IR 05000352/1989011
| ML20245H703 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/19/1989 |
| From: | Conklin C, Lazarus W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20245H694 | List: |
| References | |
| 50-352-89-11, 50-353-89-17, NUDOCS 8906300058 | |
| Download: ML20245H703 (7) | |
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V. S. NUCLEAR REGULATORY COMMISSION
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REGION I
Report Nos:
50-352/89-11 50-353/89-17 Docket Nos:
50-352 50-353 License Nos:
NPF-39 Priority Category C CPPR-107 Licensee:
Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name:
Limerick Generatina Station. Units 1 and 2
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Inspection At:
Limerick. Pennsylvania
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Inspection Conducted:
May 22-26 and June 7. 1989
Inspector:
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CrapnkllD) Senior Enfergency date Preparedness Specialist, DRSS Craig Gordon, Emergency Preparedness Specialist, DRSS Michael Stein, Sonalyst nc.
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Approved By:
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7 William Lazaqq #Ch M U Emergency date Preparedness Section, FRSSB, DRSS
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Inspection Summary:
Inspection on May 22-26 and June 7. 1989. (Combined Inspection Reoort Nos. 50-352/89-11 and 50-353/89-17)
Areas Inspected:
A routine, announced emergency preparedness inspection was conducted at the Limerick Generating Station.
The inspection areas included:
Changes to the Emergency Preparedness Program; Emergency Facilities, Equipment, Instrumentation, and Supplies; Organization and Management Control; Knowledge and Performance of Duties (Training); Independent Reviews / Audits; and Licensee Actions on Previously Identified Findings.
Results_;_ Two apparent violations of NRC regulations were identified.
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first violation relates to 10 CFR 50.54(q) and concerns the licensee's inability to maintain an effective emergency response capability, specifically i
regarding the classification of emergency and protective action recommendations.
The second violation relates to 10 CFR 50, Appendix B requirements and reflects the licensee's continued inability to take appropriate corrective action on program deficiencies.
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DETAILS 1.0 Persons Contacted The following licensee representatives attended the exit meeting held on r
May 25, 1989.
J. Doering, Superintendent - Operations i
G. Leitch, Vice President - Limerick D. Helwig, General Manager, Nuclear Servir.es Department j
E. Fogarty, Manager, Nuclear Support i
F. Weigand, Director of Emergency Preparedness J. King, Support Manager
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M. Roache, Site Emergency Planning Coordinator B. Allshouse, Superintendent - Administration T. Dougherty, Superintendent - Services Training J. Burke, Senior Auditor, Nuclear Quality Assurance The inspector also interviewed and observed the activities of other licensee personnel.
2.0 Operational Status of the Emeraency Preparedness Proaram 2.1 Chanaes to the Emeraency Preparedness Proaram No major changes were noted in the emergency plan or implementing procedures since the last inspection.
Changes that have been made received proper management and Plant Operations Review Committee (PORC) review prior to implementation.
i Several inconsistencies were noted within the emergency plan regarding the Emergency Response Organization (ER0).
Section 5 of the plan describes the ERO and delineates key responsibilities.
Appendix I-l compares the ER0 to NUREG-0654, Table B-1.
Implementing Procedure EPP-291, " Staffing Augmentation", and other procedures establish the staff augmentation process. The ERO is adequately described within these sections and procedures, however
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they do not all agree. The licensee has agreed to review this area and correct the inconsistencies.
It is not clear that the current document control process is sufficiently detailed regarding emergency preparedness documents.
A controlled copy of the Emergency Plan, located in the TSC, was found to have several pages, as well as a major section, missing.
Additionally, several procedures and accompanying forms that are contained in various emergency kits were found to be out of date.
The licensee agreed to evaluate this area. This item is unresolved and will be reviewed in a subsequent inspection (UNR 50-352/89-11-02 and 50-353/89-17-02).
Except as noted above, this area is acceptabl __ __
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2.2 Emeraency Facilities. Eauioment. Instrumentation and Sucolies i
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The inspector toured the Technical Support Center (TSC),
Operations Support Center (OSC) and Emergency Operations Facility l
(E0F). These facilities were adequate to support emergency response and were generally in agreement with the Emergency Plan j
and IPs.
Surveillance Tests (ST) for checks of equipment and i
supplies revealed that the equipment was regularly. inventoried.
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The STs were comprehensive and appeared to be well conducted,
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j however two areas of concern were noted.
The STs apparently did
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not properly address controlled copies of implementing procedures
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and forms as several were found out of date (See section 2.1).
Additionally, instruments in the OSC kits were found to be out of calibration.
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The inspector also reviewed the activation of the TSC with special emphasis on the Emergency Response Facility (ERF) ventilation system in place to meet the NUREG 0737, Supp. 1, habitability
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commitments. The system was placed in operation in accordance with EPP-201, TSC Activation. The on-shift I&C' technician was able to start up the system and verify correct operation of the system.
