ML20198E477
| 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) | |
See also: IR 05000443/1986018
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No. 50-444/86-18
Docket No. 50-443
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: -
.. a 8=
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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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 equipment.
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 license.
8605280024 e60515
PDR ADOCK 05000443 L ~
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DETAILS
1. 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 personnel.
- Denotes those present at the exit interview.
2. 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.
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3. 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 identified.
Those items which need to be addressed for resolution as a result of this
inspection are listed as "open items" in each details.section, an~d'are
summarized in detail 6, at the end of this report.~
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4. Details
A. 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 Planner.
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 met.
(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 staff.
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 inspection.
Except as noted in (2) above, this area was found to be acceptable.
B. 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 organization.
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
chart.
(0 pen)IFI(50-443/85-32-04): Assign the responsibility to
perform initial dose assessment on shift and revise Appendix A
of the Emergency Plan accordingly.
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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 inspection.
(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 Manager.
(0 pen) IFI (50-443/85-32-06): Provide. additional qualified
alternates in the line of succession for supervisory elements
of the augmented emergency organization. (In order to provide
for 24 hr./ day staffing). The licensee has committed that at
least 3 people will be trained and qualified for each of the
key positions prior to issuance of a full power license.
(0 pen) IFI (50-443/85-32-07): Complete all arrangements with
local service groups to ensure offsite support will be
available when needed. At the time of the appraisal all of the
training identified in the emergency plan for members of the
Offsite Emergency Support groups had not been completed. Also
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a letter of agreement for backup ambulance services with the
Seabrook Fire Department needs to be completed.
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 number.
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 hour.
This item had not yet been addressed by the licensee and will be
reviewed in a subsequent inspection.
(Closed) IFI (50-443/85-32-14b): Paragraph 5.3 of EPIP ER 2.2 lists
one or more incorrect alternate NRC phone numbers (e.g. (301) 952-
0550 listed vis. (301) 951-0550). The inspector reviewed the latest
revision to ER 2.2 and verified that the NRC phone numbers have been -
corrected.
(0 pen) IFI (50-443/85-32-14c) Form ER-2.2A, " Initial Notification
Fact Sheet," is the form used to accomplish initial state notifica-
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 inspection.
(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 available. (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 boundary.
Further, the information derived is only used for accident classi-
fication purposes, not for making protective action recommendations.
This does not meet the requirements of 10 CFR 50.47(b)(9) to be able
to assess and monitor actual or potential offsite consequences of a
radiological emergency, which could not be done under the present
arrangements, prior to arrival of emergency response augmentation
personnel. The licensee is evaluating this item for corrective
actions. This will be reviewed in a subsequent inspection.
(Closed) IFI (50-443/85-32-14e) 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
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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-
ancy.
(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 area.
The training in this area resulted in a noticeable improvement in
performance in this area. This area was found to be acceptable.
(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 crews.
This item is closed.
(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 boundary.
This item was not specifically readdressed during this inspection,
but will be reviewed during a subsequent evaluation of operator
training in this area.
(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 inspection.
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 below.
(Closed) IFI (50-443/85-32-15a) Complete and implement the
Emergency Plan Training Manual.
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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 area.
(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 Organization.
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 reviewed.
(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-3.1.
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 appropriate.
- (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.
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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 Manual.
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(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 Plan.
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
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a. During a review of Section 1.0 of Chapter 5 to draft Amend-
ment 58 to the FSAR, and in-force Amendment 55, it was
identified that responsibilities for each ERO position are
- listed but there is no indication regarding which respon-
- sibilities may not be delegated. This listing should be
revised to indicate responsibilities which may not be
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delegated for all assignees (50-433/86-18-01).
I b. 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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c. Radiological training has been provided to the hospital
staff by a member of the Health Physics Department staff,
however continuing training in this area has not been de-
fined. NHY should address periodic retraining in this area
to insure continuity of this function (50-443/86-18-03).
d. Section 4.2.64 of the General and Specialty Training
Program Manual lists Course 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 training.
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 teams.
The following observations were made.
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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 iodine. The licensee is eval-
uating a change to the model (50-443/86-18-07). '
Any changes made in these areas will be evaluated in a subsequent
inspection.
