IR 05000348/1981020
| ML20039D288 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 11/09/1981 |
| From: | Andrews D, Jenkins G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20039D245 | List: |
| References | |
| 50-348-81-20, 50-364-81-23, NUDOCS 8112310495 | |
| Download: ML20039D288 (41) | |
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UNITED STATES
NUCLEAR REGULATORY COMMISSION o
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U REGION 11 8-101 MARIETTA ST., N.W., SUITE 3100 os g
ATLANTA, GEORGIA 30303
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Report Nos. 50-348/81-20 and 50-364/81-23 Licensee: Alabama' Power Company P. O. Box 2641 Bimingham, AL 35291 Facility Name:
Farley Nuclear Plant Docket Nos. 50-348 and 50-364 License Nos. NPF-2 and NPF-8 Inspection at Farley Site near Ashford, Alabama Inspector:
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D. L. Andrews (Team Leader)
' Date Signed Accompanying Personnel:
M. J. Gaitanis, J. L. Kenoyer, C. R. McFarland, R. K. Roemmij:, K. M. Clark, B. F. Zalcman Approved by:
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G.R.Jenkins,Sectionghief Date Signed SUFNARY Inspection on September 21 to October 2, 1981 Areas Inspected This special announced inspection involved 546 inspector-hours on site in the performance of an Emergency Preparedness Appraisal.
Results In the area inspected, no violations, deviations or energency preparedness deficiencies were identified.
8112310495 811222 DR ADOCK 05000 t
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TABLE OF CONTENTS'
INTRODUCTION DETAILS 1.0. Administration 2.0 Emergency Organization
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2.1 Onsite Organization 2.2 Augmentation Organization-3.0 Training / Retraining 3.1 Program Established 3.2 Program' Implementation 4 ~. 0 Emergency Facilities and Equipment 4.1 Emergency Facilities 4.1.1 Assessment Facilities 4.1.1.1 Control Room 4.1.1.2 Technical Support Center (TSC)
4.1.1.3 Operations Support' Center (OSC)
4.1.1.4 Emergency Operations Facility-(EOF)
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4.1.1.5 Post-Accident Coolant Sampling and Analysis 4.1.1.6 Post-Accident Containment Air Sampling and Analysis 4.1.1.7 Post-Accident Gas and Particulate Effluent Sampling and Analysis 4.1.1.8 Post-Accident Liquid Effluent Sampling and Analysis-4.1.1.9 Offsite Laboratory Facilities 4.1.2 Protective Facilities-4.1.2.1
' Assembly / Reassembly Areas 4.1.2.2 Medical Treatment Facilities l
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4.1.2.3 Decontamination Facilities-4.~ 1. 3 Expanded Support Facilities 4.1.4 News Center 4.2. Emergency Equipment-4.2.1 Assessment Equ'ipment-4.2.1.1 Emergency Kits and Emergency-Survey Instrumentation 4.2.1.2 Area'and Process Radiation Monitors 4.2.1.3 Non-Radiation Process Monitors 4.2.1.4 Meteorological Instrumentation 4.2.2 Protective Equipment 4.2.2.1 Respiratory Protection 4.2.2.2 Protective Clothing 4.2.3 Emergency Communications Equipment 4.2.4
.Dr..nage Control / Corrective Action and Maintenance Equipment and Supplies 4.2.5 Reserve Emergency Supplies and Equipment 4.2.6 Transportation 5.0 Emergency Implementing Procedures 5.1 General Content and Format 5.2 Emergency, Alarm and Abnormal Occurrence Procedures 5.3 Implementing Instruction 5.4 Implementing Procedures 5.4.1 Notifications 5.4.2 Assessment Actions 5.4.2.1 Offsite Radiological Surveys 5.4.2.2 Onsite (Out of-Plant) Radiological Surveys 5.4.2.3 In plant Radiological Surveys
5.4.2.4 Primary Coolant Sampling 5.4.2.5 Primary Coolant Analysis.
5.4.2.6 Containment Air Sampling 5.4.2.7 Containment Air Sampling Analysis 5.4.2.8 Stack Effluent Sampling.
5.4.2.9 Stack Effluent Sample Analysis 5.4.2.10 Liquid Effluent Sampling 5.4.2.11 Liquid Effluent Sample Analysis 5.4.2.12 Radiological and Environmental Monitoring Program 5.4.3 Protective Actions 5.4.3.1 Radiation Protection During Em'ergencies 5.4.3.2 Evacuation of Owner Controlled Areas 5.4.3.3 Personnel Accountability 5.4.3.4 Personnel Monitoring and Decontamination.
5.4.3.5 Onsite First Aid / Search and Rescue 5.4.4 Security During Emergencies 5.4.5 Repair / Corrective Actions 5.4.6 Recovery 5.4.7 Public Information 5.5 Supplementary Procedures 5.5.1 Inventory, Operational Check and Calibration of Emergency Facilities and Equipment 5.5.2 Drills and Exercises 5.5.3 Review, Revision, and Distribution 5.5.4 Audit 6.0 Coordination with Offsite Groups 6.1 Offsite Agencies
6.2 General Public 6.3 News Media-7.0 Drills, Exercises and Walk-Through 7.1 Program Implementation 7.2 Walk-Through Observation Attachment:
Persons Contacted
INTRODUCTION The purpose of this special appraisal was to perform a comprehensive evaluation of the licensee's emergency preparedesss program.
This appraisal included an evaluation of the adequacy and effectiveness of areas for which explicit regulatory requirements may not currently exist.
The appraisal effort was directed towards evaluating the licensee's capability and performance rather than the identification of specific items of noncompliance.
The appraisal scope and findings were summarized on October 2, 1981, with those persons indicated in the attachment to this report.
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DETAILS 1.0 Administration of the Emergency Plan Emergency planning responsibilities at the Farley Nuclear Plant (FNP) were reviewed with respect to the requirements of 10CFR50.47(b)(16),10CFR50, Appendix E, Paragraph IV.g, and specific criteria in NUREG-0654,Section II.P.
Overall responsibility for emergency response planning at FNP has been delegated to the General Manager - Nuclear Generation, who in turn has delegated r,2cific responsibilities to the Superintendent of Procedural and Regulatory Control at the corporate level and to the Environmental and Emergency Planning Section Supervisor at the Plant Site. These individuals have been formally assigned to the respective responsibilities of Emergency Planning Coordinator (EPC), Corporate, and Emergency Planning Coordinator (EPC), on-site.
Input to emergency planning at FNP is through various routes including all supervisors and Plant Manager. All changes to the FNP Emergency Plan (EP)
and the EP Implementing Procedures (EIP's) are reviewed and approved by the Plant Operations Review Committee (PORC).
Although no specific criteria have been established for the selection of the EPC's, the individuals designated to fill the positions at both the corporate and plant levels were consciously selected based on their education, experience and previous association with emergency preparedness matters.
Professional development training for the EPC's has been provided through short courses and seminars concerning emergency preparedness presented by INPO and Scientific Applications, Inc., among others. Alabama Power Company (APCO) management is aware of the importance of maintaining state-of-the art knowledge in the area of emergency preparedness.
Based on the above findings, this portion of the licensee's program appears to be adequate.
2.0 Emergency Organization 2.1 Onsite Organization The onsite emergency organization was reviewed with respect to the requirements of 10CFR50.47(b)(1) and (2), 10CFR50, Appendix E, Paragraph IV. A, and specific criteria in NUREG 0654,Section II.B.
The onsite emergency response organization at FNP was described in Section II of the EP and FNP-0-EIP-0, Emergency Organization and Control Room Access. The Shift Supervisor has been designated the interim Emergency Director and has been delegated the authority to initiate emergency response actions, including notification of offsite agencies, until relieved by the Emergency Director or an alternate.
Functional responsibilities for responses to onsite emergencies were outlined in Table 1 and Section II of the EP. This table aid not meet l
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the staffing criteria of Table B-1,.Section II.B of NUREG 0654 in that there were no provisions for supplementing the onsite staff within a reasonable time.
A letter from Mr..F. L. Clayton, APC0 to Mr. A. Schwencer of December 16, 1980 committed to upgrade the onsite emergency organization by September 1,1981. Although the EP 'had not
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yet been revised, the inspector verified that the upgraded staffing commitment had been implemented prior to Septemi er 1.
Review of onsite staffing charts and discussions with-licensee representatives verified that the criteria of NUREG 0654 have been met.
Based on the above findings, this portion of the licensee's program appears to be adequate.
2.2 Augmentation of _the Onsite Emergency Organization -
Augmentation o f. the onsite emergency organization by corporate personnel has not been included in FNP emergency planning. Corporate personnel are designated to staff the interim EOF upon notification by the Emergency Director. Although some offsite interface functions will be assumed by the E0F Staff the interim E0F does not have complete capability to relieve the onsite organization of all offsite functions.
The interim EOF is discussed further in -0IE Report No. 50-348/80-36; 50-364/80-48 and paragraph 4.1.1.4 of this report.
