ML20057E733
| ML20057E733 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 09/30/1993 |
| From: | Barr K, Kreh J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20057E727 | List: |
| References | |
| 70-1113-93-08, 70-1113-93-8, NUDOCS 9310130098 | |
| Download: ML20057E733 (8) | |
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UNITED STATES
/,,anaso4,S NUCLEAR REGULATORY COMMISSION REGloN ll y-9 101 MARIETTA STREET, N,W., SUITE 2900 5
i it ATLANTA, oEoRolA 30323 0190 OCT t 1993 Report No.:
70 1113/93 08 Licensee: General Electric Company Wilmington, NC 28401 Docket No.:.70-1113
'Ocense'No.:
SNM 1097 Facility Name:
General Electric Company Inspection Con cted:
Sept mbor 7 1, 1993
_h2 bU Inspector:
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reh, 3441aTion__Specia' ist Dat Signed Approved by:
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K. P. Barr', Chief E0 fate Signed ~
l Emergency Preparedness Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards
SUMMARY
l Scope:
This routine, unannounced inspection was conducted in the area of emergency preparedness, and included evaluation of the following program elements:
(1)coordinationofemergencyplanningwithoffsitesupportagencies,(2)the Radiological Contingency and Emergency Plan and its implementing procedures, (3)emergencyfacilitiesandequipment,and(4)traininganddrills.
l Results:
In the area inspected, no violations or deviations were identified. The licensee's emergency preparedness program was being maintained in a' state of readiness that was adequate'to protect the health and safety of. the public as well as plant personnel. An issue was identified regarding the licensee's unfulfilled requirement to provide formal training or retraining to selected
. members of the-emergency response organization prior to the end of 1993 (see Paragraph 5 for details).
Several inconsistencies in the Radiological Contingency and Emergency Plan and its implementing procedures were noted by the inspector and corrected by the licensee prior to the end of the. inspection (Paragraph 3).
9310130098 931001 1
PDR ADOCK 07001113 l
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REPORT DETAILS 1.
Persons Contacted Licensee Employees D. Barbour, Radiation Protection Coordinator
- G. Bowman, Senior Program Manager, Compliance Improvement
- J. Bradberry, Senior Program Manager, Emergency Preparedness & Security
- R. Foleck, Senior Specialist, Licensing Engineering
- T. Hauser, Environmental Health & Safety and Nuclear Quality Assurance 1
- B. Kaiser, Manager, Fuel Fabrication Manufacturing i
- R. Keenan, Compliance Auditor
- R, Lewis, Compliance Auditor
- W. Peters, Manager, Manufacturing Technology Development
- W. Ogden, Acting Manager, Nuclear Fuel and Components Manufacturing R. Schaeffer, Supervisor, Site Maintenance
- R. Torres, Manager, Radiation Protection
- C. Vaughan, Manager, Regulatory Compliance
- P. Winslow, Manager, Licensing and Nuclear Material Management Other licensee employees contacted during this inspection included engineers, security force members, technicians, and administrative personnel.
Other Organizations B. Bissett, Emergency Room Manager, New Hanover Regional Medical Center, Wilmington, NC L. Ray, Director, New Hanover County (NC) Department of Emergency Medical Services
- Attended exit interview j
index of abbreviations used throughout this report will be found in the last paragraph.
2.
Coordination with Offsite Support Agencies (88050)
The inspector held discussions with licensee representatives and reviewed documentation regarding the coordination of emergency planning with offsite support agencies.
LOAs with four local and two State agencies were updated in early 1992, and were included in Appendix A to the RCEP.
Confirmation of the adequacy of the interfaces between the licensee and offsite support organizations was obtained through telephonic interviews with representatives of two of these agencies (see Paragraph 1),
in particular, the representative of the New Hanover Regional Medical Center praised the licensee's efforts and the resources provided on behalf of that facility.
The licensee was required by RCEP Section 7.2 and Table 7.1 to offer a)propriate training to offsite support agencies on an annual basis.
Tie inspector reviewed the licensee's records of training provided or
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offered to offsito support agencies during 1993.
Documentation was reviewed regarding three hours of onsito familiarization training given J
to 18 members of the Castle Hayne Volunteer Fire Departmont on April 27, 1993. A drill on July 12, 1993, involved participation by New Hanover Regional Medical Center Staff in treating a (simulated) contaminated, 2
injured licensee employee at the hospital.
The licensee produced 4
documentation of several other offers of training sessions for various local fire department, rescue squad, and police organizations during i
1993, which were either explicitly or tacitly declined.
The inspector i
concluded that the licensee had fulfilled the above-referenced training requirements with respect to offsite support agencies.
No violations or deviations were identified.
I 3.
Radiological Contingency and Emergency Plan / Procedures (88050)
The version of the RCEP in effect at the time of the current inspection was Revision 8 (dated October 2,1992, with supplemental pages dated October 26,1992), which received NRC approval on October 29, 1992.
Revision 8 incorporated significant changes designed to clarify and enhance the specificity of the emergency classification scheme, offsite notification requirements, and the emergency response training arogram for both licensee and offsite support personnel.
