IR 05000410/1986023

Emergency Preparedness Implementation Appraisal 50-410/86-23 on 860519-22.No Violations Noted.Major Areas Inspected: Emergency Preparedness Program,Including Organization, Administration & Procedures

ML20207D730
Person / Time
Site:	Nine Mile Point
Issue date:	07/10/1986
From:	Lazarus W, Thomas W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20207D707	List: IR 05000410/1986023 ML20207D702
References
RTR-NUREG-0654, RTR-NUREG-654 50-410-86-23, NUDOCS 8607220170
Download: ML20207D730 (23)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N .

Docket N '

License N CPPR-125 Category B-1 Licensee: Niagara Mohawk Power Corporation 300 Erie Boulevard West Syracuse, New York 13202 Facility Name: Nine Mile Point Unit-2 Inspection At: Scriba, New York Inspection Conduc d: May 19-20, 1986 Inspectors: [5f ,

.~ JJfmas, y Speciali st[/ da t'e C. Gordon, EP Specialist B. Haagensen. Battelle PNL C. Hawley, Battelle PNL A. Smith, Battelle PNL Approved by:

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dat'e odd g rus, g ief, Emergency Preparedness Section Inspection Summary: Inspection on May 19-22, 1986 (Report No. 86-23)

Areas Inspected: Emergency Preparedness Implementation Appraisal to evaluate the adequacy and effectiveness of the Emergency Preparedness Program for Nine Mile Point Unit-2, including organization, administration, procedures, training, and facilities and equipmen Results: No violations were identified. Several program areas were identified which are incomplete or require corrective action, these are listed as open items, and will need to be addressed by the licensee and reinspected in a subsequent inspection. Detail 4 of this report provides a summary listing of these items along with the determination of whether the item is required to be corrected prior to issuance of the low power license or the full power licens .

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( 8607220170 860710 PDR ADOCK 05000410 G PDR

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DETAILS Persons Contacted

• Abbott, Station Superintendent

• Boyle, Nuclear and Compliance Technician

• Burgess, Assistant Emergency Coordinator R. Burtch, Director Nuclear Information

• T. Chwalek, Emergency Coordinator G. Griffith, Unit-2 Licensing

• Hansen, Manager, Nuclear QA Operations

• Hendrick, Supervisor, Training Departmen *C. Howes, Health' Physicist L. Kassakatis, Startup and Test Engineering E. Leach, Superintendent, Chemistry, Radiation Management

• T. Lee, Special Projects, Unit-2 T. Lempges, Vice-President Nuclear Generation

• Peeling, Training Instructor

• Perkins, General Superintendent

• Salemi, Assistant Emergency Coordinator

• Savar, Compliance Licensing

• Volza, Supervisor, Radiological Support

• Weakley, Special Projects, Unit-2

• R. Zollitsch, Superintendent, Training Department The inspector also interviewed several licensed operators, health physics, administrative and training personne * Denotes those present at the exit intervie . Scope of Appraisal The purpose of this appraisal was to determine the readiness of Unit-2 to implement the Emergency Plan in preparation for licensing. The principal criteria for this appraisal are contained in NUREG-0654, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants", 10 CFR 50.47, and 10 CFR 50 Appendix E. The appraisal addressed administration, emergency -

organization, emergency training and retraining, emergency facilities and equipment, procedures, coordination with offsite groups, drills, exercises, and walk-through .

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- Inspection Details

' Administration and Organization of the Emergency Plan The inspectors reviewed Section 5 to the site Emergency Plan, emer-gency procedure EAP-3, and corporate procedure CPP-4, held discus-sions with licensee representatives and determined that the existing Unit I emergency organization has been adequately augmented to cover staffing for Unit 2 emergencies. The primary change in the overall response organization was assignment of an Operations Superintendent from the uncffected unit to serve as the TSC/ EOF liaison represent-ative. Three levels of augmentation are described in the site Emergency Plan which include designated management structures for the following major functional areas: emergency response organization, operational accident assessment, radiological accident assessment, personnel monitoring, security and access control, repair and cor-rective actions, accountability, radiation protection, and technical support to operations. Block diagrams which describe the overall and internal chain of command were included for each augmentation phas A Site Emergency Director will be available onsite at all times to assume the primary responsibility for emergency coordination, pro-tective action decisionmaking, and other exchange of information with State and offsite authorities. However, review of the Corporate Emergency Plan indicated that the Corporate Emergency Director (CED)

directs the emergency from the EOF and will also provide offsite emergency measures. Since the TSC maintains the primary interface with offsite groups for making protective action recommendations, the role of the CED should be clarified with respect to interface with offsite groups. A second concern relating to the division of res-ponsibilities between the Site Energency Director (TSC) and Corporate Emergency Director (EOF), is that the Corporate Emergency Director is not directly involved in coordinating the off-site response to the acciden The Site Emergency Director supervises both the on-site response for mitigation of the accident and the off-site interface with the state in making protective action recommendations. This is contrary to the concept of division of responsibilities between the TSC and EOF and is a concern for the following reasons:

(1) State representatives in the EOF are receiving information from the Corporate Emergency Director while the Site Emergency e Director is providing information to the state E0C via telephone (RECS) from the TSC. The potential exists for different in-forr.ation be;ng passed over the two paths.

