IR 05000443/1985032
| ML20153D396 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 02/06/1986 |
| From: | Harpster T, Lazarus W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20153D392 | List: |
| References | |
| 50-443-85-32, NUDOCS 8602240133 | |
| Download: ML20153D396 (20) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGION I-Report No.
50-443/85-32 Docket No.
50-443 License No. CPPR-135 Priority Category B-1
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Licensee: Public Service of New Hampshire P.O. Box 330 Manchester, New Hampshire 03105 Facility Name:
Seabrook Unit 1 Inspection At: Seabrook, New Hampshire Inspection Conducted: December 9-13, 1985 Inspectors:
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W.4erzarugSenior HP Specialist
' date W. Thomas, EP Specialist C. Amato, EP Specialist C. Gordon, EP Specialist J. Hawxhurst, EP Specialist G. Bryan, COMEX Corporation G. Wehmann, Bat elle Approved by:
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M4 8h T. Harpstei,' Chi if, Emergency. Preparedness
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Section Inspection Summary:
Inspectifn on December 9-13,1985 (Report No.
50-443/85-32)
g Areas Inspected:
Emergency Preparedness Implementation Appraisal to evaluate the adequacy and effectiveness of the emergency preparedness program for Seabrook Unit 1, including organization, administration, procedures, training and facilities and equipment. The inspection involved 340 hours0.00394 days <br />0.0944 hours <br />5.621693e-4 weeks <br />1.2937e-4 months <br /> by 7 NRC inspectors and contractor personnel.
Results: No violations were identified.
Several areas were identified in which appraisal would have been premature, as equipment, procedures, and training had not been substantially implemented.- These were not appraised, and will be reviewed in a subsequent inspection.
9602240133 960219 PDR ADOCK 05000443.
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DETAILS 1.
Persons Contacted A. Callendrello, Emergency Preparedness Supervisor P. Casey, Senior Emergency Planner
- W. DiProffo, Assistant Station Manager.
i S. Ellis, Security Department Supervisor
- J. MacDonald, Radiological Assessment Manager
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- D. Moody, Station Manager W. Otto, Emergency Planner
- J. Quinn, Director of Emergency Planning
- G.. Thomas, Vice President - Nuclear Production
- L. Walsh, Operations Manager The inspectors also interviewed several licensed operators, health physics, administrative and training personnel.
- Denotes those present at the exit interview.
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Scope of Appraisal The purpose of this appraisal was to determine the readiness of the
Seabrook Station to implement the Emergency Plan 1in preparation for licensing. The principal criteria for-this appraisal arel 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 appraisai addressed the areas of: emergency response procedures,~ facilities and equipment, the emergency organization, and training.
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3.
Sur. mary of Results The appraisal was not completed during this inspection because several-of the areas under review had not been sufficiently completed or were under revision. This prevented performance of an adequate evaluation. This report documents the appraisal of~those. areas for which review was completed during this inspection. The remaining = areas (and those items'
indicated as open items in this report) will be reviewed in a subsequent inspection.
Items which need to be addressed for resolution are summarized as "open items" at the end of each section of the report.
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Details i
A.
Administration of the Emergency Plan The inspector reviewed the applicant's provisions for management'
control of the administrative aspects of emergency planning to verify that responsibilities were'clearlyfassigned, appropriate authority was granted,. provisions for coordination with other-
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licensee and offsite organizations were defined, and personnel selection / qualification criteria for emergency planning personnel were established and implemented.
(1) Assignment of Responsibilities and Authority The. emergency planning responsibilities' are. described in l
Section 12.5 of the Emergency Plan, the Nuclear Production l
Organization Chart of 9/30/85, and the Seabrook Station Job.
l Specifications for the Radiological Assessment Manager, Senior
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Emergency Planner, and the Emergency Plan Training Coordinator.
l The Radiological Assessment Manager is assigned the-overall responsibility for the emergency preparedness program. His I
staff consists of an Emergency Preparedness Supervisor, a
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l Senior' Emergency Planner (addition of a second Scnior Emergency Planner has been approved), and an Emergency Plan Training Coordinator. With the exception.of the Emergency Preparedness Supervisor, job specifications were available for each member of the staff, which clearly defined responsibilities and authorities. The job specification has not yet been developed for the Emergency Preparedness Supervisor or the second Senior Emergency Planner. The' organization is established with.the Radiological Assessment Manager reporting to the Vice President l
Nuclear Production. Although the Radiological Assessment Manager and his staff are physically located on site, and apparently maintain a close liaison with the site organization,
their interface with the site management organization is not.
clearly defined in any organization charts or procedures.
