IR 05000387/1992004
| ML17157B104 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 03/12/1992 |
| From: | Eckert L, Mccabe E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17157B103 | List: |
| References | |
| 50-387-92-04, 50-387-92-4, 50-388-92-04, 50-388-92-4, NUDOCS 9203240107 | |
| Download: ML17157B104 (15) | |
Text
Licenses:
NPF-14, NPF-22 U. S. Nuclear Regulatory Commission Region I
Inspection Report
Docket/Report:
50-387/92-04; 50-388/92-04
Licensee:
Pennsylvania Power and Light Company
2 North Ninth Street
Allentown, Pennsylvania
18101
Inspection At:
When:
Susquehanna
Steam Electric Station, Berwick, Pennsylvania
February 18-21, 1992
Inspectors:
L.
ert,
mergency Preparedness
Section
C. Conklin, Emergency Preparedness
Section
D. Mannai, Resident Inspector
T. Fish, Division of Reactor Safety
J. Lusher, Emergency Preparedness
Section
~>(i
qg
date
Approved:
q li~lsz
E. McCabe, Chief, Emergency Preparedness
Section,
date
Division of Radiation Safety and Safeguards
Areas Inspected:
(EP) including the annual, partial-participation
exercise; program changes; emergency facilities, equipment, instrumentation, and supplies;
organization and management,
training, and independent reviews/audits.
Results
The licensee
demonstrated
the ability to take appropriate
action to protect the public.
Event classification, task prioritization, response
team briefings and use, technical staff
support, procedure use, and Recovery Manager performance were exercise strengths.
Other
indicators of an effective program included restructuring ofthe EP organization, the number
of individuals qualified for emergency
response
organization
(ERO)
positions,
and
administration of the drill/exercise program.
Until the
Recovery
Manager
arrived
at the
Emergency
Operations
Facility (EOF),
interaction between the Technical Support Center and the EOF was an exercise weakness.
EOF activation time and
the breadth/frequency
of ERO training were identified
as
unresolved items.
9c" 032
DOC/ 05000387
40107 920313
ADO
G
DETAILS
1.0
Persons Contacted
The following key licensee personnel attended the exit meeting held on, February 21, 1992.
J. Minneman, Supervisor', Nuclear Emergency Planning
C. Myers, Manager, Nuclear Regulatory Affairs
G. Stanley, Plant Superintendent
C. Roszkowski, Senior Emergency Planner
R. Halm, Nuclear Operations Support Coordinator
The inspectors also interviewed and observed the actions of other licensee personnel.
2.0
Emergency Exercise
The, Susquehanna
Steam Electric Station conducted
a partial-participation
emergency
exercise
on February
19,
1992, from 1:00 p.m. to 7:00 p.m.
The Federal
Emergency
Management Agency di'd not observe off-site performance.
Commonwealth ofPennsylvania
personnel observed exercise activities in the Emergency Operations Facility (EOF).
2.1
Pr~xercise Activities
Exercise obje'ctives were submitted to NRC Region I on December 6, 1991. The complete
scenario package
was submitted on January
7, 1992.
After NRC review and telephone
discussions with the licensee, minor scenario revisions were made by the licensee.
The revised scenario was challenging in event classification and allowed adequate
testing
of the major parts of the Susquehanna
Steam Electric Station Emergency Plan and its
Implementing Procedures.
Also, the scenario provided the opportunity for the licensee to
demonstrate
those areas previously identified for corrective action.
NRC observers attended the February 19, 1992 licensee briefing on the revised scenario.
The licensee
stated
that certain
emergency
responses
would be simulated
and
that
controllers would intercede in the exercise to prevent disrupting normal plant activities.
2.2
Exercise Scenario
The scenario included the following simulated events:
An 'anonymous call stating a threat involving a possible radiation release.
That led
to the declaration of an Unusual Event per EP-IP-001, "Emergency Classification."
(An EAL 16.1A security report of an attempted entry).
~
An offgas explosio Main turbine. load reject, delayed turbine trip with a stuck open stop and control
valve causing overspeed,
and reactor scram with fuel damage from the pressure and
power transient.
That led to an Alert declaration per EP-IP-001. (EAL3.2A, -C, -D
significant cladding degradation)
Decreasing reactor vessel water level, with Reactor Core Isolation Cooling (RCIC)
and High Pressure Coolant Injection (HPCI) starts.
The Condensate
Storage Tank
(CST) test line broke due to water hammer caused by HPCI actuation.
