ML20053A228
| ML20053A228 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 04/21/1982 |
| From: | Cohen I, Crocker H, Defayette R, Mojta M, Allison Robinson, Matthew Smith Battelle Memorial Institute, NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20053A219 | List: |
| References | |
| 50-277-81-28, 50-278-81-31, NUDOCS 8205250109 | |
| Download: ML20053A228 (37) | |
Text
{{#Wiki_filter:. U.S. NUCLEAR REGULATORY COMMISSION REGION I Report No. 50-277/81-28 50-278/81-31 Docket No. 50-277 50-278 DPR-44 License No. DPR-56_ Priority Category C Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name: Peach Bottom Atomic Power Station Inspection At: Delta, Pennsylvania Inspection Conducted: December 7-17, 1981 ' ncMc _ b2[22 - Inspectors: _ _ _ _R. W DeFayette, N -E date NRC Appraisal Team Leader M. Mojta, NRC I. Cohen, NRC M. Smith, Battelle Laboratories A. Robinson, Ba telle Laboratories Approved by: j M,- M kh [date [k H. W. Crocker, Chief / Fmergency Prepardness Section Region I Form 12 (Rev. February 1982) 8205250109 820429 PDR ADOCK 05000277 G PDR
TABLE OF CONTENTS Page Summary 3 1.0 Administration of Emergency Plan 4 1.1 Responsibility Assigned 4 1.2 Authority 4 1.3 Coordination 4 1.4 Selection and Qualification 4 2.0 Emergency Organization 5 2.1 Onsite Organization 5 2.2 Augmentation of Onsite Emergency Organization 6 3.0 Training / Retraining 7 3.1 Program Established 7 3.2 Program Implemented 7 4.0 Facilities and Equipment 8 4.1 Facilities 8 4.1.1 Assessment Facilities 8 4.1.2 Protection Facilities 14 4.1.3 Expanded Support Facilities 15 4.1.4 News Center 15 4.2 Emergency Equipment 16 4.2.1 Assessment Equipment 16 4.2.2 Protective Equipment 18 4.2.3 Emergency Communications Equipment 19 4.2.4 Damage Control / Corrective Action and Maintenance Equipment and Supplies 21 4.2.5 Reserves 21 4.2.6 Transportation 22 5.0 Procedures 22 5.1 General Content and Format 22 5.2 Emergency, Alarm and Abnormal Occurrence Procedures 23 5.3 Implementing Instructions 23 5.4 Implementing Procedures 23 5.4.1 Notifications 23 5.4.2 Assessment Actions 24 5.4.3 Protective Action 33 5.4.4 Security During Emergencies 35 5.4.5 Repair / Corrective Actions 36 5.4.6 Recovery 36 5.4.7 Public Information 37 1 /
TABLE OF CONTENTS (Continued) P3Le 5.5 Supplementary Procedures 37 5.5.1 Inventory, Operational Check and Calibration of Emergency Equipment, Facilities and Supplies 37 5.5.2 Drills and Exercises 38 5.5.3 Review, Revision and Distribution 38 5.5.4 Audits 39 6.0 Coordination with Offsite Groups t,0 6.1 Offsite Agencies 40 6.2 General Public 40 6.3 News Media 41 7.0 Drills, Exercies and Walk-Throughs 41 7.1 Program Implementation 41 7.2 Walk-Through Observations 42 8.0 Personnel at Fntrance Interview 44 9.0 Persons Contacted During Appraisal 44 10.0 Personnel at Exit Interview 45 2
SUMMARY
The appraisal of the state of onsite emergency preparedness at the Peach Bottom Atomic Power Station (PBAPS) involved seven general areas: Administration of the Emergency Preparedness Program Development; Emergency Organization; Emergency Training; Emergency Facilities and Equipment; Procedures Which Implement the Emergency Plan; Coordination with Offsite Agencies; and Walk-throughs of Emergency Duties. This appraisal was performed in lieu of certain routine inspections normally conducted for emergency preparedness. The appraisal team reviewed selected procedures and representative records, inspected emergency facilities and equipment, observed work practices and interviewed personnel. Deficiencies were identified which the licensee committed to correct within four months and completion dates were agreed upon between the licensee and the inspection team. These deficiencies were as follows: updated emergency procedures were not always ava.lable to all personnel with response roles a number of emergency procedures were in need of revision training for emergency response personnel was insufficient No designated emergency coordinator existed onsite augmented staf fing did not meet the criteria of Table B-1 of NUREG-0654 the emergency organizational relationships between corporate headquarters and site personnel was not clearly defined it was not clear that the stack sampling system would give results representative of actual releases In addition to these major deficiencies, the team identified about 60 other items which it believed needed imprevement. The licensee is being asked to respond in writing to each of these items and to discuss how it will resolve these concerns. These resolutions will be inspected during a follow-up appraisal. 3
1.0 Administration of Emergency Plan 1.1 Responsibility Assigned The Director, Radiation Protection Section, Generation Division, Nuclear, serves as the Emergency Planning Coordinator. He is on the corporate staff in Philadelphia and has overall coordination responsibility for development and uodating of both the Peach Bottom and Limerick Emergency Plans. This responsi-bility is in addition to his duties as Director of the Radiation Protection Section. He has recently added another member to his staff to help in emergency planning (EP). There is no individual at the site formally appointed as a Site Emergency Planning Coordinator. One individual in the Performance Test Emergency Group was recently told that he would handle these duties but no formal assignment was made and few individuals on the site staff are aware of it. Although there is no formal job description for the position, this individual does not appear to have the necessary background and experience at the present time to enable him to coordinate all emergency planning activities at the site nor is he aware of all the requirements for emergency planning. 1.2 Authority The responsibilities assigned to the corporate Emergency Planning Coordinator are supported with the necessary authority. The position is located in the Electric Production Department and the Office oi + H .ce President of the department retains overall responsibility and authority. During the appraisal, the inspectors were verbally informed by the Senior Vice President, Nuclear that he has recently requested the Emergency Planning Coordinator to report directly to him on EP matters, in addition to reporting through his normal management chain. This Senior Vice President also stated that he is now taking an active interest and role in Emergency Planning. 1.3 Coordination Coordination of all emergency planning matters, ooth onsite and offsite, is the responsibility of the Emergency Planning Coordinator. This includes being responsible for the EP budget and for obtaining letters of agreement with offsite agencies. However, the auditors noted a lack of communication in some instances between site personnel working on emergency planning matters and the Corporate Emergency Planning Coordinator. This could be the result of insufficient definition of the interaction between site and corporate personnel, or simply that it is difficult for someone removed from the site to keep abreast of events at the site. The site staff reports to, and is responsible to, the Station Superintendent. Without a well-defined position of Site Emergency Planning Coordinator, a corporate person may find it difficult to keep fully informed of station staff assignment changes. 1.4 Selection and Qualification There are no specific selection criteria established for personnel responsible for emergency planning, but the selections in the case of corporate personnel are based on the individuals' normal responsibilities and accepted industry practice (radiological health personnel). Two of these persons have been to 4
the FEMA /NRC Accident Assessment training course. In the case of the individual recently informally assigned emergency planning duties, it does not appear to the inspectors that any specific criteria were used. It appears it may have been a case of making the assignment where it would have the least impact on normal operations. Based on these findings, improvements in the following area is required to achieve an acceptable program: Prepare a job description for the Site Emergency Planning Coordinator position which describes the responsibilities and authorities for coordinating all emergency response planning and preparedness functions at the Peach Bottom Atomic Power Station. (277/81-28-01; 278/81-31-01) i 2.0 Emergency Organization 2.1 Onsite Organization The auditors verified that an onsite emergency response organization is defined and there is reasonable assurance that it can be implemented. This verification was done by interviewing many of the personnel with assigned emergency duties as described in Chapter 5 and Figures 5.2 and 5.4 of the Emergency Plan to determine that they understood their duties and are capable of implementing them. The organizational response is divided into 2 phases, interim and permanent. The interim response organization is headed by an interim emergency director who remains in control until the emergency director reports on site. The primary interim emergency director is the shift superintendent and the alternate is the shif t supervisor. The primary emergency director is the Station Superintendent and the alternate is the assistant Station Superintendent. The director is supported by teams in the folicwing functional areas: radiation protection, rersonnel safety, security, and fire and damage control. Although there are nc specific selection criteria for individuals who serve on the teams, the selection is based on the normal working duties of these individuals. The licensee has also developed a headquarters emergency team which will activate an emergency control center on the seventh floor of the Philadelphia Electric Company Building in Philadelphia. Although the intent of the licensee is to have the headquarters emergency center provide support to the site teams, the organizational chart in Figure 5.4 does not reflect this. The Figure shows the Headquarters Emergency Control Center as being in overall charge of the emergency response with all organizations, including the TSC and the EOF reporting to it. In reality, the EOF is the location for coordination of the overall licensee response, and the TSC is responsible for technical decisions regarding plant operations. All other organizations support these roles. The organizational chart gives an impression that the headquarters' control center can "second guess" the site although both site personnel and corporate personnel informed the inspectors this was not the intent or desire of the headquarters team. Based on these findings, improvements in the following area is required to achieve an acceptable program: 5
S Clarify the emergency response organizational concepts (especially Table 5.4 of the Emergency Plan) to show the EOF as the primary emergency coordination location (the TSC retains the primary responsibility for plant operations). All other organizations which provide support including corporate organizations, will provide this support through the E0F Director. (277/81-28-02; 278/81-31-02) 2.2 Augmentation of Onsite Emergency Organization The licensee has made provisions for augmenting the onsite emergency organization with outside support such as local service organizations, INPO, other utilities, Federal Agencies, and consultants (see EP-209). These can be requested directly by the Interim Emergency Director, Emergency Director, or the Site Emergency Coordinator. The licensee states that he cannot, however, meet the augmentation criteria of Table B-1 of NUREG-0654. By letter dated April 3, 1981, from Joseph Gallagher to Darrell Eisenhut, the licensee proposed a permanent staffing and augmentation plan of 15 persons on-shift at all times, rather than the 10 required by the criteria. He would augment those 15 persons with an additional 23 people within 60 minutes. (The Table B-1 criteria requires 11 additional people in 30 minutes and another 15 people in the next 30 minutes.) After 60 minutes, therefore, the licensee would have 38 people onsite or 2 more than required by Table B-1. The inspectors recognize that Peach Bottom is a very remote site and it would be extremely difficult to meet the guidance of Table B-1 for site staff aug-mentation. However, the licensee states in hie April 3, 1981 request that the EOF Director can be onsite within 60 minutes. The inspectors were told by this individual that it would take considerably longer than that because he must depart from his residence near Philadelphia. The licensee further stated in his April letter that overall direction of facility response would be assumed by the EOF Director when all centers are fully manned and that the direction of minute-to-minute facility operations would remain with the senior manager in the TSC or in the control room until the EOF Director arrived. While it is logical to have the senior manager remain in control until the E0F Director reports onsite, the inspectors believe he would be too preoccupied in the TSC or the control room to devote the required attention to the EOF. The inspectors also recognize that a recently issued procedure (EP-203) discusses the activation of the EOF by the Radiation Protection Team Leader. While the inspectors have no objections to this individual activating the EOF, they do not believe he is qualified to serve as Interim EOF Director. In some cases he is a member of management and could be a health physics "B" technician. In addition, he has other responsibilities as a team leader. Based on these findings, improvement in the following area is required to achieve an acceptable program: Expand on your letter to the NRC dated April 3,1981, to describe how the shif t personnel discussed in the letter will fulfill the intent of the functions listed in Table B.1 of NUREG-0654 for 30 minute augmentation. Describe your plan for assuring that a plant staff manager will be onsite in about 60 minutes to assume the role of EOF Director. Demonstrate by unannounced drills that additional specified persons in the proposed staffing plan can be onsite in about 60 minutes after initial notification. Records must be kept. (277/81-26-03; 278/81-31-03) 6
