IR 05000395/1985018

Insp Rept 50-395/85-18 on 850422-26.No Violations or Deviations Noted.Major Areas Inspected:Emergency Preparedness Exercise

ML20127L925
Person / Time
Site:	Summer
Issue date:	05/09/1985
From:	Cline W, Cunningham A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20127L919	List: IR 05000395/1985018 ML20127L914
References
50-395-85-18, NUDOCS 8506280226
Download: ML20127L925 (12)

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n UNITED STATES

[n 187og'o NUCLEAR REGULATORY COMMISSION

.- y[ 3 REGION 11 101 MARIETTA STHFET. j

• r ATLANTA, GEORGI A 30323

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MAY 0 9'1905 Report No.: 50-395/85-18 Licensee: South. Carolina Electric and Gas Company Columbia, SC 29218 Docket No.: 50-395 License No.: NPF-12 Facility Name: Virgil C. Summer Inspection Condu ed: "Ap}il'22-26,_1985 IInspector:

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/5//fh Oate Sfgned A. L. Cunningham /

Accompanying Personnel: L. A.:Rathbun R. J. Traub G. T. Lonergan J. M. Will, J E. A. King ,

Approved by: 2d k M f //f~

W.E. Cline,SectionOpief Date Signed Division of Radiation Safety and Safeguards

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SUMMARY Scope: This. routine, announced inspection involved 231 inspector-hours on site-

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in the area of an emergency preparedness exercis Results: No violations or deviations were identifie \

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REPORT DETAILS Persons Contacted Licensee Employees

• 0. W. Dixon, Jr., Vice President, Nuclear Operations

• R. D. Hazel, Vice President, Corporate Communications ,

• 0. S. Bradham, Director of Nuclear Operations '

• L. A. Blue, Manager, Support Services

• K. Beale, Corporate Coordinator, Emergency Planning

• M. Counts, Plant Emergency Coordinator

• W. R. Baehr, Manager, Corporate Health Physics and Emer-gency Planning

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~ * G. Connelly, Jr., Deputy Director, Operations and Maintenance

• B. Croley, Group Manager, Technical and Support Services

• Whitaker, Manager, Regulatory and Support Services

• A. R. Koon, Supervisor, Maintenance

• F. Bacon, Associate Manager, Chemistry

• J. W. Cox, Jr., Associate Manager, Health Physics

• J. P. Harrison, Manager, Nuclear Security Other licensee employees contacted included technical staff, technicians, operators, security force members, and office personne =

NRC Resident Inspector

• C. W. Hehl

• Attended exit interview Exit Interview (30703)

The inspection scope and findings were summarized on April 25, 1985, with those persons indicated in paragraph 1, above. The areas inspected were discussed in detail. No dissenting comments were received from the licensee. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspection.

i Licensee Action on Previous Enforcement Matters This subject was not addressed during the inspectio . Unresolved Items

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Unresolved items were not identified during this inspectio . Exercise Scenario (82301)

The scenario for the emergency exercise was reviewed to assure that provisions were made to test the integrated capability and a major portion of the basic elements defined in the licensee's emergency plan and I

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organization pursuant to 10 CFR 50.47(b)(14), paragraph IV.F of Appendix E to 10 CFR 50, and specific criteria defined in Section II.N of NUREG 0654, Revision The scenario was reviewed in advance of the scheduled exercise date and was discussed in detail with licensee representatives on April 3 and 22,198 While no major problems with the scenario were identified during the review, several inconsistencies became apparent during the exercis The inconsistancies, however, failed to detract from the overall performance of the licensee's emergency organizatio The scenario developed for this exercise was detailed and fully exercised the onsite emergency organization The scenario provided rufficient information to the state and local government agencies consistent with their participation in the exercis The licensee made a large commitment to training and personnel through the use of controllers, evaluators, and required personnel participating in the exercise. The controllers appeared to provide adequate guidance throughout the exercise; however, some minor prompting was noted by the inspecto This item was discussed during the exercise critiqu No violations or deviations were identifie . Drill Scenario (82301)

The scenario for the fire drill was reviewed to assure that provisions were made to test specific functions in the licensee's emergency plan pursuant to 10 CFR 50.47(b)(14), paragraph IV.F of Appendix E to 10 CFR 50, and specific criteria defined in Section II.N of NUREG 065 The scenario developed for the drill was detailed and adequately exercised the participating licensee organization and offsite local emergency agencies. The scenario provided sufficient information to the local support agencies consistent with the scope of their participation in the dril The licensee and offsite support agencies made a significant commitment to training and personnel by use of controllers, evaluators, and specialists participating in the drill. The controllers provided adequate guidance throughout the drill. No significant problems were disclosed regarding the scenario for the fire dril No violations or deviations were identifie . Assignment of Responsibility (82301)

