IR 05000280/1982005

IE Emergency Preparedness Appraisal Repts 50-280/82-05 & 50-281/82-05 on 820315-26.Noncompliance Noted:Deficiencies in Emergency Plan Re Training,Procedures & Initial Dose Assessment

ML20058H400
Person / Time
Site:	Surry
Issue date:	05/21/1982
From:	Huffman G, Jenkins G, Marston R, Mcfarland C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20058H245	List: IR 05000280/1982005 ML20058H244 ML20058H299 ML20058H330 ML20058H357
References
50-280-82-05, 50-280-82-5, 50-281-82-05, 50-281-82-5, NUDOCS 8208030574
Download: ML20058H400 (48)

Text

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UNITED STATES

NUCLEAR REGULATORY COMMISSION o

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E REGION li 101 MARIETTA ST., N.W., SUITE 3100 g

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ATLANTA, GEORGIA 30303

Report Nos. 50-280/82-05 and 50-281/82-05 Licensee:

Virginia Electric and Power Company P. O. Box 26666 Richmond, VA 23262 Facility Name:

Surry Units 1 and 2 Docket Nos. 50-280 and 50-281 License Nos. DPR-32 and DPR-37 Inspection at S rry Nuclear Sit near Surry, Virginia

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2-/ 82 Inspectors:

_.l. H0ffma [J$am Leader)

Date Signed h W f,. //

5/yl Signed l2_

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McFarland Date k.

El2tlD f~. _ R. Marston//

Date Signed Accompanying Personnel:

J. Gilliland, W. N. Herrington, W. Knox, K. Swinth, E. H.

arkee

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M Approved by:

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G. R. Jehki

, Section Chief D' ate Signed Emergency eparedness and Operational Support ivision SUMMARY Inspection on March 15 - 26, 1982 Areas Inspected This special, announced inspection involved 660 inspector-hours onsite and offs.ite in the performance of an Emergency Preparedness Implementation Appraisal, including administration, emergency organization, training and retraining, emergency facilities and equipment, procedures, coordination with offsite groups, drills and exercises, and evaluation of the Emergency Plan.

Results In the areas inspected, no violations or deviations were identified. Emergency preparedness deficiencies were identified in three areas:

Training, paragraph 3.1; Procedures, paragraphs 5.1 and 5.3; and Initial Dose Assessment, paragraph 5.4.2; (These items have been addressed by the confirnation of action letter of April 6,1982.)

8208030574 820727 PDR ADOCK 05000280 G

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TABLE OF CONTENTS INTRODUCTION PART I DETAILS 1.0 ADMINISTRATION 2.0 EMERGENCY ORGANIZATION 2.1 Onsite Organization 2.2 Of fsite Organization 3.0 TRAINING / RETRAINING 3.1 Program Established 3.2 Program Implementation 4.0 EMERGENCY FACILITIES AND EQUIPMENT 4.1 Emergency Facilities 4.1.1 Assessment Facilities 4.1.2 Protective Facilities 4.1.3 Expanded Support Facilities 4.1.4 News Center 4.2 Emergency Equipment 4.2.1 Assessment Equipment 4.2.2 Protective Equipment 4.2.3 Emergency Communication Equipment 4.2.4 Damage Control / Corrective Action and Maintenance Equipment and Supplies 4.2.5 Reserve Emergency Supplies and Equipment 4.2.6 Transportation 5.0 PROCEDURES 5.1 General Content and Format 5.2 Emergency, Alarm, and Abnormal Occurrence Procedures 5.3 Implementing Instructions 5.4 Implementing Procedures 5.4.1 Notification 5.4.2 Assessment Actions 5.4.3 Protective Actions 5.4.4 Security During Emergencies 5.4.5 Repair / Corrective Actions 5.4.6 Recovery 5.4.7 Public Information e

6.5 Supplementary Procedures 5.5.1 Inventory, Operational Check and Calibration of Emergency Facilities and Equipment 5.5.2 Drills and exercises 5.5.3 Review, Revision, and Distribution of Emergency Plan and Procedures 5.5.4 Audits 6.0 COORDINATION WITH OFFSITE GROUPS 6.1 Offsite Agencies 6.2 General Public 6.3 News Media 7.0 DRILLS, EXERCISES, AND WALK-THROUGHS 8.0 FOLLOWUP ON PREVIOUSLY IDENTIFIED EMERGENCY PREPAREDNESS ITEMS 9.0 PERSONS CONTACTED 9.1 Licensee Personnel 9.2 Other Organizations 9.3 NRC

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INTRODUCTION The purpose of this special appraisal was to perform a comprehensive evaluation of the licensee's emergency preparedness program.

This appraisal included an evaluation of the adequacy and effectiveness of areas for which explicit regulatory requirements may not currently exist.

The appraisal effort was directed toward evaluating the licensee's capability and performance rather than the identification of specific items of noncompliance.

The appraisal scope and findings were summarized on March 26, 1982, with those persons indicated in Section 9 of this report.

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a 1.0 ADMINISTRATION 1.1-1.4 Responsibility Assigned, Authority, Coordination, Selection and Qualification The administration of the Emergency Preparedness Program was reviewed with respect to the requirements of 10CFR50.47(b)(1) and (16); 10CFR50, Appendix E, Paragraphs IV. A and G; and the criteria in NUREG-0654, Sections II. A. and P.

The overall responsibility for Emergency Preparedness within Vepco lies with the Vice President of Nuclear Operations in the Richmond, Virginia corporate office.

The overall responsibility at the Surry Power Station lies with the Station Manager.

The corporate Emergency Planning organization is comprised of the Manager for Nuclear Operations and Maintenance, the Director of Emergency Planning and two Emergency Planning Coordinators.

The Emergency Planning organization under the Station Manager at Surry is the Superintendent for Administrative Services (SAS) and the site Emergency Planning Coordinator (EPC).

However, Vepco uses a matrix form of management. Therefore, the site EPC only reports to the SAS for administrative purposes and only takes direction from the SAS where emergency plar.ning is concerned. His essential lines of communications and sources of direction are the Station Manager and the corporate Director of Emergency Planning. The Station Manager reports to the Vice President of Nuclear Operations.

The site EPC also interfaces with his corporate counterparts.

For all three EPCs, coordination of emergency planning is their sole function. However, all corporate and site emergency planning personnel have had their emergency planning responsibilities for less than a year.

Consequently, many of the weaknesses identified in the appraisal have been recognized, but the staff has had insufficient time to implement changes.

The site EPC has occupied his position for about nine months. Although he has no written authority for his function, his relationship with the Corporate Director fer Fmergency Planning and the Station Menager allows him to grasp whatever authority is required to carry out his functions.

Formal means of coordination, such as committee meetings, are rare, but the site EPC effectively utilizes both formal (chain of command) and informal (across chain of command) routes of communications to accomplish his tasks.

He interfaces almost daily with Corporate and site personnel. Interfaces between Surry and North Anna are primarily through the Corporate office.

Interfaces with offsite groups and the general public have been primarily handled by Corporate personnel in the past, but recently, this is a shared function.

The selected criteria for the three EPCs is a four year degree, two years administrative experience, two year nuclear power station experience and a working knowledge of emergency planning and the site Emergency Plan.

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qualifications of the EPCs appear to exceed these minimum requirements. Since filling their positions, the EPCs have had some training, but training time has beem limited by the time required to adapt to their relatively new positions.

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i Based on the above findings, this portion of the licensee's program appears to be adequate.

2.0 EMERGENCY ORGANIZATION 2.1 Onsite Organization The onsite emergency organization was reviewed with respect to the requirements of 10CFR50.47(b)(1) and (2),10CFR50, Appendix E. Paragraph IV.

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and specific criteria in NUREG-0654,Section II.B.

The Surry Emergency Plan and Emergency Plan Implementing Procedures were reviewed and discussions were held with licensee personnel to determine the interfacing in the licensee's onsite emergency organization.

The shif t supervisor acts in the capacity of Emergency Director until relieved of his duties as Emergency Director by the Station Manager or one of his alternates.

The Emergency Director nas the overall authority and responsiblity for directing the emergency response activities, including notification of offsite agencies and providing protective action recommendations. Two Senior Reactor Operators (SR0s)

are on duty anytime one or both units are above cold shutdown. The SRO on Unit 1 is designated as the Shift Supervisor while the SRO on Unit 2 is designated as the Assistant Shift Supervisor.

There is an informal understanding among the SR0s that the Shift Supervisor on the af fected unit in an emergency will concentrate his attention on plant operations while the Shift Supervisor on the unaffected unit, after initially responding to the operational demands of the situation, will handle the administrative requirements as specified in the Emergency Plan Implementing Procedures.

The onsite emergency organization, as shown in Figure 5.4 of the Emergency Plan, basically is the same as the normal station organization, shown in Figure 5.1 of the Emergency Plan, with supervisory personnel responsible for supervising and directing emergency response activities as directed by the Emergency Director.

However, because the titles of most positions in the emergency organization are

the same as their normal functions, it is difficult to determine with assurance who in the emergency organization handles what emergency functions, how their functions interface with others, or if all emergency functions are covered. This observation was further supported by interviews with the emergency planning staf f, in that they were not certain in some cases as to who was entrusted with a particular responsibility.

The selection criteria for the personnel in the emergency organization is shown in Tables 5.la and 5.2a of the Emergency Plan. In general, these are the minimum requirements for performing the individual's regular functions and most personnel appear to have training and experience in excess of the minimum requirements.

Based on the above findings, this portien of the licensee's program appears to be adequate, but the following items should be considered for improvement:

Upgrading the descriptive material for the emergency organization so that the assignment of emergency functions and the interface between emergency functions is clarified. (50-280, 281/82-05-01)

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2.2 Augumentation of On-Site Emergency Organization The augmentation organization was reviewed with respect to the requirements of 10CFR 50.47(b)(1); 10CFR50, Appendix E, Paragraph IV.A.; and criteria in NUREG-0654,Section II.A. and B.

The on-site emergency organization is augmented by assigned personnel from the Vepco corporate staff in Richmond, Virginia. By Letters of December 18,1980 and June 1, 1981, Vepco responded to NUREG-0696 by proposing a common EOF for North Anna and Surry centered in Richmond, Virginia.

The common EOF would be the existing Corporate Emergency Response Center (CERC). The NRC responded by letter of November 23, 1981, specifying that a formal request for approval by the Commission was required.

Vepco has not yet submitted such a request.

In the interim, Vepco is maintaining a near site EOF.

The near site EOF is in the simulator building at the Training Center.

The augumentation of on-site emergency personnel is covered in Section 5.3 of the Emergency Plan. However, the details, including the implementing procedures are found in the Corporate Emergency Response Plan (CERP).

The CERP clearly specifies the emergency functions of both the augmentation personnel and their alternates by normal job title.

Since Vepco has a philosophy of utilizing personnel on the basis of their normal duties, their on-the-job experience and the criteria by which they were selected for their normal positions supports their emergency functions.

The licensee has not had a drill or performed a study against the time criteria of NUREG-0654, Table B-1.

A study of Table 5.1 in the Emergency Plan appears to meet the Table B-1 criteria for on-shift personnel and can provide twice the minimum number of site personnel at 60 minutes. However, the number of emergency personnel who could respond to the site within the 30 minutes criteria is not indicated.

The licensee indicated that it would be difficult to meet this criteria.

Based on the distance to Richmond and the location of the homes of augmentation personnel for manning the EOF, it is felt by the licensee that they cannot meet the Table B-1 criteria for manning the near-site EOF.

In order to compensate, they man both the CERC and EOF under " emergency conditions." Since the CERC is located in the corporate office, it will be manned quickly and it will remain manned as a backup to the EOF throughout the emergency.

In addition, Vepco has defined the " alert" stage as an " Emergency condition" rather than waiting until a l

" site emergency" occurs before manning the CERC and EOF. Although these actions l

may not meet the criteria in a rapidly developing site emergency, the licensee feels that the rapid manning of the CERC compensates for the potential of delay in manning the EOF near the site.

The interfaces between the onsite functional areas of emergency activity and the i

augumentation groups are shown in Figure 5.6 of the Emergency Plan.

In most cases, letters of agreement or contracts exist between Vepco and offsite augmentation groups, assuring a timely response. Provisions for augmenting the onsite organization beyond the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> depends on support from the North

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Anna Power Station and " rent-a-tech" services under contract.

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It was dif ficult to assess this portion of the licensee's program due to the deficiencies in Table 5.1 of the Emergency Plan reported as Item 1 of " Emergency Plan Deficiencies", Appendix C to the cover letter for this report.

3.0 EMERGENCY PLAN TRAINING / RETRAINING 3.1 Program Established (

The Emergency Training was reviewed with respect to the requirements of 10CFR50.47(b)(15) and (16); 10CFR50, Appendix E, Paragraph IV.F: the criteria in NUREG-0654,Section II.G. and O.

The Licensee Training Program was defined in ADM-12 "Vepco Surry Power Station Qualification and Training" dated October 29, 1981, Section 8.1.1 of the Plan; EPIP-21 " Training and Emergency Preparedness"; Sections 3 and 4 of the Corporate Emergency Response Plan; and other departmental documents.

These documents did not appear to provide the basis for the establishment of a comprehensive and well organized training program in emergency preparedness.

ADM-12 provided the fundamental guidance for station training.

Although the cover sheet was dated October 29, 1981, only page 31 had been revised. This page contained a reference, C.1.e, to " safety and emergency and other system" training for NRC examination applicants at the reactor operator level. The remainder of the pages had 1977 and 1978 dates and contained no specific references to emergency preparedness training. Section 8.1.1 of the Plan and EPIP-21 contained more detailed emergency preparedness training requirements.

These documents tended to concentrate solely on the EPIPs as the source of training information.

However, the information provided in the EPIPs is insufficient in providing the detailed information required to successfully complete all emergency response tasks. (See Section 5.1 and 5.3 for further details).

There were inconsistencies in the manner in which corporate and various station departments conducted training, and some station departments have not formally addressed specialized emergency preparedness training.

