IR 05000219/1993014
| ML20057A761 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 09/02/1993 |
| From: | Laughlin F, Mccabe E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20057A759 | List: |
| References | |
| 50-219-93-14, NUDOCS 9309150279 | |
| Download: ML20057A761 (10) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
r Docket / Report 50-219/93-14 License: DPR-16 Licensee:
GPU Nuclear Corporatice.
P. O. Box 388 Forked River, New Jersey 6,731 Facility Name:
Oyster Creek Nuclear Generating Station Inspection At:
Forked River, New Jersey Inspection Date:
August 2-5,1993
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U Inspectors:
F. J. Laughlin, Emergency Preparedness Specialist Date l
D. M. Silk, Senior Operations Engineer
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D. W. Weaver, Reactor Engineer
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Appmved:
O/* O #N C+b, )"
9f1 D E. McCabe, Chief, Emergency Preparedness Section Date
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Announced emergency preparedness (EP) program inspection, including changes to the Emergency Plan and implementing procedures; emergency facilities, equipment, instmmentation, and supplies; organization and management control, training effectiveness including emergency management interviews, and independent audits / reviews.
RESULTS The EP program was effectively implemented. Strengths were EP training and the audit program. Inspection concerns were the slowness in declaring an Unusual Vivent during the May 5,1992 forest fire and the lack of attention to detail regarding emergency response facility inventories.
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TABLE OF CONTENTS 1.0 Perso ns Co ntact ed....................................... I 2.0 Emergency Plan and Implementing Procedures....................
3.0 Eiaergency Facilities, Equipment, Instrumentation and Supplies.........
4.0 Organization and Management Control......................... 3 5.0 Knowledge and Performance of Duties (Training)
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5.1 ED/ESD Interviews
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6.0 Independent and Internal Reviews and Audits..................... 6 7.0 Exit Meeting
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DETAIIS 1.0 Persons Contacted The following licensee personnel were among those contacted during the inspection:
T. Blount, Nuclear Safety Compliance Committee Member
- J. Bontempo, Lead Emergency Planner R. Brown, Process Re-engineering Project Staff Member K. Burkholder, Information Services
- W. Cooper, Radiological Engineering Manager
- B. DeMerchant, Licensing Engineer J. Earley, Quality Assurance Auditor
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G. Giangi, Corporate EP Manager P. Hayes, Ixad Emergency Planner S. Levin, Director, Operations and Maintenance
- C. Mascari, Director, Nuclear Assurance
- S. McAllister, Emergency Preparedness Training Coordinator K. Mulligan, Manager, Operations Support A. Rone, Director, Technical Functions P. Scallon, Manager, Plant Operations W. Stewart, Safety Review Manager
- R. Sullivan, Emergency Preparedness Manager D. VanNortwick, Emergency Pfauner
- J. Williams, Support Training Manager l
- P. Thompson, Site Audit Manager l
- Attended the exit meeting on August 5,1993.
2.0 Emergency Plan and Implementing Procedurrs Inspectors reviewed changes to the Emergency Plan (E-Plan) and E-Plan Implementing Procedures (EPIPs) to ensure that E-Plan effectiveness had not been reduced.
The licensee completed a major change to the Emergency Action Levels (EALs). A May 11, 1992 meeting between the NRC and the licensee addressed NRC comments on this revision.
The licensee made further EAL revisions, and responded to the NRC concerns in a June 19, 1992 letter. An August 6,1992 NRC letter stated that the proposed EAL changes were consistent with NRC requirements and guidance, and were acceptable. This EAL change was incorporated into the General Public Utilities (GPU) E-Plan as Revision 6.
The inspector reviewed a change to EPIP-OC.02 (EPIP.02), Direction of Emergency Response / Emergency Control Center.