The onsite organization will be augmented by contractor and private company assistance identified in the EP,Section II.C. and the agreements that exist between APC0 and these identified agencies.
Based on the above findings, this portion of the-licensee's program appears to be adequate.
3.0 ' ~ Emergency Plan Training / Retraining 3.1 Program Established The Emergency Training Program was reviewed with respect to the requirements -of 10CFR50.47(b)(15) and (16), 10CFR50, Appendix E, Paragraph IV.F.,' and criteria in NUREG-0654, Section 1I.0.
The onsite portion of the FNP training program is designed for_use in two parts, General-Training and Specific Training.
Administrative Procedure (AP) FNP-0-AP-45 deals with the overall training program.
General training for each FNP APC0 employee involves an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> course with 4!s hours of the time dedicated to emergency training (FNP-0-AP-45, Appendix 0). A 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> retraining program is conducted on an annual basis for an FNP APC0 employees and is outlined in Appendix E.
Specific training for separate assignments in the emergency response organization is addressed throughout FNP-0-AP-45, each functional area is outlined in its own specific appendix,'and each category of the emergency -organization is adequately defined.
Each category has a designated lesson plan. and appendix listing for training with a corresponding retraining appendix and lesson plan to follow on a yearly
basis. Some retraining plans, such as fire brigade retraining, follos
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on a quarterly basis in accordance with Plant Technical Specification.
Corporate personnel are involved in training and -this is done on: a
. regular basis.
Training and retraining is conducted with. State and Local Agencies when possible, with annual training and retraining conducted with local ambulan'ce services, local fire departments, and the Southeastern Alabama Medical Center. Agreements letters are available to authorize this interface action.
Lesson plans with student performance objectives, useful in.
' establishing individual performance ability, are available to the qualified instructors. Both classroom it. :tures and hands-on training
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courses are utilized with occasional wals-H rough training given to-augment specific programs. Use of equipment, ability to make decisions and data interpretation are evaluated.
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Training documentation includes the individual's name, date of training, course title, instructor, as well as retraining date. for-future reference. Senedules and records on training are coordinated and maintained by the training cadre but are in a period of transition as is the entire training program.
The duties of one who discovers an emergency condition are discussed along with methods for notification.. Notification procedures are discussed for all categories. It was determined by the auditors, af ter -
several plant personnel interviews, that plant emergency telephone numbers are apparently not adequately emphasized. During interviews, few individuals could remember the appropriate telephone numbers for reporting an emergency.
Provisions exist to train members of the emergency organization in change-to procedures and equipment which occur in the period between traini : sessions.
Licensee augmentation personnel are trained in emergency procedures-if they are to enter the protected or vital areas; however, no such training is provided if plant access is only to the controlled area.
For individuals, whether functioning as contractor employees or as visitors, who have authorization to only the controlled area, emergency procedure instructions are delineated on the back side of the visitor / plant access badge card.
The FNP environmental teams have a training course for sampling and analysis under field conditions and are capable of making rough field calculations when required.
Based on the above findings, this portion of the licensee's program appears to - be adequate, however, the following item should be considered for improvement:
J Emergency notification telephone numbers should be posted by
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each PAX telephone. (50-348/81-20-01; 50-364/81-23-01)
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3.2 Program Implementation Training records maintained by the licensee indicate that all required training has been completed. Through numerous interviews the auditors established that training had actually occurred as recorded and the course content was consistent with lesson manuals and training records.
Plant personnal demonstrated an understanding of training course content as related to their duties with the exception of emergency notification telephone numbers as discussed in 3.1.
Review of records and drills and discussions with plant training instructors showed that weaknesses pinpointed in drills and exercise were followed up with modified training programs.
Based on the above findings, this portion of the licensee's program appears to be adequate.
4.0 Emergency Facilities and Equipment 4.1 Emergency Facilities 4.1.1 Assessment Facilities 4.1.1.1 Control Room The control room emergency facilities were reviewed with respect to the requirements of 10CFR50.47(b)(8),10CFR50 Appendix E, Paragraph IV.E and the criteria in NUREG-0654,Section II.H.
The main control room consists of Units 1 and 2 control rooms and is located in the Auxiliary Buildings at elevation 155.
The existing emergency communications facilities includes three (3) Plant Automatic Exchange (PAX) telephones and a dedicated Gaitronics line connecting the Control Room, TSC, OSC's and the interim EOF. Dedicated systems to the NRC, and State of Alabama and Health Physics exist.
An updated EP and the EIP's are available in the control room.
Common readouts providing data on meteorology, radiation monitoring, and process monitoring are readily available to the two units in the control room.
Habitability provisions and supplies (30 day. food supply for control room emergency personnel) appear adequate and are routinely inventoried. Space for about ten (10)
persons at the control boards appears available. Hot shutdown panels exist for each unit should the main control room become uninhabitable.
Based on the above findings, this portion of the licensee's program appears to be adequate.
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4.1.1.2 Technical Support Center (TSC)
The TSC and other emergency facilities were reviewed for requirements of 10CFR50.47(b)(8),10CFR50, Appendix E, Paragraph IV.E,.and the criteria in NUREG-0654, Section
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The TSC is adjacent to the Unit 1 end of the main -
control room in the Auxiliary Building and is supervised by the Emergency Director. This center meets the same radiation shielding-and ventilation requirements as the main control room.. There is' sufficient space available to accommodate twenty-five (25) persons.
The TSC communications includes 9 PAX lines, 2-Birmingham extensions,. and sound powered phones. The NRC Emergency Notification System (ENS) exists. Another:
' dedicated line, Emergency Notification Network ~ (ENN),
provides an immediate link to the-State of. Alabama and local ~ county-pers'onnel in Alabama'and Georgia. The NRC Health Physics Network -(HPN) dedicated line is not installed here 'at this time.
This-incomplete installation has been. referred. to the Region II Emergency Officer and Tele-Communications Branch.
Should all communications to the control room be lost,
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the 'close proximity--of the TSC allows for-~ continued effective emergency response management.
The TSC upon activation will be staffed in accordance -
with FNP Emergency Plan as follows:
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Emergency Director 2.
Operations Manager 3.
Maintenance Manager 4.
Technical Manager 5.
Health Physics Manager Reference materials, including the. Emergency Plan and Implementing Procedures, a microfiche reader and printer, a plant parameter remote monitoring capability and printout exists-in the-TSC. A plant parameter CRT-display and printout for each unit also exists in - the main control - room.
In addition a remote-monitoring system of the entire main controlboard. instrumentation is available and consists of two (2) cameras and two_ (2)
receivers per unit. The cameras are equipped with pan, tilt, focus and zoom capability.
Radio reception - is available between the TSC and ' the field monitoring.
Based on the above findings, this portion of the licensee's program appears to be adequat _
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4.1.1.3 Operations Support Center'(OSC)
The emergency facility, the OSC, and equipment were viewed against the requirements of 10CFR50.47(b)(8),
10CFR50, Appendix E, Paragraph IV.E and the' criteria in NUREG-0654,Section II.H.
The main OSC is located in the southeast corner of the Unit 1 side of the control room. This is the assembly area for chemistry and health physics (HP) personnel and the remainder of on-shift operating personnel not required at ~ the main control board.
This OSC is supervised by a HP foreman.
An estimated 15-20 personnel can be readily accommodated.
The OSC is adjacent to the HP office area which contains HP supplies, instrument storage, decon facilities and emergency cabinets and equipment.
Three other OSC's are identified for operations support as follows:
OSC - Maintenance; OCS - Security; OSC -
Service Building Auditorium.
Each of the OSC's, the-TSC, the EOF and the main control room is connected with a dedicated Gaitronic communications system. The HPN is not yet installed (See 4.1.1.2 of this report).
Based on the above findings, this portion of the licensee's program appears to be adequate.
4.1.1.4 Emergency Operations Facility (EOF)
The Emergency Operations Facility was reviewed against.
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the requirements of 10CFR50.47(b)(3),10CFR50 Appendix E Paragraph IV.E, and the. criteria in NUREG-0654,Section II.H.
The interim EOF is located in the Startup Office'in the licensee controlled area. Reference materials.such as the Emergency Plan and Implementing Procedures, piping and instrument ' drawings, record materials, equipment-diagrams and office supplies are located here. Other supplies and HP instruments-are stored in the Switch House which is also located in the licensee controlled area.
Communications at the interim E0F consists of the ENN, two direct lines to Birmingham, 3 PAX lines, and one direct line to Ashford.
The ENS and HPN were not available here. (See 4.1.1.2).
The EOF is the point of interface for federal, state, and local authorities for implementation of offsite '
emergency plans in' addition to providing a centralized meeting place for key representatives from different
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agencies including the-press. The' current interim EOF has space available for about 25 persons. Additional space is available for the interim EOF in trailers located very near the interim EOF. The ilouston County _
Emergency Operations Center will be used as an alternate EOF should the onsite E0F become untenable.
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A new EOF complex is under construction and is expected to be completed by October 1982. Upon completion, the functional operations required by NUREG 0696 will be assigned to this_facil_ity. This interim facility does not have the capability for all functions as described in the above reference..The ~ new EOF should satisfy the requirements.of TMI Action Item III. A.1.2 (2.2.2.C) long.
term upgrade of Emergency Response Facilities.
