ML18142A499

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Insp Repts 50-280/85-16 & 50-281/85-16 on 850429-0502. Violation Noted:Failure to Procedurally Require Issuance of Prompt Protective Action Recommendation to Offsite Authorities Upon Declaration of General Emergency
ML18142A499
Person / Time
Site: Surry  Dominion icon.png
Issue date: 05/23/1985
From: Cline W, Kreh J
NRC Office of Inspection & Enforcement (IE Region II)
To:
Virginia Electric & Power Co (VEPCO)
Shared Package
ML18142A497 List:
References
50-280-85-16, 50-281-85-16, NUDOCS 8507010143
Download: ML18142A499 (7)


See also: IR 05000280/1985016

Text

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Report Nos. :

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTA STREET, N.W.

ATLANTA, GEORGIA 30323

MA't 2 9 \\985

50-280/85-16, 50-281/85-16

Licensee:

Virginia Electric and Power Company

Richmond, VA

23261

Facility Name:

Surry Power Station

Docket Nos.:

50-280, 50-281

License Nos.:

DPR-32, DPR-37

Inspection Conducted:

April 29-May 2, 1985

Inspector: Jd'Kr~' ~-

}1 / ~ µ~~'-*

Approved by: fl? r ~~

. E. Cline, C "

5'-Z3*-~S-

Date Signed

~-.,23-£5

Date Signed

Emergency Preparedness Section

Division of Radiation Safety and Safeguards

SUMMARY

Scope:

This routine unannounced inspection involved 27 inspector-hours onsite

and four inspector-hours offsite in the area of emergency preparedness.

Results:

One violation was identified - failure to procedurally require issuance

of a prompt protective action recommendation (sheltering at minimum)

to

offsite authorities upon declaration of a General Emergency .

9507010143 g~g55i00

~DR

ADOCK

PDR

1.

Persons Contacted

Licensee Employees

2

REPORT DETAILS

  • H. L. Miller, Assistant Station Manager, Nuclear Safety and Licensing
  • 8. R. Parkhurst, Coordinator Emergency Planning
  • R. F. Driscoll, Manager, Quality Assurance
  • W. D. Grady, Supervisor, Quality Assurance
  • R. C. Bilyeu, Licensing Coordinator
  • W. R. Benthall, Nuclear Specialist

J. A. Baily, Nuclear Training Superintendent

G. D. Jackson, Shift Supervisor

J. S. Fisher, Assistant Shift Supervisor

F~ P. Jenkins, Assistant Shift Supervisor

Other licensee employees. contacted included technicians and office

personnel.

Other Organizations

B. F. Dixon, Sheriff, Isle of Wight County (VA)

D. Bernd, Director of Public Works, Isle of Wight County

W. C. Andrews, Jr., Sheriff, Surry County (VA)

C. Thompson, Coordinator of Emergency Services, Surry County

NRC Resident Inspector

  • M. J. Davis
  • Attended exit interview

2.

Exit Interview

The inspection scope and findings.were summarized on May 2, 1985,. with those

persons indicated in paragraph 1 abbve. A violation described in paragraph

4 (inadequate procedure for formulating protective action recommendations)

was discussed in detail. Licensee representatives acknowledged the finding

and took no exception. The licensee did not identify as proprietary any of

the material provided to or reviewed by the inspector during this

inspection.

3.

Licensee Action on Previous Enforcement Matters

(Closed) Violation 50-280, 50-281/84-01-01:

Inadequate training of Shift

Supervisors for protective action decision-making.

The inspector reviewed

and verified the licensee 1 s response to the Notice of Violation.

Lesson

plans for Station Emergency Manager training indicated appropriate emphasis

  • upon formulation of protective action recommendations .

3

(Closed) Violation 50-280, 50-281/84-01-02:

EPIP-2.01 not adequate for

transmitting a protective action recommendation to the State unless a

release is occurring. The inspector reviewed the licensee's response to the

Notice of Violation.

Revision 9 of EPIP-2.01 provided for transmission of

protective action recommendations to the State whether or not a release is

occurring.

4.

Protective Action Decision-Making (82202)

Pursuant to 10 CFR 50.47(b)(9) and (10) and 10 CFR Part. 50, Appendix E,

Section IV.D.3, this area was inspected to determine whether the licensee

had 24-hour-per-day capability to assess and analyze emergency conditions

and make recommendations to protect the public.

The inspector discussed responsibility and authority for protective action

decision-making with licensee representatives and reviewed pertinent

portions of the Surry Emergency Plan (SEP) and Emergency Plan Implementing

Procedures (EPIPs).

