IR 05000321/1989018

Insp Repts 50-321/89-18 & 50-366/89-18 on 890807-11. Violation Noted Re Failure to Repair Components of post- Accident Sampling Sys.Major Areas Inspected:Emergency Preparedness,Including Emergency Kits & Equipment

ML20247B550
Person / Time
Site:	Hatch
Issue date:	08/31/1989
From:	Gooden A, Rankin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20247B542	List: IR 05000321/1989018 ML20247B538
References
50-321-89-18, 50-366-89-18, NUDOCS 8909130070
Download: ML20247B550 (9)

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si E! - UNITED STATES

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~ NUCLEAR REGULATORY COMMISSION 4

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1g REGION ll

y ., 101 MARIETTA STREET, ATLANTA, GEORGI A 30323

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SEP 011989

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Report Nos.: 50-321/89-18 and 50-366/89-18

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Licensee: Georgia Power Company P. O. Box 1295 Birmingham, AL 35201-Docket'Nos.: 50-321 and 50-366 License Nos.: DPR-57 and NPF-5 l

Facility Name: Hatch 1 and 2 1

! Inspection Conducted: August 7-11,,1989 Inspector: M & ~

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+- @ A. Gooden Date Sfgned Approved'by!'%4M

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4W. Rankin, Chief 3//89 Fate Figned Emergency Preparedness Section-Emergency Preparedness;and Radiological Protection Branch Division of Radiation Safety and Safeguards

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SUMMARY

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Scope:

This routine, unannounced inspection was conducted in th'e crea of emergency preparednes Several aspects of the emergency preparedness program were '

reviewed to determine if the_ program was being maintained in a state. of -

operational readiness. The. review included maintenance of select' emergency l kits a.nd; equipment; organizational changes since the August 1988 inspection; l

training; independent audits; distribution of changes to the Emergency Plan and Emergency: Plan Implementing Procedures (EPIPs); and the adequacy of licensee actions'.taken on previously identified inspection finding . Results:

Within the area reviewed, a licensee-identified, non-cited violation (NCV) was noted for failure to take prompt corrective action to repair components of the ,

Post-Accident Sampling System (PASS) (Paragraph 6). A commitment was made-by

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g F the licensee management to conduct an unannounced augmentation drill during-l 1990' (Paragraph 8). Noted program strengths were' as ^110ws: (1) timely K distribution of changes to the: Emergency Plan and EPIPs (Paragraph 2);

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(2) documentation for discrepancies and/or. corrective actions resulting from equipment ' inventories and periodic tests (Paragraph 3); and (3) root cause evaluation for augmentation drill (Paragraph 5).

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8909130070 890901

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PDR ADOCK 05000321 L Q PDC

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REPORT DETAILS k+ ,

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Licensee Employees

• C.LCoggin', Manager, Training and Emergency Preparedness

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• R. Davis, . Supervisor Quality Assurance r '*0. Fraser, Manager, Site Quality Assurance

• J. Hammonds,. Supervisor, Nuclear Safety and Compliance

'*W. Kirkley,' Acting Manager, Health Physics / Chemistry

• B. Manning, Field Representative, Quality Assurance

• C. Moore Assistant General. Manager - Plant Support

.*R. Mothena, Supervisor,' Site Emergency Preparedness

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.*H. Nix, General.ManagerL- Hatch

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• W. Rogers', Chemistry Superintendent

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• S. Tipps, Mann' Nuclear Safety and Compliance

' P.; Underwood, aalt Supervisor

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Other '. licensee' employees contacted during.. this inspection included f security office' members, technicians, and . administrative personne !*AttendedLex'it interview:

,, . ..Emsrgency/P1an and lipplementing Procedures (82701)

Pursuant Lto 10 CFR 50.47(b)(16), 10 CFR 50.54(q), and Appendix E t CFR Part 50, this area was reviewed to determine whether changes were s 'made to the program since the last' routine inspection (August 1988), and

'to assess the impact of these changes on the overall state of emergency

. preparedness at the facilit The. inspector . reviewed _ Section P of. the - licensee's Emergency Plan and discussed with a licensee representative the licensee's program for making

