IR 05000395/1987005

Insp Rept 50-395/87-05 on 870223-27.No Violations or Deviations Noted.Major Area Inspected:Emergency Preparedness

ML20245A384
Person / Time
Site:	Summer
Issue date:	03/09/1987
From:	Decker T, Gooden A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20207T656	List: IR 05000395/1987005 ML20207T655
References
50-395-87-05, 50-395-87-5, NUDOCS 8703240226
Download: ML20245A384 (8)

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mR111987 Report No.: 50-395/87-05 Licensee: South Carolina diectric and. Gas Company Columbia, SC 29218 s Docket No.: 50-395 License No.: NPF-12 Facility Name: Summer i

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Inspection Conducted: February 23-27, 1987

,. Inspector: O, d 3-1- 87

" Date Signed

,f A. Gooden

', Approved by: ,)$ /hinko , 3-9-87

.T. R. Decker, Section Chief Date Signed Division of Radiation Safety and Safeguards

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SUMMARY

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Scope: This routine unannounced inspection was conducted in the area of emergency preparednes Results: No violations or deviations were identifie *

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REPORT DETAILS Persons Contacted Licensee Employees

• 0. S. Bradham, Director, Nuclear Plant Operations

• K. . E. Beale, Manager, Nuclear Protection Services F. L. Blanchard, Senior Instructor, Operator Training

• M. N. Browne, Group Manager, Technical and Support Services

• J. G. Connelly, Director, Nuclear Services

• C. M. Counts, Emergency Coordinator

• T. Frady, Associate Manager, Quality Assurance D. R. Goldston, Shift Supervisor C. E. Holland, Auxiliary Operator

• S. Hunt, Manager, Quality Control R. F. McCauley, Nuclear Training Coordinator

• D. Moore, Director,- Quality and Procurement Services

• A. M. Monsoe, Regulatory Compliance Engineer

• F. J. Leach, Manager, Quality Assurance L. C. New, Quality Assurance Surveillance Specialist-

• A. Paglia, Manager, Nuclear Licensing J. N. Poole, Shift Supervisor

• R. Bouknight, Nuclear Licensing Specialist

• M. D. Quinton, Manager, Maintenance Services R. Ruff Supervisor, Nuclear Operations Training Other licensee employees contacted included technicians, operators, security office members and office personne NRC Resident Inspector

-*R. L. Prevatte

• Attended exit interview Exit Interview The inspection- scope and findings were summarized on February 27, 1987, with those persons indicated in Paragraph 1 above. The inspector described the areas inspected and informed the licensee that there were no new items identified during this inspectio The licensee did not identify as proprietary any of the material provided to or reviewed by the inspecto . Licensee Action on Previous Enforcement Matters (Closed) Unresolved Item (50-395/86-05-01): Determine the adequacy of Fission Product Barrier Approach to event classification. By letter dated August 13, 1986, the licensee was informed that the Fission Product

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Barrier Approach as presented, was not an acceptable alternative to the  !

NUREG-0654 event-oriented classification schem . Emergency Plan and Implementing Procedures (82701-02.01) I Pursuant to 10CFR50.47(b)(16), 10CFR50.54(q), and 10 CFR 50, Appendix E, this area was reviewed to determine whether changes were made to the program since the last routine inspection (February 1986) and to assess the impact of these changes on the overall state of emergency preparedness. The inspector discussed with a licensee representative the licensee's program for making changes to the Emergency Plan and Implementing Procedures. The inspector reviewed the licensee's procedure (Station Administrative Procedure-139) governing the review and approval j of changes to the Plan and Implementing Procedures. The inspector '

verified that changes to the Plan and procedures were reviewed and l approved by management in accordance with SAP-139. It was also noted that l all such changes were submitted to NRC within 30 days of the effective '

