IR 05000387/1994008
| ML17158A311 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 05/25/1994 |
| From: | Keimig R, Maier W, David Silk NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17158A310 | List: |
| References | |
| 50-387-94-08, 50-387-94-8, 50-388-94-10, NUDOCS 9406060287 | |
| Download: ML17158A311 (14) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION I
License/Docket/Report No.:
Unit 1 NPF-14/50-387/94-08 Unit 2 NPF-22/50-388/94-10 Licensee:
Pennsylvania Power and Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Facility Name:
Inspection At:
Inspection Period:
Susquehanna Steam Electric Station Berwick, Pennsylvania May 2 - 5, 1994 Inspectors:
W. Maier, Emergency Preparedness Specialist o~
D. Silk, Senior mergency Preparedness Specialist Approved By:
I
. Keimig, Ch f Emergency Prep ness Section Areas Inspected:
Emergency Preparedness (EP) program, including: program changes; emergency response facilities (ERFs), equipment, and supplies; emergency response organization (ERO) training; audits; and corrective actions taken on previous NRC identified items.
Results:
The EP program was well implemented.
Changes made to the Emergency Plan and procedures did not decrease the Emergency Plan's effectiveness.
Changes made to two alternate off-site ERFs were not in accordance with the Plan.
One change to an off-site ERF resulted in a non-cited violation of NRC regulations.
Poor coordination, communication and general oversight of work groups responsible for these two facilities was a program weakness.
Allon-site ERFs were operationally ready.
The scope and effectiveness of corrective actions for previously identified deficiencies was a strength.
However, assessment of training effectiveness was mixed; superior knowledge and expertise demonstrated by ERO members was a strength, but the repeated use of the same EP examination to test the effectiveness of training was a weakness.
Four open items from the previous inspection were inspected and closed.
'7406060287 940525 PDR ADQt."K 05000387
DETAILS 1.0 LIST OF PERSONS CONTACTED Pnn lv i
P wr Lih T. Dalpiaz, Manager-Nuclear Maintenance J. Finnegan, Supervisor-Nuclear Compliance D. Hagan, Supervisor-Health Physics G. Jones, Vice President-Nuclear Engineering I. Kaplan, Manager-Energy Information W. Kelley, Instructor-Emergency Plan G. Kuczynski, Manager-Nuclear Plant Services J. Lex, Nuclear HP/Chem/EP Training Supervisor H. Palmer, Manager-Nuclear Operations R. Prego, Supervisor-Site Quality Verification A. Price, Unit Coordinator C. Roszkowski, Acting Supervisor-Emergency Planning G. Stanley, Vice President-Nuclear Operations W. Tabor, Nuclear Emergency Planner R. Wehry, Compliance Engineer I rR
mmi i n S. Barber, Senior Resident Inspector Denotes attendance at the entrance interview on May 2, 1994.
Denotes attendance at. the exit interview on May 5, 1994.
Other persons were interviewed or contacted by the inspectors during the conduct of the inspection.
2.0 REVIEW OF CHANGES TO EM%,GENCY PLAN AND IMPLEMENTING PRO CEDURI<$
The inspectors reviewed Revisions 16 through 20 of the SSES Emergency Plan (the Plan)
at the NRC Regional office during the weeks prior to the inspection.
These revisions were reviewed to determine if they decreased the effectiveness of the Plan.
The inspectors concluded that none of the revisions resulted in a decrease to the Plan's effectiveness.
The inspectors also reviewed some of the changes that were made to the Emergency Plan Position-Specific Procedures (PSPs)
since the last NRC inspection.
The inspectors reviewed these changes to determine ifthey were consistent with the changes made to the Plan and to determine if they decreased.
the effectiveness of the Plan's implementation.
The changes reviewed were for the primary decision makers
(Emergency Director and Recovery Manager) and for communicators in the Control Room and the Emergency Operations Facility (EOF).'he inspectors concluded that all of the changes to these procedures were consistent with the changes to the Plan and did not decrease the effectiveness of the Plan's implementation.
