IR 05000261/1982002
| ML20053B499 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 03/12/1982 |
| From: | Andrews D, Cline W, Huffman G, Jenkins G, Marston R, Mcfarland C, Stansberry W NRC Office of Inspection & Enforcement (IE Region II) |
| To: | Carolina Power & Light Co |
| Shared Package | |
| ML20053B469 | List: |
| References | |
| 50-261-82-02, NUDOCS 8205280466 | |
| Download: ML20053B499 (48) | |
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Report No. 50-261/82-02 Licensee: Carolina Power and Light Company 411 Fayetteville Street
Raleigh, N. C. 27602 Facility Name:
H. B. Robinson Docket No. 50-261 License No. DPR-23 Appraisal at H. B. Robinson site near Hartsville, S. C.
Inspectors:
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W'. E Cline (Team Leader)
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Date Signed
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3-/ 2 -&'2.
D. An,drews
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G. Huf fman
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Date Signed i'g
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3~/24 K R. Marston Date Signed
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C. McEarland '
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3-/ 2 -J 'L W.' Stanstierry
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Date Signed Accompanying Personnel:
W. Snell, A. L. Smith, K. Clark 3-/8 /Z Approved by:_
G. R. Jenkins,'Section Chie[ Operational Support Date Signed Emergency Preparedness and Division SUMMARY
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Summary
Inspection on January 25-February 4,1982 Areas Inspected This special announced appraisal involved 508 inspector-hours on site in the performance.of an Emergency Preparedness Appraisal.
Results Of the areas inspected, one violation was identified.
Appraisal deficiencies were identified in two areas: Emergency Plan Training / Retraining (Section 3.2)
and Implementing Procedures - Notification (Section 5.4.1).
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TABLE OF CONTENTS i
INTRODUCTION DETAILS 1.0 Administration 2.0 Emergency Organization
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2.1 Onsite Organization 2.2 Augmentation of Onsite Emergency Organization 3.0 Training / Retraining
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3.1 Program Establisned 3.2 Program Implementation
4.0 Emergency Facilities and Equipment 4.1 Emergency Facilities 4.1.1 As se s sme n t ' F'ac i l i t i e s
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4.1.1.1 Control' Room (CR)
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4.1.1.2 Technical Support Center (tTSC)_./
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4,.1.1. I Operations Support Center (OSC)
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4.1.1.5 Post-Accident Coolant Sampling and Analysis 4.1.1.6 Pest-Accident Containmen't' Air Sampling and
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Analysis
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4.1.1.7 Post-Accident Gaseous and Particulate Effluent Sampling and Analysis
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4.1.,1. 8 Post-Accident Liquid Effluent Samp' ling
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and-Analysis
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Offsite Laboratory Facilities 4.1.2 Protecti fe Facilities l-
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4.1. 2.'2 Medical Treatt.sen't Facilities
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4.1.2.3 Decontaminatia.1 Facilities
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4.,1. 4 News Center
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TABLE OF CONTENTS (Continued)
4.2 Emergency Equipment 4.2.1 Assessment Equipment 4.2.1.1 Emergency Kits and Survey Instrumentation 4.2.1.2 Area and Process Radiation Monitors 4.2.1.3 Non-Radiation Process Monitors 4.2.1.4 Meteorological Instrumentation 4.2.2 Protective Equipment 4.2.2.1 Respiratory Protection 4.2.2.2 Protective Clothing 4.2.3 Emergency Communications Equipment 4.2.4 Damage Control / Corrective Action and Maintenance Equipment and Supplies 4.2.5 Reserve Emergency Supplies and Equipment 4.2.6 Transportation 5.0 Emergency Impleraenting Procedures 5.1 General Content and Format 5.2 Emergency, Alarm and Abnormal Occurrence Procedures 5.3 Implementing Instructions 5.4 Implementing Procedures 5.4.1 Notifications 5.4.1.1 Prompt Notification System
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5.4.2 Assessment Actions 5.4.2.1 Offsite Radiological Surveys 5.4.2.2 Onsite (Out-of-Plant) Radiological Surveys 5.4.2.3 In-Plant Radiological Surveys 5.4.2.4 Post-Accident Primary Coolant Sampling 5.4.2.5 Post-Accident Primary Coolant Sample Analysis 5.4.2.6 Post-Accident Containment Air Sampling 5.4.2.7 Post-Accident Containment Air Sample Analysis 5.4.2.8 Post-Accident Gaseous and Particulata Effluent Sampling 5.4.2.9 Post-Accident Gaseous and Particulate Effluent Sample Analysis
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TABLE OF CONTENTS (Continued)
5.4.2.10 Liquid Ef fluent Sampling 5.4.2.11 Liquid Effluent Sample Analysis 5.4.2.12 Radiological Environmental Monitoring Program (REMP)
5.4.3 Protective Actions 5.4.3.1 Radiation Protection During Emergencies 5.4.3.2 Esacuation of Owner Controlled Areas 5.4.3.3 Personnel Accountability 5.4.3.4 Personnel Monitoring and Decontamination 5.4.3.5 Onsite First Aid / Search and Rescue 5.4.4 Security During Emergencies 5.4.5 Repair / Corrective Actions 5.4.6 Recovery 5.4.7 Public Information 5.5 Supplementary Procedures 5.5.1 Inventory, Operational Check and Calibration of Emergency Facilities and Equipment 5.5.2 Drills and Exercises 5.5.3 Reviews, Revision, and Distribution of Emergency Plan and Procedures 5.5.4 Audits of Emergency Preparedness 6.0 Coordination with Offsite Groups 6.1 Offsite Agencies 6.2 General Public 6.3 News Media 7.0 Drill s, Exerci ses and Wal k-Throughs 7.1 Program Implementation 7.2 Walk-Through Observations 9.0 Persons Contacted 8.1 Licensee Personnel 8.2 Other Organizations
8.3 NRC
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INTRODUCTION The purpose of this special appraisal was to perform a comprehensive evaluation of the licensee's emergency preparedness program.
This appraisal included an evaluation of the adequacy and effectiveness of areas for which explicit regulato ry requirements may not currently exist.
The appraisal effort was directed towards evaluating the licensee's capability and performance rather than the identification of specific items of noncompliance.
The appraisal scope and findings were summarized on February 4, 1982, with those persons indicated in Section 8.0 to this report.
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1.0 Administration of Emergency Plan The inspector conducted a detailed review of the administration of the licensee's emergency planning program.
The review involved, but was not limited to, discussions with licensee representatives, review of the H. B. Robinson Emergency Plan, review of selected H. B. Robinson Plant Emergency Procedures (PEP's), and examination of licensee emergency response / preparedness correspondence and documentation.
The licensees program was compared against the planning requirements delineated in 10CFR50.47(b)(16) and NUREG 0654 Section II.P. Within the area of emergency plan administration, the inspector evaluated the licensee program for:
assigning planning responsibilities, delegation of planning authority, planning coordination, and qualification and selection criteria for emergency planners.
1.1 Responsibility Assigned Responsibilities for administration of the emergency plan have been delineated for both the H. B. Robinson plant and corporate organization. At the corporate level, a full-time Director of Emergency Preparedness has been formally appointed.
The inspector reviewed a detailed job description and functional statement concerning the position.
The position reports directly to the Vice President of Technical Support. Within the corporate emergency planning function are four additional professional positions.
The positions are manned by personnel whose duties and responsibilities range from technical aides to senior and project planning specialists.
At the H. B. Robinson Plant the Emergency Planning Coordinator (EPC) is the Assistant to the Plant General Manager.
To assist the EPC in carrying out assigned duties and responsibilities, two professional level emergency specialists have been assigned to the plant emergency planning program.
According to licensee management, both of these professionals have been formally assigned full-time emergency planning duties at the H.
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Robinson Plant.
However, at some time in the future, one of these individuals is expected to be assigned to the CP&L Harris Nuclear Plant operation. The inspector reviewed the job descriptions for the plant emergency planning specialists. The inspector had no comments.
Licensee representatives indicated that a clear delineation of responsibility exists between the corporate and plant emergency planning staffs.
The corporate level functions primarily in a coordinating and support role, whereas the plant level functions primarily in implementing plant specific plans, procedures, training programs, and drills / exercises.
Under the current organization, the emergency preparedness function appears to be receiving senior management support and has visibility based on its location within the organization.
All plant management personnel contacted appeared to have an understanding of the plant emergency preparedness function and organization.
Based on the above findings, this portion of the licensee's program appears adequate.
1.2 Authority The inspector reviewed licensee correspondence concerning emergency preparedness, reviewed selected emergency planning personnel job descriptions, and discussed organizational authorities with licensee personnel.
The inspector reviewed in detail a licensee memo (Robinson file #11700, serial: Memo /82-48) concerning
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roles of the Corporate Director of Emergency Preparedness and the Plant Emergency Preparedness Coordinator.
The inspector had no comments on this matter.
Licensee representatives involved in emergency planning were queried concerning their rights to make decisions, use resources, and take action.
It appeared from these discussions that licensee emergency planning personnel were aware of their authorities and that sufficient authority was delegated to the operating level to accomplish established objectives. Based upon the above findings, this portion of the licensee program appears adequate.
1.3 Coordination uevelopment of emergency plans and procedures appears to be coordinated within the licensee's organization.
Licensee document (Memo from Starkey, subject:
Emergency Planning, dated 1/30/81, file 2-0-6 g) revealed that the plans and procedures were routed to various levels of plant management for review.
According to licensee management representatives, the corporate emergency preparedness organization reviews the emergency plan and proposed changes and coordinates with various offsite agencies on emergency preparedness matters.
Coordination between the plant and corporate offices appears to be defined. The respective organizational roles are prescribed in a memo from Mr. Connolly to Mr.
Black dated January 22,1982 (Robinson file #11700, serial: Memo /82-48).
According to licensee representatives, coordination with local offsite groups is generally handled by the plant staff. The plant has entered into agreements with certain offsite agencies concerning cooperation and support during an emergency.
At least seven of these agreements are with local agencies / groups which are located in communities nearby the plant.
The agreements are contained in Appendix B of the H.
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Robinson Emergency Plan.
This matter is discussed further in section 6.1 of this report. Based on the above findings, this area of the licensee program appears adequate.
1.4 Selection and Qualification The licensee has developed job descriptions for personnel involved in emergency planning.
These job descriptions specify requirements for the job to include abilities, skill levels needed, and duti n and responsibilities. All personnel occupying plant emergency planning posit
- have experience and training in radiological matters according to licensee acords.
Plant records show that plant emergency planning personnel have participated actively in CP&L sponsored training; however, these records did not reveal any record of recent professional
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j development training for plant emergency planning personnel.
The inspector
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discussed the merit of professional development training as a means of maintaining state-of-the-art knowledge with licensee management representatives.
Participation in the Oak Ridge Associated Universities REACTS program or the FEMA sponsored Emergency Planning course was discussed.
Licensee representatives stated that emergency planning personnel would be involved in professional development training in the future. The inspector indicated that this portion of the appraisal could not be closed until there was positive indication that professional developrent training programs were made available to plant emergency planning personnel.
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Based on the above review, this area of the licensee's program appears adequate; however, the following area should be considered for improvement:
A program should be established to ensure that professional development training is made available periodically to plant emergency planning personnel as a
means of maintaining state-of-the-art knowledge.
(50-261/82-02-01)
2.0 Emergency _ Organization A review of the licensee's emergency organization was conducted.
The review involved discussions with licensee representatives, review of the H. B. Robinson Emergency Plan, and review of the Plant Emergency Procedures.
The licensee's program was evaluated against the requirements in 10CFR50.47(b)(1) and NUREG 0654 Section II.A. and B.
The focus of the emergency organization review was on the onsite emergency organization and the augmentation of that organization.
2.1 Onsite Organization The licensee's onsite emergency organization is described in section 3.2 of the H.
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Robinson Emergency Plan.
The plan describes the responsibilities and duties of key positions and functional groups in the emergency organization.
These descriptions appear to be consistent with those provided in the applicable plant emergency procedures.
The plan and plant operating procedures show organizational charts which depict relationships between the functional groups within the emergency organization.
Based on discussions with licensee representatives, the relationships and various roles appear to be well understood by members of the emergency organization. The key individuals in the emergency organization are chosen based on their knowledge, training, and experience in a carticular area.
In reviewing the assignment of selected individuals to key positions within the organization, it was noted that assignments were made commensurate with their normal job responsibilities, duties, and expertise.
It was noted that in most cases the assignment cf key positions in the emergency organization was made by identifying the title of the individual who was to occupy the position.
