IR 05000338/1982005
| ML20058H216 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 06/30/1982 |
| From: | Huffman G, Jenkins G, Kantor F, Marston R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20058H018 | List: |
| References | |
| 50-338-82-05, 50-338-82-5, 50-339-82-05, 50-339-82-5, NUDOCS 8208030509 | |
| Download: ML20058H216 (60) | |
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a Rtni UNITED STATES o,t NUCLEAR REGULATORY COMMISSION
$ E REGION 11 o * 101 MARIETTA ST., N.W., SUITE 3100 o ATLANTA, GEORGIA 30303 44***
Report Hos. 50-338/82-05 and 50-339/82-05 Licensee: Virginia Electric and Power Company P. O. Box 26666 Richmond, VA 23261 Facility Name: North Anna Power Station Units 1 and 2 Docket Nos. 50-338 and 50-339 License Nos. NPF-4 and NPF-7 Appraisal at the North Anna site near Mineral, Virginia Inspectors: f4 / (Aidef 6/30/PL Date Signed
[ F. Kantor, Team Leader IAL $ had<w1 6/ss/2 /^ G. N. Huffman Uate* Signed b -
d/3OlT*L R. R. Marston Date Signed Accompanying Personnel: E. E. Hickey P. Robinson
. M. Clark E iarkee, J Approved by-
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s u '- 2 # 8A E R. Jeh J Chief Date Signed Emergenc reparedness Section EPOS Division Sumary Areas Inspected:
This special, announced appraisal involved 490 inspector-hours onsite and offsite in the performance of an Emergency Preparedness- Implementation Appraisal including administration, emergency organization, training and retraining, emergency facilities and equipment, procedures, coordination with offsite groups, drills and exercises, and evaluation of the Emergency Pla Results:
In the areas inspected, no violations or deviations were identifie Emergency preparedness deficiencies were identified in three areas: Training, Section 3.0; Emergency Plan Implementing Procedures, Section 5.0; and Initial Dose Assessment, Section 5.4.2. These deficiencies were addressed in a confirmatory letter to the licensee dated March 10, 1982.
8208030509 820727 PDR ADOCK 05000338 G PDR
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TABLE OF CONTENTS INTRODUCTION DETAILS 1.0 Administration 2.0 Emergency Organization 2.1 Onsite Organization 2.2 Augmentation Organization 3.0 Training / Retraining 3.1 Program Establishment 3.2 Program Implementation 4.0 Emergency Facilities and Equipment 4.1 Emergency Facilities 4. Assessment Facilities 4.1.1.1 . Control Room /
4.1.1.2 Technical Support Center (TSC) J 4.1.1.3 Operations Support Center.(OSC)
4.1. Emergency Operations Facility (E0F)
4.1.1.5- Post-Accident Sampling and-4.1.1.8 Analysis 4.1.1.9 Off site' Laboratory Facilities 4. Protective Facilities 4.1. Assembly /Reassemoly Areas 4.1. Medical Treatment Facilities 4.1. Decontamination Facilities 4. Expanded Support Facilities 4. News Center 4.2 Emergency Equipment 4. Assessment Equipment 4.2. Emergency Kits and Portable Instrumentation 4.2. Area and Process Radiation Monitors 4.2. Non-Radiation Process Monitors 4.2. Meteorological Instrumentation i
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TABLE OF CONTENT (CONT'D)
4. Protective Equipment 4.2. Respiratory Protection 4.2. Protective Clothing 4. Communications 4. Damage Control / Corrective Action 4. Reserve Emergency Supplies'and Equipment 4. Transportation 5.0 Procedures 5.1 General Content and Format 5.2 Emergency, Alarm and Abnormal Occurrence Procedures 5.3 Implementing Instructions 5.4 Implementing Procedures 5. Notifications 5. Assessment Actions 5.4.2.1 Offsite Radiological Surveys 5.4.2.2 Onsite (Out-of-Plant) Radiological Surveys 5.4. In-Plant Radiological Surveys 5.4.2.4- Post-Accident Sampling and Analysis 5.4.2.11 5.4.2.12 Radiological-Environmental Monitoring Program (REMP)
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5. Protective Actions 5.4. Radiation Protection During Emergencies 5.4. Evacuation of Owner Controlled Areas 5.4. Personnel Accountability 5.4. Personnel Monitoring and Decontamination 5.4 Onsite First Aid / Rescue 5. Security During Emergencies 5. Repair / Corrective Actions 5. Recovery
, 5. Public Information l 5.5 Supplementary Procedures
- 5. Inventory, Operational Check and Calibration
' of Emergency Facilities and Equipment 5. Drills and Exercises 5. Review, Revision, and Distribution 5. Audits
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TABLE OF CONTENT (CONT'D)
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6.0 Coordination with Offsite Groups 6.1 Offsite Agencies 6.2 General Public 6.3 News Media 7.0 Drills, Exercises and Walk-Through Observations 7.1 Program Implementation 7.2 Walk-Through Observations 7. Emergency Detection (EAL Recognition) and Emergency Classification 7. hotifications 7. Dose Calculations 7. Off-Site Environmental Sampling and Analysis Attachment 1: Persons Contacted Attachment 2: Evaluation of the North Anna Emergency Plan iii J
l INTRODUCTION The purpose of this special appraisal was to perform a comprehensive evaluation of the licensee's emergency preparedness program. This appraisal included an evaluation of the adequacy and effectiveness of areas for which explicit regu-latory requirements may not currently exist. The appraisal effort was directed towards evaluating the licensee's capability and performance rather than the identification of specific items of noncompliance.
The appraisal scope and findings were summarized on February 26, 1982, with those persons indicated in Attachment 1 to this repor J
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1.0 Administration of Emergency Plan
, The responsibilities and authority for radiological emergency planning and preparedness at the North Anna Power Station (NAPS) were discussed to a limited j extent in Section 8.0 of the Emergency Plan. Section 8.0 of the Emergency Plan 1 J was dated January 15, 1982; the balance of the Emergency Plan was dated July 10, 1981. The inspectors reviewed the information in the Emergency Plan as well as
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Station administrative procedures and individual professional qualification i descriptions and interviewed licensee representatives to determine the assignment
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The Station has' an assigned full-time Emergency Planning Coordinator (EPC) whose responsibilities, as specified in the Emergency Plan, include updating the Emer-
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gency Plan and Emergency Plan Implementing Procedures (EPIPs) and coordination of these plans with other response organizations, distribution of revisions, obtain-ing letters of agreement with offsite support agencies and coordination of ef forts with corporate personnel . The Emergency Plan states that the Station Manager is responsible for this individual's function."
The EPC began his duties at the Station in November 1981. Before that, emergency
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planning duties at the Station were performed as an additional duty by different individuals in the licensee's organizatio The individual filling the EPC position had approximately 8 years experience as a State Radiation Safety Officer. The EPC had received a verbal briefing on his duties and responsibil-ities upon assuming his position but was not aware of and had not seen a formal position description. The EPC interacted with the Station Manager, other Station supervi sory personnel, and Corporate emergency planning personnel. The EPC stated that he presented proposed revisions to' the Emergency Plan implementing i procedures to the Station Nuclear Safety and Operating Committee.
'The EPC position had not yet been included in Administrative Procedure ADM-1.0,
" Station Organization and Responsibility," dated October 1, 1981. Further, a i
review of the responsibilities of the Station Manager and other supervisory personnel listed in ADM-1.0 showed that no explicit reference was made to the emergency planning duties and responsibilities for anyone in' the Station organization.
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At the Corporate level, the responsibility for emergency planning within the Virginia Electric and Power Company was-transferred on January 4, 1982, from the Quality Assurance Department to the Nuclear Operations Department. The Vice President-Nuclear Operations has the overall authority and responsibility for
radiological emergency planning and preparedness. A Director of Emergency i
Planning reports to the Vice President-Nuclear Operations through the Manager-Nuclear Operations and Maintenance. The Director of Emergency Planning is responsible for coordinating emergency planning activities within the company and j
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with local, State, and federal organizations. The Director of Emergency Planning has two emergency planning specialists on his staf Position descriptions
' showing the duties and responsibilities of the Director-Emergency Planning and his staff planners were being developed at the time of the appraisal.
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Discussions with emergency planning personnel indicated that their knowledge of the principles involved in emergency planning was acquired through normal work related experience. The licensee did not have a formal professional
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development program for emergency planning personnel and the opportunity, especially for Station personnel, to attend meetings, seminars, observe exercises, etc. , was limite Based on the above findings, this portion of the licensee's program appears to be adequate, however, the following items should be considered for program improvemcnt:
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Developing position descriptions for Station and Corporate emergency planning personnel which clearly describe their respective duties, responsibilities and authority for maintaining emergency preparednes (50-338, 339/82-05-01)
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Including in the description of the Station organization and responsibili-ties in Administrative Procedure ADM-1.0 the responsibilities of the various Station personnel (e.g., Station Manager, Health Physics Supervisor) for maintaining emergency preparedness. (50-338, 339-82,-05-02)
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Providing for professional development training for emergency planning personnel to maintain state-of-the-art knowledge. (50-338, 339/82-05-03)
2.0 Emergency Organization 2.1 Onsite Organization
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The onsite emergency organization is described in Section 5.0 of the Emergency Plan and in Emergency Plan Implementing Procedure EPIP-1, " Emergency Classiff-
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cation and Organization Formation, Notification and Communications," dated January 15, 198 '
An Emergency Director has been designated who is on shif t at all times and has the authority and responsibility to initiate any emergency actions including providing protective action recommendations to authorities responsible for implementing offsite emergency measures. A line of succession for the Emergency Director position was specified in the Emergency Pian and in EPIP-1. A discrep-ancy was noted between the Emergency Plan and EPIP 1; the Superintendent of Maintenance was shown in the line of succession in the Emergency Plan but was not included in EPIP- The Shif t Superviscr acts in the capacity of Emergency Director until relieved by the Station Manager or an alternate according to the line of succession. Two senior reactor operators (SR0s) are on duty anytime _ one of the units is above cold shutdown. The SRO on Unit 1 is designated as the Shift Supervisor and the SRO on Unit 2 is designated as the Assistant Shift Lpervisor. There is an informal understanding among the SR0s that the SRO on the affected unit will concentrate his efforts on plant operations while the SRO on the unaffected unit will follow the actions required by the Emergency Plan implementing procedure mV
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The Emergency Plan identified 12 functional responsibilities during emergencies (e.g., direction and control, radiological survey and monitoring) and listed 15 categories of emergency assignment for the station staff by normal position title (e.g., Station Manager, Health Physics Supervisor). EPIP-1, Appendix 6,
" Organization During Emergencies," identified the individuals who report to the Emergency Director and_ the personnel who are located in the Technical Support Center and the Operations Support Center, all by normal position titl The resemblance between the emergency organization as described in the Emergency Plan and in EPIP-1, Appendix 6, appeared to be at best only superficial. Functional responsibilities within the emergency organization were not presented in EPIP-1.
The licensee's philosophy concerning the emergency organization was stated in EPIP-1, Appendix 6. as follows: "The emergency response organization is basic-ally 'the same as the normal station organization, with the superintendents and supervisors being responsible for supervising and directing the emergency response activities as directed by the Emergency Director." The description of the emergency organization for'the most part encompassed only the supervisory level and did not extend to the non-supervi sory elements of the emergency organization.
The licensee's emergency organization was illustrated in a chart in Figure 5.4 of the Emergency Plan and in Figure 1 of EPIP-1., There were numerous discrepancies between the two charts which contained a mixture of normal job titles, emergency positions, emergency locations, and offsite support agencies. The organization charts did not clearly specify the interfaces among the various areas of emergency activity or differentiate between the initial onsite organization made up from the normal shif t complement and the fully augmented emergency organi-zatio The information in the organization chart in the Emergency Plan was particularly misleading as it showed the Corporate office and the State Office of Emergency and Energy Services reporting to the Emergency Director. From the information presented in the Emergency Plan and EPIP-1, it was not possible for the inspectors to determine who within the emergency organization was responsible for each of the various functional areas of emergency activity or to verify whether all required areas were covere In addition, the inspectors found no means by which the Emergency Director or other key personnel could correlate the response functions and required tasks to be performed during an emergency with individuals trained and qualified to perform these functions and tasks.
Based on the above findings, this portion of the licensee's program appears to be adequate; however, the following items should be considered for improvement:
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Upgrading the descriptive material in EPIP-1 for the emergency organization so that the assignment of emergency functions and the interface between emergency functions is clarifie (50-338, 339/82-05-04)
2.2 Augmentation of the Onsite Emergency Organization Sections 5.2 and 5.3 of the Emergency Plan present information on the augmen-tation of the onsite emergency organization by of f duty Station personnel, Corporate personnel, vendor and contractor organizations, and local and State emergencj response agencie .
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The minimum shift staff is auginented within 60 minutes by 37 additional Station and Corporate personnel as shown in Table 5.1 of the Emergency Plan. EPIP-1, Appendix 4, " Notification of Emergency Response Personnel," indicates that, following the declaration of an emergency, notification of emergency response personnel will be accomplished by using the Emergency Notification List located in the Ecergency Numbers section of the North Anna Telephone Directory. In comparing the Emergency Notification List with the augmentation personnel in Table 5.1, an inconsistency was noted in the number of Health Physics Technicians included in the emergency organization. Table 5.1 shows a total of 12 Health
Physics Technicians augmenting the shift staff within 60 minutes while the
. Emergency Notification List states that a minimum of 6 technicians will be
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The licensee had no provisions to augment the Station staff within 30 minutes and
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'had not performed a study to demonstrate that the minimum staffing requirements of Table B-1, NUREG-0654 (and Generic Letter 81-10) were met. The licensee also had not performed a drill to demonstrate that the augmentation-capability
specified in Table 5.1 of the Emergency Plan could be accomplished within the indicated 60 minute The Corporate emergency organization is activated for an Alert or higher clas-sification. The Vice President-Nuclear Operations has been designated as the Recovery Manager. The Recovery Manager and his_ support staff report to the near-site Emergency Operations Facility (E0F) where the Recovery Manager becomes the senior licensee representative. The majority of the Corporate emergency organization reports to the Emergency Response Center at the Corporate offices in
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Richmond, Virginia, approximately 45 miles from the site. The Recovery Manager in the near-site E0F serves as the principal point of contact between the onsite Emergency Director, the Corporate emergency response organization, and govern-mental agencies. The Recovery Manager and the Corporate Director of Chemistry and Health Physics who assumes responsibility for offsite dose assessment in the E0F, are shown in Table 5.1 of the Emergency Plan as augmenting the Station staff within 60 minutes of the declaration of an emergenc The Emergency Plan, in Section 5.3 and Appendix 10.1, identified the offsite response agencies relied upon to provide fire, rescue (ambulance), law enforce-i ment, medical and hospital support services. Local governmental authorities and State agencies are also relied upon for assistance in the event of an emergency with potential offsite consequences. This support was documented in letters of
! agreement, dated April to July 1980, which were included in the Emergency Pla The Radiation Emergency Plan of the Medical College of Virginia, Virginia ( Commonwealth University, which documented the medical care assistance to be provided to the licensee, was included in Appendix 10.9 of the Emergency Pla Other companies, industrial organizations, and universities both within and outside the State of Virginia were identified in the Emergency Plan as being available to provide assistance if required, but formal agreements with these organizations were not presented.
l l Emergency Plan deficiencies related to minimum shift staffing and augmentation
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are identified in Attachment 2 to this report.
