ML20207J301

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Audit on 870223-0511 of Emergency Preparedness Program & Associated Emergency Implementing Procedures
ML20207J301
Person / Time
Site: Oyster Creek
Issue date: 06/26/1987
From: Macfarlane D
GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20207J096 List:
References
S-OC-87-01, S-OC-87-1, NUDOCS 8808310011
Download: ML20207J301 (34)


Text

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February 23, 1987 - May 11, 1987 S-oC-87-ol Audit dates (s) Audit No. Oyst r Creek Nuclear Generating Station N iHty

                            -                                                                                                                                                    j Reference N/A           'Rev.        N/A                       Documents:       Attachment 3                          Rev.         N/A                          l P.O.

Activity item (s) Emergency Preparedness Program Attendees Name Title Representing l 4 R.L. Long Director, Nuclear Assurance Nuclear Assurance ] 3, 5 G.J. Giangi Manager, Emergency Preparedness Nuclear Assurance ' 1, 3, 5 R.L. Sullivan Emergency Preparedness Manager Nuclear Assurance j 5 J.J. Barton Deputy Director Oyster Creek l 2, 3 R.D. Fenton Manager, Plant Training Nucicar Assurance - 2, 3, 4, 5- J.L. Wil'iams Support Prog. Trg. Manager Nuclear Assurance

  • 2 L.T. Thompson Instructor Nuclear Assurance l 3, 5 R.D. Davidson Operator Trg. Manager Nuclear Assurance (Audit Attendee List continued on Attachment #4) >

l PURPOSE l To review and assess the Emergency Plan and its associated implementing procedures l in accordance with regulatory requirements and the Oyster Creek Technical Sppcific- j ations. j SUMMATION j This audit reviewed the Emergency Plan administrative / implementing procedures and activities necessary to implement the Emergency Plan at Oyster Creek,. This included review of progthm responsibilities, training, facilities and equipment, activation and assessment notification procedures, drill observations and offsite agency interfaces. Results of this review determined that the program is in compliance with regulatory requirements and effectively implementing the Quality Assurance Program requirements. COMPLETlON June 11, 1987 l X l Close out required for l 2 l Non Conformances. Target Date Signed: - * / conct. .o ey: I

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g7 Awd.: Team Leacer Audit Approved by: o, /s/ . .. Markows 6/26/87 Director. QA Manager. QA Program Cate l l Reviewed respense. Will check implementation by: C Re Audit QA 08t' C Follow up l l Audit Satisf actorily completed, closed l l QA o.ie l l l A0000412 e si I 8800310011 00001P  ; j PDR ADOCK 05000;: ? Q PNV - - - - - - j

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S-0C-87-01 L Bn:rg:ncy Preparcon:ss ( .. P:ge 2.of 14-- , i .

             ,        II. DETAILED DISCUSSION A.         Organization                                                                                                                                                        l A review of the GPUNC Organization Plan, GPUNC Bsergency Plan, Energency Preparedness Administrative and Implementing procedures and 1986 Duty Rosters was performed to verify that the Oyster Creek'                                                                                                   l' Bnergency Response Organization was in compliance with the Code of Federal Regulations.

j It was determined from this review that an effective energency l response organization was in place to cope with radiological energencies. He organizational authorities, responsibilities and dutie- 4.41gned to seabers of the Oyster Creek Bnergency Organization - were adequately delineated in each emergency preparedness procedure to assure compliance with the above requirements. l It was also verified by review of the Operations Shift Coverage log l that a Group Shift Supervisor is on -duty at all times to identify and i classify in-plant or on-site energency conditions as delineated in the GPUNC Energency Plan and procedure 6430-IMP-1300.01. Implementation  ! of the GSS's function to perform his responsibilities required by - these procedures was performed by review of 5 drill packages and , records for 2 Unusual Events declared on 1/26/87 and 2/10/87. Records indicated that the GSS's activities were performed in accordance with program requirements. ne personnel changes to the Bnergency Duty Roster were verified by record review of the Energency Roster Duty Change Forms covering f 1986. The nomination and approval process which .is an Oyster Creek Division /Departa7at responsibility was satisfactorily implemented in accordance with the requirements of procedure 6430-ADM-1319 01. Records of sampled personnel indicated that nominated personnel set the requirements of Exhibit 5 of procedure 6430-ADH-1319.011 and, that t personnel were added or changed - to the Duty Roster by utilizing  ! Exhibit 6 of the same procedure. In addition, management responsibility to maintain the organizational readiness of energency response members on the Duty Roster was noted. All positions observed were fully staffed. We audit team verified, by drill observation, that Duty Roster Team

                                               #3 was performing their energency response assignments during the quarterly drill. of 3/27/87.                                        However,                 a lack of organizational readiness was noted during the quarterly drill in the Control Room.                                                                                                ;

It was observed that personnel were having difficulty in performing ' the Radiological Assessment Coordinator (RAC) Model. A discussion of this observation is in Section G. Procedure 6435-SUR-1310.11, which provides for Energency hty Roster maintenance, was verified by review of file records and issued duty rosters. Quarterly reviews were performed, personnel qualifications were verified and confidential telephone information was maintained and distributed by the Baergency hty Roster Coordinator in accordance-with the aforementioned procedure.

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S-0C-87-01 Energ:ncy Preparednoss t .. pig] 3 of 14 The Emergency Plan also delineates augmentation of the station's

       ,             emergency                 response                    organization        through assistance provided by
   .                 off-site organizations.                                    Ietters of Agreements, verified by audit review, were established with agencies to provide support from Federal, State and local agencies of law enforcement , fire departments, hospitals, physicians, etc. when called upon.

B. Program Adequacy The 1986 Annual Emergency Preparedness Internal Audit conducted by Emergency Preparedness (E.P.) staff members was verified, by record review, to have been completed in accordance with procedure 6435-SUR-1310.13. Areas of program review included: 1985 Annual E. P. D. Audit, GPUN Audit Report S-0C-86-03, NRC Inspection Report No. 50-219/86-07, INPO Good Practices (EP-801) Audit Procedures and the General Surveillance Program. Fifteen actions items developed from this review were assigned by the E.P. Manager to staff members for corrective action. All fifteen items were entered into the E. P. Action Item Tracking System. Review of computer records for these items indicated ' that 10 items were closed and 5 remained open. , Specifically, some of the program changes included: 1 Changing the method in which walk-through drills are conducted I (per procedure 6430-ADM-1319.01). Improving and correcting surveillance procedures associated with Emergency Phone Numbers, Prompt Notification System and Emergency Preparedness staff training to be consistent peccedure 6430-ADM-1319.02. Follow-up and close-out of previous EPD audit discrepancies. In addition to the above changes, the Corporate Emergency Plan 1000-PLN-1300.01 is also being revised by the Emergency Preparedness 1 Department to incorporate program changes developed by IMI and- Oyster Creek for Plan upgrade. Some of the changes to be reflected in the Oyster Creek Plan include: Update of emergency action levels (EAL's). ' Changes in ED/ESD responsibilities. Adding description of Post Accident Sampling System. 1 Revise Table 23 training description for clarification to more closely correspond to practice. This item is identified in audit finding S-0C-87-O'. 01. Update demographic tables. This change, once reviewed by Licensing and Energency Preparedness Departments, was anticipated to be submitted to the NRC by June 1, i 1987. l A review of administrative and implementing procedures (6430/6435 series) was performed by comparing procedural requirements against completed drill / event record packages to determine if procedures

adequately reflected program requirements and, if instructions were 4

1 4

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6 c <4 S-0C-87 r Es:rgsney Proparcda:en - 4e P:32 4 of 14-  ; ,= .,

     .                 effectively implemented.               After reviewing documents / records ' selected               ;
  • from 5 drills and 2 unusual events, 'it was verified that procedures 2

1 adequately delineated progran requirements and that ' energency response i moabers were adequately perfvains required activities and documenting i same. With the ~ exception of the- progras deficiencies identified by audit findings in this - report, program reviews and upgrade were performed and asintained by the bergency Pr(paredness Department. he audit team identified two administrative and five implementing procedures to hersency Preparedness as- being within the scope of the - l

                      -Quality -Assurance Plan - for which the ITS detarminations :were not                                 !

j -marked on the procedures' cover sheet. hergency Preparedness responded to this concern by indicating that this = ites was missed in i the procedure revision procese between -in-section reviewers and' word l processing. In-section reviewers were- reminded of their. , responsibilities and to specifically check for ITS applicability when revising' procedures. Procedures will be corrected no later than 8/30/87. A verification of corrective action ' will be performed at j

this time. Additionally, this itea will be incorporated in the 1987 1 Bsergency Preparedness Internal Audit. ,
 <                                                                                                                         i It should be noted that procedure 6430-IMP-1300.31, "Classification of                              !

