IR 05000416/1986012

Insp Rept 50-416/86-12 on 860512-16 & 21.No Violations or Deviations Noted.Major Areas Inspected:Emergency Preparedness

ML20204J530
Person / Time
Site:	Grand Gulf
Issue date:	07/09/1986
From:	Decker T, Gooden A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20204J516	List: IR 05000416/1986012 ML20204J513
References
50-416-86-12, NUDOCS 8608110132
Download: ML20204J530 (10)

Text

.,

UNITED STATES '

/ p HGuq'o NUCLEAR REGULATORY COMMISSION

• y< --

~

o REGION 11 101 MARIETTA STREET. 'E If ATLANTA, GEORot A 30323

%.s... j

.

Report Nos.: 50-416/86-12 Licensee: Mississippi Power and Light Company Jackson, MS 39205 Docket Nos.: 50-416 License Nos.: NPF-29 Facility Name: Grand Gulf 1 Inspection Conducted: May 12-16 and May 21, 1986 Inspector: ' ab f . kd

~A. Gooden Date Signed Accompanying Personnel: A. E..T baka Approved by: d/. A E 7 86 T. R. Decker, Chief Date ' Signed Emergency Preparedness Section Division of Radiation Safety and Safeguards SUMMARY Scope: This routine, unannounced inspection was conducted in the area of emergency preparednes Results: No violations or deviations were identifie PDR ADOCK 05000416 G PDR

.

, _ , - , - - - , - , _ _ - - - , - , - - _ . -

,

. 2 REPORT' DETAILS

. Persons Contacted Licensee Employees

• J. E. Cross, Site Director

• P. B. Benedict, Emergency Planning Coordinator

• J. D. Bailey, Nuclear Compliance Coordinator

• L. F. Daughtery, Compliance Coordinator L. F. Dale, Director, Licensing and Safety

• F. W. Rosser, Radiation Control Supervisor

• J. V. Parrish, Chemistry / Radiation Control Superintendent J. C. Vincelli, Chemistry / Radiation Control Technical Assistant

• D. H. Wells, Training Instructor Supervisor

• S. M. Feith, Director, Quality Assurance

• R. F. Rogers, Assistant to General Manager

• C, R. Hutchinson, General Manager J. R. Haley, Staff Assistant, Nuclear Licensing and Safety

• D. Terrell', Emergency Planning G. W. Ingram, Quality Assurance Supervisor - Internal Audits L. D. Porter, Senior Quality Assurance Representative A. W. Benson, Supervisor, Document Control A. V. Holmberg, Fire Protection Coordinator

• D. V. Rodriquez, Emergency Planning C. D. Stafford, Shift Superintendent C. Elisaesser, Shift Superintendent C. Hicks, Shift Superintendent Other licensee employees contacted included engineers, technicians, operators, and office personne Other Organizations A. C. Garner, Director, Claiborne County Civil Defense E. Blanche, Director, Tensas Parish Civil Defense S. L. Jennings, Chief, Claiborne County Fire Department E. S. Fuente, Director, Mississippi Division of Radiological Health W. H. Spell, Admfaistrator, Louisiana Nuclear Energy Division W. Neiswender, Administrator, Claiborne County Hospital NRC Resident Inspectors

• J. L. Caldwell, Resident Inspector R. C. Butcher, Senior Resident Inspector

• Attended exit interview

.

-

3 Exit Interview The inspection scope and findings were summarized on May 16, 1986, with those persons indicated in Paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection finding No dissenting comments were received from the licensee. The inspection was extended to May 21, 1986, to conduct an interview with the offsite medical support grou The following new items were identified during this inspection:

Two unresolved items * described in Pargraph 7 (Failure to provide training to four members of the emergency organization), and Paragraph 9 (no formalized procedure for documenting the review of offsite support groups agreement letters) were identified during the inspectio The inspector telephoned a licensee representative on June 27, 1986, to inform the licensee that a Region II review of the report details presented in Paragraph 7 below resulted in a violation of Federal Regulations (Failure to provide training in accordance with Administrative Procedure 01-S-04-21)

as compared to an Inspector Followup Item as discussed during the exit meeting. However, following the above referenced communication, the issue was classified as an unresolved item due to the licensee's claim that incorrect or out-of-date information was given to the inspector for revie The licensee did not identify as proprietary any of the material provided to or reviewed by the inspector during this inspectio . Emergency Detection and Classification (82201)

Pursuant to 10 CFR 50.47(b)(4) and 10 CFR Part 50, Appendix E, Sections I and IV.C, this program area was inspected to determine whether the licensee used and understood a standard emergency classification and action level schem The inspector reviewed the licensee's classification procedures. The event classifications in the procedures were consistent with those required by regulation. The classification procedures did not appear to contain impediments or errors which could lead to incorrect or untimely classificatio Selected emergency action levels (EALs) specified in the classification procedures were reviewed. The reviewed EALs appeared to be consistent with the initiating events specified in Appendix 1 of NUREG-0654. The inspector noted that some of the EAls were based on parameters obtainable from Control Room instrumentatio * Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or deviation .

