IR 05000334/1993020
| ML20059C255 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 10/21/1993 |
| From: | Eckert L, Keimig R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20059C229 | List: |
| References | |
| 50-334-93-20, 50-412-93-20, NUDOCS 9311010068 | |
| Download: ML20059C255 (19) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos.
50-334/93-20 and 50-412/93-20 Docket Nos.
50-334, 50-412 License Nos.
Duquesne Light Company Post Office Box 4 Shippingport, Pennsylvania 15077 Facility Name:
Beaver Valley Power Station (BVPS), Units 1 and 2 Inspection Period:
September 7-10,1993
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Inspectors:
ab._2c/#
/M58.5 L. Ecke8, Radiation Specialist Date Facilities Radiation Protection Section D. Silk, Senior Emergency Preparedness Specialist C. Caroll, Sonalysts Inc. (NRC Contractor)
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Approved By:
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,AC Keimig, Chief Date
Emergency Prepar ness Section
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Areas Inspected: BVPS emergency preparedness (EP), including: pmgram changes; emergency facilities; equipment, instmmentation, and supplies; organization and management control; emergency response organization (ERO) training; staff knowledge and performance
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of duties; independent reviews / audits; and public information and off-site interfaces.
Results: The EP program was, in general, thoroughly implemented and administered.
Emergency response facilities and designated equipment were operationally ready.
Management involvement in the EP program was evident. ERO staffing levels were
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maintained with individuals qualified in the established EP training program. Improvements were noted concerning the provision of performance-based EP training to licensed l
individuals. The commitment to the development of new Emergency Action Level (EAL)
guidance was also maintained. Independent program audits were acceptable and met regulatory requirements. However, concerns were raised over the adequacy of maintenance of the Emergency Preparedness Plan and the adequacy of corrective actions taken to resolve
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EP related discrepancies. No violations of regulatory requirements were identified.
9311010068 931021 PDR ADOCK 05000334 G
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DETAILS
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1.0 Persons Contacted L1 Licensee Personnel R. Balcerek, Manager, Management Services C. Bibber, Communications Specialist
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R. Brosi, Manager, Emergency Preparedness Planning (EPP)
J. Caner, Director Columbiana County Emergency Management Agency (EMA)
E. Chatfield, General Manager, NSU
R. Chiodo, Director, Beaver County EMA R. Drew, Senior Nuclear Technical Instructor L. Freeland, Operation Supervisor B. Haney, Director, Technical Training F. Lipchick, Senior Licensing Supervisor
J. Marietta, Nuclear Technical Instmetor
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W. Mahan, Emergency Preparedness Specialist J. Matsko, Manager, Outage Management G. McKee, Emergency Preparedness Specialist A. Mizia, Supervisor, Quality Services Unit
R. Moser, Health Physics Associate J. Sasala, Director, Nuclear Communications D. Spoerry, Division Vice President, Nuclear Operations
H. Szklinski, Health Physics Specialist
G. Thomas, Division Vice President, Nuclear Services
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N. Tonet, Manager, Nuclear Safety
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S. Vicinie, Senior Quality Assurance Specialist i
L2 NRC Personngj i
L. Rossbach, Senior Resident Inspector
P. Sena, Resident Inspector L3 Accompaniments R. Barkanic, Nuclear Engineer, Pennsylvania Depadment of Environmental Resources T. Reeves, Radiation Analyst, Ohio Emergency Management Agency
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2.0 Operational Status of the Emergency Preparedness (EP) Program 2.1 Changes to the EP Program I
2.1.1 Emergency Plan and Emergency Plan Implementing Procedure (EPIP) Changes The inspectors reviewed changes made to the Emergency Plan and its implementing
procedures since the last program inspection, including a sampling assessment of the impact of those changes upon Emergency Plan effectiveness. No decrease in effectiveness was noted.
2.1.2 Protective Action Recommendations (PARS)
The licensee planned to incorporate NRC's Response Technical Manual (RTM) 1992 PAR philosophy in the next revision to the PAR procedure.
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2.1.3 Letters of Acreement Letters of Agreement were reviewed and found current at the time of the inspection. One listing in the index for the letters of agreement (the Coast Guard) was no longer current.
The responsibilities concerning the Coast Guard were delegated to the Army Corps of Engineers. Thus, the letter of agreement with the Coast Guard needs to be removed and/or modified to reflect the new support arrangement.
2dd Public Information Material To detennine if 10 CFR 50.47(b)(7) and 10 CFR 50, Appendix E, Section IV.D.,
" Notification Procedures," had been met and whether NUREG-0654 guidance had been implemented, the inspectors conducted interviews, reviewed Emergency Plan Section 8.5,
" Organization Preparedness," reviewed public information material, and conducted interviews with the Director of Nuclear Communications and EPP personnel.