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(2) The Site Emergency Director may have too much responsibility in supervising on-site and off-site respons (3) Feedback regarding implementation of protective actions is provided to the E0F where the protective action status board is kept, rather than to the TSC where the recommendations are being mad , (4) The NRC Site Team is normally divided between the TSC and EOF, but would all be at the TSC during a response at Nine Mile Point, as that is where on-site response, dose assessment, control of off-site teams, and protective action decisionmaking

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As noted in the letter forwarding this report we plan to meet with the licensee to resolve these concerns prior to issuing a full power license for Nine Mile Unit For level III staffing (full augmentation of the EOF) no major changes were found in the corporate response organization. Procedure EAP-3 describes general information about the primary and alternate

representatives designated to fill each response position in addition to whom each member reports, reporting location, responsibilities, general activities, and specific actions and limitations required for their positio Procedure CPP-4 provides similar information for actions and recovery duties for each member of the corporate organ-ization. Together the two procedures allow the functional areas described above to be covered for a prolonged response (beyond 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />).

Since no major changes in the emergency organization have taken place, the current organization with the addition of extra qualified personnel will be adequate for both units. The licensee has demonstrated in previous drills and exercises that NUREG-0654, Table B-1 staffing criteria can be satisfied within the prescribed time limit In addition, separate Unit 2 staffing drills, which included staff turnover, were conducted on March 6, March 20, and May 8, 198 Except as noted below, this area of the licensee's program is accep-i table.

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Clearly define the offsite authority / responsibilities of the Cor-

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porate Emergency Director and the Site Emergency Director and identify those responsibilities which cannot be delegated (50-410/86-23-01).

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B. Training Program (1). Emergency Plan Training Program Establishment The licensee's training program for personnel assigned emergency response duties is described in Section 8.1.1 of the Emergency Plan and in Nuclear Training Procedure NTP-4. (It was noted that Section 8.1.1 of the Emergency Plan refers to procedure APN-10F, which has been superseded by NTP-4.).

The Superintendent Training - Nuclear is responsible for en-suring that personnel at NMPS receive emergency plan trainin The inspectors reviewed records and documents, interviewed members of the Training Department, and personnel assigned to various functional areas of the emergency response organizatio Categories of plant and other personnel who receive specialized emergency response training are listed in Figure 8.1 of the Emergency Plan. This table also includes a general description of involved personnel, a general description of the type of training required, and the period of time until retraining is required. Qualification requirements and training requirements for emergency response personnel are specified in the Emergency Plan Figure 5.2- Direct responsibility for EP training is assigned to two in-dividuals in the Training Department, one of which deals with plant operations only. Lesson plans specific to each emergency response function have been developed and approved (with the exception of one lesson plan addressed to core damage assess-ment, which is under development). The lesson plans were based on the results of an assignment-specific "needs analysis" and were tailored to fulfill the training requirements of the emer-gency response functio The emergency planning group was in-volved in the development and approval of the lesson plan There is a specific loose-leaf binder containing experience, training, and accomplishment records for each NMPS employe Section 14 of each record incorporates radiation protection, industrial safety, security, and other training record There is a discrete section (FC 14.3) devoted to site Emergency Plan and Procedures Training. This record reflects the course subject (including training on specific EPPs), the instructors name, quiz grades, date, and the initials of the responsible training superviso The record book also contains records of walk-through training, drill participation and exercise part-icipation. Qualification dates were recorded, based on the completion of pre-established qualification requirement . _ , - _ - ._ =.

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Retraining notifications and instruction are the responsibility of the Training Department. A crcss-reference system was em-ployed which identified all procedures which have an influence on emergency preparedness function >

The EP training for operations was_ incorporated directly into the operators' license classe It is station policy that all station shift supervisors receive the EP Emergency Director training as a qualification requiremen The inspectors reviewed the records of selected emergency res-

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ponse personnel and randomly reviewed records of the general station work-force. All records were found to be well organized and comprehensiv Personnel with potential fire brigade res-ponsibilities received multi-media Red Cross first-aid training annually, as well as EMT training through the NMPS medical staf Station policy is to provide at least one EMT-trained person on each shif A formal system has been established in the Training Department to incorporate procedure changes into lesson plan Based on the above findings, this portion of the licensee's program is acceptabl (2). Program Implementation A review of the training records mentioned above indicated that the training required by the Emergency Plan had been accomp-lished. In addition, the 1984 and 1985 Emergency Plan and Procedures audit reports of the NMPS Safety Review and Audit Board were reviewed. Two 1985 items dealing with EP training

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had been corrected and documented by memoranda to the Boar A review of the EP Exercise / Drill Deficiency file indicated that training deficiencies identified through the post-drill /excrcise critique process were formally catalogued, responsibility for correction was assigned, and the deficiencies were corrected, as

