IR 05000397/1985004
| ML17277B650 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 02/20/1985 |
| From: | Fish R, Temple G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17277B649 | List: |
| References | |
| 50-397-85-04, 50-397-85-4, NUDOCS 8503140468 | |
| Download: ML17277B650 (18) | |
Text
U.S.
NUCLEAR REGULATORY COMHISSION
REGION V
Report No. 50-397/85-04 Docket No. 50-397 License No. NPF-21 Licensee:
Washington Public Power Supply System 3000 George Washington Way P.
O. Box 968 Richland, Washington 99352 Facility Name:
Washington Nuclear Project No.
(WNP-2)
Inspection at:
WNP-2 Site, Benton County, Washington Inspection conducted:
January 14-18, 1985 Inspector:
G. H. Temple, Em rgency Preparedness Technician Wo Da e Si ned Approved By:
R. F. Fish, Acting Chief Emergency Preparedness Section Da e Signed Su~arum:
Ins ection durin the eriod of Januar 14-18 1985 (Re ort No. 50-397/85-04)
area of knowledge and performance of duties (training), follow-up of 4 open items identified during the emergency preparedness preoperational inspection of June 20 to July 1, 1983 and observation of the emergency exercise of June 1,
1983, and follow-up on Information Notice 83-28.
This inspection involved about 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br /> onsite by one NRC inspector.
Results:
No significant deficiencies or violations of NRC requirements were identified.
All 4 open items have been closed and 1 item that was previously closed has been re-opened.
8503140468 850221 PDR ADOCK 05000397'
PDR,
DETAIIS Persons Contacted
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AJ Bouchey, Director, Support Services Chitwood, Manager, Emergency Planning and Environmental Davis, Training Scheduling Specialist Day-Phalen, Principal Trainin'g Development and Evaluati ecialist Derrer, Senior Training Specialist Downs, Lead Engineer, Telecommunications Feldman, Manager, Plant Quality Assurance Flory, Foreman, Health Physics and Chemistry Gano,'Shift Technical Advisor Graybeal, Manager, Health Physics and Chemistry Hughes, Plant Technical Engineer Klauss, Senior Emergency Planner Mannion, Senior Emergency Planner Martin, Plant Manager, WNP-2 Mertens, Quality Assurance Compliance Engineer Mogle, Senior Emergency Planner Ogletree, Manager, Training Development and Evaluation Parry, Principal Health Physicist Peters, Manager, Plant Administration Quay, Manager, General and Technical Support Training Quinn, Principal Scientist Shannon, Assistant Managing Director, Operations Stickney, Manager, Technical Training Van Hoff, Senior, State Liaison
"
Wyrick, Manager, WNP-2 Nuclear License Training Programs on Program Follow-u on Information Notice The inspector verified that the licensee had received, reviewed for applicability and taken appropriate action in response to IE Information Notice No. 83-28,'Criteria for Protective Action Recommendations for General Emergencies".
Emergency Plan Implementing Procedure (EPIP)
13.14.2, Revision 2, "Process for Determining Protective Action Recommendations",
dated April 27, 1984 was found to contain the site-specific protective action recommendation guidelines compatible with those shown in Figure 1 of IE Notice 83-28.
(IN-83-28) is closed.
Licensee Action on Previousl Identified Items (Closed)
0 en Item (50-397/83-23-15):Construction of the decontamination facilities had not been completed.
Construction of the decontamination facilities at the 441 foot level of the Turbine Building and 501 foot level of the Reactor Building was complete and both facilities were operational at the time of this inspection.
The inspector noted that a
portion of the Turbine Building decontamination facility was roped off as
a radiation area due to sampling lines mounted on the wall.
The other decontamination facility contained several large barrels and water hoses.
In spite of the condition of the facilities, both appeared to be capable of meeting their intended purpose.
This item is, closed.
(Closed)
0 en Item (50-397/83-23-26):
Installation, procedure preparation and related training of Control Room (CR) activated siren(s)
were not complete.
