IR 05000003/1976014
| ML20050A684 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 01/17/1977 |
| From: | Conte R, Donaldson D, Kottan J, Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20050A676 | List: |
| References | |
| 50-003-76-14, 50-247-76-32, 50-286-76-32, 50-3-76-14, NUDOCS 8204020056 | |
| Download: ML20050A684 (22) | |
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,2 U. S. NUCLEAR RECULATORY CC:CiISSION OFFICE OF INSPECTION %'D ENFORCDiENT
REGION I
50-3 50-247 IE Inspection Report No:
50-03/76-14: 50-247/76-32: 50-286/76-32 Docket No: 50-286 DPR-5 Lic ensee:
Consolidated Edison Company of New York (CE)
License No: DPR-26 & DTF 4 Irving Place Priority:
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Unit 1: D New York, New York 10003 Category:
Unit 2: C Unit 3: C Safeguards Group:
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Loca tion: Indian Point Nuclear Generating Station; Units 1,2 & 3 Unit 1: PWR (B & W) 290 FMe Type of Licensee: Unit 2: PWR (W) 873 FMe, Unit 3: PWR (W) 1050 FMe
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Type of Inspection:
Routine, Unannounced (Emergency Planning)
Dates of Inspection:
December 7-9, 1976 Unit 1: October 20, 1976 Dates of Previous Inspection: Units 2 & 3: November 17-19,1976
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Reporting Inspector:
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/!//!77 D.'E. Donaldsgt,dia tion Specia list DATE.
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Accompanying Inspectors: M i )/ ~l
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J.J. Kottan, Radiation Specialist
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R. J.1';onte, Reactor Inspector DATE
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DATE Other Accompanying Personnel:
NONE
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DATE Reviewed By:
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/ !/7 J. P.gtohr," Chie f, Environmental & Special pATg' e
/ Projects Section 8204020056 770119 PDR ADOCK 05000003
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SUMMARY OF FINDINGS
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Enforcement Action Items of Noncompliance A.
Violations None identified, i
B.
Infractions
~ 76-14-01; 76-32-01; and 76-32-01:
Certain emergency training not
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provided to offsite fire departments.
Contrary to 10 CFR 50, Appendix E, item H, 10 CFR 19.12 and the Indian Point Station Site Emergency Plan, paragraph 14.7, the licensee failed to provide the required emergency training to two
offsite fire departments relative to the locations and boundaries of radiation areas and precautions required therein (Detail 3.b).
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C.
Deficiencies
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76-14-02; 76-32-02; and 76-32-02: Adequate records of monthly emergency equipment invent,ories were not maintained.
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Contrary to Technical Specifiation 6.8.1 and 6.10.1.b. and Emergency
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Plan. Implementation Procedure 1018, paragraphs 2.2.5 and 2.3.5, the licensee-failed to properly complete and maintain records of monthly
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emergency equipment inventories which were performed during the
. period January 1976 through November 1976.
(Detail 4. f.)
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Licensee Action on Previously Identified Enforcement Action Not applicable.
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Reportable Events
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None reported.
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-2-Other Significant Findings A.
Current Findings 1.
Acceptable Items a.
Coordination with Offsite Agencies.
(Detail 3.a. only)
b.
Facilities and Equipment.
(De tails 4. a., 4. b., 4. c.,
4.d., and 4.e.)
c.
Medical Treatment / Decontamination Facilities.
(Details 5.a.,
5.c., and 5.d.)
d.
Emergency Procedure Training.
(Detail 6.b. only)
e.
Emergency Drills.
(Detail 7)
2.
Unresolved Items
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76-14-03; 76-32-03; and 76-32-03: Adequate provisions for treatment of individuals at an offsite medical treatment facility.
(Detail 5.b.)
3.
Deviations
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76-14-04; 76-32-04; 76-32-04:
Emergency Plan training program not adequately documented in the form of lesson outlines and schedules.