2.1 FMERGENCY PLANNINGINSTRUCTIONS The inspectors reviewed the Emergency Planning Instructions (EP-AD procedures)
to determine ifthe procedures were consistent with the Plan and to determine ifthe EP-ADs met the requirements for implementing procedures under NRC's Appendix E of 10 CFR Part50.
The requirement states that changes to the Emergency Plan and its implementing procedures shall be submitted to the NRC within 30 days of'such changes.
The inspectors concluded that the EP-AD procedures were generally administrative in nature and did not meet the requirement for Emergency Plan implementing procedures.
2.2 EOF EMERGENCY PLAN (EP-AD-017)
During review of the EP-AD procedures, the inspectors noted that one of those procedures',
EP-AD-017 (Emergency Operations Facility Emergency Plan), provides direction for responding to emergency conditions (fire, bomb threat, medical emergency)
at the EOF during working hours under normal conditions.
EP-AD-017 gives guidance for evacuating the EOF and conducting personnel accountability.
However, the procedure is not clear that it applies to normal conditions and not "radiological" emergency conditions.
The inspectors were concerned that during a radiological emergency, emergency response personnel might mistakenly follow this procedure and be put at risk by evacuating to an employee recreation facility that is located across the street from the EOF.
The facility is not shielded and does not have a controlled ventilation system to protect against radiation as is the case with the EOF. Additionally, it does not contain appropriate equipment for managing response to a nuclear plant emergency.
EP-AD-017 directs personnel to relocate to this facility in the event of an emergency at the EOF and remain there until an accountability survey is taken and further direction is given.
In a radiological emergency, personnel could receive unnecessary radiation exposure ifthey evacuated to that facilityinstead of to the backup EOF, which is outside of the plume exposure emergency planning zone (EPZ).
The inspector discussed the matter with the licensee's Nuclear Emergency Planner.
He explained to the inspector that EP-AD-017 was written to fulfilla requirement by American Nuclear Insurers for a fire plan for the EOF.
The Planner stated that the procedure was included as one of the EP-AD procedures, because those were the lowest tiered procedures that covered the day-to-day operations of the EP group.
The Planner agreed that the title of the procedure could be misleading.
He also agreed that it could possibly cause emergency response personnel who were unfamiliar with its intent to mistakenly believe it was applicable to periods ofradiological emergencies.
The Nuclear Emergency Planner recognized the need to clarify the procedure and committed to do this
as part of the upcoming two year review of the procedure that was scheduled for the current month (May, 1994).
The commitment was concurred in by the Acting Supervisor of Nuclear Emergency Planning (NEP).
The inspector confirmed, by reviewing copies of the PSPs for the EOF personnel during a nuclear emergency, that there was sufficient guidance contained in the PSPs to ensure that personnel would evacuate the EOF and would set up operations at the backup EOF in the event that fire or other crises rendered the EOF uninhabitable during a radiological emergency.
2.3 KVERGENCY PLANNINGINSTRUCTION (EP-AD) PROCEDURE CHANGES As stated in paragraph 2.1 above, the inspectors determined that the EP-AD procedures did not meet the criteria to be considered Emergency Plan implementing procedures that had to be reviewed by the NRC when changed.
The inspectors did note, however, that the EP-ADs covered some subjects that are required by NRC regulations and described in the Emergency Plan.
For example:
EP-AD-005 describes the program for preparation and implementation of emergency plan exercises and drills; EP-AD-013 covers the inventory, inspection, operational testing, and calibration of emergency equipment; and EP-AD-014 covers the surveillance testing ofemergency communications equipment.
The inspectors believed that changes to these and other EP-AD procedures could result in inconsistencies with the Plan.
The inspectors also discussed this matter with the Nuclear Emergency Planner.