The licensee las also submitted RCEP Revision 0 (dated April 29,1993), to implement various format changes and to address numerous NRC questions and concerns
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i arising from previous reviews.
Subsequent to the approval of Revision 8, the licensee submitted several l
page changes, the most recent of which were designated as Revision 10, dated May 5, 1993. These revisions were reviewed by the inspector.
A change to Table 3.3, " Classification Chart," was made in response to the suggestion in NRC Information Notice 93-07, " Classification of Transportation Emergencies," that licensees may want to consider the establishment of a separate classification (e.g., " transportation emergency") for offsite transportation accidents that require activation of the licensee's emergency organization.
The inspector noted that the licensee had deleted the " Transportation" accident category as an example of an Alert in Table 3.3, but had not made the analogous change to page 3.9 of the RCEP text, which still described an "Offsite Transportation Accident" as a condition warranting the declaration of an Alert.
Another incongruity was noted by the inspector in Table 7.1 of the RCEP under the category of "Offsite Support," which stated that " Retraining will include an annual exercise or response to actual emergencies."
However, page 7.5 of the RCEP declared that exercises will be biennial, as sanctioned by 10 CFR 70.22.
The licensee agreed that the statement quoted above needed to be revised in view of the change in exercise frequency.
One other RCEP discrepancy noted during the inspector's review was that Appendix B (RCEP/ Procedures Main Index) did not reflect
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the current revision numbers and dates for the proceduros.
Page changes made to the RCEP in May 1993 should have included a revision of Appendix B to reflect the current revision numbers and dates of the RCEP Procedures, since all were revised in February 1993, l
The three specific discrepancies discussed in the two subparagraphs immediately above were corrected by the licensee prior to the end of the inspection via appropriate and approved changes to RCEP pages 3.9, 7.4, and B l.
These page changes were designated as Revision 11 and forwarded to the NRC under a cover letter dated September 10, 1993, as changes that did not decrease the effectiveness of the Plan.
The procedures for implementing the RCEP were known simply as the RCEP Procedures. All nine of these procedures were revised during 1993.
Revisions to Procedures 1-3 were issued on February 1, and Procedures 4-9 on February 15.
The inspector selectively reviewed changes contained in these revisions, and found them to be acceptable.
Many of the changes were made to address previous NRC concerns, and are discussed in detail in Paragraphs 6.a, 6.c, and 6.d.
The inspector reviewed the " master" controlled co]y of the RCEP Procedures against several controlled copies in tie ECC intended for emergency use, including those designated for the Emergency Director and the Nuclear Safety Advisor. All procedures reviewed were determined to be the current versions.
The inspector reviewed the licensee's records of event declarations since October 1, 1992. All declarations since that date occurred in 1993 and were classified as Unusual Events (which are not reportable to offsite agencies but which would typically activate the ERO). These occurred on February 4 and April 14 (both based on what was eventually determined to be a falso criticality alarm), July 4 (false criticality alarm combined with severe weather), and February 25 and March 13 (both for severe weather).
The licensee's classification of each of these events was correct.
Response actions appeared to have been timely and appropriate.
No violations or deviations were identified.
4.
Emergency Facilities and Equipment (88050)
This area was inspected to determine whether emergency facilities, equipment, instrumentation, and supplies were maintained in a state of operational readiness since th9 last such inspection (October 1992), and to assess the impact of any changes in this area upon the licensee's emergency response capability.
The licensee's ECC, located at the ;rimary personnel entrance to the Controlled Access Area, served ac tu focal point for the management of emergency response and mitigation efforts. Although occasionally used as a training or meeting room, the ECC was essentially a dedicated facility. An annex to the management area of the ECC housed portable
4 radiation-detection equipment and miscellaneous emergency response supplies.
The inspector observed that major physical improvements to the ECC were made since the last inspection.
These changes would be expected to significantly enhance the functional capabilities of that facility.
The changes were designed to achieve more efficient utilization of the existing ECC space, and included new tables, chairs, and partitions.
Other new equipment included four detailed status boards, copier, and facsimile machine. The effects of these changes on ECC operations will be evaluated by the NRC during the 1994 exercise.
Inspection of selected equipment at the ECC indicated that a fully adequate level of readiness was being maintained for that facility.
The inspector reviewed documentation of the weekly surveillances of the ECC for the period October 1, 1992 to July 18, 1993. These records indicated that the subject surveillance was effective in identifying equipment discrepancies, and that such problems were being corrected expeditiously.
Communications equipment available for emergency use was delineated in Section 6.2 of the RCEP, and included standard telephones at the ECC, several cellular telephones, base and portable VHF radio transceivers, and amateur radio equipment owned by a number of plant personnel active in that field.
Although the RCEP contained no requirements for periodic testing of the referenced equipment, the inspector determined that breakdowns in communications systems or hardware would likely be disclosed promptly because of routine use of this equipment on essentially a daily basis.
Equipment for the provision of emergency power to the ECC in the event of a loss of offsite power consisted of a 150 kW diesel generator and a battery system.