Some values used in the PAR (Protective Action Recommendation) logic Diagram of Revision 4 to this EPIP were significantly less than the values used in Revision 3. For example, the reading on the Containment High Range Radiation Monitoring System (CHRRMS) indicating actual substantial core damage in Revision 3 was
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a fission product inventory in containment that, if released, was enough to exceed Environmental l
Protection Agency lower limit protective action guidelines was 3500 R/hr in Revision 3, and
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1300 R/hr in Revision 4. The licensee stated that the values used in Revision 4 were obtained l
by using core damage estimate graphs in EPIP-OC.33, Core Damage Estimation. The 1300
R/hr value was the lowest CHRRMS reading resulting in 1 R/hr site boundary dose rate under i
any meteorological conditions, assuming the release of all drywell activity. The inspector concluded that the PAR Imgic Diagram values in Revision 4 had a technical basis and were more
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conservative than those in Revision 3, and were therefore acceptable.
The inspector reviewed Procedure 1000-ADM-1291.01, Safety Review Process, Revision 7, dated 9/15/89, which detailed the preparation, Review, and approval process of revisions to l
procedures covered by the Quality Assurance Plan. The inspector then reviewed the change
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documentation for Revision 4 to EPIP.02 and found it in accordance with licensee procedures.
The inspector reviewed Revision 7 to EPIP.02.
This Revision added a statement to the Emergency Director's (ED's) checklist (Exhibit 1) directing the ED to inform the Security Shift Supervisor to initiate Emergency Response Organization (ERO) callout after the plant page i
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initiative since it established ERO callout as an immediate action. Revision 7 documentation was also in accordance with licensee procedures.
No decrease in the effectiveness of the Emergency Plan was found to have resulted from these procedure changes. Based on the above Review, this area was being effectively implemented.
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3.0 Emergency Facilities, Equipment, Instrumentation and Supplies The inspector toured the Control Room (CR), Operational Support Center (OSC), Technical Support Center (TSC) and the Emergency Operations Facility (EOF). These facilities were
found to be in a good state of operational readiness. Selected equipment checked in each facility
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was operational and designated emergency supplies were available. The latest revisions of controlled procedures were available in all facilities.
However, the EOF and TSC communication log books, which contained copies of procedures for quick reference, did not
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Several other minor discrepancies were noted. One frisker had exceeded its calibration due date.
The licensee calibrated the instrument upon discovery. The number of portable radios in the OSC was two less than specified. The licensee stated that two additional radios could be i
attained from another location. The licensee was informed that the facility inventory should i
reflect the equipment actually present. There were other inventory discrepancies. Three quarterly inventories were completed late and, in another, a sealed radcon kit had not been inventoried. The licensee stated hat the person who completed this inventory thought that the kit was satisfactory since it was sealed. This kit was inventoried before the end of this inspection, and all items required were present. The EP Manager was aware of these items and l
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planned to: 1) rewrite the inventory procedure such that items in the facilities more closely followed the order on inventory lists, 2) allow a grace period for inventory completion in the new procedure, and 3) remind his staff, who review the completed inventories, of the imponance of procedure adherence. Completion of these actions and specification of the circumstances under which sealed packages must be inventoried will be assessed during the next inspection (IFI 50-219/93-14-01).
The E-Plan specified that a gamma spectrometer was located in the OSC.
Instead, the instrument was in a nearby radiologically controlled area. The licensee committed to revising the E-Plan to accurately reflect the location of the spectrometer.
The inspector reviewed procedure 6431-SUR-1310.09, Emergency Communications Surreillance, Revision 0, dated 8/10/92, and the records for the last six quarterly pager tests, which checked proper pager operation and ability to fill all ERO positions in a specified time. The inspector noted that no test was performed in the first quarter of 1993 and the third quarter 1992 test was conducted in the fourth quarter of 1992. The test typically exceeded the 40 minute response time allowed by the procedure by 10 to 20 minutes. In response to these findings the licensee revised 6431-SUR-1310.09 (Revision 1) to provide for a longer response time, and clarified the periodicity to require test performance for each emergency response duty section annually instead of quarterly.