Since the Rad Assessment Manager is not one of the station
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managers, he is nct represented on the Station Operations Review Committee.
The Emergency Preparedness Supervisor will function as a deputy to the Radiological. Assessment Manager. At the time of the inspection, both the Radiological Assessment Manager and the Emergency Preparedness Supervisor had been assigned additional duties of onsite and offsite EP coordination. Both are reporting to a person designated as
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Director of Emergency Planning.
This arrangement is not described in any organization charts or procedures, and has l
the effect of-_ requiring the Radiological Assessment Manager to take direction from two different sources. This was indicated.
to be'a temporary arrangement which will be discontinued prior.
to licensing.
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The following item need to be addressed in this area:
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' Develop job specifications for the Emergency Prepared-.
ness Supervisor'and the second Senior Emergency, Planner.
(50-_443/85-32-01)
(2) Coordination of EP Functions Part of the review of. responsibilities and a'uthorities-
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l discussed above included an assessment'of the effectivetess-
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of coordination of EP functions between cognizant groups.
The responsibilities for coordination of EP.. functions rests with the Radiological Assessment Manager. The interface with the Station Manager and his operations staff is not-
-defined. -The Radiological Assessment Manager indicated that he maintains close liaison with-the Station Manager and attends the weekly Station Mana'ger's meetings. 'He also attends SORC meetings, if.necessary, to present EP -
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procedures / revisions for approval. 1This interaction'of~
i the corporate EP staff with' station management needs~to be-
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clearly defined and documented.
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The following item needs to be addressed in this area:
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Define and. document the interaction between the.
corporate EP staff and the station staff.
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(3) Selection and Qualification of-EP Personnel-The job specifications reviewed for the Radiological Assessment Manager, Senior Emergency Planner,.and the l.
Emergency Plan Training Coordinator include appro-l~
priate minimum qualifications for the-respective
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-positions extracted:from.the guidance of ANSI /ANS 3.1-1978. A review of the qualification of,these individuals revealed that:the qualifications were met or exceeded in each case. As noted'in (1) above, a=
job specification has nat yet been developed for the Emergency Preparedness Supervisor. When developed this will cantain the appropriate minimum qualifica-i.
L tions for the position.
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'Except as noted for the items which.still need to be addressed by the applicant, the' management control of
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ness program were acceptable.
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B.
Station Emergency Organization (1) Onsite Organization The inspectors reviewed Section 8, " Organization" and Appendix A, " Emergency Response Organization Position' Defini-tions" of the Emergency Plan. The inspectors held discussions with applicant personnel regarding the on shift emergency organi-zation and the augmented emergency response organization.
During the initial phase of an accident primary emergency duties are carried out by control room and station (on-shift) personnel.
At augmentation, the Plan describes designated management struc-tures for the Control Room, Operations Support Center, Technical Support Center, Emergency Operations Facility, Media Center, and corporate support from the Yankee Nuclear Services Division (YNSD). However, the plan does not provide a complete organiza-tion chart to describe overall command and control, and flow of information in each response facility.
Lines of succession within each emergency facility from coordinator to working level are described. Definitions of emergency titles for each augmen-ted organization position provide a breakdown on response loca-tion, activation level, immediate supervisor, key responsibi-lities, and individuals of the normal organization designated to fill each emergency position.
Upon review of the position descriptions for the on shift organization, the inspectors found that performance and evaluation of dose assessment is not included as one of the key responsibilities.
Emergency activ-ities are carried out by personnel assigned to functional areas as follows: emergency response coordination - Response Manager, plan systems operation - Unit Shift Supervisor, operational assessment - Emergency Operations Manager, radiological and environmental monitoring - Offsite Monitoring Coordinator, repair /
corrective actions - OSC Coordinator, radiological accident assessment - Dese Assessment Specialist, radiation protection -
OSC Coordinator, technical support - TSC Coordinator and YNSD, manpower planning and logistical support - Administrative and Logistics Coordinator.
