IR 05000443/1986018
| ML20198E477 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/15/1986 |
| From: | Lazarus W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20198E468 | List: |
| References | |
| 50-443-86-18, NUDOCS 8605280024 | |
| Download: ML20198E477 (32) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report N /86-18 Docket N License No. CPPR-125 Priority Category B-1
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Licensee: Public Service of New Hampshire P. O. Box 330 Manchester, New Hampshire 03105 Facility Name: Seabrook Unit 1 Inspection At: Seabrook, New Hampshire Inspection Conducted: March 24-28, 1986 Inspectors: -
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W. g rus, y nior EP Specialist ~ date W. Thomas, EP Specialist C. Amato, EP Specialist C. Gordon, EP Specialist J. Hawxhurst, EP Specialist G. Bryan, COMEX Corporation i
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G. Wehmann, Battelle PNL .
Approved by: e m/
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f /4 W. Igj/arus,@ ting Chief, Emergency date '
Preparedness Section Inspection Summary: Inspection on March 24-28, 1986 (Report No. 86-18)
Areas Inspected: Emergency Preparedness Implementation Appraisal to evaluate the adequacy and effectiveness of the emergency preparedness program for Seabrook Unit 1, including organization, administration, procedures, training-and facilities and equipmen Results: No violations were identified. Several program areas were identified which are incomplete or require corrective action, these are listed as open items, and will need to be addressed by the licensee and reinspected in a sub-sequent 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 licens e60515 PDR ADOCK 05000443 L ~
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DETAILS Persons Contacted A. Callendrello, Emergency Preparedness Supervisor P. Casey, Senior Emergency Planner
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- 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, health physics, administrative and training personne * Denotes those present at the exit intervie . Scope of Appraisal The purpose of this appraisal was to determine the readiness of the Seabrook Station to implement the Emergency Plan in preparation for licensing. The principal criteria for this appraisal are contained in NUREG-0654, " Criteria for Preparation and Evaluation of Radiological
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Emergency Response Plans and Preparedness in Support of Nuclear Power
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Emergency Response Plans and Preparedness in Support of Nuclear Power i Plants", 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 offsite groups, and drills, exercises and walk-throughs.
. Summary of Results The appraisal was completed during this inspection. Several emergency preparedness program areas under review remain incomplete or require corrective action. This report documents the followup of the areas for
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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 identifie Those items which need to be addressed for resolution as a result of this inspection are listed as "open items" in each details.section, an~d'are summarized in detail 6, at the end of this report.~
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4. Details Administration of the Emergency Plan (1) Assignment of Responsibilities and Authority Previous Inspection _ Findings
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(Closed) IFI (50-443/85-32-01): Develop job specifications for the Emergency Preparedness Supervisor and the second Senior
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Emergency Planne The inspector reviewed the approved job specifications for both positions and found them to be acceptable. In addition the qualifications of the individual who had been hired as of the second Senior Emergency Planner were reviewed. It was determined that the education and' experience requirements of ANSI N-18.7 were me (2) Coordination of EP Functions (0 pen) IFI (50-443/85-32-02): Define and document the inter-action between the corporate EP staff and the station staf Action on this item has not been completed. The_ licensee is planning several changes to strengthen the EP staff organization in the near future. Action in this area will be evaluated during a subsequent inspectio Except as noted in (2) above, this area was found to be acceptabl Station Emergency Organization (1) Onsite Organization Previous inspection findings (Closed) IFI (50-443/85-32-03): Develop a comprehensive organi-zation chart which describes overall command, control, and information flow for emergency response facilities and each major element of the augmented organizatio The licensee has developed a series of organization charts which describe the overall command, control, and information flow for the emergency response facilities and each major element of the augmented organization. This was determined to be acceptable in lieu of a single integrated organization char (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 accordingl .
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The responsibility to perform initial dose assessment is assigned to the shift superintendent or a trained alternate in 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 this regard will be verified in a subsequent inspectio (2) Augmentation of Onsite Emergency Organization
_ Previous Inspection Findings (Closed) IFI (50-443/85-32-05): Identify authorities and responsibilities of the Response Manager that may not be delegated. This item was closed with the publication of FSAR Amendment 57 which adequately identified the authorities and responsibilities of the Response Manage (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 people will be trained and qualified for each of the key positions prior to issuance of a full power licens (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
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a letter of agreement for backup ambulance services with the Seabrook Fire Department needs to be complete C. Control Room Operator Walk-throughs Previous Inspection Findings The previous inspection findings in this area requiring followup were jointly identified as item (50-443/85-32-13). For ease of tracking, a suffix consistent with the original subparagraph of each item is being added to this numbe During the previous inspection, 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:
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(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 notifi-cation and within one hou This item had not yet been addressed by the licensee and will be reviewed in a subsequent inspectio (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 -
correcte (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-tion (also via the state, local agency notification). This form does not contain information necessary regarding whether a release is taking place (NUREG 0654 II.E3).
This item had not yet been addressed by the licensee and will be reviewed in a subsequent inspectio (Open) IFI (50-443/85-32-14d): None of the crews was able to accom-plish the dose assessment problem postulated. That function is assigned to the 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 projection was not availabl (NUREG-0654 II.0 and II.1).
