IR 05000244/1991028
| ML17309A470 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 01/30/1992 |
| From: | Eckert L, Mccabe E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17309A468 | List: |
| References | |
| 50-244-91-28, NUDOCS 9202110197 | |
| Download: ML17309A470 (13) | |
Text
III U. S. Nuclear Regulatory Commission Region I Docket/Report:
'50-244/91-28
'icen~'~".
Licensee:
DPR-18 Rochester Gas and Electric Corporation 89 East Avenue Rochester, New York 14649 Facility Name:
,Inspection Inspection At:
R. E. Ginna Nuclear Power Plant December 16-20, 1991 Ontario and Rochester, New York In'spectors:
L. Eckert mergency Preparedness Section C. Conklin, Emergency Preparedness Section J. Lusher, Emergency Preparedness Section Date Approved:
E. McCabe, Chief, Emergency Preparedne>ss Section, Division of Radiation Safety
. and Safeguards t Ivol(z Da'te Art.;is Inspected:
R. E. Ginna Nuclear Power Plant emergency preparedness (EP), including:
'ry rnm-changes:...emergency
'facilities, equipment, instrumentation, and supplies:
or~~anization hand m management: control: training: and independent reviews/audits.
I I<csults: In ability to perform an on-shift dose assessment for a steam generator tube rupture accident.divas identif'ied as a violation of 10 CFR 50.47(b)(9).
'Otherwise. the licensee was I'ound to meet NRC requirements, with potential performance improvements identified in sever tl aspects of the emergency preparedness progra DETAILS 1.0 Persons Contacted The following licensee per'sonnel attended the exit meeting held on December 20, 1991.
R. Mecredy, Vice President, Ginna Nuclear Productioh C. Anderson, Manager, Quality Assurance S. Poulton, Training Specialist J. Widay, Plant Manager G. ivleier, Manager, Training W. Gooditan, Health Physics Foreman J. St. Martin,,Corrective Action Coordinator K, Lang, Health Physicist C. Kulwicki, Quality Assurance Auditor R. Beldue. Corporate Nuclear Emergency Planner P. Polfleit, On-site Planner A. Harhay, Manager, Health Physics and Chemistry The inspectors also interviewed an'd observed the actions of other licensee personnel.
2.0 Licensee Action on Previously Identified Items OPEN (UNR) (50-244/90-27-()1) Ginna Nuclear Power Plant EPIP 1-0, "Ginna Station Event Evaluation 'ind Classification," identifies examples of initiating indications that have not been.
quantit'ied.
The licensee h;is extensively reviewed their EALscheme.
Several minor modifications were m ide to clarit'i EPIP 1-0.
These will be the subject of further NRC inspection.
3.0 Operational Status of the Emergency Preparedness Program 3.1 Changes to the Emergency Preparedness (EP) Program The inspectors reviewed changes to the Emergency Plan and Emergency Plan Implementing Procedures (EPIPs) since the last EP inspection to determine ifthey adversely affected the licensee's overall state of emergency preparedness and whether the changes had been appropriately reviewed, approved, and distributed.
EPIP 5-3, Emergency Response Facilities And Equipment Periodic Inventory Checks And Tests was recently revised into four new. procedures (EPIP 5-1, Off-site Emergency Response Facilities And Equipment Periodic Inventory Checks And. Tests; EPIP 5-2, On-site Einergency Response Facilities And Equipment Periodic Inventory Checks And Tests; EPIP 5-3. Testing Of The Ginna Nuclear Emer'gency Plan Pagers; and EPIP 5-9, Testing The Off
'ours Call-in Procedure And Quarterly Telephone Number Check). The previous EPIP was
cumbersome:
its revision was found by the inspectors to be an improvement.
The current Emergency Plan (Revision 9) does not fully reflect the current emergency preparedness program.
Although Revision 10 is in progress, additional changes need consideration.
For example:
~
Section 8 of the Emergency Plan, which describes the Emergency Operations Facility (EOF) operations as a distinct entity, could be incorporated into the body of the plan.
Many Emergency Response Organization (ERO) positions are not fullydescribed in the Emergency Plan and EPIPs.