Battery backup power was provided for the criticality warning system and the "Autocall" system, which was used to notify designated emergency response personnel to report to the ECC. The inspector examined the diesel generator and requested that it be started. Records of weekly, monthly, and annual surveillance tests of this emergency power equipment were reviewed for the period January 1 -
August 31, 1993.
These surveillances were scheduled and tracked through a computer-based system of Equipment Work Orders, and all were performed as required.
No violations or deviations were identified.
5.
DrillsandTraining(88050)
Table 7.1 of the RCEP contained the specific requirements for initial training and periodic retraining of the onsite emergency organization as well as offsite support groups.
Section 7.3 of the RCEP required the performance of periodic tests and drills in order to maintain proficiency in emergency response, ur+'
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The inspector reviewed the licensee's training program accomplishments thus far for 1993 relative to the referenced requirements.
RCEP Table 7.1 included the following specifics:
Annual retraining for the Emergency Director position "will
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include review of the basic Plan with any changes."
j Emergency Staff Advisors and Site Emergency Support groups will
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receive initial training and annual updates.
Individuals designated for Survey Teams and Reentry Teams (Health
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Physics personnel) will receive initial " extensive training" and retraining annually on the RCEP and its implementing procedures.
The inspector discussed the emergency response training program with licensee representatives and reviewed the licensee's one-page summary of 1993 training of the onsite ERO.
Training to date in 1993 consisted entirely of participation in responses to five Unusual Events (see Paragraph 3), a tabletop drill on May 27, and.a radiological drill on July 12. However, the licensee's emergency response training program did not include a " formal" com)onent as clearly implied in the various position requirements listed a)ove. Although individual participation in actual event response and drills is highly beneficial, it probably would not supply sufficient overview " refresher" training or address changes in emergency response methodology which may have occurred.
In addition, it is not always possible to have 100 percent of ERO personnel participate in event responses and drills during the course of the ye" The inspector informed licensee management that the NRC's standard i
interpretation of training requirements such as those listed above would include an expectation of a formal component such as documented self-study or classroom training. The licensee's provision of such training to all ERO personnel prior to the end of 1993 will be tracked as an IFI.
l IFI 70-1113/93-08-01:
Provision of formal initial training or annual retraining to designated members of the ERO prior to the end of 1993.
6.
Licensee Action on Previous Inspection Findings a.
(Closed) IFI 70-1113/91-02-12:
Enhancement / clarification of implementing procedures for developing PARS.
The licensee's corrective action for this concern included revisions of Procedure 2 (added last two pages), Procedure 5 (Appendix 5), and Procedure 7 (new Appendix 2). Although the licensee still had not established a predetermined PAR for each postulated accident (as suggested by the subject finding and in Section 3.3 of Regulatory Guide 3.67), the revised procedural guidance represented a significant improvement over what was previously provided.
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6 b.
(Closed) IFI 70-1113/92-15-01:
Maintaining documentation of training provided to offsite support groups.
With the assistance of the New Hanover County Emergency Services Director, the licensee reconstructed records of offsite training given on 15 separate dates during 1992 to various.upport groups.
The licensee recognized the need to retain auditable records of activities required under the RCEP, and had done so for training given thus far in 1993.
c.
(Closed) IFI 70-1113/92-15-02:
Resolution of administrative discrepancies in RCEP Procedures.
Inspection disclosed that, of the four categories of administrative discrepancies cited in the discussion of the subject concern, only the least significant (viz., text pages in some procedures had higher revision numbers than the cover page) had not yet been corrected.
The Senior Program Manager, Emergency Preparedness and Security, stated that this incongruity could and would be fully corrected in the next cycle of procedural 1
revisions.
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d.
(Closed) IFI 70-1113/92-15-03:
Review and upgrade of the RCEP Procedures I
This IFI primarily concerned Procedure 5, " Criticality,"
Sections 5-1 (Emergency Director Instruction) and 5-5 (Nuclear l
Safety Advisor Instruction). This procedure underwent a major reorganization to prioritize procedural steps and to reduce impediments to procedural " flow," with very successful results.
7.
Exit Interview The inspection scope and results were summarized on September 10, 1993, with those persons indicated in raragraph 1.
The inspector described l
the areas inspected and discussed in detail the inspection results listed below. With respect to tLe IFI, the inspector informed licensee management that RCEP training requirements for 1993 would be considered by the NRC to be unfulfilled without the provision of appropriate formal training to the affected individuals.
Licensee management was also informed that four IFls from previous inspections were considered closed, as delineated in Paragraph 6.
Proprietary information is not contained in this report. Dissenting comments were not received from the licensee.
Item Number Category. Descriotion. and Reference 70 ' '3/93-08-01 IFI - Provision of formal initial training or annual retraining to designated members of the ERO prior to the end of 1993 (Paragraph 5).
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Index of Abbreviations Used in This Report ECC Emergency Control Center ERO Emergency Response Organization IFI Inspector Followup Item LOA Letter of Agreement NRC Nuclear Regulatory Commission PAR-Protective Action Recommendation RCEP Radiological Contingency and Emergency Plan y
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