IR 05000352/1990021

Insp Repts 50-352/90-21 & 50-353/90-20 on 900827-31.No Violations Noted.Major Areas Inspected:Emeergency Preparedness Program

ML20062G409
Person / Time
Site:	Limerick
Issue date:	11/15/1990
From:	Amato C, Lazarus W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20062G407	List: IR 05000352/1990021 ML20062G402
References
50-352-90-21, 50-353-90-20, NUDOCS 9011290182
Download: ML20062G409 (10)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION I

50-352/90-21 Report Nos. 50-353/90-20 50-352 De:ket No .

NPF-39'

License No NPF-85 Licensee: Philadelphia Electric Company Post Office Box-7520

, Philadelphia, Pennsylvania 19101

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Facility Name: Limerick Generating Station Inspection'At:. Chesterbrook and Pottstown, Pennsylvania .,

Inspection Conducted: August 27-31, 1990 Inspectors: - m N [

C. G.-Amdto, Regionar Team Leader, Division of n[r!fo date Radia' tion Safety and Safeguards W. Lancaster,. Region I F. Lopresti, Region I 4

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Approved by: _ /-rm

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, Wifli'am J.7aza'rus, Clifef , . Emergency date i

Prepa ddness Section, DRSS e Inspection Summary:- Inspection on Au;ust 27-31,-1990 (Combined-Inspection Report Nos. 50-352/90-21 and 50- L /90-20)

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L Areas Inspected: Announced, routine safety inspection cf the licensee's emergency preparedness-progra ;

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Results: No violations, deviations, or unresolved items wer.e identified, l

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9011290182 901119 ADOCK 05000352

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DETAILS Persons Contacted The following licensee staff members attended the entrance or exit meetings or were interviewed by the inspectors. Staff were assigned to:

Nuclear Group Headquarters (NG), the Limeri_ck Generating Station (LGS),

or PEco Headquarters (HQ).

• "C. Adams, Manager, Emergency Preparedness, NG P. Adelizzi, Senior Engineer, HQ C. Baer, Analysts, NG

"*R. Brown, Site Emergency Preparedness Supervisor, LGS '

• " Charles, Manager, Nuclear Support Division, NG

" Civientniewicz, Superintendent, Training Department LGS

" Doering, Manager,. Projects Division, LGS

• " Dougherty, Services Training Supervisor, Training Department, LGS

• " Ducca , Jr. , Support Manager, . LGS -

R. Geiger, Manager, Departmental Operations, Corporate and Public Affairs HQ R. Gill, Branch Head, Nuclear Security, LGS

"R. Gropp, Engineer, Nuclear Licensing Section, LGS A. Hill, Document Administration Center, LGS

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D. Helwig, Vice President, Nuclear Engineering and Se* vices, NG N. Kenny, Trainer, Training Department, LGS

"*R. Kinard, Off site Support Branch Lead, LGS

"C. Lauletta, Nuclear Training Supervisor, LGb G. Leitch, Vice President, LGS

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i l *R. Mandik, LGS Branch Lead, NG -

l * Roache, Peach Botton Atomic Power Station Branch Leao, "3 l W. Rogers. Emergency Preparedness Trainer, Training Department, LGS l R. Smith, Senior Vice President, NG l A. Yarmer, Simuittor Instructor, Training Department, LOS

• Denntes those staff members who attended the entrance meeting, f

• • Denotes those staff m'mbers who attended the exit meetin !

l- *" Denotes those staff metibers who attended the entrance and exit i

meeting {

A. K. Bhattaohargrra, Nuclear Engineering, Commonwealth of Pennsylvania also attended the exit meetin The inspector interviewed and observed the action of other licensee personne A d

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3 Licensee Action on Previously Identified Items The following items were identified during a previous inspection (Combined Inspection Report Nos. 50-352/89-11 and 50-353/89-17). Based on observations made by the NRC inspectors, review of the Emergency Plan and Implementing Procedures and interviews with licensee staff, these items were satisfactorily addressed by the licensee and are close (CLOSED) UNR 89-11-02 and UNR 89-17-02: Inadequate control of Emergency Plan (EP) and Emergency Plan Implementing Procedures (EPIPs). ,

A procedure to cuntrol distribution of these documents was approved June 7, 1990, entitled " Control of Procedures and Certain Documents." In addition, an individual experienced in document control was appointed as the Document Control Supervisor. This supervisor has developed a document control improvement plan which has been implemented. Following Plant Operating Review Committee approval, a chain-of-custody is established. Upon receipt at the Document Control Center (DDC), the approved procedure is logged in, administrative 1y checked, reproduced and distributed. A Procedure Change Clerk inserts the changed procedures, and date and initials a Document i Control Form which is returned to the DDC. Superseded procedures are l destroyed. Acknowledgement forms are used for off-site distributio ,

