IR 05000395/1986005

Insp Rept 50-395/86-05 on 860224-28.Violation Noted:Failure to Provide Training to Key Member of Emergency Organization Re Fission Product Barrier Approach to Event Classification

ML20199G126
Person / Time
Site:	Summer
Issue date:	03/20/1986
From:	Decker T, Gooden A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20199G090	List: IR 05000395/1986005 ML20199G087 ML20199G100
References
50-395-86-05, 50-395-86-5, NUDOCS 8604090056
Download: ML20199G126 (9)

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UNITED STATES

[km afig% NUCLEAR REGULATORY COMMISSION y *

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j_ 101 MARIETTA STREET, t ATLANTA, GEORGI A 30323

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MAR 2 81986 Report No.: 50-395/86-05'

Licensee: SouthC'aroli'na~ElectricandGasCompany Columbia, SC 29218 Docket- No.*: 150-395 License No'.: NPF-12

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Facility _Nade: Summer _

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Inspectjon Conducted: IFebruary 24-58,.1986 Inspecto : 4; 3-20- 86

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Date Signed Accompanying: Per' son'nel : .F. L. McManu's Approved by: b f d / i [/2 4 3 4 0- PS T; R. Gecker, Section Chief - Date Signed Emergency Preparedness Section

• ^ , Division of Radiation Safety and Safeguards

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SUMMARY-Scope: This routine, unannounced inspection entailed 80 inspector-hours onsite and 4 inspector-hours offsite in the area of emergency preparednes Results: One violation was identified - Failure to provide training to a key member of the Emergency Organization regarding the " Fission Product Barrier Approach" to event classificatio .

8604090056 860328 PDR O ADOCK 05000395

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REPORT DETAILS Persons Contacted Licensee Employees

• T. L. Matlosz, Nuclear Operations Training Supervisor

• F. H. Zander, Manager, Nuclear Technical Education and Training F. Blanchard, Training Senior Instructor

• H. I. Donnelly, Senior Licensing Engineer

• B. G. Croley, Deputy Director, Operations and Maintenance

• J. P. Harrison, Manager, Nuclear Operations Services

• K. E. Beale, Coordinator Em~ergency Planning

• C. M. Counts, Plant Emergency Coordinator M. A. Garrett, Supervisor, Maintenance and Modification 0. S. Bradham, Director, Nuclear Plant Operations

• L. A. Blue, Mr:.ager, Support Services

• G. T. Liu, ISEG Engineer

• J. W. Derrick, Associats Manager, Maintenance and Engineering

• R. G. Sweet, Jr., QA Surveillance Specialist

• J. H. Barker, Senior Staff Health Physicist L. A. Smith, Security Operations N. Poole, Shift Supervisor J. Shipp, Shift Supervisor D. Goldston, Shift Supeivisor G. Guy, Shift Technical Advisor J. Llignon, Shift Technical Advisor D. Gatlin, Shift Technical Advisor W. Davis, Jr., Training Instructor H. Walters, Training Records R. King, Health Physics A. R. Koon, Associate Manager, Regulatory Compliance Other licensee employees contacted included technicians, and office personne Other Organizations H. G. Shealy, Chief, South Carolina Bureau of Radiological Health G. G. Douglass, Director, Fairfield County Emergency Preparedness Agency T. E. Feaster, Fire Inspector, Jenkinsville - Monticello Volunteer Fire Department H. K. Boyd, Jr., Director, Richland County Emergency Preparedness Office NRC Resident Inspector R. Prevatte, Senior Resident Ir.spector

• Attended exit interview i

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3 Exit Interview The inspection scope and findings were summarized on February 28, 1986, with those persons indicated in Paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection finding No dissenting comments were received from the licensee. The following new item was identified during this inspectio Violation - Failure to provide training to a key member of the Emergency Organization regarding the fission product barrier approach to event classificatio In a telephone discussion on March 26, 1986, the inspector informed the

't Senior Licensing Engineer that a Region II revi'w of the report details presented in Paragraph 3 below also identified an unresolved item (event classification).