Based on the above findings, this portion of the.
licensee's program appears to be acceptable.
Item 50-348/80-36-09; 50-364/80-48-09, shall-remain open
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until the completion of the new EOF complex.
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_ Post-Accident Sampling and Analysis Post accident sampling and analysis involves coolant samples (4.1.1.5), containment air. samples (4.1.1.6),
gas and particulate effluent samples (4.1.1.7), and liquid effluent samples (4.1.1.8). 'The facilities and equipment available for post accident l sampling and analysis were evaluated against 10CFR50.47(b)(8),
Paragraph IV.E, and selected criteria'in NUREG-0654,Section II.I.
The locations of all of the post-accident sampling areas
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i are accessible during accident conditions and are monitored for high levels of radiation. The design and shielding of the sampling areas and sample lines are
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such that radiation doses received by the user should i
not be excessive.
Remote sampling systems-are established such that personnel need to spend a minimum
amount of time in the higher radiation level areas.
Shielding for liquid sample containers and gas syringes is available for use in obtaining the samples and transporting them to the analysis facility.
If the sample analysis facility is not accessible during
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accident conditions, there are provisions to use an
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alternate facility which is already established or to move enalytical equipment to another location if L
necessa y.
Instruments and detectors for analysis which are described in the procedures are in place' and other
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equipment and tools which are described in the l
procedures are available.
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1 The sampling techniques for the post-accident samples provide for representative samples'
Each sample
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collection and analysis should be able' to be performed within three (3) hours.
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The remote post-accident sampling equipment for chemical and radiological anlaysis of reactor coolant liquid and gas samples satisfies the requirements of ' Item II.B.3 (2.1.8.a) of the TMI Action Plan.
Based on the above findings, -this portion of :the licensee's program appears to be adequate.
4.1.1.9 Offsite Laooratory Facilities
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The offsite laboratory facilities were reviewed with-respect to the. requirements of 10CFR50.47(b)(9),
10CFR50, Appendix E, Paragraph IV.E.2,. and criteria in
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NUREG 0654, Section - II.H.6.c.
APC0 has developed a method for the establishment of the interim Offsite Laboratory Facility to process environmental samples in the event of a radiological emergency. This methodology will be in use until October of 1982 when the licensee will have completed its permanent EOF which will contain complete laboratory facilities for emergency environmental sample processing and data analysis.
If either of the two reactor units goes into a shutdown mode due to emergency conditions the laboratory.
facilities of the other unaffected unit will be utilized as the offsite laboratory, since the FNP Units 1 and.2 each have individual and separate laboratories.
If the environmental conditions require an evacuation of that laboratory, the laboratory equipment can be transported to any one of two alternate and preselected locations nearby:
(1) the Water Analysis Building or (2) the Water Treatment Plant. The licensee estimates that the-laboratory equipment can be moved, calibrated and ready for operation in less than two hours.
All instrumentation is used for normal plant operation and is maintained, calibrated, checked and repaired or replaced regularly.
A mobile laboratory from the University of Georgia can be called to the plant site if mobile capabilities are desired or required in addition to various federal mobile laboratories.
Based on the above findings, this portion of the licensee's program appears to be adequate.
4.1.2 Protective Facilities
4.1.2.1 Assembly / Reassembly Area This area was reviewed with respect to the requirements of 10CFR50.47(b)(10) and specific criteria in NUREG 0654,Section II.J.
The assembly areas for site personnel and visitors are in the Service Building, Auxiliary Building, Turbine Building, Central Security Control (CSC) Building, and at the Temporary Access Point (for construction employees) as identified in EIP-10, Evacuation and Personnel Accountability, and -Section VI.E.1.a.
Evacuation, of the EP.
Visitors on tour of the site shall be immediately escorted to the Switch House by the APC0 tour guide. Visitors on tour inside the Controlled Area shall be escorted to the Service Building Auditorium. There are no offsite assembly areas. When released by the Emergency Director non-essential personnel shall either depart from the site or return to work. APC0 will provide for transportation for persons without vehicles. As indicated in Appendix A of the EP and in EIP-16, Emergency Equipment and Supplies, protective equipment and supplies are located near the assembly areas.
Based on the above findings, this portion of the licensee's program appears to be adequate; however, the following items should be considered for improvement:
Consider the need for alternate assembly areas in case of a ground release affecting the primary areas. (50-348/81-20-02; 50-364/81-23-02)
Identi fy the assembly areas on Figure 1 of FNP-0-EIP-10 and revise accordingly Section 4.2.3.4 of FNP-0-EIP-10. (50-348/81-20-03; 50-364/81-23-03)
4.1.2.2 Medical Treatment Facilities The plans for the handling and care of injured personnel potentially contaminated and/or highly radiated are contained in the EP Part II, Medical Plan and EIP-11, Handling of Injured Personnel. First aid stations are located in the Auxiliary Building near the HP office at elevation 155 and in the Service Building near the maintenance shop at elevation 155. The facilities appeared to be well stocked with supplies and equipment consistent with the EP and EIP-11 and the inventory lists are routinely verified by a HP technician per EIP-16, Emergency Equipment and Supplies. A personnel decontamination facility is adjacent to the HP office that is designated a first aid area for the radiatien controlled area (RCA) in the Auxiliary Building at
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elevation 155.
Emergency dosimetry capabilities and potassium iodine supplies are-available for EP work events.
To meet the commitments to have at least one person on each operating crew of each unit that is qualified to perform first aid the licensee has initiated a program of identifying to the shift supervisor, the first aid qualified person as part of the shift turnover process; FNP-0-EIP-11 will be modified accordingly to be consistent with EP Part I Section VI.B.3.c.
The licensee has also agreed that the overall medical plan program shall be reviewed and approved by a licensed physician as part of the emergency preparedness program.
Based on the above findings, this portion of_the licensee's program apepars to be adequate; however, the following should be considered for improvement:
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Provide a method for identifying to the Shift Supervisor of each unit, the designated first aid qualified person for each operating shift.
(50-348/81-20-04; 50-364/81-23-04)
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Provide a review of the medical program, including supplies and equipment maintained onsite for first aid treatment, by a qualified physician.
(50-348/81-20-05; 50-364/81-23-05)
4.1.2.3 Decontamination Facilities The facilities and equipment available for decontamination were evaluated against the requirements of 10CFR50.47(b)(8),
Paragraph IV.E, and specific criteria in NUREG 0654, Sections II.J. and K.
The onsite personnel decontamination facilities are as described in the EP Part I
Section VI.F.2, Decontamination and First Aid.
The personnel decontamination facility is adjacent to the HP office -in the Auxiliary Building at elevation 155 near the hot machine shop.
Personnel decontamination is conducted per procedure RCP-6 Personnel Decontamination, RCP-7 Area and Material Decontamination, RCP-8 Personnel Monitoring, RCP-10 Radiation Incident Reporting, RCP-26 Radiological Surveys and Monitoring, and RCP-29 Contamination Guidelines.
There are provisions for decontaminating personnel at the Service Building personnel assembly area by use of the inventory in the first aid station near the maintenance area in the
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Service Building. Adequate instrumentation, procedures,
decontamination supplies, and provisions for. proJer waste disposal are available at both facilitien
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Replacement clothing *(coveralls) are available from the
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plant storage area..The:. work areas and supplies were
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inspected and.the procedures were' = reviewed by. the - -
auditor.
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Based on the above findings, this po lon of the licensees program appears to be adequate.
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4.1.3 Expanded Support Facilities
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The licensee has temporary housing for NSSS ~ Vendor and
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refueling personnel in. the trailers located'between the~
f interim E0F and the Switch House.
Up to 18 trailers > ark available.
Several PAX lines (which are also ~1 inked Ea commercial lines) are available in each trailer:: Permar.unt -
facilities will be available in the newrEOF when,it is completed.
Based on the above finding, this portion of the licensee's program appears to be adequate.
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l 4.1.4 News Center
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In accordance with NUREG 0654,Section II.G, APCO' has established a news center at the' Northridge High School in
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Ashford, Alabama. The identified center has sufficient: space for a large number of news media representatives"but has -
inadequate communications at - present.
APC0 is. currently working with Southeastern Bell Telephone-Systikm to provide..
adequate communication for the news center in the-event of a major accident at the Farley Site.
In' addition, there is an
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identified space for news media representatives in the licensee's new EOF now under construction.
The ECF ' is-located onsite and should be adequate for the dissemination of information to the news media in all-but' the mast serious -
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(Class 9) accident situations. The EOF.is projected to be completed by.about April, 1982 and will be. fully operational
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by October,1982.
u Based on the above findings, this portion of the licensee's program appears to be adequate.
4.2 Emergency Equipment
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4.2.1 Assessment
4.2.1.1 Emergency Kits and Emergency Survey Instrumentation-The emergency kits and emergency survey instrumentation were reviewed with respect to the requirements of
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10CFR50.47(b)(8), 10CFR50, Appendix E, Paragraphs'IV B.
