IR 05000338/1991002

Insp Repts 50-338/91-02 & 50-339/91-02 on 910114-18.No Violations Noted.Major Areas Inspected:Training,Independent Audits,Key Program Changes & Administrative Controls Governing Distribution of Changes to EP & EPIP

ML20029B130
Person / Time
Site:	North Anna
Issue date:	02/12/1991
From:	Gooden A, Rankin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20029B123	List: IR 05000338/1991002 ML20029B122
References
50-338-91-02, 50-338-91-2, 50-339-91-02, 50-339-91-2, IEIN-89-089, IEIN-89-89, NUDOCS 9103050469
Download: ML20029B130 (8)

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UNITED STATES o

NUCLEAR REGULATORY COMMisS:ON

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101 MARIETT A STREET. N.W.

• t ATL ANT A. GEORGI A 30323

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FEB 141931 Report Nos.:

50-338/91-02 and 50-339/91-02 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:

January 14-18, 1991 Inspeccor:

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V._Ifankin, Chi'el Date Signed Emergency Prepareaness Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards SUMMARY Scope:

This routine, unannounced inspection was conducted in the area of emergency preparedness.

Several aspects of the program were reviewed to determine if the program was being maintained in a state of operational readiness.

Areas examined included:

training, independent audits, key program changes (equipment, facilities, personnel, etc.), administrative controls governing the distribution of changes to the Emergency Plan and Emergency Plan In'plementing Procedures (EPIPs), the corrective action tracking system, and maintenance of select emergency equipment.

Results:

No violations or deviations were identified.

The program elements appeared to be adequately defined and properly implemented.

Noted program strengths included management support for the program (both site and corporate);

independent audits and self-assessn'ents; response to augmentation issues; corrective action tracking system; and the onsite emergency organization was fully staffed and trained, i

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REPORT DETAILS 1.

Persons Contacted W

Licensee Employees

• G. Clark, Supervisor, Corporate Quality Assurance m

• J. Collins, Director, Corporate Nuclear Emergency Preparedness

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• R. Driscoll, Manager, Corporate Quality Assurance

• L. Edmonds, Superintendent, Nuclear Training

• G. Kane, Station Manager

• P. Kemp, Supervisor, licensing g

• J. Leberstien, Licensing Engineer

• J. Lusher, Station Coordinator, Emergency Planning

• W. Madison, Staff Emergency Planner, Corporate

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• B. McBride. Coordinator Emergency Planning H. Moyers, Shift Supervisor, Health Physics J. Rayman, Instructor

• J. Smith, Manager, Site Quality Assurance

• J. Stall, Assistant Station Manager

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H. Stewart, Supervisor, Nuclear Office Records D, Vaugh, Shift Supervisor, Security Other licensee employees contacted during this inspection included engineers, security force members, technicians, and administrative personnel.

NRC Resident inspectors

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'M. Lesser

• J. Menning

• Attended exit interview 2.

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 (May 1990), and to assess the impact of these changes on the overall state of emergency preparedness at the facility.

The inspector reviewed the licensee's administrative program for making changes to the Plan and EPIPs.

The inspector conducted a random sampling of changes to the Plan and procedures to verify that changes were reviewed and approved by management in accordance with procedures governing the development, review, and approval.

As evidaced by the transmittal dates, changes were distributed tc onsite and offsne copy holders in a timely manner.

Documentation fcr EPIP changes was reviewed to verify that l

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submittals were made to the NRC within 30 days of the approval date.

No problems were noted.

Since the lest inspection, one Plan revision.was submitted for NRC review and approval.

Changes incorjorated as Revision 13 were mailed to NRC on January 9, 1991.

At the t'.ine of the inspection, changes were being reviewed by the NRC Regional Nfice staff to determine if the changes were consistent with NRC requi.ements and commitments.

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Controlled copies of the Emergency Plan, EPirs, and/or position notebooks (e.g. Station Emergency Manager) were aucited in the Control Room, Technical Support Center (TSC), and the Local Emergency Operations facility (LE0F).

The selected documents were all current and up to date, The licensee's Agreement Letters with of fsite support agencies were reviewed and updated during the first quarter of calendar year 1990.

No violations or deviations were identified.

3.

Emergency facilities, Equipment, Instrumentation, and Supplies (82701)

Pursuant to 10 CFP 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 epsential emergency equipment, instrumentation, and supplies were maintained in a state of operational readiness.

The inspector toured the Control Room, TSC, and LEOF, and noted that facilities were in accordance with the description in Section 7.0 of the Emergency Plan.

Discussions were held with members of the emergency preparedness staff concerning modifications to facilities, equipment, and instrumentation since the last inspection.

The discussion disclosed no facility or significant instrumentation changes.

