IR 05000293/1988028

Insp Rept 50-293/88-28 on 880718-21.No Violations Noted. Major Areas Inspected:Changes to Emergency Preparedness Program,Shift Staffing & Augmentation,Knowledge & Performance of Duties & Emergency Detection

ML20151J158
Person / Time
Site:	Pilgrim
Issue date:	07/26/1988
From:	Conklin C, Lazarus W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20151J074	List: IR 05000293/1988028 ML20151J067
References
50-293-88-28, NUDOCS 8808020193
Download: ML20151J158 (5)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /88-09 Docket N i License N DPR-35 Priority Category C Licensee: Boston Edison Company Pil rir.1 Nuclear Power Station r 1, Rocky Hill Road P'1ymouth, Massachusetts 02360 Facility Name: Pilgrim Nuclear Power Station Inspection At: Plymouth, Massachusetts Inspection Conducted: July 18-21, 1988 Inspector: w f C. CDnK116, Senior Emergency

?!A6!N date'

Prepare Mess Specialist, DRSS Approved By: mm

. Pd zarus, Chief, EPf',

>!)4d7 date EP&RPB ORSS

Inspection Summary: Inspection on July 18-21, 1988, (Report No. 50-293/88-28)

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Areas Inspected: A routine announced emer enc reparedness inspection was conducted at the Pilgrim Nuclear Power Statkon.y he inspection areas included: Changes to the Emergency Preparedness Program Sh Augmentation;KnowledgeandPerformanceofDuties(Training)iftStaffingand

and Emergency Detection and Classificatio Results

No violations were identified.

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i 8808020193 880727 PDR l

0 ADOCK 05000293 PDC

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DETAILS

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1.0 Persons Contacted The following licensee representatives attended the exit meeting held on July 21, 198 R. Bird, Senior Vice President, Nuclear  :

K. Highfill, Station Direct 0r B. Lunn, Senior Compliance Engineer R. Varley, Emergency Prepared %ss Manager D. Cillispie Manager Nuclear Training Department B. Gallant, technical, Training Supervisor K. Walker, Project Manager, Emergency Preparedness A. Lee, Onsite Emergency Preparedness Manager J. Spangler, Emergency Preparedness Equipment and Facilities Manager The inspector also interviewed and observed the activities of other licensee personne ,

2.0 Operational Status of the Emergency Preparedness Program 2.1 Changes to the Emergency Preparedness Program There havo been major changes to the licensee emergericy

)reparedness program. The most significant are the newly developed

)arrier based, symptomatic Emergency Actions Levels complete concept of operations revision for emergencypreparedness (EAL's) and a and emergency management. See Section 2.4 for the discussion on EAL' The inspector reviewed EP-AD-100, "Emergency Preparedness Controlled Documents" Revision 0. This procedure provides for the preparation, review, approval and revision of all controlled emergency preparedness document Each document undergoes a detailed review and approval process ending with Operations Review Committee management (ORC), station management and emergency preparedness approval The Emergency Plan has been revised and reformatted. The format is similar to the NUREG 0654, FEMA REP-1 format. The plan has been approved by appropriate station management as well as by the ORC.

Full implementation is scheduled for October 1,1988. The plan is clearly written and adequately covers the concepts of emergency management. The inspector noted that the plan does not describe Technical Support Center (TSC) habitability it is described in the Implementing Procedures). The licensee agree (d to evaluate this are _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ .

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have also been revised and The Implementing reformatte EachProcedures (IP's) d format which includes: a table IP has a standar of contents; purpose; references; definitions; responsibilities; procedure; records; and attachments. Each IP also includes an attachment to identify changes made to satisfy commitment Classification and Response procedures are designed with a checklist format within the body of the procedure. Other major sections include: Emergency Response Facility Opert.tions; Radiological / Accident Assessment; Protective Actions; and Corrective Actions. All IP's are complete and ready for submittal to OR Implementation is scheduled for October 1 198 The IP's areclearlywritten,andprovideadequateinstructIonsforthe emergency staff to assess and respond to emergencie The inspector noted inconsistencies in the Classification and Response procedures regarding actual instructions and notes regarding actions to be taken for both classification and declassificatio The licensee agreed to evaluate this are Based upon the above review, this area is acceptabl .2 Shift Staffing and Augmentation The inspector reviewed the personnel requirements for the Emergency

