ML18150A113

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Insp Repts 50-280/87-12 & 50-281/87-12 on 870504-08. Violation Noted:Failure to Provide Training to Various Members of Emergency Organization Per Emergency Plan
ML18150A113
Person / Time
Site: Surry  Dominion icon.png
Issue date: 05/20/1987
From: Decker T, Tabaka A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18150A111 List:
References
50-280-87-12, 50-281-87-12, NUDOCS 8706030060
Download: ML18150A113 (14)


See also: IR 05000280/1987012

Text

Report Nos. :

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTA STREET, N.W.

ATLANTA, GEORGIA 30323

MAY 2 6 1987

50-280/87-12 and 50-281/87-12

Licensee:

Virginia Electric and Power Company

Richmond, VA

23261

Docket Nos.:

50-280 and 50-281

Facility Name:

Surry 1 and 2

Inspection Conducted:

May 4-8, 1987

Inspector:(~ J~

License Nos.: DPR-32 and DPR-37

{-t'r A. E. Tabaka *

s/2~'(.8 7

Date'S1gned

Accompanying Personnel:

E. D. Testa

A

/7

(r

/

Approved by: ~ -K . {/t,~,hc

T. R. Decker, Section Chief

Division of Radiation Safety and Safeguards

SUMMARY

Scope:

This routine, unannounced inspection was to evaluate selected areas of

the emergency preparedness program.

Results:

One violation was identified

Failure to provide training to various

members of the emergency organization in accordance with the Emergency Plan *

8706030060 870526

PDR

ADOCK 05000280

G

PDR

REPORT DETAILS

1.

Persons Contacted

Licensee Employees

  • E. S. Grecheck, Assistant Station Manager (NS&L)
  • H.L. Miller, Assistant Station Manager (O&M)
  • R. H. Blount, Superintendent Technical Services
  • D. J. Burke, Superintendent Maintenance
  • S. P. Sarver, Superintendent Health Physics
  • A.H. Friedman, Superintendent Nuclear Training
  • J. B. Costello, Coordinator Emergency Planning
  • B. A. Garber, Health Physicist
  • J. A. Price, Manager Quality Assurance
  • E. M. Topping, Senior Instructor
  • R. L. Johnson, Operations Coordinator
  • T. J. Szymanski, Associcate Health Physicist, Corporate
  • W. D. Craft, Licensing Coordinator
  • S. R. Burgold, Operations Coordinator (Projects)

C. Smith, Senior Clerk

V. Jones, Supervisor of Offices

K. Sloan, Shift Supervisor

M. Gabriel, Senior Reactor Operator

G. Polson, Coordinator Emergency Preparedness, Corporate

F. Cox, Supervisor Emergency Planning, Corporate

M. Haduck, Electrical Maintenance Supervisor

P. Blount, Assistant Health Physics Supervisor

J. Butrick, Health Physics Technician Trainee

Other licensee employees contacted included engineers, technicians,

operators, security force members, and office personnel.

Other Organizations

G. Urguhart, Department of Environmental Services, Conmonwealth of

Virginia

A. Warren, Department of Environmental Services, Conmonwealth of Virginia

J. Tokarz, Assistant County Administrator, Surry County

Nuclear Regulatory Commission

  • W. E. Holland, Senior Resident Inspector
  • S. G. Tingen, Inspector, Region II
  • L. E. Nicholsen, Resident Inspector
  • C. P. Patel, NRR - Licensing Project Manager
  • Attended exit interview

2.

2

Exit Interview (30703)

The inspection scope and findings were summarized on May 8, 1987, with

those persons indicated in Paragraph 1 above.

The inspector discussed the

areas evaluated and summarized the findings to include the one unresolved*

item* and the violation of regulatory requirements.

The violation

involved the failure to provide training to emergency response personnel

in accordance with the Emergency Plan and is discussed in Paragraph 9.

The licensee aid not take -exception -to any of the--items identified and -

committed to consider those areas identified as Inspector Follow-up Items.

