an inspector summarized NRCs preliminary inspection results at
  b.
  a public and media briefing hosted by the Federal Emergency Management Agency in
Other Meeting
  Manitowoc, Wisconsin.
On February 15, 2002, an inspector summarized NRCs preliminary inspection results at
                                          9
a public and media briefing hosted by the Federal Emergency Management Agency in
Manitowoc, Wisconsin.  


                                KEY POINTS OF CONTACT
10
KEY POINTS OF CONTACT
Interim Exit Meeting
Interim Exit Meeting
Licensee
Licensee
Line 538: Line 599:
L. Armstrong, Engineering Manager
L. Armstrong, Engineering Manager
W. Bartelme, EP Coordinator
W. Bartelme, EP Coordinator
A. Cayia, Site Director
A. Cayia, Site Director  
F. Flenje, Senior Regulatory Compliance Specialist
F. Flenje, Senior Regulatory Compliance Specialist
R. Hopkins, Nuclear Oversight Supervisor
R. Hopkins, Nuclear Oversight Supervisor
Line 554: Line 615:
T. Ploski, Senior EP Inspector, Region III
T. Ploski, Senior EP Inspector, Region III
K. Riemer, Chief, Plant Support Branch, Region III
K. Riemer, Chief, Plant Support Branch, Region III
                                              10


                    LIST OF ITEMS OPENED, CLOSED AND DISCUSSED
11
LIST OF ITEMS OPENED, CLOSED AND DISCUSSED
Opened
Opened
50-266/02-04-01       URI   Inadequate critique of two exercise performance issues
50-266/02-04-01
50-301/02-04-01             (Section 1EP1.b)
URI
Inadequate critique of two exercise performance issues
50-301/02-04-01
(Section 1EP1.b)
Closed
Closed
None
None
Discussed
Discussed
None
None
                                LIST OF ACRONYMS USED
LIST OF ACRONYMS USED
ANS         Alert and Notification System
ANS
AR           Action Request
Alert and Notification System
CAP         Corrective Action Program
AR
CFR         Code of Federal Regulations
Action Request
CRS         Control Room Simulator
CAP
DEP         Drill and Exercise Performance
Corrective Action Program
DRS         Division of Reactor Safety
CFR
EOF         Emergency Operations Facility
Code of Federal Regulations
EP           Emergency Preparedness
CRS
EPIP         Emergency Plan Implementing Procedure
Control Room Simulator
ERO         Emergency Response Organization
DEP
IR           Inspection Report
Drill and Exercise Performance  
MC           NRC Manual Chapter
DRS
NRC         Nuclear Regulatory Commission
Division of Reactor Safety
NUREG       Nuclear Regulatory Guide
EOF
OSC         Operations Support Center
Emergency Operations Facility
PAR         Protective Action Recommendation
EP
PI           Performance Indicator
Emergency Preparedness
SBCC         Site Boundary Control Center
EPIP
TBD         To Be Determined
Emergency Plan Implementing Procedure
TSC         Technical Support Center
ERO
                                              11
Emergency Response Organization
IR
Inspection Report
MC
NRC Manual Chapter
NRC
Nuclear Regulatory Commission
NUREG
Nuclear Regulatory Guide
OSC
Operations Support Center
PAR
Protective Action Recommendation
PI
Performance Indicator
SBCC
Site Boundary Control Center
TBD
To Be Determined
TSC
Technical Support Center


