ML20151K967
| ML20151K967 | |
| Person / Time | |
|---|---|
| Issue date: | 06/18/1985 |
| From: | Jordan E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20151K612 | List:
|
| References | |
| FOIA-87-866 NUDOCS 8506260707 | |
| Download: ML20151K967 (5) | |
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MEMORANDUM FOA: Robert D. Martin i
Regional Administrator Region IV THRU:
James M. Taylor, Director Office of Inspection and E orement l
/
FROM:
Edward L. Jordan, Director f
Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement
SUBJECT:
_ REGIONAL ASSESSMENT _OF EMERGENCY PREPAREDNESS PROGRAM ACTIVITIES - FY 85 l
5,ECT10N I - SCOPE The FY 1985 assessment plan for evaluating regional implementation of the emergency preparedness (EP) program activities concentrated on two areas:
(1) inspection of emergency preparedness exercises for near-tenn operating license (NTOL) reactors and (2) emergency preparedness exercise exemption requests.
Regional performance in these areas was evaluated in accordance with the assessment program factors transmitted in my nemoranda dated December 28, 1984 and March 1, 1985. The assessment consisted of a review of program docu-mentation and a trip to the regional office to obtain additional information and to interview regional personnel.
SECTION !! - ASSESSMENT ACTIVITIES Preliminary activities of the Emergency Preparedness Branch for the NTOL i
exercise program included the selection of a representative preoperational i
exercise conducted during the assessment period (for Region IV, the Wolf Creek exercise) and a review of the Wolf Creek inspection Report No. STN 50-482/
84-47, IE Office Procedure 0200 and IE Inspection Procedure 82301. The assess-ment trip to Region IV took place on March 12-13, 1985. Discussions were held with members of your staff concerning the Wolf Creek exercise inspection effort and a review of the Battelle contractor's exercise report was conducted.
In addition, discussions were held and correspondence reviewed with regard to exercise exerption requests for Fort St. Vrain and Cooper.
An exit interview was held on March 13, 1985 with regional management to discuss the assessment
- findings,
Contact:
D. J. Perrotti, IE 492-4871 - -
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i WN 161565 Robert D. Martii. '
SECTION !!! - ASSESSMENT FINDINGS I
This section is organized in two parts, one for each of the program areas described above.
Regional performance in each of the assessment areas was evaluated for completeness, adequacy, and consistency.
Equal emphasis was r
placed on positive and negative findings in a sunrnary form, j
A.
Inspections of EP Exercises for NTOL Reactors l
The assessment consisted of a review of the preoperational emergency preparedness l
exercise conducted on November 7, 1984 at the Wolf Creek Generating Station.
l 1.
Program Completion Factors 1
Inspection procedure Completion - The inspection procedure was closed at i
essentially 100'4 complete. Open items identified in the inspection report are to be evaluated during the next emergency preparedness exercise.
Tirely Issue - The inspection report was issued in 77 days, which represents a l
significant delay. The region has a report tracking system that can identify delays in report processing; however, because of a staff vacancy, emphasis was placed on field inspections at the expense of documentation. This staff vacancy in the Energency Preparedness Section has now been filled.
1 1
2.
Performance Adequacy Factors Scope - The scope of the inspection activity was consistent with that pre-scribed in IE Inspection Procedure 82301.
Depth - The technical depth of the inspection was consistent with the inspec-tion procedure.
i 1
i Focus on Safety issues - No imediate safety issues were identified by NRC as a l
result of the emergency preparedness exercise evaluated.
j Resource Utilization - Regional and contractor resources were effectively used.
The inspection was a team effort involving one NRC regional, one NRC head-j quarters, and six contractor personnel. An adequate level of experience and j
qualification was represented on the team.
)
i Docurentation and Correspondence - The exercise inspection report in-general followed the format and organization of IE. Inspection Procedure 82301. However, i
the report lacked details on the inspection team's evaluation of an important j
emergency preparedness area, the applicant's capability to assess a general emergency condition and provide prompt protective action recomendations to offsite authorities. The contractor's exercise report to Region IV indicated j
certain negative findings in the applicant's assessment capability and j
decisionmaking process; however, these findings were not reflected in the j
final inspection report. Regional management observed that it is the pre-l rogative of the Region IV team leader to assess the relative importance of I
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l Pc:t rt D. Martin 3
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i the team's findings and in this case it was the judgmant of the team leader not to enphasize these particular erergency preparedness areas in the inspection report.
