IR 05000413/1989004

Insp Repts 50-413/89-04 & 50-414/89-04 on 890213-17.No Violations or Deviations Noted.Major Areas Inspected: Emergency Preparedness Program to Determine If Program Maintained in State of Operational Readiness Re Emergencies

ML20247C258
Person / Time
Site:	Catawba
Issue date:	03/13/1989
From:	Gooden A, Rankin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20247C251	List: IR 05000413/1989004 ML20247C246
References
50-413-89-04, 50-413-89-4, 50-414-89-04, 50-414-89-4, NUDOCS 8903300154
Download: ML20247C258 (9)

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t 3- ,g NUCLEAR REGULATORY COMMISSION o, f REGION 11 a 101 MARIETTA ST., N.W .

, j ATLANTA, GEORGIA 30323 e,g, MARi01988 Report Nos.: 50-413/89-04~and 50-414/89-04-Licensee: Duke Power Company ,

422 South Church Street l Charlotte.:NC 28242'  ;

g- Docket Nos.: 50-413 and 50-414 License Nos.: NPF-35'and NPF-52

Facility Name: Catawba 1 and 2 Inspection Conducted: February 13-17, 1989 Inspector: Wrfd . 3-/ 3- D j Date Signed

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A. Gooderi 1 Approved by: /3- 89 W. Rankin, Chief .

Date Signed Emergency Preparedness Section Emergency Preparedness and Radiological Protection Branc .  !

Division of Radiation Safety and Safeguards R

$UMMAPY Scope-This. routine, unannounced inspection was in the area of emergency preparednes Several . aspects of- the - emergency preparedness program were inspected to

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determine if the program was being maintained in a state of ~ operational readiness for responding to emergencies. This-included a-review of training, changes to the emergency organization, distribution of changes to the Emergency Plan and Emergency Plan Response Procedures (RPs), audit reports, augmentation i staffing, and the maintenance of key facilities and selected emergency kits or  !

j- equipmen Results No violations or. deviations were identified. Strengths were noted in the following areas: 1) there a pears to be good management support for the emergency response program; 2 an effective tracking system was maintained for 4

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ensuring that prompt and . adequate corrective action is taken on items identified during drills, exercises, and audits; 3) independent audits were detailed and comprehensive; 4) many improvements had been made facility wise  !

and. administrative 1y to increase the effectiveness of the emergency preparedness program; and 5) the onsite emergency organization was adequately staffed and trained M accordance with commitments in the Emergency Plan and Station Directives. One area where immediate improvement was needed, ir the l

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formalization of a procedure governing the testing, maintenance, and followup-testing of the Alert Notification System (ANS).

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REPORT DETAILS Persons Contacted Licensee Employees P. Boger, Training Support Supervisor R. Dove, Associate Nuclear Instructor

• R. Glover, Compliance Engineer T. Hindman, Health Physics Supervisor G. Ice, Shift Supervisor

• T. Owen, Station Manager M. Ravan, Shift Supervisor J. Sammons, Shift Support Technician

1. • D. Simpson, Station Emergency Planner Other licensee employees contacted during this inspection included engineers, operators, security force members, technicians, and administrative perscane NRC Resident Inspectors

• M. Lesser

• W. Orders

• Attended exit interview

1. Participated in telephone exit interview on February 22, 1989 Emergency Plan and Implementing Procedures (82701)

Pursuant to 10 CFR 50.47(b)(16), 10 CFR 50.54(q), and 10 CFR 50, Appendix E, this area was reviewed to determine whether changes were made to the program since the last routine inspection (May 1988), and to assess the impact of these changes on the overall state of emergency preparednes The inspector reviewed Section P of the licensee's Emergency Plan and Station Directive 4.2.1 regarding the development, review, approval, and distribution of changes to the Plan and RP The inspector noted that changes were being distributed to copy holders in a timely manner, as evidenced by the transmittal dates, and a review of acknowledgement slips for selected changes since the last routine inspection. Controlled copies of the Emergency Plan and RPs were audited in the Control Room, Technical Support Center (TSC), and Operations Support Center (OSC). The selected copies that were examined, were found to be current revision At the time of the inspection, changes incorporated as Revision 11 to the Emergency Plan were being reviewed by the Regional Office Staff, for determining if changes were consistent with NRC regulation The inspector reviewed documentation for randomly selected Plan and response procedure changes to verify that submittals were made to NRC within 30 days of the approval date. It was noted that