! specified in DPMP-4, Se: tion The NMPS Emergency Preparedness Actitivity Schedule from July of 1985 through December of 1986, and the Emergency Drill Schedule, Revision II, were reviewed. The inspectors concluded

- that past and proposed drills and exercises were as described in the Emergency Plan, Section 8. Based on the above, this portion of the licensee's program is acceptabl _ - _ . _ . . . _ - . _ _ _ _ _ _ _ _ _ _ _ _ . _ - __ . -_

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(3). Control Room Operator Walk-Thorugh Observations Three separate shifts of control room operators were given scenarios to test their abilities to classify events, recommend protective actions, fill out offsite notification message forms and execute emergency procedures. The inspector provided a sequence of events and the operators were not required to assess plant status from actual indication. Plant data was provided as necessary to amplify the description of scenario events or l determine actions from procedures. The shift supervisors and l control room operators were all qualified and had completed '

required Emergency Plan trainin l

, The first scenario included power excursion from an inadvertent I

criticality during initial start up. After a time jump, a se-cond problem included a power excursion caused by reactivity oscillation causing clad failure and an unisolable steam line l

rupture on the RCIC system. The second scenario included a fire in the RCIC room, a reactor vessel level transient and a main

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steam line rupture with MSIV isolatio The third scenario

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included a small break LOCA into the drywell with a loss of offsite power and the failure of division I and II emergency diesels. Operators were evaluated on their ability to classify events, recommend initial protective actions and execute emer-gency plans and procedures. The following weaknesses were identifie Shift supervisors were generally unfamiliar with the cor-rect use of EPP-26 Protective Action Recommendation Proce-dure beyond the initial default recommendations. They did not understand how to evaluate protective action guides (PAGs) or how to evaluate precautionary evacuation cons-traints in the PAR flow chart. They could not state what constituted " substantial core damage" to answer the dec-ision block below the initial PAR decision bloc Shift supervisors were confused by EAL wording in Figure 4.1 - Attachment 6 for classification of fire related emergency action levels. When given indications of a sign-ificant fire below the Control Room floor, the operators did not classify the event as an Alert. When questioned on the meaning of the EAL indication, the shift supervisor stated he did not understan Some initial notifications would not have been completed within the NUREG-0654 15 minute time requirement because of delays in filling the initial notification message for _ _ _ _ _

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Some control room communicators were confused over the

correct form to use for NRC ENS notificatio Shift supervisors were not aware that the on shift chem-istry. technicians were responsible to perform initial dose assessment in the control room until the TSC was activate Shift supervisors did not understand how to use Figure Attachment 2 of EAP-2 to evaluate dose projections under adverse meteorological conditions for classification of a Site Area Emergenc Shift supervisors did not have a clear understanding of conditions that would constitute potential failure of con-tainment. Operators classified a small break LOCA into the dry well with coolant activity levels slightly below Tech-nical Specification limits as a General Emergency based on a failure of two fission product barriers. With 2 psig pressure in the dry well, there was little potential for dry well failure. Operators did not realize that small amounts of activity would transport through design criteria leak path Shift supervisors did not have a clear understanding of the degree of clad damage that would constitute fuel barrier failure under classification of General Emergencies based on the failure of 2 fission product barriers with the po-tential for failure of the third barrie As noted in section 3.D.(3) of this report, the Emergency Action Levels (EAL's) for fires do not follow the guidance of NUREG-0654. Changes to the EAL's and re-training the operators will be necessary. The licensee has agreed to institute a refresher training program for operators covering the above noted areas prior to issuance of a low power license. Action in this regard will be evaluated in a subsequent inspection (50-410/86-23-02).

C Facilities and Equipment

(1). Control Room The inspectors toured the Control Room and found it to have adequate space, shielding and air filtration to assure its habit-ability during various accident scenario Instruments were available to detect and measure radiation levels, airborne con-tamination and plant process system parameter Emergency com-munications systems were available for notification of offsite

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authorities and the NRC. The Emergency Plan and implementing procedures were available and inventories of checklists and decision aids were conducted monthly.

i During this review it was identified that there were no pro-visions in the Emergency Plan for receiving tornado warnings in the Control Room. Operators were uncertain as to how weather alerts would be obtained. A second area of concern involved s lack of respiratory protection inside the control room habit-ability envelope, although Control Room operators indicated that they would use respirators in the control room in the event of a l fire or toxic gas emergenc Except as noted below, this area of the licensee's program is acceptabl '

The Emergency Plan or associated procedures should contain provisions to provide weather alerts or warnings of emergency weather conditions to the control room. Operators should be aware of these provisions (50-410/86-23-03).

Respiratory protection devices should be provided for control

, room operators inside the habitability envelope of the control room (50-410/86-23-04).

(2). Technical Support Center (TSC)

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The inspectors evaluated the licensee's TSC facility to verify that the requirements / guidance of NUREC-0654, NUREG-0696, NUREG-0737 Supp. 1, and 10 CFR 50 Appendix E, concerning accessibility, habitability, working space, availability of /

reference material, communications data systems, and miscel-laneous support equipment. The TSC and its operation are des-cribed in Section 7.1.2 of the Site Emergency Plan and procedure EPP-13,"On-site Emergency Response Facilities Operations," Rev.

