IR 05000266/1999010

Insp Repts 50-266/99-10 & 50-301/99-10 on 990329-0401.No Violations Noted.Major Areas Inspected:Review of Emergency Preparedness Program & Aspect of Plant Support

ML20205R473
Person / Time
Site:	Point Beach
Issue date:	04/19/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20205R469	List: IR 05000266/1999010 ML20205R465
References
50-266-99-10, 50-301-99-10, NUDOCS 9904230036
Download: ML20205R473 (11)

Text

'

'

l

\

'

\

. \

U.S. NUCLEAR REGULATORY COMMISSION REGION ll1 Docket Nos: 50-266; 50-301 License Nos: DPR-24; DPR-27

.

Report Nos: 50-266/99010(DRS); 50-301/99010(DRS)

Licensee: Wisconsin Electric Power Company l

Facility: Point Beach Nuclear Plant, Units 1 and 2 Location: 6610 Nuclear Road Two Rivers, WI Dates: March 29 - April 1,1999 Inspector: Donald E. Funk Jr., Emergency Preparedness Analyst Approved by: Gary L. Shear, Chief, Plant Support Branch Division of Reactor Safety l

9904230036 990419 PDR ADOCK 05000266 G PDR

.

.

.

.

EXECUTIVE SUMMARY Point Beach Nuclear Plant (PBNP), Units 1 and 2 NRC Inspection Reports 50-266/99010; 50-301/99010 I

This inspection reviewed the Emergency Preparedness (EP) program, an aspect of Plant Support. The inspector selectively evaluated the quality of the EP program, related audits and reviews, reviewed the effectiveness of management controls, verifed the adequacy of emergency response facilities and equipment, reviewed a number of EP training and qualification activities, and included followup on previous inspection findings. This was an announced inspection conducted by a regional inspecto e Overall, the EP program had been maintained in an adequate state of operational readiness. Management support to the program was strong, and interviewed key emergency response personnel demonstrated a working knowledge of responsibilities and emergency procedures. (Section X1)

e Emergency response facilities, equipment, and supplies were well-maintaine Demonstration of selected emergency response equipment verifed that the equipment was operable. On shift dose assessment capability was acceptable. (Section P2.1)

e The Nuclear Tracking System was an effective method to track and close EP issue Condition Repodts were effectively utilized by the EP staff. Procedures were generally clear and easy to use with only minor problems identified in two procedures. The emergency informatKm calendar was noted as a good public relations initiativ (Section P3)

• - The EP training program was adequate. Training, drills, and exercises were properly critiqued. The interviewed Emergency Response Organization (ERO) personnel successfully demonstrated knowledge of their emergency roles. Documents to implement the training program for the revised ERO have not been fully develope ;

(Section PS)

e- The EP Manager and Supervisor demonstrated in-depth knowledge of the licensee's EP program during discussions and had initiated appropriate corrective actions on several self-identified concems. (Section P6) l e The licensee's 1998 and 1999 Quality Verification audits of the EP program were effective and satisfied the requirements of 10 Code of Federal Regulations (CFR)

50.54(t) and property followed licensee procedural guidance. The EP staffs ongoing responses _to audit findings were appropriate and timely. (Section P7)

!

l l

i b -.e u _ _ _ _ _ _ _ _ _ _ _ _ - _ _

,

.

.

e Reoort Details IV. Plant Support P2 Status of EP Facilities, Equipment, and Resources P Material Condition of Emeroency Resoonse Facilities Insoection Scope (IP 82701)

The inspector evaluated the material condition of the Control Room (CR), Technical Support Center (TSC), Operations Support Center (OSC), Emergency Operations Facility (EOF) and the offsite radiological survey team vehicles. Emergency plan sampling kits were also inspected. The licensee demonstrated the operability of i numerous pieces of emergency response equipment, including radiological survey instruments, dose assessment and plant data computer terminals, portable generators and communications equipment. Records of periodic inventories and equipment tests were also reviewe ,