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and E. and criteria in NUREG-0654, Sections II H and I.
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The = auditor, ' escorted by a' member of the Chemistry &
Health Physics (C&HP) staff, reviewed the emergency kits-and survey instrumentation.
The kits were found at locations specified in FNP-0-EIP-16.
The contents of
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the kits are inventoried completely on a quarterly basis
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with monthly checks of instrument operation, calibration s
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and battery checks.
A weekly inspection is made to insurefthat the-break-away locks are intact and if any
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are found to be broken, the entire kit is inventoried.
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All emergency kits were found to be fully equipped with the app,ropriate instrumentation calibrated and operable.
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'Upon: review of FNP-0-RCP-25, Appendix 0, it appears that
instrumsntation u' sed for. environmental surveys have the capability to measure radioiodine concentrations in air
~
of 1E-07 pC1/cc and particulate activity in-air of 1E-09
,
uCi/cc when the tests are conducted in a low background
,
J -
area.
-
FNP-0-RCP-216 outlines the use of the Nuclear
- '
'
Measurement Corporation constant air monitor (CAM) and-FNP-0-RCP-255 discusses the use of the Eberline IM 11 CAM for the detection of airborne iodine in the presence
~ t of noble gases.
All emergency instruments were maintained routinelv and calibrated in accordance with the appropriate written procedures.
. Based on.the above findings, this portion of the
,
licensee's program appears to be adequate.
4.2.1.2
. Area and Process Radiation Monitors The area and process radiation monitors were reviewed with respect to the requirements of 10CFR50.47(b)(9),
,
10CFR50, Appendix E, Paragraphs IV B. and E. 2.,.and criteria in NUREG-0654, Section'II H.
The FSAR and Tcchnical Specifications describe the fixed radiation' area and process monitors used at the FNP.
The description and location, name, type, range, and number of monitors are also covered in the Emergency Plan, FNP-2-RCP-252 and FNP-1-RCP-252.
The' design characteristics referenced in
"U" manual Nos. U264698 through U278181 define the temperature, relative humidity, pre 3sure and radiation background conditions of the conta!nment monitors. Direct readout capability in the control room for all monitors, except for R30 thrcugh R34 and the Spring-4 System is also defined.
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on the monitors at specific locations. The control room had only monitor alarm and indicators for these specific
,
units. The readouts would be accessible under accident w
conditions but there is the possibility that to obtain y
the. readings, one might receive additional exposure.
FNP-0-RCP-732 described the plant vent stack monitoring system (Sping-4). Readouts for the Sping-4 System are E
~
available from the counting room and can be obtained from the control' room panel for the system.
,
The technical specifications provide for out-of-service,
~
functional checks and calibration requirements.for.the area and process monitors. _The calibrations are conducted by the licensee in accordance with RCP procedures and by' the manufacturer when the requirements are outside the licensee's capabilities (i.e., _- high range containment monitor). Calibrations are performed across the entire response range.
'
The detectors of the monitors were located so that their readouts would accurately reflect their intended use.
~
The. efficiencies are known such that readouts can be converted to source term units. (pCf/ml). The Sping-4
',
System which monitors the vent stack.for iodine, particulates and noble gas reads out directly in units of activity concentration.
Both reactor units have
- -
locations and types of common monitors such that equal accessibility to readouts is achieved.
The auditors reviewed records which indicated that the
'
monitors were properly maintained on a routine schedule, with adequate operability and calibration checks being.
performed.. Calibration procedures for these-monitors are included in the FNP RCP Piocedures (except R-27A and B).
If there is a failure of power supplied to these instruments, there is an automatic transfer of power f rom the non-vital to the essential power board.
If this power system fails, a manual switch can convert these monitors-to power from the diesel generators.
Gaseous effluent monitors and containment high range-monitors were determined to meet requirements ' of TMI Action Plan Item II.F.1 (2.1.8.b)- and requirements of-NUREG-0737.
Based on the above findings, this portion of the licensee's program appears to be adequate.
4.2.1.3 Non-Radiation Process Monitors
-
_ _ _ _ -....
..
-
-
The non-radiation process monitors described in the Emergency Plan Part I Section V.C as being necessary for emergency detection, classification, and assessment (such as, reactor coolant system pressure and temperature, liquid levels, containment pressure and -
temperature, flow rates, fire detection and meteorology instrumentation) had readouts in the control room and were operable.
The seismic monitor had an annunciator in the control room with the monitor equipment located in the instrument' work area adjacent to the Unit 1 control room. The seismic monitors are as described in the FSAR Section 3.7.4.
The auditor reviewed the FSAR and the Surveillance Test Procedures FNP-0-STP-254.1, 254.2, 254.3 and 254.4, and observed the changing of the accelerograph triaxial record plates for e seismic monito.- in the Auxiliary Building at elevation 83.
The auditor also reviewed the technical specifications for the remote shutdown instrumentation surveillance requirements and observed representative instrumenta-tion at the emergency remote shutdown panels for Units _1 and 2 at elevation 121 in the Auxiliary Building.
Based on the above findings, this portion of the licensee's program appears to be adequate.
4.2.1.4 Meteorological Instrumentation The bases for the auditor's review of the licensee's meterological-measurements program included Regulatory Guides 1.23 and 1.97, and the critreia set forth in NUREGS-0654, 0696, and 0737.
The licensee provided a-brief description of the meterological measurements program in Section C.1 of the Emergency Plan.
The integration of the meterological data into the licensee's dose assessment scheme was described in EIP-9.
The auditors reviewed the licensee's procedures for maintaini19 the meterological measurements program as outlined in STP. 255.1.
The auditors -determined that the licensee's meteorological capabilities address the requirements of NUREG-0737, TAP III. A.2 and the criteria set forth in Appendix 2 to NUREG-0654, Rev. 1 in _ adopting the compensating measures to milestone 3.
Instrumentation on the Farley meteoroingical tower provides the basic parameters necessary to perform the dose assessment function. Strip chart records for these data are located at the meteorological station near the tower and in the control room serving Units 1 and 2.
Digitized records are also available on the plant HP
.
9825A calculator system for distribution to other emergency response facilities as an alternate means of reviewing data.
The data can be transmitted to offsite authorities through ringdown telephones, dedicated telephones, radio and the state and local agency emergency notification network. In the event the meteorological system becomes inoperable, the licensee has made provisions for access to appropriate data from an alternate service (DOTHAN - NWS Station) to provide necessary parameters characteristic of site conditions.
The licensee's preventative maintenance (PM) activities consists of a multi-tiered operational program. The-control room staff reviews the operation of recorders on a daily basis.
The C&HP Staff performs a full system calibration on a frequency that exceeds equipment specifications.
This level of a PM program, in conjunction with ongoing technical evaluation of the data, makes detection of inoperable equipment highly likely with prompt restoration of service.
The licensee's methodology for assessing offsite dose consequence considers the transport and diffusion of potential effluents in the site environment to the plume exposure emergency planning zones in an adequate manner.
The site is located in gently rolling terrain with no significant terrain features that should result in anomalous flow conditions.
Based on the above findings, it appears that this portion of the licensee's program is adequate.
4.2.2 Protective Equipment 4.2.2.1 Respiratory Protection Self contained breathing apparatus (SCBA) devices are available in the control room and in the HP office area adjacent to the OSC (at least 8 and 10 respectively).
Many (~30) air container refills are also available in the HP office area. These refills are filled with air from larger air tanks brought in by offsite vendors.
Based on the above findings, this portion of the licensee's program appears to be adequate.
4.2.2.2 Protective Clothing There are adequate bulk stores of protective clothing in a warehouse complex located about a mile from the plant (estimated for about 1,000 clothing changes).
Other smaller quan+ities of clothing are located in the HP
.. _.,
._.
- -
_ office area, the radiation control center and -in the many emergency supply cabinets (~30).
Based en the above findings, this portion of-the licensee's program appears to_ be adequate.
4.2.3 Emergency Communications Equipment This area was reviewed with respect to the requirements of 10CFR50.47(b)(6),10CFR50, Appendix E, Paragraph IV.E, and specific criteria in NUREG 0654,Section II.F.
The licensee has many separate communications systems:
commerical telephones; plant alarm and PA systems; APC0 Divisional radio system; Houston County Sheriff's radio system; and Farley plant radio system.
The NRC Health Physics Network (HPN) is to be connected to the Control Room, the NRC Resident Inspector's office, and the HP Supervisors office.
This system is not yet complete.
(See Section 4.1.1.2 of this report).
There is a single alarm system having the speci_fic meaning to request that all personnel report to assigned posts or assembly areas.
Where the aural alarm was not audible, visual alarms are provided.
This alarm notification is followed with specific instructions via the public address system. This system was tested during this visit.
Each of the key communications networks is to have a backup system and a redundant power source.
The offsite public. notification system (PNS) was reviewed during this inspection.
