IR 05000443/1986018
| ML20236C474 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/10/1989 |
| From: | Chan E NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | Fierce A MASSACHUSETTS, COMMONWEALTH OF |
| References | |
| CON-#189-8268 OL, NUDOCS 8903220172 | |
| Download: ML20236C474 (35) | |
Text
_ - . ._ _ _ _ . - _ - _ _ - _ . _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _
.o
.
gEJAIED C.ORHESPONDEN95
- [$a ns
- g%,
,
UNITED STATES 73g39 ie ! o NUCLEAR REGULATORY COMMISSION U%C
{' r,, a WASHINGTON, D. C. 20666
% *see* / '89 tiAR 13 A10:54 March.10, 1989 l CrHcL v ;-r :G '
l DCCK! W. 4 :Erv M I BFAkLH j t
Allan Fierce, Esq.
Assistant Attorney General One Ashburton Place,19th Floor Boston, MA 02108 In the Matter of PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE, ET AL.
(Seabrook Station, Units 1 and 2)
Docket Nos. 50-443, 50-444 Off-Site Emergency Planning -8d
Dear Allan:
This note confirms our telephone discussion regarding NRC Inspection Report 86-18. Although IR 86-18 is not responsive to any of the Mass AG's informal interr-)gatories. I telecopied the relevant pages to you today and I am providing you with a complete copy because it contains a previous NRC evaluation of METPAC procedures.
Yours truly, r
(AAI Elaine I. Chan
. Counsel for NRC Staff Enclosure as stated cc: Service List w/ enclosure 8903220172BN$h43 ADOCK O PDR PDR G
01 '
_ _ _ _ . _ _ _ _ - . _ _ - _ _ _ _ _ - , _ _ _ _ _ _ - - - _ - - - _ _ _ _ . _. _ ._ .__ .-_ _
... _ , , . . . . . .
k -
-
y ..
.0. ,
g.
MAY 151986 Docket Nos. 50-443 Public Service of New Haripshire ATTN: Mr. Rob..rt J. Harrison President and Chief Executive Officer P, 0, Box 330 Manchester, New Hampshire 03105 Gentlemen:
Subject: Inspection Report No. 50-443/86-18 This report forwards the findings of the Emergency Plan Implementation Appraisal, which was conducted March 24-28, 1986, by Mr. W. Lazarus and others.
of this office at Seabrook Nuclear Power Station, Seabrook, New Hampshire.
Areas examined during this inspection are described in tho NR*. Region !
Ins;xction Report enclosed with this letter. This appraisal consistea of sol,$ctive examinations of procedures, representative records, facilities and e pipw nt,. interviews with personnel, and observations of the inspectors.
Witnin the scope of this inspection, no violations were identified and no response to this letter is necessary. Items requiring corrective actions are categorized.in detail 6 of this report, as to whether they must be completed prior to fuel load or full-power Itcense.
Your cooperation with us in this matter is appreciated.
Sincerely,
. . .. ; . .. ,
' N 'i T
,
. . , .i n , ector (L')tt ,Q'
Division of Radiation Safety and-Safeguards
- Enclosure; NRC Region i Inspection Report No. 50-443/86-18 y .s' /
8605280023 860515 3 py -ADOCK 0500 0FflCIAL REC 040 COPY IR SEA 1 86-18 - 0001.0.0 - ,,
05/14/86
'TG h iII
- _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
' - -- - - - - - - . - - - - - - _ _ _ _ _ _ _ _ ___ _ _ _ _ _ _
, ,
_
go m
' j
.
Public Service'of New Hampshire '
L1 1;
CC w/ encl.:
John DeVincentis, Director,' Engineering and Licensing
~
' William B. Derrickson, Senior Vice President Warren Hall.,0perational Services Supervisor Donald'F, Moody, Station Manager - Seabrook Station
.
Gerald F. Mcdonald, Construction QA Manager l Public Document Room (POR)
Local Public.0ccument Room (LPOR)
Nuclear Safety Information Center (NSIC)
NRC Resident inspector State of New Hampshire bcc w/ encl:
Region i Docket Room (with concurrences)
Management Assistant. DRMA (w/o encl)
ORP Section Cntef FEMA R1
.
RI:0RSS R1:0R$ O tY
La:arus/ p/geb Thomas P [.,(,hg (
S//f/86 S//486 , gg'j
,l'
0FFICIAL RECORD COPY 1R SEA 1 86-18 - 0301.1.0 05/14/86
- - - - - - - - - _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _
- _ _ - _ _ _ _ -
,
'
.
U.S. NUCLEAR REGULAR 0RY COMMISSION
REGION I
Report No. 50-444/86-18 Docket No. 50-443 Priority Category B ,1 License No. CPPR-g Licensee: Public Service of New Hampshire PT O. Box 330 Manchester,NewHamplhire 63'105 Facility Name: Seabrook Unit 1 Inspection At: Stabrook. New Hamp,shlre inspection Conducted: March 24-28, 1986 s
,
Inspectors: -
' _
j' A k, nior EP Special_ist date w. g rus, l
W. Thomas EP Specialist C. Amato. EF Specialist C. Gordon, EP Specialist J. Hawshurst, EP Specialist ^
-
G. Bryan, COMEX Corporation G. Wehmann, Battelle PNL Approved by:
d.
~
rus, . ting Chief, ETnergency JI'rit..
cate
Preparedness Section
' [nsgettion Su nman: Inspection on March 24-28, 1986 ,(R_egort No. 86-18)
Areas Inspecte_d: Emergency Preparedness Implementation Appraisal to evaluate the aceQuacy and effectiveness of the emergency preparedness program for Seabrook Unit 1, including organization, administration, procedures, training and facilities and equipment, o
Results: No violations were identified. Several program areas were icentified which are incomplete or require corrective action, these are listed as open items, and will need to be adcressed by the licensee and reinspected in a sub-secuent inspection. Paragraph 6 of this report provides a summary listing of these items along with the determination of whether the item is required to be corrected prior to issuance of the low power license or the full power license.
l l ,.e
~
l e605280024-860515 PDR ADOCK 05000443 PDR 0 f
._ __
^ - - - - ' - . _ . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _
_-._- _ _ _ _ _ _ _ _ __
,
I'
L o .
c l
D_ETAILS l. Persons Contacted A. Callendrello, Emergency Preparedness Supervisor P. Casey, Senior Emergency Planner
- W. DiProfio, Assistant Station Manager S. Ellis, Security Department Supervisor
- J. MacDonald, Radiological Assessment Manager
- D. Moody, Station Manager W. Otto, Emergency Planner
- J. Quinn, Director of Emergency Planning
- G. Thomas, Vice President - Nuclear Production
- L. Walsh, Operations Manager The inspector also interviewed several licensed operators, heai tn physics, administrative and training personnel.
g
- Denotes those present at the exit interview.
f 2. Scope of Aporaisal .
The purpose of th4 5 appraisal was to determine the readiress of the Seabrook Station to implement the Emergency Pitn in preparation for
'icensing. The principal criteria for this appraisal are contained in NUREG-0654, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Energency Response Plans and Preparedness in Support of Nuclear Power Piants", 10 CFR 50.47, and 10 CFR 50 Appendix E. The appraisal addressed administration, emergency organization, emergency training and retraining, emergency facilities and equipment, procedures, coordination with of f site groups, and drills, exercises and walk-throughs.
3. Summary of Results Several emergency The appraisal was completed during this inspection.
preparedness program areas under review remain incomplete or require corrective action. This report documents the followup of the areas for which review was completed during the previous inspection (IR 85-32) as well as those areas covered by this inspection. Items which were listed as open items in the previous inspection report are addressed at the
,
beginning of each section with the disposition of the item identified.
Those items which need to be addressed for resolution as a result of this inspection are listed as "open items" in each details section, and are sumnari:ed in detail 6, at the end of this report, f
,
l
..
.
. 3
.
4. Details
.
A. Administration of the Emergency _ Plan f (1) Assignment of Responsibilities and Authority V. _revious inspection Findi_ngs
.
revelop job specifications for (Closed) IFI (50-443/85-32-01):the Emergency Preparedness Emergency Planner.
The inspector reviewed the approved job specifications for both in addition the positions and found them to be acceptable, ovalifications of the individual who had been second Senior Emergency Planner were reviewed.
It was hired as of the determined that the education and experience requirements of ANSI N 18,7 were met.
(2) Coordination of EP Functions Define and document the inter-(0 pen) IFI (50-443/S5-32-02): action between ttte corporate EP ,
Action on this item has not been completed. The licensee is planning several changes to strengthen *.ne EP staff organization ,
in the near future. Action in this area will be evaluated I during a subsequent inspection.