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1 The TSC is located at the 248 foot level of the Administration Building (lowest level below grade), and serves both Units 1 and Shielding was determined to be adequate due to the below

grade location. A ventilation system provides the same radio-logical habitability as the Control Room. Adequate reference material is available, -including as-built drawings, procedures, the Final Safety Analysis Report, Technical Specifications, and

permanent plant records (accessed through the site document control computer files). Plant data is available from the same Digital Radiation Monitoring System, Safety Parameter Display

, System, and meteorological data system that serves the Control Roo The appropriate telephone equipment is installed and i

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operational, including the NRC ENS telephone. Radio equipment is installed for communication with radiological assessment teams. W31 king time from the Unit 2 Control Room to the TSC was about 4 minutes in contrast to the 2 minute guidance of

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NUREG-0696. The purpose of the guidance was to-facilitate fece-to-face interaction between Control Room personnel and the

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Site Emergency Director in the TSC and provide access to Control Room information that isn't available in the TSC. Since the TSC data systems were served by the same computer systems as those

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in the Control Room, the data availability was essentially identical, and the communications systems adequate, thus elimi-

, nating a need to provide for face-to-face communicatio The function of the TSC was observed during the Nine Mile Point Unit 1 emergency exercise in November, 1985. No significant deficiencies were identifie Based on the above findings, this portion of the licensee's

program is acceptabl (3). Oparational Sucport Center (OSC)

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The OSC is located as described in the Emergency Plan and im-plementing precedurc EPP-13, "Onsite Emergency Response faci- .

lities Op-3 rations". The OSC is sufficient in size and equipment to function in any anticipated emergency. Procedures and cquip- >

mert specific to Unit-2 are in place in the 6mergency equipment lockers located in the OSC. The communicaticns system from the ,

OSC to the Unit-2 Control Room, TSC and the EOF is in place and -

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Based on the above findings, thi s portion of the licensee's '

prograin is acceptabl ,

(4). Emergency Operation Facility (ECF}

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The EOF is located in the basement of the Nine Mile Point (NMP)

i Nuclear Training Center,.just outside of the NMP Nuclear Station

, protected area. The EOF is a " hardened" facility with a pro-

tection factor greater than 5 and contains ventilation system .

isolation with HEPA and charcoal filter The EOF provides a location where expanded control of activities '

can be directed by the Corporate Emergehcy Director / Recovery Manager and where continLed evaluation and coordination of all emergency response activities can be performed. It is also

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An alternate EOF (AEOF) is located at the Niagara Mohawk Ser-vice Center at Howard Road, Volney (Fulton), eleven miles from the site and generally in the upwind direction. The AEOF serves the same functions as the EOF and contains similiar emergency equipment and communication system During emergencies, the EOF would have sufficient assembly space, offices and conference rooms to accommodate the Emergency Response Manager and Staff, required NRC personnel, state and local response agencies and limited news media personne Emergency kits, and additional dosimetry, decontamination materials and protective clothing for emergency use are avail-abl A hand and foot counter, frisker and a direct radiation monitor are located at the entrance to the E0F, and a continuous air particulate and gaseous monitor was connected into the building ventilation syste The emergency communication network as described in the plan is installed and operable in the EOF. Other equipment and supplies available in the EOF, such as emergency kits, monitoring in-strumentation, plant process computer terminals, Ditigal Rad-iation Monitoring System, decontamination shower and supplies, status boards and appropriate forms were in place and/or oper-able. Plant information such as copies of building prints, drawings and documentation are available on aperture cards, hard copies, and fil Based on the above findings, this portion of the licensee's program is acceptabl (5). Assembly / Reassembly Areas The inspectors verified that the assembly / reassembly areas are located as described in the Emergency Plan and Implementing Procedure EPP-5, " Station Evacuation", and are in accordance with the guidance of NUREG-0654. The inspectors toured the employee assembly areas for Unit-2, located in the "L" shaped i building, the Construction Change House, and the Intake Screen Wall building. The evacuation / assembly areas are designated by signs and each contains a number of accountability card reader station The inspectors noted that the facilities are adequate to accommodate the construction work forc Based on the above findings, this portion of the licensee's 3 program is acceptable.

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(6). Emergency Communication Equipment The inspectors reviewed section 7.2, " Communication Systems",

of the Emergency Plan, EPP-17, " Communication Procedures",

toured the Emergency Response Facilities and observed a comm-unication drill conducted to demonstrate adequate data flow between the Emergency Response Facilities and adequacy of hard-war The inspector verified that communication equipment specified in the licensee's Emergency Plan and EPP-17 is in place and oper-able, including alarms located throughout the facilities, which have specific personnel notification functions. Communications equipment is checked routinely in accordance with EPMP-3,

" Review and Revision of Site Emergency Plan and Procedures".

