ML20137Y544

Informs That Region II Enforcement Panel Will Be Held on 961113 in DRP Conference Room.Partially Deleted

ML20137Y544
Person / Time
Issue date:	11/08/1996
From:	Boland A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Gibson A, Jordan J, Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20137Y003	List: ML20137Y001 ML20137Y022 ML20137Y042 ML20137Y052 ML20137Y479 ML20137Y498 ML20137Y503 ML20137Y507 ML20137Y514 ML20137Y518 ML20137Y540 ML20137Y544 ML20137Y552 ML20137Y556 ML20137Y576 ML20137Y594 ML20137Y609
References
FOIA-96-485 NUDOCS 9704230117
Download: ML20137Y544 (9)

Text

1 From: Anne Boland f 18 To: WND2.WNP6.OEMAIL, ATP1.AFG, EWM, gTP1.JPJ, JRJg..

Date:

Subject:

11/8/961:51pm Region ll Enforcement Panel

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'R N 'u O N n1 (d The Region ll Enforcement Panel will be held at 2:00 p.m ovember'13,1 the DRP Conference Room. The Bridge numberis 301-415-76051passcod

_.i {T The agenda will be as follows: rz

1. 2:00 p. ... Browns Ferry Operator Fitness for Duty (EAW attached - the licehsee's response is being faxed to OE today)

2. 2:15 p.m. St. Lucie EP issues (EAW attached - additional reference material being faxed to OE today)

3. 2:45 p.m. Crystal River Con'ainment Penatrations (EAW attached - no additional reference material being provided) _

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i ENFORCEMENT ACTION WORKSHEET BREAKDOWN IN MANAGEMENT CONTROL OF THE ST. LUCIE EMERGENCY PREPAREDNESS PROGRAM ,

PREPARED BY: James L. Kreh DATE: November 7. 1996 This Notice has been reviewed by the Branch Chief or Division Director and each violation includes the appropriate level of specificity as to how and when the requirement was violated.

j Signature i Facility: St. Lucie Plant Units: 1&2

Docket Nos.

50 335. 50 389 License Nos.: DPR 67. NPF 16 4

Inspection Report No.: 96 18

Inspection Dates

October 7 18 and October 28 November 1, 1996 Lead Inspector: J. L. Kreh

1. Brief Summary of Inspection Findings:

Violation A On the evening of October 3. 1996, the licensee' conducted a test of its automated system known as the FPL Emergency Recall System (informally 1 called " autodialer") for notifying the emergency response organization 1 (ERO) in the event of an off-hour emergency requiring augmentation of the  !

on-shift crew fc staffing and activation of emergency response facilities I (viz., Technical Support Center [TSC]. Operational Su] port Center [0SC].

and Emergency Operations Facility [ EOF]). The autodia'er did not operate. l and no individuals received notifications during the test. A failure '

assessment by the licensee disclosed that the autodialer had been in an .

inoperable configuration for a period which apparently began on July 22. '

1996. In addition, the inspection identified the licensee's failure to adequately maintain the manual backup system (a " call tree") for ERO call-out over an indeterminate period (at least the last several years). These concurrent deficiencies represent a failure (during the period July 22-October 3.1996 at minimum) to maintain the capability to execute the provisions of the REP and its implementing procedures in a timely manner with respect to mobilization of the ERO during off-hours.

PREDECIsIONAL ENFORCEMENT INFORMATION NOT FOR PUBLIC RELEASE W/0 APPROVAL OF DIRECTOR. oE

1 ENFORCEMENT ACTION 2-WORKSHEET Violation B

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The licensee's-training program for ERO personnel has not been adequately implemented since at least 1994. This vio4 tion includes failure to provide ' opportunities for most personnel to participate in exercises and/or drills, failure to provide annual retraining to certain designated Jersonnel in 1994 and 1995, failure to provide any training for certain ERO positions with respect to selected implementing procedures, and failure to remove individuals from the ERO roster when their' respirator qualifications had lapsed.  ;

2. Analysis of Root Cause: '

The root cause of both violations is failure of licensee management to (a) provide an appropriate level of oversight of the emergency preparedness program as required by the REP, and (b) ensure the ,

implementation of timely and effective corrective actions for identified ,

findings and deficiencies in emergency preparedness.

3. Basis for Severity Level (Safety Significance):

For both violations: Sucolement VIII - Emergency Preoaredness. SL III Section C.3 'of Supplement VIII presents as an example. " Violations 4 involving . . a breakdown in the control of licensed activities involving a number of violations that are related that collectively represent a '

potentially significant lack of attention or carelessness toward licensed responsibilities." '

Section IV. A of the Enforcement Policy states that "a group of Severity Level IV violations may be evaluated in the aggregate and assigned a single. increased severity level, thereby resulting in a Severity Level III problem, if the violations have the same underlying cause or programmatic deficiencies, or the violations contributed to or were unavoidable consequences of the underlying problem."

