IR 05000348/1990009
| ML20043A952 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 05/09/1990 |
| From: | Kreh J, Rankin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20043A948 | List: |
| References | |
| 50-348-90-09, 50-348-90-9, 50-364-90-09, 50-364-90-9, NUDOCS 9005230335 | |
| Download: ML20043A952 (9) | |
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AT L ANT A. GEORGI A 30323
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Report Nos.:
50-348/90-09 and 50-364/90-09 Licensee:
Alabama Power Company 600 North 18th Street Birmingham, AL 35291-0400 Docket Nos.: 50-348, 50-364 License Nos.: NPF-2, NPF-8 Tacility Name:
Farley Nuclear Plant Inspection Condscted: April 16-20, 199
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7 ate Signed
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Emergency Preparedness Section Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards SUMMARY Scope:
This routine, unannounced inspection was conducted to assess the operational readiness of the site emergency preparedness program, and included review of the following progranriiatic elements:
(1) Emergency Plan and associated
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implementing(3) procedures; (2) facilities, equipment, instrumentatior, and supplies; organization and management control; (4) training; and (5) audits, critiques, and corrective actions.
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Results:
In the area inspected, no violations or deviations were identified.
The
licensee's emergency preparedness program was adequately managed and implemented.
Emergency facilities and equipment were properly maintained, and numerous Technical Support Center improvements were expected to be completed during the next six months.
Required program audits were thorough, and a system was in place for tracking the correction of problems in emergency i.
preparedness.
An interview with one Shift Supervisor suggested that emergency L
response training was effective.
The licensee had aggressively pursued
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necessary corrective actions for the deficiencies identified during the December 1989 exercise.
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REPORT DETAILS r
1.
Persons Contacted
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Licensee Employees
- R. Bayne, Chemistry and Environmental Supervisor E. Carmack, Unit Supervisor E. Dennis, Emergency Planning Technician
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- S. Fulmer, Supervisor - Safety Audit and Engineering Review
- R. Hill, Assistant General Manager - Operations
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- J. Hudspeth, Document Control Supervisor
- A.Livingston,EnvironmentalSupervisor(Acting)
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- D Morey, General Manager - Nuclear Plant
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- C, Nesbitt, Technical Manager
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R. Orr, Shift Supervisor
- D. Tedin,. Supervisor - Technical Training
- L. Williams, Training Manager Other licensee employees contacted during this inspection included operators, security force members, technicians, and administrative personnel.
NRC Resident Inspectors
- G. Maxwell W. Miller
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- Attended exit interview 2.
EmergencyPlanandImplementingProcedures(82701)
Pursuant to 10 CFR 50.47(b)(16),10 CFR 50.54(q), and Appendix E to 10 CFR Part 50, this area was inspected to determine whether significant changes were made in the licensee's emergency )preparecness program sinceth any such changes on the overall state of emergency preparediess at the facility, and to determine whether the licensee's actions in response to actual emergencies were in accordance with the Eme' gacy Plan and its implementing procedures.
The inspector reviewed the licensee's program for making changes to the Emergency Plan and-the Emergency Implementing Procedures (EIPs).
The-inspector verified that changes to these documents were reviewed and a> proved by licensee management. A review of selected records showed that c1anges since March 1989 were submitted to *;he NRC within 30 days of the effective date, as required.
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Through review of Eniergency Plan /EIP revisions and discussions with licensee representatives, the inspector concluded that no major programmatic changes were made since the February 1989 inspection.
Numerous EIP revisions were issued during that time, primarily in an effort to refine emergency response methodology.
Revision 6 to
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FNP-0-EIP-14. "Re-entry Procedures," and Revision 28 to FNP-0-EIP-26,
"Offsite Notification," addressed the four Exercises Weaknesses identified by the NRC during the December 13, 1989 cmergency exercise. The inspector reviewed these procedures and confirmed that adequate clarifications were t
made as described in the licensee's March 15, 1990 letter responding to NRC Inspection Report Nos. 50-348/89-32 and 50-364/89-32.
The inspector reviewed the status of the licensee's compliance with the
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requirement (in Section VIII of the Emergency Plan) for an annual review of the Emergency Plan and the EIPs.
Documentation was readily available to verify that the corporate emergency p(lanning staff had performed a review of the Emergency Plan during 1989 memo dated January 4, 1990 from M. A. Treadwell to file). However, the licensec had no formal program for undertaking and documenting an annud review of the EIPs.
