IR 05000266/1989013

Insp Repts 50-266/89-13 & 50-301/89-12 on 890522-25 & 0614. No Violations Noted.Major Areas Inspected:Emergency Preparedness Program,Actions on Previous Open Items, Activations of Emergency Plan & Training

ML20245G919
Person / Time
Site:	Point Beach
Issue date:	06/20/1989
From:	Shear G, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20245G911	List: IR 05000266/1989013 ML20245G908
References
50-266-89-13, 50-301-89-12, NUDOCS 8906290319
Download: ML20245G919 (8)

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    . REGION.III
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LReports No. 50-266/89013(DRSS); 50-301/89012(DRSS) Docket Nos. 50-266;.50-301: Licenses No. DPR-24; DPR-27

 . Licensee: . Wisconsin Electric Power Company 231-West Michigan Milwaukee,-WI 53201~
 . Facility Name: . Point Beach Nuclear Power Plant, Units'I and Inspection At: Point Beach Site, Two Creeks, Wisconsin d

InspectionCo,7uctef.May22-25,andJune 14, 1989

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 ' Inspector: Y hear    (oho /67-
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   . Date Approved By: Se1 C e    G/Maj Emergency Preparedness   Date and Effluents Section Inspection Summary Inspection on May 22-25, and June 14 1989, (Reports No. 50-266/89013(DRSS):

50-301/89012(DRSS)) Special, unannounced inspection of the following areas of-

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Areas Inspected: the Point Beach Nuclear Plant emergency preparedness program: action'on previous Open.. Items;. activations of the licensee's Emergency Plan; and-knowledge and performance of duties (training). This-inspection specifically evaluated actions to date on Open Item No'. 266/88007-01(annual. maintenance of EP training and capabilities).and on an Exercise Weakness, Open Item No. 266/89008-02 (recognition of containment release path). This inspection involved two NRC inspector Results: No violations,' deficiencies or deviations were identified. However, concerns were raised regarding the overall effectiveness of the licensee' training program'in the area of emergency preparednes l 8906290319 890621 PDR ADOCK 05000266 PDC - - _ - _ _ - _ _ _ _

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DETAILS

 ' 1. - Persons Contacted
  *J. Zach, Plant Manager
  *R. Bruno,-Superintendent Training
  ~ Knorr, Regulatory Engineer
  +*D. Stevens, Emergency Preparedness Coordinator
  *R. Chojnacki, Quality Specialist G. Maxfield, General Superintendent Operations
  *T. Malanowski, Licensing Engineer J. Smith, Training Specialist M. Baumann Engineer-II.-Corporate T. Koehler, Superintendent Maintenance M. Crouch. Assistant Maintenance Supervisor T. Guoy, Health Physics Supervisor T. Garot, Duty Shift Superintendent K. Rathgaber, Nuclear Chemistry Specialist R. Zyduck, Superintendent Technical Services
  +H. Gleason, Training Coordinator R. Leeman, NRC Resident Inspector
  * Denotes those attending exit intervie + Denotes those participating in teleconference of June 14, 198 . Licensee Action on Previously Identified Items (IP 92701) (0 pen) Open Item (No. 266/93007-01): Licensee procedures do not assure annual emergency plan training for all personnel assigned duties in the emergency plan. The licensee has revised their

. ' Emergency Plan (EP) to address annual training for personnel with EP assignments. Section 8.3.1.lb requires that key plant personnnel and personnel assigned specific duties associated with the Emergency Plan will undergo specialized training annually. This item was the l focus of this inspection but remains open because the inspectors l could not verify that annual training was being provided as described from the review of training records. This item will ' l be reviewed during a future inspectio (0 pen) Open Item (No. 266/89008-01): The licensee failed to adequately demonstrate the capability to coordinate the flow of information from the Control Room to offsite agencies and the proper use of EPIP 1.1. This was not reviewed during this inspection and will be reviewed during a future exercis (0 pen) Open Item (No. 266/89008-02): Exercise Weakness: Licensee personnel did not recognize and aggressively pursue the existence of the (scenario) containment release path. The licensee responded to this item in a letter dated May 10, 1989 stating that the Weakness