ADM-12 and Section 5.1 of the Plan contains qualification criteria for the normal organizational titles. Since there are very few dif ferences in organizational titles between the normal and emergency response organization, the licensee considers the manner in which qualifications criteria are presented to be adequate.

The qualification criteria, however, does not require the completion of emergency preparedness training before personnel are considered as a functional member of the emergency response organization.

Emergency Preparedness Training ind retraining is required annually for licensee personnel, licensee augmentation personnel, local service support organizations and the news media.

In accordance with page 8.7 of the plan, local police training would be provided by the State and County.

With respect to Emergency Preparedness Training, the Licensee's Training Department had developed lesson plans for only operator and general employee training. These plans had not been formally approved.

Additionally, there is no mechanism specified for obtaining approval of lesson plans in ADM-12. A lesson plan for Fire Brigade training was developed by the Safety Department apparently independent of the Training Department. Corporate has also developed

lesson plans; however, the plans do not contain clearly stated objectives. The Training Department is currently developing other lessons plans.

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There is no criteria stated in the ADM-12 governing the selection and qualifications of instructors.

Methods of documenting training varied from group to group. All forms do not have provisions for listing the name of individual attendees.

The training program primarily consisted of classroom type lectures which were not always followed by tests or other measures to determine the trainee's understanding of the material presented.

Very little hands-on or walk-through training was provided.

This phase of training was expected to be accomplished through personnel participation in drills and exercises, and on-the-job training provided by each department.

The organizational categories in the training matrix were not distinct enough to specify the detailed training required in all areas of emergency activities. The matrix does not include search and rescue activities; however, EPIP-9, Section 1.1.7 calls for the dispatch of " search team".

Other functional activities such as in plant radiological surveys, and repair / corrective actions were not covered in suf ficient detail in the training program.

The " Mitigating Core Damage" course provided some training relative to unusual conditions that might be expected under emergency conditons.

However, [as an example of some of the training which was not included in the training matrix]

the course did not specifically identify areas in the plant that might represent a significant radiological hazard under accident conditions.

The training program does not specifically address the use of equipment, interpretation of results and special precautions to be implemented while conducting surveys under emergency conditions.

For example, techniques for determining if a sample was taken in the plume were not covered in the Training Department's program.

All personnel are required to take the Red Cross Standard First Aid Multimedia Training. The Safety Department administers the First Aid training for the First Aid Team.

The basic set of courses beyond Multimedia had not been clearly defined for the First Aid Team. Based on a review of the training documentation, different subsets of the complete certification program had been provided to individual members of the First Aid Team.

There were no procedures and lessons plans which covered the training of local government support personnel in site access procedures, basic radiation protection and their expected roles in an emergency situation.

EPIP-21,

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Paragraph 1.7, indicated that "Offsite Fire and Rescue Units" would receive training in the Plan, and the training would be "provided by the State and/or Vepco personnel".

Section 8.1h of the Plan indicated that the Medical College of Virginia would be trained in conjunction with medical emergency drills.

Section 8.1.1.e indicated training of police would be " coordinated between the State and local counties, the station provides no formal input to this progran"

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There appears to be no formal mechanism 'for assuring'that all personnel receive training in changes to equipment and proceduris which occur between training periods.

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Provisions have been made to train non-licensee augmentation personnel upon arrival at the plant in the General Employee Training Program.

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Based on the above findings, the following deficiency was identified:

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The training and retraining program was fractionated and lacked any central

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coordination to assure that all emergency preparedness personnel' received training appropriate to their functions.

In addition, much information fundamental to operating under emergency conditions was lacking and not all functional activities for emergency preparedness were addressed. Tfie classroom exercises, where used, did not test the individuals ability to

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perform assigned functional responsibilities and many portions of'the.

training had no established perfonnance levels below which immediate '

retraining was required.

(50-280,281/82-05-02)

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s In addition, the following areas should be considered for improvement:

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Developing a training manual to provide guidance and to increase the uniformity of the training program.

(50-280,281/82-05-03)

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Developing lesson plans and tests based on the functional activities of the

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emergency response organization.

(50-280,281/82-05-04)

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Upgrading the training matrix to include all tv ainis received by members of the Emergency Response Organization.

(50-280,281/82?05-05)

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Clearly establishing the essential training required by members of the First Aid Team, (50-280, 281/82-05-06)

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3.2 Program Impimentation The Emergency Training Program was reviewed with respect to the requirements of (

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10CFR50.47(b)(15) and (16); 10CFR50, Appendix'E, Paragraph IV.F., and the criteria in NUREG-0654,Section II.0.

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s Emergency Preparedness records were inadequately maintained. All records of

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training were not forwarded to the Training Department. Some records were maintained by the various departments tha' GrrNeted the training. Also some l

training provided had not been properly & cented, s

l The inspector examined all availat' e e W q records and concluded, based on the presently defined training program, m, :cns with personnel, and walk-throughs, that all training had genarally ben conducted with the exception that

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training for members of the First Aid Team was non-uniformly applied (se4 x

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Section 3.1).

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Based on the above findings, this portion of the licensee's program appears to be adequate; however, the following matters should be considered for improvement:

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Documenting all training to include the name and grade for each attendee, a descriptive course title and lesson plan, the training date, and the instructor's name. (50-280, 281/82-05-07)

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Designating the Training Department to be the central repository for all training records. (50-280, 281/82-05-08)

4.0 EMERGENCY FACILITIES AND EQUIPMENT 4.1 Emergency Facilities 4.1.1 Assessment Facilities 4.1.1.1 Control Room The Control Room emergency facilities were reviewed with respect to the requirements of 10CFR50.47(b)(8); 10CFR50, Appendix E, Paragraph IV.E, and the criteria in NUREG-0654,Section II.H.

The main control room contains instrumentation and equipment for the control of Units 1 and 2.

The inspectors examined the control room on several occasions during the appraisal.

Current copies of the Plan and Implementing Procedures were in place. All emergency equipment, readouts and decisional information were also in place and operable. The use of the monitoring equipment, communications equipment and accident asse.ssment methodology were tested during walk-throughs with the control room personnel.

Based on the above findings, this portion of the Licensee's program appears to be

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adequate.

4.1.1.2 Technical Support Center (TSC)

The TSC was reviewed with respect to the requirements of 10CFR50.47(b)(8);

10CFR50, Appendix E, Paragraph IV.E.; the criteria in NUREG -0737,Section II. A.1.2; and the criteria in NUREG-0578, Section 2.2.2.b.

The interim TSC is located outside of the control room in the Control Room Annex.

The permanent TSC is being built adjacent to the control room.

Based on its present state of construction, it was difficult to draw any reasonable conclusions about operability of the facility under emergency conditions.

Therefore, the remainder of the report only addresses the interim TSC.

This facility was determined to have the capacity for providing adequate technical support to the control room staff under emergency conditions, with minor exceptions:

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The activation Procedure EPIP-7, APX-6, Section 2, did not have provisions for additional tables and chairs for TSC personnel to conduct work.

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Desk top working space has only been provided for two (2) NRC personnel.

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Since the interim TSC is located within the design.eMyelope of the control room, it satisfies the same habitability conditions whicti includes HEPA and charcoal filtration in the ventilation system and radiation shielding.

Its location in the control annex provides sufficient isolation, and yet provides an opportunity for face-to-face interactions between personnel responsible for control room and TSC activities.

The communications capability between the TSC and the EOF, Corporate, OSC, CR and of fsite authorities appeared to be adequate.

However, the HPN Network (HPN)

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extension had not been installed and one phone was malfunctioning which the licensee was attempting to repair. The backup communications capability for the malfunctioning phone was operable.

The interim TSC contained its own set of schematics and diagrams which were indicated by the licensee to contain the curr. t condition of the plant structure and systems.

An appropriate set of procec as and specifications were also maintained in the TSC.

Based on the above findings, this portion of the licensee's program appears to be adequate, considering the interim nature of the existing TSC; however, the following should be considered for improvement:

Revising the activation Procedure EPIP-1, APX 7, Section 2, for the interim TSC to included the installation of additional tables, desks, and other supplies to better accommodate all TSC personnel. (50-280, 281/82-05-09)

4.1.1.3 Operations Support Center (OSC)

The OSC was reviewed with respect to the requireme u, of 10CFRE.47(b)(8);

10CFR50, Appendix E Paragraph IV.E; the criteria ir NUPEG-0654,Section II.H; the critaria in NUREG-0578, Section 2.2.2.C; one' the criteria in NUREG-0737,Section II. A.1.2.

The Operational Support Center is located in the Station Switchgear Room. During an emergency, nonessential operators, the Fire Brigade, and the First Aid Team members would report to the OSC.

The remainder of the emergency response personnel would report to their respective normal work areas. This approach may delay formation of the Repair / Corrective Action Teams, and Search and Rescue Teams.

The switchgear room is large enough to accommodate a sufficient number cc personnel, however, there are no seats or desks for personnel nor emergency kits.

i Licensee respresentatives indicated that the OSC would be properly equipped when activated.

The OSC appears to be reasonable well shielded; however, the inspector questions that habitability relative to airborne contamination.

No provisions have been made for HP monitoring of the area during the course of an accident or moving to a backup location if radiological conditions become unfavorable.

Primary and backup voice communication links have been provided between the OSC, Control Room and TSC.

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Based on the the above findings, this portion of the Licensee's program appears to be adequate; however, the following should be considered for improvement:

Revising the OSC activation procedure to include provisions for personnel and en.argency equipment, to assure HP monitoring of the OSC, to require all emergency response personnel not immediately performing emergency duties to report to the OSC to facilitate the formation of the various emergency teams, and to specify relocation criteria based on potential or actual hazardous radiological conditions. (50-280,281/82-05-10)

4.1.1.4 Emergency Operations Facility (EOF)

The Emergency Operations Facility was reviewed with respect to the requirements of 10CFR50.47(b)(3); 10CFR50, Appendix E, Paragraph IV.E, the criteria in NUREG-0654,Section II.H, and the criteria in NUREG-0737,Section III, A.2.1.

The near site EOF is located in the Simulator Building which is less than one-half mile from the reactors. Consideration is being given to locating the permanent E0F in Richmond, Virginia, about 50 miles from the site.

The EOF, which includes the simulator room and other classrooms, is large enough to accommodate the expected number of corporate, state, local, and NRC personnel.

No space has been set aside for news media representatives at the EOF since the licensee has established a separate news center at the Lebanon Elementary School in the Town of Surry.

The EOF is equipped with the Emergency Plans and Implementing Procedures, drawings and diagrams showing the layout of the plant and plant systems, and an emergency kit containing most of the required supplies and equipment.

No decontamination supplies were found in the emergency kit, and not all equipment was stored at the EOF.

Equipment such as maps, status boards, etc., would be installed at the facility by plant personnel prior to the arrival of the Recovery Organization.

However, this requirement was not acluded in the Implementing

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Procedures.

l There is no sample counting equipment stored at the f acility.

The licensee indicated that the state plans to locate the mobile laboratory at the EOF for counting purposes.

There is no readout of station meteorology data in the EOF. Meteorology data would be made available by calling the TSC on one of the dedicated lines.

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Communications equipment appears to be adequate, however, the ENS extension had not been installed.

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The facility does not meet the habitability for a near site EOF.

The backup

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facility would be located at the corporate headquarters in Richmond, Virginia.

l Station EPC indicated that he was not aware of any backup power supplied to the facility.

Based on the above findings, this portion of the licensee's program appears to be adequate; however, the following items should be considered for improvement:

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Developing an implementing procedure for the activation and staffing of the EOF. (50-280, 281/82-05-11)

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Assuring that adequate monitoring and decontamination equipment are provided to support the operation of the EOF. (50-280, 281/82-05-12)

4.1.1.5 Post-Accident Coolant Sampling and Analysis The Post-accident Coolant Sampling and Analysis System was evaluated with respect to 10CFR50.47(b)(8); 10CFR50, Appendix E, Paragraph IV.E. selected criteria in NUREG-0654,Section II.I, and NUREG-0737,Section II.B.3, and the Attachment to (

II.F.1.

The interim sampling location which is commen for Units 1 and 2 was inspected, sampling procedures were reviewed (see Section 5.4.2.4), and post-accident sampling was discussed with licensee personnel. The new post-accident sampling system now installed and under test was also inspected and discussed. The system is expected to be operational by July,1982.

The post-accident primary coolant sample would be taken at the Sampling Room located at the 27 foot level in the Auxiliary Building.

The sample location should be accessible during an emergency, but licensee representatives stated that accessibility would be reevaluated at the time of an accident. The sample lines and collection points are shielded so that radiation doses received by personnel taking the sample appeared to be ALARA; however, the initial valve lineups are made in an unshielded area, so only one post-accident coolant sample can be taken. This is an interim system. The permanent system is installed and undergoing tests. The new sample system will provide for more than one sample.

The araa of the Auxiliary Building traversed to reach the Sample Room is monitored by an Area Monitor with both local and Control Room readouts.

The Sample Room itself is also monitored, with one readout near the Sample Room door and one in the Control Room.

l The sample is automatically diluted to 1:1000 and is placed in a bottle in a large shielded cask mounted on a heavy cart.

A long wrench is provided for disconnecting the sample line from the bottle. The sample is then moved into the Hot Lab, where it is further diluted and chioride and boron analyses are

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The sample is handled in a hood whers lead bricks and bags of shot are provided for shielding as required. A diluted sample is provided to the count room for isotopic analysis.

Licensee representatives stated that the analytical facilities are expected to be accessible during emergencies. If the analytical facilities become inaccessible, the analytical facilities at the contruction site, North Anna Power Station or contractor facilities could be used.

The instruments and detectors specified in the procedures were in place and ready for use. The equipment and tools specified were also available.

Provisions were made for flushing the sample lines with coolant grade water prior l

to taking the sample. The system provides for taking a representative sample, i

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Licensee representatives stated that sampling and analysis could be completed in three hours.