The inspector verified that the HP41CV calculators had been issued and that crews had been trained in their use, however, it was determined that the HP41CV program is only designed for dose calcu-lation at the site boundar Further, the information derived is only used for accident classi-fication purposes, not for making protective action recommendation 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 personne The licensee is evaluating this item for corrective actions. This will be reviewed in a subsequent inspectio (Closed) IFI (50-443/85-32-14e) 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 which is contained and controlled and l potentially affects safety systems would be classified as an Alert; i I
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and, an uncontrolled uncontained fire affecting safety systems would be classified as a Site Area Emergency. This is contrary to the guidance of NUREG 0654, App. 1, which states that, any fire poten-tially affecting 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-anc (Closed) IFI (50-443/85-32-14f): Errors in classification of accident
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conditions. Walk-through examinations were conducted with two crews during this inspection, following increased training in this are The training in this area resulted in a noticeable improvement in performance in this area. This area was found to be acceptabl (Closed) IFI (50-443/85-32-14g): Shift crews were unable to identify source material for evacuation time estimates (ETE). After further evaluation it was determined that knowledge of source material for ETE studies would not normally be expected of control room crew This item is close (0 pen) IFI (50-443/85-32-14h): Shift crews were unable to properly evaluate the static condition of 20,000 R/hr containment dome monitor reading (with the containment intact). Specifically they were unsure of whether a release would be in progress and whether EPA protective action guidelines would be exceeded at the site boundar This item was not specifically readdressed during this inspection, but will be reviewed during a subsequent evaluation of operator training in this are (0 pen) IFI (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 completed. This will be reviewed in a subsequent inspectio D. Emergency Plan Training and Retraining (1) Previous Inspection 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 belo (Closed) IFI (50-443/85-32-15a) Complete and implement the Emergency Plan Training Manua . . . .. ___
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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 SORC on March 2, 1986. Following review of the Manual, the inspectors con- '
cluded that it meets the requirements for establishment of an acceptable Emergency Preparedness training program. Training, continuing training, and requalification requirements are specified. Attendance, exemption, and documentation policies 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-ing for operators licensed per 10 CFR 55. That training is described under the separate training programs for Security and licensed operators respectively. The inspector had no further questions in this are (0 pen) IFI (50-443/85-32-15b): Specify the initial qualifica-tion criteria for selection of personnel to the positions in the Emergency Response Organizatio Criteria for assignment to Fmergency Response Organization (ERO)
positions are based or, operational assignments and qualifica-tions. A listing of the association of operational assignment to ERO position was reviewed by the inspectors; such a listing
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is not now included in Appendix A, Amendment 55, to the FSAR
"Seabrook Radiological Emergency Plan." The inspectors were advised that these criteria would be included in Amendment 58 to
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the FSAR now in preparation. This item remains open until the amendment is submitted and reviewe (Closed) IFI (50-443/85-32-15c): Lesson modules required by ER 8.2 have not all been prepared and implemented.
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The inspector verified that all thirteen training modules required for training of onsite personnel have been reviewed and approved.
! (0 pen) IFI (50-443/85-32-15d) EP training instructors do not meet the requirements of ANSI /ANS- The inspectors reviewed the SORC approved General and Speciality Training Program Manual dated March 27, 1986 and concluded that the emergency preparedness instructor qualifications listed
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(Section 5.1, page 2-5) are incomplete. There are no provisions
! for education requirements (A, AS, BS etc. in an appropriate discipline); practical experience in reactor operations and/or health physics. Seven reading assignments are listed plus a
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requirement to observe a full participation exercise. The reading requirements are appropriate, but should be extended to discussion and examination to verify knowledge level. Specifics 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.
i (Closed) IFI (50-443/85-32-15e): Revise Emergency Support Group
- training modules to stress the expected role of each specialty group. Following further review, it was determined that the
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?~ ~ emphasis of the present training modules is appropriat ; (Closed) IFI (50-443/85-32-15f): Assure that methods for train-
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ing personnel in changes to procedures and equipment are similar to methods used for the basic qualification program.
The inspector verified that this concern is adequately addressed by the descriptions in Section 1.3.2 and 1.3.7 of the approved j General and Specialty Training Program Manua (Closed) IFI (50-443/85-32-15g): Assure an adequate number 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 follcwing implementation of the Emergency Pla This item is closed administrative 1y as it is a duplicate of
, the concern being tracked under item number (50-443/85-32-06).
! (2) Current Inspection Findings i
" 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 position are
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- sibilities may not be delegated. This listing should be revised to indicate responsibilities which may not be i
delegated for all assignees (50-433/86-18-01).
I The Security Officers Lesson Plan which addresses protec-i tive actions does not address the use of-KI as a protective 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 KI (50-433/86-18-02).
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. 9 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). Section 4.2.64 of the General and Specialty Training Program Manual lists Course S65, " Mitigating the Conse-quence of Core Damage." Two levels of management are
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targeted for this training which pertains to EP. Since managers will, in general, fill key ERO positions, this course should 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. Offsite Dose Assessment Walk-throughs The inspectors requested that all personnel trained in refined dose as-sessment (METPAC) participate in a table-top discussion to determine the effectiveness of EP trainin The refined dose assessment calculations according to the Seabrook Plan are performed 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 Coordinator, who assesses the offsite radiological consequences and determines protective action recommendations (PARS). The Dose Assessment Specialist determines 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 the refined dispersion model. The METPAC operator and the sample analysis personnel, although an integral part of the assessment capability, as demonstrated in the February 24,198o exercise and walk-throughs, are not described in the Seabrook Plan (50-443/86-18-05).
The same table top exercise scenario was used for each of the two team The following observations were mad Procedure ER-1.4 does not provide for (or permit) any protective action recommendations (PAR) unless a General Emergency has been declared. Both crews felt that conditions warranted a precautionary PAR, however were reluctant to make a recommendation because they were in a Site Area Emergency. This has apparently been reinforced by training. The licensee recognizes the advantage of being able to make a PAR prior to a General Emergency and is evaluating possible changes to their procedures and training (50-423/86-18-06).
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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 uti/cc dose equivalent iodin 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 inspectio F. Facilities and Equipment (1) Emergency Operations Facility Previous Inspection Findings
! (Closed) IFI (50-443/85-32-16): Completely describe EOF ,
equipment 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- ,
(Closed) IFI (50-443/85-32-17): Complete the installation of EOF equipment. An inspection of the EOF, and observations made during the February 26, 1986 exercise confirmed that the neces-i sary equipment is installed and operational.
