ML17056B874
| ML17056B874 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 05/18/1992 |
| From: | Eckert L, Mccabe E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17056B873 | List: |
| References | |
| 50-220-92-10, 50-410-92-12, NUDOCS 9206020061 | |
| Download: ML17056B874 (20) | |
See also: IR 05000220/1992010
Text
U. S. Nuclear Regulatory Commission
Region I
Docket/Report:
License:
50-220/92-10 and 50-410/92-12
Licensee:
Niagara Mohawk Power Corporation
Post Office Box 63, Lake Road
Lycoming, New York 13093
Facility Name:
Inspection:
Inspection At:
Nine Mile Point Nuclear Station (NMPNS), Units 1 and 2
April 6-9, 1992
Scriba, New York
Inspectors:
L. Eckert,
mergency Preparedness
Section
date
J. Lusher, Emergency Preparedness
Section
C. Gordon, Emergency Preparedness
Section
Approved:
E. McC, Chief, Emergency Pre
redness
Section, Division of Radiation Safety
and Safeguards
IP 9c-
date
Areas Inspected
(EP), including: program changes;
emergency facilities;
equipment, instrumentation, and supplies; organization and management control; emergency
response
organization (ERO) training; staff knowledge and performance of duties; and
independent
reviews/audits.
Results
The EP program
was maintained
in a state of operational
readiness.
Concerns
were
identified with the
licensee's
ability to meet
commitments
made
following the
1988
Emergency Response
Facility appraisal and in the method to achieve initial accountability
following activation of the Emergency Plan.
920602006i
920520
ADOCK 05000220
9
DETAILS
1.0
Persons Contacted
The following licensee personnel were contacted during the inspection.
C. Boniti, Senior Instructor, EP Training
B. Burch, Manager, Nuclear Communications and Public Affairs
P. Carroll, General Supervisor, Nuclear Security
G. Corell, Manager, Chemistry, Unit 1
A. DeGracia, Manager, Operations, Unit 2
P. Hartnett, Program Director, EP Projects
D. Howes, Supervisor, Emergency Facilities
J. Jones, Program Director, Radiological
J. Kaminski, Program Director, Drills and Exercises
M. McCormick, Unit 2 Plant Manager
A. Salemi, Director, Emergency Preparedness
R. Smith, Training Supervisor
J. Spadafore,
Program Director, Engineering, Unit 1
K. Sweet, Manager, Maintenance, Unit 1
W. Wambsgan,
Supervisor, QA Audits
C. Ware, General Supervisor, Technical Training
S. Wilczek, Vice President, Nuclear Support
- Denotes attendance at the exit meeting held on April9, 1992.
The inspectors also interviewed and observed the actions of other licensee personnel.
2.0
Operational Status of the Emergency Preparedness
(EP) Program
2.1
Changes to the EP Program
The inspectors reviewed changes
to the Nine Mile Point Site Emergency Plan (SEP) and its
implementing procedures
(EPIPs) since the last EP inspection to determine if they adversely
affected the licensee's overall state ofEP and whether the changes had been properly
reviewed,'pproved,
and distributed.
Several procedural
changes
were initiated in response
to areas
needing improvement from the 8/13/91 Site Area Emergency.
In particular, S-EPP-5 Revision
13,
12/1/91,
"Station Evacuation"
and
S-EPP-19
Revision
8,
12/1/91,
"Site Evacuation
Procedure" were changed
to place the responsibility for accountability from with the Nuclear
Security Department.
S-EPP-20 Revision 14, 8/26/91, "Emergency Notifications" was changed
to clarify the process for activating the Community Alert Network (CAN). These procedures
received a 50.54(q) review, a safety review, and a Site Operating Review Committee (SORC)
review prior to being issued.
No changes in EP were expected
as a result of licensee identified
items in need of corrective action from the recently declared Alert. NRC review concluded that
changes
made since the last inspection have not decreased
program effectiveness.
0
Since the last inspection, the licensee used the simulator to conduct drills and planned to use
it to conduct the 1992 annual exercise.
The new Evacuation Time Estimates (ETEs) from the 1990 census were completed.
The
licensee was currently assisting in the evaluation of necessary changes to the New York State
Emergency Plan including re-evaluation of siren coverage within the EPZ and upgrade of
evacuation
routes due to high tourist population during selected
summer months.
The
impact of changes to the State Emergency Plan willbe evaluated in a future inspection.
Another change in the EP Branch related to evaluation of SEP and EPIP revisions to
determine whether there was a decrease in program effectiveness due to such changes.
In
response
to an NRC area for improvement, the licensee modified the process
so that all
changes received a formal 50.54(q) review, a safety review, and final SORC approval prior
to being implemented.
