IR 05000338/1989024

Insp Repts 50-338/89-24 & 50-339/89-24 on 890710-14.No Violations Noted.Major Areas Inspected:Functional Areas of Emergency Preparedness Program,Including Training,Audit Repts,Distribution of Changes to EPIPs & Staff Augmentation

ML20245L343
Person / Time
Site:	North Anna
Issue date:	08/07/1989
From:	Gooden A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20245L342	List: IR 05000338/1989024 ML20245L338
References
50-338-89-24, 50-339-89-24, NUDOCS 8908220087
Download: ML20245L343 (9)

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4g 74 NUCLEAR REGULATORY COMMISSION

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g e.,,, 101 MARIETTA ST., N.W.

{ ATLANTA.T.EORGIA 30323 Al5 07199

$y Report Nos.i 50-338/89-24 and 50-339/89-24

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~ Licensee: Virginia Electric and Power Company Glen Allen, VA 23060 Docket Nos.: 50-338 and 50-339 License Nos.: NPF-4 and NPF-7 Facility Name::; North Anna-1 and 2 Inspection Conducted: July 10-14, 1989 Inspector: O. d o b 6- t/- 89 A. Gooden Date Signed Approved by: f. la P/7/E7 W. Rankin, Chief / Date Signed

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Emergency Preparedness Section Emergency Preparedness and Radiological

' Protection Branch

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-Division of Radiation Safety and Safeguards SUMMARY

~ Scope:- _

This routine, unannounced . inspection was conducted in the area of emergency I preparedness. Several functional areas of the emergency preparedness program

'were reviewed'to determine if the program was being maintained in a state of

. operational readiness for responding to emergencies. This included a review of training, changes to the emergency organization and/or management control .i s .!

(ystem, distribution of changes to the Emergency Plan Implementing ProceduresE i emergency kits or equipmen _q l

Results:

Within the areas inspected, one non-cited violation (NCV) was identified for j failure to replace respiratory protection equipment in accordance with

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Section 3.3 of Periodic Test Procedure 1-PT-114 " Emergency Kit Inspection"  ;

(Paragraph 3). Noted program strengths were as follows: (1) there appears to l

be a strong)the program;-(2 commitment by Plant Management testing, maintenance, and upgradesintosupport of Warning the Early the emergency Siren responsei System (EWS); (3) timely distribution of EPIP changes to copy holders; and  ;

(4) the onsite emergency organization was adequately staffed and trained in j

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accordance with the Emergency Pla e07 PDR O ADOCK 05000338 PDC e_ __

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REPORT DETAILS Persons Contacted Licensee Employees R. Beckwith, Coordinator, Corporate Emergency Planning

• Bowling Assistant Station Manager J. Collins, Corporate Supervisor, Emergency Planning T. Crawford, Control Room Operator M. Crist, Supervisor, Operations Training D. Devor, Shift Supervisor

• S. Harrison, Coordinator, Corporate Emergency Planning J. Johnston, Shift Supervisor

• P. Kemp, Supervisor Licensing

• J. Leberstien, Engineer - Licensing J. Lencalis, Senior Instructor Nuclear W. Madison, Senior Emergency Planning Instructor

• B. McBride, Coordinator, North Anna Emergency Planning

• A. Stafford, Superintendent, Health Physics S. Tipsword, Senior Instructor, Health Physics Training Other licensee employees contacted during this inspection included engineers, operators, security force members, technicians, and administrative personne NRC Resident Inspector

• J. Caldwell

• Attended exit interview Emergency Plan and Implementing Procedures (82701)

Pursuant to 10 CFR 50.47(b)(16), 10 CFR 50.54(q), and Appendix E to 10 CFR Part 50, this area was reviewed to determine whether changes were made to the program since the last routine inspection (August 1988), and to assess the impact of these changes on the overall state of emergency preparedness at the facilit The inspector reviewed Section 8.0 of the licensee's Emergency Plan regarding the development, review, approval, and distribution of changes to the Emergency Plan and EPIPs. Station Administrative Procedures Nos. ADM-6.6 (Distribution of Station Procedures), ADM-5.4 (Processing New and Revised Procedures and Deletion of Procedures), and DCM-57 (Procedure for EPIPs) implement Section 8.0 of the Emergency Plan. Since the last inspection, although page changes were submitted for NRC review and approval, a revision to the Emergency Plan had not occurre _ - _ _ _ _ _ _ _ - _ _