Direction and Control of emergencies, including initiating emergency actions and notification of off-site authorities, is ensured at all times beginning with the Short Term Emergency Director (Unit Shift Supervisor) who is relieved by the Site Emergency Director (Shift Superintendent),
and finally the Response Manager in the EOF.
Although a training manual which includes established selection criteria has not been completed, individuals i.ssigned to carry out important response functions have work experience relevant to their emergency dutie.
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The following items need to be addressed in this area:
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Develop a comprehensive crganization chart which describes overall command, control, and information flow for emergency response facilities and each major element of the augmented organization.
(50-443/85-32-03)
Assign the responsibility to perform dose assessment in
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the control room and revise Appendix A of the Emergency Plan accordingly.
(50-443/85-32-04)
(2) Augnentation of Onsite Emergency Organization Following declaration of an Alert or higher emergency classi-fication, the onsite emergency response organization is augmented through shift personnel. When the E0F becomes acti-vated, a New Hampshire Yankee (corporate) representative fills the role of Response Manager to provide overall direction and control.
Section 12 of the Emergency Plan describes.the official duties of the Response Manager to direct the emergency, but does not indicate which authorities and responsibilities may not be delegated. Additional corporate support is provided to Seabrook (and other Yankee nuclear facilities) from the Yankee Nuclear Services Division on an as-needed basis as part of the Yankee Mutual Assistance Plan (YMAP). Appendix'B of the Emer-gency Plan identifies commur.ications/information coordination, technical support, environmental services, radiological moni-toring, and meteorological monitoring as services available through the YMAP.
Provisions for augmenting key onsite functional areas for a prolonged period of time are unavailable. The line of succession for the following supervisory elements are limited to one alternate in the positions of Response Manager, Site Emergency Director, Emergency Operations Manager, EOF Coordinator, Technical Assistants, Training Coordinator, Radiological Assistants, and Offsite Monitoring Coordinator.
Greater depth in the line of succession is needed for these positions in the event that the primary or alternate responder is unavailable.
Figure 8.15 of the Emergency Plan describes staffing for the initial phase (on shift) and augmentation phase during emer-gencies. The individuals assigned to major functional areas during each phase exceeds the minimum staffing requirements of Table B-1, NUREG-0654. The inspectors observed an emergency drill (held for training) on DecenSer 12, 1985 and determined that the number of rmercancy response staff assigned by the:
applicant is adequite. Arrangements are in place for represen-
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tatives from both the architect engineer and the NSSS vendor to provide technical assistance to the emergency organization when needed.
Local service arrangements are specified for obtaining ambulance, hospital, fire. fighting, and medical support but letters of agreement were found to be outdated.
In addition, the inspectors met with Seabrook Fire Department officials and found that fire fighting support will not be provided onsite (inside the protected area) until the training manual for off-site personnel is approved and training of fire fighters is completed. Discussions with applicant representatives also indicated that radiolcgical equipment and supplies to treat contaminated injured personnel at Exeter Hospital were not available at the medical facility.
The following items need to be addressed in this area:
Identify authorities and responsibilities of the Response
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Manager that may not be delegated.
(50-443/85-32-05)
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Provide additional qualified alternates in the line of succession for supervisory elements of the augmented organization.
(50-443/85-32-06)
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Complete all arrangements with local service groups to ensure o#fsite support will be available when needed.
(50-443/85-32-07)
C.
Facilities and Equipment An inspection was performed of the emergency facilities and equipment which were substantially complete at the time of this inspection, to determine whether the applicant would be able to effectively and efficiently respond to the scope of emergencies described in the Emergency Plan and procedures. The following facilities were inspected.
(1) Offsite Laboratory Facilities The inspector reviewed the applicant's provisions for offsite laboratcry facilities for adequacy of fixed facilities, equip-ment, procedures, and training of personnel to staff the offsite
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laboratory facilities.
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Fixed dedicated offsite laboratory analysis equipment including a Multi-Channel Analyzer (MCA) was located in the sample
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analysis room of the Emergency Operations Facility (EOF). All environmental. monitoring and evaluation will be directed from the EOF. All emergency planning arrangements for the station including area maps and emergency response procedures were available for review at the EOF.
During the appraisal it.was
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noted that the MCA was inoperable due to a failed amplifier module. A working module was obtained from the plant for the drill, but was returned to the plant when the drill'was completed.
