IR 05000277/1986006

Emergency Preparedness Insp Repts 50-277/86-06 & 50-278/86-06 on 860310-13.No Violation Noted.Major Areas Inspected:Confirmatory Action Ltr 85-17 Commitments & Min Staffing Plan for Site

ML20202F507
Person / Time
Site:	Peach Bottom
Issue date:	04/02/1986
From:	Harpster T, Hawxhurst J, Vito D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20202F450	List: IR 05000277/1986006 ML20202F445
References
50-277-86-06, 50-277-86-6, 50-278-86-06, 50-278-86-6, CAL-85-17, NUDOCS 8604140169
Download: ML20202F507 (8)

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U.S. NUCLEAR REGULATORY COMMISSION-

REGION I

50-277/86-06 Report No /86-06 50-277 Docket No DPR-44 License Nos. DPR-56 Priority --

Category _ C Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name: Peach Bottom Atomic Power Station Inspection At: Delta, Pennsylvania Inspection Conducted: March 10-13, 1986 and March 18, 1986 Inspectors: **/s . /4 5 /, /785 Ha g urst, mergency Preparedness </ dat6 Specialist, Team Leader r@Arn did

/ dite D.Spetta Vip,listSenior Emergency Preparedness Approved by: '

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T. E. ljdrpster, Rhief date Emergeficy Prepa#dness Section Inspection Summary:

Combined Inspection on March 10-13, 1986 (Report Nos. 50-277/85-36 and 50-278 85-34)

Areas Inspected: Routine unannounced emergency preparedness inspection at the Peach Bottom Atomic Power Station and a subsequent meeting held at PECO head-quarters on March 18, 1986. The inspection covered three areas: Confirmatory Action Letter No. 85-17 commitments; previous open items; and the minimum staffing plan for the PBAPS site and its relation to the emergency organizatio The inspection was performed by two NRC Region I inspector Results: The licensee has adequately met the commitments stated in the November 1985, Confirmatory Action Letter. Six open items have also been closed as a result of this inspectio No violations were identifie ts609140169 860404 PDR ADOCK 05000277 G PDR

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l DETAILS l Persons Contacted l The following licensee personnel were contacted during the inspection:

i D. Ahmuty, Administrative Support Coordinator l G. Anderson, EP Trainer (Consultant)

R. Fleischmann, Plant Manager T. Geyer, Shif t Technical Advisor A. Hilsmeir, Manager, Radiation Protection R. Kankus, Director, Emergency Planning B. Logue, Superintendent, Nuclear Services D.' 01sman, Senior Chemist t

S. Roberts, Operations Engineer D. Rombold, Senior Health Physicist (Corporate)

J. Tucker, Site Emergency Planning Coordinator T. Ullrich, Superintendent, Nuclear Generation W. Widener, Shift Superintendent S. Wookey, Training Coordinator Licensee Action on Confirmatory Action Letter No. 85-17 2.1 Background The licensee's annual emergency preparedness exercise was held on October 17, 1985. During the exercise, there was indication of poor performance in certain areas. A subsequent meeting was held to dis-cuss these problem areas and a Confirmatory Action Letter (CAL) was issued on November 11, 1985. The CAL (No. 85-17) addressed four areas where expedient corrective action was necessary along with the agreed upon completion dates. These four areas are identified and discussed belo .2 Review The inspector reviewed the reference documents listed and held discus-sions with licensee representatives to determine whether appropriate corrective actions had been taken for each of the four items belo .3 Action Items, Findings and References 2.3. (85-17-10) Review and revise PBAPS Emergency Plan and Implementing Procedures to clearly define the emergency response organization and the responsibilities of key per-sonnel and the lines of information flow among key manager i _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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2.3. Findings-The inspector determined that the Emergency Plan and appli-cable implementing procedures have been changed to reflect the general and specific responsibilities of each emergency

, response organization (ERO) position. The references to

" interim" ERO positions have been removed. The licensee

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has agreed that any person who has been designated for a particular ERO position or as an alternate to a particular ERO position should be trained to handle all of the respon-sibilities of that position. Maintaining the continuity of position responsibilities and auth)rities should provide.

for efficient personnel turnover i.nd clearer lines of

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information flow between ERO manager '

i This item has been adequately addressed by the licensee, i 2.3. References

= PBAPS Emergency Plan Section 5, Organization, Re January 1986

= . Emergency Plan Procedures (EPPS)

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= EP-120, Dose Assessment Team, Revision 2, 12/31/85

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• EP-210A, Field Survey Groups, Revision 1, 1/15/86

• EP-209, Telephone Lists for Emergency Use, Revi-sion 11, 12/31/85

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= EP-207,_ Personnel Safety Team Activation, Revi-sion 7, 9/12/85

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• EP-205A, Chemistry Sampling and Analysis Team, Revision 6, 10/16/85

• EP-201, TSC Activation, Revision 9,1/7/86

- EP-202, OSC Activation, Revision 8, 10/16/85

• EP-203, E0F Activation, Revision 9, 1/8/86 '

2.3. (85-17-02) Review and revise the emergency plan and imple-menting procedures to incorporate the basis and methodology for implementing protective action decisionmakin ,

2.3. Findings

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The inspector determined that the revised EP-317, " Deter-l' mination of Protective Action Recommendations," provides direction and guidance for the development of PARS. The inspector also noted that training was provided to key managers in the use of this procedur This item has been adequately addressed by the licensee.