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The aforementioned page! chang'es ? involving the licensee's augmentation -

staffing and arrival times, were being' reviewed by both the NRC Regional Office Staff and Headquarters Emergency Preparedness Staff to determine if changes were. consistent with NRC requirements. The inspector reviewed n documentation to verify that changes to randomly selected EPIPs had been done. in accordance with procedural requirements governing the review and

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approva ' The distribution of EPIPs to' copy holders was reviewed covering the period-June 21, 1988 to May 16, 1989 for randomly selected EPIPs. EPIP changes were distributed , in ' a timely manner in accordance with DCM-5 Documentation for selected ' EPIP changes was reviewed to verify that  ;

submittals were made to NRC within 30 days of the approval date. No problems were note Controlled l copies of the Emergency Telephone Directory, Emergency Plan, and/or EPIPs were audited in the Control Room,

. Technical Support Center (TSC), Operational Support Center (OSC). Local Emergency Operations- Facility (LEOF), and Security Shift Supervisor's

' Office. ..The selected documents that were examined were found to be current revision . No violations or deviations were identifie . . Emergency Facilities. Equipment, Instrumentation, and Supplies (82701)

Pursuant; to 10 CFR 50.47(b)(8) and (9),Section IV.E of Appendix E to 10 CFR Part 50, and Section 7.0 of the licensee's Emergency Plan, this area was inspected to determine whether the licensee's emergency response facilities and other essential emergency equipment, instrumentation, and supplies'were maintained'in a state of operational readines . Discussions were held .with a licensee representative concerning modifications-to facilities, equipment, and instrumentation since the last inspectio The inspector toured the TSC,_0SC, and LE0F, and noted that facilities were in at.cordance with the description in Section 7.0 of the Emergency Pla Discussions with members of the licensee's corporate and site emergency preparedness ' staff disclosed the following equipment and facility changes since the August 1988 inspection:

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During September 1988, the Corporate Emergency Response Center (CERC)

was relocated from the Corporate Headquarters Building at James River Plaza (Richmond, VA) to the Innsbrook Technical Center in Richmond, V *

Regarding equipment changes, upgrades were made to the EWS. The EWS I was upgraded with a Whelan, computerized, control and feedback l system. According to licensee representatives, this system shculd reduce spurious activations, provide quick assurance of test results, and simplify the siren activation procedur )

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In assessing. the: operational . status 'of' the emergency facilities, the inspector verified . that . protective equipment, and supplies were-operational and inventoried en a periodic basis.. Emergency kits and/or cabinets from the TSC, OSC, alternate. OSC, LEOF,- and Dose Control Area (DCA), were inventoried and randomly selected equipment was checked for operability. - The : selected equipment operated properly, displayed current calibration stickers, and successful battery a'nd source checks were obtaine However, the inspector. did - note one discrepancy. .Three emergency kits located ;in the DCA' contained respirator cartridges that were not replaced prior to the' shelf-life expiration in accordance with Section 3.0 of Precedure No.1-PT-114 " Emergency Kit Inspection." The-

. referenced cartridges were stamped "Use Before March 1988." The licensee took immediate action by replacing expired cartridges with cartridges that

. were marked "Use Before February 1990." To prevent further recurrence,

~the licensee's .short. term acticn was to revise the-procedure data sheet governing the equipment inventory to include a review of the cartridges expiration date during the periodic inventory. The licensee's long term action is to replace the existing ultravue facepiece respirators with a full-face . type' respirator that is compatible with Mine Safety Appliance (MSA) type- cartridges- that are documented as having an infinite shelf-lif The licensee was informed that this violation meets the criteria specified in Section V.A of the NRC Enforcement Policy for not

' issuing a Notice of Violt. tion and is not cite Non-Cited -Violation (NCV) 50-338, 339/89-24-01: Failure to maintain respirators in accordance with 1-PT-114 " Emergency Kit inspection."

