IR 05000220/1990001
| ML17056A663 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 02/28/1990 |
| From: | Craig Gordon, Lazarus W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17056A662 | List: |
| References | |
| 50-220-90-01, 50-220-90-1, 50-410-90-01, 50-410-90-1, NUDOCS 9003120554 | |
| Download: ML17056A663 (20) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos.
50-220 90-01 Docket Nos.
50-220 3U:MI License Nos.
DPR-53 DPR:69 Licensee:
Nia ara Mohawk Power Cor oration a)n ie oa racuse ew or 13212 Facility Name:
Nine Mile Point Nuclear Station Units
8
Inspection At: Scriba New York Inspection Conducted:
Januar 23-26 1990 Inspectors:
o n,
mergency repare ness Section, RSSB, DRSS a
e Approved By:
z rus ie
,
FRS
,
DRSS a
e Ins ection Summar
Ins ection on Januar 23-26 1990 Re ort Nos.
Areas Ins ected:
Routine, announced safety inspection of the emergency prepare ness program including review of previously identified inspection findings, changes. to the emergency preparedness program, review of organization and management control, inspection of independent program audits, ynd inspection of emergency response organization training.
Results:
The Site Emergency Plan, Emergency Plan Procedures, and the emergency planning program are being implemented in a manner to adequately protect public health and safety.
9003i20554 900228 DOCK 0 000220 PDC A
1.0 Persons Contacted DETAILS R.
J.
A.
K.
H.J.
H.
D.
R.
D.
D.
Abbott, Unit 2 Station Superintendent Burton, Supervisor, Nuclear guality Assurance Salemi, Hanaqer, Emergency Preparedness Dahlberg, Unit 1 Station Superintendent Dooley, Licensing Specialist Earls, Station Shift Supervisor, Unit
Hedrick, Training Supervisor Lloyd, Nuclear Training Specialist Laura, Resident Inspector Johnson, Auditor Richard, Station Shift Supervisor, Unit 2
Denotes attendance at exit meeting 2.0 Licensee Actions on Previousl Identified Items The inspector discussed the previously identified findings and concerns from Inspection Report Nos. 50-220/89-03 and 50-410/89-03 and the results are as follows:
l.
A problem was identified with the licensee's Site Emergency Plan (SEP) in that a fifth emergency classification (Sympathetic Alert) was added to the Plan.
- In 1988, a review was made to the SEP which deleted this information from the SEP.
Licensee action is determined to be adequate.
2.
In some cases, distribution of the SEP, implementation procedures, and corporate procedures were provided to NRC as 'information only'opies.
- Following review of changes to internal administrative procedures and receipt of updated SEP and procedure revisions, all documents are now rovided via controlled distribution.
Licensee action is determined to e adequate.
3.
Procedure EPP-26,
"Protective Action Recommendations",
was difficult for operations staff to use since key steps in the procedure were out of sequence.
- Review of Revision to EPP-26 indicated that the procedure was appro'priately revised.
Licensee action is determined to be adequate.
4..A need for closer cooperation between quality assurance (gA) staff and. Safety Review Audit Board (SRAB) personnel was identified in coo7dinating and reporting audit findings.
3.0
- Discussions with gA staff and review of recently issued audit reports indicated that gA audit findings and SRAB recommendations received timely issuance.
This item has been adequately addressed.
5.
Although Emergency Preparedness (EP program audits were conducted to meet the requirements of 10 CFR 50.54(t
,
one area not audited was the manner in which the program meets the p arming standards of 10 CFR 50.47(b).
- Review of current EP audit reports and discussions with auditors revealed that the gA review plan still does not include applicable NRC requirements as part of the annual audit to meet
CFR 50.54(t)
(see Section 3.0).
6.
Information provided to new personnel in General Employee Training (GET) was unclear regarding the graded approach to emergency response and the emergency classification scheme.
- The training department revised the GET presentation to more clearly identify many aspects of Site Emergency Plan implementation including the emergency classification scheme and Protective Action Recommendations (PAR).
This item has been adequately addressed.
7.
A database system to maintain all emergency response training records and a list of qualified response personnel was being developed to alleviate the problems of maintaining records manually.
