IR 05000348/1993010
| ML20045E539 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 06/07/1993 |
| From: | Barr K, Kreh J, Sartor W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20045E520 | List: |
| References | |
| 50-348-93-10, 50-364-93-10, NUDOCS 9307020181 | |
| Download: ML20045E539 (10) | |
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Q 8'4 UNITED SVATES
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' -4'og h!UCLEAR REGULATORY CONLMisslON o
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j 101 MARiETTA STREET, N.W.
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ATLANTA, GEORGI A 30323
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JUN 0 81993 Report Nos.:
50-348/93-10 and 50-364/93-10 Licensee: Alabama Power Company P. O. Box 1295 Birmingham, AL 35201 Docket Nos.: 50-348 and 50-364 License Nos.:
Facility Name:
Farley' Nuclear Plant Inspection Co ducted: May 10-14 19 3 Inspectors:
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_. Kreh, R,adiation Specialist Date Signed
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W. M. Sartor, Seritor Radiation Specialist Date Signed 7/73 Approved by:
ws K./P.'BarP, Thief Date Signed Emergency Preparedness Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards SUMMARY Scope:
This special, announced inspection was conducted to assess selected areas of-
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the licensee's emergency preparedness program and response capability as follows: (1) emergency detection and classification, (2) protective action decision-making, (3) notifications and communications, (4) shift staffing and -
off-hour augmentation, and (5) training.
In addition, a " work-in-progress" assessment was made of the licensee's ongoing transition to a 75-minute staffing capability for the Technical Support Center and the Emergency Operations facility.
Results:
b In the areastinspectede no violations.or deviations were identified.
Program strengths included the emergency response training program in general, 'a demonstrated wide-ranging familiarity with emergency respense methodology by.
three Emergency Director interviewees, and management support of the emergency planning effort.
Issues discussed during the inspection included: (1) the 9307020181 930608 PDR ADOCK 05000340 i
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the intent of the Emergency Plan with respect to the conduct of off-hour exercises (Paragraph 5), and (2) the undesirability of allowing emergency response personnel to bypass classroom training each year by successfully challenging a written examinatian (Paragraph 6).
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
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J. Deavers, Senior Plant Instructor, Continuing Training D. Grissette, Shift Supervisor
- R. Hill, General Manager
- W. Lee, Emergency Planning Coordinator (Corporate)
J. McGriff, Emergency Preparedness Technician
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- C. Nesbitt, Operations Manager W. Oldfield, Shift Supervisor
- J. Osterholtz, Assistant General Manager, Plant Support
- R. Vanderbye, Emergency Preparedness Coordinator (Site)
- W. Warren, Supervisor, Technical Training
- L. Williams, Manager, Training and Emergency Preparednes's Other licensee employees contacted during this inspection included operators, security force members, technicians, and-administrative personnel.
Nuclear Regulatory Commission
- G. Maxwell, Senior Resident Inspector
- Attended exit interview on May 14, 1993 Abbreviations used throughout this report are listed in the last paragraph.
2.
Emergency Detection and Classification (82201)
The program area of Emergency Detection and Classification was inspected to determine whether the licensee used and understood a standard EAL classification scheme.
Requirements _ applicable to this area _ are found in 10 CFR 50.47(b)(4), Sections IV.B and IV.C of Appendix E to 10 CFR Part 50, and the licensee's Emergency Plan. The edition of the Emergency Plan in effect at the time of the current inspt.ction was Revision 24, dated March 10, 1993.
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The inspector reviewed the licensee's event classification methodology l
as found in Section IV.A of the Emergency Plan and in procedure FNP-0-EIP-9, " Radiation Exposure Estimation and Classification of Emergencies," Revision-34.
Selected EAls-were-reviewed and found to be
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consistent with NRC guidance contained in Appendix 1 to NUREG-0654.
Although the two referenced licensee documents presented the EAL scheme in significantly different formats, no discrepancies in content were identified. This review determined that 'he classification scheme did_
not contain impediments or errors which could lead to incorrect or untimely classification of emergency conditions.
