ML20127F466

Insp Rept 50-302/85-18 on 850408-12.Violation Noted: Inadequate Emergency Operating Procedure for Seismic Events

ML20127F466
Person / Time
Site:	Crystal River
Issue date:	05/02/1985
From:	Cline W, Gooden A, Kreh J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20127F451	List: ML20127F447 ML20127F456 ML20127F466
References
50-302-85-18, NUDOCS 8505200461
Download: ML20127F466 (10)

See also: IR 05000302/1985018

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> UNITED STATES

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/ 'o . NUCLEAR REGULATORY COMMISSION

REGION 11

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• g 101 MARIETTA STREET,N.W.

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• g ATLANTA, GEORGIA 30323

% . . . . . #' g 0 3 585

~E' Report No.: 50-302/85-18

Licensee: Florida Power Corporation

3201 34th Street, South

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St. Petersburg, FL 33733

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Docket No.: 50-302- License No.: DPR-72

Facility Name: Crystal River 3 j

Inspection Conducted: April 8 - ., 1985

Inspect rs:

e J. L. KreW

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5 #88

Date Signed

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s/ 8 M

Date Signed

[ A. Gooden

Accompanying Personnel: A. L. th Battelle Pacific Northwest Laboratories

Approved by: /

W.*E. Cline, Chief

e 5[k F

Date Signed

Emergency Preparedness Section

' Division of Radiation Safety and Safeguards

SUMMARY

Scope: This routine, unannounced inspection entailed 90 inspector-hours onsite

and 4 inspector-hours offsite in the area of emergency preparedness.

Results: One violation was identified - inadequate emergency operating procedure

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for seismic events.

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8505200461 850502

PDR ADOCK 05000302

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

• P. F. McKee, Nuclear Plant Manager

• G. L. Boldt, Nuclear Plant-Operations Manager

- *V. R. Roppell, Manager, Plant Engineering and Technical Services

• W. L. Rossfeld, Nuclear Compliance Manager

• P. J. _ Skramstad, Nuclear Chemistry and Radiation Protection Superintendent

• E. K. Neuschaefer,-Supervisor, Radiological Emergency Planning

' *J. D. Stephenson, Radiological Emer'gency Planning Specialist

• S. G. Johnson, Radiological Emergency Planning Specialist

• W. P. Ellsberry, Nuclear Operations Training Supervisor

R. A. Arnold, Nuclear Emergency Team Instructor

D. M. Porter, (Acting) Nuclear Shift Supervisor

G. L. Sutter, Nuclear Operator

• K. . R. Wilson, Supervisor, Site Nuclear Licensing

D. D. Betts, Supervisor, Quality Audits

• M. S. Mann, Nuclear-Compliance Specialist

• J. L. Bufe, Nuclear Compliance Specialist

Other licensee employees contacted included technicians, operators, and

office personnel.

Other Organizations

G. J. Allen, Director, Citrus County (FL) Disaster Preparedness

M. H. McCormick, Radiological Emergency Plan Administrator, Citrus County

D. G. Henderson, Director of Ancillary Services, Citrus Memorial Hospital,

Inverness, FL

T. J. Larson, Director of Engineering and Environmental Services, Citrus-

Memorial Hospital, Inverness, FL

S. J. Lovenguth, Director, Emergency Medical Services, Citrus County

NRC Resident Inspectors

• T. F. Stetka

J. E. Tedrow

• Attended exit interview

2. Exit Interview

- The inspection scope and findings were summarized on April 12, 1985, with-

-those persons indicated in paragraph 1 above. A violation described in

- paragraph 11 (inadequate emergency operating procedure for seismic events)

was discussed in detail. Licensee representatives acknowledged the finding

and took no exception. The licensee did not identify as proprietary any of

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~ .the materials provided to or reviewed by the inspectors during . this

inspection.

3 .- Licensee Action on Previous Enforcement Matters

-(Closed) Violation (50-302/84-28-02): Failure to maintain emergency

implementing procedures as required by Technical Specification 6.8.1. The

inspector reviewed the licensee's November 21, 1984,. response to the Notice

of Violation and discussed with a licensee representative the action taken

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tcr prevent recurrence. The licensee had under. review a revision to AI-401

which would provide a mechanism for deleting superseded procedures simul-

. taneously with issuance. of new procedures. The inspector had no further

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questions on this matter.