The inspector observed the third quarter pager test conducted on 8/2/93. The licensee had installed a new automated dialing system which reduced the time taken to contact emergency response personnel. The response to the test was good, and all but one position out of sixty was filled. However, the inspector noted that test results did not show whether duty section personnel or off-duty personnel filled each position. Neither was pager operability verified for duty section members who did not fill their designated positions. The EP Manager stated that the replaced system had provided a printout of which people responded and the order of response. He was not aware of how to generate this information with the system but he intended to investigate the possibility. He also stated that, if the duty person failed to respond, he/she was contacted to find out why. The inspector noted that the pager tests were not a requirement but a licensee initiative to improve callout efficiency.
This area was assessed as being acceptably implemented.
4.0 Organization and Management Control The inspector interviewed the Acting Director, Oyster Creek, and the Oyster Creek EP Manager (EPM); and reviewed EP Department structure and Emergency Response Organization (ERO)
duty rosters to assess EP program administation.
The EP Department was the responsibility of the Nuclear Assurance Division. Mr. C. Mascari had replaced Mr. P. Fiedler in February 1993 as the Vice President, Nuclear. Assurance. The site EPM reported through the Manager, Corporate EP to this vice president. There were no
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other changes in EP management responsibilities. Senior management interacted with site EP personnel through staff meetings, site visits, and attendance at drills and exercises. The Manager, Corporate EP maintained an office at the Three Mile Island Emergency Operations Facility, and was accessible through frequent visits and telephone conversations, though no formal meetings were scheduled with the Oyster Creek EPM.
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The Oyster Creek EPM had a full-time staff of five, inchiding senior reactor operator (SRO),
maintenance, and health physics expertise. Two persons had recently left the EP Section. The
12ad EP Planner for Operations had been replaced by an SRO-certified individual from licensed operator training. This person had no EP background but was considered to have appropriate experience for the position. The Senior EP Planner had also left the section. This person was
a nuclear engineer and certified health physicist who had considerable computer expertise. He had not yet been replaced and was assisting the EP Section with preparations for the October full-participation exercise. A replacement was expected in the September-October time frame.
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The inspector informed the licensee that the loss of the Senior EP Planner was a concern because
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of his breadth of expertise. Related EP staffing will be further reviewed in a future inspection l
(IFI 50-219/93-14-02).
The inspector reviewed the ERO and observed several significant changes to the duty roster.
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New personnel included two Operations Coordinators, two Emergency Directors and one
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Fmergency Support Director. All replacements were experienced personnel who previously held manager positions on the duty roster. The ERO was staffed three deep in every position and was assessed as adequate.
The licensee had added four new formal positions to the duty roster. The first two were Public Information (PI) Technical Representatives in the TSC and EOF. Previously, these were PI responsibilities but not formal duty roster positions. The positions were added to ensure that
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these facilities had adequate support for writing press releases and providing media interface with management. The other two new formal positions were Joint Information Center staff writers, to ensure adequate staff support at that facility. These positions were all staffed at least three deep. The inspector noted that this initiative involved a considerable allocation of resources and
was beneficial to emergency response effectiveness.
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Based on the above, this area was being effectively implemented.
5.0 Knowledge and Performance of Duties (Training)
r Emergency response training was inspected for conformance to Emergency Plan Section 8.2.1 and the Emergency Preparedness Training Program. The inspector interviewed six Emergency Directors / Emergency Support Directors and the EP Training Instructor, observed a maintenance team training session; and reviewed lesson plans (LPs), training records, and trainee critiques.
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The licensee had taken steps to improve the overall EP training program. The EP Training Instructor had continued to redirect EP training philosophy toward a performance-based program. Training was conducted in the facilities where the ERO staff performed their duties by conducting walk-throughs and providing hands-on use of emergency equipment. That appeared to enhance the training program. For example, at the maintenance team training session observed, feedback from last year's session was combined with the performance-based training approach, resulting in job-specific training which was significantly streamlined from the previous year's training.
