IR 05000244/1995010
| ML17263B062 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 05/23/1995 |
| From: | Keimig R, David Silk NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17263B061 | List: |
| References | |
| 50-244-95-10, NUDOCS 9505310150 | |
| Download: ML17263B062 (11) | |
Text
U. S.
NUCLEAR REGULATORY COMMISSION
REGION I
License/Docket/Report No.:
DPR-18/50-244/95-10 Licensee:
Facility Name:
Inspection At:
Inspection Conducted:
Inspectors:
Rochester Gas and Electric Company (RG&E)
R.
E. Ginna Nuclear Power Station Rochester and Ontario, New York April 25 - 28, 1995 pA ll D. Silk, Senior Emergency Preparedness Specialist Approved By:
.
R.
e'f Emergency Pr redness Section Division of adiation Safety and Safeguards Areas Inspected:
Licensee's corrective actions to two violations and other issues identified during the October 1994 Emergency Preparedness (EP) program inspection (Inspection Report (IR) 50-244/94-21).
Results:
The licensee implemented satisfactory corrective actions, in sufficient scope and depth, to address the violations and other issues identified in the program inspection.
The violations were previously closed out in Resident Inspector's Inspection Report No. 94-27.
Enhanced management oversight and administrative procedures improved monitoring the conduct of quarterly siren growl tests and the distribution of Nuclear Emergency Response Plan (NERP) changes.
While the Quality Assurance (QA) and EP program are under the same manager, the required
CFR 50.54(t) audits are being conducted by individuals who are independent of the EP program.
The corporate and station EP organizations have stabilized since the last inspection.
The new Corporate Nuclear Emergency Planner (CNEP)
and the Onsite Emergency Planner (OEP) are in place, are evaluating the effectiveness of the EP program and are implementing good initiatives to strengthen the program.
The inspector also found that physically separate and redundant methods were available for communications with offsite agencies.
Various radiological dose projection capabilities in the control room, Technical Support Center (TSC),
and Emergency Operation Facility (EOF) were determined to be in good agreement.
Overall, the EP program was determined to be well implemented.
9505310i50 950523 PDR ADQCK 05000244 PDR
DETAILS PERSONNEL CONTACTED RGLE
+* F. Cordaro, Onsite Emergency Planner
J. Knorr, Manager, Maintenance/Radiation Protection/Chemistry Training
+
C, Kulwicki, guality Programs Coordinator
M. Lilley, Manager, guality Assurance
+* F. Orienter, Coordinator Radiological Safety Communications
+* P. Polfleit, Corporate Nuclear Emergency Planner
+* R. Watts, Department Manager, Nuclear Assessment
+ Denotes attendance at the October 3, 1994 Entrance Meeting.
- Denotes attendance at the October 6, 1994 Exit Meeting.
FOLLOWUP EMERGENCY PLAN AND IMPLEMENTING PROCEDURE ISSUES The inspector reviewed the Nuclear Emergency Response Plan (NERP)
and implementing procedure (EPIP)
changes to determine whether any changes resulted in a decrease in effectiveness of the emergency plan.
The inspector reviewed the procedure changes since the last inspection (listed in Section 7.0 of this report).
During this inspection, the inspector also reviewed the summaries of the last three NERP changes since they had not been submitted to NRC Region I in accordance with 10 CFR 50.54(q)
(which was identified as a violation during the last programmatic inspection in October 1994 (50-244/94-21)).
The changes to the EPIPs and the NERP were found acceptable by the inspector.
The violation had been closed by the Resident Inspectors (See NRC Inspection Report (IR) No. 50-244/94-27)).
During this inspection, the inspector conducted a followup review of the licensee's actions to correct the above mentioned violation.
The inspector found that, previously, changes to the NERP were not clearly marked for distribution to NRC Region I.
To address this situation, the licensee added NRC Region I as a controlled copy holder of the NERP and clarified the instructions regarding distribution.
The inspector reviewed the master distribution list and verified that the proper NRC recipients were designated to receive the correct number of copies of the NERP.
However, since the October 1994 programmatic inspection, NRC Region I received only one copy of revisions to the EPIPs.
This deficiency was identified by the licensee as they were reviewing their program and evaluating the methods in place to ensure that various activities are being performed correctly.
The licensee sent a letter to NRC Region I on April 7, 1995 explaining the oversight and sent an additional copy of the affected EPIP changes.
Subsequently, the licensee altered its method of distribution of the EPIPs.