3.0 Training / Retraining 3.1 and 3.2 Program Established and Implemented The licensee's program for training and retraining personnel assigned to emergency duties is outlined in Section 8.1.1 and Table 8.1 of the emergency plan. The licensee was committed to begin implementation of the training program no later than April 1981. Contrary to the program as outlined in the emergency plan, no formal training program existed and very little training had been completed prior to appraisal. The licensee has recognized this and recentJy began development and implementation of such a formal program. A new emergency training coordinator has recently been appointed; however, the major responsibility for development and implementation of the training program is being handled by a consultant. Although the lecture portion of the new program has recently begun (December 1981), the program as a whole has not been fully and formally written and approved. The inspectors reviewed part of the new training program, attended classes in progress and interviewed consultants and members of the licensee staff responsible for it. The inspectors also reviewed some tis (training instructions) from the new program. The licensee's program, when approved and implemented, will contain provisions for training and retrain-ing licensee staff (site and corporate) and county, State and local support organizations on a yearly basis. The training program will consist of classroom lecture and hands-on training with documentation of attendance and performance for both types of training. The licensee training staff said that practical hands-on training with immediate supervision and on-the-spot correction would be an integral part of the training. The consultant and licensee personnel were developing the hands-on portion of the program during the appraisal. A tentative starting date for the formal hands-on training was given as January 11, 1982. The program should contain procedures for abbreviated emergency training of augmentation personnel (e.g., contractors, HPs, vendors, etc.) brought in during an emergency. This training should be in addition to the GET (general employee training) presently envisioned by the training staf f. In addition, the program should contain criteria by which emergency preparedness instructors may be selected and qualified. In the training sessions observed by the inspectors, the method of instruction was lecture. Performance testing was by written examination at the end of a lecture covering an emergency procedure or concept. No handouts or note-taking were observed in the two sessions audited. The auditors discussed with some of the training staff the use of handouts to enhance student retention. In particular, the handing out of appropriate emergency procedures during the lecture is encouraged. The instructors had prepared for one lesson a summary sheet containing pertinent elements of the emergency organization in block form and a side-by-side listing of personnel titles in the emergency organiza-tion and normal operations titles. The sheet also contained a listing of EPs and normal operating procedures and team assembly areas appropriate to the emergency function. This single summary sheet should be distributed to the students for their own reference. Interviews with licensee emergency personnel confirmed that very few had been through any formal emergency training in addition to a general overview lecture. 7
Some of the personnel had been appointed to their positions only days to weeks before the appraisal. There was a general lack of understanding among licensee personnel as to their position and responsibility in the emergency organization. In addition, some of the personnel interviewed did not have or had not seen the new emergency procedures. Based on these findings, improvement in the following area is required to achieve an acceptable program: Complete the development of and formalize the emergency preparedness training program for Peach Bottom personnel having emergency response roles and supporting personnel. Promptly conduct training to assure that several individuals are fully trained in each functional area described in the Peach Bottom emergency response organization. (277/81-28-04; 278/81-31-04) In addition to the above findings, the following matters should be considered for improvement: Develop emergency preparedness instructor selection and qualification criteria. (277/81-28-05; 278/81-31-05) Develop a procedure for emergency training of augmentation personnel during an emergency. (277/81-2G-06/ 278/81-31-06) Increase the use of handouts and other instructional aids in emergency training classes. (277/81-28-07/ 278/81-31-07) 4.0 Facilities and Equipment 4.1 Facilities 4.1.1 Assessment Facilities 4.1.1.1 Control Room The auditors examined the control room as an emergency facility and found the following: Emergency plans and implementing procedures are available in the multi-unit control room for Units 2 and 3. Emergency action levels were understood and instruments were marked with the trip levels which would be used by the operators to initiate emergency actions and provide an indication of the event classification. The control room was supplied with respiratory protection and self-contained breathing apparatus. The necessary equipment to assist in dose assessment such as the map of the EPZ and overlays used to establish the dose profile in the plume pathway were present. 8
o Meteorological information was available to the operations personnel. Since Units 2 and 3 shared a common multi-unit control room, communication between units are automatic and readout of instruments between units are readily available. Portable radiation monitoring equipment was assigned to the control room. A continuous air monitor for the room air was in place and operable. Monitors were in place and operable for the intake air to the control room. All required communication lines were installed. Based on these findings, this portion of the licensee's program is acceptable. 4.1.1.2 Technical Support Center The interim Technical Support Center (TSC) is located on the second floor of the Unit 1 Administration Building which also would function as an Emergency Operations Facility (EOF). The permanent TSC is to be located on the third floor of the same building. The inspectors discussed with the licensee the route from the control room to the interim TSC and noted that a time and exposure evaluation was not performed by the licensee for the transverse between facilities. The proximity of the permanent T5C to the Control Room will be reviewed and evaluated by the Emergency Preparedness Development Branch. The auditors noted that the Particulate, Iodine and Noble Gas Monitor (PING) had predetermined alarm setpoints that would signal TSC personnel to activate the isolation system per EP-201, Rev. 1. " Technical Support Center Activation." The inspectors noted alternate radiation monitoring methods to verify habitability were not addressed in this procedure. During a tour of the interim TSC facility, the inspectors were informed that the PING-A2A was not operational. Additionally, the inspectors noted that a Maintenance Request Form (MRF) was not issued to correct this deficiency until the auditors discussed this issue with plant management. The PING was repaired by the time the appraisal was completed. Other equipment and supplies available in the interim TSC included: Closed circuit TV monitor Up-to-date drawings and procedures such as: FSAR, Plant Operating Procedures, Emergency Operating Procedures, Tech Specs, Emergency Plan and Implementing Procedures, Plune EPZ site maps, and as-built plant schematics. Offsite Radiological Kits and status boards for displaying plant and survey data. 9
The auditors noted that office supplies, isopleths for dose assessment and a clock were not available during the initial inspection of the TSC. (During the I appraisal isopleths for the TSC were made available as well as some office supplies.) Communication in the form of dedicated phone lines between the TSC, CR, OSC, assembly area and Load Dispatcher (Load Dispatcher has the ability to contact State agencies) were installed and operational. In addition, an ENS line to NRC:HQ was installed in the TSC. Three unrestricted commercial lines were also available in the TSC but none were specifically dedicated for NRC use. The licensee stated that contact would be made with NRC-Region I to coordinate the equipment for NRC-assigned work locations. Based on these findings, this portion of the licensee's program is acceptable, but the followng matters should be considered for improvement: Provide a backup method to verify the habitability of the TSC. (277/81-28-08; 278/81-31-08) Develop a procedure which reflects: the current TSC which encompasses the EOF; activation of this singular facility; and a diagram of working spaces for TSC and EOF functions including equipment allocation. (277/81-28-09; 278/81-31-09) 4.1.1.3 Operations Support Center As stated in the Emergency Plan (Section 7.1.3) the Operations Support Center (OSC) was located in the Plant Operations Trailer in the turbine building at elevation 165' The OSC was stocked with various routine maintenance tools but no dedicated emergency equipment kits were available. In addition, no radiation protection equipment was available within the OSC although an immediate action to verify habitability of the OSC was 1.:luded in EP-202, Rev. 1, " Operations Support Center Activation." The licensee did not provide an estimate of the dose rate which would be expected in the OSC during a design basis accident. However, the licensee had made adequate provisions for a backup facility at the offices within the Control Room boundary. (A second entrance would be available for use by OSC personnel to limit interference with plant operations activities.) Offices within the Administration Building were indicated as another alternative. Jammunications between the OSC, TSC and Unit 2 and 3 Control Room consisted of the plant page system, dedicated telephone lines and commercial telephone lines. Based on these findings, this portion of the licensee's program is acceptable, but the following matter should be considered for improvement: Provide dedicated maintenance and radiation protection survev equipment within the primary OSC location. (277/81-28-10; 278/51-31-10) 10
4.1.1.4 Emergency Operations Facility (EOF) The auditors toured the Emergency Operations Facility (EOF) and determined that the EOF was part of the general office housing the interim TSC and would use the supplies, equipment and communications available in the TSC. (See Section 4.1.1.2.) The auditors noted that EP-203, Rev. O, "Energency Operations Facility (EOF) Activation," was redundant in some action steps that were addressed in EP-201, " Technical Support Center Activation," and gave the impression that the two response centers were located within different facilities. During the appraisal, the licensee was in the progress of revising procedure EP-203 to reflect the current facility design. Based on these findings, this portion of the licensee's program is acceptable, but the following matters should be considered for improvement: See finding related to section 4.1.1.2. (277/S1-28-09; 278/81-31-09) 4.1.1.5 Post-Accident Reactor Coolant Sampling The licensee has two locations on the 165-foot level for access to primary coolant. These sample locations were installed during the original con-struction of the plants. The location with the shortest access route has two isolation valves which are operated from the control room. This location permits sampling while minimizing the radiation exposure to persor,nel taking the sample and has an area radiation monitor near the sample station. The second locatian provides samples of the reactor coolant prior to entry into the coolant cleanup system. This location is nearer to the reactor and required a longer time to reach the sample location. It has the advantage of having a continuous flow which eliminates the need for long flushing times to clear the lines and obtain a representative sample of the reactor coolant. This location does not have an area radiation monitor near the sample station. The apparatus list in HP0/CO-122 lists the sample bottle size as a 30 ounce plastic bottle. During the walk-through chemistry personnel used a 100cc plastic sample bottle with a cap which was handled with 24-inch tongs. The smaller bottle size is desirable and the apparatus list should be changed to reflect the bottle size used to take the sample. The tools, equipme ', plastic bags and the plastic bottles were readily available. A dedicated survey meter was assigned to chemistry and the technicians were trained to use the instrument. The transport of the sample was accomplished by grasping the bottle below the lid flange with the 24-inch tongs and carrying the Dottle at arm's length. This will give a dose to the person carrying the bottle which will depend on the sample volume and the concentration of radioactive material in the coolant. A sample volume of 10 ml in the bottle with a concentration of one curie per ml would give whole body dose that would be unacceptable under the ALARA concept when shielding would reduce this dose. The handling and analysis of the sample after reachirg the laboratory as provided by procedure HP0/CO-128 eppeared adequate. The auditors reviewed the status of the new post-accident sampling system to be installed to meet the NUREG-0737 requirements. The installation was near 11
completion in Unit 3 and installation is scheduled during the next refueling outage for Unit 2. This matter will be reviewed during a future inspection. Based on these findings, this portion of the licensee program is acceptable, but the following matter should be considered for improvement: Provide a procedure and equipment for transporting post-accident reactor coolant samples to the laboratory to minimize the radiation dose to personnel. (277/81-28-11; 278/81-31-11) 4.1.1.6 Post-Accident Containment Air Sampling and Analysis The licensee had an installed capacity to sample at three levels in the drywell and at two points in the torus. The sampling system provides for the measurement of the noble gases, the particulates and iodine in the containment atmosphere. The noble gas monitoring system is being supplemented by ion chambers installed in thimbles in the drywell to measure the gamma radiation emitted by the radioactive material in the drywell atmosphere. The maximum range of this ion chamber system is 1. 0 E 8 R/hr. The containment atmosphere sampling system provided for taking gas samples from the system used a syringe which would be transported to the chemistry laboratory for analysis. The chemistry laboratory was equipped to measure high-level samples with calibrated geometries out to 30 centimeters from the surface of the GELI detectors. The auditors also checked on the status of the installation of the high-level drywell monitoring system for Unit 2. Installation is scheduled during the refueling outage ea-ly in 1982. The equipment installation and personnel training will be e'.amined during future inspections. Based on these findings, this portion of the lice 1see's program is acceptable. 4.1.1.7 Post-Accident Gas and Particulate Effluent Sampling and Analysis The Samplirg station was located in the base of the exhaust stack. The exhaust from the gland packing system, the standby Gas Treatment system, and the containment purge tanks from Units 2 and 3 exhaust up through the base of the stack. This exhaust air is diluted with outside air. Under accident conditions, water vapor may be present with the fission products in the exhaust air. The dilution air from the outside will cool the exhaust air from the reactor and may reduce the temperature of the exhaust gases below the dew point. This could cause the vapor to condense in the stack and collect on the roof of the sampling location in the base of the stack, carrying with it low vapor pressure solids such as iodine. This could increase the radiation levels at the sampling location. The sampling system design does not currently provide for remote handling of the charcoal sample cartridges and no shielded containers are provided to transport the sample cartridge back to the laboratory for analysis. Samples are obtained by drawing the exhaust air through approximately 200 feet of 3/4" stainless steel sampling line. Although the line was heat-traced and insulated to reduce the condensate, the auditors question if such a system 12
