ML20204F205

Emergency Preparedness Insp Rept 50-219/87-05 on 870127-30. No Violations Noted.Major Areas Inspected:Emergency Preparedness Activities Including Emergency Plans & Implementing Procedures,Emergency Facilities & Equipment

ML20204F205
Person / Time
Site:	Oyster Creek
Issue date:	03/17/1987
From:	Amato C, Fox E, Lazarus W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20204F010	List: ML20204F003 ML20204F205
References
50-219-87-05, 50-219-87-5, IEIN-83-28, NUDOCS 8703260153
Download: ML20204F205 (9)

See also: IR 05000219/1987005

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-219/87-05

Docket No. 50-219

License No. DPR-16 Priority --

Category C

Licensee: GPU Nuclear Corporation

P. O. Box 388

Forked River, New Jersey 08731-0388

Facility Name: Oyster Creek Nuclear Generating Station

Inspection At: Forked River, New Jersey

Inspection Conducted: January 27-30, 1987

Inspectors: [ M a a;g M / 8bd /6,M@

C. G. Amato Te Leader ' date

B SS, RI RC

Mfstcy /G,/9 R

_ Eluff3eNior nsp ctor, EPS, EP&RPB

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DRSS, RI, NRC

J. J Ha xh st, Region I

. M. azargs) Chief, Emergency ' date

PreparedfuHis Section, DRSS, RI, NRC

Inspection Summary: Inspection on January 27-30, 1987, (Report No. 50-219/87-05).

Areas Inspected: Routine announced inspection of emergency preparedness

activities including Emergency Plans and Implementing Procedures; Emergency

Facilities, Equipment, Instrumentation and Supplies; Organization and Manage-

ment Control; Independent Reviews / Audit; application of NRC Inspection and

Enforcement Division. Information Notice No. 83-28; and follow-up of previous

inspection findings. In addition, the inspectors observed and evaluated

licensee emergency preparedness response to an actual Unusual Event in progress

during part of the inspection period and evaluated licensee Security-Emergency

Preparedness interface.

Results: No violations were identified. All but two outstanding follow-up

items not exercise related were closed. One unresolved item was identified

relating to the delayed staffing of on-site Emergency Response Facilities

during an actual Unusual Event on January 26, 1987. A second unresolved

item relates to clarifying the Emergency Preparedness-Security interface.

8703260153 B70317

PDR ADOCK 05000219

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DETAILS

1. Persons Contacted

• K. Barnes, Licensing Engineer

• • T. Blunt, Senior Emergency Planner

• • J. Bontempo, Senior Emergency Planner

• • • J. Christian, Lead Quality Assurance Auditor

• • R. Ewart, Lt. , Oyster Creek Security

• • P. Fiedler, V. P. and Director, Oyster Creek

• J. Kowalski, Oyster Creek Licensing Manager

• • • D. Long, Manager, Oyster Creek Security Dept.

• • • D. Mac Farlane, Manager, Oyster Creek Site Audit

• • • B. Mingst, Senior Emergency Planner

• • J. Sullivan, Director, Oyster Creek Operations

• • • R. Sullivan, Manager, Oyster Creek Emergency Preparedness

• • R. Scott, Surgeoner Manager, GPUN Public Relations

I. Wazzan, Emergency Planner

• • • J. Williams, Training Department

• Denotes those present at the entrance meeting, January 27, 1987

• • Denotes those present at the exit meeting, January 30, 1987

• • • Denotes those present at both the entrance and exit meeting.

2. Licensee Action in Previous Inspection Findings

2.1 (Closed) (219/79-18-10) A Fire Protection Safety Evaluation Report,

Table 3.1, item 3.1.12, Engineering Breathing Apparatus, required

reevaluation as to acceptable completion status. Positive pressure

type breathing units were needed which negated the use of Bio-Pak 45

units. This was identified as an unreselved item pending the licen-

see's resolution for a required breathing apparatus inventory.

The inspector reviewed licensee's resolution and noted that Scott

air packs have been obtained and provided in lieu of Bio-Pak 45

units. The use of Scott air packs meets the positive pressure

breathing unit requirement.

2.2 (Closed) (219/79-18-18) Audibility problems enceuntered during an

evacuation.

Observation of site evacuation conducted as part of the annuar

exercises since 1980 did not indicate audibility problems.

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2.3 (0 pen) (219/82-01-44) Perform an engineering study of existing

ARMS and PRMs to determine upgrading necessary to the monitoring

system to provide adequate accident detection and classification

and post-accident radiation mapping capabilities. Incorporate the

results of the study in the Emergency Plan and in the Emergency Plan

Implementing Procedures.

