ML18152A483
| ML18152A483 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 05/04/1989 |
| From: | Gooden A, Rankin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152A484 | List: |
| References | |
| 50-280-89-09, 50-280-89-9, 50-281-89-09, 50-281-89-9, NUDOCS 8905220044 | |
| Download: ML18152A483 (11) | |
See also: IR 05000280/1989009
Text
Report Nos. :
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W.
ATLANTA, GEORGIA 30323
MAY i 2 1989
50-280/89-09 and 50-281/89-09
Licensee:
Virginia Electric and Power Company
- Glen Allen, VA
23060
Docket Nos.:
50-280 and 50-281
License Nos.: DPR-32 and DPR-37
Facility Name:
Surry 1 and 2
Inspection Conducted:
April 3-7, 1989
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'
Inspector:
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A. Gooden* .*
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W. Rankin, GJ:l'(ef
Scope
Emergency Preparedness Section
Emergency Preparedness and Radiation Protection
Branch
Division of Radiation Safety and Safeguards
SUMMARY
Date Signed
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Date Signed
This routine, unannounced inspection was conducted in the area of emergency
preparedness.
Several aspects of the emergency preparedness program were
inspected to determine if the program was being maintained in a state of
operational readiness for responding to emergencies.
This included a review of
training, changes to the emergency organization, distribution of changes to the
Emergency Plan and Emergency Plan Implementing Procedures (EPIPs), audit
reports, staff augmentation, and the maintenance of key facilities and selected
emergency kits or equipment.
Results
Within the areas inspected, one violation was identified for failure to meet
the augmentation staffing requirements within the time periods specified in
Table 5.1 of the Surry Emergency Plan (Paragraph 7).
Noted program strengths
were as follows:
(1) the utilization of a co~puterized tracking system with
periodic status summaries appeared effective in ensuring that emergency
response personnel training was current and up-to-date; (2) testing,
maintenance, and recent upgrades to the early warning siren (EWS) system; and
(3) the knowledge and familic.rity with classification procedures and the
responsibilities as interim Station Emergency Manager exemplified by an
interviewee during a postulated accident review .
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REPORT DETAILS
1.
Licensee Employees Contacted
R. Beckwith, Coordinator, Corporate Emergency Planning
W. Benthall, Supervisor Licensing *
H. Collar, Supervisor - Quality, Corporate Support
J. Cormier, Manager - Quality, Corporate Support
- J. Costello, Coordinator, Surry Emergency Planning
- F. Cox, Supervisor, Corporate Emergency Planning
H. Finch, Supervisor Telecommunications
M. Gabriele, Assistant Shift Supervisor
- E. Grecheck, Assistant Station Manager
D. Hart, Supervisor - Quality
- M. Holdsworth, Supervisor Security Operations
- R. Lonnemann, Instructor, Emergency Preparedness
R. Macmanus, Supervisor Configuration Management
- A. Meekins, Supervisor Administrative Services
B. Morgan, Staff Quality Specialist
- A. Royal, Supervisor, Power Station Support/Radiation Protection
Other 1 icensee employees contacted during this inspection included
engineers, operators, security force members,
technicians, and
administrative personnel.
Nuclear Regulatory Commission
- W. Holland
- L. Nicholson
- J. York
- Attended exit interview.
2.
Emergency Plan and Implementing Procedures (82701)
Pursuant to 10 CFR 50.47(b)(l6), 10 CFR 50.54(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 (June 1988), and to assess the
impact of these changes on the overall state of emergency preparedness.
The inspector reviewed Section 8.2 of the licensee
1s Emergency Plan and
Station Admi ni strati ve Procedure No. SUADM-ADM-18 (entitled Document
Control) regarding the development, review, approval, and distribution of
changes to the Plan and EPIPS.
Randomly selected procedural changes since
the June 1988 inspection were reviev,ed for verification that licensee
management approvals were in accordance with the procedural requirements
of Station Administrative Procedure No. SUADM-SDM-21.
