IR 05000416/1989021
| ML19325D223 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 09/29/1989 |
| From: | Gooden A, Rankin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19325D221 | List: |
| References | |
| 50-416-89-21, NUDOCS 8910190195 | |
| Download: ML19325D223 (10) | |
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UNITE] STATES
. t NUCLEAR REGULATORY COMMISSION
REGION H o,
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101 MARIETTA ST N.W.
ATLANT A. GEORGIA 30323 OCT 0 219H Report No.:
50-416/89-21 Licensee:
System Energy Resources, Inc.
Jackson, MS 39205
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. Docket No.:
50-416 License No.:
NPF-29 Facility Name: Grand Gulf Inspection Conducted: August 28 - September 1, 1989 Inspector:
Q.
d 9-49-89 A. Gooden Date Signed Approved by: MI
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4 M* $9 W. Rankin,' Chief Date Signed Emergency Preparedness Section Emergency Preparedness and Radiological-Protection Branch Division of Radiation Safety and Safeguards
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SUMMARY l
Scope:
~This routine, unannounced inspection was conducted in the area of emergency
preparedness.
Several aspects of the emergency preparedness program were
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reviewed to determine if the program was being maintained in a state of
operational readiness.
The review included maintenance of select emergency
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kits and equipment, organizational changes since the September 1988 inspection,
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training; independent audits; distribution of changes to the Emergency Plan and
Emergency Plan Procedures (EPPs); and the adequacy of licensee actions taken on previously identified inspection findings..
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Results.
Within the 6 tea, inspecte!, one viniation was icentified for failvre to conduct
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e tr61ning in acendaace with procedures governing emergency preparedness training (Paragraph 5).
A comitant was made by the licensee manegement te
conduct an uncnnounced aligmentation drill during September 1909 (Paragraph F).
Noted program strengths we.re as #cilows:
(1) timely distributica of changes to l
- the Emergency Flan and EM s (Paragrepn 2); 12) documentation for discrepancies L,
and/or corrective actions resulting frorr. equipment inventories and periodic
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I T tests (Persgrarn 3); (3) cw>uttrizeri training records riate base and the fcr: cat
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C in displaying dats; and (4) the response by r.wir.ttnance to rapair tagged-wt
h equipment it. the Erergency Operations facility (EOF) (Paragraph 3).
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I 8910190195 891oot PDR ADOCK 05o00416 i
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REPORT DETAILS L
1.
Persons Contacted e
i Licensee Employees l
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- C. Hayes Supervisor, Quality Programs
- C. Hutchinson, General Manager M. Kavanaugh, Senior Emergency Planner j
- F. Mangan, Director, Plant Projects and Support
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T. McIntyre Shift Superintendent R. Moomaw, Assistant Manager, Maintenance t:
S. Mooney, Assistant Instrument and Control Superintendent
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- A. Morgan, Manager Emergency Preparedness
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- R. Patterson, Technical Assistant, General Manager
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J. Sanford, Emergency Planning Specialist
- J. Summers, Compliance Coordinator D. Townsend, Emergency Planning Specialist i
s R. Vandenakker, Emergency Planner L
- M. Wright, Manager, Plant Support
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- J. Yelverton, Manager, Plant Operations Other licensee employees contacted during this inspection ' included i
engineers, operators, security office members, technicians, ano administrative personnel, i
i NRC Resident Inspector
- J. Mathis l
- Attended exit interview I
2.
Emergency Plan and Implementing Procedures (82701)
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Pursuant to 10 CFR 50.47(b)(16), 10 CFR 50.54(q), and Appendix E to 10 CFR i
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Part 50, this area was reviewed to determine whether changes were made to
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the program since the last routine in:;pection (September 1988), and to
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y ass +ss the wpct of these cheriges on the cverall state of emergency
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S prepareoness at the fec111ty.
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i The inspector reviewed Section 8.5 of the licensee's Emergency Plan anc'
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f discussed with licensee per:,onnel the program for making changes to the
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Piar and LPPs.
1he inspector verified that changes to the EPPs uert renecced ar.d approved by management in accordance with Administrativu r
irocedure 01-S-02-2 yove: ning the development, review, and approval.
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review of trantm;tt::1 sheets disclosed that changes were being distributed
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to on:.ite and offsite holders in a timely :nantar.
The inspector reviewed
the distribution of EPPs to NRC covering the period November 1988 through
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August 1989.