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'changesLto the Plan and EPIPs. LThe inspector verified that changes to the Plan.and procedures were reviewed and approved by management in accordance with procedures governing the' development, review, and approval. A review

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of transmittal sheets disclosed 'that changes were being distributed to onsite and offsite' copy . holders. in accordance with procedure 20ACJDM-001-05 (Document Distribution and Control). - As evidenced by the-trar 4ttal hes and a review of acknowledgement slips for selected chang'es, the inspector determined that distributions were done in a timely

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manne Documentation for the' selected 73 EP Series EPIP changes was reviewed to verify.that submittals were made to'NRC within 30 days of the approval date. No. problems ' were noted. Since the -last inspection, change's. incorporated as Revision 9 to the Hatch Emergency Plan were submitted for NRC review during May 1989. At the time of the inspection,

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Revision 9 ' changes were being reviewed by the Regional Office staff to determine if changes were consistent with NRC requirement . . _ .

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Controlled copies of the Emergency Call-list, Emergency Plan, and/or EPIPs were audited in the Control' Room, Technical Support Center (TSC), and the

- Emergency Operations Facility (E0F). The selected documents that were

. examined were found. to be current. revision No violations or deviations were identifie . Emergency Facilities,' Equipment, Instrumentation, and Supplies (82701)

Pursuant _ to :10 CFR 50.47(b)(8) and '(9),Section IV.E of . Appendix E to 10 CFR P at 50,,and Section H of the licensee's' Emergency Plan, this area was inspected to- determine whether the licensee's' emergency response

- facilities .and. other' essential emergency. equipment, instrumentation and supplies were maintained in a state of operational readines Discussions were : held with a licensee representative concerning modifications to facilities, equipment, and instrumentation since the last inspection.. The inspector toured the Control Room, TSC, Operations

. SupportCenter-(OSC),and'EOFandnotedthatfacilitieswereinaccordance with Section H of the Emergency Plan. Discussions with a member of.th licensee's : Site Emergency Preparedness Staff disclosed the following facility changes since.the August 1988 inspection:

The General Office Operations Center (G00C) was relocated from Atlanta to Birmingham, Alabam *

Regarding onsite facility changes, the Service Building lunch room layout was modified. This facility serves as the OSC during an

- emergenc Based on a tour of the OSC and a discussion with a licensee representative regarding the: operational concept of the OSC and G00C, the above changes do not appear to decrease the effectiveness of the facilities to perform their intended function. In assessing the operational status 'of the emergency facilities, the inspector verified that protective. equipment, and ~ supplies were operational and inventoried on a periodic basi Emergency kits and/or cabinets from the Control Room, TSC, EOF, OSC, and External Survey Kit were inventoried and randomly selected' equipment was checked for operabilit The selected. equipment operated properly, displayed current calibration stickers, and successful battery and source checks were obtained. By review of applicable procedures and check-list documentation covering the period of September 1988 to June 1989, the inspector determined that emergency equipment (e.g., communication

. equipment and emergency. kits) was being checked'in .accordance with the procedures governing such tests. Records ' reviewed indicated that all

- discrepancies or problems identified during inventories and communications checks were corrected in a timely manner. One exception to taking prompt corrective action in response to inoperable equipment is discussed in Paragraph This finding was categorized as an NC .

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l l 3 As part of the emergency communication equipment, the inspector discussed with a licensee contact the periodic testing of the plant emergency warning system for high noise areas. According to discussions with the licensee contact .the emergency evacuation system consists of flashing red lights and administrative measures to assure personnel evacuatio According to documentation entitled " Emergency Warning Lights Test,"

Procedure 57-SV-R51-001, the emergency warning lights are tested at 12 months frequency and the beginning of each major outage. Completed procedure data packages were reviewed to verify that tests were conducted during the calendar year 1988. The inspector noted during the Control Room tour that the following equipment was operational: meteorological (wind speed, direction, and temperature) and radiation monitors (Unit 1 Reactor Building vent and the main stack monitor). In addition, the inspector observed a daily operability check on a Safety Parameter Display System (SPDS) terminal in the E0F and requested a similar operability check on terminals in the TS The licensee's management control program for the Prompt Notification i System was reviewe According to licensee documentation, as of