date, as required. During the discussion with a licensee representative, the inspector was informed that the most significant procedural changes since the February 1986 inspection involved the emergency classification procedure (EPP-001) and the notification procedure - (EPP-002). The emergency classification procedures were revised to reinstate the initiating events specified in Appendix 1 of NUREG-065 During the February 1986 inspection, the licensee's classification procedure (EPP-001) titled " Activation and Implementation of Emergency Plan,"

implemented a scheme for emergency classification that utilized a fission product barrier approac Subsequent to the inspection, the NRC determined that this approach as presented decreased the effectiveness of the emergency plan and was not an acceptable alternative to the initiating events in Appendix 1 of NUREG-065 EPP-002 was revised as a result of a violation which was identified during the 1986 annual exercis It was noted during the exercise that EPP-002, " Communication and Notifications,"

was inadequate due to failure to satisfy the 15-minute requirement of 10 CFR 50, Appendix E (See Report No. 50-395/86-08). Subsequent to this finding, EPP-002 was revised to reflect the installation of a dedicated phone system which provides the capability for making simultaneous notifications to the appropriate offsite agencies.

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The inspector reviewed the licensee's program for distribution of changes j to the Emergency Plan and procedures as described in PDP-101, " Document l Control Procedure," and SAP-139, " Procedure Development, Review, Approval, and Control." The inspector verified that current procedures and copies i

of the Plan were being ) maintained by reviewing the following controlled 43A (M. C copies:

43B (TSC), and 41 (E0F).

No violations or deviations were identified.

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5. Emergency Facilities, Equipment, Instrumentation, and Supplies (82701-02.02)

Discussions were held with a licensee representative concerning modifications to facilities, equipment, and instrumentation since the last inspection. The inspector was informed that no major modifications had been made to the ERFs; although, consideration is being given towards relocating the Operations Support Center. Regarding equipment, additional phones have been added to the ERFs, including a. ring-down phone system which provides the capability for notifying State and local governments within 15 minutes after declaration of an emergency. As stated in Paragraph 4 above, the dedicated phone system provides the capability for concurrent notifications to the offsite agencie This system can be operated in one of two different modes: (1) "All call" mode enables the licensee to notify all of the appropriate offsite autnorities simultaneously, or (2) a dedicated line for contacting each of the four counties or the State Warning Point individually. The inspector verified the prctadural change (EPP-002) to reflect the use of the "all call" mode for making notifications during an emergency. The inspector also requested and observed a communications check using the dedicated system in the Mall call" mode. It was noted that all parties responded with the exception of Fairfield County. Therefore, an attempt was made to contact Fairfield County via the Fairfield dedicated lin This attempt also faile As a result, the inspector discussed with the licensee representative the backup communications system used in the event of failure to the primary system. Backup communications is available via plant phones, and a two-way radio system with the local law enforcement agencies (LLEA). The inspector observed an unannounced check using the two-way radio system. It was determined that the Fairfield County line was inoperable and immediate action was initiated by the licensee to restore service to Fairfield Count Shortly after the communications test was conducted, the licensee's telecommunications department was able to diagnose the problem and restore servic In addition to the aforementioned communications checks, the inspector requested a communications check of the NRC Emergency Notification System. No further problems were note The licensee's management control program for the Early Warning Siren System (EWSS) was reviewed. As documented in the licensee's audit report I (Report #II-1-87-B, " Station Emergency Plan," dated February 19,1987),

" fifty-one of the one hundred and seven sirens failed during the recent annual emergency exercise. A followup retest found nine were still inoperative." This matter was discussed with a licensee representativ According to licensee documentation and discussions with the licensee representative, as a result of failures, daily tests are being conducted on the signal encoder and transmitter. A review of licensee documentation verified that daily tests have been conducted since February 11, 1987, and corrective action was taken on problems identified during tests. An EWSS trouble report form was used for documenting actions taken as a followup to siren problems. The inspector reviewed siren test records (Zones 1 and 2) for the period September 1986 to February 1987. In addition, the

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P licensee representative provided documentation _ to verify that backup

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communication systems are being . tested in accordance with EPP-022,

" Verification of Comneunications Operability."

