ML20132D542

Emergency Preparedness Insp Rept 50-528/85-10 on 850429-0503 & 13-17.Violation Noted:Failure to Provide Initial Training & Annual Retraining to Employees

ML20132D542
Person / Time
Site:	Palo Verde
Issue date:	07/03/1985
From:	Fish R, Temple G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20132D535	List: ML20132D533 ML20132D538 ML20132D542
References
RTR-NUREG-0654, RTR-NUREG-654 50-528-85-10, NUDOCS 8508010136
Download: ML20132D542 (9)

See also: IR 05000429/2005003

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U. S. NUCLEAR REGULATORY COMMISSION

l OFFICE OF INSPECTION AND ENFORCEMENT

REGION V

Report No. 50-528/85-10

Docket No. 50-528 License No. NPF-34

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Licensee: Arizona Nuclear Power Project

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P.' O. Box 52034

Phoenix, Arizona 85072-2034 l

Facility Name

Palo Verde Nuclear Generating Station-Unit 1

j Inspection At: Palo Verde Site - Wintersburg, Arizona

5! In'spection conducted: April 29-May 3 and May 13-17, 1985  !

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Inspector: T, h h O.

G.'M. Tehrple, Emetgency Preparedness Analyst

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Date Signed

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Approved by: ;e

z R. F. Fish, Chief, Emergency Preparedness Section ITate Signed

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Summary:

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Inspection on April 29-May 17, 1985 (Report No. 50-528/85-10)

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Areas Inspected: A routine, unannounced emergency preparedness inspection in

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the areas of knowledge and performance of duties (training), licensee audits

and changes to the emergency preparedness program. The inspection involved

. about 67 hours7.75463e-4 days <br />0.0186 hours <br />1.107804e-4 weeks <br />2.54935e-5 months <br /> of onsite time by one NRC inspector.

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Results: ,

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Of the 3 areas inspected, no significant deficiencies-or violations of NRC

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requirements.were,identifie'd in.2 of them. One violation of NRC requirements [

was identifie'd in-the area of' training for failure to provide initial training

and annual retraining to;some employees.

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DETAILS

1. Persons Contacted

• T. Barsuk, Emergency Planning Engineer III

• H. Bieling, Supervisor, Offsite Emergency Planning

D. Callaghan, Shif t Supervisor

M. Cates, Emergency Planning Coordinator II

• G. Clyde, ANPP Nuclear Licensing Engineer

M. Clyde, Supervisor (Acting) Shift Technical Advisor

• M. Crusa, Government Liaison

F. Doyle, Lead Engineer, Management Systems Development

V. Elish, General Employee Training Instructor III

• C. Emmett, ANPP Compliance Engineer

W. Fernow, Manager, Plant Services

T. Green, Supervisor, Training Support Services

D. Hackbert, Quality Assurance Engineer III

M. Halpin, Shift Supervisor

• F. Hicks, Manager, Training

• D. Hutton, Quality Assurance Engineer

R. Jacobs, Quality Assurance Engineer

• D. Karner, Assistant V.P. , Nuclear Production

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• J. Matteson, Quality. Assurance / Quality Control Transition

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R. Meyers, Supervisor, Fire Protection

• D. Nichols, Supervisor, General Training

R. Page, Program Manager,-ANPP Prudency Audit

• S.'Penick, Supervisor, Quality Monito' ring

• W. Quinn, Manager, Licensing ,

• C, Russo, Manager, . Quality. Audits and Monitoring

J. Sims, Emergency Planning Engineer III .

• L. Souza, Assistant Manager, ANPP Corporate Quality Assurance / Quality

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R. Thompsod, Lead Instructor, General Employee Training

l T. White, Supervisor, Quality Audits

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• D. Yows, Manager, Emergency Planning'and Preparedness

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• Denotes attendance at the exit interview on May 17, 1985.

2. Licensee Audits' ,

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The inspector examined audit reports to determine that an independent

audit / review of the emergency' preparedness program had been conducted on

an annual basis in accordance with 10 CFR 50.54(t) and Section 8.2 of the

licensee's Emergency' Plan (EP). Audit reports for 1982, 1983 and 1984

, were examined. The 1982 and 1983 audits were conducted by HMM

Associates, an outside consulting firm. The 1984 audit (Quality

Assurance (QA) Audit No.84-013) was conducted by the licensee's Quality

Audits and Monitoring Department on June 19-27, 1984 and documented in QA

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Document No. 0-84-651-CNR, dated July 16, 1984. One Corrective Action

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Report (CAR) and ten Quality Assurance Observations (QA0s) were

documented as a result of QA Audit No.84-013. Audit. findings were

reported to appropriate corporate and plant management.

