IR 05000324/1992036

Insp Repts 50-324/92-36 & 50-325/92-36 on 921119-23.No Violations or Deviations Noted.Major Areas Inspected: Emergency Preparedness,Protective Action decision-making, Notifications & Communications & Public Info Program

ML20128C936
Person / Time
Site:	Brunswick
Issue date:	11/20/1992
From:	Salyers G, Sartor W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20128C924	List: IR 05000324/1992036 ML20128C921
References
50-324-92-36, 50-325-92-36, NUDOCS 9212070059
Download: ML20128C936 (10)

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< Es a b / NOV 2 01993 Report Nos.: 50-325/92-36 and 50-324/92-36 Licensee: Carolina Power and Light Company P. O. Box 1551 Raleigh, NC 27602 Docket Nos.: 50-325 and 50-324 License Nos.: OPR-71 and DPR-62 Facility Name: Brunswick I and 2 InspectionConduc)ed: October 19- 3,)1992 Inspector: 7' de ~ /0 M /IMod9L G. D alyers /

/ Date Signed Accompanying Personnel:

Approved by: ! il __ JJ 2d ib ting Chief lateSigned

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1 iam H.~Sarto ,

E 3rgency Prepar e s Branch Rp iiological Prote t on and Emergency Vreparedness Branch Division of Radiation Safety and Safeguards SUMMARY-Scope:

This routine, unannounced inspection was conducted in'the area of emergency preparedness. The licensee's program was reviewed to. determine whether the licensee was maintaining a capability for emergency detection and classification, protective action decision-making, notifications and communications, shift staffing and augmentation, training, dose ~ assessment, and public information progra Results:

The licensee's Emergency Preparedness program was operational and fully capable of performing its function. Areas receiving comments were: quality of ERF training (Paragraph 6), the ability of dose assessment personnel to effective utilize field team data (Paragraph 7).

9212070059 921120 PDR ADOCK 05000324 G PDR

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REPORT DETAILS 3 Persons Contacted Licensee Employees

• K. Ahern, Operations Manager U-2

• H. Bean, Manager, Quality Control

• J. Boone, Regulatory Compliance

• M. Bradley, Manager, Nuclear Assessment Department (NAD)

• S. Callis, Licensing On-Site Representative

- *C. Cashwell, Training

• J. Cowan, Manager, Technical Support & Regulatory Compliance

• M. Foss, Regulatory Compliance

• R. Godley, Manager, NRC Compliance

• B. Hart, Nuclear Assessment Department

• R. Helme, Manager, Technical Support

• J. Holder, Manager, Outage Management & Modifications

• B. Houston, Senior Specialist Emergercy Preparedness

• M. Jackson, Maintenance Manager U-2

• M. Jones, Manager, Training

• M. Kesmodel, Coordinator IAP Control ard Administration

• J. Leininger, Manager, Engineering

• L. Loflin, Quality Control

• D. McArthy, Manager, Nuclear Licensing

• P. Mazzke, Training

• D. Moore, Maintenance Manager U-l

• R. Morgan, Plant Manager U-l

• R. Richey, Vice President Brunswick Nuclear Plant (BNP)

• C. Robertson, Manager, Environment and Radiation Control

• G. Thearling, Regulatory Compliance

• R. Starkey, Vice President, Nuclear Safety Department

• A, Watson, Senior Vice President BNP

• G, Warriner, Manager Control and Administration Other licensee employees contacted during this inspection included members of the emergency response organization, training staff, and office personne Nuclear Regulatory Commission

• H. Christensen, Section Chief Division Reactor Prejects

• S. Ebneter, Region 11 Regional Administrator

• J. Johnson, Deputy Director, Division Reactor Projects

• R. Lo, Project Manager NRR Project Director,

• R. Prevatte, Senior Resident Inspector

• Attended exit meeting

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2 Emergency Detection and Classification (82201)

Pursuant to 10 CFR 50.47(b)(4) and 10 CFR Part 50, Appendix E, Section IV,8 and IV.C and A)pendix 1 of NUREG-0654, this program area was inspected to determine if tie licensee used and understood a-standard emergency classification and action level schem The inspector verified that the licensee's notification procedures included criteria for initiation of offsite notifications and for development of Protective Action Recommendations (PARS). The notification procedures required that offsite notifications be made promptly af ter declaration of an emergenc The inspector reviewed documentation indicating that State and local review of the_EAls was conducted during July 1992. The event classification in the procedures was consistent with the Emergency Plan and with those required by regulation. The inspector noted that the EAls were based on parameters obtainable from Control Room instrumentation and the EAls did not appear to contain impediments or errors which could_ lead to incorrect or untimely classificatio The responsibility and authority for classification of emergency events and initiation of emergency action were described in Section 2 of the Plant Emergency Procedures (PEP) and in Sections 2 and 3 of the site Emergency Response Pla Interviews with Shift Supervisors.and Dose .

