IR 05000213/1992023

Insp Rept 50-213/92-23 on 921214-18.Violations Noted.Major Areas Inspected:Ep Program Changes,Emergency Facilities, Equipment,Instrumentation & Supplies,Ep Organization & Management Control,Training & Independent Reviews/Audits

ML20128D101
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	02/01/1993
From:	Lusher J, Mccabe E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20128D044	List: IR 05000213/1992023 ML20128D040 ML20128D053
References
50-213-92-23, NUDOCS 9302100050
Download: ML20128D101 (9)

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U. S. Nucieur Regulatory Conunission Region 1 EMERGENCY PREPAREDNESS INSPECTION REPORT License / Docket / Report: DPR-61/50-213/92-23 Licensec: Connecticut Yankee Atomic Power Company P.O. Box 270 11artford, Connecticut 06101-0270

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Pacility: IInddam Neck Plant IInddam, Connecticut Dates: December 14 18, 1992 Inspectors: :] ko-J. Lusher, Emergency Preparedness Specialist

_- 02/m/93 date J. Laughlin, Emergency Preparedness Specialist O. Bryan, NRC Consultant (Comex)

Approved: b C., ._,

QlIh3 E. McCabe, Chief. Emergency Preparedness date Section, Division of Radiation Safety and Safeguards AREAS INSPECTED Emergency preparedness (EP) program changes; emergency facilities, equipment, instrumentation, and supplies; EP organization and management control; training; and independent reviews / audit RESULTS

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, Overall, the emergency preparedness (EP) program was acceptably implemented. Strengths were evident in event classification and reporting during walk-through drills, and in- the i licensee's emergency response call-in drill program. An apparent violation was identified for lack of annual Emergency Action Level training for Technical Support Managers. Also, adequacy of EP audit review / distribution and currency of the Emergency Plan were identified

as unresolved item S0 930203 PDR G

ADOCK 05000213 PDR

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DETAILS Persons Contacted The following licensee persomiel attended the December 18,1992 exit meetir: E. Annino, Staff Assistant M. Emy, Supervisor, Operator Training Connecticut Yankee P. Bauchan, Emergency Preparedness Technician G. Bouchard, Unit I;irector W. Buck, Irad Emergency Preparedness Coordinator, Haddam Neck

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L. Delvca, Senior Emergency Preparedness Coordinator J, Falier, Nuclear Tminer

- W. Gates, Radiation Protection Supervisor, Operations 3 W. Herwig, Connecticut Yankee Administration S. Hodge, Supervisor, General Nuclear Training L. Kemp, Emergency Preparedners (Sonalysts)

J. LaPlantney, Operations Manager, Connecticut Yankee C. Libby, Supervisor, Assessment Services P. Lucky, Senior Nuclear Trainer E. Maclean, Nuclear Trainer W. McCance,12ad Emergency Preparedness Coordinator, Millstone R. Rogers, Director, Emergency Preparedness Department, Northeast Utilities W. Romberg, Vice President Nuclear Operations A. Saunders, Assessment Services Auditor The inspectors also interviewed and observed other licensee personne!. Emergency Plan and Implementing Procedures The inspectors reviewed the Emergency Plan and Emergency Plan Implementing Procedures (EPIPs). There were 14 recently approved procedure changes. Eighteen morc were in review in preparation for Plant Operating Review Committee (PORC) approval. These changes reflected organizational changes, previous NRC inspection items and drill / exercise upgrade This inspection identified the following discrepancies between facility activities and the Emergency Plan and EPIP * On May 29,1992, the Training Program Control Committee (TPCC: had concluded that EAL Training Module G007 was no longer required for Technical Support Center (TSC)

Managers, and that training was deleted. That violated the requirement for such training in the Emergency Plan approved by the Plant Operations Review Committee (PORC) and by the NRC (VIO 50-213/92-23-01). (See Report Detail 5.0.)

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• Section 3 of the Emergency Plan established the training requirements foi the Emergency Response Organization (ERO). Nuclear Training Mam.al (NTM) 3.212, Revision 3d, 8/15/91, defined the training to be conducted. The training matrices in Section 8 of the plan and NTM 3.212 differed. For example, Directors of Station Emergency Operations and the senior on shift operators were not required by the emergency plan to receive

" Emergency Action Level (EAL) Table Training," Module G007, which was being taught and which appeared to lx: appropriate training for these emergency response management positions. (See Report Detail 5.0.)

• The facility and equipment irwentory check lists in use were not as indicated in the ph No significant inadequacy was noted in the check lists in use (See Report Detail 3.0); this discrepancy was identified as a minor weakness in attention to detai ,

• During review of the EAL tables, it was noted that the Emergency Plan tables were Revision 22 and that the " Emergency Assessment" EPIP 1.5-1 tables were Revision 2 This discrepancy will be further revievred for safety significance (URI 50-213/92-23-02)

(See Report Detail 5.0).

