IR 05000324/1982019
| ML20058C157 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 06/28/1982 |
| From: | Cline W, Jenkins G NRC Office of Inspection & Enforcement (IE Region II) |
| To: | Carolina Power & Light Co |
| Shared Package | |
| ML20058C129 | List: |
| References | |
| 50-324-82-19, 50-325-82-19, NUDOCS 8207260279 | |
| Download: ML20058C157 (11) | |
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4 Cla uq#o, UNITED STATES , NUCLEAR REGULATORY COMMISSION n $ <E REGION 11 o
101 MARIETTA ST., N.W., SUITE 3100 g ATLANTA, GEORGIA 30303
.. .Daport Nos. 50-3?4/82-19-ar.d 50-325/82-19 , Licensee: Carolina Power and Light Company , 411 Fayetteville Street Raleigh, NC 27602 Facility Name: Brunswick Docket Nos. 50-324 and 50-325 License Nos. DPR-62 and DPR-71 > Inspection at the Brunswick site near Southport, NC Inspec or: ah -[[3<du,vf 6/ zf/dz.
Date Signed W. E. C1~ ( ' b d 8 8,2-- Approved by: - - G. R. Je " s, Chief Date Signed Emergenc reparedness Section EPOS Division SUMMARY Inspection on June 1-4, 1982 Areas Inspected This routine, unannounced inspection involved 26 inspector-hours on site in the areas of emergency preparedness.
Results Of the areas inspected, no violations or deviations were identified.
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. . REPORT DETAILS 1.
Persons Contacted . - Licensee Employees
- C. R. Dietz, Plant General Manager R. Morgan, Plant Operations Manager L. Boyer, Assistant to Plant General Manager
- R. Indelicato, Emergency Preparedness Specialist S. W. Morgan, Training Specialist
- R. Paulk, Regulatory Compliance Specialist M. Pastva, Regulatory Compliance Specialist W. Gurganinus, Environmental Control Specialist J. Simon, Shif t Foreman D. Robin, Senior Reactor Operator Other licensee employees contacted included technicians, operators, security force members and office personnel.
NRC Resident Inspector D. Meyers, Senior Resident Inspector
- L. Gardner, Resident Inspector
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on June 4,1982, with those persons indicated in paragraph 1 above.
3.
Licensee Action on Previous Inspection Findings (Closed) Deficiency (50-324, 325/81-26-2): Develop adequate emergency training program. An inspector reviewed and verified the corrective actions as stated in CP&L's letter of February 18, 1982.
(Details, Paragraph 5) (Closed) Deficiency (50-324, 325/81-26-3): Implement adequate emergency training program.
An inspector reviewed and verified the corrective actions as stated in CP&L's letter of February 18, 1982.
(Details, Paragraph 5) (Closed) Deficiency (50-324, 325/81-26-41): Initial dose assessment capability.
An inspector reviewed and verified the corrective actions as stated in CP&L's letter of February 18, 1982.
(Details, Paragraph 17) The inspector also reviewed the licensee actions on emergency preparedness improvement items identified during the emergency preparedness appraisal and the licensee actions / commitments documented in CP&L letter to NRC Region II dated February 18, 1982.
Status of these items is discussed in the Details of this report.
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Unresolved Items i ) Unresolved items were not identified during this inspection.
' 5.
Training
The inspector discussed the emergency response training program with licensee representatives, reviewed licensee training procedures, and v . reviewed licensee training records to include lesson plans and study guides.
~ The licensee has developed both plant procedures (PEP 4.3) and corporate
procedures (CEPIP-19) which address emergency preparedness training.
A review of licensee training documentation showed that the licensee had , i identified training requirements and had assigned responsibilities for development of instruction material and presentation of instruction.
The inspector noted that lesson plans had been developed, and reviewed selected lesson plans.
Also, the inspector noted that in several instances the licensee had develop study guides and manuals which were based on a self j paced study principle.
All self paced study material reviewed by the ! inspector contained testing requirements.
The inspector reviewed the I results of emergency preparedness tests administered by the licensee.
The ' inspector had no comment on this matter.
An examination of selected training records for key individuals in the emergency organization showed ' that these invididuals were given training on a series of emergency response i related topics.
The training given appeared to be in accordance with the i training requirements outlined in the licensees procedures.
Both CEPIP-19 ' and PEP 4.3 addressed audit, update, and revision requirements for the j emergency response training program.
The responsibility for annual audits of the emergency response training program rests with the Corporate QA function.
Responsibilities for periodic review and evaluation of the emergency response training program is shared between the corporate and
' plant emergency preparedness coordinator.