                          LIST OF DOCUMENTS REVIEWED
12
1EP1 Exercise Evaluation
LIST OF DOCUMENTS REVIEWED
                  February 2002 Exercise Scenario Manual
1EP1
                  Summary of January 2002 Drill Scenario
Exercise Evaluation
                  Licensees Time Line on Decisions on Simulated
EPIP 1.1
                  Removal of Non-essential Personnel
EPIP 1.2
                  Point Beach Nuclear Plant Emergency Plan             August 2000
EPIP 1.3
EPIP 1.1          Course of Actions                                   Revision 37
EPIP 2.1
EPIP 1.2          Emergency Classification                             Revision 34
EPIP 4.1
EPIP 1.3          Dose Assessment and Protective Action
EPIP 4.2
                  Recommendations                                     Revision 27
EPIP 4.3
EPIP 2.1          Notifications                                       Revision 22
EPIP 4.7
EPIP 4.1          TSC Activation and Evacuation                       Revision 30
EPIP 5.1
EPIP 4.2          OSC Activation and Evacuation                       Revision 14
EPIP 5.2
EPIP 4.3          EOF Activation and Evacuation                       Revision 24
EPIP 6.1
EPIP 4.7          Offsite Radiation Protection Facility Activation and
EPIP 10.1
                  Evacuation                                           Revision 1
AR-CAP002117
EPIP 5.1          Personnel Emergency Dose Authorization               Revision 13
AR-CAP002127
EPIP 5.2          Radioiodine Blocking and Thyroid Dose               Revision 13
AR-CAP002156
                  Accounting
AR-CAP002166
EPIP 6.1          Assembly and Accountability, Release and             Revision 19
AR-CAP002167
                  Evacuation of Personnel
AR-CAP002168
EPIP 10.1        Emergency Reentry                                   Revision 21
AR-CAP002169
AR-CAP002117      Joint Public Information Center Does Not Appear
AR-CAP002170
                  to be Set Up for Concurrent Kewaunee and Point
AR-CAP002171
                  Beach Plant Emergency Events
AR-CAP002172
AR-CAP002127      Supply Discrepancies in TSC, OSC, and EOF
AR-CAP002173
AR-CAP002156      Assembly/Accountability Problems in North
AR-CAP002174
                  Service Building
February 2002 Exercise Scenario Manual
AR-CAP002166      Reassess Emergency Action Level 1.1.5.1
Summary of January 2002 Drill Scenario
AR-CAP002167      Lab Coats Not Available for Sample Handlers
Licensees Time Line on Decisions on Simulated
AR-CAP002168      Milwaukee Call Center Provided Out of Date
Removal of Non-essential Personnel
                  Information to Simulated Public Callers
Point Beach Nuclear Plant Emergency Plan
AR-CAP002169      How to Document PAR Change Due to Wind
Course of Actions
                  Direction Shift on State/County Notification Form
Emergency Classification
AR-CAP002170      Reassess Assembly and Accountability Process
Dose Assessment and Protective Action
AR-CAP002171      Discrepancy in Dose Assessment Programs
Recommendations
                  Computer Monitor Display versus a Printout
Notifications
AR-CAP002172      Develop Briefing Sheets for Directors
TSC Activation and Evacuation
AR-CAP002173      Miscellaneous Equipment Issues During Exercise
OSC Activation and Evacuation
AR-CAP002174      Qualifications of Craft Personnel for Some Tasks
EOF Activation and Evacuation
                                            12
Offsite Radiation Protection Facility Activation and
Evacuation
Personnel Emergency Dose Authorization
Radioiodine Blocking and Thyroid Dose
Accounting
Assembly and Accountability, Release and
Evacuation of Personnel  
Emergency Reentry
Joint Public Information Center Does Not Appear
to be Set Up for Concurrent Kewaunee and Point
Beach Plant Emergency Events
Supply Discrepancies in TSC, OSC, and EOF
Assembly/Accountability Problems in North
Service Building
Reassess Emergency Action Level 1.1.5.1
Lab Coats Not Available for Sample Handlers
Milwaukee Call Center Provided Out of Date
Information to Simulated Public Callers
How to Document PAR Change Due to Wind
Direction Shift on State/County Notification Form
Reassess Assembly and Accountability Process
Discrepancy in Dose Assessment Programs
Computer Monitor Display versus a Printout
Develop Briefing Sheets for Directors
Miscellaneous Equipment Issues During Exercise
Qualifications of Craft Personnel for Some Tasks
August 2000
Revision 37
Revision 34
Revision 27
Revision 22
Revision 30
Revision 14
Revision 24
Revision 1
Revision 13
Revision 13
Revision 19
Revision 21


AR-CAP002175     Shift Manager Unable to Activate Primary ERO
13
                  Notification System
AR-CAP002175
AR-CAP002176      Dose/PAR Coordinator Checklist Concern
AR-CAP002176
AR-CAP002177      CRS Crew Twice Started Equipment Without
AR-CAP002177
                  Proper Investigation
AR-CAP002178
AR-CAP002178      Problems Hearing Gai-Tronics Announcements
AR-CAP002179
AR-CAP002179      Several Staff Reading Personal Reading
AR-CAP002180
                  Materials in OSC Briefing Room During Exercise
AR-CAP002181
AR-CAP002180      Participant Access Problem at Joint Public
AR-CAP002182
                  Information Center
AR-CAP002183
AR-CAP002181      Several Non-Participants Unwilling to Augment
AR-CAP002184
                  Participants When Requested
AR-CAP002185
AR-CAP002182      Several Simulator Fidelity and Controller
AR-CAP002186
                  Performance Issues
AR-CAP002189
AR-CAP002183      Several Information Flow Problems in TSC
AR-CAP002190
AR-CAP002184      Two Participants Not Fully Qualified
AR-CAP002215
AR-CAP002185      Environmental Sample Analysis Records Keeping
Shift Manager Unable to Activate Primary ERO
AR-CAP002186      Accumulated Dose Tracking Concern in OSC
Notification System
AR-CAP002189      EP Staff Involvement in Operator Training for
Dose/PAR Coordinator Checklist Concern
                  DEP Performance Indicator
CRS Crew Twice Started Equipment Without
AR-CAP002190      Two Vehicles Had Insufficient Gas
Proper Investigation
AR-CAP002215      Instances of OSC Teams Not Demonstrating
Problems Hearing Gai-Tronics Announcements
                  Good Contamination Control Practices
Several Staff Reading Personal Reading
Materials in OSC Briefing Room During Exercise
Participant Access Problem at Joint Public
Information Center
Several Non-Participants Unwilling to Augment
Participants When Requested
Several Simulator Fidelity and Controller
Performance Issues
Several Information Flow Problems in TSC
Two Participants Not Fully Qualified
Environmental Sample Analysis Records Keeping  
Accumulated Dose Tracking Concern in OSC
EP Staff Involvement in Operator Training for
DEP Performance Indicator
Two Vehicles Had Insufficient Gas
Instances of OSC Teams Not Demonstrating
Good Contamination Control Practices
4OA1 Performance Indicator Verification
4OA1 Performance Indicator Verification
                  Fourth Quarter 2001 Evaluation Forms for Three
MO4-11
                  PIs
MO4-12
MO4-11            Field Observations of Sirens Full Sound Test   November 7, 2001
MO5-12
MO4-12            Full Sound Siren Test Records - October through
AR-CAP-002214
                  December 2001
Fourth Quarter 2001 Evaluation Forms for Three  
MO5-12            Growl Sound Siren Test Records - October
PIs  
                  through December 2001
Field Observations of Sirens Full Sound Test
                  Drill Nuclear Accident Reporting Form           October 4, 2001
Full Sound Siren Test Records - October through
                  Drill Nuclear Accident Reporting Forms         December 6, 2001
December 2001
                  Drill Scenario Time Line                       December 2001
Growl Sound Siren Test Records - October
AR-CAP-002214    Reassess Which EOF Position is State/County
through December 2001
                  Communicator for PI Reporting Purposes
Drill Nuclear Accident Reporting Form
                                            13
Drill Nuclear Accident Reporting Forms
Drill Scenario Time Line  
Reassess Which EOF Position is State/County
Communicator for PI Reporting Purposes
November 7, 2001
October 4, 2001
December 6, 2001
December 2001
}}
}}

