IR 05000344/1989004

Insp Rept 50-344/89-04 on 890228-0303.Violations Noted. Major Areas Inspected:Follow Up on Two Open Items & One Unresolved Item Identified During Previous Emergency Preparedness Insps & Emergency Preparedness Program

ML20244A806
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	03/23/1989
From:	Fish R, Good G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20244A796	List: IR 05000344/1989004 ML20244A793 ML20244A798
References
50-344-89-04, 50-344-89-4, NUDOCS 8904180196
Download: ML20244A806 (9)

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U. S. NUCLEAR REGULATORY COMMISSION-

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REGION-V Report No.~ 50-344/89-04 Docket N i i

License N NPF-1 '

Licensee: Portland General Electric .;

121 S. W.l Salmon Street Portland,' Oregon .97204 .

Facility Name: Trojan'

Inspection at: Rainier, Oregon-Inspection Conducted: February 28 - March 3,1989 t Inspector: -

h t-fn 3[JJ/D G. M. Good, Emerg'ency Preparedness Analyst -Ddte 5ign d Approved by: hM R. F. Fish, Chief 3 /J-3/D Da'te Signsd -

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Emergency Preparedness Section SUMMARY:

Inspection on February 28 - March 3, 1989 (Report No. 50-344/89-04)

Areas Inspected: Unannounced, routine inspection to follow-up on two open items and one unresolved item identified during previous emergency

. preparedness inspections and to address the Operational Status of the Emergency Preparedness Program (facilities, procedures and training).

Inspection procedures 92701, 82701 and 30703 were used as guidanc Results: O' ne unresolved item and one violation were identified during this inspection. The unresolved item concerned the licensee's ability to complete required training for emergency response personnel in .a timely manner. The unresolved item from the previous inspection was identified as a violation during this inspection because it was determined that the licensee did not declare'an Unusual Event during a 11/14/88 event as required by emergency

' procedure EP-001. The results of this inspection indicated a responsiveness

to NRC concerns; however, continuing attention to detail is needed in the area of procedural compliance. The licensee's program is satisfactory; however, increased management involvement appears warrante j i

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I DETAILS

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'T. Andone, Jr. , Shift Supervisor K. W. Hanson, Shift Supervisor F. Jones, Onsite Coordinator, Emergency Preparedness-J.~W. Mullins, Training Specialist D. L. Nordstrom, Compliance Engineer

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G. G.,Perrin, Shift Supervisor A. M. Puzey, Office Supervisor, Administration .!

J. L. Thale, Supervisor, Emergency Preparedness j q Action on Previous Inspection Findings (Inspection Procedure 92701)' l

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(Closed) Open Item (87-22-01): Need for staffing and' augmentation drill This item was being held open pending acquisition of paging equipment, procedure implementation and successful completion of a dril The inspector found that the licensee had acquired the paging equipmen and had conducted an augmentation drill using established procedure .The inspector reviewed a draft report of the call-in drill that was conducted on January 31, 1989, and concluded that the. drill was successful; however, some problems were identifie Based on the results ;

of the drill, the licensee's emergency preparedness (EP) staff made several recommendations for improvemen Recommended improvements ,

included the acquisition of an automatic dialer, for message verification l in addition to elimination of time consuming call trees, and the need to conduct yearly drills or when any major change in the process occur The EP staff also saw the need to conduct drills at different time !

This drill was conducted on a weeknight, at 6:00p.m., the time when most people are likely to be at home having dinne The inspector suggested that the licensee would benefit by conducting.some drills where the individuals actually respond to the sit During the January 31, 1989, drill, the persons notified only estimated their time of arriva The e

inspector noted that only 50% of the individuals were notified within 30 minute This item is considered close (Closed) Open Item (88-09-01): Need to. improve quality control in preparation and distribution of the emergency plan and procedures. In j order to improve the preparation and distribution of the emergency plan l and procedures, the licensee has requested printing services to perform a j hand check prior to distributio This item is considered close (Closed) Unresolved Item (88-41-05): Emergency classification of main flange leak for Reactor Coolant Pump (RCP) "C" on November 14, 198 Specific details regarding this event, which began on November 13, 1988 with a turbine / reactor trip, can be found in Section 10 of NRC Inspectior Report Number 50-344/88-4 For continuity, salient points from the aforementioned inspection report have been provided below:

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. Shift Supervisor's (SS's) log entry at 1835 on November 14, 1988 ^

stated that the plant staff had identified pressure boundary leakage at RCP "C".

