IR 05000277/1985003
| ML20126E989 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 05/30/1985 |
| From: | Harpster T, Hawxhurst J, Rich Smith, Terc N, Wojnas E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20126E942 | List: |
| References | |
| 50-277-85-03, 50-277-85-3, 50-278-85-03, 50-278-85-3, NUDOCS 8506170280 | |
| Download: ML20126E989 (9) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-277/85-03 Docket No.
50-277/278 License No.
DPR-44/50 Priority Category C
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Licensee:
Philadelphia Electric Co.
2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name:
Peach Bottom Atomic Power Station Inspection At:
Delta, Pennsylvania Inspection Conducted: January 7 - 11, 1985 Inspectors:
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.Ed ojnas, Specialist Idafe Approved by:
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~/dath Emergency Pre 5aredness Inspection Summary: Inspection on January 7-11, 1985.
(Report No. 50-277/85-03; 50-278/85-03) and follow-up meeting held on March 14, 1984.
Areas Inspected:
Routine, announced, emergency preparedness inspection cover-ing changes to the Emergency Plan, Knowledge and Performance of Duties, Dose Calculation and Assessment, and Licensee Audits. The inspection involved 170 inspection hours by four region-based inspectors.
Results: Two violations and one unresolved item were identified and; two open items are noted to be considered for improvement.
Seven open items were also reviewed from previous inspections Nos. 81-28 and 83-33, five items were closed and two remain open.
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0ETAILS 1.
Persons Contacted B. Adams, Health Physicist S. Francis, Senior Engineering Technician
- A. Hilsmeir, Health Physics Supervisor D. Rambold, Corporate Health Physicist D. Wollin, Load Dispatcher (Shift Supervisor)
- G. Bailey, Emergency Planning Analyst (Contractor)
J. Mannix, Training Coordinator D. Ahmuty, Administrative Support Coordinator (Nuclear Training)
R. Gambone, Test Engineer R. MacAllester, Health Physics Supervisor J. Wilson, QA Division Site Supervisor
- 0. Smith, Assistant Superintendent
- R. Fleishman, Station Superintendent
- J. J. Tucker, Site Emergency Preparedness Coordinator
- Denotes persons who attended the exit meeting.
2.
Review of Open Items From Prior Inspections (CLOSED) 81-28-22 The inspectors reviewed selected meteorological moni-toring equipment calibration procedures, calibration records, maintenance checklists and determined that a surveillance program is established and procedures are followed to maintain equipment specifications as outlined in RG 1.23 (Rev 1.).
(CLOSED) 83-33-01 The inspectors discussed with the Emergency Prepared-ness Coordinator his appointment and responsibilities as the site EPC; also, the inspectors reviewed the position description dated 11/84 and determined that a permanent position has been established and a person meeting the qualifications outline has been appointed.
(OPEN) 83-33-02 The inspectors reviewed specific sections in the PBAPS Emergency Plan, held discussions with the EPC and determined the following with respect to revisions numbered below, requested in Enclosure 1 of Inspection Report No. 83-33:
-2,8 and 15 completed, and;
-1,2,3,4,5,6,7,9,10,12,13,14,16,17 and 18 will be considered for the July 1985 revision of the Emergency Plan.
(CLOSED) 83-33-03 The inspectors held discussions with licensee personnel and were provided with additional information documenting the dose asses-sment methods used by PEC0 for refined dose calculations at a meeting on March 14, 1985. The licensee will consider including this infcrmation in the next revision of the Emergency Pla.
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(CLOSED) 83-33-04 The inspectors reviewed EP-315 Rev. O, held a walk-through exercise with the alternate dose assessment team leader and found that the corporate dose assessment model deviates significantly from re-commended guidance (R.G.1.23 Rev.1).
The licensee is aware of the dif-ferences and will consider conforming to the regulatory standard.
(CLOSED) 83-33-05 The inspector reviewed the completed procedures No. 315 Rev. O and noted meteorological parameters from two separate instrumented towers were sequentially ordered for use in estimating atmospheric dis-persion.
