IR 05000321/1985023

Insp Repts 50-321/85-23 & 50-366/85-23 on 850715-23. Violation Noted:Inadequate Training of on-shift Operations Supervisors When Acting as Emergency Director & Failure to Adequately Maintain Emergency Implementing Procedures

ML20134N181
Person / Time
Site:	Hatch
Issue date:	08/13/1985
From:	Cline W, Marston R, Sartor W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20134N156	List: IR 05000321/1985023 ML20134N152
References
50-321-85-23, 50-366-85-23, NUDOCS 8509050027
Download: ML20134N181 (6)

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UNITED STATES

[O L E 'o NUCLEAR REGULATORY COMMISSION

[" . ~' o REGION ll 101 MARIETTA STREET, y j t ATLANTA, GEORGI A 30323

%,,,,,# AUG 2 61985 Report Nos.: 50-321/85-23 ind 50-366/85-23 Licensee: Georgia Power Con.pany P. O. Box 4545 Atlanta, GA 30302 Docket Nos.: 50-321 and 50-366 License Nos.: DPR-57 and NPF-5 Facility Name: Hatch 1 and 2 Inspection Conducted: July 15-23, 1985 Inspectors: h / M f d MB/6 W. M. Sartor,~J g Dhte Signed N Od R.R,.qayson g Date Signed Approved b :

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W E. Cline, Section (hief i O h Date Signed uvivision of Radiationfafety and Safeguards i

SUMMARY Scope: This routine, unannounced inspection entailed 68 inspector-hours o. site and 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> offsite in the emergency preparedness area Results: Three violations and two unresolved items were identifie DR ADOCK O

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REPORT DETAILS Persons Contacted Licensee Employees

• R. K. Moxley, Associate Quality Assurance Field Representative

• • • P. E. Fornel, Quality Assurance Site Manager

• R. S. Grantham, Operations Training Supervisor

• W. H. Rogers, Health Physics Supervisor

"J. E. Collins, Emergency Plan Coordinator N. L. Purdin, Emergency Preparedness Training

"H. C. Nix, General Manager - Plant Hatch A. W. Anthony, On Shift Operations Supervisor J. R. Barnes, On Shift Operations Supervisor B. Coleman, On Shift Operations Supervisor

• • S. C. Ewald, Manager, Nuclear Chemistry and Health Physics

• • L. T. Gucwa, Chief Nuclear Engineer Other licensee employees contacted included construction craftsmen, engineers, technicians, operators, mechanics, security force members, and office personne Other Organizations Stanley Crews, Administrator, Appling General Hospital L. R. Lynch, Charge Nurse, Appling General Hospital A. P. Zurbrugg, Administrator, Meadows Memorial Hospital E. Origgers, Engineering Director, Meadows Memorial Hospital M. Smith, Head Nurse, Meadows Memorial Hospital NRC Resident Inspectors

• • • P. Holmes-Ray

• Attended on site exit interview conducted July 18, 1985

• • Conference call exit interview conducted July 23, 1985

• • • Participation in onsite and conference call exit interviews Exit Interview The inspection scope and findings to date were summarized on July 18, 1985, with those persons indicated in paragraph 1 above. A second exit interview was conducted on July 23, 1985, via conference call following inspection completion. At this time, three violations and two unresolved items were discusse The first violation addressed inadequate training of On Shif t Operations Supervisors (0505) personnel when acting as Emergency Directo The second violation related to failure to adequately maintain emergency implementing procedures. The third violation concerned the conduct of

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annual audits as required by 10 CFR 50.54(t). Two unresolved items were discusseo. Georgia Power Company requested and was granted a conference call on July 26, 1985, to further discuss the violations and unresolved items. This discussion between Georgia Power Company management, Plant Hatch and NRC personnel was informative, but resulted in no changes to the inspection finding The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspectio . Unresolved Items *

Two unresolved items pertaining to emergency preparedness training and emergency support instrumentation were identified during this inspection and are discussed in paragraph . Changes to the Emergency Preparedness Program (82204)

Pursuant to 10 CFR 50.47(b)(16), 10 CFR 50.54(q), and 10 CFR 50, Appendix E, Sections IV and V, this area was reviewed to determine whether changes were made to the program since the last routine inspection on September 12-17, 1984, and to note how these changes affected the overall state of emergency preparednes The inspector discussed the licensee's program for making changes to the emergency plan and implementing procedures. The inspector verified that changes to the plan and procedures were reviewed and approved by managemen One revision to the Plant Hatch Site Emergency Plan had been made since the last insoectio Because this plan change was perceived by licensee representatives as 'a potential decrease to the effectiveness of the Plan, the licensee properly received NRC approval of this change prior to implementation in accordance with 10 CFR 50.47(b). NRC concluded the plan change requested by the licensee did not in fact result in a decrease in the effectiveness of the pla Discussions were held with licensee representatives concerning recent modifications to facilities, equipment, and instrumentatio Licensee representatives indicated that no substantive changes had been made, but that implementing procedures were being reissued in a revised numbered forma The organization and management of the emergency preparedness program were reviewed. The inspector verified that there had been no significant changes in the organization or assignment of respoasibility for the plant and corporate emergency planning staffs since the last inspectio The

Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or deviation A

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inspector's discussion with licensee representatives also disclosed that there had been no significant changes in the organization and staffing of the offsite support agencies since the last inspectio No violations or deviations were identified in this program are . Knowledge and Performance of Duties (Training) (82206)

Pursuant to 10 CFR 50.47(b)(15) and 10 CFR Part 50, Appendix E, Section IV.F, this area was inspected to determine whether emergency response personnel understood their emergency response roles and could perform their assigned function The inspector reviewed the description (in the emergency plan) of the training program, training procedures, selected lesson plans, and training reccrds, and interviewed members of the instructional staff. Based on these reviews and interviews, the inspector was unable to determine that an

. effective training program was in place because the training records are anachronistic when examined against the current trainir:g program as explained by the licensee representativ The licensee representative provided the inspector with an emergency response organization training roster which had been approved by the General Manager on March 19, 198 This training roster provides an audit base for emergency response organization training when implemented. The inspector indicated that an examination of emergency response organization training records against the training roster would be a followup item to be evaluated during a subsequent inspection (321, 366/85-23-01).