Controlled copies
of the Station Emergency Plan and EPIPs were audited in the Control Room,
2
Technical Support Center (TSC), Operational Support Center (OSC), Local
Emergency Operations Facility (LEOF), Security Control Room, and select
emergency kits.
With one exception, the selected copies that were
examined, were found to be current revisions.
The one exception involved
a controlled distribution package for* the Radiological Assessment
Director.
The inspector noted during the audit that, EPIP 4.19 (entitled
Radio Operations for Health Physics Monitoring) was not included in the
referenced controlled distribution package as indicated on the master file
distribution index.
The licensee took immediate action to correct this
finding by requesting Document Control personnel be dispatched immediately
with a copy of the current revision for inclusion into the controlled
package.
This finding was not considered significant in that the missing
procedure was an isolated case, and the TSC library, found at the same
location, maintains controlled copies of the Surry Emergency Plan (SEP)
and EPIPs.
The inspector verified that current copies of the SEP and
EPIPs were available in the TSC Library.
The inspector informed the
licensee that the current practices of auditing the controlled packages on
an annual basis and/or for drills and exercises was inadequate and needed
upgrading to include more frequent audits.
Licensee representatives
agreed with this finding and committed to conducting more frequent audits
of the contra 11 ed di stri buti ons to the Emergency Response Faci 1 i ty' s
packages.
The inspector informed licensee representatives that this
matter was considered an Inspector Follow-up Item (IFI) for review during
a subse~uent inspection .
I FI 50-280, 281/89-09-01:
Conduct more frequent audits of the EPI Ps
controlled distributions.
The inspector reviewed documentation for randomly se 1 ected Pl an and
prqcedure changes to verify that submit ta 1 s were made to NRC within
30 days of the approval date.
It was noted that all submittals were
within 30 days after the changes were made, and signatures on concurrence
sheets were consistent with those required for concurrence.
The inspector conducted a review of. randomly selected plant emergency
action levels (EALs) in preparation for conducting a walkthrough with a
key member of the licensee's emergency response organization (see
Paragraph 5).
Within the scope of the review, the licensee's emergency
classification and action level scheme was generally consistent with
guidance contained in NUREG-0654, Revision 1.
However, it was noted
that an EAL for the Notification of Unusual Event (NOUE) involving the
loss of plant communication capability had been changed.from the
initially established EAL, which included failure of all onsite
communication capability including the Station Private Branch Telephone
Exchange (PBX).
The PBX system provides switched local and trunked
telephone service.
The current EAL as*written, only includes the station
Gai-tronics system and station UHF radio.
Absent was the loss of offsite
communications.
The licensee was informed that the current EAL involving
loss of plant communications capability does not meet the intent of
NUREG-0654 involving the loss of significant communication capability.
The licensee agreed to review and revise the EAL to meet the intent of
3
Subsequent to the inspection, the inspector was contacted
telephonically by the Supervisor Emergency Planning and informed that a
detailed review had been conducted.
Based on the review, the licensee is
committed to revise the referenced EAL to reinstate the PBX system.
Regarding the loss of offsite commu*nications, notification requirements
are addressed in a Station Administrative Procedure governing 10 CFR 50.72
reporting.
The licensee representative was informed that this item will
be reviewed during a subsequent inspection.
IFI 50-280, 281/89-09-02:
Revise the NOUE EAL involving the loss of plant
communications capability to include the PBX system.
No violations or deviations were identified.
3.
Emergency Facilities, Equipment, Instrumentation, and Supplies (82701)
Discussions were held with a licensee representative concerning
modifications to facilities, equipment, and instrumentation since the last
inspection.
The inspector toured the onsite emergency response facilities
(ERFs) and noted that facilities were in accordance with the description
in Section 7.0 of the SEP.