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(OPEN) 83-33-06 The inspector reviewed the most recent version of EP-316, Rev. 5 and noted that real-time atmospheric dispersion characteristics are not included in the rapid dose assessment methodology. The licensee will consider revising the procedure to include real-time meteorological input data for rapid dose assessment or they will justify the reason it is not necessary at the site.
3.
Dose Calculations and Assessment 3.1 Review The inspectors reviewed sections EP-315, EP-316 and EP-317 of the PBAPS Emergency Procedures, held a discussion and table-top exercise with the primary and the alternate Dose Assessment Team Leader. A follow-up conference call was also held to resolve some open issues concerning the corporate dose assessment model, which is maintained offsite at the Philadelphia office.
This area of the emergency pro-gram was evaluated against the references listed below, to determine:
-if adequate procedures exist for dose calculations and asses-sment under all anticipated release conditions;
-if licensee personnel performing dose assessment recognize the uncertainties associated with dose projections, and;
-that minimum staffing of the emergency organization is avail-able and have been appropriately trained.
3.2 Findings The licensee's emergency program has several methods for determining l
doses for both iodine and noble gas releases for the plant vent (s)
l and main stack.
The inspectors noted that the licensee has not in-cluded a method to estimate the possible offsite effects from a potential ground level release pathway; for example, an unmonitored release from a steam line-break accident (83-33-07). The method used in EP-315 to estimate initial atmospheric dispersion differs from generally accepted straight-line Pasquill-Gifford diffusion curves and delta temperature measurements. A mixed approach of estimating
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atmospheric dispersion is use'd'at PBAPS. The initial dose estimates are based on diffusion curves from Brookhaven categories and stabi-lity inferred from temperature (50-277/278; 85-03-01).
The Brook-haven categories were developed from wind trace classification (specifically for Bendix aerovanes) and the generalization and appli-cation of only stable and unstable conditions is a significant devia--
tion from guidance (R.G.1.23, Rev.1.) and may not be appropriate for a river valley site.
This item is considered open (50-277/278;85-03-01)
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pending modification of EP-315 to c'onfonn with generally accepted NRC guidance on atmospheric dispersion including stability determination.
The inspectors found that licensee personnel interviewed were gen-erally knowledgeable of "the corporate computer dose model", but some lacked familiarity with site specific factors such as height of the stack and distance to site boundary.
In addition, the inspector noted that the licensee has taken exception to the minimum staffing goals for a senior health physics person within 30 minutes (NUREG-0737, Sup 1); the licensee has requested formal (see references) approval
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of a 60 minute response time for filling a senior HP position. Only one alternate dose assessment team leader is listed in EP-209 Rev.14 (10/13/84).
The PBAPS emergency response staff augmentation in radiological assessment does not indicate a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> staffing capa-bility.
This is an open item (50-277/278;85-03-02) pending revision of EP-209 to reflect the commitment to staffing made in the PBAPS Plan (Table 5.1 and 5.2) and the depth of trained plant staff avail-able for responding to a radiological emergency.
No violations were identified.
3.3 References 10 CFR 50 Appendix E Part IV.B (1/1/84)
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IE Inspection Procedure 82207 (123/27/82), " Dose Calculation and Assessment".
NUREG-0654 (Rev 1; 11/80), " Minimum Staffing Requirements for NRC Licensees for Nuclear Power Plants".
PBAPS Emergency Plan (12/83) Section 5.2.1.5.6, " Dose Assessment Team".
EP-315 (Rev. 0), " Corporate Dose Calculation".
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EP-316 (Rev. 6), " Cumulative Population Dose Calculations".
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Letters 04/03/81 PECO to NRC
"Minium Staffing Proposal" 05/15/83 PECO to NRC
" Staffing for Plant Emergency" 4.
