IR 05000293/1990008
| ML20034B746 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 04/11/1990 |
| From: | Conklin C, Lazarus W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20034B743 | List: |
| References | |
| 50-293-90-08, 50-293-90-8, NUDOCS 9004300289 | |
| Download: ML20034B746 (9) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No:
50 293/90-08 Docket No:
f.0-1993
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License No:-
DPR 35 Licensee:
Boston Edison Company
RFD #1 Rocky Hill Road Plymouth._ Massachusetts 023,60.
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Facility Name:
Pilgrim Nuclear Power Statical Inspection At:
Plymouth. Massachusetts inspection Conducted:
March 26 29.1990 Inspector:
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ethig'Cojt liii, Senior Emergency date Preparedness Specialist, Division of Radiation Safety and Safeguards Approved By:
kbkw b A d tt.Iq90 William Lazants?Cliief, Emergency date '
Preparedness Section, Division of
Radiation Safety and Safeguards
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insoection Summary: Inspection on March 26-29.1990. (Report No. 50 293/90-081 Areas inspected: A routine, announced emergency preparedness inspection was conducted at the Pilgrim Nuclear 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 / Audits.
Results: No violations were identified.
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DETAILS 1.0 Persons Contacted The following licensee representatives attended the exit meeting held on March 29,1990.
R. Bird, Senior Vice President, Nuclear R. Varley, Emergency Preparedness Manager S. Hook, Onsite Emergency Preparedness Section Manager D. Landahl, Onsite Emergency Preparedness Division Manager R. Markovich, Offsite Emergency Preparedness Division Manager J. Spangler, Facilities and Equipment Division Manager J. Morlino, Emergency Preparedness Drill and Exercise Coordinator B. Gallant, Training Supervisor C. Ful:er Miles, Nuclear Training Specialist R. Jickling, Nuclear Training Specialist S. Bibo, Audit Division Manager The inspector also interviewed and observed the activities of other licensee personnel.
2.0 Operational Status of the Emergency Preparedness Program 2.1 Changes to the Emergency Preoaredness ProgrRm There have been no major changes since the last inspection. Those changes that were made all received proper management review and approval by the Operations Reviews Committee prior to implementation.
The licensee revised IP-400, " Protective Action Recommendations". This revision resolves NRC concern regarding Protective Action Recommendations (PARS) as it ensures the user properly assesses plant conditions in determining the accompanying PAR. The licensee revised IP 210, 'TSC Activation and Response". This revision resolves NRC concern regarding operability verification of the Technical Support Center ventilation system.
The inspector reviewed the Emergency Preparedness Activity Scheduling System and the Recurring Activities Tracking System. These systems are
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computerized and networked to ensure availability to all staff. Both management and staff utilize these systems to schedule, track and-document activities. The inspector noted that all scheduled activities are accomplished in a timely manner, are properly documented and reviewed.
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The licensee has developed administrative procedure AD-103, " Validation, i
Verification and Documentation of Emergency Preparedness Computer
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Codes". This procedure defines the technical basis, program limitations, t
user guides, program logic, source codes and verification calculations for
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each program. Programs validated include: DAMAGE (Core Damage);
SAMPLE (Field Sampling); PAR (Protective Action Recommendations);
and EDAP (Dose Assessment). The inspector noted that this methodology is utilized on all new programs as well as on revisions to i
existing programs.
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In response to Information Notice (IN) 90-08, KR 85 Hazards from
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Decayed Fuel, the licensee conducted a detailed review of this document
and determined that existing procedures adequately addressed this IN.
Based upon the above review, this area is acceptable.
l 2.2 Emergency Facilities. Equipment. Instrumentation and Supplies
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The inspector toured the Technical Support Center (TSC), Operations.
Support Center (OSC) and Emergency Operations Facility (EOF). These
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facilities are adequate to support emergency response and are in
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agreement with the Emergency Plan and Implementing Procedures.
Checks of equipment and supplies revealed that the equipment is regularly inventoried, instrumentation is calibrated as required, and equipment and instruments were operable. The licensee has developed an administrative procedure, EP AD 301, " Emergency Preparedness
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Department Facilities and Equipment Surveillance". This procedure, scheduled for implementation on April 1,1990, will require bi weekly walkdowns of the Emergency Response Facilities (ERFs), monthly vehicle
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checks, and quarterly equipment inventories. The inspector noted that the Safety Parameters Display System (SPDS) is installed in both the TSC
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and EOF, The SPDS is operational, however it is still in acceptance testing. SPDS is scheduled for acceptance and implementation by December 31, 1990.
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The licensee has recently obtained four, dedicated four wheel drive vehicles for field monitoring use. Each vehicle is equipped with a field
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team monitoring radio, a 200 ampere inverter, light bar, spot light, and winch. Cellular telephones have been ordered to provide a backup to the radio. These vehicles are checked monthly. Additionally, the Duty Emergency Offsite Manager is assigned a different vehicle each week to
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help ensure vehicle availability.
