IR 05000219/1988006

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-219/88-06.Request for Withdrawal of Violation Re Audits of Emergency Program Unjustified.Response Required within 30 Days

ML20207J093
Person / Time
Site:	Oyster Creek
Issue date:	08/18/1988
From:	Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Fitzpatrick E GENERAL PUBLIC UTILITIES CORP.
Shared Package
ML20207J096	List: IR 05000219/1988006 ML20207J301 ML20207J307
References
NUDOCS 8808300226
Download: ML20207J093 (7)

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et AUG 181968 Docket No. 50-219 GPU Nuclear Corporation.

ATTN: Mr. Eugene E. Fitzpatrick Vice President and Director Oyster Creek Nuclear Generating Station P. O. Box 388 Forked River, NJ 08731 Gentlemen: Subject: Inspection No. 50-219/88-06 This refers to your letter dated June 1,1988 in response to our letter. dated May 3, 1988.

I Thank you for informing us of the corrective and preventive actions documented in your letter. In your letter, you requested withdrawal of the violation pertaining to audits of your emergency preparedness program annually as re-quired by 10 CFR 50.54(t) (50-219/88-06-02). Your response is insufficient to warrant withdrawal of the violation. The brief statements contained in Audit Report S-0C-87-01, attesting to the adequacy of state and local interface, do not appear to be sufficient justification that a detailed audit as required by your QA Plan and 10 CFR 50.54(t) was conducted.

You'are required to respond to the violation as stated in our May 8, 1988 letter within 30 days of the date of this letter. Your cooperation with us is 1 appreciated.

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Sincerely, Original Sisnod By: 8808300226 880818 ' DR ADOCK 0500 9 Stewart D. Ebneter, Director Division of Radiation Safety

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and Safeguards i cc w/enci M. Laggart, BWR Licensing Manager  ; Licensing Manager, Oyster Creek l Public Document Room (POR) i Local Public Document Room (LPDR) Nuclear Safety Information Center (NSIC) NRC Resident Inspector State of New Jersey 0FFICIAL RECORD COPY RL GPU 88 06 - 0001.0.0 l 08/02/88 i VV I!/ L ,

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GPU Nuclear Corporation '2.

bec w/ enc 1: Region I Docket Room-(with concurrences):

~ManagementAssistant,DRMA(w/oencl) .

Section Chief, DRP Robert J. Bores, DRSS

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u RI:DRSS RI$ dlDRSS : SS R S :DRSS- I r Fox Christopher Lazarus Bellamy Ebneter 7//T/88 7//{/88 7// h88 g/k/88 8/lf/88 7//f/88 0FFICIAL RECORD COPY RL GPU 88-06 - 0002.0.0 07/15/88

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Nuclear  :: g = r 3ee Forked River,New Jersey 087310388 l j 609 971-4000  ! Writers Direct Dial Number: l June 1, 1988 l Mr. Ronald R. Bellarny Facilities Radiological Safety and Safeguards Branch Division of Radiation Safety and Safeguards U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406

Dear Mr. Bellamy:

Subject: Oyster Creek Nuclear Generating Station Docket No. 50-219 Inspection Report 88-06 Response to Notice of Violation As directed by the subject inspection report dated May 3,1988, Attachment I provides our response to the Notice of Violation and our request for withdrawal of same.

Should you require any further information, please contact Brenda DeMerchant, Oyster Creek l.icensing Engineer at (609)971-4642.

Very truly yours, E. E. Fit trick Vice President and Director Oyster Creek EEF/BD/dmd (0501A) cc: Mr. William T. Russell, Administrator Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. Alexander W. Dromerick, Project Manager l U.S. Nuclear Regulatory Commission i

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Division of Reactor Projects I/II Washington, DC 20555 i NRC Resident Inspector ,m , ef ! Oyster Creek Nuclear Generating Station M+, W / J ^ ' GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation

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Attachment I - l l l-Violation: Title 10, Code of Federal Regulations, Part 50.54(t) requires licensees I who are authorized to operate a nuclear power facility to provide for a  ! review of its emergency preparedness program at least every 12 months.  ! This review shall include an evaluation of the adequacy of interfaces with State and Local Governments.