The inspector conducted walk-through evaluations with three On Shift Operations Supervisors (OSOS) to determine whether those personnel designated to act as Emergency Director during -the initial stages of an emergency had been adequately trained in this role. Two of the three OSOS had some difficulty in classifying the simulated events provided in the walk-throughs, and all three OSOS provided incorrect protective action recommendations on at least one occasion. The problem appeared to be mainly in the training area but the problem appeared to be compounded by the organization of the implementing procedures. Based on these findings, the licensee was advised that they had failed to maintain a training program sufficient to ensure that licensee employees are familiar with their specific response duties. This finding was identified as a violation of 10 CFR 50.54(q) which requires licensees to follow and maintain in effect emergency plans which meet the requirements of 10 CFR 50 and the planning standards of 10 CFR 50.47(b). Specific requirements .for emergency preparedness' training are addressed in 10 CFR 50.47(b)(15) and 10 CFR 50, Appendix E, Section IV.F (321, 366/85-23-02). It should be noted that licensee management representatives stated that a finding in a recent drill showed that improvements were needed in the area of emergency classificatio The licensee management representative further indicated that followup action was in progress to correct this self-identified proble W-

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f4 During the walk-through with the first OSOS, the inspector noted that the

! OSOS was unable to locate the procedure dealing with the initial notification to offsite agencies. The OSOS was using the Technical Support Center controlled copy of the Emergency Plan Implementing Procedures and it was incomplete in that it did not contain the Emergency Implementing Procedure 63 EP-EIP-073-0, Use of Emergency Communications. This matter is a violation (321,366/85-23-03) in that the licensee failed to maintain emergency implementing procedures as required by Technical Specification 6. . Licensee Audits (82210)

Pursuant to 10 CFR 50.47(b)(14) and (16) and 10 CFR 50.54(t), this area was inspected to determine whether the licensee had performed an independent review or audit of the emergency preparedness progra Reccrds of audits of the program were reviewed. The records showed that an ir. dependent audit of the program was conducted by Plant Hatch Quality Assurance with audit reports dated January 25 and May 7,1985. A Georgia Power independent audit was conducted May 6 - June 27, 1985. The audit .

records for 1985 showed that the State and local government interfaces were evaluated, and the licensee representatives stated the report would be made available to State and local government authoritie Audit findings and recommendations were presented to plant and corporate management. A request for the previous audit report resulted in licensee management representative stating that an independent audit of its emergency preparedness progrart in 1984 which included an evaluation for adequacy of interfaces with State and local governments had not been conducted. Licensee's awareness of this audit requirement was reflected in an Interoffice Correspondence dated October 16, 1984, requesting an annual review of adequacy of interface with State and local government for emergency preparedness prior to December 31, 1984. This matter was further discussed in a telephone conversation on July 23, 1985, between NRC management representatives and licensee plant and corporate management. This finding is identified as an apparent violation of 10 CFR 50.54(t) (321,366/85-23-04). Inspector Followup (92701)

A previous inspection listed as an unresolved item the licensee's failure to adequately document the verification of the May 1983 test of the Emergency Communication System per License Procedure HNP-4860. A review of Document Control records for this May 1983 test now includes a copy of the Georgia Emergency Management Agency Emergency Notification Network (ENN) checklist reflecting a May 10, 1983 test of the Plant Hatch ENN with all stations responding positively. The licensee has also incorporated HNP-4860 into its Surveillance Progra Based on the above findings, this unresolved item (50-321/84-38-01, 50-366/84-38-01) is close L. -

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Coordination with Offsite Agencies (92706)

- The inspector held- discussions with licensee representatives regarding the coordination - of. emergency plan training with offsite agencie The organizations and assistance to be:provided were identified and supported by current - letters of agreement. The inspector visited the offsite ~ medical

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support facilities'.and' interviewed hospital personnel and examined facilities dedicated for treatment of . radiological ' contamina't ed patient : Interviews at Appling General Hospital - Nursing Home indicated training fo . hospital personnel had last been conducted on April 2G and 27, 1984, and no training for 1985 had 'been scheduled to dat The ,Hatchf Emergency Plan '

requires annual- training for: the hospital- personnel who may'he. involved in the emergency medical assistance program. : Neither onsite plant personnel nor Georgia Power Company corporate representatives. were. able- to' provide ~.

' training records to indicate adherence to this emergency , plan . training ;

. requirement. Licensee representatives stated that they believed the records

were available to support that training. was'garformed but' were unable to locate them during the period': of the - inspection. This -finding is an i

unresolved item pending further review and evaluation (321,366/85-23-05).,

. O Personnel. interviewed at Meadows Memorial Hospital indicated their hospital l

personnel 'were being scheduled for training prio'r to the upcoming Plant Hatch's Emergency Preparedness Exe rci se.- An examination of dedicated facilities at Meadows Memorial Hospital wasimade. It was noted that-tw radiation monitoring instruments in the treatment facility for' contaminated patients were marked with calibration: stickers which, indicated the instruments were overdue for calibration. -This finding is' identified as.an unresolved item pending further review and evaluation-(321, 366/85#3-06).

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