ML18100A431
| ML18100A431 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 06/23/1993 |
| From: | Craig Gordon, Mccabe E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18100A430 | List: |
| References | |
| 50-272-93-13, 50-311-93-13, 50-354-93-09, 50-354-93-9, NUDOCS 9306300074 | |
| Download: ML18100A431 (9) | |
See also: IR 05000272/1993013
Text
Docket/Report Nos:
License No:
Licensee: *
~acility Name:
Inspection At:
U. S. NUCLEAR REGULATORY COMMISSION
REGION I
50-272/93-13: 50-311/93-13: 50-354/93-09
Public Service Electric and Gas Company
Artificial.Island (Salem and Hope Creek Generating Stations)
Lower Alloways Creek and Salem. New.Jersey
Inspection Conducted:
Inspectors:
Approved By:
Craig Z
ordon, Senior Emergency
Preparedness Specialist, DRSS
Richard K. Miller, Consultant, Sonalysts, Inc.
Ebe C. McCabe, Chief, Emergency
Preparedness Section, FRSSB, DRSS
EMERGENCY PREPAREDNESS (EP) INSPECTION SCOPE
Announced safety inspection of the EP program, including program cha.Iiges; emergency
facilities, equipment, instrumentation; and supplies; orgaliization and management control;
emergency response organiz.ation (ERO) training, including shift crew performance during walk-
through scenarios; and inspection of independent program audits. Inspection findings were based
on inspector observations, interviews of licensee personnel, and review of selected records.
RESULTS
The EP program. was found to be generally well implemented. Emergency response facilities
.
.
and equipment were operationally ready. Management support* of EP was evident. Emergency
Response Organiz.ation (ERO) training and independent program audits were complete and
thorough. Training program implementation was generally good, but procedure and training
concerns were identified during walk-through, table-top drills with operating crews. Also, a*
concern about the licensee's practice of not declaring and ieporting terminated emergencies was
identified.
930623 ~
930630007 4 05000272.:
- ADOCK
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TABLE OF CONTENTS
Persons Contacted . . . .. . . . . . . . -. . . . . . . . . . . . . . . . . . . _. . . . . ; . . . 3
Non-Declaration of Terminated Emergencies .................
- ~ . . . . .
3
-Emergency Preparedness Program Changes . . . . . . . . . . . . . . . . . . . . . . . .
4
Emergency Facilities, Equipment; Instrumentation and Supplies
. . . : . . . ._ . . .
5
_ Organization and Management Control * . . . . . . . . ; . . . . . . . . . . . -. -. . . . . 5
Knowledge and .Performance of Duties (Training) . . : . . . . . . . . . . . . . . . . .
6
6.1
Table-Top; Walk-Through Drills .......................... - 7
7.
Independent and Internal Reviews and Audits . . . . . . . . . . . . . . . . . . . . . . .
9
8.
-Exit Meeting .- . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
DETAILS
1.
Persons Contacted
The following individuals were contacted.
- C. Banner, Administrator, Nuclear EP Programs/Response
- D. Burgin, Administrator, Nuclear Offsite EP *
- T. Di Guiseppi, Emergency Preparedness Manager
- M. Dior, Shift Supervisor
- C. Fenton, Auditor, Quality Assurance Programs
- J. Hagan, Vice President, Nuclear Operations
- J. Johnson, Emergency Planner
- S. Jones, EP Instructor
S. La Bruna, Vice President, Nuclear Engineering
S. Miltenberger, Vice President and Chief Nuclear Officer
- C. Munzenmaier, Manager, Nuclear Services
- P. O'Donnell, Operations
R. Reece, Emergency Planner
L. Reiter, Director, Program Improvement
- J. Schaffer, EP Supervisor
- W. W eckstein, EP Training Administrator
- J. Wray, Radiation Protection Engineer
- Attended exit meeting on April 23, 1993.
2. .
Non-Declaration of Terminated Emergencies
The most significant concern about. the EP program since the last EP program inspection was
the Event Classification Guide (ECG) provisions that became apparent after the December 1992.
loss of overhead* annunciator system in the Salem Unit 2 control room. During that event,.
- .operators promptly restored the. system upon discovery, and the need for emergency
augmentation of the on-shift staff was thereby eliminated. An NRC Augmented Inspection Team
found that plant conditions existed for an Alert declaration prior to recognition, but no
emergency classification or declaration was made, nor was there timely notification of the
existence of the emergency condition to the States of New Jersey and Delaware or to the NRC.
