ML20207J307
| ML20207J307 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 06/05/1986 |
| From: | Heysek W GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| Shared Package | |
| ML20207J096 | List: |
| References | |
| S-OC-86-03, S-OC-86-3, NUDOCS 8808310015 | |
| Download: ML20207J307 (45) | |
Text
- _ _ _ _ _ _ _ _ _
E Nuclear Auoir aseoar Audit dates (s) February 13,__1986 - May 9, 1986_.___ Audit No.
S-0C-86-03 Facility Oyster Creek Nuclear Generating Station Reference P.O.
Rev.
Documents:
Attachment Rev.
Activity item (s)
Emergency Preparedness Program Attendees: Name Title Representing 1,3 G. J. Simonetti Lead Auditor Nuclear Assurance 1,3,4 D. L. Robillard QA Auditor Nuclear Assurance 1,3,4 P. Y. Thompson QA Auditor Nuclear Assurance 1,3 G. J. Giangi Manager-Emergency Preparedness Emergency Prep.
1,2,3,4 R. L. Sdllivan Emergency Preparedness Mgr.
Emergency Prep.
4 R. L. Long Director-Nuclear Assurance Nuclear Assurance See Attachment 3 for continuation.
Pur1 POSE To review and assess the definition and implementation of the GPUN Emergency Plan at Oyster Creek.
SUMMATION The results of the audit indicate that the plans and implementing procedures employed in activities related to Emergency Preparedness at Oyster Creek are consistent with regulatory and Quality Assurance Program requirements and that they are being effectively implemented.
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COMPLETION l X l Close out required for l
1 l Non Conformances Target Date
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h Signed:
4' ' ~ -
gg
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oncurred by:
['
Aust felm'ieT r Audit Approved by:
/s R. S. Markowski 6/5/86 u,
Director. O A Manager. QA P ogram Date
- "' ^"
l l Reviewed response. Will check implementation by:
Re-Audit GA D3t' Follow up l
l Audit Satisf actorily completed. closed QA._.
Date_____.
8808310015 880818 PDR ADOCK 05000219
^ W H12 0 "
g PNU
- y S-0C-86-03 Page 2 of 10 Discussions, observations, and. reviews performed during the audit resulted 'in the identification of two areas of improved performance:
Improved tracking of the qualification status of the emergency
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response team members.
More ef fective use of the Emergency Preparedness action tracking
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system.
Two deficiencies were identified and documented as follows:
l Emergency Preparedness administrative and surveillance procedure requirements are not being fully implemented. Refer to Finding 1.
j e
l Emergency Preparedness responded to the finding on 5/29/06.
Corrective action implementation is scheduled to be complete by 7/31/86.
On-shif t maintenance technicians assigned to emergency response positions were not trained in accordance with the Emergency Plan t
e QDR 86-017 was issued to Maintenance, Construction and requirements.
Facilities.
Several recommendations presented as a result of the audit whien would have positive impact on the Emergency Preparedness program if acted upon are:
Include in each drill critique documentation of an assessment of the interface with off-site agencies that participated in the drill.
Perform a load test of the Emergency Operations Facility emergency generator to assure it will supply necessary loads.
Review and revise those sections of the Emergency Plan referencing the Public Information Plan to clarify the scope and content of the Public Information Plan.
Proceduralize the guidelines of the Public Information Plan into Communications Division procedures.
s DETAILED DISCUSSION Initial Response Capability The GPUN Emergency Plan and implementing procedures were reviewed to assure that emergency action levels (EALs) were accurately defined and consistently described. The EALs were found to be based on defined plant and on-site /of f-site radiological conditions. The descriptions of the from the Emergency EALs and emergency classifications were consistent Plan down through the emergency and plant operating procedures.
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9 S-0C-86-03 Page 3 of 10-The effectiveness of response capability was assessed by reviewing drill packages and documentation resulting from actual declared emergencies for
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the period 3/22/85 to 2/19/86. The records indicated that appropriate protective action recommendations were made in accordance -with the established guidelines and that the duties and responsibilities, as assigned by the Emergency Plan and implementing procedures, were effectively carried out.
Direct observations were made during the 2/19/86 drill at the Emergency Operations Facility (EOF) to verify that the duties and responsibilities assigned to those personnel manning the EOF were accomplished. The response of the Emergency Support Director and the support group landers were evaluated as acceptable. Observation of the Group Leader-Maintenance and Construction and a trainee performing a startup of the EOF emergency genera or found the task performed in accordance with of EPIP-25, "Emergency Operations Facility (EOF)".
The Maintenance, Construction & Facilities (MCF) personnel and Emergency.
Preparedness personnel were interviewed to determine if a load test had been conducted on the generator to ensure it was capable.of supplying the required loads. They indicated that to the best of their knowledge no load test had been conducted. Also, Emergency Preparedness could not provide documentation of a load test. No finding was written because there is no procedural requirement, nor is there a documented commitment regarding the operability of the emergency generator. The emergency generator should be load tested to ensure that it is capable of providing power to necessary EOF loads.
Refer to Recommendation 2.
Observation of event classification in the control room during the 2/19/86 drill found that the event was promptly and properly classified.
Notifications of of f-site agencies were conducted in accordance with the Emergency Plan implementing procedures. The notifications to f ederal, j
i state, and local agencies were made in a timely manner.
The review of documentation of actual declared emergencies identified t ha t the records were not maintained in accordance with the requirements of the QA Plan.
As a result of discussion with Emergency Preparedness personnel during the course of the audit, these records were placed in fireproof storage.
Based on the limited number of records involved and the prompt corrective action to remedy the discrepancy, no deficiency report was written.
A review of procedure 6430-IMP-1300.02, "Direction of Emergency Response," was performed to verify that protective action recommendations are based upon projected dose calculations. The guidance for the protective action recommendations is consistent with the requirements of the Emergency Plan and the Environmental Protection Agency guidelines.
o S-0C-86-03 Page 4 of'10 Procedure review verified
.. equipment used to determine post-accident core and containment status (i.e., hydrogen-oxygen monitors, fuel zone level indicators, and Torus /Drywell pressure and temperature indicators) were adequately addrassed in plant operating and emergency procedures.
Many of the implementing procedures have been revised and renumbered from the old EPIP-XX scheme. tMwever, some of the Emergency Plan implementing procedures, as well as the s;stion abnormal operating and alarm response This reference procedures still reference the old EPIP-XX designations.
to the old procedure numbers could cause some confusion if the user is not f amiliar with the new numbering scheme.
Discussions between Emergency Preparedness personnel and the audit team resulted in an Emergency Preparedness commitment to provide a cross-reference from the old numbering system to the new numbering system in future procedure revisions.
Shift Staffing Augmentation and Training The Emergency Plan and EPIP-1, "Classification of Emergency Conditions,"
both require that an individual on-site be designated with the authority and responsibility to classify events, initiate emergency actions, and recommend protective actions.
The Group Shif t Supervisor position has been designated to fulfill the requirements since it is required by the OC Operating License and Technical Specifications to be filled 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. Verification was unnecessary since the position is continuously manned.
The shif t staf fing requirements established by Table 13 of the Emergency Plan were compared with the shif t staf fing requirements of the Operating License and Technical Specifications and Procedure 106 and were found to be consistent.
Surveillance records and drill packages were examined to verify that augmentation times have met the augmentation criteria in the Emergency Plan. The results indicated that all facilities were activated within the time frame specified by the plan.
Reviews of procedure 6435-SUR-1310.07, "Pager Test," surveillance documentation; and the confidential telephone list were conducted to verif y that response activation procedures can be implemented. The surveillance records indicated that the response rate to the monthly pager tests averaged approximately 60 percent.
Five of the monthly pager tests reviewed were conducted on of f-normal shif t hours (i.e., af ter 5 p.m.).