-

The inspector verified that the licensee's notification procedures included criteria for initiation of offsite notifications and for development of protective action recommendations. The notification procedures required that offsite notifications be made promptly after declaration of an emergenc During the discussions .with State and local officials regarding their periodic review of EALs used by the licensee, the inspector noted that these officials are in agreement with the licensee's EAL schem Interviews were held with three Shift Superintendents to verify that they understood the relationship between core status and such core damage indicators as containment dome monitor, inadequate-core-cooling indicator, high-range effluent monitor, fuel temperature indicator, vessel coolant level, and post-accident primary coolant analysis. All interviewees appeared knowledgeable of the various core damage indications and their relationship to core statu The responsibility and authority for classification of emergency events and initiation of emergency action were prescribed in licensee procedures and in the Emergency Plan. Interviews with selected key members of the licensee's emergency organization revealed that these personnel understood their responsibilities and authorities in relation to accident classification, notification, and protective action recommendation Selected Emergency Plan Procedures (EPPs) were reviewed by the inspector and discussed with licensee personnel The EPPs provided direction to users concerning timely classification of accident All personnel interviewed appeared to be familiar with the classification information in the EPP Walk-through evaluations involving accident classification problems were conducted with three Shift Superintendents. All personnel interviewed promptly and properly classified the hypothetical accident situations presented to them, and appeared to be familiar with appropriate classification procedure No violations or deviations were identifie . Protective Action Decision-Making (82202)

Pursuant to 10 CFR 50.47(b)(9) and (10) and 10 CFR Part 50, Appendix E, Section IV.D.3, this area was inspected to determine whether the licensee had 24-hour per-day capability to assess and analyze emergency conditions and make recommendations to protect the public and onsite workers, and whether offsite officials had the authority and capability to initiate prompt protective action for the publi The inspector discussed responsibility and authority for protective action decision-making with licensee representatives and reviewed pertinent portions of the licensee's emergency plan and procedure The plan and procedures clearly assigned responsibility and authority for accident

.

-

assessment and protective action decision-making. Interviews with members of the licensee's emergency organization revealed that these personnel understood their authorities and responsibilities with respect to accident assessment and protective action decision-makin Walk-through evaluations involving protective action decision-making were conducted with three Shift Superintendents. Personnel interviewed appeared to be cognizant of appropriate onsite protective measures and the range of protective action recommendations appropriate for offsite protectio Personnel interviewed were aware of the need for timeliness in making initial protective action recommendations to offsite official Interviewees demonstrated adequate understanding of the requirement that protective action recommendations be based on core condition and containment status even if no release is in progres Licensee procedures made provisions for contacting responsible offsite authorities on a 24-hour basis. Backup communication links with offsite authorities were availabl The inspector verified that the offsite decision-makers could be contacted from the Control Roo No violations or deviations were identifie . Notification and Communication (82203)

Pursuant to 10 CFR 50.47(b)(5) and (6) and 10 CFR Part 50, Appendix E, Section IV.D, this area was inspected to determine whether the licensee was maintaining a capability for notifying and communicating (in the event of an emergency) among its own personnel, offsite supporting agencies and authorities, and the population within the EP The inspector reviewed the licensee's notification procedure The procedures were consistent with the emergency classification and EAL scheme used by the licensee. The inspector determined that the procedures made provisiens for message verificatio The inspector determined by review of applicable procedures and by discussion with licensee representatives that adequate procedural means existed for alerting, notifying, and activating emergency response personnel. The procedures specified when to notify and activate the onsite emergency organization, corporate support organization, and offsite agencies. Selected telephone numbers listed in the licensee's procedures for emergency response support organizations were checked in order to determine whether the listed numbers were current and correct. The phone number for the Mississippi Division of Radiological Health was incorrect as liste This matter was brought to the attention of a licensee representative for resolvin No further problems were note The content of initial emergency messages was reviewed and discussed with licensee representative The initial messages appeared to meet the guidance of NUREG-0654, Sections II.E.3 and II. Licensee representa-