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July 1989, the system consisted of 2,882 tone-alert radios. The National Oceanic and Atmospheric Administration (NOAA) conducts weekly radio test Plant Security personnel confirm weekly 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 a.. the National Weather Service Office in Savannah (Agency of NOAA). Results showed tests were being conducted on a weekly basi The inspector was provided documentation by the licensee addressing the 1988 Prompt Notification g System summary statu This summary was broken down into several categories of results: (1) signal activations; (2) system outages; (3) weekly activations; (4) malfunctions causing audio distort 4cas; and-(5) the dates and cause for each of the aforementioned categvie According to documentation, the signal availability for 1988 was 99.95 percen No violations or deviations were identifie . Organization and Management Control (82701)

Pursuant to 10 CFR 50.47(b)(1) and (16),Section IV. A of Appendix E to 10 CFR Part 50, and Section B of the licensee's Emergency Plan, this area was inspected to determine the effects of any changes in the licensee's emergency organization and/or management control systems on the emergency preparedness program, and to verify that any such changes were properly factored 4.'w the Emergency Plan and EPIP The inspector's discussion with a licensee representative disclosed that severil personnel changes had been made involving both the corporate and plant staffs since the August 1988 inspection. At the corporate office, organintional changes resulted in the establishment of separate projects to suppcrt each site (e.g. , Hatch Project, Southern Company Services

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Project, Vogtle Project, etc.); and within each project exists-a cerporate

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emergency planning organizatio Previously, one corpo' rate emergency

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planning organintion served both Plant Hatch and Vogtle.- In. view of a corporate organizational change, responsibilities for interfacing with7 offsite support groups (NRC, FEMA, State, etc.) were realigned. .At the plant, key personnel changes were the results of either promotion or- a

' reassignmen An example include the Assistant General-Manager - Plant ^

Support position which was filled by a former: member .of .the corporate offic The inspector's discussion with a licensee representative disclosed that-personnel changes had also been made.to the emergency organizationisince J the August 1988 inspection as a result of ' reassignment or promotion. ' Whe 'I training records were reviewed for such -individuals, no problems were "{

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note Regarding the offsite emergency organization, no changes had been- !

mad No violations:or deviations were identifie . . Training.(82701)

Pursuant to .10 CFR 50.47(b)(2) and (15),Section IV.F of Appendix E to 10 CFR Part 50, . and Section 0 of - the Emergency Plan, this area was

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inspected l to ' determine whether the' licensee's - key emergency response

. personnel were properly trained and inderstood their emergency responsibilitie The inspector reviewed Section 0 of the Emergency Plan and the Implementing Procedure (75TR-TRN-001-05) for a description of the training program- and training procedures. In addition, selected lesson plans or instructor. guides were reviewed, and personnel with the responsibility for

. conducting and tracking the emergency response training were interviewe It was determined that the licensee maintains a formal. emergency training progra In response-to IE Information Notice No. 85-80, " Timely Declaration of an Emergency Class, Implementation of. an' Emergency Plan, and Emergency Notifications," the inspector interviewed a Shift Clerk who may be designated as an offsite.commu'nicator for the Control Room. The inspector interviewed the communicator regarding the various communications systems available from the ' Control Room for making notifications, responsibility as a communicator, backup communications systems, etc. No problems were noted. The interviewee demonstrated familiarity with the communications emergency procedures and equipment use, and no problems were noted in the areas of equipment use, message forms, or responsibility as a communicator. The inspector conducted a walk-through evaluation with a Shift Supervisor, who may be designated as the Interim Emergency Directo The interviewee was given hypothetical emergency conditions and data and was asked to talk through his response (as the Interim Emergency Director)

as if an emergency actually existe The individual demonstrated familiarity with the emergency classification procedure (73EP-EIP-001-05)

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I and various other procedares which implement the Hatch Emergency: Plan.~ No