would give a representative sample of the effluent at the top of the stack during accident conditions. If sufficient iodine were to condense on the walls of the 200-foot sample line, the amount of lodine in the sample wrald be lower than is actually present in the exhaust. This could lead to the release of more radioactive material than would be indicated by the sample analysis. The auditors could not evaluate the deposition of iodine and particulates in the line and suggest that this be evaluated. l Based on these findings, improvement in the following area is required to achieve an acceptable program: Perform an analysis of the stack sampling system to verify that samples are representative, and if they are not, provide a description of necessary remedial actions and a schedule for their completion. (277/81-26-12; 278/81-31-12) l In addition, the following items should be considered for improvement: Determine if the sample station in the base of the stack would be habitable during accident conditions. (277/81-26-1?,278/S1-31-13) Provide a procedure to ensure safe transport of the exhaust stack air samples and cartridges. (277/81-Z6-14; 278/81-31/14) 4.1.1.8. Post-Accident Liquid ~ffluent Sampling The routine chemistry program provides for the analysis of liquids prior to release to the environtent. In addition, even though the licensee has adaressed the post-accident sampling of reactor water samples from sample sinks following an accident, he has not provided a procedure for post-accident sampling of liquid effluents in such places as sumps, storm drains, or other such release points. The HP0/C0 series of procedures are adequate to cover the handling and analysis of the samples, but are not sufficient to cover the taking of the samples. Based on these findings, this portion of the licensee's program is acceptable, but the following item should be considered for improvement: Develop a procedure for identifying locations and taking liquid effluent samples follnwing an accident. (277/81-28-15; 278/81-31-15) 4.1.1.9 Offsite Laboratory Facilities The auditors determined through discussions with members of the engineering staff that the licensee was in the process of establishing a laboratory in the offsite Unit 1 administration building. The laboratory will be equipped to determine conductivity and pH and to measure the concentrations of chlorides, hydrogen, oxygen, and boron. It will also be capable of isotopic analysis and the measurement of gross beta and gamma activity and alpha activity as neces-sary for post-accident sampling measurements. The licensee has presently contracted with Radiation Management Corporation to perform these measurements. 13
Based on these findings, this portion of the Licensee's program is acceptable. 4.1.2 Protective Facilities 4.1.2.1 Assembly / Reassembly Areas The assembly areas are at the North utility building, (primary assembly area), the presidents' utility building (alternate assembly area) and the Delta service building (alternate assembly area). The North utility building is about I mile from the north gate. The presidents' utility building is a few hundred yards from the south gate. The Delta service building is about 6 miles from the north gate and about 4 miles from the south gate. The primary assembly site (North utility building) contains an emergency kit containing first aid supplies, protective clothing, respirators, dosimeters, decontamination aids, and other emergency supplies. A duplicate kit is kept at the Delta service building and the licensee stated that a third kit will also be placed in the presidents' utility building "soon". The assembly areas are not stocked with portable survey instruments although there are 4 friskers at the EOF which will be taken to the assembly areas, and discussions with the licensee's health physics personnel indicated that during a site evacuation personnel would pick up portable survey instruments and carry them to the assembly areas. Tne presidents' utility building and the North utility building are equipped with both commercial and plant telephones and the Delta service building is equipped with commercial telephones and radio communications. Based on these findings, this portion of the licensee's program is acceptable. 4.1.2.2 Medical Treatment Facilities The auditors examined the licensee's medical treatment facilities. There are two facilities where medical treatment may be administered. One is located offsite, adjacent to the site fence near the north gate and is used for first aid and routine medical treatment including blood counts. The offsite facility could be used for emergency treatment of noncontaminated personnel or personnel with minimal contamination. An onsite first aid room is located off the access co ridor leading to the Radwaste Building Control Room on the 135-foot level. The room contains a stainless gurney, mobile shielding, iodine tablets, bandages, instruments and other appropriate first aid supplies. The room is across the hall from a decontamination facility. There are no portable survey instruments or respirators stored in the medical facility, however, the equipment is readily available nearby and emergency procedures specify health physics personnel with instruments would accompany the injured / contaminated employee. Based on these findings, this portion of the licensee's program is acceptable. 4.1.2.3 Decontamination Facilities The auditors toured the onsite personnel decontamination facilities which were 1ccated in the Radwaste Building near a roll-away door for easy access by first aid teams and ambulance. The provisions included a two-head shower stall, sink for washdown, a cabinet with decontenination supplies (e.g., mild soap, potassium permanganate, sodium bicarbonate and sponges), an HP-210 probe with scalar and the routine decontamination procedures HP0/CO-7, Rev. 3 and HP0/CO-6, Rev. 5. All liyuid wastes would be sent to waste control tanks and 14
solid radioactive waste would be put into a container which is provided for that purpose. Offsite provisions for decontamination at assembly / reassembly areas were available at three locations. The auditors toured the North sub-station, 1 Presidential Utility Building and Delta Service Building and found that a source of water and mild soap was available at each building. The Delta Service Building was designated as the primary decontamination facility in section 7.1.8 of the Emergency Plan and also provided showers and a locker-room dressing area. The auditors noted that no special provisions for removing radioiodine from the skin were available, nor were replacement clothing nor data sheets to track monitoring and decontamination efforts for all evacuated individuals. During discussions with the licensee, the auditors were informed that decontamination emergency kits had been purchased from RMC and shat the licensee was awaiting delivery. The inventory listings of these kits were not available during the appraisal. Based on these findings, this portion of the licensee's program is acceptable, but the following matter should be considered for improvement: Provide appropriate supplies to enable decontamination and record tracking for the number of persons that might be expected during an emergency. (277/S1-28 16;278/31-31-16) 4.1.3 Expanded Support Facilities The auditors reviewed with the Corporate Emergency Planning Coordinator the provisions for expanded support facilities. It was indicated that the locations provided would be either the President's Utility Building or the Administration Building of Unit 1, which are existing habitable structures, or trailers would be provided with services within the North Sub-Station Area. The inspectors could not find any reference within the Emergency Plan or Implementing Procedures as to the expanded support facilities. Based on these findings, this portion of the licensee's program is acceptable, but the following item should be considered for improvement: Document within the Emergency Plan those facilities planned for use for expanded support. (277/81-25-17; 278/81-31-17) 4.1.4 News Center The auditors examined the Emergency News Center which is located within the Philadelphia Electric Company owned Muddy Run Recreation Park. The News Center is located approximately 5 miles from the Units 2 and 3 power stations. Upon activation of the News Center during events such as alert or higher, the licensee will evacuate visitors fecm the park and control admission to the park by st.tioning security personnel at the single entrance to the park. 15
. - - - - _ _ _ _ = _ _ _ - - __ - I j l The News Center could accomodate approximately 300 people and is provided with rest rooms, heat, 110 volt electric service, audio-visual equipment, 48 telephone jacks and packages of handouts for the media, but the telephone service is not yet operational to the 48 jacks. Upon activation, the News r Center would be provided with a portable paging system, tape recorders, copy g machines, and portapacs for additional power. i Based on these findings, this portion of the licensee's program is acceptable, but the following item should be considered for improvement: l Complete the installation of the telephone service at the Muddy Run News Center. (277/81-28-18; 278/81-31-18) 4.2 Assessment Equipment i i l 4.2.1 Emergency Equipment i j 4.2.1.1 Kits and Survey Instruments i The auditors reviewed the emergency kits and survey instrumentation which were shown to the auditors by members of the licensee's staff. The licensee has prepositioned supplies and instrumentation in several locations. Two kits for offsite surveys are located in the E0F area of Unit 1. The security guard at i the entrance to Unit 1 controlled the key to E0F lockers contain N the kits. The kits contained air sampling equipment, including 2 units which are powered from car batteries and 2 conventional electric powered. Each kit in the EOF included a geiger counter, friskers and ion chamber (500 R max range) to determine dose levels and appropriate anti-C clothing and supplies for 2 men per kit. The onsite survey kits will also shortly receive a high range i (20,000 R max range) ion chamber. The kits also contained a SAM II instrument to measure iodine and particulate activity. The licensee stated that he was trying to locate the technical specifications and instructions and would have them shortly. The licensee could not produce information to indicate the ability to detect and measure iodine levels in the air of at least 1 E - 7 uCi/cc in the pre-sence of noble gases. Similarly, there was no assurance that the licensee could measure particulate activity in the air of 1 E - 9 uCi/cc (Cs-137 j equivalent). Based on these findings, this portion of the licensee's program is acceptable but the following items should be considered for improvement: Include high range survey instruments in the emergency kits. (277/81-28-19;278/81-31-19) J Demonstrate and document the ability to detect radioiodine in the presence of noble gases and particulate radioactivity in the air as required by NUREG-0654. (277/81-28-20; 278/81-31-20) i 16 ! ~ _ _ _... _
I l 4.2.1.2 Area and Process Radiation Monitors The auditors reviewed the area radiation and process radiation monitors as shown within Sections 7.3.1.b.2 and 7.3.1.b.3 of the Emergency Plan and held discussions with the shift supervisor and technical assistants responsible for calibration concerning their use, operation, means of calibration, calibration procedures, performance, and placement within systems to reflect intended use. The auditors located the readouts for all of the monitors stated within the Emergency Plan. All readouts were readily observable on a control room panel except the high range drywell monitors whose readout was at the 135' elevation. The Unit 3 drywell high range monitors (4) had been installed and were in operation; however Unit 2 monitors were due for installation during February 4 1982, after shutdown of the unit. All annunciations of monitors within the control room are acknowledged by a reactor operator. If the alarm for the monitor does not reset, the cause of the alarm is investigated by checking the panels for instrumentation defects i and checking associated systems. If a monitor is believed to be faulty, it is tagged and a maintenance request form is prepared. If the monitor reading of the tripped monitor is determined to be real, the shift supervisor is notified. Calibrations are performed annually over a range of checkpoints for each monitor except for main steam line monitors which are performed during refuel-ing and the off gass monitors which are calibrated weekly. All monitor systems have redundant power supplies. 1 Based on these findings, this portion of the licensee's program is acceptable. I 4.2.1.3 Nonradiation Process Monitors Section 6.2, paragraph 2 of the Emergency Plan states, "Important parameters which may be needed by the Emergency Director include but are not limited to primary system pressure, primary coolant temperature, drywell sump pump-out rate, containment pressure, relief and safety valve operations." Dara-graph 7.3.1.f, states " Process monitors for parameters such as reactor pressure and temperature, containment pressure and temperatures, liquid levels flow rates, etc., are listed in Appendix E." Appendix E entitled " List of Instrumentation for Assessment Capabilities." which had not been included within the Emergency Plan, did not list nonradiation process monitors which are referenced in the above sections of the plan. 1 The auditors observed the following nonradiation process monitors in working t condition and readily accessible within the control roem: reactor pressure j and vessel level, turbine steam, reactor feedwater flow, reactor feedwater temperature, steam and feedsater flow, drywell pressure, wide range drywell pressure, containment temperature, recirculation loop suction temperature. Based on these findings, this area of the licensee's program is acceptable, but the following item should be considered for improvement: i l Include a list of the nonradiation process monitors within the Emergency Plan. (277/81-28-21; 27S/81-31-21) 17
4.2.1.4 Meteorological Instrumentation The bases for the auditor's review of the licensee's meteorological measurements program included Regulatory Guides 1.23 and 1.97 and the criteria set forth in NUREG-0654, NUREG-0696 and NUREG-0737. The licensee outlined the characteristics of his meteorological measurements system in Emergency Plan Section 7.3.1. The integration of meteorological data into the licensee's dose projection scheme is summarized in Section 6.2.1 of the plan and is implemented using Emergency Procedure EP-316. The auditors also reviewed the preventive maintenance program for meteorological instrumentation with the licensee. The current meteorological instrumentation provides the basic parameters (i.e., wind direction and speed and an estimator of atmospheric stability) necessary to perform the dose assessment function. Data from the meteorological measurements system were recorded on strip charts available in the control room. There were two backup sources of meteorological information in addition to the primary tower. Both of these backup towers recorded wind speed and direction while one recorded atmospheric stability based on temperature differential. Data from the backup systems were also available in the control room. The licensee has maintained a program for inspection and preventive maintenance. The instrumentation in the control room is checked five days each week and completely serviced once each month. The towers are checked twice weekly with calibrations done semi-annually by PECO. The siting and exposure of the meteorological instrumentation on the towers at the time of the appraisal was acceptable. The auditors concluded that the licensee had the capability to appropriately integrate meteorological data into the radiological assessment / projection procedures. The shift operations personnel obtain acceptable National Weather Service information from the lead dispatcher on severe weather warnings and watches in the site vicinity. Based on these findings, this portion of the licensee's program is acceptable, but the following items should be considered for improvement: Document the procedures used for the inspection of the instrumentation in the control room and the meteorological towers and verify that these procedures are being followed (277/81-28-22; 278/81-31-22) Provide quarterly calibration of the meteorological instrumentation as opposed to semi-annually. (277/81-28-23; 278/81-31-23) 4.2.2 Protective Equipment 18