] Energency Conditions" needs to indicate the availability of 3 i Lakehurst's weather service. The weather service is closed between I 2300 hours and 0500 hours. Refer to recossendation No.1. ) l C. Trainina . 1 ] A review was performed of training documents for onsite and offsite ' personnel who are required to receive training in emergency response l I 4 activities. This review was conducted to determine if the program satisfied the requirements of 10CFR50 Appendix E, the Oyster Creek j Baergency Plan and ITS implementing procedures. 1 ) Th'e results of this review indicated that the Training Program was not implementable as written. The Training Program had not been revised; , and, the RAC Model training was indeterminate. A discussion relative I I to these concerns follows. The training program requirements described in 10CFR50, Appendiz E for both on-site 'and various off-site personnel indicates that both categories are to be provided initial and periodic retraining to-ensure their familiarity with their specific energency response duties. These requirements, which are futher delineated in the Baergency Plan, were found by document review to be consistent with the aforementioned code. l 1 I l l

8 * '

                                                             -S-0C-87-01 Betrg:ncy Prsparedazs
     ..                                                       P g2 5 cf 14 A detailed review was performed of the On-Shif t, Initial Response and
       . Dnergency Support Organizations described in Exhibits 2 and 3 of Procedure 1000-ADM-1319.01. These exhibits were compared with Table 23 of the Baergency Plan to insure adequacy and consistency of training requirements for emergency response personnel.              Also, a second check was performed by comparing these documents against the Training & Education's Snergency Plant Training Program 1720.0 _(Rev.
1) to verify compliance with the Baergency Plan and Operational Quality Assurance Plan.

Results of this review indicated that Oyster Creek's Baergency Preparedness Training Program was not maintained current as required by the Operational Quality Assurance Plan. Audit finding S-0C-87-01.01 was issued. The results of this review are the following: Exhibit 2 of 1000-ADM-1319.01, "Scope of Training for On-Shift Personnel", did not capture all of the training requirements listed in Table 23 of the Emergency Plan for seven positions. Specifically, they aret GSS, GOS, CRO, Maintenance workers, GRCS, RCT and Chemistry Technicians. A listing of missing requirements are identified in audit finding S-0C-87-01.01. Exhibit 3 of 1000-ADM-1319.01, "Scope of Training for Emergency Response Personnel", describes courses and topics required to be taken by emergency response personnel. With the exception of the Dnergency Director and Bnergency Support Director, the following courses could not be correlated to the positions listed in Table 23 of the Dnergency Plant Facilities Dose Projection / Assessment Radeon Surveys Site Protection / Assembly / Accountability Emergency Radeon/ Chemistry Contaminated Injuries /Decon Emergency Notification / Call Out Public Information The Training & Education's Baergency Plan Training Program 1720.0 (Rev. 1) is not implementable as written. Specifically, references are used which have been deleted (i.e. 102.1), terms are present which are no longer app)tenhie (i.e. EEOF), documentation' requirements have changed (i.e. qualification card no longer used)and the program does not implement Table 23 of the GPUN Bnergency Plan. A review was conducted of training records (1985-1986) to substaniate training for four Radiological Controls management personnel, who were required by the requirements of Table 23 of the Energency Plan to l l

     , ,       ,                                                            S-OC-87-01 Bn:rgency Pr:paredn:ss P:33 6 of 14 receive training for the Radiological Assessment Coordinator position-(RAC) .       The auditor was unable to verify training attendance sheets for certain courses required by the program.                         As a result, audit finding S-0C-87-01.02 was issued to Plant Training since it is ' their responsibility by procedure 6430-ADM-1319.01 to maintain documentation for ell Energency Preparedness classroom training.                                    Procedure 6230-ADM-2600-03 requires that users of attendance sheets, who intend to certify an individual attendance or completion of training, shall complete the form.

Five attendance sheets which certified . Radiological Controls training for Cycle 87-1, in support of Baergency Pre paredness , were found-incomplete. Program numbers, course numbers and lesson plan numbers were omitted from each attendance sheet. Without this information it cannot be adequately verified which course was given to the class. In addition, two attendance sheets could not be produced for audit review when requested. Some two weeks later the attendance sheets were provided to the audit team af ter it was presumed that the records were lost. As a result, QDR 87-004 was issued to Radiological Controle. Initial review of Training Content Records (TCR) indicated that TCR's 781.03, "IS C Initial Training" and 781.041 "0SC Retaining" were not formally approved for classroom instruction. his concern was reported to the Training Department and their reply indicated that a signed and approved document was on file to validate Tm 781.03. The l TG 781.041 file copy had been removed and used in training, but had not been replaced. A copy was created from the word processing diskette, signed and approved. To prevent this condition from recurring, the Training Department's DCC clerk was instructed not to issue the master file copy to instructors. Review of the Training Department's Bsergency Plan Training Program 1720.0 (Rev. 1) indicated that it was not implementable as written. We program did not implement the requirements of Table 23 of the i Bnergency Plan, ne 710 series lesson plans and qualification cards j were not usedI nor was the training program changed to delete obsolete procedural references. This concern was identified to the Training l Department and their response indicated the following: 1 ) Training Program 1720.0 (Rev. 1) is no longer applicable to the

Emergency Preparedness training being conducted at Oyster Creek.

J A new Corporate Baergency Preparedness Training Program Description is being developed along with a job analysis of each emergency position. This new document will outline the training l program requirements for all GPUN sites. he job analysis will 1 identify the tasks that are performed in each position. he final , l Version should be issued by July 31, 1987. 1

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I l l I l

  • 8 '

S-0C-87-01 Ba;rg:ncy Pr:paredne:s

         - "                                                            P2g3 7 cf 14 The number of changes occurring in Baergency Preparedness Planning
            .       & Training at the Corporate and site levels were cause for the
  • Training Program 1720.0 and the 710 series lesson plans to become ineffective. This condition is being corrected by program changes. As an interim measure, the Training Department is using GPUN Corporate Baergency Preparedness Plan 1000-PLN-1300.01, Corporate Baergency Preparedness Program 1000-ADM-1319.01 and industry event items (i.e. LER's, SOER's, NUREG's, etc.).

In order to ensure consistency in training, all Tm's will be checked against Table 23 of the Daergency Plan and the Baergency Preparedness Program. The Program Description has build-in checks and balances to ensure persons who are required to comply with it do so (e . g . , the ISD process requires all lesson materials to be reviewed aud approved by Daergency Preparedness management). This review wUl be completed by June 30, 1987. Review of Tm 789.01, "Dnergency Team Training", indicated that the content for emergency maintenance and operations subjects does not 1 actually train personnel in the principles and techniques of ' activities being performed. This TCR only specifies which station l administrative and/or abnormal operating procedures can be utilized by i the various emergency response members. This concern was submitted to l the Training Department and their reply indicated the following: ' A recommendation was made to the Corporate Mana ger , Baergency Preparedness to change Table 23 of the Deergency Plan to reflect the correct interpretation of subject areas for the position  ! depicted. The training listed in Table 23 is intended to provide I general guidelines. The intent of Course 789.01 is not to train personnel in principles and techniques of activities. This type of training is addressed in skill development as a prerequisite for the craft concerned. Dnergency Team Training is concerned with Station Administrative and/or Abnormal Operat6g Procedures and how these l procedures impact on emergency team workers. The specialized training requirements delineated in Section 8 of the Dnergency Plan states that both station and station support l organization personnel assigned specific Bnergency Plan duties / responsibilities will receive specialized training for their respective assignments. Ta ble 23 of Emergency Plan lists the personnel who will receive specialized training. These personnel will be requalified annually and the interval between training cycles shall not exceed 15 months. A verification of personnel qualifications was performed by checking attendance sheets against the department's computer data base and the 1986 Bnergency Duty Roster /Dnergency Support Duty Roster for ench e

                                                     ,-e

S-0C-87-01 Bn:rg:ncy Prcparedntss

          .                                                                  P:ge 8 cf 14 quarterly period.              he results indicated that organizational readiness
          .        to support an emergency event was implemented.                 There were adequate numbers of qualified personnel to man the positions listed on the rosters. However, a weakness noted in ~ the training cycle was the necessity of. Training to depend on the 15 month cycle as opposed to a 12 month cycle plus 3 months sa fety window to qualify Table 23 pe rsonnel . Refer to Recommendation No. 2.