This area was observed to assure that primary responsibilities for emergency response by the licensee were specifically established, and that adequate staff was available to respond to an emergency pursuant to 10 CFR 50.47(b)(1), paragraph IV.A of Appendix E to 10 CFR 50, and specific criteria defined in Section II.A of NUREG 0654, Revision o

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The inspectors observed that specific emergency assignments were made for the licensee's emergency response organization, and that adequate staff was available to respond to the simulated emergenc The initial response organization was augmented by designated licensee representatives; however, because of the scenario scope and conditions, long term or continuous staffing of the emergency response organization was not require Discussions with licensee representatives indicated that sufficient technical staff was available to provide for continuous staffing of the augmented emergency organization if neede The inspectors also observed the activation, staffing, and operation of the emergency organization in the TSC, OSC, and EO At each response center, the required staffing and assignment of responsibility appeared to be consistent with the licensee's approved procedure No violations or deviations were identifie . Onsite Emergency Organization (82301)

The licensee's onsite emergency organization was observed to assure that the following requirements were implemented pursuant to 10 CFR 50.47(b)(2),

paragraph IV.A of Appendix E to 10 CFR 50, and specific criteria promulgated in Section II.B of NUREG 0654, Revision 1: (1) responsibilities for emergency response were unambiguously defined; (2) adequate staffing was provided to insure initial facility accident ,esponse in key functional areas at all times; (3) onsite and offsite support organizational inter-actions were specifie The inspectors observed that the initial onsite emergency organization was adequately defined and that staff was available to fill key functicaal positions within the emergency organization. Augmentation of the initial emergency response organization was accomplished through mobilization of off-shift personne The on-duty Shift Supervisor assumed the duties of Emergency Coordinator promptly upon initiation of the simulated emergency and directed the response until relieved by the Station Manage Required interactions between the licensee's emergency response organization and State and offsite support agencies were adequate and consistent with the scope of the exercis No violations or deviations were identifie . Emergency Response Support and Resources (82301)

This area was observed to assure that the following arrangements for requesting and effectively using assistance resources were made pursuant to 10 CFR 50.47(b)(3); paragraph IV.A of Appendix E to 10 CFR 50, and Section II.C of NUREG 0654, Revision 1, namely: (1) accommodation of State i and local staff at the licensee's near-site Emergency Operations Facility; i (2) organizations capable of augmenting the planned response were identifie .

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A State of South Carolina representative was accommodated at the licensee's EO Licensee contact with offsite organizations was prompt, effective and

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consistent with the scope of the exercise. Assistance resources from state

~ and local agencies were available to the licensee.

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i No violations or~ deviations were identifie . 1 Emergency Classification System (82301)

This area was observed to assure that a standard emergency classification and action level scheme was in use by the nuclear facility licensee pursuant to -10 CFR 50.47(b)(4), paragraph IV.C of Appendix E to 10 CFR 50, and specific criteria promulgated.in Section II.D of NUREG 0654, Revision '

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Consistent with the exercise, three classifications from NUREG 0654 were used, -namely Alert, Site Area Emergency, and General Emergency. An emergency action level matrix was used to promptly identify and properly classify the emergency and escalate to more severe emergency classification as the simulated emergency progressed. Licensee actions in this area were  !

considered adequate.

l No violations or deviations were identified.

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1 Notification Methods and Procedures (82301)

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This area was cbserved to assure that procedures were established for

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notification of State and local response organizations and emergency l personnel by the licensee, and that the content of initial and followup messages to response organizations were established. This area was further

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observed to assure that means to provide early notification to the populace within the plume exposure pathway were established pursuant to 10 CFR 50.47(b)(5), paragraph IV.D of Appendix E to 10 CFR 50, and specific

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. criteria defined in Section II.E of NUREG 0654, Revision 1.

An inspector. observed that notification methods and procedures were

! established and available for use in providing information -concerning the i simulated emergency conditions to Federal, State, and -local response organizations, and to alert the licensee's augmented emergency response organization Notification of the' State of South Carolina, and local

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offsite organizations was completed within 15 minutes following declaration of each emergency classificatio .

