ML20207E716

Insp Rept 50-443/86-30 on 860609-13.No Violations Noted. Major Areas Inspected:Emergency Preparedness Implementation Appraisal Followup,Including Organization & Training.Open Items Listed in Paragraph 6

ML20207E716
Person / Time
Site:	Seabrook
Issue date:	07/02/1986
From:	Lazarus W, Thomas W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20207E691	List: ML20207E687 ML20207E716
References
50-443-86-30, NUDOCS 8607220406
Download: ML20207E716 (11)

See also: IR 05000443/1986030

Text

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No.

50-443/86-30

Docket No.

50-443

License No.

CPPR-125

Priority

--

Category B 1-

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: June 9-13, 1986

Inspectors:

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date

! r Y~ . Y$2d -. W. Thbmas, EP '5peciaTi s't ' / Aate D. Perrotti, IE EPB Approved by: 7 W. L us,CC141ef, Emergency date Pre aredness Section Inspection Summary: Inspection on June 9-13,1986 (Report No. 86-30) Areas Inspected: Emergency Preparedness Implementation Appraisal Followup to evaluate the adequacy and effectiveness of the emergency preparedness program for Seabrook Unit 1, including organization, administration, procedures, training, and facilities and equipment, and open items from reports 85-32, 86-10, and 86-18. Results: No violations were identified. Soveral 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 prio.- to issuance of the low power license or the full power license. 86072:20406 860716 PDR ADOCK 05000443 G PDR- , _ _ _ . _ . - _ _ _ _ _ .

. . DETAILS 1. Persons Contacted .

• T. Beard, Senior Emergency Planner
• M. Campbell, Health Physics Foreman
• D. Flahardy, Health Physics Foreman
• D. Furguson, Licensing Engineer
• R. Gregory, Licensing Engineer
• T. Harpster, Emergency Preparedness Coordinator

R. Heinrics, RN First Aid Treatment Facility

• J

MacDonald, Radiological Assessment Manager

• J. Marchi, Startup QC Manager
• W. Middleton, QA Staff Engineer
• T. Pucko, Licensing Engineer

V. Sanchez, Site Licensing Supervisor G. Thomas, Vice President-Nuclear Production J. Warnock, Nuclear QA Manager

• Denotes those present at the exit interview.

2. Scope of_ Appraisal The purpose of this inspection was to followup on previous open items to determine the readiness of the Seabrook Station to implement the Emer- gency Plan in preparation for licensing. The principal criteria for this appraisal are contained in NUREG-0654, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants", 10 CFR 50.47, and 10 CFR 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, and the open items from Inspection Reports 85-32, 86-10, ana 86-18. 3. Summary of Results This report documents the followup of the areas for which review was completed during the previous inspections. Items which were listed as open items in the previous inspection reports are addressed in section 4. Those items which need to be addressed for resolution as a result of this inspecticn are listed as "open items". 4. Follow-up on Previous Inspection Findings (Closed) IFI (50-443/85-32-02): Define and document the interaction between the corporate Emergency Preparedness staff and the station staff. The licensee has defined and documented the interaction between the corpo- rate EP staff and the station staff in company memorandum SEP No. 860063, dated April 9, 1986. This memo covers normal station operation. A series

