ML20012E159
| ML20012E159 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 02/08/1988 |
| From: | Seiberling R INSTITUTE OF NUCLEAR POWER OPERATIONS |
| To: | Kindley W INSTITUTE OF NUCLEAR POWER OPERATIONS |
| Shared Package | |
| ML19324G680 | List: |
| References | |
| NUDOCS 9003300145 | |
| Download: ML20012E159 (8) | |
Text
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Institute of Nuclear Power Operations o,,,
February 8, 1988 Memorandum g
W. R. Kindley C. E. Wells p,,,,,,a ny.
R. K. Seiberling C. C. Fuller n,..a.,.
suomt TRIP REPORT - SPECIAL ASSISTANCE S. F. Stoll V! SIT TO SEA 8 ROOK STATION y,,,,,,,,
1.
BACKGROUND AND PURPOSE A special assistance visit was made to Seabrook Station at Seabrook, New Hampshire, January 25 29, 1988, at the request of George S. Thomas, vice president, Nuclear Production, t
L Three people from INPO Emergency Preparedness were asked to participate in an audit of the Seabrook Emergency Preparedness and Public Affairs Division.
Steve Stoll, Colby Wells, and Cherie Fuller were provided.
Other members of the audit team included two technical specialists from Yankee Atomic, and two representatives of the Seabrook Quality Assurance Department.
II.
8ACKGROUND AND 0H-SITE ACTIVITIES An INP0 emergency preparedness evaluator, Colby Wells, had previously observed a drill of the Media Center on 12/1/87 and of the Emergency Operations Facility and Media Center during an evaluated exercise on 12/16/87.
This special assistance visit involved work'ing with the utility quality assurance staff in conducting an audit of the Emergency Preparedness and Public Affairs Division. The audit was performed under the guidelines of INPO 85 014, Generic Guidance for Emeraency Preoaredness Review.
Audit personnel'were subdivided into three working groups.
In no instance were INPO personnel solely responsible for team findings, but the scope of work assigned did require independent research and l
interviewing, leading to separate findings in some instances.
INPO personnel were asked to participate in review of the following program areas (as per INPO 85-014):
o Organization o
Emergency Plan / Procedures o
Training RECElv O
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o Drills / Exercises MAR - 7 19go PRODUCTION 9003300145 900315 PDR ADOCK 0500 3
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-TRIP REPORT o SPECIAL AS$1 STANCE visit TO SEABROOK STATION Page 2
-o Notification j
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Public Information
-l An entrance meeting was held on January 25, documents were reviewed and interviews were held throughout the week, and an exit meeting was conducted on January 29, 1988.
The following people attended the exit meeting on January 29:
i George S. Thomas, Vice President, Nuclear Production James MacDonald, Radiation Assessment Manager Neal A. Pillsbury. Independent Review Team Manager-Bruce-J. Mizzau, Emergency Plan Facility Engineer Jeff Crafts, Manager Projects & Performance Terry Harpster Director, Emergency Preparedness Patrick D. Casey, Supervisor of Drills and Exercises S. Joseph Ellis, Manager, Response / Implementation Jeff Warnock, Nuclear Quality Manager Peter J. Stroup, Director - Response & Implementation - New Hampshire Yankee Emergency Prnaredness Timothy.'A. Cotter, New Hampshire Yankee - Manager of Emergency Preparedness Theodore L. Wiebold, Nuclear Quality Auditor Cecelia F. Esposito, Nuclear Quality Group (audit team)
Frank W. Bean, Nuclear Quality Group (audit team)
Al Parker, Senior Quality Assurance Engineer (audit team)
-Thomas P. Fuller, Quality Assurance Department Senior Engineer (audit team)
Seabrook Station senior managers have not yet been fully apprised of the audit team's finding and recommendations, but were receptive to team
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overview comments made at the exit meeting.
Personnel contacted are listed in Attachment A.
III.
SUMMARY
This report addresses only those issues which resulted from INPO personnel observations and reviews.
Issues that were primarily identified by others on the team will be addressed in the internal audit team report.
The following significant recommendations were among those discussed:
o Adhere to approved Station policy on procedure modifications.
Revisions to onsite procedures are being accomplished through the use of an unapproved change control program, administered by the EP group outside of the normal process.
