IR 05000269/1994012
| ML16154A605 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 05/13/1994 |
| From: | Barr K, Salyers G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML16154A604 | List: |
| References | |
| 50-269-94-12, 50-270-94-12, 50-287-94-12, NUDOCS 9406060126 | |
| Download: ML16154A605 (13) | |
Text
C'%"&pR REG&
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, ATLANTA, GEORGIA 30323 MAY 13 194 Report Nos.: 50-269/94-12, 50-270/94-12, and 50-287/94-12 Licensee:
Duke Power Company 422 South Church Street Charlotte, NC 28242 Docket Nos.:
50-269, 50-270, and 50-287 License Nos.: DPR-38, DPR-47, and DPR-55 Facility Name: Oconee 1, 2 and 3 Inspection Conducted: April 11-15, 1994 Inspector:
-
ez-( -S1309 G. W. alyers, pcy Preparedness Specialist Dae Signed Approved by: 'tK P.Barr,~Chief Wae Signed Emergency Preparedness Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards SUMMARY Scope:
This routine, announced inspection was conducted in the area of emergency preparedness, and included review of the following programmatic elements:
(1) Radiological Emergency Response Plan and its implementing procedures; (2) emergency facilities, equipment, instrumentation, and supplies; (3) organization and management control; (4) independent reviews/audits; and (5) trainin Results:
In the areas inspected, two non-cited violations (NCVs) were identified. The NCVs were: Failure to notify the NRC within 30 days of an Emergency Plan Implementing Procedure change (Paragraph 2). Failure to notify the NRC within one hour of losing 25 percent or greater of the Alert Notification System (Paragraph 3).
9406060126 940513 PDR ADOCK 05000269 G
The emergency planning program appeared to receive strong management suppor Emergency response facilities, equipment, and supplies were properly maintained. The requirements and commitments addressed by the emergency planning program were effectively managed by the licensee's staff. Training of emergency response personnel appeared to be effective and records of program activities were maintained and readily availabl This inspection concluded that the emergency response personnel were satisfactorily trained and the emergency response facilities and equipment were satisfactorily prepared to respond to a radiological emergency at the Oconee Nuclear Statio REPORT DETAILS Persons Contacted Licensee Employees
- P. Brandt, Safety Assurance, Emergency Planning
- R. Brown, Safety Assurance, Emergency Planning
- D. Dalton, Oconee Nuclear Station, Regulatory Compliance
- B. Dolan, Safety Assurance Manager
- T. Grant, Safety Assurance, Emergency Planning
- J. Hampton, Oconee Nuclear Station, Site Vice President
- C. Jennings, Oconee Nuclear Station, Emergency Planning Coordinator
- C. Yongue, Radiation Protection Other licensee employees contacted during this inspection included engineers, operators, technicians, and administrative personne NRC Resident Inspector
- K. Barr, Region II, Emergency Preparedness, Section Chief
- J. Harmon, Senior Resident Inspector
- W. Poertner, Resident Inspector
- Attended exit interview Abbreviations used throughout this report are listed in the last paragrap.
Emergency Plan and Implementing Procedures (82701)
Pursuant to 10 CFR 50.47(b)(16), 10 CFR 50.54(q), and Appendix E to 10 CFR Part 50, this area was reviewed to determine whether changes were made to the program since the last routine inspection (March 1993), and to assess the impact of these changes on the overall state of emergency preparedness at the facilit The inspector audited the Procedures Carts copies of the EPIPs, in Unit 1, 2, and 3 Control Room and the Emergency Telephone Directory, and EPIPs in the OSC, and the EOF. All documents audited by the inspector were the latest revision and properly maintaine The inspector reviewed the licensee's program for making changes to the EP and EPIPs. The inspector reviewed documentation of the licensee's changes to the EP and EPIPs (Volumes A, B, and C) since January 1993 to verify they were approved by management and submitted to the NRC within 30 days of the effective date, as required by 10 CFR 50, Appendix The inspector noted two incidents in which the NRC was not notified within 30 days of the procedure changes:
Change 93-09 to the Training Divisions Emergency Contingency Plan was dated May 10, 1993, and the NRC was notified of the change on June 30, 1993, (approximately 20 days past the required time limit).
