ML20140E652

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Informs That D Barss Will Be e-mailing Input on Items 5 & 6 for Incorporation Into EA Worksheet
ML20140E652
Person / Time
Site: Saint Lucie  NextEra Energy icon.png
Issue date: 11/07/1996
From: Kreh J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To: Boland A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20140E502 List:
References
FOIA-96-485 NUDOCS 9704290069
Download: ML20140E652 (8)
v • d • e


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8 0.'22 From:

James Kreh,%bl Ajile ATB /) one.

E 9-To:

y Date:

11/7/96 2:46pm

Subject:

ST. LUCIE EAW As we discussed, Dan Barss will be E-mailing his input on items 5 and 6 to you for i.ncorporation into the EAW. Feel free to call me at home tomorrow if you just can't figure it out. Good luck!

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9704290069 970423 PDR FOIA BINDER 96-485, PDR

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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.

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Signature Facility:

St. Lucie Plant Units:

1&2 Docket Nos.:

50 335, 50 389 l

License Nos.:

DPR 67, NPF 16 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 l

On the evening of October 3. 1996, the licensee conducted a test of its automated system known as the FPL Emergency Recall System (informally called " autodialer") for notifying the emergency response organization (ERO) in the event of an off-hour emergency requiring augmentation of the on-shift crew for staffing and activation of emergency response facilities (viz., Technical Support Center [TSC]. Operational Support Center [05C].

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-l out over an indeterminate period (at least the last several years). These concurrent deficiencies represent a failure (during the period July 22-i i

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.

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PREDECISIONAL ENFORCEMENT INFORMATION NOT FOR PUBLIC RELEASE W/0 APPROVAL OF DIRECTOR. OE i

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ENFORCEMENT ACTION 2-

, WORKSHEET 4

Violation S 1

The licensee's training program for ERO personnel has not been adequately i

implemented since at least 1994.

This violation includes failure to 1

provide opportunities for most persor '

to participate. in exercises -

and/or drills, failure to provide annua :etraining to certain designated i

1 3ersonnel in 1994 and 1995, failure to provide any training.for certain ERO positions with respect to ' selected implementing procedures, and i

failure to remove individuals from the ERO roster when their respirator l

qualifications had lapsed.

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2.

Analysis of Root Cause:

The root cause of both violations is failure of licensee management to I

(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 - Emeraency Preoaredness. SL III I

Section C.3 of Supplement VIII presents as an example, " Violations involving... a breakdown in the control offlicensed 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?

No Violation A Date licensee was aware of issues requiring corrective action:

October 3. 1996.

This identification credit /date applies only to the autodialer inoperability portion of the violation. The problem with the manual call-out system was NRC/CI-identified.

PREDECISIONAL ENFORCEMENT INFORMATirN NOT FOR PUBLIC RELEASE W/0 APPROVAL OF DIRECTOR, OE

ENFORCEMENT ACTION i WORKSHEET Explain application of identified credit, who and how identified and 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 Coordinator as early as April 1996), autodialer inoperability would have almost certainly have been precluded. An autodialer problem (limited in scope--not a complete system failure) also occurred during the NRC-evaluated June 1993 exercise, but corrective action for that pro W m was clearly not sufficiently comprehensive.

6.

Corrective Action Credit?

No Violation A Administrative controls have been imelemented for the autodialer under Protective Services Department Guideline No. PSG-015. " Maintenance and Testing of the Emergency Recail 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 distribution list. and a drill was conducted on October 10, 1996 with reasonably successful results, Application of corrective action credit:

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

N olation B 7.

Candidate For Discretion? No Licensee's performance in emergency preparedness is now recognized to have been particularly poor during the past 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:

PREDECisIONAL ENFORCEMENT INFORMATION NOT FOR PUBLIC RELEASE W/0 APPROVAL OF DIRECTOR OE

ENFORCEMENT ACTION 4-

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I WORKSHEET i

i OTHER FINDINGS FROM THE OCTOBER 1996 EP PROGRAM INSPECTION l

' Violation Failure to establish an Emergency Plan Implementing Procedure (EPIP), or l

to have an adequate EPIP. with appropriate implementing details to address l

certain ' aspects of the Radiological Emergency Plan as follows:

L a.

the transfer of OSC functions to an alternate location in the event

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l that evacuation of the primary OSC is required (EPIP-3100032E, "On-site Support Centers", contains no implementing details for the l

. statement in Radiological Emergency Plan Section 2.4.4 that "In the event that the OSC becomes untenable, the Emergency Coordinator will P

designateanalternatelocation.")(inadequateprocedure),and l

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b.

recovery activities upon reaching a stable plant condition following an emergency (Radiological Emergency Plan Section 5.4)

{no procedure}.

