IR 05000293/1984041

Insp Rept 50-293/84-41 on 841210-13.Violation Noted:Failure to Distribute Public Info as Specified in Emergency Plan & Failure to Update Emergency Plan & Procedure in Order to Comply W/Requirements of 10CFR50,App E,Section G

ML20129D253
Person / Time
Site:	Pilgrim
Issue date:	04/29/1985
From:	Cohen I, Harpster T, Hawxhurst J, Woltner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20129D199	List: IR 05000293/1984041 ML20129D193 ML20129D222
References
50-293-84-41, NUDOCS 8506060075
Download: ML20129D253 (9)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /84-41 Docket N License N OPR-35 Category C Licensee: Boston Edison M/C Nuclear 800 Boylston Street Boston, Massachusetts 02199 Facility Name: Pilgrim Generating Station-Inspection At: Plymouth, Massachusetts Inspection Conducted: December 10-13, 1984 Inspectors: C Am 2V Nor Al 198 [

I. Cohen, Emergency Preparedness ' date '

Specialist

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@ Hawxhur~st, Emergency Preparedness Y date

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Specialist Approved by: _

  /g//4<u::7 Terparpf.er, Chipf/, Emergency h4/)f u date
      /f PI Preparedness SectTon, DRSS Inspection Summary:

Inspection on December 10-13, 1984 (Report No. 50-293/84-41) Areas Inspected: Routine announced inspection of IE Inspection Procedures: Emergency Detection and Classification; Protective Action Recommendations; Notification and Communication; Changes to the Emergency Plan; Knowledge and-Performances of Duties; Pubi.- Information Program; Licensee Audit Results: Two apparent violations were identified: failure to distribute public information as specified in the Emergency Plan (Paragraph 7); failure to update the Emergency Plan and Procedures in order to maintain compliance with the requirements of 10 CFR 50, Appendix E, Section G (Paragraph 5).

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DETAILS 1.0 Persons Contacted

*J. Crowder, Senior Compliance Engineer
*A. Oxsen, Vice President Nuclear Operations
*C. Mathis, Nuclear Operations Manager
*J. Seery, Technical Section Head
*D. Sanford, Nuclear Training Manager
*L. Dooley, Acting Technical Training Supervisor
*J.. Johnson, Senior Resident Inspector, NRC
*E. Graham, Compliance Group Leader
*P. Manderino, Shift Technical Advisor
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*S. Wollman, Onsite Safety and Performance Group Leader
*R. Kennedy, Acting NMSD Manager
*E. Cobb, Principal Engineer
*B. Nolan, Emergency G. Fiedler, Watch Engineer C. Martin, Shift Technical Advisor G. McNeil, Administrative Assistant G. Perkins, Administrative Assistant N. Simpson, Shift Technical Advisor T. Sullivan, Watch Engineer K. Taylor,-Watch Engineer
* Denotes those present at the exit meetin .0 Emergency Detection and Classification 2.1 Review The inspectors reviewed the appropriate sections of the emergency plan and procedures, conducted table-top discussions with Watch Engineers (WE) and Shift Technical Advisors (STA) and contacted the Massachusetts Department of Public Health Director. This area of the emergency program was evaluated against the references listed below, specifically to determine:
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if the licensee has and understands standard emergency classi-fication and emergency action levels (EALs);

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if procedures have been developed, maintained, and implemented, and personnel are periodically trained to classify emergencies and take appropriate actions in a timely manner;

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if the onsite personnel designated to assume the role as Emergency Director (ED), understand their role and the inherent authority and responsibility to recommend protective measures to offsite officials; and

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if the. state and local agencies agree with the EALs and hava j reviewed these EALs each yea ' 2.2 Findings The licensee's emergency program specifies that the WE initiall, acts as ED and is . responsible for declaring and properly classifyinf. an emergency. The STA assists the ED in assessing plant conditio:s and