Overall, this program area was found to be acceptable, s Emergency Facilities, Equipment, Instrumentation and Supplie The inspector toured the Control Room, the Technical Support Center, the Opemtions Support Center (OSC), the OSC m-plant staging area, and the Emergency Operations Center, Tiiese facilities were well-maintained, and had all required emergency equipment and up-todite pmcedures. Equipment surveillances were being performed at the required frequencies, and instmments were calibrated as required. There were minor discrepancies betwu inventory lists found in the Emergency Plan and ones in the facilities, but these did not affect response capability significantly. The licensee was aware of this situation and was updating the Emergency Plan to correct i The inspector viewed the communications equipment in the < aergency response facilities, including telephones, radios, telecopier machines, and television monitors for viewing Control Room panels. All equipment identified in procedures was present. The licensee also had spare telephones for fast replacement of inoperable one Records from thme emergency call-in drills were reviewed. On<all personnel were required to respond to radio-pager activation, or a qualified relief was obtained. Records of response were maintained b, Emergency Response Organization position and time of call-in. These drills were conducted approximately quarterly and wem well-documented. The call-in drill res'ilts supported the conclusion that sufficient ERO personnel were available to adequately staff an emergency response. The on-site Lead Senior Nuclear Emergency Prepamdness Coordinator (EPC) sent a memo to the Station Vice President documenting the outcome of each dril l l

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Personnel who failed to respond were counselled by the Nuclear Senices Director, These drills and the resolution of drill discrepancies were assessed as a program strengt The inspector toured the new OSC staging area located in a low dose area outside the Health Physics Supervisor's of0cc in the radiologically controlled area in the lower level switchgear

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building. This location allowed in-plant staging for maintenance team reassignment without returning to the Emergency Operations Facility. The area had a telephone, telecopier, and status board for Maintenance Team Leader communications with the OSC Manager. This area was '

Grst utilized during the November 5,1992 station drill. At that time, only one telephone line was provided, and the telephone and telecopier could not be used simultaneously. Two more telephone lines were installed to correct that problem. The effectiveness of this staging area will be reviewed during the Matrh 1993 panial-participation exercis The inspector viewed the new 10-meter, oack-up meteorological mast, which was completed in the summer of 1992. That mast added an additional source of wind speed and direction to back up the Doppler Acoustic Sounder, which becomes ineffective during high winds or heavy precipitation. Also the anemometer vanes on all meteorological towers were replaced with vanes with heavy duty cups to p event loss during hurricane velocity winds, which I'ad occurred at Millstone during Hurricane Bob in 199 This program area was assessed as being effectively implemente .0 Organization and Management Control l

The inspectors reviewed EP staffing and noted that substantive management changes have taken place. One change had the on-site L.ead Senior Emergency Planning Coordinator, Connecticut Yankee, report to the Director, Emergency Preg'aredness, Northeast Utilities Service Company (NUSCO), with indirect reporting to the on-site Station Services Director.

l Since March 1992, N O has been reorganizing the EP Department. The Northeast Utilities

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EP organization was modified to include the Director of NUSCO Emergency Preparedness, the NUSCO EP Technical Programs staff of nine, the NUSCO off-site EP Program staff of eleven, the Haddam Neck on-site EP staff of five, and the Millstone Point on-site EP staff of six. The new total EP staffing of 35 permanent and contractor personnel replaced the previous staffing of about nine. The licensee stated that improved capability to interface with FEhM and with

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State and local EP organizations as a major factor in the reorganizatio Under the new organization, on-site EP staff functions included trsponsibility for Emergency Plan Implementing Procedure (EPIP) maintenance, EP surveillances, the on-call program, emergency respense facility maintenance, interfacing with the NRC, coordinating on-site drills / exercises, and conducting monthly / quarterly security and communication EP drills. EP Technical Programs tasks included drill / exercise scenario development, conducting  ;

drills / exercises (ir, eluding medical exercises), maintaNing the Corporate Organization Nuclear >