By review of applicable procedures and check-list documentation covering the period of October 1988 to June 1989, the inspector determined that emergency equipment (e.g. communication equipment and emergency kits) were

'being checked in accordance with the procedures governing such tests (PT-175 and PT-114). Records reviewed indicated that all discrepancies or problems identified during inventories and communications checks were corrected in a timely manner. In addition to the aforementioned test recoros, test documentation was reviewed for the primary and backup meteorological systems. No problems were note The licensee's management control program for the EWS was reviewe According to discussion with a licensee representative, the current system consists of 55 siren The licensee provided siren test records for the period September 1988 to June 1989. The records showed that the test were being conducted at the frequency specified in the licensee's periodic test procedure 1-PT-172 which implemented guidance from Appendix 3 of NUREG-065 As part of the emergency communication equipment, the inspector discussed with .a licensee contact the periodic testing of the plant emergency warning system for high noise areas. According to discussions with the licensee contact, the emergency evacuation system consists of red beacon

' lights and an evacuation alarm sounded over the plant public address syste According to the licensee contact and documentation entitled e: _

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Testina of Station Alarms, Procedure 1-MISC-9, the emergency alarms are testet w ekly; and the rotating lights are tested monthl One violation was identifie . Organization and Management' Control (82701)

The inspector's discussion with a licensee representative disclosed that several administrative changes had been made to both the normal and emergency organization since the August 1988 inspection as a result of reassignment or promotion. Example of changes in this category at the station included the reassignment of personnel previously filling the position of Maintenance Manager at North Anna Station, to the position of Station Manager at Surry. The Maintenance Manager's position was. filled by a former member of the Corporate Office. There were other examples of changes in this category; however, the changes had no significant impact on emergency preparedness. Regarding changes at the Corporate Office, the most significant changes impacting emergency preparedness involved the reporting chain for emergency planning, and a new Supervisor of Corporate Emergency Planning. The new Supervisor of Corporate Emergency Planning had been previously assigned emergency response responsibilities elsewhere as a consultant, and a station emergency planner. Corporate emergency planning previously reported to the Manager of Licensing. Since the last inspection, the reporting chain for corporate emergency planning has been assigned to the Manager of Programs. An additional change considered significant from an administrative standpoint, involved the reassignment of personnel previously filling the position Senior Vice President power to the. position Senior Vice President Nuclear. The referenced changes do not appear to decrease the effectiveness of the program. When training records were reviewed for individuals reassigned within the onsite emergency organization as key assessment personr.el (e.g. Station Emergency Managers and Accident Assessment), no problems were noted. Regarding the offsite emergency support organizations, no changes were made since the August 1988 inspectio No violations or deviations were identifie . Training (82701)

Pursuant to 10 CFR 50.47(b)(2) and (15),Section IV.F of Appendix E to 10 CFR Part 50, and Section 8 of the Emergency Plan, this area was inspected to determine whether the licensee's key emergency response personnel were properly trained and understood their emergency q responsibilitie The inspector reviewed Section 8.3 of the Emergency Plan and Administrative Procedure ADM-2.20 for a description of the training program and training procedures. In addition, selectel lesson plans or instructor guides were reviewed, and personnel with the responsibility for conducting and tracking the emergency response training were interviewe i u______.__ _ _ _ _ _ _ _ _ _ _ _ . - _ _ _ _ _ ___

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It was, determined that the licensee ma, stains a formal emergency training progra The inspector observed a licensee conducted simulator exercise in lieu of conducting walkthrough evaluations. Cognizant licensee representatives were informed by the inspector that the simulator driven exercise would be considered in the same manner as NRC walkthrough evaluations. The inspector was informed that the scenario deta;1s for the drill were confidential and unrehearsed. According to discussions- and licensee

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documentation, included as objectives were:

Accident assessment and classification

.Overall management of the accident by the Station Emergency Manager Communicator's ability to properly docu e nt, record, and notify State and local authorities

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Operate the plant in accordance with Technical Specifications (TSs)

Protective Action Recommendations (PARS)

Familiarity with procedures (Abnormal /EPIPs)

Interface and communications between operations and Health Physics-(HP) personnel Participants included an entire shift crew for the Control Room (Shift Supervisor, Shift Technical Advisor, Operators, etc.) and HP. With one exception, personnel demonstrated familiarity with the use of procedures, TS requirements, use of plant monitoring systems in accident recognition and assessment, and overall management of the acciden Event

. classification and protective action recommendations were done in accordance with procedures. The one exception involved an individual designated as an offsite communicator for State and local notification The communicator did not demonstrate familiarity or knowledge in completing the notification for This resulted in the initial notification to simuisted State / local governments exceeding the 15 minute notification time limi In response to the deficiencies observed by the communicator, the following actions were taken:

The inspector interviewed a non-licensed Control Room Operator, designated as an offsite communicator. No problems were noted with the individual's understanding of his role and/or responsibilities as a communicator in completing the notification message form. Further, when asked to conduct a test of the offsite notification system, no problems were note The licensee's Training Instructors conducted a critique at the end of the simulator drill (using a videotape) to discuss with participants their actions in response to the dril The offsite communicator's performance was included in the review. In addition, remedial training was conducted the following day for the Emergency Communicator to determine if adequate performance was attaine According to licensee documentation dated July 13, 1989, the communicator's resporsse was deemed satisfactor The inspector had i

