IR 05000387/1989023
| ML17156B300 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 08/15/1989 |
| From: | Craig Gordon, Lazarus W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17156B299 | List: |
| References | |
| 50-387-89-23, 50-388-89-21, NUDOCS 8908240310 | |
| Download: ML17156B300 (13) | |
Text
U. S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos.
50-387 89-23 and 50-388 89-21 Docket Nos.
50-387 and 50-388 License Nos.
NPF-14 and NPF-22 Priority Category C
Licensee:
Penns lvania Power and Li ht Com an 2 North Ninth Street Allentown Penns lvania 18101 Facility Name:
Sus uehanna Steam Electric Station Units
8
Inspection At:
Berwick Penns lvania Inspection Conducted; Jul 17-
1989 NRC Team Members:
C.
Z, Go on, mergency P
paredness Section date Approved By:
W.
aza
, Chief, Emergency Preparedness Section date Ins ection Summar
Ins ection on Jul 17-
1989 Re ort Nos.
50-387 89-23
~d Areas Ins ected:
Routine, announced safety inspection of the emergency preparedness (EP)
program including review of previously identified inspection findings, changes to the emergency preparedness program, review of organization and management control, inspection of independent program audits, and inspection of emergency response organization training.
Results:
No violations were identifie.0 Persons Contacted DETAILS The following personnel were contacted during the course of the inspection:
Blakeslee, J. A;, Assistant Plant Superintendent
'reslin, R. A., Maintenance Engineer Byram, R. G., Plant Superintendent Cantone, S.,H.,
Manager, Nuclear Services Dornsife, W., Pennsylvania Bureau of Radiation Protection Doty, R. L., Supervisor, Radiological and Environmental Services Edwards, J. V,, Personnel E Administration Supervisor Fitch, A., Operations Training Supervisor Iorfida, T., Instrument
& Controls Supervisor Kulzynski, G. J., Technical Supervisor Lex, J.,
Nuclear General Training Supervisor
'inneman, J,
M., Supervisor, Nuclear Emergency Planning Prego, R. J., guality Assurance Supervisor Riley, H.
L ~, Supervisor, Health Physics/Chemistry Roth, D, F., Sr, Compliance Engineer Roush, K., Supervisor, Nuclear Instrumentation Sabol, A. R.,
Manager, Nuclear guality Assurance Shane, D., Health Physicist, Operations Stanley, G., Asst. Superintendent,,Outages Stotler, R. L., Security Supervisor Whirl, C., guality Assurance Auditing Supervisor Williams, W., Licensing Specialist
- Denotes attendance at exit meeting 2,0 Licensee Actions on Previousl Identified Items (OPEN) 50-387/86-10-02 and 50-388/86-10-02:
TSC does not have any source of emergency lighting during station blackout:
To address this item, a December 1986 engineering work request was prepared and transmitted to the engineering department.
The engineering evaluation indicated that the concern could be easily satisfied by the installation of self-contained battery powered lighting units at different locations within the TSC.
A Project Funding Request (PFR) was submitted in September 1987 to licensee technical staff for consideration as a minor work project, PFR's were evaluated each year and were approved based upon need and allowable budget.
Following approval, the PFR was then resubmitted to the engineering department for action.
According to licensee representatives, this item was considered with other PFR's in 1988 and 1989 but approval was declined.
At the time of the inspection it remained under consideration by technical staff.
The inspector di-scussed this matter with key licensee representatives to'
The inspector discussed this matter with key licensee representatives to ascertain why a minor plant modification with engineering approval was not resolved for a period of almost two years.
The licensee stated that although no formal action was taken, the issue would be re-evaluated.
(CLOSED) 50-387/86-10-05 and 50-388/86-10-05:
Dose assessment of discrete puff-type releases needs review and calibration.
The inspector reviewed results of the licensee's evaluations, documented by letters dated January 28, 1987 and April 5, 1988.
The evaluations address the concern over discrete puff-type releases through use of the STREAM dose calculation summary in conjunction with puff plots and dose plots.