Latest revision as of 18:43, 16 January 2025

IR 05000266/2002-004(DRS), IR 05000301/2002-004(DRS), on 02/11-04/1/2002, Nuclear Management Company, LLC, Point Beach Nuclear Plant, Units 1 and 2. Exercise Evaluation
ML021210488
Person / Time
Site: Point Beach  NextEra Energy icon.png
Issue date: 04/30/2002
From: Grobe J
Division of Reactor Safety III
To: Warner M
Nuclear Management Co
References
EA-02-049 IR-02-004
Download: ML021210488 (18)


See also: IR 05000266/2002004

Text

April 30, 2002

EA-02-049

Mr. M. Warner

Site Vice President

Kewaunee and Point Beach Nuclear Plants

Nuclear Management Company, LLC

6610 Nuclear Road

Two Rivers, WI 54241

SUBJECT:

POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2

NRC INSPECTION REPORT 50-266/02-04(DRS); 50-301/02-04(DRS)

PRELIMINARY WHITE FINDING

Dear Mr. Warner:

On April 1, 2002, the NRC completed an inspection of your Point Beach Nuclear Plant, Units 1 and

2. The enclosed report documents the inspection results, which were discussed with Mr. M.

Reddemann and members of your staff at an interim exit meeting on February 15, 2002.

Following the on site inspection, additional information was provided by your staff that was

reviewed in the Region III office. A final exit meeting was conducted on April 1, 2002, with Mr. A.

Cayia and other members of your staff to discuss the NRCs preliminary significance determination

of the inspection results.

The inspection examined activities conducted under your license as they relate to safety and

compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed

personnel. Specifically, this inspection focused on emergency preparedness, including your

staffs determinations of performance indicators for the Emergency Preparedness Cornerstone.

The enclosed report discusses an issue involving your staffs critique of its performance during

the biennial emergency preparedness exercise that was conducted on February 12, 2002. The

NRCs preliminary conclusion is that two exercise performance concerns, which are associated

with emergency preparedness planning standard 10 CFR 50.47(b)(10), were inadequately

critiqued by your staff. The first concern was the critique of the initial protective action

recommendation that your exercise participants communicated to offsite officials. Your

exercise critique concluded that this recommendation was a successful performance indicator

opportunity. However, our inspection identified issues concerning this recommendation that

were not fully evaluated within your critique. The second concern involved your staffs critique

of the exercise participants decision making on the simulated removal from the site of non-

essential personnel, who were not members of the current shift of emergency responders, after

all onsite personnel were accounted for.

M. Warner

-2-

This issue was assessed using the applicable significance determination process as a

potentially safety significant finding that was preliminarily determined to be White, i.e. an issue

with some increased importance to safety which may require additional NRC inspection. A

basic reason for conducting emergency preparedness drills and exercises is to identify

performance and procedure concerns through the critique process so that corrective actions

can be taken before such concerns might occur during an actual emergency and possibly have

an adverse impact on health and safety. Therefore, it is important that your staffs critiques of

emergency preparedness drills and exercises be thorough and self-critical whether or not NRC

staff are also present to observe and assess these activities. Since both items are associated

with an exercise critique, rather than an actual emergency event, no apparent violation is

associated with the preliminary White finding.

Before the NRC makes a final decision on this matter, we are providing you an opportunity to

request a Regulatory Conference where you would be able to provide your perspectives on the

significance of the finding, the bases for your position, and whether you agree with the apparent

violations (if applicable). If you choose to request a Regulatory Conference, we encourage you

to submit your evaluation and any differences with the NRC evaluation at least one week prior

to the conference in an effort to make the conference more efficient and effective. If a

conference is held, it will be open for public observation. The NRC will also issue a press

release to announce the conference.

Please contact Mr. Kenneth Riemer at (630) 829-9757 within seven days of the date of this

letter to inform the NRC of your intentions. If we have not heard from you by telephone or in

writing regarding a conference within 10 days, we will continue with our significance

determination and enforcement decision, and you will be advised by separate correspondence

of the results of our deliberations on this matter.

In accordance with 10 CFR Part 2.790 of the NRC's "Rules of Practice," a copy of this letter

and its enclosure will be 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). ADAMS is accessible from the NRC Web site at

http://www.nrc.gov/NRC/ADAMS/index.html (the Public Electronic Reading Room).

Sincerely,

/RA by Roy Caniano Acting For/

John A. Grobe, Director

Division of Reactor Safety

Docket Nos. 50-266; 50-301

License Nos. DPR-24; DPR-27

Enclosure:

Inspection Report 50-266/02-04(DRS);

50-301/02-04(DRS)

See Attached Distribution

M. Warner

-2-

This issue was assessed using the applicable significance determination process as a

potentially safety significant finding that was preliminarily determined to be White, i.e. an issue

with some increased importance to safety which may require additional NRC inspection. A

basic reason for conducting emergency preparedness drills and exercises is to identify

performance and procedure concerns through the critique process so that corrective actions

can be taken before such concerns might occur during an actual emergency and possibly have

an adverse impact on health and safety. Therefore, it is important that your staffs critiques of

emergency preparedness drills and exercises be thorough and self-critical whether or not NRC

staff are also present to observe and assess these activities. Since both items are associated

with an exercise critique, rather than an actual emergency event, no apparent violation is

associated with the preliminary White finding.

