ML20247F342
| ML20247F342 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 09/11/1989 |
| From: | Helwig D PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8909180142 | |
| Download: ML20247F342 (8) | |
Text
.
f4 f
-10 CFR'21201.
~F
- g 10'CPR 2.205
~
PHILADELPHIA ELECTRIC COMPANY n
l.[
NUCLEAR GROUP HEADQUARTERS j
1
' 955-65 CHESTERBROOK BLVD.
q
{
WAYNE, PA 19087-5691 (215) 640-6650 DAVID R. HELWIG viCs PRESioEnr NUCLE AR SERVICES September 11, 1989 Docket Nos.
50-352 50-353 License Nos.
NPF-39 NPF-85 Director Office of' Enforcement
'.U.S.
Nuclear Regulatory-Commission Attn:
Document Control Desk Washington, DC 20555
SUBJECT:
Limerick Generation. Station, Units 1 and 2 Reply to a Notice of Violation and Remittance of.
Civil Penalty - NRC Inspection Report No. 50-352/89-11 and 50-353/89-17
Dear Sir:
Attached is the Philadelphia Electric Company's (PECo's) response to the August 10, 1989 NRC letter that transmitted the
" Notice of' Violation and Proposed Imposition of Civil Penalty -
$75,000 (NRC Inspection Report No. 50-352/89-11 and 50-353/89-17)"
for emergency preparedness violations at Limerick Generating Station (LGS), Units 1 and~2.
During a May 22-26, 1989 inspection, the NRC identified two apparent violations of NRC requirements.
These apparent violations were described in NRC Combined Inspection Report No. 50-352/89-11 and.50-353/89-17, transmitted by NRC' letter dated June'21, 1989.
As a result of the inspection, immediate remedial corrective actions were taken as described in our letter dated May 26, 1989.
In addition, PECo management directed that a management root cause assessment be performed to determine the cause of these violations.
8909180142 890911 PDR ADOCK 05000352 Q
PDC 0
W 0
/
om670#
g fy$,gyMI g!!!
(-_
U.S., Nuclear, Regulatory Commission
-September 11, 1988
^ * ~
Page 2
.4 On' July 6, 1989, an enforcement conference was held at
- the NRC Region I office between PECo and NRC representatives, at which time the results of the management root cause assessment were presented.
The attachment to this' letter provides a restatement of the violations and the PECo response to each violation.- A check in-the amount of seventy-five thousand dollars for payment of the imposed civil penalty is also remitted by thin letter, and is enclosed.
If you have any questions, or require additional information, please do not hesitate to contact us.
Very truly yours, 3 {
Attachment Enclosure cc:
W. T. Russell, Administrator, Region I, USNRC T. J. Kenny, USNRC Senior Resident Inspector, LGS
l;(,
s i
'*^
. Attachment V
' REPLY TO A NOTICE OF VIOLATION
't Restatement of the Violations
,a
'During.an NRC inspection conducted on May 22-26, 1989'and June
-7,fl989, violations of NRC requirements were identified.
In accordance with-" General Statement.of Policy and Procedure for NRC Enforcement Actions,".10 CFR Part 2, Appendix C, the Nuclear.
~ Regulatory-. Commission proposes to impose a civil penalty
. pursuant to Section.234 of the Atomic Energy Act, as amended-
-(Act), 42.U.S.C. 2282-and 10 CFR 2.205.
The particular violations and civil penalty are set forth below.
[
A.
10 CFR 50.54(q) requires'a licensee to follow and maintain
'in effect emergency plans which meet the standards of 10 CFR~50.47(b) and Appendix E of this part.
Specifically,
' Appendix E.IV.B (Assessment Actions) requires, in part, that emergency action' levels are to be used for determining
+
lwhen and what; type of. protective measures should be considered'within and outside the site boundary to protect the public's health and safety.
Contrary to the above, during walk-through-drills conducted in May~1989' designed to test the licensee's ability to
- recognize and classify emergency conditions, certain licensee personnel could not adequately utilize the
' Emergency Action' Level (EAL) Event Classification guides to
. classify certain types of accidents.
Specifically, four of
.'the five shift superintendents, who are designated as Interim Emergency Directors during an emergency, could not adequately classify certain types of fast breaking severe 4
accidents nor make appropriate Protective Action
_ Recommendations (PARS).
B.
10 CFR Part 50, Appendix B, Part XVI Requires, in part, that measures be established to assure that conditions i
adverse to quality, such as deficiencies, are promptly identified and corrected.
