IR 05000280/1992005
| ML18153C961 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 03/18/1992 |
| From: | Kreh J, Rankin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18153C960 | List: |
| References | |
| 50-280-92-05, 50-280-92-5, 50-281-92-05, 50-281-92-5, NUDOCS 9204080130 | |
| Download: ML18153C961 (12) | |
Text
Report Nos. :
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, ATLANTA, GEORGIA 30323
~AR 1 B 7992,
50-280/92-05 and 50-281/92-05 Licensee:
Virginia Electric and Power Company Docket.Nos.:
50-280, 50-281 License Nos.:
DPR-32, DP2-.37 Facility Name:
Surry Power Station Inspection
- February 24-28,.1992 Insp~ct6r:~~-~~~*~*-~---'~~-*
_* -~~~~~
Approved Scope:
. _Kreh
.
~
.
~~~~~*
W. * H. Rankin, *Chief Emergency Preparedness Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards SUMMARY 0~-(&~9 Date Signed 7?-l~-q2 Date Signed This routine, unannounced inspection was conducted to assess-
- the operational readiness of the site emergency preparedness program, and included selective review of the following programmatic areas:.(1) Emergency Plan and c1ssociated implementing procedures; (2) facilities, equipment, instrumentation, and supplies; (3) organization and management control; (4) training; and (5) independent and internal reviews and audit Results:
In the areas inspected, no violations or deviations were identifie From an overall perspective, the emergenc preparedness program was faun~ to be maintained in an adequate state of operational readines Program strengths were. observed with r~spect to training, management control systems, and. independent audit Three areas of concern were identified during the inspection:
9204080130.6g85a~eo
~DR ADOCK PDR o Inadequate performance of the emergency ventilation system.at the
~ocal Emergency Operations Facility
.( Paragraph 3)
b Procedural specification of verbal (instead of written) authorization by the Station Emergency Manager to notify the NRC (Paragraph 2)
O Inadequacy of the alternate Operational Support Center for its intended purpose (Paragraph 3)
- REPORT DETAILS Persons Contacted Licensee Employees
- W. Benthall, Supervisor, Licensing
- R. Bilyeu, Licensing* Engineer R. Bol~s, System Engineer
.*J. Costello, Station Coordinator, Emergency Planning
- A. Friedman, Superintendent, *Nuclear Training
- D. Hart, Supervisor, Quality
. *M. Kansler, Station Manager
.
...
- R. Kulp~ Coordinator, Emergency Planning
- *R. Morgan, Staff Qu,ality Specialis..
A. Price, Assistant Station Manager, Nucl_ear Safety &
Licensing
- W. Renz, Staff Emergency Planner (Corporate)
J. Spence, Simulator Instructor
- S. Wood, Senior Instructor, Nuclear Training
.Other.licensee employees contactedduring.this inspection included operators, security force members;.
technicians, and administrative personne Nuclear Regulatory Commission (NRC).
- M. Branch, Senior Resident Ins~ector
- F~ Jape, Chief, Test Programs Section, Region II J. York, Resident Inspector
- Attended exit interview Emergency Plan and Implementing Procedures. (82701)
Pursuant to 10 CFR 50.47(b) (16), 10 CFR ~0.54(q), and Appendix _E to 10 CFR Part SO, this area was inspected*
to determine whether significant changes were made in the licensee's emergency preparedness program since January 1991 (the last inspection in this area), to assess the impact of any such changes*on the overall state of emergency preparedness at the facility, and to determine whether the licensee's actions -in response to actual emergencies were in accordance with ihe Emergency Plan and its implementing procedure The inspector reviewed. the licensee's system for making changes to the Emergency Pla~ and the Emergency Plan Implementing Procedures (EPIPs).