4.2.2.1 Respiratory Protection The auditors reviewed the availability of SCBA (self-cor.tained breathing apparatus) respiratory equipment reserved for emergency use. The licensee had positioned airpacs in several buildings including the OSC, training building. water treatment plant and the radioactive waste building. Refilling facil-1 ties are presently adjacent to the laundry rooms in the radioactive waste building and consist of air bottles in cascade. SCBA devices are checked monthly and after each use. The licensee stated that a compressor is to be installed in the EOF at Unit 1 and will be used for emergency filling when completed. The licensee also. stated that several more 1-hour reserve tanks were on order and will be dispersed throughout the plant. The major grouping of SCBA devices (12 devices) and the refilling station were at the 116' level in the radioactive waste building. This equipment could become unusable under conditions of high airborne or direct levels of radiation. Based on these findings, this portion of the licensee program is acceptable, but the following items should be considered for improvement: Relocate the major storage site for emergency SCBA devices out of the main reactor buildings to areas of lower radiological hazard. (277/81-28-24; 278/81-31-24) Relocate the refilling area for emergency SCBAs out of the main reactor buildings to areas of lower radiological hazard. (277/81-28-25; 278/81-31-25) 4.2.2.2 Protective Clothing The auditors reviewed the location and quantity of protective clothing available onsite. The supplies were adequate. In addition, the licensee had emergency supplies at the TSC. Protective clothing was stored at the offsite assembly areas and the licensee stated that additional clothing was scheduled for placement in the near future. Based on these findings, this portion of the licensee's program is acceptable. 4.2.3 Emergency Communications Equipment The auditors reviewed the onsite and offsite communications equipment as specified in the licensee's Emergency Plan and held discussions with licensee personnel. The status of the offsite sirens which will be activated by the risk counties as notification to the population within the 10-mile EPZ was stated by the licensee as not being completed by February 1, 1932. The licensee stated that by February 1,1982, it is highly probable that notification could be made within a 5-mile radius of the plant. Notifications and communications to plant personnel and personnel close to the plant boundaries is performed by use of a public address and siren system initiated within the control room. A 6 way selector switch at the control room provides for speaker selections to activate EP-301, " Operating the Evacuation Alarm and Pond Page System"; 19
Position 1: A tape message for boaters, delivered through river speakers
- only, Position 2:
Provides for an announcement through river speakers only, Position 3: Off position, Position 4: Provides Evacuation Siren for drywell No. 2, Position 5: Provides Evacuation Siren for drywell No. 3, Position 6: Provides Evacuation Siren throughout plant system. Tests of the evacuation alarm system which were performed on December 10, 1981 in accordance with procedure ST-EP-1 showed satisfactory results for the alarm system. Operators were stationed at the river edge to confirm operability of position 1 and 2. Operators were stationed on the refuel floor, turbine building and administration building to determine operability of position 6. Visual alarms were tested by locating operators at Unit 2 and Unit 3 condensate pump pit and each diesel generator (4). No deficiencies were noted. Quarterly, sound meters are used to measure the sound level to determine the operability of the piping system. The radio system which provides communication from the control room to the York County State Police, which is used as a back-up for notification to the five risk counties, is verified daily. The record of this test is kept in the chief operator's log. The licensee maintains a 24-hour per-day capability to notify the NRC, State and local authorities within the control room. Also, each of the communication nets has a backup and a redundant power supply. ST-EP-13 requires that the licensee perform a monthly communication drill. On December 10, 1981 a satisfactory communications drill by telephone was completed with PEMA, Maryland Civil Defense, the five risk counties and the Bureau of Radiation Protection. ST-EP-14 requires that the licensee perform a quarterly communications drill. On December 10, 1981 a satisfactory communications drill was performed by telephone with the New Jersey Civil Defense Agency and the Delaware Civil Defense Agency and a radio communications drill was performed with the Pennsylvania State Police. The ringdown phones were tested between the TSC-EOF and the operations support center, the President's Utility Building, the North Sub-Station, Units 2 & 3 control room, NRC Bethesda, and Lead Dispatcher, Piladelphia. Tests of fire alarms are performed weekly in accordance with RT-1.6.2, " Actuation of Manual Fire Alarm Station." Alarm tests are performed by plant operators an the alarms tested are rotated on a weekly basis so that each alarm is tested annually. Presently, the licensee performs initial notification to the five risk counties by commercial telephone with a backup by radio to the York County State Police. When the siren system is installed direct notification to the risk counties will be performed via the siren system. 20
i 1 Based on these findings, this portion of the licensee's program is acceptable. However, the licensee was notified during the exit interview that the Commission would very likely approve a change in the implementation date for a prompt notification system from July 1, 1981, to February 1, 1982, and that the four-month time period for removing deficiencies might not apply to this system. ]_ 4.2.4 Damage Control / Corrective Action and Maintenance Equipment and Supplies l The auditors held discussions with members of the licensee's staff and determined that the licensee did not maintain dedicated reserves of parts, supplies, or equipment to be used during an emergency for damage control, corrective actions, the maintenance or replacement of equipment. Rather, the licensee depended l upon the availability of routine stocks of these materials. In addition, the auditors determined that the licensee had no provisions to identify types of materials and equipment which could be necessary during an emergency, nor had ^ developed methods for determining minimum stock levels and for ensuring that stocks are dedicated and available for emergency use. Based on these findings, this portion of the licensee's program is acceptable, but the following item should be considered for improvement: Evaluate dedicated equipment needs for damage control, corrective action and maintenance, and the positioning of this equipment at specified locations for use during an emergency and make changes where necessary. (277/81-28-26; 278/81-31-26) 4.2.5 Reserves The licensee relies on onsite inventories to augment and replenish emergency i equipment and supplies. Sufficient reserves of equipment (survey instruments, I dosimeters, etc.) are maintained to accommodate increased personnel during i outages. Interviews with plant personnel indicate a system is in place and l supplies and equipment are catalogued and inventoried, with reorder points to j insure minimum stock levels. A stores division coordinator is specified by EPC-212 to control re-supply of site storerooms. I In addition, Radiation Management Corporation will supply reserve supplies and equipment and a list of supplies which could be borrowed from sister plants is being compiled. Based on these findings, this portion of the licensee's program i, acceptable; however, the following items should be con <idered for improvement: I Check the type of equipment that will be borrowed during emergencies from sister plants and supplied by RMC for compatability with existing equipment. (277/81-28-27; 278/81-31-27) i 21
4.2.6 Transportation There are no vehicles designated for emergency use on or offsite. All members of various emergency response teams and all evacuees are expected to use private vehicles. Under adverse conditions, it might be impossible for the offsite survey or security teams to travel the roads required. During the appraisal a light snowfall occurred (less than 2 inches). Several individuals who attempted to leave the site during the snowfall were unable to travel up the hills leading from the north and south gates. This ernhasizes the potential problem of relying exclusively on private transportation in an emergency. Based on these findings, this portion of the licensee's program is acceptable, but the following items should be considered for improvement: Provide transportation from the main parking lot to the assembly area for potential stragglers during a site evacuation. (277/81-28-28; 278/81-31-28) Ot tain or designate suf ficient vehicles to permit vital emergency functions to continue under any conditions. (277/81-28-29; 278/81-31-29) 5.0 Procedures 5.1 General Content and Formal The auditors reviewed the emergency procedures and determined that the format is generally acceptable. The procedures specify the individual or organi-zational element having the authority and responsibility for performing the tasks covered by the procedures with the immediate actions necessary to implement them. They also contain references to other procedures and have signoff sheets for completed actions. There are procedures for classifying the accident and one for actions to take for each class (notifi:ation of unusual event, alert, site area emergency, and general emergency). Although the general content and format of the procedures was generally satisfactory the auditors had a dif ficult time determining if they were complete, because major revisions of all procedures were being issued during the time of the appraisal. For example, during one discussion with a licensee representative on a particular procedure, the auditor questioned a certain statement, but was told that procedure had been revised and reissued that morning. In another instance, a revised procedure which had recently been approved (on the first day of the appraisal) by the PORC did not reflect the as-built facility to which it referred. In another instance, the auditors determined that an additional procedure was necessary to cover response personnel protection. Based on these findings, improvement in the following area is required to achieve an acceptable program: 22
Review all emergency procedures to eliminate deficiencies and identify missing procedures. Issue revised and new procedures, as necessary. (277/81-28-30; 278/81-31-30) 5.2 Emergency, Alarm, and Abnormal Occurrence Procedures The auditors reviewed the emergency procedure used by the emergency director to classify an emergency (EP-101) and determined that it contains provisions to periodically evaluate the event classification and to downgrade it or upgrade it as necessary. It references the proper procedure for the classified event (EP-102 for a notification of unusual event, EP-103 for an alert, EP-104 for a site area emergency, and EP-105 for a general emergency), each of which also contains a statement that provides for periodic evaluation of the accident classification. Based on these findings, this portion of the licensee's program is acceptable. 5.3 Implementing Instructions A procedure, containing implementing instructions, exists for use by the Interim Emergency Director or Emergency Director to aid in determining the accident classification (the primary Interim Emergency Director is the Shift Superintendent and the alternate is the Shift Supervisor). The procedure was revised while the auditors were onsite to add Table 4.2 from the Emergency Plan. lhis table gives the relationships between incidents and emergency actions and breaks events into 13 functional areas as, for example: unplanned shutdowns, personnel injury, primary containment integrity, and radioactive material release. These functional areas are further subdivided into emergency action levels which are based, in the case of reactor systems, upon specific observable information such as instrument readings. Each reading is then related to 1 of the 4 classes of emergencies and gives a brief licensee and plant staff response. It also refers the Emergency Director to the specific procedure for the emergency class identified. In the case of the General Emergency, the specific procedure (EP-105) directs the Emergency Director to notify offsite authorities of the accident and to make recommendations for protective actions. Based on the above findings, this portion of the licensee's program is acceptable. 5.4 Implementing Procedures 5.4.1. Notifications The auditors reviewed procedures EP-102, " Unusual Event Immediate Actions," EP-103, " Alert Immediate Actions," EP-104, " Site Emergency Immediate Actions," EP-105, " General Emergency Immediate Actions" and discussed their contents with the Corporate Emergency Planning Coordinator. Each procedure contained a contact log (check-off list), of persons to call, a pre planned message, a statement as to who would perform notification, and a source of contacts and telephone numbers. The auditor noted that the contact logs for each emergency class did not provide for notifications to the Resident NRC Inspector. The 23