4. Identify.All Previous Escalated Actions Within 2 Years or 2 Inspections

> 95-180: PORVs Inoperable Due To Personnel Error: SL III  ;

• 96-040: Dilution Event: SL III .

> '.96-249: Multiple Examples of Inadequate 50.59 Reviews; SL III

5. Identification Credit? Yes Violation A Date licensee was aware of issues requiring corrective action:

October 3.1996. . This identification credit /date apolies only to the ,

autodialer inoperability portion of the violation. The problem with the manual call-out system was NRC/CI-identified.

l PREDECIsIONAL ENFORCEMENT INFORMATION NOT FOR PUBLIC RELEASE W/0 APPROVA! of DIRECTOR, OE ,

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ENFORCEMENT ACTION 3-  !

WORKSHEET ,

Explain application of identified credit. who and how identified and i consideration of missed opportunities:

The inoperability of the. autodialer was identified by the licensee on

10/3/96. but could have been identified much earlier if periodic functional tests (e.g. . Weekly) had been performed. With appropriate

administrative controls in place (as had been recommended by an EP J Coordinator as early as April 1996), autodialer inoperability would have almost'certainly have been precluded. An autodialer problem (limited in 2.

scope--not a complete system failure) also occurred during the NRC- .

evaluated June 1993 exercise, bu' corrective action for that problem was

clearly not sufficiently comprehensive.

4 Violation B i Date when the licensee was aware of issues requiring corrective action:

January 1996.

l-l Explain application of identification credit. who and how identified and ,

j consideration of missed opportunities:

.Many of the identified failures in the licensees training program were

, self-identified in a self-assessment that was performed in January 1996. t

- However, some of the identified failures were not self-identified, but  !

should have been through existing licensee program controls. 1

6. Corrective Action Credit? No 4

Violation A i Administrative controls have been implemented for the autodialer under l- Protective Services Department Guideline No. PSG-015. " Maintenance and j Testing of the Emergency Recall System" . Revision 0, dated 10/29/96. For the manual call-out system, individuals required to maintain a copy of the procedure were added to the controlled d'istribution list, and a drill was conducted on October 10, 1996 with reasonably successful results.

Application. of corrective action credit: (1) No credit for autodidler issue because identified by licensee EP Coordinator in early 1996 and no action taken: (2) Credit for correction of manual call-cut problem after identification to licensee on 10/7/96.

Violation B The licensee has initiated action items to evaluate and determine corrective actions for scif itentified issues. The licensee is currently completing a mass training effort for all emergency response organization positions necessitated _by recent changes in responsibilities from Corporate staff assignments to Plant staff assignments.

Application of corrective action credit: No credit because the licensee has not yet fully determined or implemented programmatic changes to resolve identified issues.

PREDECIsIONAL ENFORCEE NT INFORMATION NOT FOR PUBLIC RELEASE W/0 APPROVAL OF DIREC M ,' OE

ENFORCEMENT ACTION 4-WORKSHEET

7. Candidate For Discretion? No Licensee's performance in emergercy preparedness is now recognized to have been particularly poor during the p6st several years.

8. Is A Predecisional Enforcement Conference Necessary? Yes Why? To determine whether the subject violations represent a programmatic breakdown in emergency preparedness.

If yes, should OE or OGC attend? Yes Should conference be closed? No

9. Non Routine Issues / Additional Information:

OTHER FINDINGS PROM THE OCTOBER 1996 EP PROGRAM INSPECTION Violation Failure to establish an Emergency Plan Implementing Procedure (EPIP) or I to have an adequate EPIP with appropriate implementing details to address certain aspects of the Radiological Emergency Plan as follows.

a. the transfer of OSC functions to an alternate location in the event that evacuation of the primary OSC is required (EPIP-3100032E "On-site Support Centers", contains no implementing details for the statement in Radiological Emergency Plan Section 2.4.4 that "In the j event that the OSC becomes untenable, the Emergency Coordinator will j designateanalternatelocation."){inadequateprocedure}.and 1

b. recovery activities upon reaching a stable plant condition following i an emergency (Radiological Emergency Plan Section 5.4) {no '

procedure}.

Emeraency Preoaredness Program Weaknesses

1. Inadequate program of drills to ensure availability of sufficient ERO personnel and timeliness of ERF staffing

2. Management failure to ensure the implementation of timely corrective actions for certain emergency preparedness deficiencies and weaknesses. Examples are:

a. failure to address concerns regarding the audibility of the Gaitronics (or plant public-address system) formally identified in late 1994 and still being tracked as an open item by the licensee's corrective action system,

b. failure to provide adequate corrective action to address a guestionable captbility for notification of the State of Florida within 15 minutes of an emergency declaration (identified by an NRC inspection in February 1995), and PREDECIs!0NAL ENFORCEMENT INFORMATION . NOT FOR PUBLIC RELEASE W/0 APPROVAL OF DIRECTOR OE

i ENFORCEMEtE ACTION 5-WORKSHEET

c. failure to implement timely corrective actions for I deficiencies and recommendations identified by the critique of the Hurricane Erin response in August 1995 (examples of issues: identify hurricane-safe structures onsite and a plan for positioning personnel in those structures: designate an onsite individual to monitor the hurricane path: establish consistent staffing policies)