The inspector-noted that many of the EAls were appropriately based on parameters obtainable from Control Room instrumentation.
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The authority and responsibility for the classification of emergency events and the initiation of emergency actions were delineated in Section II.A of the Emergency Plan and in FNP-0-EIP-3, " Duties of the Emergency Director."
Interviews with three individuals who could assume the role of Emergency Director disclosed that each understood his defined role, including his authority and responsibility with respect to event classification.
During these evaluations, all of the interviewees showed proficiency and familiarity with the use of the classification scheme as they correctly categorized postulated accident conditions in the appropriate emergency class.
(See Paragraph 6 for details rsgarding the conduct of these interviews.)
The inspector reviewed the licensee's required coordination of EALs with State and local officials. This activity was addressed by means of individual letters to six organizations:
Dothan/ Houston County'(AL)
Emergency Management Agency, Blakely/Early County (GA) Emergency Management Agency, Alabama Emergency Management Agency, Alabama Department of Public Health, Georgia Emergency Management Agency, and Georgia Department of Natural Resources.
Each letter requested agency review and concurrence for the EALs in effect at the time, and all responses were received by the licensee during November-December 1992 without dissenting comments.
According to licensee records, no emergency declarations occurred between January 1, 1992, and the closing date of the current inspection.
No violations or deviations were identified in this program area.
3.
Protective Action Decision-Making (82202)
The program area of Protective Action Decision-Making was inspected to determine whether the licensee was maintaining a continuous capability to make appropriate recommendations to governmental officials to protect the public and to take appropriate measures to protect onsite workers in the event of an emergency.
Requirements applicable to this area are contained in 10 CFR 50.47(b)(9) and (10),Section IV.D.3 of Appendix E to 10 CFR Part 50, and the Emergency Plan.
The inspector determined through review of the Emergency Plan and EIPs that authority and responsibility for accident assessment and PAR decision-making were clearly assigned and were available on_ a continuous basis through the designation of the Unit 2 Shift Supervisor as interim ED.
Interviews with three individuals who could assume the role of ED
disclosed that these personnel understood their-authorities and responsibilities with respect to accident assessment, PARS for the
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public, and onsite protective actions. During these evaluations, all of l
the interviewees showed proficiency and familiarity with the PAR scheme t
as they identified the appropriate action to recommend to governmental l
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authorities to protect the public for each of several hypothetical situations classified at the General Emergency level.
(See Paragraph 6-for details regarding the conduct of these interviews.)
i No violations or deviations were identified in this program area.
4.
Notifications and Communications (82203)
The program area of Notifications and Communications was inspected to determine whether the licensee was maintaining a capability for notifying and communicating with plant personnel, offsite support agencies and authorities, and the population within the 10-mile EPZ.
Requirements applicable to this area are contained in 10.CFR 50.47(b)(5)
and (6),Section IV.D of Appendix E to 10 CFR Part 50, and the Emergency Plan.
The inspector reviewed the licensee's notification procedure FNP-0-EIP-8, " Emergency Communications." The referenced procedure contained the emergency notification message. form, and specified when to -
notify and activate the onsite emergency' organization, corporate support organization, and offsite agencies. The procedure was consistent with the emergency classification scheme used by the licensee. The notification methodology was consistent with the guidance in NUREG-0654,
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and provided a listing of names and telephone numbers of personnel and organizations who may need to be notified in the event of an emergency-condition.
Included as an attachment was an emergency roster call-list.
Documentation was provided to show that the' licensee was updating the plant notification roster on a quarterly basis.
Interviews with three individuals who could assume the role of Emergency Director disclosed that each understood his defined role, including his authority and responsibility, with respect to the notification of State and local governmental agencies and the NRC in the event of a declared emergency.
Interviewees were fully aware of the methodology and time limitations for accomplishing these offsite notifications.
(See Paragraph 6 for details regarding the conduct of these interviews.)
The licensee's Alert and Notification System consisted of three fixed sirens located in Alabama and approximately 2,200 tone-alert radios located at residences within the 10-mile EPZ.