Inspection Report No. 50-397/83-43 stated that the training part of this item had not been completed and a subsequent inspection, Inspection Report No. 50-397/84-05, stated that three certification forms had not been completed and returned.
The inspector examined the training record files that contained the supplemental training certification forms and verified that the three remaining forms had been signed and returned.
According to the records, the last certification form was completed on March 27, 1984.
This item is closed.
During the investigation into the subject of CR activated sirens, the inspector discussed the plant alarm system with licensee personnel.
According to Inspection Report No. 50-397/83-43, Open Item (50-397/83-23-24)
was closed based on the fact that the licensee was going to install visual alarms (strobes) in high noise areas and that until the strobes were installed and operational a manual sweep of identified high noise areas to assure that all personnel had been evacuated would be made.
The inspector was informed that the strobe lights had never been purchased or installed, but that tests to identify the high noise areas had been peiformed by the safety group in June 1984 and by an independent contractor in December 1984.
Further, licensee personnel stated that tests of the alarm system, to determine the siren output above ambient noise levels, were to be conducted within the next few weeks.
The inspector reviewed EPIP 13.10.1,
"Control Room Operations and Shift Manager Duti'es" and noted that the procedure did not contain a
list of identified high noise areas.
Although licensee personnel stated that CR personnel are aware of high noise areas, a list of the high noise areas was compiled by emergency preparedness personnel and posted within the CR before the end of this inspection.
Due to the apparent delay in the completion of this project and the fact that it did not seem to appear on any of the licensee's tracking systems, the inspector informed the licensee that this matter would be re-opened.
(85-04-01)
(Closed)
0 en Item (50-397/83-23-44):
Installation of the Emergency Dose Projection System EDPS and training of operators in integrated plant operation on equipment was not complete.
The installation part of this item was incomplete because the system could only be operated in the manual mode until the sensors from radioactive release points were tied into the system.
This had been accomplished at the time of this inspection.
Mith respect to the training part, the inspector noted that of the 34 people required to have Offsite Dose Assessment (ODA) training, only 5 were non-current in their training.
The inspector also noted that these individuals had last received ODA training in March 1984. It should be pointed out that the licensee's back-,up method for calculating dose projection was recently changed from a hand calculation to a battery operated computer system.
Training on the use of the new system had already begun and additional computer(s)
were to be ordered and placed in the CR and Technical Support Center (TSC).
This item is close (Closed)
0 en Item (50-397/83-23-57):
There was an excessive delay in moving unessential personnel that were to be evacuated away from the plant.
In response to this item> EPIP 13 5 2p Immediate Evacuation of the Protected Area",
was modified and provisions made to obtain vehicles to transport evacuees and a means of expediting the transport.
This item is closed.
Knowled e and Performance of Duties (Trainin )
This inspection included an examination of the licensee's emergency training program.
Section 16 of the licensee's Emergency Plan (EP)
describes the emergency training program and EPIP 13.14.7, Revision 3,
"Emergency Training", dated December 31, 1984, has been developed to implement the training program described in the EP.
This training program has been established to satisfy the requirements of 10 CFR 50.54(q),
CFR 50.47(b)
and Section IV;F of Appendix E to
CFR Part 50.
Attachment A to EPIP 13.14.7 identifies the individual training courses which comprise the emergency training program for onsite as well as offsite emergency response personnel.
There are a total of thirty (30)
individual training courses.
Attachment A consists of an Emergency Response Training Topic Sheet for each of the 30 training courses.
Each topic sheet includes a description of the course, the intended audience, contact hours, procedures to be covered, class prerequisites and topics to be covered.
Attachment B to EPIP 13.14.7 provides emergency staff member training requirements.
Attachment B is divided into the following three sections:
1) Plant Emergency Organization Member Training Requirements, 2)
Emergency Operations Facility (EOF) Emergency Organization Member Training Requirements, and 3) Headquarters and Other Emergency Organization Member Training Requirements.
