IR 05000324/1990008
| ML20033F544 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 03/06/1990 |
| From: | Gooden A, Rankin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20033F543 | List: |
| References | |
| 50-324-90-08, 50-324-90-8, 50-325-90-08, 50-325-90-8, NUDOCS 9003220014 | |
| Download: ML20033F544 (9) | |
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-. NUCLEAR REHULATORY COMMISSION '
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REGION 11.
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101 MARIETTA STREET, N.W.
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[. ; Report.NosTi[50.325/90-08and.50-324/90-08'
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ILicenseeif(CadolinaPowehand-LightCompany m
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P. OL Box'1551'..
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License.Nos.: -DPR'71 and DPR-62:
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- Docket Nos.
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E Facility Name:- Brunswick'1 and 2; s
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Inspection' Conducter Debruary$12-16,1990
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rJ t. Gooden Date Signed A
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W. Rankin, Chief-Date. Signed-
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. Emergency Preparedness Section'-
W Emergency Preparedness and Radiological
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. Protection Branch Division of Radiation Safety and Safeguards
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SUMMARY l'
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This routine, unannounced inspection was conducted in?the area of emergency x
preparedness.
Several aspects of: the: emergency preparedness program were
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re_ viewed c to determine 'if the program:was being maintained -in a state of
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,A readinessifor responding to emergencies.
Areas examined included-a review of
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training, audit reports, changes to the emergency organization, distribution of
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' changes to the Emergency. Plan and Plant Emergency Procedures'-(PEPS).-corrective
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action tracking system,. and the' maintenance of key onsite facilities and.
' selected emergen.cy kits.'
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(Within. the areas -reviewed, one non-cited violation was identified for failure
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to conduct an annual review of the Emergency Plan by the Plant Nuclear Safety -
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The following program strengths were noted:
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! As evidenced by program enhancements planned and/or implemented in
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emergency ' response training, there appears to be a strong connitment by
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plant management-for the emergency response program.
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Prompt response' in resolving -inoperable components to the onsite and
offsite warning systems,
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REPORT DETAILS 1.
Persons Contacted-Licensee Employees
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D. Cooper, Shift Operating Supervisor H. Goodwin, Corporate Emergency Preparedness Project Specialist
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- J. Harness, General Manager-
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-W. Harrison, Production Assistant
- M. Highsmith, Brunswick Emergency Preparedness Specialist B. Hinson, Radiation Control Technician.
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B. Houston, Brunswick Senior Energency Preparedness Specialist
- D. Pate, Shift Foreman
- R. Poulk, Supervisor, Regulatory Compliance
- D._Rudolf, Quality Assurance Engineer
- W. Simpson, Manager, Control and Administration
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Other licensee employees contacted during this - inspection included engineers, operators, security force members, technicians, and administrative personnel.
NRC Resident Inspector
-*W. Ruland
- Attended exit interview 2.
Emergency Plan and Implementing Procedures (82701)
- Pursuant to 10 CFR 50.47(b)(16),10 CFR 50.54(q), and Appendix E to
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10 CFR Part 50, this area was reviewed to determine whether changes were made to the program since the last routine inspection (January 1989), and-to assess the impact of these changes on the overall state of emergency preparedness at the facility.
The inspector reviewed the licensee's procedure for making changes to the Emergency Plan and PEPS. A review of selected changes since January 1989, disclosed that revisions were approved by the General Manager or designated approving authorities and submitted to the NRC within 30 days of the approval date. An audit of controlled copies shown on the distribution list provided by Document Control indicated that changes were distributed in a timely manner. The inspector reviewed control copies of the Emergency Plan and PEPS in the Control Room, Technical Support Center (TSC), Shif t Operating Supervisor's Office, and the Plant Library.