Contrary to Regulatory Guide 1.101, paragraph 2.3.4, ANSI N18.1-1971, paragraph 5.1 and generally accepted practice, the
ee failed to develop a training and retraining program, ted in the form of schedules and lesson plans, for all les of personnel having emergency duties and responsibilities.
c (Detail 6.a.)
B.
Status of Previously Unresolved Items No items with respect to emergency planning.
Management Interviews A.
Entrance Interview A preinspection meeting was held at the Indian Point Station on December 6, 1976 with the Plant Manager, Mr. T. Law.
During this meeting, the licensee was requested to idencify/ address:
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1.
Any recent plant problems, e.g.,
component failures, unucuni plant responses or radiological problems; 2.
any items of general interest, e.g.,
impending strikes, fires, facility publicity, etc.
The licensee manage =ent representative stated that there were no i
items to be ' addressed.
The inspector addressed the following areas:
1.
general scope of the inspection, including estimated duration;
2.
identification of records, procedures, and documents to be reviewed; 3.
personnel to be interviewed; and 4.
recent experience at similar facilities.
B.
Exit Interview At the conclusion of the" inspection a meeting was held at the site on December 9, 1976 with representatives of the licensee organization.
Attendees at this meeting consisted of personnel whose names are highlighted (i.e., *) in paragraph 1 of the Details Section of this The inspector summarized the purpose and the scope of the report.
inspection (Details, Paragraph 2.) and the results of the inspection
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as listed in the Summary of Findings.
Additional information was provided by licensee management and/or commitments were made which related to the information gathered and conclusions reached as described in the Details of this report.
Specifically:
1.
Management Control of Emergency Plan Implementation (Detail 8)
The inspector noted that, while the licensee had met the commitments as outlined in the February 27, 1976 letter, the adequacy of these improved controls'with respect to the overall plan would continue to be evaluated by the NRC during subsequent inspections in this area.
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a The licensee acknowledged the benefits of effective central-
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ized management control of emergency planning functions and
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indicat'ed that the importance would be stressed to responsible individuals.
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2.
Entry to Unit 1 First Aid Room (Detail 5.a.)
The licensee management stated that the procedures for gaining access to the Unit 1 First Aid Room would be reviewed with responsible individuals.
It was further stated that manage-ment had not been made aware of earlier proble=s experienced
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in gaining access to the room.
3.
System Operator Radio, Peekskill Substation (Detail 4.f.)
Licensee representatives stated that repair crews had been actively working to repair the station operator radio located at the Peekskill Substation (Alernate Emergency Coordination Center).
In addition it was stated that the radio was again operating.
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4.
Followup on QS and R Audit of Emergency Plan (Detail 9)
Licensee management stated that, although no exceptions were
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reported in the QS&R audit of the emergency plan, the findings
would be reviewed again to evaluate the possibility of implementing certain of the recondendations contained therein.
C.
Subsequent Telephone Conversation Subsequent to the December 9, 1976 exit interview, Messes D.
Donaldson, J. Streeter, and J. P. Stohr (USNRC:I) placed a tele-phone call to Mr. E. Kessig on December 15, 1976 to reemphasize the inspection findings, and clarify the status of coordindton with the offsite medical treatment facility.
The following summarizes the conversation:
1.
Inspection Findings The licensee management representative stated that the find-ings of the inspection were understood.
2.
Coordination With Offsite Medical Treatment Facility (Detail 5.b. )
The licensee representative stated that an agree =ent had been finalized with Peekskill Community Hospital since the inspection.
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In ' addition, a drill had been performed with the hospital on December 15, 1976.
It was further stated that the licensee would probably no longer utilize the facilities of the NYU Medical Center in support of the Emergency Plan.
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NRC personnel stated that the status of the licensee's pro-visions for medical treatment at the offsite facility would remain unresolved pending additional review by NRC:I inspec-
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D.
Subsequent Management Meeting The findings of this inspection were also discussed during a management meeting with the licensee on December 13, 1976.
Details
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of this meeting are contained in IE Reports 50-003/76-15, 50-
247/76-34, and 50-286/76-33.
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DETAILS 1.
