IR 05000321/1986024

Insp Repts 50-321/86-24 & 50-366/86-24 on 860818-22.No Violations or Deviations Noted.Major Areas Inspected: Emergency Preparedness

ML20206S790
Person / Time
Site:	Hatch
Issue date:	09/15/1986
From:	Decker T, Gooden A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20206S785	List: IR 05000321/1986024 ML20206S782
References
50-321-86-24, 50-366-86-24, NUDOCS 8609220372
Download: ML20206S790 (10)

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Report Nos.: 50-321/86-24 and 50-366/86-24 Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Docket Nos.: 50-321 and 50-366 License Nos.: DPR-57 and NPF-5 Facility Name: Hatch I and 2 Inspection Conducted: August 18-22, 1985 Inspector: &L M/f//4 Date Signed A. Gooden 2 .. . Approved by: u // [[/[/8

. /, R.~ Decker, Sec osfChief   Date'51gned
/ i'd Division of Rad tion Safety and Safeguards
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SUMMAR Scope: This routine, unannounced inspection was conducted in the area of emergency preparednes ,_ Results: No violations or deviations were identifie I _,

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REPORT DETAILS Persons Contacted Licensee Employees

*T. V. Greene, Deputy General Manager
*R. S. Grantham, Operations Training Supervisor
*S. J. Bethay, Regulatory Compliance Supervisor
*0. M. Fraser, Acting Quality Assurance Site Manager C. B. Boatwright, Corporate Quality Assurance
*R. K. Moxley, Quality Assurance Field Representative
*C. Dixon, Quality Assurance Engineering Support Supervisor
*J. E. Collins, Emergency Planning Coordinator N. L. Shuman, Plant Safety and Health Advisor M. L. Link, Supervisor, Health Physics Laboratory E. B. Urquhart, On-Shift Operations Supervisor R. E. Varnadore, Shift Supervisor F. I. Dove, Shift Clerk
*D. F. Moore, Nuclear Training Coordinator
*E. J. Toupin, Corporate Licensing and Safety R. N. Herz, Corporate Communications F. G. Gorley, On-Shift Operations Supervisor i T. L. Beinke, On-Shift Operations Supervisor J. Gaye, Shift Clerk Other licensee employees contacted included engineers, technicians, operators, security force members, and office personne Other Organizations R. E. Linnemann, M.D., Vice Chairman, Radiation Management Corporation

. T. Serratore, Instructor, Radiation Management Corporation D. H. Moffett, Emergency Planner, Georgia Emergency Management Agency ' R. E. Widner, Director, Toombs County Emergency Management . Agency R. H. DeJarnette, M.D., Physician, Meadows Memorial Hospital C. S. Anderson, EP Corsultant, Paragon Technical Corporation NRC Resident Inspectors I *P. Holmes-Ray G. Nejfelt '

* Attended exit interview Exit Interview The inspection scope and findings were summarized on August 22, 1986, with i those persons indicated in Paragraph I above. The inspector described the

