IR 05000424/1989018

Insp Repts 50-424/89-18 & 50-425/89-21 on 890612-16.No Cited Violations Noted.Major Areas Inspected:Emergency Preparedness Program to Determine If Program Maintained in State of Operational Readiness

ML20246Q367
Person / Time
Site:	Vogtle
Issue date:	07/12/1989
From:	Gooden A, Rankin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20246Q353	List: IR 05000424/1989018 ML20246Q352
References
50-424-89-18, 50-425-89-21, IEIN-85-080, IEIN-85-80, NUDOCS 8907210089
Download: ML20246Q367 (10)

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n REGION 11

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• ATLANTA, GEORGt A 30323 4

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• • • • • JUL 121989 : a

, a Report Nos.: 50-424/89-18 and 50-425/89-21;

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Licensee: Georgia Power Company j)

P. O. Box 1295 Birmingham, AL' 3520 . Docket Nos.: 50-424 and'50-425 -License'Nos.: --NPF-68 and NPF-8 Facility Name: Vogtle 1 and 2

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Inspec' tion Conducted: June :2-16, 1989 t

Inspector: O, [ ' /f7 7//A/#f A. Gooden / D' ate Signed; ,

Approved by: 8. J . [O J, M/.2/Pfr W. Rankin,' Chief f D6te Signed Emergency Preparedness Section .

l Emergency Preparedness and Radiological Protection Branch l Division of Radiation _ Safety and Safeguards SUMMARY' j l

Scope:

This routine, un,'nnounced inspection was. conducted in the areac off emergency pr_eparedness. Several functional areas of the.' emergency preparedness program ,

were reviewed to determine if the program was' being maintained in!a state ;o q operational readiness for' responding to emergencies. The review included the  ;

following '(1) Emergency Plan and Implementing Procedu'res changes; (2) emergency facilities, equipment, instrumentation, and supplies;- (3) organization and i management control changes; (4)-training; and (5) independent reviews / audits.- '

Results:

In the areas inspected, two non-cited violations were identified:

Failure to replace iodine ' filter cannisters in accordance with procedural requirements of EPIP-91702-C " Emergency Equipment and'

Supplies" (Paragraph 3).

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Failure to maintain all documents in the emergency response; facilities and emergency kits up to date- in accordance with procedural requirements (Paragraph 2). <

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I program strengths were also noted:

There appeared to be a strong commitment by plant management in support of the emergency response progra An effective tracking system was maintained for ensuring that prompt and adequate corrective action is taken on items identified during drills and exercise i The onsite emergency organization was adequately staffed and trained in accordance with the Emergency Plan Implementing Procedure Monthly and quarterly equipment inventories and operability checks were well documented including the actions taken to resolve any noted discrepancie i i

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REPORT DETAILS

, Persons Contacted Licensee Employees

• V.'Agro, Plant Administration Superintendent J. Carswell, Health Physics Foreman

'*G. Frederick ~, Quality Assurance Site Manager

• Gabbard, Senior Regulatory Specialist C. Hartfield, Senior Health Physics Technician K. Holmes, Plant Training and Emergency Preparedness-Manager

• Kurtzman, Supervisor, Health Physics / Chemistry Training L. Lane, Shift Clerk

• A. Masbaugh, Assistant General Manager, Plant Support

• L. Mayo, Senior Emergency Preparedness-Specialist

• J. Petro, Senior Quality Assurance Field Representative

• J. Roberts,-Emergency Preparedness Supervisor'

J. Williams, On-shift Operations Supervisor Other licensee employees contacted during this inspection included engineers, operators, l security force members, technicians, and'

administrative personne NRC Resident inspector

• Aiello

• Attended exit interview Emergency Plan and Implementing Procedures (82701)

Pursuant to 10-CFR 50.47(b)(16),10 CFR' 50.54(q), and. Appendix E to 10 CFR Part 50, this area was reviewed to determine whether changes were made to the program since the last routine -inspection. (September 1988),

and to assess the impact of these changes on the overall state Lof emergency preparedness at the facility.-

