ML20058H357
| ML20058H357 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 04/06/1982 |
| From: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Leasburg R VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| Shared Package | |
| ML20058H245 | List: |
| References | |
| NUDOCS 8208030561 | |
| Download: ML20058H357 (13) | |
Text
-
, ?p ue, o
UNITED STATES fg NUCLEAR REGULATORY COMMISSION APPENDIX A E'
es HEGloN 11
$ 4 oI 101 MAHIET T A ST.. N W.. smI E 3100 3p g
AH AN EA. GEOHGIA 30301
%,...../
APR 061982 Virginia Electric and Power Company l
ATTri: Mr. R. H. Leasburg, Vice President of Nuclear Operations
- p. O. Box 26666 Richmond, VA 23261 Gentlemen:
Subject:
Confirmation of Action - Docket Nos. 50-280 and 50-281 This refers to a telephone conversation on April 2,1982, between Mr. W. L. Stewart, Manager, Nuclear Operations and Maintenance Support, and Mr. F. J. Long of this office, concerning certain deficiencies identified as a consequence of our appraisal of the emergency preparedness program at the Surry facility on March 15-26, 1982.
Our findings were also discussed with you and Mr. J. L. Wilson, Station Manager, by Mr. G. R. Jenkins, of this office, on March 26, 1982.
Recognizing that some corrective actions were in progress prior to the appraisal, it is our understanding that you have undertaken or will undertake the following actions to resolve apparent deficiencies in your energency preparedness program.
1.
Training The initial emergency training and anncal retraining program will be a.
upgraded to establish a more comprehensive anti coordinated program which addresses all the functional activities of the energency response organi-zation. Each part of the program will includo classroom training, practical exercises, and where appropriate, a hands-on demonstration of each individual's ability to perform assigned functions.
Each part of the program will also include examinations designed to test the indivi-dual's knowledge of his assigned functional responsibilities and establish performance levels below which immediate retraining will be required.
The upgraded program will be established by August 2,1982.
b.
Emergency response personnel will be trained in the specific functional areas for which' they are assigned responsibility. The initial training for key personnel in the upgraded emergency response program will be completed by August 2, 1982.
These key personnel are the Station Manager, Assistant Station Manager, Operations Superintendent, Technical Services Superintendent, Administrative Services Superintendent, Health Physics Supervisor, others who would likely serve as alternate in these functions, and the operations personnel who would participate in an emergency that occurs during their shift.
The initial training of remaining personnel will be completed by October 2,1982.
8208030561 820727 gDRADOCK 05000280 PDR
~
~'
~
Mr. R. H. Leasburg,
2.
Procedures Energency Plan Implementing Procedure EPIP-l will be upgraded based on a.
Energency Action Levels (EALs) which clearly specify the initiating con-ditions for classifying accidents.
In addition, you will ensure that EPIP-1 supports a rapid initial accident assessment leading to the
~
formation of protective action reconmendations, the prompt notification of offsite authorities, and the effective coordination of all other implementing procedures from the initiation of the event until close-out.
b.
A review of all other Energency Plan Implementing Procedures will be accomplished and appropriate revisions and additions made to ensure that the procedures adequately implement the Energency Plan, are compatible with the energency plans and procedures of corporate, State and local organizations, and provide reasonable assurance that the necessary emergency response functions will be performed in a prompt and effective nunner. As a minimum, procedures will be revised or developed for the following emergency functional areas: notifications; in-plant and on-site radiological surveys; post-accident analysis of the primary coolant and containacnt air; post-accident sampling and analysis of stack and liquid effluents; protective actions; evacuation and personnel accounta-bility; personnel monitoring and decontamination; and search and rescue.
This developnent and revision of implenenting procedures will be completed by August 2, 1982.
3.
Initial Dose Assessacnt The procedures for offsite dose assessment will be upgraded into a clear, concise procedure or integrated procedures which ensure rapid and accurate dose assessment by shift personnel and the appropriate cenbers of the emergency organization will be trained in their use on an expedited basis.
The procedures will be upgraded and the training completed by August 2,1982.
4.
Report A written report will be submitted to this office by August 23, 1982, describing actions taken in the above areas.
