ML20206C728

Insp Repts 50-413/87-03 & 50-414/87-03 on 870316-20. Violations Noted:Failure to Maintain Emergency Plan Implementing Procedures Consistent W/Tech Spec 6.8.1.d

ML20206C728
Person / Time
Site:	Catawba
Issue date:	04/03/1987
From:	Cunningham A, Decker T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20206C691	List: IR 05000413/1987003 ML20206C687 ML20206C708 ML20206C728
References
50-413-87-03, 50-413-87-3, 50-414-87-03, 50-414-87-3, NUDOCS 8704130150
Download: ML20206C728 (10)

See also: IR 05000413/1987003

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UNITE 3 STATES

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># F fig *o NUCLEAR REGULATORY COMMISslON

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1 REGION il

101 MARIETTA STREET,N.W.

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• *- ATLANTA, GEORGI A 30323

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.....*' EPR 0 21987

Report Nos.: 50-413/87-03 and 50-414/87-03

Licensee: Duke Power Company

422 South Church Street

Charlotte, NC. 28242

Docket Nos.: 50-413 and 50-414 License =Nos.: NPF-35 and NPF-48

Facility Name: Catawba 1 and 2

Inspection Conducted: Mar 16-20, 1987

Inspector: A t, bu Y 7

Patt .51gned

A. L. Cunningham

Accompanying Personnel: D. H. Schultz

G. hmann

Approved by: &1( Y Af

T. R. Decker, Section Chief Dath Signed

Division of Radiation Safety and Safeguards

SUMARY

Scope: This special announced inspection involved review and evaluation of the

licensee's response to findings identified during the Emergency Response

Facility Appraisal conducted September 3-11, 1985 (50-413/85-39,'50 414/85-36).

Results: One violation was identified involving maintenance of emergency

preparedness implementing procedures required by Appendix A Technical

Specification 6.8.1.d(paragraph 5.c). No deviations were identified.

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REPORT DETAILS

1.- Licensee Employees

• R. E. Harris, System Emergency Planner

• M. Bolch, Station Emergency Planner (CNS)

• R. Leonard, Station Emergency Planner (MNS)

• L. E. Parker, Nuclear Production Specialist

• R. Sharpe, Nuclear Engineer-Licensing

• S. Apple, Meteorologist

R. Blessing, Associate Perfonnance Engineer

D. Lee, Staff Health Physicist

A. Dileard, Design Engineering Supervisor

F. Simpson, Applications Analyst

• Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized on March 20, 1987, with

those persons indicated in paragraph 1 above. The inspector described the

areas evaluated, and discussed in detail the inspection findings listed

below. The violation regarding maintenance of emergency planning

implementing procedures (Paragraph 5.c) was fully discussed. . No

dissenting comments were received from the licensee. The licensee did not

identify as proprietary any of the materials provided to or reviewed by

the inspector during this inspection.

3. Licensee Action on Previous Enforcement Matters

No enforcement items were identified during the Emergency Response

Facility appraisal of September 1985.

4. Unresolved Items

Unresolved items were not identified during this inspection.

5. Emergency Response Facility Appraisal Weaknesses (992078)

This section addresses the status of corrective actions implemented by the

licensee in response to Weaknesses identified during the September 1985

Emergency Response Facility' appraisal. The bracketed numbers in the

following paragraphs correspond to the item numbers assigned in Appendix A

to the letter of December 23,1985,'which transmitted NRC Report Nos.

50-413/85-39 and 50-414/85-36. All _open items identified herein will be

reviewed during subsequent inspections.

a. [1] (Closed) Appraisal Weakness (50-413/85-39-1, 50 414/85-36-1):

Meteorological data processed through the OAC was not validated. .The

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licensee performed a functional check of the Operator Aid Computer

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(0AC) . meteorological channels. An accuracy check -of - the , OAC

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meteorological' data available. on 0AC Units #1 and -#2 was also

i' performed on December 5,1985. System problems 11dentified were

corrected, and retest was performed on February 2, 1986.- >

j Meteorological data available on 0ACL Units #1 and #2 were approved

4 for official use with the exception of . sigma-theta values. The

inspector reviewed the data and associated-documentation. 4

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I b. [2] (Closed) Appraisal Weakness (50-413/85-39-2, 50-414/85-36-2):

There was no demonstration that continued availability of data in the

form of 15-minute averages of wind speed, . wind direction, and

j atmospheric stability equaled or exceeded the required 90% cumulative

data recovery efficiency. The licensee performed a study of' the

availability of meteorological data ' for CY-86. Al review 'of the .

results of this study revealed that collected wind speed, wind

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i direction, and atmospheric stability data exceeded - a cumulative

recovery efficiency of 93% during calendar year 1986.