. . 3 , of organization charts in Procedures ER 3.1 through ER 3.3 documented the organizational interaction during emergency conditions. The Seabrook Station organization chart will contain the updated organization interface between the EP staff and the station staff. (Closed) 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. The responsibility to perform initial dose assessment has been 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, included initial dose assessment as a non-delegable responsibi- lity of the Shift Superintendent or Short Term Emergency Directory in accordance with Amendment 59 to the FSAR. (Closed) IFI (50-443/85-32-09): Implement the respiratory protection pro- gram and assure that adequate supplies of respiratory protective equipment are maintained at the onsite assembly areas for emergency workers. The inspectors reviewed the procedures which implemented the respiratory protection program and toured the facilities containing respiratory pro- tective equipment for emergency workers. Annual medical examinations were required for all SCBA users. Respiratory protection training (S78) and S67F, Use of Self-Contained Breathing Apparatus (SCBA) training were also ' required. The training department had scheduled 10 sessions in May and 4 in June for respiratory training in order to meet the " Core Load" commit- ment date. SCBA training will be a continuing function and will be given on an as-needed basis once the key emergency workers have completed train- ing. Memorandum SS No. 23993 identified by department, all personnel who were required to complete training by the end of June, who required medi- cal exams, and who needed respiratory protection training. To date approxi- mately 70% of the required personnel had received the training. The capability to refill breathing air bottles was maintained on site in the Engineering Office Building (E0B). The E0B contained an operational compressor, cascade fill system, and a water bath. Also contained in the E08 were stores of extra bottles. Procedures for filling bottles and for operation of the compressor were contained in Operations Department instructions ODI.06 and ODI.07. These procedures contained the required specifications for Grade D purity set by the Compressed Gas Association for breathing air. Procedures for repair, inspection, and maintenance of respiratory equipment were contained in station operating procedures HD0965.02 and HD0965.03. The respirator cleaning facility was located near the Health Physics Access control point. The cleaning facility con- tained stores of respirator equipment, cleaning agents, and facilities for sanitizing, inventory, and inspection of respirator equipment. Emergency Respiratory Protective Equipment as specified in ER-8.1 was located in the TSC, OSC, Route 107 warehouse, and the EOF. Based on the above findings this portion of the licensee's program is acceptable. i - - - -- ~ - . - -

. . ' 4 (Closed) IFI (50-443/85-32-10): Complete and equip the first aid / treatment facility to allow treatment of contaminated injured personnel. The inspectors toured the first aid treatment facility located in.the Administration Building near the Health Physics Access control point. The facility has been fully equipped with the equipment specified in the FSAR Emergency Plan Section 10.5.1. (Closed) 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 notification and not later than one hour after the time the license declares on of the Emergency Classes. The inspector reviewed revised ER-2.2, notification of Off-Site authori- ties, Revision 04, Dated May 29, 1986 and noted that Section 3.2 contained the requirement to notify the NRC within one hour of declaration of the emergency. (Closed) IFI (50-443/85-32-14c): Form 2.2A, Initial Notification Fact Sheet, does not contain provisions for recording or reporting whether a release is in progress (NUREG-0654II.E.3). Block 5. of revised ER 2.2A contained provisions for recording or report- ing whether a release is in progress. (Closed) IFI (50-443/85-32-14d): None of the Control Room crews was able to accomplish the dose assessment problem postulated. The inspectors verified that the HP41CV calculators had been issued and that all Control Room Shift Superintendents had received training and could perform the initial dose assessment. The revised procedure provided the capability to serform dose assessment at the site boundary, 2 mi., 5 mi., and 10 mi. d1 stances. (Closed) 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. , l The inspector determined that all shift crews had received additional training recognition of radiological assessment information necessary to perform offsite dose assessment including the technical specification design leak rate through containment penetrations. (Closed) IFI (50-443/85-32-141): Shift crews were unaware of the capabili- l ties of the post accident sampling system (PASS). Training of the opera- l tors in this area has not yet been conducted due to the fact that the PASS i ! ( l l . - - - .-. . _ _ _ . _ _ _ _ , _ _ _ _ _ _

. . 5 . installation has not been completed. This will be reviewed in a subse- quent inspection. The inspector determined that information on the capability of the PASS had been communicated to all control room crews by Memorandum No. SEP 860042, dated March 17, 1986. (Closed) IFI 85-32-15d: Emergency Plan Training instructors do not meet the experience requirements of ANSI N18.7. This item referred to the fact that the licensee staff has not taken over ! the training function from the contractor who is presently conducting the training. The contractor instructors are qualified in accordance with ANSI-N18.7, and the licensee is aware that when they assume this function their instructors must also meet these requirements. (Closed) IFI (50-443/85-32-18): Complete the details of the facility, equipment and organization for the Media Center. The 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. The inspectors reviewed the recen'tly approved procedures which implemented the Media Facility. These procedures included ER-3.4, "Seabrook Station News Service Operation;" ER-3.5, " Media Center Operation;" and ER-9.1, "Public Information Interface." All procedures were dated June 13, 1986. The procedures specify the actions required to activate and operate the Station News Service, Media Center. ER-9.1 provides guidance to ensure , that an adequate and timely exchange of information occurs between the NHY organizaticn: and the Public Media organizations. (Closed) IFI 50-443/85-32-22: Implement the T.S. 6.9.2 required surveil- lance of meteorological monitoring instrumentation. The licensee has drafted procedure IX 0654.550, " Met System Checks / Data Collection," to comply with Technical Specifications 6.9.2. , (Closed) IFI 50-443/85-32-23: Revise calibration procedure IX 0654.410 to reflect required accuracy of 0.1 C for Delta -T measurements. The inspector reviewed procedure IX 0654.410 Revision 0 and verified j that the procedure reflected the required 1 0.1 C accuracy requirement. (0 pen) IFI 50-443/85-32-24: Provide the basic data required for atmos- pheric dispersion calculations (15 minute averages) which include a 'ime history of wind direction and speed at each level, and temperature s.1- ,