2.1.4.1 Regulations and Guidance Concerning Public Information Material 10 CFR 50.47 specifies that information must be made available to the public on a periodic basis on how they will be notified and what their initial actions should be in an emergency (e.g., listening to a local broadcast station and remaining indoors), the principal points of contact with the news media for dissemination of information during an emergency (including the physic;d location or locations) are established in advance, and procedures for coordinated dissemination of information to the public are established.
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NUREG-0654 provides the following guidance for implementing planning standard 7:
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Each organization shall provide a coordinated periodic (at least annually)
dissemination of information to the public regarding how they will be notified and what their actions should be in an emergency. This information shall include, but not necessarily be limited to:
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educational information on radiation; b.
contact for additional information;
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protective measures, e.g., evacuation routes and relocation centers, sheltering, respiratory protection, radioprotective dmgs; and d.
special needs of the handicapped.
2.1.4.2 Emercency Plan Public Information Material Commitments j
Section 8.5 of the Emergency Plan, " Corporate Communications," directed that the following information was to be disseminated to residents and transients within the Emergency Planning Zone (EPZ).
e Basic information on radiation Public notification system e
o Public response to warning signals e
Evacuation routes and procedums Sheltering procedures e
Section 8.5 also directed that the following methods would be used to transmit emergency planning information to residents and transients within the plume exposure pathway emergency planning zone, An ad in the local newspapers, summarizing the actions to be taken by residents will e
be published annually, e
Printed instmetions and evacuation maps will be distributed to EPZ residents.
Printed instmetions will be included in the local telephone directory, where
regulations permit.
Printed instructions and evacuation maps will be distributed to motels, hotels, and o
recreation areas.
2.1.4.3 Licensee Pmetices Concemine Public Information Material The inspectors reviewed the public information material distributed to EPZ residents and found that it provided information sufficient to meet the guidance contained in NUREG-0654.
Information intended for transients did not contain radiation information, evacuation or sheltering procedures. The information that was disseminated to transients informed them
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about the Emergency Broadcasting System (EBS) and where to tune in the event of an emergency. An EBS message would not contain all of the information delineated by the licensee's Emergency Plan. Licensee transient public information material will be reviewed in a future inspection to ensum that it meets the requirements of 10 CFR 50.47(b)(7),10 CFR 50, Appendix E, the commitments of the Emergency Plan, and meets the guidance (or pmvides an acceptable alternative) of NUREG-0654.
The inspectors found another minor discrepancy concerning Emergency Plan commitments and how the licensec implemented its EPP program in regards to the pmvision of public
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information material. As noted in Section 2.1 A.2, annual advenisements were to be placed in local newspapers in order to summarize the actions to be taken by residents in an emergency. During the interview with the Director of Nuclear Communication, he stated that advertisements in local newspapers were discontinued approximately four years ago as their effectiveness was questioned. The newspaper advertisements were replaced by
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calendars. Approximately 58,000 county-specific calendars are distributed which contain the
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required information of Section G.1 of NUREG-0654. Also, complementing the calendars is emergency information placed in local telephone directories witnin the EPZ. Thus, the licensee met the intent of informing the resident population despite discontinuatkn of the annual newspaper advertisements. The licensee pointed out that prior to each annual siren testing, advertisements are placed in the local newspapers announcing the test. As the advenisements were used to inform the public of the simn test and not to meet the annual
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public information requimment, the Emergency Plan should be updated to better reflect the
revised practice.
2.1.5 Licensee Support ofIndustry Initiatives
The licensee was the lead Pressurized Water Reactor (PWR) for the Nuclear Management and Resources Council (NUMARC) Emergency Action Level (EAL) guidance and continued to suppon shutdown EAL development. The licensee's pilot EAL scheme has been formally i
submitted to NRC for review (a formal submittal for implementation has not been made; i
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rather this submittal was in suppon of NRC's request). The licensee continued to meet industry requests for support in this regard. Additionally, the licensee continued to be active panicipant in the Westinghouse Owners Group to develop new guidance concerning severe accident management. The proposed guidance document has been submitted to NRC for its review.
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2.1.6 Changes to the EP Program Summarv
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Changes to the emergency plan and the EPIPs are reviewed as pan of the routine NRC EP inspection program. The discrepancies between the licensee's actions and the Emergency Plan (Section 2.1.3 and 2.1.4) are unresolved pending an update of the pmgram penaining to transient information, annual advertisements, letters of agreement, and reasonable assurance that the Emergency Plan is properly updated to reflect the manner in which the licensee implements its emergency prepamdness program (URI 50-334/93-20-01).
This program area was assessed as good, notwithstanding the above noted discrepanicies.
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2.2 Facilities The inspectors toured the Control Rooms (CR), Operations Support Center (OSC),
Radiological Operations Center (ROC), Technical Suppon Center (TSC), and the Emergency i
Operations Facility to assess whether these facilities, equipment, supplies, and procedures were adequately maintained. The TSC and EOF was combined into a single dedicated facility designated as the Emergency Response Facility (ERF).