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5 c. [3]- (Closed) Appraisal Weakness (50-413/85-39-3, 50-414/85-36-3):

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Changes to offsite communication procedures used in the TSC.were-

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neither reviewed nor approved in preparation for required use at all

times. Procedure RP/0/B/5000/14, Change O' , " Follow-up Notifications

from TSC," was approved for issue on December 10, 1986. This

procedure provided a method for performing follow-up notifications in

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i accordance with NUREG-0654.

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j During review and evaluation of the subject item, inspection

disclosed that several controlled copies of the Emergency Plan

! Implementing Procedures (EPIPs) did not contain the' approved revised

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Emergency Response Procedure RP/0/B/5000/14. It was determined that

j the subject procedure was not included'in controlled copies of the

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EPIPs assigned to the Station Manager, Superintendent of Maintenance,

I and the Station Emergency Planner. Station personnel ~ offered no

! explanations regarding failure to distribute the revised procedure,

! or failure to maintain all controlled copies of the EPIPs as

required. This finding was fully discussed with . licensee

representatives prior to and during the exit interview. The-licensee

I was informed that the subject finding constituted a violation :of

Technical Specification 6.8.1.d. . No dissenting comments were made.

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' Violation (50-413/87-03-01, .50-414/87-03-01): Failure to maintain

Emergency Plan Implementing Procedures. (EPIPs) as required by

Appendix A Technical Specification 6.8.1.d, Amendment 'Nos. 52 and 33 ,'

to Catawba Units 1 and 2, respectively. This item will be reviewed

during subsequent inspections.

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6. Emergency Response Facility Appraisal.0 pen Items (992078)

This section addresses the status of corrective actions implemented by the

licensee in response to Open Items identified during the referenced

appraisal. The bracketed numbers in the following paragraphs correspond

to the items assigned in Appendix B to the letter of December 23, 1985,

- which transmitted NRC Report Nos. 50-413/85-39 and 50-414/85-36. All

items identified herein which remain open, will be reviewed during

subsequent inspections,

a. [1] (Closed) Open Item (50-413/85-39-08, 50-414/85-36-03):

Installation of a separate Technical Support Center (TSC) Operator

Aid Computer (0AC) alarm video. The-inspector concurred with the

licensee's finding that, based upon a cost-benefit analysis, the need

for a separate OAC alarm did not warrant current implementation. It

was noted, however, that this item would be factored into future

review and evaluation of TSC computer equipment and needs.

b. [2] (Closed) Open Item (50-413/85-39-09, 50-414/85-36-09):

Evaluation of the licensee's response to the Technical Evaluation

Report (TER) regarding radiation monitoring. This item and

exceptions related thereto was treated in Supplement V to the Catawba

SER of February 1986.

c. [3] (0 pen)OpenItem(50-413/85-39-10,50-414/85-36-10): Correction

of the transfer of TSC-0AC data to the VAX computer to preclude

airborne contamination of personnel involved therein during possible

emergency condition. An inspector reviewed the ventilation system

arrangement to the OAC Computer Room and noted that a positive

pressure is maintained in the room. Note, however, that under

certain airborne radiological accidents, the outside air supply

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providing the positive pressure would either be manually isolated

(loss of positive pressure) or would become the source of airborne

activity. The basis for the finding was unchanged, and the inspector

concluded that this item remained open.

d. [4] _(Closed) Open Item (50-413/85-39-11, 50-414/85-36-11):

Evaluation of the adequacy of the primary computer access used in the

TSC. Inspection disclosed that computer access, as designed, was

satisfactory,

e. [5] (Closed) Open Item (50-413/85-39-16, 50-414/85-36-16):

Submittal of a description of the technical basis for the puff-

advection atmospheric dispersion model and a complete description of

the upgraded meteorological measurements program. Documentation for

the puff-advection atmospheric dispersion model is contained in the

licensee's document, "McGuire Nuclear Station Offsite Dose Assessment

Computer Model," Volume 1. A complete description of the upgraded

meteorological measurements program is contained in Volume 1,

Section 2.3 of the Catawba FSAR.