Persons Contacted Consolidated Edison Company of hew York
- Mr. T. Law, Plant Manager
- Mr. E. Kessig, Acting Manager, NPGD Mr. T. Schneiser, Reactor Operator, Unit 2 Mr. G. Liebler, Radiological Engineer
- Mr. J. Makepeace, Technical Engineering Director
- Mr. W. Thompson, Consultant QS and R
- Mr. J. Kelly, Station Chemistry Director
- Mr. B. Moroney, Chief Operations Engineer
- Mr. H. Searles, Consultant, QS and R Mr. C. Meyer, Senior Reactor Operator Ms. J. McLay, RN, Clinical Medical Representative Mr. J. Cullen, Plant Health Physicist Mr. P. Crinigan, Nuclear Environmental Monitoring Supervisor Mr. P. Gaudio Health Physics Supervisor Mr. J. Odendahl, Union Steward Mr. J. Daly, General Watch Foreman Mr. E. Imbimbo, Health Physics Supervisor Mr. L. Dombek, Health Physics Supervisor Mr. L. Volpe, Safety Supervisor Mr. A. Ferraro, Engineer
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Mr. L. Cohen Meteoroligst Mr. P. Falciano, Health Physics Technician Mr. F. Visoski, Health Physics Technician Mr. G. Warren, Security Supervisor Verplanck Volunteer Fire Protective and Rescue Association Mr. W. F. Byrnes, 1st Assistant Chief Mr. C. Keesler, Chief Buchanan Fire Department Mr. J. Lindes, 2nd Assistant Chief
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United States Coast Guard Lt. Hart, Port Safety Officer, Port of New York New York University Medical Center Mr. C. Marshall, Radiation Safety Officer Mr. F. Wilsont, Administrator Island Helicopters, Incorporated
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Mr. F. Fine, Executive Vice President 2.
General The purpose of this inspection was to review the status of the licensee's program for coping with emergencies at the Indian Point Station. Within the scope of'this inspection, the inspectors conducted independent sampling inventories of emergency equipment, reviewed emergency planning related documents and records, and held discussions with licensee and supporting offsite agency personnel.
An associated purpose of this inspection was to verify that the licensee had met certain commitments as outlined in a letter to NRC:I dated February 27, 1976.
3.
Coordination with Offsite Agencies
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a.
Agreement Documentation The inspector reviewed agreements between the' licensee and the following offsite agencies which support the imple=entation of the licensee's emergency plan:
(1) Verplanck Ambulance Association (2) Verplanck Fire Pro,tective Association (3)
State of New York, Department of Health (4) United States Coast Guard (S) New York Atomic Energy Council
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(6)
Island Helicopters, Incorporated (7)
New York University Medical Center i
The inspe tor noted that the licensee had documentary evidence that agreements had been reached with all. key supporting agencies listed in the emergency plan.
The inspector identified no inadequacies.
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b.
Licensee Contacts and Coordination Activities The inspector reviewed the licensee's Emergency Plan and related procedures'to determine the nature of the contacts
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required to be =ade by the licensee with the various offsite agencies.
The inspector noted that the following activities were required to be perfor=ed'at the noted intervals:
(1) Quarterly contact with each non-Consolidated Edison agency / person listed in Appendix D of the Emergency Plan for the purpose of verifying the correctness of telephone numbers and notification of pertinent changes to emergency procedures; (2) Yearly reconfirmation of agreements (performed during the 4th Quarter contact described in 1, above);
(3) Annual familiarization training of the Verplanck and Buchanan Fire Departments:
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(4) Annual familiarization training of the Verplanck Volunteer Ambulance Association; and (5) Notification of offsite agencies / persons prior to conduct of the annual large-scale drill to invite their partici-pation.
The inspector reviewed available documentation of the licensee's
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contacts with non-Consolidated Edison agencies / persons listed in Appendix D to the Emergency Plan and held discussions with licensee personnel to verify that the licensee had complied with the aforementioned requirements.