Based on the above findings, this portion of the Licensee's program appears to be adequate; however, the following item should be considered for improvement:

Providing for taking and analyzing more than one post-accident coolant sample. (50-280, 281/82-13)

e 4.1.1.6 Post Accident Containment Air Sampling and Analysis The post-accident containment air sampling and analysis system was evaluated

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against 10CFR50.47(b)(8),10CFR50, Appendix E, Paragraph IV.B., selected criteria of NUREG-0654,Section II.I and NUREG-0737,Section II.B.3 and the Attachments to II.F.1 The sampling location for Units 1 and 2 were inspected. The sampling procedures (See Section 5.4.2.6) were reviewed and post-accident containment air sampling was discussed with licensee personnel.

The post-accident containment air sample would be taken at a panel located at the 27 foot level of the Auxiliary Building.

The sampling locations should be accessible during an accident, but accessibility would be reevaluated at the time of an accident.

The sample lines were not shielded to reduce the radiation exposure received by the iridividual taking tne sample; however, such shielding may not significantly reduce exposure due to the. potential high radiation levels in the Auxiliary Building.

An area radiaton monitor with indicators locally and in the Control Room provides monitoring for the area of the Auxiliary Building from the entry point to the sampling panel.

Health Physics would also provide portable monitoring and dosimetry for the technician taking the sample.

Provisions had been made for transporting the sample. Studies indicate that the maximum exposure from a 1cc sample would not be in excess of 1 R/hr.

Licensee representatives indicated that some method of shielded transport would be provided if determined to be necessary.

The sample analysis facility is expected to be accessible during an accident. If exposure rates are too high, however, a backup facility at the constuction site, at contractor sites, or at North Anna Power Station could be used.

The Count Room equipment and supplies are set up and readily available. Samples will be diluted by injecting a 1cc sample into a 100cc gas bomb.

,

Provisions are made for recirculating containment atmosphere through the sample lines for fifteen minutes prior to sampling to ensure a representative sample is taken.

,

Licensee representatives stated that all required sampling and analyses could be l

completed at the site in three hours.

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The new post-accident sampling system now installed and under test was also inspected and discussed.

The system will provide four diluted samples in shielded sample bombs at programmed intervals. The system is expected to be in operation by July,1982.

Baseo on the above findings, this portion of the licensee's program appears to be adequate; however, the following item should be considered for improvemnt:

Providing a shielded container for transporting post-accident air samples. (50-280, 281/82-05-14)

4.1.1.7 Post-Accident Gas and Particulate Ef fluent Sampling and Analysis The post-accident gas and particulate effluent sarrpling systems were avaluated with respect to 10CFR50.47(B)(8); and 10CFR50, Appendix E, Paragraph IV.E., and selected criteria of NUREG-0654,Section II.I.

The sampling locations for the Unit 1 and 2 process and ventilation vents were inspected, the sampling procedures (See Section 5.4.2.8) were reviewed and post-accident process and vent sampling was discussed with licensee personnel.

The new post-accident sampling system now installed and under test was also inspected and discussed with licensee management personnel.

The system is expected to be operational by July,1982.

The ventilation vent sampling system and the process vent sampling system are expected to be accessible, but under certain conditions, the process vent sampling point, which is located over the catalytic recombiner room in the Auxiliary Building, may be in a high exposure area.

The ventilation vent sampling point is located near the Turbine Bay floor in conjunction with the High Range Stack Monitoring System.

Both points are in areas covered by area monitors, and exposure rates are to be evaluated by Health Physics prior to sampling.

Shielded sample containers are not part of the sampling equipment, but will be provided for removing the potentially high radioactive filters and cartridges.

In addition, no shielding is provided to reduce exposures from the sampling lines in either area.

All instruments and detectors used for analysis of the filters and cartridges are in place and ready for use. The rate of flow through the system is expected to provide a representative sample. The change-out and analysis of the filters and cartridges from the processes and ventilation vents could be performed within three hours.

I A key is necessary to gain access to the process vent sampling point.

A

'

cor.siderable delay was encountered in obtaining the key from the maintenance organization. However, this situation was corrected by licensee personnel, f ased on the above findings, this portion of the licensee's program appears to be adequate; however, the following item should be considered for improvement:

Providing special tools for handling and removing post-accident gas sampling cartridges and filters. (50-280,281/82-05-15)

L

4.1.1.8 Post-Accident Liquid Effluent Sampling and Analysis The facilities and equipiment available for post-accident sampling and analysis were evaluated with respect to 10CFR50.47(b)(8), 10CFR50, Appendix E,

Paragraph IV.E., and selected criteria in NUREG-0654,Section II.I.

Post-accident liquid samples are to be taken from the same points and in the same manner as normal liquid samples in accordance with Operating Procedure OP-12, Sampling System and Local Sampling.

The sample locations should be accessible, but licensee representatives stated that accessibility would be reevaluated at the time of an accident. Under certain accident conditions, some sample points, especially those in the basement of the Auxiliary Building, might be inaccessible due to the contents of the liquid waste system.

The Auxiliary Building basement is not monitored, therefore, exposure rates would have to be determined by the Health Physics staff. An area monitor is available in the Decon Building. Health Physics monitoring would be provided as necessary.

Shielded liquid-sample containers are not available and transport of a shielded cask would be difficult in the sampling areas.

The sample would normally be carried in a plastic bag, but if exposure rates were too high, Health Physics would determine a means of transportation.

Liquid samples could be diluted in the Hot Lab prior to analysis. The sample analysis facility is expected to be accessible during accident conditions.

If not, alternative analytical facilities could be used.

Instruments and equipment required for analysis are available.

The liquid effluent sampling system is expected to provide a representative sample.

It appeared that the sample could be taken and analyzed within three hours.

Based on the above findings, this portion of the licensee's program appears to be adequate; however, the following item should be considered for improvement:

Providing alternate sampling points for essential post-accident liquid effluent samples for those systems where the primary sample point is likely to be inaccessible. (50-280, 281/82-05-16)

4.1.1.9 Off site Laboratory Facilities The offsite laboratory facilities were reviewed with respect to the requirements of 10CFR50.47(b)(9), 10CFR50, Appendix E, Paragraph IV.E.2, and criteria in NUREG-0654,Section II.H.

Alternate laboratory facilities for use by the licensee during emergency situations are available at the North Anna plant, approximately 100 miles away (CEP 7.3.2).

Instrumentation at the North Anna plant duplicates the Surry facilties and is maintained, calibrated, checked and repaired or replaced routinely.

Spiked and split samples are being counted at the two plants to maintain quality control and calibration.

Additional facilities are available from the State Department of Health and letters of agreement were in place. Laboratory facilities at the Naval Shipyard

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I (Newport News), William and Mary College (Williamsburg), and Babcock and Wilcox (Lynchburg) were mentioned as alternate possibilities, but letters of. agreement'

j were not in place.

Based on the above findings, this portion of the licensee's program appears to be

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adequate.

4.1.2 Protective Facilities

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4.1.2.1 Assembly Areas i

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The Assembly Areas were reviewed with respect to the requirements of i-10CFR40.47(b)(10) and criteria in NUREG-0654,Section II.J.

Upon hearing the Emergency Signal, all personnel proceed to assembly areas (shelter areas) for personnel accountability and for further instruction (see 5.4.3.3).

The shelter areas (assembly for accountability) were located in normal

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work areas or the places where the work day started as specified in EPIP-9, the l

Emergency Plan and Vepco Project Operating Procedures (POP 2.9.2) for onsite contractors.

Radiation monitors with equipment are to be dispatched to these-areas by the Emergency Director as noted in the Emergency Plan.

Following an order to evacuate, nonessential personnel are to proceed by private auto to the remote assembly area approximately five miles south of the station.

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The site is at the intersection of two paved highways and does not have emergency supplies in the area for decontamir.ation of personnel or automobiles.

An alternate site is not provided in case the plume moves toward the remote assembly area.

!

Based on the above findings, this-area of the licensee's program appears to be

idequate; however, the following items should be considered for Improvement:

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1.

Upgrading the marking of assembly (shelter) areas and the instruction of personnel as to the location of their assembly area. (50-280, 281/82-05-17)

l 2.

Establishing an alternate offsite assembly area in case the primary site becomes unuseable. (50-280, 281/82-05-18)

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3.

Establishing a decontamination capability for timely decontamination of

l-personnel at or very near the remote assembly area. (50-280, 281/82-05-19)

4.1.2.2 McJical Treatment Facilities The primary facility for handling and care o,f potentially contaminated injured i

personnel is the First Aid Station in the front of the Administrative Building.

This facility is approximately 100 meters from the control areas and decontamination facilities.

However, general first aid kits are located in d

strategic locations throughout the plant, including near the decontamination

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area. The distance between the First Aid Station and decontamination facilities does not appear to be a problem because of the availability of well supplied

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first aid kits near the decontamination area.

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Procedures for treatment and decontamination appear to be adequate. Emergency dosimetry is available through Dosimetry Control. Potassium Iodide (KI) tablets are stored in several locations onsite and distribution is limited to Vepco employees. A poter*. al problem exists in the distribution of the KI in that the person responsible for this decision is not clearly defined. Recommended action levels for KI use by Vepco employees is found in EPIP-18.

The Medical College of Virginia (MCV) is the designated facility providing medical service for potentially contaminated persons from the Surry site.

The distance between the two facilities, which is greater than 50 miles, is not desirable for transporting an injured person.

However, MCV appears to have adequate supplies, equipment, facilities, staff, and staff training to handle up to ten contaminated patients.

Based on the above findings, this portion of the licensee's program appears adequate; however, the following item should be considered for improvement:

Clearly designating the person responsible for distibution of Potassium Iodide tablets. (50-280, 281/82-05-20)

4.1.2.3 Decontamination Facilities Decontamination facilities and equipment were reviewed against requirements of 10CFR50.47(b)(8), 10CFR50, Appendix E, Paragraph IV.E, and specific criteria in NUREG-0654, Sections II.J. and K.

The onsite personnel decontamination facilities are located in the service building near the Health Physics area.

Personnel decontamination is performed according to EPIP-10, Personnel Monitoring and Decontamination, and Section 2.4 of Vepco Health Physics Procedure Manual.

The decontamination area is approximately 100 meters from the primary first aid station. The distance should not be a problem because medical kits are located in the decontamination area.

The decontamination facility's design, location, equipment, and supplies appear adequate.

No provisions currently exist for decontamination facilities at the remote assembly site. (Section 5.4.3.4).

Also provisions for collection and disposal l

of radioactive waste and provisions for replacement clothing at the remote

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assembly area are lacking.

l Supplies and facilities do exist for decontaminating personnel at the Surry l

Lebanon Elementary School. These facilities are adequate for a limited number of

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persons only.

Based on the above findings, this portion of the licensee's program appears to be

!

adequate; however, the following items should be considered for improvement:

l 1.

Establishing a system for the collection and disposal of radioactive waste

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collected at the remote assembly area. (50-280, 281/82-05-21)

2.

Establishing a system for replacing contaminated clothing at the remote assembly area. (50-280, 281/82-05-22)

4.1.3 Expanded Support Facilities The Corporate Errergency Response Plan (CERP) designates separate areas in the Training Center Simulator Building (EOF) for use by the NRC and state and local officials.

Office space is also designated for use by recovery, field monitoring, radiological assessment and communication coordinators. An office is also designated for the NRC in the Technical Support Center (EPIP-1. Table 1).

CERP 7.0 calls for the use of trailers for additional space. Power and telephone hookups are in place for seven trailers and the availability of trailers is verified annually by contact with brokers (CERP 8.2).

Based on the above findings, this portion of the licensee's program appears to be adequate.

4.1.4 News Center Vepco has provisions for a news media center at the Lebanon Elementary School in the town of Surry.

Telephone connections are provided for 20 telephones, of which 18 will be available for the media.

These phones are stored at the emergency operations facility.

The licensee says plans are under way to store them and other equipment at the school. Arrangements are also in place for bringing copiers, a public address system and audio-visual equipment from corporate headquarters in Richmond to the news centers in the event of an emergency.

The licensee says it is purchasing dedicated equipment for this purpose which eventually will be stored at the school.

The elementary school auditorium has four electrical taps, and the stage has eight more; Vepco says its own employees can wire additional electrical service if necessary. The elementary sized tables in the auditorium would need to be replaced with adult sized tables for news media center purposes.

The news center appears to be adequately large to accommodate the press, although a larger facility might be necessary if an extremely serious accident occurred.

Parking facilities are adequate. The school auditorium has an outside entrance, which would be a plus factor if used for a news center.

Based on the above findings, Vepco's arrangements for use of the Lebanon Elementary School as an emergency press center appear adequate; however, the following items should be consiJered for improvement:

1.

Assessing the electrical wiring and making provisions for additional wiring in case needed. (50-280, 281/81-05-23)

2.

Storing the press center telephones and other dedicated equipment at the facility. (50-280, 281/82-05-24)

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3.

Making provision for adult-sized tables to replace the elementary school-sized tables. (50-280, 281/82-05-25)

4.2 Emergency Equipment 4.2.1 Assessment 4.2.1.1 Emergency Kits and Emergency Survey Instruments The emergency kits and emergency survey instruments were reviewed with respect to the requirements of 10CFR50.47(b)(8),10CFR50 Appendix E, Paragraphs IV.B. and E, and criteria in ?!UREG-0654, Sections II.H. and I.

Kits containing emergency supplies and survey instruments are stored in six onsite locations and three offsite locations. Periodic Test 38.30 contains the kit inventories, instructions for inventory, and a listing of instrument calibration due dates. Kits are sealed af ter each inventory.

The inventories of the kits were correct and all equipment was fully operational and calibrated. The kits do not contain extremity dosimeters, but the kits most likely to be used for reentry, those near the Health Physics Offices, are also n?ar the Dosimetry Control facility which issues extremity monitoring as required by the Radiation Work Permit (RWP) system.