Use ot'he Commitment Trqcking System (CATS) is not reflected in the Emergency Plan or EPIPs.
~
Some drill/exercise conceptual and administrative considerations are not described
,in the Emergency Plan (e.g., the Milestone Committee, and the use of Control Room Fores))en as Emergency Coordin actors).
~
Command and control of the ERO may not shift upon activation of the EOF. That is not reflected in the Emergency Plat).
~
Further description of the responsibilities of ERO members'while the EOF is being activated m )y he appropriate.
During a telephone discussion at'ter the inspection, the licensee stated that they were including and/or ev >lu >ting for inclusion the above items into Revision 10 of the Emergency Plan.
That plan revision will be reviewed incident to routine inspection.
The inspectors noted that the licensee's audit (described in Detail 5) also identified addition ll <reas in which the Emergency Plan could better describe important aspects of the l)H)gra nl.
3.2 Emergency Facilities, Equipment, Instrumentation and Supplies The inspectors toured the Technical Support Center (TSC), Operations Support Center (OSC). <<nd EOF. These facilities were as described in the Emergency Plan and EPIPs and were found sufficient to support emergency response.
The Pl )nt Process Computer System (PPCS) was fullyoperational and was available for use in the EOF.
All equipment in the EOF was within the required calibration period.
The t'()Ilowing computer systems in the TSg were tested:
PPCS, MIDAS (a dose assessment model). the Dose Projection Spreadsheet, and the Meteorological Data Computer.
All of
these systems were operational and available.
The inspectors also tested various cbmmunications equipment in the Emergency Response Facilities (ERFs) including: the NRC Emergency Notification System (ENS), the Health Physics Network (HPN), and commercial telephones.
These were found to be working properly.
The emergency ventilation system for the TSC (the OSC is also within the TSC ventilation system envelope)
divas tested.
That system maintains a positive pressure of 0.125 inches of water.
The system is very quiet and there is no indication of whether it has switched from n<>rmal mode tn emergency mode.
The only available indicator identified was Continuous Air llonitor (CAM) detection of an increase in radioactivity, and that could be too late.
During a telephone discussion after the inspection, the licensee stated that engineering review ot'he means to be used to verify the mode of operation of the TSC ventilation system i>> in progress.
This matter is unresolved pending further review of the adequacy of c<>ntr<>l <>ver the oper >tion >I modes of the TSC ventilation system (UNR 50-244/91-28-01).
The Ventilation Performance Test (PT-37.9, conducted annually) and the Filter Efficiency Test (PT-47.9, conducted annually) were performed on the TSC emergency ventilation syst<'.nl.
These tests demonstrated satisfactory system performance.
The inspectors tound that all ERFs were in good shape and properly stocked with supplies.
In >dditi<>n. selected inventory checks t'nr the past year were reviewed. The inspectors noted that tl>e June EOF invent<>ry check ivas not completed.
EPIP 5-3 requires that discrepancies
>re to he corrected as soon as possible
>nd noted as correct'ed on the Emergency Equipment M<>ntl>ly Inspection Log.
There were several months when that log was not completed.
Therefore. there were no records of corrective actions taken for these months.
Root cause analysis t'nr associated recurrent problems could be impeded by this record-keeping discrepancy.
This iyas t>ssessed as a potential'erformance improvement item.
The licensee's
>udit
>Iso noted this discrepancy.
Yo equipment inadequacies were identified in this area, but record-keeping was weak.
C 3.3 Organizati<>n and blanagcment Control EP Staft'ing consists ot'ne on-site planner and one corporate planner.
Off-site training is conducted by the EP stat'f.
On-site training is conducted by the Training Department.
Technical training (e.g., dose assessment)
is conducted by the EP staff or other competent personnel.
The progr tm w>s heing adequately maintained.
However, many tasks had not been formalized
>nd inconsistent results have been noted.
In addition to the Emergency Plan not heing fullycurrent (see Det >il 3.1). corrective action discrepancies (see Detail 3.2), and the int'<>rmality ot'he program (see Detail 3>5), the following were noted:
No formal means was found for assuring that sufficient staff are present to fillevery position in the ERO at all times.,
The EP staff appeared to be burdened with clerical tasks.