Contrary to the above, at the time of the inspection in May
'1989, deficiencies had not been corrected which were identified by the licensee's Nuclear Quality Assurance Department audit performed in November 1988, pursuant to the requirements of 10 CFR 50.54(t) (including inadequate
. staffing, no task analysis of emergency preparedness program, quality of training and quality of the emergency exercise program).
These deficiencies were previously identified in 1986 and 1987 audits by the same group and
. adequate. corrective actions had not been taken.
i.
r a
Page 2 These violations are classified in the aggegrate as a p
Severity Level III problem.
(Supplement VIII)
Cumulative Civil Penalty - $75,000 (assessed equally among the violations)
Response to Violations Admission of Alleged Violations Philadelphia Electric Company acknowledges the violations as stated.
Reason for the Violations Historically, PECo has demonstrated the ability to properly assess emergency action levels (EALs) and make the appropriate protective action recommendations (PARS) during our emergency exercises.
The scenarios utilized during these emergency exercises have escalated slowly, rather than being fast breaking in nature.
Therefore, there was time to activate the Technical Support Center (TSC), and consequently the TSC personnel'were in place to assess the changing emergency conditions at the emergency escalated.
On-shift Emergency Response Organization (ERO) personnel initially assume both control room and TSC responsibilities in responding to an emergency until the TSC is activated.
As a result of utilizing slow breaking scenarios, on-shift ERO personnel would only exercise those TSC related functions (i.e., EALs and PARS) during the early stages of the emergency exercise, and were generally not involved in assessing EALs and making PARS as the emergency condition escalated since these functions were carried out by TSC personnel.
The site Emergency Preparedness (EP) group staff had previously identified the need to conduct mini-drills so that shift superintendents who serve as the immediate response Emergency Director (ED) and on-shift individuals responsible for dose assessment could practice assessing EALs and making appropriate PARS during rapidly escalating emergency scenarios.
The identified need to conduct mini-drills, along with the recurring EP deficiencies cited in Violation B, were not effectively resolved for the reasons specified below.
The explanation given below applies to both violations.
As a result of the May 22-26, 1989 inspection, PECo management directed that an in-depth management root cause assessment be performed to determine the causes of the EP program deficiencies, including the' identified violations.
This root cause assessment was conducted, and the results were presented to the NRC by PECo representatives at an enforcement conference held on July 6, 1989.
The causes of the recurring EP deficiencies were determined to be the result of several programmatic weaknesses in the PECo EP program.
In summary, this root cause assessment concluded that a
Page 3 lack of effective. management attention had the most significant adverse impact on the effectiveness of the EP program.
Senior Nuclear Management was made aware of deficiencies that existed in the EP.ptcgram as well as the need for enhancements; however, a lack of self-assessment by management prevented 1) repetitive programmatic deficiencies from being effectively resolved, and 2) needed enhancements from being implemented in a timely manner.
Additional contributing factors to these deficiencies remaining unresolved were a) poor problem identification, b) non-existent or weak root cause analysis, c) inadequate formalized action plans, and d) the absence of follow-up.
These factors ultimately resulted in a decrease in the effectiveness of the EP program.
Corrective Actions Taken and Results Achieved The corrective actions taken for each violation and the results achieved are described below.
The implementation of these corrective actions have been effective in restoring the adequacy of our emergency response capabilities.
Violation A LGS management instituted the immediate corrective actions specified in our letter dated May 26, 1989, as a result of the identification of inadequacies by the NRC inspector at the exit interview on May 25, 1989.
The implementation of these immediate corrective actions reestablished the adequacy of the emergency response capabilities of LGS personnel.
Remedial training was conducted for shift superintendents who serve as the immediate response ED and on-site individuals responsible for dose assessment.
These individuals were not permitted to resume their on-shift duties until they l
satisfactorily passed this training and demonstrated proficiency in I
assessing EALs and determining appropriate PARS, and understanding
{
the relationship between EALs and PARS.
On May 26, 1989, the NRC resident inspector conducted an inspection of the remedial training sessions and verified in NRC Inspection Report No. 50-352/89-10 and 50-353/89-16 that the immediate actions specified in our May 26, 1989, letter were satisfied.
4 I
In addition, subsequent " table-top" training sessions were conducted l
for shift superintendents who serve as the immediate response ED, those individuals assigned as the TSC ED, and on-shift individuals l
performing dose assessment.
On June 7, 1989, the NRC EP inspector I
audited one of these " table-top" training sessions as documented in NRC Combined Inspection Report No. 50-352/89-11 and 50-353/89-17.
i The inspector concluded that the training content was. appropriate and was well conducted and received.