The instrumentation in use should be capable of detecting radiciodine concentrations as low-as as 1E-07 microcuries per cubic centimeter under field conditions.

However, there is doubt as to the licensee's capability for detecting particulate activity as low as 1E-09 microcuries per cuoic centimeter under field conditions.

Kit supplies appear adequate for extended monitoring activities.

Portable radiation instruments appear adequate for monitoring beta / gamma dose rates and for detecting contamination on individuals.

Based on the above findings, this portion of the licensee's program appears adequate; however, the following item should be considered for improvement:

Performing calculations or testing to assure that field sample analysis has the capability to measure air particulate activity as low as 1E-09 microcuries per cubic centimeter. (50-280, 281/82-05-26)

4.2.1.2 Area and Process Radiation Monitors The area and process radiation monitors were reviewed with respect to the requirements of 10CFR50.47(b)(9),10CFR50, Appendix E, Paragraphs IV.B. and E.2.,

and requirements in NUREG-0654,Section II.H.

A complete description of area and process radiation monitors is not contained in the Emergency Plan or Procedures. Periodic Test (PT) No. 26.2 gives the general location, function and test procedure for all operational area and process radiation monitors.

The PT Forms for the two units are separated by color coding.

All area monitors have readouts in both the monitor area and control room. All but six process monitors have readouts in the control rcom. The six steam line

monitors have readouts in the emergency switchgear room which is immediately below the control room. All monitor readouts should be accessible under accident conditions.

The detectors of the area and process monitors should provide an accurate reflection of operational conditions. No shielding effects were observed as the detectors were fixed in close proximity to their assigned medium.

In certain postulated release situations, however, monitors would be affected to various degrees by high background readings.

Four containment monitors, two in each unit, are not operational as of this date.

The licensee has requested an extension on several NUREG-0737 requirements, including implementation of high range containment monitoring. The requested deadline for implementing NUREG-0737 II.F.1 Accident Monitoring, is July 1, 1982, as per letter dated December 31, 1981.

Calibration procedures are found in CAL-RM-001, CAL-RM-044, and CAL-RM-045.

These specify at least two calibration points for each scale.

Detector efficiencies are included within the monitor's calibration so that the readouts reflect actual dose rate or concentration condition.

Readouts are equally accessible in the control rooms for Units 1 and 2.

Documentation exists to assure that inoperable instruments are either repaired or replaced promptly. Health Physics is responsible for establishing the alarm set points on the monitors. Setpoint changes are initiated by a Maintenance Request and are performed in accordance with CAL-RM-003, CAL-RM-004, and applicable Health Physics Procedures.

Area and process radiation monitors are all A.C.

powered with no backup D.C. power.

Emergency A.C. backup power is available through the diesel generators.

Based on the above findings, this portion of the licensee's program appears adequate. However, the following item should be considered for improvement:

Including in the Emergency Plan a complete listing and description of all area and process radiation monitors. (50-280, 281/82-05-27)

4.2.1.3 Non-Radiation Process Monitors A comprehensive list of non-radiation process monitors necessary for emergency detection, classification and assessment during an emergency situation was not described in the plan or the procedures. The Emergency Plan describes examples of control room instrumentation. The non-radiation process instrumentation was observed and appeared to be in place and operable.

All monitor readouts were located in the control room or the control room annex at elevation 27 feet, and were readily observable.

The seismic instrumentation is within the Periodic Testing (PT) program.

The Auxiliary Shutdown Panels for Units 1 and 2 located at elevation nine feet in the Service Building are operated per the requirements in Administrative Procedure (AP) 20, Main Control Room Inaccessibility.

The instrumentation on these panels is within the PT program and the calibration program. The electric switches and controls are not in the PT program. Checklist 68 is used to verify that the switches and controls are in the proper position for equipment I

i

controlled from the Auxiliary Shutdown Panels and to ensure that the complete transfer of control from the Main Control Panel to the Auxiliary Shutdown Panel can be accomplished if needed.

The acceptance criteria considers the check to be satisfactory if the switches and controls are in the proper positions. No functional or continuing test are required for the weekly check of proper positons.

The Station Nuclear Safety Operating Committee (SNSOC) is considering the need to include these shutdown panels in the PT Programs.

p Based on the above findings, this portion of the licensee program appears to be adequate, however, the following items should be considered for improvement:

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1.

Providing a specific listing of the non-radiation process monitors that are relied upon for classification and assessment in the emergency plan or procedures. (50-280, 281/82-05-28)

2.

Providinn for periodic testing of the electrical switches and controls at the Auxiliary Shutdown Panels. (50-280, 281/82-05-29)

4.2.1.4 Meteorological Instrumentation The basis for the review of the licensee's meteorological measurements program included Regulatory Guides 1.23, 1.97, and 1.101, and the criteria set forth in NUREG-0654, NUREG-0696, and NUREG-0737.

The Surry Power Station Emergency Plan (SEP) dated April 1, 1981, as modified by changes in February, 1982, was reviewed as well as the Emergency Plan Implementing Procedures (EPIP).

Observations during a site visit are also included in the review.

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The current meteorological instrumentation on a 45 meter tower provides the basic parameters (i.e., wi-d direction and speed and an estimate of atmoshperic stability) necessary to perform the dose assessment function.

Data from the meteorological measurements system on the 45 meter tower were recorded on strip charts in the Control Room. Meteorological instrumentation on a 20 meter tower provides backup information on strip charts in the Control Room.

Vertical temperature dif ference measurements were recorded redundantly using separate scales on the same chart in the Control Room.

Sigma / theta was also cecorded redundantly in the same manner. The strip charts appeared to be operable at the time of the inspection but some charts were not displaying the current time. The sigma / theta recorder was providing different values on a different scale of the same chart.

The Licensee has maintained a proper program for inspection and preventive maintenance of instrumentation on the towers. The instrumentation at the towers is checked daily by plant personnel and is serviced twice a week by corporate personnel.

The sensors, electronics and recorders are calibrated quarterly and the wind sensors are replaced semiannually. However, the Control Room recorders are not inspected, maintained or calibrated on a regular schedule.

The licensee's 45 meter meteorological tower meets the criteria of Regulatory Guide 1.23 regarding instrumentation, and siting and exposure of instrument All sensors appeared to be operable and calibrated at the time of the inspection.

However, the variables recorded on the multipoint recorder were difficult to read.

Based on a visit to the corporate office, the inspector found that Systems Operations Procedures require the Systems Operator to inform plant shift operations personnel of severe weather problems forecast or occurring near the site.

Complete procedures were not documented in either the SEP or EPIPs; however, procedures for response to severe weather are specified in Procedure

{

ADM-25.0.

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This portion of the licensee's program appears to be adequate; however, the following items should be considered for improvement:

1.

Establishing an inspection, maintenance and calibration program for the Control Room meteorological data recorders similar to the program provided for instrumentation at the meteorological towers. (50-280, 281/82-05-30)

2.

Modifying the control room meteorological instruments to provide single recordings of sigma theta and of temperature difference values.

(50-280, 281/82-05-31)

3.

Identifying a procedure that requires that the shift operations personnel be informed of all severe meteorological phenomena likely to affect the site.

(50-280, 281/82-05-32)

4.

Improving the recording of variables currently recorded on the multipoint recorder at the primary tower location so that the variable values will be readable. (50-280, 281/82-05-33).

4.2.2.1 Respiratory Protection The respiratory protection program was reviewed with respect to requirements and recommendations in NUREG-0041.

The licensee has an approved respiratory protection program. Four SCBA units are reserved for emergency use only in the SCBA storage areas near Health Physics.

Several other units are stored in the Health Physics area and in emergency kits.

The licensee uses a cascade refill system to recharge tanks onsite. Procedures for recharge are found in the Respiratory Protection Manual.

Based on the above findings, this portion of the licensee's program appears adequate.

4.2.2.2 Protective Clothing Presently over 1000 sets of protective clothing are available in the change area.

In addition, the warehouse just outside the protective area has enough separate pieces of protective clothing to make up 1000 sets.

Formal minimum-maximum ordering t,hresholds do not exist, but it was indicated that reordering takes place when the warehouse stock drops to 200-250 sets of protective clothing. Two sets of protective clothing are provided with each emergency kit and the North Anna Power Station stocks are available for backup.

t

Based on the above findings, this portion of licensee's program appears to be adequate.

4.2.3 Emergency Communications Equipment The Emergency Communications Equipment was reviewed with respect to the requirements of 10CFR50.47(b)(6), 10CFR50, Appendix E, Paragraph IV.E, and specific criteria in NUREG-0654,Section II.E, F., and Appendix 3.

The onsite and offsite communications equipment was equal to or better than that prescribed by the criteria and was located as described in CERP 7.2.

The system provided for notification of the NRC, corporate, state and local authorities on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis.

Backups exist for the primary communication systems and the systems have alternate power supplies.

Radio communications exist for radiological monitoring teams, security and craft operations (recovery).

Communicaticos with.the Emargency Operations Facility (EOF) and the Corporate Emergency Response Center (CERC) are also provided on primary and backup systems.

A procedure exists for alerting and activating emergency personnel in the response organizations.

Separate alarms for fire, first aid and plant emerges.cy exist on the site. The alarms are audible as required and are checked weekly for operability.

Activation of a siren system to alert the pub'ic in the EPZ is handled by the State. The alerting by the sirens is backed up by broadcasts over local radio and television stations through the Emergency Broadcast System.

The licensee is presently taking steps to cure occasional problems with accidental activation of sirens and is also performing tests to insure that the audibility of the system is adequate. A test on January 20, 1982, identified a siren that failed to activate and identified problems with the test procedure (too short an activation of the sirens).

Measurements were performed by the licensee at three monitoring sites. The sound dif ferential was below the 10 dB dif ference between the sirens and daytime ambient levels mentioned in NURt:G-0654, Appendix 3.

Based on the observations, the licensee is evaluating each siren and a new test has been scheduled for April,1982, with a full three minute activation of the sirens.

Based on the above findings, this portion of the licensee's program appears to be adequate.

4.2.4 Damage Control / Corrective Action and Maintenance Equipment and Supplies The general needs for damage control are discusseo in the Emergency Plan 6.3 Corrective Actions, Section 7.6, Damage Control Equipment and Supplies, and Section 8.1 Organizational Preparedness.

Section 8.1.1g Repair and Damage Control Teams, discusses only the training and retraining of the damage control teams.

Section 8.3, Maintenance and Inventory of Emergency Equipment and Supplies discusses only Health Physics response equipment and supplies.

Discussions with the superintendent of maintenance and the superintendent of maintenance services indicated that the primary source of supplies and equipment l

would be the warehouse, backed up by the onsite supplies at the North Anna i

Nuclear Station, and by procurement through Westinghouse, INP0, and the previously qualified vendors. Administrative Procedure (AP) 69, Warehouse Stock Material, was reviewed; emergency equipment and supplies are not designated within this procedure.

Damage control teams at the full scale exercise were satisfactorily assembled at the OSC under the direction of the TSC and OSC management representatives and are expected to be routinely assembled for all emergencies.

Based on the above findings, this area of the licensee's program appears to be adequate.

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4.2.5 Reserve Emergency Supplies And Equipment The general needs for reserves are discussed in Section 7.6, Damage Control Equipment and Supplies, of the Emergency Plan.

Discussions with the superintendent of maintenance and the superintendent of maintenance services indicated that the onsite inventory of supplies and equipment would be adequate to support emergency operations.

Minimum stock levels are maintained in the warehouses. Additional supplies and equipment would be made available from the Vepco North Anna Nuclear Power Station and by procurement through Westinghouse, INPO and the qualified vendors.

Based on the above findings, this area of the licensee's programs appears to be adequate.

4.2.6 Transportation The specific needs for transportation are not discussed in the Emergency Plan. A station ambulance is kept near the Administration Building and a backup ambulance is kept near the construction site first aid station.

Three trucks and two automobiles that are assigned to specific functions within the plant are also radio-equipped and available for emergency use. A second set of keys for these vehicles is maintained in the station manager's office.

Trailer hitches are attached to the three trucks that are available for emergency use.

Based on the above findings, this area of the licensee's program appears to be adequate; however, the following item should be considered for improvement:

Providing for the needs of transportation in the Plan and in the applicable emergency procedures. (50-280, 281/82-05-34)

5.0 EMERGENCY IMPLEMENTING PROCEDURES 5.1 General Content And Format The Emergency Plan Implementing Procedures (EPIPs) were reviewed with respect to the requirements of 10 CFR 50.47 (b); 10 CFR 50 Appendix E, Section IV; the criteria in NUREG-0654,Section II.B.

The organizational element having the authority and responsibility for performing emergency tasks is generally specified in the procedures; however, specific individuals, by emergency title, are not often specified. This problem stems

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primarily from the reluctance of the licensee to assign specific emergency titles to positions in the emergency organization.

Normal organizational position titles are still maintained by individuals when they assume a position in the emergency response organization, with few exceptions.

. EPIP-1 " Emergency Classification:

Formation, Notification and Communications,"

provides the overall implementation of the emergency plan requirements.

It contains a table of EAL's and protective action measures for onsite. However, it does not contain the basic guidance for making protective action recommendations to offsite authorities (c.f.5.4.2).

EPIP-13, APX 1 states that the Virginia Emergency Plan calls for declaring a site-emergency if radiation levels exceed 50 mr/hr substained for greater than 30 minutes. This initiating condition is not specified in the licensee's EAL's.

Action steps are not always clearly displayed in a step-by-step fashion.

In general, the procedural steps are very difficult to follow. One of the licensee personnel suggested that he would do what was appropriate based on experience, rather than follow these complicated and time consuming procedures.

The EPIPs generally referred to other EPIPs to complete the desired task. As indicated, the reference system was complicated. Some EPIPs referenced normal or routine procedures; however, the degree and frequency of referencing the_ routine procedures were insufficient. All routine procedures required to complete the detailed emergency task were not referenced in the EPIPs. These references were generally available to the user.

