IR 05000387/1993014

Insp Repts 50-387/93-14 & 50-388/93-14 on 930809-13. Emergency Preparedness Program Being Acceptably Implemented. Major Areas Inspected:Program Changes,Emergency Facilities, Equipment,Instrumentation & Supplies

ML17157C458
Person / Time
Site:	Susquehanna
Issue date:	08/30/1993
From:	Lusher J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML17157C457	List: IR 05000387/1993014 ML17157C456
References
50-387-93-14, 50-388-93-14, NUDOCS 9309090018
Download: ML17157C458 (13)

Text

I U. S. Nuclear Regulatory Commission Region I Docket/Report:50-387,-388/93-14 Licenses: NPF-14,-22 Licensee:

Pennsylvania Power R Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Facility:

Susquehanna Steam Electric Station Berwick, Pennsylvania Dates:

Inspectors:

August 9-13, 1993 J. Lusher, Emergency Preparedness Specialist Gordan Bryan (USNRC Contractor)(COMEX)

~bol~y date Approved:

E. McCabe, Chief, Emergency Preparedness Section, Division of Radiation Safety and Safeguards K /7o('?s SCOPE Emergency preparedness (EP) program inspection, including program changes; emergency facilities, equipment, instrumentation, and supplies; training effectiveness, and open items. The inspection included interviews, inspector observations, and selected document reviews.

RESULTS The emergency preparedness program was being acceptably implemented.

Strengths were noted in management involvement, in the EP audit program, and in supporting state and local governments.

A considerable effort was being applied to modify the Emergency Action Level (EAL) scheme to incorporate Nuclear Materials and Resources Council (NUMARC)EALs and document the EAL bases.

Also, enhancements to the training and drillprograms were being considered.

Changing position specific procedures without assuring completion of reviews for potential Emergency Plan degradation was identified as an unresolved item.

9309090018 930831 PDR ADOCK 05000387 PDR ~

TABLEOF CONTENTS 1.0 Persons Contacted.......................................

2.0 Emergency Plan and Implementing Procedures............

2.1 Changes to Emergency Plan Position SpeciTic Procedures

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2.2 Changes to Administrative procedures.............

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3.0 Emergency Facilities, Equipment, Instrumentation 3.1 EOF Ventilation System 3.2 Inventory Check List and Supplies

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4.0 Organization and Management Control...........................

5.0 TIaming e

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5.1 ERO On-Call List and Qualification

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5.2 Pire and First Aid Drill

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6.0 Independent and Internal Reviews and Audits 7.0 Review of Open Items..............

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1.0 Persons Contacted DETAILS The following licensee personnel attended the exit meeting on August 13, 1993.

T. Clymer, Nuclear Quality Assurance Coordinator T. Dalpiaz, Manager, Nuclear Maintenance W. Kelley, Instructor, Nuclear Training G. Kuczynski, Manager, Nuclear Plant Services W. Lowthert, Manager Nuclear Training C. Myers, Manager, Nuclear Regulatory Affairs R. Peal, Supervisor Nuclear Emergency Planning C. Roszkawski, Senior Emergency Planner R. Wehry, Compliance Engineer The inspectors also contacted other licensee personnel.

2.0 Emergency Plan and Implementing Procedures 2.1 Changes to Emergency Plan Position Specific Procedures The Susquehanna Steam Electric Station (SSBS) Emergency Plan and Position Specific Procedures were reviewed.

The Emergency Plan had been reviewed by the licensee in accordance with Emergency Planning Administrative Directive, EP-AD-015, Annual Review, Revision, and Distribution ofSSES Emergency Plan, including a 10CFR50.54(q)

review of all changes and revisions.

The Position Specific Procedures changes were in accordance with EP-AD-000, Changes to Emergency Plan Position SpeciJlc Procedures.

This procedure required a 10CFR50.59 safety review ofrequired procedures, but did not specify a 10CFR50.54(q) review for degradation of the Emergency Plan.

EP-AD-000 was therefore in need of upgrading to assure application of this safeguard against plan degradation ttuough Position Specific Procedure changes.

Inasmuch as no plan degradations were identified, this matter is unresolved pending further NRC review (URI 50-387,-388/93-14-01).

2.2 Changes to Administrative procedures The licensee had completed the conversion from coriventional, subject-oriented Emergency Plan Implementing Procedures (EPIPs) to position-oriented procedures.

The inspector reviewed NDAP-QA-0775 (Revision 2), Emergency Plan Position Specific Procedure Program, several position-specific procedures, and the Nuclear Emergency Response Organization (NERO) On-Call list procedures and qualification process.

Nuclear Training Procedure, NTP-QA-52.1 Emergency Plan Training Program, Paragraph 6.2.2.3 stated that training lapsed (expired) on the last day of the calendar month in which it was taken in the previous year.

Nuclear Department Administrative

Procedure, NDAP-QA-0776 Selection, Training and Certification of the Nuclear Emergency Response Organization, Paragraph 6.5.4 required that an individual whose training had expired retrain within the next 60 days or be disqualified for that NERO position.