Changes To The Emergency Preparedness Program 4.1 Review The inspectors reviewed procedures EP-209, EP-500, and A-21 as well as Section 9 of the Peach Bottom Emergency Plan and the annual review of the Plan to verify that changes to the Plan and implementing pro-cedures had been reviewed by licensee management to ensure compliance with 10 CFR 50.54(q).
Procedure ST/EP-3C was reviewed to verify that surveillance checks were performed on emergency equipment.
4.2 Findings It was noted by the inspector during review of procedure EP-209, Rev.
7, and Section 9 of the Emergency Plan that quarterly updates of emergency response personnel telephone numbers were not being per-formed as stated in Section 9.2 of the Emergency Plan. The appen-dices to EP-209, Rev. 7, identified when the appendices were last updated. The inspector noted the following, with respect to updating EP-209:
17 months overdue for Appendices D-6 and G; 15 months overdue for Appendices A, F, J, K, and N; and 9 months overdue for Appendices E and H.
Discussions with licensee personnel indicated that procedure EP-209, Rev. 7, had been reviewed and approved by the Plant Operations Review Committee (PORC).
The licensee provided procedure EP-209, Rev. 8 to the inspector immediately preceeding the exit meeting. The intent of this procedure satisfies the requirement of Section 9 of the Emer-gency Plan.
However, it was determined that the licensee had not performed the quarterly update of emergency telephone numbers in procedure EP-209 as specified in Section 9 of their Emergency Plan.
This had been identified as a violation by the inspectors (50-277/
278;85-03-03) but was subsequently corrected by the licensee.
(See Appendix A: Notice of Violation)
4.3 References:
EP-209 (Rev. 7 and Rev. 8) " Telephone List for Emergency Use",
Appendices A thru P.
EP-500 (Rev. 0), " Review and Revision of the Emergency Plan" (FSAR Appendix 0).
A-21 (Rev. 5), " Generation of Emergency Plan Procedures".
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PBAPS Emergency Flar., (12/83) Section 9, " Emergency Plan Review".
PBAPS Emergency Plan (12/83), Appendix F, " Emergency Plan Distribution List".
Annual Review of the Peach Bottom Emergency Plan dated December 17, 1984.
5.
Knowledge and Performance of Duties (Training)
5.1 Review The inspectors reviewed the Peach Bottom Atomic Power Station Emer-gency Plan and the Emergency Training Program to determine the train-ing required for members of the emergency organization.
The Emer-gency Plan requires individuals to receive initial training and also annual retraining. To implement this requirement the Training Pro-gram contains 15 Lesson Plans that include an emergency plan overview and other lesson plans for specialized training in the Classification System and Immediate Response; Emergency Teams and Activation; Dose Assessment and Protective Actions; etc.
The les:on plans were de-signated as, " Detailed", for members required to perform the activi-ties covered in the lesson plan and as, " Abbreviated", for members required to be familiar with the area of the lesson plan. The Train-ing Program contained a matrix that specified the lesson plans of training to be provided to each member of the emergency organization.
5.2 Findings The inspector reviewed training records for Calendar Year 1984 for 35 members of the emergency organization. The members were selected from Emergency Procedure 209 and several of its Appendices. The training records revealed the following 11 members - No Lesson Plans (LP's) Training 14 members - Each Missing 3 Detailed LP's 3 members - Each Missing 2 Detailed LP's 2 members - Each Missing 1 Detailed LP 5 members - Received all required Detailed LP's According to the records, none of the 35 members had received any required " Abbreviated" Lesson Plan Training. This has been iden-tified as a violation (50-277/278;85-03-04).
(See Appendix A: Notice of Violation.)
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1 5.3 References 10 CFR 50.47(b) (15) (1/1/84).
10 CFR 50, Appendix E. IV. F. (1/1/84).
PBAPS Emergency Plan (12/83) Section 8, " Emergency Plan Training".
EP-209 (Rev 7), " Telephone List for Emergency Use".
6.
Licensee Audits 6.1 Review The inspectors reviewed Quality Assurance (QA) audit reports for 1982 through 1984 pertaining to PBAPS Emergency Plans and Procedures and held interviews with the General Supervisor of Quality Assurance programs and with the PBAPS QA Supervisor onsite.