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3.0 Emergency Plan Training / Retraining 3.1 Program Established The licensee's Emergency Plan training program was described in Section 8.1 of the Emergency Plan and in EPIP-21, " Emergency Preparedness and Training," dated i January 15, 198 The Nuclear Training Department's training manual which described the training courses given to Station employees did not include Emer- 3
gency Plan Training. Some aspects of Emergency Plan training were covered in the Health Physics, Operator License, and General Employee Training sections of the document. In addition to Station personnel having emergency duties, training was provided for general employees, contractor employees, and persnnnel from local fire departments, rescue squads, and law enforcement agencie The Emergency Plan was not specific in which individuals within the normal organization were required to receive specialized training in emergency actions to fulfill specific emergency function The training program implementing procedure, EPIP-21, was inadequate in that it did not specify training require-ments for all emergency organization functional responsibilities and did not indicate site and corporate position which would require specialized training'for each functional responsibilit In addition, EPIP-21, failed to include training requirements for some support groups identified in the Emergency Pla Emergency preparedness training was found to be fragmented among several depart-ments outside of the Training Department such as Health Physics and Chemistr Part of the training was given in operator license training. The Emergency Plan training program lacked central administrative control and appeared to be poorly coordinate Most of the members of the emergency organization including the Emergency Director and alternates, licensed operators, supervisors with emergency duties, and health physics and chemistry technicians, received the same basic Emergency Plan training course. This consisted of a review of the Emergency Plan and the 21 EPIPs which required about 6 to 6-1/2 hours of lecture with a 1 to 1-1/2 hour walk-through practical demonstration. This course was given once a year. The
! licensee did not appear to have a procedural method to ensure that Emergency Plan training would be given to new members of the organization or that all members
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receiving the appropriate training. This weakness was related to the incomplete description of the emergency organization discussed in Section 2.1.
- The Emergency Plan training program relied chiefly upon the Emergency Plan Implementing Procedures for subject material. Thus, deficiencies which existed i in the EPIPs (see Section 5 of this report for a discussion of these deficien-
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cies) were further propagated in the training progra A set of emergency preparedness lesson plans had recently been developed. A review of these lesson i plans indicated that in general the subject courses lacked sufficient depth to l train individuals within the emergency organization in the specific emergency
! response tasks they would be required to perform in an emergency situation. This deficiency was revealed during walk-through demonstrations by the inspectors with selected' members of the emergency organization (see Section 7.2 of this report).
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Training given to Health Physics Technicians and other plant personnel did not appear tc adequately stress the elevated radiation levels and changed nuclide-compositions which could be encountered in a serious, emergency. This was (
attributed, at least in part, to the licensee's concept of responding to I emergencies with an emergency organization basically the same as the normal station organization (as stated in EPIP-1. Appendix 6) and the use of normal operating procedure In addition to the inadequacies identified in the Emer-gency Plan training that was being given, the auditors could not substantiate that meaningful training was being conducted for many of the functional areas of
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emergency activity including repair and corrective actions, decontamination, search and rescue, accountability, communications, radiation protection during emergencies, plant chemistry, analysis of high level samples, radwaste opera-tions, post-accident sampling, emergency classification, and prompt protective action deci sion-making.
Based on the above findings, the following deficiency was identified:
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The initial emergency training and annual retraining program for all plant personnel with emergency response responsibilities was inadequate in that the program did not include classroom training, practical exercises and, where appropriate, hands-on demonstrations of each individual's ability to perform assigned emergency functions. The program also did not include examinations designed to test the individual's knowledge of assigned functional responsibilities and establish performance levels below which immediate retraining was required (50-338, 339/82-05-05)
In addition, the following item should be considered for program improvement:
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Revising EPIP-21 to accurately reflect the training required for each member of the emergency organization, including offsite support groups and identify specialized training requirements for key members of the emergency organization. (50-388, 389/82-05-06)
3.2 Program Implementation Training records for Emergency Plan training were maintained in the files of the Nuclear Training Department. Training was conducted in different departments of the Station organizatio As each phase of the training was completed, the training records were updated. The latest Emergency Plan training session was presented by the Training Department in December 1981. Attendance sheets with the trainee's name, date, course subject, and instructor's name were completed at the end of the training session. When four members of the emergency organization were selected at random, the attendance sheet shcwed they had received Emergency Plan training, but in two cases the training was not entered into the records in the Nuclear Training Department.
Training was given to offsite support personnel in 1980 and 1981. The training included an overview of the Emergency Plan, notification procedures, and basic radiation protection. The training also included a review of the procedure for site access under emergency conditions. A search of the files produced a list of the attendees at the 1980 training session but the attendance records of the 1981 training session could not be locate * J
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Interviews with members of the emergency organization indicated that they had attended the basic Emergency Plan training course conducted by the Nuclear Training Department. This same training course was offered to Emergency Direc-tors, plant operators, and supervisors and technicians with emergency dutie Little of the training conducted by departments outside of the Training Depart-ment appeared to be directed toward emergency response. Walk-through demonstra-tions with plant personnel in the areas of radiation monitoring and surveying, decontamination, post-accident sampling and analysis, ' dose assessment, and prompt protective action decision making indicated deficiencies in the Emergency Plan training pro procedures see (gram as well Section 7.2as of deficiencies this report forinathe Emergency discussion Plan of the implementing walk- -
throughs).
Based on the above findings, the following deficiency was identified:
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Emergency response personnel were not trained in the specific functional areas for which they were assigned responsibility. Key members of the emergency response organization, including the Station Manager, Assistant Station Manager, Operations Superintendent, Technical Services Superintendent, Administrative Services Superintendent and Health Physics Supervisor, had not been provided specialized emergency response training relative to their functional responsibilities during an emergenc In addition, the following items should be considered for improvement:
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Developing administrative controls to ensure that members of the ,
emergency organization receive required Emergency Plan training within the prescribed time period. (50-338,339/82-05-08)
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Developing a procedure to ensure that members of the emergency organ-ization are trained in any pertinent changes to procedures, facilities or equipment which occur between scheduled training session (50-338, 339/82-05-09)
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Developing a systematic method for documenting and maintaining records of Emergency Plan training and retraining. (50-338,339/82-05-10)
4.0 Emergency Facilities and Equipment 4.1 Emergency Facilities 4. Assessment Facilities 4.1. Control Room
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The Main Control Room for Units 1 and 2 is a common room located in the Service Building. The Shift Supervisor and Assistant Shift Supervisor occupy i desks near the center of the Control Room. (The senior reactor operator on j Unit 1 is designated as the Shift Supervisor; the senior reactor operator on l Unit 2 is designated as the Assistant Shift Supervisor.) Because of their
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proximity to each other, there are no apparent communication problems between
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Current copies of the Emergency Plan and implementing procedures as well as other operating and emergency operating procedures were located in the immediate vicinity of the Shift Supervisors' desks. Emergency equipment and instrumenta-tion specified in the Emergency Plan were in place and operable. Common readouts such as meteorological data recorders were readily accessible to both Shif t (
Supervisors.
Based on the above findings, this portion of the licensee's program appears to be adequate.
4.1. Technical Support Center The onsite Technical Support Center (TSC) is an interim facility located on the '
second floor of the Records Building which is a separate building near the main plant structures. It was estimated that it would take no more than a few minutes to walk from the interim TSC to the Control Room.
The TSC is normally used as of fices rj members of the QA Department and other plant personne The licensee stated that there was enough working space to accommodate the personnel assigned to the TSC. EPIP-1, Appendix 6, indicates that 18 supervisory personnel including the Station Manager plus supporting personnel report to the TSC when the facility is activated.
Communication facilities in the TSC included dedicated and backup links to the Control Room, near-site Emergency Operations Facility (EOF), Corporate head-quarters, and State and local agencies. An NRC Health Physics Network telephone was also located in the TSC. When the TSC is activated, the Control Room and E0F are constantly linked with the TSC through two communicators wearing headsets who record incoming data and messages on status boards. There are also two computer links with the Control Room. The first link accesses normal operational Control Room data while the second link is redundant to the first and accesses abnormal data in the Control Room. The second computer terminal is also capable of receiving input from the operator in the TSC giving the TSC the capability to do data reduction and trend analysis. Since the interim TSC is in the Records Building, a complete controlled set of plant drawings, manuals and other records is available.
The interim TSC does not have any special provisions for habitability under accident condition The Emergency Plan states that radiation monitoring equipment is available for both airborne particulate and direct radiation measurement Plant personnel stated that in an emergency, a health physics technician would report to the TSC with the required monitoring equipment.
However, a specific procedure to accomplish this function did not exist nor was there a dedicated emergency kit for the TSC (see discussion in Section 5 of this report).
EPIP-1, Appendix 6, states that if the TSC becomes uninhabitable, the individuals needed to perform the " assessment function" will relocate to the Control Room.
Administrative Procedure ADM-6, " Control Room Access," indicates that only two assessment personnel may enter the Control Room during an emergency. The remaining TSC personnel are to proceed to another appropriate area, such as the j
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Operations Support Center (OSC) or EOF, and await fu'rther instruction The auditors considered the OSC to be inadequate as an alternate to the TSC due to its limited space and lack of facilities. It is also doubtful if the OSC (and EOF) would be habitable if the situation arose to make the TSC uninhabitabl The licensee has committed to provide a permanent TSC meeting regulato ry criteria. The permanent TSC, which was under construction during the appraisal, will be located immediately adjacent to the Control Room in tne Service Buildin ,
Based on the above findings, this portion of the licensee's program appears to be adequate for an interim facility, however the following items should be considered for improvement:
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Developing a procedure for providing personnel and equipment to monitor radiation levels in the interim Technical Support Center. (50-338, 339/82-05-11)
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Developing provisions for the loss of habitability i'n the interim TSC including criteria for the relocation of personnel and the designation of an adequate relocation facility where essential'TSC functions would be preserved. (50-338/339-82-05-15)
4.1. Operations Support Center The Station Lunch Room located on the ground level of the Service / Administrative Building is designated in the Emergency Plan, Section 7.1, as the Operations Support Center (OSC). The personnel who will report to the OSC, as described in EPIP-1, Appendix 6, are operators not required for plant operation, operators scheduled to relieve the onduty shift, fire brigade members, and first aid team members. EPIP-1 indicates that health physics monitoring team personnel will report to the Station Health Physics area. All other support personnel such as electricians and maintenance personnel are to report to their supervisors in their normal assembly areas. The first Shift Supervisor reporting to the OSC is te assume the duties of OSC superviso ,
The Station Lunch Room is in actuality a relatively small, narrow room with automatic vending machines and no tables or chairs. A private branch exchange (PBX) telephone and a Gaitronics paging system extension are located in the OS There are no supplies or equipment maintained in the OSC for outfitting the support teams formed in the OSC. Fire fighting equipment is located in lockers in a hallway in the Turbine Building near the lunch room and first-aid equipment is located throughout the plant. Personal dosimeters, protective clothing, and respiratory protection equipment are located in the health physics are Communication equipment, lights, etc., are located at other work assembly areas in the plan The OSC is served by normal ventilation systems and while its location may afford some protection against direct radiation, there are no special provi'sions for airborne contaminants. The licensee has not made provisions for an alternate assembly area in the event the OSC or other plant work areas become uninhabi-tabl .
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There were no procedures for activating, staf fing, and utilizing the OSC in an emergency other than the paragraph in EPIP-1, Appendix 6, identifying in general terms the groups of employees who were to, report there. The inspectors concluded that the licensee considered the OSC as just an initial assembly area for a limited nuniber of personnel rather than as a dynamic emergency response facilit Based on the above findings, this portion of the licensee's program appears to be adequato; however, the following items shculd be considered for program improvement: (
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Establishing an Operations Support Center .with suf ficient space for assigneo personnel to assemble, form into teams, be briefed, equipped with protective gear, dispatched, and directed. The OSC should include the basic necessa ry* protective equipment and supplies to prepare response personnel to perform their assigned emergency tasks. (50-338,
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339/82-05-12)
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Deve'oping an implementing procedure for activating, staffing and utilizing the OSC in an emergency situation, to include designation of an OSC Supervisor who will be immediately available on all shift (50-338, 339/82-05-13)
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Emergency Operations Facility The Emergency Plan identified the Station Visitor's Center as the interim near site Emergency Operations Facility (EOF). The Visitor's Center is located on Company-owned property approximately one-half mile from the reactor unit For a permanent EOF, the licensee has proposed a central EOF at Corporate headquarters in Richmond in conjunction with a local, near-site EO The auditors were informed during discussions with licensee management personnel that the near-site EOF will be located in the new Training Facility once the facility is completed. Until that time, the Visitor's Center will be the location of the interim near-site EO The near-site EOF is staffed by Corporate personnel. The Vice President-Nuclear Operations is designated as the Recovery Manager and is the senior licensee representative in the EOF. Space has been allocated in the interim near-site EOF for local, State and federal official The principal area of operations in the Visitor's Center is the small auditorium which is cleared of chairs when the EOF is activated and tables are set up for each working group.- Although space in the auditorium was limited, the entire building is available for use in an emergency and thus additional working space is availabl Plug-in telephones and other supplies were stored in boxes in the Visitor's Cente Communication links in the EOF included commercial telephones, a dedicated line to the Technical Support Center, ringdown lines to County and State E0Cs, and NRC Emergency Notification System (ENS) and Health Physics Net-work (HPN) extensions. Radio communication equipment for communicating with L
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field monitoring teams was also available in the EOF. The inspectors noted that the designated NRC location had only one commercial telephone line and the only ENS extension was located in a separate offic No one from the Station orga'nization was identified in Station procedures as being assigned to the E0F for support, security, or communication duties and there was no procedure for activating the EOF. Corporate personnel' indicated that the only requirement to get the EOF operational was to clear chairs, . set up tables and plug in some telephone Even this minimal effort would not be accomplished until af ter Corporate EOF personnel arrived presumably within the (
60 minute time period sp'ecified in Table 5.1 of the Emergency Pla '
Current copies of the Emergency Plan and Emergency Plan Implementing Procedures as well as the Final Safety Analysis Report and site maps were stored at the EO All other records and documents were stored in a file cabinet at the TSC which
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was to be transported to the EOF when it was activated. As there was no proce-dure for activating the EOF, there was no assurance that this material would arrive in a timely manne The interim EOF does not meet habitability requirements, that is, there are no special provisions for ventilation systems or shielding in the facility. As for monitoring the habitability, the Emergency Plan stated that radiation monitoring equipment is available for both airborne particulate and direct radiation mea-surements in the E0F. Dosimeters and TLDs and one beta / gamma survey meter were in the E0F. The licensee stated that a health physics technician would be dispatched to the E0F with appropriate instrumentation in an emergency situatio There was no procedure which explicitly covered this (see Section 5 of thi s report) nor was there a dedicated emergency kit for the EO Based on the above" findings, this portion of the licensee's program appears to be adequate for an interim facility; however, the following items should be considered for improvement:
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Developing a procedure for activating and staffing the interim near-site Emergency Operations Facility. (50-338,339/82-05-14)
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Developing a procedure for providing personnel and equipment to monitor radiation levels in the interim near-site EOF. (50-338, 339/82-05-15)
4.1. Post Accident Coolant Sampling and Analysis The inspectors reviewed the licensee's post-accident coolant sampling and anal-ytical capabilities regarding the ability to obtain and analyze high activity reactor coolant samples during accident situations. The inspectors inspected the interim sampling location which is common for Units 1 and 2, reviewed sampling procedures (see Section 5.4.2.4) and discussed post-accident coolant sampling with licensee management personnel. The inspectors also discussed briefly the new post-accident sampling system being installed. Complete installation of the new system is tentatively scheduled for June 198 J
The post-accident primary coolant sample would be taken at the same location as the normal coolant sample; however, it would be collected at a different sample poin The sample location should be accessible during accident conditions. A licensee representativa ated that accessibility would be reevaluated at the time of an acciden Ine sample lines and collection point were shielded and f radiation doses received by personnel taking the sample should not be excessive.