Each month, those personnel who did not respond to the test were contacted to determine the reason for their lack of response. The reasons provided by personnel justified their f ailure to respond. The documented follow up of the lack of response to the pager tests and the conduct of pager tests on of f-normal hours are positive steps taken by Emergency Preparedness to improve GPUN's ability to respond to emergencies.
V.
S-0C-86-03 Page 5 of 10 A./eview of training records was conducted for 30 members listed on the 12/17/85 revision of the initial response roster to verify that they had bcen trained in accordance with the requirements of the emergency preparedness program. The training records reviewed included records of annual ref resher, general employee, and respirator training, as requi re d.
Two members of the sample did not satisfy the respirator trainicg requirements, but were still assigned to the roster.. One membe r The was subsequently removed from the 3/11/86 revision of the roster.
other member remained assigned, and finally. completed the respirator training requirements and fully satisfied the training requirements on 3/26/86. As a result of these deficiencies, the training records for five additional personnel were selected and reviewed. No ot he r deficiencies were identified; and due to the apparent isolated instances in the original sample, no finding was issued.
The Training Department has developed a report that is distributed to Emergency Preparedness personnel monthly that will track emergency preparedness training status by position.
This report should allow Emergency Preparedness to prevent further assignment of unqualified personnel to the roster.
Emergency Plan training attendance records were compared to maintenance personnel shif t assignment records to verif y that the maintenance personnel had received training in accordance with Table 23 of the Emergency Plan. This review indicated that many of the craf t personnel assigned had not completed the training. QDR 86-017 was issued to MCF.
Thirty telephone numbers from the confidential telephone list were verified by comparing the telephone numbers with the phone book listing and by contacting the individuals, in the case of unlisted telephone numbers. Two of the numbers selected were incorrect. Eme rgency Preparedness and Site Security personnel were notified of the discrepancies. A review of the phone list later in the audit confirmed that the list had been updated and was correct.
Changes to Emergency Preparedness Program A review of the revised Corporate GPUN Emergency Plan (1000-PLN-1300.01),
which incorporated both the TMI and Oyster Creek site-specific plans, verified that all requirements of 10CFR50, Appendix E, were addressed and that none of the commitments or requirements of the previous Emergency Plan had been deleted. Additionally, the Emergency Plan and implementing procedure revisions included the f acility changes resulting f rom the Post Accident Sampling System (PASS) modification. All changes to the Emergency Plan and implementing procedures were reviewed by appropriate j
levels of management, i
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o, e
S-0C-86-03 Page 6 of 10 A review of the mechanism for notifying emergency response personnel of the changes to the implementing procedures indicated that the requirements of procedure 6435-ADM-1311.01, "Procedure Change and Information Notification," are not being satisfied in that there is no documented follow up of overdue acknowledgement of the procedure c hange s. Refer to Finding 1.
A review of six changes to Emergency Plan implementing procedures verified that the changes were consistent with the requirements of the Emergency Plan, and were reviewed and approved by appropriate levels of manageme nt.
Dose Calculations and Assessment / Emergency Worker Protection Methods used to perform dose calculations were examined.
EPIP-9, "Of fsite Dose Projection," was specifically reviewed to verif y that-manual dose calculations could be made in the event of computer f ailure.
An attempt was made to perform a manual dose assessment calculation following the steps outlined Ln the current revision to EPIP-9.
The calculation could not be completed consistent with the procedure.
Discussions were then held with Emergency Preparedness, Radiological Engineering, and Training Department personnel, regarding the adequacy of 1
EPIP-9.
Those discussions indicated that the procedural inadequacies were well known and that a computer program, capable of being used on any on-site IBM personal computer, had been developed to perform the dose calculation in the unlikely event that both the MIDAS and RAC systems were unavailable.
Based on the redundancy that exists with the MIDAS, RAC, and IBM-PC computer programs, the ability to perform dose assessment calculations under any probable situation was available. As a result of the introduction of the IBM program, a Procedure Change Request has been issued to rescind EPIP-9 and is presently in the review cycle.
Operability of the radiological and meteorological instruments described in the Emergency Plan and the implementing procedures to assess plant radiological conditions were observed during the 2/19/86 drill. An auditor in the Emergency Command Center verified that the area radiation monitors and the meteorological tower instruments were operable, and that i
the information f rom the National Weather Service was available. Record reviews and direct observation of performance of procedure 101.11, "Maintaining Emergency Preparedness," and inventories of on-site and off-site monitoring team kits verified that the equipment necessary for the monitoring teams to gather radiological data was available and maintained.
The Emergency Plan requires that someone with the authority to permit exposures beyond 10CFR20 limits be on site and available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. This authority is assigned to the Group Shif t Supervisor / Emergency Director. The authorized emergency exposure limits identified in the the Emergency Plan were verified consictent with the guidelines established by the Environmental Protection Agency in EPA-520/1-75-001.
q e-S-0C-86-03' ~
Page 7 of 10 Implementation of requirements in procedures 6430-IMP-1300.24, "Emergency Respiratory Equipment Issue and Control," and EPIP-40, "Site Security Emergency Actions," were checked by assuring that adequate respiratory protection equipment and protective clothing are available for emergency Equipment and clothing inventories required by the procedures use.
appear to be adequate for initial response personnel. The Emergency Respiratory Equipment Issue Facility.was examined and found to be stocked as required.
Procedure 6430-IMP-1300.21, "Personnel / Vehicle Monitoring and Decontamination," and completed inventory checklists from procedure 101.11 were reviewed to verif y that facilities for worker decontamination exist and are adequately stocked and maintained. The review indicated t hat the decontamination f acilities exist and are maintained in a continuous state of readiness.
The evacuation routes from Oyster Creek to the Remote Assembly Area (RAA) in Berkeley Township, as identified in Exhibit 1 of procedure 6430-IMP-1300,13, "Site Evacuation and Personnel Mustering at the Remote Assembly Area," were traeed to verify accuracy. Exhibit 1 incorrectly identifies the mileage f rom the intersection of Lacey Road and Route 9 to the intersection of Lacey Road and Route 618. This discrepancy is significant because the evacuation route to the RAA is marked with only.
one small sign, and many of the contractors working at Oyster Creek are not familiar enough with the area to know the location of Route 618.
This discrepancy was brought to the attention of Emergency Preparedness personnel, and a change to procedure 6430-IMP-1300.13 was initiated.
Due to the prompt corrective action taken by Emergency Preparedness Department, no finding was issued.
The dispensing of potassium iodide (KI) tablets is controlled by procedure and found to be described consistent with Food and Drug j
Administration guidelines. The KI tablets are maintained by the medical representative and prescribed by a licensed physician employed by Radiation Management Corporation.
Maintaining Emergency Preparedness Direct verification of the Emergency Operations Facility (EOF). Technical Support Center (TSC), Operations Support Center (OSC), and the Emergency Control Center (ECC) was employed to assure that each facility is equipped with communications equipment as specified in the Emergency Plan and meeting the requirements of 10CFR50, Appendix E, and 10CFR50.47(b)(6). Each facility was equipped as necessary to satisfy these requirements.
A review of the drill packages for the period 3/85 through 3/86 verified that the drills required by the Emergency Plan had been scheduled and conducte d.
No discrepancies were identified.
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4-g S-0C-86-03 Page'8'of 10 A review of - drill packages and the Emergency-Preparedness ' action item tracking system was performed to verify' that drill-comments dealing with facility inadequacy or program deficiencies were incorporated as action-These action items were reviewed to evaluate the adequacy of items.
proposed corrective actions and close-out documentation to verify. the The -review status and assess the promptness of corrective _ action.
the action. item tracking system effectively identified indicated that The adequacy of close-out open action items and their' status.
documentation was _ determined by a review of 37 randomly selected action.
Two items were closed out.without adequate resolution of all the items.
An additional 30 action deficiencies identified in the action item.
items were reviewed, and no further deficiencies with close-out documentation were identified. The action item tracking system was effective.