Distribution is effected in accordance with a distribution list, i (CLOSED) NDV 89-11-01 and 89-17-01: Protective Action Recommendations I (PARS) were not consistent with regulations as required by 10 CFR 50.47(b)(10) and senior operators were not trained to respond to fast-breaking accident EP-101, " Classification of Emergeticles", was approved on August 24, 199 This classification table includes for each General Emergency, a predetermined PAR of either sheltering or evacuation, as a function of distance and sector, i This format meets regulatory requirements and is consistent with the guidance !

of NUfJG-0654 which encourages the development and use of predetermined j l PARS foi rapidly-breaking accidents. Senior operators have received classroom, i table-top end simulator training in the use of this EP, including training 1

'or fast-breaXing accidents on the simulator. In addition to plant conditions, projected dose equivalent values are also used to determine a PAR and the extent of protective actio :

3, Operational Status of tne Emergency Preparedness Program 3.1 Response to Actual Situations Requiring Classification l

To determine if EP-101, " Classification of Emergencies" was adequate '

and operator training effective, the inspector reviewed the records for classification of actual events, i

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Three actual Unusual Events were declared since the last inspectio All were correctly classified and notifications made within the time limits set by regulations. Termination calls were also mad i Based on the above review, this portion of the licensee's emergency preparedness program is acceptabl ,

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3.2 Audit / Reviews 10 CFR 50.54(t) requires an audit / review at least every. twelve month Nine additional requirements are also listed in this citation. The inspector reviewed the licensee's Quality Assurance (QA) Procedures and the audit / review report were reviewed and auditor questioned by the inspector to determine if regulatory requirements were me The licensee's QA program is delineated in Technical Specification 6.5.2.8 a. Audits are based on Quality Assurance Procedure (QAP)

NQA-21 (audit techniques) and the Master Audit Plan (listing of audit items). The QAP and Master Plan were followed. An audit plan was developed, entrance and exit meetings were held, auditors were .

independent of the program audited (contractor personnel were also used), Commonwealth / local government / licensee interface adequacy was

! determined (government officials were contacted), drills were observed and NRC insp?ction procedures and INPO guidelines were consulted. QA reports are distributed to upper management who may, if needed, resolve disputed item >

Both nuclear stations (Peach Bottom and Limerick) and Nuclear Group Headquarters were audited. Attachments to' Audit Report CA 89-06 dealt with each corporate entity. The scope of the audit included elements necessary to ensure an adequate emergency preparedness program is in ,

I place. Eight program elements were audited at Limerick and eight I Corrective Action Requests issued to which the licensee responde Nine program elements were audited at Nuclear Group Headquarters including the Emergency News Center. The chief finding was that previously identified conditions adverse to quality had not been given appropriate corrective actio These deficiencies relating to the Emergency News Center were brought to the attention of the Senior Vice President, Corporate and Public Affairs. An inspection of the-Emergency News Center (ENC) and interviews by the inspector with ENC staff showed all necessary corrective actions were taken~.

l The 10 CFR 50.54(t) review was done by a contractor. The licensee / government interface was determined to be adequat Copies ,

of these reports were offered to offsite government Based on the above review, this portion of the licensee's emergency preparedness program is acceptabl '

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S 3.3 Emergency Facilities l

Emergency Response Facilities (ERFs) were inspected to determine if they were maintained in a state-of-readiness, i

The Control Room, Operations Support Center, Technical Support Center, Emergency Operations Facility and the Emergency News Center were inspecte ERFs were checked on a sampling basi Plans and procedures were current and in place.- Each facility was checked for a current copy of EP-101, " Classification of Emergencies." This Procedure was current at all ERFs. Maps, status boards, weather boards, unit disgrams and supporting documents were available. All communication systems tested, including the NRC's Emergency Notification System and Health Physics ;

Network, were functional. Facsimile machines and copiers were  ;

availabl '

Based on the above, this portion of the licensee's emergency preparedness program is acceptable,

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3.4 Knowledge and Performance of Duties (Training)

10 CFR 50.4/(b)(15) and Section IV.F. of Appendix E to 10 CFR 50 establish regulatory standards and requirements for training licensee Emergency Response Organization (ERO) members and Emergency Planning Zone (EPZ) Emergency Workers (EWs). The licensee's Limerick Generating Station's (LGS) training manual, training procedures, lesson plans ( and records were reviewed, and trainers interviewed to dete_rmine if l regulatory standards and requirements were me l I

ERO training is the responsibility of the LGS Training Department (TD). Training is given in keeping with the TDs training manua The TDs Nuclear Training Section is responsible for Emergency Preparedness Training (EPT). Two Health Physics trainers, one of  ;

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whom is a consultant, give EPT. EPT is based on task analysis. A training matrix and lesson _ plans _have been develope EPT is scheduled throughout the year on a six-week cycle. If necessary, one-on-one=

training is given to senior managers and vice presidents. A 1 computerized data base tracks ERO members requalification statu l Requalification is based on factual and written examinations, or a !

combination of these. About 500 of the LGS staff are ERO qualified, with at least four managers qualified for key ERO positions including forty Operations Support Center Coordinators. Post drill and exercise critiques are reviewed for training issue An informal, as. opposed to a formal, method' exists for the TD to receive emergency plan and j procedure changes. An EPT question bank is under development.