Before the NRC makes a final decision on this matter, we are providing you an opportunity to

request a Regulatory Conference where you would be able to provide your perspectives on the

significance of the finding, the bases for your position, and whether you agree with the apparent

violations (if applicable). If you choose to request a Regulatory Conference, we encourage you

to submit your evaluation and any differences with the NRC evaluation at least one week prior

to the conference in an effort to make the conference more efficient and effective. If a

conference is held, it will be open for public observation. The NRC will also issue a press

release to announce the conference.

Please contact Mr. Kenneth Riemer at (630) 829-9757 within seven days of the date of this

letter to inform the NRC of your intentions. If we have not heard from you by telephone or in

writing regarding a conference within 10 days, we will continue with our significance

determination and enforcement decision, and you will be advised by separate correspondence

of the results of our deliberations on this matter

In accordance with 10 CFR Part 2.790 of the NRC's "Rules of Practice," a copy of this letter

and its enclosure will be 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). ADAMS is accessible from the NRC Web site at

http://www.nrc.gov/NRC/ADAMS/index.html (the Public Electronic Reading Room).

Sincerely,

/RA by Roy Caniano Acting For/

John A. Grobe, Director

Division of Reactor Safety

Docket Nos. 50-266; 50-301

License Nos. DPR-24; DPR-27

Enclosure:

Inspection Report 50-266/02-04(DRS);

50-301/02-04(DRS)

See Attached Distribution

DOCUMENT NAME: G:DRS\\POI02-04DRS.wpd

To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy

OFFICE

RIII

RIII

RIII

RIII

RIII

NAME

TPloski:aa

KRiemer

RLanksbury

KLambert for

BClayton

RCaniano

for JGrobe

DATE

4/30/02

4/30/02

4/30/02

4/30/02

4/30/02

OFFICIAL RECORD COPY

M. Warner

-3-

cc w/encl:

R. Grigg, President and Chief

Operating Officer, WEPCo

R. Anderson, Executive Vice President

and Chief Nuclear Officer

T. Webb, Licensing Manager

D. Weaver, Nuclear Asset Manager

T. Taylor, Plant Manager

A. Cayia, Site Director

J. ONeill, Jr., Shaw, Pittman,

Potts & Trowbridge

K. Duveneck, Town Chairman

Town of Two Creeks

D. Graham, Director

Bureau of Field Operations

A. Bie, Chairperson, Wisconsin

Public Service Commission

S. Jenkins, Electric Division

Wisconsin Public Service Commission

State Liaison Officer

W. Curtis, FEMA, Region V

M. Warner

-3-

cc w/encl:

R. Grigg, President and Chief

Operating Officer, WEPCo

R. Anderson, Executive Vice President

and Chief Nuclear Officer

T. Webb, Licensing Manager

D. Weaver, Nuclear Asset Manager

T. Taylor, Plant Manager

A. Cayia, Site Director

J. ONeill, Jr., Shaw, Pittman,

Potts & Trowbridge

K. Duveneck, Town Chairman

Town of Two Creeks

D. Graham, Director

Bureau of Field Operations

A. Bie, Chairperson, Wisconsin

Public Service Commission

S. Jenkins, Electric Division

Wisconsin Public Service Commission

State Liaison Officer

W. Curtis, FEMA, Region V

ADAMS Distribution:

WDR

DFT

BAW

RidsNrrDipmIipb

OEMAIL

J. Dixon Herrity, OE

K. Halvey Gibson, NRR

GEG

HBC

PGK1

C. Ariano (hard copy)

DRPIII

DRSIII

PLB1

JRK1

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Docket Nos:

50-266; 50-301

License Nos:

DPR-24; DPR-27

Report No:

50-266/02-04(DRS); 50-301/02-04(DRS)

Licensee:

Nuclear Management Company, LLC

Facility:

Point Beach Nuclear Plant, Units 1 and 2

Location:

6610 Nuclear Road

Two Rivers, WI 54241

Dates:

February 11 through February 15, 2002; and

April 1, 2002

Inspectors:

T. Ploski, Senior Emergency Preparedness Inspector

R. Jickling, Emergency Preparedness Inspector

S. Orth, Senior Radiation Specialist

P. Krohn, Senior Resident Inspector

Approved by:

Kenneth Riemer, Chief

Plant Support Branch

2

SUMMARY OF FINDINGS

IR 05000266-02-04(DRS), 05000301-02-04(DRS), on 02/11-04/1/2002, Nuclear Management

Company, LLC, Point Beach Nuclear Plant, Units 1 and 2. Exercise Evaluation.

The report covers a baseline inspection by two regional emergency preparedness

inspectors, one regional radiation protection inspector, and a senior resident inspector.

The inspection focused on the Reactor Safety, Emergency Preparedness Cornerstone,

during the biennial emergency preparedness exercise, and included a review of

records related to the three emergency preparedness performance indicators for the

period ending December 31, 2001. One preliminary White finding was identified

during the inspection.

