IR 05000334/1992011

Emergency Preparedness Insp Repts 50-334/92-11 & 50-412/92-10 on 920504-08.Major Areas Inspected:Emergency Preparedness Program Changes,Emergency Facilities,Equipment & Supplies & Organization & Mgt Control

ML20210D933
Person / Time
Site:	Beaver Valley
Issue date:	06/04/1992
From:	Eckert L, Mccabe E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20210D930	List: IR 05000334/1992011 ML20210D924
References
50-334-92-11, 50-412-92-10, NUDOCS 9206180195
Download: ML20210D933 (9)

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U. S. Nuclear Regulatory Commission Region I i Docket / Report: 50-334/92-11 and 50-412/9210 Licenses: NPF 66 and NPF 73

Licensee: Duquesne Light Company

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Post Office Box 4 Shippingport, Pennsylvania 15077  :

Facility Name: Beaver Valley Power Sta! Ion (BVPS), Units 1 and 2 Inspection: May 4-8,1992  ;

Inspection At: Shippingport, Pennsylvania

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Inspectors: A un h<./tf - M/f/92 i. Eck'ert, Emergency Preparedness Section date

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J. Lusher, Emergency Preparedness Section Approved: @ -

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E. McCabe, Chief, Emergency Preparedness Section date Division of Radiation Safety and Safeguards .

Areas Inspected BVPS emergency preparedness (EP) program changes, emergency facilities, equipment and i supplies, organization-and management control, emergency response organization (ERO)

training, staff knowledge and performance, and independent reviews / audit Results -

The EP program was appropriately administered and maintained. ' Questions were raise 41 about

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the adequacy of Emetgency Response Facility (ERF) ventilation system testing and the means *

of ensuring that all Emergency Response Organization (ERO) members are properly qualifie Additionally, questions were raised about the withdrawal of off-site fire d:partments from on-site -

fire protection training and the potential long-term consequences of the lack of such training, y A management meeting with the licensee was planned to discuss associated corrective actions l

. and/or compensatory measures.

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.9206180195-920609 yDR ADOCK 05000334 PDR

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DETAILS

. Persons Contacted The following individuals were contacted during the inspectio ,

C. Bibber, Communiustions Specialist S. Blower, EP Specialist

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R. Brosi, Manager, Emergency Preparedness R. Chiodo, Director, Beaver County Emergency Management Agency M. Di Pietro, Security and Procurement' Training Coordinator

- G. Farr, Health Physics Specialist

H. Ilaney, Director, Technical Training M. Johnston, Manager, Security

F. Lipchick, Senior Licensing Supervisor W. Mahan, Emergency Preparedness Specialist J. Marietta, Nuclear Technical Instructor G. McKec, Emergency Preparedness Specialist L.- Miller, Fire Protection Engineer-R. Moser, Health Physics Associate T. Noonan, General Manager, Nuclear Operations Unit T. Ordich, Chief, Shippingport Fire Department

M. Pavlick, Director, Quality Services J. Sanko, EP Specialist

J. Sieber, Vice President - Nuclear Group

• D. Spocrry, General Manager, Nuclear Operations Services G. Svaranowie, Senior Fire Protection Engineer

- H. Szklinski, Health Physics Specialist

N. Tonet, Manager, Nuclear Safety

S. Vicinie, Senior QA Spechlist M. Welsh, Senior Planner, Integrated Planning Systems The inspectors also interviewed and/or observed the actions of other licensee personnel, and of Beaver County and Shippingport Fire Department personne *

Attended the exit meetin .0 Operational Status of the Einergency Preparedness (EP) Prograin e Changes to the EP Program The inspectors reviewed changes made to the emergency plan and its implementing procedures (EPIPs) since the last EP inspection to determine if they adversely affected EP and whether the changes had been properly reviewed, approved, and distributed. NRC review concluded that

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these changes have not decreased program effectiveness. A notable enhancement was the recent revision of the entire series of dose assessment procedures to increase readability and case of ,

use, j New Evacuation Time Estimates (ETEs) based on the 1990 census were completed. The licensee was currently assisting in the evaluation of any necessary changes to the State Emergency Plan (e.g. re-evaluating siren coverage and upgrading evacuation bus routing).

