IR 05000335/1996018
| ML17309A862 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 11/26/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17229A150 | List: |
| References | |
| 50-335-96-18, 50-389-96-18, GL-93-07, GL-93-7, NUDOCS 9612060240 | |
| Download: ML17309A862 (22) | |
Text
ei U.S. NUCLEAR REGULATORY COMMISSION
REGION II
Docket Nos.:
License Nos:
50-335, 50-389 DPR-67, NPF-16 Report No:
50-335/96-18, 50-389/96-18 Licensee:
Florida Power and Light Company Facility:
St. Lucie Plant, Units 1 and 2 Location:
Dates:
9250 West Flagler Street Miami, FL 33102 October 7-18 and October 28-November 1, 1996 Inspectors:
James L. Kreh, Radiation Specialist Daniel M. Barss, Emergency Preparedness Specialist Approved by:
Albert F. Gibson, Director Division of Reactor Safety 96i2060240 96ii26 PDR ADOCK 05000335
PDR Enclosure
EXECUTIVE SUMMARY St. Lucie Plant, Units 1 and 2 NRC Inspection Report Nos. 50-335/96-18, 50-389/96-18 The purpose of this special inspection was to review and evaluate the onsite emergency preparedness (EP) program.
Significant negative findings were identified, including three apparent violations, one apparent deviation, one Unresolved Item, and one EP Program Weakness.
A arent Violations During the approximate period July 22-October 3, 1996, the licensee failed to maintain the capability to execute the provisions of the Radiological Emergency Plan (REP) and the associated Emergency Plan Implementing Procedures (EPIPs) in a timely manner with respect to mobilization of the Emergency Response Organization (ERO) during off-hours (Section P2.1).
The EPIPs did not adequately implement the requirements of the REP in the following respects:
(a) recovery activities, discussed conceptually in REP Section 5.4, were not adequately addressed in EPIPs; (b) the EPIPs did not adequately describe and delineate the licensee's ERO and the detailed means for notifying ERO members in an emergency; and (c) REP Section 2.4.4 regarding OSC relocation was not adequately implemented by the EPIPs (Section P3.2).
The licensee failed to implement the training program for ERO personnel as specified in the REP and EPIPs since at least 1994, as evidenced by the:
(a) failure to provide annual retraining to certain designated personnel in 1994 and 1995, (b) failure to provide any training for certain ERO positions with respect to selected implementing procedures, and (c) failure to remove individuals from the ERO roster when their qualifications had lapsed (Sections P5.1, P5.3, P5.4).
A arent Deviation The licensee failed to relocate the requirements formerly found in Technical Specifications 6.8.1.d and 6.8.1.e to the Security Plan and Emergency Plan, respectively, in accordance with written commitments to the NRC (Section P3.1).
Unresolved Item The ERO training program, described in REP Section 7.2.2, did not, as implemented, include a programmatic method to ensure that each ERO member demonstrated an ability to perform assigned emergency functions through participation in exercises and/or drills (Section P5.2).
Enclosure
Emer enc Pre aredness Pro ram Weakness Management failed to ensure the implementation of timely corrective actions for certain emergency preparedness deficiencies and weaknesses.
Examples include:
(a) failure to resolve concerns regarding the audibility of the Gaitronics (or plant public-address system) formally identified in late 1994;. (b) failure to provide timely corrective action to address a questionable capability for notification of the State of Florida within 15 minutes of an emergency declaration; and (c) failure to implement timely corrective actions for deficiencies and recommendations identified by the critique of the Hurricane Erin response in August 1995 (Section P7.1).
Positive Observations Good progress has been made in the last several months to develop and implement corrective actions to address the large number of open concerns in the St. Lucie emergency preparedness program (Section P7.1).
Significant improvements in the emergency preparedness training program have been initiated (Section P5.1).
Enclosure
REPORT DETAILS Status of EP Facilities, Equipment, and Resources Mobilization of the Emer enc Res onse Or anization Ins ection Sco e
82701 The inspectors reviewed the licensee's strategy and provisions for notification and mobilization of its personnel in the event of an off-hour emergency declaration requiring activation and staffing of emergency response facilities (ERFs).
In addition to the Control Room, the licensee's ERFs comprised an onsite Operational Support Center (OSC) and Technical Support Center (TSC) and an offsite Emergency Operations Facility (EOF).
This review included evaluation of the adequacy and implementation of the following Emergency Plan Implementing Procedures (EPIPs):
EPIP 3100021E, Duties and Responsibilities of the Emergency Coordinator, Revision 43, approved September 12, 1996.
EPIP 3100023E, On-Site Emergency Organization and Call Directory, Revision 72, approved September 12, 1996.
Observations and Findin s Section 2.4 of the Radiological Emergency Plan (REP) described the licensee's methodology for notification of the emergency response organization (ERO) in the event of an emergency declaration at the Alert level or higher.
In such a circumstance, timely staffing and activation of the TSC and OSC (and the EOF at a Site Area Emergency or General Emergency declaration) would be required, except possibly for situations in which the declaration is terminated rapidly following resolution of the adverse initiating condition.
The implementing details for the ERO notification methodology were located in EPIP 3100023E.