The significance of most findings is indicated by their color (Green, White, Yellow, Red)

using IMC 0609 Significance Determination Process (SDP). The NRCs program for

overseeing the safe operation of commercial nuclear power reactors is described at its

Reactor Oversight Process website at http://www/nrc.gov/NRR/OVERSIGHT/index.html.

Findings for which the SDP does not apply are indicated by No Color or by the severity

level of the applicable violations.

A.

Inspector Identified Findings

Cornerstone: Emergency Preparedness

TBD. Two exercise performance issues, which are associated with emergency preparedness

planning standard 10 CFR 50.47(b)(10), were inadequately critiqued by licensee staff. The first

issue was associated with the licensees critique of the initial offsite Protective Action

Recommendation (PAR) that its exercise participants communicated to offsite officials. The

NRC identified issues that contradicted the licensees critique conclusion that the initial PAR

was a successful performance indicator opportunity with respect to its content. The second

issue was the licensees critique of its participants decision making process on the simulated

removal from the site of non-essential personnel, who were not members of the current shift of

emergency responders, once all onsite personnel were accounted for.

Using the Emergency Preparedness Significance Determination Process, the NRC has made a

preliminary determination that the finding was of low to moderate risk significance (White). In

accordance with NRCs Enforcement Policy, as published in NUREG 1600, it was determined

that there is no apparent violation of NRC requirements since the critique issues were related to

an exercise, rather than to an actual emergency. (Section 1EP1.b)

3

Report Details

Summary of Plant Status

The plant operated at approximately 100 percent power throughout the inspection period.

1.

REACTOR SAFETY

Cornerstone: Emergency Preparedness

1EP1

Exercise Evaluation (71114.01)

a.

Inspection Scope

The inspectors reviewed the February 2002 exercises objectives and scenario to

ensure that the exercise would acceptably test major elements of the licensees

emergency plan and to verify that the exercises simulated problems provided an

acceptable framework to support demonstration of the licensees capability to

implement its plan. The inspectors also reviewed records of a pre-exercise practice

drill, which was conducted in January 2002, to determine whether the associated

accident scenario was sufficiently different from the scenario used in the

February 12, 2002 exercise.

The inspectors evaluated the licensees exercise performance, focusing on the

risk-significant activities of emergency classification, notification, and protective action

decision making, as well as implementation of accident mitigation strategies in the

following emergency response facilities:

Control Room Simulator (CRS)

Technical Support Center (TSC)

Operations Support Center (OSC)

Emergency Operations Facility (EOF)

The inspectors also assessed the licensees 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 licensees emergency plan.

The inspectors attended the initial post-exercise critiques in the CRS, OSC, TSC, and

EOF to evaluate the licensees initial self-assessment of its exercise performance. The

inspectors later met with the licensees lead exercise evaluators to assess the licensees

refined critique of its exercise participants performances. The licensees refined

critiques results were then compared with the inspectors independent observations and

assessments.

4

b.

Findings

One preliminary White finding was identified for the licensees inadequate critique of two

exercise performance issues associated with emergency planning standard 10 CFR 50.47(b)(10). Per Supplement VIII of NRCs Enforcement Policy, as published in

Nuclear Regulatory Guide (NUREG) 1600, no associated violation of NRC requirements

was identified since the finding was associated with an exercise rather than an actual

emergency event.

This planning standard encompasses protective actions for the general public and

onsite personnel. As demonstrated by the licensees exercise performance, the

inspectors identified two issues associated with the planning standard that were not

adequately critiqued by the licensee. The first issue was that the licensee failed to

adequately critique exercise participants initial Protective Action Recommendation

(PAR) that was communicated to offsite officials. The second issue was that the

licensee failed to adequately critique exercise participants decision making on the

simulated removal of non-essential onsite personnel, who were not members of the

current shift of emergency responders, from the site after all onsite personnel had been

accounted for.

The NRC Manual Chapter (MC) 0609 divides the sixteen emergency planning standards

of 10 CFR 50.47(b) into two categories, namely risk significant planning standards and

other planning standards. With respect to the two aforementioned issues, MC 0609

states that 10 CFR 50.47(b)(10) is risk significant for offsite PARs but not also for onsite

protective actions.

Protective Action Recommendation

The first issue associated with the preliminary White finding was that the licensee did

not adequately critique the initial PAR. Based on a review of the licensees exercise

scenario manual, Section 6 of the licensees emergency plan, Emergency Plan

Implementing Procedure (EPIP) 1.3, relevant guidance in Nuclear Regulatory Guide

NUREG 0654 and Supplement 3 of this NUREG, the Environmental Protection Agencys

protective action guides, and the criteria in Nuclear Energy Institute (NEI) publication 99-

02, Revision 2, the inspectors determined that the licensees initial PAR was incorrect

and unanticipated per the scenario and should not be considered as a successful

Performance Indicator (PI) opportunity. In contrast, the licensees critique conclusion

was that this initial PAR was a successful Performance Indicator PI opportunity.

In accordance with the exercise scenario, the licensees decision maker correctly

declared a General Emergency at about 10:48 a.m. Licensee staff then formulated an

initial PAR that was communicated to offsite officials within 15 minutes of the General

Emergency declaration. The initial PAR included a correct recommendation to evacuate

the public within a two mile radius of the site. However, the inspectors specific concern

was that this initial PAR also included an unexpected recommendation to evacuate

persons within five sectors (L, M, N, P, and Q) between two and five miles from the site,

rather than evacuation of persons within three or possibly four of these sectors between

two and five miles from the site, which was predicted by the scenario and which would

be consistent with the emergency plan and implementing procedures. The inspectors

5

based their conclusion that the initial PAR was not a successful PI opportunity on a

number of factors, including:

Licensee participants were presented with plant conditions, which were correctly

recognized by those tasked with developing and approving the initial PAR, that

included a gap release from containment. The scenario also postulated a wind

direction from 90 degrees +/- five degrees, a forecast wind direction shift that

might occur, and a B atmospheric stability class before and after this possible

wind direction shift.