The corporate training procedure (CEPIP-19) also addresses training requirements and programs for corporate
] personnel who will augment the emergency organization.
A licensee repre-
sentative stated that table-top drills / exercises are used extensively as a . training vehicle.
The inspector reviewed selected licensee records ! ' concerning table-top drills / exercises and had no comments.
Based on these findings the previously identified emergency preparedness deficiencies in this area (50-324, 325/81-26-2 and 50-324, 325/81-26-3) are closed.
} 6.
Emergency Response Facilities l The inspector reviewed the licensees program concerning emergency response j facilities.
This included review of licensee procedures and records, discussion with licensee personnel and a tour of certain emergency response facilities. A summary of findings is presented below.
r a.
Technical Support Center (TSC) The inspector toured the TSC work area and reviewed drawings of TSC i layo' t and plans concerning TSC operation.
The inspector noted that
emer;ency supplies and equipment were on-hand and available for use at the iSC.
Communications equipment was on-hand and telephone outlet
recepticles were identified and marked by extension number in the TSC ' i i l i .. - - - - -. - -. - - . - - - - - - - - - _-, - _. - - - _. .. - _. _ _
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work areas. The ENS telephone extension was located in the TSC and was operable.
Based on these findings the previously identified improve-ment item in this area (50-324, 325/81-26-04) is closed.
Habitability criteria for the TSC was reviewed.
The interim TSC does not meet habitability criteria presented in NUREG 0696.
Licensee representatives indicated that the permanent TSC will meet such habitability criteria.
The inspector reviewed licensee plans and layout drawings for the permanent TSC.
The inspector had no comments concerning the proposed layout of the permanent TSC.
Prompt travel between the TSC and the control room was discussed with licensee representatives.
Licensee representatives acknowledged that the travel time between the TSC and control room was greater than two minutes, but further stated that such travel could be accomplished in 3 to 4 minutes.
The licensee pointed out that when the permanent TSC is completed that travel time between the TSC and control room will be on the order of two minutes. The adequacy of permanent emergency response facilities will be reviewed during subsequent inspections.
Based on the above considerations, the previously identified improvement item in this area (50-324, 325/81-26-05) is closed.
b.
Operations Support Center (0SC) The service building is the licensee's current OSC.
Operation of the OSC is described in the emergency plan and in the latest revision of PEP-2.2.12 Operations Support Center Leader, Evacuation Assembly Area Leader, dated March 28, 1982.
The revised procedure addresses which areas of the Service Building that are to be used for OSC purposes.
The inspector also determined that the licensee has made arrangements for a backup onsite OSC.
According to a March 1982 revision to the Emergency Plan portions of the Document Control Building can be used as a backup OSC.
The inspector toured various work areas within the Document Control Building and had no further comments about it's use as a backup OSC.
Based on these findings the previously identified improvement items in this area (50-324, 325/81-26-06 and 50-324, 325/81-26-08) are closed.
c.
Emergency Operations Facility (E0F) The interim EOF is located in the Training Building.
The interim EOF is readily accessible to both the TSC and Control Room; however the interim E0F does not meet the habitability criteria specified in NUREG 0696..The permanent E0F facility will meet the habitability criteria according to licensee representatives.
The licensee maintains status boards, system description information and related drawings in the interim E0F. The licensee does not plan to emplace or store essential or reserve emergency response supplies and equipment at the interim EOF.
The licensee currently maintains these supplies and equipment in the Service Building which is adjacent to the
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interim E0F.
In addition, prepositioned stocks of radiological i instruments and sampling devices are maintained at the CP&L Harris Center. These materials would be brought to the site by members of the , i corporate staff who provide augmentation to the emergency organization.
Based on these findings the previously identified improvement item in this area (50-324, 325/81-26-10) is closed.
i i The inspector also reviewed portions of the licensee's communications program for the E0F.
The inspector noted that the ENS phone was installed in the interim EOF and was operable at the time of the i ' inspection.
Based on these finding the previously identified improvement item in this area (50-324, 325/81-26-09) is closed.
7.
Post Accident Sampling and Analysis i a.
Reactor Coolant Sampling and Analysis The inspector reviewed the licensee's interim program for reactor coolant sampling and analysis and discussed plans for the permanent , ! system with licensee representatives.
Licensee Procedure PEP-3.3.3, i Collection of Very High Level Radioactive Samples, dated 3/28/82 makes
provisions for precautions that are appropriate during sample collec- ' tion and handling by cross-referencing procedure ERC-1500, Collection ' and Preparation Procedure for Reactor Water After a Fuel Element Accident.