The test program for each siren consisted of a weekly silent test, a quarterly growl, and an annual full cycle test. The licensee had established procedures for.
maintaining the ANS, and provided documentation to the FEMA on an annu'al-basis for-verifying ANS operability requirements.
The inspector conducted operability tests of selected ERF communications systems and found them to be fully functional. The inspector also observed a retest of the Unit 1 ERDS on May 14 following an' unsuccessful result from the first required quarterly test during the previous wee.
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Licensee personnel successfully conducted this test in accordance with FNP-0-STP-60.12, " Emergency Response Data System (ERDS) Operability Test," Revision 1, dated May 14, 1993.
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No violations or deviations were identified in this program area.
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Shift Staffing and Augmentation (82205)
t The program area of Shift Staffing and Augmentation was inspected to determine whether shift staffing for emergencies was adequate both in numbers and in functional capability, and whether administrative and
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physical means were available and maintained to augment the emergency.
organization in a timely manner.
Requirements applicable to this area are contained in 10 CFR 50.47(b)(2), Sections IV.A and IV.C of Appendix E to 10 CFR Part 50 and the Emergency' Plan.
The inspector reviewed Table 3 of the Emergency Plan, which delineated the licensee's staffing requirements for the TSC and EOF.
In terms of numbers of personnel and their designated areas of expertise (but not staffing times--see below), the listed capabilities for augmenting the shift staff were consistent with NRC guidance found in Table 2 of-i Supplement I to NUREG-0737. The licensee used an "on-call" roster which.
entailed weekly rotation of assigned crews and required designated individuals to be readily available and fit for duty. The primary method for notifying ERO personnel was an automated radio paging system known as the Community Alert Network. This computer-driven system selectively activated pagers and accepted telephonic feedback from page recipients until each ERO position was fill'd. The standard telephone system served as backup for off-hour notif' ation of the ERO.
The inspector reviewed the licensee's strategy for ensuring compliance with the Emergency Plan requirements addressing the planning standard of 10 CFR 50.47(b)(2), which specifies that " timely augmentation of
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response capabilities is available." The applicable Emergency Plan requirements were contained in Section V, which indicated that the TSC and EOF were to be staffed within two and four hours, respectively (the-OSC was staffed with on-shift personnel). Since the last quarter of 1992, the licensee has been conducting quarterly drills in which TSC personnel respond to the CAN page by telephoning a designated number to report their availability (no actual travel to the plant). These drills have been conducted using varied days and times', including a Saturday
evening and a Sunday afternoon. The most recent was held on Thursday, April 1, 1993 starting at 5:30 p.m.
The data for this drill indicated-that the estimated staffing-time-for-the TSC-and OSC was 79 minutes.
- Although some additional time would be needed to achieve facility activation following the arrival of personnel, the.above data suggest that the licensee would have been able to meet the previously stated staffing requirements if actual ERO augmentation had been necessary at the time of the drill. The EPC informed the inspector that the goal for these ER0 drills would be ta consistently achieve a staffing time of 75 minutes beginning in June 1993. Staffing of the E0F from the corporate offices in Birmingham has been tested as a component of the
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last several annual exercises by means of real-time deployment of personnel using surface and/or air transportation.. Although the
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capability of staffing the EOF within four hours has been demonstrated, these tests have consistently been announced in advance, have been conducted during regular working hours, and have involved carefully prearranged transportation.
As suggested previously in this paragraph, the licensee's current commitment to staff the TSC and E0F within two and four hours, respectively, was not consistent with NRC guidance. This issue has been the subject of ongoing discussions and meetings between the. licensee and the NRC for several years, and was preliminarily resolved in August 1992
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with the issuance of a written commitment by the licensee to revise the
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Emergency Plan and EIPs such that the TSC and E0F would be staffed by plant personnel within approximately 75 minutes after the declaration of an emergency warranting ERF activation. The licensee proposed to complete the development and implementation of this revised staffing
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methodology by October 1, 1993. The inspector discussed the progress of
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this effort with cognizant licensee representatives and concluded that the licensee could be expected to meet the goals outlined above.