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- (Closed) IFI (50-443/85-32-08)
- Assure that all dedicated emergency equipment (specified in procedure ER-8.1) located at the EOF is maintained in operable condition. During the ap-praisal an inspection was conducted of the dedicated emergency equipment located in the EOF. All equipment was determined to be operable. A program has been instituted to perform inven-tories and checks to assure continued operability.
- (2) Media Center (Emergency News Center)
- Previous Inspection Findings
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(0 pen) IFI (50-443/85-32-18): Complete the details of the facility, equipment and organization for the Media Center. The j details for the Media Center facility and equipment are complete and contained in ER- The Media Center policy and procedures are still in draft, Except as noted above this area is acceptable.
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(3) Meteorological Instrumentation 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 FSA The licensee stated that the FSAR will be revised to reflect the full meteorological monitoring program by June 1, 1986. A two step approach will provide for an interim data acquisition system prior to full availability of the plant process computer for total data handlin (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 buildin The licensee stated that a meteorologist familiar with the site will be available, during all emergencies. The duties and responsibilities will be further delineated in the Yankee Mutual Assistance Plan. This individual will have access to all local National Weather Service data and knowledge of the parameters needed by the radiological emergency response staff. This also will be addressed by the June 7, 1986 revision. The licensee is still evaluating methods to provide backup power to the meteorological instrumentatio (0 pen) (50-443/85-32-21): Provide a method of severe weather notification to the control roo A policy document is currently bring drafted which will specify the load dispatcher as providing severe weather notification to the control roo (0 pen) (50-443/85-32-22): Implement T.S. 6.9.2 surveillance requirements for the meteorological monitoring program. Opera-tors will perform the daily operability checks on the meteoro-logical monitoring system when the Technical Specification ere required to be followed, at licensing. The inspectors will verify that appropriate surveillance procedures are writte (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 ite . - _ - .- - . --
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(0 pen) (50-443/85-32-24) Provide the basic data required for
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atmospheric dispersion calculations (15 minute averages), which includes a time history (analog or digital printout) of wind direction and speed at each level and temperature difference
. with height in the control room and EO The inspector held discussions with licensee personnel and found that the data acquisition system currently in place will i be modified on an interim basis to provide the necessary
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meteorological data to onsite personnel. Future plans will
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include use of the plant process computer to provide the basic
parameters to the Control Room, TSC and EOF. The licensee will provide a full description of the program and implement the
- interim system prior to fuel loa Except as noted above this area is acceptabl (4) Non-Radiation Process Monitors The station non-radiation process monitoring system indications provided from various plant sensors include reactor coolant system
, pressure and temperature, secondary side steam pressure, status and
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function of various plant equipment components, and fire and com-bustible detector The inspector verified that the process monitoring system component installation and testing had been completed prior to_ hot functional i testing. The entire system is operational and adequate for opera-j tions under emergency condition (5) Area and Process Radiation Monitors i
The area and process radiation monitoring system (Radiation Data Management System (RDMS) is a microprocessor based acquisition and display system with readouts locally, in the Control Room, and in the
! Operations Support Center (OSC). The various parameters measured include general area radiation, process radioactivity levels, air-borne contamination levels, and effluent radioactivity levels. The system provides plant operators with warnings of accident conditions, and the capability of continual accident assessmen The RDMS installation is complete. Turnover from cor.struction and acceptance testing is in progress. Calibration ci instrumentation and final acceptance and operational testing is projected to be
- complete by June 15, 198 As a result of this inspection it was determined that this item will remain open pending review of final acceptance, calibration and operational testing data concerning the RDMS (50-443/86-18-08).
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(6) Respiratory Protection Previous Inspection Findings -
(0 pen) IFI (50-443/85-32-09): Implement the respiratory protection program and assure that adequate supplies of respiratory protection equipment are maintained at the onsite assembly areas for emergency workers. The respiratory protection program has not been fully implemented. All required respiratory protection equipment is in place in the emergency response facilities, except for the equipment to refill air bottles onsit SCBA training, respirator use training, and medical certification is expected to be completed by May 31, 198 The TSC and OSC both contained air purifying respirators and canis-ters as well as SCBAs reserved for emergency use only. Both the TSC and OSC contained an adequate supply of full face respirators and SCBAs for use during emergencies. An adequate number of spare bot-ties was present for use. Additional bottles would be available onsite from the air compressor-cascade refill facility, which is being installed onsit The air compressor-cascade equipment has been received onsite, however, installation is not expected to be completed prior to June 1, 1986. The compressor building will be located within the protected area near the constructirn building and should be useable under accident condition As a result of this inspection it was determined that in order to assure an adequate respiratory protection program the respirator bottle refill facility should be completed and the 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 inspectio (7) Communications Equipment The inspector reviewed Section 70 of the NHY Emergency Plan, Rev. 55 on Communications, held discussions with licensee personnel and visited the emergency response facilitie The emergency communication system was reviewed against the commit-ments made in the Emergency Pla The inspectors witnessed testing of the communication system during the December 21, 1985 emergency drill and February 24, 1986 full-scale emergency exercise. The system as described in the emergency plan is functional except for the ENS. A dedicated telephone line is in use in place of the EN This is acceptable until the ENS is installed. The licensee has identified several problem areas. The internal public address system speakers in some areas are inaudibl , I e
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This was due in most cases to persons tampering with the speaker or internal volume control adjustment. A system has been established to track and correct problems in this are The licensee has a survei,llance procedure, ER-8.1, which requires periodic inspection of communications systems and equipmen Procedures ER-8.1 and ER-8,5 establish responsibilities for performance of the surveillanc During the exercise on February 26,1986,~kheNuclearalertsystem (orange phone) was used, providing direct' interfaces with the Mas-sachusetts and New Hampshire State Polic At the time of the inspection', the installation of the sirens which comprise a portion of the Public Emergency Alerting System, had not been completed. This area will be reviewed in a subsequent inspec-tion (50-443/86-18-33).
