IR 05000324/1987023

Insp Repts 50-325/87-23 & 50-324/87-23 on 870713-17 & 23. Violation Noted.Major Areas Inspected:Emergency Preparedness Program

ML20237H983
Person / Time
Site:	Brunswick
Issue date:	07/30/1987
From:	Decker T, Tabaka A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20237H960	List: IR 05000324/1987023 ML20237H957 ML20237H976
References
50-324-87-23, 50-325-87-23, NUDOCS 8708170446
Download: ML20237H983 (10)

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UNITED STATES

. [p.Q Otos o. .. ,

MUCLEAR REGULATORY COMMISSION

, [ ' REGION il 101 MARIETT A STREET, N.W.-

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• - t- ATLANTA, GEORGI A 30323 g, * *. ***

f AUG 0 71987 Report Nos.: 50-325/87-23-and 50-324/87-23 Licensee: Carolina Power and Light Company P. 0. Box 1551 Raleigh, NC 27602 Docket Nos.: 50-325 and 50-324- License Nos.: DPR-71 and DPR-62 Facility Name: Brunswick 1 and 2 Inspection Conducted: July 13-17, and July 23, 1987 Inspector: -

3'N74 /R 88 A. E. Tabaka .Date-Signed-

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Approved by: M4 4 7/e[87 T. R. Decker, Section Chief Date Signed Division.of Radiation Safety and Safeguards

SUMMARY

l- Scope: This routine, unannounced inspection was to' evaluate selected areas of-

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the emergency preparedness progra .Results: Within the areas inspected one violation was identified-- Failure to maintain in effect the Emergency Plan with respect to the notification of onsite employees of the need for evacuation and- protective action i

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8708170446 870007 PDR ADOCK 05000324 (g PDR .

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REPORT DETAILS Persons Contacted Licensee Employees

• P. W. Howe, Vice President-Brunswick Nuclear Plant

• C.-R..Dietz, General Manager i

• E. A. Bishop, Manager-Operations ,

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• J. A. Smith, Director-Administrative Support

• E. R. Eckstein, Manager-Technical Support

• J. O'Sullivan, Manager-Maintenance

• A. G. Cheatham,_ Manager-Environmental and Radiation Control

• L. E. Jones, Director-Regulatory Compliance

• R. E. Helme, Director-0nsite Nuclear Safety

• T. H. Wyllie, Manager-Engineering and Construction

• P. G. Dorosko, Administrative Supervisor

• R. M. Poulk, Senior Specialist-NRC P. Snead, Senior Engineer-Environmental and Radiation Control D. Jester, Control Operator C. Cashwell, Control ~ Operator

.A. Essey, Engineering Technician 1 R. Indelicotto, Corporate Emergency Planning R. Goodwin, Corporate Emergency Planning B. Houston, Emergency Planning Specialist W. Hatcher, Security Manager R. Pennock, Training Coordinator-Health Physics T. Mull, Fire Specialist L. Ratliffe,~ Senior Specialist-Health Physics-Harris Energy and Environmental Center

Other licensee employees contacted included engineers, technicians, operators, security force members, and office personne U. S. Nuclear Regulatory Commission W. Ruland, Senior Resident Inspector l

• L. Garner, Resident Inspector

< * Attended exit interview ExitInterview(30703)

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The inspection scope and findings were summarized on July 17, 1987, with those persons indicated in Paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection findings. At the exit, licensee management agreed to submit a schedule for corrective action and completion of the evacuation alarm system Plant Modifications

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i REPORT DETAILS Persont, Contacted ,

i Licensee Employees

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• P. W. Howe, Vice President-Brunswick Nuclear Plant

• C, R. Dietz, General Manager

• E. A. Bishop, Manager-0perations

• J. A. Smith, Director-Administrative Support

• E. R. Eckstein, Manager-Technical Support

• J. O'Sullivan, Manager-Maintenance

• A. G. Cheatham, Manager-Environmental and Radiation Control

• L. E. Jones, Director-Regulatory Compliance

• R. E. Helme, Director-0nsite Nuclear Safety

• T. H. Wyllie, Manager-Engineering and Construction

• P. G. Dorosko, Administrative Supervisor

• R. M. Poulk, Senior Specialist-NRC P. Snead, Senior Engineer-Environmental and Radiation Control D. Jester, Control Operator C. Cashwell, Control Operator A. Essey, Engineering Technician 1 R. Indelicotto, Corporate Emergency Planning'