F. Facilities and Equipment
(1) Emergency Operations Facility
a. 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-8.1.
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(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-
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sary equipment is installed and operational.
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- b. (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)
- a. 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-8.1. The Media Center policy and procedures
are still in draft,
b. Except as noted above this area is acceptable.
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(3) Meteorological Instrumentation
a. Previous Inspection Findings
(0 pen)(50-443/85-32-19): Finalize the meteorological monitor-
ing system design, consistent with the FSAR commitments and
revise the program description in Section 6.2.3.1 of the Emer-
gency Plan and Section 2.3.3 of the FSAR.
The licensee stated that the FSAR will be revised to reflect the
full meteorological monitoring program by June 1, 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 handling.
(0 pen) (50-433/85-32-20): Provide for backup meteorological
measurements representative of conditions in the vicinity of
the site and provide for backup power to the instrument
building.
The licensee stated that a meteorologist familiar with the site
will be available, during all emergencies. The duties and
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 instrumentation.
(0 pen) (50-443/85-32-21): Provide a method of severe weather
notification to the control room.
A policy document is currently bring drafted which will specify
the load dispatcher as providing severe weather notification to
the control room.
(0 pen) (50-443/85-32-22): Implement T.S. 6.9.2 surveillance
requirements for the meteorological monitoring program. Opera-
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 written.
(0 pen) (50-443/85-32-23):- Modify calibration procedure
IX1654.410, Rev. 2, for delta-temperature instrumentation to
properly reflect accuracy requirements and use more specific
terminology. The licensee indicated action.has not been com-
pleted on this item.
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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 EOF.
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 load.
b. Except as noted above this area is acceptable.
(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 detectors.
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 conditions.
(5) Area and Process Radiation Monitors
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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 assessment.
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, 1986.
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 onsite. SCBA training, respirator use
training, and medical certification is expected to be completed by
May 31, 1986.
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 onsite. 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 conditions.
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 inspection.
(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 facilities.
The emergency communication system was reviewed against the commit-
ments made in the Emergency Plan.
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 ENS. 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 inaudible.
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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 area.
The licensee has a survei,llance procedure, ER-8.1, which requires
periodic inspection of communications systems and equipment.
Procedures ER-8.1 and ER-8,5 establish responsibilities for
performance of the surveillance.
During the exercise on February 26,1986,~kheNuclearalertsystem
(orange phone) was used, providing direct' interfaces with the Mas-
sachusetts and New Hampshire State Police.
At the time of the inspection', the installation of the sirens which
comprise a portion of the Public Emergency Alerting System, had not
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 acceptable.
(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 inspection. >
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
year.
(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
,
of agreement with the Seabrook Fire Department which will be
! providing this service.
i~
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 received. In addition, the procedure for
decontamination of contaminated / injured personnel (ER4.4) is
.
--
.
15
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 personnel.
In addition to completing the installation of equipment noted in
a., above, the following items were identified and will be
reviewed in a subsequent inspection.
-
Complete the revision to ER-4.4 "Onsite Medical Emergency"
(50-443/86-18-9).
-
Complete and implement the Exeter Hospital Radiological
Procedure Manual for treating contaminated injured pa-
tients. (50-443/86-18-10)
A medical emergency drill will be observed in a subsequent
inspection, to assess the capabilities in this area.
( 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 systems. 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 6.6.
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 2.
Based on the above, this area is acceptable.
(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 teams.
In plant capability for de ceting airborne iodine in the presence of
noble gases is provided. Instrumentation capable of distinguishing
beta / gamma is available.
...-.-g -. -_ - - -
<y, ,
'
. 4
.}
.
.
e
. O
Based on the above, this area is acceptable. .
, '(11) Protective Clothing
,
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.
_
Based on the above, this area is acceptable.
' ~
(12) Reserve Supplies
The licensee maintains an onsite inventory of emergency supplies and
equipment in addition to that dedicated.specifically-for emergencies.
In addition, the licensee has the ability to obtain additional sup-
plies from offsite through the Yankea:Matual Assistance Plan.
,
. Equipment available through this plan includes:
.a) Mobile Laboratory Emergenby Analysis Equipment and' Van Service
b) Mobile TLD Van Service s
'
-c) . Mobile Body Burden Van Servics,.and
' d). '
Field environmental radiation' surveillance equipment (and
personnel).