The SEP and EPIPs clearly assigned responsibility and

authority for accident assessment and protective action decision-making.

Interviews with members of the licensee's emergency organization revealed

that these personnel understood their authorities and responsibilities with

respect to accident assessment and protective action decision-making.

Walk-through evaluations involving protective action decision-making were

conducted with one Shift Supervisor and two Assistant Shift Supervisors.

Personne 1 interviewed appeared to be cognizant of appropriate onsi te

protective measures and aware of the range of protective action recommenda-

tions appropriate to offsite protection.

Personnel interviewed were aware

of the need for timeliness in making initial protective action recommenda-

tions to offsite officials.

Interviewees demonstrated adequate under-

standing of the requirement that protective action recommendations be based

on core condition and containment status even if no release is in progress.

One of the scenarios presented during the walk-throughs involved loss of all

offsite and onsite AC power for 20 minutes, combined with extensive tornado

damage to the Turbine Building.

In accordance with EPIP-1. 01 ( Emergency

Manager Controlling Procedure), all three interviewees properly classified

the hypothetical event as a General Emergency, but incorrectly determined

thit no offsite protection action recommendations would be necessary at that

point.

This is contrary to NUREG-0654 and IE Information Notice 83-28,

which constitute the Federal guidance that the licensee is required by

10 CFR 50.47(b)(10) to follow.

The inspector determined that EPIP-1.05

( Response to Genera 1 Emergency) was inadequate because under certain

accident scenarios the Station Emergency Manager would not be directed to

make a protective action recommendation.

Violation (280, 281/85-16-01):

Failure to procedurally require issuance of

a prompt protective action recommendation to offsite authorities upon

declaration of a General Emergency.

One violation and no deviations were identified in this program area.

4

Changes to the Emergency Preparedness Program (82204)

Pursuant to 10 CFR 50.47(b)(16), 10 CFR 50.54(q), and 10 CFR 50, Appendix E,

Sections IV and V, this area was reviewed to determine whether changes were

made to the program since the last routine inspection (July 1984) and to

note how these cha~ges affected the overall state of emergency preparedness.

The inspector discussed the licensee's program for making changes to the SEP

and the EPIPs.

The inspector reviewed SEP Section 8.2, which governed

review and approval of changes to the plan and procedures.

The inspector

verified that changes to the plan and procedures were reviewed and approved

by management. It was a 1 so noted that a 11 such changes were submitted to

NRC within 30 days of the effective date, as required.

Discussions were held with licensee representatives concerning recent

modifications to facilities, equipment, and instrumentation.

The inspector

toured the Techni ca 1 Support Center (TSC) and Loca 1 Emergency Operations

Facility (LEOF).

These facilities were both formally accepted in early 1985

for use by the station. Appropriate modifications to the SEP and EPIPs were

made to reflect the operational changes associated with these new emergency

response facilities.

The organization and. management of the emergency preparedness program were

reviewed.

The inspector determined that the only recent significant change

in this area was that, as of June 1, 1984, the Coordinator Emergency

Planning reported to the Assistant Station Manager, Nuclear Safety and

Licensing, rather than the Assistant Station Manager, Operations and

Maintenance.

This appeared to enhance the program.

The

inspector's

discussion with licensee representatives also disclosed that there had been

no significant changes in the organization and staffing of the offsite

support agencies since the last inspection.

The inspector reviewed the licensee's program for distribution of changes to

the emergency plan and procedures.

Document control records for the period

July 1984 to April 1985 showed that appropriate personnel and organizations

were sent copies of plan and procedural changes, as required.

No violations or deviations were identified in this program area.

6.

Knowledge and Performance of Duties (Training) (82206)

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 functions.

The inspector reviewed the description (in SEP Section 8) of the training

program, training procedures, and selected lesson plans.

Based on these

reviews, the inspector determined that the licensee had established a formal

emergency training program .

5

Records of training for key members of the emergency organization for the

period March 1984 to March 1985 were reviewed.

The inspector noted that SEP

Section 8.3.3 specified that persons designated to fill positions in the

emergency organization

11will receive, in a timely manner, training necessary

to prepare them to perform their functions during an emergency.

11

It was

determined, however, that individualized training given (generally by the

Coordinator Emergency Planning) to new key members of the emergency

organization was not documented in station training records. The inspector

discussed the desirability of such documentation with a licensee

representative, who agreed to pursue the matter.

Inspector Follow-up Item (280, 281/85-16-02):

Formal system for documenting

individualized training for new members of the emergency organization.

