IR 05000324/1985020

Insp Repts 50-324/85-20 & 50-325/85-20 on 850708-12.No Violations or Deviations Noted.Major Areas Inspected: Emergency Preparedness Exercise

ML20134N415
Person / Time
Site:	Brunswick
Issue date:	08/02/1985
From:	Cline W, Cunningham A, Postonbrown M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20134N397	List: IR 05000324/1985020 ML20134N394
References
50-324-85-20, 50-325-85-20, NUDOCS 8509050128
Download: ML20134N415 (13)

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m2 Kic UNITED STATES

/ o NUCLEAR REGULATORY COMMISSION

[ n REGION 11 3,

., j 101 MARIETTA STREET. e ATLANTA. GEORGI A 30323

% ,,,,,* AUG 2 61985 Report Nos.: 50-325/85-20 and 50-324/85-20

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licensee: Carolina Power and Light Company P. O. Box 1551 Raleigh, NC 27602 Docket Nos.: 50-325 and 50-324 License Nos.: DPR-71 and DPR-62 Facility Name: Brunswick 1 and 2 Inspection Co c Ju - -;f1985 Inspect rs: /![/ A b p %.~ Cunt 1ingham D#te Signed

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bb&t YL Xh1k4&TLWE YYW Date Yigned A. Poston-Brpwn /~

Accompanying Per;,onnel: G. W. Bethke R. Harty D. H. Schultz a Approved by: I / k N.' E.' Cline 4-Section Chief Date Signed Division of Radiation Safety and Safeguards SUMARY Scope: This routine, unannounced inspection entailed 234 inspector-hours onsite in the area of an emergency preparedness exercis Results: No violations or deviations were identifie k $ 4

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REPORT DETAILS

!. Persons Contacted Licensee Employees

• P. W. Howe, Vice President, Carolina Power and Light Company

• C. R. Dietz, General Manager, Brunswick Steam Electric Plant

• L. E. Boyer, Director, Administrative Support

• B E. Hinkley, Manager, Technical Support

• J. P. Dimmette, Assistant to Vice President

• L. G. Jones, Director Quality Assurance

• J. Oliver, Manager, Site Planning and Control

• A. Indelicato, Senior Specialist, Emergency Planning

• B. D. McFeaters, Project Scientist, Emergency Preparedness

• B. W. Morgan, Senior Specialist, Health Physics

• H. R. Goodwin, Senior Specialist, Emergency Preparedness

• A. Hegler, Radwaste Supervisor

• A. G. Cheatham, Manager, Environmental and Radiation Control Other licensee employees contacted included construction craftsmen, engineers, technicians, operators, mechanics, security force members, and office personne NRC Resident Inspectors

• H. Ruhland

• Attended exit interview Exit Interview The inspection scope and findings were summarized on July 11, 1985, with those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection finding No dissenting comments were received from the licensee. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspectio . Licensee Action on Previous Enforc'ement Matters

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(Closed) Violation 50-324/85-17-02, 50-325/84-17-02: Failure to provide for prompt issuance of sheltering recommendation at General Emergency. The inspector verified that corrective actions cited in the licensee's letter to NRC dated October 4, 1984, were implemented as define . Unresolved Items Unresolved items were not identified during the inspection.

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5. Exercise Scenario (82301) i The scenario for the emergency exercise was reviewed to assure that provisions were made to test the integrated capability and a major portion of the basic elements defined in the licensee's emergency plan and organiza-tion pursuant to 10 CFR 50.'47(b)(14), paragraph IV.F of Appendix E to 10 CFR 50, -and specific criteria defined in Section II.N of NUREG 0654, Revision The scenario was revised in advance of the scheduled exercise date and was discussed in detail with licensee representatives on June 18, 198 However, prior to conduct of the exercise, a portion of the scenario was inadvertently released to the news. media by offsite officials. As a result of this release of scenario information, the licensee had to make adjust-ments to the scenario during the week prior .to~ the exercise. No major problems with the scenario were identified; however, some inconsistencies did become apparent during the exercise. The inconsistencies did not result in a decrease in exercise performanc The- scenario developed for this exercise was detailed, and adequately exercised the onsite emergency organizations. The ' scenario also provided sufficient information to the State and local government agencies consistent with the scope of their participation in the exercis The licensee made adequate commitments to training and personnel through use of controllers, evaluators, and other required specialists participating in the exercis The controllers appeared to provide adequate ' guidance throughout the exercise; however, some prompting was observe No violations or deviations were identifie . Drill Scenario (82301)