An area monitor with readout and alarms in the control room and sample room was located in close proximity to the normal sample point. Monitoring by Health '
Physics personnel would be provided at the post accident sample location.
A large shielded cask on a transportable cart was stored at the sample point and would be used to carry the sample to the analytical facilities. According to the licensee, a remote handling tool was provided for handling the sample once in the laboratory:
According to licensee representatives, the sample analysis facility may not be accessible daring an accident depending on the severity of the acciden If the count room was not accessible, the sample could be sent to the Surry Power Station or some other facility to be analyzed.
Instruments and detectors specified in procedures were in place and ready for use. Equipment and tools such as micropipettes, syringes, etc., were available; however, no provisions had been made for special tools and equipment to be used with high activity sample In addition, tne hood area to be used for dilutions and preparation of the sample for counting had no shielding. A licensee repre-sentative stated that if the need arose, shielding might be available from some unidentified location on-site. It appeared that the sample could be taken and analyzed within three hours.
The interim sample system did not provide for a representative sample as there was no recirculation capability on the system. The permanent system will provide this capability.
Based on the above findings, this portion of the licensee's program appears to be adeouate; however, the following items should be considered for improvement:
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Providing shielding for the hood area used for the preparation and dilution of high level samples in the laborator (50-338, 339/82-05-16)
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Developing specific provisions for an alternate facility for analyzing samples if the onsite facility is not accessibl (50-338, 339/82-05-17)
4.1. Post-Accident Containment Air Sampling and Analysis The inspectors reviewed the licensee's post-accident sampling and analytical capabilities to verify the licensee's ability to sample and analyze high activity containment air samples during accident situations. The inspectors inspected the J
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sampling locations for Unit 1 and Unit 2, reviewed the sampling procedures (see Section 5.4.2.4) and discussed post-accident containment air sampling with ticensee management personnel. The inspectors also briefly discussed the new
!ampling system being installe The locations of the Unit 1 and Unit 2 post-accident containment air sample coints appeared to be accessible during emergency conditions. A study of aredicted dose rates based on a postulated severe accident had been made for all areas in the auxiliary buildin A licensee representative stated that condi-tions would be reevaluated at the time of an accident to determine accessibilit The sample lines were not shielded to reduce the radiation doses received by the technician taking the sample, however, the inspectors were told that studies had oeen performed which determined that shielding of the sample lines would not significantly reduce exposure due to the potentially high radiation levels in the
.iuxiliary building. There were no special remote handling tools for allowing the echnician to remain at a distance from the unshielded lines while taking a sampl The locations of the Units 1 and 2 containment air sample points did not have aermanent area radiation monitors. Health physics personnel would provide needed
'nonitoring and dosimetry for the technician takir.g the sampl Provisions had not been made for transporting the sample even though the proce-dures stated that the sample container could read 5 rem per hour on contac l Licensee representatives indicated that some method of shielded transport would be provided before the sample was take Depending on the severity of the accident, the sample analysis facility may not be accessibl'e under accident conditions. Specific provisions had not been made to count the containment air sample in that case, however, the licensee stated that an estimate of the gamma and beta radiation could be obtained. In addition, the sample could be sent to the Surry Power Station or some other facility for analysi No special equipment was provided for handling highly radioactive samples in the analysis facility. The hood area used for making sample dilutions was not shielded nor had provisions been made for temporary shielding to be installed when analyzing high level sample The sampling technique provided for a representative sample of containment ai The sample could be taken and analyzed within a 3-hour perio Based on the above findings, this portion of the licensee's program appears to be adequate; however, the following item; should be considered for improvement:
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Providing special tools for obtaining and handling samples containing high levels of radioactivity. (50-338,339/82-05-18)
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Providing a shielded container for transporting samples containing high levels of radioactivity. (50-338, 339/82-05-19)
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4.1. Post Accident Gas and Particulate Effluent Sampling and Analysis The inspectors reviewed the licensee's capability to sample and analyze high activity gaseous and particulate effluents during accident situation The inspectors inspected the sampling locations for the Unit 1 and Unit 2 process and ventilation system vents, reviewed the sampling procedures (see Section 5.4.2.8) I and discussed post-accident process and vent sampling with licensee management personne The sampling location for the Unit 1 and Unit 2 vent was on top of the auxiliary building. The process vent sample location was on the ground level of the auxil-iary buildin There was no shielding available for either the process or ventilation vent sampling area In addition, no special handling tools were provided for removing and handling the potentially highly radioactive filters and cartridge There were no permanently installed radiation monitors in the sampling area, however, Health Physics personnel would accompany the technician taking the samples. Shielded sample containers were not provided for trans-porting the sample All instruments and detectors used for analysis of the filters and cartridges were in place and ready for us Other special equipment for handling high activity samples in the laboratory were not described in procedures nor were they provide It was estimated that the change-out and analysis of the filters and cartridges from the process and ventilation vents could be performed within 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> Based on the above findings, this portion of the licensee's program appears to be adequate however, the following items should be considered for improvement:
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See items in Sections 4.1.1.5 and 4.1. .1. Post Accident Liquid Effluent Sampling and Analysis The inspectors reviewed the licensee's capability to sample and analyze high level liquid effluents under accident condition The inspectors observed the locations for liquid effluent sampling. The sample locations should be access-ible during accident conditions, however, licensee representatives stated that accessibility would be reevaluated at the time of an acciden According to licensee representatives, the sample analysis facility may not be accessible during an accident depending on the severity of the accident. If the
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count room was not accessible. the sample could be sent to the Surry Power i Station or some other facility to be analyze (
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An area monitor with readout in the control room was located in the proximity of each of the normal sample points. Monitoring by Health physics personnel would be provided at the post accident liquid effluent sample location as necessar Remote handling tools and other handling equipment such as micropipettes and syringes were available for use. However, licensee representatives stated that there was no shielded liquid sample containers availabl The hood area to be used for dilutions and preparation of the sample for counting had no shieldin A licensee representative stated that if the need arose, shielding might be
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dvailable from some unidentified location onsit Instruments and detectors specified in procedures were in place and ready for use.
The liquid effluent sampling system provided for a representative sampl It appeared that the sample could be taken and analyzed within three hours.
Based on the above findings, this portion of the licensee's program appears to be adequate; however, the following items should be considered for improvement:
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See Items in Sections 4.1.1.5 and 4.1.1.6.
4.1. Of f site Laboratory Facilities Alternate laboratory facilities for use by the licensee during emergency situations were available at the Surry Power Station,- approximately 100 miles awa Section 5.3 of the Emer9ehcy Plan listed five other facilities in the State with radiological count laboratories with the closest 'being at the-University of Virginia in Charlottesville, Virgini As indicated in Section 4.1.1.5 of this report, the licensee has not made any specific provisions for utilizing these facilities in an emergency.
The State Department of Health maintains a mobile laboratory with radiological and radio communication capability. This mobile laboratory will be provided to the Station in an emergency as indicated in the letter of agreement. _ The response time was estimated in Section 5.3 of the Emergency Plan to be one hour.
The Emergency Plan Section 7.3.1, stated that installed instrumentation could be moved from the laboratory if required with minimum effort in an emergency. There were no procedures for doing this and discussions with licensee personnel did not f indicate that this was considered a viable option. The licensee did indicate I that consideration has been given to purchasing mobile laboratory facilities but '
this idea is still in the planning stage.
Based on the above findings, this portion of the licensee's program appears to be adequate; however, the following item should be considered for improvement:
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See Item (50-338, 339/82-05-17) in Section 4.1.1.5.
4. Protective Facilities 4.1. Assembly / Reassembly Areas The licensee did not have a designated employee assembly area onsite. In case of an accountability being held without a Station evacuation, as determined by the Emergency Director, Station personnel report to their normal work locations. If a Station evacuation is ordered by the Emergency Director, all personnel except those with emergency duties will proceed to the primary assembly area, Louisa County High School, which is approximately eight miles west-southwest of the Station. Personal vehicles are relied upon for transportation during the evacuation, j
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The assembly area provides indoor space and parking areas sufficient to accom-rodate the potential number of evacuees. Discussions with licensee representa-tives indicated that the possible impact on students and faculty if an evacuation it ordered when school is in session has not been considere The Emergency Pian, Section 6.4.1, states that Station evacuees will be monitored and decontaminated if necessary at the high school but no emergency supplies or equipment for this purpose have been pre positioned for this purpose either at the Station or the high school. An alternate assembly area has not been l designated in case the plume is moving in the direction of the high school .
The Emergency Plan and discussions with licensee personnel indicated that the school itself is the assembly area. However, Section 10. " Emergency Procedures,"
of the General Employee Training Booklet states that all personnel reporting to Louisa County High School will remain in their vehicles and await further
,
instruction Based on the above findings, this portion of the licensee's program appears to be adequate; however, the following items should be considered for improvement:
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Establishing an emergency kit for use at the Louisa County High School assembly area. (50-338, 339/82-05-20)
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Designating an alternate assembly area in case the primary assembly area becomes unuseabl In addition, consider the possible conse-quences of school being in operation when a Station evacuation is ordered. (50-333,339/82-05-21)
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Clarifying the apparent discrepancy on exact location of the assembly area between the Emergency Plan and the General Employee Training Booklet. (50-338, 339/82-05-22)
4.1. Medical Treatment Facilities The auditors reviewed the Emergency Plan and discussed the medical treatment f acilities and treatment of injured personnel with licensee representatives. A j first aid f acility is located on the ground level of the Service Building near the entrance to the Administrative Building. There were no provisions to treat injured and contaminated personnel at this facility. Decontamination of injured personnel would be performed at the Health Physics control poin The medical treatment facility was accessible to a patient on a stretcher. The facility had operating survey instruments which had been calibrated. Communica-tions were available in the adjacent Health Physics of fice The Laundry Room near the Health Physics control point was designated in the Emergency Plan , Section 6.5.2, as an alternate first aid room. The auditors found a limited amount of first aid supplies stored in this area. Licensee personnel stated that they would provide first aid and preliminary decontam-ination in the plant at the scene of the accident. Eleven first aid lockers were located throughout the plant. The lockers contained adequate first aid supplies, however, the lockers did not contain any decontamination supplies or materials to
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prevent the spread of contamination. Dosimetry would be acquired as the First Aid team entered the controlled area. Health Physics personnel would support the First Aid team if radiological hazards were involve '
Approximately thirty individuals are designated as First Aid team members. In addition, many of the station personnel have had Red Cross Multimedia First Aid trainin .
Based on the above findings, this portion of the licensee's program appears to be adequate; however, the following item should be considered for improvement: (
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Including supplies in First Aid lockers inside radiologically con-trolled areas for preliminary decontamination of injured personnel and controlling the spread of contamination. (50-338, 339/82-05-23)
4.1. Decontamination Facilities Discussions with licensee representatives indicated that personnel decontamina-tion facilities had been established at two locations, the Health Physics Control Point (HPCP) and Louisa County High School, the primary offsite assembly are However, the emergency procedures did not formally designate decontamination areas. Medical facilities were located on site near the HPCP decontamination are The HPCP had two showers, two count rate survey meters, two portal monitors, replacement clothing and decontamination supplies including detergents and potassium permanganate. Decontamination procedures for this area were located across the hall in the Health Physics offices. There were provisions for liquid and solid waste disposal at the HPCP decontamination are Liquid waste from this area was discharged to the contaminated drain tank Dedicated decontamination supplies and monitoring equipment were not located at the Louisa County High Schoo Discussions with licensee representatives indicated that an emergency monitoring team would obtain decontamination supplies and monitoring equipment from the HPCP for use at the high school. A licensee representative also stated that an off site monitoring team may be requested to report to the high school and perform monitoring and decontamination. However, decontamination supplies, sufficient replacement clothing, and decontamination procedures were not part of the emergency kits used by the offsite monitoring team Although the high school possesses shower facilities which the Emergency Plan, Section 6.4.1, indicates will be used for decontamination, licensee represen-tatives stated that consideration had not been given to liquid waste disposa Solid waste would be disposed of into polyethylene bags and transported back to the Station for disposa Based c3 the above findings, this portion of the licensee's program appears tc be adeque a; however, the following items should be considered for improvement:
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Providing dedicated decontamination supplies and monitoring equipment for use at the primary offsite assembly area. (50-338, 339/82-05-24)
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Providing for adequate disposal of contaminated waste at the primary offsite assembly area. (50-338,338/82-05-25)
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Ensuring that adequate decontamination procedures are available at each designated decontamination facility. (50-338, 339/82-05-26)
4. Expanded Support Facilities (
The Corporate emergency organization includes an Aaministration/ Services Manager who is responsible for providing administrative, logistic, communications, and personnel support for the response organization. The Corporate Emergency Plan discusses the possibility of utilizing mobile office trailers - placed in the parking lot adjacent to the EOF to support the recovery effort. Provisions for expanded support facilities to accommodate Corporate, contractor '.nd non-licensee augmentation personnel in the event of a prolonged emergency were not indicated in the North Anna Emergency Plan or implementing procedure f Licensee represent 41.ives indicated that,' depending on available space, some of the expanded support force may be assigned to the interim EOF. Other personnel may be assigned to an architectural engineering building near the interim EOF which has a conference room, of fices, office equipment and communication system Based on the above findings, this portion of the licensee's program appears to be adequate; however, the following item should be considered for improvement: '
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Developing more definitive plans and procedures for accommodating an expanded response effort over a prolonged period of time. (50-338, 339/82-05-27)
4. News Center A Public News Center has been established on the second floor of the Mineral Volunteer Fire Department building approximately 6 miles southwest of the Station. The size of the News Center was considered by the inspectors to be marginally adequate. There is a limited amount of space in the interim near-site Emergency Operations Facility for news briefings to small groups of media personne Arrangements have been made for the immediate installation of telephones for the use of the news media. However, there were no provisions for other communication facilities or support services such as electric supply to carry added TV load, copying, PA system, audio visual equipment and security to enable the News Center to receive and transmit factual information to the public of an emergency situation at the Statio '
Based on the above findings, this portion of the licensee's program appears to be adequate; however, the following item should be considered for improvement:
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Developing arrangements for providing communication facilities and support services at the Public News Center. (50-338, 339/82-05-28)
4.2 Emergency Equipment 4. Assessment Equipment 4.2. Emergency K1ts and Emergency Survey Instrumentation The licensee had three emergency monitoring team kits pre positioned at the first-aid station located outside the secured area. Emergency kits and contents were inventoried by the inspectors. Emergency kit supplies were found in place as specified in the Emergency Plan, Appendix 10.5, " Protective Equipment and Supplies." In addition, a full complement of survey instruments were located with the pre positioned supplies in a locked cabinet. However, the emergency procedures did not specify which monitoring instrumentation was to be used with the emergency kit Inventories were currect and equipment appeared to be operable and within calibration. During the inventory, one GM survey meter was found in the "on" position; however, when battery checked, it was still within performance limits.
