IR 05000397/1992005
| ML17289A448 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 03/23/1992 |
| From: | Mcqueen A, Reese J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17289A447 | List: |
| References | |
| 50-397-92-05, 50-397-92-5, NUDOCS 9204100216 | |
| Download: ML17289A448 (19) | |
Text
4 U.
S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos:
50-397/92-05 License No:
NPF-21 Licensee:
Mashington Public Power Supply System P.O.
Box 968 3000 George Mashington Way Richland, Washington 99352 Facility Name:
Mashington Nuclear Project, Unit 2 (WNP-2).
Inspection at:
WNP-2 Site, Benton County, Washington Inspection Conducted:
February 24-28 and March 3-6, 1992 Inspector:
. VA 3 zc/ez c ueen, me e
c repare ness na ys a
e
>gne i
Approved by:
.
~Summar:
2 29 2-eese, le
,
eguar s, mergency a
e gne rep edness, and Non-P wer Reactor Branch Areas Ins ected:
This'unannounced, routine inspection by a region-based 1 nspec or, examined the following portions of the licensee's emergency preparedness program:
Open Items identified during previous emergency preparedness inspections; Shift Staffing and Augmentation; Knowledge and Performance of Duties; Operational Status of the Emergency Preparedness Program and Inspector Identified Items.
During this inspection, portions of Inspection Procedures 82205,-82206, 82701, 92701 and 92703 were used.
Results:
In the areas inspected, the licensee's emergency preparedness program
. appeared adequate to accomplish its objectives.
The licensee was found to be in compliance with NRC requirements within the areas examined during this inspection.
9204i00216 920323 PDR ADOCK 05000397
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INSPECTION DETAILS Ke Persons Contacted
"H.
L. Aeschliman, Emergency Planner
",J.
W. Baker, Plant Manager W. J. Flory, Supervisor, Radiological Services
"N.
L. Garza, Emergency Training
"A. F. Klauss, Supervisor, EP G. J. Kozlik, Shift Manager
".J.
A. Landon, Drills and Exercises Supervisor, 0 ~
E.
Larson, Manager, Emergency Preparedness
"K.
P.
Meehan, Emergency Planner M.
M. Monopoli, Manager, Support Services
"J.
V. Parrish, Assistant Managing Director of Operations G." 0.
Ray, Emergency Planner
"M.
P.
Reis, Compliance Supervisor W.
D. Shaeffer, Operations Assistant Manager R,
L. Wardlow, Supervisor, Radiological Services The above individuals denoted with an asterisk were present during the exit meeting on February 28, 1992.
The inspector also contacted other members of the licensee's emergency preparedness, administrative, and technical staff during the course of the inspection.
NRC Personnel at Exit Interview
.
A.
D. Mcgueen, Emergency Preparedness Analyst, RV 2.
Functional or Pro ram Areas Ins ected The licensee seemed,to be maintaining their previous level of performance in the following areas and their program appeared adequate to accomplish their objectives.
a.
Shift Staffin and Au mentation (MC-82205)
Two items of special interest were reviewed in the area of organization and staffing during this inspection.,
One was the status of shift staffing to preclude problems such as those discussed in NRC Information Notice (IN) 91-77, "Shift Staffing at Nuclear Power Plants,"
dated November 26, 1991.
The other. was a review of protective actions during plant -shutdowns and outages for nonessential onsite personnel.
In discussions with the site Assistant Operations Manager and the Shift Manager, the licensee indicated that day and night shifts at WNP-2 are staffed at,levels above the minimum levels of staffing indicated in 10 CFR 50.54(m) during operation and shutdown modes.
They also indicated that additional resource personnel are available on site in the event they are needed.
Past actual events have indicated no adverse impact on the ability of an on-duty shift to respond appropriately to emergency events.