During an inspection in August 1992, the issue of unannounced, off-hour exercises.was raised with licensee representatives, and the matter was tracked as an IFI (see Paragraph 7).
It was noted that Section VIII.A of the Emergency Plan specified that "one exercise may be performed every six (6) years which is unannounced, except as required for effective coordination with the management of the various agencies and for the evaluation of the health and safety of the general public." The Emergency Plan " commitment" expresses an intent to conduct an unannounced exercise from time to time, but this intent has not thus far been fulfilled.
Through an apparent misunderstanding during that previous inspection, the licensee did not realize that the inspector was referring to an " exercise" as strictly the annual, required, NRC-evaluated function as delineated in Section VIII.A.1 of the Plan. The licensee was including various nonrequired practice drills and exercise
" dress rehearsals" within the definition of " exercise".
Following discussions during the current inspection, licensee management stated-they would conduct a practice exercise (which the NRC would be invited to evaluate) prior to the end of 1993 on an unannounced, off-hour basis, and would consider meeting the intent of the Emergency Plan in the future by conducting the annual exercise every several years as an
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unannounced, off-hours function. The subject IFI will remain open, as indicated in Paragraph 7.
No violations or deviations were identified in this program area.
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6.
Knowledge and Performance of Duties (Training) (82206)
The program area of Knowledge and Performance of Duties (Training) was-inspected to determine whether the licensee's key emergency response personnel were properly trained and understood their emergency responsibilities.
Requirements applicable to this area are contained in 10 CFR 50.47(b)(2) and (15),Section IV.E of Appendix E to 10 CFR Part 50, and the Emergency Plan.
The training program for ERO personnel, as delineated ir.Section VIII.B of the Emergency Plan, was implemented by means of Training Center Procedure FNP-0-TCP-17.14, " Emergency Plan Training Administration" (Revision 3, issued May 14,1993). A governing document, FNP-0-AP-45,
"Farley Nuclear Plant Training Plan," was also applicable to ERO training. FNP-0-TCP-17.14 contained a matrix which defined the specific training requirements for each ERO position at the Farley facility. The inspector conducted a review to determine whether individuals were being trained in accordance with the referenced requirements. Names of.
15 individuals designated for key positions in the ERO were selected from the "On-Call Schedule" in effect during the week of the inspection, and their computer-based training records were reviewed against FNP-0-TCP-17.14 requirements. This review disclosed no discrepancies.
The inspector also reviewed the licensee's training objectives and lesson plans used to initially qualify and requalify individuals for three key ERO positions. The objectives associated with the respective lesson plans were coherent and suggested a logical and comprehensive instructional approach.
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Training of Radiation Monitoring Team members was reviewed in detail, including an audit of the respective examination records that supported the individual qualifications of several randomly selected personnel.
The lesson plans for this block of instruction were comprehensive, the examinations were challenging, and personnel performance on the examinations was of the highest standard. All aspects of this training module were determined to be excellent.
The inspector also noted that the " Emergency Response to Radiological Accidents" training for the staff of the Southeast Alabama Medical Center was given on numerous occasions (including day and night shifts) during July and August 1992 to a total of more than 300 employees.
In an effort to gauge the effectiveness of the emergency response training program, the inspector conducted separate interviews with three individuals who could serve as ED. The purpose of this interview process-was to-ascertain the-potential-ED's understanding of emergency
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classification, offsite notifications, protective action recommendations L
(PARS), site evacuation, emergency worker dose limits, and nondelegable responsibilities of the ED.
Each interview (60-75 minutes in duration)
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began with technical questions relating to the duties, responsibilities,.
and functions of the ED during an emergency situation, and then
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presented several accident scenarios that required event classification j
and PAR formulation, as appropriate. The inspector delineated the guidelines for the interview at the outset, including the "open book"
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nature of the evaluation.