Letters of Agreement were reviewed and found curren The licensee was the lead pressurized water reactor (PWR) for the Nuclear Management and Resources Council (NUMARC) emergency action level (EAL) guidance and contributed to the l development of that document. In particular, the licensee was involved in the development of shut down EALs, The licensee was evaluating a new revision to Environmental Protection Agency document EPA-

$20. A decision on how to best incorporate the cyability to evaluate cumulative effective dose ,

equivalent (CEDE) to off-site emergency workers was in progress. The licensee stated that this '

will require modifications to the current dose assessment mode The licensee was an active participant in Westinghouse Owners Group development of new guidance cone:rning severe accident managemen This program area was assessed as being effectively implemente .2 Faellities The inspectors toured the Control Room (CR), Operations Support Center (OSC), Radiological Operations Center (ROC), Technical Support Center (TSC), and Emergency Operations Facility (EOF) to assess whether these facilities, equipment, supplies, and procedures were adequately maintained. The TSC and EOF were combined into a single dedicated facility designated as the Emergency Response Facility (ERF).

Facilities were well maintained and ready with the exception of some out-of-date engineering drawings in the TSC. That was also noted in the licensee's annual Quality Assurance (QA) audit report for 1991. The licensee was in the process of changing the document control process for TSC engineering documents. The new control process will be evaluated in a subsequent inspection. The inspector sampled communications equipment, computer terminals, and survey equipment for operability and calibration. All sampled equipment was functional and calibrate Several downwind survey kits were inspected and found fully stocked; equipment within these kits was operational and calibrate _ _ _. ,_____ _

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The emergency response facility (ERF) ventilation system was functionally tested on schedule by the licensee per Operating Surveillance Test 58.8. This procedure directed a check for damper and fan line-ups upon system actuation. The charcoal filter was tested annually per

"ERF Building Emergency Carbon Adsorber [lVS FL-43] Sample Removal" to ensure the carbon adsorber is operating within the limits of design specifications. Ilowever, there was no testing of the IIEPA filtration system nor was there a provision for verification of facility positive pressure.10 CFR 50.47(b)(8) requires that the Emergency Response Plan must assure that adequate emergency response facilities are provided and maintained. Regulatory Guide 1.52, ' Design, Testing, And hiaintenance Criteria For Post Accident Enginected Safety Feature Atmosphere Cleanup System Air Filtration And Adsorption Units Of Light-Water-Cooled Nuclear Power Plants," provides guidance on how to meet related radiation protection requirements of General Design Criteria (GDC) 19 of 10 CFR Part 50. Applicable guidance includes NUREG-0737, " Clarification of Thil Action Plan Requirements," item II.B.2 and NUREG-0696, " Functional Criteria for Emergency Response Facilities," Item 2.6. In this case, the licensce's comtnitment to assure the ERP ventilation provided a positive pressure was identified. The inspectors did not, however, determine whether this commitment had been made into a regulatory requirement, whether specific testing requirements applied, or whether llEPA filter tests had been made a requirement. The adequacy of related testing of the ERF ventilation system is unresolved pending further review (URI 50-344/92-11-01 and 30-412/92-10-01).

Review of the licensee's facility surveillance reports and discrepancy corrective action reports for 1991 found them an effective means of ins ring readiness. Discrepancies were resolved promptly. The licensee was in the process of in iementing a tracking system to ensure that items open for a long time due to ordering, ma'nufacturing, or work delays were properly resolve This program area was assessed as goo .3 Organization nnd Management Control The inspectors reviewed the ERO and management control of the EP program to assess conformance with the Emergency Plan. Separate discussions were held with the General hianager, Nuclear Operations Services and the General hianager, Nuclear Operations Uni These individuals were familiar with their EP responsibilities. either through program support or maintaining qualification in the ERO. The hianager, EP continued to report to the General hianager, Nuclear Operations Services. The General hianager, Nuclear Operations Services reported to the Vice President, Nuclear Grou Since the last inspection, a key EP staffing change was noted. The Manager, EP was new to the position. This individual was a senior reactor operator (SRO) for about eight years, maintained ERO certification, and served as Technical Liaison prior to accepting this positio Additionally, this individual led the licensee's task force to ensure EAL conformance to

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5 NUREG-0654 and remove EAL ambiguities to assure consistent classification. This individual was instrumental to the development of NUM ARC pressurized water reactor EAL guidance, and had been extensively involved in EAL development and improvement since 198 The inspectors reviewed 50 ERO members' training records to ensure that they met the required training qualifications to be placed on the ERO call-out list. These records indicated that two persons had not completed the associated training. Also, one individual on the call-out list had been transferred and was no longer a member of the ERO.10 CFR 50.47(b)(15) requires that the emergency response plan must assure that radiological emergency response training is -

provided to those who may be called on to assist in an emergency. Prior to the end of the g inspection, the licensee initiated a complete review of the call-out list and removed the above noted individuals from the call-out list. The adequacy of ERO qualification and of call-out hst accuracy is unresolved pending determination of the qualifications, or lack thereof, of individuals on the call out list. (URI 50-344/92-11-02 and 50-412/92-10-02). - - -