The' inspector. did not conduct a very detailed inventory of-each ERF emergency kit, survey equipment, instrumentation, or supplies. However, J the inspector did verify that appropriate documents used for response- to emergencies were up to date and readily available in the TSC, EOF, and Control - Roo The Safety Parameter Display System (SPDS) was also observed and appeared to be operational for providing plant data during an i emergency. In addition, offsite monitoring kits were examined in the EOF and Security Buildin No violations or deviations were identifie . Organization and Management Control (82701-02.03)

The inspector's discussion with licensee rep'resentatives disclosed a

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significant change in the organization and management of the emergency preparedness progra According to licensee representatives and a review i of licensee documentation, significant. organizational changes ' were recently made in the management of Nuclear Security, Emergency Planning,

! and the Industrial Safety Programs. According to licensee documentation dated February 12, 1987, the specific changes and basis for making those-changes are as follows: The positions of Manager, Nuclear Security and Captain, Nuclear' I Security were upgraded by one level to new positions known as

" Manager, Nuclear Protection Services," and " Associate manager, Nuclear Security," respectivel Basis: New position levels more accurately reflect the overall

importance of Nuclear Security and Emergency Planning in the safe,

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reliable operation of the Summer Station and the attention given to these areas by NR Centralization of the Shift Lieutenants, Security Training

Instructor, and .the Security Maintenance Supervisor under the

Associate Manager, Nuclear Security.

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Basis: Centralization of these non-administrative functions under one supervisor improves the integration of these activities and

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enhances the ability of the organization to respond to maintenance concerns, Reporting to the Manager, Nuclear Protection Services is the

, Associate Manager, Nuclear Security, Security Administrative l Supervisor, and the Emergency Planning Coordinator. Reporting to the Err,ergency Planning Coordinator is the newly established position of l- Industrial Safety Specialist.

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Basis: The Manager, Nuclear Protection Services has been given the additional management responsibility of Emergency Planning and Industrial Safety functions in an effort to centralize under one supervisor all activities which routinely interface with the same State and local agencies. This change improves the ability to coordinate these activities and emphasizes single point accountabilit From the above' list of organizational changes, the most significant change regarding emergency preparedness involved the position of Manager, Nuclear Protection . Services. The individual filling that position previously served as the Corporate Emergency Planning Coordinator. The Corporate-Emergency Planning Coordinator had line responsibility for the review and update of the Corporate Emergency Management Plan, the V. C. Sumer Radiation Emergency Plan, the interface with State and local governments, and other corporate EP matters (procedural development, maintenance of the emergency plan, ._ equipment procurement, etc.). As a result of the i reassignment, management responsibility for emergency planning will not be changed; however, -the _ reporting chain for both onsite and offsite emergency planning was changed. All onsite and offsite emergency planning -

will be a site function under the management control of the Manager, Nuclear Protection Services. Daily activities involving the Station o Corporate Emergency Planning Program will be handled by the Station Emergency Coordinato The licensee interface with offsite agencies (State. and local- governments) will be handled by the Manager, Nuclear Protection Services. As a result of the aforementioned changes, the position of Corporate Emergency Planning Coordinator was deleted from the organizational char The inspector reviewed Figure 5-2, "V. C. Sumer Nuclear Station Functional Organization," dated February 1987, Revision 19, to ascertain the impact of this organizational change on the Emergency Preparedness j Progra It appears as though this change will not decrease the

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effectiveness of the emergency preparedness program. However, at the time of .the inspection, SCE&G management had not made a final determination regarding the role that the Manager, Nuclear Protection Services would

fill ~in the emergency organization. The inspector was informed that the current plans are to initially report to the TSC until the E0F is l activate Following E0F activation, the Manager of Nuclear protection i

L Services will report to the E0F to fill the position formerly filled by l the Corporate Emergency Planning Coordinator (Data Logger for the Offsite