The licensee's inventory records indicated that emergency supplies and equipment were inventoried and equipment operationally checked on a ' monthly basis as specified in PT-114. " Emergency Kit Inspection." Instruments were maintained and calibrated on a quarterly schedule as specified in Health Physics pricedures HP-3.3.3.1, HP-3.3.3.4, and HP-3.3.3.6. A review of the licensee's calibration records showed that the instrument calibration appeared accurate and that inoperable instruments were repaired or replaced in a prompt manner. However, the licensee representative stated that instruments located with the EMT kits may be removed for calibration for up to one-half day without replacement.
The pre positioned emergency kits and instruments provided sufficient numbers of instruments and supplies to equip the team members for their intended function (i.e., offsite/ site boundary monitoring). However, emergency procedures were not included in the kits. Pre positioned supplies and instruments did not exist at the TSC or EOF facilities or at the Louisa County High School assembly area. The licensee's representative stated that instruments and supplies would be obtained from the Health Physics Control Point (HPCP) for response to the above areas. A review of the licensee's instrument inventory and supplies kept at the HPCP indicated that there were sufficient instruments and supplies to respond ade-quately to the emergency facilities and assumbly areas as well as to perform in plant surveys during an emergency. However, the emergency procedures did not provide guidance on the types and quantity of supplies and instruments to be taken to each emergency facility and assembly area (see section 5.4.2.3).
Personnel that were to be assigned to emergency monitoring teams (EMT) had ready access to all instrumentation, equipment, and supplie Extremity monitoring devices for teams re-entering the facility were issued from the HPCP dose control area. GM instruments used for the detection and measurement of beta / gamma radi-ation fields were readily available at the location of the EMT kits and at the HPCP. Portable ion chambers with beta / gamma distinguishing capability were also readily available for measuring whole body dose rates inplant and offsite.
The licensee's emergency radioiodine and particulate sampling methods used a silver zeolite cartridge and a glass fiber filter paper. The radioiodine sampling cartridges, due to susceptibility to moisture pickup, were stored in
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sealed plastic containers. However, there were no chemical moisture indicators in the contairers to show if cartridges were suitable for use when removed. At least six cartridges were available in each kit for offsite monitoring and numerous cartridges were available at the HPCP for in plant radiciodine moni- /
toring. Sufficient glass fiber filters were available for particulate collection l in the kits and at the HPCP. The licensee appears to have the capability for the detection and measurement of radiciodire concentrations in air of E-03 pCi/cc under field conditions and of particulate activity in air of l 1.0 E-09 pC1/cc, respectivel Based on the acove findings, this portion of the licensee's program appears to be adequate; however, the following items should be considered for improvement:
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Establishing emergency kits or pre positioning sufficient monitoring equipment and supplies for the Technical Support Center, the near-site Emergency Operations Facility, and the Louisa County High Schoo (50-338, 339/82-05-29)
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Providing interim replacement instrumentation for those emergency survey instruments removed for repair or calibratio (50-338, 339/
82-05-30)
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Including appropriate emergern.y procedures in emergency kits. (50-338, 339/82-05-31)
4.2. Area and Process Radiation Monitors The Emergency Plan did not include specific information detailing all the area and process radiation monitors and locations relied upon for emergency detection, classification and assessment. The Emergency Plan in Section 7.3.1.2, " Radio-logical Conditions," provided only examples of area and process radiation monitor locations. The auditors examined the monitors at their locations and the readouts in the Control Room. All monitors appeared to be in place with readouts positioned in the control room to provide easy accessibility. High range monitor
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readouts were located together in one area and each had its own audible alar Discussions with licensee representatives and review of manufacturer's design specifications indicated that the monitors' operating cha.racteristics were consistent with the assessment of accident conditions for which the Emergency Plan is designed to cope. The sensors for all the monitors appeared to be located so that their readouts would accurately reflect their intended use. The ef ficiencies were known such that readouts could be converted to source term units (i .e. , pCi/ml).
The auditors examined procedural controls for maintenance, operability checks, and calibration of area and process radiation monitor A review of the licensee's records indicated that the monitors were properly maintained on a routine schedule with adequate operability and calf bration checks being performed on a shift basis in accordance with PT-37, " Radiation Monitoring Equipment Check." Each monitor had an individual Periodic Test Procedure in the PT-3 series that referenced a specific calibration procedure. The actual calibration
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procedure ~was contained in the Instrument Calibration procedures (ICPs) series.
' Calibration was cerformed at each decade in order to cover the entire range of the monito Based on the above findings, this portion of the licensee's program appears to be adequat .2. Non-Radiation Process Monitors A comprehensive list of non-radiation process monitors relied upon for emergency detection, classification and as.essment was not described in the Emergency Plan or procedure The Emergency Plan described only examples of control room instrumentation. The non-radiation process instrumentation necessa ry for classification and assessment during an emergency situation appeared to ' be in place and operable. All monitor readouts were located in the Control Room and j were readily observabl Based on the above findings, this portion of the licensee's program appears t'o be
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adequat .2. Meteorological Instrumentation '
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The inspectors reviewed the Emergency Plan and implementin'g procedures, inspected the meteorological instrumentation, and discussed the subject with licensee representative The meteorological information from a 50-meter instrumented tower provides the basic parameters (i.s.', wind direction and speed and an '
estimator of atmosphe,ric stability) necessary to perform the dose assessment function. Data from the meteorological measurements system on the 50-meter tower are recorded on strip charts in the Control Room. Vertical temperature differ-ence measurements are recorded redundantly using separate scales on the same chart. Also, meteorological instrumentation on a 10-meter tower provides backup information on strip charts in the Centrol Roo The licensee has maintained an excellent program for inspection and preventive maintenanc The instrumentation in the * Control Room and at the towers is checked daily by plant personnel and is serviced twice a week by corporate per-sonnel. The sensors, electronics and recorders are calibrated quarterly and the wind sensors are replaced semi-annuall The licensee's 50-meter meteorological tower meets the criteria of Regulatory Guide 1.23 regarding instrumentation, siting and exposure of instruments. All sensors appeared to be operable and calibrated at the time of the inspectio Meteorological conditions have been factored into the dose assessment procedur The licensee's meteorological assessment capability is consistent with the characteristics of the Class A model of Regulatory Guide 1.101 (Revision 2).
The Emergency Action Levels (EALs) in EPIP-1, Appendix 2, included initiating conditions related to observable tornado activity and high winds measured at the meteorological tower. During a visit to the Corporate offices, the inspector was informed that a system operations procedure existed which instructed the system operator to inform shif t operations personnel of severe meteorological phenomena l
forecasted for or occurring near the Station. Neither the Emergency Plan nor the procedures contained any reference to this Corporate procedure or indicated the Station response to a severe weather warnin Based on the above findings, this portion of the licensee's program appears to be adequate; however, the following items should be considered for improvement:
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Eliminating the redundant recording of vertical temperature difference on the same chart with different scales in the Control Room. (50-338, 339/82-05-32)
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Developing a procedure for system operators to inform shift operations personnel of severe weather warnings which affect the Statio (50-338, 339/82-05-33) {
4. Protective Equipment 4.2. Respiratory Protection
The licensee had a total of 20 self-contained breathing apparatus (SCBA) reserved for emergency use. Eight SCBAs were maintained in the Control Room and 12 SCBAs are kept outside the Control Room in the fire brigade lockers._ A total of 24 spare bottles are reserved for emergency us In addition SCBAs used for normal operations are located in the Health Physics area. There were no SCBAs dedicated for use in the interim Technical Support Cente The licensee had the capability for refilling SCBA bottles using a cascade system and an extra supply of bottles was availabl The cascade system was located outside of the protected area and should be accessible during accident condi-tion Based on the above findings, this portion of the licensee's program appears to be adequate; however, the following item should be considered for improvement:
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Providing dedicated self-contained breathing apparatus for use in the interim Technical Support Center. (50-338,339/82-05-34)
4.2. Protective Clothing
, Two sets of protective clothing are provided with each emergency ki The
! primary source of protective clothing in an emergency would be the clean change
, room, where approximately 300-500 sets are usually in stock. A backup supply is l available in warehouse 6 which is outside the protected area. There are usually
- 2000 to 3000 sets available in this area. Either one or the other stock should l be available under emergency situation Based on the above findings, this portion of the licensee's program appears to be adequat i 4. Emergency Communications Equipment I The inspectors found the onsite and offsite communications equipment located as
! described in the Emergency Plan, Section 7.2.
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There are adequate means for accomplishing the notification of the NRC, the State, and local authorities on a .24-hour basis. There are back-up communication systems and all communication systems have redundant power source \
The decision to alert and notify the public of an emergency is made by State or local agencies based on information.and recommendations provided by the licensee.
This is accomplished by activating a siren system within the plume exposure path-way Emergency Planning Zone followed by pre-recorded messages on local radio and television stations released through the Emergency Broadcast Syste ,
There are separate Station alarms for fire, alert and evacuation. Within the 3 Control Room, there are appropriate radiation and other abnormal occurrence alarms. When an alarm sounds in the Control Room, a print-out of the alarm is also made in the TSC as well as the Control Room. All alarms appeared to be audible and visible as require Also, they are routinely checked for operability.
Based on the above findings, this portion of the licensee's program appears to be adequate.
4. Damage Control / Corrective Action and Maintenance Equipment and Supplies A limited amount of information on the availability of damage control, corrective action and maintenance equipment and supplies is presented in Section 7.6 of the Errargency Pla The primary source of supplies and equipment would be from normal onsite inventories backed up by additional supplies and equipment from the Surry Power Station. Resources could also be made available from normal vendor listings and Westinghouse and INPO lists.
Based on the above findings, this portion of the licensee's program appears to be adequate.
4. Reserve Emergency Supplies and Equipment This area of the licensee's program was evaluated through discussion with licensee representatives and a review of the limited information in Section 7.6 of the Emergency Plan.
The licensee relies upon the onsite inventory of supplies and equipment to support emergency operation A licensee representative stated that the established inventory level of such items as survey instruments, dosimetry and protective clothing and equipment are adequate to meet at least initial emergency requirement In the event available levels were not adequate to meet emergency needs, compatible supplies and equipment could be obtained from the licensee's Surry Power Station.
Based on the above findings, this area of the licensee's program apears to be adequate.
4. Transportation of A station ambulance is kept near the construction site nurse's statio This could be used in an emergency, but the local rescue squads would be the primary
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source of medical transportatio The Loui sa ' County Rescue Squad has one ambulance and the Mineral Unit of the Louisa County Rescue Squad has' two ambulances. Local ambulance support is covered in letters of agreement with these organizations. An agreement is also in effect with the Spotsylvania County Rescue Squa The Offsite Monitoring Team has a dedicated twin cab; radio equipped, 4-wheel drive pickup truck. The second team out would use the Statiori Manager's radio equipped ca Further transportation would be obtained from the plant ~ motor
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poo Keys would be obtained from the individual or office in charge of the vehicle. Some monitoring points which might be used, especially on the plant perimeter, would require a 4 wheel drive vehicle for acces . Based on the above findings, this portion of the licensee's program appears to,be I adequat .0 Emergency Implementing Procedures 5.1 General Content and Format The licensee had 21 Emergency Plan Implementing Procedures; 8 of the EPIPs had effective cates in 1977. A review of the EPIPs found them, in general, to be incomplete, illogical in flow, and uncoordinated with Corporate, State and local emergency plans and procedures. In particular, EPIP-1, the basic procedure for classifying emergencies and initiating prompt protective actidn decisionmaking was found to be cumbersome, confusing, and difficult to follow. (See Sections 5.2 through 5.5 of this report for a more detailed discussion of individual procedures.)
Each procedure did not specify the individual or organizational element having the authority and responsibility for performing the tasks covered by the proce-dur Emergency Action Levels (EALs) and Protective Action Guides (PAGs) along with the emergency actions or protective actions to be implemented were not clearly specified. The EPIPs did not fully describe the prerequisites and con-ditions that must exist before the specified actions are performed as well as the precautions and limitations to be observed during performance of the actio i
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Action steps were not clearly displayed in a step-by-step sequential fashion. In many cases, more detailed, specific information was given in the Emergency Plan than in the EPIPs. The contrast between the EPIPs and the Abnormal Procedures (APs) and Emergency Procedures (EPs) relied upon by Station operators was especially revealing. The APs and EPs had a logical, step-by-step flow to them and it was apparent that they had been developed with the user in mind and were intended to be useful in an emergency situation. The same could not be said for the EPIP References in the EPIPs to other Station procedures such as Health Physics Procedures, Chemistry Procedures, and Radiological Environmentil Monitoring Procedures, required to complete the detailed actions were generally not included. However, the EPIPs frequently referenced other EPIPs or forms in other EPIPs in such a manner that it was necessary to go back and forth between EPIP .
The-inspectors found that deficiencies noted in the EPIPs were related to weak-nesses observed in walk-throughs of plant personnel in several functional areas of emergency activity (see Section 7.2). The inspectors determined that the EPIPs did not adequately implement the Emergency Plan.
Based on the above findings, the general content and format of all Implementing Procedures appeared to be deficient. For additional details, see the following Sections: 5.4.2.1, 5.4.2.2, 5.4.2.3, 5.4.2.4, 5.4.2.5, 5.4.2.6, 5.4.2.7, 5.4.2.8, 5.4.2.9, 5.4.2.10, 5.4.2.11, 5.4.2.12, 5.4.3.1, 5.4.3.2, 5.4.3.3, 5.4.3.4, and 5. The following actions are required to achieve an adequate program:
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Review all Emergency Plan Implementing Procedures and make appropriate revisions and additions to ensure that the procedures adequately implement the Emergency Plan, are compatible with the emergency plans and procedures of corporate, State and local organizations, and provide reasonable assurance that the necessary emergency response ' functions will be performed in a prompt and effective manne As a minimum, procedures to be revised or developed include the following emergency functional areas: inplant, onsite, and offsite radiological surveys; post-accident sampling and analysis of primary coolant, containment air, stack effluents and liquid effluents; protective actions; evacuation and personnel accountability; personnel monitoring and decontaminatlon; and search and rescue. (50-338, 339/82-05-35)
5.2 Emergency, Alarm and Abnormal Occurrence Procedures The Emergency, Alarm and Abnormal Occurrence Procedures are contained in two sets of Operating Procedures (ops), one for each unit, in the joint Control Room. The ops are divided into three sets of procedures: Normal Operating Procedures, Abnormal Operating Procedures, and Emergency Procedures. .The Emergency Proce-dures reference the appropriate Emergency Plan Implementing Procedures for reactor incidents with potential for a radiological emergency.
Based on the above findings, this portion of the licensee's program appears to be adequate.
5.3 Implementing Instructions The licensee's implementing instructions, for the planned immediate response actions which are required for each emergency condition, are contained in EPIP-1,
" Emergency Classification and Organization Formation, Notification and Communica-tions," dated January 15, 1982. EPIP-1 is a lengthy procedure; including tables, figures and its seven appendices, EPIP-1-is 86 pages in length. Some of the material was noted to be out of date.