e Modulel4, Step 5.1, of EP-001, " Emergency Classification" states '

that verified pressure boundary leakage is an Emergency Action Level (EAL)' requiring an Unusual Event (UE) declaration; however, no event was declare The SS did not declare the event because there was a question in his mind about whether there actually was pressure boundary leakage and because his management informed him that he did not have to declare the event because of Note 1 on Module 4 of EP-001. Note 1 states that "An emergency classification based on exceeding technical specifications shall be ordered if there is reason to believe the action statement time will be or has been exceeded." At the time of the log entry the plant was already in Mode 3, so there was n question about whether cold shutdown could be reached within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. It should be noted that the SS was ready to declare the UE prior to his discussions with managemen Interviews with another SS and the Control Operator who made the aforementioned log entry indicated that they would have declared the U Note 1 is not footnoted in Step 5.1 of Module 4 in EP-001 (i.e.,

there is nothing in the step or on the page to direct the reader's attention to Note 1).

.The initial decision to identify this issue as an unresolved item was based on the fact that it was important to determine what information had been provided to operations personnel during training and to evaluate what, if any, corrective actions would be taken by the license To that end, during this. inspection, the inspector reviewed the licensee's  ;

corrective actions, held discussions with licensee training personnel, l and questioned 3 SSs. The results of this effort showed that the  ;

licent.ee had taken appropriate corrective actions; EP-001 was deviated {

.(a deviation is an administrative process used to change procedures) to ,

eliminate Note 1 from Module 4; night orders were distributed to apprise i operations personnel of this situation, and; this subject was given j special coverage during subsequent training session '

Regarding the training that had been provided to operations personnel l prior to the November 14, 1988, situation, the inspector was informed j that operations personnel had never been instructed to apply Note 1 to  ;

Step 5.1 of Module 4, because Note 1 was not intended to be applied to l Step 5.1. Training personnel stated that although this particular set of circumstances had never been included as a test question in training ,

exams, if .it had, application of Note 1 to Step 5.1 of Module 4 would i have been marked as an incorrect answer. The results of the SS interviews indicated that the SSs e derstood that a UE was to be declared if pressure boundary leakage en sts. Based on the results of this inspection, the inspector concluded that at 1835 on November 14,1988, a UE should have been declared in accordance with Step 5.1 of Module 4 of ,

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EP-001, because the staff' had determined that: pressure boundary? leakage existed, even though it was later determined that the. leak was not from

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the. pressure boundar The failure to' follow'an emergency prrcedure.is'a violation'. For tracking purposes, Unresolved Item 88-41-05 is considered closed and the violation will'be tracked as Violation -89-04-0 . ~ Emergency Facilities; Equipment, Instrumentation and Supplies (Inspection Procedure 82701)

This ar.ea was inspected to verify that key facilities and; equipment were adequately maintained,'to determine whether' changes made since the las'

inspection;were adequate to meet NRC requirements and that the changes did not adversely affect the EP program. To: accomplish this the inspector; toured.the Technical Support Center (TSC), Operations Support Center.(OSC) and' Emergency Operations Facility (EOF). All of.the ERFs appeared to be in a state of operational readines Since the last time this area was inspected (July 1988), some modifications to the TSC. an ' EOF were made to accomodate the NRC's expanded site r.ena during the l

' licensee's 1988 annual emergency exercise. The exercise showed that although the NRC was able to accomplish its task wiM.in the workspace provided, there were some limitations due to available space'.

During the tour.of the EOF, two portable survey instruments with past due calibration stickers were found in the EP supply. cabinet located in the

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Mechanical. Room. EP personnel, who were present during the tour,

>promptly prepared-a Nonconforming Activity Report (NCAR). The inspector

' elected to. let the licensee's corrective action tracking system follow the resolution of 'this matter; however, Regional Radiation Protection

personne1'were informed of this matte This portion of the licensee's. program appears to be acceptable except as otherwise

indicated above. No deficiencies or violations of NRC

requirements were identified during this part of the inspectio . Changes to Emergency Procedures (Inspection Procedure 82701)

This portion of the inspection focused on the. licensee's process for making and' distributing changes to emergency procedures. The inspector was channeled into this particular area as a result of the deviation to i EP-001 mentioned in Section 2 above. ,The regulation-pertaining to this I area is Item V of Appendix E to 10 CFR 50. Item V of Appendix E states'

in part that " Licensee's who are authorized to operate a nuclear power facility shall submit any changer to the emergency plan or procedures to the Commission,'as specified in Part 50.4,'within 30 days of such changes." -Administrative Order (AO) 4-4, " Procedure Additions, Revisions, Deletions, Deviations and Corrections", a quality related procedure, also pertains to this subjec On November _28,1988, EP-001 was deviated to eliminate Note 1 from Module I 4 (Deviation Number 88-383). Another deviation to this procedure was )

issued on~ February 23, 1989; howt:ver, for the purpose of this report, the

. November 1988' deviation will be the focal poin As of the date of this

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inspection, the November.1988 deviation had not been submitted to the i Commission. . In response to the inspector's questions about,this matter, i licensee personnel stated.that deviations are not considered to be

. changes; therefore, the NRC has not been placed on the distribution list for deviations.