ference with height, in the control room and EOF. The inspector verified that the Data Acquisition system hardware has been > modified to provide the information. However, software installation and , testing has not been completed.

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. . 6 (Closed) IFI (50-443/86-18-02): The Security Officers Lesson Plan which addresses protective actions does not address the use of KI as a protec- tive action. This should be added, and additional and appropriate mate- rial 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. The inspectors reviewed tho revised Module 12, Security Lesson Plan, approved June 5, 1986. The revised lesson plan addresses the use of KI as a protective action, purpose, use, and effects. The lesson plan also identifies the Radiological Controls Coordinator as the individual respon- sible for determining the need to dispense KI. (Closed) IFI (50-443/86-18-04) Section 4.2.64 of the General and Specialty Training Program Manual lists Course S65, " Mitigating the Consequence of Core Damage." Two levels of management are targeted for this training wnich pertains to EP. Since managers will, in general, fill key ERO posi- tions, this course should be added to Figure 18.2, Revision 03 as required training for the Response Manager, EOF Coordinator (auditor basis only), Short Term Emergency Director, Site Emergency Director, and Emergency Operations Manager.

The inspectors verified that S 65, " Mitigating the Consequences of Core Damage," was required for the Response Manager, Site Emergency Director, EOF Coordinator, Emergency Operations Manager, and the Short Term Emer- gency Director. The licensee's response to this item is acceptable. (Closed) IFI (50-443/86-18-08) Calibration and operational testing of the Radiation Data Monitoring System (RDMS) was not complete. The inspectors verified that final acceptance testing and calibration had been completed. (0 pen) IFI (50-443/86-18-11): The guidance of NUREGs 0696 and 0654 has been met, except in the case of NUREG-0654 II HS, equipment installation (e.g., seismic, rad, etc...) which is not yet complete. The inspectors verified that all required instrumentation and equipment readouts required in the Control Room had been installed. However, the

seismic monitors have been removed pending completion of construction activity. After construction is completed this item will be reviewed. (Closed) IFI (50-443/86-18-12 and 86-18-29): Implement station Security Plan and demonstrate accountability. The protected area perimeter was established on May 1, 1986. The inspec- tors observed an evacuation and accountability drill on June 11, 1986, during which accountability (identifying those persons in the protected area whose location was not known) was completed in 25 minutes (30 minutes is the goal). Twelve persons were not accounted for. Nine were subse- . I l - - - - - - -- ._ - - - - - - - - - - - - - - - -_. -- .

