IR 05000397/1992029
| ML17289A933 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 09/29/1992 |
| From: | Mcqueen A, Pate R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17289A932 | List: |
| References | |
| 50-397-92-29, NUDOCS 9210230008 | |
| Download: ML17289A933 (25) | |
Text
U. S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report No.
License No.
Licensee:
50-397/92-29 NPF-21 Washington Public Power Supply System (WPPSS)
P.O.
Box 968 3000 George Mashington Way Richland, Mashington 99352 Facility Name:
Washington Nuclear Project, Unit 2 (WNP-2)
Inspection at:,
WNP-2 Site, Benton County, Mashington Inspector:
Inspection Conducted:
August 31 - September 9,
1992 Q Nn c ueen, mer ency repare ness na yst ate igne Approved by:
o r
.
ate, ie
,
a eguar s, mergency Preparedness, and Non-Power Reactor Branch ay r2-te gne
~Summar a
Areas Ins ected:
This routine inspection by a region-based inspector examined the following portions of the licensee's emergency preparedness program:
Open Items identified during previous emergency preparedness inspections; Protective Action Decision Making; Notification and Communications; Knowledge and Performance of Duties; Operational Status of the Emergency Preparedness Program and Onsite Follow-up of Events at Operating Power Reactors.
During this inspection, portions of Inspection Procedures 82202, 82203, 82206, 82701, 92701 and 93702 were used, This report further documents a licensee requested meeting following the inspection for purposes of reviewing site emergency preparedness with Region V.
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.
9210230008 920729 PDR ADOCK 05000397
NSPECTION ETAI S
Ke Persons Contacted
- H. L. Aeschliman, Emergency Planner J;
W. Baker, Plant Manager
- R. E. Fuller, Compliance Engineer L. J. Garvin, Manager, Programs and Audits N. L; Garza, Emergency Training
- J. C. Gearhart, Director, guality Assurance (gA), WNP-2 B. J.
Hahn, Engineer
- R. E. Jorgensen, Emergency Training
- J. A. Landon, Supervisor, Emergency Planning
- D. E. Larson, Manager, Emergency Preparedness (EP)
- K. P.
Meehan, Emergency Planner
- H. M. Monopoli, Manager, Support Services
'J.
V. Parrish, Assistant Managing Director of Operations G. 0.
Ray, Emergency Planner
- G. C. Sorensen, Manager, Regulatory Programs
- R. L. Utter, Supervisor, EP Operations The above individuals denoted with an asterisk were present during the exit meeting on September 4,
1992.
The inspector also contacted other members of the licensee's emergency preparedness, administrative, and technical staff during the course of the inspection.
RC Personnel t Exit Interview A. D. Hcgueen, Emergency Preparedness Analyst, RV Subse uent Meetin to Review Emer enc re aredness At the licensee's request, a meeting was held at Region V on September 9,
1992, to review onsite and offsite issues pertaining to emergency preparedness at the site.
A licensee prepared itinerary for the meeting is an attachment hereto.
The following individuals were present for the meeting.
G.
M. Good, Emergency Preparedness Analyst, RV, NRC D.
E. Larson, Manager, Emergency Preparedness (EP),
WNP-2 A. D. Mcgueen, Emergenc'y Preparedness Analyst, RV R. J.
Pate, Supervisor, Safeguards, Emergency Preparedness, and Non-'ower Reactor Branch, RV G.
C. Sorensen, Manager, Regulatory Programs, WPPSS R. L. Utter, Supervisor, EP Operations 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 objective t
rotective Action Decision Makin (HC 82202)
Authorities and responsibilities appear appropriately assigned by the licensee to assess events or conditions and'to make recommendations for protective actions.
Emergency Preparedness Implementing Procedures appear to clearly reflect these authorities and responsibilities and they appear consistent with the emergency plan.
Criteria and methodology for making offsite protective action decisions are reflected in the implementing procedures, to. include protective actions for nonessential onsite personnel.
otifications and Commun'cations
'(MC 82203)
The licensee's notification procedures appeared consistent with the emergency classification and action level scheme and provisions for verifying messages appeared appropriate.
'The scheme is tested in accordance with pertinent procedures.
Actual notifications since the last routine inspection were reviewed as indicated in subsection e below.
It was veri.fied that the appropriate communications equipment and procedures existed in the emergency facilities and appeared consistent with the needs for communication within the licensee's organization, for offsite support, and with the State and local authorities as required.