Except as noted in (2) above, this area was found to be acceptable.
B. Station Emercency_0roanization (1) Onsite Organization Previous insoeit_i_on findings
_
Develop a comprehensive organi-(Closed)
2ation chart IFI (50-443/85-32-03):
which describes overall command, control, and information flow for emergency response facilities and each
, major element of the augmented organization.
,
The licensee has developed a series of organization charts I which scribt the overall command, control, and information flow fcr the en~<tency response facilities and each major element of the augmented organization. This was determined to be acceptable in lieu of a single integrated organization Chart.
(0 pen) IFI(50-443/85-32-04):
Assign the responsibility to ,
perform initial dose assessment on shift and revise Appendix A of the Emergency Plan accordingly. )
- - - - - _ - _ _ _ _
_ _ _ _ _ _ . . .
-
.
.
The responsibility to perform initial dose assessment is I assigned to the shift superintendent or a trained alternate in l Section 10.1.1 of the Emergency Plan. Appendix A of the Emergency Plan, which defines each ERO position, does not include initial dose assessment as a duty of the Shift Superintendent or Short Term Emergency Director. This will be incorporated in Amendment 58 to the FSAR. Action in tnis regard will be verified in a subsequent inspection.
(2) Augmentation u of Onsite Emergency Organization Previous Inspection Findings Identify authorities and (Closed) IFl (50-443/85-32-05):
responsibilities of the Response Manager that may not be delegated. This item was closed with the publication of FSAR !
Amendmert 57 which adequately identified the authorities and responsibilities of the Response Manager.
(0 pen) IFI (50-443/85-32-06): Provide additional qualified alternates in the line of succession for supervisory elements of the augmented emergency organization. (In order to provide for 24 hr./ day staffing). The licensee has committed that at least 3 pecole will be trained and qualified for each of the key positions prior to issuance of a full power license.
(0 pen) IFI (50-443/85 32-07): Complete all arrangements with local service groups to ensure offsite support will be available when needed. At the time of the appraisal all of the training identified in the emergency plan for members of the Offsite Emergency Support groups had not been completed. Also a letter of agreement for backup ambulance services with the Seabrook Fire Department needs to be ccmpleted.
C. Control Room Operator Walk-throughj Previous Inspection Findings
- The previous inspection findings in this area recuiring followup were jointly identified as item (50-443/85-32-13). For ease of tracking, a suffix consistert with the original subparagraph of each item is being added to this number During the previous ir.5pection, three of the six operating crews were evaluated during during walk through examination. A fourth crew was observed during a utility conducted training drill. The following findings were made:
l
" - - - - - - _ _ _ _ _ _ _ _ _ . _ . _ _ _ _ . _ _ _
- ._ . - ____-. . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _
< n ,_ . _ ~ - - - _ .
._
_ _ _ _
-~ w.
a ,
.
.
.
(0 pen) IFI (50-443/85-32-14a) Paragraph 3.2 (et al) of EPIP ER-2.2, is not consistent with 10 CFR 50.72, in that it fails to require notification of the NRC immediately after state and local r.otifi- _
cation and within one hour.
This item had not yet been addressed by the licensee and will be reviewed in a subsequent inspection.
(Closed) IFI (50-443/85-32-14b): Paragraph 5.3 of EPIP ER 2.2 lists one or more incorrect alternate NRC phone numbers (e.g. (301) 952-0550 listed vis. (301) 951-0550). The inspector reviewed the latest revision to ER 2.2 and verified that the NRC phone numbers have been corrected.
(0 pen) IFI (50-443/85-32-14c) Form ER-2.2A, " Initial Notification Fact Sheet," is the form used to accomplish initial state notifica-This form does tion (also via the state, local agency notification).
not contain information necessary regarding whether a release is taking place (NUREG 0654 II.E3).
This item hud not yet been addressed by the licensee and will be reviewed in a subsequent inspection.
(0 pen) IFl (50-443/85-32-14d): None of the crewsThat was function able to accom- is ,
plish the e..e assessmert problem postulated.
assigned tw '.he STA ( SS) . They had not yet been trained on dose assessment. Equipment (HP-41CV calculators with the associated dose assessment program) to be used by control room personnel for dose orojection was not available. (NUREG-065a 11.0 and 11.1).
The inspector verified that the HP41CV calculators had been issued and that crews had been trained in their ase, however, it was determined that the HP41CV program is only designed for dose calcu-
!ation a'. the site boundary.
Further, the information derived is only used for accident classi-fication purposes, not for making protective action recommendations.
This does not meet the requirements of 10 CFR 50.47(b)(9) to be able to assess and monitor actual or potential offsite consequences of a radiological emergency, which could not be done under the present
,
arrangements, prior to arrival of emergency response augmentation personnel. The licensee is evaluating this item for corrective actions. This will be reviewed in a subsequent inspection.
(Closed) IFI (50-443/85-30-14e) Errors in EPIP ER-1.1 regarding emer-gency action levels. A review of EPIP ER-1 (Rev. 01). "Classifica-tion" indicated that a fire wnich is contained and controlled and 1 potentially affects safety systems would be classified ts an Alert;
_ - _ _ _ _ _ _ _ - _ . - _ - _ _ _ _ - - _ - _ _ _ _ _ _ _ _ _ - _ - _ _ - _ _ - _ - _ _ _ - _ _ _ _ _ _ - _ _ _ _ _ - _ _ - - _ _ _ - _ - _ - _ _ . _ _ - _ _ - _ - - _ _ _ - _ _ _ _ _ _ _ - - _ - - - _ -
_ _ _ _
. ,,=., -,__ _ - ..-_ .- -. __
.
.
f and, an uncontrolled uncontained fire affecting safety systems would be -lassified as a Site Area Emergency. This is contrary to the guidance of NUREG 0654, App. 1, which states that, any fire poten-tially af fecting safety systems is an ALERT; and a fire compromising the functions of safety systems is a Site Area Emergency. The in-spector reviewed EPIP ER-1.1 (Rev. 2) which corrected this discrep-ancy.
(C'3 sed) IFl (50-443/85-32-14f): Errors in classification of accident conditions. Walk-through examinations were conducted with two crews durir.g this inspection, following increased training in this area.
The training in this area resulted in a noticeable improvement in performance in this area. This area was found to be acceptable.
(Closed) IFl (50-443/55-32-149): Snift crews were unable Afterto identify further source material for evacuation time estimates (ETE).
evaluation it was determined that knowledge of source material for ETE studies would not normally be expected of control room crews.
This item is closed.
Shift crews were unable to properly (Ocen) IFI (50-443/SS-32-14h):
evaluate the static condition of 20.000 R/hr containment Specifically theycome weremonitor
- nsure
.eading (with the containment intact).
of whether a release would be in progress and whether EPA protective action guidelines would be exceeded at the site boundary.
This item was not specifically readdressed during this inspection, but will be reviewed during a subsequent evaluatiun of operator training in this area.
(Ocen) IFl (50-443/85-32-141): Shift crews were unaware of the capabilities of the post accident sampling system (PASS). Training of the operators in this area has not yet been conducted due to the fact that the PASS installation has not been c mpleted. This will be reviewed in a subsequent inspection.
-
D. Emercency Plan Tra aine and Retraining
, (1) Previous insoection Findings During inspection 85-32 several open items were identified relative to the implementation of the Emergency Plan Training /
Retraining program. These items along with their status as determined during this inspection are noted below.
(Closed) IFl (50-443/BS-32-15a) Complete and itilement the f
'
Emergency Plan Training Manual.
_ _..____ .- _ _ _ _ _ _ __ . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ . . - _ _ _ _ _ . - - - _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _
- . ..
_
.
- 7
.
Emergency preparedness training has been transferred to the General and Specialty Training Department. Emergency Prepar-edness Training requirements are an integral part of the General and Speciality Training Program Manual approved by 50RC on March 2, 1986. Following review of the Manual, the inspectors con-cluded that it meets the requirements for establi<hment of an Training, acceptable Emergency Preparedness training program.
continuing training, and requalification requirements are specified. Attendance, exemption, and documentation policir.s are stated. In structor training is required. Courses are listed and described. This manual does not apply to Security Emergency Preparedness Training or Emergency Preparedness Train-That training is ing for operators licensed per 10 CFR 55.
nscribed under the separate training programs for Security and censed operators respectively. The inspector had no further questions in this area.
(Ocen) IFI (50-443/85-32-15b): Specify the initial cualifica-tion criteria for selection of personnel to the positions in the Emergency Response Organization.