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classifying the emergency. The inspectors interviewed three W!.s and STAS; checked the training records on six WEs and the three SMs-interviewe verall, the inspector found that licensee personnel demonstrated adequate knowledge of the emergency plan and procedures for aetecting

 ,and classifying an emergency. Also, the individuals were p</riodically trained and understood their roles as part of the emergency organization. In one case, however, the inspector noted ti.at an STA was unfamiliar with the dose assessment code input and output values, relative to classifying ~an emergency. Other areas of con >:ern were also noted by the inspectors and identified to licensee rarsonnel-during the interviews. These items are discussed belo The EAL for hurricane windspeeds, greater than 90'nph for 15 minutes, appears to be unrealistically high; instrument. failure would likely. occur prior to reaching the value indicated. The licensee agreed to review EAL on hurricane windsraed and to revise it if appropriat This item is unresolvyd-(50-293/84-41-01).

- The characterized EALs in the procedures are not. consistent with the EAL chart (s), the 'and' and 'or' qualifiers differ, .in the Emergency Response Facilities (i.e., control room). The licensee agreed to review and revise Procedure 5.7.1 and the EAL chart as necessary to reflect all the appropriate action levels for classifying emergencies, and to assure ths.t they are consistent. Licensee action in this regard w611 be reviewed in a subsequent inspection (50-293/84-41-02).

- Two of the three STAS were unable to perform a timely initial dose assessment based on monitored and unmonitored radiological releases,and one STA was unfamiliar with the cose assessment procedure. The licensee agreed to emphasize dase calculation and assessment training or develop procedures that are more con-ducive to only yearly training and also, include a more thorough review of this area in future licensee audits. This will be reviewed.in a subsequent inspection (50-293/84-41-03).

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The licensee presently does not have a procedure.for continu-ously determining release rates / projected doses when instruments-(effluent, meteorological and containment) are_ inoperable, offscale, or wind direction has shifted; nor one that addresses the methods used for assessing an unmonitored release pathwa 'The licensee is reviewing the need for procedural coverage in this area. This item is unresolved (50-293/34-41-04).

No violations were identifie .3 References 10 CFR 50 Appendix E, Part IV.B (1/1/84)

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IE Inspection Procedure 82201 (12/27/82), " Emergency Detection and

 ' Classification NUREG-0654 PNGS Emergency Plan (1982), Section PNGS Emergency Procedure 5. .0 Protective Action Recommendations 3.1 Review The inspectors reviewed the procedures for making protective action recommendations and conducted walkthroughs with Watch Engineers (Emergency Directors until relieved) to determine their ability to evaluate. protective action recommendations, including consideration of offsite conditions presented by the inspector .2 Findings The' Watch Engineers did attempt to consider offsite conditions, but the licensee's procedures did not provide-guidance for decisionmaking during adverse weather conditions nor were evacuation times of sectors within the EPZ included within the procedure. The licensee is reviewing Emergency Plan Implementing Procedure 5.7.2.18 to determine a means to provide guidance for protective action recommendations during adverse weather conditions and include evacuation time for the various sectors. This item is unresolved. (50-293/84-41-05)

i No violations were identifie .3 References 10 CFR 50.47(b)(9) and (b)(10) 10 CFR 50, Appendix E, Part IV. IE Inspection Procedure 82202 (12/27/82), " Protective Action Decisionmaking" NUREG-0654 PNGS Emergency Plan, Section PNGS Emergency Procedure 5.7.2.18

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e 4.0 Notificat' ions and Communications

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L4.1: Review ' -

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1The inspector held discussions with licensee watch engineers, control , froom administrative assistants, the emergency response coordinato and reviewed records' of monthly emergency communications tests. con-ducted during April, June and July 198 ' 14.2 : Findings' Based on the above review, the' inspectors noted that the licensee, on

  -. a number of occasions, did;not complete their offsite. notifications within 15 minutes asioutlined in Procedure 5.7.2.8, " Control Roomi
  ' Emergency-Coordinator." Licensee personnel indicated that possible
  > contributors ~to the delay in completion of notifications are:

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  -a) . lackLcf training given to communicators;
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c)' use of the same ' phone for callout and callback for. verification;

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d) Use.of the callout phone for other than emergency communication.