The inspector.noted that the following activities had been performed:
(1) Quarterly contacts were made with each non-Consolidated Edison agency / person on March 10,1976; June 8,1976; and September 21, 1976;
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Reconfirmation of agreements was scheduled to be completed l
during the fourth quarter contact to be made in late December; (3)
Familiarization training of the Verplanck F' ire Protective Association and Buchanan Fire Department was conducted during 1st quarter of 1976; and (4)
Training of the Verplanck Volunteer Ambulance Association
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during the 2nd quarter of 1976.
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The inspector noted that the licensee had properly executed all offsite agency contacts with the exception of those re-lating to the Buchanan and Verplanck Fire Departments.
Section 14.7 of the approved emergency plan requires that the Verplanck and Buchanan Fire Departments be invited annually to visit the Indian Point. Station to familiarize themselves with the location ~and types of hydrants, extinguishers, first aid equipment, etc.
During the visit, they are to be informed of the location and boundaries of the Radiation Area and the precautions to be taken within this area.
Review of the licensee's records and discussions with responsible licensee personnel revealed that; (1)
The Buchanan Fire Department had not been invited to visit the site in over two years (subsequent discussions with Buchanan Fire Department personnel revealed that they had visited the site in February 1976, Detail 3.c);
and (2) Although the Verplanck Fire Protective Association and Buchanan Fire Department had formally visited the site once during the year, they were not instructed relative
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to the boundaries of the Radiation Area and the precautions to be taken therein.
10 CFR 19.12 requires that all individuals who work in any portion of a restricted area be kept informed of the storage or use of radioactive materials or of radiation in such
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portions of the restricted area and shall be instructed.in the health protection problems associated with exposure, in precautions
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or procedures to minimize exposure and in the functions of protective devices employed.
10 CFR 50, Appendix E, item H requires that the licensee train persons whose assistance,may be needed in the event of an emergency.
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The inspector identified this lack of training as an item of noncompliance.
(76-14-01; 76-32-01; and 76-32-01)
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Further investigation into this area indicated that the Buchanan Fire Department's primary response district is limited to non-
nuclear structures outside the Indian Point Site Boundary.
The Indian Point Site proper falls within the response jurisdiction of the Verplanck Fire Protective Association.
Through discussions with individuals of the Buchanan Fire Department and the Verplanck Fire Protective Association, the inspector was able to determine that the licensee's failure to provide the required
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scope of training relative to the location of radiation areas and related precautions did not affect Buchanan and Verplanck Fire Departments' willingness to respond to fires at the
licensee's facility, regardless of the fire's location.
(Detail 3.c.)
c.
Personal Interviews The inspectors contacted responsible individuals of the various offsite agencies listed in the licensee's Emergency Plan in order to verify that:
the licensee contacts as noted in paragraph 3.b had been performed; the agreements between the licensee and the various agencies were still in effect; and that the contacts were adequate to assure an effective re-sponse capability.
Agencies contacted sere:
(1)
Buchanan Fire Department (2) Verplanck Fire Protective Association
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(3)
Verplanck Volunteer Ambulance Association (4) New York University Medical Center (5)
Island Helicopters, Incorporated
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(7)
State of New York, Department of Health i
The inspectors verified that the licensee's contacts were as represented in the licensee's records and that the agreements
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with the various agencies remain in effect.
Despite this fact, the inspector noted some confusion on the part of the New York University Medical Center concerning the specific nature and extent of their role in supporting the licensee's
(Detail 5.b.)
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Discussion with the responsible individuals of the Buchanan although they and Verplanck Fire Departments revealed that, had not received the required scope of the familiarization
training, there was a clear understanding that they were not
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to enter the site without proper escort or direction by licensee
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The Chiefs confirmed their willingness and intent i
personnel.
to respond if called, and provide any firefighting service The Chief of the Verplanck-Fire which the licensee may need.
the relationship Protective Association further stated that
with the licensee had been favorable.
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that they were aware that their primary response would be to Consolidated Edison facifties outside of the-site boundary.
It was further noted that they had received specific training I
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related to site equipment in February of 1976.
The training f
however, did not address the topic of radiation areas and
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related precautions. (De tail 3.b.)