R. Goodwin, Corporate Emergency Planning ,

B. Houston, Emergency Planning Specialist W. Hatcher, Security Manager R. Pennock, Training Coordinator-Health Physics T. Mull, Fire Specialist L. Ratliffe, Senior Specialist-Health Physics-Harris Energy and j Environmental Center j l

Other licensee employees contacted included engineers, technicians, operators, security force members, and office personne U. S. Nuclear Regulatory Commission W. Ruland, Senior Resident Inspector

• L. Garner, Resident Inspector

• Attended exit interview Exit Interview (30703)

The inspection scope and findings were summar' md on July 17, 1987, with those persons indicated in Paragraph 1 above, ie inspector described the areas inspected and discussed in detail the n, ,<ection findings. At the exit, licensee management agreed to submit a schedule for corrective action and completion of the evacuation alarm system Plant Modifications I

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within 30 days of issuance of this inspection report (see Paragraph 8 below). On July 23, 1987, Mr. R. Poulk of the licensee's staff was  !

notified that the evacuation alarm finding would be identified as a violation. Licensee representatives did not take exception to any of the findings identified during the exi The licensee did not identify as proprietary any of the material provided to or reviewed by the inspector j during this inspection.

' Licensee Action on Previous Enforcement Matters (92702)

(Closed) Violation 50-325/86-25-02 and 50-324/86-26-02: Failure to provide adequate first-aid training to those emergency response personnel designated to provide this function. The inspector reviewed the changes {

made to the Emergency Plan and Plant Emergency Procedure 4.3 as well as

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the training records for selected Environmental and Radiation Control <

(E&RC) personne The actions taken by the licensee to train E&RC t technicians in first-aid appeared adequate and in accordance with the {

commitments of the November 26, 1986, response; however, during the review the inspector noted that four (4) E&RC technicians had been hired since February 1987 and had not received the required first-aid trainin [

Licensee representatives indicated that new technicians typically received all pertinent training within 6 months; however, this program was not formally documented. The licensee agreed to better document this aspect of the technician training program, inspector Follow-up Item (IFI) 50-325, 324/87-23-01: Ensure timely i training of newly hired E&RC technicians on emergency first-ai ! Notifications and Communications (82203)

Pursuant to 10 CFR 50.47(b)(5) and (6) and 10 CFR Part 50, Appendix E, :

Section IV.D, this area was inspected to determine whether the licensee was of anmaintaining)a emergency amongcapability its ownfor notifyingoffsite personnel, and supporting communicating (in and agencies the event authorities, and the population within the EP The inspector reviewed the licensee's notification procedure The procedures were consistent with the emergency classification and Emergency ,

Action Level (EAL) scheme used by the licensee. The inspector determined that the procedures made provisions for message authenticatio 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 organization, and offsite agencies; however, one item was noted. In PEP-02.6.21, Revision 10, dated July 9,1987, there was a discrepancy concerning who would provide NRC notifications (red phone) once the Technical Support Center (TSC) was activated. The procedural text indicated the Control Room (CR) while the exhibit on Page 15 indicated the TSC. Licensee representatives stated

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that the TSC was to perform this function upon activation and agreed to ,

revise the procedure to reflect thi I IFI 50-325, 324/87-23-02: Correction of the discrepancy in PEP-02.6.21 1 concerning who has the responsibility for making NRC notifications using  !

the EN Emergency telephone numbers for emergency organization personnel and '

offsite support agencies were reviewed. The numbers, contained in Plant

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Emergency Procedure (PEP) Appendix A, were periodically updated and maintained current. No problems were note The content of initial emergency messages was reviewed. The initial messages appeared to neet the guidance of NUREG-0654, Sections II.E.3 and II.E.4. Licensee ' representatives indicated' that the content of the initial- message had been previously reviewed by State authorities. The inspector was informed that a move was currently underway to standardize r. notification forms between several States in the southeast. The progress

