IR 05000293/1989009

Insp Rept 50-293/89-09 on 890619-22.No Violations Noted. Major Areas Inspected:Changes to Emergency Preparedness Program,Emergency Facilities,Equipment,Instrumentation & Supplies,Organization & Mgt Control

ML20246N400
Person / Time
Site:	Pilgrim
Issue date:	07/06/1989
From:	Conklin C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20246N398	List: IR 05000293/1989009 ML20246N392
References
50-293-89-09, 50-293-89-9, NUDOCS 8907190364
Download: ML20246N400 (5)

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"U. S. NUCLEAR REGULATORY COMMISSION

REGION I

e Report'No: '50-293/89-09 Docket No: 59-L91

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License No: DPR-35 Priority Category [

Licensee: Boston Edison Company RFD #1 Rocky Hill Roa Elypouth, Massachusetts 02360 Facility Name: Pilarim Nuclear Power Station Inspection At: Plymouth. Massachusetts

- Inspection Conducted: June 19-22. 1989 Inspector: -]kf97 Craig Conk'lin, Senior Emergency 'date Preparedness Specialist, DRSS Approved By: Cae h [c7 WilDani LacD us, Chief, Emergency cate Preparedness Section, FRSSB, DRSS Inspection Summarvi Jn.soection on June 19-22. 1989. (Report No. 50-293/89-09)

Areas Inspected: A routine, announced emergency preparedness inspection was conducted at the Pilgrim k: clear Power Station. The inspection areas included: Changes to the Emergency Preparedness Program; Emergency

' Facilities ~, Equipment. Instrumentation, and Supplies; Organization and Management Control; Knowledge and Performance of Duties (Training); and Independent Reviews / Audit Results: No violations were identifie l; PDR ADOCK 05000293 Q PDC

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DETAILS Persons Contacted The following licensee representatives attended the exit meeting held on June 18, 198 R. Varley, Emergency Preparedness Manager S. Hook, Onsite Emergency Preparedness Section Manager P. Cormier, Training Supervisor D. Landahl, Onsite Emergency Preparedness Manager J. McClellan, Quality Assurance The inspector also interviewed and observed the activities of other licensee personne .0 Operational Status of the Emeraency Preparedness Proaram , Chances to the Emeraency Preparedness Program There have been no major changes since the revised Emergency Plan and Implementing Procedures were implemented in October, 198 Those changes were made to further enhance or streamline emergency operations. All changes received proper management review and approval by the Operations Reviews Committee prior to implementatio The inspector reviewed IP-400, " Protective Action Recommendations", and noted that the procedure has an automatic action that provides for a Protective Action Recommendation (PAR)

to shelter when a General Emergency is declared. This PAR may be issued without reference to Attachment 1, the flow chart for determining PARS. This is inappropriate as it ignores potential plant conditions. The licensee agreed and will revise IP-400 accordingly. This area will be reviewed during a subsequent inspectio Based upon the above review, this area is acceptabl .2 Emeraency Facilities. Eauipment. Instrumentation and Supplies The inspector toured the Technical Support Center (TSC),

Operations Support Center (OSC) and Emergency Operations facility (E0F). These facilities are adequate to support emergency response and are in agreement with the Emergency Plan and Implementing Procedures. Checks of equipment and supplies revealed that the equipment is regularly inventoried, instrumentation is calibrab.d as required, and equipment and instruments were operable. The licensee is currently developing an administrative procedure, EP-AD-300, " Emergency Response Facilities and Equipment". This procedure will require weekly

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walk-downs of the Emergency Response Facilities (ERFs), as well as inventories of equipment when used, found disturbed, or on a quarterly basi The inspector also reviewed the TSC ventilation system in place to meet the NUREG 0737, Supp. I habitability commitments. The system was placed in operation in accordance with EP-IP-220, "TSC Activation and Response. The system started up as intended and the inspector was able to verify correct operation. The procedure does not include a step to verify that the ventilation system is operating correctly when it is started up. The licensee agreed to revise EP-IP-400 to include this verification step. The inspector

, also noted that the TSC/0SC complex is now a dedicated facility totally M er emergency preparedness control. This area will be reviewed in a subsequent inspectio Based upon the above review, this area is acceptabl .3 Organization and Manaaement Control

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The inspector reviewed the normal staffing organization as it pertains to emergency preparedness and noted that no major changes have taken place. The Emergency Preparedness Manager reports to  !