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The inspector verified that low range stack monitors, air ejector

monitors, area radiation monitors and low and high range Radioactive

Gas Effluent Monitoring Systems (RAGEMS) have been installed and

their use incorporated into five procedures. Containment high range

monitors have recently been installed, their use has not yet been

incorporated into procedures. These installations were made based

on the findings of the requested engineering study.

2.4 (Closed) (82-01-84) Specify action levels which require further

assessment of personnel radiation exposure and/or contamination and

define techniques used.

This matter is addressed in procedure 6430-IMP-1300.07

2.5 (Closed) 82-01-85) Develop specific security procedure and/or check-

lists which consolidate the security organization emergency duties.

Site Security Emergency Actions are described in Procedure

6430-IMP-1300.41.

2.6 (Closed) 83-03-02) Develop means to transfer, store, sample and

analyze highly radioactive post accident liquid wastes from LOCAs

occurring outside of primary containment.

A plan has been developed and will be found as Exhibit 4 to Procedure

6430-IMP-1300.26, " Technical Support Center" entitled " Plan for

Transfer and Storage of Contaminated Water."

2.7 (Closed) (83-03-03) Develop and implement a procedure for performing

radiological controls during an emergency.

This plan is incorporated in an appendix to Revision 2 of Procedure

6430-IMP-1300.26, The Technical Support Center.

2.8 (Closed) (84-15-11)

" Provide information showing how the criteria of NUREG-0654,

Appendix 2 is met."

Information showing how the criteria of NUREG-0654, Appendix 2 have

been met has been added to the Consolidated Emergency Plan

(1000-PLN-1300.01). Section 7.5.1.4.b identifies the equipment used

and parameters measured, while Section 7.2.4 identifies the group

. that uses the information.

2.9 (Closed) (85-05-01) Provide a listing of Emergency Director's respon-

sibilities which cannot be delegated. Index a logic diagram for

Protective Action Recommendations.

Section 5 of the GPUNC Emergency Plan for TMI and Oyster Creek lists

duties which cannot be delegated.

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E3-1 to Procedure 6430-IMP-1300.02, Revision 0, " Development of PARS" ,

is a logic diagram for forming PARS. ..

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2.10 (Closed) (85-05-02) c The annual independent review /sudit of the *

emergency preparednyRs program should include changes to the program

and an evaluation of'the interface with State and local governments.

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The annual audit,is, canducted on a sampling basis in keeping with

the NRC approved QJality Assurance Procedures. This topic has bcea

reviewed in recent audits.

2.11(0 pen)(86-04-021 Follow-up licensee invpstigation_ and resolution

of frozen sircus.

Seven sirens,all lobated in the Barnegat:Eay area froze. Freezirg was

attributed to the intake of wind driven salt water wn'ich froze inside

the sirens. . Strip heaters are being installed. This item will

remain open until correctivg action is completed and the, NRC'nas had

an opportunity to review the 9cceptance reports.

3. Response to an Actual Unusual Event

On January 26, 1987, a leak developed in a' drain line located in the'

Condensate Storage Tank-(CST) drain well. The Plant Operations Director

was contacted by the Group Shift Sup,ervisor at home about 9:44 p.m. and

advised of the;condi'tlen. The Operations Director reviewed.the Emergency

Classification scheme 4nd concluded that'this condition did not warrarit an s

emergency classification. The Operations Director d$scussed the matter

with the Vice-President and Director for Oyster Creek and advised the NRC

Senior Resident Inspector of the condition before proceeding to the site.

Following subsequent' review of cpnditiocs, the Operations Director

declared an Unusual Event at 11:43 p.m. This was a conservative act16n

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based on the uncertainties'at that time. Thb stetton siren wasosounded

and an appropriate messagerdelivered over the public address system. The

New Jersey State Police were. notified at 11:47 p.m. and the NRC at 11:55

p.m. At 12:03 a.m. , January 27, 1987, the Security Commander was cort

tacted and directed to activate the Emergenc9 Response Organization staff

for the Technical Support Center (TSC) and Operations Support Center

(OSC). A radio pager message.was transmitted for Response Team 2 members

to report to their duty st oiens. The OSC notified Security' at 1:54 a.m.

that four staff members hac not repor*.ed and at 2:00 a.m.-the TSC advised

Security three persons had'not reported. The call-out message was

. repeated at 2:00 a.m. duelto the lack of response.

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Between 2:21 a.m. and 2:27 a.m. seven staff mercbers responded to acknowl-

edge the message. The OSC and TSC were accordingly notified. At

3:10 a.m. the TSC and OSC were fully staffed.

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n GPUNC Corporate Emergency Plan specifies in Table 1, the time in which

'b personnel are to be available to the Emergency Response Centers and Emer-

C gency Response Organization positions (1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />). No such specification is

given for the Unusual Event, nor was the emergency classification trans-

.nitted over the pagers. Responders were, however, ordered to report.