Contrary to the above, GPU Nuclear Corporation (GPUN) failed to evaluate the adequacy of the interface with the State of New Jersey. l Response:

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During the subject inspection of Oyster Creek Audit Report S-0C-87-01, the section titled, "Offsite Interface" Section H, was apparently the area concentrated on to determine compliance regarding the interface with the State of New Jersey.  : i Subsequent to the NRC Inspection the audit report was reviewed with the ' Lead Auditor who had been absent during the time of the inspection. The review confirmed that the scope of audit coverage in the area of question was adequate to satisfy 10CFR50.54(t) requirements. The auditor had chosen to assess the station's compliance with the code of Federal Regulations, Part 50.54(t), by using an evaluation of a real event.

Evaluation of this event may be found on page 13 of the audit report, Section G, "Drills, Exercises, and Events".

GPUN therefore, does not concur with the Notice of Violation cited in l Appendix A of inspection report dated May 3,1988 and requests that it be withdrawn.

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-( . LICENSING ACTION 1 TEM Notify Licensing within 3 working days if: ,

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0YSTER CREEK l

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10 pen Item fl action is inappro- l (Refer to LP-002) priately assigned

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l l unable to meet due date l l l Al NUMBER l l ASSIGNED DEPT. l l DATE OF REQ. l l DUE DATE l ! I I I l I I I I l l 88038.01 l I 0A-0C AUDiis l l 5/12/88 I I 5/25/99 l REFERENCE PERTINENT DOCUMENTS: INSPECTION REPORT 88-06 DESCRIPTION OF ASSIGNMENT: The referenced insoection recort contains a nntico nf viniatinn fn r an item in your area of resoonsibilitv. Provido l icencinn with a resoonse to this violation. addressino tho 4 items rennected in the last caraaraoh of Accendix A to the attached rennet. which will he submitted by l_icensino to the NRC by ,1une 9.14RR

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ACTION ITEM RESPONSIBILITY l RETURN l PRIMARY D. MacFarlane l COMPLETED FORM I l hI & LpNSINGMANAGER I TO OC LICENSING l l l Nku 1A 11a V398 SECONDARY l l Ext.

LICENJINGCONTACT DESCRIPTION OF COMPLETED ACTION OR LIST OF ATTACHMENTS j l l l l ACTION COMPLETE REVIEWED & APPROVED RESPONSIBLE INDIVIDUAL RESPONS18Li MANAGER DATE: DATE:

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'    UNITED STATES
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..... MW o 3 ggg License No. OPR-16 Occket No. 50-219 GPU Nuclear Corporation ATTN: Mr. E. E. FitzPatrick Vice President and Director Oyster Creek Nuclear Generating Station P. O. Box 388 Forked River, NJ 08731-0388 Gentlemen:

Subject: Inspection No. 50-219/88-06 This refers to the routine safety inspection of activities authorized by NRC License No. OPR-16 conducted by Mr. C. Amato and other inspectors of this office on February 22-26, 1988 at the Oyster Creek Nuclear Electric Generating Station, Forked River, New Jersey, and to discussion of these findings by Mr. Amato with you at the conclusion of the inspection.

The areas examined during this inspection are described in the NRC Region I report which is enclosed with this letter. Within these areas, the inspection consisted of selective examination of procedures and representative records, interviews with personnel and observations by the inspectors.

Within the scope of the inspection, it appears that certain of your activities l were not conducted in full compliance with NRC requirements, as set forth in I the Notice of Violation enclosed with this letter as Appendix A. Yoc are required to respond to this Notice of Violation within thirty days - the date of this letter, l The response directed by this letter and the accompanying Notice of Violation ) is not subect to the clearance procedures of the Office of Management and  ; Budget as required by the Paperwork Reduction Act of 1980, PL 96-511. j Your cooperation with us in this matter is appreciated.