Step 8.2 of the instructions in that procedure specified that on-shift staff augmentation, when required, was initiated from the Control Room by means of either the automated system known as the Emergency Recall System (informally called "autodialer") or the manual backup system utilizing Appendix A, "Duty Call Supervisor [DCS] Call Directory", of the procedure.
On the evening of October 3, 1996, the licensee initiated a staff augmentation test using the autodialer.
The system did not operate, and no individuals received notifications during the test.
No attempt was made at that time to conduct the test using the backup method.
A failure assessment by the licensee disclosed that the autodialer had been in an inoperable configuration from about July 22 through October 3, 1996.
According to the licensee, this configuration resulted when the autodialer computer was rebooted without first closing the database file that compiled personnel information used in the notification scheme.
The inoperability of the autodialer could have been identified much earlier than October 3 had periodic Enclosure
functional tests (e.g., weekly) been performed to verify that the system was in an operable configuration.
With appropriate administrative controls in place, as had been recommended by a member of the EP staff as early as April 1996, together with testing, extended periods of autodialer inoperability would have almost certainly have been precluded.
An earlier, limited-scope autodialer problem occurred during the NRC-evaluated June 1993 exercise (see Exercise Weakness 50-335, 50-389/93-16-04:
Failure to activate the EOF in a timely manner).
Review of licensee documentation also disclosed that an ERO augmentation drill conducted on December 14, 1994 utilizing the autodialer was unsuccessful because of technical problems with the system.
Corrective actions for these previous problems were not sufficiently comprehensive to detect the recent system malfunction.
The manual backup augmentation method was a "call-tree" strategy (displayed graphically in Figure 3 of EPIP 3100023E) which depended upon notification by the DCS of persons away from the plant site, with some of those persons subsequently responsible for notifications of others.
The inspectors reviewed the details of how, and by whom, the manual call-out process would be implemented.
The inspectors interviewed 14 of the 17 persons whose names were listed in Appendix A of EPIP 3100023E as call-tree functionaries who would need to have the current version of that procedure available if contacted by the DCS during off-hours in order to notify others in the call tree.
Three individuals listed in Appendix A for the position of TSC Chemistry Supervisor and one individual listed as OSC Supervisor acknowledged that, prior to October 1, 1996, they did not maintain a copy of EPIP 3100023E at home and were not fully cognizant of their assignments in the call-tree scheme.
Most interviewees stated that they attempted to maintain a copy of EPIP 3100023E at home, but, without appropriate controlled distribution, may not have had the up-to-date revision.
Prior to October 10, 1996, only 3 of the 17 referenced individuals were on the list for controlled distribution of EPIP 3100023E, which was updated at least quarterly.
The licensee had not conducted drills or other specific training to confirm individual performance and to verify the overall function of the manual call-out system for at least the last three years.
The inspectors concluded that staffing and activation of ERFs using the manual process would not have been timely. As indicated by REP Table 2-2A, "timely" staffing and activation of an ERF means within about 60 minutes of the emergency declaration warranting such activation. A drill conducted during off-hours on October 10, 1996 was marginally successful in that it indicated staffing times of about one hour could have been achieved.
However, this occurred only after written and oral instruction, procedure distribution, and announcement of the drill to affected persons.
Since no actual travel to the plant was involved, this drill did not constitute a highly accurate measure of the actual time required to staff and activate the ERFs.
Conclusions The inspection determined that the licensee failed to adequately maintain both the automated system for ERO call-out (from about July 22 to October 3, 1996) and the manual backup system over an indeterminate period (at least the last several years).
The concurrent deficiencies in the automated and manual systems for ERO call-out represented a failure by the licensee, during the period July 22-October 3, 1996, to Enclosure
maintain the capability to execute the provisions of the REP and its implementing procedures in a timely manner with respect to augmentation of the ERO during off-hours.
This failure to comply with the requirement of 10 CFR 50.54(q) that nuclear power plant licensees follow and maintain in effect emergency plans which meet the planning standards of 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50 is identified as Escalated Enforcement. Item (EEI) 50-335, 50-389/96-18-01:
ERO augmentation scheme not maintained adequately.
P3 EP Procedures and Documentation P3.1 Radiolo ical Emer enc Plan Ins ection Sco e
82701 The inspectors selectively reviewed changes made to the REP since the NRC's previous program inspection of this area (conducted in February 1995) to determine whether any of these changes had decreased the effectiveness of the REP.
Observations and Findin s Since February 1995, the licensee had issued four revisions to the REP (Revisions 28-31).
Revision 30 (dated July 31, 1996) and Revision 31 (dated September 13, 1996) were selectively reviewed and discussed with licensee personnel, since those revisions had not been formally evaluated through the NRC's license review process.
Revision 30 primarily promulgated the modifications associated with the transfer of the Nuclear Division staff from the corporate office to the St. Lucie and Turkey Point sites.
With respect to the EP program, this entailed the transfer of program management and oversight responsibilities from the Manager, Nuclear Emergency Preparedness (in the corporate office) to the Site Services Manager (a position later renamed Services Manager, and which reports directly to the Site Vice President),
and the addition of a third Emergency Planning Coordinator to the St. Lucie EP staff.