procedures did provide for immediate notification for alert and higher cate-gories to the five risk counties, Pennsylvania and Maryland Emergency Management Agencies, NRC Operations Center, Station Superintendent, load dispatcher, Emergency Teams and Manager-Corporate Communications. The procedures also provide for the activation of the Operation Support Center and Technical Support Center at the alert and higher accident classifications. The procedures provide for activation of the Emergency Operation Facility for a site area or General Emergency Classification level. Each of the procedures provide for a consideration by the Emergency Director as to which support agency or plant personnel are needed to be notified. Authentication of the initial notification is provided by having the five risk counties contact the load dispatcher in Philadelphia, the Pennsylvania Emergency Management Agency (PEMA) contact the facility directly and the Maryland Emergency Management and Civil Defense Agency contact PEMA directly. Although not specified in the procedures, discussions with the licensee determined that at the request of PEMA, recommendations for protective actions to the five risk counties will be the responsibility of PEMA after consultation with and advice from the Bureau of Radiation Protection. The licensee intends to provide protective action recommendations to the five risk counties only if the Bureau of Radiation Protection is not functioning, or when projected doses exceed the protective action guidelines identified in the Bureau of Radiation Protection Plan. Further investigation revealed that the protective action guidelines used by the Bureau of Radiological Health are 5 Rem whole body and 25 Rem thyroid. This means the licensee would not be notifying the counties directly until those levels were projected. This is contrary to NRC policy that if a General Emergency is declared, there is a potential for exceeding 1 Rem whole body or 5 Rem thyroid at the side boundary, and the licensee should immediately notify the off site authorities in the EPZ with a recommended protective action. Based on these findings, this portion of the licensee's program is acceptable, but the following item should be considered for improvement. Clarify the reporting requirements for a General Emergency and revise the procedures accordingly. This action is part of the overall procedure review identified as necessary for Section 5.1. (277/81-28-31; 278/81-31-31) 5.4.2. Assessment Actions The auditors reviewed the emergency classification procedures EP-102, EP-103, EP-104, and EP-105. All four procedures were Revision 1 dated 12/7/81. In addition, the following procedures were reviewed: 24
EP-205A Chemistry Sampling and Analysis, EP-2058 Radiation Surveys, EP-205C Personnel Dosimetry, Bioassay ar.d Respiratory Protection, and referenced HP0/C0 procedures 121 through 129. EP-316 Determination of magnitude and direction of gaseous releases and resultant dose rates. Part 1 Offsite dose rate due to main stack release. Part 2 Determination of release rates based upon high range roof vent and main stack indicators. Part 3 Determination of dose due to iodine release. The above procedures provided by the licensee did not provide an overall procedure which coordinated all the assessment actions to be taken. The procedures did not provide guidance to the radiological assessment coordinator on how to weigh the information and data to aid in making a decision to escalate or de-escalate the emergency. This individual must be able to assess the effect on the environment of any releases from the information received from the effluent monitoring system, special effluent samples, process monitoring systems and field survey data. He must also be able to evaluate the potential for release and the environmental consequence that would result from this potential release. If two of the three barriers have been breached, he must be able to evaluate the potential for disruption of the final barrier and make recommendations to the emergency director on whether onsite and offsite protective measures are required. Therefore, the radiological assessment coordinator must have procedural guidance which assures that the necessary elemen ts are evaluated and con-sidered before making recommendations to the emergency director. The implementing procedure to guide the radiological assessment coordinator should define the actions required when certain conditions exist and establish pricrities for assessment and protective actions. The licensee's assessment program provided for the following: Containment air sampling and containment source term determination. Initial dose projection in the evcrt installed instrumentation is off scale. The licensee has a dose projection program on a programmable calculator which provides for worst case dose asse sment. Once entered into the calculator the program prints out a request for each entry required. It provides a set of sample data and the cerrect answer to be used to check the system performance. This program performs the steps defined in EP-316 Part I usi~ng straight line meteorology. Immediate notification was covered in the classification and notification procedure and was not addressed in the assessment action procedure. Trend analysis and continuous update of assessment information was the responsibility of the radiological assessment coordinator and should be covered in the EP for the RAC. l r 25
1 i No references were made in the assessment procedure EP-316 to the following: TLDs, soil samples, vegetation samples. Use of area radiation monitoring information and in plant surveys in dose assessment. An interim method using portable radiation monitoring instruments or calculational methods for estimating high-level releases. Based on these findings, this portion of the licensee's program is acceptable, but the following matter should be considered for improvement: Provide an implementing procedure to aid the person assigned the responsibility for coordination of assessment actions for trend analysis, for escalation or de-escalation, and for protective action recommendations. The procedure should guide this person to the correct actions when indicated by sample analysis and process instrumentation. (277/81-28-32; 278/81-31-32) 5.4.2.1 and 5.4.2.2. Offsite and Onsite (Out-of-Plant) Radiological Surveys The licensee's Implementing Procedure EP-205B, Rev. O, " Radiation Survey Groups," discussed methods and referenced HP0/C0 procedures for emergency radiological monitoring, addressed the responsibilities of Field and Onsite Survey Team Leaders and members, and supplied of f site and onsite survey data sheets. The auditors reviewed this procedure and the following HP0/C0 procedures to evaluate the licensee's emergency survey capabilities: HP0/C0-60, R0-1, Rev. 2, " Field Use of Eberline Ion Chamber Model RD-1," HP0/CO-62, Rev. 2, " Field Use of the Eberline GM Detector Model E-400," HP0/CO-63, Rev. 1, " Field Use of the Eberline Contamination Monitor RM-14," HP0/CO-64, Rev. 4, " Field Use of the Eberline RM-14 and HP-210 Probe as a Field Scaler," HP0/CO-65, Rev. 4, " Field Use of a Low Volume Portable Air Sampler," HP0/CO-66, Rev. 3, " Site and Offsite Area Survey," HP0/CO-67, Rev. 2, " Field Use of Eberline SAM-2 for Determination of I-131 Activities." In general, the HPO-C0 procedures included the action steps to operate the respective field instruments, required that all results be reported to the Emergency Director or Radiation Survey Team Leader, and included a pre-requisite statement concerning calibration and operability of radiation survey equipment. Specific findings concerning offsite and onsite radiological surveying will be discussed in the subsequent paragraphs. 26 --w>
a 5.4.2.1 Offsite Radiological Surveys The procedures did not adequately address radiation protection guidance for offsite teams surveying in the plume nor provide a back-up means for communi-cations if the radio communications failed. No prepositioned survey points within the plume EPZ existed but the survey kits included maps similar to the EPZ sector maps located within the EOF. The auditors also noted that no special provisions for transportation of the team (s) were specified. The offsite Data Sheet made provisions for the following: Date of each survey name(s) of individual (s) performing survey instrument used by type and serial number air sampler flow rate background radiation at time of air sample counting and sample count time. The data sheet did not include space to list mode in which the instrument was used, time of each survey, and duration of meter reading. The auditors noted that procedure HP0/CO-66 did designate a central collection point for all environmental samoles collected by the offsite team (s). Based on these findings, this portion of the licensee's program is acceptable, but the following items should be considered for improvement: Include radiation protection guidance for offsite teams surveying in the plume (277/81-26-33; 278/81-31-33) Revise data sheets to include provision for recording the time of each survey, duration of meter reading and mode of operation, in procedure EP-205B. (277/S1-28-34; 273/81-31-34) 5.4.2.2 Onsite (Out-of-Plant) Radiological Surveys The procedures did not adequately address where the emergency survey and protective equipment would be obtained for onsite (out-of plant) surveying. The onsite survey data sheet had the same format as the of fsite data sheet and therefore the same limitations (see finding under Section 5.4.2.1). The auditors also noted that no special map outlining the site perimeter with pre-selected sampling points was included with procedure EP-205B. The licensee stated that onsite teams would be dispatched to the affected areas and that sampling stations were not necessary. In addition, although communications were to be maintained between the onsite team and team leader, no communication method was specified in EP-205B. Based on these findings, this portion of the licensee's program is acceptable, but the following matters should be considered for improvement: Identify in procedure EP-205B emergency equipment location for the onsite survey team. (277/81-28-35; 278/81-31-35) 27
Identify in procedure HP0/CO-66 sampling points for the site perimeter. (277/81-28-36; 278/81-31-36) Provide for primary and backup communication methods within EP-205B. (277/81-28-37; 278/81-31-37) 5.4.2.3 In-Plant Radiological Surveys The auditors held discussions with the licensee and reviewed the following procedures to verify emergency in plant radiological survey capability: EP-205 Rev. O, Radiation Survey Team, and EP-205B Rev. O, Radiation Survey Groups. Procedure EP-205 included a general list of equipment (anti-Cs, respirators, high-range gamma survey instruments, high-range dosimeters and portable radios) to be acquired from an assembly area specified by the team leader.
- However, no procedural steps were included detailing methods for using high-range survey instruments, what range survey instruments should be used (e.g., R0-2A 50 R/hr or teletector 1000 R/hr), or precautions and prerequisites concerning radiation protection under emergency situations other than a statement to monitor exposure rates for team members and to enter the hazardous area when directed.
Procedure EP-205B (recently approved by PORC on 12/7/81) also defined the actions of the Radiation Sursey Groups including plant survey group members, but was not distributed to site personnel pending results of the NRC audit. The auditors noted that the procedure only specified to obtain necessary equipment, check operability equipment, and report data to the plant survey group leader. Again, no specific equipment and instructions on how to operate the equipment or how to label samples collected for analysis was included or referenced in EP-205B. However, the inspectors noted that an in plant survey data sheet was included in EP-205B. (For related findings, see Section 5.4.2.1.) Discussion with the licensee indicated that in plant survey equipment was routinely used and verbal radiation protection guidance would be given to the team members before entering hazardous areas. Back-shift health physics personnel who would be authorized to function on an RWP should have this information readily available. Based on these findings, this portion of the licensee's program is acceptable but the following item should be considered for improvement: o Revise procedure DP-205B to include radiation protection guidance for in-plant survey teams, methods or reference to procedure for use of all in plant survey equipment, and listing of instrument (s) and type (s) of surveys to be completed by in plant teams. This action is part of the overall procedure review identified as necessary for Section 5.1. (277/81-26-38; 278/81-31-38) 28
A 5.4.2.4 Primary Coolant Sampling The inspectors reviewed the EP series procedures but could not find any EP procedure for reactor coolant sampling. HP0/C0 procedure 122 however addressed obtaining a reactor water sample from sample sinks following an accident. the reason for having emergency procedures is to cause a change in thinking from normal operating methods to emergency operating methods. The HP0/C0 procedures did not cause this change. The HP0/C0 procedure does not provide a check list for the operation of the emergency sampling equipment. There was a reference to ALARA consideration and specific instructions on routing of personnel to minimize radiation exposure. The procedure clearly defined the sample locations in Appendix A of the procedure. The special handling equipment and building required was addressed in paragraph 7. No special data sheets were provided in the procedure. The licensee used its normal chemistry procedures for labeling and recording of sample data, and this appears to be satisfactory. The method of transporting the sample was not addressed, but the treatment of the sample on arrival at the hot laboratory and precautions to be taken were addressed. The sample could be obtained in one hour. Based on these findings, this portion of the licensee's program is acceptable but the following item should be considered for improvement. Provide an emergency plan implementing procedure for reactor coolant sampling for the current and/or the new system being installed to meet the NUREG-0578 requirements. These actions are part of the overall procedure review identified as necessary for Section 5.1. (277/81-28-39; 278/81-31-39) 5.4.2.5 Primary Coolant Sampling Analysis Procedure The auditors reviewed the EP procedures but could not find any EP procedure for primary coolant sample analysis. HP0/C0 procedure 123, which addressed sample preparation and chemical analysis of highly radioactive liquid samples, was reviewed. The procedure provided adequate methods for handling samples and the protective measures to protect the health of the personnel including remote handling and shielding. The procedure did not address the handling and analysis of the sample in the counting laboratory. The analytical procedures included the handling and dilution of high-level samples. The procedure did not establish limits on the level of radioactive samples that could be brought into the analytical or counting laboratory. There were no special data sheets for high-level samples and, therefore, could not be keyed to an EAL. The procedure does not address what is to be done with the data in terms of dis-semination to organizational elements responsible for assessment functions. The storage and retention of samples was not addressed in the procedure. The procedure provided the analytical methods required to provide the desired information within two hours. Based on these findings, this portion of the licensee's program is acceptable, but the following item should be considered for improvement. 29