No problems were note *
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Section 6.2.1 of. the Emer0ency Plan and Section 6.5.3.8 of the Technical Specifications Manual states that an annual review of the Emergency Plan shall be performed by the Plant Nuclear Safety Comittee. (PNSC). Although
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reviews were conducted during both calendar years 1987 and 1988, a review was not.' conducted during the calendar year 1989.
The cognizant licensee
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representative responsible for scheduling the annual review acknowledged t
this finding and informed the inspector that due to an administrative oversight, a calendar year 1989 review had not been performed, in
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response to the ' aforementioned finding, the licensee initiated the
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following actions:
A PNSC review of calendar year 1989 changes was scheduled for the
week cf February 19, 1990.
To prevent recurrence, an annual commitment for performing a Plan review by ~ the PNSC was included in the Emergency Preparedness Tracking System (Procedure No RCI-10.1) to ensure follow-up and verification that Plan commitments are being met.
According to a' discussion with a member of the licensee's staff, this commitment previously was not tracked via the Emergency Preparedness or plant-wide tracking system.
The licensee was informed that this finding was an example of a violation that is not being cited because criteria specified.in Section V.A of the NRC Enforcement Policy were satisfied.
Therefore, failure to conduct an annual review of the Emergency Plan by the PNSC, is considered a non-cited violation (NCV).
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NCV ' 50-325,.324/90-08-01:
Failure to conduct an annual review of the Emergency Plan by the PNSC.
D Section 6.2.3 of the Brunswick Emergency Plan required that Letters of Agreement be updated at least every two years.
In accordance with Section 6.2.3, all Agreement Letters were current and up-to-date.
One NCV was identified.
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Emergency Facilities, Equipment, Instrumentation, and Supplies (82701)
Pursuant to 10 CFR 50.47(b)(8) and (9),Section IV.E of Appendix E to l
10 CFR Part 50, and Section 6.3.1 of the licensee's Emergency. Plan, this l
area was insp(ected to determine whether the licensee's emergency response facilities ERFs)
and other essential emergency equipment, instrumentation, and supplies were maintained in a state of operational readiness.
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, and Operation SupportCenter(OSC).
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In assessing the operational status of the emergency facilities, the inspector verified.that protective equipment, and supplies - were operational and inventoried on a periodic basis.
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cabinets from the Control Room and TSC were inventoried, and randomly selected' equipment was checked for operability.
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 January l=
1989 to January 1990, the inspector determined that emergency equipment
was being checked in-accordance with procedures governing such tests (PEP-04.2 and PEP-04.6)..
Records reviewed indicated that. all discrepancies or problems identified during inventories and communications checks were corrected in a timely manner.
p 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 documentation and a discussion with the licensee 1 contact, the emergency evacuation system
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consists of an evacuation alarm and warning lights. Documentation for the period January-August' 1989 disclosed that the emergency evacuation system was being tested in accordance with Periodic Test Procedure Nos. 48.1 and 48.2.
As noted above, problems identified during' checks were resolved in
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a timely manner.
The licensee's management control program _for the Early Warning System
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(EWS) was reviewed.
The system currently consists of 34 sirens.
Test documentation for the period January 1989 to January 1990 showed that problems identified during testing were resolved in-a timely manner.
No violations or deviations were identified.
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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 3.0 of the the licensee's Emergency Plan, this
. area was inspected to detennine 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 into the Emergency Plan and PEPS.
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Several organizational changes had been made since the last routine inspection (January 1989). Based on the review and discussion of changes with a licensee contact, the changes would not have an adverse impact on i
the emergency preparedness program.
Changes were as follows:
A site change involved the position Manager of Regulatory Compliance, to whom emergency preparedness reports. Since the last inspection, a personnel change was made to this position.
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During October 1989, an " organizational analysis" occurred which
resulted in a reduction of staff at both the site-and corporate office. However, the reductions did not affect Table B-1 staffing.
At the corporate office, several personnel changes had been made as a
result of position reassignments.