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no further questions regarding the Emergency Communicator's training and/or capabilitie The inspector reviewed training _ records for several members of the onsite ;

and offsite support response organization. Selected training records were :

chosen' based on the May 1989 Emergency Personnel Notification listing of key personnel and phone numbers according to emergency response positio When personnel training records were compared with position assignments, no problems were noted. Offsite support agency training was reviewed for fire, rescue, and law enforcement agencies. Offsite support training was consistent'with requirements in Section 8.4 of the Emergency Pla No violations or-deviations were identifie . Independent Review / Audits (82701)

Pursuant to 10 CFR 50.47(b)(14) 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 program, and whether the licensee had a corrective action system for deficiencies and weaknesses identified during exercise and drill According to documentation, an independent audit was conducted by the licensee's Quality Assurance Department during the period January 12, 1989 through March 3, 1989, and documented in Audit Report No. N-89-01. The audit satisfied the annual frequency requirement for such audits. One finding and two observations were identified. The inspector reviewed documentation (Deviation Report No.89-369) to show that the identified finding had been assigned for review and corrective actio The licensee's program for follow-up action on audits, drills, and exercise findings was reviewed. The exercise and drill findings were being tracked via a system known as the " Commitment Tracking System (CTS)." A review of the CTS printout for the Calendar Year 1988 exercise indicated that 18 items were identified for corrective actions. Of the items identified, all 18 were close The inspector noted that many of the items were closed prior to the actual due date shown on the commitment tracking form. According to a licensee contact, on a weekly basis, status ]

reports are provided for review to plant managemen In addition, 1 department heads are notified weekly regarding item status specific to respective department No violations or deviations were identifie J Shift Staffing and Augmentation (82701)

Pursuant to 10 CFR 50.47(b)(2) and 10 CFR 50, Appendix E. Sections IV. A and IV.C, this area was examined to determine whether shift staffing for j emergencies was adequate both in numbers and in functional capability, and j whether administrative and physical means were available and maintained to augment the emergency organization in a timely manner.

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The inspector discussed with representatives of the licensee site and Corporate Emergency Preparedness staff, actions taken subsequent to the last routine inspection (50-338, 339/88-24) to enhance augmentation capability in response to commitments in Table 5.1 of the Emergency Pla The ' inspector was informed that augmentation results from the latest drill (June 1989) and during an actual event (February 1989 - tube rupture)

disclosed that staffing requirements and augmentation times discussed in Table 5.1~ of the Emergency Plan can not be met. The inspector reviewed documentation of the results for both the February and June response. The results along with recommendations for corrective actions were included in a memo to st3 tion management. Further, an action plan was being developed by the Corporate Office to identify major areas requiring evaluation ( notification method, response times for resources filling emergency response positions, allocation' of resources, etc.) for inclusion in a topical report for resolving augmentation problems. A violation (50-338, 339/88-24-02). was previously opened in this program area and remains opened pending further corrective action Th'e licensee has been responsive in taking actions to eliminate problems in shift augmentation as demonstrated by:

Tra,ining additional personnel to respond in areas previously where there were not enough names listed for contactin The notification list has been rearranged and prioritized in order of emergency positio However, this portion of the licensee's program requires additional resources and evaluations to be considered fully acceptabl No violations or deviations were identifie . Action on Previous Inspection Findings (92701, 92702)

(0 pen) Violation (50-338, 339/88-24-02): Failure to demonstrate the capability of meeting staffing requirements for emergency response team personne As discussed above in Paragraph 7, although the licensee has been responsive to this matter, additional corrective actions are needed for resolutio . Exit Interview The inspection scope and results were summarized on July 14, 1989, with those persons indicated in Paragraph 1. The inspector described the areas inspected and discussed in detail the inspection results belo Proprietary information is not contained in this report. Dissenting comments were not received from the license !

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The inspector informed licensee representatives that the additional details provided during the inspection in response to the violation regarding augmentation times, would be revf ewed in more detail by the Regional Office staf Item Number- Description / Reference 50-338,339/89-24-01 NCV - Failure to maintain respirators in accordance with 1-PT-114 (Paragraph 3).

Licensee management was informed that one open item was reviewed and remain ope .

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