- Change 93-10 to Engineering Directive 5.1 was approved for use on January 31, 1993, and the NRC was notified of the change on July 14, 1993, (approximately four months past the required time limit).
The late notifications were discussed with the licensee. The licensee explained that not all EPIPs are written by the Emergency Planning Organization, as an example, some of the EPIPs were written by Chemistry, Radiation Protection, and Health Physics, then forwarded to the Emergency Planning Organization for implementation into the EPIP The documents controlling site procedures, Site Directives 4.1.7, "Site Procedures," 4.1.8, "Scope and Administration of Site Directives," and 4.1.9, "Site Division and Group Manuals," did not address the issue of notifying the NRC within 30 days of changes to EPIP The licensee stated that they had identified the issue also and had taken corrective action. The licensee provided to the inspector a licensee copy of a "Memorandum To File" date October 20, 1993, in which the Manager, Emergency Planning discussed the necessity of notifying Emergency Planning group in a timely manner of EPIP changes. In the Memorandum To File, the Manager, Emergency Planning identified one EPIP and five section manual directives that had not met the 30 day notification requiremen In the Memorandum To File, the following action were identified to preclude a reoccurrence of a late notification:
Site Directives 4.1.7, 4.1.8, and 4.1.9 were revised on October 4, 1993 to require:
Emergency Planning to be placed in the review chain for all EPIP change *
Approved EPIPs be forwarded to Emergency Planning within three working days of approva *
EPIPs will be required to have a statement within the body of the procedure indicating that Emergency Planning should receive a copy of the procedure within three working days of approva *
Using the procedure index Master File, Emergency Planning will perform random audits of the table of contents of both Volumes B and C of the EPIP In addition to the Memorandum To File, PIP# 0-093-0701 was issued on October 22, 1993, concerning "timely notification to the NRC of EPIP changes." The PIP was classified as a moderately significant event based on an adverse trend. The PIP corrective actions were the changes to the Site Directives discussed in the Memorandum to File, notifying organizations having responsibility for portions of the EPIPs of the changes to the site directives, and reiterating to the notified organizations, the requirement of notifying the NRC within 30 days of a change to an EPI The inspector reviewed documentation of procedural audits performed by the Emergency Planning group as part of the corrective action discussed in the Memorandum to File. The audits did not identify any additional examples of the late notification to the NRC. The procedural audits were done December 28, 1993, January 1, 1994, February 1, 1994, and March 10, 199 The licensee was informed that the failure to inform the NRC within 30 day of a change to the EPIPs was a violation of 10 CFR Appendix Because the violation was discovered by the licensee and corrective actions were already in place, this violation will not be subject to enforcement action because the licensee's efforts in identifying and correcting the violation meet the criteria specified in Section VII.B of the Enforcement Polic NCV 50-269, 270, 287/94-12-01: Failure to notify the NRC within 30 days of making a change to the EP or EPIPs that do not decrease the effectiveness of the Pla The inspector reviewed the documentation indicating Oconee Nuclear Station had presented and reviewed the EALs with State and county emergency preparedness personnel. Neither the State nor the counties made recommendations for EAL changes at that tim No emergency declaration was made by the licensee since the last inspection in March 199 One NCV and no deviations were identifie.