Emergency Preparedness surveillance records for the period 3/85 through 3/86 were reviewed to verify that the surveillances were scheduled, performed, and documented in accordance with _ the Emergency Preparedness This review indicated that several deficiencies surveillance procedures.
exist in the conduct, review, and administrative control of the For example, a review of completed 101.11, surveillance program.
Appendices A-H, for the period of 4/1/85 through 3/31/86 was performed to verify that the f acility and equipment inventories required by procedure 101.11 and the Emergency Plan were performed.
It was identified during be this review that documentation of some required inventories could not Refer to Finding'l.
produced by Emergency Preparedness personnel.
The response to audit finding S-0C-85-02.01, issued during the 1985 stated that "Procedure 101.11 has been Emergency Preparedness audit, revised such that all inventory documentation must be reviewed by the EP Manager." As noted above, this corrective action-is not being in the implemented; however, the auditors did identify improvement inventories. Emergency Preparedness implementation of required equipment should evaluate the practice of having the Emergency Preparedness Manager review all surveillance checklists in lieu of a less time-consuming-review to assure that the surveillances are performed as required.
A review of the 1985 QA monitoring file for Emergency Preparedness was Monitoring performed to essess the adequacy of program element coverage.
activities for 1985 included coverage of drill performance, training, This review emergency preparedness and surveillance program review.
indicated that the QA monitoring of emergency preparedness activities is adequate.
Interface with Outside Agencies Interf ace activities with the state and local response organizations were ovaluated through the review of training records, communication checks, response and participation in drills, and participation in annual J
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S-0C-86-03 Page 9 of 10 exercises. The of f-site agencies participated in the 5/14/85 drill and the 6/5/85 annual exercise. The results of this review indicated that the current emergency preparedness interface with state and local government is adequate. It is, however, dif ficult to determine, by review of the drill packages whether or not the OC Emergency Preparedness Manager performs an evaluation of the interface with off-site agencies for the drills in which they participate.
Refer to Recommendation 1.
Record reviews were utilized to verify that state and local response plans which interface with the Emergency Plan are available and that letters of agreement are current and available. The State of New Jersey Radiological Response Plan and the Ocean County Emergency Plan are available in the Emergency Preparedness area of Building 12 in Forked River. The letters.of agreement are on file at TMI, and were verified to be available and current by the TMI Site Audit group.
The State of New Jersey Radiological Emergency Response Plan and the Ocean County Emergency Plan were reviewed to verify that off-site of ficials are responsible for making public notifications promptly upon being informed of an emergency condition, as required by 10CFR50, Appendix E.
Both plans adequately address the actions required of the of f-site of ficials when informed of the emergency condition and the method of activating the prompt public notification siren system. A j
review of the documentation of the required bi-weekly siren tests indicated that the tests were satisf actorily performed and that defective sirens were expeditiously repaired. No discrepancies were identified.
1 Document reviews were utilized to verif y that the evaluation of state and local government agency interface with OC, conducted during the Quality Assurance audit, is made available to these agencies as required by 10CFR50.54( t). Memos issued by the Emergency Preparedness Department (6430-86-059 and 6430-86-069) make available these audit results to the appropriate state and local interfacing agencie.
Public Information Plan Document review, direct observation, and interviews of Ccamunication Department personnel were utilized to verify that the public information program fulfills the Emergency Plan requirements and can be ef fectively implemented.
The Emergency Plan was reviewed to ensure that the Public Information Plan is identified, controlled, and capable of being implemented. The Emergency Plan designates the Communications Department as the point of contact for the public to obtain information in the event of an accident.
However, the Emergency Plan is ambiguous in that one section refers to a separate Public Information Plan, while another section implies that the Public Information Plan is an integral part of the Emergency Plan. Discussions with Communications Department personnel
s.
S-0C-86-03 Page 10 of 10 indicate that the Public Information Plan isSection VI.8 of the GPUN Emergency Plan. The Emergency Plan should be revised to clarify the -
Refer to scope, control, and location of the Public Information Plan.
Recommendation 3.
Also, the actions required by the Communications Department are presently formalized but exist as guidelines published by the Communications not Department. 'In order to provide for uniformity in the interface between the Communications Department and the public, those sections of the Public Information Plan which outline specific actions should be incorporated into formal controlled procedures. The audit team realizes that the Communications Department _ interf aces with elected and appointed officials during the public notification process.
Therefore, it is recommended that these procedures contain only the titles of the offices to be contacted, and not specific names and telephone numbers. The names and telephone numbers of these of ficials can be maintained on a separate, controlled listing issued by the Communications Department and updated as necessary. Refer to Recommendation 4.
Direct observations and personnel interviews were used to verify that the Emergency Information pamphlet had been mailed to all residents within the 10-mile emergency planning zone, and that road signs exist to provide information to transient personnel regarding evacuation routes. The auditor verified that road signs identify evacuation routes and tadio stations call numbers which broadcast emergency inf ormation. The Manager, Communications Services OC stated that the mailing list for the public information pamphlet is obtained from Jersey Central Power & Light Company and Atlantic City Electric and includes private residences and business establishments within the 10-mile emergency planning zones.
No discrepancies were noted.
Corrective Action A review of open Licensing Action Items assigned to Emergency Preparedness Department was performed to determine the status of the open items.
One Action Item remains open with a corrective action implementation.due date of 5/86.
NRC I&E Inspection 85-05 identified concerns relative to documentation of the changes to the Emergency Preparedness Program and the lack of an evaluation of the adequacy of the interface with state and local governments. The assessment of the documentation and communication of changes to the Emergency Preparedness Program was performed in accordance with che requirements of the audit checklist and documented in the "Changes to Emergancy Preparedness Program" Section of this report. The adequacy of the interf ace with state and local governments is discussed in the Interface with Outside Agencies section of this report.
3, Attachment :1 S-0C-86-03 Page 1 of.l' RECOMMENDATIONS
. Quality Assurance does not require a response to these recommendations.
However, Corporate policy requires that an internal division / department memorandum documenting your disposition of these recommendations should be written to file.
1 RECOMMENDATIONS RESPONSIBLE ORGANIZATION 1.
Include in each drill critique a Emergency Preparedness Mgr.
direct statement of an assessment
- Y adequacy of the interface a'
with off-site agencies participating in the drill.
2.
Perform a load test of the Emergency Emergency Preparedness Mgr.
generator at the EOF in Lakewood, to assure that the generator is capable of supplying all necessary loads when required.
3.
Review and revise those sections of Emergency Preparedness Mgr./
the Emergency Plan referencing the Manager-Communications Serv.
Public Information Plan to clarify the scope, control, and location of the Public Information Plan.
4 Develop and issue controlled Manager-Communications Serv.
procedures which incorporate those portions of the implementing guidelines of the Public Information Plan outlining the actions of the Communications Department.
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Audit N3.: S-0C-86-03 Date:
May 9, 1986 Nmbe noncoo,nding Audit Fi o,m.oo.
Criteria No.:
y Finding i
of 1
Facility / Functions:
Emereenev Preoaredness REQUIREMENT: ANSI 18.7-1976, Section 5.3 states that "The Administrative Controls and Quality Assurance Program shall be carried out throughout plant life in accordance with written procedures.
FINDING:
See Attached.
Potentially Reportable O Yes O No Severity level V
Cognizant Group! Activity:
Emerzency Preparedness - Oyster Creek h
Auditor You are requested to furnish CORRECTIVE ACTION for the finding by the target date below stating the CAUSE for the deficiency, including the extent of the problem, ACTION TAKEN by you to prevent recurrence, and ef-fective date of implementation of CORRECTIVE ACTION. If time required to implement corrective action ex-ceeds 30 days you are requested to identify what interim CORRECTIVE ACTION is to be taken to assure that the quality assurance program is n pr ised.