~
,
The licensee maintains a minimum stock level to insure an adequate.
<
reserve of normal,! supplies to handle emergency situations.
Based on the above, this area is acceptable.' .
,
(13) Transportation -
'
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 watts. 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 adequate.
,
!
Based on the above, this area is acceptable.
. .
,
I *
1
3
!
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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 exercise.
Based on this review, it was determined that the control room met the
guidance concerning equipment, decisional aids, and habitability.
---
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's.
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.
i
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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 radioisotopes.
Action levels requiring further assessment by the health physics
staff and the followup actions required were delegated to the Radio-
logical Controls Coordinator. Copies of monitoring and decontami-
nation procedures were available at the onsite decontamination
facility, at the Route 107 warehouse, and at the EOF.
It was determined from the review that adequate procedures existed
to facilitate personnel monitoring and decontamination under emer-
gency conditions.
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 respectively.
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 conditions.
(3) Personnel Accountability
The inspector reviewed EPIP ER-4.2, " Personnel Accountability", for
adequacy in assuring that all onsite personnel are accounted for in
an accurate and timely manner.
The procedure specifies that the Security Supervisor implements the
accountability process and reports accountability results to the
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 completed.
. _ _ . . . , .
.__ - _ . . .
, 19
4
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
.
'
will print out missing personnel by plant sector. A search would
be initiated by the Short Term Emergency Director or Technical
Services Coordinator utilizing Procedure ER-4.5, Search and Rescue.
ER-4.5 is not referenced or referred to in ER-4.2.
As a result of this inspection it was determined that this area will ,
remain open pending the implementation of the plant security program
and demonstration of the ability to complete accountability. The
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).
!
) (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 program. 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
,
vehicles equipped with 100 watt mobile radios and monitoring kits
l are available to field three monitoring teams. The procedure does
.
!
not provide the field teams with instructions for communication with >
the E0F in the event of. loss of the mobile radio capability.
,
Based on the above the following items need to be addressed in this
area:
'
-
Provide procedures for a back-up means of communications
in the event of radio failure (50-443/86-18-13).
-
Include specific instructions to the Off-site Monitoring
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 acceptable.
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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"
<
specifies the on-site radiation protection practices to be imple-
mented following activation of the Radiological Emergency Plan.
4
Specifically, the procedure addresses the following areas:
'
a) OSC Activities
,
b) Protective Area Radiation Surveillance and Control
c) In plant Surveillance and Control
d) MPC-hour Accountability
e) Dose Assessment and Exposure Tracking.
The Radiological Controls Coordinator is assigned the responsibility
j. for ensuring station emergency exposure control measures.
Based on the above, this area is acceptable.
(7) Repair and Corrective Actions
Procedure ER-7.1, " Emergency Repair and Corrective Action", Rev. 01,
provides instructions for emergency repair and corrective actions.
The responsibilities of-the Technical Service Coordinator, the
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 controls.
Based on the above, this area is acceptable.
.
4
. _ _ _ . .
.
. 21
(8) Recovery
Procedures ER-8.7, " Recovery Organization" and ER-7.3, "Re-entry and
-
Recovery", were reviewed. . Organizational authority for declaring
that a recovery phase is to be entered is included in the
procedure. Radiological conditions as well as plant operating
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 terminated.
~ ~ ~ ~ ~
Based on the above, this area is acceptable.
(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:
-
the emergency equipment has been used;
-
at scheduled quarterly intervals, or
-
if a seal on an emergency kit or locker has been broken.
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 / supplies.
The Radiological Assessment Manager is responsible for ensuring the
'
inspection, inventory, and operational checking of emergency equip-
ment and facilities.
Based on the above, this area is acceptable.
(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 location.
EP-6.0, " Emergency Facilities"
.
._ -. - - - --. ._ .-- . ..
.
. 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 identified.
Based on the above, this area is acceptable.
(11) Public Information
The inspector reviewed section 11.3 of the NHY Emergency Plan, Rev.
57, on Public Information, also draft brochures, calendars,
telephone book inserts and posters.