4. ' Emergency Detection and Classification (82201)

Pursuant to 10 CFR 50.47(b)(4).and 10 CFR Part 50, Appendix E, Sections IV.B

and IV.C, this program area was inspected to determine whether the licensee

used .and understood a standard emergency classification and action level

scheme.

The inspector. reviewed the licensee's classification procedures. The event

classifications 'in the procedures were consistent with those required . by

regulation. The classification procedures did not appear to ' contain

impediments or errors which could lead to incorrect :or untimely

classification.

. Selected- emergency action levels (EALs) specified in the classification-

procedures were reviewed. The reviewed EALs appeared to be' consistent with

the initiating events specified in Appendix 1 of NUREG-0654. The inspector

noted that some'of the EALs were based on parameters obtainable from Control

Room instrumentation.

The ' inspector verified that the licensee's notification procedures included

criteria for initiation of offsite' notifications and for ? development of

. protective action recommendations. .The notification procedures required

that !offsite notifications be made promptly- after declaration of an

emergency.

The inspector discussed with licensee representatives the coordination of

-EALs with State and~ local officials. Licensee documentation showed that the

licensee had discussed the EALs on April 18 and August 22, 1984, with State

and local officials, and that these officials agreed with the EALs- used by-

the licensee.

An interview was held with a Shift Supervisor to verify that he understood

the relationship between core status and such core damage indicators as

containment idome -monitor, high-range effluent monitor, fuel temperature

indicator, and vessel coolant level. The interviewee appeared knowledgeable

.of the various core damage indications and their relationship to core

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status. Because'she inspection occurred during a refueling outage,

Linterviews with other Shift' Supervisors were not arranged.

'The responsibility and authority for classification of . emergency events and

! initiation of emergency action were prescribed in licensee procedures.and in

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the emergency ' plan. ' Interviews with selected key members of the licensee's

emergency organization - revealed that these personnel understood - their

responsibilities and. authorities in relation to accident classification,

notification, and protective action recommendations.

' Walk-through evaluations ~ involving accident classification problems were'

conducted with one Shift Supervisor, who promptly and properly classified

the hypothetical accident situations presented to him, and appeared to bei

. familiar with appropriate classific'ation procedures.

No. violations or deviations were identified in this program area.

5. - Protective Action Decision-Making (82202)

Pursuant to 10 CFR 50.47(b)(9) and (10) and 10 CFR Part 50, Appendix E, 4

Section IV.D.3, this area was inspected to determine whether the licensee

had 24-hour per-day capability to assess and analyze emergency conditions

and make ' recommendations to protect the public and onsite workers,_ and

whether offsite officials had the -authority and capability to initiate

prompt protective action for the public.

The inspector discussed responsibility. and-authority for protective action

' decision-making with licensee reoresentatives and reviewed pertinent

- portions of the licensee's emergency plan and procedures. The plan and

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procedures clearly assigned responsibility and authority for accident ~

assessment and. protective action decision-making. Interviews with members

of the licensee's emergency -organization revealed that these : personnel

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understood their authorities and responsibilities with respect' to, accident

assessment and protective action-decision-making.

l~ Walk-through evaluations involving protective action decision-making were

i _ conducted with' one Shift Supervisor, who appeared to' be ' cognizant of

L . appropriate _onsite protective measures'and aware of_the range of-protective

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' action recommendations appropriate to offsite protection. The interviewee

. was" aware of the need for timeliness in making initial protective action

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recommendations to offsite officials. The Shift Supervisor demonstrated

adequate understanding of the requirement that protective action recom-

mendations be based on core condition and containment status even if' no

, release is in progress.

[ The capability of offsite officials to make protective action decisions and-

to'promptly notify the public was discussed with licensee representatives.

- Licensee - procedures made provisions for contacting responsible offsite

authorities on a 24-hour basis. Backup communications links with offsite

authorities were available. The inspector independently confirmed that

offsi_te decision-makers with authority for emergency response activities

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could be contacted by making a telephone call to the State of Florida and

Citrus and Levy Counties from the Control Room.

