ML20034G139
| ML20034G139 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 02/23/1993 |
| From: | Barr K, Kreh J, Wright F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20034G113 | List: |
| References | |
| 50-338-93-07, 50-338-93-7, 50-339-93-07, 50-339-93-7, NUDOCS 9303090117 | |
| Download: ML20034G139 (13) | |
See also: IR 05000338/1993007
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Report Nos.:
50-338/93-07 and 50-339/93-07
Licensee:
Virginia Electric and Power Company
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Docket Nos.: 50-338 and 50-339
License Nos.:
Facility Name:
North Anna Power Station
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Inspection Con ucted:
January 25'-29,.1993
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Inspectors:
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J. L. Kreh, Radiation Specialist
Date Signed
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h, y-F. NJrjght, Senior Radiation Specialist
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Date Signed
Approved by:
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K. 'P.
Barr, Thief
Date Sicfned
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Emergency Preparedness Section
Radiological Protection and Emergency Preparedness Branch
Division of Radiation Safety and Safeguards
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SUMMARY
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Scope:
This routine, announced inspection was conducted to assess the operational
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readiness of the site emergency preparedness program, and included selective
review of the following programmatic areas.:
(1) Emergency. Plan and associated
implementing procedures; (2) facilities, equipment, instrumentation, and
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supplies; (3) organization and management control; (4) training; and .
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(5) independent and internal audits and reviews.
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Results:
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In the areas inspected, one violation was identified for failure to.have an
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adequate procedure for identifying deficiencies in the function and
performance of the emergency ventilation system for the Technical Support.
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Center (see Paragraph 3 for details). No deviations were identified.
From an
overall perspective, the emergency preparedness program was found to be
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capably managed and maintained in an adequate state of operational readiness.
Program strengths were observed with respect to the conduct of periodic
emergency drills, the inclusion of emergency response activities in selected
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9303090117 930223
ADOCK 05000338-
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simulator training exercises, and independent audits. The following three
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areas for potential program improvement were identified during the inspection
and were discussed in detail with cognizant licensee representatives.
(1)
More consistent adherence to the Emergency Plan implementing procedures
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(based upon inspector observation of a Radiation Protection drill)
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(Paragraph 5).
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(2)
Addressing continuing inconsistencies in the preparation of offsite
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notification forms during drills (based upon review of licensee drill
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critiques) (Paragraph 5).
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(3)
Documentation of specific corrective action by. the Telecommunications
group for problems identified during the performance of communications
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surveillances (Paragraph 3).
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REPORT DETAILS
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1.
Persons Contacted
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Licensee Employees
- G. Clark, Manager, Quality Assurance
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- E. Collins, Director, Emergency Preparedness
E. Hendrixson, Supervisor, System Engineering
B. Henry, Coordinator, Emergency Planning
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- G. Kane, Station Manager
- P. Kemp, Supervisor, Licensing
- J. Leberstien, Staff Engineer, Licensing
J. Lencalis, Senior Instructor, Nuclear
- B. McBride, Station Coordinator, Emergency Planning
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- P. Quarles, Supervisor, Quality
J. Rayman, Senior Instructor, Emergency Preparedness
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- B. Shriver, Assistant Station Manager, Nuclear Safety and Licensing
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(Acting)
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W. Shura, Senior Instructor, Nuclear
- A. Stall, Assistant Station Manager, Operations and Maintenance (Acting)
Other licensee employees contacted during this inspection included
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instructors, operators, security force members, technicians, and
administrative personnel.
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Nuclear Regulatory Commission (NRC)
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- S. Lee, Resident Inspector
- M. Lesser, Senior Resident Inspector
- Attended exit interview on January 29, 1993
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2.
Emergency Plan and Implementing Procedures (82701)
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This area was inspected to determine whether significant changes were
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made in the licensee's emergency preparedness program since January 1991
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(the date of the last inspection of this area), to assess the impact of-
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any .such changes on the overall state of emergency preparedness at.the
facility, and to determine whether the licensee's actions in response to-
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actual emergencies were in accordance with the Emergency Plan and its
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implementing procedures.