The inspector noted that the I&C technician utilized an uncontrolled out of date training procedure to activate the TSC rather than EPP-201. This resulted in the Unit 2 Emergency Response Facility Data Systems not being activated.
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technician indicated that he had received training on this procedure but had not received any on-the-job training for this function.
Further investigation revealed that use of uncontrolled procedures had been previously identified by the licensee and that
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corrective actions were taken and documented.
(See section 2.5 l
for further details)
Except as noted above, this area is acceptable.
2.3 Organization and Manaaement Control The inspector reviewed the Emergency Response Organization (ER0).
It was determined that the licensee had sufficient personnel to staff all ERO positions with one notable exception.
The TSC/E0F-l Dose Assessment Team Leader had only two members for each facility.
The licensee has agreed to evaluate this area.
The inspector reviewed the normal staffing organization as it pertains to emergency preparedness. The Site Emergency Preparedness Coordinator (SEPC) reports through the Superintendent-Administration, the Support Manager, and the Vice President - Limerick to the Senior Vice President.
The Corporate Director, Emergency Preparedness reports through the Manager, Nuclear Support, the General Manager - Nuclear Service Department and the Vice President - Nuclear Services to the Senior Vice President.
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The' Emergency Plan does not define which elements of the organization will perform specific emergency preparedness functions (site or corporate). The SEPC.had a job description, but it was general'in nature.
Nuclear. Group Administrative.
Procedures (NGAPs) have been developed that provide for a division of responsibilities between corporate and site, but these were also general in nature.
NGAPs which provide detailed plan elements and responsibilities have not been developed.
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Consequently, many plan elements have been performed mostly
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because of individual effort, without detailed guidance.
The
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Director, Emergency Preparedness had been' assigned the task of'_
l defining the program and plan elements, but has not. completed this
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task..These are issues that have been repeatedly identified by licensee reports, contractor reports and NRC Inspection Reports
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for several years.
Lack of program direction was compounded by a
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lack of personnel resources ~on-site.
Site _and Corporate j
management should have been aware of these issues and the.
i progress,'or lack of progress, in resolving them. This is an j
apparent violation (see section 2.5 for further details).
2.4 Knowledae and Performance of Duties (Traininal The inspector verified that training for the ERO has been conducted. Training was current -for most members of the ERO. The emergency plan describes the training program in very basic terms at best.
Training modules have been developed specific.to ERO positions,.however, it was not clear what criteria are expected to be met. ~ Qualification criteria for key response functions were very lenient in that ERO personnel only need to take classroom-instruction and perform a read and sign of implementing procedures.
There was no provision to conduct performance based training, such as walk through or tabletop sessions, to demonstrate training effectiveness. The Training Department scheduled all emergency preparedness training.
However, there was no apparent management directive concerning requirements for training attendance.
This has resulted in problems with maintaining qualified ERO personnel as well as'with actual attendance at training sessions. At the time of this inspection the completed training records could not be audited.
Current records were immediately forwarded for entry into the Nuclear Records Data System (NRDS), but this system has an extensive
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backlog (approximately one year), resulting in a large number of
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records in storage with no reasonable method of retrieval.
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Selected groups and key ERO positions were given postulated walk through scenarios by the NRC inspectors to ascertain training effectiveness, particularly for severe accidents and rapidly escalating accidents. The major areas assessed were:
the ability
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of the Interim Emergency Director (Shift Superintendent) to
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recognize initiating conditions requiring entry into the emergency
plan and to correlate the initiating conditions with the
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appropriate emergency classification level; the ability of the
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Interim Emergency Director and Emergency Director to recognize conditions requiring escalation and to upgrade the emergency classification level as appropriate; the ability to provide appropriate protective action recommendations (PARS) in a timely manner; the implementation and use of procedures for event mitigation: the dose assessment capability of the control room shift and-TSC dose assessment personnel; and the ability to make i;
the required off-site notifications.
The personnel being
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evaluated were given data such as equipment failures and changes I
in key parameters to stimulate actions. When decisions required
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information that would be normally available, the information was l
provided by the evaluator. Walk-throughs were given to:
five control room shifts, with each shift including the Shift Superintendent, Shift Supervisor, Control Operator and Shift Technical Advisor; one Dose Assessment Team Leader (DATL); two Emergency Directors; two Recovery Managers; and one Personnel Safety Team Leader.
The inspector concluded that training was not effective based upon the following results.
The Interim Emergency Directors, as a group, could not reliably escalate emergency classifications during a fast breaking severe accident. The personnel in the DATL position were not all qualified, either through training or experience, to evaluate PARS based upon plant conditions.
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was a lack of understanding of the correlation between emergency classification levels and PARS. When identifying PARS, emphasis was heavily weighted towards radiological consequences without consideration of existing plant conditions.