RCIC turbine oscillation and overspeed trip. A RCIC steam line break pressurized
the RCIC room, causing an unmonitored and untreated radiation release
via., the
steam vent panel,
That led to a Site Area Emergency declaration per EP-IP-001
(EAL 18.38.1, -2.f, failure of RCIC steam isolation valves HV-F008 and HV-F007
to close indicated on Panel 1C601, and other indication of RCIC steam leakage).
Exercise termination.
2.3
Activities Observed
The
and
1,
2.
3.
5.
6.
7.
8.
10.
11.
NRC observed the activation and augmentation of the Emergency Response, Facilities
actions of the Emergency Response
Organization.
The following were observed;
Selection and use'f control room procedures.
Detection, classification, and assessment
of scenario events.
Direction and coordination of emergency response.
Notification of licensee personnel and off-site agencies.
Communications/information flow, and record keeping.
Assessment
and projection of off-site radiological
dose,
and
consideration
of
protective actions.
Provisions for in-plant radiation prot'ection.
Provisions for communicating information to the public.
Accident analysis and mitigation.
Accountability of personnel.
Post-exercise
critique by the licensee.
2.4
Exercise Finding Classifications
exercise findings were classified, where appropriate,
as follows. =
R":gp ii
iCh
the
'bNyp
ih
plant conditions and implement the Emergency Plan.
E<xerci e Weakne:
a less than effective Emergency Plan implementation aspect which does
not, alone, constitute overall response
inadequac ~
Area for Im r vement:
an aspect which did not significantly detract from the licensee's
response, but which merits licensee evaluation for corrective action appropriateness.
2.5
Exercise Observations
e
The NRC team noted that the activation, of the Emergency Response Organization (ERO)
and Emergency
Response
Facilities (ERFs), and the use of the ERFs, were generally
consistent with the Emergency Plan and Emergency Plan Implementing Procedures.
Overall ERF~ Observation
The following exercise strengths were identified:
~
Proficient use of the'EAL scheme
and a demonstration of good knowledge ahd
discipline by not upgrading classification when conditions did not warrant that.
~
Good use of position-specific procedures.
imulat r
ntr I Room
R
~
~
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~
~
~
~
~
~
~
The Shift Supervisor
(SS) assumed
the role of Emergency Director (ED) and provided
strong direction. The ED maintained an overall view which facilitated quick and accurate
classification of events:
Shift of command and control to the TSC went smoothly.
Operators, Communicators, and Data Recorders were given clear direction by the SS and
Unit Supervisor.
The Unit Supervisor executed the EOPs correctly and shifted properly
from one procedure to another.
Procedures
were properly used throughout the exercise.
The operators accurately assessed
changes in plant conditions and implemented corrective
actions.
Communications within-the SCR were clear and effective.
The SS frequently
apprised the TSC Operations Coordinator of essential reactor safety information.
Notifications from the SCR were made within the required time to State and local agencies
as well as to the NRC.
Changing plant and radiological conditions,
and emergency
classifications were properly announced.
The inspectors noted that several important events
(RCIC trip, RCIC steam line break, and HPCI auto-initiation) were not documented in the
Simulator Unit 1 Log. Overall:
~
SCR command and control was an exercise strength.
~
No SCR exercise weaknesses
were found.
~
SCR Logkeeping was identified as an area for improvemen Technical
u
rt
enter
T
The TSC was staffed and activated 56 minutes after the Unusual Event declaration and
prior to the Alert declaration.
TSC activation is required at an Alert.
The TSC was
activated early to remove the burden of controlling site evacuation and the security search
from the SCR.
Initiating conditions were properly assessed
and classified.
The Emergency
Director
frequently consulted with TSC managers
and provided detailed briefings to the TSC staff.
The Operations Coordinator provided good support to the ED and maintained good focus
on plant conditions, facilitating prioritization of Operations Support Center (OSC) tasks.
The TSC staff made good use of the equipment available (e.g., the plant process computer).
Notifications from the TSC were made within the required time limits to State and local
agencies
as well as 'to the NRC.
.The inspectors noted informal communications between TSC management
and the EOF.
In addition, the inspectors
observed
a lack of coordination and/or
a lack of effective
information dissemination concerning important'scenario
events.
For example:
~
Word that the security event was deemed not credible did not reach the EOF until
an update on event status was specifically requested
by the Recovery Manager.
~
The EOF Support Manager was not aware of the Emergency Director's decision to
provide a sheltering PAR.
~
Individuals did not identify themselves
b'y their ERO position during telephone
conferences,
allowing the ED decision to issue
a sheltering PAR to be readily
misconstrued
as a recommendation to the ED.