Control of personnel assigned emergency response positions requiring respirator qualifications was noted on the Nty Roster. Distribution of the Quarterly Duty Roster to department coordinators identifies those personnel whose respirator qualifications have expired. he plant coordinators are requested to make sure that these personnel update their qualifications. In addition, menos are sent in advance to advise personnel of the re-qualification due date. We Emergancy Plan, Section 8, paragraph 3, states that GPUNC will invite offsite emergency management organizations, on an annual basis, to participate in training. These organizations includes government management agencies, hospital personnei., police, fire and ambulance service etc. Review of training records, menos, planning instructions and TCR's indicaten that training was provided by the Training Department and Radiation Management Corporation to satisfy this requirement. D. Facilities and Equipment A review of emergency respcase facilities and equipment controlled in accordance with procedure 6430-ADH-1319.02 was performed. Inventory lists submitted by emergency response facilities indicated that adequate levels of equipment were on hand, instruments were calibrated and required equipment was serviceable to insure equipment readiness during an emergency event. Inventory lists were completed af ter each use but in no case were they completed less than quarterly by the assigned company organization. ne auditor verified by review of Inventory Checklists, for the events evaluated in this audit, that equipment was maintained in accordance with the above procedure. l No facilities observed during the 3/27/87 drill, Bnergency Control , Center and the Technical Support Center, were verified to have adequate equipment inventory. Required procedures, drawings and emergency phones were in place. All drawings and procedures were adequately controlled in accordance with plant procedures to ensure compliance with procedure 6430-ADM-1319.01. A review of emergency communications systems controlled by the l surveillance procedures (6435 series) was performed. It was verified by comparing test results against the surveillance schedule that emergency communication equipment was tested in accordance with the designated schedule. Test data indicated that systems were functional and available to ensure operational readiness. i l

4 . i kerstacy Preparedn3sc

         ,                                                                                                                       P:33 9 of 14 It was noted during' review of surveillance procedure 6435-SUR-1310.05,                                                          l "Prompt Notification Systes", that 7 sirens failed their surveillance                                                            ;
  • test due to weather conditions (2/12/-2/19) when the sirens became  ;

frozen. Specification OCIS-409038-001, OGGS Pr> apt Notification i Systen Freeze Protection Modification was initiated for installation - and testing to correct the deficiency. his ites is currently-tracked under Licensing Action Ites 86082.07. . i 8 E. Notifications I

A review was performed of the hergency Plan Implementing Procedures (EPIP's) dealing with notifications to onsite personnel and offsite F agencies during a declared or simulated emergency. A - total. of 5 simulated drills and two Unusual Events were included in this review. '

he initial notifications. and subsequent messages (by paging) to onsite personnel and offsite agencies (NJ State Police, NRC, BNE, Local) were performed in accordance with the requirements of th e .  ; Emergency Plan. A coarse trend of records for drills and declared i energencies supported this conclusion. 4 Problems identified in critiques pointed out the need of procedure clarification (6430-IMP-1300.03) for the EOF Communication  ! Coordinator. Shif t personnel had to be prompted to prevent the use of an incorrect form for Initia? Notification (6430-IMP-1300.03). he j Station Status Checklist had incorrect EAL numbers. when transmitted to NJBRP and offsite notifications were also incomplete. Notification of 4 $ the Unusual Event was never made to the State Police due to the alert ' being declared and the alert notification was made to Ocean County rather than the State Police. Call-out of ISC and OSC personnel was

less than acceptable. He notification problems were resolved through i assignment of action items by the Emergency Preparedness Manager. '

Notification of general public within the 10 mile Energency Planning l l Zone (EPZ) is accomplished through activation of 42 sirens which i comprise the Prompt Notification Systes. Rose sirens are maintained

by procedure 6435-SUR-1310.05 to assure operational readiness. he  ;
'                                                   actuation of the system is usually conducted annually in conjunction with a Plant exercise.                               his was verified completed by audit                                            !

i observation. In addition, it was verified by file review that 75.000 l  ! pamphle ts were sent to the general Mpulation within the EPZ on an  ! ! annual basis. He pamphlets provided information on what to do in the j oyent of an emergency. A letter (3/2/87)' from NRC Region 1 to OGGS indicates that the rederal hersency Management Agency (FMA) has determined that the d a Alert and Notification system installed around Oyster Creek Nuclear } Generating Station satisfies the requirements of , NUREG-0654/FMA-REP-1, Rev.1, and FMA-REP-10. 1 f A full review of the offaite radiological energency preparedness plans l site-specific to OGGS will be completed by FMA in accordance with FMA Rule 44CPR350 at a later date. i l 1 _ . - . _ - , , _ , . _ , , _ . _ . . - . . _ . . ...,y,-,_%,.._,_,,x.m_m,_____., y,,y.__ .._,,___m_,, ,-,_m,m__,. ..r .,,,.,_,,,m,, ,

 . ,     .                                                    S-0C-87-01 Bn:rg:ncy Prsparedness            )
    *-                                                        Page 10 of 14 F. Activation and Assessment The four classes of energency events in Section 4 of the Baergency Plan are     delineated   in procedure   6430-IM P-1300.01.       Within the procedure four energency classes are identified and instructions are provided to help classify and identify - each category and appropriate-           i energency action level (EAL). The EAL's are predetermined conditions             ;

or values which refer to radiological dose rates, specific j contamination levels of airborne or waterborne concentrations of radioactive materials, etc. which when exceeded require the implementation of the Baergency Plan via procedure 6430-IMP-1300.02. Implementation of procedure 6430-IMP-1300.02 was verified by review of records maintained by Energency Preparedness for two Unusual Events declared on 1/26/87 and 2/10/87. On each occasion, interface with the N. J. Bureau of Nuclear Engineering (BNE) was demonstrated. Representatives of BNE visited OCNGS on 1/26/87 to ensure they understood the Event and to review radiological assessment data. On 2/10/87, the OCNGS radiological assessment of the event indicated that airborne contamination levels were minimal outside of plant buildings and undetectable at the site boundary. he N.J. BNE Reuter Stokes Monitoring System detected no discernable increase above background even though the general wind direction should have carried the plume directly over a monitor. The two computer programs identified in Section 5 of the Baergency Plan for performing offsite dose assessment projections are incorporated into procedure 6430-IMP-1300.09. he systems are the RAC Model and MIDAS. he RAC Model was developed by Radiological and Environmental Controls while the MIDAS program was developed by Pickard, Iowe and Garrick, Inc. In addition to these systems, a third system which serves as a backup to the RAC/ MIDAS is BUD. This program was developed by RPS Corporation. The three systems provided by this

procedure enable the Radiological Assessment Coordinator (RAC) and Environmental Assessment Coordinator (EAC) to select, during a 1 declared emergency, the dose projection code to use for a given circumstance.

