IR 05000352/1993011

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Insp Repts 50-352/93-11 & 50-353/93-11 on 930524-27.No Violations Noted.Major Areas Inspected:Changes to Emergency Plan & Implementing Procedures;Emergency Facilities, Equipment,Instrumentation & Supplies
ML20056G959
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 08/27/1993
From: Laughlin J, Mccabe E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20056G958 List:
References
50-352-93-11, 50-353-93-11, NUDOCS 9309080007
Download: ML20056G959 (12)
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U. S. Nuclear Regulatory Commission Region I

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Docket / Report: 50-352,353/93-11 Licenses: NPF-39, 85 Licensee: Philadelphia Electric Company (PECC)

Post Office Box 195 Wayne, Pennsylvania 19087-0195 Facility: Limerick Generating Station, Units I and II Inspection: May 24-27,1993 Inspection At: Pottstown, Pennsylvania Inspectors: 3 J. LaughlpT Eniergency Preparedness Specialist ' da'te J. Lusher, Emergency Preparedness Specialist J. Will, Sonalysts, In Appmved: P 27!97 E. McCabe, Chief, Emcrgency Preparedness Section date SCOPE Announced emergency preparedness (EP) program inspection, including changes to the Emergency Plan and Implementing Procedures; emergency facilities, equipment, instrumentation, and supplies; organization and management contml, training effectiveness, and audits / review RESULTS The EP program was being effectively implemented with strengths in management involvement, effon applied to Emergency Plan and Implementing Pmcedure revisions, and quality of trainin No violations were identifie B0007 930827 PDR ADOCK 0500035 G PDR_

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TABLE OF CONTENTS

1 1.0 Persons Contacted ....................................... I

i l 2.0 Emergency Plan and Implementing Procedures . . . . . . . . . . . . . . . . . . . . . . 1 l

3.0 Emergency Facilities, Equipment, Instrumentation and Supplies ........... 4 l

4.0 Organization and Management Control . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 5.0 Training ............................................. 6 Table Top Walk-Throughs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 ED/ES D Interviews . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 6.0 Independent and Internal Reviews and Audits . . . . . . . . . . . . . . . . . . . . . . . 9 7.0 Exit Meetin g . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 i

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.. - _ i DETAILS Persons Contacted The following licensee personnel were among those contacted during the inspection:

  • C. Adams, Director, Site Support Services, Limerick Generating Station (LGS)

R. Bickhart, Auditor, Nuclear Quality Assurance

  • J. Doenng, Plant Manager, LGS

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T. Dougherty, Manager, Operations Training, LGS D. Fetters, Director, Maintenance, LGS

  • D. Helwig, Vice President, LGS L. Hopkins, Operations Manager, LGS J. Hutton, Shift Manager, LGS i
  • S. MacAinsh, Manager, Support Services, CB W. McFarland, Director, Outage Management, LGS C. Medrick, Shift Supervisor, LGS
  • J. Phillabaum, Regulatory Engineer, LGS R. Ruffe, Lead Simulator Instructor, LGS W. Rogers, Health Physics Training, LGS B. Stanley, Shift Manager, LGS R. Tomlinson, Manager, Services Training, LGS J. Tucker, Shift Supervisor, LGS l
  • Denotes attendance at the exit meeting on May 27,199 ;

i Emergency Plan and Implementing Procedures  !

Inspectors reviewed changes to the Emergency Plan (E-Plan) and Implementing Procedures (Emergency Response Procedures-ERPs) to ensure that E-Plan effectiveness had not been reduced.

The licensee completed a draft common Nuclear Emergency Plan, consolidating the Limerick and Peach Bottom E-Plans into one. This was submitted to the NRC for review under a cover letter dated March 18,1993. NRC review concluded that the draft E-Plan did not decrease the effectiveness of the individual site E-Plans and continued to meet the standards of 10 CFR 50.47(b) and the requirements of 10 CFR 50 Appendix E. The final combined E-Plan will be reviewed at the next program inspection (IFI 50-352,353/93-11-01).