This includes.instances
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where the Control Room was required to furnish personnel for fire brigade response.'iscussions with the Assistant Operations Manager and a shift manager indicated that their protective actions for nonessential onsite personnel during plant shutdowns and outages is the same as any other mode of oper ation.
Licensee Emergency Preparedness Implementing Procedures (EPIPs)
address consideration of evacuation of nonessential onsite personnel upon declaration of an'emergency event.
The procedure would function the same in a shutdown mode as in any other operational mode.
Individuals interviewed indicated a
knowledge of the responsibilities set forth in the EPIP and in the procedures for implementing those i esponsibilities.
b.
Knowled e and Performance of Duties (MC-82206)
This topic was covered during interviews with on-duty shift personnel and emergency preparedness staff members.
No weaknesses were
- indicated.
c.
0 erational Status of the. Emer enc Pre aredness Pro ram (MC-82701)
(1)
Emergency Plan and Implementing Procedures Licensee Emergency Plan Implementing Procedures (EPIP), which had been revised since the last 'routine inspection, reviewed during this inspection included:
o EPIP 13.2. 1, Man-Caused and Natural Emergencies, Revision 7, dated November 26, 1991.
o EPIP 13.5.2, Immediate Evacuation of the Protected Area, Revision 6, dated September 5, 1991.
o EPIP 13.5.5, Personnel Accountability, Revision 7, dated
.September 5, 1991.
o EPIP 13.7.8, Transportation of Injured or Contaminated Injured Personnel to an Offsite Medical Facility, Revision 7, dated December 19, 1991.
c EPIP 13.9.6, Field LAB Analysis of Environmental Air Samples, Revision 7, dated December 19, 1991.
o 'PIP 13. 10.3, Technical Support Center Operations and Technical Support Center Director's Duties, Revision 8, dated September 5, 1991.
o EPIP 13. 10.6, Plant/NRC Liaison Duties, Revision 6, dated September 5, 1991.
o EPIP 13. 10.8, Security Supervisor Duties, Revision 6, dated September 5,
199 D y
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EPIP 13. 10.9, Operations Support Center.and Operations Support Center Director Duties, Revisi.on 12, dated November 26, 1991.
EPIP 13. 11. 12, Technical Data Center Operations and Center Director Duties, Revision 8, dated November 26, 1991
'PIP 13. 11. 13, AEOF News Mriting Team Duties, Revision 9, dated September 5, 1991.
EPIP 13. 14.2, Process for Determining Protective Action Recommendations and Protective Action Decisions, Revision 13, dated December 19, 1991.
o EPIP 13. 14.5, Emergency Organization, Revision 10,- dated September 5, 1991.
o EPIP 13. 14. 8, Drills/Exercises, Revision 8, dated September 5, 1991.
In Attachment B (DRILL/EXERCISE PACKAGES) to this EPIP at section II, it is indicated that Part I Ob 'ectives (Uncontrolled Distribution:
e casa e
o p ayers,...
Although not a change from the previous version of this EPIP; )t had been noted in reviewing the objectives for the 1991 Annual Exercise that several objectives could have served as prompts to exercise players, if distributed before the exercise.
This was discussed at the time with the licensee, and it was decided that the objectives would not be distributed to players in advance of the exercise.
This.remains an apparent problem if this procedure continues to provide for such uncontrolled distribution prior to an exercise.
This was discussed telephonically with the licensee on March 6, 1992, and it was indicated that this item would be reviewed to insure prevention of prompting prior to exercises.
No apparent degradations in site emergency preparedness were noted.
(2)
Emer enc Facilities E ui ment Instrumentation and Su lies The Emergency Operations Facility (EOF), Technical Support Center (TSC) and the Operations Support Center (OSC) were toured and inspected, to include response equipment, instrumentation and calibration, and supplies on hand.
Maintenance records and corrective action requests (CAR) were reviewed regarding emergency preparedness equipment and supplies.
It was verified that in instances where supply items were short, equipment deficient or malfunctioning, were identified; appropriate requests for correction were initiated.