Sincerely, j l I l

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Ronald R. Bellamy, Ph.D., Chief Facilities Radiological Safety and Safeguards Branch Division of Radiation Safety and Safeguards -

Enclosure:

NRC Region 1 Inspection Report No. 50-219/88-06 DM

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GPU Nuclear Corporation- 2 MAY 0 3 M6S

REGION I== Report No. 50-219/88-06 Docket No. 50-219 License No. OPR-16 Friority -- Category C !

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Licensee: GPU Nuclear Corporation P. O. Box 388 I Forked River, New Jersey 08731-0388 Facility Name: Oyster Creek Nuclear Generating Station l

Inspection At: Forked River, New Jersey Inspection Conducted: February 22-26, 1988 Ir.spectors: h C.G.Amago,EmergencyPreparedness date J f /fW Specialist, EPS, FRSSB, DRSS [[ E. F. Fox, Sr., EPS, EPS, FRSSB, DRSS R. K. Christopher, EPS, FRSSB, DRSS Approved by: ul^ac k =A9 [ W. J . elariru s(_Jhi e f date Emergency Preparedness Section FRSSB, DRSS Inspection Summary: Inspection on February 22-26, 1988 (Report No.

.,50-219/88-06)

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's " " , Areas Inspected: Routine, announced inspection of emergency preparedness activities including: Emergency Plans and Implementing Procedures; Emergency

. Facilities, Equipment, Instrumentation and Supplies; Organization and Management

, Control; Independent Reviews / Audits; application of NRC Inspection and Enforce- I ment Division Information Notices Nos. 83-28 and 84-80; Emergency Operation Procedures - Emergency Plan Implementing Procedure interface; software for backup dose projections program; Plant Engineer Training; Emergency Preparedness Training; operation of the Parsippany Technical Functions Center; and Security- , Emergency Preparedness Interface.

' Results: One violation was identified, (failure to evaluate for adequacy the State interface) two outstanding, nor, exercise-related inspector follow-up items were closed, and five were opened.

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l OETAILS l 1.0 Persons Contacted j

 *J. Barton, Deputy Director - Oyster Creek G. Bond, Director, Systems Engineering, Technical Functions '

i Division, GPUNC - Parsippany

 *J. Bontempo, Lead Emergency Planner, GPUNC - Oyster Creek  .

P. Clark, President, GPUNC j

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R. Coe, Director, Training and Education - GPUNC G. Cropper, Senior Reactor Operator - Oyster Creek E. Demonch, Group Shift Supervisor - Oyster Creek

 *B. DeMerchant, Licensing Engineer, GPUNC - Oyster Creek
 *M. Douches, Lead Monitor Operations, Quality Assurance R. Ewart, Security Lieutenant, GPUNC - Oyster Creek
 *P. Fiedler, Vice President and Director, Oyster Creek S. Kempf, Jr., Emergency Offsite Planner, GPUNC - Oyster Creek J. Kowalski, Site Licensing Manager, GPUNC - Oyster. Creek H. Lapp, Manager, Plant Training, Training and Education Division, GPUNC - Oyster Creek A. Lindberg, Manager, Southern Districa, JCP&L Co.

• 0. MacFarlane, Manager, Site Audits, GPUNC - Oyster Creek S. Parsons, Manager, Corporate Training - Parsippany S. Polon, Manager, Public Information, GPUNC - Oyster Creek A. Rone, Director, Plant Engineering, Oyster Creek M. Roche, Vice President and Director, Quality and Radiation Controls - GPUNC j J. Rogers, Licensing, GPUNC - Oyster Creek C. Ruth, Operations, Quality Assurance J. Seve11e, Security Sergeant, GPUNC - Oyster Creek

 *J. Sullivan, Director, Plant Operations, Oyster Creek
 *R. Sullivan, Emergency Preparedness Manager, GPUNC - Oyster Creek S. Surgeoner, Manager, Public Relations, GPUNC - Oyster Creek
 *M. Slobodien, Director, Radiological Controls, GPUNC - Oyster Creek
 *P. Thompson, QA Audits, GPUNC - Oyster Creek  j
 *I. Wazzan, Emergency Planner, GPUNC - Oyster Creek

 *J. Williams, Mana' g er, Support Program Training, Plant Training, Training and Education Department, GPUNC - Oyster Creek T. Wilson, Vice President and Director, Technical Functions -

Parsippany

 *K. Wolf, Manager, Radiological Engineering, GPUNC - Oyster Creek The inspectors also observed the actions of, and interviewed, other licensee personnel.