Through selective
.
review of applicable documents, the inspector. confirmed that licensee management approved revisions to the
Emergency Plan and EPIPs as require Copies of the Emergency Pl~n, EPIPs, and Emergency Telephone
Directory which were available for use at the.Technicai Support Center (TSC) and Local Emergency Operations Facility (LEOF)*were checked and found to be current
- revision One revision to the Emergency.Plan (Revision 33, dated February 21, 1991) was issued since the aforementioned January 1991 inspectio Following NRC review of
- Revision 33, the licensee was informed that three changes were determined to have decreased the effectiveness of the Pla The licensee committed to correct these deficiencies through issuance of Revision 34 no later than June 30, 199 At the time of the current. inspection, the licensee was plann"ing to issue Revision 34 much sooner than the above date, probably withip the next several week Revisions to the EPIPs since January 1991 were discussed with the Station Emergency Planning Coordinator. _Various minor changes were made to upgrade and/or clarify the EPIPs, including several modifications to the emergency action levels (EALs) in Revisions 26 and 27 of EPIP-1.0 Completion of the Emergency Response Data System (ERDS) computer link with the NRC Operations Center required the creation of a new Attachment 3 to EPIP-2.-02 (Revision 8, dated December 18, 1991) addressing ERDS operatio The inspector's review of these and other s.elected EPIP changes discl6sed none that decreased the effectiveness of the licensee's_ emergency preparedness progra The inspector reviewed records pertaining to the three emergency declarations which occurred between January l,_ 1991 and *the date of the current inspectio All were declared.at the*Notificat:ion of Unusual Event level, and are summarized as follows:
Time Declared/
Date Terminated Description of Event
4/26/91 OliS/0222 Unit 1 shutdown required by Technical Specifications as.a result of "A" chiller for Main*
Control Room inoperable and
- backup power supply (No. 3 Emergency Diesel Generator) for
"B" chiller unavailable
6/02/91 6/03/91 8/02/91 Time Declared/
Terminated 1431/
0506 1710/1840
Description of Event Initiation of mode change from hot shutdown to cold shutdown based on total uncontrolled, identified reactor coolant system*leakage exceeding 10 gpm Unit 2 reactor trip from 92%
power following a safety injection signal (later determined to have been spurious); declaration based on Shift Supervisor judgment.
regarding the existence of a station condition which warranted increased awareness by State and local officials The documentation of these three events indicated that notifications to State and local governments and the NRC were made in accordance with applicable requirement The inspector's assessment concluded
_that each of the listed*events was correctly classified based on the licensee's EAL The emergency preparedness staff routinely.reviewed the response to each emergency declaration in order to identify problems or inconsistencies which may have occurre with respect to the requirements of the EPIP Section 5.2.1.1 of the Emergency Plan listed 13 primary responsibilities of the Station*Emergency Manager (SEM), the first four of which were specifically noted as not being delegable to-other personne One of these nondelegable responsibilities was "Authorizing notifications to the NRC, State and*local agencies of the emergency status." *During observation of a
.
simulator exercise (discussed further in Paragraph 5),
the inspector noted that EPIP-2.02, "Notification of NRC, 11 tasked the Emergency Communicator (typically a non-licensed operator) with completing the four-page NRC Event Notification Worksheet and obtaining SEM approval thereo The SEM was not required to sign or initial the NRC notification message prior to its transmitta During the observed exercise, the SEM cursorily reviewed the proposed NRC message and indicated his verbal approval to the Emergency Communicato However, for the State and local government notification message (prepared under EPIP-2.01, "Notification of State and Local Governments"), written approval by the SEM was required i
- prior to transmitt Thus the approval processes for the two offsite notification messages were inconsisten Moreover, the approval process for' the NRC notification message was not commensurate.with th level of importance which the Emergency Plan attached
- to the *sEM' s nondelegable re*sponsibility for authorizing notifications to the NR The licensee committed to revising the applicable procedure(s) so as to require written SEM.approval of the NRC notification message prior to.transmitta This matter will be
£allowed for corrective acti6n as Item No. 1685 in the licensee's Commitment Tracking System (CTS).