The licensee identified as proprietary the material by Phoenix Power Services Inc., regarding event classification based on the fission product barrier approach. This information was provided to the inspector as part of the emergency detection and classification revie . Emergency Detectisa and Classification (82201)

Pursuant to 10 CFR 50.47(b)(4) and 10 CFR Part 50, Appendix E, Sections I and IV.C, this program area was inspected to determine whether the licensee used and understood a standard emergency classification and action level schem The inspector reviewed the licensee's classification procedures found in Emergency Plan Procedure 001 (EPP-001) titled " Activation and Implementation of Emergency Plan." Revision 8 of EPP-001, dated December 10, 1985, implemented a scheme for emergency classification that utilized a fission product barrier approach. The three fission product barriers of concern are the fuel clad, the reactor coolant system boundary, and the containment syste Based on tne Fission Product Barrier Approach, the following applies:

Notification of Unusual Event - No barriers breached Alert - One barrier breached Site Area Emergency - Two barriers breached General Emergency - Three barriers breached The assumption, supported by detailed engineering reports, is that with one barrier intact, release of radioactive material in sufficient quantities to exceed EPA protective action guidelines beyond the exclusion area boundary I will be prevented. The inspector reviewed the safety evaluation supporting I

implementation of the Fission Product Barrier approach. The safety evaluation includes justification for changing (downgrading) many of the emergency action levels as presented in NUREG-0654, Revision 1, Appendix The safety evaluation is based on the Summer FSAR, Cha.pter 15, and/or

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engineering calculations and consideration A more detailed review is needed before determining the adequacy of the fission product barrier approach to event classification. This determination could not be made during this inspectio Therefore, this matter will be considered unresolved until the adequacy of the procedures is determine Unresolved Item . (50-395/86-05-01): Determine the adequacy of Fission Product Barrier Approach to event classificatio The inspector verified that the licensee's notification procedures included criteria for initiation of offsite notifications and for development of protective action recommendations. The notification procedures required that offsite notifications be made promptly after declaration of an emergenc 'The inspector discussed witn licensee representatives the coordination of

. EAls with State and local officials., A representative with the South Carolina Bureau of Radiological Health indicated a meeting was held during November 1985 to discuss the concept of fission product barrier approach to event classification and any issues or concerns regarding this approac Interviews were held with three Shift Supervisors, and three Shift Technical Advisors to verify that they understood the fission product barrier concept and such indicators as inadequate-core-cooling indicator, high-range effluent monitor, fuel temperature indicator, containment purge exhaust monitors, vessel coolant level, and post-accident primary coolant analysi All interviewees appeared knowledgeable of the various fission product barrier indicators and their relationship to barrier status. Interviews demonstrated that key personnel clearly understood and could effectively use the fission product barrier approach for event classificatio The responsibility and authority for classification of emergency events and initiation of emergency action were prescribed in licensee procedures and in Section 4.1 of the Summer Radiation Emergency Pla Interviews with selected key members of the licensee's emergency organization revealed that these personnel understood their responsibilities and authorities in relation to accident classification, notification, and protective action recommendation Selected Emergency Plan Procedures (EPPs) were reviewed by the inspector in preparing for walkthroughs and conducting interviews. As part of the preparation process, the inspector reviewed Attachment V to procedure HPP-904. This attachment consisted of two graphs that converts the reactor building purge exhaust noble gas (high and low) instrument reading to microcuries/ milliliter (pCi/ml) for use in manual dose calculations. The graph for the high range instrument is inconsistent with the ;ange of the instrument. That is, the meter range is 0.1 mrem /h to 1 x 105 mrem /h and the graph range is 1 mrem /h to 1 x 10' mrem /h. This matter was discussed with licensee representative who agreed to revise graph to reflect the true meter rang . . -_

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Inspector Follow-up Item (50-395/86-05-02): Revise Attachment V to procedure HPP-904 to reflect the entire meter rang Walk-through evaluations involving accident classification problems were conducted with three Shift Supervisors and Shift Technical Advisors. All personnel interviewed promptly and properly classified the hypothetical accident situations presented to them, and appeared to be familiar with the fission product barrier approach for event classificatio The licensee plan includes procedures for notification of offsite agencie The notification form has provisions for protective action recommendations and authentication of the notification transmitta Walk-throughs demonstrated that Shift Supervisors and Shift Technical Advisors understood the requirements to pronptly noti fy offsite agencies. However, on one occasion, the incorrect notification form was use It is uncertain whether this error was due to the arrangement of the notification form storage files, or human error. This matter was discussed with licensee representatives who agreed to review the filing system and emphasize the use