Dose assessment results now can be displayed for actual plume position to include highest and integrated doses for plume puffs.
Also, the STREAM model was adequately demonstrated during the 1989 emergency exercise.
(CLOSED) 50-387/86-10-07 and 50-388/86-10-07:
Meteorological monitoring program not adequate regarding tolerance limits on wind speed, wind direction, and stability; and (CLOSED) 50-387/86-10-08 and 50-388/86-10-08:
Meteorological instrument sensors not properly calibrated.
The licensee addressed these two items by making a modification to the meteorological monitoring system in 1988.
A new system of electronic sensors and microprocessor based equipment was installed on the primary and backup towers and procedures for use were revised.
Acceptance criteria for meteorological parameters is now within the limits of NRC Safety Guide 23, (CLOSED) 50-387/89-02-04 and 50-388/89-02-04:
Security Emergency Action Level for Alert classification too restrictive.
Procedure EP-IP-001 was revised to clarify each emergency action level for all classifications relating to security events.
The revision now allows the licensee's response to be based upon an increase in severity level of security threats.
A procedure change approval form dated July 10, 1989 formally incorporates the revision into the Emergency Plan.
(OPEN)
50-387/89-02-05 and 50-388/89-02-05:
Procedure EP-IP-033,
"Dose Assessment and Protective Actions", does not conform to NRC guidance.
This item was identified during the 1989 emergency exercise and characterized as Unresolved.
Immediately following the exercise, the licensee prepared an internal report for key response personnel which provided both background information and recent developments regarding issuance of protective action recommendations (PAR) to offsite authorities.
Results of the report identified the change in philosophy in formulating PAR's based upon plant parameters and the source term rather than dose assessment.
Subsequently, a revision to EP-IP-033 was drafted which includes evacuation as the initial PAR based on plant system statu At the time of the inspection, the licensee stated that the draft of the revised procedure was completed and was expected to undergo PORC review.
At the exit meeting, the licensee committed to formally implement the procedure by mid-August and complete training of operations staff by the end of September, 3.0 0 erational Status of the Emer enc Pre aredness Pro ram 3.1 Chan es to the Emer enc Pre aredness Pro ram The inspectors discussed changes to the SSES emergency preparedness program made since the last inspection with the Supervisor, Nuclear Emergency Planning (SNEP).
The most significant change occurred when the licensee revised the Emergency Plan in its entirety.
Revision 11 was issued in December 1988 to clarify certain items and update information to reflect current response practices.
Salient revisions include emergency response assignments to onsite/offsite personnel, identification. of communications equipment, changes in dose assessment methodology, and updating of equipment inventories and Letters of Agreement with offsite support groups.
These changes were made in accordance with 10 CFR 50.54(q),
do not appear to decrease the overall effectiveness of the Plan, and continue to meet the emergency planning standards of 10 CFR 50.47(b).
The functions and staff of -the Emergency Response Organization (ERO)
have remained generally stable and no major changes were noted in key response duties or assignments.
Reassignment of individuals as Recovery Hanagers w'as made as a result of changes within corporate management staff.
The Hanager -Nuclear Services has been designated as the primary Recovery Hanager and if available will be the first individual chosen who will provide overall direction and control of an emergency at the site.
Immediately following the last inspection, a personnel change was made in the SNEP position.
No changes to the duties and responsibilities for this position or other staff with onsite assignments in the emergency preparedness program were noted.
The inspector determined that other changes made since the last inspection pertaining to the ERO, management control system, emergency response facilities, and implementing procedures (other than IP-033)
have not substantively affected the licensee's overall state of emergency preparedness.
Based upon the above review, this area is acceptabl,2 Emer enc Facilities E ui ment Instrumentation and Su lies The inspector toured the Control Room, Emergency Operations Facility (EOF),
and Technical Support Center (TSC) with the SNEP.
These
.facilities were found as described in the Emergency Plan and were adequate to support emergency response activities.