, of this action will be reviewed during future inspection The licensee's . management control program for the Brunswick Public Notification' System was reviewed. As stated in Section 4.4.6 of the Emergency Plan, the system consisted of 33 fixed sirens at locations throughout the 10-mile EPZ. Maintenance of the siren system had been provided for by Corporate Communications. The inspector reviewed' siren test records for the period of September 1986 to June 1987.- The records showed that the silent tests were conducted biweekly, growl tests quarterly, and a full-cycle test annually as specified in NUREG-0654, Appendix 3. The full-cycle test was last performed on November 5,198 Problems noted during these tests appeared to be corrected in a timely manne The inspector also reviewed licensee documentation of overall system operability during the period September 1985 to October 198 For the year, operability was above 90 percent with the exception of two months for which approximately 80 percent and 85 percent operability was demonstrate Communications equipment in the CR, TSC and Operations Support Center (OSC) was inspected. Provisions existed for prompt communications among emergency response organizations, to emergency personnel, and to the publi The available communications in these facilities were consistent with the Emergency Plan and Implementing Procedures with one exceptio PEP-02.6.3, " Logistics Support Director" had not yet been updated to

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reflect the new selective signaling system for offsite notifications. The inspector was informed that the procedure was currently under revision to reflect the recent implementation of the system and would be issued shortl The inspector observed onsite communications capabilities during a table-top exercise conducted during the period of the inspection. In addition, the inspector conducted operability checks on the Emergency Notification System (ENS), the selective signaling system, and the VHF radio to Brunswick County. No problems were observed. The inspector

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reviewed licensee records for the period September 1986 to July 1987, which indicated that communications tests were conducted at the frequencies specified in NUREG-0654,Section II.N. Redundancy of offsite ar.d onsite communication links was discussed with licensee representatives. The inspector verified that the licensee had established redundant communications systems which made use of VHF radio to Brunswick and New Hanover County Sheriff's Departments, sound powered telephones, Station Private Branch Exchange, a microwave system, ,

commericial telephone lines, various automatic ringdowns, and the i selective signaling syste No violations or deviations were identifie . Changes to the Emergency Preparedness Program (82204)

Pursuant to 10 CFR 50.47(b)(16); 10 CFR 50.54(q); and 10 CFR Part 50, Appendix E, Section IV Wd V, this area was reviewed to determine whether changes were made to the program since the last routine inspection in September 1986 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 Procedure As delineated in Section 5.0, Book 1, Volume 1 of the Plant Operating Manual and Section 6.2.1 of the Emergency Plan all changes to these documents must be approved by the General Manager or the Director-Administrative Support. Examination of l records indicated that changes were approved by appropriate management personne Since September 1986, the licensee had made several revisions to the  !

Emergency Plan and Implementing Procedures. Revision 22, dated March 20,  ;

1987, was previously reviewed by the NRC confirming that the changes made i did not decrease the effectiveness of the emergency progra The i inspector also reviewed numerous changes made to the Implementing q Procedures which had not been previously evaluated by NR No changes to ,

these documents were identified which would degrade the Plan's J effectiveness. In addition, it was noted that the changes made since September 1986 were submitted to the NRC within 30 days of the effective date as require In accordance with the Emergency Plan and Technical Specification 6.5.38(j), the inspector confirmed that the Emergency Plan had been reviewed on an annual basis. The last Plant Nuclear Safety l Committee review of the Plan was October 29, 198 ]

The inspector reviewed the licensee's program for distribution of changes to the Emergency Plan and Implementing Procedures. Document Control l records for the period September 1986 to July 1987 showed that appropriate  !

personnel and organizations were sent copies of the Plan and Procedures in l

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accordance with Records Management Procedure 00 In addition, the l

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inspector reviewed selected controlled copies of the Plan and Implementing Procedures and found them to be curren ,

Discussions were held with licensee representatives concerning recent modifications to facilities, equipment, and instrumentation. The changes j included the implementation of the selective signaling system to replace l the automatic ringdown to the State and local Warning Points and the completion of the needed construction modifications to remove the ERFIS computer equipment room from the Protected Area (when the TSC is activated). Review of the Emergency Plan and Implementing Procedures indicated that appropriate revisions had been made to reflect these changes except as noted in Paragraph 3 abov A future change will be the implementation of the TSC intercom system which will allow satellite rooms to hear briefings and discussions taking place in the TSC Comand Cente The inspector observed operation of the system during the table-top exercise which appeared to be effectiv The organization and management of the emergency preparedness program were 4 reviewed. Since the last routine inspection there have been s.gnificant changes in the plant emergency staff. The Emergency Preparedness Coordinator was reassigned to the Corporate office and a new individual has filled the jo He does not have an EP background; however, a training program is being planned. In addition, a new position has been added to the EP Staff - Technical Aide. This individual will aid in many of the administrative details of emergency planning. For the Corporate staff no significant changes have taken place with the exception of the addition noted above. Significant changes in the staffing of offsite support agencies included only the reassignment of the In-Service Training Coordinator at Dosher Memorial Hospita No violations or deviations were identifie . Shift Staffing and Augmentation (82205)