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f. [6] (Closed) Open Item (50-413/85-39-25, 50-414/85-36-25):

Verification that the OSC has been expanded in size. Inspection

disclosed that the OSC has been expanded as committed.

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9 [7] (0 pen)OpenItem(50-413/85-39-27,50-414/85-36-27): Completion

of construction and establishment of operational readiness of the

consolidated CMC. The location of the consolidated CMC has been

finalized. Construction was in progress at time of inspection. This

item will remain open until such time that the subject facility is

completed and fully operational.

1. [8] (0 pen) Open Item (50-413/85-39-29, 50-414/85-36-29):

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Establishment of dedicated communication lines between the CMC and

VAX computer systems and use of dial-up access as a backup. This

item remains open until such time that the consolidated CMC

construction is completed and the facility is fully operational.

7. Emergency Response Facility Improvement Items (990278)

This section addresses the status of corrective actions implemented by the

licensee in response to Improvement Items identified during the referenced

appraisal. The bracketed numbers in the following paragraphs correspond

to the items assigned in Appendix C to the letter of December 23, 1985,

which transmitted NRC Report Hos. 50-413/85-39 and 50-414/85-36. All

items identified herein which remain open will be reviewed during

subsequent inspections,

a. [1] (Closed) Improvement Item (50-413/85-39-01, 50-414/85-36-01): ,

Moving the Emergency Coordinator's station to a centralized location

within the Technical Support Center (TSC) to enhance his interaction

with the staff, and provide viewing of the facility's status boards

and displays. Inspection disclosed that the current location of the

Emergency Coordinator's station offers no impediment to required

conduct of TSC operations.

b. [2] (Closed) Improvement Item (50-413/85-39-02, 50-414/85-35-02):

Using a different technique to alert control room operators that

core temperature data is outside of the expected range. Inspection

disclosed that 0AC program modifications which perform " range within

limits" validation checks of core-exit thermocouples (CET's) have  ;

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been completed. Range of CET's is compared to parameters such as

power and coolant average temperature, and if out-of-range relative

to these parameters, then alerting of operators is performed. CET

off-normal readings are now related to abnormal core condition.

c. [3] (Closed) Improvement Item (50-413/85-39-03, 50-414/85-36-03):

Identifying core temperature functions separately on the displays.

Inspection disclosed that 0AC program modifications which perform ,

validation checks of core-exit thermocouple (CET) readouts have been i

completed. Additionally, the validated values are used for other- l

functions, such as SPDS, wFere the five highest CETs are averaged. '

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Since the readouts are validated before usage, the inspector

concluded that no separate identification of CET functions was

required,

d. [0] (0 pen) Improvement Item: Update Data Acquisition Systems from

the plant to the Technical Support Center (TSC) and the Crisis

Management Center (CMC). All Improvement Items listed below relate

directly or indirectly to the facility data acquisition system and

are therefore included under this summary item. As indicated, all

items hereunder are open and collectively discussed in the

commentary.

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[4] (0 pen) Improvement Item (50-413/85-39-04,, 50-414/85-36-04):

Validating Operator Aid Computer (OAC) data through use of

appropriate software algorithms.

[5] (0 pen) Improvement Item (50-413/85-39-05, 50-414/85-36-05):

Automating the present manual transfer of data from the OAC-VAX

computers, providing the VAX with continuous access to data at, or

near, real time.

[19] (0 pen) Improvement Item (50-413/85-39-28, 50-414/85-36-28):

Providing the CMC with a continuous computer data input at, or near,

real-time.

[20] (0 pen) Improvement Item (50-413/85-39-30, 50-414/85-36-30):

Standardizing Catawba Station data sets to include all Regulatory

Guide 1.97 parameters in the standard format.

[21](0 pen) Improvement Item (50-413/85-39-31, 50-414/85-36-31):

Improving the method of data transmission to the CMC such that the

data is real-time, or near real-time. -

An inspector reviewed the current status of the data Acquisition

System for collection, storage, analysis, display, and communication

of plant parameters. It was determined that the system attributes

were essentially the same as those that existed at the time of the

appraisal in September 1985. Consistent with the Improvement Items

listed above, the following considerations are indicated, namely:

Validating 0AC data with computer-based algorithms.