Emergency Facilities, Equipment, Instrumentation, and Supplies (82701)
Pursuant to 10 CFR 50.47(b)(8) and (9), and 10 CFR 50.54(q), and Section IV.E of Appendix E to 10 CFR 50, this area was inspected to determine whether the licensee's ERFs and other essential emergency equipment, instrumentation, and supplies were maintained in a state of operational readiness, and to assess the impact of any changes in this area upon the emergency preparedness progra The inspector toured the licensee's CR, TSC, OSC, and EOF, and randomly selected and examined supplies and procedures and operationally tested equipment. All required supplies and current procedures were in place
and the equipment operated satisfactorily. The inspector concluded that the facilities were operationally ready, and in accordance with the description in Section H of the Emergency Pla The TSC was located adjacent to Unit I and 2 CR and the OSC was located adjacent to Unit 2 CR. In the TSC and OSC, the inspector randomly selected and examined supplies, verified the EPIPs were the latest revision, and operationally tested the overhead monitors and randomly selected communication equipment. The Units 1 and 2 ERDSs control consoles were located in the TSC and the Unit 3 ERDS console was located in the OSC. While conducting personnel interviews, operations interviewees using existing procedures, successfully activated all three unit ERDS up to the step prior to actually transmitting data to the NR No problems were noted by the inspecto The EOF communication system consisted of a network of individual telephones at each work station, and multiple direct exchange lines to Charlotte, Spartanburg, Oconee, Clemson, Greenville, and Anderson. In the event of a facility power failure, the primary EOF communication system had an eight hour battery backup power supply. Should the primary telephone system become inoperable due to a power failure, the EOF maintained a limited use, battery powered, backup "power failure telephone" system. As a further communication backup, the EOF maintained Amateur Radio Capability with Oconee county and Pickens county. The inspector noted each phone had a procedure card for dialing out attached to the phone underneath the receiver. The inspector performed several successful operational checks of various phones in the EOF. In order to demonstrate the availability and operability of the system used to electronically transmit plant information in the EOF, the licensee activated the 36 inch overhead monitor and a work station computer in the EOF. No problems were noted with the computer or communication systems by the inspecto The inspector reviewed PT/O/B/2000/02, Periodic Test of Emergency Response Communication Equipment, for the period from January 1993 to March 1994. The PT was a comprehensive weekly, monthly, quarterly, and annual communication checks of the ERF communication system. The test checked the dedicated ring-down phone system to the State and local warning points, tests of the ENS, and ERDS. The documentation indicate that the test were being performed at the required frequency. According to the records, prompt corrective actions were undertaken when equipment deficiencies were identified. No deficiencies were note The inspector observed the propane fueled EG used to supply emergency power to the EOF. Maintenance of the EG and filling of the EG's propane tank was performed by the site Commodities and Facilities Group on a quarterly bases. The inspector observed the propane tank was full and the generator appeared in good conditio In assessing the operational status of the emergency facilities, the inspector verified that protective equipment and supplies were operational and inventoried on a periodic basis. The inspector observed
a licensee representative use the appropriate enclosures in procedure HP/O/B/1009/01, "Emergency Equipment Inventory and Instrument Check,"
and perform the following inventory and equipment operability checks:
OSC Emergency Cabinet Inventory, Enclosure *
Emergency Cabinet Inventory, Enclosure 5.9 (Visitors Center)
Field Monitoring Inventory, Enclosure 5.11 (Kits)
Emergency Van Inventory, Enclosure 5.12 The kits were full stocked in accordance with the enclosures, the equipment operated properly, calibration stickers were current, and battery checks were satisfactor The inspector reviewed documentation for HP/O/B/1009/01, "Emergency Equipment Inventory and Instrument Check," PT/O/B/2000/02, "Periodic Test of Emergency Response Communications Equipment," and IP/O/B/1001/03, "Meteorological Equipment Check," the applicable procedures for inventorying and testing of emergency equipment and supplies for the period from January 1993 to March 1994. The inspector concluded from the documentation that the emergency equipment was being satisfactorily maintained in accordance with procedure The inspector reviewed the licensee's documentation of the ANS for the period form January 1993 through March 1994. Silent testing was performed weekly (One county on Monday and the other county on Friday)