Tbc inspector reviewed the LPs for Emergency Response Facilities - ECC and TSC, Emergency Direction, and Emergency Worker Training. The contents of the LPs matched the scope of training specified in Table 21 of the Emergency Plan. The LPs had been reviewed and updated in accordance with Training Department requirements. The inspector verified through interviews
that the contents of a deleted lesson plan (ERF Operations,580.0.0001) were incorporated into other LPs. This was a follow-up item from the last NRC inspection, when inspectors noted that deletion of this LP would eliminate such topics as EP basic concepts and descriptions of the four levels of emergency classification.
i The inspectors reviewed the qualification records of persons in new ERO positions and of several persons who had participated in the May 5,1992 Alert. These records were found to i
be appropriate and current. The training received by duty roster personnel was found to be consistent with the requirements of the training matrix of Exhibit 1 of the Emergency l
Preparedness Training Program. Review of the Training Department records system revealed that records were maintained on both computer database and hard copy, and were easily retrievable. The inspector found several typographical errors but, overall, the records were complete and adequate. The licensee tracked EP training and respirator training. Individuals who were approaching the 15 month time limit could be identified and informed about impending expiration of qualification.
Oyster Creek procedure 6430-ADM-1319.01, Emergency Preparedness Program, Section 5.3 detailed drill requirements. Specifically, the procedure called for four unannounced shift drills and twenty on-the-job training (OJT) drills per year. OJT drills could be substituted for unarmounced shift drills. The licensee had not performed unannounced shift drills in several years, but had substituted OJT drills instead. The licensee stated that unannounced shift drills had been discontinued due to OJT drills being more effective because they were less formal and more people could participate.
The inspector checked records confirming that the licensee had conducted 24 drills during the past year. Documentation describing OJT drills was minimal. Drill descriptions, documented on Exhibit 10 of the procedure, in most cases read like training sessions instead of drills.
Section 8.2.2 of the Emergency Plan states: " Periodic drills and exercises will be conducted in order to test the state of emergency preparedness." The inspector questioned whether OJT
" drills" were only a training tool and emergency preparedness was not being tested. The
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licensee stated, and the NRC agreed, that the quarterly drills and annual exercises tested
emergency preparedness and meet this E-Plan requirement. Also, the licensee agreed that the
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Exhibit 10 documentation was poor and planned to improve it (IFI 50-219/93-14-03).
Licensee EP staff provided strong assistance to off-site agencies through the emergency worker training program.
The inspector reviewed the LP for this training and noted that local responders were trained in basic radiation safety concepts. Participation was verified by checking the attendance records of several sessions.
5.1 ED/ESD Interviews The inspector interviewed four Emergency Directors (EDs) and two Emergency Support Directors (ESDs) to assess the quality of emergency management training. Questions concerning
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response manager duties were asked. The results were as follows:
All EDs demonstrated a very good knowledge level of their emergency duties. There was consistently good knowledge of non-delegable responsibilities, reporting duties, and expected actions for a nissed classification that is discovered after the fact. Each ED had played in or observed a drill in the last year and had completed annual requalification training. Some areas noted for potential improvement (i.e., licensee consideration) were:
Two persons were unsure of the minimum staffing necessary to activate the TSC but all
said they would refer to their ED checklist in the procedure.
One individual said he would fill ERO positions with untrained personnel if necessary
to staff the TSC. The inspector was unaware of any related proceoural guidance.
Both ESDs demonstrated a very good knowledge level. They also had played in or observed a drill in the last year and completed annual requalification training.
Overall, the training program was assessed as being effectively implemented.
6.0 Independent and Internal Reviews and Audits
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The inspector reviewed the 1993 audit report, plan, and checklist. The audit fulfilled the requirements of Technical Specifications and 10 CFR 50.54(t). It was completed by the Quality Assurance Department, which is independent of EP. Auditors had devised a new audit plan and checklist based on an audit matrix, which contained required EP items as well as general objectives. The audit plan was comprehensive and the checklist was thorough. The report was well-written, concise, and identified one finding, one performance concern, and six recommendations. The finding involved five EPIPs that had not received an annual review in
accordance with the E-Plan. This finding required an acceptable response in 15 working days.
