IR 05000338/1987005

Insp Repts 50-338/87-05 & 50-339/87-05 on 870406-10.No Violations or Deviations Noted.Major Areas Inspected: Emergency Preparedness Program

ML20213H112
Person / Time
Site:	North Anna
Issue date:	05/01/1987
From:	Decker T, Tabaka A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20213H108	List: IR 05000338/1987005 ML20213H104
References
50-338-87-05, 50-338-87-5, 50-339-87-05, 50-339-87-5, IEIN-86-098, IEIN-86-98, NUDOCS 8705190150
Download: ML20213H112 (8)

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/ 'o  NUCLEAR REGUL ATORY COMMisslON j  - ' REGION li g  j  101 MARIETTA STREET, *  t'  ATLANTA, GEORGIA 30323 -

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14AY 015 Report Nos.:- 50-338/87-05 and'50-339/87-05-Licensee: . Virginia Electric and Power Company Richmond, VA 23261

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Docket Nos: 50-338 and 50-339 , License Nos.: NPF-4'and NPF-7

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Facility Name: North Anna Power Staticn - >

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Inspection Conducted: A ril p-10,1987 Inspector: MM dA' e 4.[ '

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A. E. Tabaka // p -f Date Signed

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Accompanying Personnel: L. K. Cohen * ', , , . Approved by: M/2 / < ,, -

T. R. Decker, Section Chief .

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Date Signed Division of Radiation Safety and Safeguards-

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SUMARY Scope: This routine unannounced inspection was to evaluate selected areas of the emergency preparedness progra Results: Of the areas inspected, no violations or. deviations were identifie R705190150 870501 PDR ADOCK 05000338 G PDR _ . _ . _ . , - . . _ _ _ . . . _ _ - , ~ . _ _ .

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. REPORT DETAILS Persons Contacted Licensee Employees

*E. Smith, Jr. , Assistant Station Manager
*R. Enfinger, Superintendent, Operations L. Edmonds, Superintendent, Training
*C. Michadick, Supervisor, Training PSS-RP
*S. Harrison, Coordinator, Emergency Planning (Station)
*F. Cox, Supervisor, Emergency Planning (Corporate)
*R. Driscoll, Manager, Quality Assurance J. Stall, Superintendent, Technical Services G. Mocarski, Loss Prevention Coordinator W. Madison, Training Supervisor F. Thomason, Supervisor, Health Physics (Corporate)
*D. Hickman, Jr., Supervisor, Health Physics (Station)

J. Yates, Security Shift Supervisor

*J. Leberstien, Nuclear Safety and Licensing M. Bowling, Shift Supervisor S. Mittan, Shift Supervisor W. Anthes, Shift Supervisor S. Crossman, Assistant Shift Supervisor Other licensee employees contacted included engineers, operators, security office members and office personne Nuclear Regulatory Comission
*J. Caldwell, Senior Resident Inspector
* Attended exit interview Exit Interview (30703)

The inspection scope and findings were sumarized on April 10, 1987, with those persons indicated in Paragraph 1 above. The inspector described the areas inspected, and one finding Ws identified as a possible violatio This item was related to protective actions for non-essential onsite personnel as described in Paragraph During a telephone conversation on April 28, 1987, the inspector informed a licensee representative that further review by the Regional Office determined that the finding in question was to be classified as an unresolved item * based on its possible generic significance and the possible need for further agency action on this subjec The licensee did not identify as proprietary any of the materials provided to or reviewed during this inspectio * Unresolved items are matters about which more information is required to determine whether they are acceptable or moy involve violations or deviation . 2 Licensee Action on Previous Enforcement Matters (92702)

(Closed) Unresolved Item 50-338, 339/86-16-01: Ambiguous deleoation of the responsibility to notify offsite agencies and recommend protective actions. The inspector reviewed Re:Ision 11 to the North Anna Emergency Plan which was clarified to indicate that the Recovery Manager would assume the responsibilities for notifying State and local governments and recommend offsite protective actfons to the State upon activation of the LE0 In addition, the January 1987 revision to the VEPC0 Corporate Plan was also modified to indicate this transfer of responsibility from the Station Emergency Manager to the Recovery Manage The inspector had no further question . Emergency Detection and Classification (82201)

Pursuant to 10 CFR Part 50, Appendix E, Sections IV.B and IV.C, this program area was inspected to determine whether the licensee used and understood a standard emergency classification and action level schem The inspector reviewed the licensee's classification procedure, EPIP 1.01,