The Radiation Protection Coordinator (RPC) logbook was well maintained until dose
assessment
was assumed
by Radiation Support Manager (RSM) in the EOF; there was a
subsequent lack of logbook detail about phone calls with the RSM. The TSC Emergency
Director's logbook provided good detail. The TSC Coordinator's logbook was excellently
detailed.
Lack of formality was evident in the RPC, RSM, and TSC Coordinator logbook
identifications ofERO personnel by name rather than ERO position title. The Operations
Coordinator's log provided adequate detail. Status boards were well maintained.
Overall:
~
Frequent, detailed TSC staff and management
meetings were an exercise strength.
~
Prioritization of emergency maintenance
tasks was an exercise strength.
~
Interaction between the TSC and EOF (50-387/92-04-01 and 50-388/92-04-01) was
an exercise weaknes ~
TSC logkeeping was identified as an area for improvement.
erati ns
u
rt
enter
In general,
emergency
repair
team
(ERT) members
were notably professional
and
knowledgeable in completing their tasks.
OSC personnel accountability was maintained
throughout the exercise. ERTs were well controlled by the OSC Coordinator. Status boards
were maintained.
Teams were dispatched in a timely manner.
The OSC Coordinator's
logbook provided adequate detail.
Overall:
~
Excellent briefings of ERTs on plant conditions, radiological conditions, and tasks
were an exercise strength.
~
No OSC exercise weaknesses
or areas for improvement were found.
Emer enc
erations Facili
The decision to'an the EOF was made at 3:17 p.m.
Pagers were activated at 3:25 p.m.
The Alert was declared at 3:55 p.m. At 4:21 p.m., the EOF relieved the TSC of off-site
radiological.functions and responsibilities. The EOF Support Manager was then responsible
to the Emergency Director for off-site radiological functions and ERO command
and
control. The Pennsylvania DER and BRP were notified of the shift in EOF responsibilities
within five minutes.
Multipletask demands, position-specific procedure problems (see Detail 4.1), and the failure
to communicate
some
important event information (see
TSC exercise
observations)
degraded EOF command and control ~
The EOF was fully activated,.and
command and control of the ERO was shifted to'he
Recovery Manager (RM) at 5:40 p.m. The RM quickly established effective command and
control of the ERO.
'ff-site
radiation monitoring teams were dispatched promptly. The EOF Support Manager
and the Radiation Support Manager effectively controlled these
teams.
Good use of
procedures
was noted throughout the exercise.
The RM and EOF Support Manager/
Radiation Support Manager logbooks were excellently maintained.
Overall:
~
Control of radiation monitoring teams was an exercise strength.
~
Effective command and control by the Recovery Manager was an exercise strength.
~
Provision of prompt and thorough information to the EOF Support Manager by the
EOF technical support s'taff was an exercise strengt, ~
Other than the previously identified ineffective, interaction with the TSC, no exercise
weaknesses
were found.
~
Overloading of key interim EOF management was identified, by the NRC and by the
'licensee,
as an area for improvement.
EOF activation time (see Detail 4.0) was identified, by the NRC and by the licensee,
as an area for improvement.
'
Discrepancies in direction in different position-specific'procedures
(see Detail 4.0)
were identified, by the NRC and by the licensee,
as an area for improvement.
2.6
., Ucensee Critique
E
The NRC team attended the licensee's exercise critique on November 7, 1991. That critique
was assessed
as constructive and thorough.
In general, items. in need of correction were
identified, The inspectors noted the effective use of EP consultants in the critique process.
3.0
Ucensee Action on Previously Identified Items
OPEN (UNR) (50-387/90-18-01 and 50-388/90-18-01) Ensure EALs are clear and conform
~
~
~
~
~
~
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to NRC guidance.
Licensee Engineering and Operations are working to resolve technical
issues.
This willbe reviewed in a subsequent
inspection.
The followingareas for improvement identified during the prior annual exercise (Inspection
Report 50-387/91-19; 50-388/91-19) were acceptably demonstrated
and not repeated:
~
Informal communications
in the Simulator Control Room.
NRC review noted,
however, that communications informalitycontributed to interface problems between
the TSC and EOF during the present exercise (see Details 2.5 and 4.1).
~
OSC Health Physics work practices.
~
EOF position-specific procedures
addressing EOF habitability (see Detail 4.1).
4.0
Operational Status of the Emergency Preparedness
Program
4.1
Changes to the Emergency Preparedness
(EP) Program
The inspectors
discussed
a licensee-described
proposed
change
to the Emergency Plan
affecting EOF activation times and the assignment of an interim manager.