Equipment was verified as being in calibration.
It was found that in some instances, however, maintenance and test records were taking what appeared
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to be excessive time in reaching the emergency preparedness planner after such maintenance and tests were performed.
For example, monthly communications check documentation is normally not received until the first week of the month following the checks,'ven though'the documentation i's completed while conducting the checks and any required repairs.
Also, three currently active CARs had remarks indicating that requests for a work completion date, an overdue notification, and a status request had gone unanswered.
Second, and now pending, gueries-had to be sent on all three over one month after the snstial queries.
The tour of the Technical Support Center (TSC) indicated that previously identified conditions were recurring.
NRC Inspection Report Number 50-397/91-02, dated February 19, 1991, had indicated that in the TSC:
...the inspectors observed that most of the office space and.desks were 'being used on a day-to-day basis by plant operations personnel.
Desk tops were 'covered with papers, books, and office utility items,....
...desks are cleared before drills, and the use of the.
office space has not.affected the activation of the facility.
Since drills.are pre-planned, and emergencies are not, the licensee was cautioned,to closely monitor the TSC (and all 'ERFs) to.ensure that routine use does not degrade the emergency function of the facilities.
During the tour of the TSC, the inspectors also observed that there was a pool of standing water...'he licensee'etermined that the water resulted from a leaking relief valve on a. hot water heater located in the room...
The licensee's review concluded that the condition was a safety concern and raised the priority of the repair work.
It was noted on this tour of the TSC that some desk clutter was again evident and the water heater relief valve was again leaking, although not as much as in the previous inspection.
It was also noted that the glass door to the key cabinet housing the key to the TSC emergency equipment cabinet had been broken out and the key was missing.
The licensee determined that the glass had been broken at the beginning of the November 1991 annual emergency exercise and had not been repaired.
The key had been removed since it also unlocked the emergency meals refrigerator, which was stocked with food for TSC responders in an emergency.
It took the licensee several minutes to telephonically locate the key and have it brought to the TSC from another part of the plant.
These observations appear to indicate that TSC emergency readiness may not be receiving appropriate attention as an emergency facility. This item will be reviewed in future inspections.
(92-05-01)
The inspector discussed these items with the licensee during the exit meeting on February 28, 1992.
(3)
Inde endent and Internal Reviews and Audits (a)
Annual Audit. The 1991 Annual Audit of the Emergency
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2 tg WWP2(tdttg1551),dtd July 24, 1991 was reviewed during this inspection..
The audit report executive Summary indicated:
A total of fifteen (15) deficiencies:
five (5) Safety Level II equality Finding Reports (gFRs),
nine (9)
Level III gFRs, one (1) Commercial (FR, and two (2)
Observations were identified.
The majority of the deficiencies can be categorized as failure to perform repetitive administrative tasks
~
A contributing cause-to these failures was the lack of administrative procedures, which management has since agreed to develop.
The deficiencies, observations, and documentation pertaining thereto were reviewed.
The licensee initiated evaluation and corrective action, as appeared appropriate, on all items.
One item identified by the 'audit will be tracked by NRC as an'inspection followup item (IFI).
The audit report indicates, in part:
NUREG-0654 requires agreement letters with outside responding organizations/agencies be established and maintained as part of the Emergency Plan.
The WNP-2 Emergency Plan includes Agreement Letters as Appendix 4.
These Agreement Letters establish and describe capabilities, responsibilities, and interfaces with outs>de respond>ng organ>zations.....
The audit. found that the Agreement Letter between the Washington Public Power Supply System and the State of Washington Department of 'Emergency Preparedness and Response had expired and a replacement letter had not yet been approved.
The audit noted that There is evidence of Emergency Planning's attempts to obtain a new approved Agreement Letter, with numerous items of correspondence between Emergency Planning and applicable State of Washington personnel on file.
However, no valid agreement currently exists.