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 I staffing for emergencies was adequate both in numbers and functional capability, and whether administrative and physical means were available and maintained to augment the emergency organization in a timely manne Shift staffing levels and functional capabilities were reviewed and found to be consistent with the guidance of Table B-1 of NUREG-0654 and the commitments made in the licensee's letter to Eisenhut dated June 9,198 j The licensee had established an "on-call" system so that essential off-shift personnel were available if needed. The roster included !

individuals for the positions of Site Emergency Coordinator and other TSC i management personnel . The call-in of other emergency response organization personnel was achieved through the call-in procedures included in PEP-02.6.21 and PEP-Appendix The call-in procedures appeared to be effective in meeting augmentation goal _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _)

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! The inspector discussed staff augmentation times with licensee representatives. Licensee documentation showed that unannounced drills had been conducted to verify that augmentation times could be met. The l

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last such drill was conducted in March 1985 and indicated that response times were consistent with goals of Section 3.2- of the Emergency Pla Since that tine there have been no significant changes in call-in procedures or personnel staffing of the key positions, l

No violations or deviations were identifie . DoseCalculationandAssessment(82207)

Pursuant to 10 CFR 50.47(b)(9), this area was inspected to determine whether there was an adequate method for assessing the consequences of an actual or potential radiological releas The inspector reviewed the following procedures:

PEP-3.4.1, Initial Dose Projections PEP-3.4.7, Automation of Dose Procedures Using the IBM Personal Computer PEP-3.5.1, Confirmation of Offsite Dose Projections PEP-3.6.1, Release Estimates Based Upon Stack / Vent Readings PEP-3.6.3, Estimation of the Extent of Core Damage Under Accident Conditions The procedures had provisions for calculating doses for ground and elevated releases, nonitored pathways such as plant stack and building vents and unmonitored' pathways. The procedures called for verification of dose proiection s through environmental monitorin The inspector discussed the dose projection models used by the licensee and the State of North Carolina with representatives of the Harris Energy and Environmental Center. These discussions revealed that a detailed comparison between the Brunswick and State models had been performe .

Some differences between the models were noted; however, resultant dose ;

calculations were reasonably compatible. The licensee had attempted to !

identify exactly where the differences existed and was currently in the process of formulating conversion factors such that they might be applied to standard verification problem The licensee procedures made provision for timely incorporation of dose assessment nsults into the offsite protective action decision-making proces However, during interviews with key licensee emergency response personnel, they all appeared to recognize the uncertainties associated dose projection An inspection and operability check was made of selected equipment and support items used for dose assessment at the Control Room and Technical Support Center. No problems were observe l

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The inspector- requested and observed dose assessment' walk-throughs with'

selected Control Room operators designated as responsible for initial dose projection during an emergency. The individuals demonstrated the ability to make such calculations by using both manual and computerized method In addition, the inspector observed dose assessment in the TSC during the licensee's table-top drill. No problems were. observe The inspector discussed the backshift availability of personnel qualified to make dose calculations. Shift staffing levels-indicated that such personnel were available on all shift '

The inspector . conducted a comparison test between the licensee's dose model and the NRC Interactive Rapid Dose Assessment Model (IRDAM). For the scenario used, the two models compared favorably. The calculated doses differed by about'a factor of two. The licensee had also performed a comparison for IRDAM similar to that previously discussed for the Stat No violations or deviations were identifie . Evacuation Alarm System (92701)

The licensee had established a mechanism for notifying onsite personnel in the event of an emergency. The system employed the Public Address to transmit an audible evacuation alarm to personnel within the protected a re Emergency warning lights supplemented the audible signal where ambient noise levels were high (Steam Jet Air Ejector Room, the Emergency Switch Gear Room, and the Turbine Buildira Air Intake Rooms). The Public Address was enhanced by a volume bypass system .at selected locations providing fer maximum volume when the evacuation alarm was actuate Specifically, upon emergency alarm actuation, the bypass relays override the local volume settings to assure maximum output. Approximately 120'PA units were part of this volume bypass syste The inspector reviewed the testing and maintenance program for the evacuation alarm /PA system. In addition to the weekly sounding of the system, several performance tests (PT) cover the testing of the volume bypass system, PT-48.2.1, 48.2.2, 48.2.3, and 48.2.4. Although these are semi-annual tests; since January 1986, the only full cycle testing of the system was performed in October 198 Review of the test results indicated that approximately ~40-50 percent of the bypass units faile The only volume bypass PT conducted in 1987 was PT-48.2.2 in March which also indicated about a 50 percent (29 of 54) failure rate. The inspector attempted to evaluate the maintenance ar.d corrective action taken on the failed units for both the 1986 and 1987 pts; however, no work requests or documentation of work was found. Licensee representative were unable to assure that corrective action had be taken on the failed unit The inspector reviewed two additional pts covering the routine operation of the PA system, pts 48.1 and 48.3, the normal speaker operation and the party-page, respectively. Review of the last pts conducted indicated only minimal failures and maintenance appeared to be conducted as appropriate.