Per Attachment A to EPIP 1.3 and the output from the licensees offsite dose

projection software, which was used by participants during the exercise and

included atmospheric stability class as an input, a wind direction from 90 degrees

+/- five degrees translated into the three downwind sectors (each having a width

of 22.5 degrees) of M, N, and P.

Per Step 3.3 of EPIP 1.3 and Subsection 5.1.2 of Section 6 of the licensees

emergency plan, an offsite PAR would include evacuation of a two mile radius

from the site and typically (per EPIP 1.3) or in many cases (per the

emergency plan) three or four sectors between two and five miles downwind.

However, neither EPIP 1.3 nor the emergency plan specified what circumstances

might warrant a PAR having more than three or four downwind sectors with the

following possible exception. Step 3.4 of EPIP 1.3 stated that a PAR to evacuate

all sectors within a five mile radius of the site should be considered if either the

wind speed was less than three miles per hour or if a lake breeze effect was

identified. In contrast, the scenario postulated a wind speed remaining above

five miles per hour and no lake breeze effect.

As noted by the inspectors and as documented in a few records generated by

licensee participants during the exercise, State officials modified the licensees

initial PAR to include evacuation of only three downwind sectors (M, N, and P)

between two and five miles from the site.

The scenario manual indicated that a wind direction shift from about 90 degrees

to about 115 to 120 degrees would be issued to participants around noontime in

order to support an exercise objective of having licensee, State, and county

staffs demonstrate their capabilities to deal with changing meteorological

conditions warranting two PARs. During the exercise, the licensees exercise

controllers modified the scenarios postulated wind direction shift such that the

revised wind direction was from about 130 degrees. The inspectors interpreted

this controller action to mean that the initial PARs inclusion of five sectors

beyond two miles from the site was not forecast by the scenario and was,

therefore, unexpected by the scenario and the licensees exercise controllers.

The licensees exercise participants quickly recognized the wind direction shift to

be from 130 degrees. They developed a revised PAR that included the three

downwind sectors between two and five miles from the site that were consistent

with Attachment A to EPIP 1.3 and the output from the licensees offsite dose

projection software. The inspectors agreed with the licensees critique that the

6

development of this revised PAR was a successful PI opportunity.

The licensee generated a number of Action Requests-Corrective Action Program

(AR-CAP) documents as a result of its exercise critique. The inspectors noted

that only AR-CAP002169 addressed PARs developed during the exercise.

However, this AR addressed a concern of how to document a PAR change due

to a wind shift. Specifically, this AR-CAPs concern was whether accumulated

sectors should be documented on the form or only the newly affected downwind

sectors. Therefore, the inspectors concluded that the licensee had not

adequately critiqued its initial PAR.

Removal of Non-Essential Personnel

The second issue associated with the preliminary White finding was that the licensee did

not adequately critique its exercise participants decision making on the simulated

removal of non-essential onsite personnel, who were not members of the current shift of

emergency responders, from the site after all onsite personnel were accounted for.

An actual assembly and accountability of onsite personnel was performed during the

exercise and was successfully completed at about 10:05 a.m., which was after the Site

Area Emergency declaration and prior to the General Emergency declaration. The

subsequent removal of non-essential personnel from the site was simulated in order to

avoid further disrupting the normal work activities of personnel who were not chosen to

be otherwise involved in the exercise.

During the exercise, inspectors noted that the decision to begin the simulated removal of

non-essential personnel from the site was not made until about 12:50 p.m. The decision

occurred over 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> after all onsite personnel were accounted for and about two

hours after the licensee issued its initial PAR to offsite officials that included evacuation

of the public. The decision was to release non-essential personnel and to allow them

to leave the site using their own vehicles, although the use of buses to be provided by a

local company was discussed.

The inspectors reviewed the following documents: Sections 5 and 6 and Appendix D of

the licensees emergency plan and EPIP 6.1, which was titled Assembly, Accountability,

Release, and Evacuation of Personnel. The inspectors also reviewed AR-CAP002156

and AR-CAP002170 that were generated as a result of the licensees exercise critique,

as well as log entries made by several participants who were involved in the decision

making process. Based on the inspectors exercise observations, review of the

aforementioned documents, and assessment of the licensees February 14 and 15

critique presentations, inspectors concluded that the licensee had not adequately

critiqued exercise performance regarding participants decision making to simulate

removing non-essential personnel from the site. In contrast, the licensees position was

that its staff had adequately critiqued this decision making and that participants use of

EPIP 6.1 was acceptable.

7

The inspectors conclusion was based on a number of factors, including:

Subsection 5.1.1.d.2 of Section 6 of the emergency plan stated that an assembly

and release or evacuation will be ordered upon the classification of a Site or

General Emergency. This subsection and EPIP 6.1 stated that assembled, non-

essential personnel would either be released from the site when no radiological

conditions were present, or be evacuated from the site when radiological

conditions were present and additional actions, such as radiological monitoring

and relocation, were required.