This change adequately addressed
the NRC concern and Item Nos.
50-220/91-03 and 50-410/91-03 are closed.
This program area was assessed
as being effectively implemented.
2.2
Emergency Response Facilities (ERFs), Equipment, Instrumentation, and Supplies
The inspectors toured the Unit 1 Control Room (CR), Operations Support Center (OSC),
Technical Support Center (TSC), Emergency Operations Facility (EOF), and the Alternate
Emergency
Operations
Facility (AEOF) to assess
whether these
facilities, equipment,
instruments, supplies, and procedures were adequately maintained.
Facilities were well maintained
and ready for emergency
use.
The inspectors
sampled
communications
equipment,
computer
terminals,
and
survey equipment
to determine
operability and calibration. The inspectors found that all sampled equipment was functional
and calibrated.
Review ofthe licensee's facilitysur veillance reports and discrepancy corrective action reports
for 1991 and first quarter 1992 found them an effective means of insuring readiness.
The
inspectors reviewed communication test reports and found them acceptable.
Corrective
actions for discrepancies
were resolved promptly.
Since the last inspection, the Operations Support Center (OSC) was designated
a dedicated
emergency response
facility. The OSC was effectively used to support response
activities
during the August 1991 Site Area Emergency.
Another ERF upgrade was completed in
1991 to the AEOF, in which two commercial telephone
lines were added for the NRC's
Emergency Notification System and Health Physics Network. That was completed in June
of 1991 ~
EOF and TSC ventilation systems were functionally tested on a quarterly basis.
The HEPA
filters were'ested
every eighteen
months with dioctyl phthalate
(DOP).
To readily
determine EOF habitability, a display panel provided indication for-damper position, fan
operation (normal and emergency line-ups), and positive pressure.
4
This program area was assessed
as being effectively implemented.
29
Organization and Management Control
The EP program was reviewed, personnel
were interviewed, and activities evaluated
to
determine whether the licensee was maintaining and controlling an adequate
EP program
required by NRC regulations.
Since the last inspection, there have been no organizational changes to the program.
The
EP Branch is one of six units of the Nuclear Support Group.
The Director, EP Branch
continues to report directly to the Vice President, Nuclear Support.
There was a staff reduction in the EP Branch from ten to eight individuals. The rotational
Station Shift Supervisor (SSS) who was responsible for operations data for scenarios
and
EAL implementation, was eliminated.
The EP branch relied upon assistance
from other
groups concerning scenario development.
The licensee planned to reduce further the EP
Branch by two positions in the future. Section 8.1.2c of the Site Emergency Plan required
that
each
drill/exercise
scenario
follow the
guidelines
set forth in Emergency
Plan
Maintenance Procedure (EPMP) 4. That procedure dictated that the Plant Manager was
responsible for providing resources from various site departments for drill/exercise scenario
development.
At the time of the inspection, the inspectors noted that no resources outside
the EP Branch were being used in the scenario development process.
At the time of the
inspection, there were no personnel within the EP Branch with the proper background in
Health Physics to prepare radiological portions ofscenarios.
Previously, the EP Branch had
relied upon contractor and/or site HP support to assist in scenario
development.
This
observation was brought to the attention of the Vice President, Nuclear Support who stated
the intention to address this matter.
The EP staff backgrounds were diverse.
There was an ex-SRO qualified individual within
the EP Branch who was
assigned
to scenario
development.
Another individual was
responsible for drill/exercise coordination.
Individuals were assigned
to communications
testing and commitment tracking, procedures
and the Emergency Response
Organization
(ERO) database,
and ERF management.
The inspectors selected records maintained for the ERO to ensure they were trained and
qualified to filltheir prospective positions, and to ensure that the training dates current. The
training due dates for ERO members ranged from 5/92 to 4/93.
Individuals were required
to receive all training every twelve months, plus or minus three months. Iftraining was not
completed by this time, that person was removed from the ERO qualification roster.
The
"inspectors noted that there were no personnel who had gone beyond their grace period for
qualification. The ERO was fully staffed. The licensee goal was to maintain at least three
or four qualified personnel in all positions.
The inspectors found this goal was achieved,
with 4-6 personnel qualified in most ERO positions.
Due to a reduction in station staffing,
lists of qualified ERO individuals contained in the EPIPs were undergoing revision.
Interviews conducted
with senior management
staff indicated good involvement in EP
program administration
and in their ability to perform response
activities.
The Vice
0
President, Nuclear Support maintained close interface with the Director, EP and was kept
apprised ofprogram status. Site Emergency Directors assumed both SED and support roles
during the response to the August 1991 Site Area Emergency and March 1992 Alert.