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To ensure that the licensee's Emergency Preparedness Program is audited

annually, the audit has been incorporated into the Quality Audits Department's

scoping matrix, (Audit Scoping Matrix 18) and entered into the audit schedule.

The scope of the audit is based on NUREG-0654, Revision 1,Section II,

" Planning Standards and Evaluation Criteria". Individual audit scopes are

prepared prior.to each audit and include a portion of the above criteria, as

well as any previous problem areas. Individual audit scopes are prepared such

that ill areas are addressed over a period of two to three years. As an

example, the 1984 audit did not include an evaluation of the adequacy of the

interface with State and local governments, because this subject was addressed

in the 1983 audit. Provisions have been made to make this evaluation

available to appropriate State and local governments whenever applicable.

In addition to the Quality Audits'Dep$rtinent's formal deficiency tracking

system, the Emergency Planning Department maintains an action item tracking

system of its own. Audit findings and' deficiencies noted during exercises and

drills were found on the ' action item list. The inspector sampled a number of

audit findings and a number of deficiencies identified by the licensee during

the last annual exercise to verify that deficiencies had been corrected. Some

NRC identified improvement items contained in the NRC exercise report

(Inspection Report No. 50-528/84-37) were also sampled to determine whether

these improvements had been considered. The inspector found that all of the

deficiencies had been corrected and improvement items had been considered

and/or corrected.

No significant deficiencies or violations of NRC requirements were identified.

3. Changes to the Emergency Preparedness Program

To determine if any changes had been made to the emergency preparedness

program, the inspector reviewed changes to the emergency response

facilities and organization, changes to the EP and Emergency Plan

Implementing Procedures (EPIPs), and changes to the licensee's Emergency

Planning Department. Changes were evaluated to determine the affect on

the overall state of emergency preparedness.

The inspector toured the Emergency Operations Facility (EOF), Technical

Support Center (TSC) and Operations Support Center (OCS) and determined

that there were no significant changes to those facilities. As a

functional change, the decision has been made to move offsite (licensee)

field team direction from the TSC to the EOF. Since State and county

field teams have always been directed from the EOF, no additional

personnel or equipment will be required in the EOF. This change does not

impact the overall state of emergency preparedness.

The inspector noted three changes to the emergency response organization:

1) clerical personnel wirl fill the positions of status board keepers,

rather than technical personnel; 2) a technical information monitor has

been added to the TSC organization to function as the key contact to EOF

personnel; and 3) two NRC liaison personnel (one health physics and one

operations) have been added to the TSC organization. These changes do

not impact the overall state of emergency preparedness.

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The licensee is currently revising its EP. To complete the process, EP

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revisions are distributed to licensee management for review and comment.

All comments are addressed to the Emergency Planning Department for

resolution and disposition. The completed draf t is approved by the

Manager, Emergency Planning and Preparedness and submitted to the Plant

Review Board (PRB) review and approval cycle. Upon PRB approval, the EP

is sent to the Executive VP, VP and Assistant VP, Nuclear Production, for

concurrence. The aforementioned . organizational changes are being

incorporated into the EP and applicable EPIPs.

With respect to the EPIPs, one major change has occurred as a result of

the recently issued ANPP Administrative Policies and Procedures Manual.

Licensee personnel determined that four EPIPs were " administrative"

, procedures that did not implement any emergency response activities and,

therefore, cancelled them as EPIPs af ter they were re-written and issued

as procedures in the new ANPP manual. The inspector pointed out to

l ' licensee personnel;that although the newly issued corporate procedures

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were of ~ an administrative nature, they still implement portions of the EP

, and need to be tr'eated like EPIPs,'which includes meeting the

distribution requirement of Section V of Appendix E to 10 CFR 50.

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The following is a summary of affected procedures:

A. EPIP-01, " Emergency Organization" was cancelled January 18, 1985 and

replaced with 7N409.02.00, " Emergency Preparedness Organization and

Staffing". This procedure implements Section 4 of the EP.