In this case, the prescribed emergency classification was an Alert for a loss of annunciators. *
Since, from a safety viewpoint, that loss of annunciators did not have the safety significance of
an Alert, that specific non-declaration was not of safety importance. In the general case,
however, non-declaration of terminated emergencies .does not appear to meet the NRC and
FEMA guidance contained in the "Class Description" sections of Appendix 1 to NUREG-
0654/FEMA-REP-l.
The specific guidance involved is the first sentence of the Class
Description for each of the four emergency levels. That sentence specifies that the events "are
in progress* or have occurred."
-*
4
- The licensee indicated that non-declaration of a terminated emergency was appropriate because _
declaration of an Alert or higher condition requires a staff augmentation response. NRC review
_ noted, however, that the NRC has found prompt -declaration and reporting of terminated
emergencies without requiring the staff augmentation prescribed forongoing emergencies to be
acceptable. In such a case, for example, a licensee can deelare an "Alert-Terminated" (if so*
specified in their plan and procedures) and make the associated reports without automatic call:.out
of the Emergency Response Organization (ERO). NRC review also identified the following
reasons for declaring terminated emergencies.
Emergency declaration and reporting provides a timely trigger for licensee senior
management, State and local, and NRC _assessment of -event significance, of the
appropriateness of the licensee's action, and of the need for further follow*-up.
Declai:ation and reporting of an emergency results In its inclusion in industry and NRC
records of emergency conditions, and in associated assessments of the safety import of
the emergency conditions which occur at nuclear power p_lants.
_ *
Failure to declare and report emergency conditions could lead to_ non-identification of
licensee inability to accomplish timely identification of defined emergency conditions.
Irt this case_, the licensee revised their Emergency Classification Guide to specify one-hour
notification of the NRC and State when-a major loss of assessment capability riot exceeding an _
emergency action level was determined to occur.
That does not fully address the above
c_oncerns. Therefore, this item is unresolved pending licensee submittal of the safety justification
of not declaring and reporting terminated emergencies, and further NRC review of the safety
significance of declaration of terminated emergencies. (UNR 50-272/93-13-01; 50-311/93-13-
01; and 50-354/93-09-01).
3.
Emergency Preparedness Program Changes
A major change in the EP program since the last inspection was an upgraded notification system
development and implementation for contacting ERO personnel. In addition fo the capability_
for prompt, around-the-clock notification of large groups of licensee staff during emergencies,
system improvements included a feature to interact with notified personnel, and another which
provides progressive, computer-generated staffing reports in the Technical Support Centers and
the Emergency Operations Facility. The inspector observed a test of the new system and noted
that it functioned as the licensee stated.
--
Other program changes were reviewed and discussed with the EPC, including Emergency Plan
and Emergency Plan Implementing Procedure (EPIP) revisions. At the time of the inspection,*
the annually required Emergency Plan review was overdue, but close to completion. _Section
10 of the Plan was revised to add the hardened torus vent as a release pathway for Hope Creek.
The change received an adequate peer safety review, but was not reviewed against 10CFR50.59
criteria because the revision did not involve a change to the facility or procedures as described
5
. in the Safety Analysis Report (SAR). * Review of information contained in Memoranda of
Understanding (MOU) with New Jersey and Delaware indicated that MOUs cover only the
notifieation means without describing . how the respective State Emergency . Plans will be
. implemented. The licensee committed to reviewing each MOU and provide additional detail on
the expected level of response from State organizations. No other significant changes in EPIP
content were noted.
The Manager, EP aiso provided information about planned and ongoing program changes.
These entailed an upgrade to the site-wide accountability system (scheduled for implementation
in November 1993), hardware and software improvements for the siren Alert and Notification
System, and implementation of performance-based training using the Salem and Hope Creek
simulators for all members of shift crews.
These will be reviewed after changes are
implemented.
Based upon the above review, this area was adequately implemented.
4.
Emergency Facilities, Equipment, Instrumentation and Supplies-*
Inspection of the Hope Creek Control Room, Hope Creek Technical Support Center (TSC), and
Hope Creek Operations Support Center (OSC), indicated that facilities were in a good state of
operational readiness.
Emergency response facilities (ERFs) were adequate to support
emergency response and were in agreement with information specified in the Emergency Plan.
The Emergency Operations Facility and Salem ERFs were not inspected; these will be evaluated
during the June 1993 annual exercise.
The inspector examined a sample of designated
equipment and supplies (downwind survey kits, control room breathing air system) and noted
that surveillances of equipment were performed at the prescribed frequencies, instrumentation
was calibrated as required, and equipment and instruments were operable. One concern was
identified. Portable respirators were found to be located away from designated lockers inside
the radiation control area (RCA).
The licensee should review possible consolidation of.
respirators and other designated emergency equipment and supplies in secured lockers outside
the RCA.