In addition, the Off-site Emergency Response Organization (which provided personnel for the EOF)
became the Expanded Emergency Response Organization.
The inspectors evaluated these changes in detail and discussed them with cognizant licensee representatives, including the former Manager, Nuclear Emergency Preparedness, the Services Manager, and a Quality Assurance (QA) Senior Analyst. The inspectors determined that strong EP program oversight would be required from the Services Manager to preclude further degradation of the effectiveness of the licensee's EP program and to implement appropriate corrective actions for the findings of this inspection, and that such a level of oversight is defined and required by provisions of both the REP and procedure QI 1-PR/PSL-1, "Site Organization", Revision 30, dated September 1996.
The changes made in Revision 31 were primarily concerned with the licensee's efforts to standardize the REPs for its two nuclear plants.
Enclosure
The inspectors ascertained that the licensee had recently made changes to the Technical Specifications (TS) for the St. Lucie Plant which included implications for the REP, as well as the Security Plan.
Amendment Nos. 147 and 86 to the operating licenses for Unit 1 and 2, respectively, were approved by the NRC on August 20, 1996, and consisted of changes to the TS in response to the licensee's application dated August 16, 1995. Among numerous changes in these amendments were the deletion (for both Unit 1 and 2) of the previous TS 6.8.1.d and TS 6.8.1.e, which formerly specified that 'Written procedures shall be established, implemented and maintained" to cover "Security Plan implementation" and "Emergency Plan implementation", respectively.
These changes were proposed by the licensee in response to NRC Generic Letter (GL) 93-07, dated December 28, 1993, which authorized licensees to propose modifications to certain TS administrative control requirements for emergency and security plans.
In Attachment 2, "Safety Analysis", to the August 15, 1995 application, the licensee stated (in the introduction to the section addressing modifications to TS 6.5.1.6.i, 6.5.1.6.j, 6.8.1.d, and 6.8.1.e) that the
"selected Technical Specifications are being relocated to the Emergency Plan or Security Plan as appropriate.
Relocating these requirements to the appropriate plan willensure the control of future changes are under the requirements of 10 CFR 50.54, 10 CFR 73.55 and 10 CFR 73.56." The NRC's referenced approval stated that the
"licensee proposes to relocate these review requirements and their implementing procedures to the St. Lucie Security and Emergency Plans..."
The licensee's application did not specifically state that TS 6.8.1.d and 6.8.1.e would be deleted without relocation to the Security Plan and Emergency Plan, as applicable, nor did it provide a justification for such an approach, which would be explicitly contrary to the detailed guidance on page 2 of Enclosure 2 to GL 93-07.
As of the end date of the current inspection, the licensee had not relocated the requirements formerly found in TS 6.8.1.d and 6.8.1.e to the Security Plan or Emergency Plan, as applicable.
Condition Report (CR) No. 96-2611 was written to identify the discrepancy discussed here with respect to the REP, but corrective action was not expected to be completed until issuance of the next REP revision near the end of 1996.
Conclusions The inspectors concluded that the changes in REP Revision 30 associated with the licensee's August 1996 reorganization and the changes in Revision 31 did not decrease the effectiveness of the REP.
The licensee's failure to relocate the requirements formerly found in TS 6.8.1.d and 6.8.1.e to the Security Plan or Emergency Plan, as applicable, in accordance with a written licensee commitment, is identified as an apparent deviation (EEI 50-335, 50-389/96-18-02):
Deleted TS not relocated to Security Plan and REP.
Emer enc Plan Im lementin Procedures Ins ection Sco e
82701 The inspectors reviewed the licensee's administration of selected REP requirements through evaluation of the adequacy of the implementing details contained in the EPIPs.
Enclosure
Observations and Findin s In accordance with regulatory requirements and guidance, the licensee developed criteria to be used to determine when, following an accident, reentry and recovery action could be initiated. As guidance for developing and conducting recovery operations, the licensee developed a document entitled, "Florida Power 8 Light Company Nuclear Power Plant Recovery Plan" (Recovery Plan).
This document was not controlled as part of the REP or EPIPs, though it was clearly an adjunct to the REP and interdependent with the EPIPs.
There appeared to be no administrative guidance that controlled the development, distribution, and periodic review of the Recovery Plan.
The licensee had established, and followed, periodic review requirements for the Emergency Plan and EPIPs.
The Recovery Plan was not subject to such reviews, and was last revised on May 31, 1993.
Section IV.A, "Organization", of Appendix E to 10 CFR Part 50, concerning the content of the licensee's emergency plan, states the following: '"The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization and the means for notification of such individuals in the event of an emergency".
In Section 2.2 of the REP, a basic description of the normal and emergency response organization was provided.
Some additional details of the ERO structure were provided in EPIP 3100023E, "On-site Emergency Organization and Call Directory". This procedure generally addressed the personnel who respond to the site in an emergency.
A review of EPIP 3100023E compared to the autodialer database disclosed that 21 of the positions identified in the autodialer database were not included in the EPIP 3100023E.
A document entitled "St. Lucie Plant Emergency Response Directory" provided more details of the licensee's ERO structure.
This directory generally addressed the personnel who would respond to offsite facilities, such as the EOF, in an emergency.