To resolve the finding, the EP Section completed the required reviews in a timely manner and the item was closed.
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The performance concern involved emergency response facility inventory checklists not matching the facility configuration for ease of locating items, and depletion of supplies even when the facility had not been used. The EPM committed to rewriting the, inventory procedure.
The audit report was distributed to senior management and the section concerning off-site interface was properly forwarded to State and local offici-as, meeting the requirements of 10 CFR 50.54(t). The inspector assessed the EP audit program as a strength.
The annual Emergency Action Level (EAL) review rec,uired by 10 CFR 50 Appendix E was
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completed by mailing copies of the EALs to the New hrsey Office of Emergency Management (NJOEM) and requesting a reply. The NJOEM response indicated that they had no questions and were satisfied.
The inspector reviewed the action item tracking system.
This system was governed by Procedure 6400-ADM-1310.01, Action / tem Tracking, Revision 0, dated 2/22/93 and provided guidance for identifying, tracking, and trending action items. The last semi-annual trending report identi6cd no deficiency trend in the EP program. There were no overdue action items.
The inspector concluded that this system was effective in resolving action items in a timely
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manner.
The inspectors reviewed the critiques of five actual events from the past year. These critiques I
were thorough and well documented.
However, the inspector was concerned about the timeliness of the declaration of an Unusual Event (UE) as a result of the forest fire on May 5,
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1992. Smoke from the fire resulted in a loss of off-site power that initiated a plant trip. The loss of off-site power resulted in a condition that kept control room personnel occupied st. o. Jzing the plant. The plant tripped at 1326 and, at 1329, reactor water level decreased to tht Lo-lo Level, causing reactor and containment isolation. This condition met the criteria for an UE under Category H of the EAL Table. The UE was not declared until 1402,33 minutes after the initiating event.
The licensee explained the delay in the declaration as being because safe shutdown of the plant was the highest priority. However, if plant conditions had deteriorated further, the delay of the declaration of the UE could have adversely affected emergency response efforts. This item was self-identified by the licensee and corrective action was to remind shift personnel of the importance of timely event declaration. Inasmuch as the licensee is required to ave on-shift staffing sufficient in numbers and training to both properly respond to and report emergency conditions, the licensee's explanation that safe shutdown had highest priority, although correct, did notjustify tardy reporting. However, the inspector concluded that adequate corrective action had been taken on this licensee-identified item.
Inspectors investigated the timeliness of the declaration of another UE that occurred on January 22, 1993 when an individual working in a radiologically controlled area was injured. The accident occurred at about 1608. The individual was transporte6 crf-site for medical treatment.
Radiological Controls (Radeon) personnel anticipated an opportunity to completely frisk the i
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individual prior to transporting him off-site. However, due to the type of injury, Radeon was unable to survey the individual's back. The ambulance left the site with the injured person at about 1635. The UE was declared at 16:41,33 minutes after the event, for transportation of a contaminated or potentially contaminated person to a hospital. The injured person was subsequently frisked at the hospital and was not contaminated. The licensee stated that the
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declaration was delayed with the intention of frisking the injured person before he left the site.
When this could not be accomplished, the UE was declared eight minutes after the person left the gate. The inspector concluded that these actions met associated regulatory requirements, in that the Unusual Event was for transportation of a potentially contaminated individual, and in that the declaration was made within eight minutes of the commencement of that transportation.
Further, the inspector concluded that the licensee's approach to this matter was appropriate.
Based on the above review, this area was being adequately implemented.
7.0 Exit Meeting The inspectors met with the licensee personnel listed in Detail 1.0 on August 5,1993 to discuss the inspection scope and findings. The licensee was informed that no violations were identified.
The licensee acknowledged the findings and indicated they would be evaluated for appropriate corrective actions.
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