0 erational Statu of the mer enc P e'redness Pro ram (MC-82701)
(1)
Emer e
c Plan and Im lementin Procedures Licensee Emergency Plan Implementing Procedures (EPIP)
have been redesignated as Plant Procedures Manual (PPH)
procedures.
Thirteen of the thirty five PPMs which had been revised since the last routine, inspection, were selected and reviewed during this inspection:
~
PPH 13. 1.2, Plant Emergency Director Duties, Revision 10, dated June 22,'1992.
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PPM 13. 10.2, Shift Technical Advisor Duties, Revision 6, dated June 22, 1992.
PPH 13. 10.3, Technical Support Center Operations and Technical Support Center Director's Duties, Revision 9, dated May 4, 1992.
PPH 13. 10.5, Operations Manager Duties, Revision 5, dated May 4, 1992.
PPH 13. 10.9, Operations Support Center Director and Staff Duties, Revision 14, dated June 22, 199 ~
PPH 13. 10. 11, Plant Emergency Team Duties, Revision 7, dated Hay 4, 1992.
~
PPH 13. 11. 1, Recovery Manager Duties, Revision 7, dated June 22, 1992.
PPH 13. 11.2, Assistant Recovery Manager Duties, Revision 5, dated June 22, 1992.
PPH 13. 11.7, Radiological Emergency Manager Duties, Revision 8, dated July 29, 1992.
~
PPH 13. 13.3, Recovery Operations, Revision 5, dated May 4, 1992.
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PPM 13. 14. 1, Emergency Exposure Levels/Protective Action Guides, Revision 9, dated July 29, 1992.
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PPH 13. 14.2; Process for Determining Protective Action Recommendations and Protective Action Decisions, Revision 14, dated July 29, 1992.
~
PPH 13. 14.4, Emergency Equipment, Revision ll, dated September 5,
1991.
No apparent degradations in site emergency preparedness were noted.
(2)
Emer enc Facilities E ui ment Instrumentation and
~Su lies (3)
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 appropriate requests for correction were initiated in instances where supply items were short or equipment was deficient or malfunctioning.
Equipment was verified as being in calibration.
Inde endent and Internal Reviews and Audits (a)
)
The 1992 Annual Audit of the Emergency Preparedness Program for WNP-2 (Audit 92-596),
dated August 28, 1992, was reviewed during this inspection.
The audit report Executive Summary indicated:
'
A total of twelve deficiencies; three Safety Level II guality Finding Reports (gFRs), five Level III gFRs, one Commercial (FR, and three Observations were identified.=-
Two areas of significant concern were identified during the audit that require management attention:
~
The evacuation process, and the response and training of organizations and personnel in, the WNP-2 Exclusion Area was found inadequate.
Several organizations would not have been notified in an emergency, and would not have heard the evacuation sirens.
Also several facilities have no emergency plans, procedures or emergency postings, and many personnel ha've not received emergency
.training.
~
Responsibilities and a comprehensive configuration management policy has not been adequately defined or implemented for the control of Emergency Response facilities, systems, and equipment.
Modifications have not always received engineering approval, had
CFR 50.59 reviews performed, or been processed in accordance with Plant procedures.
Facility drawings are out-of-date and not adequately maintained or controlled, and changes were noted that cannot be identified on drawings or by personnel.
A Problem Evaluation Request (PER 292-0917)
has been issued.
The deficiencies, observations, and documentation pertaining thereto were reviewed.
The licensee had initiated evaluation actions, as appeared appropriate, on all items.
Future routine inspections will review corrective actions taken.
(92-29-01)
(b)
One observation indicated in the audit report was identified by the inspector as an item to be reviewed by the NRC in future routine inspections until the issues are resolved.
NRC Information Notice 92-32, PROBLEMS IDENTIFIED WITH EMERGENCY VENTILATION SYSTEMS FOR NEAR-SITE (WITHIN 10 MILES)
EMERGENCY OPERATIONS FACILITIES AND TECHNICAL
'I l
SUPPORT CENTERS, dated April 29, 1992, was addressed to all holders of operating licenses or construction permits for nuclear power reactors.
The notice applies to=the WNP-2 emergency operations facility (EOF)
and the technical support center (TSC).
The licensee 1992 audit indicated that "an investigation, required by PPH 1. 10.4, is currently being performed by the Nuclear Safety Engineering Group, to determine Supply System posture with respect to the Notice."
The investigation is being conducted under OER Number 85040H (Operating Experience Review).
The OER Issue Form indicated There also may be some unanswered engineering questions regarding the lack of charcoal beds in the system, system operation in a non-pressurized mode, and the systems ability to maintain habitability as designed.