Before April 7, 1995, revised EPIPs were sent to the Operations Office for distribution, but it was not clear to the Operations Office how many copies were to be sent to NRC Region I.
As a result, the licensee re-evaluated its entire
distribution method.
,Each group is now responsible for distributing'ts own changes and is responsible for the proper number of copies distributed.
This method allows more direct control of the distribution process.
The inspector was satisfied with the licensee's identification of this distribution deficiency and the corrective actions associated with i.1 3.2 The licensee was found to be appropriately self-critical with respect to enhancing the corporate call-out procedure, EPIP 3-6,
"Corporate Notifications."
The licensee's corporate call-out procedure is a phone-tree, i.e.,
a notified individual calls others who then, in turn, call other corporate responders.
One of the one-hour responders would have
"arrived" two minutes late during a simulated call-out drill that was conducted on February 13, 1995.
The "late arrival" was as a result of the individual being in the middle of the phone-tree with several responders to contact before he could leave to respond.
As corrective action, the EP group identified the one-hour responders and placed them at the beginning of the phone-tree.
They were also assigned minimal calling responsibilities so as not to delay their response.
The inspector asked if any individuals had arrived late in past simulated call-out drills and he was informed that no late arrivals had occurred.
Though only a regul'atory goal, the licensee's responsiveness, to improving the call-out procedure to ensure that the necessary corporate staffing is satisfied within one hour, was commendable.
FOLLOWUP OF EMERGENCY FACILITIES AND EQUIPMENT ISSUES During inspection 50-244/94-21, an inspector discussed with the licensee the logistics of an NRC team responding to an emergency.
As a result of that discussion, the licensee indicated that it would designate additional space in the Emergency Operations Facility (EOF) for NRC dose assessment and co-locate the NRC's Director of Site Operations with its Emergency Director.
As of this inspection, this had not been accomplished but is being tracked.
The licensee intends to modify the EOF in the future and will at that time address the location of various NRC responders.
During inspection 50-244/94-21, an inspector reviewed EPIP 5-1, "Offsite Emergency Response Facilities and Equipment Periodic Inventory Checks and Tests,"
Revision 5,
and found that the primary telephone number for contacting the NRC Operations Center was incorrect.
In addition, the back-up telephone number listed in Attachment I of EPIP 5-1 was no longer correct.
During this inspection, the inspector determined that the licensee had corrected EPIP 5-1 and Attachment I so that they now contain the proper telephone numbers.
The inspector checked procedure 0-9.3,
"NRC Immediate Notification," to ensure that other licensee procedures containing those telephone numbers were accurate.
During inspection 50-244/94-21, an inspector determined that two quarterly siren growl tests had not been performed as required.
The inspector had reviewed the 1994 quarterly growl test schedule and noted that the frequency had not been scheduled at quarterly interval Failure to conduct quarterly siren growl tests as required by the NRC-approved NERP was a violation.
The causes of missed growl tests were twofold.
First, the EP Group established a surveillance schedule with the Electric Heter Lab and Telecommunication Group but this group did not properly inform the Line Operating Group (which actually performs the tests).
Secondly, the EP group did not verify that the tests 'were being performed.
This violation was also closed by the Resident Inspectors (See NRC IR No. 50-244/94-27).
In response to this finding, the licensee immediately initiated growl tests for all of the sirens.
During this inspection, the inspector reviewed records and verified that the tests had been conducted on October 5 and 6, l994.
The licensee also expanded the membership of the Milestone Committee to 'ensure the coordination of major EP activities among supporting licensee departments and offsite organizations.
Individuals from guality Control, Operations, Communications Design and Support (responsible for siren testing),
and Electrical and Gas Emergency Planning now complement Training and EP personnel on the Committee.
The Milestone Committee, which meets monthly, uses a list to monitor the status of EP activities.
The list was expanded in scope and now indicates the schedule and charts the progress of the various activities.
The expanded list was developed by the EP group by going through the NERP and identifying recurring required activities and incorporating them into the list.
The inspector determined the list to be thorough and verified that several randomly selected items stated in the NERP were on the list, The inspector verified that the quarterly growl tests were on the list and scheduled at the proper frequency.
The inspector determined that the licensee adequately addressed the issue of the missed growl tests as well as ensured that other recurring activities are scheduled and monitored.
3.4 During this inspection, the reliability of the licensee's communication system with offsite organizations and agencies was evaluated.
The inspector interviewed the Manager, Communications Design and Support to gain insight into the independence and redundancy of the licensee's communication system.
The inspector was informed that several independent and physically separated lines connect the site with offsite organizations and agencies.