The procedure was written for the use of the Shift Supervisor / Emergency Director and while it included some instructions for each class of emergency, the instruc-tions were difficult to extract from the volume of mate-ial in EPIP-1. There were no individual sections in EPIP-1 or separate EPIPs for each class of emergency; i.e., Notification of Unusual Event, Alert. Site Area Emergency, or General Emergency. The inspectors found that it was difficult to start from an initiating condition and follow the required actions through the procedur .
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Reference was made to the appendices and other EPIPs which in turn referred to other EPIPs and back again to EPIP-1. Evidence of the difficulty in using EPIP-1 was revealed during walk-throughs with Shift Supervisors in the Control Room (see Section 7.2 of this report). It was apparent that EPIP-1 was cumber.some, difficult to use, and did not effectively assist the Shift Supervisors in making prompt protective action recommendations to offsite authoritie There are 19 pages of emergency action levels (EALs) in tabular form in Appendix 2 of EPIP-1. The EALs are generally complex and include combinations of several conditions. Several of the EALs are not based on directly observable information or specific instrument readings but refer to limits in the Technical Specifications, sampling and analysis results, and calculated dose results. The EALs as structured in EPIP-1 do not facilitate the rapid classification of emergency conditions by operations personnel . In fact, the classification of major accidents, i.e., loss-of-coolant accident, steam generator tube rupture, main steam line rupture, and fuel handling accident, is made in the Emergency Procedures (EPs) and bypasses the use of the EALs in EPIP-1. The EPs have been developed so that they are understandable, systematic, and useful to plant oper-ators in emergency situation It appeared to the inspectors that the imple-menting instructions and EALs in EPIP-1 were not useful to the operators who have to use the procedur Based on the above findings, the following deficiency was identified:
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Emergency Plan Implementing Procedure EPIP-1 does not contain Emergency Action Levels (EALs) which clearly specify the initiating conditions for classifying accident This procedure is not useful to the Emergency Director in accident situations to classify emergencies, provide prompt notification to off-site agencies in accordance with the criteria of 10 CFR 50, Appendix E. Paragraph I.V.D., or make initial protective action recommendations. (50-338,339/82-05-36)
In addition, the following items should be considered for improvement:
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Removing extraneous material from EPIP-1 and developing individual procedures for EPIP-1 appendices including the determination of the radiological consequences of releases, the Station organization for emergencies, and activation of the Technical Support Center. (50-338, 339/82-05-37)
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Integrating EPIP-1 with the Emergency Procedures for major accidents so that there is a continuous, sequential action flow for plant operator (50-338, 339/82-05-38)
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Develop an EPIP for each class of emergency. (50-338, 339/82-05-39) Implementing Procedures i
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5. Notifications The notification procedures are contained in Sections 3.0 and 6.0 and Appendices 4 and 5 of EPIP-1 and in ADM-29.6, " Notifications." Since the noti-fication procedures are incorporated into EPIP-1, the basic procedure for clas-sifying emergencies, the deficiencies noted in Section 5.3 also impact upon the notification procedure In particular, the action levels are not clearly specified for selectively notifying the different components of the onsite and of f site emergency organizatio ,
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The Shift Supervisor is responsible for making the initial notifications. The assistance o- the Security Department is obtained to notify members of the
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Station emergency organizatio The procedures do not indicate who among the Control Room staff is responsible for maintaining the communication function -
(e.g. , the NRC red phone) after the initial communications are mad Notification to offsite agencies is made by using the Insta-Phone communication system which transmits simultaneously to the State Office of Emergency and Energy Services and the five counties within the plume exposure Emergency Planning Zon The notification procedures did not indicate the notification of onsite personnel or transient members of the public close to the Statio The procedures direct the Shift Supervisor to complete Form EPIP 1.2, " Report of Radiological Emergency," before notifying offsite agencie In addition to identifying the emergency class, Form EPIP 1.2 requires information on meteoro-logy, description of released material (chemical and physical form, estimate of equivalent Curies of I-131 and Xe-133 released, iodine / noble gas ratio), actual or projected dose rates at site boundary, projected dose rates anc integrated dose at site boundary, 2, 5 and 10 miles, and recommended protecti ve actions (i.e., none, shelter, or evacuation). To complete Form EPIP 1.2 in entirety would be a difficult, time cons,uming process which, if the procedure is followed, would delay the notification of offsite officials for some time and prevent the Shift Supervisor from concentrating on critical plant operations. Although pre-determined protective actions are contained in EPIP-1, Appendix 4, it is not clear how or when they enter the notification proces .
The licensee has installed a prompt notification system consisting of 44 sirens in the plume exposure Emergency Planning Zone around the Station. A full-scale test o,f the system was conducted in January 1982. A test was also conducted during the appraisal on February 17, 1982. The test was supposed to be a silent test but although the test procedure was followed correctly, the system was inadvertently activated. A message to the public informing them that it was only a test was issued over the Emergency Broadcast System. The licensee was con-ducting an investigation to the cause of the system activatio Based on the above findings, this area of the licensee's program was determined to be deficient with respect to the procedures usefulness as indicated in Section 5.3.
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In addition, the following items should be considered for improvement:
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Including notification of onsite personnel and transient members of the public close to the Station in the r.otification procedure (50-338, 339/82-05-40)
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Revising EPIP Form 1.2 to be consistent with the requirement for prompt {
notification of offsite authorities upon classification of an emer-gency. (50-338, 339/82-05-41)
5. Assessment Action The inspectors reviewed the licensee's procedures for collecting data to assess accident consequences and the bases of recommendations for onsite and offsite protective actions. The subject was also discussed with licensee representa-tive A single procedure which orchestrated the implementation of the licensee's accident assessment scheme was not available. The following procedure's would be used by the licensee to perform dose assessment:
o EPIP-1 Emergency Classification and Organization Formation, Notifica '
tion and Communications o EPIP-2 Unplanned or Uncontrolled Release of Radioactive Material ,
o EPIP-4 Fuel Handling Accident o EPIP-5 Steam Generator Tube Rupture
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o EPIP-6 Main Steam Line Rupture o EPIP-7 Loss of Coolant Accident '
o EPIP-11 Estimating Release From Radiation Monitoring System Data o EPIP-12 Estimating Release From Station System Inventory Data o* EPIP-13 Estimating Release From Offsite Radiological Data o EPIP-14 Estimating Doses From Release Data l_ o EPIPr15 Estimating Dose From Environmental Data i
The above procedures did not logically coordinate in a step-by-step manner the implementation of accident assessment. The procedures did not provide an initial l dose assessment system which would provide quick dose projections for use in
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notification and recommendation of prompt protective actions.
]
l EPIP-1 provided graphs and nomographs for use in classifying and evaluating emergencies resulting from the actual or potential release of radioactive
! materials. However, there were no instructions or references on how to use the
! procedure. EPIP-2 identified the information that must be obtained and the l
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required actions by the Shif t Supervisor, Operations personnel and Health Physics personnel to calculate the releases of radioactivity depending on the re' ease pathway. EPIP-2 also instructed the initiation of EPIP-11. EPIP-12 or EPIP-13 as appropriate. The procedures were long, cumbersome and not easy to follow. In many cases, necessary reference to other EPIPs were not give There were 10 procedures which provided guidance to the Emergency Director for determining the necessary protective actions to be recommended to offsite authoritic All dose calculations were to be performed by Health Physics personne Once Health Physics determined the release pathway and amount of radioactivity released, the procedures did not specify how the information was to be used and who would be responsible for making protective action recommenda-tion The procedures did not present a unified method for obtaining necessary meteoro-logical and radiological information, making dose projections, and providing recommendations for onsite and offsite protective actions. Walk-throughs with Health Physics personnel demonstrated the difficulties in using the dose assess-ment procedures (see Section 7.2 of this report).
Based on the above findings, the following deficiency was identified:
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The technique for estimating potential offsite doses under accident conditions were inadequate to ensure rapid and accurate dose assessment by shi f t personnel . (50-338,339/82-05-66)
5.4. Of f site Radiological Surveys
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EPIP-16, "Off-Site Air, Contamination and Radiatior Monitoring," described the methods to be used to perform emergency of f-site ' radiological survey The emergency procedures did not specify-the equipment to be used to perform offsite radiological surveys; however, a periodic testing document PT-114. " Emergency Kit Inspection," contained this information. Walk-throughs with Health Physics technicians indicated that the procedure was not clearly written (see Section of this report). The pFocedures did noi. supply a means for all pertinent infor-mation to be recorded such.as instrument ussd,'air sampler flow rates, background .
radiation levels, et \.
Prepositioned survey points were used to determine the precise location where measurements were to be made within the plume EP Detailed maps of the sur-rounding area and a map with the prepositioned survey points indicated on it were provided to the off site monitoring teams; however, the map with the survey points was not detailed enough to find monitoring locations accuratel Each collected environmental sample would be uniquely labeled for later identificatio The emergency procedure did not specify the means by which collected data are provided to the organizational element responsible for,emer-gency assessment functions. Although the Health Physics counting room would be
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the central collection point for environmental samples, the emergency procedures did not formally designate this are s
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The procedure described the communication method to be used, including a backup method (i.e., telephone). However, walk-throughs inoicated that monitoring teams were not adequately familiar with primary communications equipment. Trans-portation for the offsite survey teams would be provided through a dedicated four-wneel drive vehicle and additional vehicles could be obtained from the Station Manager or motor pool. Keys for the dedica'ted vehicle were available at the Health Physics control point and keys for the other vehicles could De obtained at the motor pool. The emergency procedures, nowever, did not describe the means of transportatio Generml-radiation protection guidance was provided in the emergency procedure to include such items as exposure control, protective clothing, equipment, etc. The
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emergency procedure controls to be implemented during an accident appeared to be consistent with the State and local of f site monitoring requirement '
Based on the above findings, this area of the licensee's program was considered deficient with respect to form and content as indicated in Section See item (50-338, 339/82-05-44).
In addition, the following items should be considered for improvement:
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Specifying in EPIP-16 the equipment to be used to perform the offsite radiological surveys and the means for transportatio (50-338, 339/82-05-43)
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Providing in EPIP-16 a means for recording all pertinent information l with respect to of fsite surveys. (50-338, 339/82-05-44)
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Providing detailed maps in EPIP-16 with pre positioned survey points indicated on them. (50-338, 339/82-05-45)
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Indicating in EPIP-16 the means by which collected data are to be provided to the organizational element responsible for emergency assessment functions. (50-338, 339/82-05-46)
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Designating in the procedures a central collection point for all environmental samples. (50-338, 339/82-05-47)
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Assuring emergency monitoring team perscnnel are trained to operate communications equipment. (50-338, 339/82-05-48)
5.4. OnSite (Out-of-Plant) Radiological Surveys EPIP-16, "Off-Site Air, Contamination and Radiation Monitoring," described the methods to be used to perform emergency onsite (out of plant) radiological surveys. The emergency procedures did not specify the equipment to be used to perform site boundary radiological surveys; however, a periodic testing document, PT-114, " Emergency Kit Inspection," contained this information. Walk-throughs with Health Physics technicians indicated that the procedure was not clearly written (see Section 7.2 of this report). The procedures did not supply a means for all pertinent information to be recorded such as instrument used, air sampler flow rates, background radiation levels, et _
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Prepositioned survey points were used to determine the precise location where measurements were to be made at the site boundary. Each collected sample would be uniquely labeled for later identificatio The emergency procedure did not i specify the means by which collected data are proviaed to the organizational element responsible for emergency assessment functions. Although the Health Physics counting room would be the central collection point for site boundary samples, the emergency procedures did not formally designate this are The procedure described the communication method to be used, including a backup l method ( i .e. , telephone) . However, walk-throughs indicated that monitoring teams were not adequately f amiliar with primary communications equipmen Trans-portation for the onsite (out-of plant) survey team would be provided through a l dedicated four wheel drive vehicle and additional vehicles could be obtained from ,
the station manager or motor poo Keys for the dedicated vehicle were available I at the HPCP and keys for the other vehicles could be obtained at the motor pool .
General radiation protection guidance was provided in the emergency procedure to include such items as exposure control, protective clothing, equipment, et Based on the above findings, this area of the licensee's program was considered deficient with respect to form and content as indicated in Section In addition, the following items should be considered for improvement:
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See items in Section 5.4. .4. Inplant Radiological Survey Discussions with licensee representatives indicated that specific procedures addressing the methods and equipment used to perform emergency inplant radio-logical surveys did not exist. The licensee representatives stated that inplant survey methods could be found in several of the Health Physics procedure Licensee representatives indicated that the ability of inplant monitoring teams to perform surveys would rest on prior training and that methods used in of f-site monitoring would be applied to inplant survey Based on the above findings, this area of the licensee's program was considered deficient with respect to form and content as indicated in Section .4. Post Accident Primary Coolant Sampling In response to the reauirements of NUREG-0578 and letters to All Operating Nuclear Power Plants dated September 13, 1979, and October 30, 1979, the licensee developed and implemented OP-12.1, " Sampling System," on an interim basis to sample reactor coolant. The inspectors reviewed OP-12.1, " Sampling System,"
which dealt with obtaining a post-accident reactor coolant sample for Units 1 and 2. The operation of the reactor coolant post-accident sampling system was
discussed with licensee representatives and the inspectors observed the interim post-accident coolant sampling system.
_ _ _ _ _ _ _ _ _ _ _
i The procedure provided a detailed check list to be used while taking the reactor coolant sample. Section 3.0 cf the procedure identified precautions and limits to be taken while obtaining a sample. Specifically, a 2.5 rem whole-body and/or 15 rem extremity exposure for the current quarter limit had been placed on individuals performing the procedure. Tne procedure stated that use of special dosimetry should be considered, but did not identify minimum acceptable dosimetry such as high-range pocket dosimeters, finger rings, etc. In addition, instru-mentation to be used by Health Physics for dose control coverage was not specified. Use of protective clothing and respirators was not addresse The sampling point location was not addressed in the procedure, nor was the method for transporting the sampl Data sheets were not required for taking the coolant sampl There were no provisions for labeling samples for later identificatio The only special equipment identified in the procedure to be used while taking the sample was the shielded cask. The storage location of this (
l cask was not specified in the procedur According to licer,see representatives, analysis of the sample would be performed by Health Physics and Chemistry personnel. As indicated in OP-12.1, Chemistry would perform CP-11 " Boron, High Range, Titration" and CP-32 "E Calculation" and other unspecified chemical analysis. All radioactivity analysis would be done by Health Physics; however, this was not specified in the procedure Based on the above findings, this area of the licensee's program was considered deficient with respect to form and content as indicated in Section .