The inspectors verified that there is a 24-hour capability to notify the NRC, State and Local Authorities from the Control Roo It was determined that dedicated hotline telephones are backed-up by regular non-dedicated telephone line This portion of the licensee's program is acceptabl (7). Area and Process Radiation Monitors The Digital Radiation MonitoringSystem (DRMS) is installed to provide specific information on radiation levels at designated locations throughout Unit 2. The system uses a series of mon-itors and detectors and is controlled by a data processo Readouts and system access may be made from the Control Room, TSC, and E0 The DRMS is designed to detect, measurei display, and store ra-diation levels in the process and ventilation pathways and to detect radiological release rates from effluent monitors. The system is installed and operational, but preoperational and surveillance testing had not been completed at the time of this inspection. Displays associated with area and process radiation monitors and non process monitors will provide designated mon-itor locations on each floor plan, actual radiation reading or level, trip points, level alarms for water, temperature, pres-sure, and flows, detector efficency (including conversion factors), time averaged trending levels, calibratic, dates, background checks, purgetime, status of internal check source, equipment failure alarms, and specialized activities associated with each monitor. Procedures have been developed for cali-bration of instruments and monitors, and a schedule for cali-bration will be maintained,

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Except as noted below this portion of the licensee's program is acceptabl Complete the preoperational, surveillance testing and turnover of the Digital Radiation Monitoring System (DRMS)

(50-410/86-23-05).

(8). Non-Radiation Process Monitors The inspector reviewed procedure EAP-2, " Classification of Emergency Conditions", Rev. 6, to determine which non-radiation monitoring instruments are relied upon for detection, classif-ication, and assessment of events. Nineteen non-radiological parameters were identified as being used for these purposes. A review of Technical Specifications revealed that, except for five parameters all of this monitoring instrumentation is re-quired to be operable to meet Technical Specification require--

ments (either directly, as required instrumentation, or in-directly, to assure compliance with a limit on same parameter).

The remaining five parameters:

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Electrical Output (MWe),

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S/RV discharge tail pipe temperature,

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Steamflow/ Feed flow unmatched,

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Turbine building ambient temperatures, and

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Loop suction temperature, were reviewed individually to determine whether associated instrumentation was installed and operabl Based on this review it was determined that turbine building ambient temperature could not be monitored from the Control Room. -The licensee agreed to remove this as one of the para-meters to be monitored for classifying a steam line break accident. Action in this regard will be reviewed in a subse-quent inspection (50-410/86-23-06).

Except as noted above this portion of the licensee's program is acceptabl (9). Damage control kits were checked for proper equipment and stor-age considerations. Periodic inventories required by Nine Mile Point EPMP-2 were checked to verify that they had been completed as require .

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Damage control kits were inspected and found to contain suffic-ient supplies to meet corrective action needs during emergen-cies. A quarterly inventory system assures that the kits con-tain the required tools and supplies. Storage of these kits allows for proper control while breakaway locks allow emergency access for personnel not having special keys. The equipment inventory -surveillance system provides an excellent administ-rative method for assuring that the kits are fully stocked with operable equipmen Based on these findings, this portion of the licensee's program is acceptable (10). Transportation Equipment The inspectors reviewed EPP-7, Downwind Radiological Monitoring EPP-14, " Emergency Access Control", and EPP-16, " Environmental Monitoring". The inspectors determined that a total of seven vehicles are available for transportation of onsite/offsite monitoring teams. Three of these vehicles are four-wheel drive and equipped with power inverters to operate portable sampling equipmen Two of the vehicles are assigned to the on shift Chemistry and Radiological Management Supervisor and one to the on-shift computer group. All vehicles were equipped with two way radios for communication with the Control Room, Technical

, Support Center, and/or the Emergency Operations Facilit Emergency keys are contained in the Control Room,-in the down wind survey kits, ar.d in the Maintenance Shop. The ins-pectors determined that the three Category A vehicles designated in EPP-7 would be available for emergency us Based on the above findings, this portion of the licensee's program is acceptabl (11). Decontamination Facilities The inspectors toured the decontamination facilities at the EOF, near the H.P. Control Point at the 261' level of the administration building, and the new Unit 2 facility adjacent to the elevator at the 306' level (still under construction).

A review of EPP-15, " Health Physics Procedures", indicated that the new Unit 2 decon facility (306' level) was not described in the procedur Provisions have also been made for the decontamination of personnel at Assembly Area ._

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Except as noted below this portion of the licensee's program is acceptable.

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Complete and equip the Unit 2 306' level decontamination

facility, and Revise EPP-15, Section 8, to reflect the existence j of the Unit 2 decontamination facility (50-410/86-23-07).