• Denotes those present at the exit interview.

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2.0 Operational Status of the Emergency Preparedness Program 2.1 Corporate Emergency Plan The GPU Nuclear Corporation Plan for Three Mile Island and Oyster Creek Nuclear Station has been revised (Revision 1) and submitted to the NRC. The equipment lists in those sections of Revision 1 relating to Emergency Response Facilities and Equipment at Oyster Creek were checked against facilities, equipment, communications i systems and monitors. The facilities, equipment, communications and monitors were d:termined by the inspector to be in agreement with the i description. Comments on the Revision are being provided separately. ! 2.2 Emergency Plan Imolementing Procedures (EPIP) a. EPIPs at Emergency Response Facilities (ERFs) were verified to be current and appropriately reviewed. A review of the EPIPs indicates changes made since the last inspection have not affected the overall state of emergency preparedness. EPIPs were distributed and reviewed in accordance with GPU procedures.

Based on this review, this area is' acceptable.

2.3 Emergency Facilities, Equipment, Instrumentation and Supplies EPIPs, equipment, instruments, communications equipment and supplies stored or maintained in the Emergency Command Center, Technical Support Center, Operations Support Center, Emergency Operations Facility, Environmental Assessment Command Center and the off-site monitoring team assembly area were reviewed. Equipment and supplies j matched inventory lists, EPIPs were current, and with one exception, ' which was promptly corrected, instruments were within their calibration period and operable.

Based upon the above review, this area is acceptable, l 2.3 Organization and Management Control a. GPU Nuckear Corporation (GPUNC) is one of the five subsidiaries of the GPU System. GPUNC is the Oyster Creek operator. The i site organizational structure is divided between line (operations) and staff (support). Operations reports to the Vice President and Director - Oyster Creek, while support units report to GPUNC headquarters in Parsippany, NJ. Of the sixteen 1 units identified at Oyster Creek by the inspectors, seven are ' i operations related reporting to the Vice-President Oyster Creek, while nine report to headquarters. Seven of the nine support units are involved in site Emergency Preparedness, as are a

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large percentage of the Initial and Support Response Organiza-tion staffs. Included in this group are: the Emergency Pre-paredness Program; Training and Education; Radiation Controls; Communication (including Public.Information); Security; Site Audits; and Environmental Controls. A review of the current call-out roster indicated that five of the six qualified Emergency Directors and Emergency Support Directors report to l Operations. l l

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b. Effective June 1, 1987, Emergency Preparedness was transferred from the Nuclear Assurance Division of GPUNC to the Quality and Radiation Control Division (Q&RC), headed by the Vice President i and Director for Q&RC. However, the Corporate Manager for l Emergency Preparedness no longer reports directly to the Vice President, Q&RC, but rather to the Director, Emergency Prepared-ness and Environment, Q&RC. This reorganization eliminates direct contact by the Corporate Emergency Preparedness Manager with a Corporate Officer and alters the status of the site Emergency Preparedness manager to that of fifth level manager.

Consultants responsible for off-site planning have been replaced by an experienced emergency responder with an active history in Ocean County. An Emergency Preparedness Program vacancy has been filled by a nuclear engineer.

c. The inspectors interviewed the President of GPUNC and two Vice Presidents. The President estimated from five to ten percent of his time is devoted to Emergency Preparedness. He maintains qualification as an Emergency Support Director. The GPUNC , President displayed a strong working knowledge of Emergency l Preparedness issues, required action (s) and additionally, tracks ' corrective actions. He also maintains an on going high level interface with Commonwealth of Pennsylvania and State of New Jersey officials. The Vice President and Ofrector Quality Radiation Control tracks Emergency Preparedness on a daily basis l and conducts monthly reviews. He showed extensive current l knowledge of Emergency Preparedness operations and problems.