The system con'sists' of sirens and NOAA weather alert radios. APC0 has purchased a. transmitter which is located on the Farley site and is activated by NOAA
,
l from Montgomery. Procedures and pre-recorded tapes have been F
provided to NOAA in Montgomery. One tape is for daytime use and identifies radio and television stations which will provide information concerning the emergency; a second tape-is for night use since there are no 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> radio or
,
television stations serving the Georgia sector of the 10 mile
EPZ.
The night tape advises Georgia residents to tune in Alabama radio stations for information. Sirens are used for the communities of Gordon, Ashfcrd and Columbia. The entire system is in place and is functional; however, an integrated
- -
test of the system has not been demonstrated.
Provisions have been made for repair / replacement of radios which fail to function during the weekly test.
The overall system is i
planned to be tested during the exercise in November and will be declared operational on November 1,1981 following a media and public information campaign. As noted above, the entire.
system was in place and could be used in an emergency prior t
to the official operational date. A verification program was
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.23 not in place.at _the time of this appraisal. A program was being considered and will consist of either direct mailings
~
to individuals requesting a response or telephone contact with a representative-sampling of the population to insure coverage of the notification system.
Based on the above findings, this portion of the licensee's program appears to be adequate.
4.2.4 Damage. Control / Corrective. Action and Maintenance Equipment and Supplies Specific needs for onsite damage control, corrective action, and maintenance equipment and supplies were n'ot identified in the Emergency Plan. However, as stated in Section II.C.2.c of the EP, APC0 is a participating member of the Institute of Nuclear Power Plant Operations (INPO). As such, APC0 will have available upon request technical expertise from INP0.
INP0 will provide assistance in locating and arranging additional emergency manpower, equipment and the services -
of various technical experts from industry sources.
As stated in Section II.C.2.d of.the _ EP, maintenance assistance in the area of maintenance and ~ repair is made available through contracts with Davcon, Inc. and Daniel.
~
Construction Company of Alabama.
As stated in Section II.C.2.e of the EP, radiological monitoring assistance will be augmented by outside vendors as necessary through contracts with Rad Services, Inc., Applied Radiological Controls, Inc., and Nuclear Support Services, Inc.
The auditor discussed the subject with the Itcensee's staff and reviewed the administrative procedure FNP-0-AP-52, Equipment Status Control and Maintenance Authorizatio'n.
Based on the above findings, this portion of the licensee's program appeared to be acceptable.
4.2.5 Reserve Emergency Supplies and Equipment For an emergency APC0 relies on the normal inventory of supplies (e.g.
survey instruments, protective clothing, respirators) to support augmented emergency operations. The-auditor reviewed EIP-16, Emergency Equipment and Supplies and FNP-0-AP-23, Handling, Storage and Shipping of Materials, Components and-Equipment, ~ discussed the subject with the Emergen.cy Planning Coordinator and the -Maintenance Superintendent,- and toured representative areas of the storeroom in the Service Building and the warehouse used for storing protective clothing and emergency supplies.
A computerized inventory system is currently being implemented.
The computer system _will include the control of supplies and equipment used to support emergency operations. Controls to insure a minimum of reserve supplies are currently included in
.
FNP-0-AP-21, Identification and Control of Materials, Parts and Components.
Periodic verification of the inventory of supplies and equipment is included in the routine QA program.
Although APC0 does not rely on equipment and instruments from other sources, such equipment and supplies are available through INPO, from regional warehouses of the supply contractors, and from nearby utilities with nuclear facilities.
Based on the above findings, this portion of the licensee's program appears to be adequate.
4.2.6 Transportation A number of automobiles and trucks are available onsite for the use of the production (operations) and construction departments of APC0 during normal and emergency conditions.
The C & HP staff has been assigned a four wheel drive truck and _two cars that are available for HP offsite monitoring teams or other EP team transportation needs. As stated in the EP, Part I Section VI. F. 3, a plant emergency vehicle is available for first aid and medical needs and ambularice --
services are available from the Ambulance Service Company Dothan, Alabama. The onsite maintenance department has four wheel drive trucks with trailer hitches which are capable of moving emergency equipment.
Based on the above findings, this portion of the licensee's program appears to be adequate.
5.0 Emergency Implementing Procedures 5.1 General Content and Format The EIP's, which were developed in accordance with FNP Technical Specifications 6.5.1.6 and 6.8.1 were reviewed to determine that there was a procedure to effectively implement each section of the Emergency Plan and that each procedure contained sufficient information and was in a format that provided clear guidance to the emergency organization.
The FNP EIP's were found to be adequate to implement the EP and were determined to provide sufficient information concerning responsibilities, authority and sequential actions to be taken so that the overall response of the emergency organization was orchestrated.
The procedures included appropriate references to other plant procedures needed to supplement the action required and when appropriate check-off lists were included.
Based on the above findings, this Wrtion of the licensee's program appears to be adequate.
5.2 Emergency, Alarm and Abnormal Occurrence Procedures
At'FNP procedures related to alarms and abnormal occurrences have been developed and include Abnormal Operating Procedures (AOP), Annunciator Response Procedures (ARP) and Emergency Operating Procedures (EOP).
These procedures were reviewed to determine that appropriate' references were made to the Emergency Plan Implementing Procedures (EIP) so that an emergency condition defined by.the Emergency Action Level.(EAL)
statements in the Emergency Plan are promptly recognized. _The Abnormal
.
Occurrences Procedures were found to' include references to the EIP in those procedures related to emergency action levels in the Emergency Plan.
Based on the above findings, this portion of the licensee's program.
appears to be adequate.
5.3 Implementing Instructions Implementing instructions have not been utilized at FNP to provide guidance and assign responsibilities for the emergency organization.
Emergency classifications, action levels and assignment of responsibility.are. included in the Emergency' Plan Implementing-Procedures which are discussed in paragraph 5.4 of this report.
i 5.4 Implementing Procedures
,
5.4.1 Notifications Notification procedures were reviewed against the requirements of 10CFRa50.47(b)(5), 10CFR50, Appendix E,
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Paragraph IV.D and specific criteria in NUREG 0654, Section
II.D.
i The classification of an emergency-is done by the Shift Supervisor according to EIP-2. and EIP-9.
.Upon deciding which emergency action level applies, the Shift Supervisor
,
j advances to the appropriate implementing procedure for notification instructions.
,
i The sequence of notifications for Notification of' Unusual Event, Alert, Site Emergency and General Emergency 'are
'
specified in EIP-17, 12, 18 and 19, respectively.
The
notifications in all cases are initiated by the Shift l
Supervisor until relieved by the Plant Manager or one of his i
alternates. The equipment to be used in the notification, such as ring-down phones'and pagers, are specified. Planned
!
messages, announcements, and. alarms are used for the initial notifications. Telephone numbers are listed in a call sheet in EIP-8.
The responsibilities of plant officials in notifying offsite authorities concerning various events are provided in EIP-26.
Inplant notification of emergencies are by the plant alarm system, which includes both a stren and blue strobe lights
located in high noise areas.
This system was upgraded in response to IE Bulletin 79-18. Item 79-BU-18 is closed.
Based on the above findings, this portion of the licensee's program appears to be ade.1uate.
5.4.2 Assessment Actiens The licensee's' procedures for assessing the radiological consequences of an accident were reviewed with respect to the requirements of 10CFR50.47(b)(9), IJCFR50, Appendix E,
Paragraph IV.B, and specific criteria in NUREG 0654,Section II.I.
At FNP radiological accident assessment is performed by the interim Emergency Director initially, and by the Technical Support Center staff following the activation and staffing of that facility. Release concentrations and offsite equivalent dose calculations are performed in accordance with EIP-9 utilizing parameters from the meteorological system and monitors on release pathways. High range monitors have been installed on the stack which have readouts in activity concentration.
Other release pathways are also monitored (See Section 4.2.1.2).
The procedure for offsite equivalent.
dose evaluation uses a gaussion plume dispersion model and the procedure includes overlap for plume distribution in a variety of meteorological conditions to assist the Emergency Director in characterizing plume dimensions in the environment.
Dose projections are verified by offsite monitoring teams and monitoring results are integrated into the overall accident assessment scheme.
Based on the above findings, this portion of the licensee's program appears to be adequate.
5.4.2.1-5.4.2.3 Emergency Radiological Surveys The emergency radiological survey procedures were reviewed against the requirements of 10CFR50.47(b)(9),
Paragraph IV. E and specific criteria in NUREG-0654,Section II.I.
Emergency radiological surveys are taken in plant (5.4.2.3) onsite (out-of plant) (5.4.2.2), and offsite (5.4.2.1).
These surveys include direct radiation readings and the collection of gas, particulate, and iodine samples.
FNP-0-EIP-4 (Chemistry and Health Physics Support to the Emergency Plan) provides for the establishment of radiation monitoring teams which would be responsible for performing these survey.
.
.
For radiation monitoring team members performing l
environmental surveys onsite and offsite, there exists a checklist outlining their duties. These personnel are instructed to obtain an emergency kit from the CSC building and necessary monitoring equipment for.
environmental surveys. Offsite monitoring team members are to verify the operation of the vehicle's two-way radio prior to leaving the. site and if the radio is non-operational or if the vehicle is not equipped with a radio, an operable transceiver is to be picked up from
,
the primary access point (PAP).