Emeraency Preoaredness Proaram Weaknesses i

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Inadequate program of drills to ensure availability of sufficient ERO personnel and timeliness of ERF staffing l-2.

Management failure to ensure the implementation of timely corrective actions for certain emergency preparedness deficiencies and i

weaknesses.

Examples are:

a.

failure' to address concerns regarding the audibility of tne 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 questionable capability for notification of the State of Florida within 15 minutes of an emergency declaration (identified by an NRC inspection in February 1995), and c.

failure to implement timely corrective actions for deficiencies and recommendations identified by the critique of the Hurricane Erin response in August 1995 (examples of l

issues: identify hurricane-safe structures onsite and a plan

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l for positioning personnel in those structures; designate an l.

onsite individual to monitor the hurricane path; establish consistent staffing policies)

I 10.

This Action is Consistent With the Following Action (or Enforcement i

Guidance) Previously Issued:

Supplement VIII. Section C.3 i

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

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_o ENFORCEMENT ACTION 5-4 5

WORKSHEET 11.

Regulatory Message:

Management must provide strong and consistent oversight and support for emergency preparedness activities in order to ensure a viable emergency response capability at all times.

12.

Recommended Enforcement Action:

Two SL'IV violations evaluated in the aggregate as a SL III violation 13.

Should This Action Be Sent to OE For Full Review? No 14.

Exempt from Timeliness:

No Basis for Exemption: N/A Enforcement Coordinator:

DATE:

j PREDECIsIONAL ENFORCEMENT INFORMATION. NOT FOR PUBLIC RELEASE W/0 APPROVAL OF DIRECTOR, OE

d ENFORCEMENT ACTION 6-i WORKSHEET DRAFT NOTICE OF VIOLATION 1

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 1

Emergency Coordinator in the event of an Alert, Site Area Emergency, or General Emergency, and that arrangements have been made to staff the TSC 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 implemented by procedure EPIP-

3100023E, "On-Site Emergency Organization and Call Directory",

Revision 72.

The instruction in Section 8.2 of that procedure states l

that, upon the declaration of an emergency classification, "the Duty Call l

Supervisor will initiate staff augmentation" using the " Emergency Recall l

System or Appendix A. Duty Call Supervisor Call Directory to notify l

persons..."

l Contrary to the above, from approximately July 22 to October 3,1996, l

arrangements were not available to staff or activate the TSC, OSC, or EOF l

in a timely manner because the licensee did not have the ca3 ability to l

implement either the primary method (using the Emergency Recall System) or the backup method (using the Duty Call Supervisor Call Directory) for l

notifying its )ersonnel to report to the plant during off-hours to staff and activate t1e TSC, OSC, and EOF.

This is a Severity Level IV violation (Supplement VIII)..

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. 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 1

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 Roster."

Contrary to the above, the licensee failed to provide a program which 3

included an opportunity for each individual assigned to the on-site emergency response organization to participate in a drill or exercise. In PREDECIsIONAL ENFORCEMENT INTORMATION NOT FOR PUBLIC l

RELEASE W/0 APPROVAL OF DIRECTOR, OE

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ENFORCEMENT ACTION s i

WORKSHEET.

j 1994.

the licensee failed to provide training for 17 positions I

(approximately 92. individuals) identified as part of the on-site response i

organization.

In 1995, the licensee failed to. provide training for 8 positions (approximately 54 individuals) identified as part of the on '

site res)onse organization.

The licensee's training program failed to include initial or periodic retraining on certain procedures required to-be implemented by several identified positions.

In 1995. the licensee failed to remove from the emergency response organization 4 individuals who had not comaleted retraining as required.

The licensee failed to remove 6 indivicuals 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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This is a Severity Level IV violation (Supplement VIII).

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j PREDECIsIONAL ENFORCEMENT INFORMATION NOT FOR PUBLIC RELEASE W/0 APPROVAL OF DIRECTOR, OE l

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