Automating data transfer from the OAC to the VAX computer system

to provide continuous data access at, or near, real-time.

Provision of a data stream to the TSC and CMC at, or near,

real-time.

Assure that the data stream to the TSC and CMC include

Regulatory Guide 1.97 variables as a minimum.

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The inspector also determined, however, that the licensee was

actively pursuing implementation of an interim system and a "new"

system. The interim system will eliminate the mannual data transfer

from the OAC to the VAX computers (" floppy disk transfer"). The new

system (early 1988) will embrace the other desired attributes of

validation, auto-transmission, and all accident parameters being

available. However, the licensee currently envisions an up-date

frequency of three to five minutes for each data set. This frequency

may not be consistent with NRC goals of "real-time or near real

time." These items will be reviewed during subsequent inspections,

e. [6] (Closed) Improvement Item (50-413/85-39-06, 50414/85-36-06):

Designating personnel with required expertise to operate the OAC

terminal, as part of the TSC response team, or improving the OAC

interface to assure that casual users can more easily understand its

-operation. Although the subject system is not user-friendly, inspection

disclosed that .the licensee has provided a cadre of trained 0AC

computer operators who are readily available and present on all

operating shifts.

f. [7] (Closed) Improvement Item (50-413/85-39-07, 50-414/85-36-07):

Changing the OAC terminal keyboards, positioned in a nearly vertical

orientation, to an ergonomically correct position to minimize

mis-keying. Inspection disclosed that the curtant mounting of the

OAC terminal keyboards pose no significant Impediment or delay to

access of desired data.

g. [8] (0 pen) Improvement Item (50-413/85-39-12, 50-414/85-36-12):

Revising Section 5.6 of Procedure HP/0/8/1009/15 to provide adequate

instructions, and upgrading and clarifying containment leak rate

curves. An inspector reviewed the referenced procedure and noted

that no revisions were made that corrected observed procedural

problems. The inspector noted, however, that ERP HP/0/B/1009/18,

"Offsite Dose Projection", supercedes (and corrects) HP/0/B/1009/15.

The licensee intends to cancel HP/0/B/1009/15 following completion of

implementation of 1009/18.

h. [9] (Closed) Improvement Item (50-413/85-39-14, 50-414/85-36-14):

Conducting an evaluation of the quality of meteorological data

obtained from the National Weather Station (NWS) at Charlotte, and/or

the McGuire Nuclear Station meteorological facility for real-time l

conditions at Catawba. The evaluation appeared to utilize acceptable  ;

statistical and analytical concepts. The licensee's findings

included the following:

Wind Direction Data at McGuire NS or the NWS Charlotte Airport  !

yields distributions of direction differences with too much  !

scatter to reliably estimate wind direction at Catawba NS. l

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Wind' Speed Data from Charlotte Airport yield wind speed twice

that at Catawba NS. Thus, Catawba wind speed equals one-half of

the NWS Charlotte Airport wind speed..

Data from McGuire Station yields an acceptable substitute for

wind speed at Catawba Station.

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Temperature Difference - The NWS Charlotte Airport can not

provide temperature difference data.

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Data at McGuiri Station yields distribution of . temperature

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differences with too much scatter to reliably estimate the

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temperature difference at Catawba.

1. [10] (0 pen) Improvement Item (50-413/85-39-15, 50-414/85-36-15):

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Revising procedures which use meteorological data to reflect the

hierarchy for data substitution, and specifying an' assigned data '

! averaging period (i.e., 15 minutes) and valid time of the

observation. Specifying averaging period _ and valid time of the

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observation for the digital displays or sumary ' sheets provided

through the VAX computer. The initial response of the licensee ,

(letter dated June 6, 1986)-to this item was subsequently revised in

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l a letter dated June 15, 1986. The inspector confirmed that the

appropriate procedures (HP/0/B/1009/13 and HP/0/8/1009/15) have been-

revised to detail the hierarchy of data substitution and specifying

an assigned data averaging period. The hierarchy established,

however, is not consistent with the findings of the study performed

by the licensee in response to Catawba Item [9]. For example, the

revised procedures require that if the wind speed at the Catawba

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facility is not available, the data should be_ obtained from the NWS,

