ML17285A172

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Insp Rept 50-397/88-42 on 881205-09.No Violations Noted. Major Areas Inspected:Followup on Three Open Items, Operational Status of Emergency Preparedness Program & Independent Insp Review of Response to Three Recent Events
ML17285A172
Person / Time
Site: Columbia 
Issue date: 12/29/1988
From: Brown G, Fish R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML17285A170 List:
References
50-397-88-42, NUDOCS 8901180310
Download: ML17285A172 (7)


See also: IR 05000397/1988042

Text

U.

S.

NUCLEAR REGULATORY COMMISSION

REGION V .

Report

No.

License

No.

Licensee:

50-397/88-42

NPF-21

Washington Public Power Supply System

P.O.

Box 968

3000 George Mashington

May

Richland,

Washington

99352

Facility Name:

Inspection at:

Washington Nuclear Project

No.

2 (WNP-2)

WNP-2 Site,

Benton County, Washington-

Inspection

conducted:

Inspector:

Approved by:

December 5-9,

1988

'o< G.

A. Brown,

Emergency 'Preparedness

Analyst

pii'.2 ~ ~

~~

R.

F. Fish, Chief

Emergency

Preparedness

Section

Date Signed

Date Signed

~Summau

This was

an unannounced

inspection in the areas

of followup on three

open

items

identified during previous inspections,

operational

status of the emergency

preparedness

program

(procedures, facilities, organization

and management

control,

and training),

and

an independent

inspection

review of the licensee's

response

to three recent events.

"Inspection procedures

92701,

82701 and 92700

were used.

Results

No deficiencies

or violations of NRC requirements

were identified.

In general

the inspector

found strengths

in the positive attitude

and motivation of the

reorganized

emergency

preparedness

(EP) staff (see Section 3.a),

and Supply

System management's

capability to respond to internally-identified problems

(see Section 3.c)..'RC concerns

were in the quality assurance

oversight of

the

EP program (see Section 3.c), the

EP staff's capability for root cause

analysis,

and the reliability of the primary notification system

(see Section

3.d)

DETAILS

Persons

Contacted

WNP"2 Personnel:

  • G. Bouchey, Director Licensing and Assurance

"R. Chitwood,

Manager

Emergency Planning

Y. Derrer, Principal Training Specialist

L. Garvin, Manager,

Programs

and Audits

"J. Houchins,

Emergency

Planner

W. Jensen,

Corporate

Records

Manager

D. Kerlee, Principal

gA Engineer-

  • A. Klaus, Senior

Emergency

Planner

J.

Landon, Consultant,

Scenario

Development,

WNP-2

"R. Mogle, Senior

Emergency

Planner

M. Monopoly, Manager Support Services

  • R. Romanelli,

Senior

Information Officer

"V. Shockley,

Consultant,

Scenario

Development,

WNP-2

  • G. Sorensen,

Manager Regulatory

Programs

-"C. Voss,

Manager Telecommunications

  • D. Werlau, Technical Training

Others:

  • P. Grady, Bonneville Power Association

"W. Kiel, Licensing, Washington State

Liaison

D.

Sommers,

Director Benton County Department of Emergency

Management

K. Vails, Physicians Assistant,

Hanford Environmental

Health

Foundation

M. Wiggins, Director. Franklin County Department of Emergency

Management

"Indicates

those in attendance

at the

December

9,

1988 exit

interview

Follow"u

on Previous

Ins ection Findin

s

Module 92701

0 en

0 en Item 88-25-02:

Need to clarify phrase

"inadequate

control of

plant" found in, Attachment A.C.2.c(3) of EPIP 13. l. 1.

The licensee

has

proposed

a procedure revision that includes

a definition of "inadequate

control of plant" as follows: "any event compromising the functions of

safety systems

needed for the protection of the public". 'his proposed

revision is awaiting approval

by the Plant Operating

Committee

(POC)

~

Progress

on this concern is satisfactory;

however, this item will remain

open pending implementation of the revision.

0 en

0 en Item 88-25-03:

Licensee's

EPIPs

make

no distinction between

initial classification

and reclassification notifications.