Requirements applicable to this area are
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contained in 10 CFR 50.47(b)(16), 10 CFR 50.54(q)', Appendix E to 10 CFR
Part 50, and Sections 8.1 and 8.2 of the licensee's Emergency Plan.
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The version of the North Anna Emergency Plan in effect at the time of
the current inspection was Revision 14, dated August 31, 1992.
This was
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the -only change made to the Emergency Plan since the aforementioned
January 1991 inspection. The NRC's licensing review of Revision 14 was
in progress at the time of the current inspection.
Discussion with the
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Station Emergency Planning Coordinator (EPC) and selective review of the
Plan disclosed that no major programmatic modifications were
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incorporated via Revision 14.
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The inspector reviewed the licensee's system for making changes to the
Emergency Plan and the Emergency Plan Implementing Procedures- (EPIPs).
Through selective review of applicable documents, the inspector
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confirmed that licensee management approved revisions to the Emergency
Plan and EPIPs, as required.
Copies of the Emergency Plan, EPIPs, and
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Emergency Telephone Directory (latest revision dated December 16, 1992)
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which were available for use at the Technical Support Center (TSC) and
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Local Emergency Operations Facility (LEOF) were checked and found to be
current revisions.
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Revisions to the EPIPs since January 1991 were discussed with the EPC.
Various minor changes were made to upgrade and/or clarify the EPIPs,
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including several modifications to the Emergency Action Levels (EALs) in
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Revision 21 of EPIP-1.01, " Emergency Manager Controlling Procedure."
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(The NRC's formal evaluation of these EAL changes will be included in
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the previously referenced review of Revision 14 to the Emergency Plan.)
Completion in December 1991 of the Emergency Response Data System (ERDS)
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communications link with the NRC Headquarters Operations Center required
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the creation of a new Attachment 3 to EPIP-2.02, " Notification of NRC"
(Revision 8, dated May 13,1992), addressing ERDS operation (see
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Paragraph 3 for additional information regarding ERDS). The inspector
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noted that a minor change was made in EPIP-2.02 to require written
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approval by the Station Emergency Manager (SEM) of the NRC Event 3
Notification Worksheet (Attachment 1) prior to its transmittal.
This
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change was made in order to achieve consistency with a licensee
commitment for corrective action proposed during an inspection in
February 1992 at the licensee's Surry Power. Station (see Paragraph 2 of
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NRC Inspection Report Nos. 50-280,281/92-05). The inspector's review
of these and other selected EPIP changes disclosed none that decreased
the effectiveness of the licensee's emergency preparedness program.
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The inspector reviewed records pertaining to the eight emergency
declarations which occurred between January 1, 1991 and the date of the
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current inspection. All were declared at the Notification of Unusual
Event (NOVE) level, and are summarized as follows.
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TIME DECLARED /
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DATE
TERMINATED
DESCRIPTION OF EVENT
05/11/91
0500/1640
Commencement of Unit I shutdown required
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by Technical Specifications (TS) as a
result of Reactor Coolant System (RCS)
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pressure boundary leakage of 0.7 gpm
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05/24/91
0535/0606
Hydrogen burn in an isolated portion of a
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pipe under repair in the High-Head Safety
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Injection System (applicable EAL:
Confirmed report of unplanned explosion
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onsite)
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08/08/91
0250/0545
Unit I reactor trip from 99.8% power and
initiation of Emergency Core Cooling
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System (ECCS) flow as a result of a valid
Safety Injection (SI) signal
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09/20/91
1035/1035
Unit 2 reactor trip from 100% power and
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initiation of Emergency Core Cooling
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System (ECCS) flow as a result of. a valid
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Safety Injection (SI) signal (see below
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for further discussion of this event)
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11/03/91
1103/
Commencement of Unit 2 shutdown as a
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11/04/91
0034
result of exceeding TS-allowed rate of
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10 gpm for an identified RCS leak
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12/23/91
1632/
Commencement of Unit 2 shutdown required
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12/24/91
0730
by TS following declaration of
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inoperability of all three steam
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generators
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07/29/92
0425/0431
Fire which was not under control within
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10 minutes after fire fighting efforts
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began (involved two motor control centers
at the Circulating Water Intake Structure)
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08/06/92
0756/0850
SI signal causing Unit 2 reactor trip from
100% power and ECCS initiation with flow
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into the RCS
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The emergency preparedness staff routinely reviewed the response to each
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emergency declaration in order to identify problems or inconsistencies
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which may have occurred with respect to the requirements of the EPIPs.