,of proper notification forms during trainin Inspector Follow-up Item (50-395/86-05-03): Provide Training on the Use of Notification Form During the walk-throughs, several discrepancies were noted: - Evacuation Times - Tne inspector requested an evacuation time estimate be made for the affected sector. Two Shift Supervisors responded with the correct time of 153 minutes, and one Shift Supervisor responded with an incorrect time of 6 nour Investigation of the discrepancy revealed that three different documents were available in the TSC-Duty Shi.ft Supervisor's Office for estimating evacuation times: (a) EPP-005 Attachment XII, (b) Radiation Emergency Plas: Appendix J, and (c) Estimation of Evacuation Time Study, Revision 1 by Wilbur Smith and Compan Each document gives different results. This matter was discussed with a licensee representative who indicated the plan holder failed to remove Appendix J as part of plan changes transmittals. The licensee representative agreed to review the evacuation time estimates and remove the incorrect documents or procedures to avoid any further discrepancy or error Inspector Follow-up Item (50-395/86-05-04): Review the Evacuation Time Estimates and Select the Correct Method to be used, Source Term Calculations - During the walk-through, a discrepancy was noted in the source term results between the manual and computer method. The Shift Supervisor, when using the nomograph for noble gas release, estimated a curie (Ci) release rate of 200 Ci/sec. With the same data presented, the computer method indicated a release rate of

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6.5 Ci/se The licensee provided several explanations for this

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discrepancy prior to the exit meeting; however, there was not adequate time for the inspector to review the information and observe source

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term- calediations being performed. As a result, this matter was discussed with licensee representative for determining the cause and resolving the discrepanc This matter will be reviewed during a future inspectio Inspector Follow-up Item (50-395/86-05-05): Review and Correct the Discrepancy Between the Computer and Manual Method for Source Term Calculation Protective Action Recommendations (PARS) - Following the declaration of a General Emergency, all Shift Supervisors recognized the need to provide prompt protective action recommendations to off site agencie However, slight differences were demonstrated by Shift Supervisors during follow-up messages as to what protective action recommendations to make following the initial PARS (e.g. , sheltering for pregnant women, ' prevent traffic into the 10 mile EPZ, evacuation of certain sectors,etc.). This matter was discussed with licensee representative as requiring more emphasis on protective action recommendations during trainin Licensee representative agreed to place emphasis on protective action recommendations during trainin Inspector Follow-up Item (50-395/86-05-06): Training to Include More Emphasis on Protective Action Recommendation No violations or deviations were. identified in this program are . Changes to the Emergency Preparedness Program (82204)

Pursuant to 10 CFR 50.47(b)(16), 10 CFR 50.54(q), and 10 CFR 50, Appendix E, Sections IV and V, this area was reviewed to determine whether changes were made to the program since the last routine inspection (February 1985) and to note how these changes affected the overall state of emergency preparednes The inspector discussed the licensee's program for making changes to the emergency plan and implementing procedures. The inspector reviewed the licensee's procedures (Administrative Instruction -

101 and Station Ariministrative Procedure -139) governing review and approval of changes to the plan and procecures. The inspector verified that changes to the plan and procedures were reviewed and approved by management. It was also noted that all such changes were submitted tc NRC within 30 days of the effective date, as require Discussions with licensee representatives indicated no major modifications to facilities, equipment, or instrumentation since the last inspectio However, one improvement has been made in the TSC since the last inspection as a result of a wall removal. A wall was removed inside the TSC to create additional space for the command center. This modification also provides additional space for the Shift Supervisor's office Ey review of selected procedures, the inspector verified that procedural and plan changes were made to reflect the recent change in the event classification system using the fission product barrier approach, and the addition of a dedicated

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communicator to the emergency organization for alleviating notification problems identified in Information Notice 85-8 The organization and management of the emergency preparedness pogram were reviewed. It was noted that the reporting chain for the Corporate Emergency Planning Coordinator (EPC) has changed. Although the responsibilities were not changed, the Corporate EPC now reports to the Manager cf Nuclear Operations Service instead of the Vice-President of Nuclear Operations. In addition, several position titles were changed, including the reassignment

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2) Deputy Director of Site Operations. Further discussion with licensee representatives disclosed that 'he position of Area Coordinator for the South Carolina Emergency Preparedness Office was reassigned since the last inspectio The inspector's (*.iscussion with licensee representatives disclosed a change in notification procedure to the State Bureau of Radiological Health after normal working hour Previously, the Bureau of Radiological Health utilized an answering service for receiving calls after duty hour Recently, a decision was made to replace the answering service with the State Highway Patrol Dispatche The inspector reviewed the licensee's program for distribution of changes to the energency plan and procedures. Document control records for the period September 9, 1985 to February 6, 1986, showed that appropriate personnel and organizations were sent copies of plan and procedural changes, as require No violations or deviations were identified in this program are . Knowledge and Performance of Duties (Training) (82206)

Pursuant to 10 CFR 50.47(b)(15) and 10 CFR Part 50, Appendix E, Section IV.F, this area was inspected to determine whether emergency response personnel understood their emergency response roles and could perform their assigned function The inspector reviewed the description (in the emergency plan) of the training program, training procedures, and selected lesson plans, and interviewed members of the instructional staff. Based on these reviews and interviews, the inspector determined that the licensee had established 6 formal emergency training progra The inspector reviewed selected records of training fcr key members of the emergency organization for the period January 1985 to February 1986. It was noted that one Management Duty Supervisor, who serves as an Alternate Emergency Director, had not received training on the fission product barrier approach to event classificatio This is inconsistent with training requirements as specified in EPP-01 The licensee acknowledged this finding as an oversight in their training program. This item was identified as a violatio . .

