IR 05000293/1992026
| ML20127N917 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 01/21/1993 |
| From: | Lusher J, Mccabe E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20127N911 | List: |
| References | |
| 50-293-92-26, NUDOCS 9302010121 | |
| Download: ML20127N917 (7) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
License / Docket:
DPR-35/50-293/92-26 Licensee:
Boston Edison Company RFD #1, Rocky 11111 Road Plymouth, Massachusetts 02360 Facility:
Pilgrim Nuclear Power Station, Plymouth, Massachusetts Dates:
December 7-11,1992 d
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f3 Inspectors:
Ows J. Lus'iler, EnMrgency Prepardness Specialist, DRSS dat C. Gordon, Senior Emergency Preparedness Specialist, DRSS B. Haagensen, Sonalysts Incorporated (Consultant)
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Approved:
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- ct E. McCabe,(Chief, Emerg'ency Preparedness Section, DRSS date AREAS INSPECTED Pilgrim Nuclear Power Station emergency preparedness.(EP) program changes; emergency response facilities, equipment, instrumentation, and supplies; organization and management control; train" a: and independent reviews / audits.
RESULTS The EP program was being effectively administered and implemented. No violations were identified. An unresolved item was identified relating to the testing of the Technical Support Center ventilation system. Two additional NRC follow-up items were identified: the effect of the ongoing reorganization on the EP program; and clarification of and/or training on Protective Action Recommendation (PAR) Procedtre EP-IP-400.
9302010121 930120
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PDR ADOCK 05000293 G
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DETAILS 1.0 Persons Contacted The following licensee personnel attended the exit meeting on December 11,1992.
J. Alexander, Nuclear Training Manager L. Calfa, Lead Auditor R. Cannon, Senior Compliance Engineer L. Dooley, Technical Training Section Manager C. Puller-Miles, Nuclear Training Specialist D. I2ndahl, Emergency Preparedness Onsite Division Manager R. Markovich, Emergency Preparedness Offsite Division Manager J. Morlino, Emergency Preparedness Drills and Exercise Coordinator H. Oheim, Regulatory Affairs Manager W. Rothert, Director, Nuclear Engineering J. Spangler, Facilities and Equipnient Division Manager T. Swan, Operator Training Supervisor R. Varley, Emergency Preparedness Department Manager M. Williams, Senior Quality Assurance Engineer The inspectors also interviewed and observed other licensee personnel.
2.0 Emergency Plan and Implementing Procedures The inspector reviewed the Emergency Plan and Implementing Procedures change -
process. Pilgrim's Emergency Plan and Implementing Procedures must be approved by the Operations Review Committee (ORC). Pursuant to Procedure EP-AD-100,
" Emergency Preparedness Controlled Documents," about 90 changes were made to Emergency Planning procedures during the annual review cycle. Most of these were to administrative procedures (EP-ads), corporate procedures (EP-cps), and public information procedures (EP-PIs). The changes were due mostly to EP organization changes and to movement of the corporate news center from two floors to one floor -
in the Prudential Building.
NRC review found the Pilgrim Emergency Plan and Implementing Procedures to be up-to-date. All changes made were properly reviewed and approved by the licensee.
No associated reduction in Emergency Plan effectiveness was found.
Overall, this program area was found to be effectively implemented.-
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3.0 Emergency Facilities, Equipment, Instrumentation and Supplies.
The Control Room, Technical Support Center (TSC), Operational Support Center (OSC), and Emergency Operations Facility (EOF) were found to be in excellent operational readiness. Equipment supply cabinets were as described in the Emergency Plan and Implementing Procedures and were adequate to support emergency response. Computer systems were tested and operational. The Safety Parameter ' Display System (SPDS) was fully operational and available for use.
Emergency equipment was regularly inventoried, and the inventory process had been changed to incorporate operability testing. Instrumentation was calibrated as required.
Instrument batteries were in good condition. Instruments were in calibration and responded properly to check sources. All equipment and instruments were found to be operable. In the Operations Support Center (OSC) and EOF, however, there were several respirator canisters for iodine with broken seals. These were immediately
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replaced.