Regarding equipment changes, although full. implementation had not been completed, the licensee made upgrades to the communications and notificetion system for activation of augmentation personnel by procurement of an auto-dialer system.

The licensee contact indicated that activation and response time for augmentation personnel would be enhanced by the automated call-out system

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and recent procedure changes.

Full: implementation is scheduled for Spring 1991.

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In assessing _ the operational status -of the emergency facilities, the inspector veri fied that protective equipment, and supplies were operational and inventoried on a periodic _ basis.

Emergency kits and/or.

cabinets from the TSC, alternate Operational Support Center (OSC), and

. Dose Control Area (DCA) were inventoried and randomly selected equipment was checked for operability.

The inspector noted a minor problem involving two survey instruments (one located in the TSC kit, and one in the alternate OSC kit) indicating low battery.

The inspector discussed i

this item with the Health Physics Shif t Supervisor for resolution.

Other selected equipment operated properly, displayed current calibration stickers, and a successful battery and source check obtained, i

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By review of applicable procedures and check-list documentation covering the period of May 1990 to January 1991, the inspector determined that

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energency equipment (e.g. communication equipment and emergency Lits) was being checked in accordance with the procedures gowrning such tests; Records reviewed indicated that all discrepancies or problems identified during inventories and communications checks were corrected in a timely manner.

The licensee's management control program for the Early Werning System (EWS) was reviewed.

According to discussion with a licensee representative, the current system consists of 55 sirens.

The licensee provided a siren availability report dated January ?,1991 which detailed the calendar year 1990 siren availability as 95.59%.

Further, the-inspector '.eviewed siren test documentation which showed that the tests were conducted at the frequency specified in the licensee's periodic test procedure 1-PT-172 which implemented guidance from Appendix 3 of

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NUREG-0654 As part of the emergency communicetions review, the inspector reviewed the licensee's actions and response to NRC IE Bulletin 80-15 "Possible Loss of Emergency Notification System (ENS) with Loss Of Offsite Power."

Documentation showed that a design control package (DCP 80-51) issued during 1980, provided a modification (changed the power supply for the station ENS to a vital bus) in accordance with the IE Bulletin.

In addition to a vital bus providing ENS power supply, the ENS line will continue to operate until the local telephone company backup power sources are exhausted (approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> af ter loss of primary power source).

No violations or deviations were identified.

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Organization,,d Management Control (82701)

Pursuant to 10 CFR 50.47(b)(1) and (16),Section IV. A of Appendix E to 10 CFR Fart 50, and Section 5.0 of the licensee's Emergency Plan, this area was inspected _to determine the effects of any changes in the licensee's emergency organization and/or manageaent control systems on the emergency preparedness program, and to verify that any such changes were properly factored into the Emergency Plan and EPIPs.

The inspector was informed by a member of the licensee's staff that several administrative changes had been made since the last inspection.

For example, the. re-assignment of personnel previously filling the position of Assistant Station Manager at North Anna, to the position of Licensing Manager at the Corporate Office.

The Assistant Station Manager's position was filled by plant personnel previously assigned as the Superintendent of Operations.

This change had no impact other than administrative on emergency preparedness.

When training records were

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conpared to position assignment, no problems were noted.

Regarding the offsite support agencies, no changes had occurred since the last inspection.

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No violations or desiations were identified.

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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 determined whether the licensee's key emergency response personnel were properly trained and understood their emergency responsibilities.

The inspector reviewed Section 8.3 of the Emergency Plan and the Nuclear Power Station Emergency Preparedness Training Program Guide (NPS EPT) for a description of the training program and training procedures.

In addition, selected lesson plans or instructor guides were reviewed, and personnel with the responsibility for conducting and tracking the emergency response training were interviewed.

Monthly training reviews are performed for serification that emergency response personnel training is current and up to date.

The results of the review are compiled in a monthly status report that is provided to appropriate management for review and/or followup actions.

The inspector observed emergency response training for health physics personnel.

The referenced training involved both classroom and actual hands-on experience using the computerized dese projection model referred to as " MIDAS."

In addition, an individual with responsibility as an alternate Station Emergency Manager was interviewed and asked to talk through his response as Station Emergency Manager in response to postulated accident conditions.

No problems were noted in the areas of emergency action level (EAL) recognition, classification, and protective action reconmendations.

The interviewee demonstrated excellent familiarity with the emergency classification procedures (EPIP-1.01) and various other EPIPs which implement the station's Emergency Plan.

A Security Shift Supervisor was also interviewed regarding-his role and rcsponsibility in the event of a spurious siren activation.

No problems were noted.

The-individual was familiar with the procedure governing spurious siren activation and the required notifications.