Criteria for assianment to Emergency Response Organization (ERO)
positions are based or operational assignments and Qualifica"
.'
tiens. A listing of the association of operational assignment to ERO position was reviewed by the inspectors; such a listing is not now included in Aspendix A, Amendment 55, to the FSAR
"Seabrook Radiological Emergency Plan." The inspectors were advised that these criteria would be included in Amendment 58 to the FSAR now in preparation. This item remains open until the amendment is submitted and reviewed.
(Closed) IF1 (50-443/85-32-15c): Lesson modules required by ER 8.2 have not all been prepared and implemented.
The inspector verified that all thirteen training modales required for training of onsite personnel have teen reviewed and approved.
(Open) IF1 (50-443/85-32-15d) EP training instructors de not
' meet the reau an,ents of ANSI /ANS-3.1. d The inspectors reviewed the 50RC approved General and Speciality Training Program Manual dated March 27, 1986 and concluded that the emergency preparedness instructor qualifications There are no listed provisions (Section 5.1, page 2-5) are incomplete.
for education requirements ( A, AS, B5 etc. in an appropriate discipline); practical experience in reactor operations and/or health physics. Seven reading assignments are listed plus a J
l
- - - - _ _ - - - - . _ _ _ _ - _
- . - -__ ._ ..
.
.
$
.
The requirement to observe a full participation exercise.
reading requirements are appropriate, but should be extended to discussion and examination to verify knowledge level. Soecifics of what should be gained by exercise observation should be detailed. Play by instructors in the roles based on the train-ing modules they teach should be considered.
Revise Emergency Support Group (Closed) IFI (50-443/85-32-15e):
training modules to stress the expected role of each specialty group. Following further review, it was determined that the emphasis of the present training modules is appropriate.
Assure that methods for train-(Closed) IFI (50-443/85-32-15f):
ing personnel in changes to procedures 6nd ecuipment are similar to methods used for the basic qualification program.
I The inspector verified that this concern is adeouately addressed by the descriptions in Section 1.3.2 and 1.3.7 of the approved General and Specialty Training Program Manual.
(Closed) IFI (50-443/85-32-15g): Assure an adequate nu ser of qualified individuals are available for key Emergency Response Organization positions to provide for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> coverage folicwing implementation of the Emergency Plan.
This item is closed administratively as it is a duplicate of the concern being tracked under item number (50-44 3/25-32-06).
(2) Current inspection Fine- ,3s a. During a review of Section 1.0 of Chapter 5 to draft Amend-ment 58 to the FSAR, and in-force Amendment 55, it was identified that responsibilities for each ERO pusition are listed but there is no indication regarding which respon-sibilities may not be delegated. This listing should be revised to indicate responsibilities which may not be delegated for all assignees (50-433/86-15-01).
b. The Security Officers Lesson Plan which addresses protec-
'
tive actions does not address the use of K1 as a prote;tive action. This should be added, and additional and appro-priate material included in this Lesson Plan as to the purpose, use and effects of KI, as well as the identity, by title, of the persons who may approve Security Officer use of K1 (50-433/86-1B-02) .
_______- -_ - _ - _ _
_ _ ____ . . .
.
.
.
- 9
,
c. Radiological training has been provided to the hospital staff by a member of the Health Physics Department staff, however continuing training in this area has not been de-fined. NHY should address periodic retraining in this area to insure continuity of this function (50-443/86-18-03).
d. Section 4.2.64 of the General and Specialty Training Program Manual lists Course 565, " Mitigating the Conse-quence of Core Damage." Two levels of management are targeted for this training which pertains to EP. Since managers will, in general, fill key ERO positions, this course shou'id be added to Figure 18.2 Rev. 03 as required training for the Response Manager, EOF Coor-dinator (auditor basis only), Short Term Emergency Direc-tor, Site Emergency Director, Emergency Operations Manager (50-443/86-18-04).
E. O'fsite Dose Assessment Walk-throuchs l Ine inspectors requested that all personnel trained in refined dose as- )
sessment (YEIPAC) participate in a table-top discussion to cetermine the effectiveness of EP training.
The refined dose assessment calculations according to the Seaccoon Plan are perfo-med in the EOF. The group responsible to the Site Emergency Director Response Manager for offsite dose assessment consists of five people excluding the offsite/onsite survey teams. The EOF Coordinates, wne assesses the offsite radiological consequences and determines protective action recommendations (PARS). The Oose Assessment Specialist determires offsite doses and supports the EOF Coordinator. The Offsite Monitoring Coordinator coordinates the activities of offsite monitoring and sampling teams and provides field radiological data to the EOF Coor-dinator. The METPAC operator is responsible for accessing and running tne refined dispersior model. The METPAC operator and the sample analysis personnel, although an integral part of the assessment capability, as demonstrated in the February 24, 1986 exercise and walk-throughs, are not described in the Seabrook Plan (50-443/26-1E-05).
The same table top exercise scenario was used for each of the two teams.
- The following observations were made.
- Procedure ER-1.4 does not crovide f or (or termit) any protective action recommendations (PAR) unless a General Emergency has been declared. Both crews felt that conditions warranted a precautionary PAR however were reluctant *o make a recommendation because they
.
were in a Site Area Emergency. This has apparently oeen reinforced by training. The licensee recognizes the advantage of being able to mane a PAR prior to a General Emergency and is evaluating possible changes to their procedures ard training (50-423/86-IS-C6).
- _ - -__-______________
.
.
.
- The initial dose model assumption is for no iodine in the release, in spite of the fact that Technical Specifications allow operation with up to 10 uCi/cc dose equivalent iodine, The licensee is eval-uating a change to the model (50-443/86-18-07).
Any changes made in these areas will be evaluated in a subsequent inspection.
F. Facilities and Equir ent (1) Eme rg ency.. Ope ra ti on s F ac i l i_ty a. Previous lespe.ct, t ion Findings (C'osed) IFI (50-443/85-32-16): Completely describe E07 eouipment in Appendix E.3 to the Emergency Plan or procedure ER-3.3. EOF equipment is fully described in Appendix F of the Emergency Plan and procedure ER-8.1.
(Closed) IFI (50-443/85-32-17): Complete the irstellation of EOF eautement. An inspection of tne EOF, and observations made during the February 26, 1986 exercise confirmed tnat the neces-sary equiptrent is installed and operational, b. (C'esed) IFI (50-443/85-32-08): Assure that all dedicated emergency eQuiement (spect fied in procedure ER-8.1) located at tne EOF is maintained in operable condition. During tne ap-praisal an inspection was conductec of the dedicated emergency ec.; .) ment located in the EOF. All equipment was determined to
'
!
I be operable. A program has been instituted to perform inven-tories and checks to assure continued operability.
(2) Media Center 1 Emergency News Center)
a. Previous Insge_ction Findings (Open) IFI (50-443/85-30-18): Complete the deteils of tne ine facility, equipment and organi:ation for the Media Center.
details for the Media Center facility and equipment are complete and contained in ER-8.1. The Media Center policy and proceduves
,
are still in draft.
!
b. Except as noted above this area is acceptable. I
'
f
_
O
.
-
.
(3) Meteorological Instrumentation a. previous Inspection Findings (0 pen) (50-443/85-32-19): Finalize the meteorological monitor-ing system design, consistent with the FSAR commitments and revise the program description in Section 6.2.3.1 of the Emer-gency Plan and Section 2.3.3 of the FSAR.
The licensee stated that the FSAR will be revised to reflect the full meteorological monitoring program by June 1, 1936. A two step approach will provide for an interim data acquisition system prior to full availability of tne plant process computer for total date handling.
(0 pen) (50-433/85-32-20): Provide for backup meteorological measurements representative of conditions in the vicinity of the site and provide for backup power to the instrument building.
The licensee stated that a meteorologist familiar with the site will be available, during all emergencies. The duties and re:. possibilities will be further delineated in the Yankee Mutual Assistance Plan. This individual will have access to all local National Weather Service data ard knowledge of the parameters aeeded by the radiological emergency response staff. This also will be addressed by the June 7, 1986 '
revision. The licensee is still evaluating metnods to provice backup power to the meteorological instrumentation.
(0 pen) (50-443/85-32-21): Provide a method of severe weather notification to the control room.
A policy document is currently being drafted which will specify the lcad dispatcher as providing severe weather notification to the control room.
(0 pen) (50-443/85-32-22): Implement T.S. 6.9.2 surveillance? ,
requirements for the meteorological monitoring program. Opera- l
!
tors will perform the daily operability checks on the meteoro- ;
logical monitoring system when the Technical Specification are
,
required to be followed, at licensing. The inspectors will verify that appropriate surveillance procedures are written.