Each section is presented in matrix form and specifies which training courses are required and the period in which retraining is to be provided.
The majority of the courses specify annual retraining, however, one course (Emergency Organization Overview) is only required every five years, and courses such as Fire Brigade Training (FBT) and Respiratory Protection Training (RPT) are only required every two years.
For scheduling purposes, EPIP 13.14.7, Rev. 3, states that annual refresher training should be completed within 3 months of the anniversary date of initial qualification and new training course requirements, for personnel already qualified, should be completed or at least scheduled within 3 months of the revision.
The licensee's emergency organization is described in EPIP 13.14.5, Revision 1,
"Emergency Organization",
dated November 14, 1983.
This procedure identifies those persons (by job title) within the Supply System who are assigned emergency functions and provides a mechanism for updating and controlling the list of assigned individuals.
Additionally, in an effort to reduce the emergency organization into practical terms, Appendix II, "Emergency Organization Assignment List and Training Requirements",
to the EPIPs (Volume 13 of the Plant Procedures Manual)
has been developed.
Appendix II identifies the emergency organization by
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title and by emergency centers (e.g. Control Room (CR),
EOF, etc.).
Individuals noted in Appendix II have been identified by name and, in accordance with EPIP 13.14.5, the list is updated quarterly or whenever substantial changes to the emergency organization have been made.
As indicated by the title of Appendix II, the training requirements for each emergency title have been included.
Attachment A to Appendix II also provides a cross reference to NUREG-0654 Table B-l, Minimum Staffing Requirements.
The emergency training program described above was originally established, maintained and managed by the Emergency Planning and Environmental Programs (EP&EP) Department.
As of November 1983, responsibility for the emergency training program was transferred to the Technical Training Division.
Within the Technical Training Division, General and Technical Support Training (G&TST) is responsible for general employee training and all but 5 of the 30 previously mentioned training courses.
Training Development and Evaluation Programs (TD&EP), is responsible for scheduling all training and maintaining training records, and Washington Nuclear Project-2 (WNP-2) Nuclear License Training is responsible for Control Room Emergency Operations (CRE) training and Accident Assessment Training (AAT).
CRE and AAT are 2 of the 5 courses noted above (i.e., not under the direction of G&TST).
The 3 remaining courses, Communication Centers Operations (CCO), Security Force Radiological Emergency Training (SFR)
and Security Decision Center Operations (SDC) are controlled by the Security Department.
The responsibility for these 5 courses was transferred from the Technical Training Division to the respective groups around November 1, 1984.
Recognizing the need to keep EP&EP involved in the emergency training program, some responsibilities have been established for the manager of EP&EP.
These responsibilities are described in EPIP 13.14.7, Rev. 3, and they include the need to conduct a quarterly review of emergency organization personnel training status, review and approve training modules and tests, and approve individual training requirements of the emergency organization.'ith respect to maintaining training records and scheduling emergency training, TD&EP has developed a computer tracking system called Emergency Plan Training System (EPTS)."
EPTS can provide data through 7 separate reports, one of which (Report No. 3, Required Training Completed/Not Complete), is used as a tool to establish training schedules.
Report No.
3 has been formated to provide a listing of each emergency training course, each person in the emergency organization required to take the course and the date the training was completed.
Report No.
3 is updated manually from class attendance records and, in accordance with EPIP 13.14.7, Rev.
3, is provided to the Manager, EP&EP.
A quarterly report, consisting of all 7 EPTS reports, is prepared and distributed.
Although somewhat cumbersome to work with, Report No.
1 does provide a listing of the training status of each member of the emergency organization.
Report No.
1 divides the emergency organization into groups (e.g.,
operations, technical, maintenance, etc.).
Within each group, individuals are listed alphabetically by emergency organization title and training requirements for the position are noted.
Since some individuals have been identified as alternates for other emergency positions, they may be listed more than
k
once.