Communications equipment including telephones, public address system, and portable* radios
were inspected in the above facilities and were consistent with EPIPs.
Based upon the above review,* this area was effectively implemented.
5.
Organization and Management Control
The inspector interviewed the Vice President and Chief Nuclear Officer, Vice President, Nuclear
Engineering, Vice President Nuclear Operations, and Director, Process Improvement to discuss
their involvement in the program._ Management support for EP was clear; each individual
provided good awareness of EP program details. These senior licensee staff members stated that
they meet both formally and *informally with the Manager, EP to obtain updates on the status
-
6
of on..:.site and off-site program activities.
On occasion they also meet with New Jersey,
Delaware, local officials, and local support groups to discuss items of mutual interest regarding
off-site emergency preparedness.
In addition, senior staff were qualified in upper level
.emergency response organization (ERO) positions.
Based _upon discussions with licensee staff, examination of site facilities and records, Emergency
Plan and Emergency Plan Implementing Procedures (EPIP) upkeep, surveillance of designated
emergency equipment, supplies and facilities, coordination of drills and exercises, interface with
State and local *authorities, and administration of technical EP functions were adequately
maintained in accordance with applicabie EP Administrative Procedures. The EP program staff,
led by the EP Manager and four Admfo.istrators provided .excellent support to effectively carry
out these functions.
The Emergency Response Organization (ERO) was thoroughly defined in the Emergency Plan
with at least three qualified individuals in key ERO positions.
ERF management performance will be evaluated by an NRC inspection team during the June
1993 partial-participation exercise.
Based upon the above review, this area program area was well implemented.
6.
Knowledge and Perf onnance of Duties (Training)
The inspectors reviewed EP training lesson plans, examinations, qualification records maintained
via database, historical training records, and interviewed the EP instructors. Most EP training
was provided by EP Department staff.
Inspector review. found no- system to ensure that the EP training computer generated an up-to- .
date ERO personnel qualifications list/data base. Since this "qualified" data base was used for
loading the ERO personnel data base into the pager computer for ERO personnel call-out, a
poteritial for unqualified personnel being loaded into the pager computer exists.
The computer had to be manually instructed by. an operator to generate a revised ERO
qualification list/data base.
That function was performed by the Administrator of Offsite
Emergency Preparedness. The Administrator stated that he typically updated the "qualified" data
base weekly. Training was entered into the EP training computer by the course instructor and
was not verified prior to entry. The data base of qualified ERO personnel was based on these
entries. It was foun,<l that entry errors resulted in incorrectly recording that four ERO personnel
had attended classes and passed a written test, when in fact, these individuals had "tested-out"
by taking a written test, i.e, without attending the classroom instruction. The recorded errors
demonstrated that entry errors could result in placing unqualified ERO personnel in the call-out
data base of the pager computer .
7
6.1
. Table-Top, Walk-Through Drills
Table-top,walk-through drills were performed with four (4) shift crews (two Salem scenarios and
two Hope Creek .scenarios were used). The EP training staff was involved in the development
and review of th~ scenarios. EP staff and the operating crews exhibited a positive attitude
toward emergency preparedness.
Overall, crews worked well as teams during the walk-throughs .. Several errors. by individual
crew members during the scenarios were identified and corrected by other members of the crew.
However, during the walk-through, table-top drills, two crews had difficulty in determining that
the containment boundary was bypassed when a LOCA to the Auxiliary Building existed. That *
resulted in the identification of apparent weakm~sses in making emergency classifications, in.
making P ARs, in training,. and in procedural guidance. Specific observations were:
. Non-recognition of the loss of the containment boundary resulted in initial PARs less
conservative than those specified by Emergency Classification Guide (ECG) Attachment
4 (General Emergency).
In one case, however, the Nuclear Shift Supervisor/Shift
Technical Advisor (NSS/STA) later identified the Senior Nuclear Shift Supervisor's
(SNSS) {Acting Emergency Coordinator (EC)} error and recommended a correcting
change to the PAR.
Failure to recognize that the containment boundary was not functioning also resulted in
a different classification than was specified for the hypothesized event in the ECGs.
The difficulty in analyzing the integrity of the containment boundary by these two crews
indicated a rieed for additional operator training in determining . whether or not the
containment boundary was capable of performing its intended function.*
Review of the Salem ECGs i,ndicated that the Sal~ni ECG for fission product boundary
failures (Section 6. C) does not clearly address the containment boundary. For example,
EAL 6.C.2 addresses a similar condition that defines the bypassing of containment as an
unisolable faulted steam generator with a break outside of containment concurrent with
a primary-to-secondary leak. However, no guidance with this level of specificity could
be found for a LOCA outside of containment;
One crew *made a PAR upgrade, when analyzing the projected offsite dose rate, that
- resulted in recommending a less protective PAR than was specified in EPIP-105. With
the lack of identification of the loss of the containment boundary, this prevented the crew
from reaching the prescribed PAR, even when using both the operational and dose
assessment PAR procedures (ECG Attachment 4, EPIP-105, and EPIP 301).