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The inspectors reviewed communication testing procedures for the Digital Notification Network (DNN), the Boston Edison Community Offsite Notification System, and various commercial telephones. These were working properly. Testing records showed increased reliability of the DNN system.
As committed to under the Three Mile Island (TMI) Action Plan, the Pilgrim TSC ventilation system must provide the same habitability as the Pilgrim Control Room except that automatic actuation, redundancy, and seismic qualification is not required.
Inspector review of the TSC Heating, Ventilation and Air Conditioning (HVAC)
System Maintenance Procedure 3.M.4-71, performed semi-annually, found that the system had been inspected and operationally tested. The procedure specified that the
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filters should be replaced if differential pressure (dp) requirements were exceeded.
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However, no testing of the efficiency of the High Efficiency Particulate Air (HEPA)
filters or of the iodine absorption efficiency of the charcoal filter was noted. Also, there were no instructions on what to do if there was no dp across the filters.
Confirmation of assurance of continued functionality of these HEPA and charcoal filters is an unresolved item (URI 50-293/92-26-01).
Overall, implementation of this program area was assessed as good.
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4.0 Organization and Management Control All permanent positions were filled, and the EP staff was knowledgeable and stable.
Several changes in the EP orgamzaton were identified. The EP Manager now reports to the Vice President, Technical, who reports to the Sen;or Vice President, Nuclear.
The on-site EP Section Manager position was eliminated, and the on-site EP Division Manager and the Facilities and Equipment EP Division Manager report directly to the -
EP Department Manager.
The inspectors noted that, in June 1992, the Boston Edison Company began a three-phase reorganization that will take place over the next year. Reorganization goals were stated to be: to improve effectiveness and performance of the Nuclear Organization; to consolidate similar functions; to increase the span of control, resulting in fewer management layers; to consolidate the responsibilities of external relations, and to simplify the organization structure. The inspectors were also informed that the Senior Vice President, Nuclear had resigned and that Dr. E. T.
Boulette had been appointed as the Acting Senior Vice President, Nuclear.
The inspectors asked senior management personnel about the effect of the reorganization on the EP department. It was indicated that the emergency planning group would remain stable, with added responsibility for off-site activities and community public relations. Since the reorganization is new and continuing, its EP impact will be evaluated further (IFI 50-239/92-29-02).
The Emergency Response Organization (ERO) was adequately described in the-emergency plan. All positions were sufficiently staffed: three or four persons were qualified in each position.
This program area was assessed as having been effectively implemented.
5.0 Training Training records for all emergency preparedness training were maintained as specified by administrative procedures. The EP training database was validated by comparing-20 individual records of class attendance, qualification cards and test answer sheets to the computer record. No discrepancies were identified.
Five lesson plans were reviewed. The lesson plans were developed to assure competent instruction on lesson objectives. Each lesson plan was adequate. Several
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had excellent technical detail. Alllesson plans reviewed had terminal and enabling objectives developed through table-top discussion with subject matter experts. - A test question bank had been developed for each lesson objective and was periodically update.
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The ERO members were allowed to review the annual refresher training student material on a self-study basis and could elect to " test out" of the training class if the training material had not had substantial changes. A sampling of these tests were reviewed for depth, technical difficulty, and validity. The " test out" examinations were adequate to validate that the individual retained the knowledge needed to perform his/her ERO functions.
The On-Call ERO Roster for the month of December was reviewed for ERO qualification status. Approximately 50% of the training records of individuals who were assigned a rotation position on the ERO were checked. These individuals had received training within the specified time periods and fully met the administrative requirements for qualification. All ERO positions were staffed. The tracking
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database system graphically highlighted qualification status and had the ability to identify all ERO members who were fully qualified. Any individual who had not completed the qualification requirements was removed from his/her ERO position.
Three crews of operators were tested during table-top exercises which simulated fast-breaking accident scenarios. All crews demonstrated the ability to promptly classify the events and notify the state and local authorities within 15 minutes. Protective action recommendations (PARS) were made at the general emergency level. In each case, the recommended protective actions were as prescribed for the conditions provided by the scenario.
Although no unacceptable PARS resulted, inconsistencies were noted in Emergency Director (ED) and Nuclear Watch Engineer (NWE) understanding of the PAR Flow Chart of Attachment I to EP-IP-400. Some examples follow.