Each facility has been used repeatedly to support drills and exercises.
Facilities, equipment, and supplies have been maintained in a state of operational, readiness.
Equipment lockers, cabinets, and communications devices (teleph'ones and portable radios)
were inspected in the EOF, TSC, Control Room, health physics area, mobile van and at designated locations within the protected area and found to be operable.
Responsibility for maintaining equipment and supplies was shared between the emergency planning group and other site departments.
The SNEP was not familiar with the locations of some designated equipment, supplies, and kits provided by other groups but receives verification from each group after inventories are conducted.
The inspector determined that inventories of onsite and offsite radiation survey kits, data acquisition/
dose assessment systems, protective clothing, and designated emergency supplies were being maintained at the site and EOF.
Based upon this review, this area is acceptable.
.3.3 Or anization
'and Mana ement Control The inspectors reviewed task assignments for individuals within the ERO, evaluated emergency preparedness program management and administration, and held discussions with cognizant licensee personnel to determine the extent of management involvement in the emergency preparedness program.
The Supervisor; Nuclear Emergency Planning was responsible for overall program direction and most routine program functions.
Additional program support was provided at the site by the lead Shift Technical Advisor and Plant Superintendent and from the corporate office by the Manager Nuclear Services.
The emergency preparedness staff is an independent site group but reports to the Supervisor-Radiological and Environmental Services through the corporate office.
Although a change in the SNEP took place since the last inspection, basic program responsibilities were being performed.
Full time emergency preparedness staff were available to maintain the Emergency Plan and implementing procedures, emergency response facilities and designated equipment, development of exercise scenarios, training of the onsite ERO and State/local responders, and interface with offsite support groups.
The Plant Superintendent was also involved in enhancing the relationship with offsite support groups through regular meetings with the local Citizens Committe Based upon an evaluation of the emergency response training program (section 3.5. 1), it was found that the licensee had sufficient personnel, available to staff all ERO positions to ensure full coverage during a prolonged emergency.
Based upon the above review, this area is acceptable.
3.4 Inde endent Reviews Audits Audits of the EP Program were performed by a three member audit team from the licensee's Nuclear Quality Assurance (NQA) group.
Audits have been adequately conducted since 1984, provide an in-depth review of program activities, and meet the requirements of 10 CFR 50.54(t)
for independent program review.
The auditors and document control files maintain separate copies of audit reports.
Criteria for the audits were developed using guidance in documents provided in the FSAR, Technical Specifications, various Nuclear Department Instructions (NDI) and QA administrative procedures, INPO
'guidance, and certain NRC documents.
Audits were conducted from the standpoint of compliance rather than performance.
A checklist of audit items was used by the QA 'staff to perform the audits in 1987 and 1988.
Review of the checklist indicates that essential EP program functions such as the Emergency Plan (including Appendix E
requirements)
and implementing procedures,=
training, inventory maintenance, chemistry, and drills and exercises were covered.
However, there were two primary areas not audited.
These were (1)
a determination of whether the basic framework of the program meets the planning standards of 10 CFR 50.47(b),
and (2) the adequacy of interface with State and local agencies was not performed.
This is an unresolved item (50-387/89-23-01 and 50-388/89-21-01).
Additionally, the inspector could not determine if the licensee reviewed their EALs with State and local authorities.
In a
subsequent August 15, 1989 telephone conversation with a
representative of the Pennsylvania Bureau of Radiation Protection (BRP), the inspector determined that BRP had been offered training in a variety of areas including EALs.
The licensee has agreed to formalize this process.
The inspectors discussed whether the audits
'included all planning'tandards and other applicable NRC rules necessary for program implementation.
Auditors agreed to review existing NRC requirements and stated that additional information relating to review of the adequacy of offsite interface would be provided, Reports of audits conducted during 1987 and 1988 were reviewed for scope and content.
The inspector found that the reports were thorough and.detailed and discussed the results with EP and QA staffs.