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

This subject was not addressed in the inspection.

4.

Unresolved Items

5 *

One unresolved item pertaining to the evacuation of non-essential site

personnel upon declaration of a Site Area or General Emergency was

identified and is discussed in Paragraph 6.

Emergency Detection and Classification (82201)

Pursuant to 10 CFR 50.47(b)(4); 10 CFR Part 50, Appendix E, Sections IV.B

and IV.C; and Section 4.0 of the licensee's Emergency Plan, this program

area was inspected to determine whether the licensee used and understood a

standard emergency classificat_ion and action level scheme.

The inspector reviewed the licensee's classification procedure, Emergency

Plan Implementing Procedure (EPIP) 1.01, "Emergency Manager Controlling

Procedure," and pertinent portions of the Emergency Plan.

The event

classifications in both* the Plan and procedures were consistent with the

four standard classes required by regulation.

The classification scheme

did not contain any significant errors which would lead to incorrect or

untimely classification.

One discrepancy between the Plan and procedures

for the Site Area Emergency EAL, "Secondary line break with primary to

secondary leakage greater than 50 gpm and fuel damage indicated" was

noted. There appeared to be a typographical error for the Main Steam Line

High Range Radiation Monitor.

The licensee agreed to correct this error

in the next Plan revision.

Selected emergency action levels (EALs) specified in EPIP 1.01 and the

Plan were reviewed.

Those EALs examined appeared consistent with the

initiating events specified in Appendix 1 of NUREG-0654.

Many of the

licensee's EALs were based on specific plant parameters obtainable in the

Control Room, in addition to radiological monitoring results *

  • Unresolved Items are matters about which more information is required to

determine whether they are acceptable or may involve violations or deviations.

3

The following notification procedures were reviewed:

EPIP 2.01, Notification of State and Local Governments

EPIP 2.02, Notification of NRC

The Plan, in addition to the controlling procedures for each emergency

class, included criteria for initiation of offsite notifications.

These

procedures required that offsite notifications be made to the Commonwealth

and loca-1 governments within 15 minutes of -emergency declaration and to

the NRC no later than one hour after declaration.

The procedures a 1 so

contained criteria for transmitting protective action reconmendations as

applicable.

The inspector discussed with licensee representatives the coordination of

EALs with Commonwealth and local officials. Licensee documentation showed

that the annual

EAL review with Commonwealth and local government.

officials was held August 4, 1986.

Licensee representatives indicated

that no dissenting comments were received.

Interviews*were held with two shift supervisors to verify that they

understood the relationship between core status and such core damage

indicators as containment high-range radiation monitor, fuel temperature

indicator, containment hydrogen monitor, and post-accident primary coolant

analysis.

These interviewees appeared knowledgeable of the various

indicators.

The responsibility and authority for classification of emergency events

and initiation of emergency actions were clearly described in the

Emergency Plan and Implementing Procedures.

Interviews with selected key

members of the licensee's emergency organization revealed that these

personnel understood their responsibilities and authorities in relation to

accident classification,

notifications,

and

protective action

recommendations.

Selected Emergency and Abnormal Procedures were reviewed by the inspector

and discussed with licensee personnel.

These procedures directed the

users to implement the emergency classification procedure.

In many cases,

the emergency action level scheme and controlling procedures also

cross-referenced back to the applicable Abnormal and Emergency Procedures.

Walk-through evaluations involving accident classification problems were

conducted with several individuals designated as interim and alternate

Station Emergency Manager.

Personnel interviewed properly classified the

hypothetical accident situations presented to them and appeared to be

familiar with appropriate classification procedures.

The inspector reviewed licensee documentation of actual licensee events

for the period April 1986 to April 1987 to verify that events which

occurred during .this time were properly classified and that the

notifications were made within the applicable time frames.

In general,

the documentation was in order and actions appropriate to the emergency

were performed in a timely manner.