Since the June 1988 inspection, the following
changes had been made to key facilities and equipment:
0
0
During September 1988, the Corporate Emergency Response Center (CERC)
was relocated from the Corporate Headquarters Building at James River
Plaza (Richmond, VA) to the Innsbrook Technical Center in Richmond,
VA.
This facility was activated during the 1988 annual exercise, and
no problems were noted as a result of the relocation.
Consequently,
this facility was not inspected.
Regarding equipment changes, upgrades were made to the EWS.
During
January 1989, the EWS was upgraded with a Whelan, computerized,
control and feedback system.
According to licensee representatives,
this system should reduce spurious activations, provide quick
assurance of test results, and simplification of siren activation
procedure.
In -assessing the operational status of the emergency facilities, the
inspector verified that protective ~quipment,
and supplies were
operational and inventoried on a periodic basis.
Emergency kits and/or
cabinets from the TSC, Control Room, OSC, LEOF, and Maintenance Service
Complex were inventoried and randomly selected equipment was *checked for
operability.
The selected- equipment displayed current calibration
sticker, and successful battery checks were obtained.
Equipment
operability status, or response to a source check could not be immediately
determined.
The licensee's current practice is to determine equipment
operability by conducting a monthly source check.
The inspector informed
a licensee representative that, a mechanism for determining the
operability status of portable survey equipment by survey teams prior to
deployment,
would provide assurance regarding the reported detectable or
non-detectable levels of radiation following an accident.
The inspector
4
indicated there was no regulatory requirement for such device; however,
without assurance that equipment is operational, erroneous data could be
provided by field monitoring personnel.
This matter was discussed with
licensee representatives for consideration as a program improvement item.
The licensee agreed to review and evaluate, providing the capability in
the emergency kits for ensuring the operability of radiation survey
instruments prior to placing equipment in service.
The inspector informed
licensee management that this item will be tracked as an IFI for review
during a subsequent visit.
IFI 50-280, 281/89-09-03:
Review and evaluate, providing a capability in
the emergency kits for ensuring the operability status of portable survey
instruments.
By review of applicable procedures and check-list documentation covering
the period of May 1988 to March 1989, the inspector determined that
emergency equipment (e.g. communication equipment and emergency kits) were
being checked in accordance with the procedures governing such tests
(PT-55.3 and PT-55.4).
Records reviewed indicated that all discrepancies
or problems identified during inventories and communications checks were
corre~ted in a timely man~er.
The licensee's management control program for the EWS was reviewed.
According to discussion with a licensee representative, the current system
consists of 60 sirens.
The licensee provided siren test records for the
period May 1988 to March 1989.
The records showed that test were being
conducted at the frequency specified in Appendix 3 of
NUREG-0654 and
licensee's Periodic Test Procedure Nos. PT-55.5 and 55.6.
Documentation
was also provided to show that monthly maintenance was performed on the
EWS in accordance with Procedure No. SMS-EWS-02.
Further, documentation
was available in the form of deviation reports to show that corrective
action taken in response to failed sirens were well documented.
In the
event failures involved 25 percent ( or more) of the sirens, Procedure
No. SUADM-0-12 requires that notification be made to the NRC via the
Emergency Notification System (ENS).
No such notification was required
during the period for which records were audited (May 1988 to March 1989).
As part of the emergency communication equipment the inspector discussed
with a licensee contact the_ periodic testing of the plant emergency
warning system for high noise areas.
According to discussions with the
licensee contact, the emergency evacuation system consists of red beacon
lights and an evacuation alarm sounded over the plant public address
system.
According to the 1 i ce'nsee contact and documentation entitled
Operations PT/Work Schedule, the emergency alarms are tested weekly; and
the rotating lights are tested monthly.
A detailed review of this area
(testing, maintenance, and documentation) will be conducted during a
future inspection.
No violations or deviations were identified .
5
4.
