ML17292B333
| ML17292B333 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 04/13/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17292B332 | List: |
| References | |
| NUDOCS 9804210269 | |
| Download: ML17292B333 (8) | |
Text
ENCLOSURE
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<O OO rale OO O'M re c3 OA Ol roD 0 0 Cl ItBalltQ The NRC conducted an inspection January 19 through March 1, 'f997, at the Washington Nudear Project-2 (WNP.-2) facility. As a result of this inspection, the NRC identified three vfofations of NRC requirements (NRC Inspection Report 60-397/9743 and Notice ofViolation, March 28, 1997) induding a violation related to the use ofchemistry technidans {CTs) as on-.
shift heafth physics technicians (HPTs) to meet the staffing commitments ofthe WNP-2 emergency plan.
Washington Public Powe'r Supply System (WPPSS) responded to the Notice of Viofation by fetter dated April28, 1997, indicating that the limited health physics tasks to be performed in the first 60 minutes of an acddent allowed forthe use of CTs provided their training and experience were adequate.
WPPSS also indicated that Revision 19 ofthe WNP-2 emergency plan submitted on April3, 1997, clarifie the use and tralnfng of CTs to perform health physics tasks in an early phase ofan accident.
By memorandum dated June 26, 1897 (TIA97%17), NRC Region IVrequested NRR review of WPPSS's position concerning this issue given it might constitute fn a decrease of emergency plan effectiveness and have generic application. Region IValso requested NRR's review of two changes that WPPSS fmplemented in Revisions 17 and 18 of its emergency plan: one related to the fdenQication ofthe alternate emergency operations facility(FOP) location, and another to the combination of the annual radiologfcal monitoring drillwith one of the semfannuaf health physics drills.
2.0 2.1 Minimum Staffing for Nuclear Power Pfant Emergendes Omhiftfacilitylicensee responsibilities forerriergency response are unambiguousfy defined, adequate staffing to provide initialfadfityaccident response in key functional areas fs
maintained at all times, timely augmentation ofresponse capabilities is available and interfaces between various on-site response activities and offslte support and response activities are spedfled.
1 47 Radiological emergency response training ls provided to those who may be called on to assist In an emergency.
FR The applicant's emergency plans shaH contain, but not necessarily be limited to, information needed to demonstrate compliance with the elements set forth below, i.e., organization for coping with radiation emergencies, assessment actions, activation ofemergency organization, notification procedures, emergency facTiities and equipment, training, rnalntainlng emergency preparedness, and recovety.
In addition, the emergency response plans submitted by an applicant for a nudear'power reactor operating license'shaH contain information needed to demonstrate compliance with the standards described in 50A7(b), and they willbe evaluated against those standards.
F 0
The organization for coping with radiological ernergendes shall be described, induding definition of authorities, and duties ofindividuals assigned to the licensee's emergency organization and the means for notification of such individuals in the event of an emergency.
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rN w r The cnterla and recarnrnendations contained in Revision 1 of NUREG-0654IF EMA-REP-1 are considered by the NRC staff to be acceptable methods for complying with the standards in 10 CFR 50.47 that must be met in onsite and offsite emergency response plans.
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,, 5.
Each licensee shall specKy the positions or title and major tasks to be performed by the persons assigned to the funcUonal araas ofemergency activity. For emergency situations, specific assignments shall be made forall shifts and forplant staff members, both onsite and away from the site. These assignmants shaH cover the emergency functions fn Table 8-1 enNfed, "MinimumStatAng Requirements for Nudear Power Plant Emergencies."
The minimum on-shKt staffing levels shall be as Indicated in Table 8-1. The licensee must be able to augment on~ft capabilities within a short period after dedaration ofan emergency.
This capability.shall be as Indicated ln Table 8-1.
7.
Each licensee shall specify the corporate management, administrative, and technical support personnel who witt augment the plant staff as specified in the table entitled "MinimumStaffing Requirements for Nudear Power Emergencies" {Table 8-1)...
Table 2, Minimum Staffing Requirements for NRG licensees for Nuclear Power Plant Emergencies (Note: Table 2 of Supplement 1 of NUREG4737 Is the same information contained in Table 8-1 of NUREG-0654). The requirements and guidance of Supplement 1 of NUREG4737 were provided to the Industty by Generic Letter 62-33. The generic letter states that the staffing levels contained in Table 2 are goals, and not strict requirements.