The inspectors concluded that corporate restructuring has not I adversely affected the status of emergency preparedness I readiness. Corporate officers are active in Emergency  ; Preparedness, are aware of and track problems and issues.

Based upon the abeve review, this item is acceptable.

2.4 Training a. Emergency Preparedness training is provided, in selected areas by the Training and Education Department (TED). TED staff numbers l about 100 GPU system-wide with 49 assigned to Oyster Creek. Two

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hundred and eighty (280) Oyster Creek site personnel are cur-rently qualified for one or more of the 58 Emergency Response Organization (ERO) staff positions. This figure includes: members of the On-Shift Initial Response Organizations (IR0s) who staff on-site Emergency Response Facilities; and members of the Emergency Support Organization (who staff the Emergency Operations Facility and the Parsippany Technical Functions Center). The Corporate Manager for Emergency Preparedness trains and requalifies Corporate officers. Plant Training has completed a job task analysis for ERO positions and maintains a hard copy and computerized database of training records. The database is currently undergoing modification which involves a transition between two systems and GPU's Reading, Pennsylvania computer staff. As a result, the inspectors noted inconsisten-cies and encountered difficulty in tracking requalifications.

A check of hard copy records verified the accuracy of training data. Plant Training may acquire the training record tracking software of another licensee.

b. Technical staff and management training is provided in ten weeks of training over a two-year period on a modular basis. The course titles and sequences were checked by the inspectors and discussed with the TED staff. This sequence does not include training for engineers assigned to the Technical Support Center (TSC) and Parsipanny Technical Functions Center (PTFC) in severe accident analysis,. The Plant Engineering Department provides four hours of training in Core Damage Assessment (CDA). Various GPU staff members, when questioned by the inspectors about the adequacy of training in this area, responded that the engineer's I academic training is adequate and the Emergency Operations j Procedures (EOPs) will take an operator from an entry event to , core melt. TSC engineers are trained in TSC operations. Core engineers in the TSC receive the CDA training.

c. The GPU Corporate Emergency Plan (1000-PLN-1300.01, Rev 00) states in Section 8.1.2 that one of the purposes of drills is verification of the emergency preparedness of all personnel. i Oyster Creek Administrative Procedure 9473-A0M-1300.01, Rev 5, l Section 5.3.5 states that drill attendance should be recorded. 1 After the inspectors noted the fact drill attendance was not recorded, the licensee's staff agreed to record such attendance in the future. In addition, the inspectors noted one senior ERO manager had not been drilled in a year. The licensee agreed to schedule this individual for drill (s).

d. The Plant Training staff assists in drill and exercise scenario I development, observes drills and exercises and participates in debriefings.

c. A check of EP training written requests and follow-up verbal requests for rescheduling indicated a large number of repeated j l i

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. requests, rescheduling and EP training sessions. Attitude,. quality of training,, perception of the importance of EP Training and priorities were discussed as possible causes. A definitive cause was not identified.

f. Senior operators receive Emergency Director training. When on.

the simulator and responding to an incident scenario, operators are evaluated as to their ability to go from the Emergency-Operations Procedures to event classification, emergency notifi-

  - cations and call-in of the Initial Response Organization.

The inspectors determined that adequate resources have been committed to Emergency Preparedness' training. Lessons plans are. current. Hard copy training records are adequate, but the computerized data base is i

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not yet fully functional. Training of engineers assigned to the TSC is limited to CDA, an. unidentified cause persists resulting in repeated training requests, drill attendance records are not maintained for key staff members, reactor operators are trained in event classification and emergency communications, and 280 staff members are qualified in Emergency Preparedness.