(0 pen) (50-443/85-32-23): Modify calibration procedure IX1654.410, Rev. 2, for delta-temperature instrumentation to properly reflect accuracy requirements and use more specific terminology. The licensee indicated action has not been com-pleted on this item.
-- -
- _ _ _ - . _ _ _ .
_ . . . _ _ . _ _
. _ _
.______________________-_______-__--__-__-____---___-___-__--_--____a
- _ _ ._. _
.
.
.
(Ocen) (50-443/85-32-24) Provide the basic data required for atmospheric dispersion calculations (15 minute averages), which includes a time t.istory (analog or digital printout) of wind direction and speed at each level and temperature dif'erence with height in the control room and EOF.
The inspector held discussions with licensee personnel and found that the data acquisition system currently ir, place will be modified on an interim basis to Provide the necessary meteorological data to onsite personnel. Future plans will include use of the plant process computer to provide the basic parameters to the Control Room, TSC and E0F. The licensee will provide a full description of the program and implement the interim system prior to fuel load.
b. Except as noted above this area is acceptable.
(4) Non-Radiation Process Monitors The statior nea-radiation process monitoring system indications prcvided from various plant sensors include reactor coolant system pressure and temperature, secor.dary side steam cressure, statu! and function of various plant equipment components, and fire and com-bustible detectors.
The inspector verified that the process monitoring system component installation and testing had been completed prior to hut f uric t i on a l testing. The entire system is operational and adequate for opera-
tions under emergency conditions.
(5) Area and Process Radiation Monitors The area and process radiation monitoring system (Radiation Cata Management System (ROMS) is a microprocessor based acquisition and and in the display system with readouts locally, in the Control Room, Operations Support Center (05C). The various parameters measured include general area radiation, process radioactivity level', air-borne contamination levels, and effluent radioactivity levels. The system provides plant operators with warnings of accident conditions, and the capability of continual accident assessment.
The RDMS installation is complete. Turnover from construction and acceptance testing is in progress. Calibration of instrumentation and final acceptance and operational testing is projected to be complete by June 15, 1986.
As a result of this inspection it was determined that this item will remain open pending review of final acceptance,.celicration and operational testing data concerning the ROMS (50-443/86-12-03).
l l
,
-
- !
_ __
- _ _ _ _ _ _ _
- - _ - _ . - - - _ - - _ _ _
- .
I .
.
,
(6) Respir_atory Protection previo g inspection Findi_nis
_
(0 pen) IF; (50-443/B5-32-09): Implement the respiratory protection program sa1 assure that adequate supplies of respiratory protection I equipme - 3re maintained at the onsite assembly areas for emergency workers. Ihe respiratory protection program has not been fully i mp l eme n'.ed . All required respiratory protection equipment is in place in the emergency response facilities, except for the equipment to re ill air bottles onsite. SCBA training, respirator use trai ing, and medical certification is expected to be comple:ed by May '1, 1986.
The TSC and OSC both contained air purifying respirators and canis-ters as well as SCBAs reserved for emergency use only. Botn the TSC and OSC contained an adequate supoly of full face respirators and SCBAs for use during emergencies. An adequate number of spa-e bot-ties was present fo: use. Additional bottles would be available onsite from the air compressor-cascace refill facility, which is being installed onsite. The air comoressor-cascade equipment has been received onsite, however, installation is not expected to be completed prior to June 1, 1986. The compres.or buildingi will be locatec within the protected area near the Construct r n Duilding and shou d te useable uncer accident conditions.
l As a result of this inscection it was determined that in order to assure an adequate respiratory protection program the respirator bottle rtfill facility should Le completed and tre necessary training and medical certification be completed for those who will be called upon to use respiratory equipment. This area will be reviewed in a subsequent inspection.
(7) Com JniCations Ecuipment The inspecto- reviewed Section 70 of the N4Y Cmergency Plan, Rev. 55 on Communications, held discussions with licensee personnel and visited the emergency response facilities.
The emergency communication system was re,iewed against the commit-ments made in the Emergency Plan.
,
The inspectors witressed testing of the communication system durinq the December 21, 1985 emergency drill and February 24, 1986 full-scale emergency 7.xercise. The system as described in the emtegency plan is functional excoot for the ENS. A dedicated telephone line is in use in place of the ENS. This is acceptsble until the ENS is installed. The licensee has identified several problem areas. The internal public address system speakers in some areas are inaudible.
' - -
,
, ,
,
- - - _ _ _ - _ - - _ _ - - - _ _ _ - _ _ _ _ _
_ _ _ _ _ _ _ _ _ _ _ ____________-__ - __________
.
>
)
l This was due in most cases to persons tampering with the speaker or I internal volume control adjustment. A system has been established to l track and correct problems in this area, The licensee has a surveillance procedure, ER-8.1, which requires periodic inspection of communications systems and equipment.
Procedures ER-8.1 and ER-8.5 establish responsibilities for performance of the surveillance, l
/
26, 1986, the Nuclear alert system During the exercise on February (orange phone) was used, providing direct interfaces with the Mas-sachusetts and New Hampshire State Police.
At the time of the inspection, the installation of the sirens which comprise a portion of the Public Emergency Alerting System, had not inspec-been completed. This area will be reviewed in a subsequent !
tion (50-443/86-18-33).
Except as noted above, this area was found to be acceptable.
(8) Medical Treatment Facilities Previous Inspection Findings Complete and e4uip the first aid (0 pen)
treatment IFI (50-443/85-32-10): facility to allow treatment of contamin personnel. The first aid treatmer.t facility eavipment has been ordered but has not yet been received. This will be reviewed in a subsecuent inspection.
(Closed) IFl (50-443/85-32-11): Assign plan.a full A full time time nursenurse ensite as described in the Emergency joined the Seabrook Station at the beginning of the calendar year.
Ensure that (Open) IFI (50-443/85-32-12) (50-443/85-32-13):
arrangements for transportation of onsite contaminated ?a-ly described / injured in personnel are permanently available and -1 plans / procedures, including equipment and supplies for contamination control This item remains open pending training l for the offsite ambulance personnel and negotiation of a letter
, of agreement with the Seabrook Fire Department which will be providing this service.
The inspectors toured the First Aid and nurse's station located ( next to the health physics control point. Progress has been made, however it was determined that not all of the first aid
-
equipment and supplies identified on page the In addition, 10-9procedure of the Emergency for Plan has been received.
l
'
decontamination of contaminated / injured personnel (ER4.4) is
- .- ..
. ,
.
.:
.
- 3no < .
_ _ _ . _ _
.
.
A full-time nurse has been appointed and is being revised. When completed and available during daytime working hours. j fully equipped, the medical treatment facility will be adequate (
to treat radioactively contaminated and injured personnel. I In addition to completing the installation of equipment noted in a., above, the following items w re identified and will be reviewed in a subsequent inspection.
l Emergency"
- Complete the revision to ER-4.4 "Onsite Medica (50-443/86-18-9).
- Complete and implement the Exeter hospital Radiological Procedure Manual for treating contaminated injured pa-tien*s. (50-443/86-16,-10)
A medical emergency drill will be observed in a subsequent inspection, to assess the capabilities in this area.
( 9)
Operations Support Center floor of tne Administration and The 05C is located on the firstThe OSC i< in:luded i., the station emergency Service Building. The USC does not have any special -adiation if conditions warrant, the OSC
,
communications networA.
shielding or air f 41tratior, systems,The OSC facility is established as staff would relocate to the TSC.
described in EP-E.0, Section 6.1.2 and as ,,hown is maintained in OSC.
at the FigureThis 6.6. couip-Dedicated emergency equipment Acti-ment is idtntified and serviced in accordance rith EP-5.1 2.
vation and operation of the OSC is documented in EP-3.2, Revision
Based on the above, this a.ea is acceptao',e.
(10) pnemncy Kits and Survey Instrumentation Emergency kits and emergency survey instrumentation are c.ain* ained a TSC, OSC, Rte. 107 Warenouse, EOF and the the Exeter following Hospital. locations:The emerge *cy equipment maintained at each of these This procedur? provides locations is identified in Procedure ER-2.1. Wnen ap-for routine inventory checks of all emergency eauipment.
propriate, operational and calibration checks are routinely per-Equipm
,
formed. All such checks are documented.
re-entry teams has the capability forThe the emergency detection and kitsmeasurement contained of both beta and gamma radtation. re-entry teams.
sufficient instruments / supplies to adequately supprtIn-Instrumentation capable of distinguishing noble gases is provided.
beta / gamma is available.