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(12). Emergency Kits

! The inspectors toured the licensee's Control Room, TSC, OSC,

! EOF, Alternate EOF (AEOF) and the Assembly / Reassembly areas in i j order to evaluate the adequacy of the emergency equipment stored

in each facility. The inspectors verified that the kits stored 7 in the Control Room,TSC, OSC, E0F, and AEOF are as specified in EPMP-2, " Emergency Equipment Inventories and Checklists". All equipment checked was operable, radiological instrumentation calibrations were current, and the kits contained a sufficient number of instruments and supplies to-equip the number of team members projected to be required during emergency situations, j All kits contained inventory forms, which are required to be-

! completed monthly, and after each drill or exercise. All in-

! ventory sheets were examined and found to be complete. All discrepancies noted by the licensee had been corrected. Al-though there are no emergency kits located in the Unit-2

Assembly / Reassembly areas, emergency equipment needs would be -

met by the supplies stored in the OSC.

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Based on the above findings, this portion of the licensee's program is acceptable.

Emergency Procedures

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(1). General Content and Format The inspectors reviewed the licensee's Site Emergency Plan Proc-edures Volumes I & II which included Emergency Action Proce-

. dures, (EAP) Emergency Plan Implementing Procedures (EPIP)

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Emergency Plan Maintenance Procedures (EPMPs), and the Corporate Emergency Procedures (CEPs), for general content and format.

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l The procedures contain specific sections which include purpose,

! references, responsibilities, equipment, specific procedural i

steps to be followed, and figures and checklists. Procedures also highlight the conditions which exist prior to actions being j performed and describe action steps for user implementation.

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Seve'ral important EAP's and EPP's have been revised to reflect the addition of Unit 2. These include " Activation and Direction of the Emergency Plan" (EAP-1), " Classification of Emergency Conditions" (EAP-2), " Station Evacuation" (EPP-5), "Determin-ation of Core Damage under Accident Conditions" (EAP-9), and

" Site Evacuation Procedure" (EAP-19). The inspectors also re-viewed the revised procedures and verified that the revisions were acceptable Based upon the above findings, this area of the licensee's program is acceptabl (2). Emergency, Alarm, and Abnormal Occurrence Procedures The inspectors reviewed emergency, alarm and abnormal occurrence procedure The licensee has an annunciator list available in the control room which the operators use to refer them to the applicable procedure. The Emergency Operating Procedures are in the form of flow charts and are readily available to operator This portion of the licensee's program is acceptabl (3). Implementing Instructions The inspectors reviewed procedure EAP-1, " Activation and Dir-ection of Emergency Plan" and determined that it provides ade-quate instructions for the Site Emergency Director to implement the Emergency Plan including, evaluation of plant conditions, performing emergency classifications, directing the emergency response organization, and assuming overall authority during the early stages of an emergency until relieved by the Corporate Emergency Director / Recovery Manager (CED/RM). After assuming the responsibility for direction and control of the emergency, the CED/RM implements the Corporate Emergency Response / Recovery Plan. Figure 7 to CPP-3 identified the augmented corporate organization and adequately covers essential functions expected in a prolonged response. Specific responsibilities which may not be delegated by the SED are identified in Section 5.2.1 of the Site Emergency Plan. Included in the non-delegable res-ponsibilities is making protective action recommendations to offsite authorities and notification of offsite emergency man-agement agencie Review of EAP-3 indicated that the SED re-ports to the CED/RM while the Corporate Emergency Plan ident-ifies the CED/RM as the individual who provides state and local interaction as well as offsite emergency measures. Clarifi-cation is needed on who will notify state and local agencies and

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make requests for federal assistance, since these are primary responsibilities of the lead responder which cannot be delegated .

(see Paragraph 3.A).

The Emergency Plan and associated implementing procedures were  ;

reviewed and compared with referenced guidance. These proce-dures are used for the implementation of the Emergency Plan, facility activation, event classification, protective action ,

recommendations, delineation of responsibility, and actual steps ,

to be followed by the emergency response personne These procedures contain decision aids and checklists to provide abbreviated references for procedure implementation by trained '

, personnel.

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The protective action recommendation (PAR) procedure, EPP-26, requires the emergency director to recommend an immediate eva-cuation of the 2 mile radius EPZ, instead of sheltering this ragion upon declaring a General Emergency. Under certain scenarios, this immediate evacuation would result in an eva-cuation of the general public into the plume pat This PAR is contrary to NRC guidance in NUREG-0654 and I&E generic letter 83-26 which recommends immediate sheltering in the 2 mile EPZ.

. The emergency action classification table, Figure 4.1 Attachment .

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1. 6 of EAP-2, for fire related emergencies, does not meet the NUREG-0654 guidance example initiating conditions for fires potentially effecting safety system The Nine Mile Point procedure requires that damage to systems preventing cold shutdown is an ALERT, and damage preventing hot j

shutdown is a SITE AREA EMERGENCY. NUREG-0654 uses the example

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of fire potentially affecting safety systems, as an ALERT, and fire damaging safety systems, as a SITE AREA EMERGENCY.