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= PBAPS Emergency Plan, Section 6.7, Protective Actions, July 1985

- Emergency Plan Procedure, EP-317, Determination of Protective Action Recommendations, Rev. 4, January 1986 2.3. (85-17-03) Review and revise the event classification procedure to provide for both descriptive conditions and specific action levels that ensure that declarations are based upon the integration of plant parameters and radio-logical and environmental condition .3. Findings The inspector found that the Emergency Plan and event classification procedure have been changed by the licensee to indicate that the Emergency Director not only use spe-cific plant parameter action levels to effect the event classification but may use his discretion to classify or escalate the classification of the event. The licensee has added a section to Appendix EP-101-1 denoted as General Conditions to allow for this judgmental capability in Emergency Action Levels char This item has been adequately addressed by the license .3. References PBAPS Emergency Plan, Section 4, Emergency Conditions, Re January 1986

- Emergency Plan Procedure EP-101, Classification of Emergencies, Rev. 15, 1/10/8 .3. (85-17-04) Conduct training, both classroom and practical, to assure that:

(a) adequate trained personnel are available, (b) personnel are knowledgeable of EAls, and (c) personnel are knowledgeable of PAR .3. Findings The intpectors reviewed training records, held discus-sions with licensee personnel in key management positions and determined in most cases, training was effectively

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implemente The inspector found that the training progran'

will provide well qualified / trained persons for key positions to respond to an emergency. The retraining program was near completion. At the site, all except two shift superintendents had attended training for the Emergency Director position and the last two were scheduled for March 14, 1986. At the PECO corporate office both the Superintendent of Nuclear Generation and the Superintendent of Nuclear Services have been trained on the latest revisions of the PBAPS Plan and Procedures.

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This item has been adequately addressed by the license '

I 2.3. References '

PBAPS Emergency Plan, Section 5, Organization, January 1986 i

l 3. Licensee Action on Previous Inspection Findings

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3.1 (Closed) 50-277/83-06-03. Complete mechanical maintenance program l for strens.

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! The inspector held discussions with licensee representatives and l i reviewed a PECO memo dated October 11, 1985, which included the

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" Maintenance Check Sheet" and " Siren Service Manual". The inspector l noted that maintenance and surveillance on the system is ongoin The PBAPS Siren System was last serviced Fall 1985 by Susquehanna Branch Personnel and the Overhead Transmission Group. Also, the licensee has a procedure EPS-I-201, issued 12/17/85, which estab-11shes the responsibilities and methods for responding to, reporting of, and correction of siren problem .2 (Closed) 50-277/83-33-06. Consider actual meteorological measure-

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ments in the " RAPID" dose calculatio The inspector held discussions with licensee personnel and determined l

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that the proposed new computerized dose assessment program will ade-quately consider actual meteorological measurements in the " Fast A Mode."

3.3 (Closed) 50-277/85-03-01; 50-278/85-03-01. Modify EP-315 to conform with generally accepted NRC guidance on atmospheric dispersio '

The inspector held discussions with licensee personnel and noted that the proposed new computerized dose assessment program will calculate atmospheric dispersion using: delta temperature and the Pasquill-Gifford curves, and 15 minute average wind speeds and direction parameter . - _ _ _ _

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3.4 (C1'osed) 50-277/85-03-04; 50-278/85-03-04. Members in the PBAPS, emergency response organization.for the calendar year 1984, had not received the required emergency response trainin The inspector reviewed training records for 30 members of the

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emergency response organization for the calendar year 1985. The

