IR 05000413/1986040

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Insp Repts 50-413/86-40 & 50-414/86-43 on 860922-26. Violation Noted:Failure to Conduct Semiannual Health Physics Drill
ML20215N010
Person / Time
Site: Catawba  
Issue date: 10/20/1986
From: Decker T, Gooden A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20215N002 List:
References
50-413-86-40, 50-414-86-43, NUDOCS 8611040170
Download: ML20215N010 (10)


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pm f t!g UNITED STATES

'o NUCLEAR REGULATORY COMMISSION

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REGION 11 n

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101 MARIETTA STREET,N.W.

's ATLANTA, GEORGI A 30323

'+,.....,d OCT 2 9 1986 Report Nos.: 50-413/86-40 and 50-414/86-43 Licensee: Duke Power Company 422 South Church Street Charlotte, NC 28242 Docket Nos.: 50-413 and 50-414 License Nos.: NPF-35 and NPF-52 Facility Name: Catawba ~1 and 2 i

Inspection Conducted:. September 22-26, 1986 Inspector:

nb A/to/B4 A. Gooden Date. Signed

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$pproved'by:

T. R. Decker, Chief Date Signed Emergency Preparedness Section Division of Radiation Safety and Safeguards SUMMARY Scope:

This routine, unannounced inspection was. conducted in the area of emergency preparedness.

Results:

One violation was identified - failure to conduct a semi-annual health physics drill.

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REPORT DETAILS

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1.

Persons Contacted Licensee Employees

  • J. W. Hampton, Station Manager
  • H. B. Barron, Superintendent of Operations
  • M. E. Bolch, Station Emergency Planner R.' E. Harris, System Emergency Planner M. T. Boyd, Director of Media Services G. G. Barrett, Training Supervisor
  • F. P. Schiffley, Licensing Engineer
  • C. L. Hartzell, Compliance Engineer
  • G. T. Smith, Super'intendent of Maintenance
  • J. W..Cox, Superintendent of Technical Services
  • W. H. Barron, Senior Instructor
  • R. B. Wilson, Maintenance / Planning Engineer
  • G. L. Courtney, Staff Health Physicists Coordinator
  • D..S. Lee, Staff Health Physicist
  • C. S. Gregory, I&E Support Engineer
  • P. C. McAnuity, Training and Safety Coordinator
  • M. Ruhe, Staff Health Physicist
  • A. Bhatnagar, Test Engineer
  • D..Simpson, Technical Specialist
  • D. Tower,-Shift Operating Engineer P. J. Loss, Shift Supervisor C. H. Skinner, Shift Supervisor J. R. ' Thomae, Shift Support Technician J. C. Leathers, Shift Technical Advisor
  • S. S. Cooper, Assistant Operating Engineer Other licensee employees contacted included engineers, technicians,

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l operators, security force members, and office personnel.

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Other Organizations

W. R. Johnston, Chief, Bethel Volunteer Fire Department i

L. L. Fincher, Jr., Director, Charlotte-Mecklenburg Emergency Management Agency L. W. Broome, Emergency Planner, Charlotte-Mecklenburg Emergency Management Agency C. E. Howell, Director, Municipal-County Emergency Preparedness Agency of York' County (SC)

J.' P. Mooney, Public Relations Counselor, Lewis. Associates E. W. Mooney, Public Relations Counselor, Lewis Associates

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~NRC Resident Inspectors

  • P. H. Skinner
  • P. K. VanDoorn
  • Attended exit interview 2.

Exit Interview The inspection scope and findings were summarized on September 26, 1986, with those persons indicated in Paragraph 1 above. The inspector described No the areas inspected and ' discussed in detail the. inspection findings.

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dissenting comments were received from the licensee.