10. This Action is Consistent With the Following Action (or Enforcement Guidance) Previously Issued:

Supplement VIII. Section C.3 i

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PREDECISIONAL ENFORCEMENT INFORMATION . NOT FOR PUBLIC RELEAsf W/0 APPROVAL OF DIRECTOR, OE

i ENFORCEMENT ACTION 6-WORKSHEET

11. Regulatory Message: ,

Management must provide strong and consistent oversight and support for

emergency preparedness activities in order.to ensure a viable emergency L response capability at all times.

12. Recommended Enforcement Action:

Two SL IV violations evaluated in the aggregate as a SL III problem i

l 13. Should This Action Be Sent to OE For Full Review? No

14. Exempt from Timeliness: No Basis for Exemption: N/A i

Enforcement Coordinator

DATE:

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PREDECIs!0NAL ENFORCEMENT INFORMATION NOT FOR PUBLIC l RELEASE W/0 APPROVAL OF DIRECTOR. OE i

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l ENFORCEMENT ACTION 7-i WORKSHEET DRAFT NOTICE OF VIOLATION St. Lucie Plant Inspection Report Nos. 50-335. 50-389/96-18

! A. 10 CFR 50.54(q) requires that nuclear power plant licensees follow and maintain in effect emergency plans which meet the planning standards of 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50.

Section 2.4 of the licensee's Radiological Emergency Plan (REP).

Revision 31. states that activation of the Technical Support Center (TSC) and the Operational Support Center (OSC) will be initiated by the Emergency Loordinator in the event of an Alert. Site Area Emergency, or General Emergency, and that arrangements have been made to staff the TSC 1 and OSC in a timely manner. Also specified is that activation of the Emergency Operations Facility (EOF) is required for a Site Area Emergency or General Emergency. and that arrangements have been made to activate the EOF in a timely manner.

The REP requirements delineated above are implenented by procedure EPIP- l 3100023E. "On-Site Emergency Organization and C611 Directory" l Revision 72. The instruction in Section 8.2 of that procedure states that, upon the declaration of an emergency classification. "the Duty Call ,

Supervisor will initiate staff augmentation" using the " Emergency Recall l System or Appendix A. Duty Call Supervisor Call Directory to notify '

persons. j Contrary to the above from approximately July 22 to October 3.1996, arrangements were not available to staff cr activate the TSC. OSC. or EOF  :

in a timely manner because the licensee did not have the capability to l implement either the primary method (using the Emergency Recar System) or the backup method (using the Duty Call Supervisor Call Directory) for notifying its Jersonnel to report to the plant during off-hours to staff and activate t1e TSC. OSC. and EOF. l B. 10 CFR 50.54(q) requires that nuclear power plant licensees follow and maintain in effect emergency plans which meet the planning standards of 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50.

i REP Section 7.2.2. " Training of On-Site Emergency Response Organization Personnel", states. "The training program for members of the on-site emergency response organization will include practical drills as appropriate and participation in exercises, in which each individual demonstrates an ability to perform assigned emergency functions." The l licensee's Plan further states. "For employees with specific assignments or authorities as members of emergency teams, initial training and annual retraining programs will be provided. Training must be current to be maintained on the site Emergency Team P.oster."

Contrary to the above the licenste failed to provide a program which included an opportunity for each individual assigned to the on-site emergency response organization to participate in a drill or exercise, as follows:

PREDECIsI0t%L ENFORCEMENT INFORMATION NOT FOR PUBLIC F.ELEAsE W/0 APPROVAL OF DIRECTOR. OE

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ENFORCEMENT ACTION 8-l WORKSHEET

1. In 1994, the licensee failed to provide training for 17 positions (approximately 92 individuals) identified as part of the on-site response organization. In 1995, the licensee failed to provide training for 8 positions (approximately 54 individuals) identified as part of the on-site response organization.

2. The licensee's training program failed to include initial periodic retraining. or information on revisions with respect to certain procedures required to be implemented by several identified positions. These procedures included EPIP 3100026E. Criteria for Conduct of Evacuation: EPIP 3100027E. Re-entry; and EPIP 3100035E.

Offsite Radiological Monitoring.  ;

3. For the calendar year 1995, the licensee failed to remove from the l emergency response organization 4 individuals who had not completed j l retraining as' required, and their training qualifications had expire in 1994. The licensee failed to remove 6 individuals from the emergency response organization effective October 6.1996, who had not remained qualified to fill response team requirements as a result of allowing their respirator qualifications to lapse.

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d PREDECIs!0NAL ENFORCEMENT INFORMATION NOT FOR PUBLIC RELEASE W/0 APPROVAL OF DIRECTOR, OE