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In addition to the fixed radiclogical analysis. equipment.
located.in the EOF, Seabrook Station has full access to the Nuclear Services Division Mobile Environmental Laboratory, and the services of Yankee Environmental Laboratory in Westboro,'MA.
for emergency environmental sample activities. The mobile laboratory equipment' includes. a four wheel drive vehicle which can be outfitted with a gamma spectroscopy system and a data
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l processing computer. The mobile laboratory facility could be
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available for emergency environmental sample analysis at the EOF within one and one half hours after a request from Seabrook.
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Inventory, operational checks and calibration of the EOF-
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radiological analysis equipment, facilities, and supplies was
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spelled out in ER-8.1, " Emergency Equipment and Facility Inventory and Preparedness Check (DRAFT)".
This procedure provided a specific inventory listing of all EOF equipment-reserved for emergency use.
The procedure'also specified the equipment location, a quarterly inventory, operations check,-and.
calibration for emergency instrumentation. Operations checks-and inventory of emergency equipment was assigned to the admini-strative services representative who audits emergency prepared-ness document control areas. All discrepancies were to be reported to the Radiological Assessment Manager for corrective action.
l Adequate provisions have been made for offsite laboratory.
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capability utilizing both fixed and. mobile radiological analysis equipment.
The following item needs to be addressed in this area:
Assure that all dedicated amergency equipment (specified in pro-cedure ER-8.1) located at the E0F is maintained in an operable l
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condition. (50-443/85-32-08)
(2) Assembiy/ Reassembly Areas The inspector toured the onsite and offsite Seabrook Station assembly areas accompanied by the Sr. Emergency Planner.and the Health Physics Foreman.. During the tours the facilities desig-nated as assembly areas in the Emergency Plan were inspected for adequacy of location, capacity, supplies, and radiological
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protection factors. On site assembly areas consisted of the-t I
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-9 OSC,- Health Physics' Access Control Paint and the lower' level of the turbine building. Offsite assembly areas consisted of the Seabrook Greyhound Park / Route 107 warehouse and the E0F.
All assembly / reassembly areas were located as specified in the Emergency Plan and Implementing procedures.
Primary. Assembly areas located onsite were adequately equipped and large enough
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for operations under emergency conditions to accommodate all assigned personnel. Offsite assembly areas were located to facilitate ease of egress from the site-and were large enough to accommodate all relocated site personnel. The onsite facility locations were selected to ensure personnel
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radiological safety. Adequate provisions for respiratory protection equipment for emergency workers had not been made at the time -
the appraisal, since the respiratory protection program has' not been implemented.
As a result of this inspection it was determined that the assembly / reassembly area facilities were adequate for operations under emergency conditions.
The following item needs to be addressed by the applicant:
Implement the respiratory protection program and assure that adequate supplies of respiratory protective equipment are maintained at the onsite assembly areas for emergency workers. (50-443/85-32-09)
j (3) Medical Treatment Facilities The inspectors reviewed Procedure ER-4.4, "Onsite Medical Emergency" of the Emergency Plan and determined that.it ade-quately covers steps to be taken for treatment of contaminated /
injured personnel. The inspectors also observed the'first aid and nurse's stations located next to the Health Physics Access
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Control Point and determined that the facilities contain no first-aid equipment or supplies. Telephone communications were available and information transmitted via the plant paging system were audible in the area. Discussions with plant admints-trative personnel indicated that a full time nurse is not
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expected to be permanently assigned on staff until early 1986.
The following items need to be addressed in this area:
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Complete and equip the first aid treatment facility to
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allow treatment of contaminated / injured personnel.
(50-443/85-32-10)
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Assign a full-time nurse onsite as described in the Emergency Plan.
(50-443/85-32-11)
(4) Decontamination Facilities During the appraisal the applicant's decontamination facilities located onsi.te and offsite were inspected. Decontamination supplies and procedures were reviewed and a tour of each-facility was conducted.
Provisions have been made for personnel and equipment decontami-nation at each personnel assembly / reassembly area and at the Health Physics Access Control Point near the onsite medical treatment facility. Decontamination procedures were available at each location. Water and decontamination chemicals and supplies were available at each facility.
Radiation detection instrumentation, extra clothing, and provisions.for disposal of liquid and solid wastes were also available at each facility.