The inspectors asked the Planner what piecautions were taken to ensure that changes to the EP-AD procedures did not make the Emergency Plan less effective in protecting public health and safety.
The Planner provided the inspectors with documentation that showed how changes to EP-AD procedures were reviewed for safety impact on areas that are governed. by the Emergency Plan.
The Planner uses a form from-EP-AD-000, Attachment E, Safety Effectiveness Review, to document the reviews of EP-AD procedure changes.
The procedure (EP-AD-000) is titled "Changes to Emergency Plan Position-Specific Procedures" and does not specify the use of this form for changes to the EP-AD procedures.
This procedure is intended for making changes to the Emergency Plan PSPs and the purpose of Attachment E is to document the safety effectiveness review of changes to the PSPs.
The inspectors asked the Planner where the requirement for a safety effectiveness review ofchanges to the EP-AD procedures was documented.
The Planner stated that itwas not a written requirement; he was doing it on his own initiative and recognized a need for proceduralizing this practice.
He committed to ensure that the requirement for. a safety effectiveness review forinitialissues of, and revisions to, EP-AD procedures was written into a procedure governing the EP-ADs in the near future. The Acting Super visor NEP concurred with the commitment.
The inspectors concluded that requiring an effectiveness review was necessary to avoid the EP-AD procedures from becoming inconsistent with the Pla EM<WGENCY FACILITIES, EQUIPMWT, INSTRU1VHW'I'ATION, AND SUPPLIES The inspectors reviewed the readiness of communications equipment for the Technical Support Center (TSC) and the EOF. They also conducted an inventory with a technician of the emergency supply cabinets of the Control Room area.
The inspectors found no shortages of equipment for the lockers that were inventoried and determined that the communications circuits inspected in the TSC and EOF were capable of contacting off-site agencies.
The inspectors also reviewed completed inventory sheets and communications tests for the on-site facilities that had been conducted during the past year.
The technician charged with conducting the surveillances and communication tests kept good records and promptly corrected any discrepancies noted while conducting the tests.
The inspectors concluded that the inventories were being performed adequately, since there were no lapses in completed surveillances and no results that were unsatisfactory.
MEDIAOPERATIONS CENTER (MOC) RELOCATION The inspectors reviewed selected Licensee Event Reports (LERs) and Significant Operating Occurrence Reports (SOORs) generated from August 1993 through April1994 to ensure that the events described in these reports were properly classified in accordance with the Emergency Plan.
There were no occurrences or events noted that should have received an emergency classification.
However, one occurrence report, concerning the transfer of the "overflow"MOC, described a situation that constituted a violation ofNRC regulations.
The MOC is the facility in which briefings are given to news media representatives by the licensee.
It is initiallyestablished in the Energy Information Center adjacent to the site. The MOC is relocated to a facilitywith greater capacity when the number ofpeople exceed the comfort limitof the Information Center.
The "overflow" facilityis described in the Emergency Plan.
The overflow MOC was listed in the Plan as being at the YMCAin the town ofBerwick, within the 10 mile plume exposure EPZ. Itwould have to be relocated again in the event that a general emergency caused the EPZ to be evacuated.
To enhance the Plan, the licensee planned to move the overflow MOC from the Berwick YMCA to its new Northeast Division Headquarters in Wilkes-Barre, outside the 10 mile'EPZ.
The physical move was to be carried out by the staff of the Special. Office of the President (SOP), because they staffed the MOC and maintained its equipment and facilities.
The SOP staff moved the overflow MOC from the Berwick YMCA to Wilkes-Barre without notifying the NEP group.
The telephones. were disconnected at the Berwick YMCA on October 14, 1993, rendering that facility inoperable.
The SOP staff was
unaware that NRC regulatory requirements existed for the overflow MOC that had to be satisfied prior to and concurrent with the move to Wilkes-Barre.
These requirements included an effectiveness review, a revision to the Plan, and revisions to the PSPs.