8 Acknowledging finding:
' Signature
' Date Thrdet Oate 0.C. Site Audit Manager CORRECTIVE ACTION:
- 1. Response to be sent to:
- 2. For GPUN Internal Audits copy of response to VP of audited organization i
Provided By:
S v ature cate Accepted l Rejected:
Auditor Team Leader Date CLOSE OUT:
Aud>t Team Lesoer Date Computer Traciong Code Aooo0410 10 81
o l
L S-0C-86-03 l
Finding 1 of l' Page 2 of 3 FINDING:
Contrary to the above, a review of records maintained by the Emergency Preparedness Department indicate several instances of procedural noncompliance. The following are examples of procedural noncompliances, but do not constitute the complete scope of deficient records.
1.
Procedure 6435-ADM-1311.01 requires that Emergency Preparedness personnel followup with individuals not responding to Procedure Change /Information Notices. A review of the responses to four Procedure Change Not fications i
distributed by Emergency Preparedness indicates an approximate 60%
response rate with no record of the required followup, 29 of 42 individuals responded to the change to procedure e
6430-IMP-1300.11. (Sent 12/5/85, response as of 3/7/86),
12 of 22 individuals responded to the change to procedure o
6430-IMP-1300.40 (Sent 11/18/85, response as of 3/7/86).
4 of 10 individuals responded to the change to procedure e
6430-IMP-1300.21 (Sent 11/25/85, response as 3/7/86).
7 of 13 individuals responded to the change to procedure e
6430-IMP-1300.23 (Sent 12/23/85, response as of 3/7/86).
2.
Procedure 101.11 requires that completed inventories of emergency equipment be forwarded to the Emergency Preparedness department for review. The following list of procedure 101.11 checklists were located in the Emergency Preparedness of fices and had not had the required reviews.
All checklists completed during May and June, 1985 (12 total).
e Appendix B f rom Bldg.12, dated 7/16/85.
e Appendix G f rom ECC, dated 7/14/85.
e Appendix A f rom ECC, dated 8/9/85, e
Appendix G from TSC, dated 8/85.
o All checklists completed af ter the quarterly drill of 2/19/86.
e 3.
Procedure 127.2 assigns responsibility for the Emergency Preparedness Surveillance Program to the Emergency Preparedness Department. A review of Procedure 101.11 checklists indicated that the following had not been completed and there was no followup by Emergency Preparedness to have the checklists completed as required, Appendix G for EOF for the third quarter of 1985, o
Appendix G-3 for PTFC for the fourth quarter of 1985, e
Appendix G-1 for RAA, EAA and EOF for the first quarter of 1986.
e
S-0C-86-03 Page 1 of 1-PERSONS CONTACTED DURING THE AUDIT ATTENDEES NAME
-TITLE REPRESENTING
-2 R. Beck RadCon/ Chem. Training Supv.
Training & Educ.
2 R. Be rnava Security Sergeant OC Security 2
T. Blount, Jr.
Sr. Emerg. Planner Emergency Prep.
2 J. Bontempo Emergency Planner Emergency Prep.
2 T. Brownridge Outage Manager, MCF MCF 2
R. Cotter Rad. Engineer (NSS)
Rad. Controls 2
D. Halley Training Instructor Training &_Educ.
4 W. Heysek OC Site Audit Mgr. (Acting)
Nuclear Assur.
2 M. Kennish Envi ron. Scientist Environ. Controls 2
P. Kovach Corp. Emerg. Planner Emergency Prep.
2 M. Littleton Rad. Engineering Mgr.
Rad. Controls 2
R. Loe Radiological Engineer (NSS)
Rad. Controls 2
D. McCall Emer. Prep. Student Trainee Emergency Prep.
2 B. Mingst Emergency Planner Emergency Prep.
2 P. Scallon Rad. Field Oper. Manager Rad. Controls 2
W. Staehle Dresdner Associates Dresdner Assoc.
2 L. Thompson Training Inst ructor Training & Educ.
2,4 I. Wazzan Emergency Planner Emergency Prep.
2 J. Williams Support Training Prog. Mgr.
Training & Educ.
1 - Attended pre-audit conference 2/13/86 2 - Contacted during audit i
3 - Attended prepost-audit ecnference i
4 - Attended post-audit conference 5/9/86 l
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e S-0C-86-03 Page 1 of 2 REFERENCES 1.
10CFR50, Appendix E, Emergency Planning and Preparedness 2.
10CFR50.47,10CFR50.54q, Regulations Concerning Emergency Planning 3.
NUREG 0737, Clarification of TMI Action ~ Plan Requirements 4.
Reg. Guide 1.25, Assumptions to Evaluate Radiological Consequences of Refueling Accident.
S.
Reg. Guide 1.3, Rev.2, Assumptions Used for Evaluating the Potential Radiological Consequences of a Loss of Coolant Accident for Boiling
' Water Reactors 6.
Reg. Guide 1.5, Assumptions Used for Evaluation of the Potential
~
Radiological Consequences of a Steamline Break Accident at a BWR.
7.
Technical Specification, Appendix A, Sections 4.13, 6.8, and 6.9.2 8.
Operational Quality Assurance Plan, Rev.1-00 9.
Implementing guidelines: GPUN Nuclear Emergency Public Information Plan, Rev.5 10.
Oyster Creek Security Plan, Rev.18 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 Nuclear Corporation Emergency Plan for Three Mile Island and Oyster Creek Nuclear Station 16.
101.7, Rev.2, Emergency Duty Roster 17.
101.11, Rev.3, Maintaining Emergency Preparedness 18.
102.1, Rev.1, Emergency Preparedness Training 19.
103, Rev.17, Station Document Control 20.
106, Rev.36, Conduct of Operations 21.
106.2.1, Rev.1, Spill Procedures 22, 107, Rev.28, Procedure Control 23, 120.4, Rev.1, Fires 24 126, Rev.5, Procedure for Notification of Station Events j
25.
127.2, Rev.1, Emergency Preparedness Surveillance Program 26.
2000-PLN-1300.01, Rev.8, Oyster Creek Nuclear Generating Station Emergency. Plan 27.
2000-RAP-3024.01, Rev.10, NSSS Annunciator Response Procedures
)
28, 2000-RAP-3024.02, Rev.5, Electrical Annunciator Response Procedures 29.
2000-RAP-3024.03, Rev.8, BOP Annunciator Response Procedures 30.
500 Series Emergency Operating Procedures 31.
6430-ADM-1319.01, Rev.0, Oyster Creek Emergency Preparedness Program 32.
6430-IMP-1300.02, Rev.0, Direction of Emergency Response 33.
6430-IMP-1300.03, Rev.0, Emergency Notification 34 6430-IMP-1300.11, Rev.0, Emergency Radiological Survey-Of f site 35.
6430-IMP-1300.23, Rev.0, Thyroid Blocking 36.
6430-IMP-1300.24, Emergency Respirator Equipment Issue and Control 37, 6430-IMP-1300.30, Rev.0, In plant Radiation Surveys During Radiological Emergencies
e S-0C-86-03 Page 2 of 2
-REFERENCES 38, 6430-IMP-1300.35, Rev.0, Radiological Controls Emergency Actions 39, 6430-IMP-1300.40, Rev.0, Site Security Emergency Actions-
- 40.. 6430-IMP-1300.41, Rev.0,- Emergency Duty. Roster Activation 41.
6435-ADM-1311.01,- Rev.0,. Procedure and Surveillance Coordination.
42.
6435-ADM-1314.01, Rev.0, Emergency Preparedness Instructor Certification -
43.
658.4.003, Rev.3, ~ Emergency Alarm / Telephone Tests 44, 803.64, Rev.1,' Post Accident Procurement of Particulate & Radio-Iodine
- Samples f rom the Drywell 45.
831.4, Rev.2, Post Accident Sampling and Operations RAGMS 46.
831.7, Rev.4, Post Accident Sampling and Analysis; Preperation and Analysis 47.
831.8, Rev.2, Post Accident Sampling and Analysis; Estimation of Percent Fuel Failure 48.