Currently, the
Emergency Plan has a three-hour arrival time for the Recovery Manager. In the meantime,
an interim manager
is in charge of the EOF and the senior response
manager
is the
Emergency Director in the TS NRC guidance calls for EOF activation in ab'out one hour and for the EOF to relieve the
TSC ofkey off-site interfaces. At Susquehanna,
a three-hour EOF staffing delay is specified
, because of the transit time from the corporate offices to the site.
Interaction problems
between the TSC and EOF (see Detail 2.5) appear to be related to the EOF activation
delay. The licensee also identified this conside'ration and was considering alternatives.
This
matter is unresolved pending NRC review of the licensee's disposition. (UNR 50-387/92-04-
02; 50-388/92-04-02).
The inspectors reviewed Emergency Plan and Implementing Procedure changes made since
the last EP inspection for adverse effects on EP and for proper licerisee review, approval,
and distribution.
The inspectors concluded that these changes improved the Emergency
Plan and have not decreased
its effectiveness.
The inspectors
noted discrepancies
in the direction provided by some position-specific
procedures.
For example,
"Emergency
Director/TSC," and
"Radiation Protection Coordinator," do not address turnover ofresponsibility for and control
of dose calculations, communications to DER and BRP, and radiation monitoring teams to
the EOF Support Manager (ESM) or Radiation Support Manager (RSM). The Emergency
Plan directs such turnover and it is reflected iiiESM and RSM position-specific procedures.
EP-IP-215-B provides a formalized turnover form to the RSM.
No other discrepancies
were identified in this area.
- 4.2
Emergency
Response
Facility (ERF)
Equipment,
Instrumentation
and
Supplies
All equipment
was
observed
to be in an operable
condition and
was available
as
demonstrated in the exercise,
4.3
Organization and Management. Control
The licensee has implemented a significant EP organizational change that puts less distance
between staff and management
by removing a middle level manager from the command
chain. The Supervisor, Nuclear Emergency Planning (SNEP) now reports to the Manager,
Nuclear Regulatory Affairs, who reports to the Vice President,
Nuclear Operations.
In
addition, the change made line managers accountable for their parts ofthe Emergency Plan.
There were no other changes in program administration or implementation.
The EP staff has been stable and has a good discipline mix (including a former Senior
Reactor Operator).
That staff was assessed
as sufficient to meet program needs.
moS
The ERO was fully staffed.
The licensee goal was to maintain three qualified individuals
qualified in all ERO positions.
In practice, they were 4-5 deep in personnel 'qualified in
t ERO position This portion of the licensee's program was being effectively implemented.
-
4.4
Knowledge and Performance of Duties (Training)
The inspectors reviewed training records of selected individuals in the ERO and found them
to meet training requirements.
Lesson plans were reviewed and determined to be properly
reviewed and'approved.
Lesson plan content was found good.
Nuclear Training Procedure
NTP-QA-52.1 delineated
the responsibilities
for training
emergency
response
personnel
and the process
by which the Emergency Plan training
program was developed
and maintained.
That procedure delineated minimum required
reading in Attachment
1 and an ERO position/lesson
plan matrix in Attachment
2.
Attachment
1 completion was required each January.'ttachment
2 lesson plans for an
ERO position were completed in entirety for initial trainirig; each newly selected'individual
had one year to complete initial training.
Most lessons'were
not required for continued
certification. Many ERO positions received continuing EP training only through General
Employee Training (GET) requalification and required reading.
Some individuals had not
received
any EP overview training since
1982.
Lesson plan EP-001, "Emergency Plan
Overview,",was not required for recertification for any ERO.position. Also, the licensee had
concluded that fundamentals
need periodic review and was working on a video covering
basic EP concepts.
The inspectors noted that the lesson plans specified in the.matrix did
not'provide the breadth and/or frequency to insure that all individuals received the ongoing
ERO training needed.
This willbe further evaluated in a subsequent
inspection (UNR 50-
387/92-04-03 and 50-388/92-04-03).
The licensee required that all ERO members participate in a drill or exercise at least once
every four years for continued ERO certification. Further, the licensee goal was that ERO
members participate in a drill or exercise at least every two years.
The inspectors reviewed position-specific procedure
(PSP) training, which had not been
formally implemented.
The bases for training requirements
and guidelines were to be
delineated in EP-605, "On-the-Job-Training."
EP-605 was in draft form and out for review
and
approval.
