ML17263A841
| ML17263A841 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 11/15/1994 |
| From: | Keimig R, David Silk NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17263A837 | List: |
| References | |
| 50-244-94-21, NUDOCS 9411150030 | |
| Download: ML17263A841 (17) | |
See also: IR 05000244/1994021
Text
U. S.
NUCLEAR REGULATORY COMMISSION
REGION I
License/Docket/Report
No.:
DPR-18 50-244 94-21
Licensee:
Facility Name:
Inspection At:
Rochester
Gas
and Electric
Com an
RG&E
R.
E. Ginna Nuclear
Power Station
Ontario
Inspection
Conducted:
October
3
6
1994
Inspectors:
D. Silk, Senior
E ergency
Preparedness
Specialist
J. Laughlin,
Emergency
Preparedness
Specialist
F. Lopresti,
Emergency
Response
Assistant
Qe
Approved By:
.
R;
ei ig,
ef
Emergency
re
redness
Section
Division of Radiation Safety
and Safeguards
Areas Inspected:
Emergency
Preparedness
(EP) readiness,
including: procedure
changes;
Federal
Telecommunication
System
(FTS)
2000 network;
emergency
response facilities (ERFs),
equipment,
instrumentation,
and supplies;
organization
and management
control;
emergency
response
organization
(ERO)
training; independent
audits;
and the licensee's
corrective action program
pertaining to
EP items.
Results:
The program's state of readiness
was determined to be good.
Procedure
changes
were acceptable,
however,
the licensee
had not submitted
three recent Nuclear
Emergency
Response
Plan
(NERP) revisions to the Regional
Office as required
by 10 CFR 50.54(q).
The
ERFs were found to be well
equipped.
However,
two quarterly siren growl tests
were not performed
by the
licensee
as required
by the
NERP.
The
EP organization
had undergone
some staff
changes
but was found to be adequate.
The depth in
ERO staffing was at least
three'n
each position.
The
EP training program was well implemented.
Audits
were found to be satisfactory.
Corrective actions pertaining to the
program were acceptable.
No safety items were identified but two apparent
violations were issued
because
of the failure to test sirens
and the failure
to submit
NERP changes.
The two violations were
symptoms of a program
control s- weakness,
941ii50030 94ii07
ADOCK 05000244
8
DETAILS
Personnel
Contacted
RGKE
R. Beldue,
Corporate
Nuclear
Emergency
Planner
F. Orienter,
Coordinator Radiological
Safety Communications
P. Polfleit, Onsite
Emergency
Planner
W. Poulton, Training Specialist
B. Stanfield, guality Assurance
Engineer,
Independent
Assessment
Other licensee
personnel
were also interviewed during the inspection.
Nuclear
Re ulator
Commission
J. Laughlin,
Emergen'cy
Preparedness
Specialist
F. Lopresti,
Emergency
Response
Assistant
+ 'enotes
attendance
at the October 3,
1994 Entrance Heeting.
Denotes
attendance
at the October 6,
1994 Exit
Heeting.'.0
Emergency
Plan
and Implementing Procedures
The inspectors
reviewed implementing procedure
(EPIP)
changes
to
determine
whether
any changes
resulted
in a decrease
in effectiveness
of
,
the overall
emergency
plan.
Prior to this inspection,
the inspectors
reviewed the procedures
listed in Section 9.0 of this report in the
Region I Office.
The changes
were assessed
as acceptable.
During the inspection,
however,
the inspectors
discovered that three
NERP revisions
had
been
made without the Regional Office being
aware of
it.
Changes
to the
NERP can
be
made without NRC approval if they do not
decrease
the effectiveness
of the
NERP, but the changes
must
be
submitted to the Regional Office in accordance
with 10 CFR 50.54(q).
The
NRC regulations require the licensee to submit
one copy of the
changes
to the
NRC Document Control
Desk and the Resident
Inspector,
and
two copies to the
NRC Regional Office within 30 days of implementing the
change.