In addition, the inspector reviewed

the licensee's self-critique of the implementation of the Emergency Plan

4

during the December 9, 1986, incident. It appeared that the licensee had

adequately addressed and corrected the problems noted during the event,

particularly in the area of offsite corrvnunications.

No violations or deviations were identified.

6.

Protective Action Uecision-Making (82202)

-Pursuant- to 10 CFR 5ff.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 and onsite workers.

The inspector discussed responsibility and authority for protective action

decision-making with licensee representatives and reviewed pertinent

portions of the licensee's Emergency Plan and procedures.

The Plan and

procedures clearly assigned responsibility and authority for accident

assessment and protective action decision-making.

Interviews with members

of the licensee's emergency organization showed that these personnel

understood their authorities and responsibilities with respect to accident

assessment and protective action decision-making.

lhe inspector reviewed the Plan and pertinent EPIPs to determine that the

licensee had made adequate provisions for protecting onsite and offsite

individuals in the event of an emergency.

The licensee had the criteria

and methodology in place for making offsite protect1ve action

recommendations based on core status and radiological release data

consistent with those required by regulation.

However, the licensee had

not provided for a similar level of protection for onsite, non-essential

personnel in the event of an emergency. Specifically, the licensee's Plan

and procedures did not explicitly require the evacuation of non-essential

personnel upon declarat10n of a Site Area or Genera I Emergency in

accordance with NUREG-0654,Section II.J.4.

The licensee's onsite

evacuation -criteria contained in Sections 6.5.b and 6.4.1.1.a of the

Emergency Plan, EPIP 1.04,

11Response to Site Area Emergency," EPIP 1.05,

11Response to General Emergency,

11 and EPIP 4.07,

11 Protective Measures,

11 was

based solely on radiological parameters.

This was contrary to regulatory

guidance where such decision-making shall be based on event

classification/plant conditions.

Sole use of radiological data to

determine the protection to be afforded site personnel neither explicitly

nor implicitly met the protective action guidance presented in NUREl:i-0654.

This variance from published Federal guidance was not in accordance with

10 CFR 50.47(b){10) and was identified to the licensee as an unresolved

item pending further agency review.

Unresolved Item {50-280, 281/87-12-01):

Evacuation of non-essential site

personnel upon declaration of a Site Area or General Emergency.

Walk-through evaluations involving protective action decision-making were

conducted with three individuals designated to fill the position of

Station Emergency Manager.

Personnel demonstrated familiarity with the

5

use of procedures for making offsite protective actions, and they

understood the need for timeliness in making such recommendations to

offsite officials.

Given hypothetical situations, these individuals were

able to formulate the appropriate protective action recommendation for the

public.

Licensee procedures made provisions for contacting responsible offsite

authorities on a 24-hour basis.

Backup communications links with offsite

-authorities were ava-ilable.

The inspector independently confirmed that

Commonwealth and county authorities could be contacted from the Control

Room using the Insta-phone ringdown system.

/

The inspector reviewed the licensee's and Commonwealth of Virginia's

emergency response plans to determine that Commonwealth decision-makers

had predetermined criteria for use in protective action decision-making

which were consistent -with those used by the licensee.

This review

indicated the protective action. guides were consistent, and that the two

entities had agreed upon their use in a letter from the Commonwealth to

the licensee dated March 4, 1985.

No violations or deviations were identified.

7.

  • Notification and Communication (82203}

Pursuant to 10 CFR 50.47(b}(5} and (6}; and 10 CFR Part 50, Appendix E,

Section IV.D; and Sections 4.0 and 7.0 of the licensee's Emergency Plan,

this area was inspected to Qetermine whether the licensee was maintaining

  • a capabi 1 i ty for notifying and communicating {in the event of an

emergency) among its own personnel, offsite supporting agencies and

authorities, and the population within the EPZ.

The inspector reviewed the licensee's notification procedures.

The

procedures were consistent with the emergency classification and EAL

scheme used by the licensee.

The inspector determined that the procedures

made provisions for message verification.

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

agencies.

The licensee's management control program for the prompt notification

system was reviewed.