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Reactor Operators are trained in emergency preparedness by operator training and the Site Emergency Preparedness Supervisor, who was a '

formerly licensed Senior Reactor Operator. Operators have been trained and qualified to respond to rapidly-breaking accidents, classify and develop Protective Action Recommendations (PARS). To assist operators

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in classification, referrals to EP-101 are placed in the Trip Procedure The simulator has been programmed to replicate fast-breaking accidents taking operators into the Site Area Emergency and General-Emergency within a matter of minutes. Tabletops and lectures are also use The inspector observed a rapidly-breaking accident on the simulator and concluded.it met the intended purpose. Use of predetermined PARS, based primarily on plant conditions and secondly on projected dose values, meets regulatory requirements and is consistent with the guidance given in NUREG-065 Operators and technical staff are. trained in Core Damage Assessment and Mitigation, and Thermal-Hydraulics.. Operators.are given training in the use of: the Radiological and Meteorological Monitoring System; Emergency Response Facility. Display Systems; Accident and Transient Analysis; Damaging Operating Conditions, Hydrogen Hazards, and Lessons-Learned from TMI-2 and Chernoby ?

The responsibility for developing and implementing an Accident Manager (AM) program has been given to the Nuclear Group Headquarters Emergency preparedness Program (EPP). .AM is perceived by the licensee to include a set of guidance tables to be used by Technical Support Center (TSC)

Engineers. The tables will supplement Emergency Operating Procedure Computational aids will prompt the Emercency Directors at the TSC to ;

enter AM guidance which will identify preventive and mitigative action The licensee will draw upon the BWR Owners Group Severe Accident Evaluation Committee. The EPP has hired a mechanical engineer with Probability Risk Assessment capability to support this effor Resources from the LGS will also be use Training of Emergency Planning Zone emergency workers is in the responsibility of the EPP. This training is provided by a i contracto Over 1700 emergency workers have been trained in 129 l classe Training is offered to emergency worker staffs of the .

l-risk, impact and support centers, local governments and special '

district In order to handle rumor control, 450 PEco Customer Service representatives have been trained in-appropriate technique Based on the above, this portion of the licensee's emergency preparedness program is acceptabl '

3.5 Organizatien and Management Control

, The inspector reviewed the licensee's organization structure and control l systems to determine if the structure and controls were adequate to ensure an effective EP .

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l PECo has established a Nuclear Group headed by a Senior Vice President.

l This group consists of three departments each headed by a vice presiden ; The departments are: Limerick, Peach Bottom, and Enoineering and Srrvices. The departments are subdivided into divisions. Emergency preparedness at Group Headquarters and LGS is a Nuclear Support Division t responsibility and is one of four Division Branche Six units comprise the EPP; four of these units are located at Group Headquarters. The LGS unit is headed by a former senior reactor operator supported by an on-site staff of three. The Group units have lead responsibility for each site, off-site activities, and facilities and equipmen The total staff numbers 29, including eight at both sites. Professional disciplines include reactor operations, health physics, engineering'

and offsite planning. The inspector concluded the EPP is adequately staffed with the needed expertise to develop and maintain an effective '

operation EP Following an enforcement conference, management instituted an interim improvement program. . A root cause analysis was undertaken and based on the results of this, an Emergency Preparedness Improvement Program was developed and implemented. The seven elements of this program are listed below:

Program definition;

Emergency Preparedness drills and exercises;

Commitment tracking, including transition of action item

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tracking system into PIMS (Plant Information Monitoring System);

Medical emergency responses at Peach Bottom and Limerick, and

the accountability / evacuation process at Limerick; Emergency Response Organization (ERO) training and qualification; ,

Development of a "world class" emergency preparedness program at PECo;

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Management support of emergency preparedness initiatives.