E Telephone notification of State and local response organizations was promptly followed .by transmission of hard copies of the notification to-these organization Such copies included prevailing meteorological information, average release rate (source terms in.uCi/sec), site boundary integrated dose ~ projections, and recommended protective actions when 4 necessary.

i The prompt notification system (PNS) for alerting the public within the i plume exposure pathway was in place and operational. The ' system - was actuated during the exercise to simulate warning the public of significant events occurring at the reactor site. It was noted that. the PNS was

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. actuated a second time in response to an indicated system malfunction. The signal was later determined to 'be erroneous. The second alarm resulted in no apparent public confusion.

No violations or deviations were identifie . Emergency Communications (82301)

This area was observed to assure that provisions existed for prompt communications among principal response organizations and emergency

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personnel pursuant to 10 CFR 50.47(b)(6), paragraph IV.E of Appendix E to 10 CFR 50, and specific criteria promulgated in Section II.F of NUREG 0654,

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Revision 1.

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The inspector observed communications within and between the licensee's emergency response facilities (control room, TSC, OSC, and E0F), between the

, licensee and offsite agencies, and between the offsite environmental

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monitoring teams and the EOF. The inspectors also observed information flow

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among the various groups within the licensee's emergency organizatio Emergency communications were adequate and consistent with the scope of the

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exercis No violations or deviations were identifie . Emergency Facilities and Equipment (82301)

This area was observed to assure that adequate emergency facilities and

equipment to support an emergency response were provided and maintained pursuant to'10 CFR 50.47(b)(8), paragraph IV.E of Appendix E to 10 CFR 50, and specific criteria defined in Section II.H of NUREG 0654, Revision The inspectors observed the activation and staffing of the emergency

> response facilities, and observed the use of equipment at these facilitie Emergency response facilities used by the licensee during the exercise

included'the control room, TSC, OSC, and E0F.

I Control Room - Consistent with the exercise scenario, the control room s was supplement J by the reactor simulator located in the corporate training center approximately two miles from the plant site. Effective

management of ' personnel gaining access to the simulator precluded

< overcrowding, and served to maintain an ambient noise level required for orderly conduct of operations under emergency condition .

The shift supervisor demonstrated proficiency in the following critical

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(1) evaluation of conditions for classification of events; and

. (2) assessment of radiation levels associated with operation of

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specific reactor systems to identify the location of leakage source Review of the control room records and logs disclosed that following the transfer of the Emergency Director's log to the TSC, the control room operators failed to maintain the facility log during the remainder

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of the exercise. A detailed log of control room activities during

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emergency conditions provides the record of required assessment and

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, . mitigation of simulated accident This area requires improvemen (Inspection Followup Item [IFI] 50-395/85-18-01) . Technical Support Center (TSC) - The TSC was activated and staffed promptly upon notification by the Emergency Coordinato* of the

- simulated emergency conditions leading to the - Alert and Site Area i LEmergency classifications. The TSC staff appeared to be knowledgeable

. .concerning_.their emergency responsibilities, and TSC operations

!  : proceeded smoothly. The TSC appeared to have adequate equipment -for the support of the ' assigned staf TSC security was promptly

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established. The independent ventilation system was actuated during L the exercise. During operation of this facility, radiological habit-ability was routinely monitored and documented, and personnel dosimetry was distributed as required. Status boards and related visual aids were centrally. located to readily facilitate viewing by the TSC staf **

Dedicated communicators were assigned to the facility and all required

. -notifications were promptly implemented.

[ .The inspection disclosed the following additional findings, namely:

(1) engineering, maintenance, and other technical support functions were readily accommodated and factored into problem solving exercises; (2) assumption of duties by the Emergency Director was definite and firm; (3) transfer of certain emergency responsibilities from TSC to

. EOF was firmly declared and announced to the TSC staff; (4) briefings

' of.'the TSC staff were - frequent and consistent with changes in plant  ;

status _ and the related emergency conditions;- (5) accountability, including identified missing personnel, was readily implemented within _

F -the accepted thirty minute time regim Operations Support Center (OSC) - The OSC was promptly staffed upon activation of the emergency plan by the Emergency Coordinator.

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- An inspector observed that teams were promptly assembled, briefed, . and dispatched. -The OSC supervisor appeared to be cognizant of his duties and responsib.ilities. During operation of the facility, radiological habitability was routinely monitored and documented during the ear _ lier part of the exercise. The inspector noted, however, that during the

, lattee four hours of the. exercise, habitability monitoring of the This item was- discussed with licensee

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facility was ' discontinued.