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l ERP-101, Classyication of Emergencies, Revision 2, dated 5/24/93, was reviewed

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regarding an open item (IFI 50-352,353/92-28-01) associated with the wording of Appendix 11, !

" BOUNDARY DEGRADATION /LOCA," General Emergency (GE) condition #1. Revision 1

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] 1. Scram with LOCA AND no ECCS. Indicated by:

a. Failure to bring reactor level above -161"

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b. AND Containment pressure greater than 20 psig.

NRC review concluded that Item a. was confusing since the criteria to meet this condition was

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unclear. Revision 2 changed the wording in Item a. to read:

l 1. Scmm with LOCA AND ECCS unable to maintain reactor water level as indicated by:

i a. Failure to bring reactor level above -161" after 3 minutes.

j Since Revision 2 specified a time period for reactor water level to remain below -161" (tep of j active fuel) before the GE must be declared, NRC review concluded that the revision was adequate. IFI 92-28-01 was close , The inspector also reviewed the 10 CFR 50.54(q) review and 10 CFR 50.59 safety evaluation

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for this E-Plan change. These were completed by licensee procedures and were assessed as j adequate.

i i Procedure EP-C-1, Development and Maintenance of Emergency Plan and

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Emergency Response Procedures, Revision 1, dated 1/6/93, was reviewed. It specified the 10 CFR 50.54(q) review and 10 CFR 50.59 safety determination processes, and required i Plant Operations Review Committee (PORC) review and Plant Manager approval of all Emergency Plan and ERP changes. It also required an annual review of the E-Plan and

, Common ERPs (ERP-Cs), i.e. Emergency Operations Facility procedures used for both Limerick and Peach Bottom plants. However, it did not require an annual review of the ERPs.

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The inspector no:ed that the LGS E-Plan, Section 8.3.2, required that ERPs be revised to reflect changes in the E-Plan, and that they be reviewed and revised, independent of the annual E-Plan

, review, according to plant administrative procedures. No such administrative procedure was a evident.

l The licensee produced documentation that showed NRC approval to their request to change the

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Quality Assurance Program Descriptions incorporated in the Updated Final Safety Analysis j Report (UFSAR) to eliminate periodic procedure reviews. After this approval, programmatic

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controls and processes replaced the periodic reviews. The licensee's self-assessment process and j oversight by the Nuclear Quality Assurance (NQA) organization was to provide an assessment of the effectiveness of the programmatic controls and processes in maintaining procedures curren Licensee procedure AG-CG-36, Roll-out Plan for the Elimination of Scheduled i

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4 i Periodic Reviews, dated 10/1/92, implemented this initiative. This procedure identified 12 l j programs (drills, QA assessments, etc.) which would ensure that station procedures stay curren l Responsible groups were required to assess the adequacy of these programs to replace periodic l reviews of procedures assigned to them. This was to be documented on Exhibit 1, Periodic ;

Review Evaluation Fonn, to confirm that the reviews could be eliminated. Exhibit I for 1 ERPs and ERP-Cs was approved on 11/6/92. The ERPs will no longer be reviewed annually l while ERP-Cs will receive an annual review in accordance with EP-C-1. Procedure AG-CG-36 also required a biennial self-assessment to assure that controls and processes are maintaining l procedures current. This self-assessment will be reviewed in a future inspection to ensure

adequate measures are being taken to maintain ERPs current (IFI 50-352,353/93-1102).

j Procedure A-C-21, Preparation of Emergency Response Procedures, Revision 1,

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dated 9/16/92, provided de. tailed format and content guidance for the preparation of ERPs. The licensee completed a major rewrite of ERPs from 11/91 to 3/92. Forty-six Emergency l

Procedures were combined and rewritten into 28 ERPs. The inspector reviewed a sampling of

ERPs, all of which were completed in accordance with A-C-21.