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i At the time of the inspection, facilities were well maintained and ready. Audit No. BV-C-93-04 noted that good progress was made concerning maintenance of the proper mvisions of documents in the TSC, but the item was not closed as corrective actions had not been completed. The inspectors sampled communications equipment, computer tenninals, and survey equipment for operability and calibration. The inspectors found that all sampled equipment was functional and, if applicable, calibrated. Several downwind survey kits were inspected and found fully stocked; equipment within these kits was operational and calibrated.
Review of the licensee's facility surveillance reports and discrepancy corrective action reports for the first and third quaders of 1993 found them an effective means of insuring readiness.
Corrective actions to discrepancies were resolved promptly. The licensee implemented a manual tracking system to ensure that items open for a long period of time due to ordering, manufacturing, or work order delays were properly resolved for closure.
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NRC Inspection Repod Nos. 50-334/92-11 and 50-412/92-10 raised a question concerning ERF ventilation system adequacy. This item was closed (See Section 3.0 for a description of licensee actions taken in this regard). At the time of the inspection, the licensee had not detennined whether a permanently installed pressure differential monitoring device would be installed or a hand-held device would be made available for emergency response use.
Regulatory Guide 1.52 does not direct pennanent installation of such a device. This decision will be reviewed in a future inspection. Also, ERF building ventilation system functionality testing will be reviewed in a future inspection.
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This program area was assessed as being effectively implemented.
2.3 Organization and Management Control The inspectors reviewed the Emergency Response Organization (ERO) and management control of the EP program to determine conformance with the Emergency Plan. The Manager, EPP now reports to the General Manager, Nuclear Suppon. The General Manager, Nuclear Support reports the Vice President, Nuclear Operations.
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The inspectors reviewed twenty-five ERO member's training records to ensure that they met the required training qualifications to be placed on the ERO call out list. No discrepancies were found. The ERO was fully staffed. The licensee was at least four deep in all major -
site ERO positions. The Manger, EPP had authority to place and remove individuals on active ERO status. ERO removal authority resided with the Senior Vice President.
r The EP staff was stable and staff backgrounds were diverse. Staffing was ample with five individuals assigned primarily to on-site EP activities. Four individuals were assigned
specifimally to off site liaison duties. Each county within the 10 mile Emergency Planning Zone (EP1) continued to be assigned a specialist; this commitment of resources was viewed as a pmgrammatic strength.
EP tmining was the responsibility of a dedicated individual from the Training Depanment
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and two other part-time individuals. Two additional individuals within the EP Department were responsible for off-site training.
The EPP group continued to support other station groups. For example, :;everal individuals on the licensee's EPP staff assisted the station radiological controls department with internal self-assessments during outages (called radiological quality assurance). One individual supported the unit 1 outage as a containment coordinator. Another individual will support the unit 2 outage as a shift outage manager. These continuing efforts strengthened-i, relationships and reciprocal support (such as scenario development) with all station groups involved. The Manager, EPP served as a member of the Operational Experience Subcommittee. Support of this committee served to enhance relationships at the managerial level.
Organization and management contml was assessed as being effectively implemented.
l 2.4 EP Training To determine if 10 CFR 50.47(b)(15) and 10 CFR 50, Appendix E, Section IV.F.,
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" Training," had been met and whether NUREG-0654 guidance had been implemented, the
.i inspectors conducted interviews and reviewed Emergency Plan Section 8.1, " Organization Preparedness," the Duquesne Light Company Training Administrative Manual, Section 9.1, i
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" Emergency Prepandness Plan Training Program," selected training records, and Lesson Plans (LPs).
2.4.1 Training Procram Administration l
Section 8 of the Emergency Plan or the Tmining Administrative Manual did not reflect the Manager EPP's statement that ERO members will panicipate (as a player, observer, or a controller) in a drill or exercise at least once every two years for continued ERO certification. In practice, licensee ERO members were panicipating on a once-pen ye basis.
The Training Administrative Manual, Revision 3, delineated responsibilities for training emergency sesponse personnel and the process by which the Emergency Plan training program was developed and maintained. This document directed that the Director, Technical Tmining develop the annual EP course schedule. The 1993 EP course schedule was
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reviewed. No inadequacies were noted. LP content was assessed as good.
Requalification training is conducted in a classroom-based format. Training for minor EP pmgram changes may be conducted in a read-and-sign type format.
2.4.2 Interviews Interviews were conducted with two Emergency Directors (EDs) and two Emergency Recovery Managers (ERMs). The licensee was infonned that a non-panicipating representative could observe this activity. Each interview lasted approximately forty-five minutes. The interviews were open-book, and focused on the adequacy of the emergency plan implementing procedures and how individuals were trained on these.