This directory was not controlled as part of the REP and EPIPs, though it was clearly an adjunct to the Emergency Plan, and interdependent with the EPIPs.
The only available listing of the licensee's complete ERO was through the autodialer database.
Neither the REP nor its associated implementing procedures provided a clear or complete description of the licensee's organization for coping with emergencies.
The same was true for the means used by the licensee to notify individuals in an emergency.
No documents, other than the autodialer database, were available which clearly described the means for notification of all ERO personnel.
Section 2.4.4 of the REP stated, "In the event that the OSC becomes untenable, the Emergency Coordinator will designate an alternate location." The procedure expected to provide implementing details relative to this direction was EPIP 3100032E, "On-Site Support Centers",, Revision 17, approved February 5, 1996.
The only applicable implementing information in this procedure was contained in Step 8.7 of the
"Instructions" section, which consisted of the following statement:
"In the event that the OSC becomes untenable, the Emergency Coordinator shall designate an alternate location." As stated in Section 1.3 of the REP, the REP itself "provides a conceptual basis for the development of the detailed procedures necessary to implement the plan."
In repeating the "conceptual basis" found in the REP, EPIP 3100032E was Enclosure
inadequate with respect to the provision of appropriate guidance for the Emergency Coordinator and other ERO personnel regarding suitable alternate locations for the OSC and actions that may be necessary to effect the transfer of OSC functions to that alternate location.
Conclusions Several inadequacies and discrepancies were identified with respect to the implementing details provided in the EPIPs.
The inspectors concluded that the EPIPs did not adequately implement the requirements of the REP in the following respects:
(1) recovery activities, discussed conceptually in REP Section 5.4, were not adequately addressed in EPIPs; (2) the EPIPs did not adequately describe and delineate the licensee's ERO and the detailed means for notifying ERO members in an emergency; and (3) REP Section 2.4.4, addressing OSC relocation, was not adequately implemented by the EPIPs.
Prior to August 20, 1996, the licensee's TS 6.8.1.e specified that 'Written procedures shall be established, implemented and maintained covering... Emergency Plan implementation."
The examples of inadequate EPIPs listed above were present in the same status prior to August 20, 1996, as when identified during the inspection.
These multiple examples of failure to establish and maintain adequate procedures to implement the REP are identified as EEI 50-335, 50-389/96-18-03:
Inadequacies in certain Emergency Plan Implementing Procedures.
Staff Training and Qualification in EP The inspectors conducted a review of the licensee's ERO training program compared to regulatory requirements.
The following sections identify the specific areas reviewed and the results of those reviews.
Three examples of apparent violations of REP requirements in the training program are discussed in Sections P5.1, P5.3, and P5.4, and are collectively identified as EEI 50-335, 50-389/96-18-04:
Training program not adequately implemented.
Initial Trainin and Annual Retrainin of Emer enc Res onse Or anization Personnel Ins ection Sco e
82701 In order to determine the state of the licensee's training program for emergency response personnel, the inspectors reviewed the records documenting completion of required training for the years 1994 and 1995.
Observations and Findin s REP Section 7.2.2, "Training of On-Site Emergency Response Organization Personnel", stated, "For employees with specific assignments or authorities as members of emer enc teams, initial training and annual retraining programs will be provided.
Training must be current to be maintained on the site Emergency Team Roster."
The licensee's ERO training program was described in detail in EPIP 3100034E, "Maintaining Emergency Preparedness
- Emergency Response Plan Enclosure
Training."
In Section 8.0, "Instructions", of EPIP 3100034E, some emergency response positions'and the annual training required for those positions were described.
A review of the licensee's training records for the year 1994 disclosed that not all of the positions identified in the ERO were included in the annual retraining program.
Specifically, the following 17 positions were not included in the 1994 retraining program: OSC Electrical Reentry Supervisor, OSC Instrumentation and Controls Reentry Supervisor, OSC Mechanical Reentry Supervisor, OSC Electrical Chief, OSC Supervisor, OSC Coordinator with TSC, Rotating Maintenance Shift Supervisor, Electricians, Mechanics, Instrumentation and Controls Technicians, OSC Operations Support Testing Staff, Dosimetry Technicians, Paramedic, Mechanical Foreman, OSC Nuclear Material Management Staff, OSC Fire Protection, and OSC Administrative Technician/Log Keeper.
Approximately 92 individuals who were included in the ERO with specific assignments were not retrained in the year 1994.
In early February 1995, the licensee conducted a REP self-assessment, as a result of which the licensee determined that some members of the ERO were not properly requalified in 1994.
The licensee took action to correct the deficiencies that were identified. The licensee also initiated programmatic corrective action to ensure that training requirements were properly maintained.
Corrective actions were documented in St. Lucie Action Request (STAR) 950157, which was closed on May 5, 1995.
(The STAR program was the predecessor to the current system.)
The February 1995 self-assessment did not identify the broader problem of the training program's failure to include all ERO personnel; it was primarily focused on the delinquent qualifications of those identified in the existing training program.
The licensee's critique of the September 1994 accountability drill included a suggested corrective action item to "Clarify training requirements for all TSC and OSC emergency response positions in conjunction with the annual review of the Emergency Plan and Emergency Plan Implementing Procedures."