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areas inspected and discussed in detail the inspection finding No dissenting comments were received from the licensee. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspectio . Licensee Action on Previous Enforcement Matters (Closed) Violation 50-321,366/85-23-04: Failure to conduct an independent audit of Emergency Preparedness program to include evaluaticn of interface with State and local government The inspector reviewed a copy of the Corporate QA audit conducted during May and June 1985, in addition to documentation provided from the 1986 audit repor Included in each report was an evaluation of the licensee's interface with State and local government (Closed) Unresolved Item (URI) 50-321, 366/85-23-06: Radiation monitoring instruments at offsite medical support facility overdue for. calibratio The inspector inventoried all licensee provided personnel monitoring equipment at the Meadows Memorial Hospital and found current calibration stickers were affixed to each of the instruments. The inspector was informed by a licensee representative, to . prevent reoccurrence, procedure 63 EP-INS-001-0 was revised to fr.clude quarterly checks for equipment at Meadows Memorial Hospita . Emergency Detection and Classification (82201) Pursuant to 10 CFR 50.47(b)(4); 10 CFR Part 50, Appendix E, Sections I and IV.C; this program area was inspected to determine whether the licensee used and understood a standard emergency classification and action level schem The inspector reviewed the licensee's classification procedures. The classification procedures did not appear to contain impediments or errors which could lead to incorrect or untimely classification.' The emergency action levels (EALs) specified in the classification procedures were reviewed to determine if they were consistent with the Emergency Plan EALs and the initiating events specified in Appendix 1 of NUREG-0654. The inspector noted that two examples of initiating conditions for the Notification of Unusual Event (N0VE) classification were neither included in the licensee's Emergency Plan nor classification procedure. The two examples were Items 5 and 9 of Appendix 1 to NUREG-0654. This finding was also identified by the licensee's Site Quality Assurance Audit Team during a concurrent audit of the Emergency Preparedness Progra As a result, this licensee identified item will be tracked as an inspector follow-up ite Inspector Follow-up Item (50-321, 366/86-24-01): Failure to include two examples of initiating events for the Notification of Unusual Event (NOUE) classification in the Emergency Plan and classification procedure .. _-. - , ., -.

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. . The inspector verified that the' licensee's notification procedures included criteria for initiation of offsite notifications and for development o protective action recommendations. The notification. procedures required that offsite notifications be made promptly after declaration of an emergenc The inspector discussed with licensee representatives the coordination of EALs with State and local officials. Licensee documentation showed that the , licensee had discussed the EALs during January 1986, with State and local

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officials, and that these officials agreed. with the EALs used by the

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license Interviews were held with three On-Shift Operations Supervisors, and one Shift Supervisor to verify that they understood the relationship between core status and such core damage indicators as containment dome monitor, . high-range effluent monitor, containment hydrogen monitor, vessel coolant > level, and post-accident primary coolant analysis. All interviewees appeared knowledgeable of the various core damage indications and their !. relationship to core status.

! The responsibility and authority for classification-of emergency events and j initiation of emergency action were prescribed in licecsee procedures and in the emergency plan. Interviews with selected key members of the licensee's emergency organization revealed that these personnel understood their . responsibilities and authorities in relation to accident classification, notification, and protective action recomendation Selected Emergency Implementing Procedures (EIPs) were reviewed by the . inspector and discussed with licensee personnel. The EIPs provided i directions to users concerning timely classification of accidents. All personnel interviewed appeared to be familiar with the classification < information in the EIPs.- I Walk-through evaluations involving accident classification problems were l conducted with three On-Shift Operations Supervisors and one Shift ' Supervisor. All personnel interviewed promptly and properly classified the t hypothetical accident situations presented to them, and appeared to - be familiar with appropriate classification procedure No violations or deviations were identifie . Protective Action Decision-Making (82202) l ' Pursuant to 10 CFR 50.47(b)(9) and (10); 10 CFR Part 50, Appendix E, Section IV.D.3; this area was inspected to determine whether the licensee , had 24-hour-per-day capability to assess and analyze emergency conditions and make recomendations to protect the public and onsite workers, and whether offsite officials had the authority and capability to initiate pronpt protective action for the public.

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-  The inspector discussed responsibility and authority for protective action i decision-making with licensee representatives and reviewed pertinent !

portions of the licensee's emergency plan and procedures. The plan and I procedures clearly assigned responsibility and authority for accident assessment and protective action decision-makin Interviews with members of the licensee's emergency organization showed that these personnel - understood their authorities and responsibilities with respect to accident assessment and protective action decision-makin Walk-through evaluations involving protective action decision-making were conducted with three ^ 0n-Shift Operations Supervisors :and one Shift . Supervisor. Personnel interviewed appeared to be cognizant of appropriate onsite protective measures and aware of the range of protective action recommendations appropriate to offsite protection. Personnel interviewed were aware of the need for timeliness in making initial protective action reconnendations to offsite officials. Interviewees demonstrated adeoutte ' understanding of the requirement. that protective action recommendations be - based on core conditicr. and containment status even if' no release is in progres The capability of offsite officials to make protective action decisions and to promptly notify the public was discussed with licensee representative Licensee procedures made provisions for contacting responsible offsite authorities on a 24-hour basis. Backup communications links with offsite authorities were available. The inspector verified through discussion with a licensee representative that the offsite decision-makers .could be