Some EDs were not able to explain the decision block on the PAR flow chart
that evaluates "large amounts of fission products in containment". This block has a note (#2) that states that the threshold for this condition is reached when containment high range radiation monitors exceed 25,000 R/hr (Roentgens per hour) and is intended to identify core melt. Most EDs considered "large amounts of fission products" to be large in relation to normal activity in the containment at power, a very small amount. They did not realize that "large" was intended to be relative to the total potential source term from a fuel melt.
They consistently stated that "large amounts of fission products" were in containinent when containment high range radiation monitors were in the 100-1000 R/Hr range.
Several EDs stated that a " Loss of Physical Control of the Plant" implied a
loss of safety equipment or systems that prevented the operators from maintaining the plant within safety limits. They were not awa e that this decision block on the PAR Flow Chart was intended to apply only to a security threa.
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Several EDs incorrectly applied the word " consider" in the action block:
Consider Evacuation of the 2-mile ring, shelter 5 Miles Downwind. They applied this in the context of plant conditions and the potential for farther plant degradation without addres. sing the EP-IP-400 Attachment I direction to consider three explicit factors:
- Would the population at risk be able to evacuate before the plume arrives?"
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- Are the winds variable or expected to shift and affect areas where PARS are
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not met?"
- Would severe weather cause road conditions to be so dangerous as to negate
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the benefits of the dose saved?"
One ED recommended "no protective actions" at the general emergency level e
on the basis of very low projected doses off-site. He was not aware that Note
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Minimum Protective Action Recommendation when in a General Emergency is shelter 2 mile ring and 5 miles downwind.
The above indicates a weakness in PAR procedure knowledge. This finding appears similar to one identified by NRC Operator Licensing Examiners during a recent requalification examination.
The inspectors concluded that there is an indicated need for PAR Procedure EP-IP-400 clarification and/or EP-IP-400 training for all ERO personnel-who may participate in PAR formulation. This item will be re-examined (IFI 50-239/92-26-03).
Overall, EP training was assessed as good.
6.0 Independent Reviews The inspectors reviewed licensee Audit Report (AR) 91-35 (August 26-September 20, 1991), AR 92-12 (August 28-September 21,1992), various Audit Department Surveillance Reports of EP performed during 1991 and 1992, and interviewed lead auditor *
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Independent audits were performed every twelve months by at least two representatives from the Quality Assurance (QA) Department (one was lead auditor)
supplemented by an EP technical specialist from an outside independent support organization. Audited areas were included in a comprehensive Audit Plan. In addition, the QA Department conducted unannounced surveillances which focused on EP program implementation.
The inspectors concluded that the audits idendfied areas requiring corrective action and satisfied 10 CFR 50.54(t) requirements. There was a review of off-site interfaces with State and local authorities in both ARs. The scope of the independent reviews was broad-based, covering key EP elements such as the Emergency Plan, EPIPs, drills and exercises, Emergency Response Facilities and equipment, ERO training and qualification, and public information. Since the last inspection, the licensee has placed more emphasis on conducting performance-based reviews by, when possible, including a drill or exercise in the review period.
Areas not covered in the audits included assessment of EP program correspondence to the NRC planning standards of 10 CFR 50.47(b) and of program problems identified in recently issued NRC inspection reports. These aspects were identified for licensee consideration as potential program implementation improvements.
Several licensee mechanisms were in use to track open items to completion. - Audit.
findings were provided as Management Corrective Action Requests and Deficiency -
Reports (requiring immediate attention), or as Recommendation or Problem Reports, which were identified in detail in the ARs. NRC review concluded that audit findings were being appropriately brought to management attention, and that the EP staff was -
attentive in addressing and resolving issues identified by the QA-Department staff.
This area was assessed as being effectively implemented.
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7.0 Exit Meeting At the end of the inspection, the inspectors discussed the scope and findings of this inspection met with the licensee personnel listed in Detail 1 of this report.
The licensee was informed that no violations were identified. Other Aspects noted in this report were also discussed. The licensee acknowledged the NRC findings and expressed the intention of evaluating them and instituting corrective actions as appropriate.