IR 05000244/1986012

Emergency Preparedness Insp Rept 50-244/86-12 on 860826-29. Violation Noted Re Ability to Fully Staff & Augment Emergency Response Organization in Timely Manner

ML20215H049
Person / Time
Site:	Ginna
Issue date:	10/09/1986
From:	Conklin C, Lazarus W, Thomas W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20215H040	List: IR 05000244/1986012 ML20215H039
References
50-244-86-12, NUDOCS 8610210389
Download: ML20215H049 (7)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /86-12 Docket N License N DPR-18 Priority -

Category -

Licensee: Rochester G:s & Electric Corporation 49 East Avenue Rochester, New York 14649 Facility Name: R. E. Ginna Nuclear Power Plan Inspection At: Ontario and Rochester, New York Inspection Conducte - August 26-29, 1986 Inspectors: . W W.~ Thomas, TeamM 4ader, EPS, EP&RPB

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'dat/e DRSS, RI, N C

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C. Conk)in, EP Specialist, EPS dr/n date Approved by: h /4 9 [$

V. .)# Lalaffs, Chief, Emergency date PreparedneYs Section, DRSS, RI, NRC Inspection Summary: _

Inspection on August 26-29, 1986, (Report N /86-12)

Areas Inspected: Routine announced emergency preparedness irspection to follow-up on licensee action regarding findings identified during previous emergency preparedness inspections and exercises, and the examination of the licensee's emergency preparedness program related to: shift staffing and augmentation; knowledge and performance of duties (training); public information program; licensee audits; and administration of the emergency preparedness program.

. Results: One violation concerning the ability to fully staff and atgment the emergency' response organization in a timely manner was identified by the license PDR ADOCK 05000244 G PDR

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Details Persons Contacted

• • D. Burke, Corporate Emergency Planner

• • B. Snow, Superintendent of Nuclear Production

• B. Quinn, Corporate Health Physicist

• P. Wilkins, Manager of Nuclear Engineering & Licensing R. Morrill, Training Manager

• • R. Kober, Vice President Electric & Steam Production J. Jennejahn, Alternate News Center Manager

• • S. Spector, Plant Superintendent

• denotes those at the' exit interview on August 29, 198 ** denotes those present at the September 11, 1986 meetin . Follow-up on Previous Inspection Findings (Closed)(81-21-02): Several procedural deficiencies exist in SC-1.1A Ginna Station Event Evaluation, and Classificatio The Site Contingency procedures have been completely revised and renum-bered. Emergency classification is now contained in SC-100, Ginna Station Event Evaluation and Classification; SC-201, Unusual Event; SC-202, Alert; SC-203, Site Emergency; and SC-204, General Emergency. All procedures are reviewed by Quality Assurance prior to the review by the Plant Operating Review Committee (PORC). Administrative Procedure A-205 covers review, revision, and distribution of the Plan and Procedures. The inspector re-viewed current copies of the Implementing Procedures and found no deft-ciencies affecting classificatie As a result of the above findings, this item is close (Closed) (81-22-26): Evaluate the need for maintaining a supply of se-lected damage control and corrective action equipment and supplies, and for positioning the same so that it will be accessible for use during emergencie The inspector reviewed the licensee's evaluation of this item and deter-mined that the actions taken are appropriate. SC-312, Manning the Opera-tional Support Center, dated June 5,1983, assures that appropriate personnel for performance of corrective actions are available to the Plant Assessment Manager. SC-235, Repair and Corrective Action Guidelines Dur-ing Emergency Situations, dated July 12, 1983, Section 3.7 instructs the Plant Maintenance Assessment Manager to determine with the Repair / Corrective Action Team members involved, the tools, spare parts, or equipment needed for the corrective action including where they can be obtained. Since Repair / Corrective Action Team members are drawn from the normal plant maintenance staff they will have ready and knowledgeable ac-

, cess to any equipment and supplies needed during an emergency for repair / corrective action .