Audit results were categorized either as findings or recommendations/observations and discussed with EP staff when the audit was completed.
A corrective action system is in place to resolve findings through issuance of a Susquehanna Review Committee
3.5 Audit report.
The audit reports were transmitted to many individuals in corporate and plant management and a
response to. findings requested within 30 days.
A written response to each finding was required since program quality could be impacted ifdeficient issues were not resolved.
Following the response by the EP program staff, auditors evaluate and confirm commitments for corrective action.
Results of the 1987 audit identified
findings and
recommendations; the 1988 report identified
finding and
recommendations.
Specific findings related to inadequacies in basic program elements such as Emergency Plan distribution, review of implementing procedures, record-keeping for ERO training, document control, and management review of emergency incident reports.
Findings from the latest two reports have been closed.
The SNEP maintains an internal file which tracks the manner in which all outstanding recommendations were being addressed.
A review of the unusually large number of recommendations indicated that many were significant but not considered findings because they did not relate directly to a regulation, the FSAR, or technical specifications, Appropriate action on recommendations was expected to be taken but not required'he inspector noted that no higher level of licensee management support was provided to ensure that NgA recommendations were properly addressed.
Therefore, in some cases, adequate responses by EP may be provided while in other cases recommendations on deficient program areas may be left uncorrected.
The inspector reviewed the recommendations and found that several items reflect the same level of programmatic concern as findings.
These include a lack of a tracking system for drill deficiencies, early
.Unusual Event termination during response to contaminated/injured individuals, and failure to correct previously identified findings.
Conversely, other recommendations were insignificant and, if implemented, would provide little or no program improvement.
- Discussions were held with the Supervising Engineer, NgA who was the individual responsible for classification of audit results along with audit team members.
The inspector identified a
need for a filtering mechanism for all recommendations whereby significant deficiencies were given a
higher priority through appropriate management commitments while at the same time minor issues can be discussed and resolved prior to issuance of the gA report.
The licensee agreed to evaluate this area.
Except as noted above, this area is acceptable.
C Knowled e and Performance of Duties 3.5. 1 Establishment of Trainin Pro ram The inspector reviewed the licensee's program for emergency response training and noted that Section 9.0 of the Emergency Plan describes an emergency training program for different categories of personnel.
These include all personnel granted unescorted access within the
controlled zone of the site, all licensee personnel assigned to the ERO, and offsite support groups.
Specific ERO training was determined by the Supervisor Nuclear Training and includes course requirements to satisfy each emergency position.
Discussions were held with the Supervisor, Nuclear Training who provided training lesson plans, examination material, examination results, and attendance records of response training for site personnel.
Composite records were maintained via computer for each individual.
To determine when response training for any member of the ERO should be taken or when requalification was due, 3 reminder letters are sent to the individual at 30 day intervals.
Personnel who do not schedule and take the required training are subsequently deleted from the qualification list.
Review of the training file database indicated that requalification of personnel in the Recovery Manager, Emergency Director and other key ERO positions were up to date.
Expired training was found in only isolated minor cases and these were discussed, with training staff.
The basis for selection of personnel to the ERO was contained in NDI-6.6.2 and requires certain classroom instruction together with certification in a tabletop exercise or participation in either an annual exercise or health physics drill.
Training was provided to all response personnel by the Supervisor, Nuclear Generation Training.
Along with directing the training program, this individual must conduct both classroom and practical instruction in emergency classification, protective action recommendations, technical support, onsite/offsite surveys, chemistry, communications, and radiological assessment.
Although training of the ERO was adequately being maintained, the inspector expressed concern over having only one individual without additional support or assistance to cover all necessary instructor functions, coordinate response training, and continue to efficiently carry out supervisory duties.
Training of offsite support groups was provided by a member of the EP staff and was effectively being maintained.
Licensee staff meets regularly with State and local personnel for training purposes.
Review of offsite training records, review of lesson plan material, and discussions with the SNEP revealed that response training was provided to all support groups identified in section 9.0 of the Emergency Plan.