G. Drills, Exercises and Events I he periodic drills and exercises conducted during 1986 thru the 1st quarter of 1987 to test the station's emergency preparedness was l reviewed by drill records and observation. The drill records reviewed  ; by the audit team were maintained by the Baergency Preparedness Section in Building 12. A total of six drills, were evaluated (1 annual, 4 quarterlies and 1 unannounced). In addition to this review, two Unusual Events were declared by the station and were also incorporated into the audit review. l The drill records indicated that conduct of drills and stercises were scheduled and performed in accordance with the Bsergency Plan. These records indicated that drills were adequately preplanned and executed. Drill packages contained the necessary documents and records to support drill scenarios. Drill descriptions found in j

scenarios adequately delineated drill objectives and schedules for j i

! \

 , ,     ,                                                  S-0C-87-01        _ _

Bn:rg ncy Praparednees -l

     *.                                                     P ge 11 of 14                  -l assigned' emergency response personnel'. -Drills were adequately covered
       . by qualified drill observers.       Subsequent post drill critiques were satisfactorily performed. Deficiencies were . identiff ed and assigned to the applicable - organisations for corrective action. ~ Action items           l were verified to be tracked and satisfactorily closed out through                   ,

review of the Energency Preparedness Action Ites Tracking System. l 1 The . performance if Quarterly Drill, Scenario - No. 10 (Rev. 0) was observed by audit team members on 3/27/87 at the Technical Support  ! 1 Center (TSC) and the Control Roca (ECC). It was intent of the audit team to determine if the drill was. properly implemented in accordance with the _ requirements of the Energency Plan and Energency Plan  ; Inplementing Procedures.  ; i The audit team attended the pre-drill briefing -(3/26/87) and received j the drill scenario package and drill observer arabands. It was ~; observed that attendees = had met several times previously and' were ' familiar with their assigned duties.  : On the day of the drill the following observations were _ made at the  : Control room (ECC) and the Technical Support Center (TS C) . Specifically, they are ECC: Comments based on observations of RAC performance. i The RAC did not reference or utilise Appendix I of GPUN procedure 6430-IM P-1300. 35. The RAC Hodel computer used a default duration release time of 8.0 l hours. This duration is not in accordance with Section 5.3.5 of  ! the Energency Plan. j IVo RCTs were assigned to assist the RAC. One RCT sonitored  ! control room indicators and completed a data sheet for the RAC's review and use. The second RCT manned both the radiological and r enviornmental assessment lines and physically operated the RAC , Model using the IBM-PC unit. When the auditor asked the RAC if he i could use the IBM-PC unit and execute the RAC Model, he admitted l that he had missed computer training due to other engagements, but [ felt confident that the technicians are trained and capable of l using the RAC Model. Refer to audit finding S-CC-87-01-02. i The RCI manning both emergency lines and operating the IBM-PC unit j had a very difficult time attempting to communicate with both the ISC and EACC and operate the RAC Model all at the same time. The 00(GS Backup Baergency Dose Calculation Progran prepared by l RPS Corporation on 1/23/86 correlated to the Backup Dose l Calculation Computer Training (TCR #86-4, Rev. 0), prepared on i 6/4/86. However, in executing the RAC Model using the IBM-PC l unit, steps were performed which were not specified in the above  ! documents. 1 i i i

S-oc-87-01 Bserg ncy Pr:paredness v.- Page 12 ef 14 The RCT initially could not get the progras to load and bootmp

        -        and did attempt to use the BUEDCP Manual. It was. not until the
    -            observer arrived on the scene that the RAC Model was correctly set up. Af ter the RCT's initial attempt in using the BUEDCP Manual,
                - the manual was never used or referred 'to during. the remainder of the drill.
  • The RAC did not give the Energency Director a PAR after the upper limit of the PAG for child thyroid (25 REM) was projected to be exceeded greater than 40 REN.
  • One ' drill observer did more than coach during the drill. He became more of a participant in the RAC Hodel functions and was able to maintain the drill when the above personnel experienced difficulty.

These concerns were presented to Energency Preparedness for corrective action as part of the auditor's contribution to the post-drill critique. TSC

  • generally conducted themselves in a The drill participants professional manner. One instance of questioning by an engineer with the ISC Coordinator's direction was responsible for delaying the flow of the scenario; o therwise , the participants followed their prescribed role activities and responses.
  • One instance of communication between the Control Room and the ISC went awry. A request via telecopy was .ande to the TS C for information relative to the event which went unanswered for about one hour. The request came to light when the Con *rol Room called and again requested a response to their inquiry. Initially, the response should have been provided within five minutes.
  • One engineer had difficulty attempting to locate a drawing in the CARIRS Design Data Base. He was eventually instructed to go to the hard copy file as an alternative. Also, the aperature deck for the drawing being investigated was out of order.

The ISC Coordinator was not aware that Pire Water was in use in lieu of Core Spray. Unusual Event 1/26/87 A review of the Event package and critique indicated that the water inventory discrepancy which occurred during trans fer of a radwaste tank to the main condenser hot welh was adequately identified and e

S-0C-87-01 Estrg::cy Pr:paredness

       * .                                                        Pag) 13 cf 14 covered in a satisfactory manner.         However, the call out of ISC and OSC personnel was less than acceptable. Only 10 of 18 (55%) requested positions re por ted . The reason for _ poor response was due to pagers not being properly maintained or not heard by energency response seabers. Also, most members who responded did not leave a recording on the code-a-phone.

This event was covered in compliance with the hersency Plan. A total of 7 recommendations were assigned as a result of this Event. Each I action was tracked through the hersency Preparedness action Ites Tracking System and it was noted that each concern, including the above, was addressed and closed-out. Unusual Event 2/10/87 i i A review of this Event . package and critique indicated that the mergency Plan was effectively implemented. This event, which dealt with a radioactive release, was properly declared per 6430-IMP-1300.01, Classification of hersencies, EAL T-2. However, a need to clarify the wording of EAL's T-1 and T-2 guidelines was i observed. Some 12 personnel had been contaminated by noble gas daughter products inside and outside of plant structures. The activation of the Initial Response Team was commendable. Notifications were adequately performed in a timely manner. Es pecially notewor thy was the interface with the NJBNE. Incal i officials were notified in a timely manner with no apparent problems. Press releases were adequately handled. Four press releases were 1 issued during the Event. a The NRC Operations Center called, using the INS line, requesting 4 clarification as to the level of emergency. They had been told by FMA that an Alert was in progress. The EP Manager then contacted the

NJBNE and Om to request that they check this disparity and improve
;              their line of communications.           Within an hour both agencies had j              performed as requested, NJ0 m is pursuing this matter with FMA

] management. l One area of response by the Chemistry Department was very i commendable. They were able take numerous RAGES samples in less time j than is usually scheduled. i The length of time that it took to terminate this Event was a concern. Some of the reasons for this included:

  • Hesitation in taki:;3 of an Off Gas Sample due to Technical i

i Specification restraints. Incorrect assumption of the leak source attributed to the systes

drain line.

Dispatch of teams from the OSC was slow. i l J i

 ,  ,   .                                                                                              S-oc-87-01 th;rgency Pr paredness P 33 14 cf 14
  • Confusion over the purpose of an Offgas Sampling Test.
  • As a result of this Unusual Event, three actions were assigned and '

entered into the Baergency Preparedness Action Ites Tracking Systes t and are currently in an open status. i H. Of fsite Interface l In coep,11ance with 10cm50-54 (t), an interface with the Ocean County ~ 1 Sherif's Department was established 5/1/87 by the Operations Quality l Assurance Monitoring Section. The representative of the Ocean County l l Sheriff's Department clearly indicated to the GPUN representative that l he has communicated with- various people at Oyster Creek and that they have been helpful in resolving problems. This interface program will  ; be expanded to other local and state agencies in the near future to i perfore reviews relative to the emergency preparedness programs. I l r I l I , - , . , - - , , . _ - . , . . . . _ - , . - - . - , - - -, . - - - . . .

m www Nr N0l~gtg _ __.._ _ -Attachment I isias on age g, m . aec m -- Audit Pinding Aust No.: 0-0C-47-01 Dete May 11. 1987 d E Nonsentermance - - Cetteh No.: a Mneng 1 et a m l PesAty/Punettenal Wuelaar Assurense l RIQUAA844 Wit! 07VW0 Operettenal Quality Adeurasse Plan 1000=Flaa7800 01, Rev. 1-00. Pare.t.l.4(b) states that the Hansser-merseasy Prepardenses is reopenethis few monitoringi eyeluesing and assurins both Three 1411e taland and Oyster Crook stettene have emersesey preparednese prostems that are seerstaated and maintained surrent and aessee a high state of prepaiddaeos. PtNOW60 Refer to attastunent. Potentially Assertsele Q Yes 5 Ne Semity L.evel ' Ovinisent tred/ Activity: Corp. Baergency Preposednase JohnN.Chelets

                                                                                                                                                                          ~~

Augw v i eu are toeweetet to fwmleh 00RMCTIV8 ACYL 0N for the finelag ey the target esto te6ew steting ine OAW68 for the deMsteney. Inetuslag me amont of the steetem. ACTION TAM 8N by yew to prevent f.eurtenes, an

                etive sete of implementetkn of CORASCTivt A4710N. If time reeuntee to ime6oment terreevve estion
     '               Ade 40 deve you are reevestee to leentify what IMtee6m                       '              CORRSCTfVE ACTION ie te be token to eco the eveRty etevfense progrem le not sometemloed.

aannewiessins eneme: MA~ -# f/#M7 s///#7 7 v taetwre ene rarget me CORRICTIVS ACTHE t.Reesenee to be sent to - Jeha N. MriesW . i  : n e,oe m iemei ..is.ses,si,eee.neeisvs.ieu.tese, -__ TT,L* v

                                 @ rg 093 p '

j, JUN i 2 s37

                                                     )    ,' .