Decontamination procedures were contained in ER-3.3, " Emergency Operations Facility Operations," ER 4.3, " Radiation Protection During Emergency Conditions," and ER 4.6,. "Offsite Monitoring and Decontamination."
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As a result of this inspection it was determined that the onsite and offsite decontamination facilities were adequate for
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l use under emergency conditions.
(5) Expanded Support M ilities
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j During the appraisal the applicant's expanded support facilities j
were inspected and ER-3.3, " Emergency Operations Facility (EOF)
Operations" was reviewed. A tour of the EOF was conducted.
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The applicant has provided dedicated work space and resources for corporate officials, contractors, 'and the states of New Hampshire and Massachusetts response personnel at the EOF.
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Dedicated primary and' backup' communication links were provided~
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at the EOF for communication with.the site,-states, and local
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governmental organizations within the 10 mile EPZ.
As a result of this inspection it was determined that the.
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applicant's expanded support facilities, equipment, and'
procedure for operation of the EOF were adequate for operations
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under emergency conditions.
(6) Transportation The inspector reviewed Section 10.5.2 " Medical Transportation" of the Emergency Plan, inspected the onsite ambulance, and held discussions with applicant and contractor personnel. The
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ambulance currently used to transport injured personnel is owned and operated by a contractor (UE&C) and is available for NH Yankee personnel through contract agreement.
Discussions with contractor personnel revealed that-this vehicle is intended to be used for transportation of injured-only (non-contaminated)
individuals to area hospitals, and that they would rely on off-site fire departments to handle contaminated / injured personnel.
This appears to conflict with the Emergency Plan which states that the station ambulance will be used to transport injured and contaminated personnel. Also, the Letter of Agreement dated June 13, 1983 indicates that UE&C personnel are to receive annual training on how to handle contaminated / injured individuals, but no training has been provided to them in this regard. During inspection of the UE&C ambulance, the inspectors found that no radiation protection and radiation monitoring equipment is stored or maintained.
The following items need to be addressed in this area:
Ensure that arrangements for transportation of onsite
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contaminated / injured personnel are permanently available and clearly described in plans / procedures, including equipment and supplies for contamination control.
(50-443/85-32-12)
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Provide appropriate training for ambulance personnel as stated in the June 13, 1983 Letter of Agreement between Public Service Co. of NH and UE&C.
(50-443/85-32-13)
D.
Control Room Operator WalkTtroughs (1) The inspector requested that the applicant schedule all six control room operating crews to participate in walkthroughs to determine the effectiveness of EP training. Although all six were scheduled, only four crews (C-F) were actually observed as the appraisal was concluded early. As requested, the applicant made the Shift Superintendant (SS), Unit Supervisor (US), and two R0s per crew available.
Since Seabrook policy requires that the SS be STA certified, each crew also included an STA. The walkthroughs were conducted in the simulator and lasted approximately two hours each.
(2) Crews C, E, & F participated in actual walkthroughs using a scenario developed for the purpose. Crew D was observed during the utility training drill held on 12/12; that observation was considered equivalent to a walkthrough.
The inspector made the following findings:
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EPIP ER-2.2 (Rev. 02),
Paragraph 3.2 (et al), is not consistent with 10 CFR 50.72-in that it fails to require notification of the NRC immediately after state and local notification and within one hour.
b.
Paragraph 5.3 of the same procedure lists one or more-incorrect alternate NRC phone numbers (e.g. (301) 952-0550 listed vs. (301) 951-0550),
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Form ER-212A, " Initial Notification Fact Sheet," is the form used to accomplish initial state notification (also via the state, local agency notification). This form does not indicate whether a release is taking place (NUREG 0654 II.E3).
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None of the crews was able to accomplish the dose assess-ment problem postulated.
That function is assigned to the STA (SS). They had not yet been trained on dose assessment.
Equipment (HP-41CV calculators with programs for the dose assessment problem) to be used for control room dose projection was not available.
(NUREG-0654 II.0 and II.1)
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A sample review of EPIP ER-1 (Rev. 01), " Classification" indicated that:
A fire which is contained and controlled and potentially affects safety systems should be classified as an Alert; and, An uncontrolled, uncontained fire affecting safety systems should be classified as a Site Area Emergency.
Contrary to that guidance, a contained, controlled fire actually affecting safety systems should be classified as a Site Area Emergency (NUREG-0654, App. 1, initiating condition 11),
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During the walkthroughs, 49 situations requiring classi-fication of accident conditions were presented to the crews. Thirteen classification errors were made for an error rate of 26%.