Except as noted above, his area was found to be acceptabl (8) Medical Treatment Facilities Previous Inspection Findings (0 pen) IFI (50-443/85-32-10): Complete and equip the first aid treatment facility to allow treatment of contaminated / injured personnel. The first aid treatment facility equipment has t een ordered but has not yet been received. This will be reviewed in a subsequent inspectio >
J (Closed) IFI (50-443/85-32-11): Assign a full time nurse onsite as described in the Emergency Plan. A full time nurse joined the Seabrook Station at the beginning of the calendar yea (0 pen) IFI (50-443/85-32-12) (50-443/85-32-13): Ensure that arrangements for transportation of onsite contaminated / injured personnel are permanently available and clearly described in plans / procedures, including equipment and supplies for contamination control This item remains open pending t aining for the offsite ambulance personnel and negotiation of a letter
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of agreement with the Seabrook Fire Department which will be
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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 10-9 of the Emergency Plan has been receive In addition, the procedure for decontamination of contaminated / injured personnel (ER4.4) is
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being revised. A full-time nurse has been appointed and is available during daytime working hours. When completed and fully equipped, the medical treatment facility will be adequate to treat radioactively contaminated and injured personne In addition to completing the installation of equipment noted in a., above, the following items were identified and will be reviewed in a subsequent inspectio Complete the revision to ER-4.4 "Onsite Medical Emergency" (50-443/86-18-9).
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Complete and implement the Exeter Hospital Radiological Procedure Manual for treating contaminated injured pa-tient (50-443/86-18-10)
A medical emergency drill will be observed in a subsequent inspection, to assess the capabilities in this are ( 9) Operations Support Center The GSC is located on the first floor of the Administration and Service Building. The OSC is included in the station emergency communications network. The OSC does not have any special radiation shielding or air filtration system If conditions warrant, the OSC staff would relocate to the TSC. The OSC facility is established as described in EP-6.0, Section 6.1.2 and as shown in Figure Dedicated emergency equipment is maintained at the OSC. This equip-ment is identified and serviced in accordance with EP-8.1. Acti-vation and operation of the OSC is documented in EP-3.2, Revision Based on the above, this area is acceptabl (10) Emergency Kits and Survey Instrumentation Emergency kits and emergency survey instrumentation are maintained at the following locations: TSC, OSC, Rte. 107 Warehouse, EOF and the Exeter Hospital. The emergency equipment maintained at each of these locations is identified in Procedure ER-8.1 This procedure provides for routine inventory checks of all emergency equipment. When ap-propriate, operational and calibration checks are routinely per-formed. All such checks are documented. Equipment to be used by re-entry teams has the capability for the detection and measurement of both beta and gamma radiation. The emergency kits contained sufficient instruments /supalies to adequately support re-entry team In plant capability for de ceting airborne iodine in the presence of noble gases is provide Instrumentation capable of distinguishing beta / gamma is availabl ...-.-g -. -_ - - -
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, '(11) Protective Clothing
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Stores of protective clothing reserved for emergency use are main-
.tained at the TSC, OSC, Rte. 107. Warehouse, EOF and the Exeter Hos-pital. This equipment is periodically-inventorted and is accessible under emergency conditions.
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Based on the above, this area is acceptabl ' ~
(12) Reserve Supplies The licensee maintains an onsite inventory of emergency supplies and equipment in addition to that dedicated.specifically-for emergencie In addition, the licensee has the ability to obtain additional sup-plies from offsite through the Yankea:Matual Assistance Pla ,
. Equipment available through this plan includes:
.a) Mobile Laboratory Emergenby Analysis Equipment and' Van Service b) Mobile TLD Van Service s
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-c) . Mobile Body Burden Van Servics,.and
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Field environmental radiation' surveillance equipment (and personnel).
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The licensee maintains a minimum stock level to insure an adequat <
reserve of normal,! supplies to handle emergency situation Based on the above, this area is acceptable.' .
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(13) Transportation -
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The licensee,has identified eight (8) vehicles for use in the event of an emergency. Four,of these vehicles have fixed mobile 100 watt VHF mobile radios tuned to the Health 0Prysics frequency. The other four vehicles can be equipped with conversion kits that boost the
, transmitting power of portable radios from 5 to'100 watt Security procedures provide for the delivery of three of the vehicles to the EOF for use by the field radiological monitoring teams. Ambulance and fire vehicles are provided by the Seabrook Fire Department. I t .- '
appears that the size and type of vehicles reserved by the licensee for emergency use is adequat ,
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Based on the above, this area is acceptabl . .
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. 17 i (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 10 CFR 50, '
NR-0654, NR-0696, NR-0737 Sup. 1, and RG-1.97. The inspector also observed the control room as an emergency response facility (ERF)
during the February 26, 1986 observed exercis Based on this review, it was determined that the control room met the guidance concerning equipment, decisional aids, and habitabilit (15) Technical Support Center The inspector toured the facility and observed it in operation during a utility sponsored exercise in December 1985 and again, during the February 26, 1986 observed exercise, to verify that the guidance NUREGs 0696 and 0654 was met and that operation was in accordance with the appropriate EPIP' Based on this review it was determined that the TSC is within the Control Room habitability envelope and is thus served by the same filtered 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. seismic, rad, etc.) which is not yet complete. This item will be reviewed in a subsequent inspection (50-443/86-18-11).
(16) Post Accident Sampling System At the time of this inspection the installation of the Post Accident'
Sampling System (PASS) had not been completed. This area will be reviewed in a subsequent inspection (50-443/86-18-34).