In addition, discussions were held with the onsite Emergency Preparedness Coor-dinator (EPC) and a Stone & Webster consultant.
6.2 Findings During the year 1982, PEC0 QA auditors issued two reports, dated 6-1-82 and 9-13-82.
The inspectors noted that QA audits are per-formed by persons who have no direct responsibility for the imple-mentation of the emergency preparedness program.
In the 6-1-82 report, QA auditors stated that they found ne deft-ciencies and that compliance with the EP and EPIPs was verified.
This audit took place between the EP appraisal (Report No. 277/81-28 and 278/81-31 issued on 4-29-82), and the Emergency Exercise (Report No. 277/82-12 and 278/82-12) issued on 7-21-82.
PECO auditors could not find a formal response to NRC addressing an appraisal finding which required a review of all emergency procedures to eliminate deficiencies and identify missing procedures (Item 277/81-28-30; 278/81-31-30).
In addition, a follow up was not conducted by the auditors to verify that all procedures had been reviewed and revised as necessary.
In the 9-13-82 report, QA auditors concluded that the mechanisms established to assure that corrective actions are properly imple-mented were adequate and were being effectively implemented. The auditors followed up on the status of item 277/81-28-30; 278/81-31-30, and noted that some procedures were still being revised because of deficiencies identified in the implementation of these procedures during the 6-16-82 Emergency Exercise. At this time, the auditors considered the item closed.
The auditors identified that drills in preparation for the 6-16-82
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exercise had been conducted on 2/9, 4/6, 4/27, 5/12, and 6-12-82, but made no mention of deficiencies identified during the critiques of these drills or of follow ups and corrective action mechanisms.
The auditors failed to mention defict'encies identified during the emergency exercise by the NRC report, nor PEC0's critique of the exercise, and the corrective actions taken to correct deficiencies identified therein.
In the 11-14-84 report, QA auditors concluded that administrative controls, established by PBAPS to meet the re-quirements of the Emergency Plan, were adequate a'nd were being effectively implemented.
The auditors reviewed EP training records of a sample of 20 persons which had specific emergency response responsibilities and verified that 15 out of 20 had been trained or retrained for 1984.
However, no mention was made of the status of the 5 that had not been trained or retrained, e.g., whether they had been scheduled for training.
The auditors reviewed NRC Report No. 277/83-17 and 278/83-17, per-taining to the 6-28-83 emergency exercise and failed to mention the actions taken to correct all the deficiencies identified in the report, except for those referring to Health Physics for which a repeat exercise was required (See NRC Report No. 277/83-22 and 278/
-83-22).
In addition, the auditors made no mention of the PECO critique and follow up actions on deficiencies identified by the PECO staff.
Based on the above findings this area is still open for further
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investigation. This is an unresolved item (50-277/278;85-03-05).
6.3 References PECO QA Audits (6/1/82)
PEC0 QA Aud:t (9/13/82)
EPIAP 12-7-17-81 4-29-82 277/81-28,278/81-31 Exercise 06-15-17-82 7-21-82 277/82-12,278/82-12 Follow-up 01-10-14-83 3-14-83 277/83-01,278/83-01 PNS 02-23-25-83 4-05-83 277/83-06,278/83-06 Exercise 06-27-29-83 8-03-83 277/83-17,278/83-17 l
HP drill 08-03-83 10-07-83 277/83-22,278/83-22
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Routine Insp. 11-28, 12-02-83 1-26-84 277/83-33,278/83-31
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10 CFR 50.54 (t) (1/1/84).
Emergency Plan (12/83) Section 9, " Emergency Plan Review".
7.
Exit Meeting The inspectors meet with representatives of the PEC0 staff, indicated in Section 1, on January 11, 1985. Two violations and one unresolved item were identified as inspection findings, along with two open items.
The licensee indicated steps had been taken to correct one violation ands follow-up action would be planned for the other items.
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