The inspector reviewed 150 triiiiingrecords on the Personnel Qualification System (PQS).

The PQS-generated training lapse dates had been changed to the end of a quarter rather than the end of the month and the 60-day grace period before disqualification had been eliminated.

Planning for this shift to quarterly expiration of training and elimination of the 60 day grace period prior to disqualification included quarterly promulgation of the NERO On-Call lists, about one week after the close of the quarter.

That delay was intended to allow Training to complete PQS training record input through the end of quarter, but could result in individuals whose training had expired at the end of the quarter remaining on the NERO call list.

The licensee committed to review 'and correct its Administrative Procedures to ensure that there would be no lapse in quaMcation for fillingpositions in NERO.

There were no unqualified personnel on the NERO; formalization of the review requirement willbe re-evaluated in a future inspection (IFI 50-387,-388/93-14-02).

Program implementation in this area was assessed as acceptable.

Emergency Facilities, Equipment, Instrumentation and Supplies The inspector toured the Control Room (CR), Technical Support center (TSC),

Operational Support Center (OSC) and the Emergency Operations Facility (EOF) to inspect for operational readiness.

The emergency facilities were found to be as described in the emergency plan and the equipment was in good operational condition.

All survey equipment checked was in good operational condition, with calibrations within the required time periods.

AH other equipment and supplies were present as indicated by the use of inventory sheets, The Emergency Notification System (ENS) phone in the TSC to the NRC operations center was functioning properly.

3.1 EOF Ventilation System The inspector reviewed the EOF ventilation system operational and functional test and found that it met the criteria in American Society of Mechanical Engineers (ASME)

Standard N510, Testing ofNuclear AirTreatment Systems, which were referenced in the EOF ventilation system test procedure.

3.2 Inventory Check List The inspector reviewed the past year's inventory check list for the facilities and found them to be complete.

However, in the check list which established minimum requirements for the equipment and supplies, there were some items which indicated "As

Sufficient."

How "As Sufficient" was determined was not identified.

The licensee decided to change the check list to specify minimum inventory levels.

No inadequate inventory levels were noted; assurance ofadequate inventory willbe reinspected (IFI50-387,388/93-14-03).

Overall, this area was assessed as being effectively implemented.

4.0 Organization and Management Control The Emergency Response Organization (ERO) was found to be as described in the emergency plan.

All ERO positions could be filled by one of at least three qualified individuals. Four persons were qualified for most positions.

Management was involved in emergency preparedness drills and exercises and had maintained qualifications in their assigned positions.

The inspector interviewed two Emergency Directors (EDs), two Interim Recovery Managers (IRMs), and the Emergency Preparedness Supervisor.

These individuals understood their duties and the emergency response organization very well.

The Emergency Response Organization (ERO) has remained stable since the last inspection.

Because the Supervisor, Emergency Planning was attending operator licensing certification school, he was temporarily replaced by the Supervisor of Regulatory Compliance.

The supporting EP staff consisted of six highly qualified individuals.

Overall, the Emergency Preparedness Staff basically has been stable since the last inspection.

Licensee performance in organization and management control aspects of EP was assessed as effective.

5.0 Tfalillllg The SSES Emergency Plan (E-Plan) contained four pages of training requirements.

Inspector review found these insufficient for development of an EP training program, particularly with respect to training of the Nuclear Emergency Response Organization (NERO). However, the implementing procedures at the station and training department levels were found to compensate for that.

Nuclear Department Administrative Procedure, NDAP-QA-0010 (Revision 0); Nuclear DeparIment Minimum QualigcaIions

& Training Requirements; NDAP-QA-0776, Selection, Training & Certification of the NERO (Revision 1), NDAP-QA-0777 (Revision 0), Conduct of Nuclear Emergency Planning; Nuclear Training Procedure NTP-QA-52.1 (Revision 5), Emergency Plan Training Program; and the SSES Emergency Planning Training Curriculum (Revision 7) were particularly significant to the quality of the EP training program and were

reviewed in depth.

NERO qualification consisted of three phases:

selection, training and certification.

Training was defined on a per position basis in the training matrix.

Where retrainiiig was required, with the exception of the certification drill or exercise participation, traiiiing expired on the last day of the calendar month one year later while certification (drill or exercise participation) lapsed four years later on the last day of the calendar month, An individual was available forassignment to the NERO provided that his or her training had not been expired for more than 60 days.

After traiinng expiration plus 60 days, the individual was no longer qualified to fillthat NERO position. Exceptions could be granted, on a case basis, with prior approval of the Senior VP Nuclear.

Training records were tracked on the computer-based Personnel Qualification System (PQS).

The inspector spot-checked 150 source record data fields to verify correct input to the PQS; all this data had been entered correctly.

Specific E-Plan commitments to invite DER/BRP, state police, county and municipal agencies, and local fire and ambulance companies to participate in annual licensee sponsored training were also reviewed.

