IR 05000317/1986013

Emergency Preparedness Insp Repts 50-317/86-13 & 50-318/86-13 on 860721-25.No Violations Noted.Major Areas Inspected:Onsite Review of Equipment Surveillance Testing & Overall Maint of Emergency Preparedness Program

ML20209D414
Person / Time
Site:	Calvert Cliffs
Issue date:	08/28/1986
From:	Amato C, Hawxhurst J, Lazarus W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20209D401	List: IR 05000317/1986013 ML20209D397
References
50-317-86-13, 50-318-86-13, NUDOCS 8609090290
Download: ML20209D414 (12)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

50-317/86-13 Report Nos. 50-318/86-13 50-317 Docket Nos. 50-318 DPR-53 License Nos. DPR-69 Priority --

Category C Licensee: Baltimore Gas & Electric Company P.O. Box 1475 Baltimore, Maryland 21203 Facility Name: Calvert Cliffs Nuclear Power Plant, Units 1 & 2 Inspection At: Lusby,-Maryland Inspection Cor.;ucted: July 21-25, 1986 Inspectors: _ M b- W 8"/8-M Jameg HawxVur's5, Emergency Preparedness date Spi.cialist, EPS Charles Amato, Emerg'ency Preparedness

! NPES date Specialist, EPS Approved by: ~h rus ief, Emergency Preparedness

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' date ection,@EPRPB/DRSS Inspection Summary: Emergency Preparedness Inspection on July 21-25, 1986 (Report Nos. 50-317/86-13 and 50-318/86-13)

Areas Inspected: Unannounced routine inspection of emergency preparedness ,

activities and follow-up on previous open items. The inspection inclucea onsite review of equipment surveillance testing and overall maintenance of the EP program by two regional based NRC inspector Results: No violations were identified. Eight outstanding items were closed and two were opened, one of which is unresolve PDR ADOCK 05000317 G PDR

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DETAILS 1.0 Persons Contacted

• T. Forgette, Supervisor Emergency Planning G. Reimer, Plant Health Physicist L. Smialer, Senior Health Physicist L. Sundquist, Gen. Supervisor, QC and Support

• R. DeAtley, Senior Engineer / Worker Leader QA

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G. Rudigier, EP Analyst C. Rathburn, EP Analyst B. Radford, Principal Chemistry Technician G. Phifer, QA Auditor C. Quimby, QA Auditor J. Carroll, General Supervisor QAS J. Lagiewski, QA Auditor J. Roller, ER Training Coordinator J. Tiernan, VP Nuclear Generation M. Stone, Technical Training Clerk M. Eye, QA Auditar W. Pever, Records Clerk, Security J. Rivera, Shite Supervisor T. Jones, Senior Reactor Operator <

• Attended exit meetin .0 Review of Previous Open Items (Closed) IFI 50-3).7/318;84-24-04 : Perform a reliability study of the MIDAS system ar.d modify the system based on the study to ensure its availability during an inciden The inspector noted a study was performed in 1985 and forwarded to Mr. Thadani, Director, Division of PWR Licensing on July 14, 1986. The availability of the MIDAS initial dose estimate computer system was 85%

for the full year and increased to 92% for the first five months of 1986.

l The inspector determined that as an interim approach the current initial dose estimate computer system provided reasonably reliable availability.

l The method of surveillance was modified to require checking the system

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once per day, Monday through Friday. The licensee plans to install the system onsite; thereby, increasing the control and reliability of the system. The system availability study has been continued into 1986.

l 2.2 (Closed) 50-317/318;[84-24-08ithe Radiological Assessment Director (RAD)

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failed to demonstrate consraerations and recommendations of blocking agent (KI) for site personnel to the site Emergency Director (SEC) per the appropriate procedure (ERIP 4.1.15).