. . 7 quently identified as exempt. Two were unaccounted for because guards placed two badges into the racks without inserting them into the computer card reader. The last " missing person" involved a badge that had been reported lost, but guards had not properly identified it as lost by placing a " yellow card" in the badge rack. The demonstration of account- ability was acceptable. This area will be observed routinely during future exercises. (Closed) IFI (50-443/86-18-13): Provide backup means of communicating with off-site radiological r nitoring teams in the event of loss of radio commu- nications. The inspectors verified that 2 commercial telephone numbers to contact the E0F had been included in the off-site monitoring team kit procedure form ER-5.2A Revision 05. (Closed) IFI (50-443/86-18-14): Include specific instructions to the Off- site Monitoring Coordinator regarding the use of respiratory equipment and the administration of KI by the field monitoring teams for protection from airborne hazards. The inspectors verified that ER 5.2, " Site Perimeter and Off-site Monitor- ing anc Environmental Sampling," Revision 05, dated June 5, 1986 included specific instructions to the Off-Site Monitoring Coordinator regarding the use of respiratory protective equipment and KI. (0 pen) *IFI (50-443/86-18-15): Draft appropriate procedures for the per- formance of onsite (out-of plant) radiological surveys. Procedure ER-4.8, " Emergency Onsite Radiological Surveys," Revision 0, has been developed for onsite surveys. The procedure should be reviewed and clarified with regard to the following. All reference to PASS and its accompanying high radiation levels should be deleted from this procedure and incorporated into the PASS series (ER-6) procedures. Survey maps that are referenced should be attached to the procedure. The procedure con- tains no data sheets for recording survey / sample information (for example, see ER-5.2A through 5.20). This item will be reviewed in a subsequent inspection. (Closed) IFI (50-443/86-18-18): Revise T.S. 6.4.2 and implement the QA Audit Program for emergency preparedness. The inspector verified that a correction to the Proof and Review Technical Specifications was submitted to NRR on April 22, 1986, adding the Emer- gency Plan and implementing procedures to the last of required audits. The QA Manual was also revised to reflect the correct reference of T.S. 6.4.2. (Closed) IFI (50-443/86-18-19 and 86-18-20): Issue revised emergency, alarm, and abnormal procedures, and conduct operator training in the revised procedures. 1 I

. . 8 The licensee has reissued the majority of the procedures that were pre- viously in draft format. Procedure changes are routed to operators as required reading and included for review during operator requalification training. This area will be included in a separate review to determine adequacy of procedures and operator training / retraining. (Closed) IFI (50-443/86-18-21) 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 E0F coordinator. (NUREG-0654 II B 4). The inspectors verified that revised Form 2.2A, Initial Notification Fact Sheet had been corrected to allow authorization by only the Short Term Emergency Director (STED) Emergency Director (ED), or the Recovery Manager (RM). (Closed) IFI (50-443/86-18-22): The notification forms in procedures ER-1.5 do not include information regarding type of release, projected integrated dose at the site boundary, and projected dose rate or inte- grated dose at ten miles. The inspectors verified that revised Form 2.28, Revision 4 contained spaces for the following information; radioactive release rate data, meteorological data, and off-site exposure data, including dose rates and integrated doses at the site boundary, 2 miles, 5 miles, and 10 miles for whole body, and thyroid. (Closed) IFI (50-443/86-10-02 and 86-18-24): EK-1.4 directs evacuation of site personnel to the Seabrook Greyhound Dog Track when the wind is from the east. The licensee has issued Revision 5 to procedure ER-4.1 " Personnel Accounta- bility/ Evacuation," to require evacuation of station personnel at an ALERT. No contamination would be likely at that time, and use of the dog track as an off-site assembly area would not be necessary. In case of a faster breaking event where personnel were potentially contaminated, they would be evacuated to the dog track contingent on evaluation of plume track and expected dose rates at the track. (Closed) IFI (50-443/86-18-30): Complete security training for station personnel. On May 1, 1986, the protected area was established. Unescorted access has been limited to those who have completed the required General Employee Training, including security. (0 pen) IFI 50-443/86-18-32: Complete the orientation and off-site training program for New Hampshire and Massachusetts state and local officials.

