* Denotes Licensee and NUSCO personnel who attended tne exit meeting
The inspector also observed the actions of, and interviewed other Licenseeand NUSCO personnel.
2.0 Follow-up on Previous Inspection Findings
(CLOSED)(50-245/87-13-01) Inspector Follow-up Item. Training in bmebsweep procedures indicated. This training was provided during the Intcycle.
(CLOSED) (50-245/ 87-13-02) Inspector Follow-up Item. Training isindicated for operators in the consequences of Protective Actions (pas).The State of Connecticut Posture Codes coupled to NRC's Emergency ActionLevels (EAls) are in use. Protective Action Recommendations (PAPS) are,therefore, associated with the EAL. The operators do not recommend PARSand, hence, do not require training in the consequences of pas.
(CLOSED) (50-245/87-13-03) Inspector Follow-up Item. Net all NuclearSecurity Officers (NS0s) are respirator trained and fi:ed. All NS0swith the exception of those on maternity leave are respirator trainedand fitted.
(CLOSED)(50-245/87-13-04) Inspector Follow-up Item. Om ' b Ass rancedoes nt . use a check list when reviewing the Emergency bwedricu.Program (EPP). The annual Quality As.urance review cw-rs all 15 araseach year and a cheek list is, therefore, not necessary.
,. .
f .. .
.. .
''
yi ;
3,
(CLOSED) (50-245/86-14-03) Inspector Follow-up Item. NRC Health PhysicsNetwork (HPN) phones have not been installed. Six (6) HPN phones havebeen installed and are functional.
3.1 In order to determine if the Licensee has established an organization ;
which has developed and maintains an Emergency Plan (EP) which meetsthe standards in 10 CFR 50.47(b) and the requirements of Section IVof Appendix E to 10 CFR 50, as applicable, the inspector reviewed
,
I
the organizational structure, interviewed managers and personnel - ,
and identified ongoing emergency planning activities.
3.2 Northeast Utilities (NU) is a utility holding company with fivesubsidiaries including two nuclear generating companies and a service ;
ccmpany (NUSCO). One of the generating companies is the Northeast f
Nuclear Energy Company (NNECO) which operates the Millstone NuclearPower Station. Another, Northeast Service Company (NUSCO) has iestablished an Emergency Preparedness Program (EPP) which has i
developed, maintains and up-dates the EP and provides the essential '
logistics to support the Emergency Response Organiza+. ion (ER0) atthe site and at Northeast Utility (NU) headquarters in addition toproviding support and training to the State and Towns includingmairitaining the Public Alert' System (PAS) and the Public Informa-tion Program. In addition, EPP develops drill and exercise -
scenarios and is responsible r the associated logistics. A NRC t
observed exercise and three drills are conducted each year atMillstone. The EPP is supported by the NUSCO Training Department, aunit of the Connecticut Light Power Company (CLP) and several sitegroups. Scenario development support is provided by ReactorEngineering and Operations. With the exception of Corporate Head-quarters, ERO personnel are drawn from the itcensee's site staff.
,
The site Nuclear Emergency Preparedness Coordinators have not been L
assigned an active ERO function.
3.3 The CPP is "locateu" within the Engineering Division of NUSCO andis, administrative 1y, one of four Sections comprising the Radio- !
bgical Assessment Branch (RAB) which is headed by a third levelNUSCO manager who is, de facto, the Corporate Emergency Planner. t
The EPP staff is headed by a first line supervisor and numbers ten;two of these ten are assigned to the Millstone site. The EPP staffyears of cumulative experience numbers approximately 43, 25 of whichare accounted for by the RAB manager, the EPP Supervisor and thesite Senior EPC. Each of these individuals had prior EP experiencebefore joining NU. The remaining EPP staff at Berlin averages three !years of experience each. With the exception of the RAB manager, |none of the EPP staff is trained on the graduate level in Nucicar
~i
Engineering or Health Physics or has a reactor operations background.. The EPP Supervisor holds an engineering degree and has received! additional training in Health Physics. EP training opportunities are
available to the staff. Site EPCers have not yet observed operators!i
when undergoing simulator training to recognize events and symptoms,correlate these with Emergency Ops ating Procciures (EODs) orassociated procedures, classify :nd notify.