" Emergency Manager Controlling Procedure," and pertinent portions of the Emergency Plan. The event classifications in both the Plan and procedures were consistent with the four standard classes required by regulatio The classification procedure appeared cumbersome; however, licensee personnel demonstrated their familiarity with and ability to successfully use the procedure. No errors were identified in the procedures which would appear to lead to an incorrect classificatio Selected emergency action levels (EALs) specified in EPIP 1.01 and the Plan were reviewe Those EALs examined appeared consistent with the initiating events specified in Appendix 1 of NUREG-0654. Many of the licensee's EAls were based on specific plant parameters obtainable in the Control Room, in addition to radiological monitoring results. The units and ranges used for the EALs appeared consistent with those for Control Room instrumentatio The following notification procedures were reviewed:

EPIP 2.01, Notification of State and Local Governments EPIP 2.02, hotification of NRC

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The Plan, in addition to the controlling procedures for each emergency class, included criteria for initiation of offsite notification These procedures required that offsite notifications be made to the State and local governments within 15 minutes of emergency declaration and to the NRC no later than 1 hour after declaratio .

The inspector discussed with licensee representatives the coordination of EALs with State and local officials. Licensee documentation showed that the annual EAL review with State and local government officials was held March 26, 198 Interviews were held with two shift supervisors to verify that they understood the relationship between core status and core damage indicators such as containment dome monitor, high-range effluent monitor, containment hydrogen monitor and fuel temperature indicator. These interviewees appeared knowledgeable of the various indicator The responsibility and authority for classification of emergency events and initiation of emergency actions were clearly described in the Emergency Plan and implementing procedures. Interviews with selected key members of the emergency organization revealed that these personnel understood their responsibilities and authorities in relation to accident classification, notifications, and protective action recommendation Walk-through evaluations involving accident classification problems were conducted with several individuals designated as interim and alternate Station Emergency Manager All personnel interviewed promptly and properly classified the hypothetical accident situations presented to the The inspector reviewed licensee documentation of actual licensee events for the period October 1985 to August 1986, to verify that events which had occurred during this time were properly classified and that the notifications were made within the applicable time frames. In general, documentation was in order and actions appropriate to the emergency were performed in a timely manne No violations or deviations were identifie . Protective Action Decision-making (82d2) Pursuant to 10 CFR 50.47(b)(9) cnd (10) and 10 CFR Part 50, Appendix E, Section IV.0.3, this area was inspected to determine whether the licensee had a 24-hour capability to assess and analyze emergency conditions and make recommendations to protect the public and onsite worker The inspector discussed responsibility and authority for protective action decision-making with licensee representatives and reviewed pertinent portions of the licensee's Emergency Plan and procedures. The Plan and procedures clearly assigned responsibility and authority for accident assessment and protective action decision-makin Interviews with members of the licensee's emergency organization revealed that these personnel understood their authorities and responsibilities with respect to accident assessment and protective action decision-makin .

The inspector reviewed the Plan and pertinent EPIPs to determine that the licensee had made adequate provisions for protecting onsite and offsite individuals in the event of an emergency. The licensee had the criteria and methodology in place for making offsite protective action recommendations based on core status and radiological release data consistent with those required by regulation. However, the licensee had not provided for a similar level of protection for onsite, non-essential personnel in the event of an emergency. Specifically, the licensee's Plan and procedures did not explicitly require the evacuation of non-essential personnel upon declaration of a Sito Area or General Emergency in accordance with NUREG-0654, Section II. The licensee's onsite evacuation criteria contained in Section 6.4.b of the Emergency Plan, EPIP-1.04, " Response to Site Area Emergency," EPIP-1.05, " Response to General Emergency," and EPIP-4.07, " Protective Measures," was based solely on radiological parameters. This was contrary to regulatory guidance where such decision-making shall be based on event classification / plant conditions. Sole use of radiological data to determine the protection to be afforded site personnel neither explicitly nor implicitly met the protective action guidance presented in NUREG-0654. This variance from published Federal guidance was discussed as a possible violation during the exit meeting. After further review, it was determined that this issue would be identified as an unresolved item pending the completion of an agency review on the possible generic applicability of this issue (Unresolved Item 50-338,339/87-05-01).

Walk-through evaluations involving protective action decision-making were conducted with three individuals designated to fill the position of Station Emergency Manage Personnel interviewed demonstrated familiarity with the use of procedures for making onsite and offsite protective actions, and they understood the need for timeliness in making initial protective action recommendations to offsite cfficial Given hypothetical situations, these individuals were able to formulate the I appropriate protective action recommendation for the public with one exceptio For a security event classified as a General Emergency, the intervicwees consistently recommended the incorrect offsite protective action (shelte 2 mile radius, 5 miles downwind). Review of EPIP 1.05,

" Response to a General Emergency" indicated that the correct PAR (2 mile radius evacuation) was contained in the procedure; however, it was categorized under an inappropriate title leading to the incorrect PA The licensee committed to rectify this procedural deficiency in a future revision to the Plan (IFI 50-338,339/87-05-02).