Based on the above findings, the following' deficiency was identified:

The EPIPs are complex, and in many -parts, illogically sequenced and -

difficult to follow. Consequently, no assurance exists that the emergency response functions can be performed in a prompt and effective manner.

(50-280,281/82-05-35)

5.2 Emergency, Alarm And Abnormal Occurrence Procedures The E u rgency, Alarm, Abnormal Occurrence and the new Emergency Contingency Action Procedures were reviewed against the requirements of 10CFR50.47(b);

10CFR50 Appendix E, Section IV; and the criteria in NUREG-0654, Sections II.D.,

H. and I.

There are six (6) Emergency Procedures (EP):

EP-0 Immediate Action and Diagnostic Procedures for STA EP-1 Reactor Trip EP-2 Loss of Reactor Coolant EP-3 Loss of Secondary Coolant EP-4 Steam Generator Tube Rupture EP-5 Safety Injection I

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These procedures reflect an " event" approach to responding to emergency conditions. All of these-procedures contained references to EPIP's in the "Long Term Operator Actions" section. For example, EP-2, Section 4.3 states " Emergency Coordinator initiate EPIP-7".

The Emergency Procedures system is currently being transformed by vendor efforts to include Emergency Contingency Action Procedures (ECA).

This effort will result in " symptom" based procedures. One ECA has been developed which addresses the loss of all AC power. Although no ECA has been developed for loss of DC'

power, this condition is addressed in Abnormal Procedures 10 and 29, " Partial Loss of Reserve Station Service" and " Partial loss of Station Service,"

respectively.

It appears that the transformation is occurring without a loss of continuity in documentation.

There are about 80 Abnormal Procedures and numerous Annunciator Procedures. A representative number of procedures were examined. In general, these procedures did not directly reference the EPIP's.

However, based on the review and walk-through, it was concluded that there were sufficient cross-references between the procedures to activate the Emergency Plan and its implementing procedures.

Based on the above findings, this portion of the licensee's program appears to be adequate.

5.3 Implementing Instructions The Implementing Instructions were reviewed against the requirements of 10CFR50.47(b); 10CFR50, Appendix E, Paragraph IV. 0; the criteria in NUREG-0654, Sections II.C, D, H, I, and Appendix 1.

There is no implementing instruction for each class of emergency.

The implementing instructions tend to be based on an event such as Fire, Natural Disaster, Fuel Handling Accident, Steam Generator Tube Rupture, Main Steam Line Rupture, Loss of Coolant Accident, Unplanned / Uncontrolled Release, and Personnel Injury / Overexposure.

Actions for emergency classifications are integrated into the implementing procedures and tend to be nonspecific.

EPIP-1 provides the overall guidance. in emergency response actions and was written primarily for the Eme.gency Director.

Although there was no implementing instruction for each emergency classification, there were a set of EALs and initiating conditions for each emergency classification in EPIP-1, APX-1.

The EALs were generally based on readily observable information.

Most of the EALs were based on technical specifications required sampling and analysis, and did not permit the timely classification of accidents.

Additionally, several EALs limit user action through a statement which requires confirmation surveys, or sampling and analysis by HP before declaring the emergency; examples are ALERT No. 6, and SITE Nos. 3, 4, 8, and 11. There are also eleven procedures dealing with accident assessment.

These procedures specify several methods for determining dose rates and release rates; however, there is na implementing instruction which guides the user in the completion of the task in an expeditious manner.

These limitations appear to delay the prompt notification decision making process.

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.

_

,

Some EALs for natural events were specified in ADM-25 " Operation of the Station During Hazardous Times" dated August 24, 1979. These EALs were not necessarily compatible with the EALs in EPIP-1, APX-1.

The implementing instructions in EPIP-1 orchestrate the implementation of.other EPIPs which have been developed to implement or support implementation of the emergency plan. The supporting EPIPs, however, are not comprehensive enough to provide the detail necessary to implement all provisions of the Plan.

Based on the above findings, the following deficiencies were identified:

1.

EPIP-1 did not support a rapid initial accident assessment leading to the formation of protective action recommendations, the prompt notification of offsite authorities and the effective coordination of all other implementing procedures from the initiation of an event until close-out.

(50-280,281/82-05-36)

2.

EPIP-1 did not clearly specify the initiating conditions for classifying an accident. (50-280,281/82-05-37)

5.4 Implementing Procedures 5.4.1 Notifications The notification procedures were reviewed with respect to the requirements of 10CFR50.47(b)(5),10CFR50, Appendix E, Paragraph IV.D, and the specific criteria in NUREG-0654, Sections II.E, F, H, and J.

EPIP-1 lists the notification procedures in Section 3.0, 5.0 and Appendix 4 and 5.

Following declaration of an emergency and classification of the emergency, the Emergency Director (Shif t Supervisor until relieved per Appendix 6, EPIP-1)

begins the notifications per the means and priorities listed in Section 3 of EPIP-1. Provisions are made for documenting and verifying the notifications. In the case of the counties, cities and State, a specific form is used for notification and transmittal of information (EPIP-1, Appendix 5).

Af ter he is notified, the Superintendent of Operations calls out additional operations personnel as required by the conditions.

If Emergency Response Personnel are required, the Emergency Director notifies Security to initiate

~

the calls (Appendix 4). The personnel to be called are listed in the' Emergency Notification List along with their home and work phone numbers.

_

Although the notification procedures are fractionated, it appears that the notification procedures meet the intent of the criteria.

Based on the above findings, this portion of the licensee's program appears to be adequate; however, the following item should be considered for improvement:

Establish a single EPIP for notifications with clearly established event activated notification lists. (50-280, 281/82-05-38)

5.4.2 Assessment Actions

e

The licensee's procedures for assessing the radiological consequences for an accident were reviewed with respect to the requirements of 10CFR50.47(b)(9);

10CFR50, Appendix E, Paragraph IV.B.; and specific criteria in NUREG-0654,Section II.I.

There are eleven (11) separate implementing procedures related to accident assessment. They contain several methods for estimating release rates and dose rates which cover a wide variety of situations. Alternate paths are provided to achieve what is expected to be the same results.

During the walk-through, the inspector noted that personnel would of ten search back and forth through the various procedures attempting to find the appropriate information rather than proceeding forward in a step-wise fashion.

There was no overall implementing instruction to assist the user in expeditiously selecting the most appropriate route or form to complete.

The procedures contained no provisions or guidelines for recommending protective actions to offsite officials, or criteria for escalating and de-escalating an emergency classification. During the walk-through a :onsiderable amount of time was consumed looking for the protective action recommendation guidelines (PAGs).

(The inspector identified the location in the Plan in one case.) When the PAGs were located in the Plan, they were found to contain modified EPA PAGs or State of Virginia PAGs. The State system normally calls for an evacuation recommenda-tion at 2 rem whole body and 12 ' rem thyroid dose. The Plan, page 6.26, indicates that the State PAGs would be 50 percent of the EPA PAGs. However, Table 6.1 (page 31) of the Plan contains recommended actions which are not consistent with the State PAGs. The table also recommends seeking shelter and awaiting further instructions, and " consider evacuation" for children and pregnant women between the range of 1 to 5 rem whole body and 5 to 25 rem thyroid.

The EPA PAGs recommend evacuating at I rem whole body and 5 rem thyroid dose for sensitive populations unless constraints make it impractical.

The inspector recognizes that the State is the final authority in protective action decisions; however, based on the inspector's derivation of one equation and discussions with the corporate Health Physicists, the equations and graphs in the EPIPs used to project thyroid dose are based on the adult rather than the child. This implies that the State's attempt to reduce the EPA PAGs by 50 percent has been defeated in the case of the thyroid dose, since the multiplication factor between an adult and child is two (2).

The procedures contain two systems for classifying an accident. EPIP-1, APX-2, contained a table which relates EALs to the four emergency classifications. Some EALs are listed in EPIP-13, APX-1; ADM-25 and EPIP-11, APX-3, but are not listed in the Table.

The inspector questions the degree of compatibility of the two systems.

The various sources and instrumentation used to obtain release data are identified in procedures.

No clear guidelines, however, have been established for estimating the duration of release when the true release time is unknown so that potential exposures during evacuation may be estimated.

There are no implementing procedures which require the asses: ment of plant conditions following an earthquake.

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,

<

The licensee has factored meteorological conditions into the dose assessment procedures.

The meteorological assessment capability is consistent with the characteristics of the Class A model of NUREG-0654, Appendix 2.

There are no provisions for continuously updating offsite officials concerning status, or the closing out or class reduction of the emergency status in accordance with NUREG-0654, Appendix 1.

In general, the assessment procedures are too cumbersome and contain information not necessary for the immediate assessment and notification of offsite authorities. For example, they contain information on administrative reports to be sent to the NRC; calls to the insurance company, and philosophical discussions which may be more appropriately covered in a classroom setting.

There is no clear distinction made between the initial prompt response and the more long term response.

Combined, this makes the initial assessment of the accident time consuming which significantly delays recommendations of protective actions to of fsite authorities.

Based on the above findings, the following deficiency was identified:

The dose assessment procedures were so complex and cumbersome that there was no assurance that a rapid and accurate initial accident assessment could be made leading to prompt notification of offsite authorities.

(50-280,281/82-05-39)

Further, the following items should be considered for improvement:

1.

Providing guidelines for recommendations to of fsite authorities in the implementing procedures. (50-280,281/82-05-40)

2.

Basing all thyroid dose protective action recommendations on child thyroid rather than the adult. (50-280, 281/82-05-41)

3.

Incorporating in the licensee's guidelines provisions for estimating the duration of a release as recommended in EPA-520/1-75-001. (50-280, 281/82-05-42)

4.

Revising procedures to provide for promptly notifying the offsite authorities of any change to the emergency status and the closing out of emergency situations in accordance with Appendix 1, NUREG-0654.

(50-280, 281/82-05-43)

5.

Dividing the assessment and notification procedures into two phases; the initial quick response and the long term phases. (50-280, 281/82-05-44)

5.4.2.1 Of fsite Radiological Surveys The Emergency Radiological Survey procedures were reviewed against the requirements of 10CFR50.47(b)(9), 10CFR50, Appendix E, Paragraph IV.E. and specific criteria in NUREG-0654,Section II.I.

Emergency radiological offsite surveys are performed according to VEPC0 Health Physics Procedure Manual and EPIP-16. Pertinent survey procedures and forms from l

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these two sources are found in each emergency kit and in several locations in the Health physics area.

.

The licensee does not use prepositioned survey points to determine precise measurement locations within the plume EPZ. A floating point system is used to allow maximum flexibility in tracking the plume centerline. The accuracy of this system is highly dependent upon the ability of the team members to determine their location on maps and communicate this information back to the EOF.

Existing procedures do not describe primary and backup transportation for offsite monitoring teams. Nor do the procedures specify the means by which team members, vehicles, and equipment are to pass expeditiously through security when departing the plant.

Radiation protection levels and actions are not specified for offsite team members tracking a plume.

The procedures also fail to speci fy a central collection point for environmental samples and completed survey data forms, and the unique labeling of all environmental samples is not assured.

(See al so 5.4.2.2 - 5.4.2.3).

Offsite survey details are recorded on form EPIP 16.1.

The form has no provisions for recording instrument identification, mode of the instrument operation (i.e., beta shield open or closed), air sampler flow rate, background radiation levels, and sample count time.

The use of routine procedures for accident level conditions is not desirable in certain cases. For example, insufficient attention is given to special handling problems characteristic of very " hot" samples expected in accident conditions.

Based on the above findings, this portion of the licensee's program appears adequate; however, the following should be considered for improvement:

1.

Upgrading established procedures to assure primary and backup transportation for of f site monitoring teams, and the means by which team members, vehicles, and equipment are to pass expeditiously through security when departing the plant (50-280, 281/82-05-45)

2.

Upgrading established procedures to specify radiation protection levels and protective actions for offsite team members tracking a plume, a central collection point for the return of environmental samples and completed survey data form, and the unique labeling of all environmental samples.

(50-280, 281/82-05-46)

3.

Expanding form EPIP-16.1 to include spaces for instrument identification, mode of instrument operation, air sampler flow rate, background radiation levels, and sample count time. (50-280, 281/82-05-47)

4.

Revising the routine survey procedures that are used for accident conditions to include special sample handling techniques designed to avoid unnecessary radiation exposures from abnormally " hot" samples.

(50-280, 281/82-05-48)

5.4.2.2 and 5.4.2.3 Onsite and Inplant Radiological Surveys

I l

The onsite and inplant Radiological survey procedures were reviewed against the requirements of 10CFR50.47(b)(9), 10CFR50, Appendix E,

Paragraph IV.E and specific criteria in NUREG-0654,Section II.I.

Onsite and in plant surveys include direct radiation readings and the collection of gas, particulate, and iodine samples.

Emergency monitoring teams are assembled as needed by the Health Physics supervisor. The teams perform surveys according to the Health Physics Procedure Manual. However, radiological survey procedures and air particulate sampling procedures are not addressed for emergency situations.

Also, there is no provision for recording vital information for these surveys, such as date, time, name or initials, instrument type and serial number, mode of operation, duration of count, flow rates, and background radiation.

Based on the above findings, this portion of the licensee's program appears to be adequate; however, the following items should be considered for improvement:

1.

Establish emergency radiological survey and air particulate sampling procedures, including special provisions for handling abnormally " hot" samples, which are consolidated with other emergency procedures.

(50-280, 281/82-05-49)

2.

Make provisions for recording vital information for emergency onsite and inplant surveys. (50-280, 281/82-05-50)

3.

Establish a central collection point for all samples and vital sample information and include this in applicable procedures.

(50-280, 281/82-05-51)

5.4.2.4 Primary Coolant Sampling The post-accident primary coolant sampling procedures were reviewed and evaluated during walk-throughs. The procedures were evaluated against the requirements of 10CFR50, Appendix E, Paragraph IV.B, NUREG-0654,Section II.I. and NUREG-0737,Section II.B.3.