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Emergency Coordinator). The security position for the TSC organization will be filled by the Associate Manager, Nuclear Securit Training records for selected individuals assigned to the emergency organization since the last inspection were reviewed to determine if training was in accordance with the requirements of EPP-018, " Emergency Training and Drills," and Section 8.0 of the V. C. Summer Radiation Emergency Pla No violations or deviations were identifie , . -

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- Training (82701-02.04)

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Pursuant - to 10 CFR 50.47(b)(15) and 10 CFR Part 50, Appendix E, Section

IV.F, this area was inspected to determine whether emergency response personnel understood their emergency response roles and could perform

.their assigned function The inspector reviewed Section 8.0 of the Emergency Plan and EPP-018 for a description of- the training program, and training procedure In addition, selected lesson plans were reviewed and members of the instructional staff were interviewed. Based on these reviews an interviews, the inspector determine that the licensee maintains a formal-

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emergency training program.

[ During December 1986, the licensee revised Emergency Plan Procedure 001 i (EPP-001) titled " Activation and Implementation of Emergency Plan." This revision (Rev.11) dated December 9, 1986, supersedes Revision 8 of EPP-001 which implemented the fission product barrier approach to emergency classificatio Revision 11 reinstates the event-oriented approach to emergency classification. As a result, training records for key members of the onsite and offsite emergency organization for the period February 1986 to January 1987 were reviewed. . According to training records, personnel had received training on the revised classification procedur In addition, according to licensee documentation EPT-87-0002, training was provided to the offsite government agencies on the revised d

classification procedure during January 1987.- Included in the offsite

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agencies training was a tabletop exercise . involving incident classification, protective action recommendations, and notification ; The_ inspector conducted walk-through evaluations with selected key members of. the emergency organization. During these walk-throughs, individuals were given various hypothetical sets of emergency conditions and data and asked to respond as if an emergency actually existe The individuals

, demonstrated familiarity with emergency procedures and equipment, and no problems were observed in the areas of emergency detection, classification, and protective action recommendations.

j No violations or deviations were identifie . Independent Reviews / Audits (82701-02.05)

t 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 program.

i Records of audits of the program were reviewed. The records showed that i an independent audit of the program was conducted by the Quality Assurance Group during the period January 7,1987, through February 4,1987. This audit fulfilled the 12-month frequency requirement for such audits. Three findings resulted from this audit repor Those findings and recommendations were presented to plant and corporate managemen A l

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further review regarding the corrective actions for resolving those findings disclosed that two of the tliree items have been resolved, and the third item should be completed by May 1,198 The licensee's program for followup action on audit, drill, and exercise findings were reviewe Licensee procedures required followup on deficient areas identified during audits, drills, and exercise The licensee has established a tracking system known as the " Regulatory Tracking System (RTS)" for use as a management tool in following up on actions taken in deficient areas. In addition, the Site Emergency Planning Coordinator maintains a tracking system. The inspector reviewed a printout from the Regulatory Tracking System. It was noted that items are assigned to various departments or individuals with a tentative completion date. In several cases the items were completed prior to the completion date. In general, it appears that appropriate, corrective actions are being taken in a timely manne No violations or deviations were identifie . Inspector Followup (92701) (Closed) Inspector Followup Item (IFI) 86-IN-98: Offsite Medical Services. The inspector reviewed the licensee's letters of agreement with offsite medical facilities to verify that agreements were current for providing medical services to licensee personnel. A recent decision by NRC disclosed that there is currently no need for Regional Inspector involvement for the inspection of licensee arrangements for providing medical services for members of the general public, (Closed) Exercise Weakness 50-395/87-03-03: Identify and maintain all offsite radiological emergency monitoring / surveillance procedures in field team kits as Controlled issues. The inspector reviewed offsite monitoring kits in the licensee's Emergency Operations Facility (E0F), and the Security Building. It was noted that all monitoring and surveillance procedures had been assigned a Copy l number which is considered a control cop (0 pen) IFI 86-05-05: Review and correct the discrepancy between the computer and manual method for source term calculations. According to a licensee representative, this matter was still being reviewed by the Corporate Health Physics Grou t