This review was documented in detail. The inspector's assessment
concluded that each of the listed events was correctly classified based
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on the licensee's EALs.
However, the NOUE declaration on September 20,
1991 occurred more than five hours after the initiating event because of
the time required to determine the validity of the SI signal.
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effort to avoid further such untimely declarations, the liccnsee revised
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the applicable EAL to conservatively specify. "ECCS initiation with flow
into the RCS" (i.e., no SI validation required). Notifications to State;
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and local governments and the NRC of these eight emergency declarations
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were made in accordance with applicable requirements, with the exception
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of the declaration on November 3,1991, following which the licensee
identified a procedurally undocumented variance from the normal schedule
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of 30-minute informational updates to the State. Appropriate corrective
action was taken to preclude recurrence.
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The inspector verified that current letters of agreement existed between
the licensee and the offsite support organizations listed in
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Appendix 10.1 to the Emergency Plan.
These organizations included the
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O. S. Department of Energy (Oak Ridge Field Office), 5 State agencies,
and 14 county / local organizations. All letters of agreement were
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updated during 1992 (required once every two years by Section 5.3.3 of
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the Plan). Also verified through documental review was the licensee's
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conduct of the required annual reviews of EAls with governmental
authorities during 1991 (April 2 and October 2) and 1992 (December 15).
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No violations or deviations were identified.
3.
Emergency Facilities, Equipment, Instrumentation, and Supplies (82701)
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This area was inspected to determine whether the licensee's emergency
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response facilities (ERFs) and associated equipment, instrumentation,
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and supplies were maintained in a state of operational readiness, and to
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assess the impact of any changes in this area upon the emergency
preparedness program.
Requirements applicable to this area are
contained in 10 CFR 50.47(b)(8) and (9), 10 CFR 50.54(q),Section IV.E
of Appendix E to 10 CFR Part 50, and Sections 7 and 8.7 of the
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licensee's Emergency Plan.
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The inspector toured the licensee's onsite ERFs, which included the TSC,
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primary and alternate locations for the Operational Support Center
(OSC), and LE0F. Selective examination of ERF equipment and supplies
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indicated that an adequate state of readiness was being maintained.
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The inspector reviewed the status of the ERDS (previously discussed in
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Paragraph 2).
The EPC informed the inspector that the ERDS for North
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Anna was declared operational in December 1991 following an acceptance
run of several hours in which the data link with the NRC Headquarters
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Operations Center was established and validated. The ERDS link was also
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established during the January 1992 annual exercise, but had not been
tested since.
Notwithstanding the availability of a procedure
delineating how ERDS was to be used (see Paragraph 2), the EPC declined
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the inspector's request for a demonstration of ERDS operability on the
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basis that no NRC guidance has thus far been provided to implement the
quarterly tests specified in Section IV.1 of Appendix E to 10 CFR Part 50.
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The inspector observed the operation of the emergency ventilation system
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for the LE0F during a Radiation Protection drill on January 26. The
system was designed to develop positive pressure within the LEOF to
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restrict the infiltration of airborne radioactive material in the event
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of a severe reactor accident.
A permanently installed instrument
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(manometer) in the LEOF provided -a differential pressure measurement in
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inches of water gauge (WG).
The acceptance criterion specified in the
licensee's surveillance test for the LEOF emergency ventilation system
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was any reading greater than zero.
A positive pressure of 0.10 inch WG
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was readily developed when the system was actuated.