B. EPIP-35, '" Review, Update, and Revision of The PVNGS Emergency Plan"

was cancelled March 22, 1985 and replaced with 7N409.03.00,

" Emergency Plan Review and Approval", 7N409.04.00, " Emergency Plan

Change Notice" and 7N409.07.00, " Emergency Plan Implementing

Procedures Review and Approval". These procedures implement Section

8 of the EP.

C. EPIP-37A, " Emergency Preparedness Drills" was cancelled March 22,

1985 and replaced with 7N409.08.00, " Emergency Preparedness Drills".

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This procedure implements Section 8 of the EP.

D. EPIP-37B, " Emergency Preparedness Exercises" was cancelled March 22,

1985 and replaced with 7N409.09.00, " Emergency Preparedness

Exercise". This procedure implements Section 8 of the EP.

In addition to the above procedures, EPIP-36, Emergency Preparedness

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Training", has been targeted for cancellation. The corporate procedure

to replace this EPIP is 8N718.04.00, " Emergency Plan Training". Because

the corporate procedures supersede all other procedures, the Training

Department has been using the ANPP procedure to conduct training. The

ANPP EP training procedure in effect is Revision 1. Revision 2 will be

issued after procedural differences between EPIP-36 and 8N718.04.00 are

resolved. It should be noted that, at the present time, some major

inconsistencies exist between the two procedures and some delay has

occurred in getting these differences resolved. This matter is discussed

in greater detail in Section 4 of this report.

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'Since none of the corporate procedures mentioned above were distributed

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to the NRC in accordance with the aforementioned requirement,

technically, the licensee was in violation of the requirement. As an

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interim solution, during the exit interview, the licensee committed to

formally transmitting specific EP related corporate procedures during the

week of May 20, 1985. The licensee also mentioned during the exit

interview that as a.long rar.ge solution, the cancelled EPIPs might be

reinstated. Because three of the four EPIPs were just recently cancelled

and one (EPIP-01) is practically a verbatim representation of Section 4.2

of the EP, and the licensee'has committed to a timely resolution, the

matter of the violation was -terminated with the exit interview.

With respect to the administration of the licensee's emergency

preparedness program, the inspector investigated the impact of some known

vacancies and personnel changes. The Emergency Planning Department

existed for about two months without the benefit of a full-time manager.

This had an impact on filling two other vacant positions. These two

positions, Training-Administrator'and Emergency Planning Engineer, have

been vacant since the-end of 1984. .The Supervisor, Site Emergency

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Planning was promoted to Manager on April 26, 1985, leaving yet another

vacancy. The Emergency Planning Department has weathered this situation

by shifting work duties to make up for the vacancies. The inspector

concluded that the department would benefit by prioritizing the filling

of the vacancies, particularly the position of Training Administrator.

4. Knowledge and Performance of Duties (Training) I

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i The inspector examined the EP training program for offsite and

l onshift/onsite personnel. Both training programs are described in

I Section 8 of the licensee's EP and detailed in EPIP-36, Revision 1,

! " Emergency Preparedness Training". As previously mentioned, this

l procedure has been superseded by ANPP Administrative Procedure No.

8N718.04.00, Revision 1, " Emergency Plan Training". This training

program has been established to satisfy the requirements of 10 CFR

50.54(q), 10 CFR 50.47(b), Technical Specification 6.8.1 and Section IV.F

of Appendix E to 10 CFR 50.

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Initial EP training for onshift/onsite and EOF emergency response

personnel is identified in Attachment 1 to Procedure No. 8N718.04.00.

Training personnel indicated that three of the training courses listed in

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Attachment I had been deleted and the material. covered in other training

, courses. Further, a new shortened overview course (NGP-16) had been

added to the program for retraining purposes. Section 4.2.1 of procedure

No. 8N718.04.00 states that " personnel assigned to the PVNGS Emergency

Organization shall receive initial and annual retaining specific to their

emergency assignment".

Section 4.2.5 of the procedure states that retraining for emergency

response personnel "shall consist of an overview and a review of their

specific emergency responsibilities". Contrary to Technical

Specification 6.8.1 and IV.F of Appendix E to 10 CFR 50, the inspector

noted the following instances where initial training or retraining was

not provided in accordance with procedural requirements.