The inspectors
identified that
NERP Revision
12 (July 1, 1993),
Revision
13
(Hay 4, 1994),
and Revision
14 (August 31,
1994)
had not
been submitted to the
NRC Region I Office, even though they had
been
submitted
on
a timely basis to the Document Control
Desk and the
Resident
Inspector.
The reason
given by the licensee for the oversight
was that the
EP Group sends
copies of the changes
to the Document
Control
Desk and the Resident
Inspector directly, whereas
Region I is
sent copies through the licensee's
document control group.
The document
control group
had received notification of the changes
from the
EP Group
but overlooked its distribution to the Region I Office.
This is an
apparent violation (VIO 50-244/94-21-01).
3
Emergency Facilities,
Equipment,
Instr umentation,
and Supplies
The inspectors
toured the Control
Room (CR), Technical
Support Center
(TSC), Operational
Support Center
(OSC),
and
Emergency Operations
Facility (EOF) to determine their state of operational
readiness.
These
facilities were well-maintained,
contained all necessary
communications
equipment,
and conformed with the facility description in the
NERP.
Overall, they were in very good operational
condition.
However,
controlled copy Number
17 of the
EPIPs in the
TSC was missing
EPIP 2-7,
Management of Emergency
Survey Teams.
The licensee
immediately
added
a
copy of this procedure.
When questioned,
a licensee
representative
could only surmise that it had
been
removed,
used,
and not returned.
The inspector
checked other controlled copies
and found them intact.
No
other procedural
discrepancies
were noted.
The inspectors
conducted
an inventory check of sealed
equipment lockers
for the
TSC and
OSC.
These lockers
were amply supplied with necessary
emergency
equipment
and
no inventory discrepancies
were found.
The
inspectors
also reviewed the most recent
equipment inventory checklists
for the
TSC and
OSC.
These
were completed properly,
signed
by the person
completing the inventory,
and reviewed
by
EP personnel.
The inspectors
spot-checked facility radiation monitoring equipment
and found it
operational
and within calibration time limits.
Overall, the facilities
contained
adequate
emergency
equipment
which was well-maintained.
The inspectors
discussed
the logistical details of an
NRC team
responding
to an emergency with the licensee's
Onsite
Emergency
Planner
(OEP).
As
a result of that discussion,
the licensee will designate
additional
space
in the
EOF for NRC dose
assessment
and re-position the
NRC's Director of Site Operations
(DSO) with the licensee's
Emergency
Director (ED).
The inspectors
also verified the licensee's
conversion to the
FTS 2000
telecommunications
network in accordance
with Generic Letter 91-14,
Emergency Telecommunications.
The inspectors
confirmed the installation
and operation of FTS 2000 telephones
at the appropriate locations in the
CR,
TSC,
and
EOF.
The inspectors
noted that telephone stickers,
which
were provided
by the
NRC and list the new primary, back-up,
and
facsimile numbers for the
NRC Operations
Center,
had not been affixed to
"the telephones
in the
EOF and
TSC.
This matter was discussed
with the
OEP,
and prior to close of the inspection,
the inspectors
were informed
that the stickers
had
been placed
on the telephones.
This was confirmed
by the resident
inspectors
subsequent
to the inspection.
The inspectors
reviewed
EPIP 5-1, "Offsite Emergency
Response
Facilities
and
Equipment Periodic Inventory Checks
and Tests,"
Revision 5,
and
verified that it requires
monthly tests of the
FTS 2000 telephones.
However, the inspectors
found that the primary telephone
number for
contacting the
NRC Operations
Center
was incorrect.
In addition, the
back-up telephone
number listed in Attachment
1 of EPIP 5-1 was
no
longer valid.
These discrepancies
were brought to the licensee's
attention but are
now resolved
since the stickers contain the correct
telephone
numbers.
The inspectors
reviewed the licensee's
public notification system.
The
system consists
of 96 sirens
supplemented
by more than
40 tone -alert
radios within Wayne
and Monroe counties.
The activation of the system
is controlled
by the county officials.