under the jurisdiction of the respective county emergency management agencies with test results forwarded to the licensee. In addition to the silent test, the licensee's Commodities and Facilities group performed a weekly growl test at 11:50 each Tuesday from the sit Actual sounding of the system was performed quarterly. The quarterly activation test satisfied the quarterly growl and annual full activation requirement of siren system. The inspector reviewed documentation of the annual siren maintenance that was performed during March and April 1993. Documentation in the form of operations work orders to indicate that prompt corrective actions were taken in response to failed sirens or failed components of the system when needed. The inspector reviewed the 1993 Siren Availability Report for FEMA. The report indicated from January 1993 to December 31, 1993 an average availability of 99.28 percen The inspector reviewed documentation that indicated the licensee had reviewed the 1990 census data for their EPZ and had re-evaluated the number and placement of the sirens based on the requirement of FEMA Re. The study indicated the need for three new sirens in Oconee Count Documentation indicated that the licensee had procured the siren hardware and site placement and was waiting for FEMAs evaluation and approva The inspector reviewed LER #25712. In the LER, the licensee informed the NRC of a major loss to their ANS capability. The unit that triggers the Oconee County Sirens was discovered not functional due to an apparent lightning strike at 09:00 on June 27, 1993. The NRC was not informed of the event until 08:45 on June 29, 199 CFR 50.72b(1)(v) requires the licensee to notify the NRC within one hour of any event that results in a major loss of emergency assessment capability, offsite response capability, or communications capabilit The inspector reviewed PIP 0-93-0559, dated July 8, 1993, which was in response to their failing to meet the one hour notification requiremen The PIP's corrective actions were to change Safety Assurance Directive 6.4, Safety Assurance Alert and Notification System, to require Commodities and Facilities to notify the Operations Shift Supervisor anytime 25 percent (15) or more of the sirens were determined to be inoperable. The Directive further stated that this was a one hour NRC notification requirement. The corrective action also required the training of individuals responsible for repairing the Alert Notification System in the change to Safety Assurance Directive 6.4. The inspector verified these corrective actions were completed by reviewing the change to Directive 6.4 and the T10s (training documentation) for the individuals working on the ANS system. The inspector concluded that the licensee had taken reasonable corrective actions to prevent a recurrence of a late notification to the NRC should a similar event reoccu The licensee was informed that failure to inform the NRC within one hour of losing 25 percent or greater of the offsite notification system was a violation of 10 CFR 50.72b(1)(v). Because the violation was discovered by the licensee and corrective actions were already in place, this violation will not be subject to enforcement action because the licensee's efforts in identifying and correcting the violation meet the criteria specified in Section VII.B of the Enforcement Polic NCV 50-260, 270, 289/94-12-02: Failure to notify the NRC within one hour of losing 25 percent or greater of the AN Tone-Alert Radios were located in high population buildings. Examples were schools and hospitals. The radio locations were audited every two years. The inspector reviewed documentation of an audit of the Tone Alert Radio dated September 8, 1992. Documentation indicated that during the audit, batteries were replaced and the radios were verified to be in proper operating condition. Addresses and telephone numbers of establishments assigned custody of the radios were updated and the purpose of the radios was explained to the individuals. The audit indicated four radios were missing from their assigned location and were not replaced due to the associated costs and apparent lack of care by the assigned custodian. The inspector reviewed the Oconee Emergency Plan and noted that the locations of the Tone-Alert Radios are not addressed in the Oconee Emergency Plan. Section E.6 and Appendix 3 of the Oconee Plan address the Alert and Notification System and specify the means for notification of the public as a siren system. The tone alert radios issue was discussed between the Regional Radiological
Protection and Emergency Preparedness Branch Chief and the licensee's Emergency Preparedness Coordinator (EPC) on May 12, 1994. The EPC advised that the tone alert radios were an additional means of notification above the approved siren system. The EPC further advised that their submittal to the Federal Emergency Management Agency (FEMA)
on the Alert and Notification System took credit for the siren system only and not the tone alert radios. The licensee representative indicated that FEMA approved the Alert and Notification System based on 63 sirens. Following the Oconee 1994 Annual Emergency Preparedness exercise, an NRC emergency preparedness inspector reviewed the licensee's submittal to FEMA and confirmed that the Alert and Notification System was based on outdoor siren system and tone alert radios were not addressed. The licensee representatives advised the inspector and Regional management that a budget proposal had been developed which proposes the use of a Community Alert Network System (CANS), an automatic dialing feature, as an additional improved means for contacting certain businesses, hospitals, and schools of an emergency. The CANS would ultimately replace the less reliable tone alert radio The inspector verified the availability of emergency vehicles for the environmental monitoring teams in the event of an emergency. The licensee demonstrated to the inspector, access and capabilities of two fully equipped environmental field monitoring team vehicles. The licensee stated that in an actual emergency, Oconee had access to Catawba's and McGuire's emergency vehicles, Duke Power Company's other nuclear plants. The inspector concluded that the availability of emergency vehicles at any given time was adequate. The inspector verified the operability of two site vehicles by requesting the licensee start the vehicles. Both vehicles started and ran satisfactoril Visual inspection of the vehicles indicated that the vehicles were ready to respond to an emergency if neede One NCV was identifie.