Each of these elements were subdivided into a nuinber of specific .

objectives. An Action Plan was developed to track the progress of l the Improvement Plan. At the time of this inspection, the Plan was 70% complete Management, from the Board of Directors through first-line supervision,

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is involved in improving and maintaining EPP effectiveness. Emergency L

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preparedness concerns were called to the attention of shareholders in-

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a brief statement on Page'10 of the 1989 Annual Report. The Nuclear Committee of the Board of Directors on a number of occasions looked into emergency preparedness activities. The Chairr..an^of the Board of Directors signed an Official Bulletin, Serial Number 2153 " General Instructions, Corporate Nuclear Emergency Preparedness Policies."

The Bulletin was addressed to all employees and states PEco's policy

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a of being fully prepared for emergencies through implementation of the Emergency Plan and Implementing Procedures. The Senior Vice President, Nuclear Group issued a series of policy statements stating policy intent, applicability, implementation and sources. Administrative Procedures list responsibilities and accountabilities of the EPP staf Functions and responsibilities of the ERO staff are defined in.the Emergency Pla Program and personnel performance indicators have been developed which are tracked and brought to the attention of the Senior Vice President Nuclear Group. ERO responsibilities are elements in an employee's annual appraisal. Selection Managers identify candidates for the ERO and are responsible for-their ERO qualification and annual requalificatio !

Progress of the Improvement Plan and EPP activities are reviewed and tracked regularly at six levels of management. The Nuclear Group Senior Vice President discussed Ep at the monthly Station Review meetings and monthly EP meeting with the Divisional Vice President Nuclear Support. 0 p: rte" Vice Presidents review EP objectives weekly during routine staff' meetings and on a one on-one meeting basis. Divisional Managers also hold weckly EP review meetings in addition to discussion of EP at staff and status meeting The EP section manager holds weekly or more frequent meetings, while EP Branch leads track EP status on an on going basi '

Based on this information, the inspector concluded an ocoanizational structure has been developed which accommodates EP,polictos are clearly stated and distributed to all staff, frequent review meetings are held at monitor performance and employees are held accountable.

t l Based on the above review, this portion of the licensee's emergency f preparedness program is acceptabl l 3.6 Security Emergency Preparedness Interface l

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To determine if nuclear security officers (NS0s) are trained in'EP'

responsibilities, the inspector reviewed training records,. interviewed personnel and inspected the Central Alarm Station (CAS). NS0's are radiation worker qualified as well as respirator trained and fitte These officers have also been trained.in-search, rescue and ac-countability. EP security drills have not been held and there is no formal EP security interface. All security related reports to the NRC go via the control room. NSO's questioned were-not aware of

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radiation based CAS evacuation criteria. There are-no CAS area I radiation monitors. NS0's did not know who would tell them to evacuate,

!- nor could they identify the fall-back position. Upon hearing of this, the licensee agreed to take immediate corrective actio i

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Based on the above, and with the exception of CAS evacuation, this portien of the licensee's emergency plan is acceptabl ;

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3.7 Off-Site Activities The licensee is required to provide offsite support. Standards are

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giv(n in 10 CFR 50.47(b)(5) and (b)(15). Related requiremants are i stated in Sections IV.D.2 and D.3 and IV.F of Appendix E to 10 CFR '

50. Documentation relating to licensee offsite support activity was reviewed to ascertain if standards and requirements were me '

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Offsite activities involve' sixty governmental entitie Responsibility for this is assigned to the Emergency Preparedness Program. A contractor trained over 1700 Emergency Planning Zone (EPZ) emergency worker Training modules have been developed including those for table tops and team training. Public Information Brochures were distributed to all households, school districts and institutions in the EP Inserts, intended for transients, appear in eight telephone du ectories. Quarterly coordination meetings and monthly interface meetings are held with the Commonwealth and Counties. Two or three meetings a year are also '

held with each of 44 local go<ernments and districts. The sirens are tested monthly; availability foa last year was 99.4%. Emergency Action Levels and PARS were reviewed with government and copies of the 10 CFR 50 audit / review was sent to the Based on the above review, this )ortion of the licensee's emergency preparedness program is acceptable.

! 4.0 Exit Meeting An exit meeting was held with licensee personnel identified in Section 1 of this report on August 31, 1990. The inspector presented the results of the inspection and advised the licensee that no violations or deviations l were identified. Licensee management acknowledged these findings and indicated they would evaluate them and Lake appropriate corrective action

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regarding the items identifie ,

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,.. . KEGION 1 OPEN ITEM INPUT FOM i (FOM 6) x

,y A*o'dhock ll if changcd Supr .since Exit Meeting Review M l

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^e t/ Pl a nt ,,Q? }]f.,, ,$,0 ~},_ Report N /!9W Input Date // / /C/ D

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A. Add New Items: Originator:

Res Item N T,ype Sec Remarks ,

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B. Modify / Update: '

Res Item N Type Sec Remarks

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Closing closing Item N Remarks Item No. Remarks D _j))D_~ a] - -

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