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The inspectors noted, during observation of the September 10, 1985 full-scale exercise, that initially KI was considere However, the RAD didn't recommend administration of KI. As a result, an estimated seven Rem thy-roid dose commitment could have been incurred by offsite monitoring team member The inspector reviewed ERPIP 4.1.15, held discussions with two qualified RADS and noted RAD retraining has emphasized this area. The licensee has agreed to demonstrate this area of protective action decisionmakir.3 during an upcoming dril .3 (Closed) IFI (50-317/85-25-01; 50-318/85-22-01): Sufficient equipment was not provided to support a prolonged emergency, specifically communications for NRC response personne The inspector noted an evaluation was performed, and it was determined that with existing cabling, an additional ten phones can be added to the TSC area, within a da .4 (Closed) IFI (50-317/85-25-02; 50-318/85-22-02):

a) Misleading information provided to the OSC initially caused confusion and lack of sufficient controller / observer interventio , The controller / observers are provided with the details of the sce-nario and specific instructions prior to the exercise; the approp-riate time for controller intervention will be discussed and emph-asize b) When a plant team exited the auxiliary building (an actual radio-logical control area), whole-body frisking was not performed; The licensee indicated that players are provided, two weeks before the exercise, player instructions in which item No. 14 discusses controls when exiting actual radiological controlled dreas. This will be re-emphasized prior to the exercise and is also part of G.0.T. (General Orientation Training).

c) The OSC communicator was not properly trained; he had to be shown how to contact the Emergency Response Facilities (ERFs) and where the phone listings were kept.

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The licensee indicated training had been provided to the communi-cator, including practical trainin The licensee has adequately addressed concerns in this are .5 (Closed) IFI (50-317/85-25-03; 50-318/85-22-03)

a) Apparent inability to acquire a PASS sample during simulated accident conditions;

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The licensee indicated that a PASS sample was successfully taken dur-ing March and June 1986 drills. In addition, the licensee das ad-dressed this issue with NRR and developed procedures for use with the l NSSS coolant sample sink during accident conditions. This adequately addressed the EPP item; however, this area is under a separate review as discussed during an August 14, 1986 Enforcement Conference and in a January 16, 1986 letter (EA-85-102).

b) During the first PASS attempt to collect a containment atmosphere

! sample, the technician experienced problems due to procedural in adequacies and/or training problem While the PASS' system will be used during the 1986 exercise, this area is still under review (see Inspection Report Nos. 50-317/85-16; 50-318/85-15 item number 3 and NRC Confirmatory Order dated March 14, 1985).

c) During the second attempt to obtain a PASS sample, both team members encountered problems with their biopacks. As a result, it is highly unlikely they would have been able to complete the assignment since it would have taken longer than 45 minutes to do s The licensee has replaced biopacks with new hSA air pack and plans to install a cascading air supply system for use while acquiring a PASS sample. This area is also being reviewed under the above in-spection report followu .6 (Closed) IFI (50-317/85-25-04; 50-318/85-22-04):

a) Transition of direction and control for the radiological monitoring teams (outside the plant) was incomplete in that sample data (iodine air) was not transferred to the EOF; The inspector noted that after discussing transition of direction and control with the RAD that they will hand carry all the radiological information from the TSC annel to the EOF for use in decisionmaking and dissemination to State, federal and local government organiza-tion b) Meteorological data is not provided directly to the Emergency Oper-ations Facility (EOF) dose assessment personnel, consequently incom-plete and misleading information hampered the overall assessment; The licensee has indicated that the MIDAS system will be used to pro-vide meteorological data directly to the EOF dose assessment person-nel. This will be demonstrated during the 1986 exercis . - - - _ _ . - . . _ - - -

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c) Wide Range Noble Gas Monitor (WRNG) readings transmitted at 10:00 a.m. during the exercise were not verified. The readings were transmitted from the control to the E0F where they were used to com-pute off-site dose rate The licensee has followed up on this item by emphasizing the import-ance of verification of data, during the retraining of the emergency response personne d) It was not always clear who was "in-charge" of the dose assessment area (EOF). The assistant RAD frequently gave direction to staff and briefed Site Emergency Coordinator (SEC).

The inspector determined after discussions with licensee personnel that an Assistant RAD position is not officially part of the emer-gency response organizatio The RADS who respond (three are called)

to an incident (Alert or above) are all traine The inspector asked that during the 1986 exercise one RAD be designated as second shift and not participate during the exercis Controller intervention may be necessary to maintain continuity and allow the inspectors to ade-quately evaluate this are e) No dose projections were performed using projected meteorological and radiological data, only plume tracking using actual measured data was don This area will be demonstrated during the 1986 exercis f) The MIDAS computer was not effectively utilized to provide dose pro-jections. Manual centerline hand calculations were used as the pri-mary means for assessment. This area will be demonstrated during the 1986 exercis g) Integrated dose rate calculations were overly conservative, no change

. in wind direction was assumed and values were cnly calculated at 3 centerline distances (site boundary, 5,10 mi.).