contacted from the Control Room via a dedicated circuit or back-up comunications syste No violations or deviations were identifie ! . Notification and Communication (82203) Pursuant to 10 CFR 50.47(b)(5) and (6); 10 CFR Part 50, Appendix E, Section IV.D; this area was inspected to determine whether the licensee was maintaining a capability for notifying and communicating (in the event of an , emergency) among its own personnel, offsite supporting agencies -and [ authorities, and the population within the EPZ.

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The inspector reviewed the licensee's notification proceoure The procedures were consistent with the emergency classification and EAL scheme used by the licensee. The inspector determined that the procedures made provisions for message verificatio The inspector determined by review of applicable procedures and by discussion with licensee representatives that adequate procedural means existed for alerting, notifying, and activating emergency response

personnel. The procedures specified when to notify and activate the onsite

! emergency organization, corporate support organization, and offsite 1 agencie Selected telephone numbers from the licensee's emergency call i list for emergency response support organizations were checked in order to __ _ _ _ .. __ ___ _

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determine whether the listed numbers were current and correct. No problems were note , The content' of initial emergency messages was reviewed and appeared to meet the guidance of NUREG-0654, Sections II.E.3 and II. The licensee's management control program for the prompt notification system

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comunications representative, the system consists of approximately 2,100 tone-alert radios within the 10-mile EPZ. The radio distribution and The replacement is handled by the Georgia Power National Oceanic and Atmospheric Administration Comp (any Office in Baxley.NOAA) test Plant security personnel confirm test results by contacting Appling County, Toombs County, and the Hatch Visitors Center. Based on the tone-alert signal strength at any of the aforementioned locations, security affirms a positive or negative finding with the National Weather Service

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Office in Savannah (Agency of NOAA). The Plant security logbook that contains records of weekly tests was not reviewed during this . inspectio Licensee provided documentation, dated August 20, 1986, indicated the Federal Emergency Management Agency (FEMA) evaluation of the FEMA 43 test-conducted in October 1985, resulted in the determination that the prompt - ' alert and notification system for Hatch is adequate to promptly alert and notify the public in the event of an emergency at the sit l

Comunications equipment in the Control Room, OSC, and TSC was inspected.

l Provisions ' existed for prompt comunications among emergency response , organizations, to emergency response personnel, and to the public. The l installed comunications systems at the emergency response facilitics were consistent with system descriptions in the emergency plan and implementing procedure The inspector reviewed licensee records for the period May 1985 to June 1986, which indicated that commanications tests were conducted at the frequencies specified in NUREG-0654, Section II.N 2.a. Licensee records also revealed that corrective action was taken on problems identified during communications test Redundancy of offsite and onsite comunication links was discussed with licensee representatives. The inspector verified that _the licensee had

established a backup communications syste Redundancy is provided by the I use of a plant microwave that provides a direct comunication line to the l

General Office in Atlanta, or a two-way radio system from Plant security out ! to the county government's law enforcement office No violations or deviations were identifie . Changes to the Emergency Preparedness Program (82204) l , Pursuant to 10 CFR 50.47(b)(16); 10 CFR 50.54(q); and 10 CFR Part 50, l Appendix E, Sections IV and V, this area was reviewed to determine whether ' changes were made to the program since the last routine inspection on

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- July 15-23, 1985, and to note how these changes affected the overall state of emergency preparednes The inspector discussed the licensee's program for making changes to' the emergency plan and implementing procedures. No emergency plan changes had been made since the last inspection. However, implementing procedures were reissued in a revised number format since the previous inspection. The inspector verified that procedures.were reviewed and approved by. the Plant Review Board prior to implementation. It was also noted that all changes were submitted to NRC within 30 days of the effective date, as require Discussions with licensee representatives indicated that no significant modifications .tci facilities, equipment, or instrumentation had been made since the last inspection.