Maps with pre-designated sampling locations are included in the
'
emergency kit for the offsite survey teams.
Site maps are also included in the emergency kit for onsite surveys.
In plant. survey teams are directed to " perform radiological surveys as directed" and out-of plant. teams are directed to " perform a direct radiation,. air -
particulate, and radioiodine surveys in areas designated by the Emergency Director or HP Manager." However, the procedure does not discuss specific methods to. use.
during these surveys or refer to other procedures which
discuss the necessary methods.
For the offsite team, the procedure does not give specifics on performing direct radiation measurements during travel from the plant to the predesignatd location or on performing plume ~ monitoring after arrival at the location.
.
All teams are instructed to document the data but little guidance is given as to what parameters are important and should be recorded. Out-of plant teams are directed to use logbooks.
Instructions are stated for - the out-of plant teams to label their samples with the i
sample time, flow rates, location, and date; however, the procedure gives no guidance to the in plant team.
All teams are to relay pertinent data to the TSC.
All samples are to be brought to the counting facility
'
for analysis, or further analysis if necessary, and that data is to be recorded in logbooks.
Radiation protection guidance is given for radiation team members. Use of protective clothing is specified
and high range dosimeters (0-25R) are available if i
necessary.
An engineering study has been performed which estimates the exposure rate levels at different locations in the plant for a " worst case condition."
These estimates are listed on plant diagrams which are available for survey team members.
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Based on the above findings, this portion of the licensee's program arpears to be adequate; however, the following items should be considered for improvement:
In FNP-0-EIP-4, expand the discussion on survey
.
methods to be used or refer to specific procedures which discuss the survey _
methods.
(50-348/81-20-06;50-364/81-23-06)
Include data. sneets in emergency kits used. for
.
surveys or give more guidance to. team members on important parameters to be recorded.
(50-348/81-20-07; 50-364/81-23-07)
5.4.2.4-5.4. 2.11 Post-Accident Sampling and Analysis The interim post-accident sampling and analysis procedures were reviewed by the a' ditors and evaluated i
'during walk-throughs to determine,srsonnel familiarity with the procedures and procedural applicability. These procedures were evaluated' against the requirements of:
Paragraph IV.E and selected criteria in NUREG-0654,Section II.I.
FNP-0-RCP-25 Chemistry and Health Physics Activities During a Radiological Accident (Short Term) contains procedures for post-accident sampling.
Appendix A.
discussed the saiapling of radiological streams -while Appendix E contains informa, tion on preparation. of reactor coolant samples for radiological and chemical analysis. Appendix B refers to sampling of effluent -
streams and Appendix F discusses sample preparation and spectrum analysis of' particulate and iodine filters during a radiological accident. Appendix H discusses chemical analysis _during a radiological accident.
Appendices C and D discuss the relocation of chemical and radiochemical capabilities during a radiological accident, respectively..No. emergency procedures for liquid effluent sampling exist; normal procedures are discussed. in FNP-0-RCP-372.
Special procedures for analyzing the post-accident samples are discussed in FNP-0-RCP-25.
All sampling procedures provide detailed. instructions for the operation of the necessary emergency equipment.
The sampling point locations are clearly described and the procedures address the sampling media and special equipment to be esed.
Provisions exist to limit exposure to sampling personnel and verify the habitability of the. areas occupied by the
,
i sampling personnel. Each sampling team will consist of l
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a HP technician and a chemistry. technician; it is.the responsibility of the HP technician to ensure that areas are safe to enter and that excessive exposures won't be received. Samples will be transported to the q
analysis area using appropriate shielding and under surveillance of a HP technician.
FNP-0-RCP-25 discusses the labeling ~ of.
all post-accident samples.
Logbooks are to be used to record data and observations; guidance is given in
-
FNP-0-RCP-25 for some, not all, samples as to what data is important
,be recorded.
After ' review'.g the proper procedures and conducting walk-throughs with the appropriate personnel, it is the auditor's opinion that each post-accident sample could be obtained in one hour or less.
$
Normal counting procedures are discussed in FNP-0-RCP-183; most. of the normal procedures and equipment will be used when counting high level samples (e.g.
analytical equipment, software, precautions, etc.).
Dilution _of gas and liquid samples is
.
established in the post-accident sampling procedures.
"
Appendix F discusses procedures for filter and iodine sample preparation for - high level samples.
The';
j emergency procedures state that the counting geometry of the samples can be changed to attempt to achieve a
'
counting deadtime of less than 30%. It is recognized,by
licens,ee representatives that using a deadtime of this magnitude will produce counting errors; however, the l
licensee feels that the level of accuracy allowed by NUREG-0737 (a factor of 2) for emergency samples can still be obtained with this deadtime.
FNP-0-RCP-25, Appendices C and D discuss moving necessary analytical equipment to an alternate site if the analytical areas have a high background or are not. accessible.
'
Data is analyzed using a desktop -computer interfaced with the counting equipment and employing appropriate
.
software. The analytical methods should achieve the desired ends and the radiochemical analyses should be able to be completed in two hours.
' Disposition 'of coolant samples after analysis is discussed in FNP-0-RCP-25; however, no - speci f.ic
.
instructions regarding the disposition of filter or iodine samples after analysis could be found.
The licensee stated that -high activity - samples would be handled by HP personnel.
Based on the.above findings, this portion of the licensee's program appears.to be adequat.
-
. - _ -
,
- 5.4.2.12 Radiological and Environmental Monitoring Program The Radiological and Environmental Monitoring Program was reviewed _ with respect to the-requirement of 10CFR50.47(b)(9),10CFR50, Appendix E, Paragraph IV.E, and criteria in NUREG-0654 and NUREG-0737.
The licensee has. provisions ' for a radiological and environmental monitoring program to be implemented during emergencies.
FNP-0-EIP-4 authorizes plant monitoring in-plant, on site, and off site.
Offsite teams will be' assigned to make measurements;of plume passage, offsite measurements and collection _of, TLD's. No direct assignments have been made to collect.
soil samples, water samples, vegetation samples, etc.;
however, FNP-0-EIP-4 does allow the latitude to do so if it is deemed necessary. Assignments have been made for collection and evaluation of_ air sample data as well as
data computations of readings made by offsite-field monitoring teams.
The licensee has a management coordinated structure for i.
emergency environmental monitoring as discussed in.
i FNP-0-EIP-8. APC0 also is capable of conducting the
emergency monitoring program with emergency laboratory procedures as discussed in 4.1.1.9.
Power for this laboratary in its current location and
,
for each subsequent alternate location in the event of a power failure is from the non-vital to the essential
'
,
"
power board.
If this power system fails, a manual
switch can convert power from the diesel generators.
!.
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Based on the above findings, this portion of the licensee's program appears to be adequate.
5.4.3 Protecuon Actions
5.4.3.1 Radiation Protection During Emergencies
,
'
Radiation protection during emergencies was evaluated
-
against the requirements of 10CFR50.47(b)(11), and selected criteria in NUREG-0654,Section II.K.
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There is not -- an overall procedure governing; the implementation of the radiation protection program
'
during emergencies.
Emergency radiation protection procedures are referred to in other emergency procedures
!
and the emergency plan. Personnel dosimetry, exposure records, and positive access controls during emergencies are discussed in EIP's or the emergency plan. Emergency workers will receive instructions on radiological
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conditions.
Re-entry personnel are. instructed that if emergency dose rates encountered during re-entry exceed limits established by the Emergency Director, the re-entry personnel should return to a safe area and contact the Emergency Director for further instruction.
The present respiratory protection program can handle normal operations plus emergency needs; refer to section 4.2.2.1 for details.
Provisions for expanded decontamination capabilities in the event of an accident are established; refer to section.4.1.2.3 for details.
Provisions for refilling air bottles exist.
Changing and usual conditions are considered in the structuring of the emergency radiation protection program.
An engineering study has been performed to estimate possible exposure rates in specific areas in plant for a
" worst case" accident. This information is recorded on plant plans for use by in plant radiation monitoring teams, recovery, repair, and re-entry teams.
Procedures exist that describe how and by whom all health physics functions will be performed and
,i priorities of specific functions during emergency situations are discussed.
These functions include access control (FNP-0-EIP-4, EIP-10, and EIP-14),
in plant surveys (FNP-C-RCP-25), dosimetry (FNP-0-EIP-4 EIP-13, and EIP-14), decontamination FNP-0-EIP-4, EIP-11, and EIP-13),
general exposure control ( FNP-0-EI P-4, EIP-10, and EIP-11), and high level sampling (FNP-0-RCP-25 and FNP-0-EIP-4).
Based on the above findings, this portion of the licensee's program appears to be adequate.
5.4.3.2 Evacuation of Owner Controlled Areas Evacuation of owner controlled areas is initiated for each occurrence of a site evacuation as required for all Site and General Emergencies and in some cases for an Alert.