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As a result of the above findings, this item is close (Closed) (81-22-35): Link offsite dose projections to EPA recommended protective action guide The inspector reviewed SC-420, Estimating Offsite Doses, dated June 21, 1985, and determined that offsite dose projections are in accor-dance with EPA-520, Manual of Protective Action Guides and Protective Ac-tions for Nuclear Incidents, dated February 198 As a result of the above finding, this item is close (Closed) (81-22-57): Revise existing procedure SC 1.148 to include spe-cific and detailed instructions for establishing the rescue team, communi-cations, radiation protection equipment, and interface with offsite medical treatment facilitie This item was reviewed in Inspection Report No. 85-11, dated August 18, 1986. Procedure SC-1.14B has been rewritten as SC-233, Search and Rescue Operation. The inspector also reviewed Revision No. 4, dated October 16, 1984, and concurs that the initial concerns have been ade-quately addresse As a result of the above findings, this item is close (Closed) (84-08-05): ' Amend the Ginna Technical Specifications to include

" Meteorological Monitoring" which is a safety related' program. The stan-dard limiting conditions for operation and surveillance requirements for this program are shown in NUREG-9452, " Standard Technical Specifications for Westinghouse Pressurized Water Reactors".

The inspector reviewed the licensee's response to this item in a letter to Thomas T. Martin, dated July 20, 1984, and determined that the response is appropriate. The NRC's Safety Evaluati'on report, dated September 28, 1983, concludes that the Ginna provisions for the Radiolog-ical Effluent Technical Specifications. (RETS) as implemented by Technical Specification Amendment No. 57, including the meteorological monitoring program, meets the requirements of 10 CFR 50 Appendix I and NUREG-0472 Rev. 2, dated February 1, 1980. The inspector agrees that the meteorolog-ical monitoring instrumentation is not required to be incorporated into the Ginna Technical Specification As a result of the above findings, this item is close (Closed) (84-08-08): Include a procedure for implementing the currently available, refined dose model and describe the technical bases and justi-fication used for selection of the MIDAS dose assessment mode The inspector reviewed the licensee's actions taken in response to this open item, as described in a letter to Thomas T. Martin, dated September 10, 1984 and determined that the actions and response are appropriate. This item is closed.

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(Closed)(84-28-01): The inspectors noted that no written tests were give to determine if personnel had attained the level of knowledge necessary to perform the assigned emergency dutie The inspector reviewed Section 7.0 of the Emergency Plan, Maintaining Emergency Preparedness, and Administrative Procedure A-103.8, which con-tains details of the training progra In addition, selected emergency plan training program lesson plans, class attendance records, and exams were reviewed. The inspector noted that written exams are now required to demonstrate the attained level of knowledge necessary to perform the as-signed emergency dutie As a result of the above findings, this item is close (Closed)(P3-20-01): There was some question as to the required event classification regarding the ATWS among control room operator SC-100, Gf nna Station Event Evaluation and Classification, Rev. 7, dated January 6, 1986 was rewritten to include ATWS events. Additionally all control room operators have received training.on this procedure and have demonstrated proficiency in classifying ATWS event As a result of the above finding, this item is close . Shift Staffing and Augmentation The licensee's program was examined to determine its adequacy'in regard to

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the staffing of key emergency positions (depth of personnel) and the time-liness of augmentation of emergency response personnel. The following documents were reviewed: SC-600, Emergency Plan Qualification and Notifi-cation; ESP 2/1, Nuclear Emergency Offsite Response Corporate EOF / Recovery Manager Checklist; ESP 16/4, Nuclear Emergency Offsite Response EOF /Re-covery Center Continuous Manning: ESP 4/1, Nuclear Emergency Offsite Re-sponse Nuclear Operations Manager Checklist; ESP 5/1, Nuclear Emergency Offsite Response EOF Dose Assessments Checklist; and Off Hours Telephone-Alert Test of August 9, 198 A review of key positions in the TSC and EOF revealed that there were at least two people assigned to each position. However, many people were jned to more than one positio Specific examples include: the pri-f Plant Assessment Manager is also the backup to Nuclear Assessment;

. backup Plant Assessment Manager is also the primary Plant Operations

'sessment Manager; the primary Plant Maintenance Assessment Manager is Also the backup Plant Technical Assessment Manager; the backup Plant Main-tenance Assessment Manager is also the primary to Mechanical / Hydraulic System Assessment; the primary Plant Technical Assessment Manager is also the primary Administrative Communications Manager; and the backup Recovery Manager is also the primary Nuclear Operations Manager. A review of the

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call-in procedures indicate that off-shift personnel are notified by tele-phone call-outs. There is no specified duty roster or team assignments and 'staffino is accomplished by calling individuals until someone is reached for each position. Several key positions have call-out lists that are very large and could result in unacceptable response delays for cer-tain positions. A review of the results of the Off-hours Telephone Alert Test conducted on August 9, 1986 indicated that the licensee was unable to contact most members of TSC staff and unable to contact several key mem-bers of the EOF staf Based on this performance we are concerned as to the licensee's ability to staff the emergency response organization in a timely manner. Since this item was self-identified, and short-term corrective action has been taken, it was not cited as a violation (50-244/86-12-01).