The inspector verified that current letters of agreement existed between the licensee and the*
20 offsite support organizations listed in Appendix 10.1 to the Emergency Pla The licensee was in the process of renegotiating all the *letters of agreement (required once every.two years by Section 5.3.3 of the Plan).
Also verified.through documental review was the licensee's conduct of the required annual review of EALs with governmental authorities,.conducted on May 9, 199 No violations or deviations were identifie.
Emergency Facilities, Equipment, Instrumentation, and Supplies (82701)
Pursuant to 10 CFR 50.47(b) (8) and (9), 10 CFR 50.54(q), and Section IV.E of Appendix E to 10 CFR Part*50, this area.was inspected to determine whether the licerise.e' s emergency response facilities (ERFs) an associate.a equipment, instrumentation, and supplies
were maintained in a state of operational readiness, and to assess the.impact of any changes iri this area upon the emergency preparedness progra The inspector toured the licensee's onsite ERFs, which included the Control Room, Technical Support Center (-TSC), primary and alternate locations for the Operational Support Center (OSC), and Local Emergency
. Operations Facility (LEOF).
Selective examination of ERF equipment and.supplies indicated that an adequate state of readiness was being maintained, with one significant exceptio At the inspector's request, the emergency ventilation system for the LEOF was actuated on February 2 The system was designed to develop positive pressure within the LEOF to restrict the infiltration of airborne radioactive material in the event of a severe reactor acciden A permanently installed instrument (manometer) in the LEOF provided*a
....
differential pressure measurement in inches of water gauge.* The acceptance criterion sp~cified in the licensee's surveillance test for the-emergency
. ventilation system was 0.0-5 inch; the manometer reading after 20 minutes of operation was 0.03-0.04 inc Subsequent review of the results of the last-system
- surveillance in December 1990 (performed under 18-month periodic test PT-32.14, "LEOF ~ressurization Test")
disclosed that the system produced a positive pressure of 0.14 inc The licensee immediately undertook an investigation to identify the reason(s) for such a serious degradation in the performance of the emergency ventilation system over the past 14 month Prior to the end of the inspection, problems had been identified with-the seal on _the outside door in the LEOF penthouse mechanical room and with the continuity of two of the-three quick:..acting fuses associated with the HEPA *
filter train moto On March 2, the inspector was telepho~ically informed by a licensee representative that-system operability had been restored on the afternoon of February 28 following the completion of interim repairs, and that the system had generated a positive pressure of 0.18 inc During the exit interview, licensee management agreed to evaluate the reasons for.the emergency ventilation system performance failure and to take appropriate corrective actions to preclude recurrenc The licensee will track the completion of this commitment under CTS Item No. 1684, and future NRC inspections will review the adequacy of the licensee's corrective actions.'
During the emergency response exercise in August 1991, scenario developments required the OSC to be evacuated and reestablished at the Unit 1 Emergency Switchgear Room, which was the designated alternate location for the OS NRC observers found the alternate osc facility to be "poor."
A detailed basis for this conclusion was provided in Paragraph 8.d of NRC Inspection Report Nos. 50-280/91-25 and 50-281/91-2 Review of this facility during the current inspection resulted in the same conclusio The inspector was informed that development of a different location for the alternate OSC was being tracked as Licensing Issue No. 5071 _This matter will be reviewed during future inspection *
'The inspector selectively reviewed completed
_documentation for each of the following facility/equipment surveillance procedures for the period January 1, 1991 through the date of the insp!=ction:
..
