IR 05000440/1997017

Insp Rept 50-440/97-17 on 971103-07 & 971215-18.No Violations Noted.Major Areas Inspected:Ep Program

ML20199A130
Person / Time
Site:	Perry
Issue date:	01/21/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20199A128	List: IR 05000440/1997017 ML20199A123
References
50-440-97-17, NUDOCS 9801270127
Download: ML20199A130 (11)

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~ U.S. NUCLEAR REGULATORY COMMISSION REGIONlli Docket No: 50-440 License No: NPF 58 Report No: 50-440/97017(DRS)

Licensee: Centerior Service Company Facility: Perry Nuclear Power Plant Location: P. O. Box 97, A200 Perry, OH 44081 Dates: November 3 7,1997 onsite December 1518,1997 in NRC Region lli Office inspector: Robert Jickling, Emergency Preparedness Analyst Approved by: James R. Creed, Chief, Plant Support Branch 1 Division of Reactor Safety k0 d40

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EXECUTIVE SUMMARY Perry Nuclesr Power Plant, Unit 1 NRC Inspection Report 50-440/97017 The inspector reviewed the Emergency Preparedness (EP) program, an aspect of Plant Support. The inspector evaluated the quality of EP program related audits and reviews, reviewed the effectiveness of management co'itrols, verified the adequacy of emergency response facilities and equipment, reviewed EP training and qualification activities, and assessed actions on previous inspection findings. This was an announced inspection conducted by one regionalinspecto Overall, the EP program had been maintained in an effective state of operational readines Emergency response facilities, equipment, and supplies were well maintained. Management support to the program was strong. Interviewed key emergency response personnel demonstrated competent knowledge of responsibilities and emergency procedure * The licensee appropriately utilized its emergency plan when it declared an Unusual Event and made notifications to State, county, and Federal agencies in a timely manne (Section P1.1)

• Emergency response facilities, equipment, and supplies were well maintaine Demonstration of selected emergency response equipment verified that equipment was operable. (Section P2.1)

. An Inspection Followup Item was opened to track the operability of the Emergency Operations Facility's emer0ency ventilation system which was found to be leaking during this inspection. (Section P2.1)

+ The emergency plan and implementing instructions reviewed were appropriat Implementing instruction checklists effectively facilitated the use of the procedure (Section P3)

. The EP training program appeared effective. Training records indicated that emergency response personnel were trained within the required frequency. Interviewed emergency response organization personnel demonstrated competent knowledge of responsibilities and emergency implementing instructions. (Section PS)

+ A change in organizational structure occurred so that the Emergency Planning (EP) Unit Supervisor reported directly to the Nuclear Services Director. Mcnagement support for the program appeared strong. (Section P6)

. An inspection Followup Item was opened :o track the potential impact on program performance of the loss of five experienced EP Unit staff members and the EP instructor. (Section P6)

• The licensee's 1997 and 1996 Quality Assurance audits of the EP program were effective and satisfied the requirements of 10 CFR 50.54(t). (Section P7)

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Report Detalla l

IV. Plant Support P1 Conduct of Emergency Preparedness (EP) Activities  ;

P Actual Emergency Plan Activations insoection Scoce f82701)

The inspector reviewed records and documentation packages regarding plant response for an actual emergency event which occurred durin0199 Qbservations and Findings An unusual Event was declared at 2:00 p.m. on December 19,1996, due to the loss of al! telephone communications. During offsite excavation work, the offsite underground fiber optic cables were severed due to erroneous cable location Information provided to the excavating company by the telephone company. This occurred at the same time as an existing loss of the Off Premise Exchange (OPX) microwave system due to a structural failure of the site tower, which resulted in a totalloss of dedicated phone line The shift supervisor appropriately classified the Unusual Event using emergency action level (EAL) J.l.1 for emergency declaration when less than two methods of offsite communication are available. Offsite notifications to the State of Ohio and local counties were made by cellular phone and met the 15 minute requirement. The one hour call to the NRC was also made by cellular phone and initiated at approximately 2:17 p.m. The Unusual Event was terminated at 12:40 a.m. on December 20,1996, when all offsite telephone communication lines were restored. The State of Ohio, local counties, and the NRC were notified of the event termination by the *5-Way" Ringdown and the Emergency Notification System circuits from tl:e Technical Support Center (TSC) by approximately 12:47 The response to the event was reviewed by the licensee and a detailed evaluation package was compiled by emergency planning (EP) staff. The package contained an

• event observations and sequence of events" report, a potential issue form (PIF), and a cause analysis summary. The licensee identified that the classification was appropriate and offsite notifications were made in a timely manner. The licensee was evaluating possible means of increasing redundancy of offsite communications, which might include an alternate cellular radio system for State and local authority notifications, developing a contingency plan for alternate offsite communications, and the use of the local law enforcement agency's radio link, Conclusion 3 The inspector concluded that the licensee appropriately implemented the emergency phn when declaring the Unusual Event. The emergency classification was made