The " table-top" training sessions were subsequently completed on June 9, 1989.
l l
l
\\
n-____.
Page 4 Violation B As a result of the identified EP deficiencies, PECo management undertook serveral actions, both immediat9 and intermediate in term.
On June 5, 1989, a senior engineer was assigned the responsibility of overseeing site EP activities at LGS.
He will remain in that position at least until known outstanding problems with the EP program have been addressed.
During his tenure, he vill report directly to senior site management.
In addition, a management root cause assessment was conducted to determine the cause of these violations.
A number of corrective actions have been already taken to address some of the root causes identified by the management root cause assessment, which in turn resolve many of the items previously identified during reviews conducted by the PECo Nuclear Quality Assurance organization.
The LGS site EP group staff has been increased by adding a Technical Assistant, Senior Reactor Operator (on loan from the plant Operations Department), and a clerk.
A new ERO training program is being developed, which will be implemented in January, 1990, and is based upon analyses of the tasks performed.
Procedures are being revised to make them more user friendly.
The surveillance test program for emergency response equipment is being reviewed and necessary procedure revisions / deletions are being performed.
Finally, a performance based mini-drill program for ERO personnel has been implemented at LGS.
Corrective Actions Taken to Avoid Future Non-Compliance The corrective actions taken to avoid future non-compliance for each of the violations are described below.
Violation A Simulator exercises designed to demonstrate the interface between plant conditions, EALs, and PARS has been integrated into the EP training program for shift superintendents and shift supervisors, who function as the immediate response ED.
These individuals will initially receive this training and the frequency of subsequent training will be based Jpon demonstrated performance.
Based on the experience gained from the walk-through exercises conducted by the NRC, a mini-drill program has been instituted for individuals that function as the TSC ED, Emergency Operat< ions Facility (EOF) Emergency Response Manager (ERM), and the TSC/ EOF Dose Assessment personnel.
This program will ensare that these individuals are proficient in assessing EALs and making appropriate PARS.
A new training program has been instituted for the position TSC ED and EOF ERM.
This training program includes a requirement for a
- f. z i
Page 5:
formal.eight:(8)Lhour training session and completion of out-of-class assignments prior to training session attendance.
The affected individuals will' complete this~treining during the last quarter of 1989.
m Violation B
.These/ corrective actions to prevent future non-compliance also address pertinent causes for Violation.A.
A~new director-of'the Corporate EP Section was appointed'on August
.15, 1989.. This individual has extensive experience in managing a nuclear utility EP program.
In addition, the site EP groups now report'at a higher level within.the organization.
PECoihas issued Corporate and Nuclear Group EP Policies which establish clear expectations for readiness, staffing, performance, accountability, and-self-assessment for the EP program.
A long term EP program management plan is being developed which is based on the recommendations resulting from the management root cause assessment.
In' addition, this long term plan will address.
numerous other' concerns identified by a group comprised of
' individuals who are familiar with the PECo EP program.
This long
. term plan will focus on six (6) major areas necessary to ensure the maintenance of an effective EP program.
Specifically, this plan
' focuses on self-assessment / corrective' action, drills and exercises, ERO personnel selection / qualification / training, emergency response facilities and equipment, emergency response off-site interface, and EP plans and procedures.
Date When Full Compliance Will Be Achieved With regard to the specific violations, full compliance has been achieved.
The training specified in our May 26, 1989 letter, has been completed and has restored the capability of on-shift ERO
. personnel to properly classify rapidly changing accidents and make appropriate PARS.
As a result of the management root cause assessment, the EP program now receives the necessary management attention to maintain EP program effectiveness and prevent recurrence of these violations.
I 1
e i
j.[.
'je;..'.
. c-
- COMMONWEALTH.0F PENNSYLVANIA
-t-
~
L 4
ss.
CHESTER~ COUNTY D. R.=Helwig, being.first duly.~ sworn, deposes and says:
t That he is Vice President of Philadelphia Electric. Company,
=and that he has read the attached Reply to a Notice of-Violation
.'for Limerick Generating! Station, Units 1 and;-2 and knows the contents thereof; andithat the statements and matters set forth therein a're true and correct'to the best-of his knowledge, information and belief.
O Q
Vice Presid n
Subscribed and sworn'to before'me this//~r k day of 1989.
h w d6 a A
, 8 8
' Notary Public NOTARIAL SEAL =
ANGELA G. OLENGINSKI. Notary Public i
. Wayne, Chester County 1
- My Commesion Expires Sect 31.1992 l
l l'
l t
r