,

. 6 tives stated that the format and content of the initial emergency messages had been reviewed by State and local government authoritie Communications equipment in the Control Room, OSC, TSC, and EOF was inspected. Provisions existed for prompt communications among emergency response organizations, to emergency response personnel, and to the publi The installed communi' c ation systems at the emergency response facilities were consistent with system descriptions in the Emergency Plan and implementing procedure The inspector conducted operability checks on selected communications equipment in the Control Room, the TSC, and observed the use of communications equipment in the EOF during a practice drill. No problems were observed. The inspector reviewed licensee records for the period beginning January 19, 1985, which indicated that communication tests were conducted at the frequencies specified in NUREG-0654,Section II.N. Licensee records also revealed that corrective action was taken on problems identified during communication test Redundancy of offsite and onsite communication links was discussed with licensee representatives. The inspector verified that the licensee had established a backup communication system according to the description found in the licensee's Emergency Plan (Section 7.5, Communications). The backup system made use of a UHF radio system. The inspector requested an operational check and noted that the system operated properl No violations or deviations were identifie . 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 (May 1985) 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 reviewed the licensee's procedure (Nuclear Licensing Safety Administrative Procedure 1.3)

governing review and approval of changes to the plan and procedures. The inspector verified that changes to the plan and procedures were reviewed and approved by management. It was also determined by transmittal letter review that all such changes made during the period of August 1985 - May 1986, were submitted to NRC within 30 days of the effective date, as require Discussions were held with licensee representatives concerning recent modifications to facilities, equipment, and instrumentation. The inspector was informed that there had been no changes since the last inspectio 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 responsibility for the plant and

. 7 corporate emergency planning staffs since the last inspection. However, a significant change was made to the licensee's offsite emergency organizatio The position of Technical Assistant was added to the EOF Staff with the responsibility for coordinating the requests of the Offsite Emergency Coordinator (OEC) with other staff regarding matters related to plant operations and engineering. Other changes to the EOF Staff involved administrative changes (e.g., position titles, chain of command, etc.). The inspector's discussion with licensee representatives disclosed that there had been no significant changes in the organization and staffing of the offsite support agencies since the last inspectio The inspector reviewed the licensee's program for distribution of changes to the emergency plan and procedure Document control records and an examination of selected control copies showed that appropriate personnel and organizations were sent copies of plan and procedural changes, as require No violations or deviations were identifie . 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, and selected lesson plans, and interviewed members of the instructional staff. Based on these reviews and interviews, the inspector determined that the licensee had established a formal emergency training progra Records of training for key members of the emergency organization for the period January 1985 to April 1986 were reviewe The following findings were noted: Two members of the emergency organization were not provided respiratory protection training in accordance with Administrative Procedure 01-S-04-10. This procedure specified that all personnel receiving respirator training pass an initial physical examination with an annual medical review in accordance with Administrative Procedure 01-S-08-04, Section One member of the emergency organization was not fit tested in accordance with Administrative Procedure 01-S-08-4, Section 6.3, which specified that all individuals utilizing respiratory protection equipment be trained and fitted to ensure proper respiratory protectio The proper fit is to be redetermined every two years (130 days). One member of the emergency organization was not provided specialized training in accordance with Administrative Procedure 01-S-04-21,

[ l

.

-

Section 6.4, which states emergency personnel should receive specialized training predicated on their involvement in specific emergency response area One member of the emergency organization was not provided Radiation Worker II retraining in accordance with Administrative Procedure 01-S-04-2 .The inspector discussed these findings on June 27, 1986, with the licensee's Site Emergency Preparedness Coordinator. The licensee did not agree with the inspector's findings. The licensee representative indicated that the documentation provided during the inspection was not current. As a result, this matter is being identified as an unresolved item and will be reviewed during future inspection Unresolved Item (50-416/86-12-01): Failure to provide emergency response personnel training in accordance with Administrative Procedure 01-S-04-2 According to training records, with the exception of the findings stated above, all other training provided to key members of the emergency organization (both site and corporate personnel) was consistent with the approved procedure Since the last inspection, several specialized training sessions were conducted that included the following areas:

1) Communications, 2) Radiological assessment (including dose assessment, plume tracking, surveys, etc.), and 3) Public informatio In addition, several practice drills have been conducted in various areas due to exercise weaknesses identified during the December 3,1985, exercis Training for offsite emergency response support organizations was also reviewed. The review involved discussions with licensee representatives, discussions with offsite agency personnel, and an examination of licensee records and correspondenc Licensee records and correspondence indicated that annual training was provided on July 29, 1985, and August 5, 1985, to local government support agencies (Civil Defense, fire, and law enforcement)

and on December 27, 1985, to the medical support personnel and State radiological health personne The inspector conducted walk-through evaluations with selected key members of the emergency organization. During these walk-throughs, individuals were given various hypothetical sets of emergency conditions and data and asked to respond as if an emergency actually existed. The individuals demon-strated familiarity with emergency procedures and equipment, and no problems were observed in the areas of emergency detection and classification, notifications, assessment actions (to include plant conditions, in plant sample collection and analysis, and offsite monitoring), and protective action decision-making. In addition to conducting walk-through evaluations, the inspector observed a practice drill in which the licensee demonstrated the following capabilities: 1) Site Access Point (SAP) activation, 2) field team deployment, 3) timely notification to State with followup notification (FUN) messages transmitted from the EOF according to Emergency Plan

.

-

Procedure (EPP) 10-S-01-06, and 4) timely dose assessment by the EOF staff that compared favorably with the Offsite Monitoring Team result No violations or. deviations were identifie . 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 Records of audits of the program were reviewed. The records showed that an independent audit of the program was conducted by the Corporate Office Quality Assurance Group during the period February 24 - March 14, 1986, and April 15, 1986. This audit fulfilled the 12-month frequency requirement for such audits. The audit records showed that the State and local government interfaces were evaluated, and that findings concerning the interfaces were available to State and local government authorities upon request. Audit findings and recommendations were presented to plant and corporate management. Audits of the emergency preparedness program were not conducted prior to completion of construction (1982). However, a review of past audit

- reports (1982 through 1985) indicated that the licensee complied with the retention requirement for such report Licensee emergency plans and procedures required critiques following exercises and drill Licensee documentation showed that critiques were held following periodic drills as well as the ar.nual exercise. The records showed that deficiencies were discussed in the critiques, and recommendations for corrective action were mad The licensee's program for follow-up action on audit, drill, and exercise findings was reviewed. Licensee procedures required follow-up on deficient areas identified during audits, drills, and exercise The licensee had established several mechanisms for tracking identified problem The

" Quality Assurance Tracking System," maintained by Quality Assurance (QA)

Audits, is used to track audit items until they are satisfactorily complete The Corporate and Site Emergency Preparedness Coordinators (EPCs) also maintain tracking systems as a tool for follow-up on deficient items. The Site EPC tracking system was not evaluated during this inspection; however, the Corporate EPC tracking system known as " Corporate Action Tracking Management System (ATMS)" was reviewed and determined to be effective in following up on item No violations or deviations were identifie . Coordination with Offsite Agencies (82210)

The inspector held discussions with licensee representatives regarding the coordination of emergency planning with offsite agencie Written agreements existed with those offsite support agencies specified in the Emergency Plan; however, the agreements had not been renewe The most

.. 10 recent dated agreement letter for a State or local agency was 1981. Through interviews with representatives of selected local support agencies, the inspector was informed that these agencies prefer having agreement letters periodically reviewed and updated to reflect current commitments, capability, and resource This matter was discussed with a licensee representative, who indicated that agreement letters are reviewed as part of the annual emergency plan review to certify them as being current. However, no formalized procedure existed to document the agreement letter revie During a recent audit of the offsite interface by the licensee's QA Group, it was noted that the availability of certain offsite support would be prioritized during emergencies with the county receiving first priorit This matter was being tracked by the licensee for resolution. Due to the absence of a formalized procedure for documenting the review and update of letters of agreement, it could not be determined if an agreement letter review was being conducted as stated in Section 8.5 of the licensee's emergency plan. The licensee was informed that this matter was considered an unresolved ite Unresolved Item (50-416/86-12-02): Documentation of the review of agreement letters with offsite support group The inspector conducted personal and phone interviews with representatives of selected local and State support agencies (See Paragraph 1) to determine if the licensee was periodically contacting those agencies for purposes of offering training and maintaining mutual familiarization with emergency response role Those interviews disclosed no significant problems regarding the interfaces between the licensee and the offsite support agencies listed in Paragraph . Inspector Follow-up (92701)

(Closed) Inspector Follow-up Item (IFI) 85-44-04: Attachment I to Procedure EPP 10-S-01-12 appears inadequate because it failed to provide conversion factors for shutdown times greater than 12.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> A review of Attachment I, Revision 9 to EPP 10-S-01-12 indicated conversion factors for time after shutdown had been extended to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> (four days).

l