The licensee

is proposing

a revision to EPIP 13.4.1 to include

a provision that for

events

which require the maintaining of continuous

open line

communications with the

NRC, follow-up. notifications will be

made

immediately to

NRC in accordance

with provisions of 10 CFR 50.72(c)(l).

Follow-up notifications for other events will be

made immediately after

notification of appropriate

State

and local agencies.

This proposed

revision will be submitted to the

POC at the next regularly scheduled

meeting.

Progress

on this concern is satisfactory;

ho'wever, this item

will remain

open pending implementation of the revision.

0 en

0 en Item 88-25-04:

Procedures

don't provide adequate

guidance

for declaration of an Alert for loss of most or all control

room

annunciators.

The licensee is proposing

a revision to EPIP 13. 1. 1 to

include the declaration of an Alert upon the failure

of control

room

panels

P601,

P602,

and

P603 (which includes

most of the critical

annunciators).

This proposed revision is awaiting approval

by the

POC.

Progress

on this concern is satisfactory;

however, this item will remain

open pending implementation of the revision.

3.

0 erational

Status of the

Emer enc

Pre aredness

Pro

ram

Module

82701

Chan

es to the

Emer enc

Pre aredness

Pro

ram

The inspector reviewed this program area to determine if any changes

to the emergency

preparedness

(EP) program

had decreased

the overall

state of emergency

preparedness.

Changes

to the organization

and

management

control of the

EP program were reviewed during this

inspection.

At the time of the inspection the licensee

was undergoing

a major

EP

staff reorganization

which had not been

completed at the conclusion

of the inspection.

Actions that

had been completed;

however,

included:

1)

Detaching the Emergency

Preparedness

group from the

Environmental

Programs

group and. assigning

separate

managers

to

each.

This was

done in an attempt to allow the manager

more

time for EP-related

matters.

2)

Creation of an internal

EP exercise

scenario

development

group

with the sole responsibility of developing challenging

scenarios

for drills and exercises.

An experienced

licensed

operator,

a health physicist,

and senior emergency

planners

are

included in the staffing of this group.

3)

Creation of an offsite liaison section to deal with

offsite-related matters.

A full-time emergency

planner will

staff this section.

Support from other

EP groups will be

provided as necessary.

4)

Transfer of EP-related training responsibilities

from the

Supply System Training Department to the

EP Department.

A

principal training specialist with experience

in EP training

will staff this position.

The Supply System Training

Department will provide logistical support.

During interviews with EP staff members affected

by these

changes

the inspector

noted

a high degree of enthusiasm

and motivation.

They seemed

capable

and anxious to contribute to the challenges

of

the

new jobs.

EP management

appeared

supportive of their efforts.

While it is too soon to evaluate

the effect of these

changes

on the

EP program, it appears likely that they will enhance its

'ffectiveness.

~Trainin

The training program was reviewed to determine if the requirements

of 10 CFR 50.47(b)(15)

and

10 CFR 50, Appendix E, Item IV.F were

being met.

Discussions

with the

EP training specialist

and

a review

of the training records

indicated that the training for Supply

System

emergency

response

personnel

was

100K current

and that the

training included the latest

changes

to the

EP program,

The training provided appears

effective with respect to meeting the

safety objectives of the program.

Inde endent

Reviews/Audits

This program area

was

examined to determine

compliance with NRC

requirements

for an annual

independent

review of the

EP program

and

whether licensee

commitments and'corrective

actions

were implemented

in a timely manner.

. The inspector interviewed the Director of Licensing and Assurance

and reviewed guality Assurance

(gA) Audit No.88-425 (a report of

the annual

gA audit of the emergency

program conducted July 18-22,

1988).

The inspector

noted that, while the audit team members

were

qualified principal

gA auditors,

none possessed

EP expertise.

In

addition, with one. exception the scope

and depth of the audit

appeared

cursory.

For instance

the scope

included organization,

training and drills, State

and local agency interface,

and control

of FSARs.