The inspector telephoned a licensee representative on October 2,1986, to

= inform the licensee that-a Region'II review of the report details presented

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.in Paragraph 4 below (inconsistent emergency action level) resulted in'a plan inconsistency as compared to an unresolved item as discussed during the This item will be evaluated as a plan review. item and a exit meeting.

response provided in accordance with the NRC Regional Office emergency plan Also, the inspector informed the licensee representative review procedures.

that 'a Region II review of the documentation and report details in Paragraph 7 below (failure to submit implementing procedure changes to the NRC within 30 days of the effective date) resulted in-a licensee identified violation instead of an-inspector followup item as discussed during the exit.

The licensee. did not identify as proprietary any 'of the materials provided to or reviewed by the inspector during this inspection.

'3.

Licensee Action on Previous Enforcement Matters (Closed) Violation (50-413/85-29-01):

Failure to provide designated a.

emergency response training to individuals ' prior to assignment to the onsite emergency organization.

The inspector reviewed the-licensee's

~ 29, 1985, response to the Notice of Violation and discussed with August a licensee representative the actions taken to prevent recurrence. The inspector noted that Station Directive 3.8.4 (0nsite. Emergency

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Organization) and Section 0 of the Catawba Emergency Plan (Radiological Emergency -Response Training) had been revised 'to specify that an individual must participate -in emergency overview training prbr to assignment to the'onsite emergency organization.

In addition, training records ' were t reviewed for all primary personnel assigned to - the emergency organization and key personnel _with responsibilities as interim Emergency Coordinator.

Based on the records reviews and an interview with a licensee representative, the inspector had no further questions on this matter.

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(Closed) Violation (50-413/85-29-03):

Failure to fully implement the requirements of Procedure PT/0/8/4600/06 in connection with a semi-annual health physics drill.

The inspector reviewed the lice,nsee's August 29, 1985, response to the Notice of Violation and

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discussed with a licensee representative the actions taken to avoid recurrence.

A review of drills held during calendar years 1985 and 1986, indicated that documentation of drill findings were in accordance with emergency plan implementing Procedure PT/0/B/4600/06, c.

(Closed) Unresolved Item (50-413/85-29-02):

Adequate documentation to confirm training of. Shift Supervisors and other operations personnel in accordance with Catawba Emergency Plan Section 0.

A review of training records for Shift Supervisors and selected operations personnel indicated that records were maintained in an auditable manner.

Training documentation was in accordance with the Emergency Plan Section 0, and Station' Directive 2.5.1 (Station Training Program).

4.

Emergency Detection and Classification (82201)

Pursuant to 10 CFR 50.47(b)(4); 10 CFR Part'50, Appendix E, Sections IV.B and IV.C, this program area was inspected to determine whether the licensee used.and understood a standard emergency classification and action level scheme.

The inspector reviewed the licensee's classification procedures. The event classifications in the procedures were consistent with those required by regulation and thc Em?"gency Plan.

The classification procedures did not appear to contain impediments or errors which could lead to incorrect or untimely classification.

Selected einergency action levels (EALs) specified in the classification procedures were reviewed.

The inspector noted that the EAL for Condition Number 5 (primary / secondary leak rates) under the Notification of Unusual Event Classification appears inconsistent with the guidance in Appendix 1 of NUREG-0654.

The inconsistency is due to a Technical Specification action statement time limit being included.as a part of the EAL.. This matter was discussed with a licensee representative who informed the inspector that the action. statement time limit had been reviewed and approved by the NRC Regional Office.

The inspector noted that some of the EALs were based on parameters obtainable from control room instrumentation.

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 emergency.

The inspector discussed with licensee representatives the coordination of EALs with State and local officials. Licensee documentation showed that the States of North Carolina and South Carolina concurred on the Catawba EALs on July 29 and May 30, 1986, respectively.

In addition, the EALs were concurred on by Gaston County (NC) during January 1986, York County (SC) and Mecklenburg County (NC) during June 198 __

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' Interviews were held with two Shift Supervisors and one Shift Technical Advisor to verify that they understood the relationship between core status and such core damage indicators as containment dome monitor, high-range-effluent monitor, containment hydrogen monitor, and postaccident primary coolant analysis.. All interviewees. appeared knowledgeable of the various

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core damage indications'and their relationship to core status.