j Procedure A-4, Plant Operations Review Committee Procedure, Revision 12, dated 5/3/93, described the process of scheduling and obtaining PORC approval of E-Plan and ERP changes. The inspector reviewed the 10 CFR 50.54(q) review and PORC approval of E-Plan Revision 22. The review was adequate and the approval process completed in accordance with

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the procedure. Changes to the E-Flan and the rewritten ERPs were assessed as resulting in no decrease in the effectiveness of the E-Pla Procedure EP-C-6, Preparation, Conduct, and Evaluation of Emergency Response Drills and Etercises, Revision 0, dated 2/15/93, provided guidance for the preparation, conduct, and evaluation of drills and exercises. Exhibit EP-C-6-1, Drill ObjectiveJ, listed periodic drill objectives from NUREG-0654 and other sources. The licensee had a matrix of objectives to ensure their completion at the proper frequency. The inspector noted that two objectives had not been met: 1) The conduct of an exercise that begins between 6 p.m. and 4 a.m. and,2) The conduct of an unannounced, off-hours full-participation

) exercise. Federal Emergency Management Agency (FEMA) Guidance Memorandum PR-1,

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Policy on NUREG-0654/ FEMA-REP-1 and 44 CFR 350 Periodic Requirements, j dated 10/1/85, directed that these objectives be completed every 6 years. Both were last

completed in 1988, but were not scheduled again until 1995.

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The licensee produced documentation which showed NRC approval for an exemption regarding their 1990 full-participation exercise. This was done to change the exercise cycle so that

Limerick would conduct full-participation exercises in the odd-numbered years and Peach Bottom

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in the even-numbered years. The licensee stated that when the exercise was pushed back one j

year, they received permission from FEMA to push back these six-year objectives as well. This l was confirmed with FEMA Region 1, who stated that these objectives were scheduled for j

, completion during the November 1995 full-participation exercise, which was in agreement with l i the licensee's drill matri l l

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Based on the above review, this area was being effectively implemente .0 Emergency Facilities, Equipment, Instrumentation and Supplies The inspector toured the Control Room (CR), Operational Support Center (OSC) and the Technical Support Center (TSC) and found these facilities in a good state of operational readiness. Survey instruments were spot-checked and found operational and within the required calibration frequency. Off-site survey team and vehicle decontamination kits were checked complete as indicated by the inventory form The inspector reviewed the past year's surveillance tests for facility and equipment inventories and found no discrepancies. All inventories were complete and missing items were replaced immediately when necessary. All surveillance tests were reviewed by the Station Emergency '

Preparedness Superviso The inspector reviewed TSC ventilation test results for the period from September 1989 to ,

November 1992. The September 1989 test was unsatisfactory since the charcoal absorber bed failed to meet requirements. The charcoal bed was replaced and the system retested in December 1989 with positive results. Surveillance tests for 1991 and 1992 were performed satisfactoril Monthly operational surveillance tests of the TSC ventilation system were performed in accordance with procedure ST-6-EPP-320-0. The inspector noted that during this test, readings were recorded for the delta pressures across the roughing, HEPA, and charcoal adsorption l filters. An upper limit of delta pressure was established, indicating filter loading or plugging, i but no operational acceptance band was indicated to provide a lower limit of delta pressure, i which would indicate such conditions as no filter present or a ruptured filter. The licensee stated I that the procedure was being revised to establish a delta pressure operating range and specify possible causes of high and low delta pressures (IFI 50-352,353/93-11-03).

The licensee is presently testing a new automated callout system that performs Emergency Response Organization (ERO) callout by pager activation. This system will be, implemented later this year for ERO members carrying pagers. The NRC will evaluate its effectiveness during the full-participation exercise in September.

l The inspector received a demonstration of the EP action item tracking system located on the l

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l Plant Information Management System (PIMS) database. The licensee produced biweekly print-l outs of action items for management, which indicated due dates for each item. Active action  ;

items were being discussed at a monthly management meeting with the Vice President, Nuclea )

This information and other records were easily retrievable from PIM ;

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The licensee demonstrated the prompt notification system (sirens) monitoring system. All 165 sirens were polled to show operational readiness. Two sirens (90 and 165) were not operational, indicated by their number turning yellow on the screen. The licensee EP specialist immediately l

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re-polled the sirens to verify the problem and notified siren maintenance personnel. During an actual siren activation, the sirens are polled and the numbers of faulty sirens are printed out on hard copy so that route alerting can be performed in the affected areas. Siren availability for 1992 was 99.4%, which exceeded the FEMA-REP-10 requirement of 90%.