' l With the exception of improvements to the computerized training record system, repeated EP training scheduling, limited TSC engineer training, and drill attendance records the inspectors concluded an adequate training program is in place. The exceptions are inspector follow-up items (50-219/88-06-01) subject to future inspections.

d 2.5 Independent Reviews / Audits The inspector interviewed licensee personnel and reviewed Quality Assurance (QA) audit S-0C-87-01 and determined that the internal review / audit of the emergency preparedness program had been done within 12 calendar months. It was ascertained _that management does review and support QA determinations and that commitments are made and corrective actions are timely and technically adequate. With regard to QA audit scope and depth, it was determined that audit

report S-0C-87-01 did address the offsite interface. However, only the local government interface was addressed and the State interface was not evaluated.

' 10 CFR 50.54(t) requires licensees to review their emergency preparedness plan at least once every 12 months. This review shall include an evaluation for adequacy of interfaces with State and Local ' governments. Contrary to this requirement, an evaluation for adequacy of the State interface was not audited. This is a violation (50-219/88-06-02).

Exercise / drill reports and audit records were reviewed; emergency preparedness personnel were interviewed and it was determined that .

• the licensee has an adequate corrective action system for deficiencies and weaknesses identified during drills and exercises.

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Interviews with corporate management indicates that management does review and support, as well as follow through on resolution and correction of deficiencies and weaknesses in a timely manner.

Based on these observations, the inspectors concluded that with the exception of the State interface adequacy evaluation, the requirements of 10 CFR 50.54(t) were met.

2.6 Security / Emergency Preparedness Interface The inspector interviewed both Security and Operations licensee personnel and reviewed procedures to determine if a security / emergency preparedness interface is present. NUREC/CR-4093, ;

 "Safety / Safeguards Interactions During Safety-Related Emergencies at i Nuclear Power Reactor Facilities," was used as a basis for this !

portion of the inspection. It was determined that a triggering mechanism to alert both operators and security personnel to sabotage ' is in place. Guidelines are present for the security of other. safety systems, and procedures specifying counter measures to consider have been developed.

It was noted that raciological protection equipment is not available to security forces at the main gate. The licensee stated that should a radiological emergent- occur and affect that area, these guards would be evacuated. Sr,9rity forces sent to assist in the evacuation i of on-site personnel alsc would not have radiological equipment if a radiological emergency weie to occur at their post. Another area of

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concern is there appears t' be no rapid way for these guards to put - on protective clothing sh,u'd their scarch pattern require them to I enter into a radiation area. Finally, the Main and North gates are not shielded or provided with filter ventilation for protection j against radiation. The Central and Secondary Alarm Center are located within the Main Gate building. In the event of an evacuation of this facility, an alternate access point is needed. There is no provision for such an alternate.

The licensee is reviewing this area for possible improvements.

' This will be reviewed during a future inspection. (50-219/88-06-03) ; 2.7 Public Information Program The inspector reviewed "Emergency Information for Neighbors of the Oyster Creek Nuclear Generation Station and for Visitors in Ocean County" dated April, 1987, and determined that this brochure was in the process of being updated and distributed to the public. It was

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further determined, through interviews, that the material had been coordinated with and' concurred in by offsite authorities.

Additionally, FEMA had acknowledged receipt of the brochure from the State of New Jersey. It was verified that the local telephone directory and the brochure contain the requisite information required in 10 CFR 50.47(b)(7), Appendix E, Part IV,D.2 and NUREG 0654, Planning Standard G. Signs which provide emergency information for transients ue posted along routes which they would use. A phone number is provided in both the brochure and phone directory for the public to acquire additional information.

In addition to providing an information brochure to the public, the licensee has provided, quarterly, a news letter entitled "0yster l Creek Neighborhood Update" to the public which provides a reinforce-ment of previously provided emergency prepa. iness information to 1 include Offsite emergency preparedness. It a so provides additional , information on plant status as well as human interest stories. l Based upon the above review, this area is acceptable.