Scenarios for the fire and medical emergency drills were reviewed to assure that provisions were made to test specific functions in the licensee's emergency plan pursuant to 10 CFR 50.47(b)(14), paragraph IV.F of Appendix E to 10 CFR 50, and specific criteria defined in~Section II.N of NUREG 065 The scenarios developed for the drills were detailed and adequately-l exercised the participating licensee organization and offsite local

! emergency agencies. The scenarios provided sufficient information to local l support agencies ' consistent with the scope of their participation in the j drill The licensee and offsite support agencies made a significant commitment to training and -personnel by use of controllers, evaluators, and specialists participating in . the drill The controllers provided adequate guidance throughout the drills. No significant problems were disclosed regarding the scenarios for the subject drill No violations or. deviations were identified.

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' Assignment of Responsibility (82301)

This area was ' observed to assure that primary responsibilities for emergency response by the licensee were specifically established, and that adequate

. staff -was available to respond to an emergency pursuant to 10 CFR 50.47(b)(1),- paragraph IV.A of Appendix E to 10 CFR 50, and specific criteria defined in Section II.A of NUREG 0654, Revision The inspectors observed that specific emergency assignments were made for the licensee's emergency response organization, and that adequate staff was

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available to respond to the simulated emergenc The initial response-organization was augmented by designated licensee representatives; however,-

because of the scenario scope and conditions, lung term or continuous staffing of the emergency response organization was. not require i Discussions with- licensee representatives indicated that sufficient technical staff was available to provide for continuous staffing of the augmented emergency organization if neede The inspectors also observed the activation, staffing, and operation of the emergency organization in the TSC, EOF, and OSC. At each response center, the required staffing and assignment of responsibility appeared to be consistent with the licensee's approved procedure No violations or deviations were identifie . Onsite Emergency Organization (82301)

The licensee onsite emergency organization was observed-to assure that the following requirements were implemented pursuant to 10 CFR 50.47(b)(2),

paragraph IV.A of Appendix E to 10 CFR 50,- and specific criteria promulgated in Section II.B of NUREG 0654, Revision 1:: (1) responsibilities for emergency response were unambiguously ' defined;.- (2) adequate staffing was provided to assure initial ' facility accident response in key functional areas at all times; (3) onsite_ and offsite support organizational inter-actions.were specifie The inspectors observed that the initial onsite emergency organization was adequately defined and that staff was available to fill ~ key furctional positions :within the emergency organization. Augmentation of the initial emergency response organization was accomplished through mobilization of off-shift ' personnel . The on-duty Shi.ft Supervisor. assumed the duties of Emergency. Coordinator promptly upon initiation of the simulated emergenc and directed the response until relieved by the Station. Manage ..

Required interactions between the licensee's emergency response organization and State and local support agencies were adequate and consistent with the scope of the. exercise, except as noted in paragraph 11 belo No violations or deviations were identifie _ - _ _ - _ _ -

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9. Emergency Response Support and Resources (82301)

This area was observed to assure that the following arrangements for requesting and effectively using assistance resources were made pursuant to 10 CFR 50.47(b)(3), Paragraph IV.A of Appendix E to 10 CFR 50, and Section II.C of NUREG 0654, Revision 1, namely: (1) accommodation of State and local staff at the licensee's near-site Emergency Operations Facility; (2) organizations capable of augmenting the planned response were identified.

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Licensee contact with offsite organizations was conducted in accordance Nith approved procedures and was consistent with the scope of the exercis Assistance resources from local agencies were available to the license No violations or deviations were identified.