The MIDAS system will be used as the primary means to estimate off-site doses and integration will be demonstrated during the 1986 exer-cis h) Due to oversimulation (data collection and MIDAS calculations) of initial dose assessment and failure to provide adequate dose projec-tions, a scenario objective in this areas was not me The inspectors noted followup drills were held using the MIDAS system and

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2.7 a) (Closed) (50-317/85-25-05; 50-318/85-22-05): No Open/ Closed detector window readings by monitoring teams traversing the plume were mad The inspectors reviewed the methods, equipment and procedure to lo-cate and track the airborne radioactive plume. The methods and equipment are specified in ERPIP 4.1.6 Rev.11 Ch.1, utilizing the Eberline R0-2 ion chamber survey meter. The inspector noted that Open/ Closed window reading are not required by procedure. Discus-sions with the licensee indicated that open/ closed window reading with an ion chamber instrument can be ineffective and misleading since the closed window will not effectively block beta radiation from noble gases which can enter the chamber if the instrument is in the plume. The inspector agreed with this position and notes that evaluation of ion chamber use for determination of plume location should receive additional study, b) Contamination control was lacking during the handling and counting of filters. Gloves were not worn when handling the charcoal car-tridge The scintillation probe was in direct contact with the cartridge during countin This item was tracked by the Emergency Response Coordinator, results were provided to the training d aartment and included in an attach-ment to the lesson plan package. All offsite team members have received retrainin c) An estimated seven rem thyroid dose commitment could have been incur-red by team members. No mention of the use of KI was given by the RAD at the E0F. The inspector discussed with RAD and other licensee personnel and reviewed procedure ERPIP 4.1.15 Rev. 9. The licensee agreed to re-demonstrate the decision-making process for radiopro-tective drugs. (Refer to 50-317/84-08 above).

This area has been adequately addressed by the license .8 (0 pen) IFI (50-317/85-25-06; 50-318/85-22-06)

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a) Emergency notification for the Alert and General Emergency were not completed within the required 15 minute time period. The licensee indicated that the emergency communicators (ECOM) were retrained in 1986 and the revised lesson plan included reference to notification problem identified during the 1985 exercis This area will be demonstrated during the 1986 exercis b) The initial notification form (Attachment 1) for the general emergency was not completed by ECOM and it is not clear if the Maryland Emergency Management and Civil Defense Agency was notified by the licensee directly.

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As discussed above the ECOM were retrained and this area was specifically addressed during the' lesson. This area will be demonstrated during the 1986 exercis c) After declaring the General Emergency there was a deviation from NRC policy stated in IE Information Notice.83-28. Immediate Protective Actions Recommendations were not mad This area is still under review by the license .9 (Closed) 50-318/85-06-011 Followup on retraining, control of examination grades, updatesof EPIP and Lesson Plans (LPs).

Retraining and requalification is pursued until the individual success-fully completes the examination. Examination grades on an individual basis are stored in locked, steel cabinets within a fireproof building. Access to grades is authorized on a need to know basis. The EP, EPRIP and LP are revised and updated as neede .0 Emert icy Plan and Implementing Procedures 3.1 Review The inspectors held discussions with licensee personnel and reviewed selected procedures to determine:

- if significant or major changes have been made to the emergency pre-partdness program;

- tha; changes have not adversely affected the overall state of emer-gency preparedness, and;

- that changes have been reviewed, approved and distributed in accord-ance with approved licensee procedure .

3.2 Findings The inspector reviewed recent changes to the Calvert Cliffs Emergency Response Plan, Rev. 7 and Emergency Response Plan Implementing Procedures (ERPIP). ERP and EPRIPs are first evaluated by the Emergency Planning

Coordinator EPC, and then by the Plant Safety Review Committee which approves any modifications, deletions and/or additions. The approval signature has recently changed (Jan 1986) from the Plant Superintendent to Manager of Nuclear Operations. This reflects the recent change in the !

organization. The most significant procedure deletions and additions involved the original CE PASS system and the NSSS sample sink. The inspector noted that the NSSS system (now used for PASS) procedures were ,

incorporated as an ERPIP following testing, verification and deletion of !