For item 1.b. above, the report l
will include the percentage of training completed as of August 2,1982.
i If your understanding of these natters is different from that stated above, please inform this office promptly.
l-l
[
L
d
U l
O Mr. R. H. Leasburg
!.3 l
1 The response requested by this letter is not subject to the clearance procedures' of the Office of Management and Budget, as reported by the Paperwork Reduction Act of 1980, PL 96-511.
I Sincerely, cuvaL O
ames P. O'Reilly gional Administrator cc:
J. H.-Ferguson, Vice Presiden i
Power i
J. L. Wilson, Station Manager e
i d
[
i i
~
g APPENDIX B PREPAREDNESS IMPROVEMENT ITEMS Based on the results of the NRC's appraisal of the Surry Power Station Emergency Preparedness Program conducted March 15-26, 1982, the following items should be considered for improvement. (Reference is to Sections in OIE Report Nos. 50-280, 281/82-05).
1.
Upgrading the descriptive material for the emergency organization so that the assignment of emergency functions and the interface between emergency functions is clarified. (2.1) 2.
Developing the training manual to provide guidance and to increase the uniformity of the training program. (3.1) 3.
Developing lesson plans and tests to be based on the functional activi-ties of the emergency response organization. (3.1) 4.
Upgrading the training matrix to include all training received by members of the emergency response organization. (3.1) 5.
Clearly establishing the basic set of courses for the First Aid Team that are to be required. (3.1) 6.
Documenting all training to include the name of attendees, a descriptive course title, the training date, and the instructor's name. (3.2) 7.
Designating the Training Department to be the central repository for -
all training records. (3.2) 8.
Revising the activation procedure EPIP-1, APX 7, Section 2, for the interim TSC to include the installation of additional tables, desks, and other supplies to better accommodate all TSC personnel. (4.1.1.2) 9.
Revising the OSC activation procedure, to include provisions for personnel and emergency equipment, to require all emergency response i
personnel not immediately performing emergency duties to report to the OSC to facilitate the formation of the various emergency teams, and relocation of the OSC based on potential or actual hazardous radiologi-cal conditions. (4.1.1.3)
- 10. Developing an implementing procedure for the activation and staffing of the EOF. (4.1.1.4)
- 11. Assuring that adequate monitoring and decontamination equipment are provided to support the operation of the E0F. (4.1.1.4) l--
Appendix B 2
Preparedness Improvement Items 12.
Providing for taking and analyzing more than one post-accident coolant sample. (4.1.1.5) 13.
Providing a shielded container for transportating post accident air samples. (4.1.1.6) 14.
Providing special tools for handling and removing post accident gas sampling cartridges and filters. (4.1.1.7) 15.
Providing alternate sampling points for essential post-accident liquid effluent samples for those systems where the primary sample point is likely to be inaccessible. (4.1.1.8)
- 16. Upgrading the marking of assembly (shelter) areas and the instruction of personnel as to the location of their assembly areas. (4.1.2.1) 17.
Establishing an alternate offsite assembly area in case the primary site becomes unuseable. (4.1.2.1) 18.
Establishing a decontamination capability, for timely decontamination of personnel, at or very near the remote assembly area. (4.1.2.1)
- 19. Clearly designating the person responsible for distribution of Potassium Iodide tablets. (4.1.2.2) 20.
Establishing a system for the disposal of radioactive waste collected at the remote assembly area. (4.1.2.3) 21.
Establishing a system for replacing contaminated clothing at the remote assembly area. (4.1.2.3)
- 22. Assessing the electrical wiring and making provisions for additional wiring, in case needed. (4.1.4) 23.
Storing the Press Center telephones and other dedicated equipment at the facility. (4.1.4) 24.
Making provision for adult-sized tables to replace the elementary school-sized tables. (4.1.4) 25.
Performing calculations or testing to assure that field sample analysis has the capability to measure air particulate activity as low as 1E-09 microcuries per cubic centimeter. (4.2.1.1) 26.
Including in the Emergency Plan a complete listing and description of all area and process radiation monitors. (4.2.1.2)
=
l Appendix B 3
Preparedness Improvement Items 27.
Providing a specific listing of the non-radiation process monitors that are relied upon for classification and assessment in the emergency plan or procedures. (4.2.1.3) 28.
Providing for periodic testing of the electrical switches and controls at the Auxiliary Shutdown Panels. (4.2.1.3) 29.