The
NERP requires periodic siren
reliability testing at three levels of operation:
1) bi-weekly silent
tests to verify system electronic
components
are functioning,
2) quarterly manually activated
growl tests to verify siren operation,
and 3)
an annual full duration audible test of the entire system.
The
inspectors
reviewed surveillance
records to confirm adherence
to the
NERP regarding
performance of the siren reliability tests
conducted
in
1994.
Bi-weekly silent tests
and annual full duration audible test were
performed satisfactorily.
However, the last quarterly growl test
was
conducted
on March 2,
1994.
As such,
two quarterly tests
had not been
performed
as required.
The inspectors
also reviewed the
1994 quarterly
growl test schedule
(RGRE Inter-Office Correspondence
Memorandum,
dated
July 1,
1994, Subject:
1994 Ginna Siren Silent and Growl Tests).
The
inspectors
noted that the
1994 growl test frequency
was not scheduled
at
quarterly intervals.
This matter was discussed
with the Corporate
Nuclear
Emergency
Planner
(CNEP)
who promptly initiated action to have
the growl tests
performed for the
96 sirens.
Following the inspection,
the licensee
informed the inspectors
via teleconference
that the tests
were completed
on October 7,
1994
and all of the sirens functioned
properly.
Test documentation will be reviewed during
a subsequent
inspection.
The causes
of missed
growl tests
were twofold.
First, the
EP Group established
a surveillance
schedule with the Electric Heter
Lab
and Telecommunication
Group but this group did not properly inform the
Line Operating
Group (which actually performs the tests).
Secondly,
the
EP group did not verify that the tests
were being performed.
Failure to
conduct quarterly siren growl tests
as required
by the NRC-approved
NERP
is
an apparent violation (VIO 50-244/94-21-02).
Organization
and Management Control
During this inspection,
the licensee's
recent
(September
1994) re-
organization
was evaluated
as to its impact
on the
EP group.
Under the
previous organization,
the five member
EP Group was under the Director,
Corporate
Radiation Protection
and that was his sole responsibility.
Under the
new organization,
th'is
same individual is now the Manager,
Nuclear Assessment
(HNA).
The
MNA now has five areas of responsibility
of which
EP is one.
The Corporate
Nuclear
Emergency
Planner
(CNEP),
who
reports to the
HNA, was scheduled
to retire at the end of October
1994.
He will be replaced
by the
OEP.
The inspector
was informed that the
OEP
position would be posted within a few weeks following the inspection.
The retiring
CNEP has already delayed his retirement
one month to turn-
over the position to the
new CNEP.
The
new
CNEP has,
in the past,
performed various duties of the
CNEP and is, therefore,
not unfamiliar
with the position.
The Corporate Health Physicist
(CHP),
who was
previously in the
EP group,
has retired
and that position was
moved to
the station
because
the
CHP was only infrequently used for EP and when
S
5.0
the
EP group needs
any health physics assistance, it is available
onsite.
No problems related to the reorganization of the
EP Group were
apparent,
but the
NRC will monitor the impact of these
changes
during
future inspections.
The inspector
reviewed the
Emergency
Response
Organization
(ERO)
and
observed that the licensee
had at least three individuals for all key
positions.
Thus,
the licensee
has satisfactorily maintained its
during this period of re-organization
and "right-sizing".
The inspectors
also interviewed the Vice President
Nuclear Operations.
He is currently qualified as
a Recovery
Manager in the
ERO.
He stated
that
he was kept abreast
of EP issues
through the
gA audit reports,
post
exercise critiques,
meeting with the
HNA, and
by reviewing the tracking
system.
He was
aware of the transitional
status of EP due to the re-
organizational
and program changes
such
as implementing
a new Emergency
Action Levels
(EALs) and Protective Action Recommendation
methodology,
and integrating the licensee's
nuclear
emergency
response
program with
severe
weather
and gas
emergency
programs.
Overall, the inspector
determined that
EP issues
are understood
by senior
management
and
receive sufficient senior
management
attention.