The inspector reviewed Section P of the licensee's Emergency Plan-regarding the development, review, approval, and distribution of changes L to the Emergency Plan and Emergency Plan Implementing Procedures (EPIPs).,

Plant Administrative Procedures 00402-C (Licensing Document' Change -

Request) 00050-C (Procedure Development), 00051-C (. Procedures Review and Approval),.and EPIP.91701-C (Preparation and Control of Emergency Planning Documents) implement Section P ~ of the Emergency Plan. The management-system used for tracking -document changes is known as the Nuclear-Operating Records Management System (NORMS). This system provides information to Document Control personnel regarding the document approval'

date, date received by Document Control, ' current revision number, and

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other detail Since the last inspection, changes incorporated as Revision 11 to the Emergency Plan were being reviewed by the Regional I Office Staff, to determine if changes were consistent with NRC requirement The inspector reviewed documentation to verify that changes -

to the Emergency Plan (Revision 11) and randomly selected EPIPs had been

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done in accordance with procedural requirements governing the review and approval. All revisions were approved by the General Manager, and changes were submitted to the NRC within 30 days of the approval date, ,

Controlled copies of the Emergency Telephone Directory, Emergency Plan, j and/or EPIPs- were audited in the Control Room, Technical Support Center (TSC), Operations Support Center (OSC), On-Shift Operations Supervisor's J office, the Emergency Operations Facility (E0F), and in ' select emergency kits. With two exceptions, the selected documents that were examined were

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found to be current revisions. The two exceptions were as follows:

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Included in the EOF inventory are four copies of the Field Monitoring l Team (FMT) Handbook (for issuance with FMT Kits) containing survey 1 data sheets, field monitoring procedures, emergency telephone i directory, and other procedures. The inspector noted that all four handbooks contained a superseded copy of the " Emergency Response ,

Telephone Directory." According to documentation, the current j version was dated May 2,1989, the copy found in the FMT Handbooks ]

was dated February 8, 198 '

Concurrent with the NRC review of documents, the licensee's Quality Assurance Auditor identified a superseded copy of EPIP 91008-C (Duties of the Maintenance Supervisor) inside a controlled copy of a manual assigned to the TS Consequently, an audit was conducted of all controlled manuals assigned to the emergency response facility (ERF) for verification that procedures were current and up to dat No other problems were noted. This findings appeared to have been an isolated cas The cognizant licensee representative, when informed regardinn the superseded documents, took the following immediate actions: 1) current revisions to the aforementioned documents were inserted into the manual or handbooks; and 2) administrative corrective actions were documented and implementesi to resolve the aforementioned findings and prevent recurrenc The licensee was informed that the two findings considered in the aggregate, were examples of violations that are not being cited because criteria specified in Sections V. (a) and V. (g) of the NRC Enforcement Policy were satisfie Therefore, failure to maintain all documents in the ERF's and emergency Kits up to date, is considered a Non-cited l Violation (NCV).

NCV 50-424/89-18-01, 50-425/89-21-01: Failure to maintain all documents in accordance with EPIP 9170- One violation and no deviations were identifie _ _ _ _ - - - -

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1 3. . Emergency Facilities, Equipment, Instrumentation, and Supplies (82701)

Pursuant to 10 CFR 50.47(b)(8) and (9),Section IV.E of Appendix E to 10 CFR Part 50, and Section H of the licensee's Emergency Plan, this : area 1 was inspected to determine whether the licensea's. emergency response facilities and other essential emergency equipment, instrumentation, and supplies were maintained in a state of operational readiness.-

. Discussions were held with a licensee, representative concerning modifications to facilities, equipment, and instrumentation since the last inspection. The discussion disclosed the following changes:

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Regarding communications equiptnent, the South Carolina and Georgia -