Organization and Management control (82701)
Pursuant to 10 CFR 50.47(b)(1) and (16) and Section IV.A of Appendix E to 10 CFR Part 50, this area was inspected to determine the effects of any changes in the licensee's emergency response organization and/or management control systems in the emergency preparedness program and to verify that such changes were properly factored into the EP and EPIP The organization and management of the licensee's emergency preparedness program were reviewed and discussed with licensee's representative The inspector concluded after discussions with the licensee and reviewing organizational charts, that since the last inspection, there had not been any organizational or personnel change that affected Emergency Plannin No violations or deviations were identifie.
Independent Review/Audits (82701)
Pursuant to 10 CFR 50.47(b)(14) and (16) and 10 CFR 50.54(t), this area was inspected to determine whether the licensee has performed an independent review of audit of the emergency preparedness program, and whether the licensee has a corrective action system for deficiencies and weaknesses identified during exercise and drill The inspector reviewed the most recent independent audit of the Emergency Planning Program, Audit Report CM-93-09(ALL) dated December 21, 1993. The audit was conducted in accordance with Duke Power Quality Assurance Department Program Manual, Procedure QA-210 which met all of the requirements of 10 CFR 50.54(t).
The Audit was an integrated audit involving Oconee, McGuire, and Catawba Nuclear Stations. Activities audited included:
Equipment testing and inspection
Emergency drills and critiques
Annual exercises and critiques
Siren system
Document control
Training
Implementation of EPA-400
Adequacy of the ERFs
Emergency Public Information
State and County interfaces The audit 93-09(ALL) identified one finding: While the requirements for testing major components (of the Plan) have been met for the past five years, there are no procedural or programmatic controls to ensure that these requirements would be met in the futur The inspector reviewed PIP 0-94-0006, which was in response to the 93-09(ALL) audit finding. The PIP was opened on January 4, 1994, and closed on March 30, 1994. The PIP's corrective actions were to revise Procedure PT/0/B/2000/01, "Procedure For Preparing and Conducting Emergency Drills," to clearly identify the objectives requiring testing at least once every five years, and establish a mechanism to track the testing of each of the objectives. Based on the corrective actions taken and the response time, the inspector concluded that the licensee was very responsive to their audit finding The inspector reviewed the licensee's program for follow-up of findings from audits, drills, and exercises. The licensee had established a computer-based system for tracking identified deficiencies and commitments for the program. Based on the inspector's review of the three PIPs discussed within this report and a review of randomly selected corrective actions, the inspector concluded that findings were receiving prompt attention had and satisfactory corrective action The inspector reviewed procedure PT/O/B/2000/01, Procedure For Preparing And Conducting Emergency Drills. Enclosure 13.2, Schedule For Emergency Drills, specifically outlined the number and type of drills required for each quarter. The inspector reviewed a drill matrix for 1993 that noted the date, time, and drill type. The inspector verified the matrix against drill package documentation for two Site Assembly Drills (April 28, 1993, and December 30, 1993), Site Evacuation Drill (August 9, 1993), Medical Drill (November 23, 1993), and two off hours drills (April 13, 1993, and August 9, 1993).