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 respq,nd as if an emergency actually existed.

The individuals demon-

strated familiarity with emergency procedures.

No training-related problems

were observed in the areas of emergency detection/classification and

protective action decision-making, although a procedural inadequacy was

revealed (see paragraph 4).

No violations or deviations were identified in this program area.

Licensee Audits (82210)

Pursuant to 10 CFR 50.47(b)(14) and (16) and 10 CFR 50.54(t), this area was

inspected to determine whether the 1 i cen see had performed an independent

review or audit of the emergency preparedness program.

Records of audits of the program were reviewed.

The records showed that an

independent audit of the program was conducted by the licensee 1 s Quality

Assurance Department on June 18-July 30, 1984, and documented in Audit

Report No. S84-04. This audit fulfilled the 12-month frequency requirement

for such ' audits.

The audit records showed that the State and 1 oca 1

government interfaces were eva 1 uated.

Audit findings and recommendations

were presented to plant and corporate management.

A review of past audit

reports (QA Report Nos. 80-16, 81-19, 82-21, 83-04) indicated that the

licensee complied with the five-year retention requirement for such reports.

Licensee emergency plans and procedures required critiques following

exercises and drills.

Licensee documentation showed that critiques were

held following periodic drills as well as the annual exercise. The records

showed

that deficiencies were

discussed

in

the

critiques,

and

recommendations for corrective action were made.

The licensee 1 s program for follow-up action on audit, drill, and exercise

findings was reviewed.

Licensee procedures required follow-up on deficient

areas i dent ifi ed during audits, dril 1 s, and exercises.

The inspector

reviewed selected licensee records which indicated that corrective action

was

taken on

identified problems, as appropriate.

The licensee had

,.,

6

established a tracking system as a management tool in following up on

actions taken in deficient areas.

No violations or deviations were identified in this program area.

8.

Coordination with Offsite Agencies (92706)

The inspector held discussions with licensee representatives regarding the

coordination of emergency

planning with offsite agencies.

Written

agreements existed with those offsite support agencies specified in the SEP,

and the agreements had been renewed within the past two years, as required.

The

inspector

determined

through

face-to-face

interviews

with

representatives of se 1 ected 1 oca 1 support agencies that the 1 i censee was

periodically contacting those agencies for purposes of offering training and

maintaining mutual familiarization with emergency response roles.

Those

interviews disclosed no significant problems related to the interfaces

between the licensee and the offsite support agencies listed in paragraph 1.

9.

Inspector Follow-up (92701)

a.

(Closed) Inspector Follow-up Item (IFI) 280, 281/81-28-05:

Improvement

in status boards for clarity and data trending. The licensee abandoned

status boards for the TSC and LEOF in favor of video monitors

displaying plant engineering and radiological data. Computer-generated

status sheets provided frequent updates on plant conditions to TSC and

LEOF personnel.

b.

(Closed) IFI 280, 281/83-01-01:

Reconsideration of the initiating

conditions and Protective Action Guidelines for a General Emergency.

The 1 i censee reviewed this matter and determined that consistency

with the State could be maintained only be retention of the State's

dose triggers of 2 rem whole body and 12 rem thyroid at the site

boundary for a General Emergency.

c.

(Closed) IFI 280/83-28-01, 281/83-29-01:

Training on in-plant dose

contra 1 for emergency workers.

Accardi ng to 1 i censee records, this

subject was covered during Health Physics Retraining Sessions completed

on February 29, 1984.

d.

(Closed) I FI 280/83-28-02, 281/83-29-02:

control.

According to licensee records,

during Health Physics Retraining Sessions

1984.

Training on contamination

this subject was covered

comp 1 eted on February 29,

e.

(Closed) IFI 280/83-28-03, 281/83-29-03:

Improvements in training of

Fi re

Brigade.

Accardi ng

to

1 icensee

records,

the

suggested

improvements were incorporated into training and dri 11 s which were

completed for all shifts by December 30, 1984.

f .

(Closed) IFI 280,

281/84-23-01:

Provision of emergency planning

information for transient populations.

According to documents dating

from the period January-February 1985, one sign each was placed at the

7

entrances to Chippokes State Park and the Hog Island Wildlife

Management Area.

The signs both read as follows:

You are within 10 miles of the Surry Nuclear Power Station.

In

the event of a serious accident at the station, persons within 10

miles will be alerted immediately by sirens or public address

systems. After being alerted, turn on your radio for an Emergency

Broadcast System report to receive detailed instructions on

response actions.