In addition, the following items should be considered for improvement:
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Specifying in the procedures specific dosimetry, protective clothing and instrumentation to be used by individuals taking post accident samples. (50-338,339/82-05-49)
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Spicifying the sample point location for obtaining post accident samples. (50-338, 339/82-05-50)
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Indicating in the procedures the method of transporting post acciuent samples, the routes to be used, and the storage location of the shielded cask. (50-338, 339/82-05-51)
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Providing for the labeling of all post accident sample (50-338, 339/82-05-52)
5.4. Post-Accident Primary Coolant Sample Analysis The interim post-accident sampling and analysis procedures were reviewed by the inspectors and evaluated during walk-throughs to determine the familiarity of personnel with the procedures and procedural applicabilit There were no specific analytical procedures for high level sample The licensee stated that HP-3.4.1.3, " Health Physics Count Room-Instrument Operation
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Nuclear Data ND 6650 Multi-channel Analyzer," would be used for analysis of highly radioactive samples. The procedure did not address analytical methods or
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the handling of high level samples. In addition, there were no provisions for calibration of counting equipmen .
Based on the above findings, this area of the licensee's program was considered deficient with respect to form and content as indicated in Section '
5.4. Containment Air Sampling The inspectors reviewed OP-12.2, " Post Accident Containment Atmospheric Sampling System," and discussed post-accident containment atmosphere sampling with licensee personnel. In addition, the inspectors observed the interim post-accident containment atmosphere sampling system The procedure provided a detailed check list to be used while taking the containment air sample. Section 3.0 of the procedure identified precautions and limits to be taken while obtaining a sample. Specifically, a 2.5 rem whole-body and/or 15 rem extremity exposure for the current quarter limit had been placed on individuals performing the procedur The precautions indicated where high radiation levels may be expected; however, specific guidance on how to limit exposure was not addresse In addition, the procedure stated that radiation levels on contact with the sample syringe may be as high as 5 rem /hr and recommends a small container such as a tool box be used to transport the sample; however, a tool box would not provide adequate means of shielding for such a high level sample. The procedure stated that use of special dosimetry should be considered, but did not identify minimum acceptable dosimetry such as high range pocket dosimeters, finger rings, et Instrumentation to be used by Health Physics personnel for dose control coverage was not specified. Use of protective clothing and respirators was not addresse The sample points for Units 1 and 2 were clearly specified in the procedure. The only special equipment specified in the procedure is a seven inch needle ana syringe. Specific methods of transporting the sample were not identified and there were no provisions for labeling samples for later identificatio Based on the above findings, this area of the licensee's program was considered deficient with respect to form and content as indicated in Section In addition, the following items should be considered for improvement:
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See items Section 5.4. .4. Containment Air Sample Analysis The interim post-accident sampling and analysis procedures were reviewed by the i inspectors and evaluated during walk-throughs to determine the familiarity of personnel with the procedures and procedural applicability.
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There were no specific analytical procedures for high level sample The licensee stated that HP-3.4.1.3, " Health Physics Count Room-Instrument Operation Nuclear Data ND6650 Multichannel Analyzer," would be used for analysis of highly radioactive sample The procedure did not address analytical methods or the handling of high level sample In addition, there were no provisions for calibration of counting equipmen .
Based on the above findings, this area of the licensee's program was considered deficient with respect to form and content as indicated in Section 5.1.
5.4. Stack Effluent Sampling '
The inspectors inspected installed equipment and sampling locations, discussed post-accident gaseous and effluent sampling with licensee management personnel, and reviewed HP-3.2.2, " Radioactive Waste, Radioactive Gaseous Waste Sampling and Release Rate."
Section 4.1.4, Part 4 of HP-3.2.2 discusses sampling process vent and ventilation vent A or B for radiciodines and particulates during emergency situation The procedure does not provide a detailed checklist for the operation or the sampling equipment nor are the exact sample locations specified.
The use of special sample media such as silver zeolite is addressed in the procedure; however, it does not address the fact'that the silver 7eolite cart-ridge is smaller than the normally used charcoal cartridge and tha+. the silver zeolite must be secured in the cartridge holder. Special equipment to be used while removing and handling the samples are not addressed. The procedure indi-cates that samples are to be placed in plastic bags and carried. Provisions have l not been made for shielded transportation of the potentially highly radioactive sample. Data sheets were included in the procedure, but Section n4.1.4 did not refer to their use. The samples are labeled for later identification.
The procedure does not limit the exposure of the personnel taking the sample nor is the habitability of the areas traversed and occupied verified. A special RWP is not required by the procedure nor is the assistance of health physics per-sonnel for dose contro.1 required. The procedure includes precautions on entering ,
airborne areas and/or high radiation areas, but specific guidance on how to limit exposure was not addressed nor was the minimum acceptable dosimetry such as high range pocket dosimeters, finger rings, etc. , specified.
Based on the above findings, this area of the licensee's program was considered deficient with respect to form and content as indicated in Section 5.1.
In addition, the following item should be considered for improvement:
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Developing a method for securing the silver zeolite cartridge in the holder when obtaining post-accident gaseous sample (50-338, 339/82-05-53)
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5.4. Stack Ef fluent Sampling Analysis The post-accident sampling and analysis procedures were reviewed by the auditors and evaluated during walk-throughs to determine the familiarity of personnel with procedures and procedural applicabilit There were no specific analytical procedures for high level sample The licensee stated that HP-3.4.1.3, " Health Physics Count Room - Instrument Oper-ation Nuclear Data ND 6650 Multichannel Analyzer," would be used for analysis of highly radioactive samples. The procedure did not address analytical methods or the handling of high level samples. In addition, there were no provisions for calibration of counting equipmen Based on the above findings, this area of the licensee's program was considered deficient with respect to form and content as indicated in Section .4.2.10 Liquid Effluent Sampling The post-accident sampling and analysis procedures were reviewed by the inspectors and evaluated during walk-throughs to determine familiarity of personnel with the procedures and. procedural applicabilit There were no specific operating procedures that described the use of emergency liquid effluent sampling equipment. Licensee representatives stated that in an emergency liquid effluent sampling methods would be derived from two routine operating procedures, OP-12.0, " Sampling System," and OP-22.11, " Releasing Radioactive Liquid Waste." These procedures did not provide for comprehensive emergency liquid effluent samplin Based on the above findings, this area of the licensee's program was considered deficient with respect to form and content as indicated in Section .4.2.11 Liquid Effluent Sampling Analysis The post-accident sampling and analysis procedures were reviewed by the inspectors and evaluated during walk-throughs to determine the familiarity of
personnel with the procedures and procedural applicabilit There were no specific analytical procedures for high level sample The
, licensee stated that HP-3.4.1.3, " Health Physics Count Room - Instrument Operation Nuclear Data ND 6650 Multichannel Analyzer," would be used for analysis of highly radioactive samples. The procedure did not address analytical methods i
or the handling of high level samples. In addition, there were no provisions for
!, calibration of counting equipment.
l Based on the above findings, this area of the licensee's program'was considered
! deficient with respect to form and content as indicated in Section 5.1.
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5.4.2.12 Radiological and Environmental Monitoring Program Specific comprehensive radiological and environmental monitoring program procedures did not exist. Discussions with licensee representatives indicated that there were twelve environmental sampling sites at which were located low-volume air samplers with particulate filters and charcoal cartridges and environmental TLD The particulate filters and the charcoal cartridges were changed out on a weekly basi TLDs which were changed both quarterly and annually were located at the environmental monitoring sites. Additionally, two
,TLDs were reserved for emergency purposes in each of the 16 EPZ sectors. These TLDs were changed out on a quarterly basi Four control sites, located in populated areas, were also equipped with emergency TLD EPIP-17, "Of f-Site Water and, Foodstuf f Monitoring," specified certain types of environmental samples to be taken (i.e., water, animal forage, milk, etc.), but did not specify the methods by which these samples would be obtained. Routine samples were collected by a Station biologist. Licensee representatives stated that the emergency monitoring teams would rely on prior training for the know-ledge of how to obtain needed samples and where the emergency TLD sites were locate All environmental samples were sent, on a routine basis, to a vendor for radiological analysi Licensee representatives stated that they would attempt to perform radiological analysis during an emergency; however, there were no procedures to provide guidance in this are Based on the above findings, this area of the licensee's program was considered deficient with respect to procedure form and content as indicated in Section . Protective Actions 5.4. Radiation Protection During Emergencies The inspectors reviewed the licensee's Emergency Plan and procedures. There was not an overall procedure governing the implementation of a radiation protection program during emergencies. Radiation protection was generally discussed in the emergency procedures and some specific procedures were available that discussed particular areas of radiation protection. Certain routine radiation protection procedures were referenced for use during emergencies. However, licensee repre-sentatives stated that the majority of routine procedures relied upon during emergencies were not specifically reference Further, these routine procedures did not generally reflect their applicability during emergency situation Specific controls for emergency conditions, were discussed in general, but no specific procedures existed. Changing and unusual conditions were not considered in the emergency procedures. Also, plans for expanding the respiratory protec-tion program in the event of an' accident were not described in the procedure .
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1 Procedures did not exist which described how and by whom all Health Physics functions would be performed, nor the priority in which they would be performe Based on the cbove findings, this area of the licensee's program was considered deficient wi: respect to procedure form and content as indicated in Section 5.1.
f In addition, the following item should be considered for improvement:
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Developing an overall procedure for radiation protection durine emergencies which assigns responsibilities and priorities for the radiation protection of emergency workers. (50-338, 339/82-05-54)
5.4. Evacuation of Owner Controlled Areas Evacuation of the Station is described in detail in Section 6.4.1.1 of the Emergency Plan and conducted in accordance with EPIP-8, " Evacuation and Access Control Onsite."
EPIP-8 does not specify action levels which require evacuation of specific areas, buildings and the site. The location of the assembly area is specified in both the Emergency Plan and EPIP-8, but directions to the assemaly area are only in the Emergency Plan and not in EPIP-8. Evacuation routes are not marked within the plant and neither the primary nor the secondary routes to the assembly area, Louisa County High School, are marked. The potential problems arising from a Station evacuation during the time school is in session have not been addressed either in the Emergency Plan or EPIP-8 (see Section 4.1.2.1).
EPIP-8 makes provisions for specific announcements to be made v'r the PA system to direct personnel actions during an emergency. The procedure does not make reference to the accountability or personnel monitoring / decontamination proce-dure Notification of individuals in the owner contro,lled area is discussed in Section 6.4.1.1 of the Emergency Plan, but is not covered by the EPIP Based on the above findings, this area of the licensee's program was considered deficient with respect to procedure form and content as indicated in Section .4. Personnel Accountability The plant relies on a combination of audible alarms and PA announcements,to inform personnel of the emergency condition and required actions. Accountability is discussed in Sections 5.2.1, 5.2.2, and 6.4.1 of the Emergency Plan and the accountability procedures are contained in EPIP-9 and ADM-SPIP-22 (Security).
If accountability is directed without Station evacuation, personnel report to normal work areas for accountabilit Visitors, non-VEPC0 workers without security badges, and personnel with series 2000 or 3000 security badges report to the Security Building. If accountability is directed with a Station evacuation, personnel without emergency assignments clear through Security, turning in their security badge ___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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The implementing procedure and + % security procedure both specify that Security and other department heads 'd' surn in their accountability reports to the Emergency Director. The Emergency Director will determine what action is to be taken in regard to missing personne The Emergency Plan discusses responsibility for completion of accountability ir.cluding identification of missing individuals within 30 minutes and maintenance of continuing accountability. EPIP-9 does not provide for either requiremant and makes no reference to a search and rescue procedur Based on the above findings, this area of the licensee's program was considered f deficient with respect to procedure form and content as indicated in Section In addition, the following items should be considered for improvement:
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Establishing accountability procedures with the capability for completing an accountability within 30 minutes. (50-338, 339/82-05-55)
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Providing for continuing accountability af ter the initial accoLnta-bility report. (50-338, 339/82-05-56)
5.4. Personnel Monitoring and Decontamination The procedures did not provide for the monitoring of all individuals during an emergency. EPIP-10, " Personnel Monitoring and Decontamination," provided for the monitoring and the decontamination of injured personnel and emergency workers.
l HP-3.1.7, " Personnel Dosimetry - Personnel Decontamination," provided specific details about the methods of decontamination and the supplies to be used during decontaminatio Although the Emergency Plan indicated that an offsite monitoring team would have responsibility for monitoring and decontamination at the offsite assembly area, the emergency procedures did not specifically address this subject. In addition, the procedures did not address the availability of decontamination supplies to be used at the of fsite assembly area (reference section 4.1.2.3). Further, the emergency procedures did not address monitoring and decontamination at emergency response facilities, such as the Control Room and the EO The procedure provided a means for recording the names of individuals found to be contaminated, the level of contamination, the survey instruments used, and the methods used for decontamination. However, the procedures did not provide for a listing of personnel frisked and found not to be contaminate Contamination action levels, which would require further assessment, were not found in the emergency procedures; however, Section 6.5.2 of the Emergency Plan, ;
" Decontamination and First-Aid," indicated that the emergency procedures shall !
specify the levels of permissible radioactive contamination for workers and equipmen The emergency procedures did not provide correlation between contamination levels and specific decontamination procedure Problem contamination cases were to be referred to the Supervisor of Health Physics or his designe _ _______ _ ________________________________ _
The emergency procedures did not describe the means for providing collected data to the organizational element responsible for radiation protection during emer-gencie Based on the above findings, this area of the licensee's program was considered deficient with respect to procedure form and content as indicated in Section In addition, the following it m should be considered for improvement:
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Establishing contamination action levels which are correlated with specific decontamination procedures. (50-338, 339/82-05-57) .
5.4. OnSite First-Aid / Rescue Actions to be taken for a serious injury or illness were delineated in EPIP-3,
" Injured Personnel ." The procedure discussed, in general terms, the im.nediate actions to be taken by the individual (s) discovering an injured person (s). In addition, the procedure discussed alerting the Station of an injury, initiating other required procedures, and contacting the Medical College of Virginia, the agreement medical facilit The procedure did not specifically address the ;
methods to be used by the first-aid team for finding, treating, transporting and l handling injured and contaminated individuals. Guidance was not given on radia-tion protection for the first-aid team, performing preliminary decontamination, or preventing the spread of contamination (see Section 4.1.2.2).
-The procedure briefly addressed the criteria for using the MCV medical facilities and initiating the MCV-VEPCO Radiation Emergency Pla Based on the above findings, this portion of the licensee's program appears to be adequate; however, the following item should be considered for improvement:
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Providing guidance for the First-Aid teams en radiation protection; treating, transporting and handling of contaminated persons; and preventing the spread of contamination. (50-338,339/82-05-58)
5. Security During Emergencies Procedures for security support during emergencies include the following:
ADM-SPIP-09, Security Emergency Respons ADM-SPIP-22, Security During Operational Emergencie ADM-SPIP-34, Control Room Access During Emergencie .4 ADM-SPIP-35, Response to Security Contingency Event Security personnel are relied upon to perform certain predetermined action These include maintaining Station security, assisting in personnel accountabil-ity, providing escort service for offsite emergency personnel and vehicles to I facilitate their access to the Station. and assisting in the evacuation of buildings. These procedures were devaloped in accordance with the requirements of 10 CFR 7 _ . - .. . -- - . . - . _ .- - .- -- . - .
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Based on the above findings, this portion of the licensee's program appears to be j adequate.
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5. Repair / Corrective Actions i
- The licensee did .not have'an implementing procedure which described the concept
- of operations for repair or corrective action activites or the formation and I
control of emergency repair teams. Emergency exposure limits for response per-
<
sonnel were discussed in Se: tion 6.5.1 of the Emergency Plan and the procedures a for authorizing emergency exposures, exposure guidelines, and health physics consideration were contained in EPIP-18. " Emergency Exposure Criteria." Dis-cussions with licensee personnel established that the emergency organization will rely upon regular plant operations, maintenance, and Nealth physics procedures during an emergenc .