(Classification errors are measured with respect to Seabrook documentation, not NRC require-ments).
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When asked to identify source material for evacuation time estimates, one of 2 crews questioned was unable to do so.
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Three crews were unable to evaluate static conditions of containment intact and dome monitor readings of 20,000 R/HR with respect to the questions:
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Is a release in progress?
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Have EPA guidelines been exceeded at or beyond the site boundary?
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Shift crews were not aware of the range of information which could be obtained from samples taken by the Post-Accident Sampling System (PASS).
(3) Due to the above observations and the specific supporting procedure / training problems identified, this item will remain open. This open item includes the specific items above, and training of all crews on accident condition classification.
(50-443/85-32-14)
E.
Emergency Plan Training / Retraining During the appraisal the applicant's emergency preparedness plan training / retraining programs were reviewed to determine whether the programs had been established and implemented, whether the programs were adequate in scope and content, and whether all personnel assigned emergency plan duties had been trained in accordance with the established program.
Interviews were conducted with the Training Manager, Radiological Assessment Manager, Training consultant staff members, Seabrook Station staff members, and offsite. emergency responders. Available lesson plans, and attendance recoras were reviewed, and an emergency plan drill was observed.
(1) Program Establishment and implementat,1,on a.
Descriptian and Respon.cibilties The applicant has a formally documented and approved emer-gency plan training / retraining program. At the time of the appraisal, emergency prepareoless training was being conducted by a consultant.
The applicant plans to assume the training effort in this area by the middle of 1986.
Emergency Plan Implementing Procedure ER-8.2, " Emergency Preparedness Training," dated May 14, 1985 describes guidance for the initial training and periodic retraining
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of personnel having assignments in the Seabrook Station Emergency response organization.
ER-8.2 assigns the responsibility for ensuring the adequacy of the content of the Emergency Preparedness Training Program to the Radio-logical Assessment Manager (RAM). The RAM is also assigned the annual review of the Emergency Plan Training Manual, providing updates of primary and alternate emergency response organization assignments to the Training Manager, and updates of changes in procedures or equipment to the Training Manager.
The Training Manager is assigned the training program development: implementing the training program, develop-ing the Emergency Plan Training Manual, and developing training modules for offsite organizations that respond on-site.
The Training Manager is also assigned the duties of providing for and assuring adequate provisions for retraining of all personnel and maintena.1ce of training records for each member of the Emergency Response Organi-zation. At the time of the appraisal, the Scabrook Station Emergency Plan Training Manual was incomplete.
The applf>
cant should complete the training manual to ensure that the training program scope and content are evaluated ard approved by Seabrook management, and that changes to the program receive adequate review and approval.
The inspector reviewed the training matrices in Attachments 7.1, 7.2, and 7.3 to ER-8.2, and reviewed the associated lesson plans which were available.
The personnel training categories were consistent with the described station
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emergency preparedness organization and the required training was consistent with the designated emergency response functions stated in the emergency plan.
(2) Summary of Results As a result of this appraisal of the applicant's emergency training and retraining program it was determined that reappraisal of this area will be necessary in a subsequent inspection.
The following items need to be addressed prior to reappraisal:
(50-443/85-32-15)
Complete and implement the Emergency Plan Training Manual.
- Specify the initial qualification criteria for selection of
personnel for assignment to the Emergency Response 0 ganiza-tion.
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Assure that all lesson modules required by ER-8.2 are prepared,
approved, and available for use.
Assure that all training instructors meet or exceed the quali-
fication standards of ANSI /ANS-3.1, or Table 1 on INP0-82-026.
Include the emergency preparedness training qualification policy
details in the training manual, and document all training instructor qualifications.
Revise the Emergency Support Group training modules to stress
the expected role of each specialty group.
Assure that methods for training personnel in changes to proce-
dures and equipment shall be similar to the methods used for the basic qualification program.
Assure that an adequate number of trained and qualified indivi-
duals are available to provide as a minir um both a primary and a backup to staff each of the senior posit: ens within the Emer-gency Response Organizations listed in Attachments 7.1, 7.2, and 7.3 of ER-8.2.