0
-0
0
0
_6 PT-55.3, Emergency Plan Radiation Instruments and Emergency Kits Inspection and Checks (performed monthly)
- sTP-55.3, Emergency Response Facility Inventory (quarterly)
0-LSP-EW-001 (formerly STP-55.5), Early Warning System ~olling Function Test (semimonthly)*
0-LSP-EW-002 (formally STP-55.6), Early Warning System Siren Activation Monitoring (quarterly)
EWS-E/Ml, Emergency Warning System Maintenance (quarterly since September 1991; performed *
monthly prior to that date)
STP-55.4, Emergency Communications Test (superseded by the next __ three listed procedures on April 18, 1991; performed monthly prior to that date)
0-LSP-C0-001 (formerly part of STP-55.4), Monthly Emergency Communications Test 0-LSP-C0-002 (formerly part of STP-55.4),
Quarterly Emergency Communicati_ons Test -
o 0-LSP-C0-003 (formerly part of STP-55.4),
Quarterly Health Physics Emergency Radio
. Commun_ications Test O
PT-32.13, LEOF HEPA Filter (18 months)
O PT-32.14, LEOF Pressurization Test (18 months)
o, PT-32.11, TSC Leak Test (18 months)
o PT-32.12, TSC Emergency Ventilation System Laboratory Analysis (18 months)
o PT-32.15; TSC Pressure Test (18 months)
The listed surveillance procedures had been performed*
at the required frequencies, and the documentation indicated that identified problems were corrected expeditiousl The inspector witnessed the performance_of O-LSP-EW-001 on-February 2 The test was conducted at the LEOF using a computer-based feedback system, and the *results
- indicated that all 61 sirens comprising the Early Warning Notification System met the acceptance criteri *
Based upon ERF walk-downs, review of changes to the EPIPs,,inspection of. completed surveillance procedures, and statements by licensee representatives, the inspector concluded that no degradation of ERF capabilities had occurred since January 1991, except as noted above with respect to the LEOF ventilatio syste *No violations or deviations.were identifie.
Organization and Management Control (82701).
Puisuant to 10 CFR 50.47(b) (1) and (16) and Section IV.A of-Appendix E to 10 CFR Part 50, this area was inspected to determine the effects of any changes in the licensee's emergency organization *and/or management control systems on the emergency preparedness program, and to verify that any such changes were properly factored into the Emergency Plan and EPIP The organization and management of the emergency*
preparedness program were reviewed and discussed with licensee representative There were no significant organizational or personnel changes iri either the plant or corporate emergency planning groups since January 199 The individual serving as Station Emergency Planning Coordinator had been in that position for 5.5 years and reported directly to the Assistant Station Manager, Nuclear. Safety and Licensin These
- . factors helped to provide a measure of* assurance that emergency pr~paredness at the Surry Power Station would receive appropriate management attention and would have good "visibility" to station personnel~
The inspector r*eviewed the licensee's management strategy for ensuring compliance with the Emergency P-lan requirements* addressing the planning standard of 10 CFR 50.47(b) (2), which specifies that "timely augmentation*of response capabilities*is.available."
The applicable Emergency Plan requirements were contained in Section 5.2 and Tables 5.1 and The licensee performed STP-56, "Emergency Plan Augmentation Callout _Drill, II on a quarterly basis, al though this
_off-hour test involved only notification of emergency responders and determination of their availability, and did not include actual reporting to the station.* The results of STP-56 tests since January 1991 generaliy indicated that.the licensee's onsite emergency organization could be augmented in accordance with the referenced Emergency Plan commitments.* Only once every six years did the licensee plan to conduct an actual, real-time callout of the emergency organization to test off~hour staff augmentation capabilit (This
.
commitment wa*s verbal* at the time of the inspection but was to be incorporated in Revision 34 as part of the corrective action for NRC-identified deficiencies in Revision 33.)
- The inspector determined.that the following NRC
- Information Notices (INs) applicable to* emergency planning were received by the licensee and distributed to cognizant personnel, and that corrective actions, as appropriate, were completed or scheciuled:.
o IN No. 91~33:
Reactor Safety Information for States During Exercises and Emergencies
Issuance of a Revision to the EPA Manual of Protective Action Guides and Protective Actions for Nuclear Incidents The licensee's management control system.for ensuring the timely completion of required tests and surveillances was reviewed and found to be very
.
effectiv The inspector also reviewed and discussed with licensee representatives the Emergency Preparedness Incomplete Items Listing, used to track open items for the licensee's two nuclear stations as*
well as for the corporate emergency preparedness progra This listing was appropriately detailed, an indicated for each item the responsible organization and individual al.ong with a due date for completio The licensee was effectively using.this tracking system as a management tool for ensuring the completion of corrective action for identified problems in emergency prepc:1.rednes No violations or deviations were identifie.