Chemistry Procedure CP-66, Post-Accident Reactor Coolant Sampling contains procedures for post-accident sampling of primary coolant.

The procedure specifies radiation exposure limits to sampling personnel and ensures the habitability of the sampling areas through such means as specifying operation of various systems, monitoring, protective equipment and RWPs.

The sampling point location is not specified, but personnel are trained in identifying the location of sample points.

Only one sample can be taken by the interim system now in use.

The specific means of moving the sample is not, identified, however, the sample pig is mounted on a cart. No provisions are made for labelling the sample.

The procedure provides for a 1:1000 diluted sample. The procedure also provides instruction for further dilution in the Hot Lab to 1:1,000,000.

CP-66 references chemistry procedures for chemical analysis and CP-43, Isotopic Analysis, provides procedures for sample preparation for isotopic analysis and, in turn, references Health Physics Procedure HP-3.4.1.3, Nuclear Data ND6600 t

,

Multichannel Analyzer, under which count room personnel conduct the isotopic analysis

.

Based on the above findings, this portion of the licensee's program appears to be adequate; however, the following items should be considered for improvement:

1.

Modifying post-accident coolant sampling procedure to describe the required means for transporting samples to the Hot Lab. (50-280, 281/82-05-52)

2.

Specifying the sample point locations. (50-280, 281/82-05-53)

3.

Modifying the sampling procedures to make provisions for labelling the sample. (50-280,281/82-05-54)

5.4.2.5, 5.4.2.7, 5.4.2.9, 5.4.2.11 Post-Accident Sample Analysis The post-accident sample analysis procedure was reviewed and evaluated against the requirements of 10CFR50, Appendix E, Paragraph IV.E. and selected criteria of NUREG-0654,Section II.I. and NUREG-0737.

Post-accident sample analysis is performed in accordance with HP 3.4.1.3, Instrument Operation and Calibration Nuclear Data ND6600 Mltichannel Analyzer.

The procedure does not provide for analysis of high level samples.

Primary coolant samples are diluted by the chemistry technicians in accordance with CP-66 and 'CP-43, and liquid effluent samples are diluted by HP or Operations personnel to acceptable levels. Air samples are also diluted; containment air samples are diluted in accordance with EPIP-7, Appendix 1, and other gas samples are diluted by a similar method. Particilate filters and charcoal cartridges are counted as a unit. If level is too high, they may be separated, then counted.

Currently, the only other alternative is to control the sampling time to keep the level down.

Procedures do not specify methods to protect counting facilities from contamination but plastic was observed to be routinely placed between the detector head and the sample.

The procedure does not make prevision for analysis if the counting area has a high background.

The detectors are heavily shielded and a licensee representative stated that if background was significant or area was uninhabitable, the detectors would be moved to other designated areas.

The procedure does not provide for recording data on data sheets or logs nor for providing data to the organizational element responsible for the assessment function, except CP-43 assigns responsibility for providing coolant analysis to the appropriate individual. Licensee representatives stated that analytical data is recorded by the system as computer printouts and is provided to appropriate individuals in the emergency organization.

The analytical procedure makes no provision for disposition of samples after analysis.

Based on the above findings, this portion of the licensee's program appears to be adequate; however, the following items should be considered for improvement:

m

1.

Developing procedures for the analysis of high level, post-accident samples.

(50-280, 281/82-05-55)

.

2.

Revising analytic procedures to specify methods of protecting the counting facilities from contamination. (50-280, 281/82-05-56)

3.

Revising analytic procedures to specify means of counting if the counting area has a high background. (50-280, 281/82-05-57)

4.

Revising analytic procedures to specify means of recording data and to assign responsibility for providing data to the organizational element responsible for the assessment function. (50-280,281/05-58)

5.

Revising analytical procedures to provide for the disposition of samples after analysis. (50-280, 281/82-59)

5.4.2.6 Containment Air Sampling The post-accident containment atmosphere sampling procedure was reviewed and evaluated against the requirements of 10CFR50, Appendix E, Paragraph IV.E, and selected criteria of NUREG-0654,Section III.I and NUREG-0737,Section II.B.3.

EPIP-7, Loss of Coolant Accident, Appendix I, Post-Accident Containment Atmo-sphere Sampling provides a detailed checklist for the operation of the emergency sampling equipment and for the dilution of the sample for analysis.

The procedure specifies precautions and limitations to limit exposure to sampling personnel and to verify the habitability of areas occupied by sampling personnel.

The sampling point location is specified in Paragraph 2.3 of Section B of the procedures.

Specific sampling equipment to be used and sampling media are identified in the procedures. protective clothing and equipment, including dosimetry to be used, are specified.

'

The procedure specifies that the 1cc sample taken in a syringe is to be injected into the 100cc sample bomb and returned to the lab for analysis.

The method of transporting the sample was not specified but licensee management personnel stated that at the worst, the dose rate on the 100 cc sample bomb was expected to be between 1 and 100 mR/hr. No provision was made for labeling the sample for later identification.

As a result of evaluating the procedure and conducting a walk-through of the procedure, it appears that the sampling can be completed within one hour.

Based on the above findings, this portion of the licensee's program appears to be adequate; however, the general needs identified as improvement items in Paragraph 5.4.2.4 should be applied to containment air sampling.

(50-280, 281/82-05-60)

5.4.2.8 Stack Effluent Sampling

)

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The procedure for ventilation vent and process vent sampling was reviewed and evaluated against the requirements of 10CFR50, Appendix E, Paragraph. IV.E. and selected criteria of NUREG-0654,Section II.I, and NUREG-0737.

Installed equipment and sampling locations were inspected and discussed with licensee representatives. and Procedure HP-3.2.2, Radioactive Gaseous Waste Sampling and Release Rate, was reviewed.

Section 4.1.4 of the HP-3.2.2 discusses sampling the process vent and the ventilation vent for radiciodines, particulates, noble gases and tritium for planned and unplanned releases.

The procedure does not specify means of limiting exposure to sampling personnel (

or verifying habitability of the areas near the sampling point. The locations of (

the sampling points are not specified.

The procedure specifies the sampling media and special sampling media to be used such as silver zeolite cartridges. A data sheet (Form 3.2.2.4) is attached to the procedure and referred to in Section 4.1.4.

Provisions have not been made for shielded transportation of the potentially highly radioactive samples.

The procedure indicates that samples are to be placed in plastic bags and carried.

No provision is made for labelling the samples.

Based on evaluation of the procedure and a walk-through, it appears that the sampling can be completed in one hour.

Based on the above findings, this portion of the licensee's program appears to be adequate; however, the general needs identified as improvement items in paragraph 5.4.2.4 should be applied to stack effluent sampling. (50-280, 281/82-05-61)

5.4.2.10 Liquid Effluent Sampling The liquid effluent sampling procedures were reviewed and evaluated against the requirements of 10CFR50, Appendix E, Paragraph IV.E. and selected criteria of NUREG-0654,Section II. I.

There were no procedures that described the use of liquid effluent emergency sampling equipment.

Operations procedure OP-12, Sampling System and Local Sampling which is used for routine liquid sampling is also used for post-accident sampling.

The procedure limits exposure to sampling personnel and verifies the habitability of areas transversed and occupied by sampling personnel through application of Section 4.0, Precautions and Limitations. Licensee representatives stated that Health Physics personnel would survey the sampling areas under emergency conditions.

The sampling points are identified but exact locations are not specified.

Sampling media and equipment are specified; liquid samples are taken in specified containers.

The procedure does not include data sheets or specify labelling of the sample.

Transportation of the samples under accident conditions are not specified.

Based on review of the procedures and a walk-through, it appears that a sample can be collected in one hou Based on the above findings, this portion of the licensee's program appears to be adequate, however, the general needs identified as improvement items in paragraph 5.4.2.4 should be applied to liquid effluent sampling. (50-280, 281/82-05-62)

5.4.2.12 Radiological and Environmental Monitoring Programs The Radiological and Environmental Monitoring Program was reviewed with respect to the requirement of 10CFR50.47(b)(9), 10CFR50, Appendix E, Paragraph IV.E, and criteria in NUREG-0654,Section II.I, and NUREG-0737.

A comprehensive procedure including assignment of responsibility for establishing the m'onitoring team does not exist.

The procedure EPIP-16, Of f site Air, Contamination and Radioactive Monitoring, does give general guidance to the monitoring team and provides a form for recording data. EPIP-17, Offsite Water and Foodstuf f Monitoring, gives general guidance including instructional forms for the collection of samples. Routine biological samples are collected by the station biologist. Although sample types and locations are specified in the two procedures, techniques for gathering the samples are not specified. The standard procedure, Health Physics Environmental Sample Collection and Analysis, HP-3.5.1, covers the procedures in detail for standard radiological and environmental monitoring.

The routine environmental sampling sites include low-volume air samplers with particulate filters and charcoal cartridges at eight selected sites, and environmental TLDs at all 43 sites.

The particulate filters and charcoal cartridges are changed weekly and the TLDs are on annual or quarterly cycles.

The routine environmental monitors (TLD, filters, cartridges) are sent to a consultant for routine analysis. At present, selected environmental samples are analyzed by both the state and Surry's consultant under a quality control program using split samples. Calibrated facilities for analysis of samples exist at the station and can be backed up by the North Anna Power Station. The station also has its own equipment for reading environmental TLDs in an emergency.

The station personnel do not intend to use the established environmental sites for emergency analysis.

Specifically dispatched teams, under EPIP-16 and EPIP-17, will collect emergency monitoring samples. The teams have four portable air samplers, environmental TLDs and other miscellaneous hardware (bottles, filters, etc.) available in the Health Physics area for emergency monitoring.

Monitoring depends on the capability to dispatch teams across the James River (the direction of the prevailing winds). Speedy access to these areas depends on the availability of the state ferry which is five miles from the plant and could be shutdown by an evacuation.

The alternative would be to use the bridge at Newport News which may require as much as an additional hour for access to the area.

An agreement does not exist to keep the ferry operating during an emergency, or to provide alternative means of rapid access to the areas across the river.

Based on the above findings, this portion of the licensee's program appears to be adequate; however, the following items should be considered for improvement:

1.

Upgrading established procedures to assign specific authority for organizing and coordinating environmental monitoring teams. (50-280, 281/82-05-63)

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2.

Establishing a means to assure timely access to the north bank of the James River for monitoring. (50-280, 281/82-05-64)

5.4.3 Protective Actions 5.4.3.1 Radiation Prctection During Emergencies Radiation protection during emergencies was evaluated against the requirements of 10CFR50.47(b)(11), and NUREG-0654, section II.K.

'

An overall plan governing the implementation cf the radiation protection program during emergencies was not available.

The station plans to use standard radiation protection procedurss wherein they will rely on Radiation Work Permits (RWPs) and experienced' personnel to control access and doses durf eg an

~

emergency.

Although RWPs would be used to instruct and control emergency workers, this is not covered in the emergency procedures.

HP 3.3.2, Health Physics Survey Air Sampling, is apprently the only standard procedure referring to procedures for use during emergencies. Personnel dosimetry, exposure records, access control, dose assessment Ohd limiting of exposure are only covered in isodard procedures and only with regard to normal operating conditions.

.

EPIP-18 provides formal procedures for permitting exposure of personnel to emergency exposure limits.

A form is provided for authorization of excess exposure; however, administrative authority is not clearly delineated.

Emergency self cc,ntained breathing devices (SCBA) are available and a cascade system is available for filling the bottles,, or alternatively, a compressor used for filling the firemen's bottles can be employed. High range pocket dJsineters and instruments for use in high radiation fields are available.

's.

Procedures do not exist to identify responsibili. ties for the health physics

.

emergency functions, nor does a procedure exist to assign prioritfes for health physics actions during emergencies. h ving'an emergency, the Emergency Director, with his technical support staff, would be expected Co handle this resnonsibility

expeditiously.

,

Based on the above findings, this portion of the licensee's program appears to be adequate; however, the followin1 items should be considered for improvement:

.

.

1.

Developing an overall proc.edure for radiation protection during emergencies which assigns responsibilities and oriorities for health physics activities.

(50-280, 281/82-05-65)

.

2.

Developing specific 93idanct 'iithin the emergency piocedure for issuance of dosimeters to non plant versonnel, dose assessment, control of access to radiation zones, keeping e2pasure recoros, and limiting exposure during an emergency. ( 50-280, 281/62-Of-66)

'

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3.

Upgrading established precedures to p o' vide specific administrative responsibility for the authorizatio,n of emergency exposures.

(50-280, 281/82-05-67)

.

5.4.3.2 Evacuation of Owner Controlled Areas

.

N.,

s L

The evacuation of the owner-controlled areas was reviewed with respect to the criteria in NUREG-0654,Section II.J.

.

The emergency procedure EPIP-1, Section 4.1, specifies an action level at which the Emergency Director should consider evacuation and implement EPIP-8.

The location of the assembly area is specified in both the plan and EPIP-8, but specific directions to the area are not given in EPIP-8.

Evacuation routes are not marked in the plant nor is the route to the assembly area. Alternative assembly areas are not provided for in the procedures, nor are alternative actions, such as taking cover on site, if the plume is centered over the evacuation route and assembly area.

EPIP-8 makes provisions for specific evacuation announcements to be made over the P.A. system. The procedure does not make provisions for personnel monitoring or decontamination at the remote assembly area. EPIP-8 does not make reference to any accountability procedures. (See 5.4.3.2 and 5.4.3.3)

Based on the above findings, this portion of the licensee's program appears to be adequate; however, the following items should be considered for improvement:

1.

Upgrading established procedures to clearly activate the emergency plan with regard to evacuation routes, means of transportation and alternatives in case of unfavorable radiological conditions. (50-280, 281/82-05-68)

2.

Clearly marking evacuation routes both inside and outside the plant.

(50-280, 281/82-05-69)

5.4.3.3 Personnel Accountability The procedures for personnel accountability were reviewed with respect to the requirements of 10 CFR 50.47(b)(10), and the criteria of NUREG-0654,Section II.J.