However, in the case of the Accident Assessment Team Leader, Damage Control Team Leader, Operational Support Center Leader, Evacuation Assembly Area Leader, and Representative to the Forward Emergency Operations Genter there was no designation or appointment by individual title or position.
Additionally, there appeared to be no provisions for personnel to be assigned in either an interim or alternate capacity for these positions. This matter was discussed with licensee representatives from the standpoint of:
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identification of individuals so that training in the respective areas could be planned and initiated, and (2) the inpact that failure to make such assignments could have on the continuity of emergency operations.
The inspector determined from a review of plant procedures and from discussions with licensee representatives that an emergency coordinator is available onsite at all times. According to the licensee's procedure (PEP 2.1), the Shif t Foreman on duty has the authority to carry out initial emergency actions.
When such actions are initiated by the Shif t Foreman, he automatically assumes the duties
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and responsibilities of the " interim" Site Emergency Coordinator. He remains in this capacity until properly relieved by a designated individual.
Based on the above findings, this area of the licensee's program appears adequate; however, the following area should be considered for improvement:
Assignments should be made by individual title or position for the following key positions in the emergency organization:
(1) Accident Assessment Team Leader, (2) Damage Control Team Leader, (3) Operational Support Center Leader, (4) Evacuation Assembly Area Leader, and (5) Representative to the Forward EOC.
Consideration should also be given to identification of alternate and interim personnel for these positions. (50-261/82-02-02)
2.2 Augmentation of Onsite Emergency Organization The licensee emergency organization has provisio for augmentation from the Both the Plant Emergency Plan,n and the Corporate Emergency corporate structure.
Plan addresses augmentation considerations.
In addition, section 3.2 of the licensee's plant procedures contains information on augmentation and mobilization protocol. According to licensee representatives, early indication concerning the potential need for augmentation and mobilization is provided through early notification systems.
This early notification is prescribed in licensee plant procedures 2.2, 2.3, 2.4, and 2. 5.
Based on a review of the organization and manning of the corporate organization, it appears that adequate technical resources are available at the corporate office to provide a reasonable degree of augmentation to the emergency organization.
According to licensee representatives, the selection criteria for corporate augmentation of the emergency organization are based on the augmentee's experience, knowledge, and
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training in the position / area to which they will be assigned.
A review of potential assignments for selected corporate augmentees shows that the aforementioned selection criteria are applied in augmentation assignments.
The corporate organization has qualified radiation protection professionals who could
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be used to supplement the plant health physics staff beyond 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> under accident conditions.
In addition, radiation protection professionals re also available from the CP&L Brunswick Plant and the Harris Center.
i Support during an emergency is also available from the Westinghouse Corporation.
The inspector discussed Westinghouse emergency support program with an on-site Westinghouse representative and reviewed the Westinghouse Emergency Plan which is incorporated in Appendix B of the Plant Emergency Plan. The plan describes the
activities, organization, and operation of the Westinghouse emergency support i
program. According to the plan, emergency assistance can be provided to any nuclear power plant having a Westinghouse NSSS on a 24-hour, 7-day per week
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basis.
Plant management personnel and the Westinghouse representative appeared to have a good understanding of the Westinghouse plan and the relationship between the Westinghouse emergency organization and CP&L.
The Robinson emergency organization provides for coordination, notification, and mobilization of off site agencies. The interfaces with these offsite agencies are understood in that the licensee has entered into formal written agreements with key local and state agencies. These agreements are contained in Appendix B of
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the emergency plan. This program area is discussed in detail in section 6.1 of this report.
Based on the above findings, this portion of the licensee's program appears adequate.
3.0 Emergency Plan Training and Retraining 3.1 Program Establisned The emergency preparedness training and retraining program was reviewed with respect to the requirements of 10CFR50.47(b)(15) and (16), 10CFR50, Appendix E, paragraph IV.F, and criteria in NUREG0654, Section 11.0.
i The emergency preparedness training program was described in Section 6.1.1 of the Emergency Plan and implementing procedure PEP 4.3.
The Plan and procedure include training requirements for personnel assigned to the onsite emergency organization, corpnrate and other licensee support personnel who will augment the
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onsite emergency organization, general employees and of fsite support agency personnel.
The Training Supervisor is assigned the responsibility for documenting all training conducted.
Qualifications for instructors in the emergency preparedness program were included in PEP 4.3.
During the review of the above area, it was noted that some Unit 1 personnel and certain administrative and support personnel were not provided annual retraining in emergency procedures apparently due to the interpretation of Section 3.1.1 of PEP 4.3.
The word "Onsite" in this section of the procedure is interpreted to mean on the Unit 2 (Nuclear) site, within the protected area. Those individuals not having access to the Unit 2 area have been provided refresher training at the discretion of each area supervisor. The proximity of the administration building and Unit 1 to the Unit 2 facility dictates that all personnel working within the controlled area be aware of actions to take in the event of an emergency at Unit 2.
Records indicated that all licensee personnel within the owner controlled area had received initial training in emergency response procedures.
i Although the licensee has made a recent effort to provide retraining for these l
individuals, there was no established program to provide annual refresher training to all personnel working within the Controlled Area.
Based on the above findings, this portion of the licensee's program appears to be adequate: however, the following should be cor.sidered for improvement:
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Establish an annual retraining program for all permanent licensee employees within the owner controlled area to
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insure that all personnel are aware of the appropriate actions to be taken in the event of an emergency at Unit 2 (50-261/82-02-03).
3.2 Program Implemented
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The implementation of the emergency response training program discussed in paragraph 3.1 above was reviewed and discussed with licensee representatives.
The established program had not been adequately implemented at the time of this appraisal.
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The inspector reviewed lesson plans under development and discussed a proposed amendment to PEP 4.3 which delineates training responsibilities within the licensee's onsite and corporate organizations. The inspector also reviewed the licensee's internal memoranda concerning assignment of training duties, identification of training needs and priorities.
These appear to meet the objectives of the training program established by the Emergency Man and implementing procedure and should satisfy training requirement; upon implementation.
A licensee representative stated that the program,hould be implemented within the next 1 - 2 months.
Records indicated that emergency
response training had been conducted for the past two years, primarily by
contract personnel, for some members of the emergency response organi;*ation, although specific training for functional areas within the emergency organization, as outlined in PEP 4.3, was apparently not conducted.
Training records for general employee training in emergency procedures were up-to-date for Unit 2 personnel and for all personnel having access to Unit 2 and the general employee training program appeared to be adequate. Based on the above findings, the following deficiency was identified:
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The training and retraining program for emergency response personnel, described in the Emergency Plan, Section 6.1.1 and implementing procedure PEP 4.3 had not been adequately implemented (50-261/82-02-04).
4.0 Emergency Facilities and Equipmen_t 4.1 Emergency Facilities 4.1.1 Assessment Facilities 4.1.1.1 Control Room The Control Room (CR) emergency facilities were reviewed with respect to the requirements of 10 CFR 50.47(b)(8); 10 CFR 50 Appendix E, Paragraph IV.E and
criteria in NUREG-0654,Section II.H.
The CR facilities and function are described in Section 5.1 of the Plan and the duties of the CR emergency response personnel are discussed in the PEP, Sections 2.1 - 2.5.
The emergency supplies available at the CR are as described at Table 5.9-1 of Section 5.9 of the Plan.
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The CR is located on top of the Auxiliary Building at the second level. The CR has a complete set of emergency plans and plant emergency procedures.
The existing emergency communications facilities include the PA system, PBX, Key System, Sound Power, VHF Radio Transceiver, Emergency Telephone System, Security Transreceivers, Commercial Telephones, Microwave Load Dispatcher Net, Corporate Emergency Network and the NRC Emergency Notification System (ENS). Section A.2.6 of the Plan indicates that their is a Load Dispatch Radio in the CR; however, it is not present.
Based upon the above findings, this portion of the licensee's program appears adequate; however, the following item should be considered for improvement:
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Resolve the inconsistency between the Plan and the actual placement of the Load Dispatcher radio in the CR. (50-261/82-05).
4.1.1.2 Technical Support Center
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The Technical Support Center (TSC) facilities were reviewed with respect to the requirements of 10 CFR 50.47(b)(8), 10 CFR 50 Appendix E, Paragraph IV.E. and criteria in NUREG-0654,Section II.H.
The TSC facilities are described in Section 5.2 of the Plan. There appears to be no single, consolidated PEP for TSC activation and operation; although, Section 5.2 of the Plan indicates that such a procedure will be written in HBR PEP Section 3.2.
However, certain TSC function are alluded to in various HBR PEP's.
The TSC is located in the Service Building inside the fenced controlled area.
The TSC does not have the same radiological nabitability, shielding and ventilation, as the CR under accident conditions.
However, Section 5.2 of the Plan indicated the TSC is designed to meet stringent habitability requirements that will allow continuous occupancy once the TSC is activated.
In the event of a site and/or TSC evacuation, the CR will serve as a backup for the TSC.
According to PEP 2.3 the TSC is activated at the alert level. Open item 81-06-01 pertaining to TSC activation is now closed.
- t appears that personnel can move safely and easily between the TSC and CR in emergency situations. Protective clothing and equipment is available in the TSC.
There appears to be sufficient working space for assigned personnel.
Data displays, records and communication are accessible.
Based on this information open item 81-06-09 pertaining to information/ data displays is closed. The TSC is serviced from two separate electrical sources through an automatic transfer switch. The radiation monitoring equipment available to the TSC can distinguish the presence or absence of radioiodines at concentrations as low as 10 ' pCi/cc.
There are dedicated individual voice links between the TSC, OSC, CR, EOF and NRC.
The facsimile transmission capability for the TSC is provided by the facsimile equipment in the NRC Inspector's Office and one at the receptionist desk. There is an automatic ring-down and single line telephone and radio link to the local government response agency, Forward Emergency Operation Center, in Hartsville.
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There is a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> capability to communicate with the State on their Emergency Network. There appears to be sufficient telephones available for communications between the TSC and other onsite and offsite emergency control centers, and response agencies and organizations.
There is radio communication available between the TSC and field monitoring teams. There is a commercial telephone, PBX line, HBR Emergency Telephone Network and NRC-HPN and ENS telephones for NRC in the TSC. The installation of the HPN phone in the TSC results in the closure of open item 81-06-05. There are two commercial telephones, PBX telephones, and one NRC HPN and ENS telephones in the Resident Inspectors Office next to the TSC.
There are up-to-date records such as current plant Technical Specification, Plant Operating Procedures, Emergency Operating Procedures, Final Safety Analysis Report and drawings, schematics and diagrams showing current condition of plant structure and systems.
Based upon the above findings, this portion of the licensee's program appears adequate; however, the following item should be considered for improvement:
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Procedures for the activation and operation of the TSC and other Emergency Response Facilities should be provided.
(50-261/82-02-06).
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The TSC should be provided with the same radiological habitability as the CR under accident conditions. (50-261/82-02-07).
4.1.1.3 Operational Support Center (OSC)
The OSC and equipment were reviewed against the requirements of 10 CFR 50.47(b)(8),10 CFR 50 Appendix E, Paragraph IV E and criteria in NUREG-0654,Section II.H.
The OSC facility and function are described in Sections 3.2.11, 6.1.1.19 c' che Plan and PEP 2.6.12.
The OSC is located in the plant maintenance shop.
It is the assembly area for plant maintenance, operations, health physics technicians, environmental and chemistry technicians, and other plant emergency support personnel. The OSC is supervised by the I&C Foreman; however, there appears to be no formal documentation in the Plan or appropriate procedures of this designation (see section 2.1). An estimated 110 personnel can be readily accomodated in the OSC.
There are primary and backup voice communication links provided between the OSC, CR and TSC.
The existing commur.ication facilities include the PA system, commercial telephones and a direct dial line. The OSC does not provide personnel protection from direct radiation and airborne contaminants. There appears to be no documentation of an a'.ternative location in the event the primary facility becomes uninhabitable. The OSC has an Emergency Kit that includes the following equipment:
respiratory protection, protective clothing, portable lighting and portable radiation monitors.
The inspector determined that plant status information on exposure rates was provided to the OSC, and open item 81-06-12 could be closed.
Based on the above findings, this portion of the licensee's program appears to be adequate; however, the following items should be considered for improvement:
Procedures should provide for evacuation of OSC personnel in the event of a large radioactive release (50-261/82-02-08).
4.1.1.4 Emergency Operational Facility (E0F)
The Emergency Operations Facility was reviewed against the requirements of 10 CFR 50.47(b)(8); 10 CFR 50 Appendix E,
Paragraph IV E,
and the criteria in NUREG-0654,Section II.G. and H.