It was recognized that individual interviews provide a different environment from the conditions under which emergency procedures are actually implemented. Actual Emergency Action Level (EAL) declarations and PARS are more of a team effon, and individual-i interviews do not measure overall licensee ability to classify events and make PARS. (That capability has been found acceptable at BVPS during actual events and periodic emergency exercises.) Overall, the interviews indicated acceptable individual knowledge. The interviews did, however, provide indicators that merit licensee consideration from the viewpoint of determining whether EP training (and/or associated tests) should be strengthened or re-oriented to better assure maintenance of individual ability to respond to events. Specific indicators were:
Those EDs and ERMs interviewed did not demonstrate knowledge of the potential impact of the NRC Site Response Team on the licensee's Emergency Response Facilities (ERFs). They did not show knowledge of when to expect the team, how many people would arrive, where they would want to go (ERFs), or what their responsibilities would includ.
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NUREG-0654, Itera I.I, " Federal Response," (Page 28) states: "The facility licensee must make provisions for an NRC presence onsite following an accident...."
i After the interviews had been completed, this indicator was further reviewed with the EPP Manager. The EPP Manager recognized the need to make provisions for the NRC Response Team and planned to address this issue.
In one ED interview, the ED was asked to classify a series of events that were used e
in one of the table-top scenarios (LOCA, breached containment, and fuel damage).
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The ED classified the event at the General Emergency (GE) leveljust as the NSS did in the table-top scenario. However, the PAR made by the ED was different than the.
PAR made by the NSS. The ED used EPP/I-5, General Emergency, section 1.5 to make the PAR. EPP/I-5, General Emergency, Section 1.5 states that the minimum Protective Action Recommendation is sheltering within 0 to 2 miles in all sectors, j
unless a more appropriate recommendation is immediately available. This statement was misinterpreted by the ED as a default PAR to be used until he received specific dose projections from the Radiological Controls Technicians (RCTs). Based on the data available to the ED at the time, the correct PAR should have been to evacuate within 10 miles in all sectors. This PAR was determined by using EPP/IP 4.1, i
Offsite Protective Action, Attachment 1. The ED, when provided with specific radiological data, stepped through the flow chart of EPP/IP 4.1 to arrive at the correct PAR. The minimum PAR specified in EPP/I-5 is ambiguous, and was therefore subject to misinterpretation.
j Current NRC guidance concerning PAR development directs evacuation when in a severe core damage accident sequence. The licensee stated that they were aware of i
the PAR procedure (s) conflict and planned to have the problem resolved in the next
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J revision to the EPIPs.
NRC review concluded that, overall, senior ERO manag:: ment was able to implement EP pmcedures as intended. The interviewees were knowledgeable of their responsibilities and the overall ERO organization and function. However, licensee dispositioning of the above indicators (see Section 2.4.3.6 for an additional concern on informing the NRC Duty Officer)
was identified for subsequent NRC review (IFI 50-334/93-20-02).
2.4.3 Knowledge and Performance of Duties Walk-through (table top) scenarios were conducted on three different crews of control room -
Senior Reactor Operators (SROs). One crew had one scenario while the remaining two crews each had two scenarios. Each one hour scenario was a fast-breaking sequence of events that challenged the SROs to implement the EPIPs without the assistance of the augmenting staff. The NRC modified two scenarios from the Licensed Operator Requalification Training (LORT) program and developed the third. All scenarios were reviewed by the licensee prior to being presented to the SROs in the walk-through.
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The crews consisted of a Nuclear Shift Supervisor (NSS) who implemented the EPIPs and an assistant NSS who went through the Emergency Operating Procedures (EOPs). An emergency preparedness staff person was the designated communicator. Because there were no phones, designated communicator (shift Administrative Assistant) only received the notification forms from the NSS without making any calls. Dose projections for three of the scenarios were performed separately by a Radiological Controls Technician (RCT) in the EOF to utilize the computers in that facility and avoid congestion in the control room.
Throughout the scenarios and dose projection calculations, the EPP Manager was the source of plant system status and radiological data as the crews progressed through the scenarios.
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As noted above, shift Administrative assistants were not available for testing during the table-top scenarios. Two shift Administmtive assistants were interviewed during the conduct of
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NRC Inspection 50-334/92-14 and 50-412/92-13 and were found to be knowledgeable of their position requirements and EP procedures.
Debriefs were conducted after each scenario. The licensee concurrently identified the concems noted by the NRC evaluators.
2.4.3.1 First Group One table-top scenario was run with the first group. The scenario consisted of Unit #1 initially at 100% power when a small break Loss Of Coolant Accident (LOCA)
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(approximately 250 gpm) occurred resulting in pressurizer level dropping and SI initiation.
Shortly thereafter, the AE 4KV emergency bus (Train A) de-energized due to a faulty breaker that resulted in a loss of the Train A Emergency Core Cooling System (ECCS). A containment penetration leak then resulted in a radioactive release to the safeguards building.