EP Training
The inspectors
reviewed various training documents
and interviewed
training personnel
to assess
the adequacy of the licensee's
EP training
program.
The inspectors
audited the training records of several
randomly selected
individuals from various
key
ERO positions to check that their
qualifications were current.
In all cases,
the inspectors
were
shown
that the individuals had attended
the required requalification training
courses
and
had participated
in a drill or exercise
as required.
The
inspectors
also randomly selected
several
individuals that could be
required to wear respiratory protection
and found that all
had
been
trained
and qualified on the appr'opriate
type(s) of equipment.
Additionally; the inspector
reviewed lists of
ERO members
and their
qualification expiration dates
and found that
no expiration dates
were
exceeded
at the time of this inspection.
The inspectors
also interviewed the Operations Training Supervisor
and
reviewed several
records pertaining to licensed operator
EP training.
The operating
crews review event classifications
by utilizing the
during each simulator scenario
session.
The licensed operators
also
receive three
and one-half hours of EPIP training per cycle.
This
training includes table top scenarios
that involve operating
crews
as
well as the shift technical
advisor
and
an
HP technician.
The scenarios
task the players with implementing all the necessary
responsibilities
such
as event declarations,
dose projections,
and
making notifications
and
PARs.
Also,
as scheduling permits, mini-drills
have
been
conducted that integrate simulator requalification training
scenarios
with TSC and/or
EOF activation
and participation.
This not
6.0
only maximizes simulator usage
and Licensed Operator Requalification
Training
(LORT) but also exercises
the activation
and interfacing of
several
ERFs.
The inspectors
assessed
this as
a good initiative.
Independent
Audits/Reviews
The inspector
reviewed the
1994
EP audit report
and interviewed
a member
of the Quality Assurance
(QA) Department to assess
the adequacy of this
activity.
The audit was conducted
February
28 Harch 4,
1994,
under
the supervision of the
QA Department.
The two-man team consisted of one
person
from QA and one person
from the
New York Power Authority's
Corporate
Radiation Protection
Group who had extensive
EP background.
The inspector
concluded that the auditors
possessed
the appropriate
expertise
to conduct
an effective audit of the
EP program.
The scope of the audit was good,
and the. audit plan
and checklist were
adequate.
The inspector
noted that the audit fulfilled the requirements
of 10 CFR 50.54(t).
The audit report received
wide distribution to
licensee
management
and was
made available
by correspondence
to state
and county officials.
The audit identified no findings and six observations,
none of which had
any safety significance.
Findings were defined
as discrepancies
which
contradict licensing commitments,
procedures,
or applicable
purchase
order requirements.
Observations
were items in need of improvement.
The observations
were documented
via Quality Assurance
Observation
Reports
(QAORs).
Although the observations
were of no regulatory
significance,
a response
was required
from the responsible
department.
The inspectors
questioned
the
EP audit program relative to
10 CFR 50;54(t) that requires audits
be conducted
"by persons
who have
no
direct responsibility for implementation of the emergency
preparedness
program."
This requirement
prevents
a potential conflict of interest
and ensures
that audits
are conducted
in an unbiased
manner.
However,
in this organization
the
HNA is responsible for EP and for QA, who
performs the audits.
The inspector brought this to the attention of the
HNA and
a
They stated that this
same organizational
structure
had occurred in the past but there
was never
a problem
resolving
QA findings.
They stated that it was unusual for those
audited to disagree
with QA's findings.
Procedurally,
QA can elevate
issues
to the next higher level of management, if necessary,
for
resolution.
Also,
QA auditors report to lead auditors,
who in turn
report to the
QA Hanager,
who then reports to the
HNA.
Therefore,
there are several
levels of review between the auditors
and the
HNA.
Furthermore,
the
HNA does not prepare
the auditors'erformance
appraisals.
The inspectors
accepted
the licensee
explanation of the
organization
but will monitor this during future inspections
to verify
that effective 50.54(t) audits
are being performed.
Overall,
no deficiencies
were identified and this area
was
assessed
as
being satisfactorily implemented.