Organization and Management Control (82701)
The inspector's discussion with a licensee representative disclosed that
several admi ni strati ve changes had been made to both the normal and
emergency organization since the June 1988 inspection as a result of
reassignment or promotion.
Example of changes in this category at the
station included the reassignment of the person previously filling the
position of Maintenance Manager at North Ahna Station, to the position of
Station Manager at Surry.
The person previously assigned as Outage
Manager, was reassigned to the position of Assistant station Manager for
Operations; and the person previously designated as a Shift Supervisor was
reassigned to the position Superintendent of Operations.
There were other
examples of changes in this category; however, the aforementioned changes
had no significant impact on emergency preparedness.
Regarding changes at
the Corporate Office, the most s i gni fi cant change impacting emergency
preparedness involved the reporting chain for emergency planning.
The
reporting chain for emergency preparedness was reassigned from the Manager
Licensing to the Manager Programs.
An additional change considered
significant from an administrative standpoint, involved the reassignment
of the person previously filling the position of Senior Vice President Power
to the position Senior Vice President Nuclear.
As previously stated, the
changes had no impact on the operational readiness of emergency
preparedness.
When training and qualification records were reviewed for
individuals reassigned within the onsite emergency organization as key
asses~ment personnel -(eg. Station tmergency Managers and Accident
Assessment), no problems were noted.
Regarding the off site emergency
support organizations, the inspector was informed that an individual was
recently appointed as the Surry County Emergency Services Coordinator.
No
other changes had been made.
No violations or deviations were identified.
5.
Training (82701)
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 ro 1 es and could perform
their assigned functions.
The inspector reviewed Section 8.3 of the Emergency Plan for a description
of the training program and training procedures.
In addition, selected
lesson plans were reviewed, and personnel with the responsibility for
conducting the training were interviewed.
Based on these reviews and
interview, the inspector determined that the licensee had established and
now maintains a formal emergency training program.
As a method of ensuring
that emergency response personnel training is maintained current and
up-to-date, the licensee utilizes a computerized tracking system for
monitoring personnel training status.
This system identifies those
individuals whose qualification time is near expiration and/or expired~
This system also provides for notification to the individual's supervisor,
so that unless retraining is completed prior to the expiration date, those
6
persons wi 11 be removed from the emergency response personnel roster.
The inspector reviewed a Departmental Training Status Report dated
April 1, 1989, which listed persons by name, position in the emergency
organization, training due date, and the required class training.
The
inspector a 1 so randomly selected 14 names from the emergency response
personnel roster, to verify that their training was current and included
all the required classes, in accordance with specific position assignments
as discussed in section 8.3, Table 8.1 of the SEP.
No deficiencies were
identified.
The inspector conducted an interview in the LEOF with one Assistant Shift
Supervisor.
The interviewee was given sets of hypothetical emergency
conditions and data and asked to talk through his response (as the Interim
Station Emergency Manager) as if an emergency actually existed.
The
interviewee was prompt and technically sound in classifying the event, and
subsequent actions taken in response to the hypothesized accident.
The
individual demonstrated an excellent familiarity with the emergency
classification procedure (EPIP 1.01) and various other procedures which
implement the Station's Emergency Plan.
No problems were noted in the
area of emergency detection, classification, and protective action
recommendation.
The interviewee was very knowledgeable of duties and
responsibilities as Interim Station Emergency Manager.
Offsite support
agency training was reviewed for fire, rescue, and local law enforcement
agencies.
Training was conducted in accordance with Section 8.4 of the
No violations or deviations were identified.
6.
Licensee Audits (82701)
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.
Accardi ng to
documentation, an independent audit was conducted by the licensee
I s
Quality Assurance Department during the period January 12, 1989 through
March 2, 1989, and documented in Audit Report No. S89-01.
The
aforementioned audit satisfied the annual frequency requirement for such
audits.
Three findings were identified.
At the time of the inspection,
the initial responses to the audit findings were being drafted.