On March 22, 1995, the licensee revised EPIP 3100034E to add several more of the positions identified in the ERO to those described in the procedure.
A review of the licensee's training records for the year 1995 revealed that not all of the positions identified in the emergency response organization were included in the annual retraining program.
Specifically, the following eight positions were not included in the 1995 retraining program: OSC Electrical Chief, OSC Coordinator with TSC, Electricians, Mechanics, Instrumentation and Controls Technicians, Dosimetry Technicians, Paramedic, and Mechanical Foreman.
Approximately 54 individuals who were included on the ERO with specific assignments were not retrained in the year 1995.
Through discussions with cognizant licensee personnel, the inspectors determined that for those positions which did not receive annual retraining, as specified above, there was also no specific initial training provided.
Existing records also showed that no training was provided for these positions.
During the course of this inspection the licensee was conducting special training sessions intended to cover all personnel assigned to the ERO. The inspectors visited three of the training sessions.
This training was being provided because of recent Enclosure
major changes in the ERO as a result of reassignment of many functions, responsibilities, and personnel from the licensee's corporate organization to the site.
This training was not part of the established training program.
Through discussion with cognizant licensee personnel the inspectors learned that the licensee was in the process of evaluating the currently established emergency preparedness training program to identify areas that may need improvement..
Conclusion The licensee failed to provide specific initial training or annual retraining for 17 positions (approximately 92 individuals) in 1994 and for 8 positions (approximately 54 individuals) in 1995.
This is Example 1 of an apparent violation of the training requirements found in Section 7 of the REP.
P5.2 Exercise and Practice Drills Ins ection Sco e
82701 In order to determine the state of the licensee's training program for emergency response personnel, the inspectors interviewed selected individuals assigned to various ERO positions.
The inspectors also reviewed sign-in sheets for exercises conducted in 1994, 1995, and 1996.
Observations and Findin s REP Section 7.2.2, "Training of On-Site Emergency Response Organization Personnel", states, "The training program for members of the on-site emergency response organization will include practical drills as appropriate and participation in exercises, in which each individual demonstrates an ability to perform assigned emergency functions." The licensee's REP training program was described in detail in EPIP 3100034E.
This procedure made no mention of the participation of individuals in drills or exercises as part of the training program.
No arrangements were provided to ensure that each individual participated in drills or exercises, either during initial qualification or periodically thereafter.
Through interviews with cognizant licensee personnel, the inspectors learned that frequently the same individuals participated, in the same positions, from year to year,
'in both the annual exercise and practice drill(s) associated with the annual exercise.
This practice excluded other individuals qualified for those positions from participation in drills: A review of selected names from exercise sign-in sheets for the years 1994, 1995, and 1996 indicated that the same individuals did often participate in the exercise while others did not. The sign-in sheets also indicated that these individuals tended to be responding to fillthe same position each year.
However, the sign-in sheet documentation was not sufficiently detailed to verify this in each of the instances that were reviewed.
Enclosure
Conclusion The licensee had not provided a programmatic method to ensure that each individual, through participation in a drill or exercise, demonstrated an ability to perform assigned emergency functions.
Pending receipt and evaluation of additional information from the licensee (see Section X3), this matter is identified as Unresolved Item (URI)
50-335, 50-389/96-18-05:
ERO personnel not qualified through drill/exercise participation.
Trainin of Emer enc Res onse Or anization Personnel on Emer enc Plan Im lementin Procedures Ins ection Sco e
82701 In order to determine the state of the licensee's training program for emergency response personnel, the inspectors reviewed the licensee's training records documenting completion of required training for 1994 and 1995.
F Observations and Findin s REP Section 7.2.1; "Objectives", stated the following: "The primary objectives of emergency response training are as follows: 1. Familiarize appropriate individuals with Emergency Plan and related implementing procedures.
2. Instruct individuals in their specific duties to ensure effective and expeditious action during an emergency.
3.
Periodically present significant changes in the scope or content of the Emergency Plan.
4. Provide. refresher training to ensure that personnel are familiar with their duties and responsibilities."
The licensee's REP training program was described in detail in EPIP 3100034E.
In Section 8.0, "Instructions", some emergency response positions and the annual training required for those positions were described.
For most of the listed emergency response positions, individuals were to receive "Emergency Plan familiarization through review of selected Emergency Plan Implementing Procedures (EPIP)."
The annual REP training packages used in 1994 and 1995 to accomplish required training were reviewed.
For both years only the five following EPIPs were identified as needing to be reviewed: EPIP 3100021E, "Duties and Responsibilities of the Emergency Coordinator"; EPIP 3100022E, "Classification of Emergencies";
EPIP 3100023E, "On-site Emergency Organization and Call Directory";
EPIP 3100032E, "On-site Support Centers"; and EPIP 3100033E, "Off-site Dose Calculations".
As discussed in Section P5.1 above, not all personnel on the ERO received training as was required.
For those individuals who did receive training, the training consisted of an assignment to read only the previously listed five EPIPs.