The most note-worthy involving emergency preparedness was the personnel change -involving the Manager of Emergency Preparedness, and the resulting title change for the individual ' filling this position.
The title Manager, Emergency
' Preparedness was changed to Manager Emergency Preparedness and Spent Fuel.
The previous Manager of Emergency Preparedness was-reassigned
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within the corporate organization.
The overall reporting chain for emergency preparedness did not change; ultimate responsibility remains with the Vice President of Nuclear Services.
Subsequent to the organizational analy(sis study, the public information aspects of-emergency preparedness e.g. public information brochu e, f acility maintenance, planning, etc.) were reassigned f rom Corporate Communications to Emergency Preparedness and Spent Fuel Management.
The day-to-day activities for public information remains with corporate communications.
Regarding facility changes, the Corporate Emergency Operations Center (CE0C) was dissolved in view of the redundancy performed by the CE0C and Emergency Operations Facility (EOF) staffs.
However, the communications aspect of the CEOC in dealing with the media remains with the corporate office until the TSC/E0F is activated.
No violations or deviations were identified.
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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 6.1 of the Emergency Plan, this area = was inspected to determine whether the licensee's key emergency response personnel were properly trained and understood their emergency responsibilities.
The inspector reviewed Section 6.1.1 of the Emergency Plan, PEP-04.3 (Performance of Training, Exercises, and Drills), and TI-306 (Emergency Plan Training) for a description of the training program and training procedures. In addition, selected training modules or instructor guides were reviewed, and personnel with the responsibility for conducting and tracking the emergency response training were interviewed. It was
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determined that the licensee maintains a formal emergency training program.
The inspector conducted a walk-through evaluation with Control Room personnel that may be involved during the initial stages of an accident.
Interviewees were given various sets of emergency conditions and data involving a tornado and asked to respond as if an emergency actually existed.
Interviewees demonstrated familiarity with emergency procedures
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and no problems were noted in the areas of emergency detection, classification, notifications, and protective action recomendations.
l The licensee maintains a training tracking system known as Nuclear Education Training System (NETS).
Incorporated into the referenced system is Emergency Plan training.
Once each month a report is generated which
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provides _ a listing of all personnel with training to expire by.the end of r
the-following month.
Training. records were reviewed for several members
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of: the emergency organization.
When personnel training records were compared with position assignments,. no problems were noted.
Offsite support agency training was reviewed for fire, ambulance, rescue, hospital, emergency management (State, local, and Coast Guard), and local law enforcement agencies.
Training was conducted in accordance with comitments in the Emergency Plan and/or Agreement Letters.
At the time of the inspection, calendar._ year 1990 training for the offsite support agencies had not been conducted; however, documentation was provided to show that offsite contacts were notified regarding the upcoming training.
-No violations or deviations were identified.
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IndependentReview/ 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 cmergency preparedness program and whether the licensee had a corrective action system for deficiencies and weaknesses identified during exercise and drills.
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Records showed that the most recent audit of the program was conducted during'the period of August 14-25, 1989. This audit was conducted by the Corporate Office Quality Assurance Department and documented in Audit
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Report No. QAA/0021-89-04.
This audit satisfied the 12-month frequency requirement for such audits as required by 10- CFR 50.54(t) and Section 6.2.2 of the Emergency Plan.
The inspector reviewed the licensee's program for follow-up action on drill and exercise findings.
The review indicated that the licensee had an Emergency Preparedness Tracking System (Procedure RCI-10.1) for ensuring proper follow-up action on deficiencies and weaknesses identified during exercises and drills.
In addition, the inspector discussed with a i
licensee representative the Facility Automated Comitment Tracking System (known as FACTS) used for tracking identified comitment items' resulting from NRC and Quality Assurance Audits.
No violations or deviations were identified 7.
Event Followup (92700)
During the period October 1989-February 1990, one event declaration
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occurred.