The
inspector was informed by members of the Corporate and Station Quality
Assurance Department that as a result of recommendations from a Virginia
Power Contractor's audit, modifications to the Quality Assurance Program
for emergency preparedness were planned.
According to licensee personnel
and a review of documentation, the modifications would result in a more
detailed inspection to ensure compliance with 10 CFR 50.54(t).
The inspector reviewed the 1988 Emergency Exercise Post-Exercise Critique
Report, dated December 22, 1988.
According to the Exercise Report,
20 items were assigned to various individuals for taking actions.
Items
7
identified during the exercise or audits, are tracked via the Commitment
Tracking System (CTS).
This system is used as a management tool in
following up on actions taken in deficient areas.
Station Commitment
Assignment/Response Forms (SCARF) were used for tracking items in the CTS
data base.
No violations or deviations were identified.
7.
Shift Staffing and Augmentation (82205)
Pursuant to 10 CFR 50.47(b)(2) and_ 10 CFR Part 50, Appendix E,
Sections IV.A and IV.C, this area was inspected to determine whether shift
staffing for emergencies was adequate both in numbers and in functional
capability, and whether administrative and physical means were available
and maintained to augment the emergency organization in a timely manner.
The inspector reviewed Table 5.1 of the SEP and discussed with a licensee
representative staff augmentation times as determined by studies, drills,
or call-in during actual events.
The licensee representative indicated
that staff augmentation times were reviewed during the annual exercise
conducted November 1988, and
an augmentation drill conducted in
January 1989.
In addition, the licensee's remedial exercise conducted
during February 1989, included as an objective the demonstration of the
ability to augment the on-shift emergency organizatiqn in a timely and
effective manner.
The results of the aforementioned drills were as
follows:
0
0
0
During the annual exercise, the licensee identified two positions for
the TSC staff (Reactor Engineer and Mechanical Engineer) that were
not staffed within the specified times in Table 5.1 of the SEP.
Specified times were exceeded by 30 minutes in one case and 28 minutes
in the other,
In,addition, arrival times for two members of the LEOF
organization
(Recovery
Manager
and
Radiological
Assessment
Coordinator) exceeded specified times by 8 and 36 minutes respectively.
During the quarterly call-out drill conducted in January 1989,
augmentation personnel were notified and asked to provide an
estimated time of arrival (ETA) from their current location to the
station.
According to discussion with a licensee representative and
review of documentation, disc,epancies were again noted between the
ETA and augmentation times in the SEP.
A licensee representative
stated that one of the discrepancies was due to the reorganization
of the Technical Services Department which resulted in the
Core-Technical Support and Electrical-Technical Support Team not
being contacted.
An NRC exercise Observation Team noted during the remedial exercise
(conducted in February 1989) that the TSC and LEOF activations were
not timely.
According to the report (50-280, 281/89-07), the TSC was
not activated until one hour and 54 minutes after the Alert declaration;
8
and the LEOF activation took two hours and 32 minutes.
As a result,
the inspector discussed with the Emergency Planning Coordinator
actions considered or planned to improve augmentation performance
(eg. procedurally, employee relocation, etc.).
According to the
1 icensee contact, the short-term corrective action procedurally
involved prioritizing the security notification list of contact~ for
augmentation staff.
In addition, the Technical Services Staff were
retrained regarding the notification procedures for the augmentation
staff, to prevent recurrence of the quarterly drill results (failure
to contact members of the Core and El ectri ca 1-Technical Support
Teams).
The inspector was informed that no further actions had been
takened or planned at this time, and further corrective actions would be
taken pending the NRC review of North Anna proposed corrective
actions for a similar finding.
The inspector informed the licensee
that failure to meet the Surry Power Sta ti on augmentation staff
requirements is considered an apparent violation.
Violation 50-280, 281/89-09-04:
Failure to meet the Surry Power Station
augmentation staff requirements within the time periods specified* in
Table 5.1 of the SEP.