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Incident (CONI) procedure manual, maintaining key technical procedures {e.g. Emergency Action Levels (EALs), dose assessment, etc.},10 CFR 50.54(q) effectiveness evaluations; maintaining the Off-Site Facilities Infonnation System (OFIS), the Emergency Response Data System (ERDS), and the Emergency Notification and Response System (ENRS); maintaining the Berlin Emergency Operations Center (EOC); and developing technical programs. The off-site EP organization was tasked with maintaining State / local plans, the siten/radiopager program, EP data bases, telephone books, and hospital / nursing home plans, with off-site training, with interfacing with FEMA, and with coordinating off-site drills / exercise The Emergency Response Organization (ERO) was found to be adequately described in the emergency plan. All ERO positions were staffed through qualification of three or four individuals in each positio The inspectors concluded that the Emergency Operations Facility (EOF) organization included sufficient radiological controls staff members to support the Director of Site Emergency Operations (DSEO) in making accident mit!gation and classification decisions based upon radiological conditions. However, the DSEO staff in the EOF was also required to provide inputs to event classification and mitigation decisions based upon plant conditions, but there was no requistment for any operations personnel or for current or previously licensed personnel in the EOF organization. This condition was referred to the licensee for consideratio There was no requirement that the Technical Support Center (TSC) staff include anyone with an operations background. In practice, TSC staffing has included such individuals. It was nonetheless possible that the TSC could be activated by a staff with no Emergency Operating Procedure (EOP) experience or training. That could lead to a weakness in TSC ability to know when the control room staff should be departing fmm the EOPs under severe accident conditions. This matter was identified to the licensee for consideratio Overall, this program area was assessed as being effectively implemente .0 Training Emergency response training program requirements were established in Section 8 of the Emergency Plan (E-Plan), Revision 22, and amplified in the Nuclear Training Department's Emergency Plan Training Program Implementing Procedure, NTM-3.212, Revision 3. Training of off site suppon groups was assigned to the corpc, rate staf The inspectors reviewed EP training lesson plans, examinations, attendance records, Emergency Response Organization (ERO) qualification records, station on-call ERO watch lists, required drill schedules and accomplishment reports, deficiency tracking records, selected EPIPs, Sections 4 and 8 of the Emergency Plan, and NTM-3.212. Walk-throughs were conducted with tlues operating crews in the plant-specific simulator. Each walk-through was scheduled for four hours, involved two accident scenarios, and was used to assess the adequacy of Emergency Plan i

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training and of the supporting procedures. The inspectors found that all walk-through scenario classifications of events were correct and timely (including General Emergency classifications by State of Connecticut posture code), and that notifications were accomplished properl Inspector review of 62 names selected from the ERO on-calllist found that the training records correctly reflected each individual's qualification for the ERO positions assigned. This 100%

correct sample reflected a stangth in EP training program administration. However, inspector review of ERO on-call records for a three-month period noted that one individual was not eligible for ERO on-call assignment because of tmining failure. That individual was nonetheless posted to the on-call list as a Radiological Monitoring Team Leader (RMTL) from 9/21/92 to 9/27/92. This was assessed as a case of inattention to detail.

A new ERO position of Health Physics Occupational Radiation Exposure (HELPORE) System Operator was established by EPIP 1.5-52 on October 24, 199 That position was not incorpomted in E-Plan Revision 22 promulgated on June 20,1992, eight months later. This was assessed as a case of inattention to detai The E-Plan Containment Barrier Failure Table on a Section 4 pullout page incorrectly identified a potential loss of Containment Critical Safety Function Status Tree (CSFST) path as orange [a potential hazard to public safety]. As shown (correctly) in the classification EPIP, that potential loss of Containment was a red [ imminent hazard to public safety) Containment CSFST pat The Technical Specifications, in Section 6.5.1.6-j of Chapter 6, specify that the Emergency Plan and Implementing Procedures and changes thereto receive PORC (Plant Operations Review Committee) safety review. NTM-3.211, a non-PORC-reviewed supporting procedure that implemented E-Plan training, was changed on May 29, 1992, deleting requirements for the Technical Support Manager to receive Training Module G007, Emergency Action Level Training. ~ 10 CFR 50.54(q) requin:s nuclear power reactor licensees to follow and maintain in effect emergency plans which meet the requirements in 10 O 'R 50 Appendix E. 10 CFR 50, Appendix E, Section F.a, requires initial training and periodic retraining of emergency directors and/or coonlinators of the plant emergency organization. The Haddam Neck Emergency Plan, Revision 22, July 27,1992, specifies, m Figure 8-1 and Section 8.1.1, that Technical Support Managers receive, annually (1 year i 3 months), Training Module G007, Emergency Action Level Training. As of December 18, 1992, personnel qualified as Technical Support Center Managers had last received Training Module G007 training in June 1991, about 18. months previously. This was classified as an apparent violation. (92-23-01)

Licensee response to student coursc critiques was noted to be the exception rather than the rul Although a 100% response did not appear to be necessary, the inspector identified increased feedback to students as an item for licensee considention for improving student input and the E-plan tmining proces Several students had refused to list their social security numbers (SSNs) on training attendance g records. The records computer input was based upon social security numbers, and the records l

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were degraded by the time delays caused by absence of social security numbers. Specifically, three instances of training accomplished in March of 1992 but not yet posted to the computer Glcs by December 1992 were noted. This indicated a need to provide an altemate means of identifying the student The TSC staff received severe accident familiarization training. However, EAL (Emergency Action Ixvel) training was not required for Directors of Station Emergency Operations (DSEOs)

and for the licensed senior reactor operators who could be required to classify a fast-breaking emergency. Such training may be appropriate for these individuals and for other cognizant or supporting emergency msponse facility managers and staff. This matter was identified to the licensee for consideration, g

Overall, acceptable program implementation was identified in this area.