The NSS correctly classified the events at the Site Area Emergency (SAE) level on the basis of primary system leakage greater than 50 gpm with containment failure indicated. He then initiated the appropriate notifications. The "B" charging pump shaft then broke leaving the Reactor Coolant System (RCS) without any high pressure Safety Injection (SI) flow. Core
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Exit Thermocouples (CETs) increased to approximately 735 degrees F and Reactor Vessel Level Indication System (RVLIS) decreased to 32%. The NSS was then informed that the core cooling critical safety function status tree (CSFST) was RED. The NSS correctly classified the events at the General Emergency (GE) level on the basis of a challenge to three fission product barriers. The NSS initiated timely notification of the GE which included the correct PAR.
2.4.3.2 Second Group The first scenario started with the reactor at 65% power when a steam line break outside of containment upstream of the Main Steam Isolation Valve (MSIV) occurred. The break size increased eventually causing a reactor trip to be inserted and SI to actuate. The NSS declared an Unusual Event (UE) based on the steam leak. While simulating action to mitigate the steam line break, the affected Steam Generator (SG) developed a large tube i
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rupture. The NSS declared a SAE based on a SG that was faulted and mptured.
t Notifications during this scenario wem performed promptly.
The second scenario started at 100% power with the "A" Auxiliary Feedwater (AFW) pump out of service for maintenance when a sequence of events occurred leading to a loss of all feedwater flow. A feedwater regulating valve failed closed which resulted in a mactor trip.
The turbine did not trip automatically or manually until the MSIVs were closed thus causing SG inventories to decrease due to continued steaming. The "A" charging pump tripped when the reactor tripped and would not restart. The DF 4KV Bus (Train B) was lost thus disabling the "B" AFW pump and the turbine driven AFW pump tripped and could not be reset. With low SG levels and no AFW flow the heat sink CSFST was RED. The NSS then declared an SAE based on the loss of heat sink condition. With no AFW or high pressum SI flow, fuel damage resulted and RCS pressure increased and mlieved to the Pressurizer Relief Tank (PRT). The PRT rupture disc subsequently failed and RCS inventory was released to the containment. A containment penetration leak occurred resulting in a mlease path to the safeguards building. The NSS correctly declared a GE based on the breaching of three fission product barriers. The NSS initiated appropriate and timely notifications which included correct PAR during this scenario.
2.4.3.3 Third Group The third group received the one scenario that the first group mceived (LOCA, breached containment, and fuel damage) and the first scenario that the second gmup received (ruptured / faulted SG). In the LOCA scenario the NSS classified a LOCA with breached containment as an Alert when the correct classification was a SAE based on Tab 5 - RCS
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Leakage Exceeds 50 gpm and CONTAINMENT FAILURE Indicated. Later in the scenario the NSS classified the same condition with the addition of damaged fuel as a SAE when the correct classification was a GE based on TAB 8 - Loss of 2 of 3 Fission Product Barriers With the Potential Loss of the Third. These events were misclassified because the NSS did not understand the criteria used to evaluate a breach of containment. The NSS did eventually upgrade the classification to a GE when he was provided with dose projection information.
In subsequent discussion with the NSS, this individual stated that radiation outside of containment did not constitute a breached containment. He stated that since no Containment Isolate Phase B (CIB) had occurred there was therefore no high containment pressure
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condition to act as a driving force to cause a release fmm containment. In the second
scenario, the NSS properly classified the events and promptly initiated the notifications.
l 2.4.3.4 Dose Assessmen_t Dose projections were performed for three of the five scenarios. One scenario for each crew was used as the basis for the calculation. Following each set of scenarios the NRC went to the licensee's EOF to meet with a RCT designated to perform the calculation. The calculations were performed on the EOF's MIDAS computer instead of the control room computer to minimize congestion in the control roo.
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Three diffemnt RCTs performed one calculation. These individuals performed the dose projections correctly. Them was some evidence of hesitation and unfamiliarity demonstrated by one RCT, but not to the point of being unable to perform the calculation correctly and/or in a timely manner. RCTs receive training on the MIDAS computer system once per year.
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2.4.3.5 Operator EP Training Effectiveness
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The inspectors checked LORT scenarios used in the simulator to retrain operators for applicability in table top scenarios. The inspectors significantly modified LORT scenarios or developed new scenarios for use in the table-top scenarios. LORT is not intended to provide
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in-depth EP training, and in conclusion, the amount of performance-based EP training provided by LORT was not extensive. Licensee personnel also stated they do not usually practice on scenarios which postulate events at the General Emergency level in LORT (due in large part to the limitations of the simulator model). Despite these observations, no generic
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EP related inadequacies were observed from the table-top scenarios.
The licensee has modified LORT so that crews perform all EP and licensed based responsibilities on a once-per-year basis at the General Emergency level. The licensee initiated this change in order to strengthen operator familiarity with the procedures related to higher event classification. This was viewed as a positive programmatic enhancement by the NRC.