.
l
- - - - - - - - - - - - -- _ - ____.- __________ _
__
_ - _ - _ - _ _ _ - . - _ _ _ _ - - _ - _ _ _ _ - - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _
[{
- 16
,
Based on the above, this area is acceptable.
(11) Protective Clothing Stores of proter,tive clothing reserved for emergency use are main-tained at the ISC, OSC, Rte. 107 Warehouse, EOF and the Exeter Hos-pital, This cquipment is periodically inventoried and is accessible under emerg ecy conditions.
Based on the above, this area is acceptable.
l (12) Reserve S,uy lies Tne licensee maintains an onsite inventory of emergency supplies and eoutpment in addition to that dedicated specifically for emergencies.
In addition, the licensee has the ability to obtain additional sup-plies from offsite through the Yankee Mutual Assistance Plan.
Eauipment available through this plan includes:
a) Mobile Laboratory Emergency Analysis Equipment and Van Service b) Mobile TLD Van Service c) Mobile Body Burden Van Service, and d) Field environmental radiation surveillance equipment (and personnel).
The licensee maintains a minimum stock level to insu e an adequate reserve of normal supplies to handle emergency situations.
Based on the above, this area is acceptable.
(13) Tra sportation The licensee has identified eight (8) vehicles for use in the event of an emergency. Four of these vehicles have fixed 'nobile 100 watt VHF mobile radios tuned to the Health Physics frecuency. Tne other four vehicles can be equipped with conversion kits that boost the transmitting power of portable radios from 5 to 100 watts. Se:urity procedures provide for the delivery of three of the vehicles to the C0F for use by the field radiological monitoring teams. AmbulanceIt and fire vehicles are provided by the Seabrook Fire Department.
,
appears that tne size and type of vehicles reserved by the licensee for emergency use is adequate.
Based on the above, this area is acceptable.
_ _ _ _ _ _ _ - _ - _ - _ - _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _
- _ - _ _ - - _ _ _ _ - _ _ _ _ -
.
.
(14) Control Room The inspector reviewed the Seabrook Radiological Emergency Plan (REP), applicable EPIPs, selected portions of the Seabrook FSAR, and compared the facility to requirements and guidance from The 10 CFRalso inspector 50, NR-0654, NR-0696, NR-0737 Sup. 1, and RG-1.97.
observed the control room as an emergency response f acility (ERF)
during the February 26, 1986 observed exercise.
Based on this review, it was determined that the control room met the guidance concerning equipment, decisional aids, and habitability.
(15) Technical Support Center The inspector tourec the facility and observed it in operation curing a utility sponsored exercise in December 1935 and again, during the February 26, 1986 observed exercice, to verify that the guidance NUREGs 0696 and 0554 was met and that operation was in accordance with the appropriate E?lP's, Based on this review it was determined that the TSC is within the Cortrol Room habitability envelope and is thus served by the same fi'tered ventilation system. The guidance of the NUREGs has been met, except in the case of the NUREG-0654 II H 5, equipment instal-lation (e.g. sei smi., rad, etc.) which is not yet complete. Tnis item will be reviewed in a subsequent inspection ( 60-443/86-18-11) .
(16) Post Accident Sampling _ System At the time of this inspection the installation of the Post Accident Sampling System (PASS) had not been completed. T..is area will be reviewed in a subsequent inspection (50-443/86-18-34).
G. Emercency_ Response Procedures (1) Personnel Monitoring and Decontamination During the appraisal the procedures for personnel monitoring and decontamination were reviewed and discussed with the health physics supervisor. Applicable procedures were ccntained in HD0958.02,
" Radiation and Contamination Survey Techniques", ano HD0958.03, ER-4.6, "Offsite Monitoring
'
" Personnel Decontamination Techniques" and Decontamination", contained instructions for assembly ard dis-patch of monitoring and decontamination teams. These procedures provided for monitoring all personnel exiting from restricted areas and at the offsite assembly / reassembly areas,
--
__
_ __
__
- - - - - - - - - - - _ - - - - - - - - _ _ - _ - - - - - _ - - _ - - _ _ _ _ _ _ - - - - , - - - - _ _ - - - _ - -
-- _ _ _ _ _ _ _ _ _ _
.
-
.
These procedures proviced for recording the names of individuals surveyed, extent 'of contamination found, radiation detection instru-mentation used, survey methods, and results of any decontamination efforts employed. Contamination levels that require decontamination actions were specified for various levels and types of radioisotopes.
Action levels requiring further assessment by the health physics staff and the followup actions required were delegated to the Radio-logical Controls Coordinator. Copies of monitoring and decontami-nation procedures were available at the onsite decontamination facility, at the Route 107 warehouse, and at the EOF.
It was determined from the review that adequate procedures existed to facilitate personnel monitoring and decontamination under emer-gency conditions.
(2) Evacuation of Owner Controlled Areas The inspector reviewed EPIP ER-4.1, Personnel Evacuation, to deter-mine compliance with NUREG-0654 requirements.
ER-4.1 Section 4.0 contains prerequisites for evacuation of the site, specific areas of the plant, or individual buildings. Evacuation routes from the station are Clearly spelled out both in the Emergency Plan and in ER-4.1. The locations of assembly areas and the criteria for use are as described in the Emergency Plan. Provisions for con-cise oral announcements over the facility public address system, and for dispatch of security patrols to the construction building, prod-uction warehouse, education center, and the training center are centained in ER-4.1. This procedure provides for the assurance that all station personnel are notified and that the accountability and contamination monitoring are implemented by the Security Supervisor and Radiological Controls Coordinator respectively.
As a result of this inspection it was determined tnat the applicant's procedure for personnel evacuation of owner controlled areas accept-able to control operations under emergency conditions.
(3) Personnel Accountability The inspector reviewed EPIP ER-4.2, " Personnel Accountability", for
-
adequacy in assuring that all onsite personnel are accounted for in an accurate and timely manner.
The procedure specifies that the Security Supervisor implements the accountability process and reports accountability results to the l Short Term Emergency Director (Shif t Supervisor) or Technical Services Coordinator. Ine procedure establishes a thirty minute goal for completion of accountability and contains provisions for continuous accountability of all persor s onsite af ter initial accountability na5 been completed.
___
.
" ---+ _ _ . _ _ _ _ _ _ _
_ ._.
_ _ - _ ._ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ __-
- .
.
.
The accountability system relies on the use of a security computer with a manual backup utilizing Form ER-4.2A, Accountability Listing. The security computer is installed and operational, however, the card readers are rot functional. The total security program is scheduled to be implemented by May 15, 1986, at which time the card readers will be operational. The security computer will print out missing personnel by plant sector. A search would be initiated by the Short Term Emergency Director or Technical Services Coordinator utilizing Procedure ER-4.5, Search and Rescue.
ER-4.5 is not referenced or referred to in ER-4.2.
As a result of this inspection it was determined that this area will remain open pending the implementation of the plant security program and demonstration of the ability to complete accountability. The plant accountability procedure ER-4.2 should also reference ER-4.5, Search and Rescue. This item will be reviewed in a subseauent inspection (50-443/B6-18-12) .
(4) Off-site Radiological Surveys Procedure ER-5.2, " Site Perimeter and Off-site Monitoring and Environmental Sampling", identifies the methods and tauipment to be usec to perform emergency off-site radiological surveys. The Off-site Monitoring Coordinator, stationed at the EOF, is responsible for coordination of the emergency off-site monitoring and environmental sampling program. Emergency supplies collected by of f-site satpling teams are to be analyzed by either the Yan6ee Nuclear Services Division Environmental Laborato.y or the Seabrook Mobile Environmental Laboratory. A walk-through with one of the three field monitocir.g teams was conductec during a full-scale emergency preparedness drill held on December 12, 1985. Dedicated vehicles ecuipped with 100 watt mobile radios and monitoring kits are available to field three monitoring teams. Tne procedure does not provide the field teams with instructions for communication with the EOF in the event of loss of the mobile radio capability.
Based on the above the following items need to oe addressec in inis area:
- Provide procedures for a back-up means of communications
.
in the event of radio failure (50-443/86-18-13).
- Include specific instructions to the Off-site Monitoring Coordinator regarding the use of respiratory equipment and the administration of KI by the fielt monitoring teams for protection f rom airborne hazards (50-443/86-18-14).
Except as noted above, this area is acceptable.
i
. . .-
_ ________
.____ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ .. __
.
.