Emergency Notification Network (ENN) Circuits were combined into single ENN circuit, as opposed to the previous system which was comprised of a South Carolina Circuit and a Georgia Circuit 2 Consequently, each State and local government within the 10, mile-Emergency Planning Zone (EPZ), receive . simultaneous notification An additional update to equipment involved ~ the Unit 2 ERF Computer Capability in the TSC and E0 Regarding facility changes, as documented in a previous inspection report (Report Nos. 50-424/88-36 and 50-425/88-45)', the reallocation of floor space in the OSC had been completed. This reallocation did

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not appear to decrease the effectiveness of the OSC staff in responding to emergencie The inspector toured the Control Room, TSC, OSC, and E0F, and noted that facilities were in accordance with the description in Section H of the Emergency Pla In assessing the operation status of the emergenc facilities, the inspector verified that protective equipment, and supplies were operational and inventoried on a periodic basis. Emergency Kits and/or cabinets from the TSC, OSC, and E0F were inventoried, and t andomly selected equipment was checked for operability. The selected equipment operated properly, displayed current calibration stickers, and successful battery and source checks were obtained. However, the inspector did note one discrepancy. Four FMT Kits located in the E0F contained Iodine Filter l Cannisters that were not replaced prior to shelf-life expiration in ,

accordance with Section 5.0 of EPIP 91702-C " Emergency Equipment and Supplies." The referenced cannisters were stamped use before August 198 The licensee took immediate action by replacing expired cannisters with cannisters that were within their marked shelf-life. Further, to prevent recurrence, the licensee revised the procedure data sheet governing the equipment inventory to include a review of the cannisters expiration date ,

during the periodic inventory. The licensee was informed that this i violation meets the criteria specified in Section V. (a). of the NRC I Enforcement Policy for not issuing a Notice of Violation and is not cite NCV 50-424/89-18-02, 50-425/89-21-02: Failure to Replace Iodine Filter Cannisters in Accordance with EPIP 91702-C " Emergency Equipment and'

Supplies'"

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By review of applicable procedures and check-list documentation covering the period of May 1988 to June 1989, the inspector determined that emergency equipment (eg. communication and emergency kits) was being checked in accordance with procedures governing such tests (EPIP 91204-C and EPIP 91702-C). The inspector requested and observed a communications check from the TSC using the backup system (to the dedicated ring-down phone) for the Burke County warning point. No problems were noted with system operability. Records reviewed indicated that all discrepancies or problems identified during inventories and communications checks were corrected in a timely manne The licensee's management control system for the prompt Alert and Notification System (ANS) was reviewed. The ANS consisted of tone-alert radios and electronic sirens located throughout the plume exposure EP The licensee's siren test records for the period August ,1988 to June 1989, showed that tests were being conducted at the frequency specified in Appendix 3 of the Vogtle Emergency Plan. Documentation was available to show that annual siren maintenance was performed during calendar years 1988 and 198 Further, documentation was available to show that all corrective actions taken in response to failed sirens were well documente Regarding the licensee's management control system and procedures governing the ANS testing, the inspector noted that the Emergency Response Communications test procedure (EPIP 91024-C) and/or Federal and State Reporting Requirements procedure (Administrative Procedure 00152-C) do not include a trigger point er acceptance criteria in the event of significant siren failures or inadequate coverage due to a major loss of tone-alert radios and siren The licensee was informed that under 10 CFR 50.72(b)(1)(v), any event resulting in a major loss of communications capability requires notifications to the NRC as soon as practical and in all cases within one hou The licensee acknowledged ,

this finding and committed to evaluate current procedures and the Federal i Emergency Management Agency (FEMA) acceptance criteria for ANS testing and to establish a trigger point for 10 CFR 50.72 reports involving the AN l The licensee was informed that this matter was considered an Inspector {

Followup Item (IFI) for review during a subsequent inspectio !

