IR 05000277/1990012
| ML20043E410 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 06/05/1990 |
| From: | Craig Gordon, Lazarus W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20043E407 | List: |
| References | |
| 50-277-90-12, 50-278-90-12, NUDOCS 9006120402 | |
| Download: ML20043E410 (8) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
F Report Nos. 50-277/90-12 and 50 278/9012
Docket Q&.i0-277 and 50-278 License Nos. DPR-44 and DPR 56 e
Licensee:
Philadelnhia Electric Company Post Office Box 7520 Philade.jphia. Pennsylvania 19101
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Facility Name: Peach Bottom Atomic Power Station. Units 2 & 3 Inspection At: Delta and Wayne. Pennsylvania inspection Conducted: May 1418.1990
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f A ArQD, OL 6frf90 Inspector:
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C."f1(o) don, Emergency Preparedness
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Approved By:
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W. J. Igdafus, Chief, Enfergency date Preparedness Section
Inspection Summary: Inspection on May 14-18.1990 (Combined insocction Reoort
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Nos. 50 277/9012 and 50-278/9012)
l Areas inspected: Routine, announced safety inspection of the emergency preparedness (EP) program includirg review of previously identified inspection findings, changes to the emergency preparedness program, review of organization and management control, l
inspection of indepemient program audits, and inspection of emergency response
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Results: The Emergency Plan, Emergency Response Procedures (ERP), and the
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emergency planning program are being implemented in a manner to adequately protect
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public health and safety.
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DETAILS 1.0 Persons Contacted
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H. R. Abendroth, Atlantic Electric
C. L Adams, Director, Emergency Preparedness R. K. Bernhardt, EP Training Instructor G. F. Daebeler, Support Manager J. K. Davenport, Superintendent, Administration
R. L Deck, Schnieder Engineers A. D. Dycus, Superintendent, ISEG
W. M. Eckman, Auditor
E. P. Fogarty, Manager, Nuclear Support
J. F. Franz, Plant Manager
R. R. Gallagher, Site Emergency Preparedness Supervisor
N. E. Gazda, Supervisor, Nuclear Services Training
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D. P. Honan, Engineer / EOF Project Manager R. Z. Kinard, Branch Lead, Corporate EP G. P. Lengyel, Maintenance Engineer
S. P. Maingi, Engineer, Pa. Bureau of Radiation Protection S. R. Mannix, Shift Manager T. M. Neissen, Shift Manager M. J. Roache, Branch Lead, Corporate EP
R. N. Smith, Licensing Engineer
i Denotes attendance at exit meeting
r 2.0. Licensee Actions on Previously identified items in 1988 and 1989 the NRC identified several concerns associated with the licensee's ability to effectively administer the site Emergency Preparedness (EP)
programs for Peach Bottom and Limerick from the corporate office. To address these concerns, changes were made in the licensee's organization and management control system. An Action Plan was developed by the corporate EP staff that identified certain objectives which were determined necessary to provide stronger guidance to nli licensee personnel involved in program maintenance and implementation. Included among these objectives are EP program definition, methodology to qualify and maintain Emergency Response Organization (ERO) staff, a selection process for ERO positions, and improvements in tracking program deficiencies identified for correction.
In order to complete and implement each objective, a specific course of action has been planned. A series of Nuclear Group Administrative Procedures
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(NGAP) were identified which formally describe different policies which licensee l
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personne! are to follow when carrying out EP program activities. Specific NGAPs have been prepared for the following functional areas:
L Emergency Plan and Implementing Procedure reviews; 2. Tracking and rnanagement of open items; 3. ERO training and qualification;_
4. Maintenance of emergency response facilities; i
5. Scheduling and evaluation of drills and exercises; and
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6. Offsite EP program support.
- The inspector reviewed and discussed the schedule for completing the Action
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Plan with the Director, EP. It was found that the licensee has made substantial progress in upgrading the overall program and that Action Plan goals were on schedule. In addition, a PECo directive (also a NGAP) was drafted which will establish a formal company policy to assure that all personnel must support response activities at Peach Bottom and Limerick. Each NGAP requires internal review by Nuclear Group personnel and separate approvals by four vice-presidents prior to issuarice. Expedited approvals for NGAPs, particularly those which provide instructions for routine activities such as assignment of responsibilities for EP staff, tracking of open items, and selection and qualification of individuals for the ERO, would further enhance program implementation.
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Operational Status of the Emergency Preparedness Program l
3.1 Changes to the Emergency Preparedness Program
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The inspector reviewed the changes to the licensee's emergency plan and i
l implementing procedures. Changes that were made received proper review and approval prior to implementation. Section 6.4 of the Plan, i
Notification, was revised to allow follow up rather than immediate notifications to the NRC (and other PECo staff) after classification of an emergency. It appears that the licensee's intent was to improve efficiency in 15 minute notifications to state and local authorities. However, follow-up notifications to the NRC are acceptable only to the extent that the immediate notification requirements of 10 CFR 50.72 (a) continue to be met. Clarification on this revision should be provided.