4 i
(5) On-site (Out-of-Plant) Radiolo2 cal Surveys i
The inspector reviewed procedures ER-4.3, Rev. 02, "Radiat on Pro-tection During Emergency Conditions", and ER-5.2, Rev. 04, " Site Perimeter and Off-site Monitoring and Environmental Sampling" The inspector identified that there was no emergency procedure de-scribing the method and equipment to be used to perform orsite (out-of-plant) radiological surveys. The applicant acknowledged the lack of this procedure and agreed to draft appropriate procedures for these surveys (50-443/86-18-15).
(6) Radiation Protection Durin,g_E_meraencies Procedure ER-4.3, Rev. 02, " Radiation Protection During Emergencies" specifies the on-site radiation protection practices to be imple-mented following activation of the Radiological Emergency Plan.
Specifically, the procedure addresses the following areas:
a) OSC Activities ,
'l t; Protective Area Radiation Surveillance and Control c) In plant Surveillance anc Control d) MPC-hour Accour.tacility e) Dose Assessment end Exposure Tracking.
The Racio!ogical Controls Coordinator is assigned the responsibility for ensuring station emergency exposure control measuras.
Basec cn the above, this area is acceptable.
(7) Repair an0 Corrective Actions Procedure ER-7.1, " Emergency Repair and Corrective Action", Rev. 01, provides instructions for emergency repair and corrective actions.
The responsibilities of the Technical Service Coordinator, the The Maintenance Coordinator and the OSC Coordinator are defined.
procedure cescribes the concept of the operations for repair or corrective action activities. The Radiological Controls Coordinator f is recuired to provide health physics support to team members. This support includes; a) expected doses,
-
b) Required protective equipment including KI,
,
c) Dosimetry required, l
'
d) Authorized dose, e) Respiratory ha:ards, and, f) Radiological controls.
Based on the above, this area is acceptable.
'
y
<
.. .,
- - - - - - - - - - _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _
__
_- _ _ _ _ _ -. _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ _ - _ _ _ - _ _ - _ ___ _ _ - _ - __-_ _ _ _ _ _ _ _ __
-
._
,
'
!
,
,
(8) , Recovery "
Procedures ER-8.7, " Recovery Organization" and ER-7.3, .Re-entry and Recovery", were reviewed. Organizational authority for declaring that a recovery phase is to be entered is included in the procedure. Radiological conditions as well as plant operating conditions are evaluatedProcedure'ER-8.7 before terminating an emerge ncy and entry requires the agreement of ( into a recovery mode.
l the authorities of Massachusetts and New Hampshire, federal authorities, and the Response Manager before an emergency condition
'
can be terminated.
Based on the above, this area is acceptable.
(9) 1,nventery, Operational. Check, and. Cal _ibr.a. tion of. Emergency Equi Procedure ER-B.1. " Emergency Equipment and Facility inventory and preparedness Cneck", provides a specific inventary listing of all Tne specific equinment reserved for use during emergencies,An emergency eculpment locatien of the equipment is provided.
inventory and operational check is performed when any of the following occur:
- the emergency equipment has been used
- at scheduled quarterly intervals, or
- if a seal on an emergency kit or locker has been broken.
and The scheduled quarterly inspection includes an inventory check,The results of wher appropedate, operational checks are performed.
each invertory are documented and the results reported to the Radio-Health physics equipment calibration and logir.al Assessment Manager. regulate the maintenance scheduled in accordance with HD-0963.02 frecuency of inspection of dedicated radiological ecuipment/ supplies.
The Radiological Assessment Manager is responsible for ensuring the inspectien, inventory, and operational checking of emergency eculp-ment and facilities.
.
Based on the above, this area is acceptable.
(10) EmergencLK,1,n and_ Emergency. Survey._ Ins,tr,upent.ati_on A walk through was conducted of the Control Room, TSC, OSC, Rte, 107 for the purpose of verifying that the dedicated warehouse and E05 identified in the following procedures emergency facility / equipment was in the assigned location.
EP-6.0, " Emergency Facilities" i
i I
_ _ _ _ _ _ _ _ _ _ _
_ - . - ._ _ _ _ _ - - . _ _ _ _ - . _ _ _ _ _ - . - - - _
.t-o ,
.
'[.
" ' 22 EP Appendix F, " Emergency Equipment Checklist" ER-8.1, " Emergency Equipment and Facility Equipment Inventory and Preparedness Check",
The final walk through was conducted on March 25-26, 1986. An in-ventory, and when appropriate, a. functional check was made of all essential equipment at each of the above emergency respot'se facil-ities., No discrepancies were identified.
'
'-
Based on the above, this area is acceptable.
(11) Public Information
.The inspector reviewed section-11.3 of the NHY Emergency Plan, Rev.
57, on Public Information, also draft brochures, calendars, telephone book inserts and posters.
The Public Information (PI) program was evaluated against the're-quirements in 10 CFR 50 Appendix E Specific areas were. reviewed to verify the following:
- provisions were described for yearly dissemination.to the public with the EPZ;
- that the mat 6 rials contain basic emergency planning information and general information as to the nature and effects of radiation;
- measures are taken to provide information to the transient population;
- materials and information provided to the public are :oordinated with State and local government agencies, and;
- that the information provided also contains evacuation routes, sheltering directions and actions to be taken when alerted.
Based on this review it was determined that the public information section in the Emergency plan describes the bases for the program.
.
NHY nas stated that they will provide, annually,. emergency planning materials to each resident, school, nospital and nursing home within the EPZ. The inspector noted the draft materials for resi'dence (brochures and calendars) provide the general information on the j nature and effects of radiation. Also, in the draft matettal are the Emergency Radio Broadcast stations, infernation on how to shelter, and how the residents will be noti #ied, however, evacuation routes have not been finalized.
l l
l
_ _ _ - - _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - - . . _ . .
. .. . . . . -
, _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ __ _ __
e
,
l 23
'
The inspector reviewed several mailing lists covering the resident population in the EPZ. The licensee stated these lists will be updated prior to the mailings. Also, local commercial establishments (within the EP2) with fifty or more employees, schools and nursing homes will be provided tone alert radios. In addition, the licensee has made arrangements with the NH Civil Defense director and local
,
' towns to provide posters (some bilingual French /English) f or the persons on the beaches within the EPl.
Other methods the licensee plans to use for the initial distribution of emergency planning information are newspaper and radio advertis-ing, This is planned to be done concurrently with the mailing of brochures. Telephone directory advertising will be included in the 1986 Portsmouth white pages and the 1987 Newburyport and Haverhill white pages.
At present this information has not been distributed to residents in the EDZ. It is understood that the final details will have to be developed to reflect information in the NH and MA plans, however the licensee indicated that an interim pamphlet will be distributed prior to fuel load, to provide basic informattor. as to what to do if sirens are act'vated, where to receive additional informat'on, etc.
(50-443/86-18-16). The 'inal brochures will be distrioutec prior to receiving a f ull power license (50-443/E6-18-17). The information Contained in these brochures will also receive evaluation by IEMA as l part of the off site plant reviews.
( 12 ) O r l_1,1,s_ ,a n d , E n e.r c i s.e.s. .
Tne inspector reviewed procedure EP 8.3, " Emergency Preparedness Drills and Exercises", Rev. 1, which defines the program for the conduct and evaluation of emergency drills and esercises to verify that drills and esercises are properly planned and coordinated to meet the training requirements of 10 CFR 50 Appendia E. In addition a schedule of dril's was reviewed to verify that the various emer-gency response areas would be adeavately esercised.
Tne overall coordination of the drill and erercise program is the responsibility of the Radiological Assessment Manager, The Training
. Manager coordinates scheouling of the esercises alth the Radiological Assessment Manager, and ensures that they are conducted as scheduled. l A traching system has been developed to trach d'ill/erercise deficiencies and to ensure that appropriate torrective action is taken.
This area was determined to be acceptable
_ _ _ _ _ _ _ _ _ _ _ _ __
__ . _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ -
o
,
.
,
(13) Audits The inspector reviewed Chapter 18 of the QA Manual which defines the Operational 0A audit requirements. One of the requirements is to prepare an annual audit schedule which includes (among others)A the re-activities of section 6.5.2 of.the Tecnnical. Specifications.
view of the draft lechnical Specifications indicates that the appro-priate reference is section 6.4.2, not 6.5.2. It was also determined '
Emergency Preparedness was not included in the list of activities.
The licensee indicated awareness of the error in the Technical Specification reference in the QA Manual, and that Emergency Pre-paredness had not yet been added to the list of activities in section 6.4.2,as an area requiring audit. Steps are being taken to correct both of these items. .This item will be reviewed in a subsecuent inspection (50-443/86-18-18) .