I Observations and Findinas The CR, TSC, OSC and EOF were in an acceptable state of operational readiness. No concems were identified during the examination of emergency supplies, procedures, forms, and equipment in these locations. The survey team vehicles were in a sound state of readines Emergency preparedness staff had effectively maintained the readiness of response facilities and equipment. The TSC, OSC and EOF were also used for normal business purposes, but condition reports and management support had been successful in ensuring that these areas were retumed to their "as found" condition after normal business use.

l Inventory records of emergency equipment and supplies for calendar year 1998 through

!

the first quarter 1999 were reviewed. Licensee procedures stated that these inventories should be conducted quarterly and following each use. Also reviewed were monthly notification checks and communication tests. The inspector's review determined that all records had been completed as required within the appropriate time frame Two dose assessment programs were available, a simplified version for control room )'

operator utilization, and a more full-featured program for use in other facilities. Licensee staff demonstrated the operability and performance of the Meteorological and Dose Assessment-CR (MAD-CR) and the Wisconsin Electric Dose Assessment Program j (WEDAP), computer programs that would be used to generate offsite dose projection !

MAD-CR was installed in the CR, while WEDAP was available in the TSC and EO Planned replacement of MAD-CR with WEDAP had been delayed due to ongoing computer upgrade j

. .

._ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.

.

.

Each atmospheric dispersion model was a " user friendly," straight-line Gaussian plume model. Current onsite meteorological data were automatic inputs to the MAD-CR program only. An effective " operator aide," which described startup, was posted near the MAD-CR computer termina Records for the prompt alert and notification sirens for 1997 and 1998 were reviewed by the inspector. Annual operability for 1997 was 96.13 percent with 85.71 percent for the lowest month's average. The 1998 annual operability average was 96.43 percent with 89.29 percent for the lowest month's average. Siren operability exceeded the )

acceptability limit of greater than or eaual to 90 percent for a 12 month rolling average. I c. Conclusions Emergency response facilities, equipment and supplies were well-maintaine Demonstration of selected emergency equipment verified that the equipment was operable. On shift dose assessment capability was acceptabl P3 EP Procedures and Documentation a. Insoection Scooe UP 82701)

The inspector reviewed a sample of Emergency Plan implementing Procedures (EPIPs),

Emergency Plan Maintenance Procedures (EPMP) and emergency plan sections, including those related to the October 28,1998 Emergency Plan revision. Also, the Nuclear Tracking System (NUTRK) Condition Reports related to the EP program and several documents related to EP staff initiatives were also examine b. Observations and Findinas Point Beach Nuclear Plant (PBNP) EPIP 4.3, " Emergency Operations Facility Activation i and Evacuation," Revision 20, dated October 28,1998, was reviewed by the inspec'or during a demonstration of the WEDAP in the EOF The procedure prescribes the i instructions for the activation of the EOF and also describes the method by which the l EOF and Offsite Radiation Protection Facility is evacuated and responsibilities j transferred. Attachment 2 to the procedure describes the actions to obtain access of the WEDAP. Using the procedure a licensee dose assessor demonstrated access to the WEDAP using both the primary method, a personal computer, and a backup method, a floppy diskette located in the equipment cabinet. A secondary method using the Local Area Network access is described in section 2.0 of the procedure. However, this section of the procedure was determined to be no longer valid due to computer conversion to windows NT configuration in December 1998 from Windows 3.1. The licensee will revise the procedure to delete this metho PBNP EPIP 2.2, "NRC Notification," Revision 10, dated February 26,1999, was also reviewed. This procedure, which related to communications with the NRC, contained accurate statements regarding the potential for NRC responders to request "open line" communications. The procedure also included reasonable criteria for updating NRC

!

__ _____j

.