Analysis
'abte 8-1 of NUREG~54 provides staff guidance on minimum staffing for nuclear power plant emerg'ency response.
Inyarticutar, Table 8-1 caHs for three health physics technicians (HPT)
. positions on shift one for performing ingtant survey tasks, and two for~tant protective action tasks. Concerning the Ingiant protective action tasks, Table 8-1 tndicates that the two HPT positions "may be provided by shift personnel assigned other functions.
Table 8-1 atso provides for additional HPT responders tn 30 and 60 minutes to supplement the on-shift HPT staff.
Untit June 1996, per plant administrative procedures {PPM 1.3.1), the licensee required that three qualified HPTs be onwhiftwhite tn Operational Modes 1, 2 and 3 to fillthe three on-shift HPT emergency positions.
However, the emergency plan did not reflect this but instead showed one full-time position (for inytant surveys) and two shared4uty positions (for in-plant protective actions) in accordance wlithTabte B-1 of NUREG4654.
In June 1996, as part of Its downsizing efforts. the licensee changed the on-shift staffing requirements to only two qualified HPTs and permitted the on-ehiff CT to serve as the third HPT (IR 50-397/973).
In the January 19 through March 1, 1997 tnspectlon, the NRC found that (1) the CTs were assigned the responstblties ofthe emetgency response organization (ERO) onWiftHPTs but were not appropriately informed of thetr responsibilities, (2) the CTs had not
'ompleted the necessary training forthe ERO HPT position, and {3)the shift managers/emergency directors were not informed that CTs woutd be assuming the HPT fesponsl I
esponsibitities in the event ofan emergency.
Consequently, the NRC Issued a Notice of Yiotation. In a subsequent conference call, as documented In the inspection report, the NRC
{inctudtng Region IVand NRR) expressed concern that the licensee's proposed training dtd not appear adequate to prepare the non+IP quatified techntctans forthe emergency response organization (ERO) HPT position. Region fV, in lts assistance request, raised the Issue that the licensee's change in tts ERO stafling for the HPT position could represent a decrease in effectiveness ofthe emergency plan.
In a transmittal dated April3, 1997, the l(censee submitted Revision 19 of lts emergency plan.
Revision 19 has been revised to ctaitfy the fact that the two shared duty HPT positions are not required to be filled by futtkme HPTs and have been designated as HP support positions. The
l'ee also provided the NRC with an assessment of its minimum on-shift ERO staffing icensee a s t
purs ursuant to the requirements of 10 CFR 50.54(q) to demonstrate that the change d d no decrease the effectiveness ofthe pfan as prevfousfy approved.
ln its 50.54{q) analysis, the licensee indicated that there are currently two fuff-time HPTs
~ assigned to be on shift - one to filithe in-plant survey position and one to fillone ofthe two HP rt positions The remafnlng HP support position Is fdled by the on-shift CT. However, Revision 19 ofthe plan shows one full-time HPT position responsible for fn-p an surveys and two HP support shared4uty positions. The licensee notes that the use of a second fuff@me HPT on shift fs not required in Table B-1 of NUREG4654.
The licensee states that the use ofthe on~hfft CT to fiffone ofthe two HPT support positions is acceptable during the first60 minutes ofan accident based on the training CTs have received and continue to receive fn an ongoing refresher bash. This training basicaffy consists of radiation worker training and an HP support training course called "HP for Chemi try Technicians".
The radiation worker training fs general employee trainfng which provides basic f f tion on controlling and monitoring for contamination, personnel monitoring, a dosimetry as well as general work practices while ln a contaminated area. The HP upp n orma '
ort tra'd s additional HP training on how to operationally check and use a survey instrument, monitor forgeneral area dose rates, and perform a contact reading.
HP support training also addresses ALARAand contamination control techniques, and includes additional training on how to perform smear surveys, spiff response, and decontamination ofaffected areas.