No violations or deviations were identified in this program area.

6. Notification and Communication (82203)

Pursuant to 10 CFR 50.47(b)(5) and (6) and 10 CFR Part 50, Appendix E,

Section IV.D, this area was inspected to determine whether the licensee was-

maintaining a capability for notifying and communicating (in the event of an

-emergency) among its own personnel, offsite supporting agencies and

authorities, and the population within the EPZ.

The inspector reviewed the licensee's notification procedures in Section 9

of the Radiological Emergency Response Plan (RERP) and procedure EM-202

(" Duties of the Emergency Coordinator"). The procedures were consistent

with the emergency classification and EAL scheme used by the licensee. The

inspector determined that the procedures made provisions for message

verification.

The inspector determined by review of applicable procedures and by dis-

cussion with licensee representatives that adequate procedural means existed

for alerting, notifying, and activating emergency response personnel. The

procedures specified when to notify and activate the onsite emergency

organization, corporate support organization, and offsite agencies.

Selected telephone numbers listed in the licensee's procedure EM-206

(" Emergency' Plan Roster and Notification") for emergency response support

organizations were checked in order to determine whether the listed numbers

were current and correct. No problems were noted.

The content of initial emergency messages was reviewed and discussed with

licensee representatives. The initial messages appeared to meet the

guidance of NUREG-0654, Sections II.E.3 and II.E.4. Licensee representa-

tives stated that the format and content of the initial emergency messaaes

had been reviewed by State and local government authorities.

l The licensee's management control program for the Early Warnino Notification

! ' System was reviewed. According to licensee documentation ano dscussions

with licensee representatives, the system consisted of 27 fixed sirens in

i place. A commitment has been made by the licensee for 6 additional sirens

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to be installed in the near future. Mobile sirens on offsite organizational

vehicles, boats, and aircraft (all additionally equipped with loudspeakers)

were available to alert the public in areas that were not covered by the

fixed ~ siren system. Tone-alert radios were provided (3 to Levy County and

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32 to Citrus County) to those institutions that would have to organize and

direct their own internal response to an emergency. A review of licensee

i records verified that the system as installed was consistent with the

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description contained in the emergency plan. Maintenance of the system had

been provided fcr by the licensee. The inspector reviewed siren test

records for the period February through April 1985. The records showed that

full-cycle tests were conducted on a weekly basis (Friday of each week) by

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both Citrus and Levy Counties. The weekly tests had replaced the biweekly

silent tests, the quarterly growl tests, and the annual full-cycle tests.

The revised- testing procedure appeared to comply with the guidance in

NUREG-0654, Appendix 3.

Communications - equipment in the Control Room, OSC, TSC, and E0F was

inspected. Provisions existed for prompt communications among emergency

response organizations, to emergency response personnel, and to the public.

The installed communications systems at the emergency response facilities

were consistent with system descriptions in the emergency plan and imple-

menting procedures.

The - inspector conducted operability checks on selected communications

equipment in the Control Room, TSC, OSC, and EOF. No problems were

observed. The inspector reviewed licensee records for the period January 1

to March 27, 1985, which indicated that communications tests were conducted

at the frequencies specified in NUREG-0654, Section II.N.2.a. Licensee

records also revealed that corrective action was taken on problems

identified during communications tests.

Redundancy of offsite and onsite communication links was discussed with

licensee representatives. The inspector verified -that the licensee had

established a backup communications system. The backup system made use of

commercial telephones, FPC Microwave System, Public Address Exchange System,

FPC Lowband Radio, portable transceivers, maintenance telephones, crossband

radios, National Warning System, Emergency Notification System, Health

Physics Network, Local Government Radio, and the Babcock and Wilcox Tieline.

The inspector requested and observed an unannounced communications and

notification check using the backup system. The inspector noted that.the

system operated properly and that the notification message used by the

licensee representative followed the format prescribed in the licensee's

procedures.

No violations or deviations were identified in this program area.

7. Changes to the Emergency Preparedness Program (82204)

Pursuant to 10 CFR 50.47(b)(16), 10 CFR 50.54(q), and 10 CFR Part 50,

Appendix E, Sections IV and V, this area was reviewed to determine whether

changes were made to the program since the last routine inspection

(June 1984) and to note how these changes affected the overall state of

emergency preparedness.