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all submittals were within 30 days. after the changes were made, and signatures on. concurrence sheets were consistent with those. required for concurrenc No violations or deviations were identifie . Emergency Facilities, Equipment, Instrumentation, and Supplies (82701)

Discussions were held with a licensee representative concerning modifications to facilities, equipment, and instrumentation since the last inspection. The inspector toured the onsite emergency response-facilities (ERFs) and noted that facilities were in accordance with the description in .section H of the Emergency Plan and relevant ~ response procedure Since the May 1988 inspection, the following changes had been made to key facilities and equipment:

The OSC was relocated from.the Operators Kitchen area in the Service Building to the Cable Spreading Room on the 574 ft. elevation of the Service Building. This facility was noted as being maintained in an operational mode, though not a dedicated facility. Telephones, name tags, and other administrative items were left in place rather than stored away in cabinet Cosmetic changes were made to the TSC to incorporate the relocation of the wod area for the Station Manager and Plant Superintendent New generators were installed in each of the environmental monitoring vans to ensure that adequate power was available for operating air samplers and analytical equipmen In assessing the operational status of the emergency facilities, the

'nspector verified that protective equipment, and supplies were operational and inventoried on a periodic basi Emergency kits and/or cabinets from the TSC, OSC, Emergency Sample Van, and Temporary Administration Building were inventoried and randomly selected equipment was checked for operability. The selected equipment operated properly, displayed current calibration sticker, and successful battery checks were obtained. By review of applicable procedures and check-list documentation !

198 covering the period that emergency of May(e equipment to January equipment, communication 1989, the inspector determined meteorological equipment, and emergency kits) were being checked in accordance with procedures governing such test (HP/0/B/1000/06, IP/0/B/3343/01, and PT/0/B/4600/05). The inspector requested and observed an unannounced communications check from the Control Room using the dedicated ring-down phone system to the State and local warning points; and the Crisis Management radio was tested for operability with the Mecklenburg County j warning point. The inspector also conducted a communications test with

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the NRC Operations Center from the Control Room using the Emergency Notification System (ENS). No probleins were noted; contact was established via each communications network tested. Records reviewed

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H indicated tha't all: discrepancies or problems identified during inventories l

and' communications checks were corrected in a timely manne The licensee's management . control program , for the ANS was reviewe According to discussion with a licensee representative, the current system consists ~ of 77 sirens within the 10-mile emergency planning zone. (EPZ);: -

and tone alert radios for schools, businesses, and other industrialize facilities within the plume exposure pathway. The licensee ~provided siren test records for the period July '1988 to January'1989.- The records showed that tests were being conducted at the frequency specified in Section of..the Station Emergency. Plan and Appendix 3 of_the Crisis Management Plan (cmp). When questioned regarding a- procedure which ' governs the testing and. maintenance'of the ANS, the licensee contact informed-the inspector that a formalized procedure did not exis Documentation was provided to show that the testing requirements specified in the Emergency Plan and CMP exceeded.the guidance in NUREG-0654, Appendix Further documentation-was available to show that corrective action taken in . response to failed sirens were well documented. In the event failures involved 25 percent (or more) of the sirens, notifications were made to the NRC via the EN Such notifications were made twice during the period for which records were audited (July 1988 and October 1988). However, the licensee was informed that 'the absence of a formalized procedure ' delineating responsibility for the testing, maintenance, the test acceptance criteria, and reporting / followup requirements was considered a potential violation of Technical Specification' Section 6.8.1: " written procedures be established, implemented, and maintained covering Emergency Plan implementation." The licensee acknowledged this finding regarding the absence of a formalized procedure, and the need for formalizing the current practice of a check-list for testing and followup actions; but the licensee stated that "the basis for the violation was not understood."