, Charlotte Airport. However, the study concluded that the win'd speed

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at the Charlotte Airport is-not a suitable substitute for the Catawba

Station. This item will remain open until the discrepancy is

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resolved.

j. [11] (Closed) Improvement Item (50-413/85-39-17, 50-414/85-36-17)

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Identifying regional and forecast meteorological information to be

i provided on request by the National Weather Service Station in

i Charlotte. The licensee maintains a staff of professional

meteorologists and routinely receives meteorological ~ data from NOAA.

It appears that the licensee's expertise in this field permits its

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staff to adequately provide regional and forecast meteorological data

during an emergency.

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k. [12] (0 pen) Improvement Item (50-413/85-39-19, 50-414/85-36-19):

Modifying the computerized dose assessment model to include ingestion

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pathway dose calculations and making available to the NRC or -

~;- submitting to the NRC documentation related thereto. The licensee-

reported that.invastigation'of commercially available dose assessment

models was not ccmpleted. A final decision to include the capability

to calculate ingestion pathway doses has_-not been made.

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1. [13] (Closed) Improvement Item (50-413/85-39-20, 50-414/85-36-20)

l Evaluating the Nuclear-23 method to ensure that both whole body and- .

thyroid doses are appropriately' considered in protective action'

l reconnendations. Inspection disclosed that the -licensee evaluated

i. ' the Nuclear-23 method to ensure that both whole body and thyroid

l doses were appropriately . considered in protective . action

, recommendations. The evaluation technique and results were reviewed -

and determined acceptable.

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i m. [14] (Closed) Improvement Item (50-413/85-39-21, 50-414/85-36-21):

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Providing an uninterrupted power line for all necessary components of

the TSC data acquisition system. Inspection disclosed that an '

- uninterrupted power supply for all necessary components of the data

acquisition and display system . was provided. The necessary

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components of the data acquisition and display- system are: 1).0AC,

2) Mohawk data link, 3) VAX -computer, 4)LA-120 terminal;

F 5) telephone lines, 6) Tektronics terminal; and 7) dose assessment

terminal.

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n. [1E] (Closed) Improvement Item (50-413/85-39-22, 50-414/85-36-22):

Revising Enclosure 4.1 of Procedure RP/0/A/5000/01 to include

specific radiological levals which correspond to emergency action

level for Notice of Unusual Event and Alert classifications'in lieu

of referencing Technical _ Specifications limits. Inspection disclosed

that Emergency Action Levels listed in .RP/0/A/5000/01 for

radiological conditions were specific values based on observed plant

conditions or specific instruments. The inspector. concluded that the  ;

1 EALs were in compliance with requirements and guidance promulgated in

Appendix E to 10 CFR 50, and NUREG-0654.

o. [16] (Closed) Improvement Item (50-413/85-39-24,' 50-414/85-36-24):

Establishing a method to assure that all plans and/or procedures

brought to the TSC by responders are verified as updated, controlled-

l documents. Inspection disclosed that lesson plans reflected emphasis

on use of controlled documents by Emergency Response personnel, and  ;

that personnel observed during drills and exercises were using '

controlled documents.

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p. [17] (0 pen) Improvement Item (50-413/85-39-26, 50-414/85-36-26)

Developing a permanent method of displaying plant mimics in the OSC.

Inspection disclosed that development of the above was not completed 3

at time of inspection. This item will remain open until such time .

that display methods have been finalized and implemented.

q. [18] (0 pen) Improvement Item (50-413/85-39-27, 50-414/85-36-27):

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Verifying the completion of construction of the consolidated CMC.

!. Construction of the consolidated CMC was in progress at time .of

, inspection. This item remains open until such time that construction

[ is completed and the facility is fully operational.

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r. [22] (Closed) Improvement Item (50-413/85-39-32, 50-414/85-36-32):

Reviewing Enclosure 5.5 to Procedure HP/0/B/1009/13 regarding Source

Term " Corresponds to" to ensure that its intended purpose is

) understood. The inspector reviewed the procedure and determined that

Enclosure 5.5 was revised to eliminate reference to source term.

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