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inspector's request, the licensee assembled documentation which indicated that the intent of the subject requirement Lad generally been met during each of the pitst five years through a combination of (1) EIP reviews associated with NRC, audit, or critique findings; (2) inputs / suggestions from the Training Department; and (3) required biennial reviews of safety-related procedures.
The licensee planned to formalize the process of conducting and documenting the required annual reviews of the EIPs.
Since the EIPs were categorized as safety-related procedures, a safety review of each was to be conducted every 24 months in accordance with the requirements of the Operations Quality Assurance Policy Manual, procedure FNP-0-AP-1 (" Development, Review and Approval of Plant Procedures"), and the Final Safety Analysis Report.
Inspection disclosed that the licensee's tracking and recordkeeping systems relative to safety reviews of the EIPs were poor; three days were required to produce documentation which even then was incomplete.
Licensee management was informed during the exit interview that an apparent violation had been identified for failure to conduct safety reviews of four procedures (FNP-0-EIP-4, -10-15, and -17) during the past 24 months.
On April 26, 1990, licensee representatives telephonically informed the inspector that documentation of unexpired safety reviews for the EIPs in question had been discovered.
The inspector received and reviewed this documentation on May 1, 1990, and
on the same date telephonically informed the _ licensee's Technical Manager that the subject potential violation had not occurred. As a result of the above as well as the licensee's internal audit findings, a corrective action plan was being developed to improve the trecking and documentation of all safety reviews of plant procedures.
The inspector reviewed records pertaining to the two Notification of Unusual Event (NOVE) declarations which had occurred since February 1, 1989.
On November 12,1989, Unit 1 safety injection actuated on low steam-line pressure.
On March 17, 1990, as a result of heavy rains, a
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L high river level was projected to affect the plant site. In each case, the NOVE was declared promptly upon recognition that applicable classification L
criteria had been met, notification messages were completed, and all I
offsite notifications were made within one hour as required.
No violations or deviations were identified.
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Emergency Facilities. Equipment, Instrunentation, and Supplies (82701)
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Pursuant to 10 CFR 50.47(b)(8) and (9), 10 CFR 50.54(q), and Section IV.E of Appendix E to 10 CFR Part 50, this area was inspected to determine whether the licensee's emergency response facilities and other essential emergency equipmer.t. instrunentation, and supplies were maintained in a state of operational readiness, and to assess the impact of any changes.in this area upon the emerge.1cy preparedness program.
The inspector toured the licensee's emergency response facilities (ERFs),
including the Control Room, Technical Support Center (TSC), and Operations Support Center (OSC).
All facilities and emergency equipment therein appeared to be maintained in an appropriate state of readiness. According to observations by the inspector and statements by licensee representatives, no significant ERF changes were made since the last inspection.
Several minor improvements were noted in the TSC, and more were scheduled for near-term completion.
The inspector reviewed selected records of communications tests performed in accordance with Surveillance Test Procedure FNP-0-STP-60.0, " Emergency Communications Operability Tests."
The documentation indicated that problems which were ident1fied were corrected expeditiously.
Also reviewed was the system for periodically verifying operational readiness as delineated in FNP-0-EIP-16, "Emerg m y Equipment and Supplies."
Completed versions of this procedural inventory were selectively reviewed and found to have been performed as required 'during the period from the first quarter of 1989 to the first quarter of 1990.
Based upon ERF walk-downs, review of applicable portions of.the Erergency i
Plan, inspection of completed surveillance procedures, and statements by licensee reoresentatives, the inspector concluded that no-degradation of ERF capabilities had occurred since February 1989.
No violations or deviations were identified.
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4.
Organization and Management Control (82701)
Pursuant to 10 CFR 50.47(b)(1) and (16) and Section IV.A of Appendix E to 10 CFR Part 50, this area was inspected to determine the effects of any changes in the licensee's emergency response organization and/or management control systems on the emergency preparedness program, and to verify that such changes were properly factored into the Emergency Plan l
and EIPs.
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The organization and management of the emergency preparedness program were i
reviewed and discussed with licensee representatives. As was the case in February 1989 when this programmatic elenent was last formally reviewed, the Chemistry Foreman was serving in the additional role of acting Environmental Superviscr.
The individual permanently assigned as Environmental Supervisor (the position responsible for the daily administration of the emergency preparedness program) was expected to be
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undergoing Senior Reactor Operator training until approximately May 1991.
The acting Environmental Supervisor had been provideo formal training]
through attendance at an INPO [ Institute for Nuclear Power Operations course on emergency preparedness, and stated that approximately 80 percent of his working hours were devoted to emergency planning.