The scheduled completion date for the OER is indicated as October 1,
1992.
This item will be reviewed for resolution in the next routine EP inspection at the site.
(92-29-02)
(c)
An anomaly was noted in the emergency plan requirement for scheduling yearly emergency preparedness audits.
The plan indicated:
An audit will be conducted annually in accordance with the Plant Technical Specifications.
The plan defined "annually" as
...yearly, normally between two consecutive annual emergency exercises.
CFR 50.54(t) states that
...the licensee shall provide for a review of its emergency preparedness program at least every 12 months...
Licensee Technical Specification Section (TS) 6.5.2.8 indicates that These audits shall encompass:
... f.
The Emergency Plan and implementing procedures at least once per 12 months per
CFR 50.54(t).
N
At the exit meeting, the licensee indicated the emergency plan will be changed to specifically reflect the TS requirement.
(92-29-03)
'censee Initiatives ualit Action-Team AT for the 0 erations Su ort Center OSC In NRC Inspection Report Number 50-397/91-02, based on interviews with two OSC director-designees, it was observed that (2)
(3)
...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 to address the OSC performance issues.
A guality 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 was expected to make its recommendations prior to June 1992.
The (AT focused'ts information gathering in three areas: Facilities, Organization and Training. The licensee indicated during this inspection that the OAT summary report and recommendations, as revised, were issued on August 20, 1992. All recommendations were accepted and are in the process of'being implemented.
Scenario Generator The licensee had briefed the inspector in a previous routine inspection 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 was scheduled for inhouse testing near the end of April 1992.
The scenario generator is now in use by the EP staff and should enhance emergency preparedness training since it allows for production of more realistic radiological conditions in the plant and will model the plant source term and plant systems.
The licensee demonstrated the scenario generator to the inspector during this inspection and.indicated that it is already being used in drill and exercise development.
Emer enc Pre aredness Im rovement Plan The licensee has developed an Emergency Prep'aredness Improvement Plan for fiscal year 1993 which consists of three part f r'
Upgrade the image and functional performance of site emergency centers, Reduce the emergency organization size and increase the depth of staffing for the remaining positions, and
~
Increase the involvement of emergency response organization members in defining and developing emergency response capability.
The plan has been distributed to emergency organization managers by the Assistant Managing Director, Operations, and their full support was solicited.
Onsite Follow-u of Events at 0 eratin Power Reactor Facilities
~
(NC-93702)
Four unusual events (UE) had been reported to the NRC Headquarters Operations Officer (HOO) since the last routine emergency preparedness inspection at WNP-2.: One other reported event affected emergency plan implementation, but did not meet criteria for declaration of an emergency event.
On July 6, 1992, an unusual event was declared at WNP-2 and a manual reactor scram from 14 percent power due to a safety relief valve (SRV) stuck open for greater than two minutes.
The Unusual Event (UE) was declared at 5:05 a.m.
Local offsite agency notifications were made within seven minutes.
Notification to the NRC was made about 45 minutes later.
(2)
'3)
(4)
At 1:40 p.m.
on July ll, 1992, the licensee declared an Unusual Event after an SRV stuck open during testing.
Local offsite agency notifications were made within six minutes.
Notification to the NRC was made about 52 minutes later.
The event was terminated at 2:07 p.m.
At 7:40 a.m.
on August 13, 1992, the licensee declared an Unusual Event based on a five-gallon per minute unidentified leak rate as measured in the drywell sump.
Local offsite agency notifications were made within five minutes.
Notification to the NRC was made about 51 minutes later.
At 3:20 a.m.
on August 15, 1992, the licensee declared an Unusual Event following 15 to 20 percent (peak-to-peak),
core-wide power oscillations during reactor startup.
Local offsite agency notifications were made within seven minutes.
Notification to the NRC was made about 26 minutes later.
(MOO Event Number 24055)
I H
I
'I t
In each of the above events, a review of the circumstances and.
documentation pertaining thereto indicated that the event classifications appeared appropriate and. that timely notifications and follow-up notifications were made to the county and state agencies.
A review of the licensee Emergency Preparedness Implementing Procedure (EPIP) 13.4.1 (Notifications), indicated that notification requirements are:
Section 3. 1, 3.:
"Notify offsite agencies within 15 minutes of event classification....."
Section 3. 1, 7.:
"Direct that the NRC Communicator (within one hour of event classification:
,a.
Provides the NRC with event information....."