Training records were reviewed for 15 randomly selected members of the emergency organization.

Training records were chosen based on the-December 1990 Emergency Telephone Directory.

Names were randomly selected from various emergency positions on the emergency response position matrix.

When personnel training records were compared with position assignments, no_ problems were noted.

Training was reviewed for the offsite fire, rescue, and county emergency services agencies.

No problems were noted.

Documentation disclosed that training was provided fire, rescue, and county Emergency Services on December 10, 1990, with a special session provided on November 29, 1990 for Holly Grove and Locust Creek volunteer fire and rescue personnel.

In addition, local law enforcement training was provided on October 9, 1990.

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s Regarding augmentation drills, a licensee contact provided documentation to show the results of notifications drills conducted on October 12 and December 6, 1990.

According to discussions and documentation, the estimated times of arrival provided by respondents were within 60 minutes.

However, en actual drill requiring that personnel respond to the site had-not been performed during the calendar year.

The licensee indicated that program enhancements in the area of augmentation (auto dialer system, additional staffing, and prioritization of notifications) would be tested during an upcoming unannounced augmentation drill requiring actual travel to the site.

This ~ item is being tracked by the licensce's commitment tracking system for performance during calendar year 1991.

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No violations cr deviations were identified.

6.

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 drills.

According to documentation, an ndependent audit was conducted by the d

Corporate Office Quality Assuram Departrent during the period August 16 through September 21, 1990, and documented in Audit Report No. C90-18.

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The audit team was comprised of VEPC0 and contractor personnel.

The audit was very detailed and appeared to provide an in-depth review of very key elements of the station and corporate of fice programs.

Four audit findings and eight observations were identified, The inspector reviewed documentation to show that the findings had been assigned for review and corrective action.

The inspector noted in addition to the required 50.54t annual audit by the corporate office, the site's Quality Assurance group had performed an assessment in the area of minimum staffing during off

. hours, and observed a semi-annual radiological monitoring drill.

A self assessment program implemented by the licensee appeared to aid in the-identification of issues or areas requiring improver,ent to ensure that the program was_being properly maintained.

The licensee's program for follow-up action on audits, drills, and exercise findings was reviewed.

The exercise and dril-1 findings were-being}." tracked via a system known as the " Commitment Tracking System (CTS A review of-the CTS printout for the calendar year 1989 exercise indicated that all items were closed.

Exercise items identified during the 1990 exercise critique were summarized in an action plan for resolution.

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No violations or deviations were identified.

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Emergency Plan Implementation (92700)

The inspector reviewed the completed procedure package which resulted from a Notification of Unusual Event (N04E) declaration made on September 24, 1990.

The event declaration was due to an unplanned release greater than technical specifications.

Although no problems were noted with the event classification and offsite notifications, the inspector noted that several items were omitted from the emergency notification termination message:

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No message number was assigned The notification start time was not included The emergency event termination time not included

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in addition to the above items, an inconsistency was noted between the procedural steps found in EP!P-2.01 and the notification message form (Attachment 2 of EPIP-2.01). Line 32 of the procedure states " record your name and emergency position title on botton of Attachment 2."

However, Attachment 2 had no space for this information.

The inspector discussed the aforementioned items with the Site and Corporate Emergency Preparedness Coordinators.

In response, the licensee initiated the following actions and comr 'tment tracking for resolution:

CTS #02-91-0501-001 was issued to training that during the communicator requalification training, training will emphasize -to communicators all required spaces on the notification form be completed in accordance with procedural requirements.

Incomplete Items List (IIL) #6-054 was assigned to Corporate

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Emergency Planning to review EPIP-2.01 and revise as necessary to ensure compatibility with attachments.

No violations or deviations were idontified.

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NRC Information Notice (92701)

The inspector discussed with a licensee representative their response to the following Information Netices (ins):

IN No. 89-89 " Event Notification Work Sheets."

The inspector reviewed documentation which disclosed the licensee had reviewed the referenced IN and determined that the additional information in the IN would be applicable to their site and procedures.

The information contained on NRC Form 361 is currently incorporated into an Operations Standard.

IN No. 90-34 " Response to False Siren Activations." According to the documentation and a discussion with members cf the licensee's staff, the siren control system prints out any siren sounding on an

. arm printer in the station's security office.

A general order entitled

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'Early Warning Siren." provides guidance and instructions on what actions to take in response to siren activations.

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Ex;t interview

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The-inspection scope and results were summarized on January 18, 1991, with those persons indicated in Paragraph 1.

The inspector described the areas inspected and discussed in detail the commitment tracking items issued in response to the communicators actions during the NOUE (Paragraph 7).

Proprietary information is not contained in this report.

No dissenting con.ments were expressed by the licensee,

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