There was no coordination between the groups to make the move, and the administrative and procedural changes and reporting requirements that went withitwere not carried out.
The NEP group found out about the dismantlement of the Berwick facility and the establishment of the Wilkes-Barre facility in early November.
The problem was documented on a Significant Operating Occurrence Report (SOOR Number 93-374). A root cause analysis was performed and revealed both NEP and SOP to be lacking in their understanding ofwho was responsible for ensuring compliance with the requirements that applied to the MOC. The Plan was revised to reflect the change that was made, and the required reviews to verify that the effectiveness of the Plan was not decreased were performed.
The NEP group revised the PSPs to reflect the change and submitted the changes to the NRC on December 1,
1993.
This date exceeded the 30-day limit established in 10 CFR Part 50.54(q) for ensuring that changes to emergency plans are reported to the NRC.
The licensee recognized that the period of 48 days from the time of the MOC move to its report to the NRC was a violation of 10 CFR 50.54(q) and the Nuclear Compliance group evaluated the violation for reportability. No formal reportability requirement was identified, but the occurrence was communicated orally to the resident NRC inspectors arid to the regional NRC staff.
The licensee took immediate corrective actions when the move was identified and initiated actions to prevent recurrence.
The Plan and procedures were promptly and appropriately revised to reflect the actual location of the MOC.
The actions taken to prevent recurrence include an agreement between the NEP and SOP groups that establishes responsibility for ensuring regulatory compliance for the MOC with the SOP staff. It also specifies greater communications between these two groups and with the Nuclear Compliance group to prevent a recurrence.
The inspectors found that this incident was a violation of NRC regulations.
The inspectors reviewed the SOOR and the Plan and procedures that were affected by"the change in the MOC location.
The inspectors concluded that the actions taken to correct the problem were prompt, effective and comprehensive, particularly the revisions to the Plan and procedures.
The inspectors also acknowledged the licensee's comprehensive evaluation and efforts to determine the reportability of this event and the fact that it was reported it to the NRC staff orally when no formal reporting requirement was identified.
The inspectors also commended the performance of a root cause analysis for this event as an excellent initiative.
The inspectors reviewed the last three NRC EP inspection reports for Susquehanna, and could not find any indication that this event was a potentially recurring problem that
should have been recognized and corrected previously. They also determined that it was
. not a willfulviolation based on interviews with the Special Assistant'to the President, who directed the move to the MOC, and other licensee personnel.
The inspectors also acknowledged that the violation of the 30 day reporting requirement was primarily compliance oriented and not a safety issue or one that impacted the public.
The inspectors judged the violation and the corrective actions taken to meet the criteria for mitigation of enforcement sanctions as listed in 10 CFR Part 2, Appendix C, VII,B.(2).
This violation, therefore, is classified as a licensee-identified non-cited violation.
BACKUP EMERGENCY OPERATIONS FACILITY The inspector reviewed SOOR Number 93-382 that was written on November 16, 1993 that described a degradation of the Backup Emergency Operations Facility (BEOF) in Hazleton.
That facility is normally occupied by, a company division that is not related to the nuclear plant.
This SOOR described a problem similar to the one involving the relocation of the MOC and documented how the BEOF had become degraded due to the removal of equipment that is used to respond to emergency conditions.
The equipment included a radio antenna, a data terminal, and some of the telephone lines.
The documentation described the extent of the problem and stated that the equipment could be replaced quickly, but "significant confusion could be expected."
The SOOR also described the corrective action that was taken to restore the BEOF to its fullyoperational status.
The antenna was reinstalled, the data terminal was restaged (and additional terminals were added),
and telephone lines were re-installed, marked for identification, and tested to ensure operability.
Additionally, emergency response telephone directories were updated to reflect the new phone numbers, and a preventive maintenance procedure was established that required a test'of the BEOF telephone lines and radio antenna semi-annually.