A recent change was made to the on-shift staff. The junior technical assistant, who was responsible for performing dose assessment in the control room, was replaced by an additional on shift health physics technician. Relevant training was provided and health physics technicians
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- were qualified to implement dose assessment functions. Although emergency response capability was not reduced, it was unclear whether the licensee performed a formal review of this change to meet 10 CFR l
50.54 (q). The licensee's procedures for performing 50.54(q) reviews will be evaluated during the next scheduled inspection.
Based upon the above review, this area is acceptable.
3.2 Emergency Facilities. Equipment. Instrumentation. and Supplies Emergency Response Facilities (ERF) are designed to meet the requirements of 10 CFR 50.47(b)(E) and (9),Section IV of 10 CFR 50, Appendix E, NUREG-0737, Supplement 1, and Reg. Guide 1.97.
Equipment, status boards, communications systems, plans, procedures, habitability and access control provisions were checked in the control room, Technical Support Center (TSC), Operations Support Center (OSC), and Emergency Operations Facility (EOF). Status boards, maps, facility diagrams, plans, procedures, drawings, and equipment were in place and maintained, equipment was in calibration, tmd communication equipment operative in all ERFs. Special EP surveillance tests are used to perform inventories of radiation survey kits and supplies. Designated computers used to calculate projected doses to the environment were available and operable.
A meeting was held with the Director, EP and the licensee's Project Manager to discuss upcoming plans fer the proposed joint EOF / Emergency News Center for LhvAk and Peach Bottom. After the u
NRC approved the facility m March 690, the licensee developed project L
and contracting strategies, cost considerations, imd a schedule of design and construction phases. Expected time to complete the facility is
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between 12 and 18 months. The Director, EP indicated that he would l
keep NRC apprised of progress on the project.
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Based upon the above review, this area is acceptable.
l 3.3 Organization and Management Control The Director, EP is assigned overall responsibility to ensure the L
emergency preparedness program is properly implemented. Regular meetings are held between the Director and senior licensee corporate l
l management to review and update program status. Information covered l
includes current program activities and a report of action items issued, open, and closed each month for the corporate office and Peach Bottom
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'j site. Review of the action item list showed that open items were receiving appropriate attention and only a few lower priority items were
overdue.
At Peach Bottom, the Site Emergency Preparedness Supervisor carries out administrative EP functions and frequently attends site management j
meetings. Interface between the site and corporate EP staffs was found l
to be much improved due to changes in the corporate EP organizational structure. Individual branch lead positions which oversee site activities J
were established for both Peach Bottom and Limerick. Additional full time positions were authorized at the corporate office (4 positions) and at
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the site (2 positions). Top EP staff positions have been filled and active-
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recruiting is underway to fill newly authorized vacancies.
- The Emergency Response Organization (ERO) is adequately described in the Emergency Plan. Key positions are staffed four deep and personnel i
have consistently demonstrated effective response during exercises.
The inspector determined that br. sic responsibilities to mana;,e the EP program have been adequately implemented since the last inspection.
Such responsibilities include maintenance of the Emergency Plan, implementing procedures, emergency response facilities and designated equipment, development of exercise scenarios, training of on site ERO and State / local responders, and cooperation with off site support groups.
Based upon the above review, this area is acceptable, i
3.4 Knowledge and Performance of Duties Table 8.1 of the Emergency Plan provides an outline of initial training, and annual retraining, for each function within the ERO. Included are training requirements for Emergency Directors, emergency response facility directors, and team members for technical support, dose assessment, radiation surveys, damage control, fire safety, chemistry, security, and recovery. In February 1990, an EP Training Program Plan was issued to formally provide specific objectives, responsibilities, training methods, and evaluation criteria to implement the training program.
Discussions were held with the Training Supervisor and EP training instructor who provided training lesson plans, examination materials, examination results, and attendance records of response training for site personnel. In addition, the program plan used to perform off site training was discussed with licensee corporate staff and contractor representatives.
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Training provided to key response personnel by the training department
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includes both classroom and practical exercises in emergency classification,
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protective action recommendations (PAR), technical support, on site /off-site surveys, chemistry sampling, dose assessment, and communications.
Since the last inspection, the licensee has emphasized the value of
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practical and walk through training. Upgraded qualification criteria for ERO functions now require all personnel to demonstrate response ability during requalification and periodically perform in annual exercises.