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management during the critiqu The post accident sampling system (PASS) appeared to be adequate for

, emergency ' samplin The PASS team demonstrated proficiency i operating the automated post accident sampling system requisite for collection of liquid and air samples.

" ~ Emergency Operations Facility (EOF) - The EOF is located in the

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Training -Building approximately two miles from the plant sit The facility appeared to be adequately equipped and staffed to support an

[ emergency response.

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E0F-security was promptly established, and the independent ventilation system was actuated. During operation of the facility, radiological habitability was routinely monitored and documented. Status boards and j

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other related visual aids were strategically located and were readily accessible for viewing by the EOF staff. Dedicated communicators were assigned to the facility, and all required notifications were promptly made. A disparity in dose projections and assessments approximating a factor of two was detected in calculations conducted by the TSC and E0F. This finding was noted both by the inspectors and licensee staf This matter was discussed in the critique and the licensee indicated action would be taken. Actions taken on this matter will be reviewed in a future inspection (IFI 50-395/85-18-02)

No violations or deviations were identified regarding emergency response facilities and equipmen . Accident Assessment'(82301)

This area was observed to assure that adequate methods, systems, a equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition were in use as required by 10 CFR 50.47(b)(9), paragraph IV.B of Appendix E to 10 CFR 50, and specific criteria in Section II.I of NUREG 0654, Revision The accident assessment program included an engineering assessment of plant status, and an assessment of radiological hazards to onsite and offsite personnel resulting from the accident. During the exercise, the engineering accident assessment team functioned effectively in analyzing the plant status to provide recommendations to the Site Emergency Manager concerning mitigating actions required to reduce damage to plant equipment, prevent releases of radioactive materials, and terminate the emergency conditio Radiological assessment activities involved several groups. An inplant group was effective in estimating the radiological impact witHn the plant based on inplant monitoring and onsite measurements. Offsite radiological monitoring teams were dispatched to determine the level of radioactivity in those areas within the path of the plume. Radiological effluent data was received in the E0F. The EOF calculations were computed and compared on a timely basis with results received from the TSC and offsite monitoring groups. Disparity in calculations between the two facilities is discussed abov Routine inventory and verification of the contents of monitoring kits issued to offsite radiation monitoring team personnel was conducted. It was noted that required contents of each kit were provide It was also noted, however, that no spare batteries or radios were provided. No instrument or radio failures occurred during offsite surveys and monitorin The post-accident sample system (PASS) was used to collect a sample of primary coolant as a part of the drill. The PASS functioned properly and procedures were followed closely, with adequate concern being given to radiation and contamination control practices. The sample was analyzed in accordance with established procedure Health physics coverage was provided for all aspects of the sampling and analysis and ALARA practices were employed.

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No violations or deviations were identifie . Protective Response This area was observed to determine that guidelines for protective actions, consistent with federal guidance, were developed and in place, and protective actions for emergency workers, including evacuation of non-essential personnel, are implemented promptly as required by 10 CFR 50.47(b)(10) and specific criteria in NUREG 0654,Section I The inspector observed the licensee's program for personnel accountabilit The inspector noted that upon sounding of the site evacuation alarm, personnel appeared to proceed promptly to designated assembly point Initial' accountability appeared to be completed in about 20 minute Accountability was continued until all personnel were accounted for approximately 30 minutes after initial accountability chec The prompt notification system 1n the EPZ was actuated and the sirens were operational. Protective actions regarding sheltering of area occupants was implemented as required. Prompt notification of the public was successfully implemente The protective measures decision making process was observed by the inspectors. Recommendations implemented by the EOF were timely, effective, and consistent with the above criteria. Protective measures recommendations were provided by the licensee to the State of South Carolina and local offsite organization No violations or deviations were identifie . Radiological Exposure Control (82301)

This area was observed to determine that methods for controlling radio-logical exposures in an emergency were established and implemented for emergency workers, and that these methods included exposure guidelines consistent with EPA recommendations as required by 10 CFR 50.47(b)(11), and specific criteria defined in Section II.K of NUREG 065 An inspector noted that radiological exposures were controlled throughout the exercise by issuing supplemental dosimeters to emergency workers and by conducting periodic radiological surveys in the emergency response facilitie Exposure gaidelined were in place for various categories of emergency actions, and adequate protective clothing and respiratory protection were available and used as appropriat Health Physics control of radiation exposure, contamination control, and radiation ares access appeared adequate. Health Physics supervisors were observed to brief survey teams adequately. Dosimetry was available and was used; high range dosimeters were also available in case they were needed. A communicator and data logger were established at the health physics access point and appeared to function in a satisfactory manne No violations or deviations were identifie _ . _ - ._ .- . -. . .. -

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. 17. Public Education and Information (82301)

This area was observed to assure that information concerning the simulated I emergency was made available for dissemination to the public as required by 10 CFR 50.47(b)(7), 10 CFR 50, Appendix E, paragraph IV.D, and specific- criteria in NUREG 0654,Section II.G.