FNP-0-EIP-10, Evacuation and Personnel Accountability, and FNP-0-EIP-7, Security Support to the
'
Emergency Plan, provide for the implementation of the commitments made in the EP Part I, Sections VI.E.1.a and VI.E.1.e.
The public address system for the plant is used to notify the personnel to evacuate the affected I
areas. To notify the personnel working in the warehouse and construction -work areas (principally Daniel Construction Company employees) the shift supervisor or j
emergency director has to activate a separate public l
I
_ _ _ _ _ _ _
address switch. Activation of this switch is not noted in EIP-10.
Securit.y support to evacuations are deliniated in EIP-7.
EIP-7 does not include a requirement to have one or more motorized patrols with a public address system for each vehicle touring the roads within the owner controlled area and the river front area to inform all personnel outside of the area covered by the fixed position, station public address system and persons on the river.
Security support also provides transportation of "found" personnel to the Switch House.
Security support currently performs the above functions, but EIP-7 needs to be changed to assure routine performance of the above work.
APC0 does not have signs marking the primary and secondary evacuation routes as marked on figure 11 of the EP; however, the personnel have exhibited a knowledge of location of the evacuation routes and the assembly areas during the past EP drills and exercises.
'
The need to identify the assembly areas has been noted in paragraph 4.1.2 of the report.
Based on the above findings, this portion of the licensee's program appears to be adequate; however, the following items should be considered for improvement:
Modify FNP-0-EIP-7 to require Security to activate motorized patrols with public address systems to tour the roads within the owner controlled area and the river front road to inform all personnel outside the areas covered by the fixed position public address systems of the need to evacuate and to provide, or assure, transportation of "found" personnel to the Switch House. (50-348/81-20-08; 50-364/81-23-08)
5.4.3.3 Personnel Accountability The procedures for personnel accountability was reviewed for the requirements of 10CFR50.47(b)(10), 10 CFR Appendix E Paragraph IV.B, and the criteria of NUREG-0654 Section II.J.
Upon hearing the Plant Emergency Alarm, a variable tone alarm, all persons report to their pre-assigned assembly areas.
The following locations are designated as assembly areas; Service Building auditorium and maintenance shop; Switch House; and the plant road immediately east of the Daniel Construction Company Office complex.
Each supervisor accounts for personnel in his group and reports the results to the senior individual at the
assembly area.
Within the protected area, the accountability report is made immediately after the number of missing personnel are determined; this is in coordination with the senior plant guard in the Primary and Temporary Access Points. Accountability is reported to the Emergency Director by the senior plant guard. A similar operation occurs within the controlled area and results in a report to the Emergency Director.
The reports are not delayed as a result of trying to locate the missing personnel.
Details are provided in FNP-0-EIP-10 and FNP-0-EIP-14.
Based on the above findings, this portion of the licensee's program appears to be adequate.
5.4.3.4 Personnel Monitoring and Decontamination Procedures for personnel monitoring and decontamination were reviewed against the requirements of 10CFR50, Appendix E,
Paragraph IV.E and the criteria of NUREG-0654, Sections II.J and II.K.
Personnel monitoring and decontamination is the responsibility of the C&HP group and during an emergency the responsibility of the Radiation Monitoring Team as stated in the Emergency Plan Section IV.B.4.
Procedures for personnel monitoring are contained in FNP-0-RCP-8 Personnel Monitoring, and for contamination, FNP-0-RCP-6 Personnel Decontamination.
These and other related procedures discussed in parsgraph 4.1.2.3 provide for monitoring individuals leaving restricted areas and at assembly areas, documenting the findings, guidance and procedures relative to decontamination levels and actions and responsibilities.
EIP-4 also provides direction and guidance relative to emergency-organization responsibilities and radiation protection program activities.
Based on the above findings, this portion of the licensee's program appears to be adequate.
5.4.3.5 Onsite First Aid / Rescue Procedures for onsite first aid and rescue were reviewed against the requirements of 10CFR50, Appendix E,
Paragraph IV.E and the criteria of NUREG-0654, Sections II.K and II.L.
The plans for handling and care for first aid and rescue care of injured personnel are as stated in the Emergency Plan Part II, Medical Plan, and FNP-0-EIP-11 Handling of Injured Personnel. The related facilities are as stated in section 4.1.2.2 of this report. The procedures cover
the methods for receiving, recovering and handling injured persons who may &lso be contaminated.
The Medical Plan and FNP-0-EIP-11 describe the interface and criteria for using the offsite medical facility. A HP trained person is assigned to the first aid team to provide radiation protection guidance.
Based on the above findings, this portion of the licensee's program appears to be adequate.
5.4.4 Security During Emergencies Procedures for security support during emergencies were reviewed for the requirements of 10CFR50.47(a) and (b),
10CFR50 Appendix E, Paragraph IV.A and criteria in NUREG-0654 Section II.A.
Security measures to be placed in effect during emergencies are specified in the FNP-0-EIP-7.
Security personnel are relied upon to perform certain predetermined actions.
These include maintaining plant security, assisting in personnel accountability, providing escort service for offsite emergency personnel and vehicles to facilitate their expeditious access at the emergency scene, and assisting in the evacuation of buildings. These procedures were developed in accordance with the requirement of 10CFR Part 73.
Based on the above findings, this portion of the licensee's program appears to be adequate.
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5.4.5 Repair / Corrective Actions Repair / Corrective Actions were reviewed for the criteria of NUREG-0654 Section II.K. Procedure FNP-0-EIP-14 provides the guidelines for re-entry into the plant areas to:
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Ascertain personnel evacuation.
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Rescue trapped or injured personnel.
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Determine extent of damage.
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Perform actions which are required to eliminate a source or potential source representing a hazard to the general public or to prevent a substantial loss in property.
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Assess radiological and or other hazardous conditions in order to establish definite personnel exclusion area boundaries.
The Emergency Director or the Shift Supervisor is responsible for selecting and authorizing qualified personnel for re-entry and the assignment of a team leader. Exposure limits are set with the aid of health physics personne..
Based on the above findings, this portion of the licensee's program appears to be adequate.
5.4.6 Recovery Recovery procedures were reviewed for the requirements of 10CFR50.47(b)(13),10CFR Appendix E, Paragraph IV.H. and the-criteria of NUREG-0654 Section II.M.
FNP-0-EIP-20 provides the means for the Recovery Manager to notify the Plant Manager and the company management that a decision has been reached to initiate a recovery operation. This information is provided to the NRC, and State and Local authorities as well as any changes to the structure of the recovery organization.
FNP-0-EIP-14 designates. the Emergency Director as the authority. to authorize re-entry.
FNP-0-EIP-20 and EIP-28 include guidance for effectively using _ resources to provide for the limitation and management of radiation exposures.
Specific criteria and procedures will be developed when required, considering maximum protection for plant personnel i
and the general. public.
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Based on the above findings, this portion of the licensee's
program appears to be adequate.
5.5 Supplementary Procedures 5.5.1 Inventory, Operational Checks 'and Calibration of Emergency Equipment, Facilities and Supplies This portion of the licensee's emergency response program was reviewed with respect to the requirements of 10CFR50.47(b)(8),
10CFR50, Appendix E, Paragraphs IV E. and G., and criteria in
FNP-0-EIP-16 lists all-emergency kits and equipment as well as specifying the location of that equipment.
Reviews of the
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procedures accompanied by a comprehensive audit of this equipment indicated that the inventory portion of the system was functioning as designed.
The review of records on functional checks, calibration, and inventory audits showed that the instruments, equipment, and other emergency supplies are checked and replaced in accordance with established requirements.
One chemistry-health physics technician is assigned the responsibility for the performance of the emergency equipment -
readiness checks and for assuring that noted deficiencies are corrected as discussed in 4.2.1.1.
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The licensee's records indicate that the plant emergency vehicle is tested for operability each week, is maintained full of gasoline, and kept in a dedicated state of readiness.
An emergency survey vehicle is used on a daily basis for various sample collections.
The present survey vehicle is scheduled for replacement with a new vehicle already ordered.
Based on the above findings, this portion of the licensee's programs appears to be adequate.
5.5.2 Drills and Exercises The licensee's program for drills and exercises was reviewed with respect to the requirements of 10CFR50.47(b)(II),
Paragraph IV.F.
and criteria in NUREG-0654,Section II N.
Plant exercises and drills are administered in accordance with FNP-0-EIP-15 by the Emergency Planning Coordinator and in accordance with a scenario developed in advance of the exercise. Documentation and evaluation of all observer and participant comments are collected in a critique after the exercise drill and responsibilities are assigned by management to assure that corrective actions are implemented.
Rotation of shift work allows for all plant personnel to become involved in drills and exercises.
Health Physics Drills are conducted on a semi-annual basis.
Fire Drills are currently conducted on an annual basis, but the licensee plans are to adjust this schedule to a quarterly basis. Medical Drills and Radiological Monitoring Drills are also conducted on an annual basis while Communication Drills are held on a quarterly basis.
The licensee is now in the process of up grading the documentation of drills and increasing the frequency of Communications Drills to a monthly basis.
