IR 05000317/2014003
| ML14252A229 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 09/04/2014 |
| From: | George Gellrich Exelon Generation Co |
| To: | Document Control Desk, NRC Region 1 |
| References | |
| IR 2014003 | |
| Download: ML14252A229 (3) | |
Text
,J __ IvGeorge GellrichExeton Generation. Site Vice PresidentCalvert Cliffs Nuclear Power Plant1650 Calvert Cliffs ParkwayLusby. MD 20657410 495 5200 Office717 497 3463 Mobilewww.exeloncorp.comgeorge.gellrich@exeloncorp.com10 CFR 50.47September 4, 2014U. S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2Renewed Facility Operating License Nos. DPR-53 and DPR-69NRC Docket Nos. 50-317 and 50-318Subject: Response to Preliminary White Finding in Inspection Report No.50-317(318)/2014-003Reference: 1. Letter from Ho K. Nieh (NRC) to George H. Gellrich (Exelon), datedAugust 8, 2014, Calvert Cliffs Nuclear Power Plant -NRC IntegratedInspection Report 05000317/2014003 and 05000318/2014003 withPreliminary White FindingOn August 8, 2014, Calvert Cliffs Nuclear Power Plant (CCNPP), LLC received the NuclearRegulatory Commission Integrated Inspection Report (Reference 1) describing a preliminaryWhite finding associated with the site's failure to maintain in effect an emergency plan that metthe requirements of 10 CFR 50.47(b)(4) and 10 CFR Part 50, Appendix E, for Unit 2 betweenthe dates of October 11, 2013 and March 4, 2014. Specifically, during the replacement of theUnit 2 Main Steam Line Radiation Monitors (MSLRMs), Calvert Cliffs' staff inaccuratelycalculated the associated Emergency Action Levels (EALs) effluent threshold values for Alert,Site Area Emergency, and General Emergency (GE), and incorporated these thresholds into theEALs.Exelon appreciates the opportunity to provide its perspective on this matter through this writtenresponse. Exelon fully understands the importance of maintaining an effective Emergency Planto protect the health and safety of the public and plant personnel and concurs with theperformance deficiency and apparent violation as identified in Reference 1; however, Exelonbelieves this condition posed minimal risk to the health and safety of the public and had very lowoverall safety significance.The incorrect EAL threshold values for the Unit 2 MSLRMs were identified by Exelon whilepreparing for the same MSRLM upgrade for Unit 1. On determining that the Unit 2 MSLRM EALthreshold values were inappropriately low, Exelon immediately documented the issue in itscorrective action program and promptly implemented appropriate compensatory measures. The Document Control DeskSeptember 4, 2014Page 2compensatory measures utilized pre-planned, procedurally captured actions that rely on otherinstalled plant radiation monitors unaffected by this issue and/or by field readings taken andevaluated by trained Emergency Response Organization staff.A causal analysis was completed in May 2014 that rigorously evaluated this event. The causeof this event was determined to be that site leadership did not manage risk commensurate tothe potential consequences associated with an inaccurate EAL revision. Specifically,management did not appropriately manage the change with the appropriate amount of technicalrigor. Additionally, assessments of the extent of condition and extent of cause were completedto ensure that all learnings from this event were fully captured and acted upon. Correctiveactions have been completed, which include application of Exelon's existing, formal process toensure the appropriate technical task risk/rigor controls are applied when revising the EALs.This process requires the evaluation of consequence, human performance, and process riskfactors in determining the required methods to be used to ensure the correct amount of rigor isapplied to prevent errors. This improved level of risk/rigor has been used in the determining therevised Unit 2 and new Unit 1 MSLRM EAL threshold values. These values will be implementedonce the applicable monitors are modified to adequately support the required range ofindication. The new MSLRM EAL threshold values for both units are planned to beimplemented by October 10, 2014.The following provides support of Exelon's position that this issue is more appropriatelycharacterized as a finding of lesser significance. The position is prominently based ondocumented studies regarding the ability to safely evacuate the public during an event;suggesting this to be a less significant outcome when compared to missing or delaying theclassification of