In consideration of the additional assistance provided by a technician working full-time in this area, the inspector concluded that adequate personnel resources were being allocated to the maintenance of the licensee's emergency response capability.
Availability of off-shift personnel to staff the TSC following an emergency declaration at Alert or higher was tested by means of unannounced drills, in accordance with Section 5.2.6 of procedure FNP-0-EIP-15, " Emergency Drills."
Off-hour drills (limited to pager or telephone contact and indication of persor.nel availability) were conducted on September 27, October 18, October 31, and November 17, 1989, and on February 1 and March-3, 1990.
As a result of various problems disclosed during these drills, the licensee was investigating options for expediting the callout process, including automated notification systems.
In addition to these augmentation drills, the licensee conducted one practice exercist with each of the three "on-call"~ TSC crews during February-March 1990.
Each of these unannounced exercises began at about 5:00 a.m.
and. involved real-time activation of the TSC staff, thus further testing the licensee's capability to augment the onsite emergency response organization.
In all of the drills cited in this paragraph, the actual or projected time required to staff the TSC was within the two-hour limit specified in the Emergency Plan.
No violations or deviations were identified.
5.
Training (82701)
Pursuant to 10 CFR 50.47(b)(2) and (15),Section IV.F of Appendix E to 10 CFR Part 50, and Section VIII of the Emergency Plan, this area was -
inspected to determine whether the licensee's key emergency response personnel were properly trained and understood their emergency responsibilities.
The inspector reviewed documentation of the emergency response training program, including training procedures and selected lesson plans, and l'
interviewed members of the instructional staff.
Based on these reviews l
and interviews, the inspector determined that the licensee had established a formal emergency training program.
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Records of training for selected key members of the emergency response
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organization were reviewed.
The training records revealed that assigned personnel, including some designated as alternates, were provided with training which was appropriate, in terms of content and frequency, and consistent with applicable requirements.
In an effort to gauge the effectiveness of the emergency response trainin
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program, the-inspector conducted an interview (approximately 90 minutes)g
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with one Shift Supervisor, the position designated as interim Emergency Director (until relieved by the General Manager or alternate).
The
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interview examined the Shift Supervisor's general knowledge of emergency
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response methodology is well as his specific understanding of such matters
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as emergency classification, onsite and offsite protective actions,
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notification, and nondelegable responsibilities of the Emergency Director.
The interviewee was given sets of hypothetical emergency conditions and was asked to talk through the response he would give as Emergency Director
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under such conditions.
The interviewee demonstrated a good understanding
of the general concepts as well as the specifics of the emergency response program.
No significant problems were identified during this interview.
In a letter dated March 15, 1990 responding to NRC Inspection Report
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Nos. 50-348/89-32 and 50-364/89-32, the licensee described completed and
planned corrective actions for the four Exercise Weaknesses identified in
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the referenced report.
The inspector queried licensee representatives
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regarding the implementation of these corrective actioiis, and reviewed relevant documentation.
During February-March 1990, one tabletop drill and one operational drill were conducted for each of the three "on-call"
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TSC crews.
Each of these drills lasted 4-5 hours and involved 15-20 players.
Various personnel and hardware performance prob 1 cms were identified during these drills, resulting in further changes in emergency response training, EIPs, and supportive equipment.
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No violations or deviations were identified.
6.
IndependentReviews/ Audits (82701)
l Pursuant to 10 CFR 50.47(b)(14) and (16) and 10 CFR 50.54(t), this area was inspected to determine whether the licensee had performed ae
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independent review or audit of the emergency preparedness program, and whether the licensee had a corrective action system for deficiencies and weaknesses identified'during exercises and drills.
Records showed that an independent audit of the program was conducted by the Safety Audit and Engineering Review group during the period November 11, 1989 to January 31, 1990, and was documented in Report t
No. 90/04, dated February 7, 1990.
The inspector determined that
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the audit had been thorough, based on review of the very extensive checklist that had been employed by the auditors.
The audit produced seven " comments" but no noncompliances.
The checklist indicated that an evaluation of State and local government interfaces with the licensee was
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L The licensee's program for follow-up action on findings from audits,
drills, exercises, and NRC inspections was reviewed.
The 11ceasee had F
established a computerized tracking system called the Emergency planning Punch List as a tool for managing the follow-up actions taken in response i
to the subject findings.
Each tracked finding was prioritind for completion on a scale of 1 to S.
It appeared that this system functioned effectively, and that appropriate corrective actions were being s
k implemented in a timely manner.