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A. One individual identified as the primary onsite Technical

' Engineering Coordinator in the emergency response organization had

not had refresher overview training since 11/12/82.

B. One individual identified as the primary Radiation Protection

Coordinator in the emergency response organization had never had

initial training in Survey and Sampling. This course is required

annually for this position.

C.' One individual identified as a back up Radiological Assessment

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Communicator had never had initial training in EOF Operations and

Survey and Sampling. In addition, this individual had not had

overview training since-'10/03/83.

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D. Eight individuals identified as Satellite Technical Support Center

(STSC) Communicators / Operations Personnel / Fire Team members have had

refresher overview training within the last 15 months, but the

longer initial overview training was never received.

. E. Of the 34 Analysts / Systems Engineers listed on the Training Records

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Management System (TRMS) printout, only 6 of the individuals had

i ever received initial TSC Operations training, however, most were

- current in their overview training.

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The inspector discussed Item E with training personnel and was informed that

j since refresher overview training included an individual's responsibilities in

i the facility to which they were assigned, initial facility operations training

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was not being provided. This decision was made at the instructor level and no

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record of Training Management and/or Emergency Planning authorization could be

produced.

i The inspection also disclosed a number of problems with the TRMS. It should

be noted that the TRMS is a new computerized system being used to track

emergency response training. The system was designed to correct weaknesses in

the previous tracking system. The weaknesses in the previous system had been

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identified by NRC and the licensee's audit department. The licensee has been

, using the current system since February 1985. Copies of the printout are sent

i to supervisors once a month to keep them informed of the training needs of

their employees. The inspector found the TRMS printout to be inaccurate. By

! checking microfiche training records,.the inspector noted several instances

where training had been completed, but was not reflected on the TRMS output.

It should be noted that this represents conservatism in that those individuals

would be required to receive annual retraining earlier than necessary. For

the position of Radiological Assessment Coordinator, Survey and Sampling

training is required by Procedure No. 8N718.04.00, however, it is not listed

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on the printout. None of the individuals (primary or alternates) had ever had

this training and it is not clear whether training would have been scheduled

in the future. Supervisors are required by Station Manual Procedure No.

81AC-0ZZ01, "PVNGS Training Records", to review applicable procedures and

submit to the Training Department forms identifying training commitments for

job classifications of individuals reporting to them. Completed forms are

then incorporated into TRMS which uses code numbers to identify individual

training courses. It should be noted that the Survey and Sampling course was

< not a requirement identified in EPIP-36 for the Radiological Assessment

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, Coordinator position. Since these codes are not identified in either of the

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two training procedures, the inspector had some concerns about whether

supervisors could identify course titles from the codes printed on the TRMS.

The examples of overdue / incomplete training noted above should not be

considered as a complete list. The inspection disclosed that these particular

cases were only representative of the deeper problems with the emergency

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training program. The inspector's first examination of the TRMS printout

! revealed that out of about 900 individuals, approximately 36% were not up to

date in their training when the annual training year (a procedure requirement)

was used along with current training requirements. Records for 669

individuals were examined. The inspector was made aware of a December 18,

1984 memorandum from the Plant Manager which granted a 15 month period for

completing training. Further, the memorandum states that protected area

access cards, (ACAD) "may" be pulled if retraining is not completed prior to

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the 15 months. This was done apparently in an effort to ensure that training

is conducted in a timely manner. The list of individuals not current in their

training dropped significantly when the 15 month training year was used.

Additionally, based on the incomplete state of the TRMS printout, microfiche

records were accessed to confirm training status of as many individuals as

time permitted. Some individuals were found to be current, based on the

microfiche records. As previously mentioned, the licensee considered training

complete for those individuals who had completed refresher overview training

without specialized initial training. This represented a significant number

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of individuals.

i The inspectbr also found some inconsistencies between the names listed on the

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TRMS for certain emergency response positions and those names appearing on the

individual facility staffing list that is prepared by the Emergency Planning

Department. . Individuals ~are entered into the TRMS automatically by job

classification'or manually by Social Security Number. Emergency Planning

personnel reported that training records are not checked prior to adding

personnel t'o the Staffing List. It appears that the mechanism for placing

individuals on the TRMS and the Staffing List should be reviewed.