The reading dropped
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to zero when an LEOF pressure boundary door was opened, but returned to
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0.10 inch WG within a few seconds after the door was closed.
Section 7.1.5 of the Emergency Plan stated that the Corporate Emergency
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Response Facility (CEOF) in Glen Allen, VA was available as a backup
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f acility should the LEOF become unavailable during a response to an
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eme rger.cy.
Licensee records indicated that the transfer of
responsibilities from the LEOF to the CEOF was tested and successfully
demonstrated in real time during an exercise dress rehearsal on
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April 24, 1991.
The transfer was facilitated by the fact that the CEOF
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was fully equipped, so that only personnel had to be moved.
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The inspector selectively reviewed completed documentation for each of
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the following facility / equipment surveillance procedures for the period
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January 1, 1991 through the date of the inspection:
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1-PT-77.9, TSC Emergency Ventilation System Operability Test
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(performed every 18 months)
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1-PT-77.10, LEOF Emergency Ventilation System (18 months)
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0-PT-ll4, Emergency Kit Inspection (monthly)
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1-PT-172.2, Early Warning System Sirens Activation Monitoring
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(quarterly)
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1-PT-175.1, Insta-Phone, State DES [ Department of Emergency
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Services], and NRC Communications Operability Test (monthly)
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1-PT-175.2A, Emergency Communications System Test (quarterly)
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The listed surveillance procedures had been performed at the required
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frequencies, and the documentation indicated that identified problems
were corrected expeditiously.
However, a problem not recognized by the
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licensee was identified by the inspector during review of documentation
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for 1-PT-77.9 (Revision 2, approved July 19, 1989).
The inspector
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reviewed records of this surveillance test as performed on May 23, 1991
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and December 8, 1992. Step 7.1.10 of this procedure stated that the
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acceptance criterion for the pressure in the TSC was 2 0.125 inch WG (a
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number commonly used by licensees in Control Room and TSC emergency
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ventilation system performance tests).
In both of the referenced
completed procedures, this criterion was indicated as having been met,
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and the overall test results were certified as " satisfactory." However,
the parameter which was compared to the criterion was a sum of three
manometer readings (recorded in procedural step 6.5) in separate areas
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of the TSC.
In the May 1991 test, these three readings individually
exceeded the 0.125 inch criterion, but in December 1992 were recorded as
0.02, 0.14, and 0.08 inch WG, with an indicated sum of 0.24 inch WG.
In
discussions with cognizant licensee representatives, the inspector
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questioned the physical validity of summing three individual pressure
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readings for comparison with the acceptance criterion, noting that one
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or two of the individual readings could be zero or less than zero while
still meeting the procedural requirement relative to the sum.
Such a
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condition would not be consistent with the design goal of having
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positive pressure in all areas of the TSC.
Licensee representatives
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presented an overview of the TSC emergency ventilation system design and
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the complex relationship between that system and the Turbine Building
ventilation system.
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On January 27, the licensee issued Deviation Report No. N-93-164, which
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documented the inspector's identification of the condition wherein the
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given positive pressure criterion for the TSC was not met during the
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performance of 1-PT-77.9 in December 1992.
Further analysis by the
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licensee concluded that the design of the TSC emergency ventilation
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system was such that no intrusion of airborne radioactive material would
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occur as long as the ambient pressure in the TSC was positive (i.e., the
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acceptance criterion should have been > 9 inch WG instead of
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2 0.125 inch WG).
Prompt corrective act:on was taken by the licensee in
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the form of a revision of 1-PT-77.9 to rectify the cited deficiencies.
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Notwithstanding these actions, the licensee was informed that the matter
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discussed above constituted a violation of the requirements of
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Section 8.7 of the Emergency Plan, which specified that emergency
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equipment, including the TSC ventilation system, "shall be periodically
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tested to identify and correct deficiencies."
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Violation 50-338, 50-339/93-07-01:
Failure to have an adequate
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procedure for identifying and correcting deficiencies in the function
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and performance of the TSC emergency ventilation system.