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correctly and offsite notificatiens were timely. The evaluation package was detailed and provided good assessments of the event and the licensee's respons P2 Status of EP Facilities, Equipment, and Resources P Material Condition of Emergency Resoonse Facilities (ERFs) Insoection Scoce (82701)

The Irispector evaluated the materiel condition of the control room, TSC, Operations Support Center (OSC), and Emergency Operations Facility (EOF). Radiation Monitoring Team (RMT) kits were also inspected. The licensee demonstrated the operability of numerous pieces of emergency response equipment, including radiological survey instruments, dose assessment and plant data computers, and communicetions equipment. Records of periodic inventories and equipment tests were also reviewe b, Observations and Findings The control room was well maintained and had current EP procedures available. The emergency notificatloo < istem phone was verified operabl The OSC. TSC, and EOF were well maintained. Recent enhancements included the relocation of the Emergency Response Information System (ERIS) consoles from the TSC Display Room to the adjacent room to support TSC engineering activities and to the OSC * Briefing Room" to support health physics assessments. The relocation of these consoles should provide less congestion in the TSC and more information in the TSC Display Room. Also,"VAX" terminals had been replaced with networked personal computers (PCS)in the OSC area, EOF Records Room, TSC, EOF, and Backup EO The networked PCS in these areas should provide greater access to plant records, procedures, and transfer of news releases. The RMT vehicles had been sequentially replaced with four newer end larger vehicles. Telephones, computer terminals, and other equipment were verified operable in the response facilities. Current procedures were available in these facilities. Status boards in the facilities were in good materiel condition and ready for us During the March 1996 EP program inspection, one of the EOF's two heating, ventilation, and air conditioning (HVAC) system intake fans was out of service. This situation resulted in a loss of confidence in the reliability of the remaining fan, which was operable. Although only one fan was required to provide the minimum flow needed during emergency conditions, the margin of safety was reduced. The licensee took action to correct the problem after the arrival of replacement part During this inspection a different problem was identified with the operability of the EOF's HVAC system. A leakage test was conducted, and the system failed due to leakage along the sealing surface of the isolation damper. Ajoint analysis of the system's maintenance history, past test results, and potentiel concerns was unable to identify recurring problems or inherent system problem . . . - - .-. - - - --- - - - - - - - - - - - . _ . - . .

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This system is important for personnel safety in the event of an EOF activation to reduce j the likelihood of an airbome radiation release from entering the facility. The failure of the HVAC system under those conditions would cause the licensee to move emergency ,

response coordination and management to a distant, less used, t'ackup facilit Consequently, the materiel condition of the EOF's HVAC system will be evaluated -

during future inspection activities (Inspection Followup item 50-440/97017-01(DRS)). i Prompt alert and notification system records for 1996 and 1997 were reviewed by the inspector. Annual operability for 1996 was 99 percent, with 98 percent for the lowest month's average. The current 1997 annual operability average was greater than 98.6

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percent, with 96 percent for the lowest month's average. The successful functioning of this important system was attributed to an effective maintenance program. Siren operabl"ty exceeded the acceptability limit of greater than or equal to 90 percen The inspector reviewed the semi-annual augmentation test records. No problems were  !

identifie Conclusions Recurring, but unrelsted problems were identified with the EOF's HVAC syste ,

However, overall, the response facilities' equipment, and supplies were well maintaine All emergency equipment requested to be demonstrated were verified operable. The prompt alert and notification system was well maintaine P3 EP Procedures and Documentation 1 Insoection Scone (82701)

The inspector reviewed a selection of emergency plan implementing instructions (EPIs)

and emergency plan section Observations and Findings Section 8.0, " Maintaining Emergency Preparedness," of Revision 13 of the Emergency Plan was reviewed by the inspector. This section of the plan included identification of the organizational responsibilities for the EP program, training requirements, annual program review, and drill and exercise program. Section 8.1.2 appropriately identificd responsibilities and requirements for training plant personne Suction 4.0, " Emergency Conditions," of tha plan incorporated new plant specific EALs that had been approved by NRC's Office of Nuclear Reactor Regulation. This section also identified the protective measures to be recommended to the State and county officials upon declaration of a General Emergency. These protective action recommendations (PARS) were consistent with guidance in Supplement 3 to NURE / FEMA-REP _ _ -- . __ _ _ ._ _ . _ _ _ . ~ . _ . ___ _ ___ - .