G. Emergency 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 contained in HD0958.02,
" Radiation and Contamination Survey Techniques", and HD0958.03,
" Personnel Decontamination Techniques". ER-4.6, "Offsite Monitoring and Decontamination", contained instructions for assembly and 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.
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. 18 These procedures provided 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 radioisotope Action levels requiring further assessment by the health physics staff and the followup actions required were delegated to the Radio-logical Controls Coordinato Copies of monitoring and decontami-nation procedures were available at the onsite decontamination facility, at the Route 107 warehouse, and at the EO It was determined from the review that adequate procedures existed to facilitate personnel monitoring and decontamination under emer-gency conditions.
l (2) Evacuation of Owner Controlled Areas l
The inspector reviewed EPIP ER-4.1, Personnel Evacuation, to deter-
, mine compliance with NUREG-0654 requirements.
i
! ER-4.1 Section 4.0 contains prerequisites for evacuation of the site, I 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 contained 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 respectivel As a result of this inspection it was determined that the applicant's procedure for personnel evacuation of owner controlled areas accept-able to control operations under emergency condition (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 manne The procedure specifies that the Security Supervisor implements the accountability process and reports accountability results to the Short Term Emergency Director (Shift Supervisor) or Technical Services Coordinator. The procedure establishes a thirty minute goal for completion of accountability and contains provisions for continuous accountability of all persons onsite after initial accountability has been complete . _ _ . . . , .
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, 19
i 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 not functional. The total security i
program is scheduled to be implemented by May 15, 1986, at which
, time the card readers will be operational. The security computer
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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 Rescu ER-4.5 is not referenced or referred to in ER- 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 accountabilit The i plant accountability procedure ER-4.2 should also reference ER-4.5,
! Search and Rescue. This item will be reviewed in a subsequent
! inspection (50-443/86-18-12).
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) (4) Off-site Radiological Surveys a
Procedure ER-5.2, " Site Perimeter and Off-site Monitoring and
) Environmental Sampling", identifies the methods and equipment to be used 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 progra Emergency supplies collected by off-site sampling teams are to be analyzed by either the Yankee Nuclear Services Division Environmental Laboratory or the Seabrook i Mobile Environmental Laboratory. A walk-through with one of the three field monitoring teams was conducted during a full-scale emergency preparedness drill held on December 12, 1985. Dedicated
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vehicles equipped with 100 watt mobile radios and monitoring kits l are available to field three monitoring teams. The procedure does
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not provide the field teams with instructions for communication with >
the E0F in the event of. loss of the mobile radio capability.
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Based on the above the following items need to be addressed in this area:
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Provide procedures for a back-up means of communications in the event of radio failure (50-443/86-18-13).
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Include specific instructions to the Off-site Monitoring i
Coordinator regarding the use of respiratory equipment and
! the administration of KI by the field monitoring teams for protection from airborne hazards (50-443/86-18-14).
! Except as noted above, this area is acceptabl i l
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.. 20 (5) On-site (Out-of-Plant) Radiological Surveys The inspector reviewed procedures ER-4.3, Rev. 02, " Radiation Pro-tection During Emergency Conditions", and ER-5.2, Rev. 04, " Site Perimeter and Off-site Monitoring and Environmental Sampling".
i The inspector identified that there was no emergency procedure de-scribing the method and equipment to be used to perform onsite (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 During Emergencies Procedure ER-4.3, Rev. 02, " Radiation Protection During Emergencies"
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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:
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a) OSC Activities
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b) Protective Area Radiation Surveillance and Control c) In plant Surveillance and Control
d) MPC-hour Accountability e) Dose Assessment and Exposure Trackin The Radiological Controls Coordinator is assigned the responsibility for ensuring station emergency exposure control measure Based on the above, this area is acceptabl (7) Repair and Corrective Actions Procedure ER-7.1, " Emergency Repair and Corrective Action", Rev. 01, provides instructions for emergency repair and corrective action The responsibilities of-the Technical Service Coordinator, the Maintenance Coordinator and the OSC Coordinator are defined. The
! procedure describes the concept of the operations for repair or corrective action activities. The Radiological Controls-Coordinator is required to provide health physics support to team members. This support includes; a) expected doses, b) Required protective equipment including KI, c) Dosimetry required, d) Authorized dose, e) Respiratory hazards, and, f) Radiological control Based on the above, this area is acceptable.