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With regard to the performance of 1-PT-175.1 and 1-PT-175.2A, the
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inspector noted several instances in the records of completed tests in
which identified communications equipment problems were simply indicated
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as having been " reported to Telecommunications." The test records did
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not include documentation of the nature or date of any corrective action
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that may have been taken by the Telecc'mmunications group.
The EPC
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stated that repairs by Telecommunications were typically accomplished in
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a timely and thorough manner. The EPC planned to consider implementing
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a practice of documenting, in the records of the subject periodic tests,
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specific corrective action by the Telecommunications group for problems
identified during the performance of communications surveillances.
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was an area for potential program improvement.
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Based upon ERF walk-downs, review of changes to the EPIPs, inspection of
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completed surveillance procedures, and statements by licensee
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representatives, the inspector concluded that no degradation of ERF
capabilities had occurred since January 1991.
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One violation and no deviations were identified.
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4.
Organization and Management Control (82701)
This area was inspected to determine the effects of any changes in the
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licensee's emergency organization and/or management control systems on
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the emergency preparedness program, and to verify that any such changes
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were properly factored into the Emergency Plan and EPIPs.
Requirements
applicable to.this area are contained in 10 CFR 50.47(b)(1) and (16),
Section IV.A of Appendix E to 10 CFR Part 50, and Section 5 of the
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The organization and management of the emergency preparedness program
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were reviewed and discussed with licensee representatives. There were
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no significant organizational or personnel changes in either the plant
or corporate emergency planning groups since January 1991. The
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individual serving as EPC had been in that position for five years and .
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reported directly to the Assistant Station Manager, Nuclear Safety and
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Licensing. These factors helped to provide a measure of assurance that
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emergency preparedness at the North Anna Power Station would receive
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appropriate management attention and would have good " visibility" to
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station personnel.
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The inspector reviewed the licensee's management strategy for ensuring
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compliance with the Emergency Plan requirements addressing the planning
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standard of 10 CFR 50.47(b)(2), which specifies that " timely.
augmentation of response capabilities is available." The applicable
Emergency Plan requirements were contained in Section 5.2 and Tables 5.1
and 5.2.
The licensee performed 0-PT-172.4, " Emergency Response
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Organization Notification Test" on a quarterly basis, although this off-
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hour test involved only notification of emergency response organization .
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(ERO) personnel and determination of their availability, and did not
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include actual reporting to the station. The results of 0-PT-172.4
tests conducted since January 1991 indicated that the licensee's onsite
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emergency organization could be augmented in accordance with the.
referenced Emergency Plan commitments.
According to Section 8.6.1 of
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the Emergency Plan, at least once every six years the licensee would
conduct an actual, real-time callout of the emergency organization to
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test off-hour staff augmentation- capability during an annual emergency.
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exercise.
Review of drill records disclosed that the licensee had
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conducted a (nonrequired) augmentation test as part of a " combined
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functional drill" on March 20, 1991. According to the documentation,
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callout of ERO personnel commenced at 5:04 a.m., and ERFs were activated
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within the time limits specified in the Emergency Plan.
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The licensee utilized a performance monitoring process to periodically
evaluate the effectiveness of various site programs, including emergency
preparedness. This process was initiated approximately six months prior
to the January 1991 inspection and was known as the " North Anna
Performance Annunciator Panel." The program established performance
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criteria for personnel, equipment and program elements.
The program
elements were graded in accordance with their performance criteria on a
quarterly bases. The performance criteria for the emergency
preparedness program were sufficiently challenging to generate
improvements. The licensee's documentation showed the emergency
preparedness performance trend had shown continued improvement in 1991
and 1992.
Generally, the emergency preparedness program areas had been
characterized as " Satisfactory" or a "Significant Strength" (the highest
rating) during that period. The Annunciator Panel program appeared to
be an effective management tool for improving the license's performance
in the area of emergency preparedness.
