IR 05000277/1988012

Safety Insp Repts 50-277/88-12 & 50-278/88-12 on 880419-20. No Violations Noted.Deficiencies Found in Emergency Action Level Scheme & Personnel Response.Major Areas Inspected: Emergency Preparedness Training Program

ML20154F712
Person / Time
Site:	Peach Bottom
Issue date:	05/11/1988
From:	Craig Gordon NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20154F705	List: IR 05000277/1988012 ML20154F701
References
50-277-88-12, 50-278-88-12, NUDOCS 8805240042
Download: ML20154F712 (5)

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U. S. NUCLEAR REGULATORY COMISSION

REGION I

Report Nos: 50-277/88-12 and 50-278/88-12 Docket Nos: 50-277 and 50-278 License Nos: DPR-44 and OPR-56 Licensee: Philadelphia Electric Company 7301 Market Street Philadelphia, Pennsylvania 19101 Facility Name: Peach Bottom Atomic Power Station Inspection At: Delta, Pennsylvania Inspection Conducted: April 19-20, 1988 Inspectors: bu M /u C. Z. Gdrdon Emergency Pr $aredness 5^[5 &

date Specialist,ERSSB,DRSS C. Con li EPS, FRSSB, DRSS ,

Approved by: .

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Ed/fr date M Lazatu) Chief, Emergency Preparedness $ection,FRSSB,DRSS Inspection Summar Inspection on April 19-20, 1988 (lieport Nos. 50-277/88-12 and 50-278/88-12)y:.

Areas Inspected: Routine announced safety inspection of the emergency preparedness training program including program establishment, implementation, and walkthroughs of emergency response personne Results: No violations were identified. Deficiencies were found in the TT6ensee's Emergency Action Level (EAL) scheme and in response by personnel to classify emergencies and r se appropriate protective action 4 recommendations.

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l 8805240042 883513  ;

PDR ADOCK 05000277

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. F DETAILS 1.0 Persons Contacted D. Ahmuty, Training Instructor R. Andrews, Supervisor Training Services R.Burnhardt,SiteTraIningCoordinator G. Gellrich, Shift Mana K. Kanouse, Supervisor,gerSecurity Training D. McRoberts, Shift Manager B. Standbau Shift Supervisor J. Wilson, gh,lity Qua Assurance Auditor C. Wike, Consultant K. Schlecker, Site Emergency Preparedness Coordinator 2.0 Operational Status of the Emergency Preparedness Program Knowledge and Performance,of Duties The inspectors reviewed the licensee's program for energency response training and noted that Table 8.1 of the Emergency Plan identifies specific initial training and annual retraining for different categories of personnel within the emergency res onse organization (ERO). These include Emergency Directors (ED , and team members for technical support, dose assessment, radia ion surveys, inplant repair, and first aid and rescu Discussions were held with the Station Training Coordinator (STC) who provided training lesson plans, examination material, '

?xamination results, and attendance records of site 3ersonne The STC conducts introductory training for the ERO tirough an Emergency Response Plan Overview sessio This is supplemented with specialty courses in emergency classificacion, facility

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activation, communications, technical support, PASS sampling, personnel safety team response, dose assessment team response, !

and other special training. Dose assessment training is >

provided by different instructors who have the necessary experience in these areas. The background and qualification of the STC appeared adequate to provide most emergency preparedness ,

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lesson plans are detailed and focus on important response element Table 2 to the EP Training Course Plan contains matrix that specifies lesson plans given to each representative of the ERO by emergency title.

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Inspection of licensee records indicated that they were complete and up to date. At least three individuals are qualified in each key ERO positio Included are Station Management (shift supervisors and Shift Managers qualified as ED's and upper level manage) ment qualified as Emergency Response Managers. The site vice president is the senior site official responsible for everyday direction and control activities. Since he is not ED oualified, the inspectors discussed with licensee staff the possibility of providing ED training to the site vice presiden In addition, the inspectors reviewed the Peach Bottom Restart Plan, Rev. 1, dated April 8, 1988 and noted that the Plant Manager (the senior site representative after the site vice is committed to becominc a qualified ED. However, a president)iew record rev did not list this incividual as completing all necessary training for the function (50-277/88-12-01 and 50-278/88-12-01).