A sampling of previous preoperational emergency preparedness exercise reports
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was done to determine any trend in report details.
From a review of the exercise reports for Waterford 3 (February 8,1984), Comanche Peak (November 14, f
1954), and Wolf Creek, it was noted that there was a definite trend to reduce report details on control room operator actions, and TSC and EOF activities such as ass' :smnt, decisionmaking, and prompt notification and recomendation of prctective actions to offsite authorities. Regional managerent stated that more succinct inspection reports consistent with MC 0610. "Inspection Reports," are a regicnal objective, t
The Wolf Creek exercise report was inconsistent with regard to the terminology l
used to present exercise findings and to identify those findings requiring followup evaluation.
Region IV indicated that corrective action is being taken to ensure that exercise report findings are documented consistent with reju-latory requirements and guidance. The regional staff exprcssed a concern that additional guidance is needed from the O!E program office in the documentation of exercise findings and in report content for emergency preparedness inspec-tion activities.
l Applicant Contacts - Meetings and c r,tects between the applicant and inspection i
team were in accordance with established policies, f
8.
Emergency Preparedness Exercise Exemption Requests 4
Exercise exemption request packages fer Fort St. Vriin and Cooper were reviewed, i
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1.
Program Completion Factors l
When Required - Reviews were conducted on a timely basis, j
Timely Issue of Documentation - In the Fort St. Vrain case, there was some delay in processing the exemption package because the licensee submitted a I
supplemental request for postponerent of its exercise from July to August 1984 in order to take advantage of the irpending rule change which revised the i
requirements related to exercise frequency.
The rule went into effect on i
August 6,1984.
The Fort St. Vrain exemption activity at the region.was closed j
out by memorandum on July 30, 1984, i
l In the Cooper case, the exemption package was processed and fomarded to NRR 4 days after an extended due date. The documentation was considered to be within an acceptable tireframe.
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JUN 1819M.
Robert D. Martin i 2.
Performance Adequacy Factors Scope - The scope of the reviews was consistent with that prescribed in the Februa ry 21, 1984 memorandum, "Exercise Frequency Exemption Requests," and the April 24, 1984 memorandum, "Exercise Exemption Requests."
Depth - The technical depth of the reviews was consistent with that prescribed by the above referenced memoranda.
Resource Utilization - Regional resources were effectively used.
Documentation and Correspondence - Documentation was consistent with program requirements and provided a clear record of review.
SECTION IV - ASSESSMENT CONCLUSIONS The results of the assessment of Region IV implementation of the preoperational exercise inspection program and the processing of exercise exemption requests indicate a satisfactory level of implementation for these EP program areas.
The areas selected for review were of limited scope; therefore, conclusions drawn are confined to the one preoperational exercise and two exercise exemp-tion requests selected for review.
With respect to the preoperational exercise inspection program, it is reconinended that the region:
A.
Complete its plans to standardize the tems used to report exercise findings so that they are consistent with regulatory requirements ano guidance.
B.
Ensure that exercise reports contain sufficient detail on emergency preparedness functional areas (e.g., assessment, decisionmaking, and prompt notification and recorrendation of protective actions to offsite authorities) to support an NRC finding regarding the applicant's imple-mentation capability.
C.
Expedite the issuance of exercise reports.
The filling of a staff vacancy in the Emergency Preparedness Section is expected to assist in this regard.
rd L. Jordan, Director ivision of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement cc:
see page 5
g JUN 181;er.
~
Robert L. Martin,
cc:
R. H. Vol 'i rre r, I E J. 6. Partlow, IE B. K. Grimes, IE
- 5. A. Schwartz, IE D. B. Matthews, IE K. E. Perkins, IE F. rantor, IE C. R. Van Niel, IE D. J. Perrotti, IE D. M. Rohrer, IE W. L. Fisher, IE E. W. Brach, ED0
_