The inspector informed the licensee that failure to develop a procedure for implementing Section E.6 of the Plan regading testing and maintenance of the ANS was considered a potential violation of Technical Specification 6.8.1 pending further review by Regional Managemen Subsequent to the exit, the licensee provided additional details, including copies of the offsite agencies ANS testing and activation procedures (PT/01 Rev. 2, dated November 30, 1982, and PT/02, Revision 2, dated November 30, 1983). Based on the additional information and documentation to substantiate that testing was being conducted in accordance with commitments and regulatory requirements, the licensee was informed on February 22, 1989, that this matter was considered .an Inspector Followup Item. (IFI) rather than a Technical Specification violation. The licensee stated that action would be taken to develop a Compliance Manual Section Procedure for ANS testing, maintenance, and foll ow-u IFI 50-413,414/89-04-01: Formalize a procedure for ANS testing, maintenance, and follow-up action No violations or deviations were identifie _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - .

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I 4 4. Organization and Management Control (82701)

l The inspector's discussion with a licensee representative disclosed that several administrative changes had been made to ' both the normal and emergency organization since the May 1988 inspection as a result of retirement, reassignment, or promotion. Examples of changes in this category included the reassignment of personnel filling the

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Superintendents' position The individual previously assigned as Superintendent Technical Services, was reassigned to the position of Superintendent Station Services; and the individual filling the position of Superintendent Station Services was reassigned as Superintendent Maintenanc The position Superintendent Technical Services, to whom the

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Compliance Engineer reports, has ultimate responsibility for emergency

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planning. The individual filling this position was reassigned from the Oconee Statio The aforementioned changes had no impact on the operational readiness of emergency preparedness. When training and qualification records were reviewed for individuals reassigned within the emergency organization as key assessment personnel (e.g. Emergency Coordinators and accident assessment), no problems were noted. Regarding the offsite emergency organization, no changes had been mad No violations or deviations were identifie . Training (82701)

Pursuant to 10 CFR 50.47(b)(15) and 10 CFR Part 50, Appendix 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 Section 0 of the Emergency Plan, and Station Directive 2.5.2 for a description of the training program and training procedures. In addition, selected lesson plans were reviewed, and personnel with the responsibility for conducting the training was interviewed. Based on these reviews and interview, the inspector determined that the licensee had established and maintains a formal emergency training progra The inspector conducted walkthrough evaluations with selected key members of the emergency organization. Two Shift Supervisors were interviewed and given sets of hypothetical emergency conditions and data and asked tu talk through his response (as the Iterim Emergency Coordinator) as if an emergency actually existed. The interviewees were prompt and technically sound in classifying the event, and subsequent actions taken in response to the hypothesized acciden Interviewees demonstrated excellent familiarity with the emergency classification procedure (RP/0/A/5000/01)

and various other response procedures which implement the Station's Emergency Pla No problems were noted in the area of emergency detection, classification, and protective action recommendation. In addition, an interview was conducted with a Shift Support Technician designated as Offsite Communicator for the Control Room. The interviewee demonstrated familiarity with all available communication systems and the responsibility as a communicator, Further, when asked to demonstrate

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notification methodology using a backup system (Crisis Management two-way radio) to the dedicated ring down phone to State / local governments, the communicator was aggressive in gaining net control and completing the communications tes All personnel were familiar with their duties and responsibilitie Training records were reviewed for several members of the onsite and offsite support organization Names of onsite emergency response personnel were randomly selected from Station Directives 3.8.4 and 2.5.2, to verify that their training was current and included all required trainin No problems were notec'. According to a licensee contact, on a periodic basis, personnel training is reviewed for identifying those individuals whose qualification time is near expiratio This system provides for notification to the individual's supervisor that a requalification is' required. Offsite support agency training was reviewed for fire, rescu, hospital, and local law enforcement agencies. Training was conducted in accordance with Section 0 of the Emergency Pla Nc violation or deviations were identifie . Licensee Audits (82701)