The precautions specified include requirements for dosimetry, keeping exposures ALARA, securing equipment, using the two man approach, and provisions for issuing Radiation Work Permits (RWP).
Based on these findings the previously identified improvement items in this area (50-324, 325/81-26-25 and 50-324, 325/81-26-26) are closed.
The inspector discussed the previously identified improvement item i concerning shielding of sampling lines leading to the sample hood l (50-324,325/81-26-12).
The licensee has not made any provision for
shielding these lines.
A licensee representative indicated that administrative controls such as limiting stay times and working under ! RWPs would be used to minimize exposures.
Furthermore licensee repre-i sentatives stated that an evaluation of shielding requirements of the ! interim post accident sampling system revealed that installation of the permanent system could be accomplished in about the same amount of time , l as it would take to place shielding about the interim system.
The ' licensee is currently working on the system for Unit 2.
Based on the above considerations, this previously identified improvement item (50-324,325/81-26-12) is closed.
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b.
Containment Air Sampling and Analysis ! The inspector reviewed the licensee's program for post accident , containment air sampling and analysis.
The analytical procedures used ' , for determining activity levels in airborne samples were discussed with , i licensee representatives.
Licensee procedure ERC 0150, Normal and i Emergency Sampling of the Drywell CAC Monitor, dated April 23, 1982 i , t i
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provides recognition that airborne samples may contain sufficient quantities of radioactivity material such that a sample handling problem may exist.
To overcome such problems the procedure makes provisions for such precaution and controls as p.rotective clothing, _ personnel dosimetry, remote handling, and RWPs.
Based on an interview with ERC representatives, it appeared that licensee personnel under-stood the procedure.
Based on these findings the previously identified improvement item (50-324, 325/81-26-27) is closed.
In addition to making provisions for handling of samples both during and prior to analysis the licensee has taken action to improve the analysis capability for high level samples.
Procedure ERC 2201, Calibration / Operation of ND 6600 Multi-Channel Analyzer has been developed which addresses ur.ique geometry consideration and increased sample to detector distances for counting radioactive filters and cartridges.
The licensee has also initiated action to calibrate the instrument for the various counting geometries which are expected to be used.
Based on these findings the previously identified improvement item in this area (50-324, 325/81-26-28) is closed.
The licensee's program for collection of containment air samples was reviewed.
Although the licensee has developed a procedure ERC 0150 (discussed above) for handling radioactive samples, no provisions have been made for shielding or other modifications necessary to minimize exposure to personnel during the actual sample collection process.
Licensee representatives stated that administrative controls would be used as opposed to engineered controls (e.g. shielding) to minimize exposures until such time that the permanent system is installed.
Based on these considerations, the previously identified improvement item (50-324, 325/81-26-13) is closed.
c.
Effluent Sampling and Analysis The inspector discussed the post accident effluent sampling and > analysis program with licensee representatives and reviewed licensee effluent sampling and analysis procedures.
It was noted that the licensee had developed two additional procedures relating to post accident sampling of effluents.
The procedures are ERC 1503 entitled Emergency Sampling of Stack Monitors and ERC 1502 entitled Emergency Sampling of Reactor and Turbine Building Vent Monitors.
The procedures address precautions and administrative controls necessary during sample collection.
The procedures cross reference appropriate health physics procedures.
A licensee representative stated that these procedures were considered interim in nature and would be subject to revision upon further evaluation of this program area.
Based on these findings, previously identified improvement items in this area (50-324, 325/81-26-14 and 50-324, 325/81-26-29) are closed.
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8.
Protective Facilities The inspector discussed the decontamination program with licensee repre-sentatives.
Thc primary detuntamination facility is the Decontamination Station which is located in the Service Building.
Provisions are made for decontamination at alternate locations.
The inspector verified by physical inspection that decontaminat'on supplies were stocked in kits at alternate locations, i.e., the TSC and the Visitor Center. Each kit contained proce-dures for conducting decontamination operations.
The procedures described the instrumentation to be used, recommended decontamination agents, and provided guidance on decontamination techniques.
Based on these findings the previously identified improvement item in this area (50-324, 325/81-26-16) is closed.
9.
Emergency Assessment Equipment Revision 5 of the licensees Emergency Plan changed Section 3.0 to specify that two environmental survey teams would be avilable.
In order to support these environmental team the licensee has set aside two environmental kits at the Visitor Center.
The inspector verified that the kits were in place and that inventory sheets were maintained with each kit.
The inventory sheets specified that protective clothing and respiratory protective equipment were accountable items within each kit.
Inventory requirements for kits are specified in licensee procedures ERC 0600 entitled RC Action for Site Evacuation and PEP 4.2 entitled Emergency Facilities and Equipment.