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Facilities and Equipment (1) Emergency Operations Facility (EOF)
The inspectors reviewed a description of the Emergency Opera-tions Facility (E0F), section 6.1.3 of the Emergency Plan, toured the facility and observed an integrated emergency response drill which included utilizing EOF personnel and equip-ment.
The EOF and supporting equipment were evaluated against acceptance criteria in: NUREG-0696; HUREG-0654; Supplement I, NUREG-0737; and, the guidance provided in TI 2515/55.
Specific areas were reviewed to determine the following:
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There are provisions for an EOF to coordinate emergency response activities.
The facility and equipment have been fully described in the
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plan.
The equipment and supplies are installed and operational.
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A surveillance procedure has been developed to properly maintain the facility and equipment.
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The E0F is located approximately-14 miles-north of Seabrook at Newington Station on. Gosling Road.in Newington, New Hampshire.
The E0F is _a dedicated facility and will serve as a base for management:
of overall licensee emergency response.
It also serves as the-forward -field offir.e for the State of New Hampshire.
The emergency communications network, which will be fully evaluated in a subsequent inspection, was installed and operable 'in the EOF,.
except for the NRC red phone. -The equipment maintained ct the EOF was not fully described in the Emergency Plan, Appendix E.3 or in procedure ER-3.3, " Activation of the Emergency Operations-Facility". Some equipment such as the plant process computer-terminal, decontamination shower, status boards, and forms were not-operable or complete. Plant information such as copies of
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building prints, drawings and manuals were available on aperture cards, hard copy, and thru the FINIS document control system. The EOF had sufficient assembly space, offices and cnnfere.ce rooms to accommodate the Emergency Response Manager and staff the NRC, and the States of New Hampshire and Massachusetts.
Overall operation and layout of the E0F during the integrated drill aopeared to be adequate relative to having the necessary equipment and facility layout.
Except for the below items which still need to.be addressed by the applicant, the Emergency Operations Facility (EOF) aspects of the emergency. preparedness program were acceptable.
The following items need to be addressed in this area:
Completely describe EOF equipment in Appendix E.3 to the
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Emergency Plan or procedure ER-3.3 (50-443/85-32-16).
Complete installation of EOF equipment.(50-443/85-32-17).
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(2) Media Center (Emergency News Center)
The inspector reviewed Section 6.1.6, " Media Center" of the Emergency Plan, toured the facility and observed part of an integrated emergency response drill which utilized key personnel-in the center.
The media center was reviewed against the following guidance.
There are provisions for a media center, and the
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facility'and equipment have been fully described in the plan.
The equipment, supplies and personnel are sufficient'in
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numbers and type to' perform the established function.
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Surveillance and activation procedures are established to.
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ensure timely setup, availability and operation _of equip-ment in the facility.
The Media Center is located at the Newington Town Hall, approx _imately 14 miles north of the Seabrook site in Newington, New Hampshire.
.The Media Center, when activated, will provide telephone service (approx. 30 phones); large work area;= briefing hall with a PA system; schematics and audio visual equipment; and, administrative supplies.
In addition, a communication network is established with the EOF from which Press Releases formulated by the Emergency News Director are-received. These releases are disseminated and explained by the'
Emergency News Manager at the Media Center. The facility is activated at the Alert level or above or at the discretion of the Emergency News Manager.
The Emergency News Manager and staff monitors the news media, maintains rumor control, coordinates-the flow of information concerning plant conditions to the news media and manages the acti-vities of Seabrook News Services. The duties and responsibilities of personnel associated with the Media Center have been described as well as the organization, information flow and function of the group.
The facility layout and equipment are adequate to support this function. However, the details for the facility, equipment and organization are currently only in draft and are not part of station controlled procedures and policy documents (i.e. Emergency Response Procedures and Plan).
(50-443/85-32-18)
Except as noted above, the media center (Emergency News Center)
aspect of the emergency preparedness program were acceptable.
(3) Meteorological Instrumentation The inspector reviewed a description of the meteorological monitoring program, and visited the onsite tower and control room. The program was reviewed against acceptance criteria in RG 1.97, RG 1.23, NUREG-0654, Supplement 1 - NUREG-0737 and the review elements established in TI 2515/55. The review guidance includes the following.
Meteorological instruments provide the basic parameters
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required by the emergency plan and procedure.
All instruments are adequately described and maintained.
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Surveillance procedures have been established and imple -
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mented to ensure operability.