The Public Information (PI) program was evaluated against the re-
quirements in 10 CFR 50 Appendix E. Specific areas were reviewed to
verify the following:
-
provisions were described for yearly dissemination to the-
public with the EPZ;
i
-
that the materials contain basic emergency planning
information and general information as to the nature and
effects of radiation;
-
measures are taken to provide information to the transient
population;
-
materials and information provided to the public are coordinated
with State and local government agencies, and;
-
that the information provided also contains evacuation routes,
sheltering directions and actions to be taken when alerted.
Based on this review it was determined that the public information
section in the Emergency plan describes the bases for the program.
NHY 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 finalized.
,
_ _ . .
.
. 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
>
persons on the beaches within the EPZ.
Other methods the licensee plans to use for the initial distribution
of emergency planning information are newspaper and radio advertis-
,
ing. This is planned to be done concurrently with the mailing of
brochures. Telephone directory advertising will be included in the '
i
'
1986 Portsmouth white pages and the 1987 Newburyport and Haverhill
white pages.
At present this information has not been distributed to residents in
It is understood that the final details will have to be
!
the EPZ.
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.
4
"
(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.
d
!
(12) Drills and Exercises
>
.
'
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
<
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 exercised.
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 scheduled.
A tracking system has been developed to track drill / exercise
deficiencies and to ensure that appropriate corrective action is
j taken.
This area was determined to be acceptable.
4
-
.
.
- 24
,
(13) Audits
'
The inspector reviewed Chapter 18 of the QA Manual which defines the
Operational QA audit requirements. One of the requirements is to
.
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 6.5.2. It was also determined
Emergency Preparedness was not included in the list of activities.
The licensee indicated awareness of the error in the Technical
Specification reference in the QA Manual, and that Emergency Pre-
paredness had not yet been added to the list of activities in section
6.4.2,as an area requiring audit. Steps are being taken to correct
both of these items. This item will be reviewed in a 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-
'
partment Records Manual, compared it with NUREG-0654 elements P.4,
P.5, and P.10, and toured the Document Control Center facilities.
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
<
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 correct.
As a result of this inspection it was determined that the
applicant's procedures for review, revision,-and distribution of the
Emergency Plan and Implementing procedures are acceptable,
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
't
- - _ - _ _ _ _ _ _ _ _ _ - _ . .
.
. 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 inspection. (See para. F.8)
Except as noted above, this area is acceptable.
(16) Emergency, Alarm, & Abnormal Procedures
The inspector reviewed chapter 5 of the Emergency Plan, the Seabrook
--- ---~~
site specific version of the Westinghouse Owners Group (WOG) Emer-
gency Response Guidelines, and selected emergency alarms, and ab-
normal operating procedures to evaluate conformity to requirements &
guidance provided by 10 CFR 50, NUREG-0737 Supp. 1, & Regulatory
Guide 1.33.
Based on this review it was determined that, although none of these
procedures has been formally promulgated, most of the required
procedures exists in a refined draft stage which are in conformance
with the referenced guidelines and requirements. Formal promulgation
of the 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:
a. 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
coordinator. (NUREG-0654 II B 4) (50-443/86-18-21).
b. The followup notification forms found in ERs 1.2 through 1.5
et al do not:
-
indicate type of release (airborne, waterborne) (NUREG-0654
II E 4 0),
-
Project integrated dose at the site boundary (NUREG-0654 II E
4 H),
- . ._. . . - _-. .-- .
.
. 26
-
Project dose rate and integrated dose at 10 miles
(NUREG-0654 II E 4 I), (50-443/86-18-22).
c. Revise ER-1.3 fig. 1 paragraph 13 to add the on shift HP
tech as an alternate advisor to be consistent with ER-4.1
paragraph 5.3.3 (50-443/86-18-26),
d. 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 SAE.
(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.)
'
e. 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
'
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).
'
f. 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 g. 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:
-
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).
= . _. . . .
.
. 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 subject.
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
~~-
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
'
.
1985 and again during the exercise of February 26, 1986, and made the
following observations:
-
The protected area perimeter control system (fencing, E fields,
badging, etc.) has not yet been established (50-443/86-18-29).
,
l
-
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
,
4
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
4
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 tack.
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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4
.- . _ - . . . - . - - .-. , . _ -
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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
1
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 information.