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The ERO was fully staffed. The licensee was at least four deep in all positions except for the Environmental Assessment and Dose Projection Coordinator. That position was three dee The licensee stated the intention of qualifying another individual for this positio The EP staff backgrounds were diverse. Staffing was ample, with five individuals assigned primarily to on site EP activities. One of these individuals was previously SRO qualified and was assigned primarily to development of operations data for drill / exercise scenarios. Four individuals were assigned specifically to off site liaison duties. Each county within the 10 mile Emergency Planning Zone (EPZ) was assigned a specialist; this was assessed as a program

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strengt EP training was the responsibility of a dedicated individual from the Training Department. Two additional individuals within the EP Department weic responsible for off-site trainin ERO qualification control was assessed as unresolved. Otherwise, EP management control was assessed as effectiv .4 Knowledge and Performance of Duties (Training) '

The inspectors reviewed the 1992 EP training program, which established the EP training schedule and course requirements for the ERO during the yea The inspectors reviewed several lesson plans and found them current and complete. Les.,9 plans were reviewed prior to presentation and were updated as required. The 1991 QA auu:

noted, as an area for improvem:nt, that lesson plans should be reviewed annually and that suct review should be documented. The Emergency Planning Department was in the process of implementing this improvemen _

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'h'wo shift Administrative assistants were interviewed and were found to be knowledgeable of their position requirements and EP procedure Off site training was conducted by the EP Department. For the period from January 1,1992 to May.1,1992, 378 personnel were trained. Annually, 1000-2000 individuals were being trained in Emergency Operations Center (EOC) operations, route alesting, radiation worker training, radiation officer training, equipment, decontamination, and traffle control, f

This program area was assessed as being effectively implemente .5 Independent Reviews / Audits The independent review required at least every 12 months by 10 CFR 50.54(t) included an evaluation of the adequacy of the off site interface. To determine if these requirements were

. met, the inspector reviewed the licensce's Technical Speci0 cations and Quality Assurance Procedures (QAPs), interviewed the QA auditors, reviewed the Audit Plan and audit checklists, and reviewed the QA reports and QA surveillance report Technical Specification (TS) 6.5.2.8 required an annual assessment of the Emergency Plan and its implementing procedure Section 8.3.c. of the Emergency Plan, " Maintaining Preparedness," required an annual review which met 10 CFR 50.54(t) and TS requirement Off site audit results were made available to the Statt, and County governments as require EALs were reviewed by the licensee with the surrounding Counties and the Commonwealth of Pennsylvania, State of West Virginia, and the State of Ohio as require The ir.spectors reviewed audits and surveillances conducted by the Quality Services (QS) Unit and concluded that they conformed to QA procedures. The inspectors reviewed audit plans and checklists and found them goo Audit reports were sent to the EP Manager, licensee management, and the county emergency management office The inspectors noted the licensee's intent to cooperate with the other Pennsylvania licensees to initiate a technical expert exchange program in order to enhance EP audits / reviews. This was being considered to move the EP audit to a more performance-based evaluatio .

This program area was assessed as goo .6 Cominitment Tracking The inspectors reviewed the system by which corrective actions were tracked. Items requiring corrective actions were maintained on the site commitment tracking system (CTS). This system was maintained by Licensin _-.

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The Emergency Preparedness Planning (EPP) Department conducted root cause analyses for QA and NRC areas of concern / improvement when appropriate. Generally, CTS open items received management attention up to the General hianager level. Reports were regularly sent to the General hianagers and action addressecs. Duc dates were negotiated between responsible partie Corrective action follow up was reviewed for NRC Inspection Report Nos. 50-334/91-03 and 50-412/91 04 and audits llV C-91-03 and 11V-C 92-01. The inspectors determined that a sociated matters sere being properly reviewed and had received appropriate corrective actio This program area was assessed as being effectively implemente .7 Drill and Excrehe Program Section 8.1.4.f of the Emergency Plan, EPP/IP 1.1, " Notifications," and IIVPS Operating hianual 40 established guidance and responsibilities for communications tests. The inspectors reviewed documentation of the conduct and results of these tests and concluded that these activities conformed to the above noted document Section 8.1.3 of the Emergency Plan designated the hianager, EP as cogninmt for the development, coordination, and conduct of drills and exercises (except for emergency squad related drills which were the responsibility of the Operations Supervisor). The Emergency Plan required that IIVPS conduct the annual exercise and the following drills: medical emergency (annual), radiation emergency (annual), health physics (semi annual), and effluent monitoring (annual). EPP maintained a rolling six year objective matrix to ensure that all sixteen planning standards of NUREG-0654 were being teste The inspectors reviewed the drill / exercise scenario development process for the drills and exercises conducted in 1991 and found it effective. Previous concerns and new procedures received emphasis through inclusion in drill / exercise objectives. Drills and exercises conducted met Emergency Plan requirements for 1991. All drills / exercises were approved by senior management. Drill / exercise records were reviewed and found complete. Drill reports were timely and widely distributed to management. Drills / exercises provided varied challenges to the ERO. Four full station drills / exercises were conducted in 199 This program area was assessed as being effectively implemente .8 Pubtle Infonnation and Off site Interface The inspectors interviewed public relations personnel to determine how information was disseminated to the general public. The licensee distributed calendars annually to the States and to the Counties in the ten-mile emergency planning zone (EPZ). Additionally, the licensee i