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 reviewe According to documentation, an independent audit was conducted by the licensee's Quality Assurance Department during the period November 11, 1988 through January 6,1989, and documented in Audit Report No. NP-88-20(CM). The aforementioned audit satisfied the annual frequency requirement for such audits. No concerns, or significant findings were identifie The licensee's program for followup action on audit, drill, and exercise findings were reviewe The inspector reviewed a sample of 1988 exercise items to determine if corrective actions were being taken to resolve item The licensee had established a computerized tracking system known as the Catawba Action List File (CALF). It was noted that items were assigned to various individuals with a tentative completion dat Documentation from the February 1988 exercise showed that 57 items were identified; the inspector noted that only four items remained opene No violations or deviations were identifie . Shift Staffing and Augmentation (82701)

Pursuant to 10 CFR 50.47(b)(2) and 10 CFR Part 50, Appendix Sections IV.A and IV.C, this area was inspected to determine whether shift staffing for emergencies was adequate both in numbers and in functional capability, and whether administrative and physical means were available and maintained to augment the emergency organization in a timely manne The inspector reviewed Figure B-1 of the Catawba Emergency Plan and

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6 discussed with a licensee representative staff augmentation times as ;

determined by studies, drills, or call-in during actual event The '

licensee representative indicated that an augmentation drill had been conducted, but the augmentation personnel arrival times were not documente The inspector reviewed documentation for a TSC activation drill conducted on July 9,198 However, there was no documentation available to verify NUREG-0654 Table B-1 guidance. The inspector informed the licensee that, in view of commitment to meet Table B-1 augmentation staffing, a drill should be conducted periodically to verify augmentation capability. The inspector further stated that personnel turnover combined with other human factors (single parents, caring for the elderly and/or handicapped, etc.) could lead to the unavailability of emergency response personnel for meeting staffing requirements. A licensee representative acknowledged this finding and committed to conducting an augmentation drill during the calendar year 1989, for verification of Table B-1 requirements. Consequently, the licensee was informed that this matter is considered as an IF IFI 50-413, 414/89-04-02: Cnnduct an augmentation drill to verify and document Figure B-1 staffing requirements and arrival time No violations or deviations were identifie . Exit Interview The inspection scope and results were summarized on February 17, 1989, with those persons indicated 'in Paragraph 1. The inspector described the areas inspected and discussed in detail the inspection results listed below. The licensee did not identify as proprietary any of the material provided to or reviewed by the inspector during this inspectio A potential Technical Specification violation for failure to develop a procedure governing the testing, maintenance, and follow up on the ANS was discussed in detail (see Paragraph 3). Licensee management agreed that improvements were needed, including a formalized procedure; but the basis for a violation was not clear. The Station Manager indicated that the details on this matter would be reviewed in conjunction with the Technical Specification requirements for evaluating the basis of the violation. On February 22, 1989, the inspector informed the Station Emergency Planner that, based on a further review of the inspection details and information provided subsequent to the inspection, the inspection finding in Paragraph 3 (failure to develop a procedure for implementing Section of the Emergency Plan regarding testing and maintenance of the ANS)

resulted in an IF The Station Emergency Planner committed to the development of a Compliance Manual Section Procedure governing the ANS

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testing, maintenance, and followu Item Number Description / Reference 50-413,414/89-04-01 IFI - Formalize a procedure for the ANS

. testing, maintenance, and followup actions

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50-413,414/89-04-02 IFI - Conduct an augmentation drill to verify and document Figure B-1 staffing requirements and arrival times (Paragraph 7).

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