The licensee planned two facility upgrades in the near future. The TSC will be refurbished during plant entrance modifications, scheduled for completion in November 1993. The TSC will be maintained in operational readiness throughout this period. Also planned was the construction of a new health physics field office, which will be used as the Operational Suppon Center. This facility will be located between the present Administration Building and the TSC. These initiatives were noted as significant enhancements to licensee response capabilitie Based on inspector review, this area was effectively implemente .0 Organization and Management Control l The inspector interviewed the Station Vice President (VP), Plant Manager, Corporate EP Manager, and the Site EP Supervisor; and reviewed EP Department staffing and Emergency Response Organization (ERO) status to assess EP Program administratio The Limerick Site EP Supervisor reported through the Director, Site Support Services to the Station VP. The former Corporate EP Manager replaced the Support Manager in February 1993 as the Director, Site Support Services (new title for Support Manager). This was noted as a positive change for EP since the Site EP Supervisor's new immediate supervisor has extensive EP background, an established relationship with the Site EP Supervisor, and is positioned to represent EP issues to senior management. The Site EP Supervisor had weekly informal meetings with the Director, Site Support Services, and documented bi-weekly meetings with the Station VP, to discuss EP issues. Management support of EP was noted as a strengt The new Corporate EP Manager, formerly the Offsite EP Supervisor, assumed his position in February 1993. He had several years of EP experience and was promoted when his predecessor became the Director, Site Support Services. The corporate EP group was reorganized fron; 3 branches into 2, with the two station branches for Limerick and Peach Bottom being combined  ;

into one, Station Support. The corporate group formerly had 14 positions, which was reduced to 11. This group was relatively stable with two recent additions, one from operations and one from training. Both indiOials were former senior reactor operators (SROs) and were assigned to the Station Support Branch. Neither had EP experience but both had adequate background I and experience for the position l l

The Site EP Supervisor had a staff of 4, which included former SRO, health physics, and clerical expertise. Two of these staff were new to EP. The new analyst for program / assessment was an engineer and former SRO who joined EP in May 1993. The new analyst for training / drills had not transferred to EP as of this inspection. He was most recently in Operations Support and was also a former SRO. He was expected to arrive in June. Neither l

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of these new personnel had any previous EP experience but had adequate training and background to fill these position The Site EP Supervisor maintained his previous responsibilities and assumed two new ones:

hospital interface with the associated emergency response hospitals and siren system oversigh This did not appear to adversely impact EP workloa The ERO structure remained the same and was relatively stable. There were four qualified Emergency Directors (EDs) at the time of this inspection. One ED had recently left and another was leaving soon to become an Emergency Response Manager (ERM). Replacements were two former Corporate Spokespersons, maintaining a total of 5 EDs. The two new personnel had not completed their training, so were not yet assigned to the ED positio There was a major turnover of Damage Repair Team Izaders (DRTLs). One person remained from a group of five, one previously qualified person requalified, and three new personnel were recently trained. The licensee had a well-thought-out plan for accomplishing these changes, ensuring completed training before assignment to the duty roster. All site ERO positions were staffed at least three-deep. The corporate group, which staffs the Emergency Operations Facility, had identified all people changing ERO positions due to corporate restructuring and form" lated a deliberate training plan to accommodate the changes. This roster was three-deep in all positions as wel Based on the above, this area was effectively implemented and was assessed as a strengt .0 Training The inspector reviewed EP training instructions, training records, lesson plans, and simulator scenarios; interviewed EP training personnel, and conducted table-top scenarios with three shift I crews to determine the adequacy of the Limerick EP training progra EP training records were maintained in accordance with licensee administrative procedures. The training database maintained on the Plant Information Management System (PIMS) was validated by comparing individual class attendance records, qualification cards and test answer sheets to the computer record. No discrepancies were identified in the training records sampled. All !