Inventories are conducted by the ERC group.
Licensee records for the past quarter showed that inventories had been conducted.
Based on these findings the previously identified improvement items in this area (50-324, 325/81-26-17, 50-324, 325/81-26-18, and 50-324, 325/81-26-19) are closed.
10. Meteorological Program The meteorological program was discussed with licensee representatives.
According to iicensee procedures the primary source of meteorological information for plant personnel is via the plant computer which is remotely connected to the onsite meteorological tower.
Backup information is available from National Weather Service at the airport in Wilmington, NC.
Licensee procedures provide the telephone numbers for the National Weather Service, and were quite explicit in terms of the order of priority for obtaining meteorological information from onsite and offsite sources.
Another source of weather infromation is from the CP&L load dispatcher.
According to licensee representatives the load dispatcher is in direct contact with the control room and routinely provides information on severe weather conditions across the service area.
The communications link between the load dispatcher and control room is available 24 hours per day. Based on these findings the previously identified improvement items in this area (50-324. 325/81-26-20 and 50-324, 325/81-26-21) are closed.
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11. Assessment Action The inspector reviewed the licensees program for dose projection.
The licensee has made a recent revision to three procedure dealing with dose projections.
The revised procedures are: PEP 3.4.1 Initial Dose Projec-tion, dated March 28,1982; PEP 3.4.2 Whole Body Dose Projection, dated April 9,1982; and PEP 3.4.3 Thyroid Dose Projection, dated April 9,1982.
PEP 3.4.1 is primarily intended for use by operator personnel prior to activation of the TSC.
The revised PEP 3.4.1 contains a step by step methodology for making an initial dose projection. A calculation worksheet is provided in the procedure as an aid in making the projection.
The procedure takes into account that the initial thyroid projection uses as an iodine source term,15% of the noble gas monitor source term.
Procedure PEP 3.4.1 makes provisions for identifying sources of meteorological inform-ation and recording of essential meteorological parameters on the calcula-tion worksheet.
The procedure, including worksheet, is organized in such a manner that it lends itself to prompt review and successive projections.
PEP's 3.4.2 and 3.4.3 are primarily intended for use by the technical staff once the TSC is activated.
These procedures tend to be more technical in nature than PEP 3.4.1; however in procedures 3.4.2 and 3.4.3 maximum use is made of tabular values and graphs as opposed to computatior,a1 methods. The procedures provide a range of sigma-y and sigma-z values for stability classes A thru G rather than relying on a computational method.
Based on these findings the previously identified improvement item in this area (50-324,325/81-26-22) is closed.
12. Offsite and Onsite Radiological Surveys The licensee's program for conducting onsite and offsite radiological surveys was reviewed by the inspector. The review consisted of discussions with licensee representatives, review of procedures and inspection of supplies and equipment.
The inspector noted that the licensee had recently revised PEP 3.5.1 entitled Confirmation of Intial Dose Projection.
The revision addressed the use of silver zeolite cartridges in taking air samples and provides information on specific instrumentation useage and location of kits containing the instrumentation.
Based on these findings, the previously identified improvement item is this area (50-324, 325/81-26-23) is closed.
Plant personnel conduct onsite radiological surveys in accordance with PEP 3.3.1 entitled In-Plant Monitoring and Surveys.
The inspector discussed implementation of this procedure with licensee representatives.
In review-ing the procedure it was noted that the procedure was generic in nature and that reference was made to specific ERC procedures for details concerning conduct of surveys.
Based on these findings the previously identified improvement item in this area (50-324, 325/81-26-24) is closed.
13. Protective Actions The inspector reviewed the licensees programs for protective actions during an emergency.
The areas reviewed included radiation protection / control, evacuation procedures, and personnel accountability.
In conducting the review the inspector reviewed changes to applicable licensee procedures and
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discussed protective action programs with licensee representatives.
The inspector noted that the procedures dealing with specific actions during an Alert, Site Area Emergency, and General Emergency (i.e. PEP 2.3 to 2.5) had been revised to make provision for informing personnel of preferred evacua-tion routes and areas to be avoided during an evacuation. The licensee has also revised PEP 3.8.1 entitled Evacuation.
The revision specifies the location of the primary assembly area as the plant parking lot.
Based on these findings, the previously identified improvement items in this area (50-324, 325/81-26-30 and 50-324, 325/81-26-31) are closed.
The inspector also reviewed licensee procedure ERC 0600 entitled RC Actions for Site Evacuation, dated May 1, 1982. The procedure provides guidance on radiological limits for Assembly Areas, specifies health physics mustering points, and makes provisions for controls at alternate assembly areas. The inspector discussed the procedure with licensee representatives.