Assessment personnel disclosed that the interviewees understood their role, responsibilities and authorities in event classification, notification, and PAR Selected Emergency Operation Procedures (E0Ps) were reviewed to determine-if the E0Ps referenced the PEPS.- The inspector concluded that neither the PEPS nor the Emergency Plan were integrated into the operator actions of the E0P. The licensee stated, due to the complexity of the E0Ps and the Emergency Plan, and the number of changes that occur in the two documents annually, that the referencing'of the two' documents increased l the potential for procedural error The licensee further stated that i emphasis _was placed on the E0Ps and Emergency Plan EALs in licensed -

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operators training. The inspector concurred with the licensee remarks-and noted that integration (referencing) of the E0Ps and EALs is not a requirement.

l No violations or' deviations were idcatifie . Protective Action Decision Making (82202)

Pursuant to 10 CFR 50.47(b)(9)(10) and 10 CFR Part 50, Appendix E, l Section IV.D.3, this area was inspected to determine whether the licensee

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had 24-hour-a-day capability to assess and analyze emergency conditions and make recommendations to protect the public and on-site workers, and i:

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'3 whether offsite officials had the authority and capability to initiate prompt protective actions for the publi The inspector reviewed portions of the licensee's Emergency Plan and procedures which describe the responsibility and authority for protective action decision-making. The steps of the General Emergency Procedure assigned the responsibility for protective action decision-making to the Emergency Response Manager (ERM). The Radiation Control Manager and Technical Analysis Manager provide support to the ERM by recommending on-site and offsite protective actions to the ERM. The licensee also provides for protective actions for on-site nonessential personnel by having the ERM consider site evacuation for Alert and higher classification The inspector reviewed the following PEPS for guidance on protective action decision-makin * PEP-02.1, Initial Emergency Conditions e PEP-02.5, Emergency Control - General Emergency e PEP-02.6.16, Emergency Response Manager Each of the above procedures contained a flowchart for determining PARS based on plant condition No violations or deviations were identifie Notification and Communication (82203)

Pursuant to 10 CFR 50.47(b)(5)(6) and 10 CFR Part 50, Appendix E, Section IV.D., this area was inspected to determine whether the licensea was maintaining a capability for notifying and communicating (in the event of an emergency) among its own personnel, with offsite supporting agencies and authorities, and with the population within the Emergency Planning Zone (EPZ).

The inspector reviewed the licensee's notification procedures. The inspector determined that the procedures made provisions for message verificatio The content of the initial emergency messages was reviewed and discussed with licensee' representatives. The initial messages appeared to meet the guidance of NUREG-0654, Sections II.E.3-and II.E.4. Licensee representatives stated that the format and content of the initial emergency messages had been reviewed by State and local government authoritie The licensee's program for alerting the community in an emergency within the EPZ was reviewed. The system consists of 34 sirens within the EPZ which are activated by the local counties E0C. The inspector observed

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the annual full test of the Alert Notification System (ANS) conducted on October 22, 199 The test consisted of two full actuations of approximately one minute duration and three minutes apart. On the first test, 32 of the 34 sirens sounded and rotated properly. On the second test, 33 of the 34 sirens sounded and rotated properly. One-siren failed both tests. Repairs on the two failed sirens were initiated and completed within two days. The inspector reviewed records that indicated satisfactory operation of bi-weekly silent tests and quarterly growl tests of the AN Each year, local residents within the 10-mile EPZ are mailed an information handout about the plant and calendar. The calendars identify radio and television channels which broadcast emergency information if the sirens sound, evacuation routes and shelters for each zone within the EPZ and other information about the emergency preparedness progra The inspector determined by reviewing applicable procedures and by discussions with licensee representatives that procedures were in-place for alerting, notifying, and activating emergency response personne The licensee uses a personnel pager system to activate the Emergency Response Organization (ER0). The inspector reviewed the licensee documentation of the monthly pager test. The review indicated that the licensees had been testing the system in accordance with their Plan and that the system had functioned properly. If the pager system failed, the licensee had provisions for a manual call-in of ERO personne Communications equipment in the EOF was inspected. Provisions existed for prompt communications among emergency response facilities, emergency-response _ personnel, off site. agencies, and to the public. The inspector witnessed a demonstration of, and reviewed documentation that indicated satisfactory performance of the monthly communication test from the Control Room and the TSC. The system allows simultaneous (group) calling of the State and local agencies from the Control Room or the TSC. The installed communications at the Emergency Response Facility (ERF) were consistent with systems descriptions-in the Emergency Plan-and Plant Emergency Procedures (PEPS).