2.4
Knowledge and Performance of Duties (Training)
The inspectors
reviewed selected
training records of ERO personnel
to ensure that the
records were being maintained and that lesson
plans were current and appropriate for
designated
positions.
Lesson plans (LP) were revised and approved by the Director, EP in 1990. Also, during the
training sessions,
the instructors covered Licensee Event Reports (LER) and experiences
gained from real events.
EP training staff prepared
a new booklet which provided an
overview of the EP program,
This booklet was used in EP training classes
and General
Employee Training.
Also reviewed were class evaluation sheets to determine whether comments provided by
attendees
were considered by training staff in their LP reviews. The inspectors found that
such comments were included in LPs and provided instructors with ideas for better class
presentations.
Most ERO training was given in the classroom. The EP training instructors
were switching to performance based training by providing demonstrations in the ERFs. EP
instructors
stated
that
changes
in ERO training were
expected
by a shift toward
a
performance-oriented
structure.
Training Change Orders (TCOs) were used to make corrections and changes to lesson plans.
As a result of the concern identified in communications capability during the August 1991
Site Area Emergency, TCOs for communicators were put in place to stress the importance
of following notification procedures in proper sequence.
The inspectors performed walk-through scenarios with Health Physics (HP) and Chemistry
technicians to examine the effectiveness of training for those individuals responsible for
performing on-shift dose assessment.
Two Dose Assessment
teams consisting of an HP and
a Chemistry technician were chosen. The teams performed well on both scenarios and were
able to develop appropriate Protective Action Recommendations
for the Shift Supervisor
to consider.
This program area was assessed
as being effectively implemented.
2.5
Independent Reviews/Audits
An independent review is required at least every 12 months by 10 CFR 50.54(t) and included
an evaluation of the adequacy of the off-site interface. To determine ifrequirements were
met, the inspectors
reviewed the licensee's
Technical Specifications,
Quality Assurance
Procedures
(QAP), interviewed Quality Assurance
(QA) auditors,
reviewed the Audit
Scoping Plan and Audit checklists, and reviewed final QA reports for 1991.
Technical Specification Section 6.5.3.8 for each
Nine Mile Point unit required
an
independent
annual review/audit by the Safety Review and Audit Board (SRAB).
This
requirement
was
met
through
18.10,
Revision
13,
1/13/92 "Quality Assurance
Department Nuclear Audit Program". To avoid duplication of resources,
the annual audit
and the 10 CFR 50.54(t) review were combined.
Significant items, or those not adequately
addressed,
were included in a Deviation Event Report (DER) (Report Detail 2.6).
18.10 directed the Supervisor, Quality Assurance Audits provide standard Audit Scoping
Sheets
for each required audit.
The inspector reviewed the Emergency
Preparedness
Scoping Sheet and noted that it did not contain specific direction as to the evaluation of the
adequacy of off-site interface per
10 CFR 50.54(t) and discussed
this as an area for
improvement.
The Supervisor QA audits was reviewing the EP QA Scoping Sheet for
improvement and stated the intention to address this area for improvement.
Overall, audits and surveillances
conducted
by the Site QA Department
since the last
inspection conformed to QA procedures.
No recurring items were noted.
The inspectors
reviewed audit plans and found them effective.
Audit reports were submitted to the
Director, EP and senior licensee management.
The inspectors
reviewed the April 3,
1991 QA report and concluded
that the report
conformed to Quality Assurance
Procedures.
A team of three auditors
assessed
the
effectiveness of a drill conducted on February 26, 1991.
Eight drill/exercise observations
were identified, of which three were noted as recurring items.
These recurring concerns
were elevated to DER and involved dispatch of emergency repair teams (ERTs) from the
OSC, failure to provide appropriate notification from the TSC within 15 minutes, and failure
to dispatch ERTs in a timely manner,
To resolve these concerns, additional training was
given to affected personnel.
The audit team concluded that the ERO was effective in
implementing the SEP.
The inspectors also reviewed audit No. 91011-RG/IN performed under the SRAB, The audit
included an assessment
of: organization and administration, plan and procedures, training,
drill, facilities and equipment, assessment
and notification, public information, coordination
with off-site agencies,
an'd corrective action. Seven observations
an'd one DER were issued.
The DER was identified in the August 1, 1991 drill and related to the failure to make an
off-site notification within 15 minutes of declaring an emergency.
Overall, the audit team
concluded
that an effective emergency
preparedness
program was being implemented.
Copies of this audit report were sent to the New York State Radiological Emergency
Preparedness
Group and the Oswego County Emergency Management Office as required.