3.4 Executives and managers are routinely U volved with EP to varyingdegrees. The Divisional Vice President is actively involved withan industry group concerned with severe accident analysis. Hemaintains qualification as a Corporate Emergency Director (CED),reviews drill and exercise scenarios as well as changes to the EP andit's Implementing Procedures, manages by exception data, will takedisciplinary action against those personnel who should participate indrills and exerciset sut don't and could have done so. He maintainsan active interface with the State and Town Governments. TheDepartment Director has an extensive background in severe accidentanalysis. He routinely acts as an exercise or drill controller ar.duses "standard" management techniques to keep abreast of EPactivities. The RAB Manager devotes about half time to EP.Activities include ongoing contacts with the State and towns,interface with site managers and meeting with his EP Supervisor.
3.5 The EPP is located within an engineering division and departmentand is managed by engineers; it is a multi disciplinary program.Staff consensus indicattd additional and on going training is neededif future EPCers are no- to become narrow and weak generalists. SiteEPCers are considered ar essential function.'
Based on the above findings, this segment of the Licen e's EPP isacceptable.
4.0 Training
4.1 To ascertain if adequate radiological training for NU and off sitepersonnel is provided as required by 10 CFR 50. 47(b)(15) and SectionIV F of Appendix E to 10 CFR 50, the training organization wasreviewed, training matricies, lesson plans, examinations, and graderecords were studied and personnel interviewed.
4.2 Training is largely the responsibility of the NUSCO Nuclear TrainingDepartment (NT) the Director of which reports to the Vice Presidentfor Nuclear and Environmental Engineering. NT act1;1 ties areconcentrated at the Nuclear Trainin) Center located at the Millstonesite. The NT staff numbers about 120, three of whom are dedicated toEP training which is the responsibility of General Nuclear Training.EP training is provided for each site and Corporate Headquarterspersonnel; there is, in addition, a Nuclear Fire Training group atNiantic. This training is available to NU and community fire-fighters. Specialized training is given by subject matter expertswho may be members of the NU staff or contractor employees (ex.medical training is provided by the the Yale University Hospitalstaff). NT trainers are qualified following eisnt (8) days oftraining; they also participate in The Northeast Training Workshop
,.
- - - .
_ _ _ _ _ _ _ _ _ _ _ _-- __- - - _ _
** J. .
,
..
>'
5
and Conferences and may receive in-house training. The Supervisor,General Nuclear Training, audits training sessions and stated he issatisfied with the quality of the training.
4.3 There are 28 Lesson Plans (LPs) for the 21 ERO positions. TheseLPS are not based on job ' task analysis (JTA). A pilot program isunderway using four (4) EP LPS to determine the use of this approach.All LPs are reviewed annually and revised as necessary to reflectfeed back from drills and exercises. Every EP and EP ImplementingProcedure change goes to Training. A Training Project Control*
Committee has been established which meets monthly; EPCers, Operatorand Health Physics trainers may attend these meetings. Each Lo coversheet provides signature blocks for subject matter experts, another'
trainer and the S"pervisor, General Nuclear Training, who review andapprove these. A Nuclear Training Manual (NTM) has been developedand has been under review for a year. It is still classified as adraft; final approval is expected this year.
' 4.4 If scheduled training is missed, makeups must be scheduled. Linesupervisors are responsible for insuring all their staff members areproperly trained and currently qualified. Th9 NTC is responsiblefor training and providing the sites with negative training results.The site determines the outcome of negative training results.Training is classified as significant or interim. Significanttraining is classroom training while interim training is read and2
| sign. Eighty (80) percent is the passing grade.
4.5 Operators are trained in Emergency Action Level (EAL) classification.
! and associated communications procedures. Managers and directors2 are, in addition, trained in Protective Action Recommendations (PARS)i and the Connecticut State Posture Codes. At the time of this' inspection about 600 site personnel were trained for one or more of
the 21 ERO positions 15 of which are on call positions and six are4 support positions. There are, at least, five persons qualified for
each ERO position.