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W. R. Kindley
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TRIP REPORT'- SPECIAl. AS$15TANCE VISIT TO SEABROOK STATION Page-3 l
Ensure adequate coordination and control of smergency public l
o information and education activities.. Responsibility and 1
accountability for those activities have not been clearly assigned.
Changes to the program are being made without appropriate approvals.
Improve training on the emergency plan and supporting procedures o
a to ensure compliance with station training procedures.
Currently the emergency preparedness training programs are not being developed or implemented in accordance with the Station Training -
Manual Procedures.
o Provide records of raquired program activities.
Program documentation is not being adequately maintained.
IV.
DISCUSSION AND RECOMMENDATIONS FOR IMPROVEMENT A.
ORGANIZATION Strengthen overall direction and. management of emergency preparedness i
program. Develop responsibilities and authorities for each management, supervisory and professional position that are clearly defined and understood. The command hierarchy, reporting chains and working relationships are not' clearly defined or understood ame,g personnel involved with the program.
Responsibility for review and
't retrieval of documentation _is not clearly defined, resulting in the inability to retrieve information in a timely manner, l.- Several New Hampshire Yankee personnel interviewed did not know their complete assigned duties and responsibilities and indicated they had not_ever seen their position descriptions. They further indicated they were now performing duties which they stated were outside of their normal duties.
2.
Position descriptions are not available for all major positions outlined in the present organization chart.
Those position descriptions obtained had not been approved and in some cases two different position descriptions existed for the same position.
3.
There is no document, form, or system in place that describes all l
the duties and responsibilities of the Radiological Assessment L
Manager. This position has many duties and reviews assigned by procedures.
Interviews and follow ups on document reviews L
indicated several of these tasks were not being done or documented.
4.
While the plan and implementing procedures were readily available for review, additional related documents were not. Written verification of required quarterly reviews, position i
l descriptions, and other documentary evidence of mandatory program activities are not being adequately maintained.
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- w. R. Kineley TRIP REPORT C SPECIAL A5515fANCE.
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V!$1T TO SEABROOK $TATION Page 4 o
'B.. EMERGENCY PLAN / PROCEDURES Revise the Emergency Plan and emergency plan implementing procedures j
in accordance with approved station procedures to correct errors and conflicting information and ensure they accurately reflect current
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desired practices. The emergency plan in some instances is not consistent with the emergency plan implementing procedures and/or business as it is being conducted.
Some emergency plan responsibilities are not being carried out. Revisions to emergency plan implementing procedures are not being done in accordance with station procedure.
i 1.
A review of the letters of agreement found in the emergency plan, I
appendix 0, indicates five out of seven have not been reviewed and updated on an annual basis.
Section 11.3 indicates emergency public information has been distributed annually since 1986 den in fact it has never been distributed. Appendix G does not indicate the existence of emergency plan implementin ER 1.0 " Classification of Emergencies at Zero Power.g procedure Appendix E does not reflect changes to the public notification system.
2.
Revisions to on site procedures are being accomplished through the use of an unauthorized change control program, administered by the emergency preparedness group outside of the approved l
process.
Changes can be made and approved, training can be performed, and these procedures can be used for drills and/or exercises without having gone through the process outlined in ER 8.4 which includes final approval by the Vice President, Nuclear Operations.
Interviews and document reviews indicated that "short cuts" are being used to speed up even this process and user impacts are not being considered. No documentation exists for this unauthorized process.
C.
IRAINING F
Ensure emergency preparedness training complies with approved station training procedures. Many training department procedures are not being followed in the development or administration of the emergency preparedness training program.
1.
Emergency preparedness training programs do not currently comply with the requirements specified by procedure.
Procedure 2005 -
Training Records specifies that each individual is to have a training file, which contains documentation of all training received by that individual. Contrary to this procedure, emergency preparedness training records are filed by module number and date, and are not reflected in an individual's
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I training file. Lesson plans are not in compliance with Procedure i
2010 Instructor Guide Format. The format of several emergency preparedness lesson plans differs significantly from that specified by procedure.
Procedure 2014 Instructor Qualification contains well defined selection criteria, and clearly specifies the qualification program to be used to qualify training instructors.. Emergency preparedness training j
instructors are not being qualified, or selected in accordance with the criteria specified in this procedure.