The inspectors reviewed Licensee Event Reports (LERs) for both units in 1993. Of the approximately 25 LERs reviewed, one event needed to be classified. An SI actuation resulting from an instmment failure met the criteria for an Unusual Event and was classified by the licensee in accordance with EPIP/I-l Attachment 2, Tab 10, SIS Initiation.
2.4.3.6 Knowledge and Performance of Duties Summary Overall, the crews correctly identified plant conditions, pmmptly declared the events, initiated state and local notifications within 15 minutes, and included the cormct PARS for the GEs. The protective actions that were recommended would have protected the health and safety of the general public under the circumstances of the scenarios. The misclassifications
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that occurred in the one scenario were the result of the NSS not understanding 11e uiteria used to evaluate a breach of containment coupled with the artificial conditions in which the scenarios were performed. This appears to be an isolated incident and not indicative of a l
generic weakness among the licensee's NSSs.
-l The licensee has incorporated NRC Form 361 into their procedum for NRC notifications of 10 CFR 50.72 mportable events. The NSSs did not complete the sections on release rates, the percentage of technical specification limits on release rates, and stack monitor readings when filling in the notification forms. This information would be requested by the NRC Protective Measures Team and by the Operations Officer shortly after NRC notification on i
the Emergency Notification System (ENS).
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Post-inspection NRC review of the table-top scenarios noted the following:
During routine watchstanding in the plant, another senior licensed operator (the other
unit NSS) would have been readily available to assist the shift to handle the workload of an emergency.
The focus on tmining assessment rather than on actual shift response denied the tested
shift the opportunity to consult with knowledgeable management by telephone.
It was recognized that table-top scenarios (also are conducted with only a ponion of
the actual shift staff) provide a different environment from the conditions under which emergency procedures are actually implemented. Actual EAL declarations and PARS are more of a team effort, and table-top scenarios do not measure overall licensee ability to classify events, make PARS, or provide sufficiently detailed information to outside agencies.
RCTs (who perform shift dose projection calculations) do not currently practice with
operators in the EP LORT training sessions. The RCTs and licensed individuals were tested separately. The NSS relies upon the RCT for dose pmjections to support proper EAL selection and, therefore, proper event classification. The Manager, EPP planned to evaluate this particular aspect concerning the conduct of operator performance-based EP training.
The inspectors concluded that the scenarios provided valid training insights (as intended),
even though they were not representative of an actual event response.
2.4.4 EP Tmining Summary This program area was assessed as being effectively implemented.
2.5 Independent Reviews / Audits An independent review is required at least every 12 months by 10 CFR 50.54(t) which includes an evaluation of the adequacy of the off-site interface. To detemiine if requirements were met, the inspectors reviewed the licensee's Technical Specifications, Quality Assurance (QA) Procedures, reviewed the Audit Plan and Audit checklists, reviewed the QA reports and QA surveillance reports.
Technical Specification (TS) 6.5.2.8 required an annual assessment of the Emergency Plan and its implementing procedures. Section 8.3.e. of the Emergency Plan, " Maintaining Preparedness" required an annual review which met 10 CFR 50.54(t) and TS requirements.
The results of the off-site portion of the audit was made available to the state and county governments as required (see section 2.9). EALs were reviewed with the surrounding
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Counties and the Commonwealth of Pennsylvania, State of West Virginia, and the State of Ohio as required (see Section 2.8).
The inspectors 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 good. Audit reports were sent to the Manager, EPP, licensee'
management, and the county emergency management offices.
The inspectors noted that the inclusion of a technical expert on audit team BV-C-93-04 was a positive audit program enhancement. No deficiencies were identified by the licensee audit team. The licensee audit team concluded that quality-related requirements of the EPP program were effectively implemented.
With the exception of walkthrough testing, the licensee conducted its audits in a manner similar to that used by NRC as contained in NRC Inspection Procedure 82701. The licensee
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audit team did not note the discrepancies concerning Emergency Plan maintenance (Section 2.1.1) and commitment tracking (Section 2.6). Additional audit team focus on these EP program areas is warranted.
This program area was assessed as being well implemented.
2.6 Commitment Tracking The inspectors reviewed the system by which corrective action: were tracked. Items requiring corrective actions were maintained on the site Commitment Tracking System (CTS). This system was maintained by Licensing.
i The Emergency Preparedness Planning (EPP) Department conducted root cause analysis for QA and NRC areas of concern / improvement when appropriate, Generally, CTS open items received management attention up to the General Manager level. Reports were regularly sent to General Managers and action addressees. Due dates were negotiated between responsible i
parties.
To determine if 10 CPR 50.47(b)(14) and 10 CFR 50, Appendix E, Section IV.F.,
" Training," had been met, the inspectors conducted interviews, reviewed Emergency Plan
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Section 8.1, " Organization Preparedness," reviewed drill / exercise reports, reviewed -
drill / exercise observer reports / notes, scenario objectives and training LPs.