.
.
Two crews did not recommend evacuation of the appropriate downwind sectors .when the
wind was coming from a direetion that bordered two sectors.
That resulted in the
recommendation of a less protective PAR than was pres<;ribed and was not consistent
8
- with the EP training the crews had received. The NSS/STA on one of the crews caught
the SNSS.'s error, resulting in the correction of the downwind sectors to be evacuated on
the PAR upgrade. In additfon, the SNSS on the other crew recognized and corrected his
own error during his follow-up explanation of his emergency classification and PAR after
the close of the scenario.
The crews exhibited some difficulty in making PAR upgrades utilizing EPIP 105
Appendix 3 and EPIP 301 Attachment 7. For example, during one of the scenarios, a
SNSS -asJced the Shift Radiation Protection Technician (SRPT) how the SRPT had
determined the distance to which he should evacuate and what the term ... evacuate" m~t
on the PAR Table of EPIP 105 Appendix 3, page 6. Post-scenario discussions with crew
- members indicated a need for additi<;mal training on the determination of a PAR upgrade
and the use of EPIP 105, PAR Guidelines, and of EPIP 301, Radiation Protection
Technician Onshift Response.
_The crews generally found it difficult to complete portions of the NRC data sheet on
radiological release information.
When asked to complete a NRC Data Sheet for
transmission, numerous blanks were left without any indication as to what information
the communicator should provide to the NRC *Headquarters Operations Officer. The
SNSS was significantly involved in the completion of the data form because of the
remaining crew members unfamiliarity with the completion of the data sheet, which could
significantly distract hi_m from his primary duties as EC during accident mitigation. _
During the walk-throughs, the following procedure adequacy concerns were identified.
The PAR Tables provided in Appendix 3 of EPIP 105(S&H), PAR Guidelines, and
At.tachment 7 of EPIP 30l(S&H), Radiation Protection Technician Onshift Response, do
not provide specific guidance as to the sectors or distances for which evacuation or
sheltering should occur when determining PARs based on actual or projected offsite dose
rates. This contributed to crew difficulty in determining PARs (item 4 above).
The procedures appeared to be cumbersome and confusing for most of the crews. Even
the SRPT who was well-versed in the PAR Table had difficulty recording and relating
the projected off-site dosage rates to the PAR Table "action" values. The PAR Table in
these EPIPs did not have a worksheet aid or sign-off checklist, and was one of the few
Artificial Island EPlPs without-an appropriate aid for such an activity.
After the walk-through drills were completed, the inspectors met with EP instructors to discuss
observations. The licensee staff committed to address the NRC concerns through improvements
in the EP training program and procedure revision, where appropriate. These matters will be
further reviewed by the NRC after licensee assessment.
9
7.
Independent and Internal Reviews and Audits
Quality assurance reviews of the entire EP program were conducted independently each year by
the QA Program Department staff. The 1992 audit was performed by a senior staff engineer.
In addition, the site Audit Department performed separate evaluations of selected drills and
exercises to supplement the annual reviews. The inspector reviewed the audit and surveillance
reports issued by each group, discussed audit conduct with the lead auditors.
Theinsp_ector determined that the 1992 -audit was sufficient to satisfy the requirements. of 10
CFR 50.54(t), identified areas requiring corrective action, and covered a review of off-site
interface with State and local authorities. The ATS (corrective action system) was in place and
used to track iteins to completion. Review of the reports indicated that activities of the EP
program_were conducted effectively since the previous audit. Only minor recommendations for
EP improvement were made. Audit and .surveillance reports provided good detail for potential
EP program enhancement. Audits and surveillance reports were distributed to senior plant
management. Following the inspection the licensee provided the 1993 audit report which had
been completed at the time of the inspection. Report findings were clear and no additional
concerns were identified with the exception of the site-wide accountability system. The EP staff
has been attentive to resolving items identified by in audits.
'
This program area was assessed as being well implemented.
8.
Exit Meeting
- The inspector met with licensee personnel denoted in Section 1 at the conclusion of the
inspection to discuss the scope and findings of this inspection as detailed in this report.
The licensee was informed that no violations were identified. Several areas where improvement
. seemed appropriate were discussed. The licensee acknowledged these findings and agreed to
evaluate them and institute corrective/improvement actions, if appropriate.