EPIP-01, Rev.6,' Classification of Emergency Conditions 49.
EPIP-07, Rev.5, Of f site Medical Assistance Contaminated Injury /
Radiation Overexposure 50.
EPIP-09, Rev.5, Of f site Dose Assessment 6
51.
EPIP-10, Rev.3, Emergency Radiological Survey-Onsite-52.
EPIP-12, Rev.5, Personnel Accountability 53.
EPIP-13, Rev.4, Site Evaluation and Personnel Accountability Af ter. Site Evaluation 54. EPIP-14, Rev.3, Damage Control and Emergency Team Organization 55.
EPIP-15, Rev.2, Toxic / Flammable Gas Release 56.
EPIP-22, Rev.1, Search and Rescue 57.
EPIP-25, Rev.3, Emergency Operation Facility 58.
EPIP-26, Rev.4, Technical Support Center 59.
EPIP-27, Rev.3, Operations Support Center 60.
EPIP-29, Rev.2, Recovery Operations 61.
EPIP-31, Rev.2, Environmental Assessment Command Center (EACC) 62.
50-219/83-01 I&E Inspection Report
/
63.
50-219/83-03 I&E Inspection Report 64 50-219/83-04 I&E Inspection Report 65.
50-219/83-23 I&E Inspection Report 66.
50-219/84-13 I&E Inspection Report 67.
50-219/84'-15 I&E Inspection Report f
68.
50-219/85-03 I&E Inspection Report 69.
50-219/85-05 I&E Inspection Report 70.
50-219/85-09 I&E Inspection Report 71.
50-219/85-13 I&E Inspection Report 72.
50-219/85-17 I&E Inspection Report 73.
I&E Notice 83-28, Criteria for Protective Action Recommendations for General Emergencies 74 S-0C-80-50 75.
S-0C-81-19 76.
S-0C-83-02 77 S-0C-84-02 78.
S-00-85-02
Audit Nog N'
Comp 1stzd by:
Prrpared by:
S-O 5-02 Subj:ct:
ERIC CilECKLIST Date: z/g fr/M Date:
~
EMERGENCY PLANNING Approved by 4 2 /f [
l Pane l of 2 nnre-y
- i un o <
Z 2 Reference y Remarks Document Requirements I.
The program issued at the time of this audit is 1.
The regulatory requirement coverage of an audit is delineated in Section i displayed in Sections II and III of the reference of the reference document. Requisite document. The date at the top of the audit plan detail is provided on the reference indicates when the content and revision status document.
of this program was confirmed.
2.
Pending licensing based document (s)
II.
The time span covered by this audit is:
may be in the process of review for approval by the Nuclear Regulatory 3/85 - 2/86 Commission during the period covered III.
Specific activities to be audited are identified by the audit. This review may limit the regulatory requirements that are in the checklists and are listed by title below:
actually in effect. Also responses to
- Emergency Detection and ClassificatIrn Nuclear Regulatory Commission Inspection
- Protective Action Decisica Making decoMmMsfu m e Notification and Communication tive action which may not be due.
These
- Changes to Emergency Preparedness Program s m dhed h SWm W
- Fhift Staf fing and Augmentation / Training of the reference document with the
- Dose Calculations and Assessment / Post requisite detail.
Accident Sampling
- Public Information Program
- Emergency Worker Protection 3.
The basis of this audit is the programs
- Maintaining Emergency Pzeparedness delineated in Section II and III of
- Follow-up of Previous Audits and NRC the reference document. Consistency Instructions / Commitments between regulatory requirements and this basis will be confirmed during this audit.
4.
The checklist (s) which are attached represent a crystalization of the required actions / characteristics that will be confirmed. Tine purpose of this checklist (s) is to asrure a knowledge based sampling concept.
This means that deliberate directed actions are to be taken by the audit team to identify the state of compliance of the activities defia.ed by the reference document.
l
4.-
ERIC CilECKLIST - EMPRCENCY PLANNING 3 **9'
'I lieference m
4 flavinitaments us o Ilenessks docunnent
> z z t
- 5. Objective evidence that shall be used is documented evidence and/or observa-tion.
Documented evidence is records and issued procedures.
=
- 6. As a minimum, the objective evidence utilized to determine the >.sults and j
the period of review will be documented 1
I either directly on the checklist under l
the remarks section, or be referenced l
to attache,; tables or the audit report.
The documerr sion will be in legible handwriting of the perso.1 completing the checklist.
- 7. A tabular list of record titles / file numbers will be provided at the completion of the audit.
- 8. Well structured tables / figures should be developed /u ed when warranted to
(
facilitate the collection and evalua-l tion of data; and, the supervisory k
review of the results.
- 9. The Regulatory Guides and Industry Standards not in Appendix C of the QA Plan which are applicable to this audit will be listed in Section IV of the reference document.
l m
m m
N h
6 l
^
B s'^>
s
_ma
~
Emergency Planning S-0C-86-03 Page 1 of 2 Checklist A Prepared By:
h m c h 71l G
Approved By M'As/Gd 4//J//d Completedfy[//
J7 _'
r y
EMEkGENCY DETECfl0N CLASSIFICATION t
REQUIREMENTS REMARKS.
- 1. -Review site Emergency Plan and the implementing procedures to verify that emergency action levels are based on plant conditions and onsite and offsite radiological conditions l
2.
Verify by review of correspondence that the state and local agencies agree with the EALs and have reviewed i
i the EALs each year ao required by f
10 CFR 50, Appendix E Part IV.B.
l 3.
Verify that the classification procedure is adequate to ensure prompt and correct classification in accordance with 10 CFR 50, Appendix E, Part IV.C.
I l
i I
4.
Verify that procedures exist and are l
l adequate to effect,ively use post TMI indicators to determine core and i
1 containment status.
l l
1
- I 1
i ll
)
?>
-o, e
. Emergency Planning S-0C-86-03 Page 2 of 2 5.
Verify by review of the Emergency Plan and implementing procedures that there
.is one individual on site 24-hours per day who has the authority and responsibility'to classify events. initiate emergency actions, and to recommend protective actions.
6 Verify that the Emergency Action Levels are incorporated into the plant operation emeegency procedures.
r 7
Verify by review of the Emergency Plan and Implementing Procedures that provisions have been included to provide response to radwaste shipping accidents..
r 3
?
?
I 1
i 1
l 1
i 1
i l
r
v
- - ~...
ry, r.,
Emergency Planning S-0C-86-03 Page 1 of 1 Checklist B 2.k(&f 66 Prepared By:
m M 2-///[f6 Approved By:
,m Completed yh i
V PROTECTIVE ACTION DECISION MAKING REMARKS REQUIREMENTS 1.
Verify by review of drill packages and critiques / summaries of actual emergencies that the emergency organization effectively implemented the Emergency Plan and demonstrated the following:
a)
The appropriate protective action recommendations based upon plant condition and onsite/offsite radiological conditions were made.
b)
The duties and responsibilities assigned in accordance with the emergency plan and implementing procedures w'ere carried out.
2.
Verify by review of documentation that off site officials have the capability to make prompt public notifications as specified in 10 CFR 50, Appendix E, Part IV.D.3.
Emergency Plat:ning
-S-0C-86-03 Page 1 of 2 Checklist C Prepared By:9 EkW 6 em Approved By:M, %
1/4[,/(c Completed [y((
k' V
NOTIFICATION AND COMMUNICATION REQUIREHENTS REMARKS 1.
Verify that the procedures litted in Section III.C, of the reference document are consistent with the emergency classi-fication and emergency action level schemes 7
contained in the Emergency Plan.
2.
Verify by review of drill packages that notifications to federal, state, and local agencies are made as required.
o 3.
Verify by review of records that initial response team and full mobilization team personnel mobilization procedures are implementable, verify accuracy of the confidential phone list on a sample basis.
4.