The EOF is described in Section 3.3.1 - 3.3.2 and 5.4 of the Plan and PEP 2.6.16.
However, there is no procedure established to activate and operate the EOF, even though Section 5.4 of the Plan indicates that " Procedures for EOF activation and operations will be prepared as part of HBR PEP Section 3.2."
The HBR EOF is located in the Plant Administration Building.
In the event of a site evacuation, the Darlington County Emergency Operation Center (EOC) located in Darlington, S.C., will serve as a backup location for the EOF. The E0F does not appear to meet the ventilation habitability criteria indicated in Table 2, NUREG-0696. There were no detectors in the EOF to distinguish the presence or absence of radiciodines at concentrations as low as 10 ' pCi/cc. There also was no personnel dosimetry equipment present.
There is space near the EOF which may be used for a limited number of news media personnel during an emergency.
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The construction of a new EOF is being considered. The EOF is activated by and under the direction of Vice President - Nuclear Operations when a Site or a General Emergency condition exist.
Activation is discretionary for lesser emergencies. The Vice President - Nuclear Operations will assume the position of Emergency Response Manager.
Communication equipment at the EOF consist of the public address system, the PBX, Emergency Telephone System, Commercial Telephone, Corporate Emergency Network and NRC ENS and HPN. There are at least 2 designated commercial telephones and ENS and HPN extensions installed at the NRC assigned work location.
There is a facsimile transmission capability between the EOF, TSC and NRC-0P center. There is reliable backup means of communication.
There appears to be sufficient non-dedicated voice communication links to provide access to the NRC, other federal, state and local agencies and emergency support organizations.
Communication with the field monitoring teams prior to activation of the EOF is maintained at the TSC. When +,e EOF is activated, the field monitoring teams, and the communication witn them, will be provided by Harris Energy and Environmental Center.
All the necessary licensee Plans and Procedures, FSAR and ER and State and local Emergency Plans and Procedures are on hand. A site map with markings to depict preselected monitoring points is available.
Plant layout drawings are also present.
There are sufficient administrative supplies.
There is no emergency personnel protective equipment in the EOF; however, this equipment is available at the Plant Access Building.
There was no first-aid kit, decontamination supplies and clock at the EOF.
The lack of a decontamination kit is discussed in Section 4.1.2.3 of this report.
The EOF provides sufficient space for management of overall emergency response including coordination with federal, state and local officials, coordination of off-site radiological and environmental assessment, and determination of recommended public protective action.
The inspector determined from the above findings that open item 81-06-02 which related to separation and redefinition of EOF functional responsibilities could be closed.
Based upon the above findings, this portion of the licensee's program appears adequate; however, the following items should be considered for improvement:
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Procedures for the activation and operation of the EOF should be provided (50-261/82-02-09).
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Provide ventilation protection for the EOF as indicated in Table 2, NUREG-0654 (50-261/82-02-10).
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Provide detectors to distinguish the presence or absence of radiciodines at concentrations as low as 10 7 pCi/cc (50-261/82-02-11).
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Provide a First-Aid Kit and clock at the EOF (50-261/82-02-12).
4.1.1.5 Post-Accident Sampling and Analysis 4.1.1.6 Post-Accident Containment Air Samp'ing and Analysis
The post-accident reactor coolant and containment sampling and analysis program was reviewed. The facilities and equipment available for post-accident sampling and analysis were evaluated against 10CFR50.47(b)(8), 10CFR50, Appendix E, Paragraph IV.E and selected criteria in NUREG-0654,Section II.I. The inspector interviewed the Radiation Control (RC) Supervisor, the Environmental & Chemistry (E&C) Supervisor, the E&C Foreman, and an E&C Technician, concerning post-accident reactor coolant and containment sampling and analysis and related facilities and equipment.
Those interviewed indicated that the licensee reviewed, selected and procured a Combustion Engineering designed permanent Post-Accident Sampling System (PASS) capable of collecting both coolant and containment samples.
The system appears to be in accorcance with NUREG-0737, Item II.B.3. guidelines. The system is partially installed and is scheduled for completion during the March 1982 refueling outage.
The permanent PASS was a January 1, 1932 NUREG-0737 requirement, however, in accordance with a letter dated December 29, 1981 from CP&L to NRC, an extension of time was requested until startup after the March 1982 refueling outage.
Until installation of the permanent PASS is completed, the licensee plans to utilize the interim sampling system.
This equipment appears to be accessible during accident condition > and is also monitored for high levels of radiation with appropriate remote readouts in the control room.
The design is such that remote sampling systems have been established so that personnel need to spend a minimum amount of time in extremely high radiation areas, thus radiation exposures received by users should not be excessive.
Tongs, carts, and lead shielding are available for use in transporting highly radioactive liquid and gas samples to the hot laboratory.
If the sample analysis facility is not accessible during post-accident conditions, there are provisions to use backup analysis and counting capability available off-site at the Brunswick site, the Harris Energy and Environment Center or the Harris mobile radioactive analysis laboratory.
The licensee's sampling, collecting and analysis techniques for handling post-accident samples indicated that sampling results can be completed within three (3) hours.
Based on the above findings, this portion of the licensee's interim program appears to be adequate, however, the NRC will review and evaluate the permanent PASS system when it is placed in operation.
4.1.1.7 Particulate Effluent Sampling and Analysis The post-accident gas and particulate effluent sampling and analysis program was reviewed in accordance with the NRC requirements specified in sections 4.1.1.5 and 4.1.1.6 above.
Discussions were conducted with the Environmental and Chemistry Supervisor and Foreman. The system currently in use by the licensee is an interim system which consists of a three channel unit which monitors particulate, iodine and noble gases and reads out in cpm. The system monitors plant vent, condenser air-ejector vent and steam generatcr flash tank vent releases.
In the event of a post-accident release, procedure ES-4, " Gaseous Ef fluent Accountability", is available to explain the details for collecting and handling these samples.
A walk-through was conducted to demonstrate that this system was operational.
The above system is being replaced by a Particulate, Iodine and Noble Gas Monitor (PING-2AT The structure containing the equipment is located on the auxiliary building roof next to the venting stack and has the capability of monitoring low level and post accident type releases. Particulate filters and charcoal / silver zeolite cartridges to be used for post-accident sample collection are located in a shielded housing with quick-disconnect fittings.
A cart is available for transporting samples to the hnt laboratory. This system has been operated, but due to instrument problems, thought to be caused by high temperatures, has been taken out of service. However, the system is scheduled tc be repaired and placed in operation during the 1982 spring outage.
PING-2A was a January 1, 1982 NUREG-0737 requirement, however, in accordance with a letter dated December 29, 1981 from CP&L to NRC an extension was requested until startup after the March 1982 refueling outage.
Based on the above findings, the licensee's interim program appears to be acceptable, however, the NRC will review the permanent PING system when it is placed in operation.
4.1.1.8 Post-Accident Liquid Effluent Sampling and Analysis The post-accident liquid effluent sampling and analysis was reviewed in accordance with the NRC requirements speci fied in section 4.1.1.5 and 4.1.1.6 above.
The inspector discussed post-accident liquid effluent sampling and analysis capability with the licensee representatives mentioned in section 4.1.1.7 above.
No facility modifications are anticipated at this time.
The licensee representative stated that post-accident sampling from this area would be handled by following routine low level sampling procedure described in Procedure ES-3, " Liquid Waste Release", and by taking appropriate collecting and analysis steps on an "as needed basis" for high activity samples.
Sample analysis would be performed in the hot laboratory or by use of backup analytical capability at the Brunswick site or the Harris Center.
Based on the above findings, the licensee's program appears to be adequate.
4.1.1.9 Offsite L_aboratory Facilities Of fice laboratory facilities were reviewed in accordance with the requirements of 10CFR50.47(b)(9), 10CFR50, Appendix E,
Paragraph IV.E.2, and criteria in NUREG-0654,Section II.H.6.C.
CP&L has developed a method for establishing
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offsite laboratory facilities to process environmental samples and perform data I
analysis in the event of a post-acr.ident radiological emergency.
In the event of a radiological emergency in which the in plant laboratory become uninhabitable, laboratory support is available at the Harris Energy and Environmental Center (HEEC) in New Hill, N.C.
Necessary laboratory equipment is available at the HEEC and could be utilized in the event of an in plant radiological accident.
HEEC could also dispatch its mobile laboratory unit.
This unit could arrive at the licensee's plant site and be placed in operation
from 4 - 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> af ter being requested.
The mobile laboratory is equipped to analyze environmental samples, in plant samples and process TLD's.
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If for some reason the above mentioned facilities could not be made immediately available, the Brunswick plant laboratory equipment could be utilized within a 3 - 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> period.
Based on the above findings, this portion of the licensee's program appears to be adequate.
4.1.2 Protective Facilities 4.1.2.1 Assembly / Reassembly Areas When an area evacuation is called for, assembly areas will be selected as appropriate for the situation and a designation will be made over the PA system.
For a site evacuation the Plant Emergency Procedure, PEP-3.8.1, Evacuation, designates the parking areas outside the administration building as the primary assembly area. PEP's 3.8.2, Personnel Accountability, and 3.8.4, Access Control, and other procedures for health physics and decontamination activities are also applicable.
The assembly locations are used exclusively for accountability.
Monitoring and decontamination is to be conducted as people are exiting to the assembly area. Af ter accountability, personnel who may be required for Emergency Response would go to the OSC. Any equipment necessary for use in the assembly area would be obtained at its regular location.
If conditions so required, an alternate assembly area, such as the visitor center, may be designated.
Based on the above findings, this area of the licensee's program appears to be adequate.
4.1.2.2 Medical Treatment Facilities This area was evaluated by inspection of the facilities and supplies, review of the applicable procedures, and discussion with licensee representatives.
The first-aid room is located in the Auxiliary Building, approximately 50 feet from the decontamination room and 40 feet from the HP Records Office. The room is small, but readily accessible.
One sink is available in the room.
An adequate stock of medical supplies and equipment is on hand.
Procedures for treament and decontamination, contamination and survey instruments, and emergency dosimetry are available in the nearby HP Records Office.
The medical supply inventory has been removed from the PT under which the other emergency kits are inventoried and checked. The list from the PT is still used for conducting the
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inventory, but a written, approved requirement does not exist.
A procedure (PEP-3.8.3) for the administration of Potassium Iodide is in effect.
KI is on order, but not yet available on site. A licensee representative stated that, in an emergency, supplies could be obtained from CP&L's Brunswick Plant.
These actions result in the closure of open item 81-06-08.
Communications equipment is not available in the first-aid room. A PA system is available on the wall about 30 feet away and other communications are available in the HP Records Office.
Based on the above findings, this area of the licensee's program appears to be adequate; however, the following items should be considered for improvement:
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Communications equipment should be provided in the first-aid room (50-261/82-02-13).
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A procedure should be available for the inventory and check of the medical supplies and equipment (50-261/82-02-14).
4.1.2.3 Decontamination Facilities The inspector evaluated this area through inspection of the facilities and equipment, review of procedures, and discussion with licensee representatives.
The Frisker Room is located adjacent to the Male Dress-Out Area in the Auxiliary Building. There are two showers and two sinks in the room which drain to the Chemical Drain Tank.
Solid waste is deposited in a plastic-lined, 55 gallon drum. A frisker survey instrument is available in the adjacent Male Dress-Out Area. Additional instruments and decontamination procedures are available in the nearby Unit 2 Hot Lab.
The Female Dress-Out Room is also used as a decontamination area by female personnel.
It has a shielded frisker booth, and a shower ar.d sink which drain to the Chemical Drain Tank.
Several yellow plastic bags are available for solid waste.
Both decon rooms have a supply of decontamination supplies, including Phisoderm, Radcon, and Propanol.
Provisions are made for establishment of monitoring points in an emergency.
Points are specified at the main entrance, guard locations, visitors center, and others locations as directed by the Radiation Control Director. According to licensee representatives, decontamination supplies are not established in prepositioned kits for use at points other than the in plant decontamination room and the hospital.
Personnel Protection and Decontamination Team members would pick up decontamination supplies from normal stocks when required.
Based on the above findings, this portion of the licensee's program appears adequate; however, the following item should be considered for improvement:
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Prepositioned decontamination kits should be established at locations where they might be required and add inventory and inspection requirements to the emergency kit procedure (PT-43) (50-261/82-02-15).
4.1.3 Expanded Support Facilities The licensee has office space available for expanded corporate, contractor, and non-licensee augmentation personnel that would be required for the emergency preparedness program.