According to licensee documentation and discussions

with licensee representatives, the system consisted of 48 fixed sirens.

Thirteen additional sirens are to be added in the near future to enhance

the notification coverage. A review of licensee 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

January 1986 to January 1987.

The records showed that the required tests

6

were completed and that no abnormal maintenance or equipment failure

existed.

Communications equipment in the Control Room, Operations Support Center

{OSC), Technical Support Center {TSC), and Local Emergency Operations

Facility {LEOF) was inspected.

Provisions existed for prompt

communications among emergency response organi zati ans, to emergency

.response . personne,l, and to the public.

The installed communications

systems at the emergency response faci l i-ties were -consistent with system

descriptions in the emergency plan and Implementing Procedures, with the

exception of the Health Physics Network {HPN) as noted in Paragraph 7

below.

The inspector conducted operability checks on selected communications

equipment in the Control Room.

No problems were observed.

The inspector

reviewed licensee records for the period January 1986 to January 1987

which indicated that communications checks. were conducted at the specified

frequencies.

Licensee records al so revealed that corrective action was

taken on problems identified during communications checks.

Redundancy of offsite* and onsite communication links was discussed with

licensee representatives.

The inspector verified that the licensee had

established a backup communications system which made use of the

following: 1) Various internal and external Ringdowns; 2) county and

Commonwealth Insta-phone Loop; 3) .General Office Off-Premises Extension;

4) Private Branch Exchange; 5) Commercial Phones; 6} Two-way UHF radio to

the local Sheriffs office; 7) State Controlled Administrative Telephone

System.

The

inspector requested and observed an unannounced

communications and notification check using the county and Commonwealth

Insta-phone Loop system.

No violations or deviations were identified.

8.

Changes to the Emergency Preparedness Program (82204)

Pursuant to 10 CFR 50.47{b)(16); 10 CFR 50.54(q); and 10 CFR Part 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

{ February 1986) and to note how these changes affected the overa 11 state

of emergency preparedness.

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

Emergency Plan and Implementing Procedures.

The inspector reviewed

Sections 8.2.1 and 8.2.2 of the Emergency Plan and Procedure SUADM-LR-01,

"Station Nuclear Safety and Operating Co111111ittee,

11 which govern the review

and approval of changes to the Plan and procedures.

The inspector

verified that changes to the Pl an and procedures were reviewed and

approved by management as required~

-

The inspector reviewed licensee documentation to determine that the

licensee had performed a review and update of the Emergency Pl an and

Emergency Telephone Directory as required by Sections 8.2.1 and 8.2.3 of

the Emergency Plan.

The dqcumentation indicated that the reviews and

7

updates were performed for 1986 as appropriate.

However, during a review

of several procedures which support the Emergency Plan, a procedure was

identified which had not been updated in a timely manner.

Specifically,

in June 1986, an error in a conversion factor was identified in AP-5.20,

Radiation Monitoring System Ventilation Vent Monitors Alert/Alarm," and a

formal deviation was written. Although this deviation was reviewed by the

Station Nuclear Safety and Operating Committee no action had been taken to

date to correct the error.

Follow-up on the revision to this procedure

will oe reviewed at a future date. - -

Inspector Follow-up Item (50-280, 281/87-12-02): Untimely implementation

of corrective action to a known error in AP-5.20.

During the period of March 1986 to May 1987 several revisions were made to

the Emergency Plan and Implementing Procedures.

Upon Regional review no

changes were identified to have decreased the Plan's effectiveness.

It.

was determined by transmi tta 1 1 etter review a 11 these

changes were

submitted to the NRC within 30 days of the effective date as. required~

with one exception.

In a letter dated J~ne 5, 1986, from the licensee to*

the NRC Region II, it was identified that several revised Implementing

Procedures had not been submitted as. required.

Upon identification of the

problem, the licensee performed an internal audit of the procedures to

ensure that all revisions were properly transmitted, those that were not

wer~ sent, and a 30 day conmitment was entered into its internal

Commitment Tracking System to ensure future transmittals were timely. The

inspector noted the implemented corrective actions, and found no submittal

problems after July 1986.