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, Section IV.A and IV.C, this area was inspected to determine if shift staffing for emergencies was adequate both in numbers and in . functional capability, and whether administrative and physical means were available and maintained to~ augment the emergency organization in a timely manne The inspector also discussed staff augmentation times with licensee representatives for the backshift periods. Section 3 of the Brunswick

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Emergency Response Plan (ERP) addressed the organization and the

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responsibilities of the emergency organization. The staffing and organization of the Emergency Response Organization meet the guidance of NUREG-0654 Rev. 1, Criteria for Preparation and Evaluation of Radiological- Emergency Response Plans and Preparedness in Support of Nuclear Power Plants. In Section 6 of the ERP, the licensee committed to an augmentation drill requiring travel to the site once every 24 month Brunswick Records for an unannounced augmentation drill in January 1991, were reviewed. The records indicated that the ERFs were staffed within the required time limit No violations or deviations were identifie . Knowledge and Performance of Duties (82206)

Pursuant to 10 CFR 50.47(b)(2) and (15) and 10 CFR Part 50, Appendix E, Section IV.F, and Section B 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 responsibilitie At BNP an individual is considered qualified for their emergency responder roles by maintaining their training current. The ER0 trainin records are conputerized. The computer lists each member of the ERO and the dates in which they completed each training course. In. response to cast training violations the licensee has incorporated a " Micro" function

.nto the computer for tracking ER0 training. The Micro program identifies members of the ERO at 90 days, 60 days, and 30 days prior to each training' course expiration date. _If a member's training should indicate " expired", security is requested to remove their site access badg The inspector reviewed the ER0 Roster and reviewed randomly selected members traiaing records. The' inspector's review did not identify any ERO member with expired qualification In order to determine whether emergency response personnel had received adequate training, whether they understood their emergency response roles, and whether they could perform their assigned functions, the inspector conducted interviews with two individuals qualified as .

Emergency Response Manager. The interviewees demonstrated the ability to classify accident conditions, make initial notifications, and demonstrated a proficiency with the PEPS. In order to ascertain the interviewees overall understanding of the EP program, the inspector _ asked some general overview questions concerning the EP program. As an example:

• When fully activated, what is the function of the TSC, EOF?

e At what emergency classification level is the E0F activated?

• In a General Emergency when full activated, which facility is

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responsible for performing dose assessments and who is. responsible for making PARS?

Neither interviewee satisfactorily answered the questions. The inspector discussed with the licensee representative-the apparent weakness of the interviewee's overall knowledge of the EP program and it's operatio The inspector interviewed two additional individuals responsible for dose assessment. During the interviews, each individual ~successfully

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demonstrated the ability to use the computer (IRDAM program) to perform dose assessments and recommend PARS based on the computer output. -The inspector asked both interviewees to back calculate the field team data and make dose assessment and PARS based upon that dat Both interviewees displayed difficulty in performing the_ task. This is discussed in Paragraph 7 of this report. With that exception, the ,

interviewees demonstrated capability to perform both manual and computer dose projections and to recommend PAR The inspector reviewed the emergency responder training program and test used during the last training cycle. The inspector noted that the initial and requalification training for ERO members was a self study progra Students were given a student handout or lesson plan for:needed courses. The student was expected to study the handout or lesson plan and at a later date, demonstrate their proficiency by satisfactorily completing a test of the material. The inspector selected tests for different ERO positions and compared each test over the past two. year The inspector noted that the test consisted of ten multiple choice or matching questions. Further review of the tests revealed that;seven of the ten questions were the_same on two consecutive years exams and_that-the remaining three were similar. The method of course presentation and the quality of testing were discussed with the licensee. -The licensee stated that the question bank from which the test questions originate was limited. The licensee states that ERO training was a-licensee identified concern and -that they-had recently hired an instructor specifically-

. designated for EP training and a consultant to assist the' instructor i upgrading the EP training program. The inspector's discussion with the new EP instructor noted that the licensee intends to totally revamp the-- -

- EP training program. The : licensee'. is working toward : developing;the'

program based on a systematic approach to training, using job and task; analysis, subject matter experts.and peer review. The' licensee

- representatives stated they intend to develop the program along the same guidelius used in the operator licensing program. The licensee also stated that. student handouts.and lesson plans are to be reviewed and rewritten if necessary. The inspector reOfewed the licensee. development-plan and time line for upgrading the EP training program.1The inspector's review of the new training program development and discussion with-the licensee revealed that the licensee had committed to improving *

the program and was in the process of following through with the program presented to the inspector. The licensee was informed the upgrading of

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the EP training program following the guidance of a systematic approach to training would be tracked as an Inspector follow-up Item (IFI).-

IFI 50-324, 325/92-36-01: Upgrade the EP training program following the guidance of a systematic approach to training .