The Emergency Plan and associated procedures do not assign responsibility for dose projection to a person who would be i located in the control room at the start of an accident (before

! the TSC is activated). Although the on-shift chemistry tech- '

) nicians have received training on dose projection, there is no i

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procedural requirement for them to report to the Shift Super-visor and start initial dose projection at the commencement of i

the radiological release prior to TSC activiatio The EALs in EAP-2 do not provide the Emergency Director with appropriate indications and guidance to determine the degree of damage to the clad that would constitute barrier failure for use in classification of General Emergencie /

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The EALs in EAP-2 do not provide the Emergency Director with guidance on process monitor or control room indications that constitute potential for the failure of fission product barriers. Reference to design pressures, temperatures, coolant levels and flows are appropriate indications to assist operators or emergency directors in determining potential barrier failur The EALs in EAP-2 do not support the classification of equipment failure leading to the plant's inability to go into cold or hot shutdown, unless the cause of this eouipment failure was a fir This is contrary to the NUREG-0654 Appendix 1 guidance initi-ating conditions for Alert and Site Area Emergenc Except as noted above, and summarized below, this area is accep-tabl Change the immediate protective action recommendation upon reaching the General Emergency classification to prevent an immediate evacuation of the 2 mile EPZ if an immediate release of short duration is occurring and people would incur a higher dose during the evacuation than if they took shelter and allowed the plume to pass (50-410/86-23-08).

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Revise figure 4.1 Attachment #6 of EAP-2 to provide for classification of fires in accordance with the guidance of NUREG-0654 (50-410/86-23-09).

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Assign responsibility for initial dose projection functions to an on-shift person who would report to the Control Room at the activation of the Emergency Plan (50-410/86-23-10).

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Provide definition for the amount of clad damage that con-stitutes the failure of the cladding barrier in the EAL on barrier failure for the General Emergency. These indica-tions should be readily obtained from control room process monitors such as containment high range rudiation monitors or main steam line radiation monitors as Se'l as actual sample activity levels (50-410/86-23-11).

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Provide definitions in the EALs in EAP-2 for which com-binations of equipment or system failure would prevent the plant from proceeding to cold or hot shutduwn, such that an Alert or Site Area Emergency classification would be ap-propriat (The cause of this equipment failure should not be limited to a fire) (50-410/86-23-12).

(4). Assessment Actions The inspectors reviewed the licensee's procedures for assessing the potential or actual consequences of offsite releases of

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i radioactive materials. These procedures included EPP-1, Rad-iation Emergencies; EPP-7, Downwind Radiological Monitoring; EPP-8, "Offsite Dose Estimate"; and EPP-16, " Environmental Monitoring".

The procedures detailed the steps to be taken in the Control Room, TSC, and EOF to determine offsite dose assessment and compare the dose assessment with actual field monitoring dat The dose assessment system in use consists of a dose asse:sment computer program which utilizes automatic input from the mete-

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orological tower. The computerized system calculates whole-body, skin, and child thyroid doses from a plume released on site, at the site boundary, 2 miles, 5 miles, and 10 miles downwiad, using release rates input from the Area Radiological

Monitoring System or from environmental survey data.

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In the event the computer system is not available, a backup system utilizing the Offsite Dose Estimator (a manual calculator method using input source term and meteorological dispersion parameters similar to those used in the computer progra Another backup calculational method was in the process of de-velopment. This method will consist of an FSAR default accident

, analysis, in which the incident will be compared to the accident i

scenarios developed in the Unit-2 FSAR, for which whole body and thyroid doses at the site boundary have been determined. The second backup method was not operational at the time of the appraisal, but was expected to be operational in the near fu-tur Walk-throughs on the computerized dose assessment system proce-dures were conducted during the appraisal with the Radiological Assessment Coordinator, two chemistry and radiological manage-

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ment staff members, and three radiation chemistry technician All personnel who participated in the walk-throughs demonstrated

, the ability to use the dose assessment equipment and i procedures.

Based on the above findings, this portion of the licensee's program is acceptabl (5). On-Site Radiological Surveys The inspectors reviewed EPP-7, " Downwind Radiological Monito-ring", which was used to perform emergency onsite, out-of plant radiation surveys. For perfnrming emergency radiological sur-

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veys EPP-7, Figures 3,4 and 5 provided survey points and des-cription locations for onsite and offsite sample locations.

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Figure 1 of EPP-7 was a multi-survey data sheet for recording inplant/ downwind /re-entry information which was used by survey teams to record date, time, location, surveyor's initial, team members, instrument used, model and serial number, mode of operation, duration of reading, air flow rates, background, and count time. Figure 2 of EPP-7 was a survey team report which

identified the organization or person to whom the sample infor-mation should be forwarded for assessment, and EPP-7, section 5.1.5, e. stated that results of measurements should be trans-mitted back to the TSC or EOF, and if the radio was inoperable, to use the nearest pay telephone to report the result EPP-7 instructs the team members to return labeled air samples, both filters and cartridges, data sheets, etc., to the approp-riate organization responsible for emergency assessment func-tions. An envelope containing the necessary information was provide Based on the above, this area of the licensee's program is acceptable.