(14) R ? Li e g, ,Ap y i,.s i o,n ,,,,a n d ,,0,i_s t r i bu t i,o n, 0 f, ,t h e, Em.e r g e n c y _P 1,a _n The inspector reviewed the Document Control Center organization and functional responsibilities section of the Nuclear Production Oe-cartment Records Manual, compared it with NUREG-0654 elements P.4, P.S. and P.10, and toured the Document Control Center facilftfes. l The inspector determined that Emergency Plan Implementing Procedure telephone numbers are reviewed quarterly. The responsibility for review is assigned to the Sr. Emergency Planner. . Changes to the Plan and Implementing Procedures are required to be appro,ed oy the
Station Operations Review Committee (S.O.R.C. ). The Plan and g Procedures we-e current and distribution was in accordance with the ,
! approved distribution list. The names, titles,.and telepnone l numoers of selected procedures were verified to be correct.
As a result of this inspection it was determined that the applicant's procedures for review, revision, and distribution of the Emergency Plan and Implementing procedures are acceptable.
{
(15) First Aid / Rescue The inspectors reviewed procedure ER-4.4 "Onsite Medical Emergency" in the Emergency Response Program Manual, and determined that it
'
covers action to be taker in the event treatment of contaminated /
injured individuals is necessary. The procedure includes provisions for receiving, recovering, tr1nsporting, and handling persons who may beenme radioactively contaminated onsite and provides for radio-
'ogical controls offs'ta. However, discussions with NH Yankee health physics personnel indicated that proceCure ER-4 4 was being revised l in its entirety (50-443/86-18-09). It was also identified that the .
!
l l
..
. ~ . -
...
.
> __.
L - _ - _ _ - _ _ _9
_ _ . - - _ _ _ _ _
I
.
. 1 Radiological Procedure Manual for Exeter Hospital (where contami- l nated/ injured personnel are treated) was incomplete (50-443/86-18-10). l Facilities, equipment, supplies, and other arrangements necessary for the
'
the applicant to implement this procedure were also incomplete at time of this inspection. (See para. F.8) !
j Except as noted above, this area is acceptable.
I (16) Emergency,,, Alarm,,& Abnormal Procedures The inspector reviewed chapter 5 of the Emergency Plan, the Seabroo6 site specific version of the Westinghouse Owners Group (WOG) Emer-gency Response Guidelines, and selected emergency alarms, and ab-normal operating procedures to evaluate conformity to requirements &
guidance provided by 10 CFR 50, NUREG-0737 Supp. 1, & Regulatory Guide 1.33.
Based on this review it was determined that, although none of these procedures has been formally promulgated, most of the required procedures exists in a refined draft stage which are in conformance with the referenced guidelines and requirements. Formal promulgation
of the procedu*es is expected in the near future, and action in this regard will be reviewed in a subsequent inspection (86-443/E6-Is-19).
Operators have been trained in these draft procedures, however a final training effort for all operators after the procedures are
.
l formally promulgated will be necessary. This area will be reviewed in a subsequent inspection (50-443/86-18-20). ]
( 17 ) Imp,1,emeni ng,,P, rocedure,5 The inspector reviewed Seabrook EPIPs ER-1,2 through 1.5, the pro-cedures for Notification of Unusual Event through General Emargen:y, and compared them with guidance from NUREG-0654 Based on tnis review it was identified that:
a. Ir,itial not.ftcation forms and some of the followup notification forms incorrectly allow the EOF Coordinator to sign, authori:ing notification. This authority cannot be delegated to the EOF c oo rdi r a t<0 r . (NUREG-0654 11 B 4) (50-443/E6-18-21).
i
'
b. The f ollowup notif icattor, f orms f ound in ER$ 1.2 through 1.5 et al do not:
- indicate type of release (airborne, waterborne) (NUREG-0054 f !! E 4 0),
- Project irtegrat6d dose at the site boundary (NUREG-065 11 E 4 H),
l
-
4
. .
manus ~.
-
-
I
_
- - - - _ _ _ - - - _ _ _ _ _ _ - _ - _ _ _ - - - - _ - _ _ _
- - _ _ - _ _ _ _ _
.
.
.
.
10 miles
- Project dose rate and integrated dose at (NUREG-0654 !! E 4 !). (50-443/86-16-22). HP c.
Revise ER-1.3 fig. 1 paragraph 1
.3 to add iththe on sht ER-4.1 l tech as 5.3.3 an alternate advisor to be consistent w (50-443/86-18-26).
paragraph d.
Procedure ER-1.4 contains the following errors:
The instructions to the SEO concerning selection of evacuation alternatives as a function of wind direction appear to befor w in error. At present, It is located generally downwind track is the designated site.
f or winds f rom that sector (50-443/86-18-24).
f The caution after step 4 of figure 1 prohibits Pro declaration of a Site Area Emergency (SAE). In combin-block on the standard followup information sheet. SAE.
nen ation, these items infer a prohibition bited fromagainst PA tne staff expressed the belief that they were prohi (See paragraph F.)
e.
Steps 18-20 of form 2.2B (contained to project dose atinthe Eks-1.5 site and 2.2) recuire use of the HP-41 calculator This reovirements cannot be n.et boundary, 2 miles, and 5 miles. (See paragraph D.1, with the present HP-41 system and software.
item 85-32-14d),
Plan ogs. A-J anc A-2 snould be teen-6).
i f.
- tem E of tne Emergencytified as a non-delegaDie f unction (50-443/c A of The listing of primary and alternate staffing in Appendix SEDs) (50-g.
the Plan dif f ers f rom that of procedgre 2.1 (e.g.
443/96-18-27).
(18) Assessment Actions applicable Seaorook emergency ine preparedness inspector The inspector r2 viewed procedures, and Section 5 of the borgency Plan. actions were consis f verified that assessment NUREG-0654 except as noted below:
( Se e
-
The operating shift has nn dose projection capacility 02ragraph U.1 )
-
D w edural problems with the notification pro:ess a e identif ied elsewnere (See paragraph G.17).
_.
~ _ ---_
-
.
.
( l 9 ) C Ms s i f 1,c 4.t i o_n_,5 c he,me, R_ev 1_ew :,
Outside the scope of the EP Appraisal, but within the month prior to this inspection, the insDeCtor Completed two technical reviews of the Seabrook Emergency Plan EALs and procedare ER-1.1 under NRC Head-twice with the utility on that subject, cuarters sponsorship and metseveral differences existed betwcen the it was identified that plan and that of proce-classification scheme shown in the EmergencyThe licensee has proposed satisfactory dure ER-1.1 (draf t Rey, 4),
corrective action concerning these differences, by issuance of This item Revision 4 to ER-1.1 and Amendments 56 and 57 to the FSAR.
will ce closed f ollowing review of these changes (50-443/86-18-28).
(20) Se Hr.ity During. Emergencies E
The inspector reviewed this area dur'ng a utility drill in December 26, 1986, and race tne 1935 and again durirg tne rxercise of February followirg observations:
- The protected area perimet.er control system (fenc tng, E fields, u ba0ging, etc.) has not yet'been established (50-443/86-lE-29).
- Station personnel have not cortpleted full scope General Employee Training nor has the EP training program been final bed and completec in this area. Security training is a component of both (50-443/E6-18-30).
(21) Coordinaticr witti Cffsite Groups Tne auditors reviewed Appendix E of the Errergency Plan (letters of Agreefrent with of f sit.e agencies support personnel) and met with representatives from six support groups to determine to what extent the program for coordinating emergency planning and response activities with each group has been developed and irrplemented by the applicart. Discussions were held with key response personnel from the towns of Exeter, NH, Kingston, NH, Brentwood, NH, Seabrook, NH, West Newburg, Mass, Exeter Hospital, and Seabrook Greyhound tack.
All representatives expressed a clear understanding of their agency's The role and responsibility in response to Seabrook emergencies.
inspectors found that arrangements for technical and adm'nistrative
' support at each facility were consistent with the language specified Fire Depart-in leturs of agree, tent with the exception the Seabrook ment. Agreenents or centracts between the applicant and each offsite group v ere either current or in the pr ocess of beitig updated with the erce,7 tion of Exeter Hospital. Ef forts trade by the applicant to co-ordinate notifications and communications, emergency response train-Classrcom ing, and routine exchange of inf orfration are acceptable
- -- ___ ----_
_ _ _ _ _ _
.
l i .
training of State and local groups in New Hampshire and Massachusetts remains incomplete. New Hampshire representatives had the oppor- ,
j tunity to participate in the full-scale emergency exercise held on February 26, 1986. In Massachusetts, no practical training (drills or walkthrough ) has been provided to response personnel. (See section 3). Controlled copies of the Seabrook Emergency Plan and Procedures are maintained in local libraries for reference by local officials. Copies were not raintained at Exeter Hospital. Local town managers were familiar with the appl! w t's procedures as they affect State avd local response regarding notifications, communica-tions, and info ~ nation fis from the site to them. Managers also indicated that re. commendations for protective measures which were agreed on by State and uti".ity officials would be implemented at the local level w'thout delay immediately following communication of all critical information.