' '.* problems'were. noted in the areas of emergency detection, classificatio and protective : action y recommendation. As a -further demonstration of knowledge and familiarity with procedures, the _ interviewee' was given simulated-- plant monitor . readings and asked ~ to perform manual dose 4^'

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projections using the prompt -dose ' assessment methodology .(73EP-EIP-018-0S LPrompt Offsite Dose' Assessment). No problems were noted. The: interviewee

, talked ? through :the procedure's . flow chart without any impediments and promptly ~ calculated the projected offsite dos Training records were. ' reviewed ' for selected members of the onsite-emergency' organization. . Training records were. chosen based on the July 1989, list of_ qualified responders assigned to 'the emergency response position matrix. The, ins

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matrix (dated July.1989) pector to the. compared emergencythecallemergency list (dated response ' position July 1989).

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When personnel training records were compared with position assignments, no problems were note 'The inspector discussed with a licensee representative the results of augmentation drills conducted since the August 1988 inspection to verify augmentation. times in Table B-1 of the Hatch Emergency . Pla Documentation' was provided .to show that an augmentation drill was conducted on May 31, 1989, between the hours of 6:00 p.m. and midnigh The; drill results were inconsistent with Table B-1 of the Hatch Emergency Plan. Augmentation time -for offsite personnel and facility (TSC, OSC,

~' EOF) activation is . 60 min'ute/.. During the May 31, 1989- drill, the facility l activation times 'wera TSC and OSC 70 minutes and the E0F 85 minutes. According to discussions with licensee representatives and a review of drill documentation, the delays were attributed to an insufficient number of communicator / recorders being available to transmit data between the emergency response facilities (ERFs). The organization lacked five communicatorirecorders. As a result, the inspector discussed with the Site F.mergency Preparedness Supervisor actions considered or

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. planned to improve augmentation performance. . The inspector was informed D as follows: I Subsequent to the drill, a Management Oversight Risk Tree (MORT)

analysis was conducted into the root cause for failure to augment within 60 minute ;]

As a result of the MORT analysis, corrective actions were recommended

, to enhance .the augmentation arrival times. The corrective actions i included training additional personnel to serve as communicator / recorders and training for facility (TSC, OSC, E0F, etc.) managers stressing the need for prioritizing personnel assignments during an emergenc The licensee was informed that the effectiveness of the corrective actions I can only be demonstrated by conducting an augmentation drill to verify )

that Table B-1 augmentation staffing and arrival times can be met. The licensee contact agreed to conduct an unannounced augmentation drill to

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verify Table B-1 augmentation requirement The inspector indicated that this matter would be considered an Ir:spector Follow-up Item (IFI) for review during a subsequent inspectio IFI (50-321, 366/89-18-01): Conduct an unannounced augmentation drill to verify that Table B-1 augmentation staffing and arrival times can be me No violations or deviations were identifie . Independent Review / Audits (82701)

Pursuant to 10 CFR 50.47(b)(14) 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 program and whether the licensee had a corrective action system for deficiencies and weaknesses identified during exercise and drill According to documentation, independent audits were conducted by the licensee's Quality Assurance (QA) Department on the following dates:

September 6-16, 1988 (documented in Audit Report No. 88-F.P-2), and January 10-27, 1989 (documented in Audit Report No. 89-EP-1). The Georgia Power Corporate Office, Safety Audit and Engineering Review Group (SAER),

conducted an audit during April 17 through May 3,1989 (documented in Audit Report No. 89-3). A more recent auc'it was initiated during late July 1989 (to be documented in Audit Report No. 89-EP-2) and is scheduled for . completion during August. The aforementioned audits satisfy the annual frequency requirement for such audits. The inspector noted during the review of Audit Report No. 89-EP-1, that prompt actions had not been taken to restore equipment used in an emergency to an operable statu The licensee's audit identified problems with PASS. According to the report and discussions with licensee representatives, the hydrogen in-line analyzer had been out of service since April 1987, and the conductivity analyzer was out of service since October 1984. This finding was identified in the referenced audit report as a Category II audit findin The inspector reviewed additional documentation (e.g., corrective action tracking form, licensing action request, design change request, etc.) and noted the following:

The conductivity analyzer was restored to operation during March 1989, i

A design change request (DCR 2H89-080) was submitted and approved on May 18, 1989, to replace the existing hydrogen analyzer with a newer more reliable model that has vendor suppor The licensee was informed that allowing equipment to remain inoperable for

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more than 18 months (hydrogen analyzer) in one case and greater than four l years (conductivity analyzer) in another is inconsistent with 1 10 CFR Part 50, Appendix B, Criterion XVI, regarding corrective actio However, in light of actions taken subsequent i.o the audit finding, this l

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I l matter appears to meet the criteria specified in Section V.G.1 of the NRC  ;

Enforcement Policy for non-citatio NCV (50-321, 366/89-18-02): Failure to take prompt corrective actions to repair the hydrogen and conductivity analyzer Other audit findings and observations discussed in the above audit reports were reviewed by the inspector to determine if findings had been assigned for review and corrective action. No problems were noted. The licensee's audits appeared detailed and comprehensive. The results of the most recent audit'(89-EP-2) will be reviewed during a subsequent inspection' .

The licensee's program for follow-up action on audit, drill, and exercise findings was reviewed. The exercise and drill findings were tracked in accordance with the Training Department Procedure . for action item tracking. QA and NRC audit findings were tracked by Nuclear Safety and Compliance via the Action Item Tracking System (known as AIT). The inspector reviewed a sample of items from the annual exercise conducted on November 16, 1988, and noted that items were assigned to various departments _ or individuals with a tentative completion date. According to a licensee contact a Training Department Action Item List Summe y is generated on a weekly basis roarding item status specific to assigned individual One non-cited violation was identifie . Action on Previous Inspection Findings (92701, 92702)

(Closed) IFI 50-321, 366/88-25-01: Revise Procedure 63EP-TET-001-0S (Control and Testing of Emergency Communications Equipment) to ensure that the appropriate documentation is entered on Attachment 1 to 63EP-TET-001-0 The prr'cedure referenced above had been cancelled and replaced with a new procedure (73EP-TET-001-0S) that required personnel conducting the test to complete all items listed on Attachments 1, 2, and 3 to the procedur Additionally, responsibility for conducting the periodic test was reassigned to emergency preparednes As further verification that the I corrective action was effective, the inspector reviewed documentation i covering the period of September 1988 to July 1989 and noted that '

documentation was in accordance with the procedural requirement (Closed) IFI 50-321, 366/88-25-02: Upgrade administrative controls and procedural requirements of 63EP-INS-001-0S to ensure that emergency Kits 1 and contents are being maintained current and in an operational state of readines The procedure referenced above had been cancelled and replaced with a new i procedure (73EP-INS-001-05) which required personnel conducting the

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inventory to ensure procedures / forms listed on each inventory sheet are current revisions by referencing the latest revision of the procedure

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inde In addition, the inventory and administrative control of emergency

' kits were assigned solely to Health Physics. Previously, Health Physics and Emergency Preparedness shared the administrative control over kit The inspector further verified the effectiveness of the corrective actions !

by inventorying kits at randomly selected location No problems were note . iExit' Interview

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The inspection scope and results were summarized on August 11, 1989, with those persons indicated in Paragraph 1. The inspector described the areas inspected and discussed in detail the inspection results listed below. In response to the IFI detailed in . Paragraph 5 of the report, the General Manager committed to conduct an unannounced augmentation drill during the :

calendar year 1990. The licensee did not identify as proprietary any of '

the material provided' to or reviewed by the ' inspector during the inspection. There were no dissenting comment Item Number Description / Reference 50-321, 366/89-18-01 IFI - Conduct an unannounced augmentation drill to verify that Table B-1 augmentation staffing and arrival times can be met (Paragraph 5).

50-321, 366/89-18-02 NCV - Failure to take prompt corrective actions to repair the hydrogen and conductivity analyzers (Paragraph 6). l Licensee management was informed that two open IFIs were reviewed and i closed (Paragraph 7).

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