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This area was observed to assure that a standard emergency classification and action level scheme was in use by the licensee pursuant to 10 CFR 50.47(b)(4), Paragraph IV.C of Appendix E to 10 CFR 50, and specific l

criteria promulgated in Section II.D of NUREG 0654, Revision 1.

l An emergency action level matrix was used to promptly identify and properly I classify the emergency and escalate to more severe emergency classifications i as the simulated emergency progressed. Licensee actions in this area were

< considered adequate.

i An inspector observed that the emergency classification system was used

consistently with the Radiological Emergency Plan and Implementing Proce-The system appeared to be adequate for classification of the

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dure simulated accident. The respective emergency procedures provided for initial and continuing mitigating actions during the simulated emergenc No violations or deviations were identifie . Notification Methods and Procedures (82301)

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, This area was observed to assure that procedures were established for notification of State and local response organizations and emergency

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personnel by the licensee, and that the content of initial and followup messages to response organizations were established. This area was further observed to assure that means to provide early notification to the populace within the plume exposure pathway were established pursuant tn

, 10 CFR 50.47(b)(5), Paragraph IV.D of Appendix E to 10 CFR 50, and specific criteria defined in Section II.E of NUREG 0654, Revision An inspector observed that notification methods and procedures were established and available for use in providing information concerning the simulated emergency conditions to Federal, State, and local response organizations, and to alert the licensee's augmented emergency response

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organizations. The NRC was notified within one hour following declaration of each emergency classification. The licensee notified the State within 15 minutes. Approximately one half hour following the licensee's notification of the State, the State Emergency Response Team (SERT) indicated that it was not yet activated. Thus the additional notifications of counties and other State organizations that would normally be made by SERT had not been made.

l The EOF communications staff immediately initiated and completed the

required notifications which would have been handled by SERT had it been

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activate The above findings were also identified and discussed by the licensee during their controller / evaluator critique following the exercis This exercise weakness will be reviewed during subsequent exercise: (Inspector Followup Item (IFI) 50-324/85-20-01,50-325/85-20-01).

The prompt notification system (PNS) for alerting the public within the plume exposure pathway was in place and operational. The system was actuated during the exercise to simulate warning the public of significant events occurring at the plant sit No violations or deviations were identified.

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12. Emergency Communications (82301)

This area was observed to assure that provisions existed for prompt communi-cations among principal response organizations and emergency personnel pursuant to 10 CFR 50.47(b)(6), Paragraph IV.E of Appendix E to 10 CFR 50, and specific criteria promulgated in Section 11.F of NUREG 0654, Revision Communications among the licensee's emergency response facilities and emergency organization, and between the licensee's emergency response organization and local offsite authorities were adequate and consistent with j the scope of the exercise and drills (fire and medical). In reference to l the exercise, however, the licensee identified the need for improvement in l communications between the licensee and the State. The identified weakness posed no impediment to attainment of the exercise objectives.

j No violations or deviations were identifie . Emergency Facilities and Equipment (82301)

l This area was observed to assure that adequate emergency facilities and

! equipment to support an emergency response were provided and maintained l pursuant to 10 CFR 50.47(b)(8), Paragraph IV.E of Appendix E to 10 CFR 50, f

and specific criteria defined in Section II.H of NUREG 0654, Revision The inspectors observed activation, staffing, and operation of the emergency response facilities involved, and evaluated the equipment therein provided

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for emergency use during the exercise. Emergency response facilities

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activated during the exercise included the control room technical support

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center (TSC), operations support center (OSC), and the emergency operations

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facility (E0F). Control Room - The inspector observed that reactor control room opera-l tions personnel acted promptly to initiate required responses to the simulated emergency. Emergency procedures were readily available, generally followed, and factored into accident assessment and mitiga-

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l Control room personnel involvement was essentially limited to those assigned routine and special operational duties. The shift supervisor and control room operators were cognizant of their duties, responsi-l bilities, and authoritie These personnel demonstrated an under-standing of the emergency classification system and demonstrated the ability to use specific procedures to determine and declare the proper classification, Technical Support Center (TSC) - The TSC was activated and promptly staffed following notification by the Coordinator of the simulated emergency conditions leading to the Alert classification. The facility staff appeared to be knowledgeable concerning their emergency duties, authorities, and responsibilitie Operation of the facility appeared to be acceptable. This facility was provided with adequate equipment for support of the assigned staf TSC security was promptly establishe Status boards wre strategically located to facilitate viewing by the TSC staff. Status boards were updated as required to chronicle changes in plant status, accident assessment and mitigation throughout the exercis The inspectors noted that a status board dedicated to trending of simulated plant systems and engineering data was consistently maintained and updated during the accident sequenc The TSC was equipped to provide a capability for performance of airborne, general area, and contamination monitoring. It was noted, however, that such capabilities were of little benefit in maintaining TSC habitability regarding facility access control and the evacuation i policy practiced by the licensee during the exercise. The OSC staff