a GE and not evacuating the public in a timely manner.As stated previously, Exelon concurs with the performance deficiency and apparent violation asidentified in Reference 1; however, Exelon disagrees with the characterization of the findinghaving low to moderate safety significance (White). On the contrary, Exelon believes thiscondition posed minimal risk to the health and safety of the public. Inspection ManualChapter 0308, Attachment 3, Appendix B, Technical Basis for Emergency PreparednessSignificance Determination Process, provides the following with respect to determination of afinding of a lesser significance:"The (Emergency Preparedness) EP (Significance Determination Process) SDP providesguidance for the inspector to consider diverse and/or redundant (Program Elements) PE,MITIGATING FACTORS, and COMPENSATORY MEASURES, taken in determining if theaffected (Planning Standard) PS FUNCTION would still be accomplished, albeit in adegraded manner, thereby justifying a lesser significance."Furthermore, the consequences of evacuating the public have been demonstrated to beconsiderably less significant when compared to the significance of delaying or not declaring aGeneral Emergency.NUREG/CR-6864, Volume 1, Identification and Analysis of Factors Affecting EmergencyEvacuations, studied the efficiency and effectiveness of public evacuations of 1,000 or morepeople, in response to a number of events such as natural disasters and technology hazards.The study concluded that safely evacuating people from the affected area saved lives andreduced the potential number of injuries from the hazard. The study also identified a high levelof cooperation among agencies, use of multiple forms of emergency communications, and well-
Document Control DeskSeptember 4, 2014Page 3trained emergency responders contributed to the efficiency and effectiveness of the evacuation-all of which are attributes of Exelon's Emergency Plans.Additionally, NUREG/CR-6042, Perspectives on Reactor Safety (SAND93-0971), Revision 2,Section 5.3 Protective Actions, discusses the following regarding the relative consequencesbetween evacuating and not evacuating a given population:"Objections have been raised to evacuation because of fears of panic or injuries during theevacuation.. .on the average, it would be far less risky for a person to evacuate than toremain within 2 to 3 miles of a nuclear power plant experiencing a severe core damageaccident."Another potential outcome that bears consideration regarding the significance of this issue isthat the same set of plant conditions that would have led to the over-classification of a GEdeclaration as a result of the inaccurately low Unit 2 MSLRM EAL threshold values, could haveresulted in an acceptable GE classification through assessment of the station's Fission ProductBarrier Matrix in the EALs. The acceptable GE classification would have required the use of thejudgment threshold under the loss or potential loss initial conditions in assessing the fuel cladbarrier, along with the recognized loss of the reactor coolant system and containment barriersdue to specific, non-judgmental thresholds.Finally, upon review of similar findings issued by the Nuclear Regulatory Commission forradiation monitor threshold errors, White findings have been typically assessed to licenseeswhere the radiation monitor EAL threshold values were incorrectly high or off-scale. In such acase, a GE declaration would have been delayed and protective action recommendations wouldnot have been immediately implemented. Considering the difference in consequences betweenthe two situations, Exelon contends that the significance of the Calvert Cliffs issue would bemore appropriately characterized as a finding with very low safety significance based on theminimal impact of the error from prematurely or unnecessarily evacuating a portion of thepopulation within the emergency planning zone.Exelon is mindful of the risks to the public associated with an evacuation; however, Exelonbelieves the actual safety risk posed to the public from this issue to be very low, and is thereforemore appropriately characterized as a less significant finding.There are no regulatory commitments contained in this correspondence.Should you have questions regarding this matter, please contact Mr. Douglas E. Lauver at(410) 495-5219.Respectfully,GHG/MJF/bjdSite Vice Presidentcc: NRC Project Manager, Calvert Cliffs NRC Resident Inspector, Calvert CliffsNRC Regional Administrator, Region I S. Gray, MD-DNR