The randomly selected EPPs were submitted within 30 days of
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the approval date in accordance with 10 CFR 50.54(q).
No problems were r.oted.
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Since the last inspection, changes incorporated as Revisions 18 and 19 to the Grand Gulf Emergency Plan were submitted for NRC review on January 31,
1989 and June 21, 1989.
By letter dated June 9, 1989, changes incorporated as Revision 18 had been approved by the Region 11 staff. At t;ie time of the inspection, Revision 19 changes were being reviewed by the
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Regional Office staff to determine if changes were consistent with NRC
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l requirements.
Controlled copies of the Emergency Telephone Directory, Emer ency Plan, and/or EPPs were audited in the Technical Support Center (TSC), Operations c-
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Support Center (OSC), and the EOF.
The selected documents that were
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examined were found to be current revisions.
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No violations or deviations were identified.
3.
Emergency Facilities Equipment, Instrumentation, and Supplies (82701)
Pursuant to 10 CFR 50.47(b)(8) and (9),Section IV.E of Appendix E to 10 CFR Part 50, and Section 7.0 of the licensee's Emergency Plan, this area was inspected to determine whether the licensee's emergency response facilities and other essential emergency equipment, instrumentation, and supplies were maintained in a state of operational readiness.
Discussions were held with a licensee representative concerning modifications to facilities, equipment, and instrumentation since the last inspection.
The inspector toured the Control Room, TSC, OSC, and E0F.
Discussions with a member of the licensee's staff disclosed the following facility and equipment changes since the September 1988 inspection:
The Corporate Emergency Center (CEC) was relocated from the
Mississippi Power and Light (MP&L) Electric Building to the recently completed System Energy Resources Incorporated (SERI) corporate office building.
The EOF office areas that were previously dedicated for emergency use
are being used by the Emergency Freparedness staff as office space l -
for conducting day to-day operat'echs.
Equipment changes involved the deletion of tur dediated rig-)down
phones (Executive Conference Lines and the Corcorate Hot-Lines, ahu the implementation of a r.tw dose assessment peckage (including H
computer) known as ME50 REM JR.
According to the licenne contact,
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chtnges to the communication system were made in vicw of recent phone (
upgrsde> which prcvidts the same capability as the previous system.
f io Regarding the dote assusment niethocology, the intpictor was provided
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l documentatior, to show that training was providad to the State of Mississiopi personnel on July 28, 19M.
At the time of the i
inspection, a comparability study was being conducted between MESOPEM l
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and the methodology used by the State of Louisiana. When questioned j
regarding the comparability of MESOREM with the NRC dose projection
program (IRDAM/RASCL), the licensee contact stated a comparability
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study would be initiated upon issuance of RASCAL.
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Although the dose projection methodology was not evaluated, based on the discussion with a licensee representative regarding the method being a
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Class A model with site specific factors incorporated for Grand Gulf, the
above change does not appear to decrease the effectiveness of the program.
Based on a tour of the emergency response facilities (ERFs) and a j
discussion regarding the operational concept of the EOF, the above i
facility and equipment changes do not appear to decrease the effectiveness i
of the facilities to perfonn their intended function.
In assessing the operational status of the ERFs, the inspector verified that protective
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equipment, and supalies were operational and inventoried on a periodic
basis.
Emergency kits and/or cabinets from the Control Room TSC, OSC, EOF, Site Access Point (SAP), and Offsite Monitoring Team (OMT) Kit were
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inventoried and randomly selected equipment was checked for operability. _
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With two exceptions, the selected equipment operated properly, displayed
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current calibration stickers, and successful battery and source checks
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were obtained.
The two exceptions were as follows:
(1) an inoperable survey instrument was found in the offsite monitoring kit (Kit No.1), and (2) three of six aerial radiation monitors (ARMS) in the EOF would not respond to source check.
In response to the above, the licensee took prompt action to repair all
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three ARMS in the EOF and replaced the inoperable ion chamber with an
operable chamber.
By review of applicable procedures and check-list documentation covering the period of October 1,1988 to July 1989, the inspector determined that emergency equipment (e.g., communication i
equipment and emergency kits) was being checked in accordance with the
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procedures governing such tests.
Records reviewed indicated that all discrepancies or problems identified during inventories and communications
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checks were corrected in a timely manner, i
As part of the emergency communication equipment, the inspector discussed with a licensee contact the periodic testing of the plant emergency warning system for high noise areas.