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was evacuated through the plume into the TSC, thus rendering approxi-

! mately half of the TSC/ EOF facility a surface contaminated area. As a l consequence, sufficient supplies required to decontaminate the large number of personnel were not available. Licensee management attention is directed toward reviewing existing onsite contamination control

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measures, access control procedures, and decontamination capabilities.

l It was not apparent that current measures and procedures are consistent with guidance promulgated in Sections K-6 and K-7 of NUREG 0654, Revision 1. This item was also discussed by the Itcensee during their controller /avaluator critique. This exerct weakness will be reviewed

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Inspectors observed that the TSC radiological group maintained no tabular and/or survey map data to chronicle in plant and offsite radiological conditions reported by monitoring teams. At the onset of the offsite release, dose projection responsibilities were transferred

from TSC to EOF with the TSC performing a backup function. The lack of l offsite monitoring records precluded the use of such data to confirm l the accuracy of dose projections calculated by the EOF. This exercise l weakness pertaining to maintenance of in plant and offsite radiological

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monitoring records by emergency response facilities will be reviewed l

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during future emergency exercises (IFI 50-324/85-20-03, 50-325/85-20-03). ,

c. Operations Support Center (OSC) - The OSC was promptly staffed following activation of the emergency plan by the Emergency Coordinator. An inspector observed that teams were promptly assembled, briefed, and prepared for deployment. The OSC supervisor appeared to be cognizant of his duties and responsibilitie The NRC inspectors and licensee observers noted, however, that improvements in the following areas were indicated, namely: limit the amount of personnel

, traffic through the OSC in transit to the food service area; and l

excessive noise in the relocated OSC following evacuatio It was observed tht.t an air sample taken in the OSC was improperly collected. Instead of remuving the filter, the technician turned off the sampler and transported the entire sampler to the counting roo This exercise weakness pertaining to adherence to accepted sampling procedures will be reviewed during subsequent exerciseh (IFI 50-324/85-20-04, 50-325/85-20-04).

d. Emergency Operation Facility (EOF) - The EOF was promptly activated and staffed in a manner consistent with the exercise scenari The factitty staff appeared to be knowledgeable regarding their emergency duties, authorities, and responsibilities and the required operation appeared to be acceptable. The facility was provided with adequate equipment for support and maintenance of the assigned staff. Security was promptly established and effectively maintaine Status boards were strategically located and were frequently updated to chronicle changes in plant status, accident assessment and mitigation throughout the exercis Inspectors observed that status boards dedicated to trending of simulated plant system changes and engineering data were consistently updated during the accident sequence. The initial briefings by the ERM and TSC to EOF personnel were detaile The ambient noise was maintained at an acceptable level within the facility throughout the exercis Observers noted that the initial protective action following declara-tion of the General Emergency was to evacuate zones A, B, C, and D and shelter all other remaining zones downwind of the plume. This decision was based on erroneous assumption that the subject zones could be evacuated prior to arrival of the plume (Procedure PEP-2.5). This l

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l recommendation, however, was promptly cor*ected and rendered consistent ;

with exercise condition The notification form (Exhibit 2.6.21-1, Plant Emergency Procedure) ;

l provided for distribution to the State and cffsite agencies regarding l the recommended responses to the declared General Emergency was

! incorrectly filled out resulting in brief confusion with the State.

l These findings indicated that additional training of EOF personnel regarding protective action recommendation and attending procedures including notification and communications is needed. This exercise ;

weakness will be reviewed during a subsequent exercise (IFI 50-324/85-20-05, 50-325/85-20-05).