The licensee'id obtain a letter extending the current agreement until a
new one is negotiated.
In that this is an emergency plan requirement, the item will be tracked until an appropriate letter is promulgated.
(92-05-02)
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(b)
,Licensee Drill and Exercise Criti ues Two licensee emergency preparedness drill/exercise evaluation reports were reviewed:
o Final Evaluation Report 8 Critique, Exercise
'91, dated February 6, 1992.
NRC inspectors had identified one exercise weakness and ll observations which were documented on Corrective Action Reports (CARs).
The licensee had identified two documented findings for which CARs were initiated.
o Remedial Field Team Drill '91, Memorandum dated December 20, 1991.
No deficiencies or items for correction were identified by the licensee.
d.
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Licensee Initiatives (1)
ualit Action Team ( AT) for the 0 erations Su ort Center i.
In NRC Inspection'eport Number 50-397/91-02, dated February 19,,
1991, based on interviews with two OSC director-designees, it was observed that
~.=.based on the results of the OSC Director interviews, the licensee should consider whether corrective actions are necessary to ensure that the OSC can be effectively managed during an emergency.
Licensee CAR Number 91-0002 was initiated on May 9, 1991, to address the OSC performance issues.
A equality Action Team ((AT)
.was selected to review the issues and make appropriate recommendations to plant management.
'The first meeting was held on November 25, 1991, and the team is expected to make its recommendations prior to June 1992.
The (AT has focused it',
information gathering in three areas:
Facilities, Organization and Training.
(2)
Scenario Generator The licensee briefed the inspector on a project schedule for development of a "plant specific exercise scenario radiological data generation computer program."
The project was initiated in January 1992 and is scheduled for inhouse testing near the end of April 1992.
Development of documentation, manuals, and training.materials is scheduled for April and May 1992.
The
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project is divided into 6 task groups.
- The scenario qenerator should enhance emergency preparedness training since st allows for production of more realistic radiological conditions in the plant and will,model the plant source term and plant system i i
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e.
Onsite Followu of Written Re orts of Nonroutine Events at Power eac or aci 1 les (1)
On February 20, 1992, an'nusual event was declared at WNP-2 because of a technical specification (TECH SPEC) required shutdown.
The event report to the NRC Operations Officer was documented as follows:
Licensee entered TECH SPEC 3.0.3 (one hour to repair or start a
TECH SPEC required shutdown).when engineering determined that their reactor building.to wetwell vacuum
'reakers (butterfly valves) setpoints were set in the non-conservative direction.
Licensee has one hour per TECH SPEC 3.0.3 to correct the setpoint problem or at the end of the following six hours be in a'ot shutdown condition.
(Unusual Event was declared because of the TECH SPEC required shutdown).
Licensee has notified the State and County.
Unusual event was terminated at 1935PST when TECH SPEC 3.0.3 was exited.
(2)
At 1: 15 p.m.
on February 25, 1992, the licensee declared an Unusual Event upon entering'Technical Specification 3.0,3 when both post-LOCA hydrogen recombiners were declared inoperable, which affected the operability of the containment atmosphere control (CAC) system.
The NRC Preliminary Notification of an Event or Unusual Occurrence (PNO-V-92-05), dated February 26, 1992, pertaining to this event indicates:
'he licensee terminated the Unusual event at 7:30 p.m.
(on February 25) when the plant reached Mode 3, where the,CAC system is not required to be operable.
In both of the above events, a review of the circumstances and documentation pertaining thereto indicated that the event classifications were appropriate and that timely notifications and follow-up notifications were made to the county, state and the NRC in accordance with approved procedures.
3.
Follow u on Previous Ins ection Findin s
a.
(Open)
Follow-up Item (91-33-01).
Emer enc Notification S stem (ENS) Mannin Failure in 1991 nnua xercsse During the 1991 Annual Emergency Exercise, it was noted at the TSC that the online Emergency Notification System (ENS).communicator with
'the NRC was unable to view status boards from his'location.