This notification procedure is not fully consistent with regulatory requirements contained in 10 CFR 50.72(a)(3),
which states in part:
The licensee shall notify the NRC immediately after notification of the appropriate State or local agencies and not later than one hour after time the licensee declares one of the Emergency classes.
At the exit meeting the licensee indicated that Plant Procedures Manual (PPM) 13.4. 1 was being changed to specifically reflect the requirement in 10 CFR 50.72(a)(3).
Additionally, the plant manager notified Shift Managers by interoffice memorandum on September 4,
1992, to immediately implement the requirement. as stated in 10 CFR 50.72 pending amendment of PPH 13.4. 1. (92-29-04)
(5)
On June 5,
1992, the licensee notified the NRC that the
hour helicopter service provided by the U.S. Department of Energy (DOE) for offsite Columbia River alerting would be discontinued at midnight on June 7,
1992.
To compensate for this loss, the licensee has installed. seven trailer-mounted sirens along the river as an interim measure to cover that portion formerly alerted by helicopter.=
As a permanent measure, the licensee will install permanent sirens to cover the area appropriately.
These measures were coordinated with.Region X of the Federal Emergency Hanagement Agency (FEHA) to insure requirements and commitments of the offsite emergency preparedness plans are met.and that the plans can be properly implemented.
Follow u on Previou ns ection Findin s
a.
(Open)
Follow-up Item (91-33-01).
Emer enc Notification S stem ENS Mannin Failure in 1991 Annual Exercise 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 discussions with'the NRC base team, it was indicated that the line was left unmanned at times up to fifteen minutes while gathering requested data.
This was'ontrary to'0 CFR 50.72(c)(3),
which indicates that
"Each licensee shall, during the course of the event: Haintain 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 fulltime coverage of the ENS.
A review of this item during this inspection determined that the licensee has installed portable telephones for manning of the ENS and HPN during events.,
'he 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
'irect the designated communicators to remain on the line with NRC communicators during the course of the emergency event.
This item will be reviewed for closure during the 1992 annual exercise.
b.
(Exercise Observation)
ose 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 Heteorology and Unified Dose Assessment Center (HUDAC)
staff performed a.dose consequence assessment of a complete core damage scenario.
To perform this assessment, the HUDAC staff utilized the core inventory of radionuclides tabulated in Chapter 15 of the FSAR and attempted to estimate the response of the elevated release point monitor.
Rather than use the iterative process that was actually used, the HUDAC staff should have had a
more efficient method for estimating the offsite consequence of a release of 100X of the, core inventory.
Such a method would have facilitated smoother interaction with the NRC site team and operations center staff, In a review of this item during a
previous inspection, the licensee indicated that they were looking at several options to accomplish this type task.
One method under review was the NRC RASCAL program.
Other suggested programs were identified by FEHA Region X as possible, solutions.
These and other options are being evaluated by the licensee and the most promising one will be considered for implementation.
It was determined during this inspection that the licensee has installed
"RASCAL" for dose assessment and that personnel are being trained in the use of the program.
This item will be reviewed in the 1992 annual exercis t
(Closed)
Follow-up Item (92-05-01).
TSC Readiness Issues During the past three routine inspections, tours of the Technical-Support Center (TSC) indicated that previously identified conditions were recurring.
The TSC did not appear in a state to be quickly and efficiently converted to an emergency facility.
The inspectors had also observed that there was a standing pool of water in the TSC instrument room.
The licensee determined 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 during the last routine inspection tour of the TSC that some desk clutter was still evident in the actively used office areas, but the TSC decision center area appeared cleared and ready for use as an emergency center.
An inspection of the TSC during this inspection found that it was in a more orderly state than previous visits.
The water heater valve was no longer leaking and had apparently been repaired.
Preparation and activation of the TSC will be observed during the 1992 annual emergency exercise.
(Closed)
Follow-up Item (92-05-02).
utdated A reement Letter with WA State One item identified by the licensee's 1991 annual audit is being tracked by the NRC as an inspection follow-up item (IFI).
The audit report found that the Agreement Letter between the Washington Public Power Supply'System (WPPSS)
and the State of Washington-Department of Emergency Preparedness and Response had expired and a replacement letter had not yet been approved.
During the previous inspection, the licensee indicated that the
.
parties to the agreement had set a 90 day target date as of the week of that inspection (Hay ll - 15, 1992) for execution of the letter.
That agreed date was not met.
In that this is an emergency plan requirement, the item was established as an inspection follow-up item to be tracked until, resolved.