E i. Prevlete tyt , _ _ _

                                                                                                                                                             - evie -

I accepte'4/Rejecteet ~~ a.asrier .u___ m

4065 00ft g ,, __

Senereo sm sese aoG8heie to,si j m tcc tra 03 IW1 80tti '

                                                                                                                                                                  .Me!I   90

Findlbk'T"Attcchment

  • . S-0C-87-01
 )
 .'    FINDING:

A review of the Emergency Preparedness training program requirements delineated in Exhibits 2 and 3 of 1000-ADM-1319.01 and the Emergency Plan Training Program 1720.0 (Rev 1) in conjuction with Table 23 of the Emergency Plan indicated that training requirements were not maintained current as evidenced by the following inconsistencies.

1. Exhibit two of 1000-ADM-1319.01 (On-Shif t Organization) did not caputre all the training requirements listed in Table 23 of the Emergency Plan.

Specifically, they are: Position Missing Requirements CSS /GOS Emergency Actions CR0 Callout of Personnel, Formal Communications Maint. Workers Callout of Personnel, Radio Communications, Log Keeping, Revelant EPIP's GRCS Interface of Ops. Personnel RCT's Communica tions , Interface w/ Ops. Personnel Chem. Tech. 's Communications, Procurement of Chemistry Samples

2. Exhibit three of 1000-ADM-1319.01 (Initial Response Emergency / Emergency Support Organization) delineates courses and topics required to be taken by emergency response personnel. With the exception of the ED and the ESD, the following courses could not be correlated to the positions listed in Table 23 of the Emergency Plan.

Specifically, the courses are:

             .      Facilities.
             .      Dose Projection / Assessment
             .      Radeon Surveys
             .      Site Protection / Assembly / Accountability
             .      Emergency Radeon/ Chemistry
             .      Contaminated Injuries /Decon
             .      Emergency Notification / Call Out
             .      Public Information

wss en..un. &

 *   -                                                                     Finding 1 Attechm:nt -

S-0C-87-01

   ~        3. The Emerge:cy Pic: Training Pr: gram 1720.0 (Rev.1) is not implementable as written. Specifically,
a. References are used which have been deleted (i.e.102.1).
b. Terms are present which are no longer applicable (i.e. FEOF). I
c. Documentation requirements have changed (i.e. qual. card no longer i used) .
d. Program does not implement Table 23 of the GPUN Emergency Plan.

(See marked-up copy which is attached). 1705Q/15 i 1 l l 1 l l l l l l

               .                                                                                    J

e . Attachment I-

                                                                                                                                                                                     ~

Number U Mr l CO.PO=ir(?MtGt.CY, 1 tan i000.,t..i30..gi  ; Title i CPU WUCLtAR-CORPORATION EMERGENCY PL'AN FOR THRtt M!tt ND '

                        !! lam 0 Ane 65$Tth CRttK WUCLEAR STATIONS                                                                                                                          '

0 00 TAatt n Pratonte inAtutac roa trume twatermer artPostr PratammfL ggg: Staf f and group eeneers will be assigned by their respective Group teaders/ Coordinator uno will also assign their training and ensure their availattitty during an vergency.s I l Petition /Titia t w anney Pian trainina

            - Emergency Olrector
            - Operations Coordinator                                           These individuals will receive training in the
            - Shif t Supervisor (TMI-I only)                                   following areas: tmtgency Organization. Emergency
            - Shtf t Foreman                                                   Fat 111ttet. Emergency. Action tevels. Emergency
           - to Assistant                                                      Classifications. Concept of Operations. Emergency
           - Emergency support Ofrector                                        CorTunte.4tions. Otse Projection and Assessment.
           - t$0 Assistant                                                     Protective Actions. Emergency Action and procedural responsittlities.                                                                                            )
           - Emergency Preparedness Rep.
           - Group teader R&tC                                                                                                                                                              }
           - Public Information Rep.                                                                                                                                                        1
           - Media Center Technical Advisor
           - Control Room Operators (TMt 2)
           - Shtf t Technical Adytter Group $nift Supervisor (OCNG$ only)
          - Group Operating Supervtsor (OCnG$ only)
          - Control Room Operators (TM1-1 and)

OChGS) This training util include techniques and metnocology in operating cortunications equipment, proper Ica keeping and formal corvunication. TMI 1 Caos util also include notification of offsite agencies. OCMG5 Ce0s will include callout of personnel.

          - Radiological Assessment Coordinator                                                   Tnese individuals will receive training in the following areas: Plant Systems affecting 00se
          - Radiological Engineering support                                 Assessment. EACC Coerations. RAC Operations, RAC/[AC Responsibilities and Interf aces. Oose Projection and
         - Environmental Assessment                                          Assessment.

cose projectionProtective Actions. Practical Factors on equipment. Coordinator -

         - Met / Cost Coordinator
         - Radiological Controls Coordinator                                                   This training will include emergency organization.

fr eMecency classification corvunications. and rac111ttes,caccess controD dose ervattment estensions, relevant LPIPs. search and rescue and interf acing with hospital, safety, security and rad con personnel, h - Group tadiological Controls

     -       Supervtsor                                                     thistraintne=111includefecesscentral.

r comitment dose '-

                                                                      - ,                entension                  relevant (P!Ps.\oost      acciden
e. sampling syst
    -                                                                                                             rgency organizatio A fse111ttes m_cwvien tca t ion and interfactag atth hospital, safety.

1.EGEND: mse gr up and operattons personnel

                                                                                                                                           ~
1. Training topics not covered either through Training Program 1720.0 Olev.1) or currently used TCR's.

I

2. Training topics not consistently covered or meeting the requireteents of i Section 2.5(b) of the GPL'NC Operational QA Plan, I g

(23 1 0001050t1 82 tPF

Attachment I Number j U N ' CORPORAft t GleCY PLAN 1000-PLN 1300.01 Title

    .                 GPU DUCLEAA_f 0APWtATION EMERGtsCY PLAN FOR THRtt MILE                                      Revisiott No.
                      !$LANO Ae0 GT&TER,,,CRttK NUCLEAR STATIONS 0 00 Taalt 21 (Cont'd)

PtAroore TRArurus ran cPune tuttctucy attposit PttiokktL Detitian/ Title Ente r son e y Plan Trainina

             - Radiological Controls                                  This training will include emergency creAntn tion; Technician                                   4. Trac ti t tied energency classification Ccommunicat ionTS-- /.
                                                                /*~ emergency kit instrunant use. EP!Ps. procer samoi tng techntquTITLecess controD and interfectng with
  • hospital. safety. security and operations personne) concerning injuries and decontamination of personnel and vehicles.
             - Radiological / Environmental Survey                   This training includes energency kit instrument use.

Teams relevant (P!Ps. formal radio consuunications, preper sampling techniques and practical exercises.

             - f5C Coordinator                                       The infernv i 4 to be covered includes Emergency Organizatin     (mergency Response Factitties. emergency'
            - TSC Engineers classif te.. on and consnuntcations. It will also          ?

ine1use fae 1_ity activation. relevant EP!Ps.

            - Group tescer - Technical Support               g,.{ concept of i.serationi)and 4rt11smanship techniques.

(TM!-1 and OCNGS only) , g

            - RTSC Coordinator (TMI 2 only)                                                                                                     '
            - Tecnnical Support Represen-tative (ECF)
            - OSC Coordinator
            - Group Leader - amitntstrattve Support
            - Group Leader - Maintenance.