IFl 50-424/89-18-03, 50-425/89-21-03: Include an Acceptance Criteria in the ANS Test Procedure for 10 CFR 50.72 Reportin One violation and no deviations were identifie . Organization and Management Control (82701)

Pursuant to 10 CFR 50.47(b)(1) and (16),Section IV.A of Appendix E to 10 CFR Part 50, and Section B of the licensee's Emergency Plan, this area was inspected to determine the effects of any changes in the licensee's emergency organization and/or management control systems on the emergency ;

preparedness program, and to verify that any such changes were properly factored into the Emergency Plan and EPIP I

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The inspector's discussion with licensee representatives disclosed that several personnel changes had been made involving both the corporate and plant staffs since the September 1988 inspection. At the corporate office, organizational changes resulted in the establishment of separate projects to support each site (eg. Vogtle Project, Hatch Project, Southern Company Services Project, etc). and within each project exits a corporate Emergency Planning organizatio Previously, one corporate emergency planning organization served both Vogtle and Plant Hatch. Personnel changed involved the reassignment of personnel from the position of Plant Training and Emergency Preparedness Manager to the position of Manager-Safety Audit Engineering Revie In view of corporate organizational change, responsibilities for interfacing with offsite support groups (NRC, FEMA, State, etc.) were realigned. Regarding Corporate Office facility changes, the General Office Operations Center had been relocated from Atlanta to Birmingham, Alabama. At the plant, as previously discussed, the individual filling the position of Plant Training and Emergency Preparedness Manager was reassigned to the Corporate Office. Consequently, an individual designated as Technical Assistant to the Plant Manager is acting in the position Plant Training and Emergency Preparedness Manage The inspector's discussion with a licensee representative disclosed that personnel changes had also been made to the emergency organization since the September 1988 inspection as a result of reassignment, or promotio When training records were reviewed for such individuals, no problems were note Training records confirmed that training requirements were satisfied prior to position assignment. Regarding the offsite emergency organization, no changes had been mad The operators for the Savannah River Site had changed, but the day to day interface and contact regarding ;

emergency planning was not affecte '

No violations or deviations were identifie . Training (82701)

Pursuant to 10 CFR 50.47(b)(15),Section IV.F of Appendix E to 10 CFR Part 50, and Section 0 of the licensee's Emergency Plan, this area was inspected to determined whether the licensee's key emergency response perscnnel were properly trained and understood their emergency responsibilitie The inspector reviewed Section 0 of the Emergency Plan and EPIP 91601-C for a description of the training program and procedures. In addition, selected lesson plans were reviewed, and personnel with the responsibility l for conducting the training was interviewed. As a result, the inspector -

determined that the licensee maintains a formal emergency training j progra In response to IE Information Notice No. 85-80 " Timely, Declaration Of an Emergency Class, Implementation of an Emergency Plan, and Emergency Notifications," the inspector interviewed a shift clerk who may be designated as an offsite communicator for the Control Room. The inspector interviewed the communicator regarding the various communications systems

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available from the Control Room for making notifications, communicator responsibilities, backup communications. systems, etc. . No problems were -

noted. The interviewee demonstrated familiarity with the communications emergency procedures and equipment, and no problems were observed in the areas of: equipment operability, message authentication or responsibility as communicator. The inspector conducted a walk-through evaluation with an on-shift operations supervisor (0S05) and a Health. Physics Forema During these walkthroughs, . individuals were _ given hypothetical emergency conditions and data and asked .to respond as .if an emergency actually -

existed. .The interviewee demonstrated familiarity with emergency procedures and equipment, and no' problems were~ observed in the areas of emergency detection, classification, dose projection, and protective action recommendation Further, the 0S05 was very knowledgeable of'

duties and non-delegable re. possibilities.as Interim Emergency Directo Training records were reviewed for selected members of the onsite and offsite support organization No problems were..noted. Offsite suppo agency training was reviewed for fire, rescue, hospital, and governmental support agencie Offsite - support training was consistent with requirements in the Vogtle Emergency Plan and EPIP 91601-C " Emergency Preparedness Training."