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

to the Emergency Plan and Implementing Procedures.

Examination of

selected controlled copies indicated that the appropriate onsite persons

were sent copies of the changes made since the last routine inspection.

Although no controlled copies of the Plan and procedures were found to be

out-of-date, the inspector did observe that the licensee had failed to

remove old, uncontrolled emergency procedures from the LEOF Corporate

position packets.

The licensee did not rectify this problem during the

course of the week; however, the procedures still remain uncontrolled.

The maintenance of these packets will be reviewed at a future date.

Inspector Follow-up Item: (50-280, 281/87-12-03): Failure to remove old,

uncontrolled procedures from the LEOF Corporate position packets.

Discussion with licensee representatives concerning modifications to

facilities, equipment, and instrumentation indicated that several changes

8

had been made.

These changes included installation of the new Health

Physics Network Phones and the completion of the Safety Parameter Display

System Computer.

The Plan has not yet been updated to reflect these

recent changes; however, the licensee indicated this would be performed

during the next Plan revision.

The organization and management of the emergency preparedness program were

reviewed.

Since the last routine inspection, several plant management

changes have been made as- we 11 * as- the pl a cement of a new person in the . _

position of Site Emergency Preparedness Coordinator.

Because these

personnel changes do not reflect any change in assfgnment of

responsibility, they, in themselves, do not appear to have any affect on

the Plan

1s implementation.

Further discussion with licensee

representatives also disclosed that there had been no significant changes

in the organization and staffing of Corporate and offsite support agencies

since the last inspection.

No violations or deviations were identified.

9.

Knowledge and Performance of Duties (Training) (82206)

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

IV.5; this area was inspected tci determine whether emergency response

personnel understood their emergency response roles and could perform

their assigned functions.

The inspector reviewed the description (in the Emergency Plan) of .the

training program,* training procedures, and selected lesson plans, and

interviewed members of the instructional staff.

Based on these reviews

and interviews, the inspector determined that the licensee had established

a formal emergency training program.

The inspector reviewed training records .for key members of the emergency

organization for the period January 1986 to April 1987. A random s.ampl ing

of the training record for approximately twenty (20) individuals indicated

that eight (8) had not received specialized emergency training as required

-by Section 8.3 and Table 8.1 of the Emergency Plan.

The individuals

lacking the required training were from various alternate positons in the

emergency organization.

Typically, emergency training provided to upper

management and technician level personnel appeared adequate while most of

the individuals deficient in training were mid-level management in the

normal plant organization.

In addition, Section 8.3.1 of the Plan stated

that the department superintendent and supervisors have been assigned the

responsibility for ensuring that their personnel receive adequate

training.

This responsibility also included the identification of

specific individuals who may serve as primary, interim or alternate

emergency response personnel.

Although departmental emergency

notification call-out listings were available, a formal identification of

emergency position personnel was not found for each department.

The

.

failure to ensure that all personnel expected to respond to an emergency

9

receive the training required by the Plan was identified to the licensee

as a violation.

Violation: (50-280, 281/87~12-04) Failure to provide training to response

personnel in accordance with the Emergency Plan.

According to the licensee's documentation, other aspects of the training

program were being provided.

Records indicated that emergency drills were

contfucted in accordance with Section 8.5 of t-he Emergency Plan.

These

drills included communications, medical transport, environmental,

radiological, and post-accident sampling drills.

In most cases, the

drills were conducted in conjunction with the annual exercise.

The inspector also reviewed documentation concerning the training of

offsite support agencies.

These records showed that the groups indicated

in Sections 8.4 and 8.8 of the Plan were invited to participate in annual

training. Actual participation by the local groups appeared satisfactory.

Discussions with licensee representatives and documented meeting agendas

indicated the required training subjects were offered.

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 walk-through the response as they would during an actual

emergency.