The inspector concluded that drills were being conducted in accordance with the frequencies identified in the procedur No violations or deviations were identifie.
Training (82701)
Pursuant to 10 CFR 50.47(b)(2) and (15), and Section IV.F of Appendix E to 10 CFR Part 50, this area was inspected to determine whether the licensee's key emergency response personnel were properly trained and understood their emergency responsibilitie The Emergency Response Training Manual implemented Section 0, Emergency Response Training of the Oconee Emergency Plan. While reviewing the Emergency Response Training Manual, the inspector noted the Emergency Response Training Matrix in the training manual listed the required training modules for the different ERO positions. The inspector reviewed selected training modules lesson plan and objectives, and discussed Emergency Plan Training with personnel responsible for the trainin Training for the non-licensed ERO staff was provided by the Emergency Preparedness Group and Non-licensed Training Group. Licensed operators received their ERO training as part of their Licensed Operator Trainin The Training Department maintained a computerized personnel history of all the training for ERO personnel stationed at the site. The inspector randomly selected six members of the ERO from different site organizations and used the computer tracking system to verify that their training was current. The inspector then verified that the computer data agreed with hard copies of their training documentation for the randomly selected individuals. No discrepancies were note The inspector conducted two interviews with operations personne During the interviews, the inspector verified that the data referenced in the EALs were obtainable from control room indications and that the operations personnel were knowledgeable of the EALs. Also, during the interviews as a verification of training and knowledge of their responsibilities, the inspector observed the interviewees use procedures to activate the ERDS system up to the point just before actually transmitting data offsite. No concerns were noted by the inspector with the EALs or performance of the interviewee The licensee's Emergency Response Training Manual required the Station Emergency Planner to conduct an annual audit to verify that ERO personnel training is being maintained current. The inspector reviewed the 1993 Training Audit. The audit indicated emergency response personnel training was being properly maintaine Offsite support agency training was reviewed for fire rescue and medical personnel. Offsite support training was consistent with the requirements in the Station Emergency Plan and the Emergency Response Training Manua Based on the documentation reviewed and the discussion with licensee personnel, the inspector concluded that the licensee was effectively implementing their emergency training progra No violations or deviations were identifie.
Exit Interview The inspection scope and results were summarized on April 15, 1993, with those persons indicated in Paragraph 1. The Non-Cited Violations stated in Paragraphs 2, "Failure to notify the NRC within 30 days of making a change to the EP or EPIPs that do not decrease the effectiveness of the Plan," and Paragraph 3, "Failure to notify the NRC within one hour of losing 25 percent or greater of the ANS," were restated. No propriety information was reviewed during this inspection. No dissenting comments were made by the license Item Number Status Description and Reference 50-260, 270, 289/94-12-01 Closed NCV - Failure to notify the NRC within 30 days of making a change to the Emergency Plan
.or Emergency Plan Implementing Procedures (Paragraph 2).
50-269, 270, 287/94-12-02 Closed NCV 94-12-02 - Failure to notify the NRC within one hour of losing 25 percent or greater of the offsite notification system (Paragraph 3). Index of Abbreviations Used in this Report AN Alert and Notification System CFR Code of Federal Regulations CR Control Room EAL Emergency Action Level ENS Emergency Notification System EOF Emergency Operating Facility
EP Emergency Preparedness EPIP Emergency Plan Implementing Procedure EPZ Emergency Planning Zone ERDS Emergency Response Data System ERF Emergency Response Facility FEMA Federal Emergency Management Agency IFI Inspector Follow-Up Item LER Licensee Event Report NCV Non-Cited Violation OSC Operational Support Center PIP Problem Investigation Process QA Quality Assurance TS Technical Specification TSC Technical Support Center