Computer systems,.
such as EROS, have redundant lines as well.
Also, the licensee has other methods of communications available.
Cellular phones, microwave, and radio are alternate methods to maintain communications.
The inspector was also informed that the licensee's communication system has been challenged in the past by a variety of severe conditions.
The licensee's system has experienced fire, loss of power, and a severe ice storm within the past several years.
During these separate events, parts of the communication system became inoperable but the entire system did not fail.
Communications were either re-routed through alternate lines or other methods of communications were used.
The licensee has plans to enhance its present communications system by adding another line and by contracting an additional cellular phone carrier.
The lessons-learned from those past conditions will be used in designing the enhancement.
Based upon discussions with the licensee, the inspector concluded that
i 3.5 3.6 4.0 sufficient independence and redundancy exists within the licensee's communication system to ensure continued contact with offsite organizations or agencies.
The inspector compared dose projection capabilities among the various emergency response facilities (ERFs).
The licensee has three dose projection methods.
One is a quick hand calculation estimate for site boundary doses that would be performed.in the control room for fast-breaking events.
Another is a personal computer (PC) method which is available at the Technical Support Center (TSC)
and the EOF.
The third method of dose assessment is to access the HIDAS code.
The inspector had the Corporate Nuclear Emergency Planner (CNEP) perform two dose projections using the PC method in the EOF.
The inspector then had the Onsite Emergency Planner (OEP) input the same data into the PC in the TSC.
The outputs from the two PCs were identical.
The inspector then had the CNEP perform the hand calculation method.
Its results were conservative, less accurate than the PC method (as would be expected for a simplified method),
but it produced comparable results.
The HIDAS method is the most accurate and detailed of the three methods but it takes about 15 to 20 minutes to input the data before getting results.
Therefore, the PC method is used for initial assessment by the TSC or EOF and then HIDAS is used to verify or amplify the projections, The inspector compared the PC method results with those of HIDAS.
The most significant difference between the two methods was in dose projections close to the site where the PC method was more conservative.
Overall, the inspector concluded that the PC method was identical between the TSC and EOF and that the three methods sufficiently overlap and complement each other.
No significant discrepancies should exist among the dose projections computed at the different ERFs.
In summary, based upon the licensee's corrective actions in response to the issues identified during inspection 50-244/94-21, the thoroughness of the communication system, and the dose projection capabilities, the inspector concluded that the licensee's facilities, equipment and program governing these areas were in good condition.
FOLLOWUP OF LICENSEE ORGANIZATION ISSUES As of October 1994, the licensee had undergone significant re-organization.
Under the new organization, the EP Director was promoted to the Hanager, Nuclear Assessment (HNA) and was given five areas of responsibility of which EP was one.
The CNEP, who reports to the HNA, retired at the end of October 1994.
He was replaced by the OEP whose position was then open.
The Corporate Health Physicist (CHP),
who was in the EP group, retired and the position was moved to the station.
During this inspection, the HNA, CNEP, and OEP were interviewed to assess their, perspectives of the re-organization.
The HNA was satisfied with both the new CNEP and OEP.
The CNEP and OEP complement the EP group by bringing health physics (HP)
and operational experience to the group.
With the CNEP possessing an HP background, the EP group was'ble to compensate for the loss of the CHP.
The CNEP uias already familiar
I 5.0 with many his new duties due to his previous position as the OEP.
The current OEP was in the Results and Tests Group where he interfaced with operations, engineering, and the maintenance departments.
Both the CNEP and OEP are well known and have good working relationships with other station personnel due to their previous positions.
Both have developed a good questioning attitude in all aspects of the EP program as demonstrated by the initiatives discussed in Section 6.0.
The inspector assessed the condition of the EP group as stable and capable of implementing the program.
FOLLOMUP OF THE INDEPENDENT AUDITS 6.0 During inspection 50-244/94-21, an inspector questioned the EP audit program relative to
CFR 50.54(t)
because it requires audits to be conducted
"by persons who have no direct responsibility for implementation of the emergency preparedness program."
This requirement prevents a potential conflict of interest and ensures that audits are conducted in an unbiased manner.
However, in the licensee's re-organization, the HNA,is responsible for EP and for gA (who performs the audits).
The inspector accepted the licensee explanation 'of the organization but stated that this would be evaluated during future inspections to verify that independent audits were being performed.
During this inspection, the inspector interviewed members of the EP group and the lead gA auditor who conducted the Harch 1995 audit of the EP program.
The inspector did not review the gA audit report at the time but instead focused on the staffing of the audit team and its conduct.