- Beginning in January 1990, the licensee began to implement the new computer based system to keep records of personnel training.
Preparation for input of EP records are being made by EP instructors.
This item has been adequately addressed.
Inde endent Reviews Audits The independent quality assurance review of the EP program was conducted in December 1989.
The report, issued on January 18, 1990, satisfies the requirements of 10 CFR 50.54(t).
The audit was performed by one member from the Safety Review and Audit Board (SRAB)
and one member from the Corporate gA department usinq a designated checklist.
The inspector reviewed the checklist and discussed audit preparation and audit findings with the lead auditor.
Audits covered basic EP program functions such as implementing
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rocedures, training, inventory maintenance, interface with State and ocal agencies, and drills and exercises.
Also included in audit reports is a-comparison of the Site Emer'gency Plan with 10 CFR 50, Appendix E
'equirements and review of NRC inspection reports.
Audits do not cover the planning standards of 10 CFR 50.47(b) while NRC inspection report reviews are performed only to the extent of determining the status of viAations or exercise open items.. The inspector explained to auditors that reviews of NRC documents should be more detailed to include what actions are taken by licensee EP staff to address any significant NRC concerns identified in inspection reports.
If the auditor finds the program deficient with regard to a specific planning standard, this should also be identified.
Results of the audit indicated that activities of the EP program were conducted effectively since the previous audit.
Strengths were noted in the areas of procedure quality, interface with offsite authorities, and resolving drill deficiencies.
Two problem areas resulting in Corrective Action Requests were identified which related to the licensee's ability to efficiently obtain post-accident samples and implement a site-wide
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ublic address system.
EP staff are currently addressing these items.
istribution of the audit report was extensive and incluled senior managers and the SRAB.
Except as noted above, this area is acceptable.
Or anization and Mana ement Control The inspector reviewed the normal staffing organization pertaining to administration of the emergency preparedness (EP) program and noted that several staff changes have taken place within the past few months.
The EP staff includes nine (9) authorized professional positions which include the Manager, EP, drill and exercise coordinator, and an administrative/projects coordinator.
In October 1989, a new Manager, EP was selected to direct program activities.
This individual was chosen from within the program and is familiar with routine emergency preparedness program tasks.
The inspector noted that of the nine positions, two positions were vacant, one of which is the administrative/projects coordinator who is responsible for maintaining status of open items, coordinating training, drafting procedures and interfacing with licensing staff.
The second vacancy is the dril) coordinator position which had only minor impact on the program, since drills and exercises were held according to the schedule identified by procedure.
In addition to becoming familiar with carrying out his new duties, the Manager, EP is also covering the admin/projects function.
As a result, the Manager, EP is at risk for becoming administratively overburdened.
The inspector discussed these concerns with the Manager, Nuclear Services who indicated that active recruiting to fill vacant positions was in progress and that consideration was being given to obtaining operations, health physics, and engineerinq support to assist the EP staff.
Although improvements could be made in attention to such details as equipment maintenance, document distribution, and traininq coordination, through the efforts of the Manager, EP and other staff, high priority items are being adequately maintained.-
Themnnual revision of the Site Emergency Plan was completed in late 1989 and clearly delineates major'esponsibilities to support response activities.
Prior to 1990, the licensee maintained a corporate plan whi0h described many of the emergency functions car ried out by senior licinsee staff.
Since a large amount of similar information was also included in the corporate plan, the SEP and corporate plans were combined and duplicate information eliminated.
Actions are currently in progress to revise all implementing procedures to correspond to the standard site format.
The Manager, EP stated that revisions would be completed sometime in mid-1990.
The Emergency Response Organization (ERO) is adequately described in the SEP.
Key positions are staffed at least three deep and personnel have consistently demonstrated effective response during exercises.
Since the last inspection the licensee has taken steps to improve initial notification times to the on-call organization.
The new system is a
computer aided process which uses a telephone service called the Community Alert Network (CAN).
Once activated, the CAN provides immediate contact of designated licensee pager holders and furnishes preliminary emergency information.
Although the system appears to be an improvement over the former system, concerns were identified with shift training and use of the CAN (See Section 5.0).