The inspector reviewed the licensee's program for making changes to the

emergency plan and implementing procedures. The inspector verified that

changes to the plan and procedures were reviewed and approved tv management.

It was also noted that all such changes were submitted to NRC within 30 days

of the effective date, as required.

Discussions with licensee representatives indicated that no significant

modifications to facilities, equipment, or instrumentation were completed

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L since 'the last Linspection. Planned augmentation of ' the. Early Warning

Notification System is discussed.in paragraph 6.

The ' organization and manag'ement of the emergency preparedness program were -

reviewed. The inspector was informed that the onsite corporate organization

had :been enhanced by staffing of the . position of , Manager, Site Nuclear

~,~ . Operations Technical Services, who reports to the Director, Site Nuclear

Operations. The -inspector's discussion with licensee. representatives :also

disclosed that the State's Bureau of Emergency Management.was transformed

into :the Division of Emergency Management, resulting in numerous titular

changes among the staff of_that agency.

The: inspector _ reviewed the licensee's program for distribution of changes to

cthe emergency! plan and procedures. Document control records for the period

. January 1984 to March 1985 showed that appropriate personnel .and organiza-

tions were sent copies of plan and procedural changes, as required.

' No violations.or deviations were identified in this' program area.

'8. Knowledge and Performance of Duties (Training) (82206)

Pursuant - to 10 CFR 50.47(b)(15) and 10 CFR Part 50, Appendix E,

'Section IV.F, this area was inspected to determine whether emergency

response personnel understood their emergency response roles and could

perform their_ assigned functions.

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The '. inspector reviewed. the description (in the emergency _ plan) of the

training program, Jtraining procedures, and selected lesson plans, and

interviewed members of the instructional staff. Based on these reviews and

-interviews, the inspector determined that the licensee had established a

formal emergency train'ing program.

Records of training for key members of the- emergency organization for the

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period - August 1984 to March 1985 were reviewed. The training records

-revealed 'that personne1 ' designated as alternates or given interim respon-

sibilities in the emergency organization were provided 'with _ appropriate

training. According to. the training ' records,- the type, amount, and

frequency of training were consistent with approved procedures.

The inspector conducted a walk-through evaluation with a Shift Supervisor.

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During this walk-through, the individual-was given various hypothetical sets

. of- emergency conditions and data and asked to respond as .if an emergency

actually existed. The individual demonstrated familiarity with emergency

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procedures and -equipment, . and no problems were observed in the areas of -

emergency detection and classification, notifications, and protective action

decision-making.

No violations or deviations were identified in this program area.

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.9. Licensee Audits (82210)

!~ Pursuant 1 to 10 CFR 50.47(b)(14) and. (16) and 10 CFR 50.54(t), this area.was

inspected to determine whether. the licensee -had performed an independent >

' review or audit of the emergency preparedness program.

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Records of-audits of the program were reviewed. The records showed that an-

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independent audit of the program was conducted by the Quality Programs. '

Department from January 1 to-February 22, 1985, and documented in Report No. .

3. QP-265, dated ' arch 22,.1985. This audit fulfilled the 12-month frequency

requirement - for such audits. The audit records showed that the State and

local - government interfaces were evaluated. . A licensee . representative

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l stated that findings concerning the interfaces were to be made_available to

State' and local government authorities in the near future. Audit findings

, and recommendations were presented to plant and corporate management. A

review.of past cudit reports indicated that the licensee complieo with the

, five year' retention requirement for such reports.

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Licensee emergency plans and procedures required critiques following

exercises and drills. Licensee documentation showed that critiques were

1 - held following periodic drills as well as the annual exercise. The records

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.showed that deficiencies were discussed -in the critiques, and recommen-

dations for corrective action were made.

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The ' licensee's ' program for follow-up action on audit, . drill, and exercise

findings was reviewed. Licensee. procedures required follow-up on deficient

areas identified during audits, drills, and exercises. The inspector

reviewed licensee records which. indicated that appropriate corrective action

was taken on ~ problems ~ identified during the 1984 ' exercise and audit. The

licensee-had established a tracking system as a management tool in following

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- up on actions taken in deficient areas.