A review of assigned responsibilities and instructions in several selected EPIPs compared to the five EPIPs included in the annual training package revealed that many personnel were not receiving specific training on several of the procedures that they would be required to Enclosure
implement in performing their assigned emergency response duties. The following EPIPs, and associated ERO positions that would implement the EPIP, are specific examples:
EPIP 3100027E, "Re-entry" - Emergency Coordinator, Radiation Team Leader, OSC Supervisor, Re-entry Team Supervisor, Re-entry Team Member, OSC Status Board Keeper, and OSC Dose Recorder.
EPIP 3100026E, "Criteria for and Conduct of Evacuation" - Emergency Coordinator, Assembly Area Supervisor, and TSC Security Supervisor.
EPIP 3100035E, "Off-site Radiation Monitoring" - Radiation Team Leader and TSC Supervisor.
In addition to not receiving initial or annual retraining on all applicable procedures for a specific position, personnel were not informed of significant changes that were made to procedures.
For example, EPIP 3100026E was revised significantly in September 1994, and again in February 1995.
No documentation was available to indicate that affected ERO personnel were informed of the changes made to the procedure.
c.
Conclusion The licensee's training program failed to include initial training and annual retraining on all procedures required to be implemented by ERO personnel in several identified positions.
The licensee also failed to ensure that ERO personnel in several identified positions were informed of relevant changes in EPIPs.
This is Example 2 of an apparent violation of the training requirements found in Section 7 of the REP.
P5.4 Maintenance and Control of Emer enc Res onse Or anization Qualifications a.
Ins ection Sco e
82701 In order to determine the state of the licensee's training program for emergency response personnel, the inspectors reviewed the licensee's training records documenting completion of required training for 1994 and 1995.
The inspectors also reviewed a copy of the Scenario Roster Listing Duty Roster (autodialer database),
dated October 9, 1996; the Radiation Exposure Monitoring & Access Control System (REMACS) Exposure Summary Report, dated October 11, 1996; and the Emergency Team Roster, dated October 2, 1996.
b.
Observations and Findin s REP Section 7.2.2, "Training of On-Site Emergency Response. Organization Personnel", states in part, "For employees with specific assignments or authorities as members of emer enc teams, initial training and annual retraining programs will be provided.
Training must be current to be maintained on the site Emergency Team Roster."
The ERO training program was described in detail in EPIP 3100034E.
Section 5.4.3 stated that the Protection Services Supervisor was responsible for:
Enclosure
"Removing individuals who fail to maintain training qualifications for EPIP 3100023E,
"On-site Emergency Organization and Call Directory" and the FPL Emergency Recall System (autodialer) database when notified by the appropriate department head or the Training Department."
In EPIP 3100034E, Section 5.7 stated: "Department heads responsible for personnel fillingthe following positions shall ensure that these persons are currently Radiation Control Area Training (RCAT) and respirator qualified: (151)
OSC HP Tech,..., (161) OSC Electrician..."
A review of the licensee's training records for the year 1994 revealed that two individuals fillingthe position of TSC Security Supervisor did not complete annual retraining in 1994.
These two individuals remained on the On-site Emergency Organization and Call Directory for the year 1995 without having completed retraining as needed.
In early February 1995, the licensee conducted an EP self-assessment.
This self-assessment identified that no documentation could be found for the qualifications of the two individuals fillingthe position of TSC Security Supervisor.
The licensee initiated programmatic corrective action to ensure that training requirements were properly maintained.
The licensee's corrective actions were documented in STAR 950157 which was closed on May 5, 1995.
The Emergency Preparedness Functional Area Audit conducted between March 27, 1996 and August 14, 1996, Audit No. QAS-EMP-96-1, found that one individual filling an OSC position as a Mechanical Reentry Supervisor had not completed the annual requalification training as required.
The administrative systems failed to remove this individual from the ERO upon expiration of training requirements.
Corrective actions implemented by STAR 950157 were not successful in preventing recurrence of the deficiency.
The Emergency Team Roster, dated October 2, 1996, issued by the Training Department identified several individuals as not having current respirator qualifications. A review of the autodialer database, dated October 9, 1996, compared to the REMACS Exposure Summary Report, dated October 11, 1996, revealed that four individuals listed as (151) OSC HP Tech and two individuals listed as (161) OSC Electrician were not respirator-qualified as they were required to be for their respective positions.
The four individuals listed as OSC HP Tech were identified in the October 2, 1996, Emergency Team Roster as not having current respirator qualification. The two individuals listed as OSC Electrician were not identified in the October 2, 1996, Emergency Team Roster.
Again the licensee's administrative systems failed to remove these individuals from the ERO upon expiration of training requirements.
Conclusion For the calendar year 1995, the licensee failed to remove two individuals from the emergency response organization who had not completed retraining as required, and whose qualifications had expired in 1994.
The licensee also failed to remove six individuals from the emergency team roster effective October 6, 1996, who had not Enclosure
remained qualified to fillresponse team requirements as a result of allowing their respirator qualifications to lapse.
The licensee did not have an effective method of systematically ensuring that individuals assigned to the ERO are current in required training and qualifications.
This is Example 3 of an apparent violation of the training requirements found in Section 7 of the REP.