4. Knowledge and Performance of Duties (Training)

The licensee's program was examined to determine the adequacy of th3 training program and to determine if required training has been performe The following documents were reviewed: ESP 15/1, Nuclear Emergency Offsite Response Emergency Operations Facility Training Program; EOF Training Records; A 103.8, Emergency Plan Training Program; Simulator In-structor Guide Lesson Plans; and various individual onsite training record The inspectors verified that a training program is in place for onsite and offsite personnel, which includes several training modules with associated quizzes. As a result of this review it was determined that minimum train-ing requirements for each emergency response position are not identifie It was also noted that the present EOF training records system is cumber-some to use making it very difficult to verify that all required training has been performe As a result of the above review, the licensee should define the mini-mum training requirements for each EOF position and should evaluate the present training records systems to ensure that verification of required training can be accomplished (50-244/86-12-02).

5. Public Information Program The licensee's public information program was examined to determine the adequacy of information disseminated to the public and the timeliness of distribution. The following documents were reviewed: Nuclear Emergency Response Plan: R. E. Ginna Nuclear Power Plant Emergency Planning Infor-mation Calendar for Monroe and Wayne Counties; the NYNEX Telephone Direc-tory for Wayne County; and the Rochester Telephone Directory for Monroe Count The inspector determined that the information contained in the above docu-ments was correct and distributed. A call to the licensee telephone num-ber listed in the brochures provided adequate assurance that additional

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information or assistance would be provided. The licensee regularly in-terfaces with Wayne and Monroe County officials on the content and adequa-cy of the documents. In addition, the licensee has contracted with a transportation and evacuation consultant to provide continuing program updates based upon changing population and highway condition No inadequacies were identifie . Licensee Audits The licensee's program was examined to determine the adequacy of the annu-al independent audits performed. The following documents were reviewed:

Audit of Nuclear Emergency Response Plans / Procedures and related Utiliza-tion, and Audit Reports 86-23A:JB and 86-23B:JB dated July 1, 1986 with associated QA audit-checklist The Licensee QA department conducted a detailed audit of the emergency preparedness plans and procedures in May of 1986, The audit included a review of plans and implementing procedures, state and local interfaces, drills and exercises, training, personnel interviews and corrective ac-tions.taken. The QA audit is detailed, however, it failed to identify the basic staffing and augmentation problems identified during this inspectio As a result of the above review, the licensee QA audit process should be evaluated for its effectiveness in identifying deficiencies in the the Emergency Preparedness Program (50-244/86-12-03). This item is unresolved and will be reviewed in a subsequent inspectio . Organization and Management Control The licensee's program was examined to determine the adequacy of adminis-trative controls, specifically related to maintenance of emergency pre-paredness and the Corporate Emergency Planne The following documents were reviewed: Nuclear Emergency Response Plan, sections 7 and As a result of this review the inspectors determined that the Corporate Emergency Planner is responsible for the overall implementation of he onsite and offsite emergency plans and implementing procedures. Specific duties include all EOF training, EOF facilities and equipment maintenance ano drill / exercise scenario coordination. The onsite Training Manager is responsible for all onsite emergency preparedness training and documenta-tion. The Health Physics / Chemistry Manager is responsible for onsite equipment inventories and telephone checks. It was noted, however, that several of the onsite responsibilities are not delineated in the Pla Additionally, there is no formal established review protocal for the Cor-porate Emergency Planner to verify onsite actions and initiate / follow-up corrective actions due to the fact that he has no direct authority over,

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or feedback from those managers responsible for their parts of this progra As a result of the above review, the licensee should clearly establish all onsite maintenance responsibilities in the plan and evaluate a formal re-view process to ensure the Corporate Emergency Planner is cognizant of onsite actions (50-244/86-12-04).

8. Exit Meeting On August 29, 1986, the inspectors met with those individuals identified in Section 1 and discussed inspection findings as detailed in this repor ; A second meeting was held on-site on September 11, 1986 to discuss correc-tive actions for the concerns identified regarding staffing and augmenta-tion (detail 3). At no time during this inspection was written material provided to any licensee personnel by the inspector r

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