The personnel accountability system is described in EPIP-9 for plant personnel and in VEPC0 Project Operating Procedure (POP) No. 2.9.4 for construction personnel. The Shif t Supervisor is given final responsibility for accountability and for the formation of search teams as required (EPIP-9). The Emergency Plan calls for completion of accountability in 30 minutes, but EPIP-9 does not address accountability within 30 minutes. Although EPIP-8 calls for an initial listing of personnel remaining onsite, a procedure for continuing accountability of these personnel is not provided. The magnetic card identification system will provide accountability, but procedures for using the system for continuing accountability are not documented in the Emergency Procedures.

Personnel accountability procedures are initiated by an emergency signal.

To assure that personnel in the high noise areas are notified, operations personnel are dispatched to high noise areas (containment, auxiliary building, turbine buildings, service building and safeguard buildings) with portable loudspeakers to announce that the emergency signal has been sounded. Th announcement states that personnel should report to the area in which their work day begins. In the procedures, some confusion exists with regard to assembly points. The basic rule seems to be to report to the point at which the work day begins, but several

s

assembly areas exist in work areas that may be nearer than the point at which the day starts (auxiliary building).

The personnel accountability procedure also calls for. notification of individuals (on owner-controlled property) at the north end of the Peninsula. However, other than warning the individuals, it is not clear what actions should be taken by the individuals (i.e., evacuate, move to plant).

Based on the above findings, this portion of the licensee's program appears to be adequate; however, the following items should be considered for improvement:

1.

Upgrading established procedures to assure completion of accountability within 30 minutes and providing for continuing accountability of onsite personnel. (50-280, 281/82-05-70)

2.

Revising procedures to clearly indicate where personnel are expected to assemble for accountability under all circumstances. (50-280,281/82-05-71)

3.

Revising procedures to indicate exactly what actions individuals on the north end of the Peninsula will be requested to take.

(50-280, 281/82-05-72)

.

5.4.3.4 Personnel Monitoring and Decontamination Procedures for personnel monitoring and decontamination were reviewed against the requirements of 10CFR50, Appendix E, Paragraph IV.E and the criteria of NUREG-0654, Sections II.J. and K.

Personnel monitoring and decontamination is the responsibility of the Health Physics group. Personnel making a routine exit from the plant appear to be well monitored for contamination.

During an emergency evacuation of the plant, personnel are to bypass monitoring points and proceed to the assembly area for accountability.

Personnel are then to proceed to the remote assembly area if conditions warrant.

Current procedures do not assure Health Physics personnel will be dispatched to monitor personnel in the remote assembly area. No means of recording vital survey information at the remote assembly area exists. Also, the licensee has no procedure or plans for personnel decontamination at the assembly areas.

Based on the above findings, this portion of the licensee's program appears adequate; however, the following item should be considered for improvement:

Establishing or upgrading existing procedures to assure that Health' Physics personnel are dispatched to monitor personnel in the remote assembly area.

The procedures should describe the monitoring and decontamination methods, establish contamination action levels for decontamination, and provide a form for recording all pertinent survey information for each person.

(50-280,281/82-05-73)

5.4.3.5 Onsite First Aid / Rescue

Procedures for onsite first aid and rescue were reviewed against the requirements of 10CFR50, Appendix E, Paragraph IV.E and the criteria of NUREG-0654., Sections II.K. and L.

The plans for handling first aid and rescue care of injured personnel are as stated in Vepco Accident Prevention Manual, Article 103, and EPIP-3 Injured Personnel.

Several significant oversights were identified in the procedures which describe the care of an injured person who may be contaminated.

In EPIP-3, no one is designated to call for the onsite ambulance when an employee needs offsite medical care.

Also no ambulance driver or backup drivers are designated. The provisions for dosimetry exchange in the ambulance appear to be inadequate in that the arrival of replacement dosimetry for the ambulance crew is not assured. EPIP-3 directs the Shif t Supervisor to notify the Medical College of Virginia of the accident severity, however, no instructions are given as to when the notification is to be made. Also, the procedures contain no mention of Health Physics coverage for offsite rescue squads providing supplemental site support.

Based on the above findings, this portion of the licensee's program a'ppears to be adequate; however, the following items should be considered for improvement:

1.

Expanding the implementing procedures to designate the personnel responsible for calling the onsite ambulance into service, driving the ambulance, and exchanging dosimetry prior to ambulance departure. (50-280, 281/82-05-74)

2.

Revising the implementing procedures to specify when the shif t supervisor is to notify the hospital, and to assure health physics coverage for medical / rescue personnel arriving from offsite locations.

(50-280, 281/82-05-75)

5.4.4 Security During Emergencies Procedures for security support during emergencies were reviewed with respect to the requirements of 10CFR50.47(a) and (b),10CFR50, Appendix E, Paragraph IV. A.

and criteria in NUREG-0654,Section II. A.

Security measures to be placed in effect during emergencies are specified in the following procedures:

EPIP-1 Appendix 4, Notification of Emergency Response Personnel EPIP-8 Evacuation and Access Control Onsite EPIP-9 Personnel Accountability SEC-24 Security During Emergencies SEC-26 Fire Protection These procedures were reviewed and discussed with the security superintendent and the operations superintendent.

Security personnel perform the initial notification of emergency response personnel, assist in personnel accountability during site evacuation and perform other support activities during the emergencies, drills and exercises. These procedures were developed in accordance with the requirements of 10CFR73.

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Based on the 'above findings. this area of the licensee's program appears to be

j adequate.

5.4.5 Repair / Corrective Actions The Repair / Corrective Actions were reviewed for the criteria of NUREG-0654,

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Section II.K; Section 6.5.1 of the Emergency Plan and EPIP-18 provides guidelines and Protective Action Guides for reentry into the plant. Guides and i

guidelines are classified according to the nature of reentry such as: emergency workers, lifesaving activities, and 10 CFR quarterly limits.

In addition,

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EPIP-18 specifies 10CFR20, VEPCO, and Virginia State Exposure Limits and Contamination Limits. The Emergency Director uses these guides and guidelines in

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j authorizing exposure for each job and on Emergency Exposure Authorization Forms.

Other than authorization of specific exposure limits, the Emergency Organization will use regular Plant Operations, Maintenance and Health Physics Procedures as i

much as possible during an emergency.

Operations for repair or corrective action activities are described in the Emergency Plan in Section 6.3, Corrective Actions, and Section 7.6 Damage Control

Equipment and Supplies, and Section 8.1.1, Repair and Damage Control Teams, as

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reported in items 4.2.4 and 4.2.5 of this report.

Based on the above findings, this area of the licensee's program appears to be

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adequate.

5.4.6 Recovery

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Those parts of the Emergency Plan and the Corporate Emergency Response Plan (CERP) describing the Recovery Program were reviewed with respect to the requirements of 10CFR50.47(b)(13),10CFR50, Appendix E, Paragraph IV.H, and the criteria of NUREG-0654,Section II.M.

Section 9.3 of the CERP provides the means for the Corporate Response Manager, in consultation with the Recovery Manager, the Surry Station Emergency Director and principals on the CERP team to announce that the Recovery Phase is beginning.

Section 9.0 and 9.1 of both the Emergency Plan and the CERP provide for an evaluation of plant operating conditions as well as onsite and offsite radiological conditions to be considered in reaching the decision to enter the recovery mode of operations. Notifications to be made before a recovery mode may be assumed are specified in Section 9.2 of both the Emergency Plan and the CERP.

' Key positions in the recovery organization are identified in Section 9.4 of the Emergency Plan and in Section 3.0 and 5.0 of the CERP.

Both the Emergency Plan and the CERP provide guidance for limitation and management of radiation exposures.

Specific criteria and additional emergency procedures will be developed when required, considering maximum protection for plant personnel and the public.

Based on the above findings, this area of the licensee's program appears to be adequate.

5.4.7 Public Information

Vepco's procedures adequately identify the company organizations involved in news dissemination and the manner in which the information programs would. function in the event of an emergency, including the identification of a utility spokesman and the means of coordination.

The procedures call for the company Quality Assurance Manager to be the News Center Director, with the Vice President for Public Af fai rs as Alternate Director.

The Quality Assurance Manager is technically competent in nuclear matters and is experienced in dealing with the press.

A rumor control program procedure has been draf ted but not yet been issued.

Based on a preliminary reading by the reviewer, it appears to be adequate.

On the basis of this review, the licensee's emergency public information program appears adequate. The rumor control program will remain open pending review of the procedure af ter issuance. (50-280, 281/82-05-76)

5.5 Supplementary Procedures 5.5.1 Inventory, Operational Check and Calibration of Emergency Equipment, Facilities and Supplies This portion of the licensee's program was reviewed against the requirements of 10CFR50.47(b)(8), 10CFR50, Appendix E, paragraphs IV.E, and G.,

and criteria'in NUREG-0654,Section II.H.

Emergency kit and equipment inventories are performed by Health Physics in accordance with Periodic Test No. 38.30.

The PT designates the frequency of inventory, the location of the kits, the equipment required, and provides a form for convenient documentation.

The form provides areas for noting problems, deficiencies, and corrective actions.

Inventory checks, operational checks and instrument calibrations were up-to-date on all kits inspected and inventories were correct in all.

A limited supply of radiological equipment is stored in the plant ambulance; however, no provision currently exists for a periodic inventory of this equipment.

Based on the above findings, this portion of the licensee's program appears adequate; however, the following item should be considered for improvement:

Including the periodic inventory of radiological equipment and supplies stored in the plant ambulance in a periodic test. (50-280, 281/82-05-77)

5.5.2 Drills and Exercises The licensee's program for drills and exercises was reviewed with respect to the requirements of 10CFR50.47(b)(14), 10CFR50, Appendix E, Paragraph IV.F. and criteria in NUREG-0654,Section II.N.

Plant exercises and drills are administered in accordance with Section 8.1.2 and 8.1.3 of the Emergency Plan and EPIP-21 by the Emergency Planning Coordinator and in accordance with a scenario developed in advance. Inspection of records showed that the drills and exercises were conducted at the required frequencies.

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Full scale exercises which involve participation with Federal, state and local agencies have been conducted. Critiques of the exercises are held and comments from qualified observers are documented.

EPIP-21 requires that the Station Manager assure than any deficiencies identified by the critique are addressed and appropriate action is taken. A tracking system documents the corrective action taken for the Station Manager.

Status reports of deficiencies identified in the October 30-31, 1981, exercise were reviewed.

Individuals assigned responsibility for various croups of corrective actions have submitted reports to the Emergency Planning Coordinator.

A summary of the comments has been sent to the Corporate Director, Emergency Planning, by the Surry Station Manager.

Provisions are made for holding backshif t drills and exercises.

Responses to actual events are not considered a substitute for the required drills and exercises.

Based on the above findings, this area of the licensee's program appears to be adequate; however, the following item should be censidered for improvement:.

Having the Emergency Planning Coordinator maintain a log of all Emergency Planning correspondence and reports. (50-280,281/82-05-78)

5.5.3 Review, Revision and Distribution The review. revision and distribution of the Emergency Plan and Implementing Procedures were reviewed with respect to the requirements of 10CFR50.47(b)(16),

10CFR50, Appendix E,

Paragraph IV.G, and selected criteria of NUREG-0654,Section II.P.

Section 8.2 of the Emergency Plan states that the Emergency Plan and Emergency Plan Implementing Procedures (EPIP) are formally reviewed by the System Nuclear Safety and Operating Committee (SNSOC) annually and that revisions to the plan and/or EPIPs are reviewed and approved by this committee prior to distribution per the Administrative Procedure, ADM-13, Review of Procedures.

The tables of contents for the Emergency Plan and the EPIPs do not note the revision number and date of issue for each item.

Telephone numbers are reviewed each quarter as specified in Section 8.5 of the Emergency Plan.

Records were reviewed to determine that changes in the Plan and Implementing Procedures were distributed in accordance with the distribution list.

The records also indicate that the distribution was correct. These items are annually audited by the site QA group.

This area of the licensee's program appears to be acceptable; however, the following item should be considered for improvement:

Adding the current revision number and date of issuance to each item in the Table of Contents for the Emergency Plan and the EPIPs.

(50-280, 281/82-05-79)

5.5.4 Audit The audit program was reviewed relative to the requirements to ICCFR50.54(t),

10CFR50, Appendix E, Paragraph IV.G, and selected criteria in NUREG-0654,Section I The audit program is discussed in Section 8.4 of the Emergency Plan.

The Emergency Plan and Emergency Procedures have been audited annually by.the onsite QA audit group.

The audit involves discussions with personnel, inspection of equipment, and a review of related documentation. The QA auditors also observe emergency drilis and some QA auditors are used as evaluators for emergency exercises.

The QA onsite group documents followup of the findings reported in the VEPCO, NRC and INPO emergency planning audits and inspections.

Procedures and documentation relative to the above were reviewed and discussed with the QA manager and the QC supervisor.

Either, or both, of these persons review all changes to site procedures and attend the meetings of the Station Nuclear Safety and Operating Committee (SNSOC).

Currently, the station QA Manual is being revised in conjunction with a corporate QA reorganization. The draft of the revised QA manual, Section 5.6.le, provides for a QA audit of the Emergency Plan and Implementing Procedures every 24 months, as required by Technical Specification 6.1-13 item 3.2.5.

The current 1982 schedule of audits does not include an audit of emergency planning activities and procedures.

The QA manager and the QC supervisor recognize the need for an annual audit as required by 10CFR50.54(t), and to followup the findings of the NRC appraisal program inspection.

Relative to the current program, audit reports 581-19, S81-19A, S80-16, S79-26, S79-26A and S73-21, were reviewed.

The audit checklist does not specifically address the assessments that are to be made as to the completeness of the procedures and the adequacy of training as stated in Section S.4 of the Emergency Plan.

The audits of drills and exercises have not documented the related commitments in Section 8.1.2 and the audits of small scale exercises and drills listed in Table 8.1.