! The licensee is reviewing the offsite notifications procedure and make appropriate changes to provide a high. probability of completing offsite notification within the required 15 minutes. This will be

  'followed.in a subsequent inspectio (50-293/84-41-06)
  'No' violations were identified.

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  '10 CFR 50.47(b)(6).

- IE Inspection-Procedure 82203 (12/27/82), " Notifications and Communications"- NUREG-0654-NUREG-0696

PNGS Eme'rgency Plan,-Section PNGS Emergency Procedure 5.7. .0 ' Changes to the Emergency Preparedness Program 5.1 Review The inspectors reviewed' changes to the emergency preparedness program - and what had_ beer incorporated into the emergency plan and appropriate implementing procedures.

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The current _ PNPS Emergency Plan was issued April 1981 and has not

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been revised for any changes. Emergency Procedures have been updated

  .to. reflect current practice while the Emergency Plan which they.

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 -implement is out of.date. Discrepancies exist between the Emergency Plan and. implementing procedures for.the reorganization of the Nuclear Organization and other current practice The PNPS Quality Assurance Department's annual audit report on Emergency Plan for both 1982 and 1983 also stated this deficienc The inspectors' determined that this is a violation of 10 CFR 50.54(q)

which. states, in part, that "a. licensee authorized to possess and/or operate a nuclear power reactor shall follow and maintain in effect emergency plans which meet the standards in 50.47(b) of this part, and the requirements in Appendix E to' this part." (50-293/84-41-07)

 'See Appendix A, Notice of Violatio .3 References 10 CFR 50.54(q)

10-CFR 50, Appendix E IE Inspection Procedure 82204, " Changes to the' Emergency Preparedness Program" PNPS Emergency Plan, Section N. .0 Knowledge and Performance of Duties 6.1 Review-The inspectors held discussions with licensee training personnel, reviewed lesson plans, test records, attendance records,_and dis-cussed the-training courses with selected individuals. The inspector F conducted walkthroughs with licensee emergency response personnel responsible 'for assuming the role of ED during an emergency. A scenario of changing plant operating conditions and events was pro-vided to each individual or team _(when a STA was available) and their responses evaluated. This area of the emergency program was evaluated-against the references listed below, specifically to verify: ' - that a training program is established and maintained as required by 10 CFR 50.47(b)(15);

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that the type and amount of training provided to key emergency organization personnel is adequate, the individuals understand their responsibilities and can perform their assigned duties; and

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_that formal documenta' t ion of training is available to audit the program and that appropriate tests or drills to determine the effectiveness of the training were administere . _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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6.2 - Findings

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The inspector determined that all of the six WEs whose training records were reviewed had received general emergency preparednes's and specialized training for their roles as EDs in 1984. Also,.the three

 . STAS had received similar training. However, prior training records were not readily available for verification of 1983 training. In addition, the inspectors found that testing used to determine the   o effectiveness of the emergency director training was invalid in that  .l no passing grade could be determined. The inspector was informed   j
 - that a computer tracking system for EP training has been developed,  'I but not yet implemented and a more effective testing program was   l planned for future trainin '

The licensee plans to imr'ement a tracking system for general and ' specialized EP training to provide assurance that personnel assigned to the EP vrganization are adequately trained in accordance with Section N.8 of the PNGS Emergency Plan and also to provide for simpler Emergency Plan Training Program audits. This item will be reviewed in a subsequent inspection (50-293/84-41-08).