Emergency Response Facilities (ERF) are designed to meet the requirements of 10 CFR 50.47(b)(8)
and (9),Section IV of 10 CFR 50, Appendix E,
NUREG-0737, Supplement 1,
and Reg.
Guide 1.97.
Equipment, status boards, communications systems, plans, procedures, habitability and access control provisions were checked in the control rooms, Technical Support Center (TSC), Operations Support Center (OSC),
and Emergency Operation Facility (EOF).
Status boards, maps, facility diagrams, plans, procedures, drawings, and equipment were in place and maintained, equipment was in calibration, and communication equipment operative in all ERFs.
Designated computers used to calculate projected doses to the environment were available and operable.
Based upon the above, this area is acceptable.
5.0 Knowled e and Performance of Duties The SEP provides a training list of required course instruction for emergency response personnel within the ERO.
These include Emergency Directors, emergency response facility directors, and team members for technical support, dose assessment, radiation surveys, damage control, fire safety, chemistry, and security.
Both primary and requalification training criteria are described.
In order to verify implementation of training courses, the inspector interviewed Unit 1 and Unit 2 shift personnel.
The Senior Shift Supervisors (SSS)
who serve as Emergency Directors (ED) during emergencies have received classroom and practical traininq within the past year and are qualified EDs. Demonstrations were required in direction and control, emergency classification, notification and communication, and protective action recommendations.
SSSs appeared knowledgeable and familiar with their assigned duties and responsibilities wit&onh exception.
The licensee has implemented the new CAN system to make more efficient initial notifications to key support personnel.
Howgver, training on use of the new system has not always been effective.
Shift operations personnel stated they have received only a brief overview about system operation and were aware of its capability, but received no formal (practical) training on how to use the revised notification procedure.
Of greater concern was the lack of familiarity with the revised procedure on the part of the radioactive waste operators (RWO).
The RWOs are the individuals designated to use the procedure to immediately notify upper level licensee management and offsite authorities.
RWOs have been adequately trained to make notifications to New York state and county officials via the Radiological Emergency Communication System (RECS) but encountered problems in efficiently implementing the CAN procedure during inspector walkthroughs.
The procedure appeared to be sufficiently detailed to be accomplished with minimal training, however, some practical training may be appropriate to improve effectiveness.
This item is unresolved (50-220/90-01-01 and, 50-410/90-01-01).
The licensee committed to provide additional training in use of CAN to affected shift personnel.
Training records are manually maintained on file for each individual.
During th'e previous inspection, the inspector noted that the training instructor developed his own database files to track when response training for each member of the emergency organization has been taken and when requalification was due because the new computer system to maintain all records of the Training Department was under development.
At the time of this inspection use, of the new database system had just begun.
Training staff indicated that input of ERO training records was part of their near term workload.
6.0 Assessment Re ardin Restart Action Plan Underl in Root Causes 2 and
For Underlying Root Cause (URCf 2, Problem Solving, certain activities have occurred in the EP area since the last inspection which had potential impact on administration of the program and relate to this URC.
Among these are:
1. Identification of FEHA offsite deficiencies from the Hay 1989 full participation exercise.
2. Personnel change of the Hanager, EP 3. Vacancies in two EP staff positions 4. Incorporation of the Corporate Emergency Plan into the SEP 5. Upgrade and revision of EP implementing procedures into the-standardized site format.
6. Preparation of exercise scenarios independent of contractor support 7. Development of action plan to utilize the training simulator for drills and exercises
The licensee has shown good initiatives in addressing these items.
FEHA identified deficiencies were resolved through a remedial drill held in October 1989; recruitment to fill vacancies has been active; and program administration has been effective despite staffing changes and the hsgh amount of time consuming efforts on behalf of the EP staff.
For URC 4, Standards of Performance/Self-Assessment, the primary item attributable to this URC relates to the licensee's initiative to improve efficiency in the area of notifications and communications during emergencies.
While the intention is considered noteworthy, underlying concerns were identified.
The licensee implemented and provided brief information about the new communications system (see Section 5.0) to personnel, but could have provided more effective training on its use.
Worker feedback and management oversight on the new procedure was minimal.