The individuals demonstrated familiarity with their emergency

response roles, and no problems were observed in the areas of emergency

detection and classification, notifications, dose calculation and

protective action decision-making.

One violation was identified.

10.

Dose Calculation and Assessment {82207)

Pursuant to 10 CFR 50.47{b){9), this area was inspected to determine

whether there was an adequate method for assessing the consequences of an

actual or potential radiological release.

The inspector reviewed the following dose assessment procedures: EPIP-4.08

titled Initial Offsite Release Assessment and EPIP-4.28 titled Class "A"

Dose Calculation Model.

The procedures had provisions for calculating doses for ground, monitored

and unmonitored pathways such ,as the plant building vents, containment

leakage, and steam releases.

The procedures allowed for refinement of

dose projections through incorporation of feedback from field monitoring.

The inspector discussed the manual (EPIP), computer (RAD/MET), and

Commonwealth dose projection models to detennine their compatibility. The

differences between the EPIP and RAD/MET have been discussed, and the

differences are understood; however, the documentation to support the

EPIP, RAD/MET and the Commonwealth comparison has not been completed *.

10

Inspector Foll ow-up Item (50-280 ,281/87-12-05) Documentation of the

manual, computerized and Commonwealth dose assessment models such that

differences a re known and understood by a 11 pa rt i es prior to their

required use.

The licensee's procedures made provision for timely incorporation of dose

assessment results into the offsite protective action recommendation

process.

However, during interviews with key licensee emergency response

personnel, they all appeared to recognize the uncertainties associated

with dose projections and the importance of making protective action

recommendations based on plant conditions.

An inspection and operability check were made of *selected equipment and

support items used for dose assessment in the Control Room, TSC, and LEOF.

During the operability check of the Class "A" Dose Calculation Model, the

inspector observed the computer system to be inoperable.

It appeared that

during a system update of the data base configuration, key files needed to

make the system operable were deleted or modified.

This problem had not

been identified by the licensee.

Inspector Follow-up (50-280, 281/87-12-06) program operability of the

computerized dose calculation model.

The inspector requested and observed dose assessment wa 1 k-throughs by

selected licensee personnel designated as responsible for dose projection

during an emergency.

The individuals demonstrated their ability to make

such calculations using both manual and computerized methods after the

missing computer files had been reinstalled.

The inspector discussed the backshift availability of personnel qualified

to make dose calculations.

Licensee representatives stated that such

personnel were avatlable on all shifts.

The inspector verified from a

  • review of current staffing levels and back-shift walk-throughs .that this

capability existed.

No violations or deviations were identified.

11.

License 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 censee 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 Quality Assurance

Department and was documented in. Audit Report No. 86-04, \\dated May 16,

1986.

This audit fulfilled the 12-month frequency requirement for such

audits. A review of the past five annual audit reports indicated that the

licensee had complied with the five-year retention requirement for such

reports, and that the audit findings and recommendations were presented to

plant and*corporate management.

11

The audit records showed that the Commonwealth and local government

interfaces were evaluated.

In past audits, QA has identified findings

involving offsite support groups; however, the inspector was not provided

formal documentation that indicated offsite groups had been made aware

that these findings were available for their review.

Inspector Follow-up Item (50-280, 281/87-12-07) Ensure that QA findings

from the- annual Emergency Preparedness Program Audit concerning _the_

offsite interfaces are readily available to ColTITlonwealth and local

authorities.

Licensee emergency plans and procedures required critiques following

exercises and drills.

Licensee documentation dated October 1, 1986,

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's program for follow-up action on audit, drill, and exercise

findings were reviewed.

Licensee procedures required fol low-up. on

deficient areas identified during audits, drills, and exercise.

The

inspector reviewed licensee records for the 1985 exercise which indicated

that corrective actions were taken on identified problems, as appropriate.

The licensee had established a tracking system as a management tool in

following up on actions taken in deficient areas, and deficiencies for the

1986 exercise were being tracked.

No violations or deviations were identified.

12.