. members were selected from Emergency Plan Procedure EP-209 (callout

- list) and several of its appendices. The inspector found that the f

training for the selected individuals had been completed with some ,

minor exceptions. The most notable exception was the shift super-visors who were listed in the records under training for the position of. Emergency Director. All of the shift supervisors had only been-trained in a portion of the lesson plans required for the Emergency Director position in 1985. This discrepancy'was explained by the licensee in that the previous approach of designating interim emer-gency response organization positions affected the training of the shift supervisor In 1985, the shift supervisors were designated as Interim On-Shift Emergency Directors and did not receive the full complement of Emergency Director training. The licensee has committed to training the shift supervisors in all of the Emergency Director lesson plans in 198 .5 (Closed) 50-277/83-22-01; 50-278/83-22-01. Personnel making entries into radiologically controlled areas during emergencies should be qualified to wear SCBA The inspector held discussions with licensee personnel and noted that a system was in place to track those persons currently qualified to wear SCB The program, PRPP4, is updated nightly Monday through Friday and provided to Station Health Physics and Bechtel Corporation personnel who are responsible for distribution of all respiratory equipment. This information will be available in the Auxiliary OSC during an emergenc .6 (Closed) 50-277/83-22-02; 50-278/83-22-02. Management review to ensure an adequate system is implemented to maintain current list and to notify supervision when SCBA requalification is require The inspector noted that respiratory protection training is offered annually coincident with general employee training and supervision can track employee qualification on the PRPP4 computer listin .0 Minimum Staffing Requirements for Emergency Response Background In the past several years, the licensee has submitted to NRC/NRR licensing proposed exceptions to the staffing goals for emergencies noted in NUREG-0737, Supplement 1, and reiterated in NUREG-0654/ FEMA-REP-1, Revision 1, Table B-1. The inspector reviewed the latest submittal by the licensee (dated February 11,1986) to determine its accuracy as related to present PBAPS staffing and to future staffing commitment .-_ _ _ _ . . . _ . _ . . , _ _ . _ _ . _ . _ _ , _ _ _ _ _. _ _ - - _ _ . _ _ _ _ . _ _

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I Review and Findings The following findings were noted:

a) The licensee has stated that offsite dose assessment calculations within.the first 30 minutes after a fast breaking accident has begun will:be performed by a person "on-shift" who is trained at the same'

level ~as senior health physics management personnel. The submittal does not state what plant department this person will come from or what minimum qualifications will be required. of this person. Although it is acknowledged that this person will be specified af ter the new computer dose assessment system is installed-and appropriate training is completed, the inspector inquired as to what person would currently be tasked to perform this function. The prevailing response was that the Shift Superintendent (as Emergency Director) is responsible for-assuring that the initial dose assessment is done and-that he would appoint someone t'o do it. The unanimous response to the follow-up

, question of....What person would be appointed?....was the Shift Technical Advisor (STA). The inspector noted that this action would appear to burden the STA with too many "immediate" response tasks.

i This will be detailed further in a later discussion of STA respon-sibilities in this report.

I The inspector then inquired as to what person would probably be tasked to perform this function in the future if this responsibility is taken away from the STA. The tentative response was the Sr.nior Health Physics Technician on-shif The inspector questioned as to whether this person has the basic qualifications and experience to fill an emergency response organization position which involves protective action decisionmaking. This will have to be considered

in the final resolution of this area.

Ouring a follow-up meeting held at the PECO corporate office on

March 18, 1986, management representatives stated that the STA will i

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not be tasked with the dose assessment function after the refined dose assessment model is installed and appropriate personnel are l t aine It was not stated, however, who specifically will be tasked with performing this function. The licensee stated that the needed qualifications of this person will be determined after the new dose

, assessment model and its output are evaluated and acceptance tested which is scheduled for the third quarter of this yea >

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b) The licensee has taken exception to the Table B-1 requirement of supplying an additional person within 30 minutes after the start of as accident to provide Core Physics / Thermal Hydraulics calculations an<i consultation. The licensee has stated that the STA on-shift will per form both of these function The acceptability of the STA per-for;ning both of these Table B-1 functions is a matter of discussion bet ween the licensee and NRC/NR ,

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c) The licensee submittal of February 11, 1986 appears to indicate that there are two people on shift to initiate repair and corrective actions following an incident, one representing mechanical mainte-nance and the other representing electrical maintenance. Interviews with site personnel indicated that these functions are performed by one person who has the capability to identify the craft work that would be needed. Although this approach would appear to be a fea-sible alternative. the licensee should clarify what is stated in the submitta d) It is not clear from the submittal whether all of the required on-shift health physics emergency response functions will be met by the staffing proposed in the February 11, 1986 submitta e) In general, the positions noted in the licensee's submittal should be more specifically related to onsite positions so that agreement with Table B-1 requirements can be more clearly evaluate f) The licensee agreed, on March 18, 1986, to follow up on these areas of ambiguity and clarify their minimum staf f position at the PBAP In addition, a drill to evaluate the initial emergency organization using the minimum staffing plan is tentatively scheduled for September 198 Exit The licensee acknowledged near completion of the CAL action items and has scheduled drills for the next two quarters in 198 The licensee also agreed to follow-up on the clarification and implementation of their minimum staffing plan relative to the initial emergency organizatio At no time during the inspection were written materials given to the license .