According to discussions with the i
licensee contact, the emergency evacuation system consists of revolving
red lights and en evacuation alarm to assure personnel evacuation.
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According to documentation, the emergency warning lights are tested at 18 months frequency, Comp 1Med procedure data pcckeges were reviewed to
verify that tests were conductco during the calendar year 1988.
During an E9F tour,, toe inspector observed an operability source check on
thr. APNs as verificatiu tha^; ac' cions taken by raintenance personnel were
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effectile in nsolving source check discrepancies.
En problems wre noted.
Ali AMs were operating within the set point raNe and responded
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properly to che source check.
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The licensee's management control program for the Alert and Notificetion
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System (ANS) was reviewed.
According to documentation, the system
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consisted of 43 sirens.
Thirteen sirens are located in Tensas Parish, Louisiana, and 30 sirens are located in Claiborne County, Mississippi.
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September 1988 through April 1989.
Results showed that problems
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identified during testing were resolved in a timely manner, o
No violations or deviations.were identified.
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Organization and Management Control (82701)
Pursuant to 10 CFR 50.47(b)(1) and (16),Section IV. A of Appendix E to
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10 CFR Part 50, and Section 5.0 of the licensee's Emergency Plan, this area was inspected to determine the effects of any changes in the licensee's emergency organization and/or management control systems on the emergency preparedness program, and to verify that any such changes were
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properly factr. red into the Emergency Plan and EPIPs.
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1he inspec. tor's discussion with a licensee representativo disclosed that
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several personnel changes had been made involving both the corporate and plant staffs since the September 1983 inspection.
The most significant change regarding emergency preparedness involved the consolidation of the i
onsite (plant) arid of fsite (corporate) planning function into one program
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with : ole responsibility assigned to the site.
This also resulted in.:
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change to the emergency preparedness reporting chain.
Previously, site i
emergency planning reported to the Superintendent of Radiation Control; and corporate emergency planning reported to the Manager, Emergency
Preparedness and Executive Assistant to Vice President, Nuclear Operations.
As a result of the change, all onsite and offsite emergency j
planning will be a site function under the management control of the
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Director, Plent Projects and support.
Daily activities involving the i
station or corporate emergency planning program will be handled by the
Manager, Emergency Preparedness (formerly, Supervisor Emergency
Preparedn-ess).
The aforementioned reorganization within the emergency i
planning program was discussed with members of the Region !! staff during
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a meeting in Atlanta on August 28, 1989.
Additional changes that were
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discussed included personnel changes in certain station management t
positions, ar.d the reassignment of certain program functions from the i
corporate rffice to the site.
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1he inspector's of scussion with a lictnsee representative disclosed that personnel changes had also been made to the emergency organization since
i the September 1988 inspection as a result of reatsignment or promotion.
Most changes were personnel reassignments involving individuals previous 1f f
assigned to the emergency response organizadon.
When training records
were reviewed for sucn individuals, tome incensiste.)cies were noted, and
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are discussed below in Parar:ri.ph 5.
RegardiN the offsite local support organizations, no significant change had been r:ade.
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No violations or deviations were identified.
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Training (82701)
Pursuant to 10 CFR 50.47(b)(2) and (15),Section IV.F of Appendix E to 10 CFR Part 50, and Section 8.2 of the Emergency Plan, this area was t
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inspected to determine whether the licensee's key emergency response personnel were properly trained and understood their emergency responsibilities.
i The inspector reviewed Section 8.2 of the Emergency Plan and the various implementing procedures for a description of the training program and training procedures.
In addition, selected lesson plans or instructor guides were reviewed, and personnel with the responsibility for conducting and tracking the energency response training were interviewed.
It was determined that the licensee maintains a formal emergency training-program.
Training records were reviet x #or several members of the emergency organization.
Training recoras were chosen based on the monthly on-call list. Emergency Telephone Book, and the list of responders assigned to the emergency response position matrix.
When personnel training records were compared with position assignments, the inspector noted the following:
Six individuals assigned to the offsite emergency organization had
not been trained in accordance with Emergency Preparedness Administrative Procedure (EPAP)-203.
Four of the six individuals designated as E0F Consnunicators or EOF Communications assistants had not completed the required communications training module (EPTS-4 or EPTf-20) pf, indicated in Attachment C of the training procedure; one individua'l was assigned to the position Radiation Energency Manager (REM) during the second quarter 1989 prior to completing Emergency Assessment training module (EPTS-6); and one individual designated as Radiological Assessment Coordinator had not completed Emergency Assessment training module (EPTS-6).