I Information was provided to the media and the public in advance of the -

exercis The information included details on how the public would be notified and the initial actions which should be taken in an emergency. A rumor control program was also in place.

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The licensee activated and staffed a near site Emergency News Center (ENC).

The facility was;used by the licensee for preparation, coordination and

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dissemination of emergency -news information. Written press releases were prepared and issued from the EN Releases issued were timely, and adequately reflected . plant emergency conditions. A corporate spokesman was designated to conduct periodic press briefing The briefings were technically accurate and presented in a manner readily understood by layme Visual aids were adequately used. Question and answer sessions were held after each briefin <

No violations or deviations were identified.

18. Recovery Planning (82301)

. This area was reviewed pursuant to the requirements in 10 CFR 50.47(b)(13),

10 CFR 50, Appendix E, paragraph IV.H, and the specific criteria in NUREG 0654,Section II.M.

i The licensee conducted a brief recovery planning session prior to termina-

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tion of the exercise. Licensee planners discussed the need for administ-rative and logistical support, . manpower needs, engineering service needs, and implementation of the recovery organization.

i i No violations or deviations were identifie . Exercise Critique (82301)

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.The licensee's critique of the emergency exercise was observed to determine that shortcomings identified as part of the exercise were brought to the

attention of management for corrective action, as required by 10 CFR 50.47(b)(i4), 10 CFR 50, Appendix E, paragraph IV.F, and the specific

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criteria in NUREG 0654,Section I A formal critique was held on April 25, 1985, with exercise controllers and observers,. licensee management, and NRC representatives. Weaknesses

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identified during the exercise and plans for corrective action were discussed. Licensee action on weaknesses identified will be reviewed during

, a subsequent inspection.

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A public critique was scheduled for April 26, 1985, at 2:00 The critique meeting was opened and then cancelled since neither news media representatives nor members of the public were in attendanc . Followup Items (Closed) Inspector Followup Item (IFI) 50-395/85-06-01: Documentation of Training. Review of emergency preparedness training and test files disclosed that the subject training is routinely documented as require (Closed) IFI 50-395/84-07-02: Improvement of procedures for monitoring tea Through performance, the monitoring team demonstrated an understanding of procedures and familiarity with survey instrument . Notification and Communication (82203)

Pursuant to 10 CFR 50.47(b)(5) and (6) and 10 CFR Part 50, Appendix E, Section IV.D, this area was inspected to determine whether the licensee was maintaining a capability for notifying and communicating (in the event of an emergency) among its own personnel, offsite supportino agencies and authorities, and the population within the EP The inspector reviewed the licensee's notification procedure (EPP-002). The procedure was consistent with the emergency classification and EAL scheme used by the licensee. The inspector determined that the procedure made provisions for message verificatio The inspector determined by review of applicable procedures and by discussion with licensee representatives that adequate procedural means existed for alerting, notifying, and activating emergency response personnel. The procedures specified when to notify and activate the onsite emergency organization, corporate support organization, and offsite agencie Selected telephone numbers listed in the licensee's procedures for emergency response support organizations were checked in order to determine whether the listed numbers were current and correct. No problems were note The content of initial emergency messages was reviewed and discussed with licensee representative The initial messages appeared to meet the guidance of NUREG 0654, Sections II.E.3 and II.E.4. Licensee representa-tives stated that the format and content of the initial emergency messages were reviewed by State and local government authoritie The licensee's management control program for the prompt notification system was reviewe According to licensee documentation and discussions with licensee representatives, the system consisted of 106 fixed sirens, two PA speakers at a recreation area, and ten tone-alert radio A review of li ensee records verified that the system as installed was consistent with the description contained in the emergency plan. Maintenance of the system had been provided for by the licensee. The inspector reviewed siren test records for the period February 15, 1984, to April 15, 1985. The records showed the following: (1) silent tests were conducted weekly from the encoder antenna to a decoder in the machine shop; (2) growl tests were

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conducted monthly at each siren from a portable encoder; (3) a full-cycle test was conducted annually as -specified in Appendix 3 of NUREG 0654, Revision 1.

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No violations or deviations were identified in this program are !

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