CE system procedures on June 6, 1986. This area is acceptabl )i

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The inspector found that a description of the following emergency equip-ment has not been included in the Emergency Plan and/or in the ERPIP:

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Post-accident sampling system;

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Plant parameter phone system; and Currently used Initial and Refined Dose assessment computer

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system (methodology)

This item will be reviewed in a subsequent inspectio IFI (50-317/86-13-01; 50-318/86-13-01).

The inspector acknowledged that an outline of the system capability and a reference to the full description in the FSAR would adequately address the requirement (10 CFR 50 Appendix E.IV E) for describing facilities and equipmen The inspector verified the operability of select pieces of equipment in the TSC and OSC. All were operabl However, a new terminal installed in the OSC to improve information flow was not operable, the licensee indicated that it would be fully functional by the 1986 emergency exercise. The average dose assessment computer availability for January 1986 to May 1986 was 92% with only one month below 90% (April at 78%). The inspector also noted that the five licensee EP staff. tour the facilities on,a montnly basis along with the routine testin .

All EPP and EPRIPs checked in the CR, TSC and OSC were current and com-plet .0 Emergency Facilities, Equipment, Instrumentation, and Supplies 4.1 Review The inspector held discussions with licensee personnel, visited the onsite emergency response facilities and verified the operability of select (quipment. This area was evaluated relative to commitments made in the Emergency Plan and ERPIP to determine:

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if key facilities and equipment are adequately maintained;

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changes in the program have been implemented; and,

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if changes have adversely affected the licensee's emergency preparedness progra Findings The inspectors witnessed part of the monthly surveillance test on notifi-cation and communication equipment, reviewed past monthly records and found that this equipment had been maintained and inoperable equipment replaced. The inspector also noted that the ISC computer terminal in the OSC had been installed as part of the corrective actions from previous finding _

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5.0 Organization and Management Control 5.1 Review The inspectors held discussions with senior licensee management, inter-viewed selected persons in the-emergency organization and reviewed the latest management staffing positions to determine:

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that changes made to the licensee management organization are reflected and/or incorporated in the emergency organization; and,

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the above changes have been properly incorporated into the Emerge,ncy Plan and implementing procedure .2 Findings The inspector noted that the licensee has recently effected organizational changes; however, as a matter of BG&E management policy individuals assigned to specific positions in the emergency organization keep their titles, responsibilities etc., until replaced. Two new positions were added: Communication Support Manager and Mechanical Maintenance ana Modification Support Manage The Communication Support Manager has authority and responsibility for coordination of all telecommunications activities previously under Admin-1strative Support. The Mechnical Maintenance and Modification Support Manager, and also the Meterologist position are also included in the Plan Section 3.0, " Organization" Attachment 4. However, their duties and responsibil-ities have not been included. All individuals assigned to the licensee's emergency organization need clearly defined responsibilities, duties and lines of authority. This item is unresolved (50-317/86-13-02; 50-318/86-13-02).

The licensee has made some changes to the Emergency Medical Assistance Program and has also incorporated the Letter of Agreement in the Emergency Response Pla One item of concern was identified in this are The staffing of the Emergency Planning Unit (EPU) has changed: One posi-tion, Emergency Planning Analyst (EPA) was lost; another position was downgraded; a supporting position - secretary - was abolished; and sce-nario development was transferred to the Training Unit.(TV). The EPU staff is now comprised of a Supervisor, two EPAs, one Emergency Planner, two Engineering Technicians (ETs) and a clerk. One EPA is responsible for off-site planning and works mostly with the State government of Marylan In addition, the licensee funds two Maryland State Emergency Planning position . .