Review of training lesson plans (LP) and test materials revealed that
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information was not current and that LP documents have not been revised since 1986. References were made to deleted positions within the ERO, as well as outdated ERPs. As a result, it does not appear that lesson plans are beneficial in helping instructors give classroom and practical instruction. Lesson plans for each course instruction should be revised to reflect up to date organizational elements and procedures. Examination questions which directly relate to any changes made to lesson plans should also be revised.
Training of off site support groups is provided via contractor support.
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Periodic status reports on types of training given and number of attendees are provided to EP corporate staff. Information covered includes general overviews concerning radioactive materials, radiological monitoring, and decontamination. Records of training were thorough and complete.
In order to verify the effectiveness of training, the inspector l'nterviewed Unit 2 and Unit 3 shift personnel. Shift Managers, who serve as l
Emergency Directors (ED) during emergencies, have received classroom l
and practical training (either in EP training or through operator requalification) within the past year and are qualified EDs.
Demonstrations were required in direction and control, emergency classification, notification and communication, and protective action recommendations. Shift Managers interviewed appeared knowledgeable
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i and familiar with their assigned emergency duties and responsibilities.
I Walk through exercises were condected to test the ability of on shift personnel to perform radiological assessment in the control room. The I
scenario involved General Emergency conditions with a fission product
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release through the reactor building roof vent. The shift manager and health physics technician performed manual and computer assisted dose
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I assessments and used ERP-317, Determination Of Protective Action
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Recommendations, to formulate PARS.
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After calculations were completed using each method, PARS were compared. Difficulty was observed on the part of the shift manager in arriving at a consistent PAR when comparing computer results with guidance given in ERP 317, Attachment 4, Protective Action Guide. One
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method gave a recommendation to shelter and one method gave a recommendation to evacuate, and both methods used the same conditions.
Dose assessment methodologies of ERP 317 should be reviewed to ensure
that PARS can be easily determined and that results are consistent when both methods are used. This item is unresolved (50 277/9012-01 and 50-278/90 12 01).
Training records are maintained via computer database for site personnel.
To determine when response training for any member of the ERO was taken or when requalification is due, periodic review of computer files is
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necessary. Reminder letters are sent to ERO members indicating expiration of train!ng and that requalification is needed. The inspector reviewed the computer system to track training records and found that the system was adequately implemented.
Except as noted above, this area is acceptable.
3.5 Independent Reviews / Audits The quality assurance review of the EP program was conducted by an independent team in November and December 1989. The report, issued on January 30,1990, was a change from previous assessments in that it l-covered separate reviews of the corporate, Peach Bottom, and Limerick
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programs. The audit was performed by a contractot under the direction of a senior member of the Nuclear Quality Assurance (NOA)
l Department. A checklist from the NQA audit plan is used as guidance i
for each area examined. The inspector reviewed the results of the audit c
report and discussed audit preparation and findings with the lead auditor.
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r The audit covered basic EP program functions such as the Emergency L
Plan and implementing procedures, ERO training, inventory maintenance, i:
interface with State and local agencies, and drills and exercises. A corrective action system is in place to resolve findings identified in the audit report. Audit results are categorized as corrective action requests (CAR) or recommendations. CARS relate to pctential problem areas of the program and are issued by NQA to the Director, EP for resolution.
Response time to address a CAR is 30 days. Following the response by EP program staff, auditors evaluate and confirm commitments for
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g corrective action.
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Results of the audit indicated that activities of the EP program have
shown continued improvement in several program areas over the past few years. Strengths were noted in the areas of emergency response procedure (ERP) quality, resolving and reducing the number of oper.
items, and interface with off site support groups.
The audit identified several problem areas which resulted in CARS and recommendations to EP staff. Significant items included training i
deficiencies, inadequate Emergency Plan and ERP distribution, and program administration deficiencies (now included in the EP Action Plant EP staff are currently addressing these items.
q One previous audit finding was noted in which licensee staff has not taken
appropriate corrective action and relates to the failure to effectively
implement the Corporate Communication ERO. The review identified unqualified company spokespersons, inadequate notification procedures for corporate communications staff, a lack of interface with offsite media personnel, and an informal management system to ensure that the corporate communications program is maintained. A management corrective action request (MCAR), which identifies issues adverse to quality requiring a higher level of management attention, was issued to the Senior Vice President, Corporate and Public Affairs. Response to this MCAR describing corrective actions to be taken was accepted by NOA.
EP staff are working together with corporate communications personnel to resolve items.
Distribution of the audit report was extensive and included senior managers at the site and corporate offices.
Based upon the above review, this area is acceptable.
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4.0 Exit Meeting The inspector met with the licensee personnel denoted in Section 1 at the conclusion of the inspection to discuss the findings as presented in this report.
.The inspector also discussed some areas for improvement. The licensee acknowledged the findings and agreed to evaluate them and institute corrective actions as appropriate.
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