EP-209, " Telephone Lists For Emergency Use " were also reviewed to ensure that qualified personnel are notified during emergencies. EP-209 contains a list of 22 appendices of licensee and suppo't personnel grouped by functional area. The inspectors identified three individuals who were not qualified to perform response functions (50-277/88-12-02 and 50-278/88-12-02). The licensee has agreed to evaluate the process of ERO personnel essignments and to formalize this process as appropriat Walk-throughs, focusing on knowledge and performance of emergency response duties, were conducted with shift supervisors and shift managers. All aru qualified as Emergency Director The inspectors determined that the training received by thcse individuals, which included emergency classification protective action decisionmaking and recommendations, and notifications to offsite authorities, was provided within the past yea The inspectors found th:.t the individuals were knowledgeable in various aspects of plant operations, mitigation and use of 3rocedure The inspectors noted that practical training that 1as been provided to shift personnel doesn't allow for a full range of actions because of simulator limitations. This has resulted in the operators not being familiar with the early stages of fast breaking accidents, and the resultant actions to be accomplished. In each walk-through, Protective Action Recommendations (PAR s) were either inadequate or not made to State authorities for a fast breakin declaration of a General Emergency (g scenarioanc 59-277/88-12-03 that recuired the 50-278/88-12-03). Thr licensee agreed to evaluate this areas and upgrade training as appropriate. Also, inconsistencies were observed in responses when using emergency action levels to

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classify events. The inspectors expressed concern over the level of detail and thoroughness of EAL's. Many accident conditions are not covered and would inhibit proper classification. Individuals were observed to rely on the General Condition EAL if exact parameters or initiating conditions could not be found in other event categorie Specific concerns regarding the Peach Bottom EAL's are identified Section . Emergency Detection and Classification The inspector reviewed EP-101,'" Classification of Emergencies" against the guidsnce of NUREG-0654. This review identified many inconsistencies and/or omissions of the guidance. Specific areas include: Earthquakes - no Unusual Event classification, inconsistent '

initiating conditions for Alert and Site Area Emergency; Tornado or Hurricane - No Unusual Event classification, inconsistent initiating conditions for tornado at Alert, and no initiating conditions for tornado or hurricanes at Site Area Emergency; Instrument Failure - incomplete initiating conditions at Unusual Event; Hazards - no initiating conditions for Site Area Emergency; Security - no initiating conditions for any cla>sification; Anticipated Transient without Scram - no initiating conditions for any classification; Personnel Injury - incorrect usage on the procedures; Plant Annunciators - no initiacing conditions for any classification; ,

, Unplanned Shutdown - incorrect usage of the procedures; and 1 ECCS initiated - no initiating conditions for Unusual Even During walkthroughs, the operators made extensive use of the General Condition EAL for the four emergency classification Review of the General Condition EAL indicates that for each

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classification, initiating conditions are vague and restited in inconsistent operator response when classifying events (See section 2.1). Additionally, this section does not identify specific components, systems, instrument readings, or 'dantify initiating conditions as required by 10 CFR 50 Appendix E.I The licensee stated that the EAL's were under revision. A discussion with the individual responsible for EAL content and a review of the draft revisinn of the Etl.'s indicated that most of the above mentioned EAL's are st'll not. properly addressed. The licensee has indicated that they w ?1 institute a complete review of the EAL's to bring them into conformance with NUREG-0654 guidance. Additional long term actions will also be an evaluation of symptom based EAL's; undertaken integration of including:L's the EA with the Emergency Operating Procedures; and the incorporation of human factors in EAL design. This is an Unresolved Item. Licensee actions and progress in this area will be reviewed in a subsequent inspection (50-277/88-12-04 and 50-278/88-12-04). Exit Meeting The inspector met with the licensee personnel denoted in Section 1 at the conclusion of the inspection to discuss the findings as presented in this report. The inspector also discussed some areas for improvement. The licensee acknowledged the findings and agreed to evaluate them and institute corrective actions as l appropriat At no time during the inspection did the inspectors provide any written information to the licensee, i

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