' 4.6 About 70 Corporate personnel are trained for Corporate OrganizationNuclear Incidents (CONI); these personnel man the Corporate
'
Emergency Operating Center (CE0C). One quarter of these are assignedto Dose Assessment. Training had not begun at the time of this,
inspection but all are within the nine to 15 mcath requalification'
| window. Completion of this training will be verified by inspectionprior to the first 1988 NRC observed exercise. Training in severeaccident is being offered for the first time to select CONI
|personnel.
4.7 Training is offered to State and Town personnel in three areas.,
Attendance is taken but examinations are not administered. Thistraining fc,r 1988 was underway at the time of this inspection end
[ had been largely completed. This training included review of EAls; and PARS.\
. - - . - . - - - _ - ._ -
_ _ _ _ _ _ _ _ _ _ _ _ _
l
[-
. .., ..
6
Based on the above determinations, this portion of the Licensee's EPP isacceptable.
5.1 E0Ps and $ssociated Abnormal Operating Procedures (AOPs) were checkedfor each of the three Millstone Units as were EALs to determine ifthe requirements of Section IV B of Appendix E to 10 CFR 50 andstandard 10 CFR 50.47(b)(4) are met.
5.2 E0Ps and A0Ps as well as appropriate administrative procedures containreferral to Emergency Plan Implementing Procedures (EPIPs) for EALdetermination. The classification scheme is found in EPIP-4701wr. ch contains colored coded, human factor engineered classification'
charts. Events, symptoms and barrier breech analysis are factoredinto these charts. Since PARS are associated with the Posture Codes,they cre predetarmined; only two PARS are listed and these are forGeneral Emergency (GE); they are designated GE Bravo and GE Alpha.Operator EP training includes use of classification and notificationprocedures.
Based on the above findings, this portion of the Licensee's EP isacceptable.
6.0 Emergency Response Facilities (ERFs)
6.1 The Control Rooms, Technical Support Center, Operatiors Support CenterEmergency Operations Facility (EOF) and the Corporat; Emergency OperationsCenter (CE0C) were checked to determine if they are properly equip e dand currently maintained in keeping with the requirements of Section IVE of Appendix E to 10 CFR 50.
6.2 Each facility was checked. Plans and Procedures we,a current.
Equipment was functional and within calibration windows. SelfContained Breathing Apparatus, face pieces and canisters wereproperly stored and useable. EOF filter banks were maintainedper schedule and the E0F emergency diesel electric generator fueltank was full. The protection factor for the EOF is 500.
6.3 Eighteen on the off site communications systems were identified.These include dedicated, hard wired, point to point telephonecircuits, commercial phone lines going to different exchanges,NU and commercial microwave transmission capability, fiber opticslines, facsimile machines and data transmission capability. Oper-ability of phone systems was checked on a sampling basis. Alllines so checked were found to be functional. The NRC's ENS andHPN lines are included in the preceding listing.
6.4 The ERO is activated by voice pager which is tested twicedaily. The inspector observed one test; results were satisfactory.Test records also indicate acceptable results. Monthly verification
i
.w--
/ :, .
. .
7
tests are also made and results are recorded. Records of thesetests indicate acceptable results. The Millstone Director on calldoes not have a cellular phone while the Duty Officer does. Since inthe event of a fast breaking accident, the State might wish todiscuss the timing of PAR implementation or extent, contact with theDirector during transit to the site is recommended. This matter wasdiscussed with the Licensee who agreed to review the matter. Thiswill be subject to a follow up inspection.
Based on these findings, this portion of the Licensee's program isacceptable.
7.0 EP-Security Interface
7.1 To ascertain if Nuclear Security Officers (NS0s) were properly trained,qualified and annually requalified to support implementation of the EP,the inspector checked their training program ar.d records.
7.2 NS0s are EP trained and are also Radiation Worker qualified, as wellas respirator trained and fitted. Training extends to search andrescue plus accountability.
Based on the above facts, this portion of the Licensee's program isacceptable.