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The organization and management of the emergency preparedness program were reviewe A licensee representative indicated that significant administrative changes had been made to both the corporate and plant emergency planning organization since the last inspection. The changes at ! the Corporate Office involved the reporting chain for the EP Manager, and-the creation of four positions on the EP Manager's staff. The site change involved the reporting chain for the Emergency Planning Coordinato According to a licensee representative, although changes were administrative 1y significant, the responsibility for the Hatch Emergency.

' Planning Coordinator was not changed. The inspector's discussion with licensee representatives disclosed that there had been no significant changes in the organization and staffing of the offsite support agencies since the last inspectio ' The inspector reviewed the licensee's program for distribution of changes to the emergency plan and procedures. Document control records for the period August 1985 to June 1986, showed that appropriate personnel and organiza-

tions were sent copies of procedural changes, as required.

' No violations or deviations were identified.

i Shift Staffing and Augmentation (82205) L Pursuant to 10 CFR 50.47(b)(2) and 10 CFR Part 50,- Appendix E, Sections IV.A

and IV.C, this area was inspected to determine whether shift staffing for emergencies was adequate both in numbers and in functional capability, and whether administrative and physical means were available and maintained to augment the emergency organization in a timely manne The NRC inspector reviewed Table B-1 of the emergency plan and discussed

, shift staffing and augmentation with a licensee representative to determine l if the goals and criteria of Table B-1 of NUREG-0654 could be met. The , licensee has established an " Emergency Call List," that contains personnel i home and office phone numbers along with pager numbers, so that essential off-shift personnel may be contacted if neede The emergency call list ,

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appears to be adequate for shift staffing and augmentation to deal with emergencies.- The inspector- discussed staff augmentation times with the licensee

;  representative. The licensee representative indicated that call-in during a previous exercise .had confirmed that Table B-1 augmentation times could be me However, no records were available for review that would verify Table B-1 augmentation times had been demonstrated during an exercise, or dril No violations or deviations were identifie . Knowledge and Performance of Duties (Training) (82206)

Pursuant to 10 CFR 50.47(b)(15) and 10 CFR Part 50, Appendix E, Section IV.F, this area was inspected to determine whether emergency response personnel understood their- emergency response roles and could perform their assigned function The inspector reviewed the description (in the emergency plan) of the training program, training procedures, and selected lesson plans, and-interviewed members of the instructional staff. Based on these reviews and i interviews, the inspector determined that the licensee had established a formal emergency training progra Records of training for key members of the emergency organization for the period August 1985 to June 1986, were reviewed. The training records for a random selection of key personnel indicated that personnel are being

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i provided with appropriate trainin A recent change to the training ' procedure (75 TR-TRN-001-0S, titled " Radiological Emergency Response Training", dated May 22, 1986) involved the implementation of a revised training matrix. The revised matrix appears to provide more specialized and i restrictive training that is specific to a given positio The licensee , representative indicated that the revised training matrix also allows more effective use of training resource As a result of the revised training i ' matrix, personnel who were qualified to serve in various positions in the emergency organization under the previous training requirements, will not be required to complete additional training as required under the revised training matrix until the next annual retraining date. Therefore, the licensec has initiated an aggressive training schedule for all primary and alternate personnel with responsibilities in the emergency organizatio The schedule for completion is the end of the calendar year 1986. This item is being tracked by the licensee's Site Quality Assurance Department and NRC ! in a previous inspection report as an inspector follow-up item (321,366/86-07-01).

