IR 05000352/1989017

Insp Repts 50-352/89-17 & 50-353/89-25 on 890724-27.No Violations Noted.Major Areas Inspected:Effectiveness of Training Conducted to Correct Inability of Operators to Properly Classify Events in Escalating Emergency

ML20247N278
Person / Time
Site:	Limerick
Issue date:	09/07/1989
From:	Conklin C, Lazarus W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20247N240	List: IR 05000352/1989017 ML20247N233
References
50-352-89-17, 50-353-89-25, NUDOCS 8909260183
Download: ML20247N278 (4)

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U. S. NUCLEAR REGULATORY COMMISSION l

REGION I

Report Nos: 50-352/89-17 I 50-353/89-25 l' Docket Nos:- 50-352 50-353 License Nos: N_PF-27 Priority Category _C CPPR-107-

-Licensee: Philadelphia Electric Company 2301 Market Street l Philadelphia. Pennsylvania 19101 Facility Name: Limerick Generatino Station. Units 1 and 2 Inspection At: Limerick. Pennsylvania Inspection Conducted: July 24-27.1989 Inspector: e d ~

P l!P4 Craig Co3klin, Senior Emergency date Preparedness Specialist, DRSS Gary Weale, Sonalyst In Approved By: M 7 5 Willijuvlazard, Chief, Emergency date Preparedness Section, FRSSB, DRSS Inspection Summary: Inspection on July 24-27. 1989. (Combined Inspection Report Nos. 50-352/89-17 and 50-353/89-25)

Areas Inspected: A special, announced emergency preparedness inspection was conducted at the Limerick Generating Station. The inspection area was limited to evaluating the effectiveness of training conducted to correct training weaknesses identified as a result of the inability of operators to properly c classify certain events in a rapidly escalating emergenc flesults: No violations were identified. Corrective actions taken to correct training weaknesses were effectiv PDR ADOCK 05000352 G PNU

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,j-DETAILS 1.0 Persons Contacted The following licensee representatives attended the exit meeting held on j

l July 27, 198 G. Leitch, Vice President - Limerick J. King, Support Manager M. Roache, Site Emergency Planning Coordinator T. Dougherty, Superintendent - Services Training C. Wike, Emergency Preparedness Technical Branch Lead (Actire)

D. Neff, Licensing Engineer A. MacAinsh,- Manager - Limerick Quality E. Firth, Superintendent - Training Limerick Generating Station G. Bell, Superintendent - Quality Assurance The inspector also interviewed and observed the activities of other licensee personne .

2.0 Licensee Actions on Previous 1v Identified Items During the inspection, the inspectors reviewed the licensee's progress in responding to items identified during a previous inspection (Combined  :

Inspection Report No. 50-352/89-11 and 50-353/89-17).

CLOSED (Violation) 50-352/89-11-01 and 50-353/89-17-01: The licensee  !

could not properly classify certain types of accidents and make l appropriate Protective Action Recommendations (PARS). l i

Walk-throughs were given to four Control Room shifts, with each shift containing a Shift Superintendent, Shift Supervisor, Control Operator, Shift Technical Assistant (STA) and Shift Clerk; and to four Dose '

Assessment Team Leaders (DATLs). The major areas assessed were: the ability.of the Shift Superintendent (Interim Emergency Director) to j properly recognize initiating conditions and classify the event at the  !

correct emergency classification level; the ability to provide  !

appropriate PARS in a timely manner; the dose assessment capability of the Control Room, Technical Support Center (TSC) and Emergency l Operations Facility (E0F) personnel; and the ability to make the ,

required off-site notifications. The personnel being evaluated were  !

given data such as equipment failures and changes in key parameters to stimulate actions. The inspectors noted that all Control Room personnel ,

had received recent training in classification and dose assessmen !

The walk-throughs with the four Control Room shifts indicated that all four shifts could recognize events that required an emergency  !

classification. All four shifts arrived at well-reasoned and correct  ;

emergency classifications in a timely manner and made the required I emergency notifications. When General Emergency classifications were declared, all four shifts knew that PARS were required to accompany the '

off-site notification. All four Shift Superintendents and STAS were i familiar with the EALs and the guide ines for PARS based upon plant

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conditions. The STAS were very knowledgeable in dose assessment I concepts and methods, and all were able to perform dose calculations utilizing both the installed dose assessment computer program as well as the backup manual calculation metho All DATLs had received recent training in formulating PARS based upon plant conditions. The walk-throughs with the four DATLs indicated that they were very knowledgeable in dose assessment concepts and methods and were able to perform dose calculations utilizing both the installed dose assessment computer program as well as the backup manual calculation method. Some reluctance was noted on the part of the experienced DATLs to make an initial PAR based upon plant conditions. This responsibility was reaffirmed with them during the walk-throughs. The performance of a newly trained DATL indicated that the current training program is satisfactor The walk-throughs indicated that training on event classification and PARS was effective ba.ied upon observed performance. Several areas were observed, which while they did not adversely affect performance, should be evaluated for corrective action. They are:

- Procedures EP-103, Alert; EP-104, Site Area Emergency; and EP-105, General Emergency; each contain approximately three pages of Emergency Director (ED) directions and telephone notifications required to execute a site evacuation. This alignment of duties will result in the ED being distracted from other potentially high priority tasks for several minutes or cause a delay of site evacuation until time is available to implement the long series of directions and notifications;

- Several disconnects exist between Appendix EP-101-3, Emergency Action Levels and Appendix EP-317-3, Protective Action Recommendations Based on Plant Conditions. Examples include: EP-101-3 contains a General Emergency EAL for loss of power, but there is no corresponding PAR in EP-317-3; EP-101-3 contains two different plant condition EAls for a General Emergency classification on boundary degradation / Loss of Coolant Accident (LOCA), but only one of these is discussed in EP-317-3; and there is little P"=rity between the description of plant conditions listed in EP-101- .Jr the General Emergency classification due to loss of hot / cold shutdcwn capability and those given in EP-317-3;

- There is currently no procedural requirement for periodic updates to off-site authorities unless there is a change in emergency classification. Therefore, two of the four shifts did not issue follow-up messages despite significant plant changes;

- Due to the disconnects between Appendix EP-101-3 and Appendix EP-317-3, the inspectors noted that the DATLs and STAS had some difficulty in choosing a PAR when existing plant conditions were not clearly defined in EP-317-3; and

- The procedures for manual calculations of projected off-site doses are unnecessarily cumbersome. This evolution requires the use of four

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separate procedures and five separate worksheets, some of which are multi-paged. Some reference data was required to be copied to more than one worksheet, even though that data was only used onc In summary, although some procedural problems were identified, the Shift Superintendents were all able to adequately recognize plant conditions and make appropriate emergency classifications. Additionally, the STAS and DATLs properly analyzed actual and plant conditions, and were able to provide conservative PARS to the ED. The licensee acknowledged these findings and agreed to institute corrective actions. This area will be reviewed in a subsequent inspectio .0 Exit Meetina The inspector met with licensee personnel denoted in Section 1 at the conclusion of the inspection to discuss the scope and findings of this inspection as detailed in this report. The licensee acknowledged the-findings and agreed to institute corrective actions as appropriat At no time during this inspection did the inspector provide any written information to the license _ - - - _ - - _ - _ - - _ - _ _ _ - _ _ _ _ _ _