The planned use of these offices are included in the plant communications system described in Appdndix A of the Plan and in PEP 3.1.2, Communications Activities. Use of these ;.upport facilities is also discussed in PEP 3.2.2, Mobilization of Outside Orr;anizations and Personnel, and PEP Appendices A.1 through A.4 relati.ve to outside organizations and augmenation personnel.
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Based on the above findings, this portion of the licensee's program appears to be adequate.
4.1.4 News Center The licensee has made provisions for both a primary and an alternate news media center.
The primary news media center is the plant visitor center and the alternate is the Center Theater in Hartsville, S.C.
At these localities, arrangements have been made for:
electrical supply to carry added TV load, copying, audo-visual equipment, and security.
The inspector noted that the primary news media center is marginally adequate in si: e.
The alternate news media center appears adequate in size.
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Based on the above findings, this area of the licensee's program appears adequate; however, the following areas should be considered for improvement:
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Determine as to whether a PA system is available in the Center Theater and, i f necessary, evaluate the need to install such a system or alternate approaches to installing a PA system 50-261/82-02-16).
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Evaluate the requirements for providing expanded telephone service to the alternate media center (Center Theater) (50-261/82-02-17).
4.2 Eme rge_ncy_E_ qui pmen t 4.2.1 Asse_s_sment Equipment The inspector verified this area by review of procedures and records, inspection of emergency kits and contents, and discussions with licensee representatives.
The emergency kits are discussed in general terms in PEP-4.2, and specific listings of kit contents and schedules for inventory, check, and calibration are provided in PT-4'.
Specific calibration and operation instructions are provided in Health Physics procedures.
PT-43 makes provisions for removing inoperable instruments from service.
The kits were located as specified in the procedures and would be accessible to the teams provided for in the Emergency Plan and Procedures. It was noted that some inventories were not correct but a licensee representative stated that seals would be placed on the kits so that unauthorized use or tampering could be veadily detected.
In ad"ition, some essential components such as charcoal and silver zeolite cartridges, RM-14 instruments to count the samples, and the adaptor required to fit the cartridges to the air sampler, were present in the kits but not listed on the inventory.
Emergency communication equipment was listed for some kits, but was not further identified as to the particular type of equipment.
TLD's are provided in the emergency kits. These could be used as ankle dosimetry for teams reentering the facility. Finger ring-type TLD's would be issued at the HP Records Of fice.
Instruments for reentry may be provided from emergency kits or from Health Physics Records Office or Unit 2 Hot Lab.
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A review of PEP-3.5.1 and Appendix A of E.S.-4 shows that instrumentation used for emergency environmental surveys has the capability of detecting and measuring radiciodine and particulates to the required minimum detectable activities.
Portable ion chamber instruments are provided for measurement of high level dose rates and GM instruments are provided for measuring medium and low beta gamma dose rates.
Instruments and other equipment appear to be adequate for the planned emergency teams.
Provision is also made for in plant detection of radiciodine by use of silver zeolite cartridges.
A calibration program is provided for and implemented.
It was noted that a survey instrument in the Hospital Emergency Kit and a Bendix Air Sampler in the j
Plant Media Center Kit was past due calibration.
It was noted that these discrepancies had been listed by the licensee on the last monthly inventory and corrective action was taken while the NRC Appraisal Team was on site.
It was also noted that most air samplers in the kits were calibrated for Red Dust Filters only.
Discussion with licensee representatives indicated that calibration standards for other modes of operation were lost er damaged when sent for calibration. Licensee representatives stated that replacement standards were expected in from a week to a month and that, in case of an emergency, previous calibration data could be used.
Based on the above findings, this portion of the licensee's program appears to be adequate; however, the following items should be considered for improvement:
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Essential equipment in the kits should be lised on the kit inventories (50-261/82-02-18).
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Procedures should specific the type of emergency communications euqipment for each applicable emergency kit (50-261/82-02-19).
4.2.1.2 Area and Process Radiation Monitors The area and process radiation monitors were reviewed with respect to the requirements of 10CFR50.47(b)(9),10CFR50 Appendix E, Paragraphs IV.B. and E.2.,
the criteria in NUREG-0654,Section II.H. and NUREG-0737, Sections III.D.3.3. and II. F.1. wi th attachments.
ine area and process monitors described in the emergency plan are in place with read-outs in the control room.
However, RMS-30 (Fuel Handling Building),
RMS-31A, B and C (Main Steam Lines), RMS-34 (Low range particulate; iodine and noble gas) and RMS-36 (high range particulate, iodine and noble gas) are not operable.
In the interim, all requirements are being met by alternate low and mid-range monitors with the high range covered by manual methods.
NUREG-0737 requires that permanent systems be in place and operable by January 1,1982.
However, CP&L requested an extension from the NRC, Division of Licensing, by letter of September 15, 1981. The permanent system will be reviewed following the 1982 refueling outage.
It appears that all area and process monitors have operating characteristics consistent with potential plant accident conditions, their sensors accurately _
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reflect their intended use and all monitors are positioned so that their readouts are accessible.
Conversions are made from each meters readout into values which accurately reflect radioactive concentrations and release rates by means of curves which have been corrected for ef ficiencies.
All instruments are maintained under a bi weekly Periodic Testing program.
Calibrations are performed across the entire range of each instrument under Procedure HP-42 during refueling intervals (about once each year), whenever a detector is changed and whenever any anomally occurs, such as failure during a source check.
Inoperable instruments are repaired or replaced within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and all monitors have redundant power supplies.
Based on the above findings, this portion of the licensee's program appears to be adequate.
4.2.1.3 Non-Radiation Process Monitors The non-radiation process monitors were reviewed with respect to the requirements of 10CFR50.47(b)(9); 10CFR50, Appendix E, Paragraph b; and, the criteria in NUREG-0654,Section II. I. and NUREG-0737,Section II.F.1.
The non-radiation process monitors described in the Emergency Plan were all in place and operable. All non-radiation process monitors have easily read meters in the control room except for the seismic detection device, which sets off an alarm in the control room for earthquakes exceeding 0.01g in acceleration.
The monitors are located at two points within the plant. The procedure requires that a complete control room and plant check be performed after a seismic alarm, followed by development of the seismic indicator photographic films from the monitoring stations. Then, the approval of the plant manager must be obtained to continue operating. Based on the above findings, this portion of the licensee's program appears to be adequate.
4.2.1.4 Meteorological Instrumentation The bases for the inspector's review of the licensee's meteorological measurements program included Regulatory Guides 1.23 and 1.97 and the meteorological criteria criteria set forth in NUREG-0654, NUREG-0696 and NUREG-0737.
The licensee outlined the characteristics of their meteorological measurements system in the Emergency Plan Procedures Section 3.4.3.
The integration of
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meteorological data into the licensee's dose projection scheme is summarized in the Emergency Plan Procedures Section 3.4.1, Rev. 5.
The inspector reviewed the licensee's meteorological instrumentation and its associated preventive maintenance program.
l The current meteorological instrumentation provides the basic parameters (i.e.,
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wind direction, speed and an estimate of atmospheric stability) necessary to perform the dose assessment function. Data from the meteorological measurements
system were available in the control room at request on a computer terminal.
If l
the data is unavailable via the computer terminal, CP&L meteorologists in
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Raleigh, North Carolina can provide the onsite meteorological information.
In the event the onsite data is unavailable, the necessary data can be reached from the National Weather Service in Columbia, South Carolina The licensee has maintained a program for meteorological instrumentation inspection and preventive maintenance. The instrumentation in the meteorological shed is examined and checked at least two times each week.
Calibrations consisting of a complete electronic check of the systems is done every six weeks and all instruments are calibrated and replaced semi-annually.
In addition, CP&L meteorologists carry out a daily examination of the data for each of the five week days. The siting and exposure of the meteorological instrumentation of the
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towers at the time of the appraisal was acceptable.
The inspector concluded that the licensee had the capability to integrate appropriately meteorological data into the radiological assessment / projection procedures.
The shift operations personnel will obtain acceptable National Weather Service information on severe weather warnings and watches in the site vicinity from the load dispatcher.
Based on the above findings, this portion of the licensee's program appears to be adequate.
4.2.2 Protective Equipment 4.2.2.1 Respiratory Protection The inspector evaluated this area by inspection of the equipment and through discussion with licensee representatives.
The primary means of respiratory protection would be through in place filtering systems. Full-face masks are also provided for emergencies. There are 10 Self Contained Breathing Apparatus (SCBA) units provided for emergencies with 20 spare bottles.
Ten SCBA units with 20 spare bottles are also assigned to the fire
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brigade. There are also 10 Model 1 SCBA's which are considered out of service, but still useable.
The compressor used to refill the SCBA bottles is located in the Fire Equipment Building. A backup capability exists at the Hartsville Fire Department.
i Based on the above findings, this area of the licensee's program appears to be adequate.
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4.2.2.2 Protective Clothing
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Stores of protective clothing are reserved for use and would be readily available under emergency conditier:
This protective clothing is in the stores area of the maintenance shop near tne emergency Operation Support Center area where the emergency teams would standby if activated.
Protective clothing could also be obtained from the regular in plant stock, from other storage facilities onsite, from the Brunswick nuclear facility, and from nearby supply companies.
The inspector discussed the subject with the stores foreman and observed the stores of emergency protective clothing.
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Based on the above findings, this protion of the licensee's program appears to be adequate.
4.2.3 Emergency Communication Equipment This area was reviewed with respect to the requirements of 10CFR50.47(b)(6)
10CFR50 Appendix E, Paragraph IV.E., and specific criteria in NUREG-0654,Section II.F.
The Emergency Communication equipment was described in Sections 3.2.9, 3.2.12, 3.3.2.2, 3.5 and Appendix A of the Plan and PEP's 2.2 - 2.5, 2.6.14 and 3.1.1 -
3.1.3.
The licensee has numerous separate communications systems:
Public Address System (PA); PBX Telephone System; Key System Telephones; Sound Powered Telephone System; VHF Radio Transcivers: Emergency Telephone and Radio System; Plant Security; Corporate Telephone Communication System Commercial Telephone; Dedicated Telephone System to Load Dispatcher; Corporate Emergency Communication Network; Load Dispatcher Radio Communications; Corporate Information Data Communications; NRC Emergency Notification System (ENS) and NRC Health Physics Network (HPN).
The inspector reviewed the above procedures, inspected communication facilities and discussed with licensee representative emergency communications in the emergency response facilities (See 4.1.1.1 - 4.1.1. 4).
There is an onsite aural alarm system implemented for Local and Site Evacuation and Fire notifications. During the weekly test of the alarm system, in one area on the second floor of the turbine deck in the south east corner, the audible alarm was not heard while ear plugs were used.
Each of the emergency communication networks have a backup system and a redundant power source. Provisions for routinely checking the operability of emergency communication devices and equipment are discussed in Section 5.5.2 of this
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report. The offsite Public Notification System (PNS) is discussed in Section 5.4.1.
There is a 24-hour per-day capability to notify the NRC, State and local authorities.
Based upon the above findings, this portion of the licensee's program appears adequate; however, the following item should be considered for improvement:
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Ensure emergency alarms are noticeable in high noise area (50-261/82-02-20).
o 4.2.4 Damaje Control / Corrective Action and Maintenance Equipment and Supplies
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(5.4.5 Repair / Corrective Action)
The Damage Control, Corrective Action and Maintenance Equipment and Supplies area was reviewed with respect to the requirements of 10CFR50 Appendix E, Paragraph IV E and G and the criteria in NUREG-0654,Section II.H.
The Damage Control / Corrective Action function at HBR was described in Section 3.2.2, 3.2.8, 4.3, 5.11 and 6.3 of the Plan and PEP 2.6.11 and 3.10.
The Emergency Repair Director (ERD) is responsible for management of efforts to repair and maintain equipment during an emergency, install emergency structures,
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install systems and components, and perform mitigation and clean-up activities during an emergency. He provides direction to any Damage Control Team and to the OSC Leader. PEP 2.6.2 describes the ERD's responsibilities, objectives, actions, scope and authority.
The ERD is designated in the Plan:
Primary-Maintenance Supervisor, Aiternates-Engineering Supervisor and Maintenance Engineer. The Damage Control Team Leader (DCTL) and members are selected by the Site Emergency Coordinator and the ERD, according to the nature of the task.
PEP 2.6.11 describes the DCTL's responsibilities, objectives, actions and limitations. PEP 3.10 describes the Damage Control Team's activities.
Other corrective actions that may be taken to mitigate various emergencies are documented in the Fire Protection procedures and the Security Plan and procedures.
Of fice assistance can be provided by the Brunswick Steam Electric Plant, Harris Energy and Environmental Center, EBASCO Services, Westinghouse and INPO.
Based upon the above findings, this portion of the licensee's program appears to be adequate.