The-. responsibility and authority for. classification of emergency events and initiation of emergency action were prescribed in licensee procedures and in-

~the emergency plan.-

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 recommendations.

Selected Emergency Plan Implementing Procedures (EPIPs) were reviewed by the.

' inspector and discussed with licensee personnel..

The EPIPs provided directions to users concerning timely classification of accidents.

All personnel interviewed appeared to be familiar with the classification information in tue EPIPs.

Walk-through ~ evaluations involving accident classification problems were conducted with two Shift Supervisors and one Shift Technical Advisor.

All personnel interviewed promptly and properly classified the hypothetical-acc.ident situations presented to them, and appeared 'to be familiar with appropriate classification procedures.

No violations or. deviations were. identified.

5.

Protective Action Decision-Making (82202)

Pursuant to 10 CFR 50.47(b)(9) and (10); 10 CFR Part 50, Appendix E, Section IV.D.3, this area was inspected to determine whether the licensee had 24-hour-per-day capability to assess and analyze emergency conditions and make recommendations to protect the public 'and onsite workers, and whether offsite officials had the. authority and capability to initiate -

prompt protective action for the public.

The inspector discussed responsibility and authority for protective action decision-making with licensee representatives and reviewed pertinent portions of the licensee's emergency plan. and procedures.

The plan and procedures clearly assigned responsibility and authority for accident assessment and : protective action decision-making.

Interviews with members of the -licensee's emergency organization showed that these personnel understood their authorities and ' responsibilities with respect to accident assessment and protective action decision-making.

Walk-through. evaluations involving protective action decision-making were conducted with two Shift Supervisors and one Shift Technical Advisor.

Personnel interviewed were aware of the need for timeliness in making

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initial' protective action recommendations to offsite officials.

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The capability of offsite officials to make protective action decisions and to.promptly notify the public was discussed with licensee representatives.

Licensee procedures made provisions for contacting responsible offsite authorities on a 24-hour basis.

Backup communication links with offsite authorities were available.

The inspector independently confirmed that offsite decision-makers with authority for emergency resp'onse activities could be contacted via backup communications link by conducting a radio check from the Control Room with the Gaston County and Mecklenburg County warning points.

No violations or deviations were identified.

6, Notification and Communication (82203)

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

'The inspector reviewed the licensee's notification procedures.

The proced_ures were consistent with the emergency classification and EAL scheme used by the licensee.

The inspector determined that the procedures made provisions for message verification.

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The inspector determined by review of applicable procedures and by discussion with. licensee representatives that adequate procedural means

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existed for alerting, notifying, and activating emergency response personnel.

The procedures specified when to notify and activate the onsite emergency organization, corporate support organization, and offsite agencies.

Selected telephone numbers listed in the licensee's procedures for -emergency response support organizations were checked in order to determine whether the listed numbers.were current and correct. No problems were noted.

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The content of initial. emergency messages was-reviewed and appeared to meet the guidance of NUREG-0654, Sections II.E.3 and II.E.4.

Licensee representatives stated that the format and content of the initial emergency messages had been reviewed by State and local government authorities.

The-licensee's management control program for the prompt notification system was reviewed.

According to licensee documentation and discussions with licensee representatives, the system consisted of 77 fixed sirens.

As a backup system, county vehicles are available with warning and communications equipment.

A review of licensee records verified that the system as installed was consistent with the description contained in the emergency plan. Maintenance of the system had been provided for by the licensee. The I

inspector reviewed siren test records for the period August 22, 1985, to July 2, 1986.

The records showed that prior to April 4,1986, silent tests were conducted every two weeks, growl tests quarterly, and a full-cycle test annually as specified in NUREG-0654, Appendix 3.

On April 4,1986, the

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. quarterly growl test was replaced by a full cycle test; other types of test or maintenance was not affected.

According to a licensee representative, a bi-weekly silent test is conducted and the report is provided to FEMA Region IV.

Maintenance cards were available for the verification that system tests and maintenance is being performed. No offsite agency problems relating to the prompt notification system were disclosed during the inspection.