Corrective action follow-up was reviewed for the exercise weaknesses noted in NRC Inspection Report Nos. 50-334/92-14 and 50-412/92-13 and several drills. The inspectors evaluated the licensee's actions taken to resolve EP related discrepancies for their adequacy and timeliness. Actions of a long-term nature were, in general, evident by some means e.g.,
incorporation of lesson learned in a training lesson plan or demonstration of the inadequacy as a scenario objective. In some cases, the inspectors noted insufficient attention to detail l
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pertaining to the documentation and resolution of EP related deficiencies. Three examples follow. The first tnd third examples pertain to a lack of documentation which prevent an evaluation of corrective action timeliness. The second example pertains to the adequacy of the corrective action and how it was applied.
NRC Inspection Report 50-334/92-14 and 50-412/92-13 noted an exercise weakness concerning contml of damage repair teams. This weakness was adequately demonstrated as noted in NRC Inspection Repon 50-334/93-03 and 50-412/93-03. However, documentation of the actions taken to resolve this exercise weakness was poor. The inspectors were unable to develop a timeline of licensee actions that had been taken to resolve the weakness as the-l licensee was unable to produce documentation of meetings held to resolve this discrepancy j
(or through means other than meeting minutes and accompanying meeting attendee list). In
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summary, the inspectors were unable to determine the timeliness of corrective actions taken in regards to this exercise weakness.
'l NRC Inspection Report 50-334/92-14 and 50-412/92-13 noted an area for improvement j
concerning declaration of emergency conditions when recognized. The following is excerpted from that repon, "... the TSC ED recognized that a Site Area Emergency (SAE)
emergency action level (EAL) had been reached. It was then decided to declare the SAE several minutes later. Also, the TSC ED stated over the ERP paging system that accountability was to begin at 1815." NRC review identified no valid reason for delaying either declaration of a recognized emergency condition or personnel accountability.
Corrective actions regarding the emergency declaration discrepancy were limited to TSC EDs. No specific licensee actions concerning NSS's were evident (the NSS serves as the ED
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until the TSC is activated and takes command and control of the on-site emergency response). It is important to note that corrective actions must be applied in a sufficiently broad manner to prevent a similar future violation (10 CFR Part 2, Appendix C).
The inspectors reviewed the May 1,1992 final repon penaining to the March 5,1992 chemistry PASS drill. One observer noted that there were some " procedural errors" but did
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not note their nature. This observer also noted that the procedure was, in fact, not used.
Licensee EPP staff were unable to inform the inspectors of the nature of these panicular procedural errors. Therefore, the inspectors were unable to conclude that this particular drill deficiency had been corrected and/or properly tracked for proper demonstration of corrective actions in the next PASS drill.
The licensee's ability to meet the requirement that " periodic exercises are (will be) conducted to evaluate major portions of emergency response capabilities, periodic drills are (will be)
conducted to develop and maintain key skills, and deficiencies identified as a result of exercises or drills are (will be) corrected" per 10 CFR 50.47(b)(14) is unresolved pending further review (URI 50-334/93-20-03).
This program area was assessed as being adequately implemented. The finding in this area was accepted by the licensee. Also, the inspectors noted prompt licensee attention to this
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particular matter in that the licensee EP staff had held meetings and was close to
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implementing corrective actions to address this EP program deficiency prior to the NRC exit meeting.
2.7 Drill and Exercise Program To detennine if 10 CFR 50.47(b)(14) and 10 CFR 50, Appendix E, Section IV.F.,
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" Training," had been met and whether NUREG-0654 guidance had been implemented, the inspectors reviewed Emergency Plan Section 8.1, " Organization Preparedness," scenarios, critique notes, final reports, and interviewed cognizant EPP staff.
Section 8.1.3 of the Emergency Plan designated the Manager, EP as cognizant for the development, coordination, and conduct of drills and exercises. The Emergency Plan
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required that BVPS conduct the annual exercise and the following drills: medical emergency l
(annual), radiation emergency (annual), health physics (semi-annually), and effluent monitoring (annual). EPP conducts scheduling meetings that provide a mechanism which helps ensure the sixteen planning standard criteria of NUREG-0654 are being tested each year in drills and exercises.
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The inspectors reviewed the drill / exercise scenario development process for the drills and J
exercises conducted in 1992 and found it good. Previous concerns and new procedures received emphasis thmugh inclusion in drill / exercise objectives. Drills and exercises j
conducted met Emergency Plan requirements for 1992. All drills / exercises were approved by senior management. Drill reports were timely and widely distributed to management.
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I Drills / exercises provided varied challenges to the ERO. Four full station drills / exercises were conducted in 1992. In some cases, drill / exercise records were reviewed and found incomplete with regards to documentation of corrective actions (see Section 2.6).
This program area was assessed as good.