If an actual event occurs, the response to that is not counted as a drill.
The news media is not normally incorporated into drills, but are invited to participate in all exercises. Members of the news media are invited to visit the FNP on a quarterly basis for briefings on plant activities and information updates.
When drills or exercises are conducted there are basically two classes of plant employees that do not become involved as players:
(1) Plant personnel necessary to keep the plant operational; (2) Personnel who function as drill / exercise monitors or observers.
Based on the above findings, this portion of the Licensee's Program appears to be adequte.
5.5.3 Review, Revision, and Distribution
The review, revision, and distribution of the emergency plan and implementing procedures were reviewed against requirements of 10CFR50.47(b)(16), 10CFREO, Appendix E, Paragraph IV G., and selected criteria of NUREG-0654, Section II-P.
Procedures which implement the emergency plan are reviewed at least once each year; the Safety Audit and Engineering Review section is responsible for this review.
Changes resulting from drills or facility changes are to be incorporated into the procedures.
Telephone numbers are reviewed at least every quarter.
The plan and procedures had been reviewed, approved and updated as required.
Changes had been distributed in accordance with the approved distribution list.
It was observed by the auditors that some of the procedures which were changed very recently were yet to be distributed.
A random selection of the names, titles, and phone numbers in the implementing procedures were found to be correct.
Based on the above findings, this portion of the licensee's program appears to be adequate.
5.5.4 Audit The audit program was reviewed against requirements of 10CFR50.54(t), 10CFR50, Appendix E, Paragraph IV (G), and selected criteria in NUREG-0654,Section II.P.
The emergency plan and procedures which implement the emergency plan is audited at least once every 12 months by the Safety Audit and Engineering Review section as indicated in Part 1,Section VII. C of the Emergency Plan. The audit involves a review of the emergency plan against criteria in NUREG-0654, inspections of equipment to document its calibration and operability, and discussion with plant personnel. A formalized tracking system is established to ensure that weaknesse are corrected within a specific time period.
The audit section requires that drills and exercises are performed within the required time periods, that they are observed by training personnel, and that significant comments regarding the drills and exercises are addressed.
Based on the above findings, this portion of the licensee's program appears to be adequate.
6.0 Coordination with Offsite Groups 6.1 Offsite Agencies
The area of offsite support agencies was reviewed with respect to the requirements of 10CFR50.47(b)(3) and (12), 10CFR50, Appendix E,
ParagrapF U 2, and specific criteria in NUREG 0654,Section II.L.
i The auditor discussed offsite support egencies with licensee representatives and reviewed support agreement letters contained in Appendix E of the Emergency Plan. Agreements have been concluded with
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various offsite groups to provide assistance in an emergency and the letters of agreement were current. Training has been provided for all offsite support groups who may be called on to assist in an emergency.
In general, all offsite groups responding to the site-will be accompanied by Public Safety Officers while inside the protected area boundary.
On September 30, 1081, the inspector and licensee representatives i
visited the Southern Alabama Medical Center; Pilcher's Ambulance Service Company in Dothan, the Dothan Fire Department and the Houston County Civil Defense-Office to discuss emergency - response to an
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accident at Farley with representatives of those agencies.
The individuals contacted at each of the above agencies were cognizant of their expected role.in an emergency at the Farley site,.had'been provided training relative to their respective roles, and were satisfied that adequate communications concerning emergency response between their organizations and APC0 have been provided.
Based on the above findings, this portion of the licensee's program-appears to be adequate.
6.2 General Public
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Information to be provided to the public in the event of an emergency.
at the Farley Plant was reviewed with respect to the requirements of 10CFR50.47(b)(7), 10CFR50, Appendix E, Paragraph IV.D and specific criteria in NUREG-0654.
Alabama Power Company has implemented a program for public information in conjunction with the distribution of tone alert radios to households within the 10 mile EPZ. These radios were distributed by personnel on a house-to-house basis. Both written and verbal information on the.use of the radios during an emergency at the Farley Plant was provided to
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the recipients.
The distribution of the radios has been followed up with news articles on public information in an emergency.
APC0 committed to continue the public information program on a annual basis.
Based on the above findings, this portion of the licensee's program appears to be adequate.
6.3 News Media The licensee's program for acquainting the news media with emergency response actions at the FNP was - reviewed with respect to the
requirements of 10CFR50.47(b)(7), 10CFR50, Appendix E, Paragraph IV.F,
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and specific criteria in NUREG 0654,Section II.G.
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Alabama Power Company has been active in providing orientation and information to the news media concerning emergency planning and accident response at the FNP. Seminars for news media representatives have been conducted approximately quarterly over the past year and APC0 plans to continue with an aggressive information program. Most of the seminars have been conducted at the Farley site and have ir.cluded orientation tours, general information on plant design and operation and accident response scenarios.
These seminars have been well attended and have included participation by both the plant staff and corporate representatives.
Based on the above findings, this portion of the licensee's program appears to be adequate.
7.0 Drills, Exercises and Walk-Throughs 7.1 Program Implementation The licensee's implementation of drills and exercises was reviewed with respect to the requirements of 10CFR50.47(b)(14), 10CFR50, Appendix E, Paragraph IV F. and criteria in NUREG-0654,Section II N.
The dril!s and exercises required by the emergency plan and procedures have been conducted in accordance with the established procedures (FNP-0-EIP-15).
Critiques of exercises and drills were written.
Improvement items identified in the last exercise had been resolved as was the case for most of the drills; some drills had no improvement items.
Based on the above findings, this portion of the licensee's pro' gram apperas to be adequate.
7.2 Walk-through Observations The auditors interviewed several ApC0 employees who had been trained and qualified by the licensee to function on the radiation monitoring teams. The discussions were directed towards each individual's duties and functions as a member of specific survey teams.
The individuals who were interviewed wera C&HP technicians, who had good basic skills dealing with equipment operation and facilities and were generally knowledgeable in the performance of assigned tasks. The initial response to an emergency concerning identification of alarms, reporting to their respective assembly areas, and other actions prior to being assigned to a specific survey team was well understood by those plant personnel interviewed. They were also knowledgeable as to what emergency equipment would be required and utilized for off-site monitoring as well as knowing where to obtain this equirment.
(emergency kits, vehicle keys, communications equipment, etc.).
Each survey team member knew the proper procedures to follow to find the assigned survey locations, how to properly collect the filter-iodine data, and what to do with this data once cc,llecte However, most C&HP technicians interviewed showed little or no familiarity with proper plume monitoring techniques.
Some of the individuals interviewed indicated that even though they had received the proper monitor training designated by the licensee, additional and more comprehensive training would be desirable. It was the auditors' impression that such additional training would benefit and strengthen the licensee's survey program.
C&HP technicians who are responsible for obtaining post-accident samples were also interviewed with respect to their duties during emergencies. All showed an understanding of FNP-0-RCP-25 and exhibited familiarity with the proper sampling equipment.
Counting room personnel were familiar with techniques to be used with high-level samples.
Several Shift Supervisors were interviewed concerning the duties and responsibilities of the interim Emergency Director and were asked to perform radiological assessments using EIP-9 and parameters supplied by the inspector.
All individuals interviewed appeared to be knowledgeable and well trained in emergency classifications, emergency action levels (EAL's), and dose assessment calculations.
Based on the above findings, this portion of the licensee's program appears to be adequate.
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ATTACHMENT TO REPORT NOS.
50-348/81-20; 50-364/81-23 PERSONS CONTACTED R. P. Mcdonald, Vice President Nuclear Generation
- W. C. Hairston, Plant Manager
- K. W. McCracken, Superintendent, Procedures and Regulatory Control
- C. D. Nesbitt, Technical Superintendent
- R. D. Hill, Operations Supervisor-
- W. C. Carr, Supervisor, SAER
- W. R. Bayne, Plant Chemist
- H. N. McClennan, General Plant Engineer
- R. H. Graham, Security Supervisor
- W. G. Gripentog, Sector Supervisor, Emergency Planning
- M. W. Mitchell, Sector Supervisor, Health Physics
- B. P. Patton, Sector Supervisor, Plant Health Physicist -
- R. B. Wiggins, Sector Supervisor, Training
- D. R. Culver, SAER A. M. Davidson, Shift Supervisor J. L. Upchurch, Shift Supervisor R. Bowen, Shift Supervisor J. Clark, Shift Supervisor S. G. Brunner, Jr., Shif t Supervisor B. W. Vanlandingham, Shift Supervisor J..L. Deavers, Shif t Foreman B. Shipman, l'i'J:tenance Superintendent K. Jones, Material Supervisor J. Hudspeth, Document Control Supervisor G. Waymire, General Plant Engineer D. Morey, Operations Group Supervisor J. Thomas, I&C Supervisor R. Yancey, Electrical Engineer M. Grays, C&HP Foreman
- W. H. Bradford, NRC Senior Resident Inspector
- T. A. Peebles, NRC Resident Inspector In addition to the above, representatives of health physics, chemi stry,
operations, maintenance, security and the administrative staff were interviewed.
- Attended exit meeting