2.9 Emergency Operating procedures (E0ps) l The E0Ps were upgraded and became effective January 1988. They are in flow chart format. One set will be laminated and kept in the control room. There are four, color coded sets covering the reactor vessel; primary containment; secondary containment (the reactor butiding); and release to the environment. The E0Ps contain

"prompts" referring operators to the appropriate emergency classification in Exhibit 1 to EPIP 9430-IMP-1300.01, Rev. 4,
"Classification of Emergency Conditions." Reactor operators were trained and knowledgeable in E0P-Emergency Plan Implementing Procedure interface.

Based on the above, this area is acceptable.

2.10 Dosimetry a. The iiispectors re 'iewed the Oyster Creek Emergency Dose Manual (9300-A0M-4010.3, Rev. 0) and discussed calculation of projected doses and dose ceamitments with Radiation Control staff. Cal-culations are mide using one of three computer systems: MIDAS; the Radiologic &l Assessment Computer Program (called RAC) and the Back-up Dasimetry Program (BUD). The IAst two programs are run on personal computers and may be used in any Emergency Response Facility as long as input data is available. A MIDAS intelligent terminal is available only in the Emergency Opera-tions Facility when the Environmental Accident Assessment Center is functional. Projected thyroid dose commitment calculations requires measured iodine release rates or, in absence of these, a partition of a gross release rate into noble gas and iodine components using measured or default iodine to noble gas ratios.

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At Oyster Creek the stack release is measured end reported as a count rate which is converted to a gross activity release rate using a calibration factor. Until a sample of the release can be obtained and analyzed, a conservative iodine to noble gas ratio would be used following procedures in the Emergency Dose Manual resulting in over-estimates of projected thyroid dose commitment, b. The actual iodine to noble gas ratio can be obtained from analysis of silver zeolite cartridge located in a sampling point for the stack. This point is within a room at the sta:ks base and the collection point is a component of the Radioactive Gas Effluent Monitoring System (RAGEMS). Under severe accident conditions the dose rate in the RAGEMS room might preclude entry or restrict access time to a value which might preclude successful sample collection assuming the Emergency Director would authorize an informed volunteer to collect the sample by approving an emergency worker dose limit. Cpu recognizes these problems and has completed a time and motion study with respect to collection of a RAGEMS sample, posting administrative limits for the RAGEMS room and providing RAOCON support for the Chemistry Technician collecting the sample, c. The NRC has addressed the problem of over-estimating calculated doses in IE Information Notice 85-52, noting that such values could lead to confusion, delay protective action or lead to unnecessary protective action. The licensee's Radiation Control staff acknowledged the problem and that stated sters would be taken to correct the default rates to a realistic value, but no timetable was given for completing the corrective action.

This will be reviewed during a future inspection.

(50-219/88-06-04) 2.11 Field Sampling The volume. collected for iodine analysis by on and off-site monito - ing teams wat reviewed by the inspectors with the staff of Environmental Controls. It was agreed, that a volume of one cubic foot was sufficient if the sample were to be analyzet by a Ge-Li or NaI detector. However, such agreement could not be reached for off-site sampling when a field analysis using a Distenfeld Collector and a G-M tube. The licensee agreed to reeiew this matter and compute the minimum sample volume needed for a specified statistical performance specification. The licensee acknowledged collection of an excessive sample was not consistent with dose minimization practices and reduces the time available for field teams to undertake additional field measurema,its.

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This item will be subject to future inspection. (50-219/88-06-05) 3.0 Exit Meeting

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The inspectors met with licensee personnel listed in Section 1 at the conclusion of the inspection. The licensee.was informed that one viola-tion was identified. The inspectors also discussed areas for improvement.

The' licensee acknowledged these finding and agreed to evaluate them, institute corrective action as necessary and include needed corrections in the Consolidated Plan and Implementing Procedures. At no time during the course of the inspection did the inspectors give the licensee written material, l I