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Violation (50-395/86-05-07): Failure to provide a key member of the emergency organization with training on the fission product barrier approach to event classificatio According to training records, with the exception of the finding stated above, all other training provided to key members of the onsite emergency organization was consistent with approved procedures. , Three specialized training sessions for " Emergency Communicators" were Esid since the last inspection. The most recent training for communicators was conducted for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> on February 5,1986. The annual training for corporate personnel was conducted on February 20, and February 27, 198 The inspector conducted walk-through evaluations with selected key me.mbers of the emergency organization. During these walk-throughs, individuals were given various hypothetical sets of emergency conditions and data and asked to respond as if an emergency actually existed. The individuals demon-strated familiarity with emergency procedures and equipment, and no problems were observed in the areas of emergency detection and classificatio One violation and no deviations were identified in this program are . Licensee Audits (82210)

Pursuant to 10 CFR 50.47(b)(14) and (16) and 10 CFR 50.54(t), this area was inspected to determine whether the licensee had performed an independent review or audit of the emergency preparedness progra Records of audits of the program were reviewed. The records showed that an independent audit of the program was conducted by the Quality Services Group during January 1985, and during the week of January 13-22, 1986. This audit fulfilled the 12-month frequency requirement for such audit The audit records showed that the State and local government interfaces were evaluated, and that findings concerning the interfaces were made available to State and local government authorities. Audit findings and recommenda-tions were presented to plant and corporate management. A review of past audit reports indicated that the licensee complied with the five year

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retention requirement for such report Critiques required by the licensee's emergency plans and procedures were conducted following exercises and drill Licensee documentation dated May 8, 1985, showed that a critique was held following the annual exercis The records showed that deficiencies were discussed in the critiques, and recommendations for corrective actions were mad The licensee's program for follow-up action on audit, drill, and exercise findings were reviewed. Licensee procedures required followup on deficient areas identified during audits, drills, and exercise The inspector reviewed a selection of licensee records which indicated that corrective action was taken on identified problems, as appropriat The licensee has established a tracking system known as the " Regulatory Tracking System

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(RTS)" for use las a management tool in following up on actions taken in deficient area No violations or deviations were identified in this crogram are . Coordination with Offsite Agencies (82210)

The inspector held discussions with licensee representatives regarding the coordination of emergency planning with offsite agencies. Written agreements existed with those offsite support agencies specified in the emergency plan, and the agreements had been renewed within the past two years, as required. However, several agreements are due for renewal during 1986. The inspector conducted personal interviews with representatives of selected local and State support agencies (paragraph 1) to determine if the licensee was periodically contacting those agencies for purposes of offering training and maintaining mutual familiarization with emergency response roles. The interviews indicated that training is being provided as specified in the Summer Emergency Plan and EPP-01 The inspector discussed with the offsite support groups, the licensee's recent change in event classification employing the fission product barrier approach. During the discussion, the inspector was informed that training on the fission prcduct barrier approach to event classification was conducted by the licensee on February 6,1986. This training also included a table top exercise. A representative for the South Carolina Bureau of Radiological Health indicated a draft of the fission product barrier approach to event classification was provided for review by the licensee in October 1985. During November 1985, a meeting was held to discuss the concept and eny concerns or issues that the review process may have raise No problems were noted regarding the interface between the licensee and offsite support agencies listed in Paragraph No violations or deviations were identifie . Inspector Follow-up (92701)

(Closed) Inspector Follow-up Item (IFI) 395/82-41-21: Food Pathway Contamination (ASLB Supplemental Partial Initial Decision, August 4,1982,Section VIII.6). The inspector reviewed a brochure titled " Agriculture and Nuclear Power in South Carolina". This brochure provides specific information for farmars and livestock owners regarding protective action for farm animals and commodities in the event of an emergency at a nuclear power plant. A discussion with licensee representative and a representative of the South Carolina Emergency Preparedness Division indicated that the .'

brochures were distributed statewide by Clemson University Cooperative Extension Service on two occasions (most recently, just prior to 1985 Summer exercise).

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