>

,

i responders of changes in plant conditions and major decisions. However, comments in I sections 3.2 and 5.0 needed further clarification regarding the required timeliness of j such notifications. The procedure states "the NRC shall be notified within one hour after l

- declaration of a classified emergency" but, the requirement in 10 CFR 50.72(3) states

"immediately after notification of the appropriate State or local agencies and not later than one hour after the time the licensee declares one of the Emergency Classes." The procedure as written may give the false impression that the licensee has one hour to make NRC notifications even if the opportunity exists to make the notification soone The licensee stated the procedure will be revised to be consistent with the regulation The inspector reviewed NUTRK (the process that the EP group uses to identify, track and close EP issues) and associated procedures NP 5.4.1, "Open item Tracking System," Revision 6, dated March 3,1999, and NP 5.3.1, " Condition Reporting System," Revision 13, dated March 31,1999, to determine the range of issues identified and the effectiveness of tracking and disposition of the identified issues. Approximately 186 Condition Reports related to the EP program were generated since the last inspection. The items reviewed were clearly identified by number and description, cognizant management and responsible persons were identified, due dates, and item status were listed. These useful reports were used to document and track the progress and completion of corrective actions related to a spectrum of items identified by EP staff, Quality Assurance staff, and critiques of exercises, drills, and classroom trainin The Public Education and Information calendar which was distributed during the month of October 1998, was reviewed. This full color document included information from the past *Public Safety Information" booklets and a calendar for October 1998 through December 1999. The development of the " Emergency Information" calendar was a good public relations initiative and a joint effort between the State of Wisconsin, Manitowoc County, Kewaunee County, Point Beach Nuclear Plant, and the Kewaunee Nuclear Power Plan j .Q9ng.lMqikt01 I

I The NUTRK was an effective method to track and close EP issues. Condition Reports were effectively utilized by the EP staff. Procedures were generally clear and easy to

]

use with only minor problems identified in two procedures. The emergency information calendar was a good public relations initiativ P5 Staff Training and Qualification in EP Inspection Scope (IP 82701)

l The inspector reviewed various aspects of the EP training program. The review included

'

interviews with selected key emergency response organization personnel (a TSC manager and an Emergency Notification System communicator), drill and related critique records, attendance records, lesson plans and the call-out list of Emergency Response Organization (ERO) personnel. Records from the training tracking program were compared with the call-out list to determine whether ERO personnel on the call-out list

.

f

.

were qualified. Respirator and Self-Contained Breathing Apparatus (SCBA)

qualifications of plant personnel were also reviewe b. Observations and Findings Records reviewed indicated that quarterly, or as needed, revisions to the ERO call-out roster were issued, as appropriate, since the last inspection. Review of these rosters indicated that the numbers of personnel assigned to specific positions in the ERO were acceptabl After what was determined by plant management to be a failed EP drill in July 1998, plant management decided that the structure of the ERO required major changes. A decision was then made to make these changes prior to the November 1998 NRC evaluated exercise. For a three month period, August through October, the licensee set out to qualify personnel in a revised ERO that partially consisted of new titles, positions and responsibilities. These changes were part of an October 28,1998, emergency plan chang The licensee then set aside its approved training procedure (TRPR) TRPR 34.0,

" Emergency Response Training Program", Revision 4, dated September 18,1997 and EP lesson plans and developed Position Instruction Manuals (PIMs), specific instructions for each ERO position and two lesson plans, LP2802, "New Emergency Response Organization TSC/OSC", Revision 0, dated September 10,1998 and LP2805, "New Emergency Response Organization EOF /OSRPF", Revision 0, dated September 17, 1998, to use in this qualification effort. The training consisted of three phases, classroom, table top drill, and a performance based drill. Following successful I completion of these components, letters of qualification were sent to the training department for the individual The EP supcrvisor stated that the above method was permitted by exercising the portion of the training procedures which allows the owner of the training program (in this case, the EP Manager) to exempt personnel from portions or all of the otherwise identified training. The inspector determined that while this may be technically permitted its use should be for a specific case by case basis; however, the licensee used this method to qualify approximately 190 individual Using a sampling from the old ERO call list it does appear that ERO members were property qualified prior to the changeover and that any new members, since the three month period, are now being trained using the EP training matrix in the TRPR until the TRPR is revised and approved and new lesson plans and qualification cards are developed to reflect the new ERO training program. .The implementation of the required documents for the new ERO training program will be tracked as an Inspection Followup item (IFl 50-266/301-99010-01).