the Senior Vice President - Nuclear. The emergency preparedness staff are divided into an Onsite and Offsite section. All positions in the staffing organization, both supervisory and staff, are currently filled by permanent staff. Additional consultant support is still being utilized, particularly in the Offsite sectio The Emergency Plan, Section P, very clearly delineates the major j responsibilities and authorities for implementing and maintaining the program, including: revisions; distribution; supporting plans -

and procedures; cross reference criteria; audits; and maintenance of the emergency telephone director In addition to the above, the licensee has developed and maintains a volume of administrative procedures which delineate the specific requirements for program maintenance. These procedures include documents for: preparation, review and control of the Emergency Plan and Implementing Procedures; emergency preparedness organization and responsibilities; corrective action systems; records retention; scheduling and conduct of the drill and exercise program; equipment testing and maintenance; and ,

management of the on-call organization. These procedures are very 1 clear and thoroug The Emergency Response Organization (ERO) is adequate'ly described in the emergency plan. All positions are staffed three deep, with a corporate goal of four deep. The inspector noted that staff has been identifiec and training is progressing to make most positions ,

four deep. The ERO is notified by a Computerized Automated l

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l informs responders' of off normal conditions, makes individual I calls to response personnel and maintains a' list of the current l ERO including estimated response time The inspector reviewed Nuclear Organization Procedure N0P-88A4,

" Assignment of Responsibilities in Support of the PNPS Emergency l

Preparedness Program". . This procedure requires station managers L to provide. qualified individuals for the ERO, as well as maintain a procedural mechanism to meet this requirement. Additionally, this procedure tasks individuals to inform Emergency Preparedness ;

I t when they will not be available for duty rotation. The inspector noted that this program enables the Emergency Preparedness Section to ensure that the ERO is kept current and availabl Based upon the above review, this area is acceptabl .4 Knowledae and Performance of Duties (Trainino)

The PNPS Training Manual, Section 5.5, delineates the training requirements for both initial and requalification trainin The licensee maintains an annual training cycle. Lesson plans were reviewed and found to be current and properly reviewed and approved. A formal mechanism is in place to ensure that the Emergency Preparedness Section is aware of and reviews significant changes to the lesson plans. Training records are kept on a computerized database system. This' system was very easy to use and all records were immediately accessible. Additionally, the licensee maintains a hard copy qualification card for each individual in the ERO. These records include tests and test results and were also immediately accessible. The inspector reviewed selected training records against the current Emergency Telephone Directory and determined that training for the ERO was curren In order to determine the effectiveness of training, the inspector conducted a series of walk-throughs. These walk-throughs were held with two shifts, each shift including a Nuclear Watch Engineer (NWE), Nuclear Operations Supervisor (NOS), Shift Technical Advisor, an Emergency Director (ED), and an Off-site Radiological Supervisor. The scenarios included events resulting in an off-site release and a fast breaking event resulting in a declaration of a General Emergency. Classifications were timely and correct. Associated PARS were timely and in accordance with the ifcplementing procedures. The inspector noted that the NWE and NOS personnel do not receive the same training as the ED nor any dose assessment or PAR training. Although the inspector did not observe any difficulties, it is not apparent that consistency in performance can be maintained. The licensee agreed, and will revise their training program to ensure that NWE and NOS personnel receive ED training. This area will be reviewed in a subsequent ;

inspectio J

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Based upon the above review, this area is acceptabl .5 Independent Reviews / Audits The independent audit was conducted on October 17 to November 8, 1988. The audit was performed by the Quality Assurance department and utilized a consultant for technical expertise in emergency ;

preparedness. The checklist utilized was very detailed and thorough. The audit was critical and came to proper conclusions regarding the findings. Distribution of the audit report was extensive and included senior managers and the Nuclear Review Boar The inspector also reviewed the licensee's drill and exercise i program. The licensee maintains a rolling six year plan for exercise objectives, as well as an annual plan for drill objectives. The licensee performed 17 drills and exercises during 1988. These drills included major elements such as staffing and augmentation, notification, evacuation and accountability, Post i Accident Sampling, and several integrated drills. These drills far exceeded the specified required drills in the Emergency Pla All drills were well planned, properly approved and documente Co rective actions were evident as well as management involvement in the conduct of these drills and in corrective action Communications tests were also conducted in accordance with the Emergency Plan and Implementing Procedures. The inspector noted that the communications tests conducted do not fully meet the intent of communications drills for transmitting information and for verification of the content of the information. The licensee agreed and will revise this aspect of the communications test This area will be reviewed in a subsequent inspectio Based upon the above review, this area is acceptabl .0 Exit Meetina ,

The inspector met with licensee personnel denoted in Section 1 at the conclusion of the inspection to discuss the scope and findings of this inspection as detailed in this repor The licensee was infortned that no violations were identifie Several areas of improvement were discussed. The licensee acknowledged these findings and agreed to evaluate 'them and institute corrective actions as appropriat At no time during this inspection did the inspector provide any written information to the licensee.

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