Based on the above findings, this area of the licensee's program appears to be adequate; however, the following items should be considered for improvement:

1.

Providing for an annual audit of the Emergency Plan and Energency Implementing Procedures in the appropriate manual or procedure (50-280, 281/82-05-80)

2.

Providing audit assessments and comments relative to the items specified in Section 8.4 of the Plan. (50-280, 281/82-05-81)

3.

Expanding the audit checklist item for drills and exercises to specifically address the commitments in Section 8.1.2 of the Emergency Plan for the drills and exercises listed in Table 8.1.

(50-280, 281/82-05-82)

6.0 COORDINATION WITH OFFSITE GROUPS 6.1 Off site Agencies The auditor discussed offsite support agencies with licensee representatives and reviewed the current support agreement letters contained in Section 10.1 of the Emergency Plan.

Training has been provided for all offsite support groups who may be called on to assist in an emergency. All offsite groups responding to the site will be accompanied by VEPC0 escorts while inside the protected area boundar On March 22, 1982, the inspector and the site Emergency Planning Coordinator visited the Surry County Sherif f, the Surry County Coordinator, the Isle of Wight Rescue Squad, and the Smithfield Fire Department to discuss emergency response to an accident at Surry. The individuals contacted at each of the above agencies were cognizant of their expected role in an emergency at the Surry site, had been provided training relative to their respective roles, and were satisfied that adequate communications concerning emergency response between their organizations and Vepco have been provided. Each of the above have participated in recent drills and exercises and each of the above are acquainted with the Surry site werk areas.

Based on the above findings, this area of the licensee's program appears to be adequate.

6.2 General Public Vepco has published brochures containing information about emergency planning and radiation, with specific instructions about notification in case of an emergency.

These brochures were distributed by the counties. Different editions are printed for different communities within the 10-mile emergency planning zone. Emergency planning information also has been placed in telephone books, utility bills and is provided in such places as motels and campgrounds where it would be available to transients. VEPCO plans to update this information annually.

Based on the above findings, the licensee's program of information for the general public appears to be adequate.

6.3 News Media

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The licensee has a program for familiarizing the media with its emergency plans, including information about news center arrangements, utility spokesmen, points at which information would be released, accident sequences, radiation information and plant operations. VEPC0 conducted such a familiarization briefing last fall and plans to hold one annually.

Based on tFe above findings, this portion of the licensee's program appears to be adequate.

7.0 DRILLS, EXERCISES AND WALK-THROUGHS 7.1 Program Implementation The licensee's implementation of drills and exercises was reviewed with respect to the requirements of 10CFR50.47(b)(14),10CFR50, Appendix E, Paragraph IV.F.,

and criteria in NUREG-0654,Section II.N.

The drills and exercises required by Section 8 of the Emergency Plan and Procedures have been conducted in accordance with the established procedure EPIP-21. Critiques of exercises were written.

The critique items of the full scale exercise conducted October 30 and 31, 1981, have been followed up and the documentation was reviewed.

The corrective actions for the critiques of the drills and exercises are audited by the QA grou r

Based on the above findings, this area of the licensee's program appears to be adequate.

7.2 Walk-Through Observation 7.2. f.1, 2 and 11 Observation of Emergency Detection, Emergency Classification, and Protective Action Decision Making Several walk-throughs were conducted in the control room by members of the team.

The Operators seemed well versed in responding to conditions associated with the reactor system. There appeared to be no problems in going from the annunciator procedures, abnormal occurrence procedures and emergency procedures into the EPIPs.

However, some difficulties were encountered in the use of the implementing procedures. This greatly increases the time required to assess the emergency conditions, to classify the accident, and to make appropriate recommendations to of fsite authorities. Personnel consumed a considerable amount of time searching back and forth through the procedures.

The guidelines for making protective action recommendations could not be immediately located since they were not in the EPIPs.

Personnel were familiar with the EALs presented in the Table in EPIP-1, APX-2, but unfamilar with those presented in other procedures. Personnel appeared to be capable of making reasonable onsite protective action decisions.

Based on these observations, this portion of the licensee's program appears to be adequate.

7.2. f( 3) Walk-Through Observations - Notifications The personnel contacted during this part of the appraisal were knowledgeable and interested in properly performing the requested notification.

Both the discussions and the drills went relatively smoothly. When the primary means of executing a notification did not proceed smoothly (no answer), established alternatives were executed promptly. One observation from the personnel was that the documentation for emergency procedures (EPIP-1) could be improved, a point made in earlier sections of this appraisal.

Based on these observations, this portion of the licensee's program appears to be

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adequate.

7. 2. f( 4 ) Dose Calculations i

A walk-through using appropriate EPIPs was performed to determine if individuals would demonstrate the basic skills and knowledge necessary to perform dose

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calculations.

These walk-throughs included the control room and health physics I

personnel performing their portion of the dose calculations procedure.

The control portion consisted primarily of reading monitors and reporting the

results to health physics.

Health physics personnel experienced some

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dif ficulti,es using the procedures to determine releases and the associated

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offsite dose. All were able to complete the procedure with some prompting by the inspector. Delays were experienced in determining which form to complete, or

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which method to use. A considerable amount of time was consumed in searching through the eleven procedures.

Personnel were not completely familiar with the alternate methods suggested by the procedures.

The personnel performing the walk-through felt that the time spent in calculating off site doses could be greatly reduced by increased retraining.

Based on the inspector's overall assessment of the performance and use of procedures it may take more than 30 minutes to complete an initial offsite dose assessment.

The problems detected in this area of the licensee's program are covered by the deficiency and improvement items in Section 5.4.2 of this report.

7.2.f(5) through 9 Walk-through Observations Post-Accident Sampling and

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Analysis Walk-throughs were conducted in the following major areas of post-accident sampling and analysis. All of the systems involved were interim systems:

Primary Coolant Containment Air Stack Effluent Liquid Effluent In plant radiciodine sampling and analysis.

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Sampling crews composed of HP Technicians, Chemistry Technicians, or Operators (as appropriate) were observed conducting simulated sampling after an initial period of discussion concerning allowable dose, stay time and protective equipment.

No significant discrepancies were noted in the conduct of these walk-throughs.

Results were discussed with the individuals and appropriate supervisors.

The results of these exercises are evaluated under the procedures area of this report.

Based on these observations, this portion of the licensee's program appears to be adequate.

7.2.f(10) Offsite Environmental Sampling and Analysis Health Physics personnel appeared to be familiar with their role and responsibility during accident response. Several Health Physics technicians and supervisors were requested to perform various functions assigned to them in the Emergency Plan. The primary area of interest was radiological assessment through the sampling and monitoring of offsite, onsite, and in plant locations.

Health Physics technicians, in general, demonstrated a satisfactory capability for monitoring radiation levels, taking particulate air samples, and taking iodine air samples. Heavy reliance is placed on training and " common sense" to i

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accomplish monitoring tasks. Technicians displayed an obvious reluctance to use the established emergency procedures by performing surveys according to routine procedures.

There were indications that the emergency procedures were too cumbersome and confusing to use in the field.

The technicians were not fully aware of protective measures available for use whcn performing monitoring tasks under accident conditions. This is probably due to the lack of guidance in the present procedures.

Based on the above findings, this portion of the licensee's program appears adequate; however, the following items should be considered for improvement:

1.

Upgrading the Health Physics training to include monitoring techniques under adverse, high radiation conditions. (50-280, 281/82-05-83)

2.

Training technicians to be aware of protective measures available for keeping exposures to a minimum when monitoring in high radiation conditions (50-280, 281/82-05-84)

8.0 Followup On Previously Identified Emergency Preparedness Items a.

(Closed) (50-280, 281/78-28-02) The older meteorological system is no longer used to provide meteorological data for Surry Power Station. A new backup meteorological system started providing data for the Station in August, 1981.

b.

(0 pen) (50-280, 281/79-27-01) The evacuation procedures for the construction area have been strengthened by a new plan, Project Operating Procedure - 2.9.4.

However, evidence of an evacuation drill was not available.

This item must remain open until the adequacy of the corrective actions have been demonstrated.

c.

(Closed) (50-280, 281/IEB-79-18) Warning lights have been installed in the charging pump room and in the emergency diesel generator rooms.

These lights are activated by the same switch as the plant emergency alarm.

EPIP-9 provides for dispatch of personnel to other high noise areas (auxiliary building, containment, etc.) to notify personnel that the alarm has been sounded.

d.

(Closed) (50-280, 281/80-04-01) A letter of agreement with the County of Isle of Wight dated September 17, 1981, is included in the Emergency Plan, Section 10, Appendix 10.1, Copies of Agreement Letters. Neither EPIP-1 nor the Emergency Plan currently identify the use of offsite medical consultants, other than the Medical College of Virginia (MCV)

for radiological purposes. The qualifications of the MCV doctors that are used for incidents involving radiation and contamination are adequate.

e.

(Closed) (50-280, 281/80-04-03) Emergency Preparedness retraining has been provided to the potential Emergency Directors.

Currently, Emergency Directors are provided training in all EPIPs.

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f.

(Closed) (50-280, 281/80-04-04) Audit reports S78-21, S79-26, 579-26A, S80-16, 581-19 and 581-19A were reviewed. The standard checklist has

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i been revised and improved. The corrective actions for items 4 and 5 of audit S79-26 have been made.

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g.

(Closed) (50-280, 281/81-28-01) A memo dated February 9, 1982, (Index 232) was written indicating that evacuation of the News Center would not be a problem during an actual emergency. The news center has an

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open line with the E0F which would warn the center if their sector

required evacuation.

h.

(Closed) (50-280, 281/81-28-02) The licensee has reviewed the problem concerning the smooth transition of the Emergency Director position by I

the shift supervisor to the plant manager.

Steps would be taken to l

minimize the noise and excessive management personnel in the Control

Room during the initial briefing. An Assistant Shift Supervisor will i

be assigned to facilitate the smooth transition, i

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(Closed)

(50-280, 281/81-28-03) The Fire Brigade implementing i

procedure, EPIP-19, has been revised to reflect appropriate actions to be taken prior to reporting at the fire location.

The Fire Marshall

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now reports.to the Control Room and the Fire Brigade goes directly to-the fire scene.

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(Closed).(50-280,281/81-28-04) Emergency Kits have not been provided for the OSC. The licensee has elected to provide necessary equipment

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i during the activation phase of the OSC.

This IFI is satisfied by j

another finding resulting from the appraisal which requires activation procedure to detail the equipment to make the OSC a functional i

facility.

k.

(0 pen)- (50-280, 281/81-28-05) The licensee is in the process of

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improving :tatus boards for Clarity and to reflect ' data trends. The

project should be completed before the next exercise.

1.

(Closed) (50-280 281/81-28-06) The licensee has agreed to provide data sheets in the TSC with proper units during the next exercise.

m.

(Closed) (50-280, 281/81-28-07) The licensee representative has agreed

to reduce inconsistencies between projected EOF data and-field team l

data in the excerise scenario.

'(Closed) (50-280, 281/81-28-08)' A i

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memo by the licensee dated February 9, 1982, (Index 239) was written indicating that less simulation will be attempted in future exercises.

o.

(Closed) (50-280, 281/81-28-09) The licensee designed the exercise scenario around limitations placed by offsite organizations.

In further exercises, the licensee will attempt to increase the data authenticity supplied to offsite monitors while accommodating offsite organization requirements.

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(Closed) 50-280,281/81-28-10) The onsite ambulance radio is presently operating on the same frequency as the Medical College of Virginia Hospital.

The quality of communications is poor until the distance between the two is decreased to less than 40 miles.

9.0 Persons Contacted 9.1 Licensee Personnel Vepco Corporate (

• R. H. Leasburg, Vice President of Nuclear Operations

• J. Martin, Jr., Director of Emergency Planning E. Topping, Emergency Planning Coordinator F. Curling, Director of Training Services

• J. Ogren, Supervisor, Operations and Maintenance Surry Site

• J. L. Wilson, Station Manager

• R. F. Saunders, Assistant Station Manager

• C. Winecoff, Fire and Safety Manager S. Sweaney, Security Supervisor

• L. Edmonds, Supervisor, Nuclear Training

• S. Sarver, Health Physic Supervisor 0. Costello, Staff Assistant (SNSOC)

0. Weyman, Security Manager W. O'Hara, Construction Site Safety Supervisor L. Miller, Chemistry Supervisor (Acting)

R. Mudd, Superintendent, Maintenance Services M. Griffin, Superintendent, Electrical Maintenance P. Krause, Supervisor, Air Monitoring J. Kent, Field Supervisor F. Martin, Supervisor, Meteorological Operations W. Ball, Jr., Chief, System Operations W. Kibler, Superintendent of Maintenance

• E. DeWandel, Superintendent of Records Management G. Kane, Superintendent of Operations T. Swindell, Chemistry Supervisor F. Rentz, Quality Control Supervisor R. Driscoll, Quality Assurance Manager D. Christian, Technical Services Superintendent R. Johnson, Shif t Supervisor L. Morris, Shift Supervisor S. Neidermeyer, Shift Supervisor J. Angler, Shift Supervisor

• F. Cox, Emergency Preparedness Coordinator In addition to the above, operations personnel, technicians and craf ts persons were contacted.

9.2 Other Oro_anizations

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M. Purser, E. M. Technician, Atlantic Nuclear Services D. Broga, RSO, Medical College of Virginia W. Andrews, Surry County Sheriff R. Robertson, Surry County [ispatcher C. Thompson, Surry County Energency Director J. Stallings, Chief, Smithfield Fire Department J. Treier, President, Isle of Wight Rescue Squad D. Barrett, Past President, Isle of Wight Rescue Squad 9.3 NRC

• G. R. Jenkins, Chief, Emerge 1cy Preparedness Section, RII

• D. B. Matthews, Section Leader, Emergency Preparedness Licensing Branch,

• D. J. Burke, Senior Resident Inspector

• M. Davis, Resident Inspector

• Attended management exit briefing on 3/26/82.

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