Establishing an inspection, maintenance and calibration program for the 4
Control Room meteorological data recorders similar to the program provided for instrumentation at the meteorological towers. (4.2.1.4)
- 30. Modifying the control room meteorological instruments to provide single recordings of sigma theta and of temperature difference values.
(4.2.1.4) 31.
Identifying a procedure that requires that shift operations personnel be informed of all severe meteorological phenomena likely to affect the site. (4.2.1.4) 32.
Improving the recording of variables currently recorded on the multi-i point recorder at the primary tower location so that the variable values will be readable. (4.2.1.4) 33.
Providing for the needs of transportation in the Plan and in the applicable emergency procedures. (4.2.6) 34.
Establishing a single EPIP for notifications with clearly established event activated notification lists. (5.4.1) 35.
Providing guidelines for recommendations to offsite authorities in the implementing procedures. (5.4.2) i 36.
Basing all thyroid dose protective action recommendations on a child's thyroid rather than the adult. (5.4.2) 37.
Incorporating into the licensee's guidelines provisions for estimating the duration of a release as recommended in EPA-520/1-75-001. (5.4.2) 38.
Revising procedures to provide for promptly notifying the offsite authorities of any change to the emergency status and the closing out of emergency situations in accordance with Appendix 1, NUREG-0654.
(5.4.2) 39.
Dividing the assessment and notification procedures into two phases; the initial quick response and the long term phases. (5.4.2) i
,n c
e Appendix B 4
Preparedness Improvement Items 40.
Upgrading established procedures to assure prima ry and backup transportation for offsite monitoring teams, and the means by which team members, vehicles, and equipment are to pass expeditiously through security when departing the plant. (5.4.2.1) 41.
Upgrading established procedures to specify radiation protection levels and protective actions for offsite team members tracking a plume, a central collection point for the return of environmental samples and completed survey data forms, and the unique labeling of all environment samples. (5.4.2.1) 42.
Expanding form EPIP-16.1 to include spaces for instrument identifica-tion, mode of instrument operation, air sampler flow rate, background radiation levels, and sample count time. (5.4.2.1) 43.
Revising the routine survey procedures that are to be used for accident conditions to include special sample handling techniques designed to avoid unnecessary radiation exposures from abnormally " hot" samples.
(5.4.2.1) 44.
Establishing emergency radiological survey and air particulate sampling procedures, to include special provisions for handling abnormally " hot" samples, which are consolidated with other emergency procedures.
(5.4.2.2) 45.
Making provisions for recording vital information for emergency onsite and inplant surveys, (5.4.2.2) 46.
Establishing a central collection point for all samples and vital sample information and including this in applicable procedures.
(5.4.2.2) 47.
Modifying post-accident coolant sampling procedures to describe the required means for transporting samples to the Hot Lab. (5.4.2.4) 48.
Specifying the sample point locations. (5.4.2.4) 49.
Modifying the sampling procedures to make provisions for labelling the sample. (5.4.2.4) 50.
Developing procedures for the analysis of high level, post accident samples. (5.4.2.5) 51.
Revising analytical procedures to specify methods of protecting the counting facilities from contamination. (5.4.2.5) 52.
Revising analytical procedures to specify means of counting if the counting area has a high background. (5.4.2.5)
e Appendix B 5
Preparedness Improvement Items 53.
Revising analytical procedures to specify means of. recording data and to assign responsibility for providing data to the organizational element responsible for the assessment function. (5.4.2.5)
- 54. Revising analytical procedures to provide for the disposition of samples af ter analysis. (5.4.2.5)
- 55. Applying the general needs identified as improvement items in paragraph 5.4.2.4 to containment air sampling. (5.4.2.6)
- 56. Applying the general needs identified as improvement items in paragraph 5.4.2.4 to stack effluent sampling. (5.4.2.8)
- 57. Applying the general needs identified as improvement items in paragraph 5.4.2.4 to liquid effluent sampling. (5.4.2.10) 58.
Upgrading established procedures to assign specific authority for organizing and coordinating environmental monitoring teams. (5.4.2.12) 59.