4.2.5 Reserve Emergency Supplies and Equipment This area was reviewed with respect to the requirements of 10CFR50.47(b)(8);
10CFR50 Appendix E, Paragraph IV E and G and the criteria in NUREG-0654 Section II.H.
HBR relies on the normal inventory of supplies (e.g.,
survey instruments, protective clothing, respirators) to support augmented emergency operations.
If additional equipment is necessary, the following agencies could be called upon by CP&L to support this need: Harris Energy and Environmental Center; Department of Energy, Savannah River Operations; BSEP; and South Carolina Electric and Gas.
There appears to be no procedures describing the establishment, stocking and issuing of reserve emergency supplies and equipment. This was discussed with the Senior Specialist-Emergency Planning and the Stockroom Foreman. There is a small inventory of protectiva clothing stored separately in the stock room marked as reserve eneroency equipment.
It appears that this is backup for the Emergency Kit in the OSC. There are maximum stock levels established for such supplies.
Outage utilization is the criteria used to establish these levels. These stocks are inventoried each time an item is issued.
Based upon the above findings, this portion of the licensee's program appears to be adequate; however, the following item should be considered for improvement:
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Provide a procedure describing stockage, issuance, and inventory of the resarve emergency supplies and equipment (50-261/82-02-21).
4.2.6 Transportation The transportation area was reviewed with respect to the requirements of 10CFR50.47(b)(8); 10CFR50 Appendix E, Paragraph IV E and G; and the criteria in NUREG-0654,Section II.H.
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There are vehicles set aside and specifically designated for use in supporting the emergency response. A number of automobiles and trucks are available onsite for use during normal and emergency conditions.
The Environmental Monitoring Team has a four wheel drive truck that is used normally to collect on and offsite samples weekly. This vehicle is available and controlled by the Environmental and Chemistry Foreman (Environmental Monitoring Team Leader).
Ambulance and fire services are provided from offsite. The onsite maintenance department and security force have trucks of various weight rating and carrying capacity and others vehicles that can be made available for emergency purposes.
Based on the above findings, this portion of the licensee's program appears adequate.
5.0 Emergency Implementing Procedures 5.1 General Content and Format The emergency implementing procedures (PEP's) were reviewed to determine that there was a procedure to implement ef fectively each section of the Emergency Plan and that each procedure contained sufficient information and was in a format that provided clear guidance to the emergency organization. The Robinson PEP's were found to be adequate to implement the Emergency Plan and were determined to provide sufficient information concerning responsibilities, authority and sequential actions to be taken so that the overall response of the emergency organization was orchestrated. The procedures included appropriate references to other plant procedures needed to supplement the actions required. Based on the above findings, this portion of the licensee's program appears to be adequate.
5.2 Emergency Alarm and Abnormal Occurrence Procedures The Robinson Annunciator Alarm and Abnormal occurrence procedures were reviewed and discussed with operations personnel to determine the adequacy of the interface between these procedures and the Emergency Plan and Implementing Procedures. Several of the abnormal occurrence procedures referenced applicable Emergency Instructions; however, none of these procedures keyed the operator into the initiating actions for the Emergency Action levels of implementing procedure PEP 2.2 through PEP 2.5.
Discussion with operations personnel indicated that these procedures are intended for use by the control room operators and that additional actions to be taken in a given situation are dictated by the Shif t Foreman or other supervisory personnel.
In addition, with the recent upgrade of e
the Emergency Plan and procedures there is a clear pathway to identifying and classifying an emergency condition, with respect to the Emergency Plan through implementing procedure PEP 2.1.
The Shif t Foreman is responsible for classifying an emergency; however, all operations personnel are trained in the sequential process of identifying and classifying an emergency using this procedure.
Based on the above findings, this portion of the licensee's program appears to be adequate.
5.3 Implementing _ Instructions
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Implementing instructions at the Robinson Plant, Unit 2, are identified as Emergency Instructions (EI's). These instructions identify emergency actions to be taken by operations personnel in the event of several identified emergency conditions concerning the operation of the plant. The EI's were reviewed with respect to the interface between identified emergency conditions in the EI's and the Emergency Plan and implementing procedures (PEP's). A few of the EI's reference the Emergency Plan although not all EI's which may be directly related to an existing condition of an EAL contain a reference to the appropriate PEP.
Discussions with operations personnel indicated that reference to the Emergency Plan in the EI's were included prior to the upgrade of the Emergency Plan and PEP's and that such references were no longer necessary since the operators are trained in the use of PEP 2.1, Initial Emergency Actions. This procedure is essentially a step by step guide in classifying an emergency condition based on the four categories of emergencies contained in PEP 2.2 through PEP 2.5.
All operations personnel are trained in the identification and classification of energencies using PEP 2.1.
Based on the above findings, this portion of the licensee's program appears to be adequate.
5.4 Implementing Procedures 5.4.1 Notification The licensee has developed implementing procedures which provide for notification of the onsite emergency organization and offsite organization to include the corporate organization, contractor, and governmental agencies (local, state, and federal ).
The extent of notification is dependent upon the emergency classification. The licensee classifies emergencies in accordance with NUREG-0654 criteria, i.e., unusual event, alert, site emergency, general emergency. The licensee makes the classification determination based on emergency action limits prescribed for the various emergency classifications in PEP 2.1.
Plant emergency procedures, PEP 2.2 - 2.5, contain instructions concerning issuing announcements to the plant staff over the plant paging system and provide for issuing messages to key points of contact in the onsite emergency organization and the offsite agencies.
Preplanned messages for each emergency classification are found in these procedures.
To insure that appropriate agencies and organization are contacted, a checklist is provided within the procedures for each emergency classification. Telephone numbers for various emergency response organizations and key points of contact are provided in Appendix A to plant emergency procedures.
Licensee representatives indicated that these numbers were periodically reviewed and updated.
The inspector inquired about licensee provision for authentication for notification to offsite authorities. A " call back system" is used as an authentication scheme. The details of the authentication scheme is provided in PEP 3. An unresolved item (50-261/81-33-03) was reviewed which concerned notification of of fsite agencies during an alert emergency during 1981.
The licensee did not notify the State of South Carolina within 15 minutes of the declaration of an alert as required by:
10CFR50, Appendix E, paragraph IV.D.3; the planning standard of 10CFR50.47(b)(5); and specific criteria in NUREG-0654, Appendix 1.
The Robinson Emergency Plar states that notification of offsite agencies will be made in accordance with emergency procedures PEP 2.2 through 2.5.
Footnotes in attachments to these classification procedures concerning immediate notification of offsite agencies, provide up to 60 minutes to notify identified agencies for each emergency classification. While the time frame provided for the Ususual Event class may be appropriate, if agreed upon by the State of South Carolina, the notification time limits for the alert through general emergency classes are at variance with the requirements noted above. UNR 50-261/81-33-03 is closed and a preparedness program deficiency is identified concerning notification of of f site agencies.
Based on the above findings, the following deficiency is identified:
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Implementing procedures do not provide for notification of State and/or local governmental agencies within 15 minutes of the declaration of an alert or higher class of emergency as required 50-261/82-02-22).
5.4.1.1 Prompt Notification System
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The inspector reviewed the licensee's program for prompt notification and alerting offsite response organizations and the general public. The licensee has installed sirens as a warning system within the 10 mile EPZ.
Licensee records show that 45 sirens have been installed.
The inspector reviewed design and operations information for the siren system.
The inspector observed siren systems at five locations near the plant. Siren are mounted on utility poles and are omni-directional in that they may be rotated 360.
The licensee indicated that testing of the sirens had been conductea. The inspector reviewed selected test resalts. Two siren tests, the silent test and growl test, were performed in accordance with the test guidance in Appendix 3 to NUREG-0654.
Licensee representatives indicated that the system was fully operational and placed in service on February 1, 1982.
Licensee representatives indicated a full scale test of the entire system was planned for later this year.
The inspector discussed the operation and activation of the siten system with emergency preparedness personnel from Darlington County. The Darlington County emergency preparedness coordinator indicated that he participated in testing of e
five sirens and was satisfied with the results.
The inspector reviewed Darlington County procedures for activation of the siren system. The procedure designates those personnel having authority to authorize activation of the siren system. On February 2, 1982, the inspector verified that the siren encoder was in place and operational at the Darlington County sherif fs office. The inspector discussed methods for notifying local officials regarding activation of the siren system with Darlington County officials and licensee representatives. The use of dedicated phones was discussed with local officials and licensee representatives.
Transmittal of messages via the EBS system was also discussed. According to local officials and licensee representatives no preplanned messages are available for broadcast over the EBS at this time. The inspector discussed the merit of such messages.
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i The inspector discussed the prompt notification system with plant public information specialists.
The public information specialist indicated that news media coverage was given to the testing of the siren system during the week of January 11, 1982.
The inspector reviewed licensee news releases concerning the test and reviewed a local newspaper account of the siren test program.
The inspector also discussed the prompt notification system with representatives from WHSC, a radio stction in Hartsville.
The representative indicated that radio coverage was given to the test program. The representative indicated that they received numerous inquiries concerning the tests during the week the tests were conducted.
Based on the above findings, this area of the licensee's program appears adequate; the following area should be considered for improvement:
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Picticipate with state and local officials in evaluating installation of dedicated phone systems for use in emergencies and assist local / state agencies in development of technically accurate EBS message (50-261/82-02-23).
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Develop a procedure and train operators in the use of the Robinson Emergency Radio System which connects the TSC with the State of South Carolina EPD (50-261/82-02-24).
5.4.2 Assessment Actions The licensee's procedures for assessing the radiological consequences of an accident were reviewed with respect to the requirements of 10CFR50.47(b)(9),
10CFR50, Appendix E, Paragraph IV.B. and specific criteria in NUREG-0654,Section II. I., II.J., and II.M.
There is no single procedure for assessment action.
However, the appropriate procedures are found in the Plant Emergency Procedure (PEP) Section 2.1 through 2.5 with references to other sections as needed. The Site Emergency Coordinator has full responsibility for all actions under the plan.
In the initial stages between recognition of an emergency and the Site Emergency Coordinator assuming control, the Shif t Foreman acts as Interim Site Emergency Coordinator.
The PEP's in Section 3.6 provides adequate means for the assessment of the source term during a release of liquid or gaseous ef fluents from the plant. The PEP's in Section 3.4 provide several means for hand derivation of dose protections, automated dose projections and the determination of dose isopleths which would be drawn by hand.
The dose projections would be confirmed and further refined by data derived from plume tracking and the expanded monitoring procedures in PEP Section 3.5.
The PEP's are designed to yield dose projections from either a puff or continuous release at the site boundary, 1, 2, 5 and 10 miles from the release point.
However, the procedures allow scaling down to as close as 1 meter from the source. The sources covered are the containment building, main stack, air ejector, fuel building, and steam lines. At the present time, not all process monitors are operational, even though they are in place and appear to meet the requirements of NUREG-0737 (see section 4.2.1.2).
There are effective back-up manual methods for deriving the needed data for dose projections.
The plan provides for repeated assessments at no longer than 30 minute interval assessment data.
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Based on the above findings, this portion of the licensee's program appears to be adequate.
5.4.2.1~
Offsite Radiological Survev.
The inspector evaluated this area by reviewing the Emergency ~ Plan, PT-43 and
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PEP's, and through discussion with licensee representatives.
i Equipment to be used to_ perform _ emergency of f site.radiolog ical surveys i s specified in PI-43, and methods are specjfied dn tre '3.5. series of PEP's.
Of fsite monitoring is divided into three areas, each covered.by a. procedure:
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PEP-3.5.1, Confirmation of Initial Of f-Site Dose Projections
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PEP-3.5.2, Expanded Environmental Monitoring PEP-3.5.3, Plume Tracking by Actual Measurement-
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Of fsite monitoring is coordinated'witir the Sta e progsaEF.through PEP-3.5.4.
Of fsite monitoring is usually done at prepositioned survey'l points depending on wind direction and the particular type of monitoring. Maps are,provided in the.
monitoring kits with mon.toring points or locations marked on them.
Provision is made for recording all required data with exception of:
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Name(s) of individual (s) who' performed the survey, Identification of instrument used (type and serial number),
Air sampler flow rate, and
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Background radiation at time of each count.
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Provisions ii made for iabeling and dispositior', of al1 environmental semp1~es, but-
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not for disposition' of data recorued by the Eny'ironmental Monitor.ng Team.
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Communication equipment is specified in PT-43, but noither" primary < f secondary
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means of communications is 'sp'ecified in the PEP-3r5 series 6f prccedures. A licensee representative stated that the initial monitering team wou'd pick up the designated radio and use the E&C truck for transportation while tne other team would use a radio-e, quipped vehicle.