The inspectors reviewed the latest surveillance copy of this procedure and determined that operability of the BEOF equipment was being satisfactorily monitored.
A letter was written to the company division occupying the facility to ensure that all personnel were aware of the requirements for the equipment there.
The inspectors concluded that the corrective actions taken were adequate to restore the BEOF to fully operational status and to prevent recurrence.
Based on the information contained in the SOOR and interviews with personnel, the inspectors concluded that the BEOF would have been able to function, ifneeded, during its period of degradation.
The SOOR indicated that 13 phone lines were still available, the radio antenna was able to be replaced quickly, and backup data terminals were available.
The degradation of the BEOF was identified by NEP at about the same time as the identification of the MOC move to Wilkes-Barre.
Each of these events listed a lack of communication and coordination between the NEP group and the organizations that occupy or are responsible for the facilities involved as a root cause.
The inspectors
concluded that each facility was able to perform its function in the event of an emergency.
They concluded; however, that a lack of NEP oversight of these facilities and a failure to communicate the regulatory requirements to all involved parties were potential program weaknesses.
4.0 To evaluate the effectiveness of the licensee's Emergency Preparedness (EP) training program, the inspectors reviewed various records and procedures and interviewed several Emergency Directors (EDs) and Recovery Managers (RMs).
4.1 TRAININGPROGRAM REVIEW The inspectors reviewed attendance records for EP drills and exercises conducted'during the period of August 1993 through April 1994.
During drills, there was sufficient diversity ofpersonnel participation such that the same individuals were not playing in the same positions during each drill, There was also rotation among personnel who filled the "referee" positions (controllers/evaluators).
The inspectors sampled the attendance records of the last four NRC exercises for the ED and RM positions.
The inspector found that one individual had been the ED in three of the four exercises whereas there had been three different RMs for the same exercises.
The inspector noted that more diversity in the ED position during exercises would allow other EDs the opportunity to gain more experience and, thus, strengthen the 'Nuclear Emergency Response Organization (NERO).
The inspectors reviewed the lesson plans, classroom handouts and the examinations for two EP courses that occurred during the week of this inspection.
The courses were Emergency Classification and Dose Assessment and Protective Action. The inspectors determined that the lesson plans and handouts for these courses were acceptable.
However, when reviewing the examinations for these courses, the inspector found that the same ED examination had been administered from year to year and within each year for the last several years for the Emergency Classification course.
The inspectors brought this to the attention of the EP training personnel and challenged the value of using the same examination as an indicator of training effectiveness.
The licensee's training department staff agreed.
The EP training supervisor agreed to correct the problem by varying future examinations by 30%.
The inspectors felt that this was
- necessary to ensure that the training department is able to determine the effectiveness of training on all of the concepts of EP.
The failure of the training department to develop
- a variety of challenging examinations by which to evaluate the effectiveness of EP training was seen as a potential program weakness by the inspectors.
The inspectors reviewed the qualifications of the NERO members.
The qualifications were found to be current and in accordance with the training matrix.
A sample of recently added NERO members'raining records were also reviewed and found to be in
accordance with the training matrix. The inspectors verified that maintenance personnel on damage control teams were trained on a variety of respiratory protection apparatus and would be capable of responding in a variety of radiological conditions.
In conclusion, the inspectors determined that the overall EP training program was being effectively implemented.
4.2 EMERGENCY RESPONSE PERSONNEL INTFWVIEWS The inspectors interviewed several EDs and RMs.
The interviews tested the EDs'nd RMs'P knowledge and experience.
The inspectors determined these individuals to be very familiar with their EP duties.
These individuals were also noted to have very broad nuclear power plant backgrounds and were very experienced in operation of the Susquehanna Station. The inspector concluded that the individuals were well trained and quaMed to staff these key NERO positions and considered this to be a program strength indicative of a sound EP training program.