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EPl B8, * Protective Actions and Guides," Revision 8, was reviewed by the inspecto This revisien included a decision flow chart to assist responsible persons in making PARS based on plant conditions and actual or projected dose EPI A2, ' Emergency Actions Based On Event Classification," Revision 7, was revised to include ah four of the emergency classification levels (EALs)in this one implementing

'qstruction. An event classification checklist was attached to this instruction which summarized appropriate immediate and follow up actions to the decision maker, c. Conclusions Reviewed sections of the emergency plan and implementing procedt'res were consistent with regulatory guidance. Checklists enhanced use of the EPi P5 Staff Training and Qualification in EP a. Insoection Scoce (82701)

The inspector reviewed aspects of the licensee's training program. The reviews included interviews with selected key emergency response organization (ERO)

personnel, including a TSC Emergency Coordinator, EOF Emergency Coordinator, and control room Acting Emergency Coordinator. Course critique forms, attendance records, examinations, and the Emergency Response Telephone Directory were also reviewed, b. Observations and Findinas Interviews with three key emergency response personnel indicated appropriate krowbdge of procedures and emergency responsibilities. The EOF and TSC Emergency Coordinators oemonstrated knowledge of the new PAR flow chart and of the NRC's and Department of Energy's incident response. During the interviews, personnel commented on the generallesponsiveness of the EP staff, the improve.nents made to the facilities and equipment, and that the facility walk throughs and drNs, which were used for initial and requalification training, were effectiv A review of selected records indicated that drills and training were formally critique Training records were compared with the Emergency Response Telephone Directory to verify that ERO personnellisted on the calllist were qualified. All ERO personnel were currently qualified for their emergency response positions, c. Conclusions The EP training program appeared effective. Competent knowledge of emergency responsibilities and procedures was demonstrated by three key ERO personnel. Dri!!s and facility walk-throughs were effectively used as part of training. All personnellisted in the Emergency Response Telephone Directory were qualified for their emergency response position __

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l P6 EP Organization and Administration The inspector discussed a change made to the EP program organizational structure since the last program inspection. The EP Unit Supervisor reported direMy to the i Naclear Services Director and not through the Regulatory Affairs Manager. This more  !

direct reporting path shortened and should improve the management communication pat The loss of five out of 12 experienced EP staff members from the EP Un:t (two clerks were replaced with temporaries)ln the last year and the pending loss of the EP instructor was discussed with the EP Coordinator. The accumulative impact of these

losses necessitated changes to the program and additional effort by the staff. Changes to the program included changing non required activilles from proceduralized activities i

, to informal chc:ks (emergency phone tests), reducing the number of emergency

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procedures that had to be periodically revised, and providing the annual public information in brochure form instead of in an elaborate calenda The inspector found that the program appeared to continue to be effective due to the more direct management report, statements from interviewed ERO personnel, and by >

the emergency facility and equipment upgrades. Examples of management support ,

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included new and upgraded equipment in the facilities, replacement of the Duty Roster program with the Dialogic Communicator system, new RMT vehicles, implementation of an informative EP web site, revision of emergency proceduros, and implementation of improved EALs. However, the loss of six experienced EP Unit staff members could have potentiallong term effects on the program. This issue will be tracked as an Inspection Followup item (50-440/97017-02(DRS)).

P7 Quality Assurance in EP Activities Insoection Scoce (82701)

The inspector reviewed the Quality Assurance Section (QAS) Audit Number PA 97 06,

" Emergency Plan," dated June 3,1997, and Audit Number PA 96-08, " Emergency Plan,"

dated April 4,1996, Observations and FindiDOS The QAS staff's 1997 audit concluded that the EP program was being effectively implemented. No significant problems wero identified. The implementing instructions were current, the emergency facilities, and equipment were ready and capable of supporting emergency response. The audit, which satisfied the requirements of 10 CFR 1 50.54(t), identified that the interface with the State and counties had been strong. Also identified was the EP unit's continued strong performance, which was especially _

noteworthy due to a 30% staff reduction in 199 The OAS staff's 1996 audit concluded that the EP program demonstrated continued strong performance. The report noted the plant organization was well prepared to  !