Backup meteorological data is available,
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Supplemental meteorological parameters have been considered
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that are representative of the EPZ, in the vicinity of the site (up to 10 miles).
Backup power is available to the meteorological tower and;
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Equipment is installed or-provision made to notify the
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control room of " severe" weather.
The applicant outlined the characteristics of the meteoro-logical monitoring program and provided the inspector with the System Design Description for Meteorological Monitoring at Seabrook Station, (Draft 11/28/84). A partial description and outline of the instrumentation, monitoring location and data acquisition system were also included in FSAR_, Section 2.3.3 and Emergency Plan, Section 6.2.3.1.
The licensee indicated that the system was not in final form and would be modified.
The Seabrook Station maintains a 210 foot high meteorological tower with~ wind speed and direction measurements at 43 and 209 feet, and vertical temperature differences between 43 and 150 feet and between 43 and 209 feet.
The tower is located approxi-mately 1700' NNW of the Unit 1 containment structure. The meteorological tower and instrument shelter were visited by the inspector.
The meteorological tower can provide basic. wind speed, wind direction and delta temperature measurements needed to calculate atmospheric dispersion. The program does not include backup or supplemental meteorological measurements. Data availability for dispersion calculations over the last five years of data compiled ('79
'83) ranged from a high of 99.3% to a low of 84.1%. The yearly data unavailability goals were exceeded only once over this 5 year period.
In addition during the passage of hurricane Gloria (9/27/85) both wind sensors failed at approxi-mately 70% their design extreme wind. speed of 100 mph. The licensee stated that the new meteorological calibration and maintenance contract contains a clause for 24hr response to fix instruments after a problem has been identified. The licensee also. indicated that a recurring problem of an underground cable flooding was corrected by installation of a new above ground conduit.
Surveillance on the tower and equipment,is performed, twice weekly by I&C personnel and NSD in Framingham, MA. through remote interrogation.
The daily channel checks required by
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Preventive mainte--
nance and calibration checks are performed semi-annually which is consistent with the requirements.
The'. latest calibration e
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19 procedure for Delta Temperature (DT) IX1654.410, Rev. 2 was found to be inadequate. The required accuracy of the system as indicated in the procedure (DT<t 0.2C), is much less restrictive then the Root-Sum-Squared system accuracy committed to in the FSAR Table 2.3-28a of a DT < 0.18F. (0.10C), which conforms to guidelines established in R.G. 1.97.
The inspector verified that real-time meteorological data was available at the instrument building and control room; however, the plant computer only provided instantaneous values. No historic data was available (24 hrs).
Presently, forecast data can be obtained over the phone from NSD in Framingham, who will access the WSI weather information system.
It is planned for the system to be modified to provide for 15 minute average values, and to procedures to be developed for direct access of WSI.
The following items need to be addressed in this area:
Finalize the meteorological monitoring system design,
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consistent with the FSAR commitments and revise the program description in Section 6.2.3.1 of the Emergency Plan and Section 2.3.3 of the FSAR (50-443/85-32-19).
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Provide for backup meteorological measurements represen-tative of conditions in the vicinity of the site and provide for backup power to the instrument building (50-443/85-32-20).
Provide a method of severe weather notification to the
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control room (50-443/85-32-21).
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Implement T.S. 6.9.2 surveillance on the meteorological monitoring program (50-443/85-32-22).
Modify calibration procedure IX1654.410, Rev. 2 for Delta
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Temperature to properly consider accuracy requirements and use more specific terminology (50-443/85-32-23).
Provide the basic data required for atmospheric dispersion
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calculations (15 minute averages), which includes a time history (analog or digital printout) of wind direction and speed at each level and temperature difference with height in the control room and EOF (50-443/85-32-24).
In addition, the following should be considerations of coastal environments reviewed to ensure protective action recommenda-tions are accurate:
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Surface wind flow reversals due to mesoscale frontal
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passages.
The return of effluents onshore that had previously
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drifted over water during the prior night's land breeze.
Encapsulation of plumes in retura flow layers aloft.
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Inland wind. shifts at convergente zones.
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Exit Interview A meeting was held with the licensee representatives at the conclusion of the inspection (see detail 1 for attendees), to disucss the scope and findings of this appraisal as described in this report.
At no time during this inspection was any written material provided to the licensee.
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