The ERO is notified by telephone, at an Alert or higher emergency classification, to respond to their respective ERFs.
Pagers are available for key personnel as a back-up.
EPIP 1-5 (Notifications) and EPIP 3-6 (Corporate Notifications) govern calling in the ERO and utilize, i call tree methodology.
The Control Room notifies the Gas Dispatcher and a Telephone Service, and directs them to perform their respective call trees.
The Control Room also notifies the Plant Manager (or alternate) as well as the Recovery Manager (RM). The Gas Dispatcher contacts the TSC Director; Technical, Operations and Plant Maintenance Assessment; the TSC Communicator, and the Survey Center Manager.
When these six positions ire filled. the remaining individuals are called.
The Telephone Service contacts t'our key st'it'f (Dose Assessment, HP/Chemistry, and two HP Technicians).
They also
~;ont ici six survey team members.
The EOF staff is contacted by a cascading telephone call tree (EPIP 3-6). That tree is initiated by the.RM and continues until all positions are filled.
The licensee's audit identified the fact that while the call-in process is adequate, the process is subject to competing priorities as the call-in is conducted over commercial lines.
An inconsistency was noted between the EPIP 5-4 qualified individuals listing and the positions listed in EPIP 3-6: 'or the listed Technical Assistant to the Corporate Spokesperson.
the licensee was unable to show full qualification. Additionally, individuals
- issigned is Recovery Manager,.Nuclear Operations Manager, Technical Assistant to the Corpor;It@ Spokesperson.
Corporate Nuclear Emergency Planner, EOF Dose Assessor, TSC Dose Assessor.
ind Health Physics/Chemistry Manager were listed under more than one posItign. including both EOF and TSC positions. Such double assignment raises the question ot st ift'ing sufficiency for prolonged emergency operations.
It was clear, however, that there
<<re sufficient personnel to support protracted o'perations in all other key positions.
During i telephone discussion after the inspection, the licensee stated that they plan to qu;ilify more personnel in all of the above noted positions except for Recovery Manager.
(There ire enough individuals qualified as Recovery Manager as long as assignments to
'other positions do not cause a shortage.)
This matter willbe re-examined incident to routine NRC inspection..
3.4 Knowledge and Performance of Duties (Training)
Two matrices, one for on-site'personnel and one is for EOF personnel, delineate ERO positions <<nd required training. An attachment to EPIP 5-4 lists the personnel qualified for e ich ERO position.
Th it attachment is updated each July and January.
Training consists of cl'issroom sessions, practical work, drills, and tabletop sessions.
Lesson pl;ins were complete ind concise.
Where appropriate, tests are administered.
A passing
gr ide is 80%. Lesson Plans are reviewed annually, prior to usage, and receive two technical reviews <<s well as two approvals.
Training was currently scheduled to be completed within ipproximately a two-month window each year, and was essentially complete for 1991. A few individuals in the ERO must still receive training in order to remain on the qualified list.
Tr'iining records are computerized, easily accessible, and accurate.
Screens are available that show the training courses, duties and grades.
Hard copies of training records can be e isily obtained.
Review of the records indicated that some key individuals were trained in 1991, but significantly after their annual due date (three to five months).
The inspectors determined that this was due to personal scheduling problems.
This indicates that some
=individuals may continue to be listed as qualified beyond their qualification period.
However, the inspectors determined that all individuals in the ERO are currently qualified.
Selected lesson plans were examined and found.to have received proper licensee review and
- ipprov;il.
Operators were given walk-through examinations which required accident
<<l;issit'ic ition as part nf their Job Performance Measure.
The inspectors also observed a
c'lsll'iltycontrol drill and noted that it provided good ERO training. A positive drill aspect w;i>> the use of mock-ups to add realism and maintain player interest.
Effectiveness of training was reviewed by conducting walk-throughs with key staff.
Two shit'ts comprised of.a Shift Supervisor (Emergency Coordinator), Control Room Foreman.
Shift Technical Advisor, and Health Physics Technician were tested.