.
Based on the above findings, this area of the licensee's program was considered deficient with respect to procedure form and content as indicated in Section . Recovery i
Section 9.3 of the Corporate Emergency Response Plan (CERP) provides the means for the Corporate Response Manager, in consultation with the Recovery Manager,
Emergency Director and members of the Corporate -Emergency Response Team, to announce that the recovery phase is beginning. Sections 9.0 and 9.1 of the CERP
] provide for an evaluation of plant operating conditions as well as onsite and
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offsite radiological conditions to be considered in reaching the decision to
! enter the recovery mode of operations. Notifications to be made before a l recovery mode may be assumed are specified in Section 9.2 of both the Emergency Plan and the CERP. Key positions in the recovery organization are identified in Section 9.4 of the Emergency Plan and in Sections 3.0 and 5.0 of the CERP. The l CERP provides guidance for limitation and management of radiation exposures.
I Specific criteria and procedures will be developed when required, considering maximum protection for plant personnel and the public.
I Based on the above findings, this portion of the licensee's program appears to be adequate.
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! 5. Public Information f i
.
The dissemination of information to the news media during an emergency situation l is a Corporate function and is described in the Corporate Emergency Response Plan l (CERP) and implemented in CPIP-2. The CERP identifies the organizations involved j in news dissemination, specifies their locations and provides ways of contacting the Interim provisions have been made for the initial dissemination of
,
information to the news media prior to the establishment of the licensee's Public News Center. The utility spokesman is clearly identified. Provisions have been
- made for coordinating information among the various spokespersons of the various organizations and groups and sources of information to be used by the
} spokesperson are adequately specified. Provisions for rumor control, including i responding to public inquiries separate from the news media, and coordination of j the news information function with other organizations have been made.
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E;ased on the above findings, this portion of the licensee's program appears to be adequat .5 Supplementary Procedures S. Inventory, Operational Check and Calibration of Emergency Equipment, Facilities and Supplies I The emergency procedures did not provide a specific inventory listing of all
! equipment reserved for use during emergencies nor did they specify the location ,
of the equipment. The frequency at which emergency equipment was to be calibra-i ted was specified in Health Physics procedures HP-3.3.3.1, HP-3.3.3.4, and HP-3.3.3.6 (see Section 4.2.1.1). Inventories and operational checks were performed on a monthly schedule as specified by Performance Test, PT-114, j " Emergency Kit Inspection." Extra batteries for the emergency equipment were on
- a change-out schedule of every six months; however, the batteries were not dated when placed in emergency inventories. Equipment not inventoried on a routine basis was also checked on a monthly basi However, operational checks of i
emergency communications located with the emergency kit supplies were not
!
performed.
!
The responsibility for the performance of the emergency equipment readiness checks and for correcting any noted deficiencies was not delineated in the
,
emergency procedure Based on the above findings, this portion of the licensee's program appears to be adequate; however, the following items should be considered for improvement:
-
Developing specific procedures for the inventory and operational check
. of all emergency equipment and supplies; including an inventory listing l of all equipment reserved for use during emergencies and its locatio (50-338, 339/82-05-59)
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Delineating the responsibility for emergency equipment readiness and for the correction of any noted deficiencies and developing a system
, for assuring replacement of limited shelflife supplies prior to end of
- life. (50-338, 339/82-05-60)
i l 5. Drills and Exercises Station exercises and drills are administered in accordance with Sections 8. and 8.1.3 of the Emergency Plan and EPIP-21, " Training and Emergency Prepared-
, ness," by the Emergency Planning Coordinator and in accordance with a scenario
- developed in advance. Inspection of records showed that all drills and exercises l were conducted at the required frequencies.
'
Annual exercises are conducted which involve participation with Federal, state
! and local agencies. Critiques of each exercise are held and comments from
'
qualified observers are invited. EPIP-21 requires that the Station Manager will issure that any deficiencies identified by the critique are addressed and appro-
'
priate action is taken.
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Status reports of deficiencies identified in the June, 1981, exercise were reviewed. A licensee representative stated that the reports were not issued at any fixed period, but instead were issued as corrective actions were completed.
Individuals assigned responsibility for each corrective action were not identified and, for the most part, corrective action due dates were not specified.
Provisions are made for holding backshif t drills and exercises in Sections 8.1.2 and 8.1.3 of the Emergency Plan and in EPIP-21.
Based on the above findings, this portion of the licensee's program appears to be adequate; however, the following items should be considered for improvement: I
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Reporting the status cf corrective actions for deficiencies identified during drills and exercises within a fixed period, such as quarterl (50-338, 339/82-05-61)
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Labeling each item of corrective action determined for a deficiency identified during a drill or exercise with the name or title of the individual assigned responsibility for completion, and a due date for completion of the corrective action. (50-338, 339/82-05-62)
5. Review, Revision and Distribution Section 8.2 of the Emergency Plan states that the Emergency Plan and Emergency Plan Implementing Procedures are formally reviewed by the System Nuclear Safety and Operating Committee (SNSOC) annually and that revisions to the Emergency Plan and EPIPs are reviewed and approved by the SNSOC prior to distribution.
Telephone numbers are reviewed each quarter as specified in Section 8.5 of the Emergency Plan. Records were reviewed to determine that changes in the Plan and Implementing Procedures were distributed in accordance with the distribution list. The records also indicated that the distribution was correct.
Based on the above findings, this portion of the licensee's program appears to be adequate.
5. Audits The Emergency Plan and its associated Implementing Procedures are audited by the Station Quality Assurance (QA) Department. An audit was performed in October 1980 and another audit estimated to be 75"o complete was currently in progress at the time of the appraisal . The frequency for the audit of the emergency pre-paredness program was established in the Station Technical Specifications, Section 6.5.3.1.C, and in the QA Manual, Section 18, as once every two years.
The Emergency Plan, Section 8.4, also stated that an audit will be conducted every two years .' 'The auditors informed QA personnel that 10 CFR 50.54 (t)
reouires a review of the emergency preparedness program at least every 12 months.
The station audits involved a review of the Emergency Plan, inspection of facilities and equipment, and discussions with station personne Criteria for the review were extracted from NUREG-0654 and NUREG-0696. In addition, the current ongoing audit was being conducted in accordance with the questions
_ _ _ _ _ _ _ _ _ _ _ _ _ - . _ ______________J
contained in the NRC inspection document, Temporary Instruction 2515/55,
" Emergency Preparedness Implementation Appraisal Program." The QA Department intends to rely on TI 2515/55 in future audits of the emergency preparedness program at North Anna.
Deficiencies identified in the audits were documented and corrective actions were tracked until all open items were closed ou Formal reports were prepared of the audit findings and the followup corrective actions.
Based on the above findings, this portion of the licensee's program appears to be adequate; however, the following item should be considered for improvement:
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Revising the Technical Specifications, QA Manual, and the Emergency Plan to indicate that audits of the emergency preparedness program will be conducted at least every 12 months, as required by 10 CFR 50.54 (t).
(50-338, 339/82-05-63)
6.0 Coordination With Offsite Groups 6.1 Of f site Agencies The inspectors discussed offsite support with licensee representatives, reviewed training records, and visited State and local agency representatives in order to assess the licensee's coordination ef forts with of fsite agencies.
The inspectors met with the Operations Officer and other personnel of the State Office of Emergency and Energy Services and toured the State Emergency Operations Center in Richmond, Virgini During the tour, the inspectors examined the equipment for activating the Early Warning System and issuing messages over the Emergency Broadcast System.
The inspectors discussed the State's role in a radiological emergency, the response time to get the EOC fully operational, and the process for arriving at a protective action decision assuming an actual or projected of fsite release of rad i oac ti vi ty . State personnel expressed complete satisfaction with the coordination efforts of the licensee and it was apparent that the State and the licensee had a close working relationship.
The inspectors met with the County Administrator of Louisa County and the Emergency Services Coordinator and Radiation Defense Of ficer of Spotsylvania County. Louisa and Spotsylvania Counties cover the majority of the 10-mile plume exposure pathway Emergency Planning Zone. The inspectors discussed the emergency organizations, response times, and the protective action decision making process in each County. The local officials indicated that they were satisfied with the cooperation ard coordination efforts of the licensee. The Spotsylvania officials expressed some concern over the recent inadvertent activation of the Early Warning System. Various emergency organizations within the two counties had participated in drills and exercises at the North Anna Power Station.
The discussions with offsite officials indicated some hesisitancy in the use of predetermined protective actions based on the licensee's classification of an emergency and, hence, the potential for some delay in reaching a protective action decision especially during non regular hour Based on the above findings, this portion of the licensee's program appears to be sdequate; however, the following item should be considered for improvement:
-
Reviewing the predetermined protective actions in State, local and licensee emergency plans to ensure consistency with NUREG-0654, Appendix 1, especially for General Emergency conditions, and providing training for offsite decision. makers in this subject are (50-338, 339/82-05-64)
6.2 General Public Provisions have been made for the dissemination of emergency planning information to the public within the plume exposure Emergency Planning Zone (EPZ), including the transient populatio The information is coordinated with State and local agencies and is updated and disseminated at least annually. Information provided the public tells how they will be notified and what their actions should be in the event of an emergency. Dissemination of this information is accomplished by mailing brochures and cards and placing special transient information brochures in motels and recreation areas within the EPZ. Emergency information is also scheduled for publication in local telephone books. The information is in a form likely to be available in a residence during an emergency. The brochures contain elementary information on radiation and provide a contact for additional informa-tion.
Based upon the above findings, this portion of the licensee's program appears to be adequate; however, the following item should be considered for improvement:
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Posting in public access areas, such as picnic areas, beaches and boat ramps, within the 10-mile EPZ, Emergericy planning information .fo r transients using nearby Lake Anna. (50-338,339/82.-05-65)
6.3 News Media The licensee has a program commitment described in the Corporate Emergency Response' Plan for familiarizing the news media with emergency plans, points of contact for release of public information, and information about radiation. The program commitment is on an annual basis and has been conducted at least once.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
7.0 Drills, Execises and Walk-Through Observations Program Implementation The drills and exercises required by the Emergency Plan and procedures have been conducted in accordance with the established procedure, EPIP-21, " Training and Emergency Preparedness." Critiques of exercises were written. Twelve of nine-teen improvement items identified in the last exercise (June 6,1981) had been resolved (see Section 5.5.2 of this report for specific comments).
Based on the above findings, this portion of the licensee's program appears to be adequat .. _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _
7.2 Walk-Through Observation 7. Emergency Detection (EAL Recognition) and Emergency Classification Tne inspectors conducted walk-throughs in the Control Room on several different shifts with the Shift Supervisors and Assistant Shift Supervisors on duty. The Shift Supervisors have the responsibility and authority to function as the Emergency Director in the initial stages of an emergenc Thus, the Shift Supervisor position is one of the most critical in the emergency organizatio The Shift Supervisors were given information on plant conditions and stack
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monitor readings associated with postulated accidents and requested to walk-through their respons The assumed conditions were derived from, but not identical to, the emergency action levels (EALs) in Appendix 2 of EPIP-1. An example scenario was as follows: Saturday day shift. both units operating 100.; '
reactor trip Unit 2; containment pressure increasing; safety injection fails to function; containment radiation monitor increasing; vent monitor reads 10' CP , The Shif t Supervisors responded by going to the Emergency Procedures (EPs) which classified the accident into one of the major accident categories; i.e.,
loss-of-coolant accident, steam generator tube rupture, et The EPs then referred the Shift Supervisors to EPIP-1, " Emergency Classification and Organization Formation, Notification and Communications." It was at this point that the Shif t Supervisors began to experience difficultie EPIP-1 is a cumbersome, difficult to follow, nonsystematic procedure (see Section 5.3 of this report). The Shift Supervisors were required to refer to several other EPIPs to complete the classification proces In fact, the Shif t Supervisors had prepared packages of EPIPs which could be pulled out depending on the initial assessment in the EP For example, the prepared package for a loss-of-coolant accident contained EPIPs 1, 2. 7, 8, 9, 11, 12 and 1 In addition to the number of procedures, the Shift Supervisor using the package was required to jump back and forth between procedures. For example, Step 1.2 of EPIP-1 says for a loss-of-coolant accident to initiate EPIP-7. EPIP-7. Step 1.2, {
says initiate EPIP-1 and, for further guidance, initiate EPIP-2. At this point three EPIPs would have been initiated which presumably required the Shift Supervisor to simultaneously complete all three. Invariably several procedures would be spread out across and around the Shift Supervisor's desk in the Control Room and it became difficult to follow the classification proces Another reason for breaking the EPIPs down into packages was that the 3-ring binder in which the EPIPs were kept was thick and clumsy to handl As there were no tabs, it became very tedious and frustrating to leaf through the binder to find individual EPIPs and EPIP form The Shift Supervisors had dif ficulty in completing Form EPIP-1.2, the basic notification form. EPIP-1.2 is a complex form which requires several different categorien of informatio To complete the form, a Shift Supervisor had to (1) classify the emergency, (2) determine areas affected, (3) recommend pro-tective actions. (4) characterize the release, (5) determine the meteorological conditions, and (6) calculate actual anc projected dose rates and integrated dose at the site boundary, 2, 5 and 10 miles. While the information in Form EPIP- is important information which will eventually be required in determining the
. _ _ _ _ _ _ _ _ _
appropriate response, it is not necessary in order to make the initial emergency classification and notification of offsite agencie None of the Shift Super-visors were able to complete Form EPIP-1.2 in what would be considered a timely manner Several Shift Supervisors indicated they would wait for a sample to be taker, and analyzed or for Health Physics personnel to complete a dose calculation before making offsite notification It was noted that the Shift Supervisors never referred to the graphs and nomograms in Appendix 1 of EPIP-1 for assistance in evaluating the radiological consequences of the postulated releases, and gave only passing reference to the EALs in Appendix 2 of EPIP- The Shift Supervisors verified that they had attended the basic 8-hour Emergency Plan training course in which all 21 EPIPs are reviewed. This same course is ,
given to Emergency Directors, Supervisors with emergency duties, and health physics, chemistry and instrument technicians. Only a relatively small part of this training was devoted to emergency detection, classification and notification s procedures (see Section 3.1).
Despite the problems observed in classifying emergencies, the inspectors were favorably impressed by the dedication and professionalism of the Shif t Super-visors. The inspectors had the oppo'rtunity to observe the operators respond to a reactor scram on a back shif t. In this case, it was not necessary to refer to the EPIPs but a Shift Supervisor indicated the difficulty they had in using the EPIPs under actual conditions. The inspectors concluded that the problems encountered in the Control Room in classifying emergencies and making timely notifications were directly related to the confusing and unwieldy EPIPs which the Shift Supervisors were forced to rely upon, the licensee's inappropriate utili-zation of the concept of EALs, and a weak Emergency Plan training progra . Notifications The County and State ringdown loop (Insta-Phone) was used to put out a test message on a back shift. The State E0C and the five Counties within the plume exposure pathway Emergency Planning Zone were contacted and responded in an expeditious manner. The inspectors concluded that the Insta-Phone notification system is an efficient and effective means for notifying offsite agencie However, as discussed in Section 6.1, follow-up interviews with officials of the State and Louisa and Spotsylvania Counties and a review of the protective action decision making process indicated the potential for some delay in the process for making prompt protective action decisions especially during non regular hours.
s
! 7. Dose Calculations
!