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aced information in the local telephone directories and newspaper The licensee also uistributed transient brochures to centers of transient populations and requested a signed receipt for the brochure The licensee provided a media training session on basic plant systems and relative risk. A two-day training session was conducted on October 9 and 10,1991 for State and local of0cial EALs, protective action recommendations (PARS), industry initiatives and other topics were discussed. The EPP Department assisted in the local law enforcement training session This program area was assessed as being effectively implemente .9 l' ire Protection / Security /EP Interrnee The inspectors interviewed two personnel from the site Orc protection group and found that there was a good interface with the EP department. Fire protection engineers assived in drill scenario developmen The inspectors interviewed two security personnel to check the interface with the EPP Department and found it extensive. Security had a member on the scenario development committe At the time of the inspection, all Ove Plan "A" (primary response) Gre departments had ceased to participate in llVPS hiutual Aid Fire Plan, in a h1 arch 28,1992 letter to the hianager, EP, the Hookstown, Industry, hiidland, and Racoon Volunteer Fire Departments had stated that they had ceased to participate in the hiutual Aid Fire Plan, in this letter, these four companies stated their intention to continue participation in activities associated with the Emergency Preparedness Plan (EPP). None of these departments has pulled out of the Beaver County hiutual Aid Agreement. The result was that these departments had dropped out of specine training for on-site fire response but not out of the actual response rol The inspectors interviewed representatives of the Shippingport Fire Department to discuss their relationship with the licensee. The Chief, Shippingport Volunteer Fire Department stated that they would no longer participate in the hiutual Aid Fire Plan. Additionally, it was stated that the Shippingport Volunteer Fire Department personnel would continue to participate in activities associated with the EPP. They also stated that they will continue to attend EP training classes, but not site fire protection training classes. The Chief, Shippingport Volunteer Fire Department indicated that they would respond to a county request for assistanc The inspectors noted that associated NRC requirements and licensee commitments to the NRC were met for the near term. Section 8.1.2.d. of the EPP specified that representatives of local Gre companies participating in the hiutual Aid Fire Program were to be invited to attend a training program annually. Section 8.1.4.c. of the EPP specined that at least one drill in a calendar year involve the participation of a local off site fire department. Over time, the off-site nre departments' ability to effectively contribute to on site Ore fighting activities might be

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adversely impacted by a lack of periodic fire departmuit training. This matter will be evaluated further (IFI 50-334/92-1103 and 50-412/9210 03). A management meeting with the licensee to discuss associated corrective actions and/or compensatory measures was planne .10 Actual Events Two events required implementation of the Emergency Plan since the last inspectio At 0225,1/18/91, the licensee declared an Unusual Event (UE) due to a reactor coolant system pressure boundary leak for Unit 1. The event was terminated at 0600 on 1/19/91 after the plant reached cold shutdow A second UE was declared at Unit 2 at 1406,5/1/92, based on an inadvertent safety injection, The reactor was in Mode 5 at the time. This event consisted of a loss of a vital bus, which caused RCS*P457 (protection channel 1) to trip. RCS*P455 had already been tripped for maintenance. That satisned the two of three logic for safety injection (SI) with pressure below 1845 psig. The event was terminated at 1448 after the SI signal was reset, normal charging was restored, letdown was restored through the residual heat removal system flowpath, both diesel-generators were secured, and the lost vital bus was restore The inspectors reviewed logs of events since the last NRC review of EP program activitie Response to these events was determined to be appropriate, initial and follow up notincations were complete and timely. These events did not require augmentation of the ER Classification of and response to these events was assessed as effectiv .0 Licensee Action on Previously identifled items There were no open item .0 Exit Meeting The inspectors met with the licensee personnel denoted M Section i at the conclusion of the inspection to discuss the inspection scope and findings. The i:~ensee acknowledged the findings and stated their intention to evaluate them and institute corrective cetions as appropriate.