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. 21 (8) Recovery Procedures ER-8.7, " Recovery Organization" and ER-7.3, "Re-entry and
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Recovery", were reviewed. . Organizational authority for declaring that a recovery phase is to be entered is included in the procedur Radiological conditions as well as plant operating l'
conditions are evaluated befcre terminating an emergency and entry into a recovery mode. Procedure ER-8.7 requires the agreement of j the authorities of Massachusetts and New Hampshire, federal authorities, and the Response Manager before an emergency condition can be terminate ~ ~ ~ ~ ~
Based on the above, this area is acceptabl (9) Inventory, Operational Check, and Calibration of Emergency Equipment Procedure ER-8.1, " Emergency Equipment and Facility Inventory and Preparedness Check", provides a specific inventory listing of all equipment reserved for use during emergencies. The specific location of the equipment is provided. An emergency equipment inventory and operational check is performed when any of the following occur:
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the emergency equipment has been used;
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at scheduled quarterly intervals, or
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if a seal on an emergency kit or locker has been broke The scheduled quarterly inspection includes an inventory check, and when appropriate, operational checks are performed. The results of each inventory are documented and the results reported to the Radio-logical Assessment Manager. Health physics equipment calibration and maintenance scheduled in accordance with HD-0963.02 regulate the frequency of inspection of dedicated radiological equipment / supplie The Radiological Assessment Manager is responsible for ensuring the
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inspection, inventory, and operational checking of emergency equip-ment and facilitie Based on the above, this area is acceptabl (10) Emergency Kits and Emergency Survey Instrumentation A walk through was conducted of the Control Room, TSC, OSC, Rte. 107 warehouse and E0F for the purpose of verifying that the dedicated emergency facility / equipment identified in the following procedures was in the assigned locatio EP-6.0, " Emergency Facilities"
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. 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 response facil-ities. No discrepancies were identifie Based on the above, this area is acceptabl (11) Public Information The inspector reviewed section 11.3 of the NHY Emergency Plan, Re , on Public Information, also draft brochures, calendars, telephone book inserts and poster 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:
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provisions were described for yearly dissemination to the-public with the EPZ; i
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that the materials contain basic emergency planning information and general information as to the nature and effects of radiation;
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measures are taken to provide information to the transient population;
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materials and information provided to the public are coordinated with State and local government agencies, and;
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that the information provided also contains evacuation routes, sheltering directions and actions to be taken when alerte Based on this review it was determined that the public information section in the Emergency plan describes the bases for the progra NHY has stated that they will provide, annually, emergency planning materials to each resident, school, hospital and nursing home within the EPZ. The inspector noted the draft materials for residence ;
(brochures and calendars) provide the general information on the nature and effects of radiation. Also, in the draft material are the Emergency Radio Broadcast stations, information on how to-shelter, and how the residents will be notified. However, evacuation routes have not been finalize ,
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. 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 EPZ) 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) for the
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persons on the beaches within the EP Other methods the licensee plans to use for the initial distribution of emergency planning information are newspaper and radio advertis-
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ing. This is planned to be done concurrently with the mailing of brochures. Telephone directory advertising will be included in the '
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1986 Portsmouth white pages and the 1987 Newburyport and Haverhill white page At present this information has not been distributed to residents in It is understood that the final details will have to be
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the EP 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 information as to what to do if sirens are activated, where to receive additional information, etc.
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(50-443/86-18-16). The final brochures will be distributed prior to receiving a full power license (50-443/86-18-17). The information
, contained in these brochures will also receive evaluation by FEMA as part of the off site plant reviews.
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(12) Drills and Exercises
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The inspector reviewed procedure ER-8.3, " Emergency Preparedness Drills and Exercises", Rev. 1, which defines the program for the conduct and evaluation of emergency drills and exercises to verify that drills and exercises are properly planned and coordinated to
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meet the training requirements of 10 CFR 50 Appendix E. In addition a schedule of drills was reviewed to verify that the various emer- "
gency response areas would be adequately exercise The overall coordination of the drill and exercise. program is the responsibility of the Radiological Assessment Manager. The Training Manager coordinates scheduling of the exercises with the Radiological; Assessment Manager, and ensures that they are conducted as schedule A tracking system has been developed to track drill / exercise deficiencies and to ensure that appropriate corrective action is j take This area was determined to be acceptable.
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- 24
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(13) Audits
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The inspector reviewed Chapter 18 of the QA Manual which defines the Operational QA audit requirements. One of the requirements is to
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prepare an annual audit schedule which includes (among others) the-i activities of section 6.5.2 of the Technical Specifications. A re-view of the draft Technical Specifications indicates that the appro-priate reference is section 6.4.2, not 6. It was also determined Emergency Preparedness was not included in the list of activitie 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 subsequent
] inspection (50-443/86-18-18).
(14) Review, Revision, and Distribution of the Emergency Plan
)]
The inspector reviewed the Document Control Center organization and functional responsibilities section of the Nuclear Production De-
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partment Records Manual, compared it with NUREG-0654 elements P.4, P.5, and P.10, and toured the Document Control Center facilitie The inspector determined that Emergency Plan Implementing Procedure telephone numbers are reviewed quarterly. The rasponsibility for review is assigned to the Sr. Emergency Planner. Changes to the
Plan and Implementing Procedures are required to be approved by the Station Operations Review Committee (S.0.R.C.). The Plan and
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Procedures were current and distribution was in accordance with the approved distribution list. The names, titles, and telephone numbers of selected procedures were verified to be correc 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, j
(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 taken in the event treatment of contaminated /
injured individuals is necessary. The. procedure includes provisions for receiving, recovering, transporting, and handling persons who may become radioactively contaminated onsite and provides for radio-logical controls offsite. However, discussions with NH Yankee health
, physics personnel indicated that procedure ER-4.4 was being revised in its entirety (50-443/86-18-09). It was also identified that the
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. 25 Radiological Procedure Manual for Exeter Hospital (where contami-nated/ injured personnel are treated) was incomplete (50-443/86-18-10).
Facilities, equipment, supplies, and other arrangements necessary for the applicant to implement this procedure were also incomplete at the time of this inspectio (See para. F.8)
Except as noted above, this area is acceptabl (16) Emergency, Alarm, & Abnormal Procedures The inspector reviewed chapter 5 of the Emergency Plan, the Seabrook
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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 1.3 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 procedures is expected in the near future, and action in this regard will be reviewed in a subsequent inspection (86-443/86-18-19).
Operators have been trained in these draft procedures, however a final training effort for all operators after the procedures are formally promulgated will be necessary. This area will be reviewed in a subsequent inspection (50-443/86-18-20).
(17) Implementing Procedures The inspector reviewed Seabrook EPIPs ER-1.2 through 1.5, the pro-cedures for Notification of Unusual Event through General Emergency, and compared them with guidance from NUREG-0654. Based on this review it was identified that: Initial notification forms and some of the followup notification forms incorrectly allow the EOF Coordinator to sign, authorizing notification. This authority cannot be delegated to the EOF coordinato (NUREG-0654 II B 4) (50-443/86-18-21). The followup notification forms found in ERs 1.2 through et al do not:
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indicate type of release (airborne, waterborne) (NUREG-0654 II E 4 0),
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Project integrated dose at the site boundary (NUREG-0654 II E 4 H),
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. 26
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Project dose rate and integrated dose at 10 miles (NUREG-0654 II E 4 I), (50-443/86-18-22). Revise ER-1.3 fig. 1 paragraph 13 to add the on shift HP tech as an alternate advisor to be consistent with ER- paragraph 5.3.3 (50-443/86-18-26), Procedure ER-1.4 contains the following errors:
The instructions to the SED concerning selection of evacuation i alternatives as a function of wind direction appear to be in error. At present, for winds from 080 through 180, the dog track is the designated site. It is located generally downwind for winds from that sector (50-443/86-18-24).