personnel assigned to ERO positions were qualified for those positions. However, the tracking I system did not track the type of drill or exercise (station drill, mini drill, table-top exercise, etc.) l that was completed, nor the ERO position filled. This made reconstruction of who performed in what position very difficult, and raised a question as to whether the licensee requirement for tri-annual drill panicipation was met. No NRC deficiency was identified, but the licensee was informed that more accurate drill documentation would ensure completion of their training requirement The inspector reviewed the on-call ERO roster in ERP-110 for personnel qualification statu Training records of individuals assigned an ERO position were checked to ensure that they had l

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completed all training requirements. All individuals listed for ERO positions had received the required training within the specified time periods and, except for the drill / exercise participation documentation already noted, fully met the administrative requirements for qualification. All ERO positions were staffed. There were four individuals who were delinquent in their qualification requirements and several people who had exceeded their annual periodicity and were in their grace period. No delinquent individuals were assigned ERO position The general and senior level lesson plans were reviewed for technical content. In most cases, lesson plans were adequate and several had excellent technical detail. However, the lesson plan for the Technical Support Center (TSC) ED was virtually identical to the one for the Control Room (CR) ED. This was true despite the fact that the TSC ED has a number of responsibilities not required of the CR ED. The inspector noted this as a potential flaw in TSC ED training effectiveness.

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l Lesson plans contained specific objectives, some of which were satisfied by table top discussion with subject matter experts. A test question bank supporting lesson plan objectives was developed for each lesson plan and these were reviewed and updated annuall ERO members were permitted to review the general EP training lesson plan and " test out" of the annual requalification training if the material had not substantially changed. A sampling of these tests were reviewed for depth and technical difficulty. These were adequate to validate a minimum knowledge level for performance of ERO function The inspector reviewed simulator training scenarios for adequacy. Of the 39 scenarios in use, only one proceeded to the General Emergency (GE) level, and 13 led to a Site Area Emergenc Three of the latter 13 could be continued to the GE level, but would involve extended periods of operator inactivity. The inspector pointed this out to the licensee as a possible deficiency in training shift crews to classify fast-breaking high level events and formulate protective action recommendation Several instructor qualification folders were reviewed. The inspector determined that the instructors met all requirements of the instructor certification program outlined in licensee procedure .1 Table Top Walk-Throughs Inspectors conducted table top walk-through exercises with three crews of operators consisting of a shift manager, shift supervisor, shift technical advisor, and health physics technician. Each crew was required to respond to two fast-breaking accident scenarios which progressed to the General Emergency leve All crews demonstrated the capability to promptly classify the events and notify state and local authorities within 15 minutes. Protective action recommendations to the State were conservative and would have protected the health and safety of the public under the scenario circumstance Although all three crews displayed proper concern for the protection of evacuees, they failed to ,

recognize and deal with the radiological hazard to personnel reporting to the site for staff augmentation. Further, the crews generally made good use of procedures but EDs were consistent in their variable and incomplete use of the ED check-off list (Appendix ERP-200-1 -

Form 5), and in their failure to employ Appendix ERP-200-1 Form 6 (Unaffected Unit Operations).

Personnel made errors in filling out the Emergency Notification Message Form (Appendix ERP-

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200-1 Form 1) and the Protective Action Worksheet (Appendix ERP-300-9). For example, there were instances of wrong times, wrong dates, lines left blank, and crossouts with no SS initial This raised questions as to whether communicators could accurately transmit the information to offsite officials. The walk-through format did not require operators to actually perform the notifications, so the effect of these errors was not evaluated. The inspector informed the licensee of NRC concern and the apparent need for additional training in this area. Completion of procedural forms will be reviewed in a future inspection (IFI 50-352,353/93-11-04).