The inspector noted the inclusion on the L
Punch List of 81 items from the licensee's critique of the December 1989 l
exercise, indicating thorough documentation of that critique.
L No violations or deviations were identified.
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7.
NRCInformationNotices(92701)
The inspector determined that the following NRC Information Notices (ins)
were received by the licensee, reviewed for applicability, and distributed to cognizant personnel, and that corrective actions, as appropriate, were completed or scheduled:
Failure of Licensed Senior Operators to Classify Emergency Events Properly
Event Notification Worksheets
Kr-85 Hazards from Decayed Fuel 8.
ActiononPreviousInspectionFindings(92701)
a.
(Closed) Inspector Follow-up Item (IFI) 50-348, 50-364/88-30-02:
I Clarifying procedure and aroviding staff training in use of Control t
Room seismic-detection ' nstrumentation for quantification and i
classification of seismic activity.
Classification -criteria were clarified in Abnormal Operating Procedure A0P-20.0, " Seismic Event" (Revision 5, dated February 8, 1990, was reviewed).- and in the emergency classification summary i
found in FNP-0-EIP-9,
" Radiation Exposure Estimation and
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Classification of Emergencies" (Revision 26, dated November 17, 1989).
Appropriate training to address this IFI was provided during
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the 1989 Operator License Retraining, according to the inspector's
review of lesson plans and objectives.
b.
(Closed) IFI 50-348,50-364/88-30-07:
Reviewing the calculational basis i
for the conversion of mR/hr to mci /cc for the Eberline monitors ISB, 150, and 60A-D.
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The licensee provided documentation of the subject review in the form of correspondence from the contractor (Bechtel Power Corporation)
dated January 13, 1989 and March 1, 1989.
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_ Closed) IFI 50-348, 50-364/88-30-08:
Reviewing the atmospheric l
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transport / dispersion portion of the licensee's dose assessment model.
The inspector reviewed a 1985 Dose Assessment Intercomparison Study I
involving the licensee and the States of Alabama and Georgia. This
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study was performed in part to address the subject IFI; the results showed reasonable consistency among the three models. The referenced
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document apparently was not available to the NRC inspector at the time the subject IFI was opened.
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(Closed)IFI 50-348, 50-364/89-01-01:
Revising the Emergency Plan and
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EIPs to specify that the TSC will be fully staffed and operational within one hour af ter activation is ordered.
Licensee management decided against changing their commitment regarding staffing of the TSC. (See Paragraph 9 for further discussion.)
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(Closed)IFI 50-348, 50-364/89-01-02:
Development of a surveillance procedure for the PA speakers to ensure the audibility of the Plant
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Emergency Alarm.
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The licensee revised the surveillance procedures (FNP-0-STP-60.4 through -60.10) for the purple visual beacons to include checks of the PA speakers located in the areas covered by the beacons.
This approach essentially checked only PA speakers in high-noise areas, but the licensee had decided against the notion of including all l
plant PA speakers in a formal surveillance program.
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[The next four items are discussed collectively following their listing:]
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(Closed) Exercise Weakness 50-348, 50-364/89-32-02:
Failure to make offsite notifications of emergency declarations in a manner consistent with procedure FNP-0-EIP-26.
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(Closed) Exercise Weakness 50-348,50-364/89-32-03:
Failure to brief, control, and track two of seven reentry teams as specified by
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procedure FNP-0-EIP-14.
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(Closed) Exercise Weakness 50-348, 50-364/89-32-05:
Fa11ure to provide adequate means for reentry teams to communicate with.the TSC.
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(Closed) Exercise Weakness 50-348, 50-364/89-32-06:
Failure to provide a timely and a?propriate protective action recommendation to
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cognizant offsite aut aorities following the General Emergency
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declaration.
Inspection disclosed that the licensee vigorously pursued corrective
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actions for the four Exercise Weaknesses listed above.
The specific i
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bases for closure of these items are discussed in Paragraphs 2 and 5, l
above.
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Exit' Interview i;
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The inspection scope and results were summarized on April 20, 1990, with; those persons indicated in Paragraph 1.
The inspector described the areas b'
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Nine previous
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p Plant man 6gement was informed that closure of IFI 89-01-01.(s ee
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Paragraph 8.d) should not be construed as representing the NRC's b
unequivocal concurrence in the licensee's commitment to staffing of L
emergency response facilities.
Although proprietary information was reviewed during this inspection, none is contained in this report, On May 1, 1990, : the inspector telephonically inforned a licensee e-
- management representative that a potential violation discussed during the exit interview had not in fact occurred (see Paragraph 2 for details).
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