The unusual event was terminated at 8:25 p.m., Tuesday, January 27, 1987.

The inspector determined that during the time of this event, a limited

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State of Emergency was in effect in Southern Ocean County, but most main

roads were plowed and passable. The inspectors also concluded that: the

Unusual Event declaration was conservative; the delay in fully staffing

( the TSC and-0SC did not impede management of the event; and following the

2:00 a.m. notification, several staff members reported to their emergency

,p duty stations within a half hour of notification.

( The inspectors further concluded that the delayed staffing of the TSC and

OSC under these conditions may indicate a deficiency in the Emergency Plan

and/or the Implementing Procedures or management controls which could

l impede activation and timely staffing of the Emergency Response Facilities

when needed. The licensee has been requested to reply in writing to these

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concerns. The item is unresolved. (50-219/87-05-01)

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,, h 4.' Annual Quality Assurance Audit of the Emergency Preparedness Program

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1b i The inspectors reviewed the emergency preparedness audit program to verify

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that +ffective audits had been conducted at least every 12 months as

required by 10 CFR 50.54(t). The inspectors reviewed all audit reports

and also the contents to determine if the other requirements stated in 10

CFR 50.54(t) were met.

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The inspectors determined the audit was carried out every year with one

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,\ ex'ception. The audit was not undertaken for a twelve month period when

5\ the licensee's Technical Specifications (TS) required biannual audits.

4, . The TSs were subsequently amended to meet the requirements of 10 CFR

50.54(t). Since this appears to be an isolated occurrence with minimal

5 f safety sigriificance, this was not cited as a violation.

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b' Independent reviews / audits have been conducted every 12 months with the

above noted exception by the Quality Assurance staff following Quality

Assurance Procedures. A review of these reports indicates:

a. ,ade,quacy of State interface was determined from the licensee's

. perspective;

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b. the State was notified in writing of the interface evaluation;

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c. idrillsandexerciseswereobservedandevaluated;

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d. recnemendations for improvements are written and response and/or

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resolution must be obtained; W ,

e4 . - resolution, in the. event of differing' opinion can be brought to the

ryfcorporate,officerlevel.

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The inspector had no further' questions in.'this area. YM ,

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5. . Emergency Plan and Implementing Procedures

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To verify if significant or major changes were made to the Emergency ~ Plan

and Implementing Procedures, the taspectors' reviewed these and discussed

the revised Plan and Pro'cedures with the. licensee's Emergency Preparedness

U'  ! staff. The inspectors # determined that: a single consolidated GPU Nuclear

4 Corporation Emergency Plan and' Procedures for TMI and Oyster. Creek had

been developed, distributed and became effective February 10, 1986; e

changes'were reviewed and approved by GPUNC management and review com-

n3i ttees; there is no adverse effect on the licensee's overall state of

emergency preparedness; emergency training is based on the consolidated

acPlan and Oyster Creek Implementing Procedures; the consolidated Plan and

? ~ Procedures are available in all Emergency Response facilities and have

also been sent to the NRC and New Jersey State government; and have been

found to meet the requirements of 10 CFR 50.54(q) and Section V to

Appendix E to 10 CFR 50. The inspectors further concluded that ' Protective

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Action Recommendations are based on barrier breech analysis,'in keeping

with NRC Information Notice 83-28 (IE IN 83-28) and,~as appropriate, pro- ,

h?jecteddosesanddosecommitments. A logic diagram similar to that in IE

IN 83-28 is incorporated into Oyster Creek Procedures. - A matrix of 3

a initiating conditions for emergency classification has also been developed _.

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and included in the Oyster Creek Procedures. -

6. Einergency Equipment, Fa lities, Instrumentation and Supplies y ,3 N

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-A sample of supplies and?equipment was chec'ked to determine if' supplies, ,

o equipment and instruments are maintained in a state of operational ' ,

readinessp ,

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Tha contents of a locker was. checked and found to be in accord with the

in'ventory in the Plan. One survey instrument was inoperable,'but was

promptly replaced. ,

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! m The inventory lists are complete and meet NRC requirements. No changes

have been made;in this area which would adversely effect licensee

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w>  ;? # response. The' Emergency Preparedness program at Oyster Creek maintains

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a surveillancd! program in this area. ,

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.This area was found to be acceptable. t

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7. Organization and Management Control

Managers were interviewed and the organizational structure studied by

the inspectors to determine if there is upper level management and

involvement, the organization meets the Plan, Technical Specification

descriptions and the effects of management's involvement and organiza-

tional structure on emergency preparedness; and adequacy of the EP staff.

Based on this review, it was determined that the organizational struc-

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tures are in agreement with the description in the Plan and Technical

Specifications. Adequate numbers of staff are assigned to this area,

and upper-level management remains involved in maintaining the EP

program.