One violation and no deviations were identified.
8.
Action on Previous Inspection Findings (92701, 92702)
(Closed) IFI (50-280, 281/88-22-01):
Develop a system to ensure that the
most recent revision of local government Emergency Plans are placed in the
LEOF visual file.
By letter dated August 1988, the licensee requested the Virginia
Department of Emergency Services to include Virginia Power on the
distribution list for all future changes to the offsite response plans
(State/local) for Surry and North Anna Power Stations.
The inspector
further noted during a facility tour, that current versions of the State
and local government plans were available in the LEOF visual file.
(Closed) IFI (50-280, 281/88-22-02):
Review Procedure AP-37 titled
Seismic Event to make it user friendly.
The inspector reviewed a copy of Procedure AP-37 entitled Seismic Event,
Revision 00.01, dated February 7, 1989.
Minor changes were noted in the
ac~ions required in response to a seismic event.
A walkthrough using a
postulated seismic event was not conducted.
This item is closed solely on
the basis of the 1 i censee' s review and subsequent changes to the
referenced procedure.
(Closed) IFI (50-280, 281/88-22-03):
Demonstrate that augmentation
personnel identified in Table 5.1 can be made available in the times
specified by conducting periodic unannounced notification drills.
9
Augmentation times were documented during the 1988 annual exercise, and an
emergency response callout drill conducted January 19, J989.
During both
dri 11 s, the augmentation times were not met.
Consequently, the item
involving the conduct of periodic notification drills is closed, but a new
item is opened as a violation (see Paragraph 7), for failure to meet
augmentation times in Table 5.1 of the SEP.
(Closed) I FI ( 50-280, 281/88-22-04):
Ensure that Security emergency
notification call lists contain the most recent revision of the emergency
phone lists.
Sµbsequent to the inspection (IE Report No. 88-22), two procedures were
developed:
(1) Emergency Planning Office Guide-11 (EPOG-11) dated
March 29, 1989, and (2) Security Procedure Known as General Order Number
11 dated September 1, 1988.
Procedure EPOG-11 was developed to ensure
that the Emergency Telephone Directory was being maintained current and
up-to-date, and distributed to the appropriate locations following
revision.
The security procedure provides guidance and instructions for
ensuring that security personnel take the appropriate actions in response
to distributions for maintaining document as current and up-to-date.
9.
Exit Interview
The inspection scope and results were summarized on April 7, 1989, with
those persons indicated in Paragraph 1.
The inspector described the areas
inspected and discussed in detail the inspection results listed below.
Proprietary information is not contained in this report.
Dissenting
comments were received from the licensee regarding the potential violation
discussed in Paragraph 7 (failure to meet augmentation staffing
requirements in accordance with Emergency Plan).
Dissenting comments from
the licensee were based on corrective actions for this finding pending the
NRC review of proposed corrective actions for North Anna i nvo 1 vi ng a
s imi 1 ar finding.
There were no further dissenting comments.
_The
inspector informed the licensee that findings were preliminary and the
information provided regarding the similar finding at North Anna would be
reviewed by the Regional Office Staff.
Item Number
50-280, 281/89-09-01
50-280, 281/89-09-02
50-280, 281/89-09-03
Description/Reference
I FI: _ Conduct more frequent audits of the EPI Ps
controlled distributions (Paragraph 2).
IFI:
Revise the NOUE EAL involving the loss of
pl ant communications capabi_l ity to include the
PBX System (Paragraph 2).
IFI:
Review and evaluate, providing a capability
in the emergency kits for ensuring the
operability status of portable survey instruments
(Paragraph 3).
50-280, 281/89-09-04
10
Violation:
Failure to meet the augmentation
staff requirements within the time periods
specified in Table 5.1 of the Station Emergency
Plan (Paragraph 7).
Licensee Management was informed that four open items were reviewed and
closed.