. The current ERO has at least three Response individualsOrganization (ERO) trained for each key positio identified and Appropriate senior station management personnel have been assigned command and control position A new ERO has been identified to conform with the requirements of the new plan and implementing procedures. Each position has a minimum of three members, with most sositions having four member Training is in progress and the new ERO will be implementeri on October 1, 1988. The ins)ector noted that there is no formal mechanism to address new lires departures and transfers. The l licenseeagreed,andwilldevelopanadministrativeprocedureto I identify when personnel changes affect the ER Based upon the above review, this area is acceptabl .3 Knowledge and Performance of Duties (Training)

The training program was reviewed during inspection 50 293 This review was primarily concerned with the lesson plans and /87 4 associated training conducted and/or being developed to support the l new emergency preparedness program that will be implemented on  !

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lesson plans have been completed for most classes. Lesson plans I have been properly approved for those classes started. Emergency l preparedness overview is essentially complete for the ERO. Other  ;

specialized training has been started including: Emergency Action  !

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Level training; and Dose Assessment training. Training records reviewed were complete and accessible. Each training session provides for validation testing. A mechanism is in place to address test failure The inspector also audited an EAL class. The information presented was in accordance with the applicable procedures. It was presented '

in a clear and concise manner. The instructor communicated very well with the class and was able to effectively answer all question Based upon the above review, this area is acceptabl .4 Emergency Detection and Classification The licensee has developed and implemented barrier based, symptomatic EAL's. These EAL's have been inte current Emergency Operating Procedures (E0P's) grated

. Where with the appropriate, EAL trigger points have been derived from operational curves and data contained in the E0P's. The licensee has quantified indicators and identified specific instruments and equipmen Additionally, the licensee has incorporated those EAL s that are strictly event based. With only minor exceptions, the EAL's are consistent with federal guidance. The licensee has also addressed human factors in the EAL format. Classification is performed from the highest classification to the lowest, giving a greater assurance of proper classification. The licensee is scheduled to incorporate EAL trigger points in appropriate E0P's in early 198 The inspector discussed several areas of concern including:

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addressing proper interface between the Nuclear Watch Supervisor and Shift Security Supervisor for classifying security events;

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provide further clarification and quantification for earthquake EAL's;

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evaluate the site area emergency classification for certain man made events; and

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evaluate the unusual event and alert classification for events due to turbine component failure and turbine casing penetratio The licensee agreed to evaluate these areas. In summary, the inspector noted that the new EAL's are much improved and should greatly assist plant operators in quickly and promptly classifying event Based upon the above review, this area is acceptabl ___

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3.0 Licensee Action on Previous Inspection Findings During the inspection, the inspector reviewed the licensee's progress concerning the items opened during previous inspections (Inspection Reports 50-293/87-54 and 50-293/88-09). The status of these items is as follows:

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(CLOSED) 87-54-01: The initial notification forms do not allow for approval by the Emergency Director, nor do they provide for possible protective actions at a Site Area Emergenc The inspector reviewed the revised initial notification forms and determined that they provide for Enargency Director approval, as well as for protective action Based upon the above review, this area is acceptabl (CLOSED 87-54-02: Several key emergency positions in the organiza) tion do not have sufficient depth to support prolonged operation The licensee has provided trained individuals for each key emergency position. See Section Based upon the above review, this area is acceptabl (CLOSED) 88 09 01: The control room administrative assistant did not correctly follow the initial notification procedur The inspector reviewed the supplemental training given to the Administration Assistants (AA s). The AA's were given hands-on training in the simulator for a variety of condition Additionally, they interfaced directly with controllers playing Commonwealth and/or NRC officials and were required to respond to a variety of question Based upon the above review, this area is acceptabl .0 Exit Meeting The inspector met with the licensee representatives listed in Section 1 of this report at the end of the inspection to discuss the scope and findings of this inspection as detailed in this repor The licensee was informed that no violations were identified. The inspector discussed several areas for improvemen At no time during this inspection did the inspectors provide any written information to the licensee.