B I tt d t d September 3 1997, the lfcensee fnformed the NRC that it had recently provided yeer ae fh CT lth dd tional training to supplement the radiation worker training and the ppo training previously described to enhance their capabilities to perform the expe e e cted HP duties during the first60 minutes of an emergency.
This new training entitled, Special Training Sessions Topfc: HP Support During Decfared Emergency forChemistry Technicians" has been th existi training course HP forChemistry Technfdans,'nd was completed on e NRC the June 10, 1997.
In a telephone conference held on December 9, 1997, with the NR, ficensee i ica a
nd'ed that alf CTs had received this supplemental training. The staff noted that although the new training was not devefoped using a formal Systems Approach g
to Tralnln
{SAT)as defined in 10 CFR 50.120 and 55.4, itwas developed foffov/ingits principles. The staff examined the corresponding training handout and found that it adequately addresses the tasks that CTs are expected to perform ln the first 60 minutes of an emergency in conformance with guidance provided ln Table 8-1 of NUREG-0654, namely access control,. HP coverage for response actions, personnel monitoring and dosimetry. The staff also noted that as part of this training, the CTs are made familiar In particular with the following HP, Administrative and Implementing procedures:
Plant Procedures Manual (PPM) 11.2,6.1, Issuance and Retrieval of Personnel Oosimetty, PPM GEN-RPP44, Entry fnto, Conduct in, and Exitfrom Radiologically Controlled Areas," PPM GEN~-11, Use ofthe Total Exposure System
{TES)'or Access Control," PPM 132.1, Emergency Exposure LevefslProtective Action Guides," PPM
..7B Em ency Maintenance."
Further, the licensee indicated ln the December 9 tefephone conference that refresher training for CTs to perform H ',
pa duties, in rticutar during emergencies, wi provi e II be
'd d on an annual basis.
The licensee also indicated that during ardin HP tasks.
outages CTs are given HPT duties, and thus gain practical experience regar ing Apart from the Justifications based on training ofthe CTs, the licensee provides in its 50.54(q) analysis the following rationale to Justify the use of CTs fn lieu of HPTs:
(1) The extensive use ofelectronic dosimeters at VNP-2 provides personnel worfang in the Ith both neral area doss rate reading as well as cumulative dose reading. These dosimeters have the capability to alarm ifthey detect radfation that exceed p
s reset limits.
(2) AIIpersonnel working in the power block receive training regarding high radiation areas and control ofthose areas.
This training enables them to understand how radiofogicaf controlled areas (RCA) boundaries are established as well as the meaning ofdifferent RCA ch th how to handle themselves fn regard to these conditions and how to provide access control to high radiation areas iflt becomes necessary.
{3) ln the early stage ofan emergency (first 60 minutes), health physics support Is only necessary to provide personnel working on repair and corrective actions with independent radiation monitoring information so that they can focus on their tasks. Ths ficensee indicated that such monitoring can be provkfed by the onwhlft CT.
As no ea
- ier, As ted rl'er ln addition to the mfnfmum an-shift staffing (10 total), Tabfe B-1 of NUREG-0654 lis for the capabity to augment the onwhtft staff ln 3(hainutes with an additional 11 res onders, ofwhich 6 are to be HPTs. Because of the remote focatlon ofthe site, e
a roved the licensee's request to eliminate the 30-minute rssponders at WNP-2 during NUREG%892 March 1982), The lack of30-minute rssponders Iicensin of ths plant (SER, reater e hasis on e capa ii
'h O'I'Iles and expertise of the on-shift staff to perform the sr en res nse functions until additional resources arrfve. To a certain exten,t b
f30 'te responders by assigning more than e has co snsated forthe absence o min e
B-1 ofNUREG4654 to the shift staff. The on-shift the minimum number shown in Table B-1 of ana s shows a minimum of 16 staffin table provided by the licensee ss part of its 50.54{q) analysis s a mini uafs assf ned on shift during Modes 1, 2 and 3, and 14 during Modes 4 and 5. The indi%du~assigns
"'N'd ati4 'HM"",abut%" 'Me number offull-time HPTs spscified fn Table 8-1 of number to two, one more than the minimum NUREG-0654. As noted earlier, the current additional HPT on shift Is a controlled and not required by the licensee's emergency plan.