On December 22, 1989, an Alert declaration was made due to the loss of audible annunciators on the Unit 2 Reactor Turbine Generator Board
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(RTGB). The inspector reviewed completed notification forms and notes from log books maintained by key emergency response personnel in the Control Room and TSC. ;No problems were noted in the areas of classification,--
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notification, - or activation.
Actions in response to the incident and
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mitigating actions were prompt and effective.
All. notifications were
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done in a timely manner consistent witti procedural requirements.
l No violations or deviations were identified.
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Action on Previous Inspection Findings (92701, 92702)
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(Closed) Violation 50-325,324/88-37-03:
Failure to correct exercise i
weakness.
The inspector reviewed documentation that indicated actions were taken to-resolve the' exercise weakness and prevent a recurrence-of problems involving timely follow-up notifications. Actions that were l
taken included training of all Operations personnel and Emergency
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Comunicators; and revision of PEP-02.6.21 entitled " Emergency
Communicator."
Further, a review of documentation for three events
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that occurred during calendar year 1989 disclosed no problems with
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the timeliness of the initial or follow-up notification messages, b.
(Closed)'IFI 50-325, 324/89-'26-05:
Hurricane emergency declarations
not consistent with anemometers.
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The hurricane emergency action levels were reworded to include contacting the Corporate Meteorological Center for onsite wind estimates greater.than 100 mph.
Utilizing information from the National Weather Service, satelite photos, and aircraft measurements,
'y the corporate' office would provide estimated wind velocities.
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(Closed) IFI 50-325, 324/89-31-01: Develop an acceptable follow-up notification form, and conduct additional training regarding the timeliness of the follow-up message.
i The inspector reviewed a follow-up notification form that was i
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included as an attachment to PEP-02.6.21.
A walk-through with Control Room personnel and a review of select training records l
disclosed that personnel were familiar with both the initial and
follow-up notification form.
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(Closed) Violation 50-325, 324/89-31-02:
Failure - to provide follow-up notifications to State / local agencies in accordance with PEP-02.6.21.
The inspector noted that actions were taken by the licensee in accordance with the licensee's response to the Notice of Violation dated November 27, 1989.
Further, during events which occurred in September and December 1989, no problems were noted with the initial
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or follow-up notifications to offsite authorities. All notifications were done within the time limits specified in PEP-02.6.21.
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(0 pen)IFI 50-325, 324/89-31-03: Conduct an unannounced augmentation drill to verify that Table D-1 of NUREG-0654 staffing and arrival times can be met.
At the time of the inspection, plans were reaffinned for conducting the referenced drill within the previcusly comitted date of March 1990.
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(Closed) Violation 50-325, 324/89-31-04:
Failure to provide members of the emergency organization with training in accordance with PEP-04.3 and 11-306.
The inspector reviewed training for several individuals assigned to the emergency organization and no problems were noted.
In addition to conducting the required training, since the September 1989
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inspection, the licensee had implemented a training tracking system
for ensuring that ;nrsonnel training was current and up to date. The aforementioned actions were consistent with the licensee's response to the Notice of Violation, g.
(Closed) IFt 50-325, 324/89-31-05:
Develop and implement an effective tracking system for emergency response training.
A computerized tracking system known as NETS it maintained by the Brunswick Training Unit for scheduling e.nd tracking of all Emergency Plan training.
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Exit Interview The inspection scope and results were sumarized on February 16,19SO, i
with those persons indicated in Paragraph 1.
The inspector described the areas inspected and discussed in detail the inspection results listed below.
The licensee did not identify as proprietary any of the material provided to or reviewed by the inspector during this inspection.
Dissenting coments were not received from the licensee.
Item Number Description / Reference -
50-325, 324/90-08-01 NCV - Failure to conduct an annual review of the Emergency Plan by the Plant Nuclear Safety Comittee (Paragraph 2).
Licensee management were informed that seven items from previous inspections were reviewed and six items are considered closed (Paragraph 8).