High and Icw range dosibeters,-protective clothing, rain suits, and respirators
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are provided in the Environmental Moni toring. Kits PEP-2 ~ 6'.6., paragraph 3.1.8
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specifies that exposure control,is in accordance with PEP-3.7.1.
Based on the above findings, this area of the licensee's prograr? appears to be adequate ['however., the following items should be considered for improvement:
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Data ' sheets should be changed to make provision f',r recording:
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Names of individuals performing surveys,
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Type and serial number of instruments used in survey,
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Air sampler flow rates, ahd
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isackground radiation at time of each count (50-261/$2-02-25).
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Provision should be inade 'f o r disposition of, cata sheets after s
monitoring team has completed job (50-261/82-02-26.).
5.4.2.2
.Onsite (out-of plant) Radiolooical Survey
The inspector evaluated this area through a' review of 'the Emergency Plan,
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procedure PEP's-3.3.L and 3.3.2; discussion with licensee representatives; and inspection of emergency instrumentation.
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Equipment to De used for the surveys may be taken from emergency kits or normal health physics stocks.
PEP-3.3.2 provides general ~ sur;vey and protection instructions enly.
A licensee representative stated that data sheets and
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Instructions in PEP-3.3.1 would be used in conducting onstte surveys, however, PEP-3.3.2 does not' ~ref er to PEP-3.3.1.
Based on the above findings, this area of the licensee's program appears to be adequate; however, the following should be considered for improvement:
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PEP-3.3.2 should be changed to either provide detailed instructions for survey in this area of should be cro'ss-referenced to equivalent instructions in PEP-3.3. (50-261/82-02-27).,
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Changes to PEP-3.3.2 should include:
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Instruction for labeling samples
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team Specify primary and, backup communication for onsite (out-of plant)
survey team (50-261/82-02-28).
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5.4.2.3 In-clant Radiological Surveys The inspector evaluated this area thrcugh a review of the Emergency Plan, procedure PEP's-3.3.1,
-3.7.1, and-2.6.7; discuss' ion with licensee i
representatives; and inspection of e nergency kits used by in plant teams.
Methods of conducting the in plant surveys are' specifie,d in PEP-3.3.'1.
Equipmer,t is listed in PT-43.
Instruments may be provided from regular bealth physics stocks.
Exhibits attached to PEP-3.3.1 provide a means to_ record required information for direct rsdiation surveys, airborne radiation surveys, and contamination surveys.
Samples are labeled in accordance with RCP's, but PEF-3.3.1 does not provide. labeling' instructions.
Samples are taken to the i
counting facility to be counted. Ne provisions is made for ' disposition of data sheets 9enerated by the in plant teams.
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Operability checks for communications equipment is mentioned in PEP-3.3.1, but equipment is not specified.
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26 Radiation protection guidance is provided in PEP-3.3.1, paragraphs 3.1 and 3.5, and PEP's-3. 7.1 and 2.6. 7.
Based on the above findings, this area of the licensee's program appears to be adequate; howaver, the following should be considered for improvement:
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PEP 3.3.1 should be amended to provide:
labeling instructions for samples instructions for disposition of original data sheets generated by the survey team (50-261/82-02-29).
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Primary and backup communications for the in plant survey teams should be specified (50-261/82-02-30).
5.4.2.4 Primary Coolant Sampling 5.4.2.5 Primary Coolant Sampling and Analysis 5.4.2.6 Post-Accident Containment Air Sampling 5.4.2.7 Post-Accident Containment Air Sampling and Analysis The interim post-accident sampling and analysis procedures were reviewed by the
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inspector and evaluated during walk-throughs to determine personnel familiarity with the procedures and procedural applicability.
These procedures were evaluated in accordance with requirements contained in 10CFR50, Appendix E, Paragraph IV.E, and selected criteria in NUREG-0654,Section II.I.
Prior to the delayed completion of the Post-Accident Sampling System (PASS),
referenced by a letter of extension which is addressed in Section 4.1.1.5 and 4.1.1.6 of this report, the licensee will continue to use the interim sampling system techniques. Procedures of compliance include CP&L PEP-3.3.3, " Collection of Very High Level Radioactive Samples," CP-3, Appendix I, " System Sampling Procedures," EI-16, " Post-Accident Containment Venting System," and P4432/20 -
Appendix A, " Containment Atmosphere Analysis."
The post-accident procedures were reviewed by the inspector and evaluted during walk-throughs to determine personnel familiarity with the procedures and procedural applicability.
Procedure PEP-3.3.3 and PEP-3.3.4 contains guidance relevant to all types of post-accident sampling.
They specify duties of the plant monitoring team, tasks to be performed, radioactive limits and actions to t'e taken, emergency response, sampling collection and analysis precautions, proper labeling and logging of samples, alternative analysis capabilities, contamination and radiation protection requirements, and personnel exposure control systems.
Procedures CP-3, EI-16 and P4432/20 contain detailed instructions for the collection and analysis of primary coolant and containment samples, specifies emergency type tools and equipment, valve lineups and counti :g techniques.
The CP&L sampling procedures provide detailed instructions for operation of the necessary equipment. Sampling points are identified and guidance is provided for
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the collection of samples from the primary coolant and containment.
Sample preparation steps prior to and including pH, boron, and chloride analysis are covered, however, the inspector noted that the undiluted reactor coolard sample which could be h'ghly radioactive in a post-accident. condition was being diluted on the work bench without shielding.
This observation was brought to the attention of the Environmental and Chenistry Supervisor which resulted in a CP-3, Appendix I procedural change while the inspector was on-site. The procedure now directs that undiluted post-accident samples are to be handled in a chemical hood protected by lead shielding.
Provisions exist to limit exposure to sampling personnel and verify the habitability of the areas occupied by the sampling personnel.
Each sampling team consists of an HP technician and a chemistry technician. The HP technician will provide HP monitoring services to ensure the areas are safe to enter and that exposures are held to a minimum.
Samples will be transported to the analysis area using appropriate shielding and under HP surveillance.
Data is analyzed using a desktop computer interfaced with a Ge(L1) Spectroscopy System.
The analytical method used should provide the analytical information required and a licensee representative indicated that the analysis could be performed within 1-2 hours following collection.
The remaining portions of post-accident samples upon completion of the analysis, unless instructed to retain, would be disposed in the hot laboratory sink and throughly flushed with potable water.
Based on the above findings, this portion of the licensee's interim program appears to be adequate, however, the NRC will review and evaluate the permanent PASS system when it is placed in operation.
5.4.2.8 Stack Effluent Sampling 5.4.2.9 Stack Effluent Sampling Analys_i_s i
The interim post-accident sampling and analysis procedures were reviewed by the inspector and evaluated during walk-throughs to determine personnel familiarity with procedures and applications.
These procedurs were reviewed in accordance with NRC regulations specified in Section 5.4.2.4 through 5.4.2.7 of this report.
Prior to the delayed completion of the PING-2A system referenced by a letter of extension which is addressed in Section 4.1.1.7 of this report, the licensee will continue to use the interim sampling procedures.
If an abnormal high release of e
radioactive particulate, iodine or noble gases is suspected from the main vent stack, the guidelines contained in ES-4, Appendix A,
" Gaseous Effluent Accountability," and other procedures referenced in section 5.4.2.4 through 5.4.2.7 of this report will be followed.
A primary concern is the elevated exposure rates which could be encountered while securing, transporting, counting, and disposing of the particulate filter paper and iodine cartridges.
The procedures cover protective factors such as time, distance, shielding, HP monitoring, dosimetry, protective clothing, re spi ratory protection, etc. required in sample retrieval preparation and analysis.
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Appendix A referenced above provides T guide for the ana'ysis of samples which are highly radioactive and cannot be counted on the low level counters. This is accomplished by taking direct radiation readings at predetermined distances and converting the mR/hr or CPM readings to pCi by the use of graph curves.
It was determined that the post-accident sampling procedures provide detailed instruction for the collecting, labeling, analysis and logging of samples and that the analytical results could be obtained within three hours.
Disposal of the high activity samples would be handled by HP personnel.
Basad on the above findings, the licensee's program appears to be adequate.
5.4.2.10 Li_ qui.d_ Effluent Sampling The licensee has no specific post-accident radioactive liquid effluent sampling procedure. The licensee representative stated that the routine effluent sampling and analysis program described in Procedure ES-3, " Liquid Waste Release", would be used. Procedures are available for the type sampling and analysis used in the accounting and release of low level liquid radioactive effluents. Continuous low level releases from the steam generators and batch type releases from the monitor tanks, waste condensate tanks and various other systems are released dependent on activity level per unit volume.
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In the event of a post-accident situation, the licensee's repr3sentative indicated that it would not pose an immediate problem since the disposal of high radioactive liquids could be contained and would not pose c problem since the processing of the liquid waste would more likely be required during the recovery phase following an accident.
The routine procedure listed above could be modified accordingly, or new procedures could be developed for specific situations if needed.
Based on the above findings, the licensee's program appears to be adequate.
5.4.2.12 Radiological and Environmental Monitoring Program The inspector evaluated this area by a review of the Emergency Plan and Procedures, inspection of equipment, and discussion with licensee representatives.
The Radiological and Environmental Monitoring Program is implemented under PEP-3.5.2, Expanded Environmental Monitoring. The program is implemented under the same management structure as other emergency off site monitoring.
Specific details of monitoring and sampling are found under E.S.-1, which is used for routine environmental monitoring and sampling.
Equipment required for this expanded sampling program is maintained in the E&C truck, which is used by the Environmental Team. When the EOF is activated, the expanded monitoring will be i
performed by the Corporate Environmental Teams, using their own equipment.
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Based on the above findings, this area of the licensee's program appears to be
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adequate.
i 5.4.3 Protective Action
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i 5.4.3.1 Radiation Protection During Emergencies Radiation protection during emergencies was evaluated against the requirements of 10CFR50.47(b)(11), and selected criteria in NUREG-0654,Section II.K.
There is no single energency procedure for radiation protection during an emergency. The appropriate emergency actions are covered by separate emergency procedures, Routine radiation protection activities are covered under separate Chemistry, Radiation Control and Environmental Control procedures. Procedures
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for radiation protection under emergency conditions are contained in Section 3.7 of the Plant Emergency Procedures (PEP) including emetgency work permits, exposure control, monitoring, dosimetry and protective gear.
Response to changing and ususual conditions are covered by PEP Section 3.3 including in plant and on-site monitoring and surveys, and the collection and analysis of very high level samples.
Additional measures are found in PEP Section 3.8, including access control and the administration of radioprotective drugs.
The overall responsibility for the above actions are given to the Radiological Control Director.
The responsibility for mitigition and decontamination activities is given to the Emergency Repair Director. Both report directly to
the Site Emergency Coordinator.
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Based on the above findings, this portion of the licensee's program appears to be adequate.
5.4.3.2 Evacuation of Owner Controlled Areas i
Section 4.4.2.2 of the Emergency Plan and Plant Emergency Procedure (PEP) 3.8.1, Evacuation, provide for the evacuation of areas within the site and the evacuation of the entire site at the discretion of the Emergency Coordinator.
Conditions for initiating evacuations are described in PEP's 2.2 - 2.5 which relate to the emergency action levels.
Evacuation routes are not designated in the plan or procedures; these would be announced over the P.A. system. The procedure specifies the assembly area for a site evacuation and requires an announcement of any alternate assembly areas for an area evacuation.
Oral announcements to be made on evacuation routes, alternate assembly areas, or o
other special instruction will be determined as required. No specific messages have been planned.
Plant emergency alarms and announcements, accountability procedures, search and i
rescue procedures, and security procedures combine to provide a means to verify t
that all individuals within the exclusion area have been warned of emergency conditions and nave followed instructions.
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Based on the above findings, this area of the licensee's program appears to be
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adequate; however, the following items should be considered for improvement:
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Provide for informing personnel of recommended evacuation routes from plant areas in emergency conditions (50-261/82-02-31).
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Specify the alternate assembly areas for a site evacuation in PEP 3.8.1 (50-261/82-02-32).
5.4.3.3 Personnel Accountability The procedures for personnel accountability were reviewed in regards to the requirements of 10CFR50.47(b)(10); 10CFR50 Appendix E, Paragraph IV B; and the criteria of NUREG-0654,Section II.J.
Personnel accountability measures to be placed in ef fect during emergencies are specified in paragraph 4.4.2.2 of the Plan; PEP 3.8.2 and PEP 3.9.6.