The individuals interviewed by the inspectors were identified as top level emergency response personnel of their respective organizations, i.e., Civil Defense Directars, Selectmen, hospital president, police chief, and fire chief. It was determined that the representative.,
are generally content with the applicant's ef f ort for coord'nating emergency preparedness issues, and Civil Def ense (Emergency Operations Center) directors stated that the language contained ir letters of agreement would be honored.
Encept as noted below, this area of the licensee's program is acceptable.
- The licensee should ensure that all letters o' agreemsnt are current, reviewed, and contain mutually acceptable language to all parties invo'ved in each agreement (50-443-86-1E-31).
- Complete the orientation and offsite training program for New l Hampshire and Massachusetts State and local of ficials (training effectiveness will be evaluated by FEMA). (50-443/86-18-32). l S. Suuary_ Listing _of Open Ite_ms The following is a composite list of items from the appraisal conducted in December, 1985 (IR 85-32), and this inspection, which had not been satisfactorily resolved at the conclu> ion of this inspection. Except for those items indicated by (*) all will be corrected prior to fuel load.
.
Asterisked items will be corrected prior to issuance of s full power license.
(55-32-02): Define and document the interaction between tre corporate EP i'
.Laff and the station staff.
(25-32-04): Assign the responsibility to perforst iritirl dose assessment on snift and revise Appendir A of the Emergency Pian accor11r.g'y.
.
WI W I M
_- - _ _ _ _ - _ - _ _ - - _ - _ _ _ _ _ _ _ _ _ _ _ _
-_____ __
- ~
.
.
.
Provide additional qualified alternates for key ERO 4(85-32-06):
positions to assure the ability to staff the augmented organi:ation on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis.
Complete arrangements with offsite survey groups to ensure (85-32-07):
availability of offsite support during emergencies.
Complete implementation of the respiratory protection (85-32-09):
program (training and air bottle refill capability).
Complete installation of equipment in the First-Aid Facility.
(85-32-10):
Ensure that arrangement for transportation of onsite con-(ES-32-12/13):tamiaated/injurou personnel are made and described in plans and proce Paragraph 3.2 (et al) of EPIP ER-2.2 is twt consistent with (35-32-14a):
tne requirements of 10 CFR 50.72, in that it does not reovire notification o' the NRC immedia.tely_a,f,te.c the state (s) and within one heur.
Form ER 2.2A, " Initial Notification Fact Sheet". < ices not (25-32-14c):
contain provisions for recording or reporting whether-a release is in progress (NUREG-0654 II.E.3).
No on-shift dose assessment capability is proviced.
(25-32-14d):
Shift operating crews were not aware of containment cesign (85-32-14n):
leak rate specifications.
Shift operating crews were not . ware of tne capabilities of (85-32-141):
the Post Accicent Sampling System (PASS).
(85-32-15b):
Ovalification criteria for assignment to positions in the Emergency Response Organization were not specified.
EP training instructors do not meet the esperience require-(B5-32-15d):
ments of AN51/ANS-3.1.
and Complete procedures which describe the equipment (85-32-18):
o*ganization of the Media Center.
Finali:e the meteorological system design co<,sistent with (25-32 19): pla-
.
F5AR commitments, and *evise description in the Emergency Provide for backup meteorological measurements representa-(95-32-20):
tive of canditi ons ir the vicinity of tt.e site.
(95-32-21): Previde a method for notification of impending severe weather to the Centrol Room.
s
.
.
- . - - - - -
- _ - . _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _
t
. .
.
,
Implement surveillance program procedures for meteorological (85-32-22):
equipment (to be done concurrent with issuance of operating license).
(85-32-23): Modify calibration procedure IX-liS4.410 to reflect minimum required accuracy of delta-T instrumentation of 0.1 degrees centigrade.
(85-32-24): Provide for main.aining a historic record of basic dat a required for atmospheric dispersion calculations.
ste:lfy which (86-18-01): Emergency Plan, Chapter 5, Section 1, does not responsibilities of ERO staff members may not be delegated.
(86-18-02): The Security Officers' Lesson Plan does not incloce discussion of the use of K! as a possible protective action.
(86-18-03): Periodic radiological retraining of the hespital staff has not been developed or scher.uled.
(86-13-04): Mitigation of core damage training is not reovired for the Response vanager, 5.0F Coordinator, Short Term Emergency Director, Site Emergency Director, or the Emergency Operations Manager.
(86-18-05): HEToAC Operator and sample analysis personnel are rot deu ribed in the Emergency Plan as augmentation personnel.
(86-18-06):
Procedure ER-1.4 does not provide for (or allow) cy protective action recommendations (PAR) to be made unless a General Emergency has oeen declared.
..
( E 6- 18-0 */ ) : The initial dose assessment model assumes no iodine in the release.
(B6-18-08): Complete operational testing and turnover of the Radiation Data Monitoring System.
(E6-18-09). Complete the revision to ER-4.4, "Onsite Medical Emergency" (s6-16-10): Complete and implement the Exeter Hospital Radiological Procedure Manual.
(E6-18-11):
Installation of instrumentation in the ISC is not co plete
'
(NUREG-0654 11.H.5).
(86-18-12): Implement *he station security progran and demonstrate the
,
' ability to perform accountability of onsite personnel during an energency.
(86-18-13): Provide backup means of communication with off-site radiological teams in event of loss of radio com.munications.
i
_
___- -
,
.
Include f.pecific instructions to Off-site Monitoring
,
(66-18-14): j Coordinator regarding use of respiratory eavipment and K1 in prucedures.
(86-15-;5): Draft appropriate procedures for the performance of onsite (out-of-plant) radiological surveys.
(66-13-!6):
Distribute interim public informationon brochures, providing siren activation, basic information concerning what action to ta#L where to receive additional information. etc.
DistriDute final detailed public information brochures 4(86-16-17):
describtng all necessary e-ergency planning information for ine public, including evacuation routes.
($6-15-18)-
Revise 1.5. 6.4.2 ard implement the QA audit program for emergency preparedness.
(66-15-;9)- promulgata firal version of emergency, alarm, aad abnormal pro:edu'es.
eserators in the final versiuns of emergency.
(56-!S-231: T r a i r.
ADnorma', ard alarm proceduces (!6-;5-21)- Revise proc'f.res ER-1.2-1.5 to reflect that the authority to a,teer te notif1:attor cannot be deleaated to the EOF Coordinator.
Tre Followup Notifi ation Forms in precedures FR-1.2 through (!6-18-22):
E;-l.5 oc not irciude in ormation regarding type of release, projected integratec dose at the s'te boundary, and projected dose rate or integrated dose at ten miles.
(56-16-23):
ER-1 3. Figure 1, does not identify the on-shift HP techni-cian as an alternate Advisor, to be consistent with ER-4.1.
Procedure ER-;.4 contains en erro concerning the selection (66-1B-24): .has evacua-of evacuation alternatives as a function of wind direction.
tion to the dog track when wind is blowing toward the track.
HP 41 Calculator Cannot be used to calculate the doses at 2, (86-18-25):
5, and 10 miles reau. ired by procedures ER 1.5 and 2.2.
Item E of Emergency Plan pgs. A-l and A-2 should be (56-1S-26):
.
icentified as a ron-delegable function.
A ( BE-}S-27 ):
The listing of primary and alternate staf f * ng ir Appendix I
o' the Plan is not consistent with ER-2 1 (e.g. SED).
(if-18-28): Revise EP-l.} and FSAR to be consistent with E Ats of N'JR E 5- C L 54.
l
-
..
- _
l t -
.
'
9 (86-18-29): Implement site Security Plan.
(86-18-30): Complete security training for station personnel.
(86-18-31): Verify that all letters-of-agreement are current.
(86-18-32):
Complete the orientation and off-site training program for New Hampshire and Massachusetts state and local officials. I (86-18-33): Complete installation and testing of PEAS sirens. 1 Complete installation of the Post Accident Sampling System
<%'( 86- 18-3 4 ) :
,
6. Exit interview At the conclusion of the inspection on March 28, 1986, the inspector met with representatives of the licensee (see detail 1 for attendees) to discuss the findings of this inspection as detailed in this report.
At no time during this inspection was any written material provided to the licensee.
!
i
.
l
-
l
.
.