Construction and Factilties

           - Radiological Controls $wpoort
               ;oordinatcr
           - Material Managem nt Coordinator (CCNGS o'ily)
           - Group Leader a securtty Support
           - Maintenance Forenan (TMI-I and                         The training will include emergency _ organizatien.

TMI-2) f ac$11 ties. eempunicationticoncept of operations'

           - (mergency Maintenance g;       Coordinator                                          ag rgency operations and maintenance, search and                 a rescue, and post accident radiological controls.J 3
      & - Maintenante Worters (TMI-1 and o                                TMI-2)                       f_te ti t t ies . emerceaev cla s s if(t c a n enT c:rvnunica t ion Maintenance Technician (CCMGS)                2,-{ emergency ocerations ano maintenanch search and 2                                                             rescwe. anc relevant EP!Ps. THI-I maintenance i                                                             tecnntetans are also traired in logkeeping and callout of personnel. TM! 1 utt11ty personnel will Q                                                             oe trained in map reading and radio co-riunicatior.s.

C;4C$ Maintenance Tecnnic14as are alle tri'-ef 'n

      '"                                                            7 4 31o co"T'%nicationl{og teeoing ano callout CP /e (Ge r a:n r gy 1

AOQQ10lo 11 82 II) I 3'Q18

Attachment I

                                                                                                                                 *~*"

ENuclear C . ,0. ,7 h sC , ,t . , ,<,.,,,g.,, i Title Geg suCLEAFCotPORAT10m (NERGtBC, PL'AN FOR THRtt MILE N N-

                      !$ lam Ame ellff t.CittK isUCLEAR STAf!Otil                                                                           0-00 u u .n < Cont.d)

Pitfoofe itArutma rom rJt.aae twedtimey if1Penir Platammf t 1 Petitian/fitle Emarannew Plan f rainina 1

              . ayu111ary Operators (TMt.1)                          me
              . toutument Operators (OChCS)                         est training wt11 inclu d :. r :r emeratioks D .:2,, ,

ans restological controls in a pois accleont envirofwent. TM! l Aos are also trained in  ! search and rescue. l l

             . Chemistry Technician                                 this trainine =111 inclues                   the(gertencyV /*

Chemistry Coordinator Corsantiation, racilities, one comunanicattens) It will also cover sne procesurai guisance rer i procurement and analysts of chemistry sangles, l l

             -   auxiliary Operators (TNI.2)                        This training will includebten8F eseretienth d e

('"haintenenseyzaaren and rescue. ,et.t accident radio = iogicas controls, and callout of personnel. . ECC Cossuunications Coordinator This training will inclu0e tes inteues and methodology #

            -    (CC Copewnicators                                 in operating componications equipment, proper                                 -

logkeeping and formal communications. t0F Communications Coordinator (CF Communicators

            -   Copewnications Personnel (0CNGS)
            -   Security This training util cover the concept and sethodology
            -   Security Coordinator                              for accountan111ty and operation of the taiernency attamm1v aram-(1ecurity processingens             11willrelevant also include EPIPs.  (seerteC /.
            . Emrgency assemely area Coordinator
            -   Medica) eepresentative the training will include emergency organtastion, f actitties, classification and copewnications.

It will also includt discussion of interfacing with I hospital, safety, security and rad con personnel for action concerning injuries.

                                                   ~

l l R t 5

        ~
  • l
          ?                                                                                                                                                      \

A00010s011 e2 (23 3 4:018 i

 ~

Attachment 1 Audit Finding Audit NL: S-0C-37-01 Date: May 11. 1937 E Noncenfctrmnce Criteria No.: Finding 2 2 of 2 Facility, Functions: Nuclear Assurance REQUIREMENT: Program, para. 6430-ADM-1319.01 (Rev.3) Oyster Creek Emergency Preparedness 4.3.3 states that Manager, Plant Training shall..."maintain documentation a report of all Emergency Preparedness classroom training and provide to Emergency Preparedness quarterly, prior to roster publication. , { l 1 FINOINO: Refer to attached. Potentially Reportable C Yes D No Severity Level V Cognizant Group / Activity: __ Manager, Plant Training __ h . N. M Zj. p/ Auditor  ! for the deficiency, including the extent of the problem, ACTIO , fcctive ce:ds dateyou 30 days of are implementation requested to i ntify ofwh CORRECTIVE ti ACTION. If time required to , on ex. implement cor the quality assurance program is n r im CORRECTIVE ACTION is to De taken to assure that d.

    -cknowledging finding-                                                    E-     -

ign 'r e - Dati * ' M ~ Tar t C%te f CORRECTIVE ACTION: , 1 R sponse to be sent to [_d[1NtD SNMM 2 For GPUNinternal Aud ts copy of response to VP of audited organization I SEE ATTACHED a, l J a Provided By # n

                               ~
      -                                                                                  r atwee                                                     '
                                                                                                                                      ' Ca(e ACCeDted Rejected AuO 10' Team LeaQ4r^

Oate OSE OUT: ..

                                .A .mo., r . m ,. . _ _
                                                                               ..                          f c.,.               .                 l Comowter Tracteg Code ~

aoooo41o 1o 01

Atsachment 1 [5SBng ?J Att:chae:t I S-0C-87-01

h Contrary to the above, attendance sheets for four ltadiological Control sanagement personnel who were required to receive RAC training from 1985 1 through 19M were not available for audit reviei. 1 i

, A matriz delineating RAC position training requirements for Messrs. Littleton, Arbach, Scallon and Derby is attached to this finding to identify the year and lesson number for which records couldn't be 1 mated i to substantiate training; received or excused. l l l i .I l i j i l 1 l ,i  ! 1 i l l

                                                                                                  -                                                                                                           ~~

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                                                                                                                                                           ~
                    , Attachment I                                        Quality Doficiancy Rsport
                  '                                                                                                             REV i                                                                                                                                DATF g"

QJ Q f RECTYPF C0 bot LOCATION i FORMNO Aocot209 Unit OC QDR No. O RETENTION PENANENT

      ! 1. lNITI ATION Initiated by:            3. '; Christian                                          Dept:       0A Audits                 Date' Time:   5/12/87
      ,      Res ponsibihty:          Bovd Leavitt                                             Dept;     Rad. Controis               Notified (Date Time)." U M Requirement:          0.C. Trainine Dent. Records Precedures 6210-AW-2A00.01 % v.0-001.                                                            l Paracraoh a.l.2 Training Attendance / Completion Records, suo-cars. ... 23 states                                                              i I

that "users of th E form who intend to certify an individuals attendance or completion of traininc descrieed in an acoroved procram description and their j associated TCR shall complete the items of inf ormation contained on the attendance sheet". I Deficiency: Contrary to the above, five attendance sheets which certified Radiolatical Controls Trainine for Cvele 87-1 in supoort of Emereency Preparedness Training were not completed to reflect the following: Procram Number, Course Number and Lesson Numbers with their revision status. Uithout this .1 formation, you cannot actuallv know what instruction was civen. Also, two attencance sheets couldn't be oroduetd for audit review and were assumed to be lost. Then subsequentiv  ! retrieved within a few days. Also, one attendance sheet which represented the l trainin: provided bv P. Schwartz on RAC Comouter Model was signed by S. McAllister i for F. Schwartz when he forcot to sien-off the attendance sheet. f DELIVER TO OQA M AN AGER (SITE INITIATED)/QA ENGINEERING M ANAGER, CORPORATE (CORPORATE INITIATED) OR UNIT / GROUP SHIFT SUPERVISOR /SRO (B ACKSHIFTS & WEEKENDS). l I2. EVALU ATION AND VALIDATION (IF EVALU ATED AS POTmTlALLY REPORTABLE, NOTIFY UNIT l M ANAGEMENT: NOTIFY AND SEND COPY OF QDR TO LICENFING) ~ Date Time Received: 83112181 NOO YES NO

  • ES NO YES NO Potentially Reportable Under.10 CFR2O 10 CFR50 10 CFR73 lx ~

g g 10 CFR21 xl 10 CFR71 l A L.E.R. X Evaivated By: @ , OCDA- rMr.A S//2/87 l'/of Name Tit:. osi Te, Unit Management Notified- . .

                                                                             'N.me                              Tit e                            cete T.m.