5 Independent Reviews The 1991 Emergency Preparedness (EP) Program Review was conducted from September 1991 m February 1992 under Corporate Organization for Nuclear Incidents (CONI) Procedure 11.01, Revision 11, October 10, 199 That directive assigned procedure implementation responsibility to the Supervisor, Radiological Protection Section (RPS).

The 1991 review identified inadequate training of Pmduction Operations Services Laboratory  !

d environmental teams as a problem. Correction was achieved by December 18',1991, indicating an effective corrective action functio The 1991 review used a checklist as an aid to evaluate whether the requirements of 10CFR50.54(t) were being met. No checklist inadequacies were identined. However, the Review Report documented satisfactory completion of items based on existence of procedares written to satisfy requirements, or on interviews with personnel responsible for their completio No observation or review of procedure implementation was reporte CFR50.54(t) also requires a review of the EP program at least every 12 months by persons who have no direct responsibility for implementation of the program. The 1991 licensee review was completed by personnel from the Radiological Protection Section and the Radiological

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Engineering Section. Both of these individuals reported directly to the Supervisor, Radiological Assessment Branch (RAB), who was responsible for EP. Thus, the review's independence was questionable because the myiewers reported directly to the Supervisor, RAB. This. issue was identified as Unresolved in Inspection Report 50-213/91-09 (URI 91-09-02). However, the MarchJuly,1992 Emergency Plan and 10CFR50.54(t) . Program Audit was conducted under the direction of the Quality Services Depar' ment. This audit was an improvement over the 1991 review, both in content and auditor independence. Auditors used the checklist as a guide and documented findings by writing assessments for each area evaluated. The audit identified five Unresolved Items and one Recommendation, none of which required responses according to

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licensee procedures (only findings did), though auditors requested and received responses for two of the Unresolved Items. Unresolved item 91-10-02 is therefore close CFR50.54(t) requires each nuclear power reactor licensee to include, in the emergen:y preparedness program reviews required eveg 12 months, an evaluation of the adequacy of interfaces with State and local governments and of licensee drills, exarcises, capabilities, and procedure The licensee's March 4uly,1992 Connecticut Yankee Atomic Power Plant emergency review did not include an evaluation of the adequacy of interfaces with State and local governments. It also did not include an evaluation of the licensee's drills and exercises:

the medical drill on April 1,1992 was the only drill evaluated, and no assessment was made of the drill program as a whole. An associated issue was identified as a non-cited violation in Inspection Report 50-213/91-09 (91-09-01): the 10 CFR 50.54(t) requirement that the part of the review involving the evaluation for adequacy of ir.terface with State and local governments shall be made available to the appropriate State and INal governments was not accomplished for the September 1991-Febmary 1992 emergency preparedness program revie Proper accomplishment and distribution of the required emergency preparedness program review for the March 1992-February 1993 is unresolved (URI 50-213/92-23-03) pending review of the j licensee's audit program as accomplished for the 12-month period ending in February 1993. The licensee expressed the intention of correcting this matter by December 31,199 The inspector reviewed the EP drill and exercise program. In 1992, the licensee conducted three station mini-drills, a dress rehearsal, and the annual exercise. After each drill, the Lead Senior Nuclear Emergency Prepandness Coordinator (EPC) sent a summary of drill comments to the Nuclear Services Director, and prepared drill reports which were signed by the Nuclear Services Director and Station Vice President. The Lead Senior EPC tracked significant items for improvement in the Emergency Plan Commitment Follow List (EPCFL).

The inspector reviewed the latest EPCFL Items wem tracked by source, corrective action required, status, and due date, and were assigned to specific persons for completion. Six items were open, three of which were past their due date. These three concerned procedure changes that wem awaiting approval of the Pp.nt Operations Review Committee. Overall, The EPCFL was assessed as effective in assuring ppropriate corrective actions were take Records of three actual events were kviewed. These were all Unusual Events CJEs). One was caused by an instrumentation malfudtion resulting in incorrect rod position indication. Two were for gaseous radioactive releases. One of the radioactive releases was declared prematurely, did not require a UE declaration, and was later withdrawn. Overall, event classification and reporting were appropriate and conservativ .0 Exit Meeting

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At the end of the inspection, an exit meeting was held to ciscuss the inspection scope and I

findings with the licensee personnel listed in Report Detail i l

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The licensee was informed about the inspection findings and their preliminary classification Most aspects noted in this report as being referred to the licensee for consideration were also discusse The licensee acknowledged the NRC findings and expressed the intention of evalua ing them and instituting corrective actions as appropriate, i

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