The inspector's review of selected lesson plans ccacluded that the existing Emergency Plan student handouts and lesson plans contained sufficient information to satisfactorily train members of the ER0 in their positio One IFI and no violations or deviations were identifie . Dose Calculation and Assessment (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 licensee procedures:

• PEP-02.6.16, Emergency Response Manager

• PEP-03.4.1, Initial Dose Projections

• PEP-03.4.2, Whole Body Dose Projections

• PEP-03.4.3, Thyroid Dose Projections e PEP-03.4.7, Automation of Dose Projections Procedures Using the IBM Personal Computer

• PEP-03.6.1, Release estimates Based Upon Stack / Vent Readings The procedure provides the conditions and prerequisites for making L protective action recommendations based on plant conditions and/or calculated or measured dose rate :he licensee's dose assessment and PARS are based on actual plant conditions, IRDAM Computer Code, then actual field team dat The inspector interviewed two individuals responsible for dose assessment. During the interviews, each individual successfully demonstrated the ability to perform dose assessments and recommend PARS using both the manual calculation and the computer (IRDAM program).

The inspector presented both interviewees the following problem; You are given field team data that was considerably higher than the

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computer generated projected dose. Back calculate the data to the source term and make revised dose assessment and PARS based upon that dat Both interviewees displayed difficulty in performing the task. One interviewee did not complete the task, and the other interviewee's methodology and solution was questioned by the inspecto The results of the interview was discussed with licensee representative The licensee stated that at present, they do not have a procedure or computer program for back calculating field team data. The licensee stated that they had also identified the cor:cern and provided their Action Item Tracking List to the inspector. Item 4 on the Action Item a Tracking List, stated " Develop a guideline to perform back caiculations to be used at the projects and to be approved by the Dose Assessment Working Group (DAWG)". The licensee stated that a draft procedure for performing back calculations was written and was presently at the Corporate Office for editing. The licensee committed to finalize and implement the procedure for back calculating field team data to the source term. The inspector informed the licensee that the commitment to develop and implement the procedure for back calculating field team data to the source term and make dose assessments and PAR recommendations h; sed on the back calculated field team data would be tracked as an IF IFl 50-324, 325/92-36-02: Develop and implement the procedure for back calculating field team data to the source term and make dose assessments and PAR recommendations based on the back calculated field team dat One IFI and no violations and no deviations were identifie . Public Information Program (82209)

Pursuant to 10 CFR 50.47(b)(7), Criteria in NUREG-0654,Section II.G, and Section G., Public Education and Information of the licensee's Emergency Plan, this area was reviewed to determine if the licensee was disseminating information to the public in the plume exposure pathway EP The licensee provides emergency preparedness and protective action information to the public in conjunction with the State and local government. The licensee utilized calendars and brochures to inform the publ ic. A licensee representative stated that the calendars and brochures were updated annually and mailed to residents and businesses within the 10-mile EPZ. The calendars include information on early warning systems, emergency broadcast stations, sheltering procedures, evacuating procedures, evacuation routes and maps, special needs, radiation and contamination controls, and telephone numbers for agencies to obtain additional information. Brochures designed for students within the 10-mile EPZ were also issued at school l

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The inspector independently verified that emergency preparedness information was being uisseminated to area merchant No violations or deviations were identifie . Action on Previous inspection Findings (92701)

The inspector reviewed the open items from the previous inspection and concluded the items could best be evaluated and closed during an annual exercise inspection. No open items were closed during this inspectio . Exit Interview The inspection scope and results were summarized on October 23, 1992, with those persons indicated in Paragraph 1. The inspector described the areas inspected and discussed in detail the inspection results. No proprietary information was reviewed during this inspection. The licensee acknowledged the findings concerning utilization of field team data, and upgrading of the EP training progra Item Number Category. Description. and Reference 50-324,325/92-36-01 IFl: Upgrade the EP training program following the guidance of a systematic approach to training (Paragraph 6).

50-324,325/92-36-02 IFI: Develop and implement the procedure for back calculating field team data to the source term and make dose assessments and -

PAR recommendations based on the back calculated field team data (Paragraph 7).

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