Personnel accountability procedures for Local Evacuation and Site Evacuation alarms are essentially the same. Personnel are to report to their supervisor / leader / director at the respective assembly / work /
emergency assignment areas.
Each supervisor accounts for personnel in his group and reports the results on the Emergency Accountability Form to the Evacuation Assembly Area Leader or Emergency Security Team Leader, as designated in the PEP.
The " Emergency Accountability Form" is completed by either listing the names and last known location of missing persons or entering none as appropriate. Accoutability is to be reported to the Site Emergency Coordinator by the Emergency Security Team Leader within 30 minutes of a declared Alert, Site of General Emergency.
Based on the above findings, this portion of the licensee's program appears to be adequate.
5.4.3.4 Personnel Monitoring and Decontamination The inspector evaluated this area by review of procedures and discussion with licensee representatives.
Monitoring is required for all personnel exiting from radiation control areas by Health Physics Procedure HP-28.
Monitoring at other points is specified in PEP's-3.3.2,
-3.7.2, and-3.8.4.
Information such as names, contamination levels, and survey instrument used is recorded on form #HP-28-1.
Provision is not made for recording of decontamination methods used for skin.
Contamination levels that require decontamination are specified in HP-28.
In an emergency, initial decontamination is attempted in accordance with PEP-3.9.5.
If these initial attempts are unsuccessful, reference is made to HP-28 for other methods.
If decontamination as specified in HP-28 is ensucressful, futher attempts will only be done as determined by a physician.
HP-28 specifies routing and disposition of form HP-28-1, but no procedure specifies handling and disposition of the form during an emergency condition.
A licensee representative stated that vehicle monitoring is recorded on a routine survey form, however, the PEP's have no provision for recording identification and results of monitoring and decontamination attempts on vehicle l
Based on the above findings, this area of tne licensee's program appears to be adequate; however, the following should be considered for improvement:
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Provide for recording decontamination methods used for skin and record results decontamination attempts (50-261/82-02-33).
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Provide for handling and disposition of form HP-28-1 or equivalent when used under emergency conditions (50-261/82-02-34).
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Add provisions tc appropriate PEP to include instructions for recording identification ana results of monitoring and decontamination on vehicles (50-261/82-02-35).
5.4.3.5 Onsite First-Aid / Rescue The inspector evaluated this area by review of Appendix E of the Emergency Plan, review of PEP's 3.9.2, 3.9.3, and 3.9.6, and discussion with licensee representatives.
The methods for receiving, recovering, transporting and handling injured persons who may also be contaminated are specified in the three PEP's.
Adequate provisions exist for retrieval of monitoring devices from injured personnel.
These provisions result in the colsure of open item 81-06-19. Criteria for using the of f site medical treatment facility are discussed in PEP's 3.9.2 and 3.9.3 and in Appendix E of the Emergency Plan.
Initial evaluation and treatment may be done at the plant with advice from a physician if determined necessary.
Treatment may also be done at the plant medical facility by a physician if it was not determined that hospitali:'ation was required.
Radiation protection guidance is provided for the search and rescue team in PEP 3.9.2 and PEP 2.6.8 in which the Team Leader is referred to PEP 3.7.1.
Based on the above findings, this area of the area of the licensee's program apepars to be adequate.
5.4.4 Security During Emergencies Procedures for Security Support during emergencies were reviewed in regards to the requirements of 10CFR50.47(a) and (b); 10CFR50 Appendix E, Paragraph IV A; and criteria in NUREG-0654,Section II.A.
Security measures to be placed in ef fect during emergencies are specified in paragraph 3.2.7 of the Plan, POM Security Procedure S-14, and PEP 2.6.10 and 3.8.4.
Security personnel are relied upon to perform certain predetermined actions. These include maintaining plant security, personnel accountability, escorting emergency vehicles and searching CP&L property outside the controlled area to include Lake Robinson within the approximately 1400 ft.
radius exclusion area during Site Evacuation.
The inspector also verified that arrangements have been made to include security access procedures in exercises and procedures had been revised concerning access to the site for emergency vehicles. These action result in closure of open items 81-06-11 and 81-06-18 respectively.
Based on the above findings, this portion of the licensee's program appears to be adequate.
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5.4.5 Repair / Corrective Action (See Section 4.2.4)
5.4.6 Recovery The inspector reviewed Section 7.0 of the Emergency Plan and applicable sections of the Corporate Emergency Plan and discussed recovery organization and operations with licensee representatives. The Emergency Response Manager would determine when the recovery phase is to be entered and would actuate the Recovery Organization.
The recovery ef fort provides for evaluation of both onsite and offsite conditions and consequences. The Emergency Plan describes the transition from the emergency organization to the recovery organization, specifies the key positions in the recovery organization, and describes the licensee's preplanning to effect recovery from an emergency.
The specific Recovery Organization is described in the Emergency Plan and Corporate Emergency Plan, with individuals and alternates identified, by title, to fill the key positions.
The inspector also determined that the recovery center functional responsibilities were redefined in accordance with NUREG 0696 and provisions were made for improving visual aids in the recovery center.
Consequently, open item 81-06-13 and 81-06-14 are closed.
Based on the above findings, this area of the licensee's program appears to be adequate.
5.4.7 Public Information Licensee procedures adequately identify the organizations involved in news dissemination. This includes organizations within the company, State of South Carolina, NRC, and news media outlets. These procedures specify the location of the organizations and describe the methods for contacting them. The procedures also provide methods for coordinating the dissemination of information to the organizations needing such information.
A review of corporate communications implementation procedures revealed that the procedures should be expanded to specify clearly how interim provisions for inital dissemination of information to the news media should be handled prior to establishment of the news center. This matter was discussed in detail with licensee representatives.
Licensee procedures identify the utilities spokeman. However, the procedures do not appear to address the spokesman's primary or major sources of current information (e.g., EOF, corporate, control room). The licensee has provided for coordinating information among spokesman from other organizations.
The inspector evaluated the licensee's program for rumor control. The licensee has made provisions for rumor control coordination with the news information func. ion from other organizations. The inspector noted that the licensee rumor contral program is weak from the standpoint that no provisions existed to notify the public of the 24-hour-a-day rumor control phone number.
Based on the above findings, this area of the licensee's program appears adequate; however, the following areas should be considered for improvement:
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Expand corporate procedures to describe how initial information will be disseminated to the news media prior to establishment of the news media center (50-261/82-02-36).
Identify the official of point of contact for information to be used by the corporate spokesman (50-261/82-02-37).
Specify how the general public will be notified of the rumor control telephone number (50-261/S2-02-38).
5.5 Supplementary _In formation 5.5.1 Inventory, Operational Check and Calibration of Emergency Equipment, Facilities and Supplies The inspector evaluated this area through a revies of the Emergency Plan and selected Emergency Procedures, discussion with licensee representatives.
Part 4.2.1.1 of this Appraisal Report also addresses portions of this functional area review.
Responsibilities for emergency kits are assigned to the Emergency Planning Coordinator by PEP-4.2.
Specific details pertaining to the kits are delineated in PT-43, which provides a specific listing of emergency equipment with the exception of emergency communications equipment.
This discrepancy is tracked under section 4.2.1.1 of this Appraisal.
Frequencies of inventories, operational checks, and calibrations are specified in PT-43 for all equipment listed as component of an emergency kit.
Based on the above findings, this area of the licensee's program appears to be adequate.
5.5.2 Drills and Exercises The licensee's program for drills and exercises was reviewed with respect to the requirements of 10C FR50. 47( b)( 14 ), 10CFR50 Appendix E, Paragraph IV.F, and criteria in NUREG-0654 Section II.N.
Plant exercises and drills are administered by the Emergency Planning Coordinator in accordance with Section 6.1.2 of the Plan and PEP 4.3, Performance of Training, Exercises and Drills.
Scenarios were developed for the exercises e
conducted on March 11 & 12, 1931 and December 15, 1981 (See IE Reports 40-261/S1-6 and 50-261/81-28).
Documentation and evaluation of all observer i
comments have been collected in critiques after the exercises and responsibilities have been assigned by management to assure that corrective actions are implemented.
Administrative Instruction (AI-12), Plant Reports, secti a 12.7, Procedure for Plant Tickler and Regulatory Action Item List (RAIL),
is currently being revised to incorporate the RAIL system.
The purpose of the RAIL system is to assure that the NRC's findings requiring responses and/or actions are responded to in a timely manner.
The inspectors discussion with specialists responsible for RAIL provided assurance that the licensee's response to the CP&L exercise critique findings will be incorporated into RAIL in the AI-12, section 12.7 management control system.
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Drills are conducted as part of the training programs for health physics and the fire brigade. The health physics drills conducted prior to the March 11-12, 1981 exercise included radiological monitoring and in plant radiation protection activities.
The health physics work has been reorganized such that these two functions are now the Radiation & Control Section and the Environmental &
Chemistry Sections; no in plant radiation protection drills have been conducted since March 12, 1981.
Section 6.1.2.1, of the Emergency Plan and PEP 4.3, commit to semi-annual rac1ation protection drills.
The annual medical emergency drill was incorporated into the annual full scale exercise on March 11-12, 1981.
A medical training session was conducted November 4,1981 with Byerly Hospital and Darlington County personnel.
According to Section 6.1.2.1 of the Emergency Plan the frequency of communications drills with state and local governments are stated to be monthly within the plume exposure EPZ and quarterly within the ingestion pathway EPZ.
This is consistent with NUREG 0654 criteria. Powever, PEP 4.3 states that the frequency of communication drills with state and local governments will be quarterly and communication dirlls with state and county Emergency Operations Center and field assessment teams will be annually.
Based on a review of licensee records and conversations with licensee representative during the period April 1, 1981 - February 4, 1982 the licensee apparently failed to onduct quarterly communications tests as required by PEP 4.3.
The inspector also discussed the merit of using standard messages contained in PEP's 2.2 through 2.5 and inclusion of the personnel / organization noted in PEP -Appendices A-1 through A-4 in future communication drills.
Fire drills were held in accordance with the Fire Protection Manual, Section 6, Fire Drills Program.
The inspector discussed the subject with the senior specialist in charge, reviewed the documentation for the Fire Brigade drill conducted Spet.mber 17, 1981 and the December 29, 1981 drill with the Hartsville Fire Department, and observed the equipment in the fire equipment house.
News media coverage of the annual emergency exercise should be added to the performance objectives and the tasks to be evaluated as stated in the Plan, Section 6.1.2.2 and PEP 4.3 item 3.3.3.
Public information services should be incorporated into the Plan such that their procedures, equipment and facilities are exercised annually.
The failure to follow procedure PEP 4.3 which specifies the frequenc requirements for in plant radiation protection drills and communication drills is an apparent violation of Technical Specification 6.8.1.
(50-261/82-02-39).
In addition to the above apparent violation the following should be considered for improvement:
Incorporate the individual items of the CP&L critiques of exercises and drills into the tickler and tracking system of Procedure AI-12 (50-261/82-02-40).
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Preplanned messages similiar to those in PEP-2.2 to 2.5 should be used in communication drills (50-261/S2-02-41).
Clarify the frequencies to be used for the communication drills to eliminate the differences in the requirements as stated in the Plan section 6.1.2.1 and PEP 4.3, item 3.2.1.1 (50-261/S2-02-42).
Incorporate the news media coverage of major exercises into the drills and exercise section of the Plan and PEP 4.3 (50-261/S2-02-43).
5.5.3 Review, Revisions and Distribution The review, revision, and distribution of the emergency plan implementing procedures were evaluated in accordance with requirments contained in 10CFR50.47(b)(16),10CFR50, Appendix E, Paragraph IV G., and selected criteria of NUREG-0654 Section II.P.
The Emergency Plan Implementation Procedures are reviewed and updated yearly; the
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Plant Nuclear Safety Committee is responsible for this review. Telephone numbers
are reviewed quarterly. Changes resulting from drills or changes in the facility or enviror.s are incorporated into the emergency plan. Plan and procedures were distributed as required.
The emergency plan and procedures had been reviewed and approved and updated in calendar year 1981.
This was documented in the minutes of the Plant Nuclear Safety Committee which met following the March 1981 exercise.
Changes to the Emergency Plans and Procedures are distributed by Document Control in accordance with the approved distribution list. Also, a random selection of the names, titles and phone numbers in the implementing procedures were found to be current.
Documentation forms are available to provide records for future reference.
Based on the above findings, this portion of the licensee's program appears to be adequate.
5.5.4 Audit The audit program was reviewed against requirements of 10CFR50.54(t),10CFR50, Appendix E, Paragraph IV (G), and selected criteria in NUREG-0654,Section II.P.