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was a performance problem and not a generic issu Further, the licensee stated that no corrective action could be identified or implemented. The NRC does not agree with this statement since this inspection appeared to identify a generic problem. Therefore, this item will remain open pending further review during a future inspectio (0 pen) Open Item (No. 266/89008-03): OSC' procedures should be modified to require activation of the OSC concurrently with the TSC,- to provide augmented manpower to carry out any TSC directed initiatives. This item was not reviewed and will be reviewed during a future inspectio (0 pen) Open Item (No. 266/89008-04): Emergency Plan Emergency Kit inventories should be revised to ensure adequate supplies are available to support multiple inplant teams. This item was reviewed and the licensee had not made any progress on this item. This will be reviewed during a future inspection, (0 pen) Open Item (No. 266/89008-05): Sample handling techniques were poorly demonstrated by both field teams during the exercis This item was not reviewed and will be reviewed during a future inspectio (0 pen) Open Item (No. 266/89008-06): Unresolved Item: During the exercise the licensee was unable to obtain and analyze a containment air sample when containment air pressure exceeded 5 psig. This item was not reviewed and will be reviewed during a future inspectio (0 pen) Open Item (No. 266/89008-07): Unresolved Item: During the exercise it was noted that the licensee lacked a procedura for counting an air sample taken from the plant which had (scenario) elevated levels of radioactive iodine present. This item was not reviewed and will be reviewed during a future inspectio . Activations of the Licensee's Emergency Plan On March 29, 1989 at 0843 hours. Unit 2 experienced a main step-up transformer lockout main generator breaker trip and concurrent turbine and reactor trips. The' reactor trip was the result of a chain of events caused by a turbine trip which was the result of a transformer bushing fault caused by an inadvertent actuation of the tranformer's fire protection system. An Unusual event was declcred at 0845 hours and terminated at 1205 hours on the same da Documentation relating to this event was reviewed and analyzed to determine if actions met those requried by the Emergency Plan. All j actions and notifications initiating and terminating this event were j appropriately made and the event was properly classified per the l EAL schem a _ _ _ _ _

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. Knowledge and Performance of Duties (Training) (82206)

The Point Beach Emergency Plan (EP) requires EP training annually for_ key plant personnel and those individuals assigned specific duties associated with the Emergency Plan. This program should provide for annual training using a systematic approach on portions of the Emergency Plan and EPIPs which specifically affect the trainees role in the emergency response - organization. In addition, biennially, all personnel assigned to Point Beach Nuclear Plant (PBNP) will receive orientation and training in the general content of the Emergency Plan and EPIPs. The Point Beach Training Department employs a Training Needs Analysis procedure to identify individual and group training requirement During the-inspection the training records for 14 individuals were reviewed. Seven of the 14 training files reviewed were those of employees who had been employed at PBNP for greater than 18 months and the other seven files were of individuals who had been employed for 18 months or less. Five of the 7 employees with greater than 18 months of service were also selected for walkthroughs/ interviews. The records reviewed included training attendance sheets, the training departments training tracking system, and the training departments official personnel training file The review of the licensee's training records identified numerous discrepancies between the attendance sheets, training tracking system, and the official training file The discrepancies consisted of such things as dates of training in the official records being different than the dates of the attendance sheets, training recorded in the official ; record having never been held, and training held that was never recorded ! in the official record. Also, it was noted that in most cases the records were at least six months out of date. These problems appeared to be administrative in nature and were verified as such through interviews with the training staff. More emphasis should be placed on the accurate documentation of EP training. This is an Open Item (No. 266/89013-01).