In discussi,ons with the NRC base team, it was indicated that the line was left unmanned at, times up to fifteen minutes while gathering
'equested data.
This was contrary to 10 CFR 50.72(c)(3),
which indicates that "Each licensee shall, during the course of. the event:
Maintain an open, continuous communication channel with the NRC Operations Center upon request by the'NRC."
This request had been made by the NRC. It was indicated that action was necessary to insure manning and assignment of duties to provide for full-time
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coverage of the ENS.
A review of this item during this inspection determ>ned that the licensee has installed portable telephones for manning of the ENS and HPN during events.
The licensee communicator with NRC calls the NRC Duty Officer and requests a patch onto the ENS and/or HPN telephone bridge(s),
and is then able to remain on the line full time.
Also, the licensee indicated that appropriate
, procedural changes have been made to direct that the designated communicators are to remain on the line with NRC communicators during the course of the emergency event.
This item will be reviewed for closure during the, next annual exercise.
(Closed)
Follow-up Item (91-33-02).
Technical Su ort Center (TSC) Filter Testin not =Proceduralize sn accor ance ws mer enc an e usremen A licensee Problem Evaluation Request (PER) 291-892, dated October 30, 1991, indicated that The HEPA and'arbon filters of the TSC HVAC unit are currently not being tested to requirements consistent with the design bases.'urns
Roe Technical Memorandum 1261, FSAR page. 8.3-4f, and the MNP-2 SER page 12-5 all indicate that postaccident conditions in the TSC will be maintained the same as the control room.
The 2" carbon bed in AMA-FU-52 is claimed to have an efficiency os-95K.
PPM 10.2.83.indicates that AMA-FU-52 is tested to the requirements of Reg Guide 1. 140 which. allows 70%
efficiency for a 2" carbon bed.
Testing to Reg Guide 1.52 requirements is necessary to obtain 95K efficiency credit.
Technical Memorandum No.
TM-2016 is being issued to further document this need.
Emergency Plan section 10.2.2.2 commits that the TSC "is as habitab'le as the control room;".but as indicated in the PER, habitability test standards for the TSC were indicated as a 70X criteria whereas the control room criteria was for 95K.
A telephone call from the licensee to Region V on November 26, 1991, indicated that they had determined that 'testing of the TSC habitability had been done at the 95K level all along and met standards of Regulatory Guide 1.52.
Appropriate documentation of the testing. so indicates.
The problem, therefore, appeared to be procedural rather than a testing failure.
Action was taken to update the procedures to indicate testing of the TSC filters to the same standards as the control room.
A review of test results covering the past two years confirmed that filter efficiency surpassed the 95K criteri (Exercise Observation)
Dose Pro 'ections for Future Offsite Releases It was observed during the 1991-Annual Emergency Exercise that approximately 45 minutes prior to the termination of the exercise, following discussions with the NRC Site Team and Operations Center Staff, the Meteorology and Unified Dose Assessment Center (MUDAC)
staff performed a dose consequence assessment of a complete core damage scenario.
To perform this,assessment, the MUDAC staff utilized the core inventory of radionuclides tabulated in Chapter
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of the FSAR and attempted to estimate the response of the elevated release point monitor.
In a review of this item during this inspection, the licensee indicated that they are looking at several options to accomplish this type task.
One method under review is the NRC RASCAL program.
Other suggested programs were identified by FEMA Region X as possible solutions.
These and other options will be evaluated by the licensee and the most promising one will be considered for implementation.
4.
Exit Interview.
On February 28, 1992, at the conclusion of the site visit, the inspector
.
met with the licensee representatives identified in paragraph 1 above to summarize the scope and the preliminary results of this )nspection.
The inspector noted that the previously open items would be closed.
The inspector reviewed the concerns discussed in paragraph 2 above and the licensee indicated that they woul'd review improvements to their procedures and performanc )