Other walk-through observations: '

  • ERP-200, step 2.1.8 refers to ERP-317 which is no longer effectiv * Operators used abbreviations and acronyms on Appendix ERP-200-1 Form 1, Emergency Notification Message Form, in Item 3, Brief Non-technical Description of the Event, which could have been confusing to the communicator and the Stat * Licensee procedures provided no guidance to the ED for the disposition of Appendix ERP-300-9, Protective Action Worksheet. EDs used the worksheet to make a PAR to the State via an informal telephone call but were not directed to retain an accurate copy for a legal record of the PA In summary:
  • Shift personnel were generally knowledgeable and used procedures effectivel They demonstrated very good training in event recognition and classification; making notifications to local authorities, and in dose assessment and PAR formulatio * General crew weaknesses included: 1) failure to deal with the radiological hazard to personnel reporting to the site, 2) Variable and incomplete use of the ED Check-off List, and 3) Errors in filling out the Emergency Notification Message Form and the Protective Action Workshee ;

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9 ED/ESD Interviews The inspector interviewed four EDs to assess the quality of emergency management trainin Questions concerning ED performance of duties were asked. The results were as follows:

All EDs demonstrated a good knowledge level of their emergency duties. There was consistent good knowledge of event classifications, notifications and p.otective action recommendation Some areas for potential improvement were:

  • Some individuals were unsure of the meaning of the bordered note in ERP-101, Step 2.0 which read: " Implementation of this procedure does not constitute ,

implementation of the Emergency Plan."

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  • One person was not clear on which time is recorded at the bottom of Appendix ERP-200-1 Form 1, and how it differs from the time recorded in Step * Three individuals did not understand how to verify Appendix ERP-200-1 Form

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1 in accordance with Step 3.1.3 of ERP-110. One thought this was accomplished

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by signing the Form I under Step *

All understood that field team data was more accurate than dose projection information, but two people were unsure of reasons why field team data could be twice projected level Based on the above review, this area was being effectively implemente .0 Independent and Internal Reviews and Audits The inspector reviewed the audit reports from 1991 and 1992, inteniewed the auditors, and discussed the audit plans, checklists, and reports with the auditor The 1991 audit and 10 CFR 50.54(t) review was conducted from September 23-October 25, 199 'cchnical expertise was provided by United Energy Services, who performed the independent 10 CFR 50.54(t) review. The 1992 audit and 10 CFR 50.54(t) review was conducted from September 21-November 30,1992. During this audit, the 10 CFR 50.54(t)

review was performed by the Nuclear Quality Assurance Departmen Audit plans and checklists were comprehensive and thorough. Major portions of the Emergency Preparedness Program were reviewed in considerable depth to ensure effective program implementation. Audits consisted of two weeks at Limerick, two weeks at Peach Bottom, and one or two weeks at corporate headquarters in Chesterbroo The 1991 audit identified five strengths and initiated eight Corrective Action Requests (CARS),

while the 1992 audit identified six strengths and initiated four CARS. No regulatory deficiencies

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were identified. CARS required a 30-day written response on actions taken for correction and to prevent recurrence. The inspector noted that some CARS were corrected before the audits

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were completed. The Action Item Tracking System was assessed as effective in ensuring

, appropriate corrective actions were take Limerick. had one actual event since the last inspection, an Unusual Event declared on July 13, l 1992 for a fire involving a permanent plant structure lasting greater than ten minutes. The event report was well-written and was reviewed by the EP Depanment, j Based on this review, the audit / review area was effectively implemented.

j Exit Meeting

.i The inspection team met with the licensee personnel identified in Detail 1.0 on May 27,1993 to discuss the inspection findings. The licensee was informed that the issue concerning periodic

review of Emergency Response Procedures was unresolved pending funher NRC review. ' Utis was subsequently resolved with the submission of funher documentation. The licensee acknawledged the findings and indicated they would be evaluated for appropriate corrective

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