[ No violations or deviations were identified in this program area.

110. Coordination with Offsite Agencies (92706)

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The inspector held discussions with licensee -representatives regarding the

coordination of emergency planning with offsite agencies. Written agree-

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. ments existed with those offsite support agencies specified in the emergency

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plan. The inspector determined through face-to-face interviews with

0 representatives of key local support agencies that the licensee was

i periodically contacting those agencies for purposes of offering training'and '

maintaining mutual familiarization with emergency response roles. Those

~ interviews disclosed no significant problems related to the interfaces

between the licensee and the.offsite support agencies listed in paragraph 1.

11.- Inspector Follow-up (92701)

[, a. (Closed) Inspector Follow-up Item (IFI) 302/81-14-58: Establishment of

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a traffic evacuation plan for the Crystal River Generating Complex. An

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evacuation procedure had been developed, with issuance anticipated

within 60 days. The inspector had no further questions on this matter.

. b. (Closed) IFI 302/82-08-01: Installation of additional telephones at

Corporate Command Center (CCC), with ring lights and ring volume

control. According to the licensee, these matters were resolved.

Information on CCC telephones was contained in REP-07 (" Operation of

the Corporate Command Center").

c. (Closed) IFI 302/82-08-02: Improvement in CCC operations with respect

to overcrowding, noise levels, status boards and data displays, and the

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communications burden on the Recovery Manager. Through discussions

with licensee representatives and review of REP-07, the inspector

determined that the stated finding had been adequately addressed.

- d. (Closed) IFI 302/82-13-03: Improving capability of meteorological

system to assess the impact of shoreline environment upon plume

trajectory. When completed, the licensee's Emergency Dose Assessment

System (t!DAS) will include the effects of sea-breeze circulation on

dose projections if meteorological data indicate the presence of a sea

breeze. The availability date for EDAS is indeterminate due to vendor

software problems, according to the licensee. However, based on the

licensee's intention to continue working toward completion of EDAS,

this item is closed.

e. (Closed) IFI 302/83-06-01: Including more technical data and-infor-

mation on corrective actions in press releases. The inspector reviewed

selected press releases from the January 1985 exercise, and found them

to be concise, clear, and sufficiently detailed from a technical

standpoint. Discussion of corrective actions was included in the

releases.

f. (Closed) IFI 302/83-06-03: Reviewing the manual dose assessment

procedure. This item was largely resolved during a previous inspection

(see Report No. 50-302/84-18, paragraph 8). A discrepancy between the

manual and computer methods, with respect to the default value for

duration of release, was resolved during the current inspection.

g. (Closed) IFI 302/83-06-06: Providing training for Emergency Medical

Team. The training program (lesson plan and instructions) for the

Emergency Medical Team was upgraded and 12 persons were trained. Nine

of' those individuals were assigned to the Emergency Medical Team.

h. (Closed) IFI 302/84-18-07: Qualifying use of backup meteorological

tower information when effects of coal pile may be significant.

Appropriate qualifying instructions were incorporated into Revision 3

of EM-204(A) and EM-204(C) and Revision 4 of EM-204(B).

1. (Closed) IFI 302/84-28-01: EALs for prompt classification of seismic

i events. The classification matrix in EM-202 was revised to provide

EALs suitable for prompt classification of a seismic event

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(Revision 24, page 34). He'ever, the second element of this finding

(which was classified as a licensee-identified violation) was not

corrected. Procedure AP-96; (" Earthquake") was not revised to correct

the inadequacy discussed in paragraph 4 of Report No. 50-302/84-28.

Because this problem was not corrected within a reasonable time, the

. test-(in Section V.A of Appendix C to 10 CFR Part 2) for qualification

as a licensee-identified violation is no longer met. Failure to

establish and implement an adequate emergency procedure for earthquakes

is a violation of Technical Specification 6.8.1.a.

Violation (302/85-18-01): Inadequate emergency procedure for seismic

events.

The need for timely followup on licensee identified problems was

discussed in a telephone conversation between NRC regional and licensee

management representatives. Licensee representatives acknowledged

NRC's concern and indicated attention would be given to this matter.

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