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Based upon the above review, this area is acceptable, l
2.3 Organization and Management Control 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. The liceni.ee has 17 of 18 permanent staff position filled and is actively working to fill the remaining vacancy.
Consultant support is still being utilized, particularly in the Offsite section.
Major responsibilities and authorities for implert.enting and maintaining the program are clearly defined in the emergency plan and two volumes of administrative procedures. The licensee has continued to develop administrative procedures to ensure the program is maintained efficiently and timely.
The Emergency Response Organization (ERO) is adequateiv described in the emergency plan. All positions are staffed three or four deep. In order to help maintain the ERO current, the licensee is infoimed of personnel termination actions by an Employment Transfer Memo. This allows immediate updating of the Computerized Automated Notification System.
Based upon the above review, this area is acceptable.
2.4 Knowledge and Performance of Duties (Training)
The PMPS Training Manual, Section 5.5, delineates the training requirements for both initial and requalification training. The licensee maintains an annual training cycle. Lesson plans were reviewed and found to be current and properly reviewed and approved. A formal
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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 current.
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The licensee has developed a Monthly ERO Training Matrix report. This
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i report lists each ERO position, the individuals assigned to that position, and their qualification status, including training dates. This report is l
distributed monthly to managers to help ensure personnel attend
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scheduled training. Personnel who do not attend required retraining, or i'
fail training, are removed from the ERO. Additionally, site access is removed for those individuals who do not attend their required ERO l
training. The licensee has also implemented special controls to ensure
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that individuals who receive training in the licensed operator program do not miss their emergency preparedness training.
The inspector reviewed procedures P.12, " Student and Training Program j
Evaluntion" and T.19, " Examination Administration Standard". These procedures set the policy to follow if an indMdual fails a test. Essentially, i
the individual is given a recovery period, which may include remedial
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work or retraining, and administered another test. Although the licensee's informal policy is to retrain and retest immediately, the inspector noted one instance where an individual failed the test and was not retrained and-
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retested until two weeks later. This individual was not removed from the
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ERO during this period. The licensee agreed to evaluate their methodology regarding retraining and retests.
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Based upon the above review, this area is acceptable.
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2.5 Independent Reviews /Audlhi i
The independent audit was conducted on August 15 to September 15, l
1989. 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
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I critical and carne to proper conclusions regarding the findings.
Distribution of the audit report was extensive and included senior managers and the Nuclear Safety P.eview Audit Committee. The audit properly included a detailed review of the licensee /offsite interfaces and the results of the interface review were shared with the Commonwealth of Massachusetts and the local communities.
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The inspector also reviewed the licensee's drill and exercise program.
The licensee maintains a rolling six year plan for exercise objectives, as
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well as an annual plan for drill cbjectives. The licensee performed 11 drills and exercises during 1989. These drills included major elements such as staffing and augmentation, notification, and several integrated drills. These drills exceeded the specified required drills in the a
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Emergency Plan. ' All drills were well planned, properly approved and documented. The inspector noted that some documentation was incomplete regarding checklists and approving / reviewing signatures, and one report was not issued until three months after the completion of the
drill. The licensee agreed to ensure all documentation is properly
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completed and to evaluate timeliness of the drill reports. Corrective actions were evident as well as management involvement in the conduct of these drills and in corrective actions.
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l Communications tests were also conducted in accordance with the
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Emergency Plan and Implementing Procedures. The inspector was able to determine that all tests were properly conducted. However, the
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documentation, particularly regarding corrective actions and follow up
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retests, were not formally documented. The licensee agreed to evaluate and fully document needed corrective actions and retests. The inspector
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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. This is a repeat issue noted
in Inspection Report IR 50-293/89-09. The licensee has revised the communication drill procedure to allow for verification receipt of a facsimile message, but the inspector determined this test message did not meet the intent of message content verification. The licensee agreed and will revise this aspect of the communications tests.
Based upon the above review, this area is acceptable.
2.6 Emergency Action Levels (EALs)
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The licensee has developed and implemented _ barrier based, symptomatic
l EALs. Inspection Report IR 50-293/88 28 documented a review of these new EAI.s and discussed several areas of concern. The licensee addressed these concerns and the EALs were subsequently reviewed by an NRC contractor. Specific details of the contractor EAL review are as
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Review Summarv
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The Pilgrim Nuclear Power Station classification system closely adhered to regulatory requirements and the guidance of NUREG-0654. The EALs
and the Emergency Action Level Technical Basis Document amplified on '
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the NUREG 0654 initiating conditions and provided concise plant specific information on which to base emergency classifications. The licensee's
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approach provided coverage of both symptomatic conditions and events
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which could not be treated on a symptomatic basis. The Emergency Action level Technical Basis Document included a cross reference section between NUREG 0654 cxample initiating conditions and Pilgrim Station
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EALs. The Emergency Action 12 vel Technical Basis Document also included detailed definitions of key phrases used in the EALs that would y
be critical to the classification process. The technical basis for each EAL was cross referenced to the applicable Technical Specification Paragraph.