The representatives appeared to have an understanding of the procedure.
Based on these findings, the previously identified improvement item in this area (50-324,325/81-26-35) is closed.
14.
Public Information The inspector reviewed corporate communications implementing procedures.
The procedure established a government liaison function and assigned responsibility for the government liaison functional area.
The procedures also described release of news information, coordination of news items with government agencies, and notification of public information officers at the state government level.
Based on these findings, the previously identified improvement item in this area (50-324, 325/81-26-33) is closed. The inspec-tor also inquired about licensee programs for rumor control but was advised that procedures relating to this program area were still under development.
The licensee's program for dissemination of routine emergency planning information to the general public was reviewed.
The licensee has revised procedure PEP 4.5 enititled Public Education and Information to require annual public dissemination of general information concerning radiological emergency planning for the Brunswick plant.
The procedure also addresses other features of the public education program which includes provision for development of brochures and educational pamphets, use of speakers bureaus, and preparation of information for TV and radio outlets. Based on the above finding the previously identified improvement item for this area (50-324, 325/81-26-39) is closed.
15.
Reentry Reentry planning and training program was reviewed.
According to licensee representatives the reentry team consists of personnel from the ERC group.
During an emergency situation these ERC personnel would be within the emergency organization known as Radiation Control Operations.
Responsi-bilities for the reentry team and team members is provided in Section 4.4.3 of the licensees emergency plan.
Participation on a reentry team is on a .. -. _ _ __- - _.
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voluntary basis according to the licensee.
However to be on the team an individual shall have had emergency preparedness training.
A review of selected licensee records for reentry team members showed the individuals to be health physics technicians and all had been given technical emergency response training in such areas as respiratory protection, damage control and radiation protection.
Based on the above findings the previously identified improvement item in this area (50-324, 325/81-26-36) is closed.
16. Drills and Exercises The licensee's program for implementing drills and exercises is documented in PEP 4.3 entitled Performance of Training, Exercises, and Drills dated December 23, 1981.
The procedure prescribes the frequency for conducting certain types of drills and exercises and spells out planning and coordina-tion responsibilities for drills and e.ercises.
Planning and coordination responsibilities include scenario development and a rrangements for observers, evaluators, controllers, briefings and critiques.
Based on these findings the previously identified improvement item for this area (50-324, 325/81-26-37) is closed.
Licensee Procedure PEP 4.1 entitled Recordkeeping and Documentation, dated March 25, 1982 addresses followup and corrective action from drills and exercises.
The system described by this procedure provides for tracking both licensee and NRC identified items.
A review of selected licensee drill / exercise records showed that the tracking system had been implemented.
Based on these findings the previously identified improvement item in this area (50-324, 325/81-26-38) is closed.
17.
Walk-Through Observations The inspector conducted a follow-up review of the licensee's action on the emergency preparedness deficiency relating to initial dose assessment (50-324, 325/81-26-41) which was identified during the walk-through observation portion of the emergency preparedness appraisal.
The review consisted of a review of licensee procedures (see comments in paragraph 11 above), discussions with licensee representatives, review of the training program, review of training records, and a walk through dose assessment.
With respe : to the licensees training program in this area, the inspector noted from lesson plans that training emphasis is given to initial dose projection : methods.
A review of training records for the period late November 1981 to early December 1981 indicaced that operator personnel had received emergency preparedness t raining which included training in dose projection methodology.
A licensee representative stated that recent table top exercises included provisions for conducting dose projections.
The inspector requested that a senior reactor operator conduct an initial dose assessment in the presence of the inspector.
The operator was given wind speed, wind direction, atmospheric stability class, stack flowrate and the stack high range monitor reading.
The operator was then asked to provide initial whole body dose assessments at the site boundary and at two
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miles.
Upon receiving the parameters the operator selected the proper emergency procedure (PEP 3.4.1) and initiated hand calculations.
The individual appeared knowledgeable of the dose projection methodology and was able to produce a result within 10 minutes of the starting time.
Upon completion of the caluclations the inspector asked the individual to describe what he would do differently in order to project a thyroid dose.
The individual correctly described the procedure.
The individual was also asked to intrepret the numercial results obtained for the initial whole body dose projection and to make any recommendation he felt appropriate.
Based on the individuals responses the inspector determined that the individual had a comprehensive understanding of dose projection and protective action principles and practices.
Based on the above findings the previously identified emergency preparedness deficiency in this area (50-324, 325/81-26-41) is closed.
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