The licensee's procedures made provisions for contacting responsible offsite authorities on a 24-hour basis. Back-up communication links with offsite authorities were available and included insta-phone loop, microwave, commercial, and radio system One unresolved item was identifie ,

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. 5 Knowledge and Perfonnance of Duties (Training) (82206) Pursuant to 10 CFR 50.47(b)(15) and 10 CFR 50, Appendix E, Section IV.F, this area was inspected to determine whether emergency response personnel had been provided appropriate training and that they understood their emergency response roles and could perfonn their assigned function The inspector reviewed Section 8.3 of the licensee's emergency plan which described the emergency preparedness training program and requirements in detail. In addition, selected lesson plans were also evaluated. Based on these reviews, the inspector determined that the licensee had established a formal training progra Training records for selected members of the emergency organization for 1986 and 1987 were reviewed. These records indicated that personnel designated as interim, primary, and alternates in the emergency organization were- provided with training appropriate to their assigned positions. Although no individuals were identified on the "on-call" list whose training had lapsed beyond the annual plus or minus 25 percent frequency for training, a consistent trend of training being performed beyond the twelve months but within the three month grace period was observed. Continual use and reliance on the extension period is contrary to the intent of annual trainin Discussions with licensee representatives and review of training tracking records, indicated that several groups provided the training required by the Emergency Plan, but no centralized and formalized method was in place to coordinate and track the training provided by the individual groups to ensure that all training is given on an " annual" frequency over a long term period. Licensee representatives agreed to evaluate the situation (IFI 50-338, 339/87-05-03).

The inspector also reviewed documentation coacerning the training of offsite support agencies. These records showed that the groups indicated in Section 8.4 of the Plan were invited to participate in annual trainin Actual participation by the groups appeared satisfactory. Meeting agendas and course outlines indicated that the required training subjects were include The inspector conducted walk-through evaluations with selected key members of the emergency organization, specifically, two shift supervisors, an alternate Station Emergency Manager, and a communicato During these walk-throughs, individuals were given hypothetical sets of emergency conditions and asked to respond as they would during an actual emergency as well as questioned concerning their overall role and responsibilitie The individuals demonstrated their familiarity with their emergency response roles, emergency detection and classification, protective action decision-making, and notification No violations or deviations were identifie _ . _ . _

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. 6 Licensee Audits (82210) Pursuant to 10 CFR 50.47(b)(14) and (16) and 10 CFR 50.54(t), this area was inspected to determine whether the licensee had performed an independent review or audit of the emergency preparedness progra Records of audits of the program were reviewed. The records showed that an independent audit of the program was conducted by the licensee's Quality Assurance Department beginning February 9, 1987 (Audit No. N-87-02). This audit fulfilled the 12-month frequency requirement for such audits. The 1987 post audit meeting had not yet been conducted nor had the report been issued; however, the inspector reviewed the preliminary finding Review of past audits and discussions with QA representatives indicated that the State and local interfaces as well as drill and exercise performance were adequately evaluated. Audit findings and comments were presented to appropriate station and corporate management. A review of station records indicated that the licensee had complied with the five-year audit report retention requirement Sections 8.5 and 8.6 of the Emergency Plan required drill evaluations and exercise critiques, respectively. Licensee documentation for drills and exercises held since the last inspection indicated that such activities were performe The records further showed that deficiencies and weaknesses were identified as well as recommendations for corrective actio The licensee's program for followup on audit, drill, and exercise findings was reviewe There were several mechanisms in effect for tracking the progress of such items. The Quality Assurance Department tracked audit findings through its Quality Assurance Tracking and Trending System. The group documented progress on each item until satisfactory responses and corrective actions were completed. Other items such as drill and exercise findings are formally tracked on the Connitment Tracking System. A review of selected findings indicated that identified items had received proper licensee attention and corrective actions were completed in a timely manne No violations or deviations were identifie . InspectorFollowup(92701) (Closed) IE Information Notice 86-98: Offsite Medical Services. The inspector verifiee that the licensee had established an agreement with a hospital for the treatment of contaminated individuals; however, no back-up arrangements had been made. According to an April 1980 SER, the primary facilities are adequate, and no back-up hospital is required for the treatment of site personne The adequacy of these current arrangements and the need for back-up hospitals for treatnent of the general public, however, will be evaluated by FEMA at a later dat .

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b. (Closed) Inspector Followup Item 50-338, 339/86-03-01: Back-up E0F Comunication System Based on the results of the licensee's test of the LEOF comunication capabilities after a loss of AC power, the inspector determined that the licensee had adequately provided for back-up comunication Although comur.ications capability would be significantly inhibited, sufficient battery and AT&T backed telephones would remain should primary AC power be los c. (Closed) Inspector Followup Item 50-338, 339/86-16-04: Followup on exercise identified items. A sampling of self-identified exercise items was evaluated and found to be adequately corrected and/or addressed. }}