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EHERGENCY RREPAREDNESS

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S -0C-87-01 Distribution: P.R. Clark, President R. Heward, Director, Maintenance, Construction and Facilities R.L. Long, Director, Planning and Nuclear Safety I.R. Finfrock, Jr. , Chairman GORB R.W. Keaton, Director Quality Assurance M.J. Slobodien, Radiological Controls Director, Oyster Creek R. Whitesel, Nuclear Safety Assessment Director D. Cafaro, Manager Environmental Controls, Oyster Creek R. Fenton, Manager Plant Training, Oyster Creek E. Growney, Manager Safety Review, Oyster Creek K.O.E. Fickeissen, Manager Nuclear Safety G. Giangi, Manager Emergency Preparedness R.S. Markowski, Manager Progrsm Development / Audit R. Fenti, Manager Mod / Ops QA, Oyster Creek R.L. Sullivan, Emergency Preparedness Manager

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Audit File: S-0C-87-01 DCC File No. 20.0002.0011.006.06 .

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Oyster Creek Audit S-0C-87-01 Date: June 26, 1987 g Emergency Preparedness 0.C. Site Audit Kinager Location: Gyster Creek From: D. MacFarlane Deputy Director, Oyster Creek Division To: J. J. Barton The attached audit report is forwarded for your review. 'Ihi s audit assessed the definition and implementation of the Emergency Preparedness Program at Oyster Creek.

Two audit findings and one Quality Deficiency Report were issued and are included as Attachment I. A preliminary review of these noncompliances indicate that they were not re por table . Initial responses to these noncompliances have bec - received and are being evaluated by the audit staff.

Two recommendations have also been made as a result of this audit sud are included as Attachment II. Quality Assurance does not require a response to these recommendations. However, GPUN corporate policy requires that an internal division / department memorandum documenting your disposition of these recommendations be written to file.

In accordance with Oyster 4l reek rechnical specifications, Section 6.5.2, an Independent Safety Review of this audi* is required and must be performed by the Quality and Radiological Controls Division. A memorandum requesting this review and a copy of this report will be forwarded to the appropriate safety review coordinator to arrange for performance of this review.

If there are acy questions concerning this audit, please contact the Site Audit office at extension 4150.

N be D. MacFarlane O.C. Site Audit Manager DM/lga 1732R/24 A0000648 8 83

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Nuclear Memorandum

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Oyster Creek Audit S-0C-87-01 June 26, 1987 Subject: Date: Faergency Preparedness 0.C. Site Audit Manager Location: Oyster Creek From: D. MacFarlane To: Director, Quality and Radiological Controls M. B. Roche lhe att' ached audit report is forwarded for your review. This audit assessed the definition and implementation of the Emergency Preparedness Program at Oyster Creek.

Two audit findings and one Quality Deficiency Report were ist.c ed and are included as Attachment I. A preliminary review of these noacompliances indicate that they were not reportable. Initial responses to these noncompliances have been received and are being evaluated by the audit staff.

Two recommendations have also been made as a result of this audit and are included as Attachment II. Quality Assurance does not require a response to these recommendations. However, GPUN corporate policy requires that an internal division / department memorandum documenting your disposition of these recommendations be written to file.

In accordance with Oyster Creek Technical Specifications, Section 6.5.2, an Independent Safety Review of this audit is required and must be performe.d by the Quality and Radiological Controls Division. A memorandum requesting this review and a copy of this report will be forwarded to the appropriate safety review coordinator to arrange for performance of this review.

If there are any questions concerning this audit, please contact the Site Audit office at extension 4150.

k !l44' '_.

D. HacFarlane O.C. Site Audit Manager j DM/lga 1732R/23

l l A0000648 8 83 i

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I t.. TABLE OF CONTENTS d S-0C-87-01

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EMERGENCY PREPARE 0 NESS PAGE l I. Summati0n..............................................................l I I . De tai l e d Di sc u s si o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 A . O r ga n i z a ti o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 B. Program Adequacy................................................... 3 C. Training...........................................................4 D . F ac i l i t i e s a nd E qu i p me nt . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

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E . N o t i f i c a ti o n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

i F . Ac ti va ti o n a nd A s se s sme n t. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

G. Drill s , Acti vi ties a nd Events. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 H . O f f si te I n te r f ac e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 . Attachment I - Findings Attachment II - Recomendations ' Attachment III - Referenca Document List Attachment IV - Audit Attendees l

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