4.3 SHIFT WALKTHROUGHS The inspectors conducted tabletop walkthrough examinations with two crews of operators.
The purpose of these walkthroughs was to evaluate the ability of the Shift Supervisors (SSs),
acting as Emergency Directors, to assess, classify, and direct emergency response to scenarios presented by the inspector.
Each walkthrough was conducted with the Shift Technical Advisor (STA) and a Plant Control Operator (PCO)
from the shift in attendance.
The STA was present to advise the SS in the assessment and classification of the events, and the PCO was present to simulate notification procedures.
Each crew was given two scenarios that escalated through the various levels of emergencies that are listed in the Emergency Plan.
The scenarios included a tornado impacting the site, a security event, and two LOCA events in order to evaluate the ability of the crew to respond to fast-breaking events that escalated to General Emergencies.
The ability of the EDs to make on-site and off-site protective action recommendations was also evaluated.
The crews showed no weaknesses in their knowledge and use of the Emergency Action Levels that are indicators of emergencies.
The classifications by the EDs were correct and timely (within 15 minutes) in all cases.
Both of the STAs that were evaluated were able to contribute to accurate classifications and were able to recommend sound protective actions to the EDs.
The PCOs were knowledgeable in their duties and made their simulated notifications on time in all cases.
One crew was consistently conservative in their actions; they classified events as Alerts or Site Area Emergencies before the thresholds for those classifications were reached, but their rationales for taking the conservative approach were acceptabl The inspectors concluded that the crews were well trained in their assessment, classification, and notification ofaccident conditions and duties. The performance of the operating crews and their level of knowledge were considered to be a program strength that was consistent with the performance of the EDs and RMs.
4.3 TRAININGOF OFFSITE AGENCIES While reviewing Susquehanna's EP training matrix, the inspectors interviewed the offsite NEP Planner and checked the training that was provided to the State Police and the local news media personnel.
Records documenting the offering of training to,the State Police were readily available from the Security department.
(Each year, the State Police make a determination if training is necessary based on staff turnover.)
However, it was diffi'cult to determine if training was being provided to media personnel because the training matrix was not consistent with what was stated in the Plan.
The training matrix only specified annual radiation training; however, Section 9.4 of the Plan, (Public Education and Information), stated that, in addition to radiation training, media personnel were to receive (or be offered) training on the Plan and licensee points of contact for information. The inspectors'informed the NEP Planner of the discrepancy between the Plan and the training matrix.
The Planner stated that the discrepancy would be corrected.
The NEP Planner was also able to produce various documentation showing that the commitments of the Plan were being met. The inspectors were satisfied that the proper training was being provided, since documentation ofthe availability ofthe training specified in the plan was demonstrated.
5.0 AUDITS The licensee had not yet completed an audit of the EP program since the last NRC inspection in that area (August 1993).
The audit was in progress and scheduled for completion in the near future. The inspector interviewed the lead auditor for the current audit.
The auditor informed the inspector that the audit team was composed of individuals that were not associated with the EP group.
One audit team member was from the EP group of another utility to provide technical expertise as weH as an independent perspective.
The inspector reviewed the audit checklist that was being used by the audit team.
The checklist consisted of items from the Code of Federal Regulations, the Susquehanna Emergency Plan, PP&L Nuclear Department procedures and EP administrative procedures..
The audit plan also included EP's response to previously identified audit and NRC findings. The inspector considered the checklist to be comprehensive and thorough. The NRC willreview the audit findings during a future inspectio EFFECTIVEMNS OF LICENSEE CONTROLS'uring the inspection, a brief review of the licensee's action item tracking systems was performed.
Based on an interview with the SNEP, the inspectors determined that the
'umber of EP related items has decreased since the EP items were placed on a plant-wide tracking system about two years ago.
EP does not track the number of outstanding items over time.
The inspectors found that the EP Group does not assign priority to items placed in the system and that it was the responsibility of the individual assigned to resolve the item to determine its priority. Currently, there is no method to track/trend repeated occurrences related to EP. The SNEP stated that a system of tracking EP items by correlating them to NUREG-0654 objectives was under development.