The inspectors are also concerned that the record keeping system is largely unauditable and of questionable reliability. Records should be easily audited by licensee personnel to verify that requirements of the training program are being met. During the inspection several individuals were identified as not being current in their training based upon training ; records available at the time of the inspection. In a teleconference on June 14, 1989 with licensee representatives, additional information was provided that would indicate that these individuals were current in their I required training. The information obtained in the teleconference was not made available to the inspectors at the time of the inspection, giving the impression that these individuals were not trained at the proper frequenc It also appears that there is great potential for personnel to slip through the training system due to poor record keeping. From the documentation provided to the inspectors, it was extremely difficult to determine what training an individual had attended, what training was required, and when retraining was required. As stated earlier several of the individuals whose training records were reviewed appeared to not have been trained at the proper frequency. Not until the teleconference of June 14 was it __.__ _-.

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easily'auditable and that the records.of training provided are maintained in one area in order to verify the requirements of.the training' program are being' met. lThis is an Open Item (No. 266/89013-02). '! t The licensee _ revised their Emergency Plan on January 19,1989 adding the requirement for annual training for key plant personnel and those

  . individuals assigned specific duties associated with the Emergency Plan, j
  'The inspectors were not able to evaluate whether or not this aspect of
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the plan had been implemented due to the fact that only.approximately four months had passed between the revision date and the date of this inspection. Licensee representative indicated to the inspectors that a program was underway to implement this portion of the pla Implementation of this portion of the training program will be reviewed during a future inspection. This will continue to be tracked as Open Item No. 266/88007-0 As indicated previousiy the inspectors also reviewed training records for seven individuals who had been employees of PBNP 18 months or les Training procedure TRPR-10 requires that PBNP new hires receive prompt indoctrination on the Emergency Plan and EPIPs. As of the date of this inspection only three of the seven new employees whose files were reviewed had received the GET trainin One inspector attended and evaluated a portion of the GET training offered May 24, 1989. The training was informative and appeared appropriate for the personnel in attendance. The portion of the session l attended covered the necessary basic'information required at the plant in addition to basic aspects of the Emergency P1w and EPIPs. It was noted in this session that all of the attendees had been on staff for-approximately one yea Individuals selected for walkthroughs/ interviews were personnel who are qualified to fill key Emergency Response organization positions in-the Technical Support Center (TSC). The individuals selected were all personnel who would normally serve as the backup person to the primary staff. The key TSC positions evaluated were Technical Support Manager, Plant Operations Manager, Emergency Support Manager, Operations Support Director, Health Physics Director, Core Physics Coordinator and

 . Chemistry Director. Each of the interviews conducted consisted of

45-to 90 minutes of questioning utilizing a combination of questions i on the Point Beach training program, mini-scenarios, and hour long  ! scenarios. The main theme of questions and scenarios was comparison of core, containment, in-plant, on-site and offsite radiological and chemistry conditions for consistency and abnormalities. The results  ! of the interviews are summarized below: I Formal EP training is primarily obtained as the result of internal normal departmental reviews (e.g., Health Physics, Technical Services), or for those personnel who also serve as Duty Technical Advisors (DTA) (generic position STA), through the DTA training

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program, rather than as part of a specific EP training progra Although the interviewees demonstrated familiarity with the EPIPs, had participated in drills and exercises, and had received relevant departmental training and self :;tudy, their individual training records as indicated earlier do not always reflect this trainin Periodic EP re-training, based upon interviews and training records review, appears to concentrate primarily on organizational matters, i facility activation, communications, and accident classificatio ' EP training does not concentrate on more detailed subjects such as data analysis, problem solving, performing calculations, and identifying inconsistencies in dat Based upon responses to interview questions, analysis of abnormal source term and radiological data in the TSC is the responsibility 1 of the Core Physics Group. This group is staffed with personnel whose normal positions are in the Plant Technical Services Departmen Health Physics and Chemistry personnel do not have primary responsibility for analyzing radiological data with respect to consistency with perceived overall plant status (i.e. core r.onditions, release paths outside containment, et( ). Chemistry and Health Physics personnel interviewed had great difficulty determining order of magnitude correlation of coolant, containment, auxiliary building, onsite, and offsite radiological data presented in several mini-scenarios. The scenarios included both situations : with and without containment leakage, and with varying degrees of core damage. Shift Superintendents, Reactor Engineers and Maintenance personnel did quite well when presented with the same scenario The Core Physics group demonstrated that they have the knowledge to perform analysis, but indicated that others in the TSC must first bring seemingly abnormal data to their attention. It therefore appears that the root cause of the recent Exercise Weakness (late identification of containment leakage) may be a combination of lack of accident condition problem solving training and lack of coordination between those groups eceiving and reviewing data and the group responsible for analyzing the data. Operations personnel, OSC personnel, Chemistry and Health Physics personnel should be better trained to recognize abnormal conditions and communicate them to the Core Physics grou Other problems noted in the course of conducting this inspection are: The apparent lack of communication between the Training Department and other departments within the plant. Intradepartmental training that is provided is not being " fed" back to the Training Department for incorporation into the training records. Also, the lack of communication between the EP section and the training department was obvious and contributed significantly to some of the problems identified earlie .