The approach to the development of the EALs appeared to parallel the
BWR owners group approach to the Emergency Operating Procedures.
i As a result, there appears to be more integration of the EALs with plant
operating procedures. Few discrepancies or questions were noted during
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Evaluation Criteria i
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Evaluation of the licensee's EAL classification scheme was based upon 10 CFR 50 requirements and NUREG 0654 guidance as follows:
1, 10 CFR 50.47(a)(4) requires that "A standard emergency T
classification and action level scheme, the basis of which includes facility system effluent parameters, is in use by the nuclear facility
licensee, and State and local response plans call for reliance on t
information provided by facility licensee for determination of minimum initial offsite response measures."
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10 CFR 50, Appendix E.IV.B requires in part that, "The means to be used for determining the magnitude of and for continually
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assessing the impact of the release of radioactive materials shall be o
described, including emergency action levels that are to be used as
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criteria for determining the need for notification and participation
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of local and State agencies...." It further requires in this part that
"The emergency action levels shall be based on in plant conditions and instrumentation in addition to onsite and offsite monitoring."
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3, 10 CFR 50, Appendix E.IV.C requires in part that, " Emergency action levels (based not only on onsite and offsite radiation
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monitoring information but also on readings from a number of
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sensors that indicate a potential emergency, such as the pressure in containment and the response of the Emergency Core Cooling System) for notification of offsite agencies shall be described."
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NUREG 0654 Planning Standard, Section D.1 states that "An Emergency Classification and Emergency Action Level scheme as set forth in appendix 1 must be established by the licensee. The specific instruments, parameters, or equipment status shall be shown for establishing each emergency class, in the in plant emergency procedures. The plan shall identify the parameter values and equipment status for each emergency class."
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NUREG 0654 Planning Standard, Section D.1 states that "The initiating conditions shall include the example conditions found in Appendix 1 and all postulated accidents in the Final Safety Analysis Report (FSAR) for the nuclear facility."
General Methodolocv The emergency classification procedure provided eight general categories of emergencies. Five of the EAL categories are symptomatic and are based upon the status of fission p:oduct barriers, degrading plant
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conditions and personnel safety These five categories include Reactor
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Fuel, Reactor Plessure Vessel, Primary Containment, Secondary Containment and Radioactive Release. Two event based categories include Internal Events and External Events. Internal events relate to -
abnormal or emergency events associated with plant systems. External events relate to abnormal or emergency conditions which affect or may affect plant systems. The last category entitled Other provides the Emergency Director the latitude to classify and declare emergencies based upon his judgement of plant conditions. The EALs are backed by the-Emergency Action Level Technical Basis Document that provides background and interpretation info'rmation. Each EAL is uniquely identified with a four-part number indicating category, parameter within the category, number of the EAL for the Parameter, and the classification level.
Detailed Review Comments The following comments are provided in the order of the Example Initiating Conditions of Appendix 1, NUREG-0654, with the number and a short descriptive phrase from NUREG-0654 provided first. Absence of any comment indicates that the EAL was acceptable.
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Notification of Unusual Event (NOUE #14.a) Aircraft crash on-site or unusual aircraft activity over facility, i
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The licensee EAL for this condition was EAL 7.3.1.1, External Events. This EAL included an aircraft crash on site but did not i
include unusual aircraft activity over the facility and should be reviewed, f
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(NOUE #14.b) Near or onsite explosion.
l The licensee EAL for this condition was EAL 7.3.1.1, External Events. This EAL did not address a near site explosion and should be reviewed.
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(NOUE #14.c) Near or onsite toxic or flammable as release.
The licensee EAL for this condition was EAL 7.3.1.1, External Events. This EAL did not address a near site toxic or flammable gas release and should be reviewed.
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(Site Area Emergency #9) Transient requiring operation of shutdown systems with failure to scram (continued power generation but no core damage immediately evident).
The licensee EAL for this condition states, " Boron injection into the RPV intentionally initiated (boron injection required) with either:
Standby Liquid Control (SBLC); or One or more of the methods detailed in Procedure 5.3.20 Alternate Borate Injection."
The licensee EAL and the NUREG 0654 example initiating condition are not equivalent in terms of anticipatory response to indicated plant conditions. The licensee EAL is based upon a combination of procedural requirements and plant conditions. The example initiating condition is based upon anticipated protective functions that did not work. - This EAL should be reviewed for consistency to the example initiating condition.
3.0 Exit Meeting The inspector met with licensee personnel denoted in Section 1 at the conclusion-l of the inspection to discuss the scope and findings of this inspection as detailed in this report.
The licensee was informed that no violations were identified. Several areas of improvement were discussed. The licensee acknowledged these findings and agreed to evaluate them and institute corrective actions as appropriate.