l No violations or deviations were identifie l 14. AccidentAssessment(82301) l This area was observed to assure that adequate methods, systems, and equip-ment for assessing and monitoring actual or potential of fsite consequences ,

of a radiological emergency condition were in use as required by 10 CFR 50.47(b)(9), Paragraph IV.B of Appendix E to 10 CFR 50, and specif te ,

criteria promulgated in Section II.! of NVREG 0654, Revision ,

i The accident assessment program included an engineering assessment of plant status, and an assessment of radiological hazards to onsite and offsite personnel resulting from the accident. During the exerciso,'the engineering accident assessment team functioned adequately in analyzing the plant statue to provide recommendations to the Site Emergency Manager concerning mitigating actions required to reduce damage to plant equipment, prevent releases of radioactive materials, and terminate the emergency conditio Control room personnel were also involved in assessment activities. Control room assessment actions and response to the simulated seismic event were observed. It was noted that Step 2 of Annunciator Procedure app-VA-28-6-4 which addressess Seismic Events, requires that if acceleration exceeds 0.089, the licensee should immediately initiate a controlled shutdown of both unit It was noted, however, Unit 2 remained at 60*. power for approximately four hours after the simulated seismic event occurred. It was further noted that no temporary changes to the subject procedure were issued to account for the deviation, nor ws there any apparent discussion of invoking use of 10 CFR 50.54(x) regarding reasonable departure from a Itcense condition or Technical Specification during an emergency. The licensee's action and available remedial options were discussed with licensee representatives. This item was also discussed in the critiqu The value of additional training in assessment of such situations was included in both discussion Radiological assessment activities involved bath onsite and of fsite group An in plant group was effective in estimating the. radiological impact within

, the plant based on in plant monitoring and onsite measurements. Offsite

! radiological monitoring teams were dispatched to determine the level of J

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radioactivity in those areas within the path of the plume. Radiological effluent data was received in the TSC and EOF. The nffsite dose assessment l and protection calculations were consistent with scenario values. It was I observed that several problems regarding coded radios, controller / evaluator interpretation of scenario package, and reporting of radiation levels detected on the micro-n meter. These problems, however, posed no impediment to the exercise, nor achievement of exercise goals.

! Routine inventory and verification of the contents of monitoring kits issued to offsite radiation monitoring team personnel was conducted by each team member prior to deployment. Listing of required contents of each kit was provide No violations or deviations were identifie . Protective Response (82301)

This area was observed to determine that guidelines for protective actions, consistent with federal guidance, were developed and in place, and protective actions for emergency workers, including evacuation of non-essential personnel, were implemented promptly as required by 10 CFR 50.47(b)(10), and specific criteria promulgated in Section !!.J of NUREG 0654, Revision The inspector observed the licensee's program for personnel accountabilit The inspector noted that upon sounding of the site evacuation alarm, personnel appeared to proceed promptly to designated assembly point Initial accountability appeared to be completed approximately 30 minutes +

after initial accountability check The protective measures decision making process was observed by the j inspectors. Protective actions implemented by the control room and TSC were j timely, adequate, and consistent with the above criteri Protective measures recommendations provided by the licensee to the State of North Carolina and local offsite organizations consistent with the scope of the exercise scenario, findings regarding protective action response recommen-dations and notifications are discussed in paragraph 13.d. abov No violations or deviations were identifie . RadiologicalExposureControl(82301)

l This area was observed to determine that methods for controlling radio-i logical ' exposures in an emergency were established and implemented for energency workers, and that such methods included exposure guidelines consistent with EPA recommendations as required by 10 CFR 50.47(b)(11), and specific er..erta defined in Section !!.K of NUREG 0654 Revision An inspector noted that the radiological exposures were controlled i throughout the exercise by issuing supplement dos 1 meters to emergency

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workers and by conducting periodic radiological surveys in the emergency l

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- . ,, I i 10 response facilitie Exposure guidelines were in place for various categories of emergency . actions, and adequate protective clothing and respiratory protection 'were available for use as, require ~

Health phys 1cs control of radiation exposure, contamination control, and radiation area access appeared adequata: Health physics supervisors were observed to brief survey tJams adequatply. Dosimetry was available and was used. High range dosimeters were available if needed. A communicator and data logger were established at the health physics access point and appeared to function in a satisfactory manner. It was noted, however, that exposure control attending evacuation of the OSC was lacking. This item is discussed in paragraph 13.b., abov No violations or deviations were identifie . Medical and Fire Drills (82301)