With the exception of the state police and one ambulance company, the

'nvitations extended were accepted and appropriate training had been provided withinthe past 12 months.

ERO On-Call List and Qualification The inspector reviewed two NERO On-Call lists (Revisions 4 Bc 5 dated 4/1/93 8r.

8/5/93, respectively) against training records and found that one individual remained on the NERO On-Call list and fulfilledperiodic duties as Damage Control Coordinator for five months with an expired qualification.

Specifically, Qualification EP-054 expired 12/31/92 and disqualification was required on 2/28/93.

The individual remained on the qualification list, served as Damage Control Coordinator between 3/1/93 and 8/2/93, and requalified on 8/2/93.

No associated NDAP-QA-0010 Paragraph 1.1.(a)

special exception to the qualification rule was sought from or granted by the Senior VP Nuclear.

The licensee stated that this problem had been identified in a June 1993 Quality Assurance audit which found about 10 cases of disqualified persons continuing to serve in the NERO.

Subsequent to the QA finding, the individuals identified by QA were requalified on an expedited basis.

A 100% licensee review of qualification status of all persons in NERO uncovered others not detected in the QA sample.

These persons were also requalified on an expedited basis; all requalification was completed by 8/2/93. In view ofthe licensee s identification and correction ofthis problem, the inspector had no further questions, but identified effectiveness of actions to prevent recurrence for future NRC inspection (IFI 50-387,388/93-14-04).

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5.2 Hre and First AidDrill The inspector observed a combined Fire and First Aid drill conducted with the on-site Fire Brigade and First Aid teams and off-site Fire and Ambulance Companies. The off-site companies participating were:

Shickshinny Fire Department, East Berwick Hose Company ¹2, Salem Township Fire Company ¹1, Shickshinny Volunteer Ambulance Association, Berwick Ambulance Association, and the Berwick Hospital Paramedic Unit.

Also participating in the medical part of the drill were Geisinger Medical Center and Berwick Hospital Center.

The drillwas assessed as exceHent training.

There was excellent interface between on-site and off-site organizations.

Also, the critiques were detailed and effective, with good feedback from the off-site units.

Overall, licensee performance in EP Training was assessed as effective.

6.0 Independent and Internal Reviews and Audits To assess 10CFR50.54(t)

implementation, the inspectors reviewed Nuclear Quality Assurance EP Audit Reports92-034 and 93-060.

A meeting was held with the lead auditor for both audits to discuss the planning and preparation for the audits, as well as audit scope, contents and findings.

EP program reviews were conducted annually by the Nuclear Quality Assurance staff.

The audit plan and audit check list used included the Emergency Response Plan and the Emergency Response Plan Position Specific Procedures (PSPs), the Emergency Response Plan program and emergency response organizations, training and drills, notification and communications, facilities and equipment, public information, and coordination with off-site support groups.

Surveillance audits were also conducted during the year or upon request.

The inspectors found that the 1992 and 1993 audits were thorough and comprehensive.

These audits included interviews of off-site officials to determine the adequacy of the interfaces with State and local authorities.

State and local authorities were notified of the results of the 10CFR50.54(t) portion of the audit during the annual meeting with off-site officials.

Emergency Planning shifted all tracking of corrective actions from the emergency management tracking (EMTRAC) system to the site-wide Deficiency Control and Corrective Actions Program.

That provided wider dissemination of and attention to EP items.

Overall, the audit program was assessed as comprehensive and effectively implemente.0 Review of Open Items (OPEN)

(UNR 50-387/388-90-18-01)

At the time of this inspection, the licensee was still re-evaluating EALs for conformance to NRC guidance and to assure that all EALs are clear and unambiguous.

This item willremain open until the NRC has completed review of the NUMARCEAL scheme which was submitted to the NRC in March 1993.

(CLOSED)

(UNR 50-387/388-92-04-03)

The inspector noted that the lesson plans specified in the matrix did not provide the breadth/or frequency to insure that all individuals received the ongoing ERO training needed.

This item was corrected by the Supervisor Emergency Preparedness's annual review of the emergency planning training program and by licensee review of the emergency preparedness overview lesson plan (EP-001R) being required every three years.

(CLOSED)

(UNR 50-387/388-92-04-02), 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 appeared to be related to the EOF activation delay. The licensee also identified this consideration and was considering alternatives.

This item is closed as the licensee has incorporated into the emergency plan the Interim Recovery Manager position and a minimum required staff of thirteen to man and activate the EOF within one hour.

This corrective action was also effectively demonstrated during the February 24, 1993, FEMA-graded Exercise.

8.0 Exit Meeting The inspectors met with the licensee personnel listed in Detail 1.0 at the conclusion of the inspection to discuss the scope and findings.

During the exit meeting, the areas for potential improvement areas were discussed.

The licensee acknowledged the findings and stated the intention ofevaluating these and would take corrective action as appropriat l I

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