!- .A0 4-4 defines a deviation as "A temporary and/or on-the-spot revision to an approved procedure. Except during an emergency as specified in Section 3.7, a deviation SHALL NOT change the intent of the procedure."

A0 4-4 actually provides for three different types of deviations; use only one time; use for a specified time only, and; use until incorporated in next revision. The latter of the types of deviations is considered by ,

A0 4-4 to be both a dev &. ion and a revision. A0 4-4 defines a revision !

as "Any permanent chang m a procedure." These types of deviations are used for procedures when ji, is important to get the change reviewed and approved promptly. Deviations must be reviewed and approved within 14 days of implementation; however, it can take much longer to issue a revision. Attachment 1 (page 2 of 2) of A0 4-4, Plant Operating Manual (POM) Procedure Change Form, under the heading " Deviation Information" states that " Administration will automatically process a revision, unless otherwise indicated." It would appear that deviation / revisions are actually permanent changes to procedure '

The inspector examined the POM Procedure Change Form that was completed for Deviation Number 88-383 and found that it had been processed as a deviation /revisioni however, as of the date of this inspection, EP-001 had not been automatically revised as required by A0 4-4. The inspector was informed that the emergency procedures are not processed by the administrative group, like all the other portions of the POM. Instead, emergency procedures, and changes thereto, are processed by the Nuclear Safety and Regulation Department (NSRD). The EP group, within NSRD, has been responsible for processing changes to the emergency procedure When the inspector questioned the EP Supervisor about the processing of ,

Deviation 88-383 he indicated that he'was not aware that A0 4-4 required l an automatic revision for deviation / revisions. The EP Supervisor stated that he was holding the deviation until the next revision, which was i being planned for the June 1989 time fram The precedure revision would ,

be submitted to the NRC at that tim '

The inspector expressed the following concerns related to this issue: ! Since the NRC monitors the licensee's actions, including event

. classification, during emergencies, it is important that both organizations work from the same procedure or communication problems could arise which could complicate an already encumbered situatio ! Has an appropriate level of training been providad to user's of A0

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4-4 and other administrative procedures? Is the instructional guidance in A0 4-4 adequate to permit user's to correctly implement the procedure without benefit of assistance?

The licensee responded to this entire issue by volunteering to put the NRC on distribution for deviations to the emergency procedures. The i

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licensee also intends to submit the current deviations. The EP staff stated that EP-001 would be revised now, instead of waiting for Jun The licensee agreed that a potential existed;for a. communication problem '

during a emergency if the NRC and licensee organizations used emergency procedures that were not consistent with one anothe '

No deficiencies or violations of NRC requirements were identified during

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this part of the inspectio . Tr'aining (Inspection Procedure 82701)

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This part of the inspection was conducted to verify that the licensee's key emergency response personnel have been properly trained and understand their emergency responsibilitie Applicable requirements include 10 CFR 50.47(b)(15) and Item IV.F of Appendix E to 10 CFR 5 To-accomplish this part of the inspection, the inspector interviewed a small sample of selected individuals to determine whether they had been properly trained and understood their responsibilities during an emergency and verified that training was being conducted in accordance with established procedure The inspector interviewed three SSs in order to evaluate the effectiveness of the licensee's EP training program. SSs were chosen because in an emergency they would be required to act as the Emergency Coordinator (EC) until relieved by the Duty Plant General Manager (DPGM).

In addition to being asked general questions about their responsibilities as EC, each SS was asked to classify five different (unrelated) emergenc events and provide the protective action recommendations (PARS) for onsite personnel and the general public. The results of the interviews j are as follows: ' All of the SSs were slower at classifying the higher levels of emergencies. When presented with a situation where there was a loss of coolant accident (LOCA) greater than make-up and an inadequate performance from the Emergency Core Cooling System (ECCS), one SS responded that it was at least a U All of the SSs required some prompting to get to the additional PARS at the General Emergency (GE). There was also confusion related to the use of the evacuation zones. One SS thought that PARS were addressed in terms of downwind sectors. The use of evacuation zones has been in place for several year Two of the SSs could not provide the definition of " source term." One of the SSs had never participated in an integrated drill or  :

annual exercis Another one of the SSs stated that it had been 4 l or 5 years since he had participated in on j Two of the SSs displayed less confidence when asked what dose rates at the Exclusion Area Boundary (EAB) would result in an Alert j classificatio One SS went to the PAR procedure before looking at j the classification procedure. The SSs did not appear to be familiar I

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I with the fact that these dose rates are based upon the Environmental Protection Agency Protective Action Guidelines (EPA PAGs).