P7 Quality Assurance in EP Activities P7.1 Corrective Action Pro ram Ins ection Sco e
82701 The inspectors reviewed the licensee's program for identifying and correcting weaknesses and deficiencies in EP.
This review included the evaluation of numerous identified issues and their respective corrective actions in the CR, Plant Manager Action Item (PMAI), and EP Action systems.
b.
Observations and Findin s Critique items from a site accountability drill conducted in September 1994 identified problems with the audibility of the site-wide public-address system (Gaitronics), and the need for the addition of an alert tone (alarm).
The licensee initiated corrective actions for the addition of a new alarm under STAR 94110314.
A request for engineering assistance (REA) 94-068-90 was issued to initiate the appropriate action to result in installation of the new alarm.
For unidentified reasons the REA was never completely processed, the item was not budgeted, and no actions were implemented.
In early 1996, STAR 94110314 was closed and transferred to PM96-03-247 (in the PMAI system) for administrative reasons due to discontinuance of the STAR program.
Subsequently, the licensee discovered that REA 94-068-90 had not been implemented.
A new REA (REA 96-084) was issued on September 16, 1996 to initiate the necessary actions to resolve the issue and result in the installation of the new alarm.
This item has been budgeted by Maintenance for 1997.
The licensee initiated corrective actions to verify the audibility of the Gaitronics system under STAR 94110315.
The licensee identified that this issue was similar to a previously addressed issue identified in NRC Bulletin 79-18, concerning the audibility of alarms in high-noise areas.
The licensee had responded to the NRC on September 21, 1979, indicating that the site was then in compliance with Bulletin 79-18.
In early 1996, STAR 94110315 was closed and transferred to PM96-02-423 for administrative reasons (i.e., discontinuance of the STAR program).
As of November 1, 1996, the licensee had not completed action to resolve the issue of audibility of the Gaitronics system throughout the site.
In February 1995, an NRC inspection identified apparent performance problems with respect to the 15-minute requirement for notification of the State of Florida.following an emergency declaration (see Paragraph 5 of NRC Inspection Report Nos. 50-335/95-03 and 50-389/95-03).
As documented in that report, the inspector observed two drills conducted in the Control Room simulator as part of the Licensed Enclosure
Operator Requalification (LOR) Training Program.
The time periods required to begin the State notifications were 27 and 26 minutes, well beyond the 15-minute criterion.
The report documented the licensee's initiation of STAR 950172 to track appropriate follow-up and corrective actions for this issue.
Although the STAR was subsequently closed after modifications to EPIP 3100021E and the training in this area, problems with notifications continued to be raised by licensee personnel during LOR training.
The issue was formally identified again in CR 96-1465, which was initiated by a member of the Operations staff on June 19, 1996.
The inspector's review of this issue determined that the licensee's past practice of conducting most drills and exercises during normal working hours had precluded identification of a problem with Control Room staffing.
Under such conditions, it was legitimate for an "extra" Nuclear Plant Supervisor (NPS) to appear in the Control Room immediately after the drill or exercise commenced to assume a position called NPS Communicator.
This extra NPS was not typically onsite during off-hours, and would not be readily available to serve as NPS Communicator.
During the current inspection, the licensee decided to train a pool of knowledgeable personnel in the Rotating Maintenance Shift Supervisor position to serve as offsite communicator following an emergency declaration.
Although it appeared that this approach was likely to be successful, it represented an instance of untimely root-cause identification and ineffective management oversight of EP problem resolution.
In late July and early August 1995, the St. Lucie site and adjacent areas were affected by Hurricane Erin. As a result of the hurricane, the licensee declared a Notification of Unusual Event in accordance with established procedures.
Subsequent to the event, the licensee developed a draft critique of the site's response to Hurricane Erin. A total of 50 recommendations for corrective actions were identified in the draft critique.
Some examples of these corrective actions included the following: identifying hurricane-safe structures onsite and a plan for positioning personnel in those structures; designating an onsite individual to monitor the hurricane path; and establishing a consistent staffing policy. This draft critique was never finalized and issued by licensee management to assure that corrective actions were taken following the event.
Hurricane Bertha threatened the St. Lucie site in early July 1996, after which the licensee again prepared a critique of its response actions.
A total of 17 recommendations for corrective actions were identified in the draft critique for Hurricane Bertha.
On August 23, 1996, the draft critiques for Hurricane Erin and Bertha were communicated by memorandum to the Vice President - St. Lucie Plant.
As of November 1, 1996, the licensee had initiated corrective actions for some of the issues identified in the critiques.
Licensee management acknowledged that necessary corrective actions deriving from the Hurricane Erin critique should reasonably have been completed by June 1, 1996, which was the beginning of the 1996 hurricane season.
Conclusions The inspectors concluded that licensee management failed to ensure the implementation of timely corrective actions for certain emergency preparedness deficiencies and weaknesses.
The significant examples identified were: (a) failure to address concerns in a timely manner regarding the audibility of the Gaitronics (or Enclosure
plant public-address system) formally identified in late 1994; (b) failure to provide timely corrective action to address a questionable capability for notification of the State of Florida within 15 minutes of an emergency declaration; and (c) failure to implement timely corrective actions for deficiencies and recommendations identified by the critique of the Hurricane Erin response in August 1995.