One individual assigned to the monthly on-call list as a TSC
Commur.icator had not received the required training as specified in Add.nistrative Procedure 01-S-04-21. " Emergency Preparedness Training Program." Specifically, the individual f ailed to complete retraining for respiratory certificetion in accordance with Administrative Procedure 01-S-04-4.
EPP-23 Section 6.2.5, states that superintendents / managers are
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required (via a niemo) to verify that all personnel they have assigned
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to fill emergency on-call positions are currently qualified and remain qualified while assigned.
A licensee representative acknowledged the above findings and indicated the following actions would be taken:
p EOF communicator training (EPTS-20) will be conducted on
September 1. 1989.
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individuals identified as having not completed the required
training, would be removed from the on-call list pending completion of all training requirements.
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training (EPTS-6) for the REM was completed subsequent to the second quarter of Calendar Year 1909.
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organization training will include certification requirements l
for offsite training to be identical as onsite training discussed in EPP-23 Section 6.2.5.
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This item is identified as a violation of 10 CFR 50.54(q) which t
requires the licensee to follow an Emergency Plan which meets the planning standards in 10 CFR 50.47(b).
During the June 1987 inspection, a violation was identified in the area of training for onsite plant assessment personnel (0pcrations Coordinator). A repeat findinD in the area of training appears to warrant increased attention to the current practices for tracking emergency response training.
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Violation (50-416/89-21-01):
Failure to provide seven members of the emergency organization with training in accordance with EPP-23 and EPAP-203.
Offsite support agency training was reviewed for fire, hospital, local law enforcement, and governmental support agencies.
Offsite support training was consistent with requirements in the Emergency Plan and EPAP-203. The inspector conducted a walk-through evaluation with a Shift Superintendent, who may be designated as the Interim Emergency Director.
The interviewee was given hypothetical emergency conditions and data and was asked to talk through his response (as Emergency Director) as if an emergency actually existed.
The interviewee demonstrated familiarity with the emergency classification procedure and various other procedures which impicment the Grand Gulf Emergency Plan.
No problems were noted in the areas of emergency detection, classification, and protective action recommendation.
The inspector discussed with a licensee representative the results of augmentation drills conducted since the September 1988 inspection to verify augmentation times in Table 5-1 of the Grand Gulf Emergancy Plan.
Documentation was provided to show that on a periodic basis,
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au mentation drills were condacted to determine the following:
j (1 availability of emergency response persennel during off-hours;
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(2 length of time required to notify personnel; and (3) estimates of arrival time for augmentstion persennel to the site.
Inccnsistency was noted between the drill results and Table 5-1 of the Emergency
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Plan.
For example, during the dri?1 conducted on December 20, 1988, it took one hour to notify the on-call communicator; 30 minutes augmentation capability for plant systems engineer with core / thermal l
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hydraulic expertise was not demonstrated; and several other 30 and
00 minutes augmentation capabilities were either not met or
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demonstrated.
As a result, the licensee was informed that recent drills and provision of beepers with an improved operating range were
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considered enhancements to the augmentation program.
However, the
augmentation goals in Table 5-1 had not been demonstrated for all
support functions (e.g., plant systems engineering, damage control, etc.).
In addition, a drill involving real-time notification and travel to the site during off-hours had not been conducted.
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I augmentation response can only be demonstrated by conducting an
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unannounced drill involving an actual response to the plant by
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augmentation personnel.
The licensee acknowledged this item and
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agreed to conduct an unannounced augmentation drill requiring that personnel travel to the site for verification of Table 5-1 i
augmentation requirements.
The inspector indicated that this matter would be considered an Inspector Followup Item (IF1) for review during a subsequent inspection.
IFl 50-416/89-21-02:
Conduct an unannounced augmentation drill to verify that Table 5-1 augmentation staffing and arrival times can be
met.
One violation was identified.
6.
Independent Review / Audits (82701)
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Pursuant to 10 CFR 50.47(b)(14) and 10 CFR 50.54(t), this area was inspected to determine whether the licensee had performed an independent review or audit of the emerg(ncy preparedness program and whether the licensee had a corrective action system for deficiencies and weaknesses identified during exercises and drills, t
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According to documentation, independent audits were conducted by the licensee's Quality Systems Group during the period September 14 through October 17, 1988 (documented in Audit Report No. QSA-88/0061). A previous audit reviewed by the NRC was conducted on November 16-19, 1987
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(documented in Audit Report No. MAR-87/34).