The inspector also noted that approximately 100 individuals appearing on the

TRMS listing have never had any emergency response training at all. The

licensee should make'an. attempt to determine whether these individuals are new

hires or have simply not been scheduled for training. The licensee has not

established a time limit for completing training for newly hired personnel.

l The inspection disclosed another example of training not being conducted in

accordance with procedural requirements. Section 4.1.1 of procedure no.

l 8N718.04.00 states that " annually, PVNGS personnel shall receive general

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instruction on the Emergency Plan concerning personnel assembly,

accountability, evacuation and reassembly". This requirement is also

described in Sections 4.3.1.1 and 4.3.1.3 of EPIP-36. EPIP-36 is noted with

an effective date of 3/25/83. Contrary to this procedural requirement,

personnel who do not require unescorted access into the security protected ,

area do not attend annual site access training to receive ACADs and have not i

been given this basic training and indoctrination on an annual basis. This

type of training is only given once when individuals are first hired. This

effects mainly clerical personnel reporting to the licensee's Administration

Building. Since retraining in this area has never been conducted,

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coordination between the Training Department and the Emergency Planning

Department appears to be in question, particularly in the area of procedure

development.

The inspector also examined the training records for offsite emergency

response personnel. The inspector reviewed only the ANPP corporate personnel

records. Of the 122 individuals listed, 87 were overdue in their training if

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a 12 month training year was used, however, none were overdue using the 15

month training' year. The delay in training resulted from the need to revise

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the corporate procedures, the need to rework the overview training course and

the lack of personnel-to accomplish these tasks. During the exit interview,

i licensee personnel reported that every effort would be made to conduct the

required training before

i the 15 month period was exceeded. This appears to be

an adequate resolution. r

To evaluate their familiarity with the EP and EPIPs, the inspector presented a

NRC prepared scenari6 to two Shift Supervisors. The scenario involved all

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four emergency classifications and required the use of the plant's Technical

Specifications. Both Shift Supervisors clearly understood their

. responsibilities during an emergency and both effectively utilized the

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Technical Specifications and applicable EPIPs.

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One violation of the NRC requirements described in the first paragraph of this

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section, failure to train and retrain personnel on emergency preparedness in a

timely manner, was identified during this portion of the inspection

(85-10-01).

5. Emergency Plan Implementing Procedure Review

As part of the emergency preparedness licensing program, the Region V

Emergency Preparedness Section is required to perform an annual review of '

changes to licensee's EPIPs. This review was accomplished in the office,

prior to this inspection. The following procedures were reviewed.

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EPIP-02, Revision 2, Emergency Classification

, EPIP-03, Revision 6, Notification of Unusual Event Implementing Actions

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EPIP-04, Revision 5, Alert Implementing Actions

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EPIP-05, Revision 5, Site Area Emergency Implementation Actions

EPIP-06, Revision 5, General Emergency Implementing Actions

EPIP-14A, Revision 3, Release Rate Determination

EPIP-14C, Revision 0, Continuing Dose Assessment

EPIP-20, Revision 3, Personnel Assembly and Accountability

EPIP-22. Revision 3. Personnel Injury

EPIP-27, Revision 3, Post Accident Sampling

EPIP-38, Revision 5, Emergency Equipment and Supply Inventory

EPIP-56, Revision 1, Ultimate Heat Sink Emergency Water Supply

The changes made continued to implement the EP, did not reduce the

effectiveness of emergency preparedness and did not result in a failure to

meet the performance standards in 10 CFR 50.47 (b).

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6. Exit Interview

An exit interview was held with the licensee on May 17, 1985 to discuss

the details of the inspection. In addition to the personnel identified

in Section 1, Mr. Roy Zimmerman, NRC Senior Resident Inspector, was

present. The licensee was informed of an apparent violation of the

training requirements of 10~CFR 50.54 (q). With the exception of the

failure to provide annual training to personnel who do not frequent the

protected area, the programmatic problems described in Section 4 were

-discussed. Subsequent to NRC: Region V management concurrence, this

matter was discussed by telephone with ANPP Nuclear Licensing personnel

on June 21, 1985. 'The inspector also expressed some concern about the

vacancies in the Emergency Planning Department with the expectation that

the vacancies can be_ filled now that a full-time manager has been

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