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Facilities and Equipment t
I The inspector reviewed the licensee's facilities and equipment at the~ locations and with respect to the specific criteria listed below:
a.
Emergency Kits The inspectors conducted independent inventories and inspections *
. of the emergency equipment specified on the inventory checklists
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appended to Implementation Procedure 1018.
The equipment inspected was positioned at the following locations:
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(1) Control room 1-2 (2) Control room 3
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l (3) Emergency Control Center (Service Center)
(4) Alternate Emergency Control Center (Peekskill Substation)
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(5)
Emergency Survey Vehicle
(6)
Backup Emergency Survey Vehicle l
During the conduct of this portion of the inspection, two discrepancies (shortages) were noted in comparison with the items listed on IP 1018 inventory sheets, i.e., one decontamination
kit and four portable radios were missing from the emergency i
control center.
Discussion with the licensee individual responsible for the status of the emergency equipment indicated-
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that the location of the four portable radios had been changed to the guard house at the entrance to the protected area.
This had been done so that the radios would be used on a continual basis, thereby allowing any malfunctions to be quickly identified and repaired.
The licensee representative further stated that the inventory listing would be updated to reflect this change in location.
With respect to the missing decontamination kit, the licensee representative stated that it had been present during the last monthly inventory and immediate measures would be taken to replace it.
The inspector had no further questions concerning the inventory discrepancies.
b.
Emergency Control Centers During the performance of the emergency kit inventories and inspections, the inspectors verified that the licensee's Emergency Control Centers were located at the Service Center and Peekskill Substation as specified in the Emergency Plan and implementation procedures.
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c.
Emergency Communications Equipment The following emergency communications equipment specified in the Emergency Plan and implementing procedures was inspected:
(1)
Unit 3 Control Room:
9 telephones
(2)
Unit 1-2 Control Room:
2 base station radios (3)
Emergency Control Center:
1 base station (4) Alternate Emergency Control Center:
1 plant base station 1 system operator station (5)
Emergency Survey Vehicle:
1 mobile radio (6)
Backup Emergency Survey Vehicle:
1 mobile radio The inspector verified that this equipment was available and operable.
The inspector identified no inadequacies.
d.
Radioactive Release Monitoring Instrumentation The plant instruments (ef fluent and meteorological) for monitoring the release of radioactivity which were specified in the Emergency Plan, implementing procedures and/or technical
specifications were inspected for all 3 units.
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The inspector noted that the Unit 1 and Unit 3 area and process radiation monitors and the digital =eteorological data display in the Unit 1-2 control room were operable.
Several of the Unit 2 monitors were undergoing repair at the time of the inspection.
The inspector identified no inadequacies.
Calibration, Maintenance and Inspection Procedures / Schedules e.
The inspector reviewed procedures and schedules established by the licensee for calibrating, maintai,ning and inspecting the emergency response equipment listed in the Emergency Plan, implementing procedures, and/or technical specifications.
This review indicated that the aforementioned operations were required to be performed at a specified interval and in accordance with established procedures.
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The inspector identified no inadequacies.
f.
Records - Calibration, Inspection and Maintenance
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The calibration, inspection, and maintenance records of
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emergency equipment, instruments and facilities were reviewed on a sampling basis to verify that they were being maintained in a state of readiness as required by the licensee's pro-cedures.
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s The inspectors noted that required instrument calibrations, communications system checks and alarm checks had been per-formed as required.
While reviewing the records of emergency equipment inventories performed in accordance with IP 1018, the inspector noted that several inspection records were missing.
A detailed, review of those inventory sheets which were available indicated that for certain discrepancies noted, there was no indication that corrective action had been initiated or completed.
In re-sponse to the inspector's questions, the licensee representa-tive stated that he was certain that the inspections had been performed and that to the best of his knowledge all noted deficiencies had been corrected.
inspector failed to locate the missing records.Further investigation by the
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The inspector noted that there were no major discrepancies in the inspector conducted inventories when compared with the licensee's most recent inspection inventory, however, the licensee's failure to adequately maintain inspection records constituted an item of noncompliance.