Subsection 3.2.3 of Section 5 of the emergency plan stated that non-essential

personnel will be released if conditions allow; however, these conditions were

not specified. Step 4.4 of EPIP 6.1 stated that an evacuation of non-essential

personnel to an offsite assembly area shall be considered under certain

projected or measured radiological conditions, or other hazards.

Following the licensees critique presentation on February 14, the inspectors

asked the licensees exercise controllers about the acceptability of the

participants considering the use of buses from a local company to transport non-

essential personnel from the site. The licensee indicated that it believed that an

agreement existed with a local company to provide such a support. In contrast,

the inspectors did not identify evidence of pre-planning, either in the emergency

plan or in EPIP 6.1, to use a local company to provide buses to remove non-

essential personnel from the site during an emergency.

At its February 14 critique presentation, the licensee gave the inspectors copies

of two AR associated with its exercise critique of the implementation of EPIP 6.1.

Eight concerns associated with the assembly and accountability processes in

one onsite building were summarized in AR-CAP002156. Assembly and

Accountability Process was the title of AR-CAP002170, which also listed eight

concerns. Although one of these eight concerns was when to evacuate

assembled personnel, the AR did not also list a concern about when to release

assembled personnel consistent with the emergency plans and EPIP 6.1's

different meanings of the words release and evacuate.

After the licensees February 14 critique presentation, the inspectors asked other

questions about the participants decision making on removing non-essential

personnel from the site, such as whether the decision to begin removing non-

essential personnel was considered to be timely and what road was eventually

chosen to reach the Site Boundary Control Center (SBCC). The inspectors

concluded that the licensee did not have sufficient information available to

respond to these questions.

Significance Determination

Appendix B to NRC Manual Chapter (MC) 0610* includes criteria for determining

whether an issue warrants further analysis and documentation in an inspection report as

a finding. Using these criteria, the inspectors determined that the issues of the

licensees failure to adequately critique: (1) its participants initial PAR and (2) its

participants decision making on the simulated removal of non-essential personnel from

8

the site were issues that had a credible impact on safety. Each issue could also be

viewed as a precursor to a significant event and would, if left uncorrected, under the

same conditions become a more significant safety concern. Both critique issues were

evaluated as such because a basic reason for conducting Emergency Preparedness

drills and exercises is to identify performance and procedure concerns so that corrective

actions on such concerns can be taken before these concerns may occur during an

actual emergency and have an adverse impact on health and safety.

Appendix B to MC 0609 divides the 16 emergency planning standards of 10 CFR 50.47(b) into two categories, specifically risk significant and other planning

standards. With respect to the two aforementioned issues, Subsection 5.10 of Appendix

B states that 10 CFR 50.47(b)(10) is risk significant for offsite PARs, but not for onsite

protective actions.

Rather than have a separate finding for each critique issue, it is appropriate to identify

one preliminary finding to encompass both issues and to focus on their common factor,

specifically that both issues were inadequately critiqued by licensee staff. It is then

appropriate to assign a preliminary significance to the evaluation of the licensees

critique that is associated with the more risk significant of the two critique issues (White)

(Unresolved Item No. 50-266/02-04-01 and 50-301/02-04-01).

4.

OTHER ACTIVITIES

4OA1 Performance Indicator (PI) Verification (71151)

a.

Inspection Scope

The inspectors reviewed the licensees records related to each of the three emergency

preparedness PIs to verify that the licensees program was implemented consistent with

the industry guidelines in Nuclear Energy Institute publication No. 99-02 and related

licensee procedures. Specifically, licensee records related to the performance of the

Alert and Notification System (ANS), key Emergency Response Organization (ERO)

members drill participation, and Drill and Exercise Performance (DEP) were reviewed to

verify the accuracy and completeness of the data submitted to NRC for the period

October 2001 through December 2001.

b.

Findings

No findings of significance were identified.

4OA6 Meetings

a

Exit Meeting

The inspectors presented the preliminary inspection results to Mr. M. Reddemann and

other members of licensee management and staff at an interim exit meeting on

February 15, 2002. The licensee acknowledged the information presented. No

proprietary information was identified. On April 1, 2002, a final exit meeting was held

with Mr. F. Cayia and other members of licensee management and staff.

9

b.

Other Meeting

On February 15, 2002, an inspector summarized NRCs preliminary inspection results at

a public and media briefing hosted by the Federal Emergency Management Agency in

Manitowoc, Wisconsin.

10

KEY POINTS OF CONTACT

Interim Exit Meeting

Licensee

J. Anderson, Production Planning Manager

L. Armstrong, Engineering Manager

R. Arnold, Chemistry Supervisor

W. Bartelme, EP Coordinator

A. Cayia, Site Director

G. Corell, Chemistry Manager

D. Hettick, Performance Assessment Manager

V. Kaminskas, Maintenance Manager

M. Kelley, EP Coordinator

C. Krause, Regulatory Compliance

K. Pavley, Nuclear Oversight Manager

M. Reddemann, Site Vice President

R. Repshas, Site Services Manager

J. Strarsky, Operations Manager

S. Thomas, Radiation Protection Manager

R. Walsh, Nuclear Oversight

D. Weaver, Assistant Manager

T. Webb, Licensing Manager

W. Yarosz, EP Manager

Final Exit Meeting

Licensee

J. Anderson, Production Planning Manager

L. Armstrong, Engineering Manager

W. Bartelme, EP Coordinator

A. Cayia, Site Director

F. Flenje, Senior Regulatory Compliance Specialist

R. Hopkins, Nuclear Oversight Supervisor

V. Kaminskas, Maintenance Manager

M. Kelley, EP Coordinator

R. Pulec, Assistant Director

R. Repshas, Site Services Manager

D. Schoon, Operations Manager

T. Taylor, Plant Manager

S. Thomas, Radiation Protection Manager

E. Weinkam, Regulatory Services Director

W. Yarosz, EP Manager

NRC

R. Caniano, Deputy Director, Division of Reactor Safety, Region III

T. Ploski, Senior EP Inspector, Region III

K. Riemer, Chief, Plant Support Branch, Region III

11

LIST OF ITEMS OPENED, CLOSED AND DISCUSSED

Opened

50-266/02-04-01

URI

Inadequate critique of two exercise performance issues

50-301/02-04-01

(Section 1EP1.b)