The inspectors
also reviewed
six QA surveillance
audits and found them effective in
'ugmenting the annual audit/review.
An independent
EP audit conducted by a contractor
to provide another view of the commitment control process found no program concerns.
This program area was assessed
as being effectively implemented.
2.6
Commitment Tracking
The inspector reviewed the systems
by which corrective actions were tracked.
Items
requiring corrective actions were maintained on three systems:
Noncompliance tracking
system (NCTS), Quality Assurance Database,
and EP Work Track.
Since the last inspection, NCTS became
the exclusive station corrective action tracking
system for NRC identified concerns.
NCTS reports
were sent monthly to the Plant
Managers and the Vice Presidents.
NCTS items were prioritized with assigned commitment
dates.
Additionally, the EP section developed their own commitment tracking system called
EP Work Tracking.
The system used to issue Corrective Action Recommendations
was eliminated and replaced
with Deviation Event Reports to track program weaknesses.
Audit Observations that were
not adequately
resolved
become
DERs.
The QA database
included DERs and was
maintained in accordance with QAP 15.03 "Deviation/Event Reports". DER disposition due
dates were assigned by the Plant Manager with input from the Director, EP.
EP Work Tracking included all items in the other two tracking systems.
Each week the EP
Department
held
a
staff
meeting
in
which
items
were
reviewed,
due
dates
assigned/negotiated,
and resources
committed to item resolution.
The Director, EP was
responsible for the closeout of items solely within this system.
It was noted that the licensee had no means of tracking procurement
items (needed
as
corrective actions to ERF surveillances) that may be open for extended periods of time due
to ordering, manufacturing, or work order delays to closure.
EP Work Tracking had no
provisions for categorization of items to facilitate root cause
analysis.
The inspectors
discussed
this with the Director, EP as a possible area for improvement. This item, along
with a determination on the effectiveness of changes to the commitment tracking system will
be followed up in a future inspection.
2.7
Drilland Exercise Program
The Emergency plan Section 8.3 and EPMP-4 established guidance and responsibilities for
drills and
exercises.
These
included
drill development,
management
and
referees,
scheduling, approvals, corrective actions and objectives. A change in conduct of the annual
exercise from contractor to site resources willbe made for 1992. As a result of this change,
the inspectors discussed
areas to improve administration of the drill/exercise program with
EP staff.
The inspectors
also
found that there
was
no formal system
for tracking
drill/exercise objectives except to review demonstrations
in scenarios conducted throughout
the previous year. Also, this was noted in Audit Report No. 91011-RG/IN as an opportunity
for improvement. At the time of the inspection, the Program Director, Drills and Exercises
was formulating a scenario development committee to prepare the 1992 scenario. Adequacy
of drill/exercise program administration and review of the 1992 scenario willbe performed
during the next scheduled
inspection.
All drills were approved by senior management
in accordance with EPMP-4.
Emergency
Plan requirements for 1991 drillactivities were met. Two fullstation drills were held during
1991 and included responses
to a variety of different events and initiating conditions. Drill
packages were timely, complete, and distributed to management.
All reports included an
overall summary, strengths and weaknesses
for each facility, whether objectives were met,
and recommended
corrective'actions.
This program area was assessed
as good.
2.8
Public Information
To determine adequacy of the public information program, the inspectors interviewed the
licensee's Public Affairs Director.
After the 1991 Site Area Emergency, public affairs and other licensee representatives
met
with local media staff to discuss possible areas for improvement in media relations. During
the annual media training session, the licensee held a walk-through drillat the Oswego EOC
where the news media personnel participated
as EOC officials. In addition, the licensee
conducted
a seminar with the media given by the Executive Vice President - Nuclear and
the Vice President-Nuclear Support on waste transportation.
This program area was assessed
as being effectively implemented.
3.0
Licensee Action on Previously IdentiTied Items
In 1988, the NRC performed an appraisal of the licensee's emergency response facilities to
determine how each facility met NUREG-0737, Supplement
1 criteria.
Findings were
documented
in Inspection Report Nos. 50-220/88-25 and 50-410/88-24.
Short-term items
were adequately
addressed
and
resolved
and the licensee
had
been working toward
completing long-term commitments.
The inspectors
reviewed the licensee's
progress
in
meeting outstanding open items from the appraisal.
The status of each item is as follows.
CLOSED (IFI 50-220/88-25-04
and 50-410/88-25-04) Verify and validate dose projection
software.
The licensee completed the verification and validation for the dose projection software and
issued results in a report dated April4, 1992. The inspectors reviewed the report and found
it extensive and thorough.