(76-14-02; 76-32-02; and 76-32-02)
While inspecting the licensee's records of emergency communicaticas system checks perfor=ed in accordance with procedure NEM-B-04, the inspector noted that the system operator radio located in the Alternate Emergency Coordination Center was shown as being out of service for several consecutive months.
Discussion with the licensee revealed that the radio malfunctioned inter-mitantly and that an almost continual effort over the past several months had been conducted to restore the radio to service.
Con Edison's evaluation of the radio indicated that the radio itself was not malfunctioning, and telephone company evaluation of phone lines indicated that the phone lines for the radio were also functioning properly.
The inspector noted that repair crews were again working on the radio during the inspection.
The licensee stated that the operability of this radio was not vital te the implementation of the emergency plan, however, its repair would be pursued until proper operation is restored.
At the completion of the inspection, t
the inspector was informed that the radio was once again functioning properly.'
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The inspector reviewed the licensee's emergency plan and verified that the malfunctioning radio was not a vital notifi-cation link and that other means could be used to contact the system operator if needed.
The inspector had no further questions regarding this radio.
5.
Medical Treatment / Decontamination Facilities
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a.
Onsite The onsite facilities and associated equipment for medical
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treatment and personnel decontamination specified in the
Emergency plan were inspected.
While attempting to inspect the contents of the Unit 1 First Aid Room (72' elevation) medical cabinet the inspector noted that there s confusion as to where the key for the cabinet l
was located.
It took approximately an hour for the cabinet to I
be opened. The inspector learned that similar difficulty had been previously encountered and a bolt cutter had to be used i
I to gain entry to the cabinet.
The inspector discussed this occurrence with the licensee management in that it indicated an apparent deficiency in the training of individuals.
(Detail j
6)
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The inspector verified that the locations and inventories of medical' supplies at the following were adequate.
Unit 1 First Aid Room (72' elevation)
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Unit 1 & 2 First Aid Room (conventional side)
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The inspectors identified no inadequacies with respect to the locations and inventories of medical supplies and equipment.
.b.
Offsite
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The plans and facilities for handling emergency medica 1 patients at the New York University Medical Center were reviewed through; discussions with responsible offsite agency personnel; review of the agreement between the licensee and the offsite
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facility; and review of related licensee and offsite agency-procedures and plans.
During these discussions, the inspector became aware of coordination problems.
The New York University Medical Center has been the primary offsite treatment facility for approximately 10 years.
According to NYU personnel-initially, coordination activities were acceptable to NYU Medical Center officials, but recently, however, coordination on the part of the licensee has been less than desired. According to NYU Medical Center officials, specific questions'have been posed to the licensee regarding:
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the number of emergency and long-term patients that may
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require treatment at any one time; the range,and extent of
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physician specialty services expected to be provided by NYU Medical Center staff physicians; the adequacy of NYU facilities
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and equipment to support planned services; and the conduct of casualty drills.
The -inspector performed a detailed review of the emergency plan requirements pertaining to coordination with the New York
Medical Center.
Section 14.0 of the licensee's emergency plan outlines the coordination activities to be performed and required that NYU Medical Center be contacted quarterly to i
verify the correctness of the (telephone) listing and that during one of their quarterly contacts, the validity of the agreement be confirmed.
The inspector noted that the licensee had performed the required quarterly contacts for the first three quarters of 1976, with the fourth quarter contact scheduled
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to be made in December, prior to the conduct of a drill.
Section 14.9 requires that each offsite agency be called in
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advance of.the scheduled annual drill and be invited to participate.
The inspector determined that, to date, the licensee had met all established requirements with respect to contacting and coordination with the NYU Medical Center.
However, the established requirements were not insuring that the contacts were adequate for the offsite medical treatment facility to maintain and provide an effective. response capa-bility.
However, final evaluation of the adequacy of the medical
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arrangements with NYU Medical Center are considered unresolved pending the scheduled contact by the licensee during December and answers to NYU Medical Center's aforementioned questions.