7
Effectiveness of Licensee Controls
8.0
8.1
The inspectors
reviewed documentation
and interviewed
EP,
gA,
and
licensing personnel
to determine
the adequacy of licensee control
mechanisms
for problem identification and correction.
Licensee
procedure
A-30, Ginna Commitments
and Actions, described
the process
used for management
of commitments
and action items.
This procedure
was
written as part of a commitment to the
NRC to establish
and maintain
a
commitment tracking system.
It summarized
management
responsibilities
for Commitment/Action Item (C/AI) tracking, established
the Commitment
and Action Tracking System
(CATS) Administrator,
and outlined proper
disposition of all licensee
C/AIs. It assigned
C/AI priority by item
source,
distinguishing regulatory
agency
items from other sources.
The licensee effectively tracked
and resolved C/AIs.
The inspectors
noted that the Licensing Department's
CATS Administrator had
a separate
file on each
item, including all findings in
NRC reports.
When
responsible
departments
completed corrective actions,
they were signed
off and the
CATS database
was updated.
The inspectors
noticed
one
weakness
in CATS administration.
Although the Licensing
CATS
Administrator received training on Procedure
A-30 in 1991
when the
procedure
was written, there
was
no ongoing training program for
department
CATS coordinators.
For example,
the
CATS Coordinator
was
not familiar with the procedure
and was incorrectly filling out
documentation for submission to licensing.
This did not result in any
documentation
deficiencies,
however,
since the licensing administrator
was trained
on the procedure.
Audit findings were documented
in Audit Finding Corrective Action
Reports
(AFCARs)
and audit observations
in gAORs.
Both were tracked in
the
CATS,
and both required
a response,
although only the
AFCARs
required action to correct deficiencies.
The inspectors'eview
of the
most recent
CATS printout revealed
two items, neither of which were
safety significant, that were overdue.
The
CATS was generally effective
in resolving items in the allowed time frame.
Review of Open Items
(CLOSED) IFI 50-244/93-11-02:
During Inspection
93-11 (July,
1993), the inspectors
noted several
issues
pertaining to licensed operator shift crews.
During table-top
exercises,
which simulated fast breaking accident
scenarios,
the
inspectors
observed
areas
related to their
EP duties that could be
improved,
such
as radiological
hazards to
ERO personnel,
verification of
accuracy of dose projection calculations,
and
EAL interpretation.
During this inspection,
the inspector
interviewed the Operations
Training Supervisor
and reviewed several
records pertaining to licensed
operator
EP training.
It was determined that the licensed
operators
receive three
and one-half hours of EPIP training per cycle.
This
training included table-top scenarios
that involve operating
crews
as
8;2
well
as the shift technical
advisor
and
an
HP technician.
The scenarios
require the participants to perform their
ERO responsibilities,
such
as
event declarations,
dose projections,
and making notifications
and
PARs.
Also,
as scheduling permits, mini-drills have
been conducted that
integrate simulator requalification training scenarios
with TSC and/or
"
EOF activation
and participation.
This not only maximizes simulator
usage
and
LORT simulator scenario training but also-exercises
the
activation
and interfacing of several
ERFs.
The inspector
assessed
this
as
a good initiative.
During normal
LORT, the operating
crews review
event classifications
by utilizing the
EALs during each simulator
scenario
session.
Therefore,
based
on the crews'raining
and the
absence
of any poor performance
indications during the November
1993
exercise,
this item is closed.
(CLOSED)
URI 50-244/93-18-01:
During the November
1993 exercise,
an area for potential
improvement
was
identified regarding the formation of a repair team to restore
power to
a valve so that
a leaking pipe in the auxiliary building could be
secured.
Specifically,
due to the high radiation level
and iodine
concentration
in the vicinity of the motor control center
(60 rem
general, area),
the health physics/chemistry
manager
recommended
an air
.
fed respirator for personnel
radiation protection.
The available
electrical
maintenance
personnel,
however,
were not respirator-
qualified.