By letter dated September 4,
1992, File: G02-92-213, the licensee provided NRC with a copy of a letter to the Washington State Division of Emergency Hanagement, Subject:
HEHORANDUH OF UNDERSTANDING FOR EHERGENCY PREPAREDNESS.
In the letter to the state, the licensee indicates:
In researching the basis for the HOU we find that its purpose is to describe the concept of operations to be employed in responding to an emergency and 'to indicate agreement between the State of Washington and the Supply System on that subject.
We note that concept of operations is.described in.2;4 and other sections of the Washington State Fixed Nuclear Facility Emergency Response Plan.
By this letter the Supply System confirms its
agreement with the concept of operation as described in the Washington State Fixed Nucl'ear Facility Emergency Response Plan, Revision 8 dated June 14, 1991.
While this action provides compliance with regulatory requirement, we believe that a mutually acceptable Hemorandum of Understanding would be preferable.
Our Emergency Preparedness staff will
'ontact you in the near future and is prepared to travel to Olympia to work with you on a replacement HOU.
The licensee indicates in the letter to the NRC that the letter to the State of Washington was discussed with FEHA Region X,.and that discussion affirmed that the action taken by the licensee appears to fulfillthe intent of the regulatory'equirement.
This was confirmed by Region V telephonically on September 15, 1992, with FEHA Region X.
(Open)
Follow-up Item (92-17-01).
TSC Relocation Issues'
review of Emergency Plan Implementing Procedure (EPIP)
13. 10.3, Technical Support Center Operations and Techni'cal Support Center Director Duties, Revision 9, dated Hay 4, 1992, contained an added
"Action 10" on page 3 of 8, which indicated that
"When advised the TSC is uninhabitable, the Plant Emergency Director will select staff members to go to the Control Room or the Emergency Operations Facility based on functional need."
The licensee confirmed that there was no alternate TSC "per se,"
and that the support expertise required in such cases would be redistributed to the most appropriate location to continue support.
"Open C.A.R.
Report" (Corrective Action Request)
90-0062 indicated a finding that the "Control Room (CR) may not be adequate for handling TSC staff.
Last 3 drills have had scenarios that rendered the TSC uninhabitable and made it necessary to relocate TSC staff members to the CR.
Observations of this work arrangement note that the Simulator (thus the CR)
may lack adequate space and equipment to support this influx of personnel."
The C.A.R. remarks section-indicated that "Installation of phones in the control room is waiting for action on HWR AR 5693 (est.
completion August 92)."
This item was reviewed during this inspection and it was
.determined that to mount the additional telephones in the control room requires a seismic evaluation, which the licensee indicated has been initiated.
This item will remain open to review progress in resolving this issue.
(Closed)
Follow-up Item (92-17-02).
Shorta e of Environmental Team Hembers During the last routine inspection, it was determined that an open licensee Corrective Action Request (CAR) Report 92-0001 indicated a finding that "on January 14, 1992, Supply system emergency responders were contacted by the Helita Automatic Dialer as part
h
~
ij l
of a routine notification test.
Only five Field Team members were contacted.
During a notification test conducted on February 13, 1992, only three Field Team members were contacted."
To address this 'potential regulatory problem, the licensee recruited and trained three new team members for call-out.
Two are trained health physicists.
As a result, the 'two most recent drills (Harch 26 and April 27, 1992)
had met the six team member requirement with no difficulty.
A review of this item during this inspection indicated that monthly drills continue to meet the six team requirement without difficulty.
This item is closed.
4.
Exit Interview.
On September 4,
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 inspection.
The inspector indicated which previously open items would be closed.
The licensee was provided with details of the items discussed in sections 2.c and 2.e above.
In the September 8,
1992, meeting at Region V, the licensee reviewed the topics listed in the attachment hereto and indicated the current status.
This was followed by a discussion of potential improvement items such as root cause identification and corrective actions, habitability and maintenance of emergency facilities,'nd continued staffing of the emergency preparedness staff.
ATTACHHENT:
Heeting Agenda, US NRC and Supply System Emergency Preparedness, September 8,
199 MEETINGAGUA US NRC AM)SUPPLY SYSTEM EMERGENCY PREPAREDNESS, SEPTEMBER 8, 1992 STATUS OF FEMA, STATE AND LOCALISSUES
'EMA Findings MOU With Washington State I
Oregon Ingestion Planning US DOE Helicopter Issue IMPROVl2dZNTINITIATIVES OSC Quality Action Team On Site EP Improvement Plan Emergency Action Levels
- NRC CONCERNS
I 1