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f The apparent lack of support of the training program at the I mid-management leve The inspectors were. told of cases in which , training sessions were scheduled by the Training Department and then L.

H no one or very few people attended the session. This too contributes directly to-the' problems identified in the course of the-inspectio Very little testing or evaluation of individuals attending training is being ccnducte d. . Many EP positions do not have a continuing training frequency other than the biennial requirement for the general trainin Based upon the inspection findings, the training program at PBNP is marginally adequate to maintain an adequate level of preparedness at the plant. During this inspection two new open ~1tems were identified relating to the poor record keeping (No. 277/89013-01) and the unreliability of the training tracking system (No. 266/89013-02).

Open Items No. 266/88007-01 and No. 266/89008-02 will remain open, as indicated earlier, for further revie . TMI Safety Issues Management System (SIMS) Items On October 31, 1980, the NRC issued NUREG-0737, which incorporated-into one document all TMI-related items approved for implementation by the Commission at that time. On December 17, 1982, the NRC-issued Supplement I to NUREG-0737 to provide additional clarification regarding Regulatory Guide 1.97 (Revision 2) - Application to Emergency Response Facilities, and Meteorological Data, as well as other areas. The status of the completion of these TMI SIMS items are internally tracked by the NR ' The October 6,1988 Inspection Repcrt (No. 266/88021,301/88019)

... provided a status listing of the SIMS items related to emergency preparedness. The following listing'provides an updated status of those SIMS items that were "open" in the October 6, 1988 Repor All other emergency preparedness.related SIMS items are closed (complete)ornotapplicabl II Current. Status: Closed This item has been determined to be no longer applicable, and has been administratively close . III.A. Current Status: Closed This item has been determined to be no longer applicable, and has been administratively close _ - - _ _ -

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7 - III.A. Current Status: Close'd This item has been determined to be no longer applicable,. and.has been administrative 1y close i-III.A.2.6- Current Status: Closed-This item has been determined to be no longer applicable, and has been administratively close l III.A. Current Status: Closed This item has'been determined to be no longer applicable, and has been administratively close ' MPA-F-63 Current Status: Open , This item involves a review of the TSC during a future inspectio MPA-F-65 Current Status: Open This item involves a review of.the E0F during a future inspectio . Exit Interview (30703) The inspectors met with the licensee representatives denoted in Section 1 on May 25, 1989. The inspectors summarized the scope and results of the

 . inspection and discussed the likely. content of thel inspection repor Open Items No. 266/88007-01 and No.-266/89008-02 were specifically discussed with the licensee in addition to other observations, including:' out of date training records, individuals whose training wa not current, initial training for new hires not being timely, lack of
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communication between departments, the apparent lack of support'of the training program at the mid-management level, and the results of the walkthroughs/ interviews. The licensee indicated that none of the information-disclosed during the inspection was considered proprietary in natur The inspector discussed the new Open Items identified in this report in a subsequent telephone conversation with the Emergency Planning Coordinator on June 14, 198 l i

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