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
'
are generally content with the applicant's effort for coordinating
emergency preparedness issues, and Civil Defense (Emergency Operations
'
Center) directors stated that the language contained in letters of
agreement would be honored. .
!
Except as noted below, this area of the licensee's program is '
acceptable.
,
-
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).
' -
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 load.
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 accordingly.
-
.
. 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 /> basis.
(85-32-07): Complete arrangements with offsite survey groups to ensure
availability of offsite support during emergencies.
(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 Facility.
-
(85-32-12/13): Ensure that arrangement for transportation of onsite con-
taminated/ injured personnel are made and described in plans and procedures.
(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 hour.
(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 provided.
(85-32-14h): Shift operating crews were not aware of containment design
leak rate specifications.
(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 specified.
(85-32-15d): EP training instructors do not meet the experience require-
ments of ANSI /ANS-3.1.
(85-32-18): Complete procedures which describe the equipment and
organization of the Media Center.
(85-32-19): Finalize the meteorological system design consistent with
FSAR commitments, and revise description in the Emergency Plan.
(85-32-20): Provide for backup meteorological measurements representa-
tive of conditions in the vicinity of the site. 1
(85-32-21): Provide a method for notification of impending severe
weather to the Control Room.
_
.
. 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 centigrade.
(85-32-24): Provide for maintaining a historic record of basic data
required for atmospheric dispersion calculations.
~ ~ ~ -
(86-18-01): Emergency Plan, Chapter 5, Section 1, does not specify which
responsibilities of ERO staff members may not be delegated.
(86-18-02): The Security Officers' Lesson Plan does not include
discussion of the use of KI as a possible protective action.
,
(86-18-03): Periodic radiological retraining of the hospital staff has
not been developed or scheduled.
(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.
'
(86-18-05): METPAC Operator and sample analysis personnel are not
described in the Emergency Plan as augmentation personnel.
(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 declared.
(86-18-07): The initial dose assessment model assumes no iodine in the
release.
(86-18-08): Complete operational testing and turnover of the Radiation
Data Monitoring System.
(86-18-09): Complete the revision to ER-4.4, "Onsite Medical Emergency".
(86-18-10): Complete and implement the Exeter Hospital Radiological
Procedure Manual.
(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 emergency.
(86-18-13): Provide backup means of communication with off-site
radiological teams in event of loss of radio communications.
i
.
. 31
(86-18-14): Include specific instructions to Off-site Monitoring
Coordinator regarding use of respiratory equipment and KI in procedures.
(86-18-15): Draft appropriate procedures for the performance of onsite
(out-of plant) radiological surveys.
(86-18-16): Distribute interim public information brochures, providing
basic information concerning what action to take on siren activation,
where to receive additional information, etc.
- -~-
$(86-18-17): Distribute final detailed public information brochures
~ ~ ~ ~
describing all necessary emergency planning information for the public,
including evacuation routes.
(86-18-18): Revise T.S. 6.4.2 and implement the QA audit program for
(86-18-19): Promulgate final version of emergen y, alarm, and abnormal
procedures.
(86-18-20): Train operators in the final versions of emergency,
abnormal, and alarm procedures.
(86-18-21): Revise procedures ER-1.2-1.5 to reflect that the authority
to authorize notification cannot be delegated to the E0F Coordinator.
(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 miles.
(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-4.1.
(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 track.
(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 2.2.
(86-18-26): Item E of Emergency Plan pgs. A-1 and A-2 should be
identified as a non-delegable function.
(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
-
.
'
32
(86-18-29): Implement site Security Plan.
(86-18-30): Complete security training for station personnel.
(86-18-31): Verify that all letters-of-agreement are current.
(86-18-32): Complete the orientation and off-site training program for
New Hampshire and Massachusetts state and local officials.
(86-18-33): Complete installation and testing of PEAS sirens.
JI(86-18-34): Complete installation of the Post Accident Sampling System
6. Exit Interview ,,
At the conclusion of the inspection on March 28, 1986, the inspector. met
with representatives of the licensee (see detail 1 for attendees) to
discuss the findings of this inspection as detailed in this report.
At no time during this inspection was any written material provided to
the licensee.
.
O
.
e
%___.____________..___