Communications equipment in the Control Room and TSC was inspected.

Provisions existed for prompt communications among emergency response organizations, to emergency response personnel, and to the public.

The installed communications systems at the emergency response-facilities were consistent with system descriptions in the emergency plan and implementing procedures.-

The' inspector conducted operability checks on the Emergency Notification System phone and the Duke Power Crisis Management Emergency Radio System.

No problems were observed.

The inspector reviewed licensee records for the period July 25, 1985 to September 4, 1986, which indicated that communications tests were conducted at the frequencies specified in NUREG-0654,Section II.N.2.a.

Licensee records also revealed that corrective action was taken on problems identified during communications tests.

For example, the January 24, 1986 test identified the OSC telephones designated for health physics as inoperable.

A work order was written and corrective action was completed on February 20, 1986.

Redundancy of offsite and onsite communication links was discussed with licensee representatives.

The' inspector verified that the licensee had established a backup communications system.

The backup system made use of the Duke Power Crisis Management Emergency Radio System, or the Station's Local Law Enforcement Radio to York County.

The inspector requested and observed an unannounced' communications and notification check using the Duke Power Radio system.

The inspector noted that the system operated properly and no problems were observed.

No violations or deviations were identified.

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Changes to the Emergency Preparedness Program (82204)

Pursuant to 10 CFR 50.47(b)(16); 10 CFR 50.54(q); and 10 CFR Part 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 of June 1985 and to note how these changes affected the overall state of emergency preparedness.

The inspector discussed the licensee's program for making changes to the emergency plan and implementing procedures.

The inspector reviewed the licensee's system (as discussed in Section P of the Catawba Emergency Plan and Station Directive 4.2.1) governing review and approval of changes to the plan and procedures.

The inspector verified that changes to the plan and procedures were reviewed and approved by management. During the review, it

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was noted that several implementing procedures had been revised since the last inspection.

However,' the licensee failed to submit these changes to the NRC within 30 days of the effective date.

This finding was also identified by the licensee and documented in a letter to the NRC Document Control Desk.

The corrective action to prevent reoccurrence was.also included in the licensee's correspondence to the NRC Document Control Desk (a letter from Hal B. Tucker to Document Control. Desk dated September 8, 1986).

According to a licensee representative, the corrective action has been implemented.

'As a result, this licensee identified violation (LIV)'

will be reviewed during a subsequent inspection.

LIV (50-413/86-40-01, 50-414/86-43-01):

Failure to submit ' implementing procedure changes to the NRC within 30 days of the effective date.

Discussions were held with licensee representatives concerning recent modifications to facilities, equipment, and instrumentation. No significant changes or modifications have been'made since the Emergency Preparedness Implementation-Appraisal (EPIA) followup inspection of May and October 1984.

The organization and management of the emergency preparedness program were reviewed. At the station level, the Superintendent of Integrated Scheduling position was reassigned since the June 1985 inspection.

The inspector's discussion -with a licensee representative also ~ disclosed that the Area 2 Coordinator's position for the South Carolina Emergency Preparedness Division had been reassigned since the last inspection.

The' inspector reviewed the licensee's program for distribution of changes to the ~ emergency plan and procedures.

Selected document control records for the period October 1985 to August 1986, showed that appropriate personnel and organizations were sent copies of plan and procedural changes, as required.

No violations or deviations were identified.

8.

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 functions.

The inspector reviewed the description (in Section 0 of-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 a formal emergency training program.

Records of training for key members of the emergency organization for the period March 1984 to September 1986, were reviewed.

The training records revealed that personnel designated as alternates or given interim responsibilities in the emergency organization were provided with

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. appropriate training.

According to the training records, the _ type, amount, and frequency of training were consistent with approved procedures.

However, it was noted during the records review that a semi-annual-health physics drill involving post accident containment air sampling which was

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scheduled for fugust-1985, then cancelled and rescheduled (for October 1985),

was' not conducted during' the calendar year 1985.