Licensing Notified: CYES %NO Name Tite Oat. Time

Saf ety Significance.

g g important to Saf ety C Signi'  ? Not In sortant to Saf ety C t.ot Significant Not importent to Saf ety , S Justification (if Not Signifscant Not important to Saf ety): 1 Corrective Actx>n Response Date: I[27M7 Confirmed Action Party. (30 asys or less from transminal cates Name 2 g oCA.M C.AE.MC Care FORW ARD TO RESPONSIBLE ACTION PARTY

ATTACM1ENT 2 g*-

.                                                                  AUDIT   S-0C-87-01 PAGE    1     0F       1 RECOMMENDATION (S)

The following recommendations are offered for consideration based upon observations and discussions during the audit. ,These recommendations are not a requirement and may be acted upon as determined by the addressed organization. Quality Assurance does not require a response for and will not follow up on these recommendations. RECOMMENDATION RES PONSIBILITY

1. Review and incorporate the following into Emergency Preparedness Mgr.

procedure 6430-IMP-1300.31 to maintain Frocedure relevance - Delete reference 6.3 - it is no longer appicable; insert in Section 5.4.3 a note to indicate that Lakehurst's weather service is not available from 2300 hours to 0500 hours.

2. Maintain specialized training for nar. Plant Training emergency response personnel on an annual 12 month basis (+3 month safety window) as opposed to reliance on a 15 month cycle.

ge Attachment III S-0 C-87-01 Page 1 of 3 REFERENCES

1. 10CFR50, Appendix E, Emergency Planning and Preparedness
2. 10CFR50.47,10CER50.54q Regulations Concerning Energency Planning
3. NUREG 0654/ FEMA REP-1, Oct. 1980, Criteria for Preparation and Evaluation of Radiological Ptergency Response Plans and Preparedness
4. NUREG 0737, Clarification of IMI Action Plan Requirements
5. Reg. Guide 1.25, Assumptions to Evaluate Radiological Consequences of Refueling Accident.
6. Reg. Guide 1.3, Rev. 2, Assumptions Used for Evaluating the Potential Radiological Consequences of a Loss of Coolant Accident for Boiling Water Reactors
7. Reg. Guide 1.5, Assumptions Used for Evaluation of the Potential Radiological Consequences of a Streamline Break Accident at a BWR
8. Technical Specifications, Appendix A, Sections 4.13, 6.8, and 6.9.2
9. Operational Quality Assurance Plan, Rev.1-00
10. Oyster Creek Security Plan, Rev. 21
11. Program Description 1720.0
12. Training Department Program Manual .
13. 1000-ADM-1319.01 Rev. 0-00, GPU Nuclear Emergency Preparedness Program
14. 1000-PLN-1300.01, Rev. 0-00, GPU Nuclear Corporation Emergency Plan for Three Mile Island and Oyster Creek Nuclear Station 15, 1000-PLN-1330.01, GPU haclear Corporation Emergency Plan for Three Mile Island and Oyster Creek Nuclear Station 16, 103, Rev.19, Station Document Control
17. 106, Rev. 43, Conduct of Operations
18. 106.2.1, Rev. 1 Spill Procedures 19, 107, Rev. 30, Procedure Control
20. 120.4, Rev. 2, Fires
21. 126, Rev. 6, Procedure for Notification of Station Events
22. 2000-PLN-1300.01, Rev 8, Oyster Creek Nuclear Generating Station Energency Plan
23. 2000-P -3024.01, Rev. 20, NSSS Annunciator Response Procedures j
24. 2000-RAP-3024.02, Rev. 8, Electrical Annunciator Response Procedures ,
25. 2000-RAP-3024.03, Rev.13, BOP Annunciator Response Procedures l
26. 501, Rev. 68 Annunciators 2nd Alarms
27. 6430-ADM-1319.01, Rev.1, Oyster Creek Emergency Preparedness Program j
28. 6430-ADM-1319.02,- Rev. O, Emergency Response Facilities & Equipment l Maintenance '

6430-ADM-1319.03, Rev. O, Medical Communications 29.

30. 6430-IM P-1300. 01, Rev. O, Classification of Emergency conditions
31. 6430-IMP-1300.02, Rev. 3, Director of Energency Response
32. 6430-IMP-1300.03, Rev. 5, Emergency Notification
33. 6430-IMP-1300.23, Rev.1, Thfroid Blocking
34. 6430-IMP-1300.24, Rev. 3, Emergency Respirator Equipment Issue and Control
35. 6430-IMP-1300.30, Rev.1, In-plant Radiation Surveys During Radiological Ebergencies .

Attachment III S-0C-87-01 o Page 2 of 3 REFERENCES

36. 6430-IMP-1300.35, Rev. 3, Radiological Controls Energency Actions l
37. 6430-dip-1300.40, Rev. 2, Site Security Emergency Actions l
38. 6430-dip-1300.41, Rev.1, Energency Duty Roster Activation l
39. 6435-ADM-1311.01, Rev. 2, Procedure Change and Information Notification (

6435-ADM-1311.02, Rev.1, Procedure and Surveillance Coordination 40.

41. 6435-ADM-1310.01, Rev. 3, Emergency Telephone System Test ,

l 42, 6435-SUR-1310.03, Rev.1, Baergency Preparedness Staff Training

43. 6435-SUR-1310.04, key. 1, Energency Radio Communications Test
44. 6435-SUR-1310.05, Rev. 2, Prompt Notification System Surveillance
45. 6435-SJR-1310.06, Rev. 2, Emergency Telephone Number Verification 1
46. 6435-SUR-1310.07, Rev. 3, Pager Test
47. 6435-SUR-1310.08, Rev. 2, Emergency Preparedness Action Item Tracking System
48. 6435-SUR-1310.10, Rev.1, Visitor Access for Emergency Preparedness Section
49. 6435-SUR-1310.11, Rev. O, Energency Duty Roster Maintenance 1
50. 6435-SUR-1310.12, Rev. 2, Tone Alert Radio Surveillance
51. 6435-SUR-1310.13, Rev. O, Annual Internal Emergency Preparedness Program ,

Audit l

52. 6435-ADM-1319.01, Rev. O, Energency Preparedness Instructor Certification
53. 658.4.003, Rev. 3, Emergency Alarm / Telephone Tests
54. 631.4, Rev. 3, Post Accident Sampling and Operations RAGMS
55. 831.7, Rev. 5, Post Accident Sampling and Analysis; Preparation and Analysis
56. 831.8, Rev. 2, Post Accident Sampling and Analysis; Estimation of Percent Fuel Failure.
57. 6430-IM P-1300.01, Rev. O, Classification of Emergency Conditions
58. 6430-IMP-1300.07, Rev. 2, Of fsite 'ndical Assistance Contaminated Injury / Radiation Overexposure
59. 6430-IM P-1300. 32, Rev. O, Energency Radiological Monitoring
60. 6430-EKP-1300.12, Rev.1, Personnel Accountability
61. 6430-IMP-1300.13, Rev. 2, Site Evaluation and Personnel Mustering at The Remote Assembly Area.
62. 6430-IM P-1300.15, Rev. O, Toxic / Flammable Gas Release
63. 6430-IM P-1300. 25, Rev. O, Emergency Operation Facility (E0P)
64. 6430-IMP-1300.26, Rev. 2, Technical Support Center
66. 6430-IM P-1300. 27, Rev. O, Operations Support Center
67. 6430-IMP-1300.29, Rev. 1, Recovery Operations
68. 6430-IMP-1300.31, Rev.1, Environmental Assessment Command Center (EACC)
69. 50-219/83-01 I&E Inspection Report )
70. 50-219/83-03 I&E Inspection Report
71. 50-219/83-04 I&E Inspection Report
72. 50-219/83-23 I63 Inspection Report
73. 50-219/84-13 I&E Inspection Report
74. 50-219/84-15 I&E Inspection Report I
75. 50-219/85-03 I&E Inspection Report l l
                                                                                            }

Attscheent III

  • S-0C-87-01
      .                                                                                                                           Page 3 of 3 REFERENCES
76. 50-219/85-05 I&E Inspection Report
77. 50-219/85-09 I&E Inspection Report
78. 50-219/85-13 I&E Inspection Report
79. 50-219/85-17 I&E Inspection Report
80. 50-219/87-05 I&E Inspection Report
81. I&E Notice 83-28, Criteria for Protective Action Recommendations for Geteral Emergencies
82. I&E Nctice 86-98, Of fsite Medical Services
83. S -0 C-80-50
84. S-0C-81-19
85. S -0 C-83-02
86. S-0C-84-02
87. S-0C-85-02
88. S -0 C-86-03 s