- The caution after step 4 of figure 1 prohibits Protective
- Action Recommendations (PAR) during initial notification of declaration of a Site Area Emergency (SAE). There is no PAR block on the standard followup information sheet. In combin-ation, these items infer a prohibition against PARS at SA (This inference was confirmed during the E0F 'walkthroughs when
, the staff expressed the belief that they were prohibited from making a PAR if at SAE) (See paragraph F.)
' Steps 18-20 of form 2.28 (contained in ERs-1.5 and 2.2) require i
use of the HP-41 calculator to project dose at the site
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boundary, 2 miles, and 5 miles. This requirements cannot be met with the present HP-41 system and software. (See paragraph D.1, item 85-32-14d).
' Item E of the Emergency Plan pgs. A-1 and A-2 should be iden-tified as a non-delegable function (50-443/86-18-26).
l The listing of primary and alternate staffing in Appendix A of the Plan differs from that of procedure 2.1 (e.g. SEDs) (50-443/86-18-27).
(18) Assessment Actions The inspector reviewed applicable Seabrook emergency preparedness procedures, and Section 5 of the Emergency Plan. The inspector verified that assessment actions were consistent with the guidance of NUREG-0654 except as noted below:
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The operating shift has no dose projection capability (See paragraph D.1.)
I -
Procedural problems with the notification process are identified elsewhere (See paragraph G.17).
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. 27 (19) Classification Scheme Review:
Outside the scope of the EP Appraisal, but within the month prior to this inspection, the inspector completed two technical reviews of the Seabrook Emergency Plan EALs and procedure ER-1.1 under NRC Head-
, quarters sponsorship and met twice with the utility on that subjec It was identified that several differences existed between the-classification scheme shown in the Emergency Plan and that of proce-dure ER-1.1 (draft Rev. 4). The licensee has proposed satisfactory
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corrective action concerning these differences, by issuance of Revision 4 to ER-1.1 and Amendments 56 and 57 to the FSAR. This item will be closed following review of these changes (50-443/86-18-28).
(20) Security During Emergencies The inspector reviewed this area during a utility drill in December
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1985 and again during the exercise of February 26, 1986, and made the following observations:
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The protected area perimeter control system (fencing, E fields, badging, etc.) has not yet been established (50-443/86-18-29).
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Station personnel have not completed full scope General Employee
- Training nor has the EP training program been finalized and l completed in this area. Security training is a component of
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both (50-443/86-18-30).
i (21) Coordination with Offsite Groups The auditors reviewed Appendix E of the Emergency Plan (Letters of i Agreement with offsite agencies support personnel) and met with j representatives from six support groups to determine to what extent
, the program for coordinating emergency planning and response l activities with each group has been developed and implemented by the
applicant. Discussions were held with key response personnel from the towns of Exeter, NH, Kingston, NH, Brentwood, NH, Seabrook, NH, s West Newburg, Mass, Exeter Hospital, and Seabrook Greyhound tac All representatives expressed a clear understanding of their agency's role and responsibility in response to Seabrook emergencies. The inspectors found that arrangements for technical and administrative support at each facility were consistent with the language specified in letters of agreement with the exception the Seabrook Fire Depart-
, ment. Agreements or contracts between the applicant and each offsite group were either current or in the process of being updated with the exception of Exeter Hospital. Efforts made by the applicant to co-
- ordinate notifications and ' communications, emergency response train-
, ing, and , routine exchange of information are acceptable. Classroom I
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. 28 training of State and local groups in New Hampshire and Massachusetts remains incomplete. New Hampshire representatives had the oppor-
, tunity to participate in the full-scale emergency exercise held on February 26, 1986. In Massachusetts, no practical training (drills or walkthroughs) has been provided to response personnel. (See i
section 3). Controlled copies of the Seabrook Emergency Plan and
~; Procedures are maintained in local libraries for reference by local officials. Copies were not maintained at Exeter Hospital. Local i
town managers were familiar with the applicant's procedures as they j affect State and local response regarding notifications, communica- 1 i tions, and information flow from the site to them. Managers also
indicated that recommendations for protective measures which were 1
) agreed on by State and utility officials would be implemented at the ,
local level without delay immediately following communication of all critical informatio The individuals interviewed by the inspectors were identified as top level emergency response personnel of their respective organizations,
- i.e., Civil Defense Directors, Selectmen, hospital president, police chief, and fire chief. It was determined that the representatives
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are generally content with the applicant's effort for coordinating emergency preparedness issues, and Civil Defense (Emergency Operations
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Center) directors stated that the language contained in letters of agreement would be honore .
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Except as noted below, this area of the licensee's program is '
acceptable.
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The licensee should ensure that all letters of agreement are i
current, reviewed, and contain mutually acceptable language to
- all parties involved in each agreement (50-443-86-18-31).
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Complete the orientation and offsite training program for New Hampshire and Massachusetts State and local officials (training effectiveness will be evaluated by FEMA). (50-443/86-18-32).
, 5. Summary Listing of Open Items l
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 conclusion of this inspection. Except for. those items indicated by (*) all will be corrected prior to fuel loa Asterisked items will be corrected prior to issuance of a full power license.
t (85-32-02): Define and document the interaction between the corporate EP l staff and the station staff.