(6). In-Plant Radiological Surveys The inspectors reviewed EPP-6, "In-Plant Emergency Surveys", and EPP-6 referenced procedures which are used to perform emergency inplant r3diological surveys. EPP-6 provides procedures for station personnel to follow when performing inplant surveys and sampling operations du' ring and after an emergency, these in-cluded direct radiation measurements and air sampling performed in the course of damage control operations. Radiation pro-

- tection training was.provided by the Nuclear Training Department

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. -and emergency procedures are written from the viewpoint of the persons responsibile for performing the survey Radioactive samples are uniquely labeled using a labeled en-velope with appropriate information to identify the sample for later identification. Samples are delivered to the Chemistry Laboratory for analysis and storage. Plant survey data sheets are forwarded to the Chemistry and Radiation Protection Depart-

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/ ment Supervisor or Chief Technician in the OSC for forwarding to

the Station Survey / Sample Team Coordinator or others as directed. Portable radios ~are,6 sed as a primary means of com-munication, with the paging system and telephones as a secon-dary. Team briefings are req 6 ired to include radiation pro-tect' ion guidanc '

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Based on the above findings, this portion of the licensee's program is acceptabl /

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(7). Evacuation and Accountability Station evacuation (to on-site assembly areas) and site eva-cuation-(to an off-site, remote assembly area) are detailed in procedures EPP-5, " Station Evacuation", Rev.9 and EPP-19, " Site

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Evacuation", Rev.4, respectively. These procedures also detail the systems in place for accountability of personnel following evacuation. The assembly areas are clearly defined in the -

procedures. The time goal for completion of accountability .s (identification of those persons who have not evacuated, or whose location on-site is not known) is set at 30 minutes by _

procedure which is consistent with NUREG-0654. An account-ability demonstration has not been completed for Unit 2. This item will be reviewed in a subsequent inspection (50-410/86-23-3).

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Except as noted above, this portion of the licensee's program is acceptabl (8). Inventory, Operational Check and Calibration of Emergency

Equipment Facilities and Supplies The inspectors reviewed EPMP-2 and held discussion with licensee representatives responsible for inventory and calibration of emergency equipmen The prccedure is adequate, in that it provides an inventory listing of emergency equipment, the lo-

, cations of equipment kits and cabinets, frequency of emergency equipment inventory, and checklists for conducting inventorie Specific examples of designated emergency equipment routinely checked are: survey instruments, dosimeters, air samplers, decontamination supplies, first aid supplies, respirators, SCBAs, batteries, portable generators, and portable radio The procedure indicates that discrepancies shall be corrected within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> and delineated on the appropriate checklis Based upon the above findings, this area of the licensee's program is acceptabl . Summary of Findings and Composite Listing of Open Items

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i During the appraisal it was determined that several Emergency Preparedness '

Program areas were incomplete or required corrective action. These areas are listed as open items and are addressed within each section of this '

report and detailed below as to whether they need to be resolved prior to

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low power or full power license issuance. Items indicated by (*) are required prior to full power license, all other items are required by low

power license.

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(86-23-01): Clearly define the offsite authority /responbilities of the Corporate Emergency Director and the Site Emergency Director, and identify those responsibilities for each position which cannot be delegate (86-23-02): Conduct refresher training for operators in areas noted m s during walk-through examinations, s .

(86-23-03): The Emergency Plan or associated procedures should contain provisions to provide weather alerts or warnings of emergency weather

. conditicns to the control room. All control room operators should be aware of the provision '

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• (86-23-04): Respiratory protection devices should be provided for i . control room operators inside the habitability envelope of the control roo (86-23-05): Complete the preoperational, surveillance testing, and turnoverLof the DRM (86-23-06): Delete the reference to turbine building ambient temperature

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as indication of a steam line break in EAP- *(86-23-07): Complete, test, and equip the Unit-2 306' Level decontam-ination facility and revise EPP-15, section 15 to reflect the existence of the Unit-2 decontamination facilit (86-23-08): Changetheimmediate[rotectiveactionrecommendationupon reaching the General Emergency classification, from an immediate eva-cuation of the 2 mile EPZ, to sheltering within a 2 mile radius and 5 miles downwin ,

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(86-23-09): Revise figure 4.1 Attachment #6 of EAP-2 to provide for fire EAL's consistent with the guidance of NUREG-065 (86-23-10): Assign responsibility for initial dose projection functions to an on-shift person who would report to the Control Room at the activation of the Emergency Pla (86-23-11): Provide definition for the amount of clad damage that con-stitutes the failure of the cladding barrier (EAL for barrier failure for

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the General Emergency). These indications should be readily obtained from Control Room process monitors such as containment high range radiation monitors or main steam line radiation monitors as well as actual sample A activity levels.

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(86-23-12): Provide definition in the EALs in EAP-2 for what combinations J of equipment or system failure would prevent the plant from proceeding to cold or hot shutdown (Alert or Site Area Emergency classification). The cause of this equipment failure should nat be limited to a fire.

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• (86-23-13): Unit-2 should complete an accountability demonstration to

< assure that the 30 minute accountability time limit can be achieve . Exit Interview At the conclusion of the inspection on May 22, 1986, the inspectors met with regresentatives of the licensee (see Detail 1 for attendees) to discuss the findings of this inpsection as detailed in this report.

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At no time during this inspection was any written material provided to the license i i

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