Little attention

was devoted to such areas

in the

EP

program

as detection

and classification of emergency

events,

protec-

tive action decisionmaking,

dose calculations

and assessment,

public

information, communications,

and staffing augmentation capabilities.

Representative

findings included:

there

was

no established

procedures

to cover processing,

management,

and approval of Corrective Action Records

(CARs)

EP personnel

informally stored

documents

rather than utilized

central files.

there

was

no standard for EP in the Functional

Manual for

Nuclear Operations.

The main emphasis

of, the audit seemed

to be slanted

more toward

procedural

than programatic

and managerial

assessments.

The areas

of scope,

depth,

and audit team composition requires further review

and evaluation

and is considered

to be

an open item and will be

identifie'd as

Open Item 88-42-01.

Once

a deficiency is identifi,ed by its internal organizations,

the

Supply System

management

appears willing and capable of taking firm

and positive steps

to correct it.

For instance,

plant and corporate

gA surveillances

identified numerous

problems in the administrative

controls for amendments

to the Final Safety Analysis'eport

(FSAR).

The

FSAR is the base

document for 10 CFR 50.59 (changes,

tests

and

experiments)

evaluations,

and is

a required

document for the

Emergency Operations Facility (EOF), the Technical

Support Center

(TSC),

and the Control

Room.

These suryeil,lances

and audits

identified a total of 43 discrepancies

in three sets of FSARs.

As a

result,

the Programs

and Audits Manager issued

a Request for

Management Action.

In response,

Supply System

management

required

immediate updating of the.FSAR,

conducting

a higher level independent

review (Licensing

Engineer) of the next

FSAR amendment,

increasing the frequency of FSAR surveillance,

establishing

a,program to review and verify specific

FSAR

sections

by combination of plant walkdowns,

Lead Technical

Review meetings,

and interviews with those

using the system,

and

making appropriate staffing adjustments

to improve the

management

control of FSAR amendments.

The gA program is effective with respect

to meeting the safety

objectives of the program.

4.

Inde endent

Ins ection

Module 92700)

The inspector

reviewed the licensee's

response

to three recent

Unusual

Event declarations.

The first event occurred

on May 12,

1988 (resin

spill in Radwaste Building), the second

on August 24; 1988 (unidentified

leak rate greater

than technical specification limits), and the third on

November 21,

1988 (reactor

shutdown required

by technical specifications).

During the review, Franklin and Benton County Department of Emergency

Management

representatives

were contacted,

Control

Room logs reviewed,

and records of monthly communication tests

examined.

It was noted that the licensee's

investigation of the August 24th event.

included

a statement

by the shift, manager that

he was unable to notify

the local offsite agencies within the required time because

he was

detained

by discussions

with the

NRC.

The shift manager also stated that

he was unable to use the

CRASH (primary notification) system

on this

occasion.

While the licensee's

investigation did identify the untimely notification

problem, it failed to address

either of the following issues:

Why did the shift manager notify the

NRC first instead of the local

agencies

as required?

Was it because

of procedure

inadequacy,

deliberate

ignoring of the procedure

requirements,

or a training

inadequacy?

What was the problem with the

CRASH notification system?

Was it

system failure, operator error, or a training deficiency?

This inability of the

EP Department to demonstrate

root cause analysis

capabilities

requires further review and evaluation

and is considered

to

be an open item.

This item will be tracked

as

Open Item 88-42-02.

A review of the records 'of the monthly communication tests

revealed

that the

CRASH system

had failed four monthly tests

during the previous

18-month period,

and, in addition,

was inoperable during two actual

emergency

events.

The licensee's

resolution of the reliability of this

primary communications

system requires further review and evaluation

and

is considered

to be

an open item.

This item will be tracked

as

Open Item

88-42-03.

Exit Interview

An exit interview was held on December

9, 1988 with licensee

repre'sentatives.

Attendees of this interview are identified in Section

1

of this report.

The licensee

was advised that

no violations or

deviations

were identified during this inspection,

but that three

concerns

were identified as

open items.

Also discussed

during this

interview were other items

and observations

described

in Section

3 of

this report.