This item is closed.
CLOSED (IFI 50-220/88-25-09 and 50-410/88-25-09) Unit 1 event historical capabilities in
need of upgrade.
The licensee has adequately increased Unit 1 event historical capability to be consistent with
Unit 2. This item is closed.
CLOSED (IFI 50-220/88-25-07 and 50-410/88-25-07) Verification of plant sensor data.
The inspectors reviewed licensee records of Unit 2 computer point verifications conducted
during 1990 and
1991 and determined
that identified inconsistencies
and errors were
corrected.
This item is closed.
OPEN (IFI 50-220/88-25-05
and 50-410/88-25-05) Review adequacy of safety parameter
signal isolation.
Completion was scheduled for September
1992 following the refueling
outage.
OPEN (IFI50-220/88-25-06 and 50-410/88-25-06) Plant computer system had no reserve for
heavy use periods. The licensee willupgrade the plant computer system.
This upgrade was
scheduled to begin September
1992.
The inspector
reviewed the licensees
actions
to the above
two items and found that
unnecessary applications were removed from the computer and supplementary core memory
added.
However, at the time of the inspection, installation and testing of the new plant
computer system was not completed. These items will remain open until an assessment
of
the new system can be made.
OPEN (URI 50-220/88-25-08
and 50-410/88-25-08) A protection factor of five was not
attainable at the double exit doors to the Emergency Operations Facility (EOF).
EOF habitability is determined during emergencies
by radiation surveys and air sampling of
the general area throughout the facility. To address the protection factor issue, the licensee
committed to perform an evaluation of EOF shielding with a due date of 12/31/91 for the
evaluation. At the time of the inspection this analysis was not initiated. Discussions with the
licensee personnel indicated that the evaluation was expected to be complete by 12/31/92.
This item remains open until the licensee provides the evaluation.
In addition, the inspectors followed-up NRC identified concerns (NRC Inspection Report
Nos. 50-220/91-19 and 50-410/91-19) resulting from the licensee's response during the August
1991 Site Area Emergency. The status of each items is as follows.
CLOSED (NCV 50-220/91-19-01
and 50-410/91-19-01)
The licensee failed to notify the
ERO via the CAN in a timely manner.
Additional training of Control Room communicators
was immediately provided with
emphasis
on making notifications in proper
sequence.
Although additional training is
sufficient to close the item, performance ofcommunicators willbe evaluated during the 1992
'nnual exercise.
OPEN (URI 50-220/91-19-02
and
50-410/91-19-02)
Oswego
County "Green
Cards" to
expedite ERO personnel through off-site roadblocks were not carried by all members of the
ERO.
The Director, EP issued
a memorandum
to all ERO members which reinforced the need
for personnel to carry their Green Cards.
The inspectors noted that additional reminder
10
signs
and
posters
were located
throughout
the site.
QA Surveillance
conducted
an
unannounced audit by requesting a demonstration of Green Card possession and found that
a significant number of individuals had failed to carry their cards on their person,
Many of
these individuals had left their cards within their vehicles. Another memorandum was issued
to stress
the importance of carrying the Green Card at all times.
At the time of the
inspection, additional surveillances
had not been
conducted.
This item remains
open
pending further review.
OPEN (URI 50-220/91-19-03 and 50-410/91-19-03) Accountability of personnel within the
protected
area
was
not completed
within 30 minutes
of the
Site Area Emergency
classification.
The NRC identified two concerns associated with this item. The first related to the overall
responsibility for accountability
being
shared
among
the
Maintenance,
Security,
and
Operations
departments.
The licensee
revised the accountability procedure
so that the
Security staff now controls the accountability of personnel during emergency events.
The
inspectors noted this change
as a noteworthy enhancement
to the process.
The second
concern, however, was associated with the licensee's ability to meet the NRC's guidance to
perform an initialaccountability within the protected area in about 30 minutes. The changes
made in procedure and responsibility appear to address continuous accountability only, and
it remains unclear how initial accountability willbe achieved.
CLOSED (URI 50-220/91-19-04 and 50-410/91-19-04) Adequacy of the licensee's resolution
of Action Plan items.
Following the event,
a comprehensive
list of items for possible corrective action was
compiled
and
prioritized
by the
staff.
The
inspectors
reviewed
the
status
of
implementation of the high priority items and noted that good progress was being made.
This item is closed.
4.0
Exit Meeting
The inspectors met with the licensee personnel denoted in Detail 1 at the conclusion of the
inspection to discuss
the inspection scope and findings.
The licensee acknowledged
the
findings and stated
their intention to evaluate
them and institute corrective actions
as
appropriate.