, ' The inspectors also'noted, based on the table-top discussions, that the knowledge level of the WEs and STAS was weak in the areas of

 . dose assessment and protective action decisionmaking. A review :,f

[ the EP training program audits indicates that similar problems had i been identified in audit NTD #84-364. The licensee is considering u more closely their internal audits-and is reviewing the need to I provide additional practical-based training to the individuals responsible for performing initial dose assessment and protective . action decisionmaking. This item is unresolved (50-293/84-41-09).

i No violations were identifie .3 References 10 CFR 50.47(b)(15), 1/1/84 IE Inspection Procedure 82206,12/27/82, " Knowledge and Performance l of Duties" [ NUREG-0654, Revision 1, 11/80, " Radiological Emergency Response ! Training" PNGS Emergency Plan 1982, Section N.8.1.1, " Training" Boston Edison Office Memorandum NTD #84-364, 8/23/84, " Emergency Plan Training Program Recommendations"

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7.0 Public Information Program 7.1 Review The inspectors reviewed Section 6.4.3, Part 5, of the PNGS Emergency d Plan, Massachusetts Department of Health Public Information brochures (dated 9/82) and held discussions with licensee personnel. This area ] of the PNGS emergency program was evaluated against the references listed below, specifically to determine:

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that basic emergency planning information and general radio-logical information is disseminated to the public in the EPZ on-an annual basis; and

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that signs or other measures which are used to provide informa-tion to the transient population provide appropriate informatio l.2 Findings

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The licensee's Emergency Plan specifies that emergency planning

g information will be provided to the public yearly through direct a mailing and hand distribution to residents within the emergency planning zone. This is in accordance with the requirements of 10 CFR 50, Appendix E, for annual d;ssemination of such materia The licensee did not provide emergency planning information or general radiological information to the public in the EPZ by the abovn provisions for 1983 and 198 The licensee has indicated that the information was provided to the public in the EPZ periodi-cally, but could not demonstrate what information was included or to whom it was disseminated. This is a violation (50-293/84-41-10). 2 In addition, the licensee's Emergency Plan requires that informa-tion for the transient population within the EPZ be provided through strategic stockpiling of brochure The licensee has indicated that this information was provided via newspaper advertisements and radio announcements. This area requires further review to determine what .; provisions for disseminating emergency planning informatien, to the

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transient population within the plume exposure pathway, would be useful if an accident occurs. This item is unresolved -

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One violation was identifie .3 References h 10 CFR, Part 50, Appendix E, Section PNGS Emergency Plan (1982), Section 6.4.3, Part 5 - NUREG-0654 (Revision 1, 11/80), Section 9, "Public Education Information" IE Inspection Procedure 82209 (12/27/82), "Public Info Program" -4 Emergency Public Information (9/82), Massachusetts Department of -T Public Health  % _ _

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9 8.0 Licensee Audits 8.1 Review

 'The. inspectors noted that independent audits were performed at least annually by the Quality Assurance Department. .The audit was performed to determine consistency between the PNPS-1 Emergency Plan and the requirements.oi 10 CFR 50, Appendix E. The INP0 Good Practice EP-801,
 " Generic Procedures and Guidance for Emergency Preparedness Quality Assurance Review," 3/83, was used to determine that the checklist and conduct of the .sudit were in compliance with the requirements of 10 CFR 50.54(t). The inspectors reviewed the latest Audit Report N dated January 19, 198 .2 Findings l  Deficiency and observation findings made by the independent review
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group were ifocumented and reported to management. Corrective action L ' was taken and documented with the exception that the PNPS Emergency Plan does not reflect the current Operational or Emergency Organizations. This action item in the 1982 Audit Report was

upgraded to Deficiency Report No. 1199 in the current audit report to

} document the still unsatisfactory condition as the Plan has not been updated. This condition is reported as a violction in Section 6 of this repor No violations were identifie . 8.3 References 10 CFR 50.54(t) IE Inspection Procedure 82210, " Licensee Audits Emergency Plan," Section 8 9.0 Exit Meeting On December 13, 1984, the inspectors met with the individuals listed in

 . Paragraph 1 and summarized the scope and findings of the inspection.

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