' The inspector reviewed 1985 off-site training records for local Emergency Management Agencies and noted that training was provided to Civil Defense / Emergency Management Agency Directors on June 21, 1985. Additional training conducted during 1985 included EALs, Emergency Worker, and Reception Center training. Attendance sheets and lesson plans were _ _ _ _ _ _ _ _ , _ _ _ _ _____. _ _ _ _ . . _ . - .

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available for revie During the course of the inspection, the inspector observed the annual medical training provided by Radiation Management Corporation (RMC) at Meadows Memorial Hospital. RMC conducted training-at the Appling General Hospital on August 18, 1986, and Meadows. Memorial Hospital on August 19, 1986. The presentation was well organized and included a combination of lectures, demonstrations, walkthroughs, and discussions on transporting, handling, and treatment of a contaminated victi The participants in this training included plant, hospital, and ambulance personne In response to IE Infonnation Notice No. 85-80, " Timely Declaration of an Emergency Class, Implementation of an Emergency Plan, and Emergency Notifications", the inspector interviewed two Shift Clerks who are designated as Comunicator/ Recorder for the control room. The control room Comunicator/ Recorder is responsible for initial comunications to the offsite agencies via the Emergency Notification Network (ENN). Interviewees demonstrated familiarity with the communications equipment (ENN) and their responsibility as communicators. A review of training records verified that both interviewees had been provided specialized training for Comunicator/ Recorder. In addition, one individual stated she-had served as Comunicator/ Recorder during an ' actual event (N0UE involving river water level) at Hatch during July 198 . Licensee Audits (82210) 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 had performed an independent review or audit of the emergency preparedness progra Records of audits of the program were reviewed. The records showed that the last independent audit of the program was conducted by the Plant Hatch Quality Assurance Department during the period October 16 - November 1, 1985, and the Georgia Power Corporate Quality Assurance Office during the period May 6 - June 27,1985. The most recent audit to fulfill the 12-month frequency requirement was conducted by the Corporate Quality Assuranca office during the period June 22 - August 18, 1986 (audit report No.86-EP-1). At the time of the site visit, the report was not published and available for review. The Lead Auditor for the Corporate audit group i provided the inspector with adequate documentation to verify that the State I and local government interfaces were evaluated. On August 27, 1986, a final I

copy of the audit report was provided to the inspector. This verified c

' previous documentation as provided by the Auditor during the site visit. In

, addition to the Corporate office audit to fulfill the 12-month frequency l requirement, the Site Quality Assurance Department was conducting an audit i simultaneously with the inspection herein reported. The report number for l-the site Quality Assurance audit is 86-EP-2, with an audit period of ' August 13-26, 1986. Audit findings and recomendations were presented to plant and corporate management. A review of past site Quality Assurance reports indicated that the licensee complied with the five-year retention requirement for such reports.

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Licensee emergency plans and procedures required critiques following exercises and drills. Licensee documentation showed that critiques were held following periodic drills as well as the annual exercise. The records showed that deficiencies were discussed in the critiques, and recommendations for corrective action were mad The licensee's program for follow-up action on audit, drill, and exercise findings was reviewe Licensee procedures required follow-up on deficient areas identified during audits, drills, and exercise The inspector reviewed a sample of licensee documentation which indicated that corrective action was taken on identified problems, as appropriate. The licensee had established a tracking system known as the " Action Items Tracking System (AITS)," Procedure No.10 AC-MGR-005-0S, titled " Corrective Action Trending and Tracking," for use as a management tool in following up on actions taken in deficient area No violations or deviations were identifie . Coordination with Offsite Agencies (82210) The inspector held discussions with licensee representatives regarding the coordination of emergency planning with offsite agencies. The inspector a noted that written agreements existed with selected offsite support agencies specified in the errergency plan, and the agreements were renewed during January 1986. The inspector determined through personal and telephonic interviews with representatives of selected local and State support agencies

that the licensee was periodically contacting those agencies for purposes of l

offering training and maintaining mutual familiarization with emergency I response roles. Those interviews disclosed no significant problems related to the interfaces between the licensee and the offsite support agencies listed in paragraph 1.

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