Verify by observation that each facility has the communication equipment specified in the Emergency Plan, and that the equipmant meets the requirements of 10 CFR 50, Appendix E./10 CRF 50.47 (b) (6) i i
i Erarg:ncy Plcnning S-0C-86-03 Page 2 of 2 5.
Verify by document review that the evaluation of state and local government interface con-ducted during the audit is made available to these agencies in accordance with 10CFR50.54(t),
Emergency Planning S-0C-86-03 Page 1 of 1 Checklist D Prepared By:
@c% M tid %(o Approved By:
fu 2
'#[#
Completed [yh, k
o
.u CHANGE TO EMERGENCY PREPAREDNESS PROGRAM REQUIREKENTS REMARKS 4
i 1.
Verify by procedure review that changes to emergency facility equipment and instrumentation have been incorporated into the Emergency Plan and implementing l
procedures.
2.
Verify that changes to the emergency organization, administration and maintenance of emergency preparedness, I
and to the training program have been reflected in changes to the Emergency Plan and implementing procedures.
3.
Verify by record review that the above changes were reviewed by appropriate i
levels of management.
i 4.
Verify by record review that state and local response plans which interf ace with the emergency plan are available i
and that letters of agreement are avail-i able and current.
1 Emergency Planning W
~
S-0C-86-03 Dage 1 of 1 l
Checklist E W dW Prepared By.Maw //[ 2M///L Approved By:
Completed [y
[
v SHIFT STAFFING AND AUGHENTATIOK/ TRAINING REMARKS REQUIREMENTS 1.
Verify by review of documentation that response team members are qualified and that their qualification has been maintained via refresher training.
i 1
2.
Verify by review of personnel qualAfications that personnel can meet or exceed the fuctional requirements for staffing required by NUREG 0654 table B-1 and NUREG 0737.
3.
Verify implementing procedures are consistent with the Emergency Plan to provide for effective shift augmentation in accordance i
with the plan 4.
Keview surveillance records to verify that augmentation imes have been
)
checked to ensure euguentation meets the criteria in the Emergency Plan.
I J
5.
Verify by review of records that a
training has been provided to f
off-site emergency agencies, i
l
. c.
Emergency Planning S-0C-86.
Page 1 of 1 Checklist F e
'2\\ 1 fdo Prepared By:
-7h((h Approved By:
fc Completed [y[Of DOSE CALCULATIONS AND ASSESSHENT/ POST ACCIDENT SAMPLING REQUIREMENTS
, REMARKS 1.
Verify that adequate procedures exist and
- hat pers:nnel -are trained to perform manual dose calculations in the event of computer failure.
p 2.
Verify that protective action recommendations are based upon dose calculations correlated with the degree of uncertainty. The basis of the various recommendations should be delineated in procedures and consistent with the Emergency Plan.
J 3.
Verify by record review that radiological and metorological instruments described in the Emergency Plan and' procedures used to 1ssess plant radiological conditions are avuilable and maintained.
l q
4.
Verify that procedures are in place which 1
{
relate post accident monitoring readings to core condition, radioactivity concentrations, release i
rates, and total activity.
i j.
l I
Emergency Planning S-0C-86-03 Tage 1 of 1 Checklist G ILkid8N Prepared By:
1_
/b Approved By:
-a 2
Completed ((Jf
[
PUBLIC INFORMATION FROGRAM REQUIREMENTS REMARKS 1.
Verify by review of records that an updated public information package is sent annual'.y to people located within the EPZ.
2.
Verify by observation that road signs or other measures are maintained which provide information to the transient population.
3.
Verify by procedure review and observation that there is a point of contact for the public to obtain additional information I
in the event of an accident and that the i
facility / equipment is maintained.
i i
I:
Emergency Plcnning S-0C-86-03
~
Page 1 of 1 Checklist H mN Prepared By:
Approved By:Mae 2[//!'16 Completed
[
/
s/
EMERGENCY WORKER PROTECTION gQUIREMENTS REMARKS 1.
Verify by procedure review that 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> availability of someone with the authority to permit exposure beyond 10 CFR 20 limits is on site.
2.
Veri'.y by procedure review that emergency exposure limits fall within the EPA guidence.
i 3.
Verify by procedure review adequate l
respiratory protection equipment and protective clothing are available for emergency personnel.
4.
Verify that issuance of KI tablets are I
controled in accordance with, (NCEP) Report
- 55, FDA guidance June 29, 1982, Federal Register Notice page 28158.
5.
Verify that adequate facilities exist and I
are maintained to provide for worker decontamination.
Emergency Planning S-0C-86-03 Page 1 of 1 Checklist I Prepared By: 9A N \\Md Approved By:Mst<med 2[N6 y]((
/[
Completed v
MAINTAINING EMERGENCY PREPAREDNESS REQUIREMENTS REMARKS 1.
Verify by review of drill packages that applicable drill comments dealing with facility inadequacy or program deficiencies are tracked.
2.
Evaluate promptness of corrective action by a review of Emergency Preparedness Action Item Tracking System. Perform a comparison of action item open/ closed dates, identify the number of items over-due (establish a trend), and verify follow-up activities for overdue items.
3.
Verify by record review that the basis for closeout of action items are documented.
4.
Verify by record review that the surveillances performed by Emergency Preparedness are scheduled and documented.
5.
Perform an inventory of facility equipment utilizing 101.11 forms for a sample of facility lockers.
^*
Emergency Planning S-0C-86-03 Page 1 of I Checklist J Prepared By D e N&d Approved By:
e ra
/
Completed [y((
[
V FOLLOW-UP OF PREVIOUS AUDITS AND NRC COMMITMENTS / INSPECTIONS REQUIRP.MENTS REMARKS 1.
Review the Licensing Action Items-assigned to Emergency Preparedness and determine the status of selected items.
There currently are no open audit findings against Emergency Prep.
P v
s s,
Emergency Planning S-0C-86-03 Page 1 of 1
_ Checklist K Prepared By:_D h 2kl 8h Approved By:
[w< r 3///N'8 Completed *[y[)
[/
V REVIEW OF QA MONITORING / INSPECTION REQUIREMENTS REMARKS 1.
Review the QA Monitoring file maintained on Emergency Preparedness items. Assess the adequacy of program coverage.
o.
E*
Aua. Not*
Comp 1sted by:
WOM_
Prepared by:
Sub ect: CENERIC CHECKLIST MRM E,
hrs:
Date-Emergency Plan
~
Pane I of 2 8
.n unO 42 Reference g3:
Remarks Document Requirements 1.
The regulatory requirement coverage 1.
The program issued at the time of this audit is of an audit is delineated in Section I displayed in Sections II and 111 of the reference of the reference document. Requisite The date at the top of the audit plan detail is provided on the reference document.
indicates when the content and revision status document.
of this program was confirmed.
2.
Pending licensing based document (s)
II.
The time span covered by this audit is: 02/66 - 02/07 may be in the process of review for approval by the Nuclear Regulatory Commission during the period covered by the audit. This review may limit identified III.
Specific activities to be audited are the regulatory requirements that are in the checklists and are listed by title below:
actually in etfect. Also responses to Nuclear Regulatory Commission Inspectio-Organization reports provide commmitments for correc-Training tive action which may not be due.
Thes.
Emergency Detection Classification items are delineated in Section VI i
Protective Action Decision Making of the reference document with the Notification and Communication requisite detail.
Changes to Dnergency Prep. Program Dose Calculations & Post Accident Sampling 3.
The basis of this audit is the programs Public Information Program delineated in Section 11 and III of Emergency Worker Portection the reference document. Consistency Maintaining Emergency Preparedness between regulatory requirements and Followup of Previous Audits this basis will be confirmed during this audit.
4.
The checklist (s) which are attached represent a crystalization of the required actions / characteristics that will be confirmed. The purpose of this checklist (s) is to assure a knowledge based sampling concept.
This means that deliberate directed actions are to be taken by the audit team to identify the state of complian<
of the activities defined by the i
referciam ow.ameut.