The inspectors also found that the licensee had no formal system for tracking the fulfillmentof six year exercise objectives; records were kept and retrieved manually.'The inspectors asked, for and were shown documentation that the six year objectives for off-hours and unannounced exercises were met.) The inspectors were informed that a tracking system for these exercise objectives was also under development.
Because of the informalityof certain aspects of the EP tracking system, its effectiveness relies upon manual efforts.
The inspectors concluded that the planned improvements would enhance the EP program.
The inspectors did not identify any missed requirements under the current system.
They concluded that the current system was adequate for ensuring that action items were addressed and corrected.
CORRECTIVE ACTIONS The inspectors reviewed the effectiveness of the licensee's corrective actions for identified deficiencies and found them commendable.
They evaluated these while inspecting the problems that were encountered with the alternate off-site facilities (see paragraphs 3.1, 3.2 above).
They also evaluated them while inspecting actions taken to address open items that were identified in the last NRC EP inspection.
The inspectors found that the actions taken in response to identified deficiencies that were documented on SOORs were very comprehensive and aggressively pursued; for example, a specific reportability assessment that the Nuclear Compliance Group performed within three days of the identification of the MOC problem.
Root cause determination was practiced and documented.
The resolution was specifically documented on a form that the responsible parties had to sign to accept the corrective actions imposed.
The issue was resolved in a very short period of time.
The inspectors concluded that this was due to the systems in place and the quality mindset and dedication of the NEP group.
They found that the management tools and the positive attitudes of the responsible personnel were a
significant program strength.
7.0 REVIEW OF OUTSTANDINGOPEN ITFMS The inspectors reviewed four items that were opened during the last EP inspection.
These items were an unresolved item that dealt with review of Position-Specific
Procedure changes and three inspector-followup-items that dealt with maintenance of NERO individual qualifications and the specified quantities of certain emergency supplies.
The items are discussed below.
(CLOSED)
URI 50-387,388/93-1401 During inspection 93-14 (August 1993), the inspectors identified that changes to the Position-Specific Procedures (PSPs) had not been specifically reviewed to determine if they reduced the effectiveness of the Emergency Plan as required by 10 CFR Part 50.54(q).
During this inspection, the inspectors found that the governing procedure for changes that are made to the PSPs, EP-AD-000, (Changes to Emergency Plan Position-Specific Procedures)
had been revised. Achecklist'was added to ensure that a safety effectiveness review in accordance with 10 CFR Part 50.54(q) was completed for all changes made
'to the PSPs prior to the changes being implemented.
The inspectors also reviewed a random sample of changes that were made to the PSPs during the first calendar quarter of 1994 and found that a safety effectiveness review had been completed for these changes, The inspectors concluded that the corrective action taken for this item was adequate.
This unresolved item is closed.
(CLOSED)
IFI 93-14,02 During Inspection 93-14, the inspectors identified inconsistent procedural guidance pertaining to the length of the grace period allowed to NERO members whose qualifications had expired.
The Personnel Qualification System (PQS) grace period extended to the end to the calendar quarter, but procedure NDAP-QA-0776 (Selection, Training and Certification of the Nuclear Response Organization) allowed only a period of 60 days.
Therefore, the possibility existed for a qualification to expire without the individual being removed from the NERO for a period of 30 days.
During this inspection, the inspectors reviewed the licensee's corrective actions for this item. The licensee initiallyreplaced the 60 day requirement in NDAP-QA-0776 with the PQS grace period (the end of the calendar quarter).
However, NDAP-QA-0776 was recently eliminated and its contents were incorporated into NTP-QA-52.1, Emergency Plan Training Program.
The inspector verified that this procedure states that qualification expires on the last day of the calendar quarter.