I (85-32-04): Assign the responsibility to perform initial dose assessment i
on shift'and revise Appendix A of the Emergency Plan accordingl .
. 29 4(85-32-06): Provide additional qualified alternates for key ERO positions to assure the ability to staff the augmented organization on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basi (85-32-07): Complete arrangements with offsite survey groups to ensure availability of offsite support during emergencie (85-32-09): Complete implementation of the respiratory protection program (training and air bottle refill capability).
(85-32-10): Complete installation of equipment in the First-Aid Facilit (85-32-12/13): Ensure that arrangement for transportation of onsite con-taminated/ injured personnel are made and described in plans and procedure (85-32-14a): Paragraph 3.2 (et al) of EPIP ER-2.2 is not consistent with the requirements of 10 CFR 50.72, in that it does not require notification of the NRC immediately after the state (s) and within one hou (85-32-14c): Form ER 2.2A, " Initial Notification Fact Sheet", does not contain provisions for recording or reporting whether a release is in progress (NUREG-0654 II.E.3).
(85-32-14d): No on-shift dose assessment capability is provide (85-32-14h): Shift operating crews were not aware of containment design leak rate specification (85-32-141): Shift operating crews were not aware of the capabilities of the Post Accident Sampling System (PASS).
(85-32-15b): Qualification criteria for assignment to positions in the Emergency Response Organization were not specifie (85-32-15d): EP training instructors do not meet the experience require-ments of ANSI /ANS- (85-32-18): Complete procedures which describe the equipment and organization of the Media Cente (85-32-19): Finalize the meteorological system design consistent with FSAR commitments, and revise description in the Emergency Pla (85-32-20): Provide for backup meteorological measurements representa-tive of conditions in the vicinity of the sit (85-32-21): Provide a method for notification of impending severe weather to the Control Room.
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. 30 (85-32-22): Implement surveillance program procedures for meteorological equipment (to be done concurrent with issuance of operating license). '
(85-32-23): Modify calibration procedure IX-1654.410 to reflect minimum required accuracy of delta-T instrumentation of 0.1 degrees centigrad (85-32-24): Provide for maintaining a historic record of basic data required for atmospheric dispersion calculation ~ ~ ~ -
(86-18-01): Emergency Plan, Chapter 5, Section 1, does not specify which responsibilities of ERO staff members may not be delegate (86-18-02): The Security Officers' Lesson Plan does not include discussion of the use of KI as a possible protective actio ,
(86-18-03): Periodic radiological retraining of the hospital staff has not been developed or schedule (86-18-04): Mitigation of core damage training is not required for the
! Response Manager, E0F Coordinator, Short Term Emergency Director, Site Emergency Director, or the Emergency Operations Manager.
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(86-18-05): METPAC Operator and sample analysis personnel are not described in the Emergency Plan as augmentation personne (86-18-06): Procedure ER-1.4 does not provide for (or allow) any protective action recommendations (PAR) to be made unless a General Emergency has been declare (86-18-07): The initial dose assessment model assumes no iodine in the releas (86-18-08): Complete operational testing and turnover of the Radiation Data Monitoring Syste (86-18-09): Complete the revision to ER-4.4, "Onsite Medical Emergency".
(86-18-10): Complete and implement the Exeter Hospital Radiological Procedure Manua (86-18-11): Installation of instrumentation in the TSC is not complete (NUREG-0654 II.H.5).
(86-18-12): Implement the station security program and demonstrate the ability to perform accountability of onsite personnel during an emergenc (86-18-13): Provide backup means of communication with off-site radiological teams in event of loss of radio communication i
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. 31 (86-18-14): Include specific instructions to Off-site Monitoring Coordinator regarding use of respiratory equipment and KI in procedure (86-18-15): Draft appropriate procedures for the performance of onsite (out-of plant) radiological survey (86-18-16): Distribute interim public information brochures, providing basic information concerning what action to take on siren activation, where to receive additional information, et * -~-
$(86-18-17): Distribute final detailed public information brochures
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describing all necessary emergency planning information for the public, including evacuation route (86-18-18): Revise T.S. 6.4.2 and implement the QA audit program for emergency preparednes (86-18-19): Promulgate final version of emergen y, alarm, and abnormal procedure (86-18-20): Train operators in the final versions of emergency, abnormal, and alarm procedure (86-18-21): Revise procedures ER-1.2-1.5 to reflect that the authority to authorize notification cannot be delegated to the E0F Coordinato (86-18-22): The Followup Notification Forms in procedures ER-1.2 through ER-1.5 do not include information regarding type of release, projected integrated dose at the site boundary, and projected dose rate or integrated dose at ten mile (86-18-23): ER-1.3, Figure 1, does not identify the on-shif t HP techni-cian as an alternate Advisor, to be consistent with ER- (86-18-24): Procedure ER-1.4 contains an error concerning the selection of evacuation alternatives as a function of wind direction...has evacua-tion to the dog track when wind is blowing toward the trac (86-18-25): HP 41 calculator cannot be used to calculate the doses at 2, 5, and 10 miles required by procedures ER-1.5 and (86-18-26): Item E of Emergency Plan pgs. A-1 and A-2 should be identified as a non-delegable functio (86-18-27): The listing of primary and alternate staffing in Appendix A of the Plan is not consistent with ER-2.1 (e.g. SED).
(86-18-28): Revise ER-1.1 and FSAR to be consistent with EALs of NUREG-065 .
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(86-18-29): Implement site Security Pla (86-18-30): Complete security training for station personne (86-18-31): Verify that all letters-of-agreement are curren (86-18-32): Complete the orientation and off-site training program for New Hampshire and Massachusetts state and local official (86-18-33): Complete installation and testing of PEAS siren JI(86-18-34): Complete installation of the Post Accident Sampling System 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 repor At no time during this inspection was any written material provided to the license .
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