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effectively support emergency response activities using the resources provided. One attribute noted in this report was the effective interface between the EP Unit and the State and local governments included with the 1996 audit were the offsite interface evaluations of the three counties and the State of Ohio's Emergency Management Agency. Two issues were identified in this audit related to a lack of attendance at pre-exercise briefings by exercise participants and controllers, and the lack of a formal mechanism for the OSC Supervisor to callin craft and technician support. PIFs effectively documented and corrected these two issues. Thess issues were entered in the plant's corrective action program, which effectively tracked the items, Conclusions The licensee's 1997 and 1996 QAS EP program audits were effective and satisfied the requirements of 10 CFR 50.54(t). The audits were of good scope and depth. Corrective actions were effectively documented, tracked, corrected, and closed by the EP staf P8 Miscellaneous EP issues P LOoon) Insoection FollowuDJtem No. 50-440/96009-01(DRP): During the 1996 emergency exercise, the control room crew demonstrated inadequate monitoring of panet instrumentation when the annunciators were lost. Corrective actions initiated included development of a potentia llssue form, which suggested that a method be developed to monitor syt,tems for proper operation and then to train the operators on the technique. This item will remain open pending completion of appropriate corrective action P LQpen) Insoection Followuo item No. 50-440/96009-02fDRS): During the 1996 emergency exercise, an Exercise Weakness was identified when the General Emergency notification form was transmitted to the State and county agencies without a PAR. Corrective actions initiated included development of a potentialissue form, which identified the appropriate root cause and corrective actions to be taken. An Emergency Planning Note was communicated to plant personnel. Training was provided to emergency response organization personnel having protective action recommendations responsibility, an emergency plan change was initiated, and the dose assessment software was revised to include the default PAR. This item will remain open pending appropriate demonstratio P8.3 LQpen) Insoection Followuo item No. 50-440/96009-03fDRS); During the 1996 emergency exercise, a number of EOF status boards were not used effectivel Corrective actions initiated included updating EOF status boards to reflect significant protective action information and delete old dose assessment information which was not required. This item will remain open pending appropriate demonstration of EOF status board usag .

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E Jinnagement Meeting l Xi ExN Meeting Summary The inspector presented the inspection results to lloonsee management at the conclusion of the onsite inspection on November 7,1997. As a result of a telephone conference with licensee l staff on December 18,1997, which was neeoed to obtain additional Information related to procedures, emergancy plan sections, and lesson plans, it was determined that no violations of ,

NRC requirements were identified. The licensee acknowledged the findings presente :

The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary No proprietary informatbn was identifie ;

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I PARTIAL LIST OF PERSONS CONTACTED Licensee J. Anderson, Senior Emergency Pr Coordinator D. Cleavenger, Emergency Planner >

R, Collings, Quality Assurance Manager C. Elberfeld, Compliance Engineer T. Rausch, Peny Quality and Personnel Development Director M. Roseum. Emergency Planning Supervisor R. Schrauder, Nuclear Engineering D!rcetor K. Wierman, Emergency Preparedness Instructor NBC J. Clark, Resident inspector D. Kosloff, Senior Resident inspector QEMA E. Eowards, Radiological Analyst INSPECTION PROCEDURES USED IP 82701 Operational Status of the Emergency Preparedness Program i

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ITEMS OPENED, CLOSED, AND DISCUSEED Opened 50-440/97017 01(DRS) IFl Track the operability and availability of the EOF's HVA /97017-02(DRS) IFl Track the potentialimpact of a loss of staff from the EP -

Uni Discussed 50-440/96009-01(DRP) IFl Control room crew inadequately monitored panel Instrumentation after the emergency exercise loss of annunciator /96009-02(DRS) 'IFl - Exercise Weakness identified for falling to provide a

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protective action recommendation to State and county officials on the General Emergency notification for /96009-03(DRS) IFl . Some of the EOF status boards were not used effectively during the 1906 emergency exercise.-

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LIST OF ACRONYMS USED ,

DRP Division of Reactor Protection DRS Division of Reactor Safety EAL Emergency Action Level EOF Emergency Operations Facility EP Emergency Planning EPl Emergency Plan Instructions

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ERIS Emergency Response Information System ERO Emergency Response Organization HVAC Heating Ventilation and Air Conditioning IFl Inspection Follow up flem OPX Off Premise Exchange OSC Operations Support Center PAR Protective Action Recommendation PC Personal Computer PDR Public Document Room Plc Procedure / Instruction Change PIF Potentialissue Form .

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QAS Quality Assurance Section RMT Radiation Monitoring Team TSC Technical Support Center '

PARTIAL LIST OF DOCUMENTS REVIEWED Emergency Plan 6,4, "Offsite Protective Actions," Revision 13, PIC 5, dated May 28,199 Emergency Plan 8.0, " Maintaining Emergency Preparedness," Revision 13, PIC 5, dated May 28,199 ,

Procedure EPI-B8," Protective Actions and Guides," Revision 8 dated May 1,199 Procedure EPI A2," Emergency Actions Based On Event Classification,* Revision 7, dated April 4,1997.

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Procedure PSI-0001, * Maintenance of the Emergency Response Telephone Directory,"

Revision 6, Plc 1, dated January 15,199 Procedure PAP-1701, * Records Management Program," Revision 7 Plc 1, dated September 8, 1997, Procedure TMA 4201, " Documentation of Training," Revision 3, PIC 2, dated August 6,199 Procedure TMP 2302, " Emergency Plan Training Program,' Revision 2, dated January 15, 1997, s

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