These issues are collectively identified as an EP Program Weakness, and will be tracked as Inspection Follow-up Item (IFI) 50-335, 50-389/96-18-06:
Untimely corrective actions for some EP deficiencies.
P7.2 Audits a.
Ins ection Sco e
82701 An independent audit of the emergency preparedness program was required to be performed at least annually by REP Section 7.3.4 and 10 CFR 50.54(t).
The following audit reports were reviewed and discussed with licensee representatives:
Quality Assurance Audit Report QSL-OPS-94-06, dated June 6, 1994 Quality Assurance Audit Report QSL-OPS-95-07, dated June 16, 1995 Quality Assurance Audit Report QAS-EMP-96-1, dated August 16, 1996 b.
Observations and Findin s The audits were. conducted annually as required and addressed applicable emergency preparedness program areas.
The audits focused on verification of compliance with NRC requirements and the REP.
The inspectors reviewed audit checklists and found them adequate.
No significant findings were disclosed by the 1994 and 1995 QA audits.
The 1996 audit identified three findings, all of which were similar to the violations or weaknesses documented in this report.
The report summary stated that
"The findings in this audit indicate a decline in St. Lucie readiness and Emergency Preparedness program effectiveness."
From discussions with licensee personnel and review of applicable documentation, the inspectors determined that the auditors had appropriate training and qualifications to perform EP audits.
C.
Conclusions The audit program met required frequencies, and the audits were adequate and performed in accordance with regulatory requirements.
Enclosure
MANAGEMENTMEETINGS X1 Public Exit Meeting Summary The inspectors presented the inspection results (substantially as delineated in the Executive Summary) to members of the licensee management and the public at the conclusion of the inspection on November 1, 1996.
The licensee acknowledged the findings without dissenting comments.
X3 Follow-up Management Meetings via Teleconference On November 14, 1996, a follow-up teleconference between Mr. J. Scarola, Plant Manager, and Mr. E. Merschoff, Director, Division of Reactor Projects, NRC Region II, was conducted to discuss the issue regarding qualification of ERO personnel through drill and/or exercise participation (Paragraph P5.2).
The licensee committed to provide additional written information relative to this matter by November 20, but this date was later changed to November 25, 1996 at the licensee's request.
The subject information was not factored into this report.
On November 25, 1996, a follow-up teleconference between Mr. A. Stall, Vice President - St. Lucie Plant, and Mr. K. Barr, Chief, Plant Support Branch, NRC Region II, provided licensee management with the final categorization of inspection findings as delineated in the Executive Summary of this report.
The most significant change from the findings as presented during the exit meeting of November 1 was the addition of an apparent deviation.
On November 26, 1996, a follow-up teleconference between Mr. A. Stall, Vice President - St. Lucie Plant, and Mr. K. Barr, Chief, Plant Support Branch, NRC Region II, informed licensee management that an issue previously identified as an Unresolved Item had been categorized as an apparent violation (Section P3.2 of inspection report).
Enclosure
PARTIALLIST OF PERSONS CONTACTED M. Allen, Training Manager G. Casto, Emergency Preparedness Supervisor R. Dawson, Protection Services Supervisor D. Fadden, Services Manager D. Mothena, Manager, Plant Services (Corporate)
J. Scarola, Plant General Manager A. Stall, Vice President - St. Lucie Plant E. Weinkam, Licensing Manager Enclosure
INSPECTION PROCEDURES IP 82701:
Operational Status of the Emergency Preparedness Program
~Oened ITEMS OPENED CLOSED AND DISCUSSED 50-335, 50-389/96-18-01 EEI 50-335, 50-389/96-18-02 EEI 50-335, 50-389/96-18-03 EEI 50-335, 50-389/96-18-04 EEI 50-335, 50-389/96-18-05 URI 50-335, 50-389/96-18-06 IFI ERO augmentation scheme not maintained adequately (Section P2.1)
Deleted TS not relocated to Security Plan and REP (Section P3.1)
Inadequacies in certain Emergency Plan Implementing Procedures (Section P3.2)
Training program not adequately implemented (Section P5)
ERO personnel not qualified through drill/exercise participation (Section P5.2)
Untimely corrective actions for some EP deficiencies (Section P7.1)
Enclosure
LIST OF ABBREVIATIONSUSED CFR CR DCS EEI EOF EP EPIP ERF ERO FPL GL IFI LOR NPS NRC OSC PMAI QA RCAT REA REMACS REP STAR TS TSC URI Code of Federal Regulations Condition Report Duty Call Supervisor Escalated Enforcement Item Emergency Operations Facility Emergency Preparedness Emergency Plan Implementing Procedure Emergency Response Facility Emergency Response Organization Florida Power and Light Company Generic Letter Inspection Follow-up Item Licensed Operator Requalification Nuclear Plant Supervisor Nuclear Regulatory Commission Operational Support Center Plant Manager Action Item Quality Assurance Radiation Control Area Training Request for Engineering Assistance Radiation Exposure Monitoring 8 Access Control System Radiological Emergency Plan St. Lucie Action Request Technical Specification Technical Support Center Unresolved Item Enclosure