Coordination with Offsite Agencies (82210)

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

Emergency Plan, and the agreements had been renewed within the past two

years, as required.

The inspector determined through telephonic

interviews with representatives of selected local and Conmonwealth support

agencies that there were no significant problems related to the interfaces

between the 1 i censee and the offs i te support agencies 1 i sted in

Paragraph 1.

No violations or deviations were identified.

13.

Emergency Facilities and Equipment

Pursuant to 10 CFR 50.47(b)(8); and 10 CFR Part 50, Appendix E, Section

IV. E; this area was reviewed to determine whether adequate emergency

facilities and equipment to support the emergency_ response are provided

and maintained.

12

The inspector toured the various on and near-site emergency facilities

including the Control Room, Technical Support Center, Operations Support

Center, and Local Emergency Operations Facility.

During the tour it was

observed that certain installed radiation monitoring equipment did not

appear operable in the TSC and LEOF.

Although this equipment is

calibrated annually, licensee representatives indicated that the monitors

were not part of a regular performance testing program.

Inspector Follow-u-p Item (50-280, -281/8-'7-12-08) No-periodic-operability - -

_

checks on installed radiation monitoring equipment in the TSC and LEOF.

The tour also revealed that the pressure seals on the penthouse level

exterior doors of the LEOF did not appear to provide a leak tight barrier.

According to licensee representative and the Emergency Plan this facility

is designed to maintain a positive pressure during emergency operation,

and meet the requirements of NUREG-0696.

It was not apparent during the

inspection that preventive maintenance nor testing was performed to ensure

the system could maintain the designed positive pressure.

Inspector Follow-up Item

(50-280, 281/87-12-09): Review documentation to

ensure that LEOF habitability is in accordance with NUREG-0696 as

committed to in the Section 7.1.d of the Emergency Plan.

The inspector reviewed the monthly inventory and operability checks on

selected emergency equipment and kits.

For the period of January 1986 to

December 1986, established kits were inventoried as appropriate. Problems

noted during equipment operability checks were documented and corrected as

. required~

No violations or deviations were identified.

14.

Inspector Follow-up (92701)

a.

(Closed) *Inspector Follow-up Item (IFI) 50-280, 281/87-33-01:

Follow-up on licensee corrective action on 1985 emergency exercise

findings. A sampling of self-identified exercise items was evaluated

and found to be adequately corrected and/or addressed.

b.

(Closed) IFI (50-280/86-08-0l): Emergency position training lesson

plans were not available for review.

The emergency response training

plans were available for each of the training sessions provided.

The

documentation was available which cross-referenced each lesson plan

with the required training class as specified in Table 8.1 of the

Plan.

c.

(Closed) IFI (50-280/86-08-02): Inconsistency in shift supervisor

interviews with respect to protective action decision-making.

Walk-through evaluations were conducted with three individuals

designated as either interim or alternate Station Emergency Manager *

These individuals appeared cognizant of their responsibility to make

13

protective action recommendations and responded with the appropriate

protective action when given hypothetical plant conditions.

d.

(Closed) IE Information Notice 86-98: Offsite Medical Services.

In a

letter dated March 12, 1985, the NRC identified the lack of a

designated back-up hospital for the treatment of site individuals as

an Emergency Plan deficiency.

Upon evaluation of the licensee's

response, _dated April 25, 1985, it was determined that the

arrangement made for medical -services -was appropriate.

The adequacy

of these current arrangements and the need for back-up hospitals for

the treatment of the general public, however, will be evaluated by

FEMA at a later date.

e.

(Closed) IFI (50-280, 281/87-EP-01): Verification of the audibility

of alarms in high noise areas.

The inspectors observed an actuation

test of the various emergency al arms.

Al though during the limited

observation no problems were noted, all documentation concer~ing the

licensee's evaluation of alarm audibility, the placement of

additional PA units, and the deletion of previously implemented

administrative controls in the old EPIP-9 were not available. for

review.

This information will be reviewed in a future inspection.

(Inspector Follow-up Item 50-280, 281/87-12-10)