The audit team consisted of a team leader, an auditor, and a
technical assistant who was from the EP group of a another nuclear utility.
The team leader stated that the team had experienced no interference in conducting the audit and that he had no reservations about the current organizational structure impeding the conduct of independent audits of EP.
All of the issues or findings from the audit were resolved at the CNEP level.
At the audit team's exit meeting, the HNA (who was the previous EP Director) asked detailed questions about the audit team's findings.
The HNA's intention was to ensure that the EP program was functioning as it is required.
As a result, the audit was extended to address the questions raised by the HNA.
The inspector concluded that the licensee's organizational structure with respect to gA and EP appeared to be acceptable.
EHERGENCY PREPAREDNESS INITIATIVES Since the October 1994 inspection, the. licensee had implemented several initiatives as a result of the findings during that inspection and insights from the new CNEP and OEP.
A qualification manual for the OEP position was recently developed.
The Hilestone Committee membership, tracking list, and distribution of meeting minutes was increased.
Siren test reports that are sent to New York State officials not only contain the results but also the dates of the next scheduled tests as a reminder to all parties.
There has been more interface with the Gas and Electric Emergency Planner in the area of cross-training and e'valuation of
7.0 exercises to share experiences.
The EP group is now responsible for distributing NERP EPIP changes instead of the Operations Office to ensure proper distribution.
The corporate call-out procedure was significantly enhanced after a simulated call-out exercise resulted in one of the responders
"arriving" two minutes late.
The licensee conducted verification and validation testing for a new, more user-friendly, PC dose assessment method that will be implemented in the near future.
The inspector concluded that these initiatives were enhancements to the EP program.
LISTING OF NERP AND EPIP CHANGES A review of revisions to the NERP and EPIPs was conducted by the inspector and are included below.
The inspector concluded that changes made were acceptable and did not decrease the effectiveness of the EP program.
Procedure No.
Procedure Title Revision EPIP 1-0 EPIP 1-5 EPIP 1-6 1-14 2-1, P 2-3 EPIP 2-4 EPIP 2-11 EPIP 2-12 EPIP 2-14 EPIP 2-18 EPIP 3-4 EPIP 3-6 EPIP 4-1 EPIP 4-2 EPIP 4-3 EPIP 4-4 EPIP 4-5 EPIP 4-6 EPIP 4-7 EPIP 5-1 EPIP 5-2 EPIP 5-3 EPIP 5-4 EPIP 5-5 IP 5-6 5-7 5-9 Ginna Station Nuclear Emergency Response Plan Ginna Station Event Evaluation and Classification Notifications Site Evacuation Station Call List Protective Action Recommendation Emergency Release Rate Determination Emergency Dose Projections - Manual Method Onsite Surveys Offsite Surveys Post Plume Environmental Sampling Control Room Dose Assessment Emergency Termination and Recovery Corporate Notifications Public Information Response to an Unusual Event Public Information Response for Alert or Higher Accidental Activation of Ginna Emergency Notification System Sirens Rumor Control Public Affairs Notification Joint Emergency News Center Activation Public Information Organization Staffing Offsite Emergency Response Facilities and Equipment Periodic Inventory Onsite Emergency Response Facilities and Equipment Periodic Inventory Checks and Testing Testing the Ability to Notify Primary NERP Responders Emergency Plan Implementing Procedure Training Program Conduct of Drills and Exercises Annual Review of Nuclear Emergency Response Plan Emergency Organization Testing the Off Hours Call-in Procedure and quarterly Telephone Number Check 12, 13,
19 19,20,21,22
7
5,
7 7,
5 6,
3 17, 18,
4
5,
8,
12 12, 13,
6
12
8. 0 CONCLUSIONS Based upon the results of inspection 50-244/94-21 and the findings of this inspection, the inspector determined that the licensee's EP program was being well implemented.
The two violations and other issues cited in IR 50-244/94-21 were attributed by the licensee to distractions caused by the significant changes that occurred last year such as a new protective action recommendation methodology, a new emergency action level scheme, a new organizational structure, and the retiring of several EP group members.
As a result, the licensee was in a reactive mode rather than a proactive mode, which resulted in the various oversights.
9.0 EXIT MEETING The inspector met with the licensee personnel identified in Section 1.0 at the conclusion of the inspection to discuss the inspection scope and findings.
The inspector highlighted the items in Sections 2.0 through 8.0 of this report, and provided a summary evaluation of the EP program.
The licensee acknowledged the inspector's findings and commen i J
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