The inspector reviewed Section 6.2.2 of the Emergency Plan and discussed the area o
of audits with licensee representatives.
The Emergency Plan states that independent audits will be performed every year by the Emergency Preparedness Unit of the Corporate Technical Services Department and the Corporate Quality Assurance Department (CQAD).
No specific procedures have been developed for assuring performance of these audits or for acting on the results of these I
audits. Although an audit has not yet occurred, it has not been a year since the required implementation date for Emergency Plan / Procedures.
The inspector reviewed the Corporate QA Program, Section 16, Audits,and CQAD-1, Procedure for Corporate and ASME QA Audits. Neither the Corporate QA Program nor the procedure for conducting an audit provide for an evaluation of the Emergency Preparedness capabilities and procedures.
The site QA group performs surveillance activities only ano ssists CQAD on audits of drills and exercises
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at Robinson. The inspector reviewed the site surveillance reports for both the medical drill on October 2, 1981 the small scale radiological exercise of December 15,1981 (See IE Report No. 50-261/81-28). Based on the above findings, this area of the licensee's program appears to be acceptable.
6.0 Coordination with Offsite Groups 6.1 Offsite Agenci_e_s An evaluation was conducted of the licensee's program for coordination with offsite agencies.
The evaluation was conducted by interviewing licensee and offsite personnel, review of licersee procedures, and review of written agreements with offsite agencies.
The inspector noted that the licensee has obtained formal written agreements concerning emergency support with the State of South Carolina Emergency Preparedness Division, Oak Ridge Associated Universities (REACTS Program), and seven local agencies. All agreements had been signed by appropriate parties within the last year.
The inspector discussed the agreement content with selected offsite agencies.
All agency personnel interviewed seemed knowledgeable of the agreements and appeared to bc willing to carryout their emergency support commitments.
All agency representatives interviewed indicated that they had good relations with licensee amergency planning personnel.
A review of licensee records showed that offsite agencies participated in radiological exercises.
Selected offsite agency personnel were interviewed concerning their participation in radiological exercises. The agency personnel interviewed indicated that they found the exercise to be a valuable training experience.
The inspector reviewed the document control program for distribution of plans and procedures to offsite agencies. According to licensee records, controlled copies of the emergency plan and procedures are provided to local government emergency service agencies that operate within the plume exposure (10 mile) EPZ. Copies of the emergency procedures are also provided in the emergency kits at the Byerly Hospital in Hartsville.
Based on the above findings, this portion of the licensee's program is corsidered adequate.
6.2 General Public A review was conducted of the licensee's program for providing information to the general public.
Section 6.1.4 of the licensee emergency plan provides the planning basis for this program. The program provides for participation with the South Carolina Governor's Office Public Information Program concerning disaster preparedness public education.
Besides this program, CP&L conducts public education programs for persons living in the vicinity of the H. B. Robinson Plant. According to the licensee's plan and based on statements made by licensee representatives, this program consists of mailing informational brochures and presenting speeches to various local groups and organizations.
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The inspector reviewed brochures mailed to residents within the plume exposure EPZ during 1931. The inspector also reviewed the draf t brochures to be mailed in 1982.
It was noted that the draft brochure did not contain significant information concerning the warning sirens installed about the plant, nor did it contain information about actions to be taken upon hearing the siren.
Licensee representatives indicated that the brochure would be modified to reflect information concerning the siren system.
The licensee's provisions for dissemination of radiation emergency information to the transient population was reviewed. The inspector discussed the placement of informational brochures at localities where the transient use might be highest, e.g.,
hotels, motels, selected business firms, and local recreational areas.
Licensee representatives agreed to give consideration to this matter.
Based on the above findings, this area of the licensee's program appears adequate; however, the following areas should be considered for improvement:
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Distribute emergency information brochures at locations used by the transient population (50-261/82-02-44).
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Revise public information brochures to contain information pertaining to the siren system and subsequent actions (50-261/82-02-45).
6.3 News Media The licensee has a program for familiarizing the news media with emergency plans, points of contact for information, and basic information concerning nuclear plant operations and radiation and radioactive m;terial.
Licensee records show that such a program was conducted in 1981.
Licensee representatives indicated that such a program was planned for 1982; however, licensee procedures do not specify how f requent such a program should be conducted. The merits of an annual program were discussed with licensee representatives.
Based on the above findings, this area of the licensee's program appears adequte; however, consideration should be given to the following improvement:
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A documented commitment should be made to brief the news media annually on emergency preparedness matters (50-261/82-02-46).
7.0 Drills, Exercises, and Walk-Throughs
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7.1 Program Implementation The licensee has established and implemented a program for conducting drills and exercises.
The licensee maintains records of drills and exercises to include i
critique results and recommendations.
Licensee records showed that major exercises were coordinated with offsite agencies.
The inspector interviewed of fsite agency personnel concerning exercise coordination.
All off site agency personnel contacted indicated that the licensee had coordinated drill exercises with them in an adequate manner.
Details concerning implementation of this program are discussed further in section 5.5.2.
This area of the licensee's program appears adequat __
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7.2 Walk-Through_ Observation 7.2.1 Emergency Detection 7.2.2 Emergency Classification 7.2.3 Notification A walk-through exercise was conducted by the inspector to determine the capability of license personnel to include the Shif t Foreman to detect, classify, and iniate notification relevant to an emergency situation.
The licensee personnel were requested to take appropriate emergency action based on an off-site release supplied by the inspector. Licensee personnel took appropriate action as defined by plant procedures.
The licensee personnel appeared to be knowledgeable and will trained in emergency classification, emergency action levels (EAL's) and appropriate notifications.
Based on the above findings, this portion of the licensee's program appears to be adequate.
7.2.4 Off-site Dose Calculations Two Control Operators on different shif ts and an RC Technician normally assigned to the TSC during an emergency were selected for a walk-through on dose projections. The Control Operators were asked only to perform the task outlined in PEP 3.4.1 which also requires deriving the source term using PEP 3.6.1.
The RC Technicians was asked to perform most of the procedures in Section 3.4 of the PEP's.
Even though two of these individuals appeared to be very familiar with the procedures, all three experience significant difficulty in deriving the dose projections by hand calculational methods. Some of their difficulty appeared to be the fault of the format of the procedures.
In this connection, one individual made an error in units, resulting in a projected dose 1,000,00 times too high, even though a note in the procedure warned the user to check the units. A second individual made an error in entering raw data into his calculator, several times, which resulted in a projected dose 1,000 times too low.
The second individual was almost unable to perform the calculation be cause he was unfamiliar with the calculator available.
Later, when equipped with his own calculator, he experienced few problems. The automated method presented no problems and yielded accurate results rapidly.
During the exercise in June 1981, an open item was established as a result of an individual selecting the wrong calculational method (50-261/81-06-07). None of the individuals tested experienced this problem during this walk-through.
Consequently item 50-261/81-06-07 is closed.
However, it was difficult to determine how much of the problems actually encountered in the walk-through could be attributed to the format of the procedures and how much could be attributed to training, including use of available equipment. However, it was concluded that minimum confidence could be placed in obtaining accurate initial dose projections using hand calculational methods for PEP-3.4.1 and PEP-3.6.1 under emergency conditions.
Based on the above findings this area of the licensees program appears to be adequate; however, the following item should be considered for improvement:
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Provide training on initial dose projection procedures and review i
format of dose projection procedures to facilitate use (50-261/82-02-47).
7.2.5 Post Accident Samp Hng and Analysis 7.2.6 Containment Ai-Sampling and Analysis 7.2.7 In Plant Sampling and Analysis The Environmental and Chemistry and Radiation Control technicians who are responsible for obtaining post-accident sampling data were intreviewed and walk-throughs were conducted to determine their skills in an emergency situation pertaining to post-accident primary coolant, containment and liquid and/or effluent sampling and analysis.
The walk-throughs were directed toward each individuals training, operation of equipment, sample handling and analysis, counting techniques, procedure familiarity, and performance of their assigned tasks.
Each individual observed appeared to be capable of responding to the required tasks in an acceptable manner.
Based on the above findings, this portion of the licensee's program appears to be adequate.
7.2.8 Offsite Environmental Sampling and Analysis The inspector evaluated two groups of three Environmental & Chemistry Technicians each in this area. One technician in each group was asked to demonstrate how to load and unload the particulate filters and charcoal cartridges in the air samplers.
No discrepancies were noted in this part of the test.
All six personnel were then requested to write what information they would record on the sample envelope. All personnel recorded all important information, including some not required by PEP-3.5.1.
Each technician was then given required sections from PEP-3.5.1, including the data sheet; and Appendix A of E.S.-4, including the curves (3 & 4) required for environmental analysis.
They were then given data to fill out the data sheet (Exhibit 3.5.1-2) including essential data such as:
air sampler flow rate, sampling time, count rate on particulate filter, and count rate on iodine cartridges. They were then requested to determine activity on each filter (done by graphic method using count rate), and using filter activity and calculated total flow, to calculate the airborne concentration of particulates and iodines.
a One individual tried to apply instrument efficiencies to the graphical solution which gave incorrect answers, but he understood the correct method when it was explained. Normally, the environmental team would report filter activities, and c.oncentrations would be calculated by the Radiation Control Director.
The Radiation Control Director should be able to assist any teams experiencing difficulty in determining the sample activity or airborne concentrations. Based on the above findings, this area of the licensee's program appears to be adequate.
7.2.9 Protective Action Decision Making i
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l This area of the licensee's program was discussed with licensee representatives i
having responsibility for making protective action recommendations.
Licensee r
representatives appeared knowledgeable of procedures and protective action l
options available to them under various situations.
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Based on these findings, this area of the licensee's program appears adequate.
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8.0 Persons Contacted 8.1 Licen_s_ee Personnel CP&L Corporate
- R. C. Black, Jr., Director of Emergency Preparedness W. F. Trolenberg, Project Specialist, Emergency Preparedness R. Godwin, Senior Specialist, Emergency Preparedness CP&L Harris Center B. Meyer, Health Physics Senior Specialist CP&L Site
- R. B. Starkey, Plant General Manager
- R. Connally, Assistant to Plant General Manager W. Crawford, Man:ger, Operations and Maintenance
- S. Crocker, Manager, Environment and Radiation Control
- J. Curley, Manager, Technical Suponrt
- H. Young, Director. 0A/QC
- J. A. Eaddy, I&C Supervisor
- C. L. Wright, Regulatory Compliance Specialist
- !F. Gilman, Regulatory Compliance Specialist TD. Baur, QA/QC Specialist
- L. Williams, Senior Specialist - Security i C. A. Betner, Training Supervisor
. H. Barnes, Radiochemistry Technician
- J. Hill, Radiochemistry Technician D. Batton, Shif t Foreman
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E. Lee, Shi f t Foreman
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F. Watkins, Environmental Chemistry Foreman P,. Moore, Senior Control Operator T. Woenker, Junior Specialist Radiochemistry P. Odom, Senior Engineer - Mechanical Maintenance L. Sansbury, I&C Foreman R. Williamson, Planner Analyst R. Forgey, Radiochemistry Specialist W. L. MacCready, Radiation Control Supervisor R. Moore, Senior Control Operator e
D. Winters, Control Operator R. McGirt, Senior Generation Specialist R. Abbot, I&C Foreman J. Hardy, Control Operator P. Monroe, Stockroom Foreman A. Snipes, Communication Foreman M. L. Layton, Specialist, Environmental and Chemistry A. Taylor, Chemistry Technician C. Parrott, HP Technician T. Strout, Chemistry Technician
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P. Monroe, St es Foraman S. Andrews, Document Control Specialist R. Denny HP Foreman J. V. Rudisell, Security Chief B. Watkins, Administration Supervisor J. E. Brooks, Shift Foreman D. Boan, Radiochemistry Foreman In addition to the above persons, operations personnel, technicians and craf tspersons were contacted.
8.2 Other Organization D. Payne, TMI Coordinator - Westinghouse R. Muth, Site Service Manager - Westinghouse H. Shealy, Director, South Carolina Radiological Health L. Mimms, Director, Darlington County EPD N. G. Dudley, Sbariff Darlington County G. Ziebell, Dire tor, Hartsville Rescue Squad G. Perkinson, Cactain, Hartsville Fire Department T. M. Goldman, A>!ministrator, Byerly Hospital L. Morris, Corporal, South Carolina Highway Patrol N. Truesdale, News Director WHSC, Hartsville 8.3 NRC
- G. R. Jenkins, Chief. Emergency Preparedness Section, RII
- R. Van Niel, Section Leader, Emergency Preparedness Licensing Branch, IE:HQ
- S. Weise, Resident Inspector
- Attended management exit briefing on 2/4/82.