EP lesson plans are detailed and focus on important response elements or implementing procedures.
The lesson plan for Emergency Director training provides an outline of learning objectives on emergency classifications, facilities, ERO, dose assessment, communications and protective action recommendations (PAR).
Only one course was required for requalification for a specific response function and does not include reiteration of basic emergency information covered in general employee training, Examination questions relate directly
information covered in general employee training.
Examination questions relate directly to lesson plan material and individuals must demonstrate proficiency in their respective response duties as part of the annual requalification.
Performance of response personnel has consistently been demonstrated in drills and walk-through exercises, and no concerns were identified with response of personnel to emergencies.
3.5.2 Im lementation of Trainin Pro ram and Walk-throu hs In order to ascertain training effectiveness of the ERO in response to severe accident conditions and rapidly escalating events, the inspectors conducted walk-throughs of four control room crews.
Each shift crew consisted of a Station Shift Supervisor (SSS), Unit Shift Supervisor, Shift Technical Advisor (STA),
and Health Physics Technician for dose assessment, and Reactor Operators for notification and communication.
The walk-throughs focused on the duties and responsibilities of the shift functioning as a 'eam to implement EALs in the EP Plan.
Specific response areas observed were:
- detecting emergencies and implementing appropriate response procedures;
- classifying emergencies;
- making appropriate onsite and offsite notifications;
- performing dose projection and assessment activities; and
- formulating onsite and offsite protective action recommendations.
Overall performance of each shift was adequate and demonstrated the ability to implemen't the EP Plan effectively.
Evidence of training was observed as each shift demonstrated knowledge of implementing procedures and familiarity with EALs.
Good direction and control were observed.
Details of walk-through results were presented and discussed with the licensee.
Some areas for improvement were noted and discussed with the licensee including:
- The current format of the Emergency Director implementing procedure does not provide an adequate cross reference to other essential response procedures such as EP-IP-002, "Notifications", EP-IP-007,
"Site Evacuation" or EP-IP-033, "Protective Action Recommendations".
Checklists to help perform these functions were also not available.
As a result, three shifts did not direct a site evacuation for non-essential personnel when a Site Area Emergency was declared.
- Three shifts were given a scenario involving failures of 2 of 3 fission product barriers coupled with a potential or actual loss of the third boundary.
A correct classification of General Emergency
was made by each shift, but none of the three provided offsite PAR's; All three Emergency Directors
{ED) indicated that they could not issue a
PAR until dose rate calculations were complete.
Although EP-IP-022 indicates that the ED can issue a
PAR based on technical assessment of plant conditions which could present a potential for an offsite release, no guidance was provided as to how such a
PAR was developed.
This finding reinforces: previously identified NRC concerns regarding the licensee's PAR procedure (see Section 2.0, items 50-387/89-02-05 and 50-388/89-02-05).
-
When attempting to direct a site evacuation, two'f the three shifts thought that the control room communicator should announce a site evacuation, but communicators expl,ained that they had no guidance on how to make such an announcement.
Further, none of the three shifts provided information on the site evacuation to State and local response officials as directed by EP-IP-002 and EP-IP-007.
- All health physics technicians assigned to perform computerized dose assessment indicated that projected population doses could not be made on plant parameters alone and needed an, activity release rate or data from offsite survey teams.
In addition, instructions to perform dose calculations based solely upon source term data were contained in EP-IP-009, but only TSC staff were trained to use the procedure.
Since health physics technicians were available on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis but were not trained to use EP-IP-009, a concern w'as identified regarding the lack of dose assessment capability in a
rapidly escalating emergency.
The licensee committed to address identified concerns through additional training where necessary.
4.
~E The inspectors met with the licensee personnel denoted in Section I at the conclusion of the inspection to discuss the findings as presented in this report.
The licensee acknowledged the findings and agreed to evaluate them and institute corrective actions as appropriate.
At no time during the inspection did the inspector provide any written information to the license