9. Training

Lesson Plans and Training Records were reviewed by the inspectors who

also conducted walk-throughs to ascertain the currency and effectiveness

of Emergency Preparedness Training. Off-site training was also reviewed.

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There are 976 full-time GPUNC nersonnel at the OC site and the adjacent

Forked River Site. All receive Leneral Employee Training. Abcut 275 site

personnel are currently trained and qualified in Emergency Response Organi-

zation positions. At least three persons are qualified for each position

so each of the three Priority teams may be fully staffed. There are, in

addition, trained and qualified alternates. Off-site training is also

conducted. Security Officers and Reactor Operators are also trained in

Emergency Preparedness.. Walk-throughs with operators indicated an area

of' concern.- They experienced difficulty in locating the correct procedure -

when given a scenario by the inspectors. The inspectors attributed this

to two factors: a) when examined by training, they were given the needed

procedure and not required to locate it; and b) the procedures a*e identi-

fied by a cumbersome thirteen alphanumeric designator. As a result of

this review, it appears that training should require the operators to

locate the correct procedures when being examined; and secondly, the proce-

dures should be improved from a human factors standpoint (e.g. color coded

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tabs with key words) to improve operator response time. This approach

is in use within the TMI procedures. This item will be reviewed in a

subsequent insoection.

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The State of New Jersey conducts off-site training and has provided

training for 181 Emergency Workers in Ocean County and 78 such workers

at the State level.

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10. Emergency Preparedness - Security Interface

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To determine any pctential performance deficiencies or conflicts between

Security and Emergency Response operations / disciplines, the inspectors

selected and interviewed four individuals. three who are qualified as

Emergency Of rectors, and the fourth as a Security Organization manager.

A similar scenario was discussed with each individual assuming they were

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acting as the on-shift ED. Their knowledge of the basic functions, such

as: detection of the problem; stabilization of the plant; classifica-

tion of the event; and, notification of offsite authorities, was clearly

evident. Also, dose assessment and protective action decision-making were

considered by all. Although final recommended actions were different, the

inspector determined all actions were acceptable, and concluded that the

weakest area, based on the scenario given, was the safeguards / safety

interface. Additionally, the inspectors interviewed the OCNPGS Security

Manager and determined that from the security perspective an interface

exists which could be utilized in an emergency involving sabotage or

potential for sabotage. The training of the ED appeared to be effective

in the areas discussed except as noted.

The inspectors identified a weakness in the interface between safeguards

and operational safety during radiological emergencies. The following

areas were of concern:

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no triggering mechanism to suspect sabotage;

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no guidelines to verify the security of other safety systems, and,

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no procedures specifying the type of counter measures to consider.

The licensee is reviewing this area for possible corrective action. This

item is unresolved. (50-219/87-05-02)

11. Public Notification

Correspondence between the licensee and Region II of the U.S. Federal

Emergency Management Agency (FEMA) was reviewed by the inspectors to

determine if the requirements of 10 CFR 50.47(b)(5) and Section IV.D of

Appendix E to 10 CFR 50. The inspectors determined FEMA has completed

an analysis of the Alert and Notification System and determined that

there is reasonable assurance the system is adequate to promptly alert

and notify the public in the event of a radiological emergency at

Oyster Creek. The evaluation was conducted pursuant to 44 CFR 350,

evaluative criteria and Appendix 3 to NUREG-0654/ FEMA-REP-1, Revision /

and FEMA-REP-10. This finding is in addition to that noted in Section

2.11 above regarding corrective action to prevent a recurrence of frozen

sirens.

12. Remote Assembly Area (RAA)

The RAA is located at the Jersey Central Power & Light Berkeley Opera-

tions Headquarters, Route 530 almost contiguous to the Miller Air Park.

. The inspectors reviewed driving instructions and drove one of two routes

to the RAA to determine if instructions were clear and the RAA appro-

priately marked or could be so marked in case of an emergency. A few

minor improvements which could be made were discussed with the licensee,

however, this area was found to be acceptable.

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13. Exit Meeting

Following completion of the inspection, two of the emergency preparedness

inspectors and the resi, dent inspector met on January 30, 1987 with those

individuals identified in Section 1. Inspection findings detailed in

this report were presented and discussed. -The licensee acknowledged the

findings and agreed to evaluate them and institute corrective action as

necessary.

At no time during this inspection did the inspectors provide any written

information to the licensee.

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13. Exit Meeting

Following completion of the inspection, two of the emergency preparedness

inspectors and the resi. dent inspector met on January 30, 1987 with those;

individuals identified in Section 1. Inspection findings detailed in

this report were presented and discussed. The licensee acknowledged the

findings and agreed to evaluate them and institute corrective action as

necessary.

At no time during this' inspection did the inspectors provide any written

information to the licensee.

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