Provide an implementing procedure in the EP series that provides for: methods of analysis; the limitation of radiation levels to be applied to personnel and facilities; tracking of samples; reporting of data (keyed to emergency action levels) to the personnel responsible for assessment and protective actions; and escalation and de-escalation of the emergency classification. These actions are part of the overall procedure review identified as necessary in Section 5.1 (277/81-28-40, 278/81-31-40). 5.4.2.6 Post-accident Containment Air Sampling The licensee provided the auditors with HP0/C0 health physics and chemistry procedures which are used instead or Emergency Plan Implementing Procedures. The following procedures were reviewed: HP0/CO-121 " Obtaining Drywell Gas Samples from the Containment Atmosphere Dilution Cabinet." HP0/CO-124 " Retrieving and Changing Sample Filters and Cartridges from the Drywell Radiation Monitor." HP0/CO-125 " Obtaining Drywell Gas Samples from the Drywell Radiation Monitor Sampling Station." These procedures identified the sample location and the sampling points. The radiological protection of personnel assigned to take the samples was provided for by requiring a radiation survey of the route to the sample location and of the sample location itself, and then issuing an RWP for personnel to follow in obtaining the sample. The procedures provided a step-by-step instruction to be followed to obtain the sample. Points not addressed in the procedures were as follows: Data sheets were not provided for recording the data for each sample. The mechanism for transporting the sample was not discussed. Provision for uniquely labeling each sample was not discussed. No checklist is provided to ensure vital steps are not omitted. The use of the same procedures for routine and emergency use places an additional burden on management to ensure that personnel taking emergency actions have shifted from the normal mode of operation to an emergency mode of operation and be able to deal with abnormal conditions. Based on these findings, this portion of the licensee program is acceptable but the following item should be considered for improvement: 30
Provide an emergency plan implementing procedure which provides the information contained in the HP0/C0 procedures 121, 124 and 125. In addition, consideration should be given to providing a checklist, data sheets and provision for pre-labeling samples. (277/81-28-41; 278/81-31-41) 5.4.2.7 Contaminated Air Sample Analysis Procedure The auditors reviewed HP0/C0-127, " Procedure for Sample Preparation and Analysis of Highly Radioactive Particulate Filters and Iodine Cartridges." The procedure provided the analytical steps to be followed in the analysis of the samples. Provisions for calibration of the counting system were provided in the chemistry procedures. The procedure discussed the method of handling and analyzing high-level samples and of protecting laboratory personnel from radioactivity and direct radiation from the sample. The procedure had no discussion of techniques to insure the protection and usability of the primary laboratory if the background is too high. No analytical data sheets were provided in the procedure; however, standard chemistry procedures provided for data sheets and labeling of samples. The data sheets are not keyed to the EALs. The procedure had no reference to the reporting of results to the organizational element responsible for assessment actions and protective action decision making. The disposition of the sample was discussed (it would be disposed of as radioactive waste or stored for future use, depending on analytical results). The analytical methods would achieve the desired results. The analysis would be completed in two hours and the results reported. Based on these findings, this portion of the licensee's program is acceptable, but the following item should be considered for improvement: Provide a procedure in the EP series which addresses post-accident sampling analysis. The procedure should include checklists, data sheets, labeling of samples and reporting of results. (277/81-28-42; 278/81-31-42) 5.4.2.8 Stack Effluent Sampling The licensee provided the inspectors with a Health Physics and Chemistry Procedure HP/CO-126 " Obtaining the Iodine and Particulate Samples from the Stack and Roof Vents Following Accident Conditions," which they used instead of an emergency procedure. Procedure HP0/CO-126 listed the precautions to be taken and the methods to be employed to minimize radiation exposure to per-sonnel taking the samples. The procedure clearly identified the location and the sampling points in pictures and drawings. The sample media used and the sample cartridges to replace the samples removed were identified. Data sheets for recording the data concerning the samples were not provided in the pro-cedure. The procedure required a survey to be made and a RWP issued in advance of entry to remove the samples. The time requirement to make this survey and obtain the RWP would require more than one hour due to the distance and route that must be taken to reach the stack sample location. 31
O = Based on these findings, this portion of the licensee's program is acceptable, but the following item should be considered for improvement: Provide an Emergency Plan Implementing Procedure for Sampling of the Exhaust Release Points which Integrates the sampling steps in HP0/CO-126 into the Emergency Procedure. Consider the inclusion of a data sheet to record vital information relevant to the sample and methods for providing packaging and pre-labeling. (277/81-28-43; 278/81-31-43) 5.4.2.9 Stack Effluent Sampling Analysis The auditors reviewed HP0/CO-127 " Sample Preparation and Analysis of Highly Radioactive Particulate Filters and Iodine Cartridges." The procedure provides for handling and analysis of highly radioactive samples and cartridges. There was a provision for calibration of the sample counting equipment to allow analysis of high-level samples. Procedures established the method of section-ing highly radioactive samples and cartridges to permit the sample to be analyzed with dead times on the pulse height analyzer of less than 30 percent. The radiation safety of personnel and the protection of the facility had been provided for by requiring radiation monitoring of sample preparation and analysis by Health Physics personnel. The procedure does not provide a data and analysis sheet for high-level samples keyed to FALs. The procedure appears to achieve the analysis of high-level samples and reporting results within two hours. Based on these findings, this portion of the licensee's program is acceptable. 5.4.2.10 Liquid Effluent Sampling The auditors reviewed available procedures and held discussions wth the senior engineer for chemistry and radiation protection. The licensee considered this to be a normal routine function adequately covered by existing RWPs and there-fore no emergency procedures exist. Transfer of liquids in piping system between onsite tanks was not considered an emergency action which required special procedures. The licensee did not consicer displaced primary coolant would require sampling and analysis. Based on these findings, this portion of the licensee's program is acceptable, but the following item should be considered for improvement: Include a procedure for post-accident sampling of displaced liquid and liquid effluent in the emergency plan implementing procedures. (277/81-28-44; 278/81-31-44) 5.4.2.11 Liquid Effluent Sampling Ana'ysis The licensee provided adequate procedures for analyzing liquid primary coolant samples in procedure HP0/CO-123 " Sample Preparation and Chemical Analysis of Highly Radioactive Samples." 32
Based on these findings, this portion of the licensee's program is acceptable. 6.4.2.12 Radiological and Environmental Monitoring Program (REMP) The auditors reviewed EP-C-315, " Recovery of Post Emergency Envir onmental Monitoring Samples" with licensee corporate staff and determined that the licensee had provisions to implement a REMP on a timely basis. The procedure took into account the assignment of duties for collection and evaluation of environmencal TLDs, soil, water and biological samoles. Primary and alternate sample collectors are assigned in addition to a short paragraph describing the samples to collect and a map indicating the sample locations Analytical capabilities were available through an agreement with Radiation Management Corporation (RMC). The auditors noted that the REMP would be initiated for long-term environmental monitoring by the Site Emergency Coordinator located at the EOF. The licensee stated that results would be available within 7 hours. Offsite survey teams dispatched from the EOF would supply the necessary dose assessment data during the interim. Based on these findings, this portion of the licensee's program is acceptable. 5.4.3 Protective Action 5.4.3.1 Radiation Protection During Emergencies The auditors reviewed EP-205, 205A, 205B, 205C and 316. These procedures address activation and duties of the Radiological Protection Team and associated sub groups including plant and field surveys, chemistry sampling and analysis, dosimetry, bioassay and respiratory protections, and dose assessment under accident conditions. The Emergency Procedure for respiratory protection (EP-205C) does not contain provisions for expanding the supply of respirators or list HPO procedures for refill and reuse of respiratory equipment. Based on these findings, this portion of the licensee's program is acceptable, but the following item should be considered for improvement: Amend the follow-up instructions in EP-205C for the Personnel Dosimetry Bioassay and Respiratory Protection Group Leader to include reference to procedures to process respiratory equipment for reuse. (277/SI-28-45;278/81-31-45) 5.4.3.2 Evacuation of Owner-Controlled Areas The auditors reviewed the EPs 303, 304, 305 and 306 covering evacuation of owner-controlled areas. The EPs contain emergency action levels which initiate evacuation, specify location of assembly areas and list criteria to decide which assembly area to use. The procedures contain prepared statements for use over the public address system to direct er.ergency, essential and non-essential personnel to the correct assembly points. The partial and site evacuation procedures include reference to personnel accountability procedures 33
and the site evacuation procedure instructs the Personnel Safety Team leader to carry out applicable procedures as necessary, regarding search and rescue, personnel assembly and accountability, first aid, a.1d personnel monitoring and decontamination. Based on these findings, this portion of the licensee's program is acceptable. 5.4.3.3 Personnel Accountability The auditors discussed emergency procedures for personnel accountability with security personnel and the Personnel Safety Team leader. After an emergency evacuation, a computer list of all personnel who have entered the plant will be generated and compared to a computer list of all personnel who have left the plant. It is the estimate of security personnel that exit of all onsite personnel and computer generation of a list of all personnel which had exited the plant would take about 30 minutes. The subsequent steps of comparing security badges with the lists of personnel, compiling a list of personnel still onsite and transporting the list to the Personnel Safety Team Leader and Shift Superintendent would take about 30 additional minutes (60 minutes total). Based on these findings, this portion of the licensee's program is acceptable, but the following item should be considered for improvement: Decrease the time required to identify onsite and missing individuals from 60 minutes to 30 minutes. (277/81-28-46; 278/81-31-46) 5.4.3.4 Personnel Monitoring and Decontamination The auditors reviewed the following procedures to verify that the licensee had established provisions for monitoring and decontaminating individuals and equipment leaving restricted areas and at assembly / reassembly areas: EP-207, Rev. I " Personnel Safety Team Activation." EP-311, Rev. O " Handling Personnel with Serious Injuries, Radioactive Contamination Exposure, or Excessive Radiation Exposure - Emergency Director Functions." HP0/CO-6 " Personnel Contamination Survey Techniques." HP0/CO-7 " Personnel Decontamination Procedure." HP0/CO-8 " Decontamination of Tools and Equipment." The licensee stated that personnel evacuated from the site would be monitored at the portal monitors and frisker (HP-210 probe) location set up by the Personnel Safety Team. Appropriate Anti-Cs would be distributed to these persons identified as contaminated. All personnel would report to the pre-announced assembly area to be more intensively monitored and decontaminated i f necessary. 34
O Emergency Procedures 207 and 311 were written as implementing instructions for activation of the survey teams responsible for personnel monitoring and decon-taminations. In addition EP-311 nakes provisions for contamination / exposure criteria levels an- ' scribes the necessary follow up actions for eight situations encompa. a combination of personnel exposure / contamination and injury circumstanc e routine Health Physics and Chemistry Operating Procedures were r 'n EP-207 and would be relied upon to define decontamination s. The routine moni decontamination procedures provided a means to s record personne', af contaminated victims, and a place to record the results of any ( . amination efforts; but did not provide sketches to facilitate descr stion of the body area (s) affected or tracking contamin-ations. In addition, neither EP-207 nor any of its referenced procedures addressed the means for providing collected data to the organizational element responsible for radiation protection and follow-up actions as described in EP-311 The auditors also noted that the HP0/C0 procedures did not address the methods of monitoring that would be conducted during an accident situation involving numerous victims, or actions to be taken for renoval of radiciodine. Based on these findings, this portion of the licensee's program is acceptable, but the following item should be considered for improvement: Revise the appropriate procedures to include: methods of monitoring and decontaminating groups of personnel during accident situations; special considerations for skin contaminated with radiciodine; data sheets and body sketches to track decontamination events and ensuring that collected data are provided to the emergency organizational elenent responsible for radiation protection during emergencies. (277/S1-28-47;278/81-31-47) 5.4.3.5 Onsite First Aid and Rescue The auditcrs reviewed EPs 207, 20/A, and 311, which cover onsite first aid and rescue. The procedures give radiation protection guidance for the emergency team members and address methods for recosering, transporting and handling injured personnel who nay also be contaminated. The first aid procedures describe criterion for using onsite or offsite nedical facilities. Two members of the personnel safety team interviewed had not yet received 207A seven days after final approval. Based on these findings, the licensee's program is acceptable, but the following item should be considered for improvement: Implement Emergency procedure 207A. (277/SI-28-4S; 278/81-31-48) 5.4.4 Security During Emergencies The auditors reviewed security procedures PP-2, " Emergency Admittance Procedure," PP-10, " Emergency Conditions Implemented" and PP-11 " Security Force Actions During a Site Evacuation." The contents of these procedures were discussed 35