Due to the need to restore
power to the valve
(HOV-851A),
the
Emergency Coordinator waived the respirator qualification
requirement'.
1
During this inspection,
the inspectors
reviewed the licensee's
corrective action to this issue.
The licensee
issued
a memorandum to
all
ERO personnel.
It provides
management's
policy of having sufficient
personnel
who are respirator qualified.
Furthermore, it specified the
type of respirator for which
ERO groups,
such
as
damage repair teams
and
survey teams,
are to be qualified.
The licensee
reviews individual
respirator qualifications
on
a monthly basis
when the General
Employee
Training qualifications are reviewed.
The inspectors
sampled
several
ERO members that could be required to wear
a respirator
and found that
they were qualified for their specified respirator
equipment.
Therefore,
based
upon the licensee's
policy and the verification that
ERO members
are properly qualified, this item is closed.
8.2
(UPDATE) URI 50-244/93-18-02:
During the November
1993 exercise,
an area for potential
improvement
was
noted regarding
a failure to issue
a timely protective action
recommendation
(PAR).
When
a
GE is declared,
a
PAR is to be issued with
the 15-minute notification.
The licensee's
notification form lists four
choices for PARs:
1) There is no need for protective actions outside the
site boundary,
2)
Need for protective action is under evaluation,
3)
Sheltering
recommended,
and 4) Evacuation
recommended.
During the
exercise,
the
GE was declared
at approximately
10: 15 a.m.
At 10:25
a.m.,
the licensee
issued
the
- "Need for protective action is
under evaluation."
The licensee
was prepared
to issue
a
PAR based
on
plant conditions at the time of the
GE declaration,
however, prior to
making the offsite notifications, plant conditions
changed
such that the
PAR also changed,
The licensee
took time to evaluate
the latest plant
and radiological conditions to make the appropriate
PAR,
and correctly
issued
the
PAR to shelter at 10:55 a.m.
This was
40 minutes after the
GE had
been declared
and did not meet the
15 minute goal.
During this inspection,
the inspector determined that the licensee
deleted
"Need for protective action is under evaluation"
as
a
option.
This removes the implication that
PAR issuance
can
be delayed.
Also, the inspector
reviewed requalification training lesson
plans
and
confirmed that the objective of issuing
a
PAR within 15 minute of the
declaration
was emphasized
to potential
decision-makers.
However,
due
to the potential public impact of delaying
a
PAR, this issue will remain
open pending timely and accurate
PAR issuance
by the licensee
during
an
NRC evaluated
exercise.
9.0
Listing of Document
Change
Reviews
As discussed
in Section 2.0 of this report, the inspectors
reviewed
recent
changes
to the Ginna Nuclear
Emergency
Response
Plan Implementing
Procedures
(EPIPs) to determine if any of these
changes
decreased
the
effectiveness
of the procedures.
The following revisions
were reviewed:
Revision
s
1-0
1-5
1-6
1-11
1-12
1-14
1-15
2-1
2-2
2-4
2-5
2-6
2-8
2-10
2-11
2-12
2-13
2-14
2-18
3-3
3-6
3-.7
4-1
4-2
4-3
15,
16,
17,
& 18
16,
17,
& 18
5
8
2
6
7
10
& 11
5
6
24&5
3
2
35&6
4
44&5
2
14
& 15
4
& 5
3
5
4
4-5
4-6
4-7
5-1
5-2
5-3
5-4
5-5
5-6
5-7
5-10
10
2
7
4
6
8. 7
8, 9,
10 5 ll
10
& 11
5
2ll
25,3
No degradations
in procedure effectiveness
were. identified.
10.0
Exit Meeting
The inspectors
met with the licensee
personnel
identified in Section
1.0
at the conclusion of the inspection to discuss
the inspection
scope
and
findings.
The inspectors
highlighted the items in Sections
2'.0 through
9.0 of this report,
and provided
a summary evaluation of the
EP program.
The licensee
acknowledged
the findings and commitments
made during the
inspection
as stated
by the'nspectors.