Discussions with workers up to the Senior Shift Supervisor level revealed that they believed the new system would provide better notification times to the ERO, but they were not comfortable in its use due to the lack of practical experience.
i.tl ~Eit N ti The inspector met with the licensee personnel denoted in Section 1 at the conclusion of the inspection to discuss the findings as presented in this report.
The inspector also discussed some areas for improvement.
The licensee acknowledged the findings and agreed to evaluate them and institute corrective actions as appropriate.
'0 Docket Nos.
50-220 50-410 NOR g g )gag Niagara Mohawk Power Corporation ATTN:
Mr. Lawrence Burkhardt, III Executive Vice President Nuclear Operations 301 Plainfield Road Syracuse, New York 13212 Gentlemen:
Subject:
Combined Inspection Nos. 50-220/89-22 and 50-410/89-17 This refers to your letter dated October 16, 1989, in response to our letter dated September 14, 1989.
Thank you for informing us of the corrective and preventive actions documented in your letter.
These actions were examined during a subsequent inspection of your licensed program and were found to be satisfactory.
We regret the delay in acknowledging your correspondence.
The enclosure to your letter contains Safeguards Information that has been determined to be exempt from public disclosure in accordance with 10 CFR 73.21.
Therefor e, it will receive limited distribution and will not be placed in the NRC's Public Document Room.
Your cooperation with us is appreciated.
Sincerely,
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JBiBQ."- g)pyqg James H. Joyner, Chief Facilities Radiological Safety and Safeguards Branch Division of Radiation Safety and Safeguards OFFICIAL RECORD COPY RL NMP 89-17 0001.0.0 11/19/90 g&
0)
Niagara Mohawk Power Corporation h'oyg g )
cc w/encl:
L. Burkhardt, III, Executive Vice President C. Mangan, Senior Vice President J. Willis, General Station Superintendent W. Hansen, Manager, Corporate Quality Assurance K. Dahlberg, Unit 1 Station Superintendent R. Randall, Unit 1 Supervisor, Operations C.
Beckham, Manager, Nuclear Quality Assurance Operations J. Perry, Vice President, Quality Assurance R. Abbott, Unit 2 Station Superintendent J. Firlit, Vice President, Nuclear Generation J.
Warden, New York Consumer Protection Branch T. Conner, Jr.,
Esquire J. Keib, Esquire
. G. Wilson, Senior Attorney Director, Power Division, Department of Public Service, State of New York State of New Yor k, Department of Law Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
K. Abraham, PAO (28)
SALP Reports and (2) All Inspection Reports NRC Resident Inspector State of New Yo'rk, SLO Designee bcc w/encl:
Region I Docket Room (with concurrences)
NRC Project Inspector Management Assistant, DRMA (w/o encl)
R. Bellamy, DRSS J. Linville, DRP D. Limroth, DRP G. Meyer, DRP M. Conner, DRP (Salp Reports Only)
J. Caldwell, EDO R. Martin, NRR RI:D Dexte /mk 11/4D/90 RI:D S
RI RSS j
Ke ig Joyner 11/2-'/90 11/Z4/90 OFFICIAL RECORD COPY RL NMP 89-17 0002.0.0 11/19/90
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V NIAGARA V MOHAWK NINE MILEPOINTUNIT2/P.O. BOX 63. LVCQMING.NY 13093/TELEPHONE (315) 343-2110 October 16, 1989 L<. William Regional Administrator Region I, USNRC 475 Allendale Road King Of Prussia, PA 19406
Dear Mr. Russell:
RE: Nine Mile Point Site Docket No. 50-220/50-410 Enclosed is our response to the Notice Of Violation contained in your Inspection Report No. 50-220/89-22 and 50-410/89-17, dated September 14, 1989.
t We hereby request that the material submitted with this letter be withheld from public disclosure in that the response contains Safeguards Information of a type specified in 10CPR73.21.
Sincerely, JPB/gd Enclosures
,.- >z,F,8 Joseph P. Beratta Manager Nuclear Security WHEN SEPARATED FROM ENCLOSURES'ANDLE THIS DOCUMENT AS DECONIROLLED
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