Included in Report No.
1 is the date that training (by course)
was last completed, the date when retraining is due and the lead time (advance notice) for each course.
The inspector interviewed the Training Scheduling Specialist (TSS) to determine the process used for scheduling emergency training.
This individual stated that based on the data provided in EPTS Report No. 3, he determines which classes need to be conducted and who needs to attend them.
After some coordination with the Manager, GSTST, to determine instructor availability, the TSS produces a monthly schedule, in the form of a calendar of classes to be conducted.
Although EPIP 13.14.7, Rev.
states that scheduling will be arranged through department managers, the TSS stated that he usually notifies the individual attendees or their secretaries.
The TSS explained that because he had only been in his current position since October 1984, he did not know all of the reporting chains.
Recognizing the need to have additional controls in this area, the Manager, GSTST indicated that they intend to start notifying the individuals'anagers, preferably 6 weeks in advance of training.
During this inspection, the inspector examined the emergency training records for a selected group of emergency response personnel.
The inspector selected the Control Room Emergency Center personnel which consists of Shift Managers, Control Room Supervisors, Reactor Operators and Shift Technical Advisors.
The inspector obtained the current Emergency Organization Assignment List and Training Requirements (Appendix II described above),
dated October 1984, in order to identify those individuals assigned to these positions.
Additionally, the inspector discovered that the GRTST Manager tracked the training status of emergency response personnel using his own system.
This personal tracking system was easier to use than the EPTS Reports and it was verified that the Manager's manually updated records were consistent with the EPTS Reports.
Since both sets of records were being manually updated on a daily basis (EPTS Computer Reports are only run once per month and updated manually in-between),
the training records were considered to be current as of the date of this inspection.
Based on the examination of the aforementioned training records, the inspector determined that of the 35 individuals identified as Control Room Emergency Center personnel, 10 individuals were not current in all of the required emergency training.
The break down is as follows:
Shift Mana ers Required Training
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AAT, CRE, RPT, ODA, Emergency Organization Overview (EOO), Protective Action Recommendations (PAR) and Technical Support Center Operations (TSC)
Of the 6 Shift Managers identified (1 from each of 6 rotating shifts),
had not had CRE Training since April 1984 and 1 had not had RPT since May 1984.
Only 1 of these individuals had completed both TSC and PAR Training, however, since these courses were not added to the list of
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required training courses for Shift Managers until November 1984, according to EPIP 13.14.7, Rev. 3, they are considered to be current.
Control Room Su ervisors Required Training
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AAT, CRE, EOO, ODA, PAR, RPT Of the 6 Control Room Supervisors identified (again, 1 from each shift),
1 had not had CRE Training since April 1984.
Only 1 had completed PAR Training, but this was because it was considered to be a new requirement.
Reactor 0 erators Required Training
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AAT, CRE, EOO, RPT Of the 16 Reactor Operators identified (all but 2 shifts identify 3 individuals),
3 had not'had CRE Training since April 1984 and 1 had never had initial CRE Training.
Shift Technical Advisors Required Training
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AAT, CRE, EOO, ODA, PAR,'PT Of the 7 Shift Technical Advisors identified, 1 had not had AAT or CRE Training since April 1984, 1 had not had ODA Training since March 1984 and 1 had never had initial,CRE Training.
During the course of the inspection, several discussions with the Managers of EPSEP and GSTST were held to discuss the status of emergency response training, including the results of the inspector's examination.
During these discussions, the inspector was informed that an audit of the training and qualification of the VHP-2 plant staff had been conducted during the period September 25-28, 1984.
As a result of this audit (No.84-309),
3 equality Finding Reports ((}FRs) were issued, 1 of which (No.
of 3), described a deficiency in the area of emergency training.
Specifically, the audit disclosed that 65 plant personnel were overdue for certain emergency response training courses and that 8 plant personnel had not received all initial training.