J
Sealsject:
Aindle eso.:
..: 2-GENERIC O.
Kl.1ST g * **#
Ilefossence en en O 4
Ilensest(s Ileenielsessiente docuniesit 3
g z
- 5. Objective evidence that shall be used
~
is documented evidence.snd/or observa-tlon.
Documented evadence is records and issued procedures.
- 6. As a minimum, the uts icct ive evidence utilized to determitie the results. mad the period of review will be documented either directly on the checklist uniler the rt-m.a r ks sec t ion, or lie ref er enced to at tached t.sh'es or the audit report.
The documentation wil! be in legible handwriting of the person completing t he clieck t ist.
- 7. A tabular 1ist of record titles /ffle numbers will be provided at the completion of the audit.
structured tables / figures should
- 8. Well be developed /used when warranted to facilit.ste the collection and evalua-tion o! data; and, the supervisory
~
~
review of the results.
- 9. The Regulatory Guides and Industry Standards not in Appendix C of the QA Plan which are applicable to this audit will be listed in Section IV
]
of the reference document.
~
1 1
e 6 _
6 _ N
SQbject;'
Pr; pared by:
Audit No.
Data:
S-0C-87-Oi
.'INERGENCY PLANNING Approved by:
Date:
Page 1 of 12 RMUIREMENTS RhrtxENCES KEMARKS A.
ORGANIZATION 1.
Review the Program Plan (Section 5 Figure 18),
OCNGS Technical S xcification (Figure 6.2.2) and tie GPUN Organizational Ourt and verify that the emergency organization is defined clearly and documented for the following functional areas:
a, emergency response coordination b.
plant systems operation c.
operational accident assessment d.
radiological environmental survey and e.
first aid / rescue f.
personnel monitoring g,
decontamination h.
security of plant and site access control 1.
repair / corrective actions J.
personnel accountability K.
radiological accident assessment 1.
Communications m.
radiation protection n.
plant chemistry o.
radwaste operations p.
technical support q.
nanpower planning and logistical support r.
public information and education 2.
Verify by above review that persons who may be, assigned to the above functional areas of emergency activity are specified at all levels.
3.
Determine by interview of above selected personnel that they understand their assigned emergency response duties and required interfaces.
Audit Noa
Subject:
'S-0C-87-01 EMERGENCY PLANNING
^
Page 2 of 12' REQUIREMENTS REFERENCES REMARKS 4.
Verify by program review that administrative provisions are in place that ensure the Foergency Director has the authority to support his responsibility and carry out this duties.
5.
Verify by program review that administrative provisions are in place for ensuring adequate coordination between the site emergency organization and the following:
a.
corporate headquarters b.
federal government c.
state government d.
local government e.
news media f.
other organizations referenced in the plan 6.
Verify by program review that corporate personnel who will augment the on-site emergency organization are specified by position or title for each of the following areas (if needed):
a.
emergency response coordination b.
operational accident assessment c.
radiological accident assessment d.
radiological monitoring and environmental survey e.
health physics f.
technical support l
g.
manpower and logistical support h.
public information i.
license representative to state EOF j
j.
dosimetry and measurements j
7.
Determine if a roster of qualified individuals for each position or title has been developed and updated on a quarterly basis for each function listed in #6 above.
4
\\
Audit No.-
l 5@jict: '
S-0C-87-01
.' EMERGENCY P!ANNING Page 3 of 12 REQUIREMENTS REFERENCES REMARKS I
t 8.
Review a sample drill and verify that the station has' demonstrated the minimum augmentation specified in 1000-PI.N-1300.01, paragraph 5.2.;
9.
Verify by program review that adequate support services are
-identified, can be notified on a 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis, and can support a protracted
- response, for the following:
a.
fire b.
police / security c.
ambulance d.
medical e.
transportation f.
communications g.
temporary sleeping quarters j
h.
food and water i.
sanitary facilities j.
equipment and supplies procurement k.
other support services
[
described in the plan.
- 10. Verify by program review that specific individuals or disciplines (departments) are assigned and have responsibility for the following emergency-preparedness activities:
7 a.
training i
b, developing drill and exercise j
1 scenarios I
c.
conducting-drills and exercises i
d.
inventorying and maintaining i
emergency facilities and i
equipment e,
maintaining and updating implementing procedures f.
auditing the emergency program 1
l
- 11. Verify by Emergency Plan review
]
that Item #10 above are doctanented in the plan.
I l
l l
i
Audit No.
Subget:
S-0C-87-01 DERGENCY PLANNING Page 4 of 12 REQUIRBGNTS REFERENCES RBRRKS B.
Training 1.
Verify by document / record review that the Mgr. Plant Training has developed, implemented and maintained the O.C.
E:nergency Preparedness Training Program
-1720.
Sample personnel Qualification Cards versus Course l
Application liatrix Functional Group Training Matrix Off-Site Organi:ational Training
- Matrix, etc. (Forms 3,4,65).
2.
Select an appropriate sample size Roster and from the Emergency Duty / retraining verify that training schedules for emergency duty personnel were executed to maintain personnel readiness xr training requirements; and, tTat timely notification of necessary training to roster personnel was initiated.
3.
Verify by review of classroom attendance sheets that roster personnel who received Emergency Preparedness classroom training were present and had signed-off the attendance sheet.
1 4.
Review a sampling cf Emergency Duty Roster Change Forms Exhibit i
5 of 6430-AIM-1319. 01 for personnel selected for emergency preparedness training and verify l
that training was completed in 4
accordance with OC Training Program 1720, 1
5.
Review Exhibit 1
of 6232-AIN-
)
2623.04 and verify that Training 6 lilucation personnel who conducted Emergency Preparedness Training were certified and qualified per this procedure; and also met the i
requirements of E.P.
Training Program 1720.
. Audit No.
-~~
Sgojecer S-0C-87-01
."EERGENCY PLANNING Page 5 of 12 9
REFERENCES REMARKS REQUIREMENTS 6.
Review Exhibit 1
of 6435-AIM-1319.01 and verify that employees assigned to the Emergency Preparedness Dept. who provided instruction
.to other o
plant organizations were i
certified.
- Also, determine if i
instmetor evaluations-were performed-by the
'IllE Section during one of the presentations.
i 7.
Review the required reading-file maintained by the E.P.
Surveillance Coordinator for the EP Section and verify that 2
Exhibits 1, 2 and 3 are maintained to ensure that staff members have completed their assigned self study subjects.
3-i 8.
Review Table 23 of the Emergency Plan and select a representative number of personnel assigned Emergency Plan duties and responsibilities and verify that they received specialized training and requalification training annually not to exceed 15 months between training cycles, j
9.
Verify by review training documentation that the local medical representative recalved emergency training on an annual basis regarding site access j
emergency organization including discussion of.
interfacing with
- hospital, security and RadCon personnel for action concerning j
injuries.
- 10. Verify training documentation that GPUN has invited emergency management organizations such as N.J.
Office of Emergency Management State of Bureau of Radiation Protection, and Ocean County Dept. of Emergency Services to participate on an annual basis 1
in a training program, i
2
Audit No.
Subj.ct: e 3-0C-87-01
. EMERGENCY PLANNING Page 6 of 12 REQUIREMENTS REFERENCES REMARKS
- 11. Review the list of off-site support agencies and verify that an offer of training was made and executed for hospital personnel ambulance and rescue, police and fire departments.
- 12. Review Training Development Manual and verify by number / designation that training categories are consistent with the emergency activities in the station's emergency organization as defined in the Emergency Plan and procedures, for example:
a.
emergency response l
coordination b.
plant systems operation k
c.
radiological environmental survey and monitoring d.
fire fighting i
e.
first aid / rescue (Red Cross l
Standard First Aid-Maltimedia j
f.
personnel monitoring g.
contamination control and decontamination h.
security and site access control i.
repair / corrective actions j.
personnel accountability k.
radiological accident assessment 3
1.
communications m
radiation protection and in-plant radiological survey and monitoring n,
plant chemistry o.
radwaste operations p.
technical su) port q.
emergency pu)1ic information I
13.