Training (82701)
Pursuant to 10 CFR 50.47(b) (2) and (15) arid Sectioh IV~E of Appendix E to 10 CFR Part 50, this area was inspected to determine whether the licensee's key emergency response personnel were properly trained and understood ~heir emergency responsibilitie The inspector reviewed the Nuclear Power Station Emergency Preparedness Training Program Guide, which is referenced in Section 8.3 of the Emergency Plan as the
governing document for such trainin In an effort to gauge th~ effectiveness of this training program,. the inspector observed a Control Roomsimulator*exercise, which was part o,:E.the Licensed Operator Requalification Progra This.90-minute exercise involved.a loss-of-coolant accident (LOCA) *outside containment which ultimately resulted in the (simulated)*declaration of a Site Area Emergency.* Exercise participants were*from the IIA" shif The inspector observed from the simulator booth at. the outset and later. in close.
proximity to the player Attention was focused in particular* on the Shift Supervisor (serving as interim
.SEM) and the two Emergency Communicators in order to ascertain personnel understanding of eme*rgency clas~ification, notifications to offsite authorities, protective actions, site evacuation, nondelegable responsibilities of the SEM, and acquisition of offsite support service Except for the issue discussed earlier regarding the approval process for the NRC notification message (see Paragraph 2)~ the inspector had no concerns with respect to the observed exercise.
. The participants demonstrated thorough understanding of the overall concepts of the emergency response program as well as the specifics of the applicable EPIPs. *
No violations or deviations were identified~ Independent and Internal Reviews/Audits (82701)
.
.
Pursuant to 10 CFR 50.54(t) and Sections 8.2.1 and of the Emergency Plan, this area was inspected to determine whether the licensee had performed an
.independent audit of the emergency preparedness program, and whether the emergency planning staff had conducted a review of the Plan and the EPIP *
The most recent required independent audit of the program was conducted by the licensee's Quality Assurance* (QA) group during the period June 25 -
August 5, 199 This audit. was performed by a team of eight persons, and reviewed the emergency response capabili.ty for both of the licensee's nuclear stations
- and the corporate off ic This was unusually *
comprehensive and detailed for an audit of this typ The results were.documented in Audit Report No. 91-10,
- dated September 3, 199 The audit produced five
"findings" (three applicable to Surry) and two*
"observations II (both *applicable to Surry).
In a letter to the Virginia Department of Emergency Services dated October 9, 1991, the liceniee described the offsite interface problems identified by the audit and the*
proposed corrective action The inspector reviewed J
-the audit and subsequent corrective actions with a QA specialist, who offered documentation indicating.that all of the Surry open items from the-audit *except one of* the observations had been closed.* The inspector also determined that all findings from the 1990 QA audit_ (Report No. 90-01) had been close *
The annual internal review of the Plan and EPIPs covered the period October 1990 - October 1991 and was documented in a memorandum dated November,19, 1991 from the Station Emergency Planning Coordinator-to the Station Nuclear Safety and Operating Committe The review adequately ?tSSessed program accomplishments and needed correc,tive actions*.
No violations or deviations were identifie.
Exit Interview The inspection scope and results were summarized o February 28, 1992 with those persons indicated in Paragraph The inspector described the areas inspected and discussed iri detail the inspection result Three commitments for corrective action offered during the course of the inspection by licensee representatives were confirmed by the Station Manager; these are discussed in Paragraphs 2 and Dissenting comments were not received from the license Although proprietary information was reviewed during this inspection, none is contained in this report.