The inspector determined that the following NRC Information Notices
(ins) applicable to emergency planning were received by the licensee
since January 1992 and distributed to cognizant personnel, and that
corrective actions, as appropriate, were completed or scheduled:
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IN No. 92-08*:
Revised Protective Action Guidance for Nuclear
Incidents
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Problems Identified With Emergency Ventilation
Systems for Near-Site (Within 10 Miles) Emergency Operations
Facilities and Technical Support Centers
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IN No. 92-38*:
Implementation Date for the Revision to the EPA
Manual of Protective Action Guides and Protective Actions for
Nuclear Incidents
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IN No. 92-62*:
Emergency Response Information Requirements for
Radioactive Material Shipments
For those ins marked with an asterisk, the licensee's corporate
emergency preparedness group had determined a need to develop an " Action
Plan" to properly address the issues.
The licensee's management control system for ensuring the timely
completion of required tests and surveillances was reviewed and found to
be effective. The computer-based Periodic Test Scheduling System
provided weekly information on upcoming test due dates.
The emergency
preparedness staff maintained a detailed calendar of periodic
requirements specified in the Emergency Plan and EPIPs. The inspector
also reviewed and discussed with licensee representatives the Emergency
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Preparedness Incomplete Items Listing, used to track open items for the
licensee's two nuclear stations as well as for the corporate emergency
preparedness program.
This listing was appropriately detailed, and
indicated for each item the responsible organization and individual
along with a due date for completion.
The licensee was effectively
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using this tracking system as a management tool for ensuring the
completion of corrective action for identified problems in emergency
preparedness.
No violations or deviations were identified.
5.
Training (82701)
This area was inspected to determine whether the licensee's key
emergency response personnel were properly trained and understood their
emergency responsibilities. Requirements applicable to this area are
contained in 10 CFR 50.47(b)(2) and (15),Section IV.E of Appendix E to
10 CFR Part 50, and Section 8.3 of the licensee's Emergency Plan.
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The licensee maintained the Nuclear Power Station Emergency Preparedness
Training Program Guide, which is referenced in Section 8.3 of the
Emergency Plan as the governing document for such training.
The status
of the training program was reviewed by selecting names of individuals
designated for key positions from the ERO roster and reviewing their
training records to verify that training requirements were being
implemented. A review of the training records for each of the selected
individuals revealed that personnel had received the required training
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and that training was current.
The inspector reviewed the licensee's
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training objectives and associated lesson plans for several key ERO
positions.
The training material content appeared appropriate relative
to the need to address the duties and responsibilities of each of the
selected positions.
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In an effort to gauge the effectiveness of this training program, the
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inspector observed a Control Room simulator training exercise, which was
conducted on January 28 as part of the Licensed Operator Requalification
Program.
This exercise involved the simulated loss of Main and
Auxiliary Feedwater and Condensate System flow, which ultimately
resulted in the simulated declaration of a General Emergency.
The
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inspector observed from the simulator booth at first, and later in close
proximity to the players. Attention was focused in particular on the
Shift Supervisor (serving as interim SEM) in order to ascertain his
understanding of emergency classification, formulation of offsite and
onsite protective actions, site evacuation, and nondelegable
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responsibilities of the SEM. The Control Room simulator crew promptly
identified the occurrence of an initiating condition for entering the
The crew properly classified the event and worked
through the applicable EPIPs.
The SEM correctly formulated an offsite
protective action recommendation. The exercise did not evaluate offsite
notification functions.
The inspector observed Chemistry and Radiation Protection personnel
perform emergency response functions in a practical exercise conducted
on January 27 in accordance with continuing training program
requirements. The training utilized written lesson plans and included
classroom instruction. The students were rotated through various ERO
positions they may be required to fill during a radiological emergency,
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including the TSC dose assessment team, plant monitoring, and offsite
field team monitoring.
Following the practical exercises, the
activities were critiqued with the training instructors. The training
appeared appropriate for the students' needs and the instructor was
knowledgeable of the various ERO position duties he was teaching and
observing. During the exercises, the inspector noted that the students
were not utilizing and completing the various written emergency
procedures for their assigned duties. The issue was discussed with
members of the training department.
Students were expected to follow
the appropriate procedure requirements during the exercises but were not
required to complete associated documentation.