In* addition, two Recovery Managers and a Dose Assessment Manager were given walk-throughs.
Scenarios included i fast-breaking event needing a General Emergency (GE) declaration and Protective Action Recommend;ition (PAR) and a Steam Generator Tube Rupture (SGTR)
accident requiring 'in on-shift dose assessment.
All individuals were very knowledge'ihle.
Actions taken were prompt, correct. and conservative.
During the SGTR walk-through, the shit'ts recognized the need to perform a dose assessment.
They were aware of a dose
- issessment procedure and unsuccessfully tried to work through it. (The shift crews had not received training on this complex procedure.)
In this case, the Emergency Coordinators properlv classified the event usini. the discretion permitted by EPIP 1-0, Ginna Station Event Ev:ilu ition And Classification.
However, the inability of the shift crews to perform a dose
- issessment provides a potential for untimely or improper event classification.
10 CFR Part 5().47(b)(9)
states that "adequate methods, systems and equipment for assessing and nionitoring the;ictual or potential off-site consequences of a radiological emergency condition are in use." The inspectors concluded, that the licensee did not have an adequate method of performing on-shift dose assessment for the postulated SGTR.
This was an
- ipp irent violation (VIO 50-244/91-28-02).
After the inspection, the licensee provided a table of initiating conditions developed utilizing irea raditition monitor readings for important release pathways.
NRC review found the i ible acceptable as a classification tool. Also, during a subsequent telephone discussion, the licensee stated that they;ire retrainingi all of their Health Physics. technicians on dose
<<ssessment principles and EPIP methodologies.
That training is expected to be completed
in January 1992.
These actions were assessed as sufficient.
Overall, training was considered good.
3,5 Independent Reviews(Audits The licensee's independent EP audit was conducted on May 1 through May 23, 1991. That audit.was performed by the Quality Performance Department and utilized a technical expert in emergency preparedness on the team. The audit also met the requirements for the review required by 10 CFR 50.54(t).
NRC review concluded that the licensee's team performed a generally effective audit which came to proper conclusions.
The audit, which included a review of off-site interfaces, was properly distributed to management.
A copy was also provided to the State of New York, Monroe County, and Wayne County as required.
The audit team utilized a checklist in order to insure proper audit scope.
The independent audit checklist is modified annually and is based upon regulations, NUREGs, Information Notices, lNPO Guidelines, the Emergency Plan, and other utility and in'dustry concerns.
Inspector review found that the licensee's drill and exercise program met NUREG-0654 objectives.
The drills included major elements such as staffing and augmentation, notil'ication, and several, integrated drills.
Drills and exercises receive management
.
concurrence ihrough the Milestone Committee.
The licensee was in the process of implementing a one-year and a rolling five-or six-year plan for exercise objectives.
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Program formality and consistency was thereby lacking.
Communications tests were conducted in accordance with EPIP 5-3 (Emergency Response Facilities and Equipment Periodic Inventory Checks and Tests).
Test results are recorded hy ERFs on several different attachments to EPIP 5-3. The communications test results for 1991 were reviewed.
In general, discrepancies for communications tests conducted during 1991 were adequately corrected and reviewed.
However, the April and June pager test checklists (Attachment 15) were not completed.
Program administrative management was thereby l icking. (The licensee's audit also noted these discrepancies.)
The licensee has provided greater support to Wayne County than in previous years because there has been turnover in the Wayne County Office of Emergency Management.
Way'ne County Office of Emergency Management personnel were interviewed and expressed satisfaction of the support that they have received this year from the Rochester Gas and Electric Corporation.
Overall. the licensee's review and audit function was found to meet NRC,requirements, with program administrative
>nd management improvement opportunities evident in program
formality. consistency, and record-keeping.
4.0 Exit bIceting The inspectors met with the licensee personnel denoted in Detail 1 at the conclusion of the inspection to discuss the scope and'findings of this inspection as detailed in this report.
The licensee was informed that an apparent Violation was identified.
The inspector also discussed several other areas for improvement. The licensee acknowledged the findings and stated their intention to evaluate them and institute corrective actions as appropriate.