with the site Security S'ipervisor and the Corporate Emergency Security Officer. Proceaures PP-2 and PP-11 had been approved by PORC and Procedure PP-10 had not yet been submitted to PORC. All members of the security force had been trained in the implementation of Procedures PP-2 and PP-11. The auditor discussed the training program with the security training of ficer and reviewed training records which verified that the security force was trained to implement the approved procedures. The role of the security force during an emergency is to assure that all personnel exiting the protected area deposit their badges, monitor themselves by use of the portal monitors, use friskers to determine specific areas of contamination if the portal monitor alarms, and ensure the evacuee puts on the appropriate protective clothing to contain contamination. In addition, the security force provides for rapid admission to the plant of assisting nonplant personnel and equipment (e.g., firemen, ambulance) and controls the entering and exiting of vehicles at predetermined road points. Also, security provides a listing of personnel within the plant's protected area by use of a computer listing and badge control. The auditors performed a walkthrough with two security emergency team members. Observations noted during this walkthrough appear in Section 7.2. Based on these findings, this portion of the licensee's program is acceptable, but the following item should be considered for improvement: Submit procedure PP-10 to PORC for review and train the security force on its contents. (277/81-28-49; 278/81-31-49) 5.4.5. Repair / Corrective Actions The auditors reviewed EP-206B entitled, Emergency Repair Group" and held discussions with licensee's personnel. The auditors determined that the procedure addressed the concept of operation of repair and corrective action teams, but did not address the criteria used to select members of the team; the types of skills and training required of team members; the location and contents of specific instruments and other equipment to be used, communication means and precautions to be employed. Based on these findings, this portion of the licensee's program is acceptable, but the following item should be considered for improvement. Incorporate into EP-206B specific locations and descriptions of equipment (e.g., radiation detection instruments, tools, etc.); the criteria and logistics of selection of repair team members; communication means and precautions to be employed. This action is part of the overall procedure review identified as necessary for Section 5.1. (277/81-28/50; 278/81-31-50) 5.4.6 Recovery The auditors reviewed the licensee's actions in regard to the initiation of the recovery phase as they appeared within the Emergency Plan and discussed these actions with the Corporate Emergency Coordinator. The Emergency Control Of ficer, in coordination with the Emergency Director, the site Emergency 36
Coordinator and the Federal and State Government liaison activates the recovery phase. The Emergency Coordinator provides for an evaluation of plant operat-ing conditions as well as the in plant and out-of plant radiological conditions in this decision. Notifications to the various individuals and agencies that the recovery phase has been implemented is the responsibility of the site emergency coordinator. The licensee is in the process of changing the recovery organization chart to identify key positions within the organization. Based on these findings, this portion of the licensee's program is acceptable, but the following item should be considered for improvement: Complete recovery organization chart and amend the Emergency Plan to include the revised chart. (277/81-28-51; 278/81-31-51) 5.4.7 Public Information The auditors reviewed the corporate communications Emergency Procedure and discussed the procedure with the Vice President, Corporate Communications and members of his staff. The procedures identify the personnel involved in news dissemination, specify the locations of communications personnel, specify the method for coordinating the internal dissemination of information to the various locations and individuals, provide for initial dissemination of information to the news media prior to the establishment of the news center, specify the utility spokesman and sources of information and provide for responding to public inquiries separate from news media. Based on these findings, this p,ortion of the licensee's program is acceptable. 5.5 Supplementary Procedures 5.5.1 Inventory, Operational Check and Calibration of Emergency Equipment, Facilities and Supplies The auditors reviewed the contents of ST/EP-3A, Rev. 8, Emergency Equipment Operational Check. The procedure provided checklists for inventory purposes and showed quantities of specific items and their locations. The procedure required that inventories be taken semi-annually or af ter the lockers' seals were reported open. Radiation survey instruments were replaced with newly calibrated instruments during the semi-annual inventory. In addition, battery checks were specified for a monthly basis. Signatures of HP and Shif t supervision were needed to verify inventory completion. The procedure did not include action steps detailing operational checks.for the various instruments. The inspectors alsa noted that no criteria we'e included for situations when a maintenance request form would be needed to correct any malfunctioning equipment. Based on these findings, this pertion of the licensee's program is acceptable, but the following item should be considered for improvement: 37
Revise the emergency equipment inventory and calibration procedure to define the specific checks required to insure instrument operability, and steps to take when discrepancies are encountered. (277/81-28-52; 278/81-31-52) 5.5.2 Drills and Exercises The auditors reviewed several of the surveilance test / emergency procedures (ST/EPs). The procedures address some of the specific areas in the emergency l plan and provide methods for documenting and evaluating task performance. 1 Some of the procedures do not direct the drill coordinator to critique the drill and assess corrective actions for deficiencies. Some of the procedures reviewed do not reference a procedure or give instructions as to who assigns individual responsibility to implement corrective actions. Two of the ST/EPs contained reference to outdated EPs. There are no ST/EPs written for Radio-logical Monitoring or Health Physics drills. In the Emergency Plan, the Health Physics and Radiological Monitoring drills are proposed in conjunction with the annual exercise; however NUREG-0654 requires part of the Health Physics drill to be completed semi-annually. The Radiological Monitoring and Health Physics drills are required by NUREG-0654 "in addition to the annual exercise" (Section N.2). The annual exercise ST/EP-8 does not specifically make provisions for backshift or unannounced exercises as required in NUREG-0654. Based on these findings, this portion of the licensee's program is acceptable, but the following items should be considered for improvement: Provide a Radiological Monitoring ST/EP to include an annual drill in addition to the annual exercise. The ST/EP shall be compatible with NUREG-0654, Section N.2.d. (277/81-28-53; 278/81-31-53) Provide a Health Physics ST/EP to include semi-annual and annual drills in addition to the annual exercise. The ST/EP shall be compatible with NUREG-0654, Section N.2.c.1. (these actions are part of the overall procedure review identified as necessary for Section 5.1). (277/81-28-54; 278/81-31-54) Review existing ST/EPs and bring all references to EPs up-to-date. (277/81-28-55; 278/81-31-55) Standardize ST/EP format so that all procedures clearly indicate critique responsibilities and the responsibility for corrective actions. (277/81-28-56; 278/81-23-56) Amend ST/EP-8 to include orovision for backshift and unannounced exercises as required by t TEG-0654, Section N.1.b. (277/81-23-57; 278/81-31 -57) 5.5.3 Review, Revision and Distribution of Emergency Plan and Procedures The auditors held discussions with Site Quality Control representatives and corporate Radiation Protection personnel to determine if the emergency plan and procedures were reviewed annually, that revisions to the documents follow a controlled distribution system and that names and telephone numbers for emergency reponse personnel are verified quarterly. 38
Section 8.2 of the Emergency Plan indicated that a member of the Electric Production Department staff would be responsible to initiate an annual review of the Emergency Plan and if substantive changes were needed an Operations Safety Review Committee would address the recommendations. Procedural methods were established in EP-500 " Review and Revision of Emergency Plan, Rev. 0" to cover the plan review function. The Emergency Implementing Procedures-were reviewed and distributed on an annual basis using the following administrative procedures: A-2 " Administrative Procedure for Control and Use of Documents, Rev. 19; A-21 " Generation of Emergency Plan Procedures, Rev. 5." Procedure A-2 prescribed the method of control and distribution of revisions to the Implementing Procedures; and A-21 delegated the review responsibility to Engineer Administration and the distribution responsibility to Office Staff. A listing of all control document copy holders was included in A-2 as well as an example of the procedure distribution check form to verify procedure revision accuracy. The plan and procedures had been reviewed, approved and updated as required. The auditor noted that not all emergency response personnel were included in a distribution scheme to ensare that they were familiar with their emergency functional role and coordination with the emergency organization. The auditors noted that A-21 also established the responsibility for quarterly reviews of names and telephone numbers of emergency response personnel as per ST/EP-12 " Emergency Telephone List (EP-209) Review, Rev. 2." Based on these findings, improvement in the following area is required to achieve an acceptable program. Develop and implement a method to insure that updated emergency procedures are available for use when and where needed by all persons who have emergency resoonse roles. (277/81-28-58; 278/81-31-58) 5.5.4 Audits of Emergency Preparedr.ess Peach Bottom Technical Specifications Section 6.5.2.8.e speci fied that the Operations and Safety Review Committee shall initiate an independent audit of the emergency preparedness program at least once every 24 months. In addition, Section 8.6 of the Emergency Plar. specified that copies of the findings shall be forwarded to the Emergency Planc.iag Coordinator (EPC). The EPC stated tFat corporate QA Department conducts the audit every 24 months and includes observation of drills within the report. A recent audit involving personal discussions, contact with support groups and a paper review was being finalized during the NRC appraisal and was given to the auditors at the exit interview. A review of this audit report showed it to be satisfactory. Based on these findings, this portion of the licensee's program is acceptable. 39
6.0 Coordination with Offsite Groups 6.1 Offsite Agencies The auditors contacted responsible individuals within the following organizations to verify that there was an understanding of responsibilities and roles in response to an emergency at the licensee's facill. and that these understandings were consistent with the agreements and licensee procedures and the expectations of both parties: Radiation Management Corporation, Delta-Cardiff Ambulance and Fire Co., Pennsivania State Police, Harford Memorial Hospital, Department of Energy, Pennsylvania Emergency Management Agency, Maryland Emergency Management and Civil Defense Agency, Harford County Civil Defense Agency, Cecil County Civil Defense Agency, York County Emergency Management Agency, Chester County Emergency Management Ager:y, and Lancaster County Emergency Management Agency. The auditors verified that the licensee had contacted the appropriate organizations for the purposes of drills, exercises, training and offering of radiation monitoring equipment. All parties contacted spoke favorably about the cooperation between the licensee and their respective organizations. The inspe: tors noted that all letters of agreements or memos of understanding did not appear within the emergency plan. Also, all parties on the distribution list did not receive the most recent changes to the plan. On December 10, 1931, the auditors attended a meeting conducted by the licensee to discuss with County and State civil defense representatives the following items relating to emergency preparedness: status of siren installation, system for activating sirens, prompt notification, agreements related to the siren system, status of emergency plans, exercises and public education program. In addition the licensee offered county representatives an invitation to atter.d an orientation program for emergency management personnel to be conducted on January 11, 1982 at the Peach Bottom Information Center. County represen-tatives at the meeting were also invited to attend a future training session to be given by Radiation Management Corporation. Based on these findings, this portion of the licensee's program is acceptable, but the following items should be considered for improvement: Distribute recent changes of the emergency plan to those on the distribution list. (277/81-28-59; 278/81-31-59) Include all letters of agreement in memos of understanding within the emergency plan. (2S3/81-26-60; 278/81-31-60) 6.2 General Public The auditors held discussions with the Vice President, Corporate Com unications and members of his staff. The licensee is preparing a brochure with a remov-able insert posting, for mail distribution to residences within the 10 mile EPZ. A printed chart and copy of the brochure was reviewed by the auditors. The draft included information concerning the classes of emergencies and their meaning, means of notification, a list of local radio stations, steps to be 40
taken, major evacuation routes and a contact for additional information. The licensee is coordinating the emergency action information with the local counties and has requested that they supply evacuation routes for their respective areas. The brochure did not contain information concerning radiation. However, the licensee has issued a grant to the Pennsylvania State University's Department of Nuclear Engineering to develop such information for individuals within the 10-mile EPZ and to acquaint them with nuclear energy and radiation. The inspectors noted that this matter was discussed within a news article in the Delta Star, dated August 27, 1981. Based on these findings, this portion of the licensee's program is acceptable, but the following item should be considered for improvement: Complete and distribute to the general public, the brochure covering emergency information. (277/81-26-61; 278/81-31-61) 6.3 News Media The auditors held discussions with the Vice President, Corporate Communications and members of his staff concerning the program to acquaint news media with the emergency plans, information concerning radiation, and points of cortact for release of public information in an emergency. The licensee intends to conduct a meeting with the news media at the Muddy Run News Center.
- However, the licensee could not provide a specific date as to when the meeting would take place.