, . 9 The training is described in procedure ER-8.2, Revision 3 as " Emergency Support Group Training." Some training has been conducted, however due to the length of time involved since the last exercise and the anticipated ' submission of the Massachusetts Emergency Plan, the training will be com- pleted (and the effectiveness evaluated in an exercise) prior to issuance of a full power license. (0 pen) IFI (50-443/86-18-33): Complete installation and testing of the Alert and Notification system sirens . The inspector reviewed General Test Procedure GT-E-115, " Electronic Outdoor Warning Siren Remote Station Initial Test and Energization Procedure," and the test results for tests conducted between May 2-30, 1986. Testing was satisfactory for all but three of the 144 sirens. These three had not been installed due to litigation or gaining an easement. GT-E-115 is a local silent test of the sirens. An activation test will be conducted prior to issuance of low power license to verify that the sirens can be successfully activated from a remote location. Followup on installation of the remaining sirens, and activation testing will be conducted in a subsequent inspection. (Closed) IFI (50-443/86-10-01): Classification of the Chlorination Building explosion during the February,1986 exercise was incorrect. The licensee issued Revision 5 to procedure ER-1.1 " Classification of Emergencies" which clearly classifies an explosion (without station damage) on or near site as an UNUSUAL EVENT, and as an ALERT if station damage results. (Closed) IFI (50-443/86-10-03): No security department representative is assigned to the Technical Support Center during activation. The licensee has evaluated the need for having security department repre- sentation in the TSC and concluded that having a security supervisor available to assist at the TSC as necessary was satisfactory. The inspec- tor concurred with that determination. (Closed) IFI (50-443/86-10-09): Procedure ER-3.2 in the OSC has not been revised to reflect the latest change to Form ER-3.28 (Revision 2). The licensee has issued and distributed ER-3.2, Revision 3. 4 (Closed) IFI (50-443/86-10-10): Extremity TLDs were not considered for the containment . .mosphere sample team although they were involved in handling a 40R/hr (contact) source. Revised form ER-3.28 (Rev. 2) does not have provisions for the Radiological Controls Coordinator to specify the use of extremity TLDs (ER-3.2 and ER-6.2 contain these provisions). Form ER-3.2B has been revised to include a provision for extremity TLDs. , ,-e - --. .., ---.r.,, -- - - . . - --,-. .- --r --n ~, - - - + n--. - e - . - . -.,,w., n --r -.

. . 10 (Closed) IFI (50-443/86-10-12): The method of tracking personnel exposures of re-entry team members is not clearly specified. Procedure ER-3.2, " Operational Support Center Operations," Revision 3 includes the instructions for tracking personnel exposures using Form ER-4.3B. (Closed) IFI 50-443/86-10-15: Delays occurred in EOF decisionmaking due to lack of trending critical parameters. The licensee has installed status boards displaying graphical trends for 15 critical plant parameters in a manner identical to that used in the TSC. (Closed) IFI (50-443/86-10-17): There is no PA speaker in the dose assess- ment areas of the EOF. Several important announcements were not heard as a result. The licensee has added a new speaker at the dose assessment area in the EOF. Memo from P. Casey to D. Fergeson, dated May 6, 1986, indicated that the speaker was installed on March 4, 1986, and successfully tested. This item is closed. 5. Medical Emergency Drill The licensee conducted a medical emergency drill on June 11, 1986, simula- ting an injury to a workman which included radioactive contamination. The objective of the drill was to demonstrate the ability to transport and treat a contaminated individual at an off-site medical facility. The simulated injury involved a broken lacerated arm, with excessive bleeding. Skin contamination was simulated to vary from 500-8000 cpm on the upper torso of the individual. The man was initially treated by site health physics and Emergency Medical Technicians. Based on the mans physical condition, the decision was made to transport the man to the Exetu Hospital for treatment. Ambulance response from the Seabrook Fire Department was prompt. Contamination control during transporting the man to the hospital was good. The hospital emergency room staff was alerted by radio of the extent of injury, the patient vital signs, levels of skin contamination and expected arrival time. Response involved preparing the Emergency Room entrance and floors with a plastic floor covering to pre- vent spread of contamination and preparing the cast room as a treatment area. Protective clothing was donned by the emergency room doctor and two nurses. Preparations were completed well before the ambulance arrived. Two health physics technicians responded from the site to assist in pre- paration and contamination control during the treatment of the injured man. Upon arrival of the ambulance, the medical staff decontaminated the injured man and treated the injuries. The response of the hospital emer- gency room staff was excellent. Their knowledge of procedures and their ability to implement them in a timely, professional manner reflected an

, . 11 adequate degree of readiness to handle this type of casualty. No defici- encies were identified in'this area. 6. Summary Listing of Open Items 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.

• (85-32-06): Provide additional qualified alternates for key ERO positions

to assure the ability to staff the augmented organization on a 24 hour basis. (85-32-24): Provide for maintaining a historic record of basic data required for atmospheric dispersion calculations.

• (86-18-07): The initial dose assessment model assumes no iodine in

the release. (86-18-11): Installation of instrumentation in the CR is not complete (NUREG-0654 II.H 5).

• (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.

• (86-18-32): 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.

• (86-18-34): Complete installation of the Post Accident Sampling System

7. Exit Interview At the conclusion of the inspection on June 13, 1986, the inspectors 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. }}