2.8 Public Information and Off-site Interface To detennine if 10 CFR 50.47(b)(7) and 10 CFR 50, Appendix E, Section IV.D.2.,
" Notification Procedures," had been met and whether NUREG-0654 guidance had been implemented, the inspectors conducted interviews with public relations personnel and county directors, reviewed Emergency Plan Section 8.5, " Corporate Communications," of the Emergency Plan, and selected pertinent documentation for additional verification.
The licensee planned to take over training for the surrounding county MSI hospitals and ambulance organizations. This is a change in responsibility as the Commonwealth of Pennsylvania provided this training in the past for the surrounding counties in Pennsylvania.
An October 2,1993 training session on radiation injuries was planned. The session sponsors were the University of Pittsburgh Graduate School of Public Health, Washington Hospital, and the Duquesne Light Company.
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The licensee continued to assist in the evaluation of any necessary changes to the State Emergency Plan (e.g. re-evaluating siren coverage and upgrading evacuation bus routing) and Pennsylvania Bureau of Radiation Protection (BRP) concerning updates to incorporate the EPA-400 Protection Action Guideline (PAG) manual methodologies and changes to 10 CFR 20.
A three day training session was conducted on August 4-6,1993 for the involved States and local officials in which EALs, protective action recommendations (PARS),.ndustry initiatives, training of BVPS radiation workers, low level radioactive waste, and other topics were discussed. The EPP Department assisted in the local law enforcement training sessions.
On August 24,1993, the licensee provided training to off-site agencies on the technical basis of dose projection methodologies used at BVPS and planned changes in this regard.
The licensee hosted two conferences on January 28-29 and Febmary 10-11, 1993 to discuss issues pertaining to the implementation of the EPA-400 PAG manual. The meeting were conducted with officials from the Commonwealth of Pennsylvania and the States of Maryland, Ohio, and West Virginia. Other utility representatives also attended.
The inspectors interviewed the Director, Columbiana County Disaster Services Agency (CCDSA) and the Director, Beaver County Emergency Management Agency (EMA) after the conduct of the inspection by telephone. Both directors indicated that they had a good working relationship with the BVPS staff. Both directors also noted that the quality of support in regards to siren maintenance and EAL training was very good. The Manager, EPP planned to maintain the current level of radiological emergency planning support to the risk counties for fiscal year 1994. The Manager, EPP stated that efforts would be made to provide training on siren system activation / termination and would be repeated as needed (with a maximum 18 month frequency).
This program area was assessed as being effectively implemented.
3.0 Licensee Action on Previously Identified Items CLOSED (URI 50-344/92-11-01 and 50-412/92-10-01) No testing was conducted on the ERF HEPA filtmtion system nor was there a provision for verification of facility positive pressure.
i The licensee completed the following actions concerning this discrepancy.
e Procedure IBVT 1.58.2, "ERF Building Emergency Filters In-Place Leak Test,"
Revision 1,6/9/92 was developed. This procedure provided High Efficiency
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Particulate Air (HEPA) and charcoal adsorber tests.
Procedure IBVT 1.58.4, "ERF Building Area Pressure Monitoring," Revision 0,
6/29/92 was developed. This procedure provided a pressure differential test.
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Operating Surveillance Test (OST) 1/2.58.8, "ERF Emergency Ventilation
Recirculation Test," Revision 0 was developed. This procedure provided a system fuctionality test, The following table provides information as to when these pmcedures were performed and the results of the tests reviewed and approved by licensee management.
Procedure Approval Date IBVT 1.58.2 8/2/93 IBVT 1.58.4 8/2/93 These actions were assessed as appropriate and the item is closed on this basis. The adequacy and maintenance of ERFs is part of the mutine EP inspection program. This area will be reviewed in future inspections.
CLOSED (IFI 50-334/92-11-03 and 50-412/92-10-03) All (five) Plan "A" responding fim departments ceased to participate in the BVPS Mutual Aid Fire Plan.
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No violation (s) or failure to meet commitments occurmd as a result of the Plan " A" fire departments' temporary refusal to participate in the BVPS Mutual Aid Fire Plan. Subsequent to the inspection, the licensee and plan "A" fim departments established a support arrangement. Each Plan "A" fire department has provided an affirmation to their commitment to the BVPS Mutual Aid Fire Plan in writing. These agreements were cosigned
.j by the Manager, EPP. The licensee has met the emergency plan requirement to conduct a
drill with off-site fire protection support. The above noted agreements were established as follows.
Fire Depatment Affirmation Date Shippingport Volunteer Fire Company 7/30/92 llookstown Volunteer Fire Company 7/30/92 Industry Volunteer Fire Company 7/30/92
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Raccoon Township Volunteer Fire Company 7/31/92 Midland Volunteer Fire Company 7/30/92
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4.0 Exit Meeting The inspectors met with the licensee personnel denoted in Section 1 at the conclusion of the inspection to discuss the inspection scope and findings. The licensee acknowledged the findings and stated their intention to evaluate them and institute corrective actions as appropriate.
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