I 2.
No documentation exists to certify that EAL's are being reviewed 1
annually with State and local governmental authorities as required by applicable regulations.
Interviews with the l
cognizant instructor indicate classification was reviewed with the state of New Hampshire officials, but not EAL's. No l
instruction of local officials was offered or conducted.
L 3.
Emergency preparedness training is not adequately coordinated to ensure that all appropriate training is completed as required.
No single person is assigned overall responsibility for ensuring that all emergency response personnel receive appropriate specified training. Training for Emergency Response Organization security personnel is conducted by the security organization.
Short term emergency director training was conducted as part of the operator requalification. program in the past, but interviews indicated they do not plan to continuo such training.
Emergency i
preparedness staff were unaware of that training gap.
4.
The required reading program, which ensures all emergency response organization personnel are aware of procedure changes, was discontinued last fall. No plans are in process to reestablish the program and no alternative means of informing the entire emergency response organization of current and changing procedures is being implemented.
D.
PUBLIC INFORMATION Strengthen coordination and management of various elements of the emergency public information program.
Review and coordination between individuals responsible for segments of the program is sometimes lacking entirely and seldom documented in retrievable fashion.
There are multiple and in some cases significant discrepancies between the plan and the implementing procedures, and l'
among the implementing procedures. Documentation of certain required program activities does not exist.
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- 14. R. Kindley TRIP REPORT. SPECIAL A$$!$TANCE VI$1T TO SEASR00K STATION Page 6 1.
Strengthen and clarify assignment of responsibility and accountability for the emergency public information and education program. Coordination and cooperation between the emergency preparedness and the corporate communications staffs needs significant improvement.
Changes are made by the emergency planning staff to Media 4.
Center precedures without review or concurrence by Corporate Communications personnel who operate that facility.
b.
Corporate Communications personnel do not review public education materials designated for distribution to EPZ residents.
Further, they do not have copies of, or the opportunity to review, changes to the emergency plan which is the base document for the Media Center operation, c.
Offsite emergency planning personnel who write plan and education materials for state (New Hampshire) approval have never seen the onsite implementing procedures, even though those procedures have multiple references to offsite interface.
2.
Correct the multiple discrepancies in the plan and procedures.
Implement a review process which more effcetively curtails such discrepancies in future changes, a.
The plan, Section 11.3, states that public information materials are reviewed and distributed annually to residents within the plume EPZ.
These materials have never been distributed, b.
Media Center operations, by procedure, rely upon access to the Short Term Emergency Director to establish information credibility. However, the procedures for Notification of Unusual Event Alert, Site Area Emergency, and General Emergency do not assign the Short Term Emergency Director any responsibility to be available to or provide information to the Media Center personnel.
Lack of this support significantly hampered media center operation during observed drills.
~3.
Ensure documentation of required program elements is readily available. Annual media training was conducted in February 1986 and in December 1987. No documentation exists for the 1986 training, and no documentation of training content exists for 1987 training.
Attendance sheets and an agenda do exist although copies of those documents were not available for review.
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i-g W. R. Kindley TRIP REPORT SPECIAL A55!$7ANCE VISIT TO SEABROOK STATION Page 7 Further, the media call out list should be reviewed quarterly along with all other notification call lists.
No documentation of this review is available. This call out list is not included as an attachment to the Media Center implementing procedures, or available in the emergency preparedness division.
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ATTACHMENT A.
Personnel Contacted George Gram Executive Director of Emergency Preparedness and Community Re'ations Jim MacDonald, Radiological Assessment Manager Terry Harpster, Director of Emergency Preparedness Pat Casey, Supervisor of Drills and Exercises Rick Mays, Drills and Exercises Fred Staccia Training Program Coordinator EP Dennis Pachulski, Lead Trainer Onsite Emerge (ncy) Response Organization Kathy VonWald, New Hampshire / Maine Support Organizations Mike Bovino, Senior Planner Onsite and Planning Staff Tony Callendrello, New Hampshire Planning Staff Hearing Support 1
Evalyn Fisher, New Hampshire Planning Staff 1
Sue Perkins, Activity Coordinator Paul Frechette, Senior Planner l
Dick Winn, Director, Corporate Communications David Scanzoni, Manager News Services O
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