The EPC was present during each of the interviews to allow for confirmation and firsthand understanding of observations.
Each interviewee was judged to have demonstrated comprehensive understanding of the ED duties and responsibilities in the event of an emergency. All emergency classifications and PARS were timely and correct. No problems were identified during these interviews.
The inspector reviewed the licensee's assessment and documentation of ERO performance during the emergency response training drills conducted since the last NRC inspection of this program area in August 1992. Some of these drills were not specifically required by the Emergency-Plan, but rather were conducted in order to ensure maintenance of~an adequate level of ERO response capability in the event of an actual emergency.
The documentation of each drill included a list of objectives, scenario, summary of drill events, and critique items. The inspector determined that the drill critiques identified substantive issues for corrective action and that the licensee was either monitoring the status and progress of such planned corrective actions or had completed same. The inspector reviewed the critique records for indications of repetitive performance problems during the period in question.
No' adverse trends were identified.
This schedule of training drills suggested a significant level of dedication of the licensee's resources to maintaining and improving emergency response capabilities, and was considered indicative of plant management's commitment to the emergency preparedness program. One example of particular note in support of this conclusion was the training exercisc conducted on September 15, 1992.
In addition to the usual ERO activation, the exercise included objectives for the annual medical emergency / health physics drill and full activation and operation of the Alternate EOF in Headland, AL. The licensee critique concluded that all objectives were met and identified several enhancement items.
The inspector reviewed the licensee's follow-up of an issue raised during a February 1992 inspection, tracked as an IFI (348,364/92-07-01), and subsequently closed.
This issue concerned the provision in FNP-0-AP-45 allowing ERO personnel, including designated EDs, to challenge an examination in lieu of attendance at annual classroom training for emergency responders.
Closure of this IFI during
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an August 1992 inspection was based upon the issuance of a. memorandum from the Plant General Manager which specified that personnel designated for ED training were expected to attend ED retraining sessions.
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directive had-not been established permanently by incorporation in
FNP-0-TCP-17.14 or any other procedure. A revision of FNP-0-TCP-17.14, presented to the inspector just prior to the exit interview, added a requirement that designated on-call EDs must attend ED classroom retraining.
Further discussion of this matter during the exit interview resulted in Revision 3 (issued May 20, 1993) to FNP-0-TCP-17.14, which
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I broadened the training requirement to specify that all on-call personnel who serve in emergency response positions must attend Emergency Plan retraining, and that any exceptions to this requirement must be documented by the Training Manager. 'This issue is now considered fully resolved.
No violations or deviations were identified in this program area.
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Licensee Action on Previous NRC Inspection Findings (0 pen) IFI 50-348, 50-364/92-22-01:
Conducting an unannounced exercise during calendar year 1993.
As discussed in Paragraph 5, this issue was not fully resolved, but the licensee stated they would conduct a practice exercise during 1993 which would partially satisfy the intent of the Emergency Plan with respect to unannounced, off-hour exercises.
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Exit Interview The inspection scope and results were summarized on May 14, 1993, with those persons indicated in Paragraph 1.
The inspector described the areas reviewed and discussed the inspection results in detail, including the two issues described in the " Summary" section of this report.
The first of these two issues will continue to be tracked as an.open item (as indic;ted in Paragraph 7).
The second was fully resolved by a procedural revision provided after the closing date of the inspection (see Paragraph 6). Although proprietary information was reviewed during this inspection, none is contained in this report.
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Abbreviations Used in This Report ANS Alert and Notification System CAN Community Alert Network CFR Code of Federal Regulations EAL Emergency Action Level ED Emergency Director EIP Emergency Implementing Procedure EOF Emergency Operations Facility EPC Emergency Preparedness Coordinator
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EPZ Emergency Planning Zone.
ERDS Emergency Response Data System ERF Emergency Response Facility
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-Emergency Response Organization FEMA Federal Emergency Management Agency IFI Inspector Follow-up Item NRC Nuclear Regulatory Commission OSC Operations Support Center PAR Protective Action Recommendation TSC Technical Support Center
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