Periodic unannounced, off-hours augmentation drills were conducted and critiqued using appropriate criteria for assessing drill pelformance. After noting that timely responses l were declining, management support was obtained to increase the frequency of these drill .

.

Two ERO members, who would either communicate directly with NRC responders or who would supervise others communicating with NRC, were interviewed. Their knowledge of their responsibilities was acceptable. A dose assessor demonstrated excellent knowledge of the WEDAP dose projection progra Review of respirator and SCBA qualification documentation provided the following information:

DEPARTMENT 6h,f YN{-- hf NUMBER oF YYb$ff TRAINING / MEDICAL RESPIRATOR fff, sCBA QUALIFIED

',

INDIVIDUALS QuAUFIED QUALIFIED Radiation Protection 47 44/37 35 21 Operations 115 108/110 98 88 Instrument Maintenance 23 16/14 14 6 Electrical Maintenance 23 21/19 18 2 Mechanical Maintenance 33 28/27 27 2 Chemistry 18 15/12 11 9 NRC Information Notice 98-20, " Problems with Emergency Preparedness Respiratory Protection Programs," was issued June 3,1998. This information notice alerted licensees to multiple generic weaknesses in respiratory protection programs supporting emergency preparedness. Respiratory protection qualifications included three parts; respir-tory training, medical testing, and a mask fit. The numbers represented the currer.1 respiratory qualifications by department. The results of this review indicated that there appears to be sufficient respirator and SCBA qualified personnel to respond in the event of an emergency. Discussion . indicated that licensee personnel were aware of the information notice, and had evaluated its informatio Conclusions The EP training program was adequate. Training, drills, and exercises were properly critiqued. The interviewed ERO personnel successfully demonstrated knowledge of their emergency roles. Documents to implement the training program for the revised ERO have not been fully develope P6 EP Organization and Administration

' InsDection Scooe (IP 82701)

The inspectors conducted discussions with the EP staff regarding the current EP organization and anticipated change I

.

.

4 Observations and Findinas l Significant changes have been made to the EP organization since the last routine inspection in June 1997. At that time, the EP staff consisted of three individuals, an EP Coordinator, an EP Specialist and an EP instructor. The current organization consists of six individuals. A new position of Manager, Emergency Response was created who ,

reports to the Manager-Regulatory Services and Licensing. Reporting to the EP 1 manager is the Supervisor of Emergency Response and his staff which consists of an Emergency Plan Coordinator, an Emergency Planning Specialist, an EP Technical Coordinator and an Emergency Planning Training Specialist who works in the EP '

department, but is matrixed to the training department. All of these individuals with the exception of the Emergency Plan Coordinator are new to the Point Beach EP organizatio Discussions with the site EP staff determined that numerous enhancements to the program have been either completed or in progress. The activation of the EOF was changed from a site area emergency to the alert level. This change enabled the ERO to change its focus so that the TSC and EOF could better divide and concentrate its responsibilities toward onsite versus offsite activities. Other enhancements in progress are the installation of an automated notification system (Dialogic) to decrease the time to complete the call out process and revision of the emergency action level scheme to remove inconsistencies and add a numerical identifier to each actio Conclusions .

The EP Manager and Sur>ervisor demonstrated in-depth knowledge of the licensee's EP program during discussions and had initiated appropriate corrective actions on several self-identified concem P7 Quality Assurance in EP Activities P7.1 Audits Inspection Scope (IP 82701)

The inspector reviewed Quality Verification (QV) audit report A-P-98-04, dated April 8, 1998 and QV audit report A-P-99-02 dated March 25,1999. The review included an interview with the audit team leader and a team member. The inspector also reviewed EPMP 3.4 Emergency Preparedness Program Revie Observations and Findinas During the period of February 8 - 19,1999, a QV audit of EP was performed. The audit was performed by five individuals, including two functional experts from other nuclear licensees' EP organizations. The auott's scope satisfied the requirements of 10 CFR 50.54(t) and was conducted in accordance with EPMP 3.4, " Emergency Preparedness Program Review," Revision 8, dated December 28,1998. The auditors properly

• l

.