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A walk-through using appropriate EPIPs was performed to determine if individuals could demonstrate the basic skills and knowledge necessary to perform dose calculations. The walk-through started in the Control Room where EPIP-2, i " Unplanned or Uncontrolled Release of Radioactive Material," was initiate Af ter .the Shift Supervisor, with the assistance of shif t operators, performed the appropriate steps, data required in EPIP-2 was sent to the Health Physics Depart-i ment where a technician was assigned to perform the calculations. The inspectors
, explained to the technician that he was to perform all calculations as if he were
! the shift technician leader in an accident situatio The technician was not
- aware that EPIP-2 and EPIP-11, " Estimating Release From Radiation Monitoring System Data," should be initiated. He discussed with the inspectors the need to l
._- _ _ _ . . _- . . . _ - _ . - _. _ . ___ -_ _- - - _ _ _ .. _ -- . _ . -
take samples to perform the dose calculations. At the time, he said there was no way that he knew of to interpret the monitor reading in CPM that had been given j hi After performing some calculations on assumed sample data from vent
.
samples, the technician realized that he must initiate EPIP-11. The technician
'
demonstrated the ability to perform the steps in EPIP-11, but could not complete j the dose assessment program which required the use of several procedure The technician stated that he had received Emergency Plan training but it had
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been some time ago and the opportunity to do dose calculations had been limite Discussions with licensee representatives indicated that training on all EPIPs was performed once a year. This is the only training given on use of the dose assessment procedures. The inspectors concluded that the problems observed in i performing the dose calculations were the result of confusing procedures and lack of training specific to the individual's emergency response function (see Sections 3.1 and 5.4.2).
7. Off-Site Environmental Sampling and Analysis The inspectors conducted a walk-through of the licensee's offsite monitoring capability. A scenario was established to an offsite monitoring team selected at random by an Assistant Supervis6r of Health Physics. The offsite monitoring team consisted of two individuals assigned from the Health Physics Sectio The inspectors accompanied the individuals, made observations, proposed questions and
, discussed the ;rocedures.
, The monitoring team was requested to proceed to a given site boundary monitoring
poin They obtained a' dedicated vehicle, supplies, and instrument for this l purpose. Upon arriving at the monitoring location, the team began to perform j sampling specified in the emergency offsite monitoring procedure. One individual
- obtained a GM meter and proceeded to locate the hypothetical plume. However, the j individual exhibited confusion as to the exact method by which the plume would be
, located. Further, he did not utilize the ionization chamber provided in order to accurately measure the exposure from the plum ,
.
The other individual demonstrated a lack of knowledge that the air sampler should
, be kept out of the rain (it was raining at the time) by such means as placing it -
under the raised hood or in the truck cabin. When analyzing the particulate i
filter and silver zeolite cartridge for radiation levels, they were not separated i to obtain individual measurements. Also, because the team had neglected to take ,
with them the available rate meter compatible with the appropriate beta / gamma probe, the air samples had to be evaluated using the GM meter. Upon further .
, questioning, it became clear that the team members thought that using the GM
! meter was the proper technique; they never consulted the applicable area of the procedure for guidance.
- The procedure required the team to communicate with the plant by means of two-way
. radi However, the radio was not operational, and the team members did not I appear to be aware of alternate communication methods. The team members conjectured that their inability to make contact with the plant was because of their own lack of familiarity with the two-way communications system. Later it i was confirmed that the radio was in f act not operational.
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Based on the observations during the wall-through, it was evident that the procedures were not clear and that the training of monitoring team members was not adequat .
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ATTACHMENT 1 Persons Contacted Licensee Personnel
'
J. H. Ferguson, Executive Vice President Power '
l *R. H. Leasburg, Vice President Nuclear Operations W. L. Stewart, Manager Nuclear Operations and Maintenance
- R. Cartwright, Station Manager E. W. Harrell, Assistant Station Manager ,
- S. L. Harvey, Superintendent Operations
- A. H. Stafford, Supervisor Health' Physics
- A. L. Hogg, Manager Quality Assurance '
- J. A. Hanson, Superintendent Technical Services
L. B. Jones, Supervisor Chemistry
- F. P. Miller. Supervisor Quality Assurance Operations
- J. W. Martin, Corporate Director of Emergency Planning i *E. M. Topping, Corporate Emergency Planning Coordinator
- T. A. Carder, Emergency Planning Coordinator
- W. W. Cameron, Corporate Director Chemistry and Health Physics
- E. Fellows, Staff Assistant (Mgr.)
- J. R. Harper,' Superintendent Maintenance M. L. Johnson, Assistant Supervisor Health Physics R. F. Anderson, Shift Supervisor J. R. Hayes, Shift Supervisor R. C. Starr, Shift Supervisor
- V. C. West, Shift Supervisor
! J. C. Lancalis, Assistant Shift Supervisor
. R. O. Enfinger, Assistant Shif t Supervisor i C. G. Meyer, Assistant Shift Supervisor
- R. D. Garner, Supervisor Nuclear Training j J. B. Breeden, Nuclear Training Coordinator G. E. Pederson, Nuclear Training Coordinator
,
L. E. Retzer, Fire Marshal T. Abercrombie, Assistant Instrument Supervisor
,
j In addition to the above, several technicians, craftspersons, operations personnel and clerical support were interviewe Other Organizations
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N. S. McTague, Operations Officer, Virginia Office of Emergency and Energy Services
H. Allard, Virginia Office of Emergency and Energy Services
- W. Eib, Virginia Office of Emergency and Energy Services l C. E. Kube, County Administrator, Louisa County H. Kennon, Sheriff, Louisa County i R. Scott, Emergency Director, Spotsylvania County
! H. Lewis, Radiation Defense Officer, Spotsylvania County
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-p- -
g 4y -yy. +- . - --y.- , m-s-me -
p_- p -- _y-. , y , _- -- + -%- p--. -
- D. F. Johnson, Senior Resident Inspector
- G. R. Jenkins, Chief, Emergency Preparedness Section
- D. B. Matthews, Section Leader. Emergency Preparedness Licensing Branch
- Attended Exit Meeting
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ATTACHMENT 2 Emergency Plan Deficiencies Based on the results of th'e NRC's review of the North Anna Power Station Emergency Plan (Revision 1, January 15,1982), the following deficiencies have been identified: (References in parentheses are to criteria of NUREG-0654, Revision 1). (A.1) The Emergency Plan does not explicitly state that 24-hour per day manning of communication links is provided by each organizatio . (A.3) Letters of agreement with some emergency response support organization are missin . (A.4) The Emergency Plan does not clearly specify by title the individual in the licensee organization who is responsible for assuring continuity of resource . (B.5) The Emergency Plan does not contain a detailed description of the emergency organization and does nct identify responsibilities for each functional area of emergency activity. The Emergency Plan provides no statement regarding meeting the minimum staffing requirements of Table B-1, NUREG-0654, by July 1, 1982, and Table 5.1 of the Emergency Plan does not satisfy the objectives in Table B-1 of NUREG-0654 for the 30 and 60 minute augmentation of the emergency organizatio . (B.6) The block diagram in Figure 5.4 of the Emergency Plan indicates that all onsite and offsite components of the emergency organi-zation report to the Emergency Director. This illustration is not consistent with the emergency organization as expressed in other sections of the Emergency Plan and completely ignores the sub-stantive role of the Recovery Manager in the near-site Emergency Operations Facilit . (B.9) The services to be provided by contractor and private organi-zations are not adequately described in the Emergency Plan or covered by letters of agreemen . (C.2) There is no indication that the licensee is prepared to dispatch representatives to principal offsite governmental emergency operations center . (C.4) No letters of agreement are included for the organizations listed in Section 5.3.2 of the Emergency Pla . (D.1) The Emergency Plan fails to meet the criteria for the emergency )
action level (EAL) schemes in Appendis 1 to NUREG-0654 as noted belo _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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Unusual Event
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Initiating Condition 1 (SI initiated). The EALs should include indications of flow in one or more of the SI system '
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Initiating Condition 2 (Radiological Ef fluents). The relevant gaseous and liquid alarms are not listed with the specific parameters or equipment {
status that will establish this class of emergency. Also the requirement for laboratory analysis should be droppe Verification of an alarm by instrument reading should suffic Initiating Condition 3 (Fuel damage). An EAL for rate of fuel failures should be adde Alert
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Initiating Condition 1 (Severe loss of fuel cladding). The EAL for the rate of fuel failure is not addresse In addition, the use of a 1200 F core exit temperature rather than the more common 700 F should be justified.
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Initiating Condition 2 (Failure of one steam generator tube with loss of i offsite power). Increasing radiation levels at the air ejector monitor or in the steam generator blowdown are not totally reliable for diagnosing a steam generator tube ruptur Other symptoms should be added, such as increasing water level in the steam generator and changes in pressurizer pressure. The suggestions in NUREG-0818 should be considere Initiating Condition 4 (Steam line break with significant primary to -
secondary leakage). EALs based on radiation levels in the steam generator blowdown and in the condenser exhaust should be added to cover possible additional failures of steam generator tubes caused by increased pressure differentia Initiating Condition 6 (High radiation levels). The requirement for a confirmatory Health Physics survey should be dropped as a precondition for declaring an Alert unless it can be completed within 15 minutes of the initial alarm in order to ensure that offsite authorities are promptly notified . as per NUREG-0654, Appendix 1. In addition, a containment high range monitor reading should be added to the EA Initiating Condition 12 (Fuel damage). The requirement for analysis by Health Physics should be dropped unless it can be completed .within 15 minutes of the initial alar Site Area Emergency
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Initiating Condition 2 (Degraded core with possible loss of coolable geometry). An EAL for high core temperature should be adde Initiating Condition 5 (Steam ?ine break with significant primary to secondary leakage and indication of fuel damage). Using the primary to secondary leakage rate existing prior to the steam line break as a basis for the EAL is acceptable. However, additional failures of the steam generator
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tubes may occur because of increased pressure differential caused by the steam line break. EALs based upon radiation levels in the steam generator blowdown and in the condenser should be added. In addition, the use of a 1200 F core exit temperature rather than the more common 700 F should be justified.
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Initiating Condition 10 (Major damage to spent f uel). The requirement for analysis by Health Physics to confirm the release of radioactive material from the fuel before activating tFe Emergency Plan should be dropped.
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Initiating Condition 13 (Radiological effluents). The requirement for confirmation by Health Physics should be dropped unless this action can be completed within 15 minutes of the initial indication of an acciden Consideration should be given to the use of other indicators to confirm effluent readings. Also, the EAL should be stated in terms of dose rate rather than dose at the site boundary.
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Initiating Conditions 15 (Severe natural phenomena) and 16 (other hazards).
The requirement that the reactor units not be in cold shutdown should be dropped. Occurrence of any of these conditions is grounds for a Site Area Emergency regardless of whether or not the units are in cold shutdown.
General Emergency
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Initiating Condition 1 (Radiological effluents). The Emergency Plan refers to 2 rem whole body and 12 rem thyroid doses at the site boundary rather than the 1 rem /hr whole body and 5 rem /hr thyroid dose rates specified in Appendix 1 NUREG-065 It should also be noted that Appendix 1, NUREG-0654, refers to effluent monitor readings corresponding to 1 rem /hr whole body and 5 rem /hr thyroid dose rates at the site boundary rather than the' site boundary dose rates themselves. Effluent monitor readings are missing from the EA In addition, the EAL should contain other plant parameters (e.g. , radiation levels in containment with leak rate appropriate for existing containment pressure) to project site boundary dose rates. All acticns specified in the EAL to confirm the plant condition should be accomplished within 15 minutes or sooner from the time at which operators recognize than an emergency has occurred.
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Initiating Condition 2 (Loss of 2 out of 3 fission product barriers). ine Emergency Plan includes EALs for LOCAs but not for steam generator tube ruptures. In addition, an EAL for inadequate subcooling should be added tu the LOCA EALs. Also, the use of 1200 F as a core exit temperature indicating a loss of fuel clad integrity rather than the more common 700 F needs to be j usti fied .
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Initiating Condition 3 (Security). A General Emergency should be estab-lished if the Control Room or any other vital area is occupie .
(D.2) The following initiating conditions in NUREG-0654, Appendix 1, were not addresse Unusual Event: 4, 5, 7, 8, 9,11 and 17
- Alert: 10
- Site Area Emergency: 9
- General Emergency: 7 1 (E.6) The Emergency Plan should be revised to reflect the current status of the emergency public notification syste . (G.1) The specific needs of the handicapped are not addressed in the licensee's public information progra .
1 (H.2) The Emergency Plan should be revised to describe the final selected design for the Emergency Operations Facility.
1 (H.6) The Emergency Plan fails to indicate if the radiological monitors and sampling devices are in accordance with the minimum require-ments of the NRC Radiological Assessment Branch Technical Position for Environmental Radiological Monitoring Programs.
1 (H.7) The Emergency Plan does not address providing for offsite radio-logical monitoring equipment in the vicinity of the nuclear facility.
1 (H.9) The Emergency Plan fails to indicate if the OSC has adequate capacity to accommodate reporting personnel. Supplies and equip-ment are normally kept at the Health Physics office or warehouse and will be transferred to the OSC as needed. However, the location of the Health Physics office and warehouse in relation to the OSC is not indicated nor is it clear that.the transfer of equipment can be easily accomplishe For example, will the movement of equipment and materials be delayed by having to enter or cross controlled access areas or by avoiding exposure to radiation.
1 (H.10) The Emergency Plan does not specify that equipment will be inspected after each use or if the calibration schedule complies with the vendors' specifications.
1 (H.12) The Emergency Plan does not identify a central point for.the receipt and analysis of all field monitoring data and coor-dination of sample media.
1 (H.5) The Emergency Plan does not describe the provisions for access to meteorological information by the EOF, TSC, the NRC Incident Response Center, and the appropriate State agenc .
20. (I.10) The Emergency Plan does not list all of the key isotopes (i.e. ,
those given in Table 3 of NUREG-0654) nor are there provisions for estimating integrated dose from the projected and actual dose rates and for comparing these estimates with protective action guide . (J.1) The Plan fails to indicate the time established for warning and advising onsite personnel of an emergency situatio . (J.10.a) The Plan does not _ include maps showing evacuation areas,
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relocation centers in host areas, and shelter area The map showing sampling and monitoring locations (Figure 7.7) does not include designators as prescribed in Table J-1, NUREG-065 . (J.10.b) The Plan does not include a map showing population distribution by evacuation area . (K.5) Although the Plan on page 6.43 defines the action level for decontamination as 1000 dpm/100 cm 2, it is not clear if the level applies only to contaminated personnel or also includes supplies, instruments and equipment. A table showing the decontamination action levels for personnel, equipment and areas would be helpfu . (N.1) The Plan does not indicate that exercises and drills are conducted according to NRC and FEMA rule !
26. (N.2) The Plan does not address the need to include the aspect of understanding the content of messages as part of communication drill In addition, communications and recordkeeping are not addressed as part of Radiological Monitoring Orill . (P.7) The listing of implementation procedures does not include the sections of the Plan to be implemented by each procedure'. ,
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