8.0 Off Site Activities
8.1 To determine if the Licensee's on going activities meet the requirementsof Section IV D of Appendix E to 10 CFR 50 and appropriately supportoff site entities, the inspector interviewed State officials, reviewedthe test records for the Alert and Notification System, inspectedthe Joint News Center and reviewed dissemination of information tomembers of the public within the ten mile Emergency Planning Zone(EPZ).
|
8.2 There are 125 four function sirens within the 180 degree EPZ forMillstone. One of these functions is the public alerting system.These sirens are battery mounted atop 3c foot, dedicated poles.Surveillance is conducted manually every other week. In addition,
there is a quarterly load test in lieu of a growl test as well as an;
annual test when all the sirens are acitated. About 90% of theTowns carry out monthly full function tests. Malfunctions arecorrected as soon as possible; this activity is the responsibility ofthe NU Regional Test Group at Madison, CT. Results are sent to the
l Connecticut Office of Civil Preparedness (OCP) for retransmittal toU.S. FEMA-I. Results for 1987 were sent to the OCP on January 22,1988 and indicated 96N availability. Surface water clearance'
procedures are in place.
8.3 Seventeen Letters of Agreement (LOAs) are current with State, U.S.government entities, Police, Fire and Ambulance services, Amtracand bus companies.
iI
l
-
~, .
.
8
8.4 The Joint News Center (JNC) is co-located in the State E0C inHartford. A NU work area is also provided at this location sized toaccommodate four persons. The press briefing room seats 42comfortably and and has 12 press phones. A rumor control area isestablished with space for eight tables. The Emergency BroadcastSystem center is also located here. A Media Training Manual has beendeveloped and the annual media briefing session held.
8.5 A two page insert has been placed in sev=n telephone directoriesfor both sites. This information appears in 470,000 phone books.Evacuation routes are shown, EBS and TV stations are listed andreception centers identified and correlated with evacuation routes.Instructional material is not mailed to residents. Similar materialfor farmers has been prepared; 4200 out of 10,000 copies have beendistributed. About 20,000 transient hand outs have been printed andare distributed at parks and recreational centers. A Spanishlanguage emergency information brochure has been prepared.
8.6 State and Town officials have been briefed with respect to EALs,PARS and the Posture Codes.
8.7 Connecticut State Office of Civil Preparedness personnel stated theywere satisfied with the License's support and cooperation.
Bases on the above, this portion of the Licensee's EP is acceptable.
9.0 Independent / Review Audit
9.1 10 CFR 50.54(t) requires an a,nual review / audit of the EP by qualifiedindividuals having no direct responsibility for program implementation.The inspector checked review orotocol, records and results to determineif this requirement is met.
9.2 The review is conducted by staff members of another Section of theRadiological Assessment Oranch in which th EPP is located. Thereis no matrix since all aspects of the EPE are covered annually.The reviews are conducted in four quart. ly segments and includedetermination for adequacy of the Stat and local government inter-face. Findings and recommendations r-,t be acted upon satis-factorily. Reports are distributed annually. A review of resultsobtained so far this year indicates they are extensive but resemblea compliance datermination since the quality of the EP and it'ssupporting resources are not addressed.
Based on these findings and with the exception of the nature of th: activity.this portion of the Licensee's EP appears acceptable.
.
|
T
'| : .
. .
9
10.0 Dosimetry
10.1 To find out if the Licensee is maintaining and calibrating ventmonitors and meteorological sensors tower, operation and calibrationrecords were reviewed and methodology was discussed with staff. Thissegment of the inspection relates to 10 CFR 50.47(b)(9).
10.2 Sensor and electronic calibration records indicate that maintenanceand calibration is conducted per the established schedule.Instrumentation was functional and in calibration. No determinationas to the adequacy of techniques was made. This will be doneduring a future inspection.
10.3 Dose calculations were intercompared with results obtained by theConnecticut State Department of Environmental Protection using the a
same source terms and MET data. Results showed good agreement.
Based on the above, this po"tion of the Licensee's EP is acceptable.
11.0 Exit Meeting
An exit meeting was held with Licensee personnel listed in section 1.0 ofthis report. The Licensee was advised no violations were identified. Theinspector also discussed some areas for improvement. The Licenseeacknowledged these findings, and agreed to evaluate them, and institutecorrective action. At no time during the course of the inspection did theinspector give the Licensee written material.