A more recent audit is planned for the September 1989 time frame to include an audit of the
annual emergency preparedness exercise. The aforementioned audits satisfy
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the annual frecuency requirement for such audits.
No significant findings were identifiec.
The licensee's program for followup action on audit, drill, and exercise
findings was reviewed.
Licensee procedures required followup on deficient
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areas identified during audits, drills, and exercises.
Items were being tracked via a system known as the Action Tracking Management System (ATMS)
referred to as "ATS."
Weekly status reports are sent to responsible individuals and plant management for revie.
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The inspector reviewed a sample of items from the Calendar Year 1988
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exercise and noted that items were being completed by the due date, and in i
some instances prior to the assigned completion data.
According to the
most recent printout, a total of four items remain opened.
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No violations or deviations were identified.
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Action on Previous Inspection Findings (92701, 92702)
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(Closed) IFI 50-416/87-24-01:
Verify shift staff augmentation times using announced and unannounced drills.
According to documentation, an off-hours r.otification drill was conducted i
during the last quarter of 1988.
The drill results indicated that
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Table 5-1 augmentation times were not met.
Subsequent to the drill, the licensee took actions in other areas for improving the augmentation
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program (e.g., Time Estimate Study, prioritization of notification, and new pagers were issued to the majority of personnel filling Table B-1 augmentation positions.
In addition, periodic notification drills are
conducted for obtaining response personnel estimated time of arrival (ETA)
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at the station. The licensee was informed that this item is closed, but a new item will be opened (See 50-416/89-21-02) based on a commitment to i
conduct an off-hours unannounced exercise requiring that key personnel
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respond to the plant site (See Paragraph 5).
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(Closed) IFI 50-416/89-03-01:
Ensure completion and effective operation
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of the ANS FSK digital activation system.
l The inspector reviewed documentation dated February 24, 1989 and March 17, 1989, which described the ACA compulert siren activation and monitoring system as fully tested, and accepted for use by officials of Claiborne
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County Civil Defense and Tensas Parish Emergency Preparedness.
Further, the inspector reviewed system operability records for the first and second quarter of Calendar Year 1989, and noted that results were reported as 88 percent and 97 percent respectively.
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(Closed) Violation 50-416/89-03-02:
Failure to document all training of
offsite support agency (s) regarding monitoring, testing, and operation of
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r The inspector reviewed licensee documentation to verify that actions had been taken in accordance with the licensee's response to the Notice of
Violation dated March 15, 1989.
According to the documentation, training
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for offsite agencies was conducted on January 30 and 31,1989.
In addition, the inspector reviewed a procedure (entitled Operations, Management and Maintenance of the Public Alert and Notification System Sirens) developed for the offsite support agenc1es which provides guidance on operation, maintenance and management of the ANS.
Corrective actions to prevent recurrence involved revising Emergency Preparedness Administrative Procedure-203 to include provisions for annual training of offsite support personnel regarding the ANS sirens.
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Exit Interview
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The inspection scope and results were summarized on September 1,1989, with those persons indicated in Paragraph 1.
The inspector described the
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areas inspected and discussed in detail the inspection results listed
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above.
The licensee did not identify as proprietary any of the material provided to or reviewed by the inspector during this inspection.
In response to the IFI detailed in Paragraph 5 of the report, the General
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Manager committed to conduct an unannounced augmentation drill during September 1989, that would require augmentation personnel to respond to the plant site.
Regarding the training violation discussed in Paragraph 5, the inspector was provided documentation and details by.the
~u Emergency Preparedness Manager to show that actions discussed in
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Paragraph 5 had been initiated and in some instances already completed.
The licensee was informed that the appropriateness of these actions would be reviewed in more detail at the Regional Office.
There were no dissenting comments.
Item Number Description / Reference
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50-416/89-21-01 Violation - Failure to provide seven members of the emergency organization with training in accordance with EPP-23 and EPAP-203 (Paragraph 5).
50-416/89-21-02 IFI - Conduct an unannounced augmentation drill-to verify that Table 5-1 augmentation staffing and arrival times can be met (Paragraph 5).
Licensee management was informed that three open items were reviewed and
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closed (Paragraph 7).
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