Based on these findings, this portion of the licensee's program is acceptable, but the following item should be considered for improvement: Conduct a meeting with the news media to acquaint them with tne emergency plan. (277/S1-28-62; 273/81-31-62) 7.0 Drills, Exercises and Walk-Throughs 7.1 Program Implementation The auditors reviewed surveillance testing records and found that most of the ST/EP drills and exercises had been conducted as required by the emergency plan and procedures. The last medical drill (ST/EP-4) was conducted Jan-uary 28, 1980. There have also been several real medical emergencies. The inspectors were told that a drill had been scheduled for early December 1981 but had been postponed and has not yet been rescheduled. Previous emergency preparedness reguiations had required a medical drill every two years but present regulations and the emergency plan specify such a drill annually. The first aid drill is required monthly but was omitted in October for unknown reasons. Drill identified improvement items had been resolved, and there is a system in place to follow up on corrective actions. The auditors reviewed the system with the ST/EP coordinator and found it to be generally acceptable. Based on these findings, this portion of the program is acceptable; but the following items should be considered for improvement: 41 l
Perform a medical drill in accordance with required frequency. (277/81-28-63; 278/81-31-63) Provide a time restraint for corrective actions identified by dri11s. (277/81-28-64; 278/81-31-64) 7.2 Walk-Through Observations 7.2.1 Shift Superintendents and Shift Supervisors The auditors conducted walk-throughs (or interviews) with several shif t superintendents and shift supervisors to determine if they understood their role and responsibilities as Interim Emergency Director, and could properly classify accidents. The individuals interviewed were generally aware of their responsibili ies and were aware that they had a responsibility to classify the accident. G ien some General Emergency scenarios related to gaseous radio-active materi_1 release, they were able to make the classifications of the accident with)ut too much difficulty. They were aided by the strip chart recorders in che contral room which had been prelabled to indicate recorder readings which corresponded to each emergency class. This is an excellent aid. If the scenario did not involve a gaseous release, however, the clas-sification was more difficult. When asked if they were familiar with Table 4.2 of the Emergency Plan (see Section 5.3 of this report) which would make this classification easier, most answered in the negative. There was also a general tendency by the individuals to want to make dose calculations for the general emergency before notifying the offsite author-ities. They did not completely understand the rationale that a general emergency automatically means there is a potential for exceeding the PAG values offsite and therefore the authorities should be notified immediately without waiting for dose calculations. Based on these findings, this portion of the licensee's program is acceptable; however, the following item should be considered for improvement: Training on the new EAL table in EP-202, should include the purpose of EALs, and emphasize that no waiting is necessary for dose calculations (af ter a general emergency is declared) before notifying offsite authorities. This should also be emphasized to the offsite authorities during their training. (277/81-28-65; 278/81-31-65) 7.2.2 Walk-through of Sampling of Primary Coolant Sampling and Analysis A walk-through of primary coolant sampling with the Sr. Chemistry Technician and the Sr. HP Technician indicated that the personnel could safely sample primary coolant using the existing installed sample points providing radiation levels permitted access to the sampling point. No provisions were demonstrated to provide shielding for the sample during transport to the chemistry labor-atory. The apparatus list in the procedure called for a 30-ounce plastic bottle, however, a 100 ML bottle was used. Provisions had been made in Unit 3 for remote sample analysis, but training and operating procedure had not been implemented and this capability was not demonstrated. Finding and observation were evaluated and reported in Section 4.1.1.5. 42
7.2.3 Walk-through of Particulate and Gaseous Effluent Sampling of the Exhaust Air Released from the Station Elevated Release Point (Stack Release Point) The sampling location was in the base of the stack. The exhaust air pipes from both units enter the stacks from underground and go up one side of the stack to discharge into the stack where the air is combined with outside air forced into the stack by three fans. The discharge is allowed to mix for about one hundred feet prior to sampling. The sample line is 3/4-inch stain-less steel which is heat traced and insulated. The sample was drawn by a vane type positive displacement pump through a particulate filter and a charcoal filter then into a gas counting chamber, and discharged back into the stack. The filter holder is a type which screws together compressing an 0 ring seal. This sample holder requires hands-on contact to change the filter and the cartridge. No provision was made to shield the sample during transport. The validity of the sample in the presence of water vapor during a reactor accident was not clear to the auditors. The habitability of the sample station during sampling following an accident could also not be determined. Personnel taking the sample were prepared to monitor the dose received and the contact dose on the sample. Findings and observatons f rom this walk-through were evaluated in Section 4.1.1.7. 7.2.4 Walk-through of Dose Assessment The licensee demonstrated the methods used to evaluate the dose resulting in the plume pathway using a computer program on a Texas Instrument TI-51 program-mable calculator. The program provided a request for each input required and computed the dose at the distance specified. It provided a sample case with an answer to verify that the system was functioning. A second system was used, which uses the corporate computer and a more complex modal. This model still gave only straight line meteorology and would not track plume meander during class D. E, and F conditions. The findings were evaluated in Section 5.4.2. 7.2.5 Offsite Environmental Sampling The auditors selected a radiation survey team which would, during emergency conditions, conduct offsite surveys, and conducted a walk-through of their actions to determine their access to equipnent, usability and adequacy of procedures as well as the level of proficiency of personnel taking air samples. The auditors noted that the equipment and supplies were located in an emergency locker within the Emergency Operations Facility (EOF). The effsite team communicated with the team leader using walkie-talkies. No difficulties were encountered with communications, although a back-up communications method was not provided. The auditors noted that the offsite team followed the applicable HP0/C0 procedures and experienced no problems in obtaining the air sample or conducting dose rate surveys. However, EP-205 " Radiation Survey Team" was not used by the team because they had not been trained or been made familiar with this procedure, i 43
The findings and observations summarized were evaluated as part of the findings in Sections 3.2, 4.2.1.1, and 5.4.2.1. 8.0 Personnel at Entrance Interview 4 10:15 A.M., December 7, 1981 NR_C Robert DeFayette Marie Mojta Ira Cohen NRC_(PNL} Al Robinson Mary Smith NRC (Resident Inspector) Curt Cowgill Randy Blough Philadelphia Electric Company Joe Cooney Tom Payne Walt Knapp Ted Ullrich John Yacyshyn 9.0 Persons Contacted During Appraisal Charles Aldred Lois Kissinger E. V. Secott** S. Baehm** Walter Knapp George Swayne John Ballantine S. Koffler* Sam Tharpe A. Z. Belser** S. J. Kovacks Ed Travers Art Beward J. Langer* > Jim Valinski Vince Boyer P. Leese Andy Wargo Sam Boyle Larry Levey John Webster Cliff Brenner R. W. MacAllester J. H. Wheeler R. W. Bulmer S. Mahar Bill Widener Pete Byrne Allen Marie Harry Wilson Tom Cabrey D. R. McCallin J. R. Williams Joe Campbell George McCarty Rex Wright T. Campbell ** J. McGoldrick Joe Cooney M. J. McGuinn R. Curry"* Dave McRoberts Shields Daltroff Howard Metz John Davenport Robert Moore D. Dick Tom Msci: D. B. Ellenberg Bill Pieper Dave Filson J. N. Raymond 44
.l a e j i l 9.0 (Continued) i l Joe Gallagher Larry Rhodes Norbert Gazda Steve Roberts Ron Harper S. Salsburg Allen Hilsmeir R. Schackelford** Tom Jones K. W. Schlecker J. W. Kilduff* H. A. Schwart: Tom King D. Schweller*** 10.0 Personnel at Exit Interview 9:00 A.M., December 17, 1981 Vincent S. Boyer Senior Vice President - PECo Joseph W. Gallagher Manager-Elect. Prod., PECo M. J. Cooney Supt. Generation Div-Nuclear. PECo W. T. Ullrich Supt. PRAPS, PECo Samuel Boyle PECo W. J. Knapp PECo Norbert F. Garda Eng.-HP PBAPS, PECo K. W. Schlecker Instructor, PECo John Yacyshyn Site Emerg. Plan Coordinator, PBAPS, PECo J. W. Kilduff Sydney & Webster Engineering Co. Sheldon A. Schwartz USNRC - HQ Gary L. Snyder USNRC - Region I C. J. Cowgill USNRC, Sr. Resident Inspector Robert DeFayette USNRC - HQ M. Y. Mojta USNRC - Region I Al Robinson USNRC/PNL Marvin L. Smith USNRC/PNL Ira Cohen USNRC - Region I (
- Contractor
~ State / local personnel DOE, Brookhaven 45
o /pm Et3 k, NUCLEAR REGULATORY COMMISSION UNITED STATES 99 -{ e 3 REGloN I % '< \\ -[ 631 PARK AVENUE
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x NG OF PRUSSI A, PENNSYt.V ANI A 19406 DEC 2 41981 Docket Nos. 50-277 50-278 Philadelphia Electric Company ATTN: Mr. Vincent S. Boyer Senior Vice President, Nuclear Power 2301 Market Street Philadelphia, Pennsylvania 19101 Gentlemen: This letter refers to a meeting between you and other members of your staff, and Mr. Robert W. DeFayette, Appraisal Team Leader, and other members of the NRC Emergency Preparedness Implementation Appraisal Team, which was held at the Peach Bottom Atomic Power Station on December 17, 1981. It also refers to telephone conversation between Mr. Joseph W. Gallagher, Manager, Electric Production Department, and Mr. Gary L. Snyder of my staff on December 23, 1981. With regard to the matters discussed at the meeting we understand that you will undertake and complete the following actions: 1. Develop and implement a method to insure that updated emergency procedures are available for use when and where needed by all persons who have emergency response roles. This will be accomplished no later than February 1,1982. 2a Expand on your letter to the NRC, dated April 3,1981, to describe how the shift personnel discussed in the letter will fulfill the intent of the functions listed in Table B.1 of NUREG-0654 for 30 minute augmentation. b Describe your plan for assuring that a plant staff manager will be onsite in about 60 minutes to assume the role of E0F Director. c Demonstrate by unannounced drills that additional specified persons in the proposed staffing plan can be onsite in about 60 minutes after initial notification. Records must be kept. This will be accomplished no later than February 1, 1982, except that the drills will be completed by March 1,1982. Sa Complete the development of and formalize the emergency preparedness training program for Peach Bottom personnel having emergency response roles and supporting personnel, b Promptly conduct training to assure that several individuals are fully trained in each functional area described in the Peach Bottom emergency response organization. CCNTACT: H. W. Crocker (215) 337-5208 L2W/NooO
4 Ap Philadelphia Electric Company 2 DEC 2 41981 c Complete initial training of other personnel. Formalization of the training program and the prompt training of selected individuals will be accomplished no later than February 1, 1982. Training of other personnel will be accomplished no later than April 15, 1982. 4. Prepare a job description for the Site Emergency Planning Coordinator position which describes the responsibilities and authorities for coordinating all emergency response planning and preparedness functions at the Peach Bottom Atomic Power Station. This shall be accomplished no later than February 1, 1982. 5. Review all emergency procedures to eliminate deficiencies and identify missing procedures. Issue revised and new procedures, as necessary. This will be accomplished at a uniform rate and completed no later than April 15, 1982. 6. Clarify the emergency response organizational concepts (especially Table 5.4 of the Emergency Plan) to show the EOF as the primary emergency coordination location (the TSC retains the primary responsibility for plant operations). All other organizations which provide support, including corporate organizations, will provide this support through the EOF Director. This will be accomplished no later than February 1,1982. 7. Perform an analysis of the stack sampling system to verify that samples are representative, and if they are not, provide a description of necessary remedial actions and a schedule for their completion. This will be accomplished by no later than March 15, 1982. l In addition to the above actions, please inform this office in writing when each of the aforementioned actions have been ccmpleted. If our understanding of your planned actions described above is not in accordance with your actual plans and actions being implemented, please contact this office by telephone (215) 337-5000, within 24 hours. Your cooperation with us on this matter is appreciated. l Sincerely,
- Z M W NW MjIaid C. Haynes Ygionti Administrator l
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s e Philade1p'nia Electric Company 3 DEC 2 41981 cc: S. L. Daltroff, Vice President, Electric Production J. W. Gallagher, Manager, Electric Production Department M. J. Cooney, Superintendent, Generation Division (Nuclear) W. T. Ullrich, Station Superintendent Troy B. Conner, Jr., Esquire Eugene J. Bradley, Esquire Raymond L. Hovis, Esquire Michael J. Scibinico, II, Assistant Attorney General Public Document Room (PDR) Local Public Document Room (LPDR) Nuclear Safety Information Center (NSIC) NRC Resident Inspector Commonwealth of Pennsylvania l l l l l ..}}