I Subsequent additional discussion with licensee management indicated that Consolidated Edison is planning to phase out
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i the use of the NYU Medical Center as the primary offsite
medical treatment facility and to use Peekskill Community Hospital instead. According to a licensee representative,.
these plans are in the final stages and a coordinated drill is scheduled with Peekskill Community Hospital on December 15, 1976.
The inspector stated that the whole area of offsite medical arrangements would be considered an unresolved item
pending the licensee's final arrangements and a subsequent NRC review in this area.
(76-14-03; 76-32-03; and 76-32-03)
c.
Emergency Transportation The availability and responsiveness of round-the-clock trans-i portation for injured and/or contaminated individuals to the offsite medical treatment facility were inspected by discussions i -
with licensee management and responsible offsite personnel,
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and review of the licensee's procedures, records, and agree-ment, i
Emergency transportation is provided by the Verplanck Volunteer Ambulance Association and Island Helicopters, Incorporated.
The. inspector verified that these agencies had received re-quired training from the licensee (Detail 3.b.) that the agreement was in effect (Detail 3.a.) and that the scope and nature of the licensee's contacts were adequate to insure an effective response capability by this agency.
i The inspector identified no inadequacies.
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d.
Physicians Services The inspector held discussions with' licensee management and inspected agreements concerning arrangements for physicians to-treat injured and/or contaminated individuals.
The inspector's review indicated that these arrangements remain in effect.
The inspector identified no inadequacies.
i e.
Changes in Medical Treatment / Decontamination Facilities The inspector. held discussions with licensee management and
reviewed records and reports to determine if any changes had been made.in the medical treatment facilities and. arrangements for medical treatment since the last Emergency Planning inspection.
The' inspector noted that while no changes had been made, plans were being formulated to use the Peekskill Community Hospital in place of the New York University Medical Center.
The licensee stated that these plans were in the final stages, with. completion expected shortly.
(Detail 5.b.)
6.
Emergency Procedures Training a.
Training Program Organization The basic requirement for training individuals in the various
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aspects of their Emergency Plan duties originates in 10 CER
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50, Appendix E, item H, which states that the licensee's emergency plan shall contain, " Provisions for training of employees of the licensee who are assigned specific authority and responsibility in the event of an emergency and of other persons whose assistance may be needed...."
The licensee's NRC approved emergency plan,' paragraph 14 broadly outlines the-licensee's program for meeting the requirements of 10 CFR 50 Appendix E as they relate to the emergency. response organi-
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zation.
This section of the Emergency Plan requires the (
following:
(1)
Internal practice exercises to demonstrate adequate
familiarization with the procedures by members of the staff; i
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Training of radiation safety supervisory personnel in the supervision of monitoring teams, interpretation of data, estimates of radiation doses, operation of survey vehicles portable survey and air sampling equipment, contamination surveys and radiation field determinations; (3)
Annual familiarization training of the Buchanan and Verplanck Fire Departments; (4)
Training in first aid and personnel decontanination for the Verplanck Ambulance Association, to include practice in the use of the plant decontamination facilities and the portable decontamination kits.
In addition to the aforementioned specific requirements, the Plant Training Manual outlines in broad terms, initial emer-gency plan training requirements to be met for personnel newly assigned to the Indian Point Station.
The inspector noted that the licensee had not prepared a cohesive, formal program to implement this aspect of the emergency plan.
In order to clarify how the licensee was
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attempting to meet these training requirements, the inspector and licensee discussed the various aspects of the training.
This discussion centered around how the licensee performs initial and re-training of members of the licensee's emergency organization, particularly emergency team members, and personnel.
at the offsite medical treatment facility.
The licensee stated that the details of training had not been put into a cohesive training program, but, in practice, what is done is the following:
(1)
Emergency team members:
Primarily trained during quarterly drills, with any specific re-training needed being provided
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subsequently to the drill and based upon the drill results which indicates that'such a need exists.
This retraining is provided to the team members by their subsection chief.
(2)
Emergency Directors: Trained in a 1-on-1 student-instructor setting, with the student being walked through a simulated response while filling the Emergency Director position.