No violations or deviations were identifie . Independent Review / Audits (82701)

l Pursuant to 10 CFR 50.47(b)(14) and 10 CFR 50.54(t), this area was l'

inspected to determined whether the licensee had performed an independent review of audit of the emergency preparedness program, and whether the licensee had a corrective action system for deficiencies and weaknesses identified during exercise and drill According to documentation provided to the inspector, independent audits of the program were conducted by the Corporate Office Safety Audit and Engineering Review group during the period April 17, 1989 through May 8, 1989 (documented in Audit Report No.:89-4). The most recent audit was initf ated on June 1,1989 and scheduled for completion on June 15, 198 The most recent audit.(to be documented in Audit. Report No. OP-12-89/28)

was conducted concurrent with the NRC . inspection. . The aforementione audits fulfilled the 12-month frequency requirements- for such audits. member of. the most recent audit team was interviewed regarding 'the areas audited and the results. One potential finding with direct applicability to the NRC inspection results was the failure to reuve a superseded copy of EPIP-91108-C from a co ; rolled manual in the TSC (Paragraph 2). *

The- results of the aforementioned audit rill be reviewed during a subsequent inspectio The licensee's program for followup action on audits, drills, ard exercise findings was reviewed. The exercise and drill findings were being tracked'

via an emergency planning tracking system known as the "Vogtle EP Action

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Item Report." This system is maintained by the emergency planning staff for ensuring followup actions are taken on deficient items. In addition, exercise and drill findings along with Quality Assurance and NRC Audit findings are tracked by the plant-wide open item tracking (0IT) system (Administrative Procedure 00104-C). According to a licensee contact, on a weekly basis, status reports are provided for review to plant managemen The inspector reviewed items identified during the calendar years 1988 and 1989 exercises and/or drills. According to the Vogtle EP Action Item Report, a total of seven items remain opened. Most items were being completed by the due date if not soone No violations or deviations were identifie . Shift Staffing and Augmentation (82701)

Pursuant to 10 CFR 50.47(b)(2) and 10 CFR 50, Appendix E, Sections, I and IV. C, this area was examined to determine whether shift staffing for emergencies was adequate both in numbers and in functional capability, and whether administrative and physical means were available and maintained to augment the emergency organization in a timely manne The inspector reviewed Table B-1 of the Emergency Plan and discussed shift staffing and augmentation with a licensee representative to determine if )

the goa's and criteria of Table B-1 of NUREG-0654 could be- met. The licensee had established an automatic computer-based telephone notification system referred to as "MELITA." On a quarterly basis, a recall orill is conducted to perform the followin (1) verification that '

the MELITA auto-dialing system is operational (2)g: verification that phone and beeper numbers for augmentation staff are current; (3) determination of the percentage of personnel that can be notified and properly respond to the message; and (4) estimates of arrival times for augmentation personnel at the Plant Entry Security Building (PESB). The call-in procedure ,

appeared to be effective in meeting Table B-1 goals. According tn j discussion with members of the licensee's staff, an unannounced 4 augmentation drill (involving actual travel to the plant by response 'l perso*"es) is being considered as part of an upcoming exercis ;

No violations or deviations were identifie . Exit Interview i

The inspection scope and results were summarized on June 16, 1989, with

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those persons indicated in Paragraph 1. The inspector described the area inspected and discussed in detail the inspection results listed belo ,

The licensee did not identify as proprietary any of the material provided '

to or reviewed by the inspector during this inspection. Dissenting comments were not received from the license The licensee acknowledged the findings as presented by the inspector. As stated in the summary of this report, the inspector acknowledged thos'; areas cf program strength _ _ _ _ _ _ _ _ _ _ - _ .

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Item Number Description and Reference 50-424/89-18-01,'50-425/89-21-01 NCV - Failure to maintain all documents in accordance with EPIP 91701-C (Paragraph 2).

50-424/89-18-02,50-425/89-21-02 NCV - Failure to replace Iodine Filter Cannisters in accordance with EPIP 91702-C (Paragraph 3).

50-424/89-18-03, 50-425/89-21-03 IFI - Include an acceptance criteria in the ANS test .

procedure for 10 CFR.50.72 reporting (Paragraph 3).

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