In accordance with the licensee's equality Assurance (gA) procedures, a written response to the
/FR was submitted which included:
1) Action taken to correct the deficiency, 2) Action taken to eliminate the cause of the deficiency and, 3) The implementation date of the stated corrective action.
The response that was submitted by the Manager, Technical Training stated that all deficiencies would be corrected by January 1,
1985; Licensed Operator requalification training in the simulator is comparable to CRE Training and will be credited as meeting the requirement for refresher training; AAT, ODA and TSC refresher training would be satisfied upon successful completion of a refresher exam.
The response also stated that the status of emergency training was being manually tracked and that Emergency Planning would perform their quarterly audit of the program, in accordance with EPIP 13.14.7, Rev. 3.
Additionally, the. response stated that a new computer tracking system would be in place by June 1,
1985.
It should be pointed out that, as a modification to this corrective action, waiver exams were being given for CRE and AAT Training.
Waiver
e
exams for ODA Training would not be given due to a recent change in the back-up method used to calculate dose projections (see Details Section 3, Open Item 83-23-44).
To determine the adequacy of the licensee's corrective action, the inspector examined the waiver exams given in lieu of AAT and CRE refresher training.
The inspector determined that these two refresher exams appeared to adequately test the individuals',knowledge of the material that would have been covered in classroom training.
The inspector also verified that the Manager, EPSEP had reviewed and approved the waiver exams.
In consideration of the licensee's position that Licensed Operator Requalification Simulator Training is comparable to CRE Training, the inspector examined copies of the scenarios which are used in the simulator and a sample of a Simulator Exam Report which lists 12 specific areas to be addressed in the evaluation.
This material, as well as the topics and procedures covered in CRE Training, were compared and discussed with Region V personnel.
Based on these discussions, for the purpose of this inspection, the simulator trai'ning was found to be comparable to CRE Training.
Therefore, since the 8 individuals identified as non-current in their CRE Training had completed the simulator training, all were considered to be qualified to perform their function(s) in an emergency.
It should be pointed out that the licensee's Emergency Training Program has undergone some significant changes during the past year.
In addition to a change in management, an extensive Job.Task Analysis was initiated in March 1984 in an effort to try and pare down the amount of training given to emergency response personnel.
As a result of the work completed to date on the Job Task Analysis, licensee training personnel determined that there was a considerable amount of duplication within the training program as a whole.
Based on this information, the 5 training courses discussed earlier in this section were transferred to those program areas where qualified individuals could judge the amount of duplication and produce lesson plans accordingly.
Additionally, the Technical Training Division had developed a Technical Training Manual, dated December 5, 1984, that describes the mission,of'the Technical,Training Division and provides for a systematic approach to the development and management of the training program.
Licensee personnel explained that the effort devoted to these two projects prevented the development of emergency training refresher modules., Training personnel indicated that the initial training courses were too long and detailed to consider using them for refresher training.
'As a result of the audi;t, the Job Task Analysis was put on hold so that the refresher modules could be produced prior to retraining those individuals who were over due in their emergency training.
Licensee personnel further explained that the availability problems associated with CR personnel also led to the training problem that currently existed at the site.
No significant deficiencies or violations of NRC requirements were identified.
Exit Interview
At the conclusion of the inspection, the inspector met with those persons so identified in section 1.
Mr. A. D. Toth, Senior Resident Inspector, NRC, was also present.
The scope of the inspection and the findings, as shown in sections 2 and 3 were discussed.
With respect to section 4, the inspector informed the licensee that it appeared that the requirements identified in the first paragraph of section 4 had not been completely satisfied.
The inspector stated that all of the information obtained from that part of the inspection would be discussed with Region V
Management personnel before a final decision on the matter of a violation could be made.
Licensee personnel were subsequently informed by telephone on January 25, 1985 that the decision had been made not to issue a Notice of Violation in the area of training based on the fact that the Licensed Operator Simulator Training appeared to be equivalent to CRE Training and an internal QA audit addressed problems in the training progra I g
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