'Th d
ofth tra i
'ded toth eml tasks, serves on ths fire brigade, and fs also expected to orm plant support HP functions as an additional duty.
s a equacy o onshmCTto fillNeHP su~n~MMisnot th ~
d d (2) 0't e'Hp'"p e workload ofthe on shift CT who is primanfy responsible l
td of ii hI e
tasksfntheeventofanemergency.
nasu yo other thin s that the radiation protection and chemfs~
staffing keels, the NRC found, among other things, technfdans have a hfgh workload during postulated accident scenarios 9&48, "Results of Shift Staffing Study, October 10, 1995).
In addition, the absence of30-minute responders at WNP-2 puts greater emphasis on the capabilities of the on shift HPTa to fuffiffthe essential emergency response functions shown in Table 8-1 of NUREG4654 until additional resources arrive.
Conclusion Based on the review of Revision 19 ofthe WNP-2 emergency plan and the licensee's related 50.54(q) analysis, the staff finds that there has been a reductfon fn the level of HPT expertfse on shift at WNP-2 end that the use of the onwhfft CT to filione of the HP support positions fs a furlher diminution in the level ofavailable ~hfftHPT expertise because ofthe CT"s workload in the event ofan emergency.
Therefore, the staff concludes that there has been a decrease ln effectiveness ofthe licensee's emergency response capability.
2.2 Alternate Emergency Operatfons Fadtfty Location Analysis ln a June 1983 letters the NRG. the licensee committed to modffy its emergency plan to designate its headquarters building at 3000 George Washington Vlay in Richland, Washington, as the alternate location for the emergency operations facility(EOF).
Itwas determined on September 27, 1996, during an NRG inspection at WNP-2, that the WNP-2 emergency plan (Revision 17) did not indicate any alternate EOF location. Following is inspection, the NRC issued a Notice of Deviation on October 25, 1996 (NRC Inspection Report 50-397/96-14 and Notice of Deviation).
The WNP-2 emergency'lan was subsequently rnodiTied to reflect the commitment regarding the alternate EOF. The staff has venffed that the latest revision of the WNP-2 emergency p an (Revision 19) includes an appropriate Indication ofthe alternate EQF.
Conclusion Based on the review ofWNP-2 emergency plan Revisions 18 and 19, the staff has determined that the licensee fulfilledits commitment to designate its headquarters building at 3000 George Washington Way In Richland, Washington, as the location for the alternate EOF, and thus consfders the Issue as dosed.
2 3 Rad(ological Monitoring Drilland Health Physics Qciffs-~
Analysis NURE&4654 Evaluation Criterion N.2.d, provides for annual radiological monitonng dnlfs I'h colfection and analysis of sample media (e.g., water, vegetati
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'on soll and afr), and Ifivoving 8
provisions for communications and record keeping. Criterion NZ.e(1) provides for semiannual health physics drills invotving response to and anatysls of, simulated etevated airborne and liquid samples and direct radiation measurements in the environment.
Based on a State ofWashington audit performed in 1996, NRC Region tV expressed a concern that the WNP-2 emergency plan might not meet the above crtterta. NOTE 3 ofTable 8-1, Required DrillElements, in Revision 17 ofthe emergency plan, had been changed to state, "
The performance of the annual Radiological drill Involving collection and anatysis offield samples may be used to satisfy the requirements forone of the semiannual Health Physics drills involving simulated elevated radiation levels.
The staff held a telephone call with the licensee on November 13, 1997. The licensee explained that the annual radiological monitoring drillis notused to replace one of the semiannual health physics drills as coukf be interpreted by reading NOTE 3 of Table 8-1 ofthe emergency plan.
ln order to avert such interpretation, the licensee committed to suppress Nate 3 ln the next revision of the plan. The ticensee later provided the staff with PPM 13.14.8, "Dntt and Exercise Program," which presents the WNP-2 dritt and exercise program. The procedure clearly indicates that the radiologicat monitonng driltis not u'sed to replace one ofthe semiannual health physics drills.
Conclusion Based on the information provided by the licensee concerning the radiological monitoring drill and the health physics drills, the staff concludes that fhe plan continues to meet the drill guidance provided in NUREG4654.
Principal Contributor. F. Kantor Date:
April 13, 3998
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