Based upon these findings, the inspector determined that the licensee could not properly classify certain types of accidents and make appropriate PARS.
This is an apparent Violation of 10 CFR 50.54(q), which requires a licensee to follow and maintain in effect emergency plans which meet the requirements of 10 CFR 50.47(b) (VIO 50-352/89-11-01 and 50-353/89-17-01).
These areas were discussed with the licensee, and management made the following commitments at the exit meeting to correct this weakness.
Beginning on May 25, 1989, remedial emergency response training will be conducted for each shift.
Each shift will not be allowed to assume the shift before successfully completing this training.
For the shift manning the control room at the time of the exit, an ED and DATL, deemed proficient based upon the walk through, will be present until all remedial training is accomplished.
Additionally, table-top trtining sessions will be conducted for all shifts in the areas of classification and dose assessment within two weeks. After these efforts are complete, I
the licensee will perform a comprehensive evaluation of the identified problems and provide corrective actions to prevent recurrence. This commitment was documented in a letter to the NRC
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on May 26, 1989.
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On May:26, 1989 the Senior Resident: Inspector for Limerick audited
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.a: training session for shift. personnel. The inspector concluded that the content of this. training, as well as personnel
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performance was. acceptable and met the intent of the above referenced commitment letter.
On ' June.7,1989, the inspector audited a table-top training.
session' for shift personnel, as well.as. for an ED.and Recovery
' Manager..This. training content was appropriate and was well conducted and received.
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'Indeoe'ndent Reviews / Audits
The 1988 Nuclear Quality Assurance (NQA) 50.54(t) audit was quite.
detailed and thorough...The report identified. several major areas of concern.
It was noted that the audit was. approved by the Nuclear Review Board and received extensive management -
distribution..
The report contained a'. recommendation regarding insufficient-staffing to accomplish the site emergency preparedness functions.
The report went on'to: state that. management and administrative-controls did not ensure the quality and readiness.of the program.
It stated this was an identified SALP concern.
Specific areas cited included:
-. lack of on-site emergency preparedness' staff;
- lack of.an emergency preparedness task analysis;
- the quality of the. drill program;
-- the quality of the training program; and
--the. direction and control of the problem.
These findings indicated potential programmatic breakdown in emergency preparedness and were consistent with past audits and-NRC' inspection findings. Yet the report did not classify these
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issues and determined that the EP program was acceptable. ' There was no apparent attempt to compare these findings.to past-findings. There was no evidence to indicate that management-understood the significance of this report. This area was
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addressed.in Inspection Report No. 50-352/88-01 and resulted in
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issuance of a Notice of Violation due to deficiencies that were
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recurrent or not properly addressed. The' licensee's response of
April.4, 1988 indicated that this violation had been corrected.
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'During this inspection it was determined that these problems
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has resulted in a decrease in the effectiveness of the emergency L
preparedness program as indicated by training performance. This
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is an apparent violation of 10 CFR 50, Appendix B, which requires V
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that measures be established to assure that conditions adverse to quality, such as deficiencies are promptly identified and corrected (VIO 50-352/89-11-02 and 50-353/89-17-02).
The inspector reviewed the drill and exercise program.
Drills and exercises were performed as specified in the emergency plan.
i Surveillance Tests were utilized to document findings and j
management was made aware of the findings. The Action Item System was utilized to track corrective actions. A review of drill
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j critiques revealed that many problems recurred in each drill. A review of the Action Item system revealed that each time the Q
problem was identified, it was corrected. However, recurrent, j
similar problems indicate that root causes were not properly
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addressed and it appeared that they had not been recognized.
l Special drills were performed for site evacuation and staff augmentation. The evacuation drills indicate that many problems existed in accountability following site evacuation.
An augmentation drill conducted by the licensee during the inspection was poorly conceived in that it addressed only a portion of the 60-minute responders in the plan.
Of those that responded, the majority did not meet the 60-minute goal.
It was not recognized by the staff that this performance was indicative of a problem in this area.
3.0 Exit Meetina The inspector met with licensee personnel denoted in Section 1 at the conclusion of the inspection to discuss the scope and findings of this I
inspection as detailed in this report.
In summary, independent reviews, NRC inspections and internal licensee staff have repeatedly identified weaknesses in the licensee's emergency preparedness program. These weaknesses appear to be a direct result of lack of program definition and allocation of responsibilities, and management control of these activities. The licensee was informed that two apparent violations existed (see details 2.4 and 2.5).
The licensee acknowledged these findings and agreed to evaluate them and institute corrective actions as appropriate. Additionally, the licensee presented immediate, short term corrective actions as a result of this inspection.
These actions were verbally concurred upon by NRC Region I management.
Subsequent to the meeting, these commitments were transmitted to the NRC by a May 26, 1989 letter.
At no time during this inspection did the inspector provide any written information to the licensee.
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