This finding is inconsistent with Section N.2.e of the Station Emergency Plan. This finding was acknow) edged by licensee representatives.. As a result, this item is identified as a violation of 10 CFR 50.54(q) which requires the licensee.to follow an. emergency plan which meets the -planning standards in 10CFR50.47(b).

Violation ~(413/86-40-02and414/86-43-02):

Failure to conduct a semi-annual health physics drill Jin raccordance.with emergency plan involving the collection of simulated elevated airborne samples from the post accide'nt containment air sampling system.

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The inspector reviewed 1985 and 1986 training records 'for various offsite support. agencies.

It was noted that training was provided in'accordance with Section'0 of the station emergency plan. Three drills were held during 1986 with various components of the offsite support agencies.(fire support.

- medical support, and a table top drill-involving several offsite agencies).-

' Attendance sheets, lesson plans, and drill objectives were available for review.

During the course 'of.the--inspection, the inspector observed

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training for State, County, and. Duke Power personnel. regarding the preparation of news releases for exercises and/or Emergency Broadcast System (EBS) messages during an actual event. This training was provided by Lewis Associates Public Relations firm.

The presentation was well organized and included a combination of lectures, demonstrations, discussions, and sessions involving news release preparations.

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In. response to -IE Information ~ Notice No. 85-80, " Timely Declaration of an g

Emergency-Plan, and Emergency Notifications," the inspector interviewed one L

Shift Support Teci.aician who is designated as an Offsite Communicator for i

the Control Room.

The offsite communicator is responsible for ~ initial communications to the offsite agencies (State and county) via the selective signaling. telephone -system.

The interviewee demonstrated familiarity with the communications equipment (including backup communications systems) and the responsibility as a communicator. A review of training records verified that the-interviewee had ' received spcialized training for offsite communicator.

-In addition, the. interviewee had served as coninunicator during an actual event at Catawba during' June 1986.

The inspector conducted walk-through evaluations with selected key members of the emergency organization. During these walk-throughs, individuals were given various hypothetical sets of emergency conditions and data and asked to talk through the response they would make if such an emergency actually existed. The individuals demonstrated familiarity with emergency procedures

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and. equipment, and no problems were observed in the areas of emergency detection' and classification, notifications, assessment action (to include

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plant conditions, in-plant sample collection and analysis), and protective

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action decision-making.

One violation and no deviations were identified in this program area.

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LicenseeAudits(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 program.

Records of audits of the program were reviewed. The records showed that an independent audit of the program was conducted by -the licensee's Quality Assurance Department (Audit Report No. NP-85-25 [CM]) on December 9,1985 to January 6,1986.

This audit fulfilled the 12-month frequency requirement s

for such audits.

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 recommendations were presented to plant and corporate management.

A review'of past audit reports indicated that the licensee complied with the five-year-retention requirement for such reports.

Licensee emergency plans and procedures required critiques following exercises and drills.

Licensee documentation showed that critiques were held following periodic drills as well as the annual exercise. The records showed that deficiencies were discussed in the critiques, and recommendations for corrective action were made.

The licensee's program for follow-up action on audit, drill, and exercise findings is the Catawba Action List File (referred to as " CALF"). Licensee procedures required follow-up on deficient areas identified during audits, l

drills, and exercises.

The inspector reviewed licensee records which indicated that corrective action was taken on identified problems, as i

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The licensee's tracking system appears to be effective as a

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management tool in following up on actions taken in deficient areas.

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No violations or deviations were identified.

10. Coordination with Offsite Agencies (82210)

The inspector held discussions with licensee representatives regarding the

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coordination of emergenc, olanning with offsite agencies.

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agreements existed with those offsite support agencies specified in the'

emergency plan, and the agreements had been renewed within the past three l

years, as required.

The inspector determined through interviews with l

representatives of selected local support agencies that the licensee was l

periodically contacting those agencies for purposes of offering training and l

maintaining mutual familiarization with emergency response roles.

Those

interviews disclosed no significant problems related to the interfaces between the licensee and the offsite support agencies listed in Paragraph 1.

No violations or deviations were identified.