.

identified several program strengths, six items requiring corrective actions, and some improvement items. All concerns identified during the 1998 audit were resolved. EP staff were responsive to the auditors' findings. The EP organization has also scheduled itself for three self assessments to be accomplished during calendar year 199 The EP audit also contained an evaluation of the effectiveness of offsite interfaces with State and local govemments which is required by 10 CFR 50.54(t). The evaluation of j adequacy of offsite interface had been accomplished by documentation review and face j to face interview Conclusions The licensee's 1998 and 1999 QV audits of the EP program were effective and satisfied the requirements of 10 CFR 50.54(t) and properly followed licensee procedural  ;

guidance. The EP staff's ongoing responses to audit findings were appropriate and )

timel l

!

P8 Miscellaneous EP lasues (Closed) Inspection Followuo item 50-266/301-98020-01: Issuance of dosimetry to control room personnel under emergency conditions was not proceduralized. Corrective action included revising EPIP 1.3 * Emergency Event - Immediate Actions" to include step 13 under the Duty Shift Superintendent actions to issue self reading dosimetry to CR personnel at the Alert or higher classification. This item is close (Closed) Insoection Followuo item 50-266/301-98020-04: During the November 1998 EP exercise it was identified that a State geographic subarea map was needed in the EOF. As an interim measure a one inch scaled map was obtained and placed in the EOF for use by managers and dose assessment personnel. Other long term options for a overlay of the present sector map are being pursued by the EP staff. This item is close V. Manaaement Meetinas I X1 Exit Meeting Summary The inspector presented the preliminary inspection results to members of licensee management at the conclusion of the inspection on April 1,1999. The licensee acknowledged the findings presented. Overall, the EP program had been maintained in an adequate state of operational readiness. Management support to the program was strong, and interviewed key emergency response personnel demonstrated a working knowledge of responsibilities and emergency procedure The inspector asked the licensee whether any materials examined during the inspection should

. be considered proprietary. No proprietary information was identifie l l

_a

.

.

I PARTIAL LIST OF PERSONS CONTACTED Licensee M. Findley, Manager, Emergency Response L. Flanagan, EP Plan coordinator T. Garraway, QV Specialist D. Gehrke, QV Supervisor D. Haese, EP Training Specialist R. Hayden, EP Supervisor R. Hopkins, QV Supervisor S. Johnson, EP Technical Coordinator V. Kaminskas, Manager Regulatory Services and Licensing J. Knorr, Manager, Regulatory Compliance C. Krause, Regulatory Compliance R. Milner, EP Training Coordinator A. Pusztal, QV Senior Specialist M. Reddemann, Site Vice President K. Yunk, EP Specialist  ;

i NRC F. Brown, Senior Resident inspector P. Simpson, Resident inspector  ;

I I

INSPECTION PROCEDURES USED i

IP 82701 Operational Status of the Emergency Preparednecs Program ITEMS OPENED, CLOSED AND DISCUSSED Opened

)

50-266/301-99010-01 IFl implementation of the training program for the revised emergency response organizatio ]

Closq#

50-266/301-98020-01 IFl issuance of dosimetry to control room personnel under emergency conditions was not proceduralized 50-295/301-98020-04 IFl Need for state geographic subarea map in the EOF DIELugMtd None

,.

.

LIST OF ACRONYMS USED CFR Code of Federal Regulations CR Control Room EOF Emergency Operations Facility EP Emergency Preparedness EPIP Emergency Plan implementing Procedure EPMP Emergency Plan Maintenance Procedure ERO Emergency Response Organization IFl inspection Followup Item MAD-CR Meteorological and Dose Assessment-Control Room NRC Nuclear Regulatory Commission NUTRK Nuclear Tracking System-OSC Operations Support Center PBNP Point Beach Nuclear Plant QV Quality Verification SCBA Self-Contained Breathing Apparatus TRPR Training Procedure TSC Technical Support Center WEDAP Wisconsin Electric Dose Assessment Program i

11