Completed procedures and
documentation were not evaluated. The licensee did not make any
specific commitments relative to requiring " full" use of the procedures
during training exercises, but acknowledged the potential benefits of
procedure familiarization that could be derived from such an approach.
This matter was offered for the consideration of the licensee as a
possible area for program improvement.
The inspector reviewed the licensee's assessment and documentation of
the ERO performance during five emergency exercises and drills conducted
in 1992. Nearly all of the exercise / drill objectives were met and the
licensee's critiques identified few deficiencies. These unfulfilled
objectives were discussed with licensee representatives. Through these
discussions, the inspector determined that the appropriate issues were
identified for corrective action and that the licensee was monitoring
the status and progress of such planned corrective actions.
The
inspector reviewed the critique records for trends during 1992.
No
adverse trends were identified. However, the inspector noted that some
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type of problem with emergency notifications was identified in four of
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the five drill / exercise functions in 1992.
In general, the specific
problems were minor and not repetitive. The notification issues were
discussed with licensee representatives and no additional corrective
actions, other than those designated for specific critique findings,
were planned. This matter was offered for the licensee's consideration
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as a possible area for program improvement.
The licensee's ERO drill / exercise schedule for 1992 was very aggressive.
The level of dedication of the licensee's resources to maintaining and
improving emergency response capabilities was indicative of station
management's commitment to the emergency preparedness program.
No violations or deviations were identified.
6.
Independent and Internal Reviews / Audits (82701)
This area was inspected to determine whether the licensee had performed
an independent audit of the emergency preparedness program, and whether
the emergency planning staff had conducted a review of the Plan and the
EPIPs. Requirements applicable to this area are contained in
10 CFR 50.54(t) and Sections 8.2.1 and 8.9 of the licensee's Emergency
P1an.
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The inspector reviewed reports documenting the last two required annual
independent audits of the emergency preparedness program.
These audits
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were conducted by the licensee's Quality Assurance (QA) organization
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during the periods June 25 - August 5, 1991 (Report No. 91-10) and
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April 14 - May 27, 1992 (Report No. 92-08).
These were company-wide
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audits wh'ch examined the emergency response capability for both of the
licensee's nuclear stations and the corporate office. The inspector
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determined that the audit teans utilized qualified personnel, including
some with emergency planning experience. The audit checklists were
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comprehensive and detailed, and encompassed appropriate emergency
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preparedness procedures, regulatory requirements, and guidance. The
audits scrutinized the implementation of the Emergency Plan and EPIPs,
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training, drills and exercises, facilities and equipment, interf aces
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with offsite agencies, and program documentation. Audit findings
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appeared to be effectively documented, tracked, and controlled, and were -
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consistently corrected in a timely manner. The follow-up and closecut
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of identified issues by QA appeared appropria'c. These annual audits of
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the emergency preparedness program were identified as 1 program
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strength.
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The two most ecent annual internal reviews of the Plan and EPIPs were
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completed on vane 19, 1991 and September 21, 1992, respectively, an.1
were each documented in a memorandum from the EPC to the Station Nuclear
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Safety and Operating Committee. These reviews were effective in meeting
the intent of the applicable Emergency Plan requirement in that they
adequately assessed program accomplishments and needed corrective
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actions, and received management attention.
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No violations or deviations were identified.
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7.
Exit Interview
The inspection scope and results were summarized on January 29, 1993
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with those persons indicated in Paragraph 1.
The inspector described
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the areas inspected and discussed in detail the finding listed below.
The inspector made reference to the areas for potential program
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improvement which are listed in the " Summary" section of this report,
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3
although these items were not discussed substantively during the exit
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interview. Dissenting comments were not received from the licensee.
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Although proprietary information was reviewed during this inspection,
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none is contained in this report.
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ltem Number
Category, Description, and Reference
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50-338, 339/93-0/-01
VIOLATION:
Failure to have an adequate
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procedure for identifying and correcting
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deficiencies in the function and performance of
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the TSC emergency vestilation system
(Faragraph 3).
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