Therefore, when the quarterly PQS-generated list of expired NERO individuals is issued, it is synchronized with the NTP-QA-52.1 expiration date.
The inspectors determined that the licensee's actions were acceptable to prevent unqualified individuals from remaining assigned to the NERO with current qualification. This item is close.3 (CLOSED)
IFI 93-14-03 During inspection 93-14, the inspectors noted that several emergency equipment check lists specified required amounts of certain items to be "as sufficient." No guidance was given in the checklists as to what constituted an "as sufficient" quantity. The inspectors discussed this item with NEP personnel, and NEP committed to change the checklists to specify minimum inventory levels.
During this inspection, the inspectors verified that the words
"as sufficient" were removed as a required quantity from all checklists except for the quantities of herculite vinyl covering specified for use by the off-site hospitals.
They discussed this with the Off-site Nuclear Emergency Planner.
He showed the inspectors a copy of a change to the equipment checklists for the hospitals that was awaiting approval.
The new revision specified an exact requirement. The inspectors=considered the corrective action for this item to be adequate.
This item is closed.
7A (CLOSED)
IFI 93-14-04 During inspection 93-14, the inspector identified an individual on the NERO list whose qualification had been expired for five months.
During this inspection, the inspectors reviewed a computer print-out of training and
~ expiration dates, individual training records, and the backup NERO list (the Telenotification System) to ensure that individuals with expired qualifications were not on-call to respond to an emergency.
The inspector reviewed the print-out and no individuals with expired qualifications (as annotated on the print-out) were on the NERO list. Two individuals who were on the most recent NERO On-Call list (April 18, 1994)
were not found in the print-out.
Upon further investigation, the inspectors determined that these two individuals had been recently removed from the NERO list (due to reasons other than expired qualifications). The inspectors then checked the Telenotification System to confirm the status of the two individuals in question.
The Telenotification System is the system that the Station Security Department uses to automatically notify NERO members to respond to an emergency.
The Telenotification System is updated immediately following any NERO personnel change.
(The printed copy of the NERO On-Call list is updated only when several changes need to be made.)
The inspectors determined that the two individuals had been removed from the Telenotifiication System and would not be notified to respond in the event of an emergency.
The inspectors also sampled individual training files of personnel recently added to the NERO.
The sampling confirmed that the training they had received was in accordance with the training matrix and was in agreement with the data on the print-out.
NERO members are informed by letter when their qualifications are about to expire.
The letters are sent to the members by the training coordinators for the members'ork groups at 90, 60, and 30 day intervals prior to the expiration of the individuals
qualifications. When the expiration occurs, the individuals are removed from the NERO
. and are sent letters notifying them as such by the SNEP.
The inspectors audited those individuals that were sent notification letters on April15, 1994 against the current NERO list. Allaudit records revealed that those individuals were no longer on the NERO or have since received the necessary requalification training before being placed back on the NERO.
Also, on a quarterly basis, the functional leads (the lead individual for the NERO positions) receive a print-out to check the qualification status ofindividuals within their group.
Thus, several methods are in place to identify and address expiring qualifications.
The inspectors were not able to identify any individuals on the NERO that had expired qualifications and found that the licensee's system was capable of identifying and removing individuals whose qualifications had expired.
The. inspectors were satisfied with the licensee's efforts to maintain the NERO with qualified individuals.
This item is closed.
8.0 EXIT INTERVIEW The inspectors met with the Vice Presidents of Nuclear Operations and Nuclear Engineering and selected members oftheir staffs at the conclusion of the inspection.
The inspectors presented a summary of their findings and discussed the non-cited violation of the NRC requiiements.
The inspectors also reviewed the prompt and thorough corrective action taken by the NEP group that justified mitigation of enforcement sanctions.
The strengths and weaknesses of the Susquehanna EP program that they observed during the inspection were also discussed.
The licensee acknowledged the inspection findings and the inspectors'omment, and confirmed the commitments documented in this inspection report.