A redical drill and a fire drill were also held in conjunction with the annual exercise. Both drills were conducted adequttely and the stated drill objectives were accomplished. No significant drill weaknesses were note No violattons or deviations were identifie ,

1 Exercise Critique (82301)

The licensee's critique of the emergency exercise was observed to assure that shortcomings identified as part of too exercise were brought to the attention of management for corrective action, as required by 10 CFR 50.47(b)(14),10 CFR 50, Appendix E, Paragraph IV.F. and the specific criteria in NUREG 0654,Section I A formal critique was held on June 20, 1985, with exercise controllers and observers, licensee management, and NRC representatives. Wennesses identified during the exercise and plans for corrective action were discussed. Licensee action on weaknessos identified will be reviewed during a subsequent inspection. Observation of thV' Mconsee controller / evaluator critique, held prior to the exit critique. was included as part of the exercise evaluation. Observation disclosed that the licensee conducted a detailed critique of the exercise and operation of the emergency response facilities. The critique it.cluded identification and discussion of weak-nesses and required improvements, , documentation thereof, and required corrective actions. Significant findings were summarized during the exit critiqu No violations or deviations were identifie . Regional Assistance Committee (RAC) Report A copy of the RAC report pertaining to of fsite support igency performance will be provided via a separate transmitta ,

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20. Inspector Followup (92701) (Closed) Inspector Followup Item (IFI) 50-324/82-12-01: Initial Emergency Response in Control Room. Inspection confirmed that the Shift Operations Supervisor delegated responsibilities consistent with procedural requirements regarding declaration of Emergency Classifi-cation and implementation of appropriate response, initial assessment and notificatio (0 pen) IFI 50-324/82-12-04: Public Address System for TSC and EO This item has not been resolved. To date, operating PA systems have not been provided in the subject emergency response systems, (Closed) IFI 50-324/82-12-05: Verification of Emergency Controller Message Inspection confirmed that two dedicated communicators were provided to implement the following functions: (1) monitor incoming data and alert TSC management to important changes in data; (2)

updating TSC status board l 1 (Closed) IFI 50-324/82-12-06: Conference Room Noise Problems in TSC and EO Inspection confirmed that ambient noise was maintained at acceptable levels in the cited Emergency Response Facilities, (Closed) IFI 50-324/83-16-04, 50-325/83-16-04: Make Improvements in the Fire Protection Program. Inspection verified that adequate safety equipment, clothing, and personnel training were provided as require (Closed) IFI 50-324/84-17-01, 50-325/84-17-01: Guidance on Protective Action Recommendations for a General Emergency Due to a Security Threat. Inspection disclosed that appropriate changes were made in Plant Emergency Proceuure 02.5 (Emergency Control - General Emergency). (Closed) IFI 50-324/85-17-03, 50-325/85-17-03: Practical Guidance for Formulating Protective Action Recommendations Based on Projected Dos Inspection discloskd that, consistent with corrective actions taken by the licensee definitive guidance was provided to Shif t Operation Supervisors, (Closed) IFI 50-324/85-17-04, 50-325/85-17-04: Backup Communication Links With Offsite Agencies. Inspection disclosed that an alternate backup phone number was provided for contacting New Hanover count . (Closed) IF! 50-324/85-17-05, 50-325/85-17-05: Periodic Drills to Verify Table 8-1 Augmentation Times. Inspection disclosed that periodic drills were assigned to verify that augmentation times defined in Table B-1 could be routinely me (Closed) IFI 50-324, 325/85-17-06: Scope of Audit of Interfaces with State and Local Agencies. Inspection disclosed that audit of inter-faces with State and local agencies is listed as audit item 10.17.3 The scope of the cited item also includes review of required biennial I

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updating of licensee agreements with State and lecal and county organization k. (Closed) IFI 50-324, 325/85-17-07: Updating Agreements with Supporting Organizations at Least Every 2 Years as Specified by ERP Section 6. Inspection disclosed that the subject updating was implemented as define . (0 pen) IFI 50-324, 325/85-17-08: Isseance of dosimetry to emergency workers remaining onsite after evacuatio .

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