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The ETs are responsible for emergency equipment surveillance and resolu-tion of drill and exercise problems. The EPU is responsible for off-site training and the TV for on-site training. The State of Maryland has sub-mitted, to the Chairman of FEMA Regional Assistance Committee III, a letter certifying the currency and adequacy of off-site training. EPU's off-site activities also extend to the three involved counties. There have been no changes in off-site agreements, understandings or relations except as noted belo The inspectors determined that on January 1, 1986 a re-organization became effective establishing two divisions having generation responsibility:

The divisions are the Nuclear Energy Division and the Fossil Energy Divi-sion. Each Division is headed by a Vice-President. The purpose of the re-organization was function alignment and limitation or reduction of the number of management levels between the work force and the executive level. Emergency Planning (EP) before the organization was a Unit and remained a Unit following re-organization. This is the fifth and lowest organization level. The Emergency Planning Unit (EPU) is headed by a Supervisor who reports to the Chief of the Quality Control Support Sec-tio .0 Training 6.1 Review / Findings The inspectors identified twelve (~2) Emergency Response Organization (ERO) positions, and the personnel currently requalified to fill these positions. Three individuals were selected to determine the degree of training and understanding of the Emeraency Plan (EP) and their roles. The ones chosen were: Recovery Manager; Shift Super-visor; and a Senior Reactor Operator. The oral discussions consisted of questions and hypothetical situations (micro-reactor accident scenarios).

The following observations were made: ERO responsibilities were under-stood; Emergency Action Level classifications were correct; required notifications were identified; and appropriate Emergency Response Plar Implementing Procedures (ERPIPs) were selected. In addition, during a control room walk through, cognizant staff identified and located instrumentation which will be used during an emergency to indicate, among other things, vessel water level, containment pressure and radiation intensity, hydrogen concentration and core outlet temperature. These individuals also discussed in detail the use to which this information would be put during an emergenc Based on these observations, the inspectors concluded-Emergency Response Organization (ERO) personnel have been properly trained and understand their emergency responsibilitie . _ _

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, The inspectors determined that drills and exercises are witnessed by l observer These coservers are drawn from the Quality Assurance '

Unit, various line knits and, at times, may also include consultants and staff members from other reactor utilitie Each drill and exer-cise is critique Thirteen drills and exercises have been held since 1980; one c arcise plus at least one drill is conducted annu-ally. As a result of observer reports, changes may be made to the Emergency Response Plan, (ERP), Emergency Response Plan Implementing Procedures (ERPIPs) and lesson Plans. If changes are made, they result in altered Revision Numbers and vertical lining in the right margin located opposite lines containing altered material. Changes require review and approval. Auditing procedures are described in greater detail witSin Section 7 below. The inspectors concluded it appears that a corrective action system for identifying deficiencies and weaknesses noted during drills and exercises is in place, and functional. Corrective actions are taken. Changes are documente . QA Audits of the Emergency Preparedness Program 7.1 Findings The inspectors determine that the Quality Assurance Support Section (QASS) annually reviews tne Emergency Preparedness Program (EP). A review of EP audit repor;s showed this function has been audited every year since 1980 with the exception of 198 The 1981 and 1982 audits findings were combined in a single report. The 1986 audit was in progress during the inspectio Following analysis of the EP audits and inspection activities, the inspectors concluded that:

(a) Drills and exercises are observed by auditors; (b) State and County officials are contacted to determine interface adequacy; (c) The Emergency Plan, Emergency Plan response implementing pro-cedures, lesson plans, facilities and equipment and training records have been audited; (d) Audit reports are sent to EP for their acceptance of findings and recommendations. If acceptance is not obtained, the issue (s) must be resolved by upper management within a specified period of tim (e) All audit reports are forwarded through four levels of manage-

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ment until they reach the V.P. for Nuclear Generation, who is responsible for resolving all disputed findings and recommend-ation (f) Appropriate state and local government officials are informed in writing of the results of any audits which concerns off-site

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interface.

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(g) Records have been retained since 198 Based on these findings, the inspectors concluded that: the EP program is reviewed annually by reviewers who have no direct responsibility for EP; state and local government interfaces are reviewed and government advised of the results; drills, exer-cises, capabilities and procedures are reviewed; results are documented and reported to plant and corporate management; and records are retained for a period of five year .0 Exit The inspectors met witt licensee personnel indicated in Section 1 of this report and preserted the findings and recommendations noted. Staff members acknowledged the findings and recommendations and agreed to consider these items for corrective action At no time during the inspection was written material provided to the license .

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