Review a
sampling of approved
)
t lesson plans from training categories listed in #6 above and verify that:
1 a.
Lesson plans have clearly j
gg udent performance
Sybjectt.
Audit No.
s-0C-87-01
. EMERGENCY PLANNING
?
Page 7 of 12 REQUIREMEN15 REFERENCES REMARKS I
b.
Training Content - Records are consistent with the content delineated in the lesson plan.
- 14. Review the file maintained for I
cach drill / exercise conducted during audit review period and verify that the Emergency Preparedness Manager did the following:
a.
Coordinate the assignment of personnel to prepare a
- scenario, b.
Coordinate efforts with other participating emergency personnel, organizations, and agencies.
c.
Obtain reqJired approvals (refer to applicable Administrative Procedures).
d.
Coordinate a date for drill execution and arrange for qualifled observers, e.
Critique the results of the drill.
f.
Assign personnel to correct any deficiencies.
g.
Ensure that deficiencies are 4
corrected.
h.
Ensure that proper documentation is retained.
- 15. Verify by schedules / file review I
that the following drills / exercises were conducted in accordance with the Emergency Plan, a.
Medical Emergency Drill b.
Fire Emergency Drill (per Fire Protection Plan) c.
Communication Link Test d.
Radiological Monitoring Drill e.
Radiological Controls Drill f.
Ha:ardous Material Spill l
Drill (per GPUNC Environmental Control Plan)
S.
Radiation Emergency Exercise o
Sybj.ct:o Audit No.
S-0C-87-01 EMERGENCY PLANNING Page 8 of 12 REQUIREMENTS REFERENCES REMARKS 1
16.
For those emergency drills / exercises conducted each quarter / annually, verify by record review of Exhibit 1
of 6430-ADM-1319.01, that the Bnergency Preparedness ihnager conducted drill / exercise through the use of the exhibit.
- 17. Select a sampling of personnel from the Emergency Duty Roster and perform interviews relative to the encrgency preparedness training received to verify the employees knowledge, duties / responsibilities that were to be acquired through program training.
C.
EMERGENCY DETECTION CIASSIFICATION 1.
Review site Emergency Plan and the implementing procedures to verify that emergency action levels are based on plant conditions and onsite and offsite radiological conditions l
2.
Verify by review of correspondence that the state and local agencies agree with the EALs and have reviewed the EALs each year as required by 10 CFR 50, Appendix E.
Part IV.B (Assessment Actions).
3.
Verify that the classification procedure is adequate to ensure prompt and correct classification in accordance with 10 CFR 50, Appendix E, Part IV.C (Activation of Emergency Organization).
4.
Verify that procedures exist and are adequate to effectively use post TMI indicators to determine core and containment status.
5.
Verify by review of the Emergency Plan and implementing procedures J
that there is one individual on site 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day who has the authority and responsibility to classify
- events, initiate emergency
- actions, and to recommend protective actions.
Subjectn Audic No.
S-0C-87-01~
,' EMERGENCY PIANNING Page 9. of 12 REQUIREMENTS REFERENCES REMARKS 6.
Verify that the Emergency Action Levels are incorporated into the plant operation emergency procedures.
7.
Verify by review of the Emergency Plan and Implementing Procedures i
that provisions have been included to provide response to radwaste i
shipping accidents.
4 D.
PROTECTIVE ACTION DECISION MAKING 1.
Verify by review of drill packages and critiques / summaries of actual emergencies that the emergency organization effectively implemented the Emergency Plan and demonstrated the following-i a
'!he appropriate protective action recommendations based upon plant condition and onsite/offsite radiological conditions were made, b
'Ihe duties and responsibilities assigned in
[
accordance with the emergency plan and implementing i
procedures were carried out, t
2.
Verify by review of documentation that off site officials have the i
j capability to make prompt public notifications as specified in 10 4
CFR 50, Appendix E.
Part IV.D.3 (Notification Procedures).
E.
NOTIFICATION AND CONUNICATION 1.
Verify that the procedures listed in Section III.C, of the reference document are consistent with the emergency classification and
)
emergency action level schemes l
contained in the Emergency Plan, EmbI YtikNob to Eh!$8 n
state, and local agencies are made as required.
J 1
I
Audit No.
Sub).ct:
s.0C-87-01
- EMERGENCY PLANNING Page 10 of 12 REFERENCES REMARKS REQUIREMENTS 3.
Verify by review of records that initial response team and full mobilization team personnel i
mobilization procedures are t
implementable, verify accuracy of the confidential phone list on a j
sample basis,
~
4.
Verify by observation that each facility has the communication equipment specified in the l
i Emergency
- Plan, and that the equipment meets the requiremencs of 10 CFR 50, Appendix E./10 CRF 50.47 (b) (6) i 5.
Verify by document review that the evaluation of state and local government interface conducted during the audit is made available to these agencies in accordance l
with 10CFR50.54(t).
i l
F.
CHANGE TO EMERGENCY PREPAREDNESS PROGRAM 1.
Verify by procedure review that changes to emergency facility equipment and instrumentation have been incorporated into the Emergency Plan and implementing
]
procedures.
}
l 1
2.
Verify that changes to the emergency organization, administration and maintenance of emergency preparedness, and to the training program have been i
reflected in changes to the Emergency Plan and implementing procedures.
1 3.
Verify by record review that the above changes were reviewed by l
appropriate levels of management.
i 4.
Verify by record review that state and local response plans which q
interface with the emergency plan i
1 1
are available and that letters of i
agreement are available and current.
l
l o
o Audit No.
%]ect:
S-0C-87-01 INERGENCY PLANNING Page 11 of 12 1
l REFERENCES REMARKS REQUIRIMENTS G,
DOSE CAILULATIONS AND ASSESSbEVr/ POST _
ACCIDFXT SAMPLING 1.
Verify that adequate procedures exist and that personne; are trained to perform manual dose calculations in the event of computer failure.
2.
Verify that protective action recommerdations are based upon dose calculations correlated with the degree of uncertainty.
The basis of the various reco:nmendations should be delineated in procedures and consistent with the Emergency Plan.
3.
Verify by record review that radiological and netorological instruments described in the Emergency Plan and procedures used to assess plant radiological conditions are available and maintained, i
4.
Verify that procedures are in place which relate post accident monitoring readings to core
[
condition, radioactivity concenwations, release rates, and total activity.
H.
PUBLIC INFOR4\\ TION PROGRAM 1.
Verify by review of records that an updated
'public information package is sent annually to people located within the EPI.
I 2.
Verify by observation that road signs or other measures are maintained which provide infonnation to the transient populatf.tn.
3.
Verify by procedure review and observation that there is a point obtain" aYbti'oN1 $foi tik in the event of an accident and that the f act'.lity/ equipment is maintained.
j
..c g3--
i 0
s.0C-87-01 GENCY PLANNING Page 12 of 12 REQUIRB E IS REFERENCES kBiARKS I.
BERGENCY h'ORKER PROTECTION 1.
Verify by procedure review that 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> availability of someone with the authority to permit exposure beyond 10 CFR 20 limits is on site.
2.
Verify by procedure review that
'mergency exposure liu.ts fall ithin the EPA guid1nce.
3.
Verify by procedure review adequate respiratory protec'.lon equipment and protective clothing are available for emergency personnel.
4 Verify that issuance of KI tablets are controled in accordance with, (NCEP) Report
- 55, FDA guidance June 29, 1982 Federal Register Notice page 28158.
5.
Verify that adequate facilities exist and are maintained tc-provide for worker decontamination.
K.
FOLLOW-UP OF FREVIOUS AUDITS AND NRC CONIDENTS/INSPEC[JONS 1.
Review the Licensing Action Items assigned to Energency Preparedness and determine the status ci selected items.
.