This program
aspect will'e included,
as appropriate,
in future EP
inspections.
I
No unacceptable
conditions were identified in this area; continuing program improvement
efforts were noted.
4.5
Independent Reviews/Audits
The licensee's Nuclear Quality Assurance (NQA) audit was conducted from October
14,
1991 to November 18, 1991. Three persons made up the audit team, which worked about
six weeks.
The team observed several EP drills and evolutions.
No adverse findings were
~
made,
six observations
were noted, and no recurring items were identified.
The audit
checklist was thorough, and the report was submitted to EP management
and to PP&L
upper management.
As required, NQA audit results were provided to the Commonwealth
of Pennsylvania 'and local governments.
Corrective actions were tracked on the computerized Emergency Management Open Item
Tracking System (EMTRAC). EP-AD-003, "Nuclear Emergency Planning (NEP)
Tracking,'-'evision
0, 6/24/91, described
that system.
Inputs were derived from EP activations,
exercises, drills, audits, and inspections.
The inspectors noted that the system did not track.
items that might be identified by other means (such as Surveillance Tests). The Supervisor,
NEP reviewed and approved all completed actions.
Detailed reports were generated
to
describe items, status, priorities, dates,
etc.
A hard copy of assignments
and corrective
actions taken was maintained.
This system was unique to NEP. To avoid duplication and
provide consistency, NEP was in the process of transitioning to the station's tracking system.
AD-QA-426, Revision 0, 8/26/91, "Deficiency Control and Corrective Actions Program,"
described
this system.
NRC identified items were currently entered
and the licensee
planned to enter other items by 4/1/92.
Use of this system was expected to.give greater
visibilityof EP problems to management.
Causal factor analysis was not specifically addressed
by NQA.
However, NQA audited
previously closed items and QA Surveillance Report 91-088 dated 1/3/92 concluded that
closure of reviewed items was effective.
Corrective action follow-up was
reviewed for Item FHD-0062, which questioned
the
adequacy of review of the assumptions
and calculations on which PARs are based.
This
Priority 1 item was based
on misinterpreted fuel damage
estimates providing high dose
calculations which could affect Protective Action Recomm'endations
(PARs) by making them
more conservative.
FHD-0062 was generated on March 18, 1991 and due on June 14, 1991.
As of February 22, 1992, the status list provided (and dated November 7, 1991) showed this
item as open.
But, EMTRAC did not identify any interim resolutions or directions, or
provide a revised due date.
Neither could the NEP Supervisor identify the current status
and projected resolution date.
The inspectors concluded that the transition to the station tracking system was a good self-
improvement initiative that should better assure open item follow-up and updating. Overall,
this program area was assessed
as being well implemented.
Procedure NSI-2.2.1, "Coordination, Organization, and Management ofExercises and Drills,"
Revision 5, 3/21/91, established guidance and responsibility for drills. This included drill
development,
management
and referees,
scheduling,
approvals,
corrective
actions,
and
objectives, Procedure EP-AD-001, "Recordkeeping: Nuclear Emergency Planning," Revision
3, 11/21/91, established documentation requirements for drills, exercises and actual
events.'n
addition, NEP maintained a five-year exercise schedule that was approved by the Plant
Superintendent.
There was no documentation of tracking of drill/exercise objectives. NEP
indicated that they intend to develop a method of tracking thos Six station EP drills were being conducted
each year.
In addition, separate
drills were
conducted for off-site municipalities (1/yr). There were also contaminated injured pei'son
drills (2/yr) and off-site fire company drills (2/yr). NEP also supported State drills (4/yr).
\\
Drillpackages were timely, complete, and widely distributed to management.
Allreports
included an overall summary, strengths and weaknesses
per facility, met/unmet objectives,
and recommended
corrective actions. Allrecords were submitted yearly for microfilming.
Both microfilm and hard copies were designated to be maintained for the life of the plant.
This program area was assessed
as being effectively implemented.
I'he
inspector reviewed a draft licensee report on the January
18, 1992 Unusual Event
involving an offgas hydrogen explosion and a contaminated injured man.
The licensee's
report was very detailed and arrived at sound conclusions, It included root cause analysis.
The draft report appeared
to be appropriate.
5.0
Exit Meeting
The inspectors met with the licensee personnel denoted in Detail 1 at the conclusion of the
inspection to discuss
the inspection
scope
and findings.
The. exercise
weakness
and
unresolved items were identified. The inspector also discussed areas for improvement. The
licensee acknowledged the findings and stated their intention to evaluate them and institute
corrective actions as appropriate.