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Although maintenance subsequent to those pts would probably correct some of the operability problems identified during the bypass system failures, this would not correct problems particular .to the bypass system. In addition, not all warning units are contained in the routine pts such as warning lights which are only part of the bypass syste A significant contributor to the lack of scheduled pts and assurance that maintenance on the bypass system was performed appeared to be that the original Plant Modifications (80-060 and 80-062) remained open with the system not yet having been turned over to operations. The licensee had

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initiated an attempt to closeout these mods; however, the work remains incomplet The inspector observed several actuations of the evacuation alarm system, evaluat%g five plant areas for audibility / visibility. Of the locations inspec od, one unit was found to be inaudible in the Feedwater Pump Room 1A area. Further investigation by plant engineers indicated that the PA unit was inoperable. It should be noted that to the knowledge of the

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inspector, this problem was not repaired during the course of the l

inspectinn, nor were any administrative measures implemented to assure that upon evacuation the areas would be checked for personne One specific case of inaudibility of the PA system should be noted. As discussed in NRC Report 50-325, 324/87-12, it was identified that a failure of the Public Address system could have been a major contributing factor to the September 13, 1986, reactor scra Upon identification of the previously discussed maintenance and operability problems, the licensee committed to provide a schedule for corrective action and completion of the Plant Mods to the NRC within 30 days of the date of this repor In addition, compensatory actions were formulated and relayed to the resident inspectors to be implemented until such time as the system was evaluated and declared fully operationa Specifically, a Standing Instruction was issued calling for a security sweep of all areas in the event of building or site evacuation. However, on July 23, 1987, the licensee was informed that the failure to maintain in effect the Emergency Plan was a violation of 10 CFR 50.54(q).

Specifically, the failure to adequately provide for alert and notification of onsite personnel in accordance with Section 4.4.2.1 of the Emergency Plan as evidenced by the inoperability of the PA unit in the Feedwater Pump Room 1A are Violation 50-325, 324/87-23-03: Failure to maintain in effect Section 4.4.2.1 of the Emergency Plan as indicated by the inoperability of the Public Address / Evacuation Alarm system in the Feedwater Pump Room 1A are _ _

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9 Inspector Follow-up (92701) (Closed) IFI 50-325/86-25-01 and 50-324/86-26-01: Clarification of the 15 minute notification statement such that there is no ambiguity on the time frame in which State and local authorities will be notifie The inspector reviewed pertinent procedures and observed that appropriate changes had been made. The statements were revised to indicate that notifications would be made within 15 minutes of emergency declaratio (Closed) IFI 50-325/86-34-01 and 50-324/86-35-01: Review changes made to EALs for the fire event categor The inspector reviewed PEP 2.1, Revision 19, dated March 20, 1987. Section 7 " Fire," was revised to indicate that a fire within the protected area lasting more than ten minutes was to be classified as an Notification of Unusual Event (N0VE), and a fire which could potentially affect vital !

safety-related equipment was to be classified as an ALERT. The new EALs were in accordance with the guidance of NUREG-0654, Appendix (0 pen) IFI 50-325/86-34-02 and 50-324/86-35-02: Exercise Weakness:

Procedures did not accurately reflect all parties on the automatic ringdown telephones used for notificatio The licensee had implemented a new selective signaling system for maintaining communications with the State and local Warning Points and Operation Centers. PEP 2.6.21, Revision 10, dated July 9, 1987, included the new system and what entities would be on the communication link. The inspector observed a test of the 10-22 selective signaling to the Warning Points and Coast Guar The procedures accurately reflected those parties on the line; however, this item will remain open until the next full scale exercise at which time full implementation will be evaluate l l

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