(3)
Health Physics Supervisory Personnel:
Trained in a like manner as E=ergency Directors, sometimes in connection with the quarterly drills conducted to train team members.
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The inspector noted that a training program was ongoing for certain categories of individuals, however, the licensee had not formally established a program with respect to delineating the scope, nature and frequency of the training to be provided to all categories of individuals having emergency responsibilities and duties.
This failure to have an established emergency training and retraining program, documented in the form of lesson plans and schedules, constituted a deviation from standard practices of the industry and accepted standards of the NRC as promulgated in paragraph 2.3.4 of Regulatory Guide 1.101 and ANSI N18.1-1971, paragraph 5.1.
(76-14-04;
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76-32-04; and 76-32-04)
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7.
Emer2ency Drills a.
Drill Procedures The inspector reviewed the approved procedure which governs the conduct of emergency drills at the Indian Point Site (IP 1019).
It was noted that this procedure included pro-visions for testing the notification of offsite agencies.
The inspector identified no inadequacies.
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b.
Drills Conducted The inspector reviewed available documentation of drills conducted since the previous emergency planning inspection in January 1976.
It was noted that several limited scope drills had been conducted although no specific requirements existed.
The licensee stated that an informal policy of conducting quarterly drills had been established.
Documentary evidence of these drills having been conducted was found-in ecmpleted EPCAR's (Emergency Plan Corrective Action Reports) issued as a result of the drills and in ECC log book entries.
The inspector verified that observers were used to evaluate the response and that critique comments were documented in
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the form of EPCAR's.
c.
Personal Interviews The inspector conducted interviews with three licensee drill participants and determined that. the aforementioned drills had been conducted.
During these discussions, the inspector determined that individual team members had received no training other than that gained from participating in the quarterly drills.
Individuals stated thag outside of their participation in drills, they could not recall having had any specific training sessions concerning procedural revisions or refresher discussions.
(Also see paragraph 6.a.)
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d.
Drill Followup The inspector reviewed the licensee's method of following up on comments from drills.
It was noted that the =ajority of the EPCAR's addressed the need for training in various areas.
The inspector attempted to verify that these EPCAR had been closed through additional training, but was unable to verify that such training had taken place.
(Also see paragraph 6.a.)
The inspector did verify that EPCAR's relating to resolution of items concerning the adequacy of timing and content of procedures, facilities and equipment had been assigned for followup action and were either resolved or corrective actions were in progress.
8.
Implementation of Licensee Management Control Commitments The inspector reviewed implementation of licensee management controls which were outlined in a licensee letter to NRC:I dated February 27, 1976 in reply to the findings of IE Inspection 75-09; 75-15; 75-30.
The parpose of this review was to verify that the licensee had met the outlined commitments.
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a.
Strengthened Management Review The inspector held discussions with knowledgeable individuals and determined that emergency equipment inventories and communication checks were periodically reviewed by the Manager, Nuclear
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Services.
The Manager, Nuclear Services was not available for discussion, but the inspector noted the initials of this individual on various inventory sheets, indicating that reviews had been performed.
The inspector discussed the adequacy of this management control mechanism in light of the findings detailed in paragraph 4.f. of this report.
The inspector further noted that priority had been placed upon radio repair as evidenced through review of communications check logs, b.
EPCAR Followup System The inspector noted that deficiencies noted during drills and formal reviews of the emergency plan were documented on Emergency Plan Corrective Action Reports (EPCAR). EIt was noted that this system was being actively utilized and that the responsibility for followup on all EPCARS was being performed by the Radiological Engineer.
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c.
Independent Corporate QSSR Audit Program The inspector verified that the licensee had for=ulated an audit program for the Station Emergency Plan and Implementa-tion Procedures.
The inspector reviewed the audit procedure (number QSR 405, dated 3/22/76) and the findings of a complete two part audit conducted in accordance with QSR procedure 405.
The audit findings reported no deficiencies, but did present various recoc=endations to improve the plan.
The inspector discussed the audit findings and recommendations with licensee management who stated that the recommendations would be evaluated for possible implementation.
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