Closed

None

Discussed

None

LIST OF ACRONYMS USED

ANS

Alert and Notification System

AR

Action Request

CAP

Corrective Action Program

CFR

Code of Federal Regulations

CRS

Control Room Simulator

DEP

Drill and Exercise Performance

DRS

Division of Reactor Safety

EOF

Emergency Operations Facility

EP

Emergency Preparedness

EPIP

Emergency Plan Implementing Procedure

ERO

Emergency Response Organization

IR

Inspection Report

MC

NRC Manual Chapter

NRC

Nuclear Regulatory Commission

NUREG

Nuclear Regulatory Guide

OSC

Operations Support Center

PAR

Protective Action Recommendation

PI

Performance Indicator

SBCC

Site Boundary Control Center

TBD

To Be Determined

TSC

Technical Support Center

12

LIST OF DOCUMENTS REVIEWED

1EP1

Exercise Evaluation

EPIP 1.1

EPIP 1.2

EPIP 1.3

EPIP 2.1

EPIP 4.1

EPIP 4.2

EPIP 4.3

EPIP 4.7

EPIP 5.1

EPIP 5.2

EPIP 6.1

EPIP 10.1

AR-CAP002117

AR-CAP002127

AR-CAP002156

AR-CAP002166

AR-CAP002167

AR-CAP002168

AR-CAP002169

AR-CAP002170

AR-CAP002171

AR-CAP002172

AR-CAP002173

AR-CAP002174

February 2002 Exercise Scenario Manual

Summary of January 2002 Drill Scenario

Licensees Time Line on Decisions on Simulated

Removal of Non-essential Personnel

Point Beach Nuclear Plant Emergency Plan

Course of Actions

Emergency Classification

Dose Assessment and Protective Action

Recommendations

Notifications

TSC Activation and Evacuation

OSC Activation and Evacuation

EOF Activation and Evacuation

Offsite Radiation Protection Facility Activation and

Evacuation

Personnel Emergency Dose Authorization

Radioiodine Blocking and Thyroid Dose

Accounting

Assembly and Accountability, Release and

Evacuation of Personnel

Emergency Reentry

Joint Public Information Center Does Not Appear

to be Set Up for Concurrent Kewaunee and Point

Beach Plant Emergency Events

Supply Discrepancies in TSC, OSC, and EOF

Assembly/Accountability Problems in North

Service Building

Reassess Emergency Action Level 1.1.5.1

Lab Coats Not Available for Sample Handlers

Milwaukee Call Center Provided Out of Date

Information to Simulated Public Callers

How to Document PAR Change Due to Wind

Direction Shift on State/County Notification Form

Reassess Assembly and Accountability Process

Discrepancy in Dose Assessment Programs

Computer Monitor Display versus a Printout

Develop Briefing Sheets for Directors

Miscellaneous Equipment Issues During Exercise

Qualifications of Craft Personnel for Some Tasks

August 2000

Revision 37

Revision 34

Revision 27

Revision 22

Revision 30

Revision 14

Revision 24

Revision 1

Revision 13

Revision 13

Revision 19

Revision 21

13

AR-CAP002175

AR-CAP002176

AR-CAP002177

AR-CAP002178

AR-CAP002179

AR-CAP002180

AR-CAP002181

AR-CAP002182

AR-CAP002183

AR-CAP002184

AR-CAP002185

AR-CAP002186

AR-CAP002189

AR-CAP002190

AR-CAP002215

Shift Manager Unable to Activate Primary ERO

Notification System

Dose/PAR Coordinator Checklist Concern

CRS Crew Twice Started Equipment Without

Proper Investigation

Problems Hearing Gai-Tronics Announcements

Several Staff Reading Personal Reading

Materials in OSC Briefing Room During Exercise

Participant Access Problem at Joint Public

Information Center

Several Non-Participants Unwilling to Augment

Participants When Requested

Several Simulator Fidelity and Controller

Performance Issues

Several Information Flow Problems in TSC

Two Participants Not Fully Qualified

Environmental Sample Analysis Records Keeping

Accumulated Dose Tracking Concern in OSC

EP Staff Involvement in Operator Training for

DEP Performance Indicator

Two Vehicles Had Insufficient Gas

Instances of OSC Teams Not Demonstrating

Good Contamination Control Practices

4OA1 Performance Indicator Verification

MO4-11

MO4-12

MO5-12

AR-CAP-002214

Fourth Quarter 2001 Evaluation Forms for Three

PIs

Field Observations of Sirens Full Sound Test

Full Sound Siren Test Records - October through

December 2001

Growl Sound Siren Test Records - October

through December 2001

Drill Nuclear Accident Reporting Form

Drill Nuclear Accident Reporting Forms

Drill Scenario Time Line

Reassess Which EOF Position is State/County

Communicator for PI Reporting Purposes

November 7, 2001

October 4, 2001

December 6, 2001

December 2001