-- - . - . _ _ . ,- - . . -- . _ , , . _ , , ~ , , , . . _ _ . - _ , . _ . , . _ - . . _ . . _ . . . , , , _, , . . , ,_, _,, , , - , - ~,..m..

l 1 J Attochment IV I h

/

ATTENDEES NAME TITLE REPRES ENTING 1 5 M. Slobodien Radiological Controls R&EC 3,4,5 J.B. Leavitt Manager, Radiological Field Ops R&EC 3 P.J. Kovach Corporate Emergency Planner Nuclear Assurance 1, 2, 5 T.B. Blount, Jr. Sr. Ekergency Planner Nuclear Assurance 3, 5 I.A. Wazzan Jr. . Emergency Planner. Nuclear Assurance ; 3 B. C. Mings t Baergency Planner Nuclear Assurance 3 J.E. Bontempo Emergency Planner Nuclear Assurance 3 J. Parker Manager Public Af fairs Communications 3 D. Ranft Manager, Maintenance Eng's Oyster Creek 3 R. Harkleroad Supv. , Instr./ Cont'l Eng's Oyster Creek 3 J. Charterina Engineer III Oyster Creek 3, 4, 5 R.W. Fitts QA Auditor NJClear Assurance l 1,2,4 M. Orski QA Auditor - Tech Specialist Nuclear Assurance 1, 2, 4, 5 J.N. Christian Lead QA Auditor Nuclear Assurance 2, 5 D. MacFarlane OC Site Audit Manager Nuclear Assurance 3 S.C. Mc Allister Supr. Radiological Training R&EC 3 P.E. Schwartz Environmental Scientist R&EC l 4 1 - Attended pre-audit confe. ence 2/24/87 2 - Attended audit meeting with Training Department 3/17/87 1 3 - Contacted during audit 3/17/87 ' 4 - Attended informal presentation 5/7/87 5 - Attended post-audit conference 5/11/87 l l i

i r.. Memorandum ENuclear Date: June 5, 1986

Subject:

GPUN AUDIT REPORT S-0C-86-03 EMERGENCY PLANNING location: Oyster Creek From: OC Site Audit Manager (Acting) File: S-0C-86-03 W. G. Heysek I To: Director, Nuclear Assurance Division - R. L. Long Deputy Director, Oyster Creek Division - J. J. Barton

                                                                                                                /

This audit reviewed , The attached audit report is forwarded for your review. the conduct of Emergency Plan activities at Oyster Creek. A preliminary One audit finding was issued and is included as Attachment 2. review of the audit finding indicated that it is not reportable. Four recommendations Quality have been made Assurance as not does a result requireofathis audittoand are response l included as Attachment 1.However, GPUN corporate policy requires that an these recommendations. internal division / department memorandum documenting your disposition of f these recommendations should be written to file, l In accordance with 1000-ADM-1291.01, "GPUN Nuclear Safety Review and Approval Procedure," the Nuclear Assurance Division is responsible for the Memorandums requesting the review and a copy j safety review of this report. j of this report will be forwarded to the responsible safety review l coordinator to arrange the performance of the review. If there are any questions concerning this audit, please contact the undersigned. P W. G. YSEK OC Site Audit Manager (Acting) WGH/lga 0723Q/16 A0o00648 8 83

y .. June 5, 1986 GPUN AUDIT REPORT S-0C-86-03 EMERGENCY PLANNING-cc: Chairman, GORB - 1. R. Finf rock, Jr. Director, Quality Assurance - N. C. Kazanas

                  -Director, Radiological and Environmental Ce ntro..s - R. Heward Emergency Preparedness Manager - R. L. Su'livan Manager, Communications Services OC - J ' T. Fidle r.                   l Manager, Emergency Preparedness - G. Citagi Manager, Environmental Controls OC - D. Caf aro Manager, OC QA Mod / Ops - R. Fenti Manager, Plant Training OC - R. Fent >n Manager, Program Development / Audit - R. S. - Mr.ckowski l

Manager, Saf ety Review Oyster Creek - K. Fickeissen j Manager, Technical Support - MCF OC - R.: J. Blouch NSAD Director - R. Whitesel NSCC Senior Staff Assistant OC - P. Ahern ) President - P. R. Clark l Radiological Controls Director OC - D. Turner Safety Review Manager OC - E. Growney TMI QA Audit Group - K. T. Fornicola l I l l i I i I l l i

~ Nuclear memorandum

Subject:

GPUN AUDIT REPORT S-0C-86-03 Date: June 5, 1986 EMERGENCY PLANNING Fnxn: OC Site Audit Manager (Acting) Location: Oyster Creek W. G. Heysek S-0C-86-03 To: Manager, QA Program Development & Audit R. S. Markowski As required by the Nuclear Safety Review and Approval Matrix attached to Corporate Procedure 1000-ADM-1291.01, Nuclear Assurance Division is requested to perform a safety review of the attached subject aulit report. Also attached is a completed Review Evaluation Form. If you agree with our preliminary determinations on the form, please document your concurrence by signing and returning it to the OC Site Audit Manager. If you disagree with our determinations on the form, please contact me immediately. Any comments snould be made on this memo and signed and dated by the commentor. v our evaluation is requested to be returned within 60 days of receipt. If mi t .w;1d have any questions, please contact the Site Audit of fice at X4150. fty% Y-W. G. H SEK OC Site Audit Manager (Acting) WGH/1ga 0723/17 At tac hment Comments: Signature Date , AX40648 8 83

Nu21 ear

    .'                                                     Review Evaluation Form (Matrix Section lV)

GPUNC Nuclear Oyster Creek Nuclear Station Page 1 _of 1 File No. Title Emereeney Preoaredness Audit S-OC-86-03

1. Does the document involve a significant nuclear safety / environment imoact previously evaluated in a Yes O Licesing Basis Document?

No @

2. Does the doceent involve a significant nuclear safety / environment impact not previously evaluated in Yes O a Licensing Basis Document?

No O

3. Does it require a change to the Technical Specifications ?

Yes O No Q

4. Does the document require a revision requiring a change to a Licensing Basis Document?

Yes O No D Note: If any of the answers to 1 thru 4 are "Yes" a detailed evaluation must be attached,and a chang Basis Document must be submitted to Licensing. Details of Evaluation (Attach additional pages,if necessary) Based on the evaluation of the Audit Report, in which no significant Nuclear Saf ety/ Environmental issues were identified, questions 1 and 2 were answered "No". Furthermore, no Licensing Basis Documents were found to require change, therefore, questions 3 and 4 were answered "No". Preparer

                        %            mW. w   i
                                                                           &/W61 Date       /

O - The un. drsigned has reviewed 15is document and is in agreement with the evaluation. O - Please provide furtherinformation as requested. Safety Rev;"" Date 1000. ADM.129101 3 A00016o3

b

  • TABLE OP CONTENTS S-0C-86-03 Emergency Prepareddess PAGE
                                                 .............s               . . . . . . . 1 PURPOSE . . . . . . . . . . . . .

1 SUMMATION . . . . . . . . . . .,. . . . . . . . . . . . - . . . . . . . . 2 DETAILED DICCUSSION . . . . . . . . . . . . . . . . . . . . . . . . . . Initial Response Capability . . . . . . . . . . . . . . . . . . -2 4 Shif t Staf fing Augmentation and Training . . . . . . . . . . . 5 Changes to Emergency Preparedness Program . . . . . . . . . . . 6 Dose Assessment / Worker Protection . . . . . . . . . . . . . . . 7 Maintaining Eeergency Preparedness . . . . . . . . . . . . . . Interface with Outside Agencies . . . . . . . .. . . . . . . . 8 9 Public Information Plan . . . . . . . . . . . . . . . . . . . . Corrective Action . . . . . . . . . . . . . . . . . . . . . . 10 , At tac hment 1 - Recommendations Attachment 2 - Audit Pinding At tac hment 3 - Persons Contacted i

                                                                                                   )

Attachment 4 - References I i 1 i}}