Based upon the results of these interviews, the inspector concluded the following: .The SSs would benefit from more practice at classifying the higher levels of emergencies. A real emergency may not follow a ,

progression through the lower level l i The SSs would benefit from more practice and/or training at making PARS at the higher level classification iii. All SSs would benefit from regular participation in integrated drills or the annual exercis To' determine whether the licensee was conducting training in accordance with established emergency procedures the inspector reviewed EP-501

" Training and Orills",' discussed the EP training program with training personnel and reviewed records maintained by the EP training instructo The licensee's training program consists of a combination of self-study ,

training modules, on-the-job training, classroom training and table top- {

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trainin Facility drills and integrated drills are also conducte Paragraph 3.3.2.1 of.EP-501 states that " Retraining for all personnel with Radiological Emergency Response duties shall be conducted annually."

EP-501 provides for annual retraining on Radiological Emergency Response Plan (RERP) Overview (Training Module El-A-00). Based on a review of the records maintained by the EP training instructor, the. inspector found that approximately 75% of the emergency response organization had not had RERP Overview training since January 1988. The Control Room (CR) staff was the only group that was up-to-date on this trainin During discussions with the EP training instructor, the. inspector was inforred that a training report, which includes a list of those individuals who have not completed their training requirements, is issued on a quarterly basi The training instructor indicated that the list includes those individuals who will be due for training in the next quarte None of the individuals mentioned above (75% of the emergency response organization) appeared on the 4th quarter 1988 training repor The training instructor stated that this was an oversight on his par The. instructor had not been aware of this situation until it was mentioned by the inspecto .

Pertinent to this matter, the training instructor stated that a 3 month extension period is used to complete training requirements; however, no documentation was produced to support of this statement. Using the 3 month extension period would mean that the individuals who had exceeded the 12 month training requirement in January 1989 would not technically be overiue until April 1989. When the training instructor was asked about whether he could complete the training before April', he indicated that the current RERP Overview lesson plan would have to be modified ,

before he could conduct the trainin He explained that in 1988, the {

Overview training had been provided as part of the annual General l Employee Training (GET). Subsequent to the January 1988 training, a '

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management, decision was made to split apart

RERP 0verview training, because of-the amo6h,the~GET training from.thet of time

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1the combined training and because only'those individuals assigned.'

emergency. response duties are required to take the RERP.0verview-

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Based on the records review and the discussions with'the EP training ,

e instructor, the inspector concluded that'she:had no reason to expect that the. licensee would have ! completed the training before April because,.the licensee's system for tracking training status had broken down,tthe RERP-Overview lesson plan .needed to be_ modified and there were approximately 150 individuals who needed to be trained. -Additionally, the inspector-concluded that the licensee should determine whether an appropriate level of: management attention was being.provided<in this area and whether the interface between the training'and.EP staffs-has been sufficien o Resolution of this matter will be tracked as Unresolved Item 89-04-0 An unresolved item is a matter about which more information is required to ascertain whether it is an acceptable item, a' deviation lor a

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violatio . Exit Interview-(Inspection Procedure 30703)

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An exit interview was held on March 3, 1989, to discuss the preliminar findings of-the inspection. The attachment to this report identifies the licensee personnel who were present at the meeting.. In addition to the'

" inspector. Mr. R. Barr, Senior Resident Inspector, was present. During the exit interview. the inspector stated that it appeared that three

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violations of;NRC requirements had'been identified. The findings as described in Sections 2-6 of this report were discussed except for the procedure deviation / revision item covered in Section 4 and the training completion item covered in Section 6. Both of these items were identified as' potential violations at the exit interview. Subsequent to the inspection,-it was determined that the ' training matter would be categorized as an unresolved item instead of a violation and the procedure item was not a violatio 'l

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ATTACHMENT:

' EXIT INTERVIEW ATTENDEES C. H. Brown, Branch Manager,' Quality Operations J. W. Mullins, Training Specialist S. B. Nichols, Branch Manager, Training D. L. Nordstrom, Compliance Engineer

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A. M. Puzey, Office Supervisor, Administration J. D. Reid, Manager, Plant Services R. L. Russell, Branch Manager, Operations R. P. Schmitt, Manager, Operations and Maintenance J. L. Thale, Supervisor, EP 1 C. P. Yundt, Plant General Manager .

G. A. Zimmerman, Manager, NSRD f

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