Establishing a means to assure timely access to the north bank of the James River for monitoring. (5.4.2.12)
- 60. Developing an overall procedure for radiation protection during emergencies which assigns responsibilities and priorities for health physics activities. (5.4.3.1)
- 61. Developing specific guidance within the emergency procedures for
-issuance of dosimeters to non plant personnel, dose assessment, control of access to radiation zones, keeping exposure records, and limiting exposure during an emergency. (5.4.3.1)
- 62. Upgrading established procedures to provide specific administrative responsibility for the authorization of emergency exposures. (5.4.3.1)'
- 63. Upgrading established procedures to clearly activate the emergency plan with regard to evacuation routes, means of transportation and alter-i natives in case of unfavorable radiological conditions. (5.4.3.2) l 64.
Clearly marking evacuation routes both inside and outside the plant.
l (5.4.3.2) l
- 65. Upgrading established procedures to assume completion of accountability within 30 minutes and providing for continuing accountability of onsite personnel. (5.4.3.3) 66.
Revising procedures to clearly indicate where personnel are expected to assemble for accountability under all circumstances. (5.4.3.3) i e
Appendix B 6
Preparedness Improvement Items 67.
Revising procedures to indicate exactly what actions individuals on the north end of the Peninsula will be requested to take. (5.4.3.3) 68.
Establishing or upgrading existing procedures to assure that Health Physics personnel are dispatched to monitor personnel in the remote assembly area.
The procedures should describe the monitoring and decontamination methods, establish contamination action levels for decontamination, and provide a form for recording all pertinent survey information for each person. (5.4.3.4) 69.
Expanding the implementing procedures to designate the personnel responsible for calling the oasite ambulance into service, driving the ambulance, and exchanging dosimetry prior to ambulance departure.
(5.4.3.5) 70.
Revising the implementing procedures to specify when the shif t super-visor is to notify the hospital, and to also assure health physics coverage for medical / rescue personnel arriving from offsite locations.
(5.4.3.5) 71.
The rumor control program will remain open pending review of the procdure af ter issuance. (5.4.7) 72.
Including the periodic inventory of radiological equipment and supplies stored in the plant ambulance in a periodic test. (5.5.1) 73.
Having tbe Emergency Planning Coordinator maintain a log of all Emergency Planning correspondence and reports. (5.5.2) 74.
Adding the current revision number and date of issuance to each item in the Table of Contents for the Emergency Plan and the EPIPs. (5.5.3) 75.
Providing for an annual audit of the Emergency Plan and Emergency Plan Implementing Procedures in the appropriate manual or procedures.
(5.5.4) 76.
Providing audit assessments and comments relative to the items speci-fied in Section 8.4 of the Plan. (5.5.4) 77.
Expanding the audit checklist item for drills and exercises to speci-fically address the commitments in Section 8.1.2 of the Emergency Plan for the drills and exercises listed in Table 8.1.
(5.5.4) 78.
Upgrading the Health Physics training to include monitoring techniques under adverse, high radiation conditions. (7.2.10) 79.
Training technicians to be aware of protective measures available for keeping exposures to a minimum when monitoring in high radiation conditions.
(' 2.10)
L
=
APPENDIX C EMERGENCY PLAN DEFICIENCIES Based on the results of the NRC's review of the Surry Plant Radiological Emergency Plan (Revision 2), the following deficiencies have been identified:
(Reference in parentheses are to criteria of NUREG-0654, Rev.1).
1.
(B.S.) The Emergency Plan provides no statement regarding meeting the minimum staffing requirements of Table B-1, NUREG-0654, by July 1,1982, and Table 5.1 of the Emergency Plan does not satisfy the objectives in Table B-1 of NUREG-0654 for the 30 and 60 minute augmentation of the emergency organization.
2.
(B.7) The augmentation organization appears to meet the criteria of NUREG-0654 but it is difficult to assess what emergency functions are performed by the organizational structure shown in Figure 5.4 of the Emergency Plan, since normal operational titles are used. Also, Section 5.3.1.e of the plan states only that " informational releases will be coordinated with the appropriate governmental authorities", without stating by whom and how it will be accomplished.
3.
(C.4) No letters of agreement are included for the organizations listed in Section 5.3.2 of the Emers ncy Plan.
4.
(0.1) The Emergency Plan fails to meet the criteria for the emergency action level schemes in Appendix 1, NUREG-0654 as noted below.
The use below of the word "should" connotes a suggestion for improvement rather than an Emergency Plan deficiency.
Unusual Event Initiating Condition 2 (Radiological effluents). The relevant gaseous and liquid alarms are not listed with the specific parameters or equipment status that will establish this class of emergency. Also the requirement for laboratory analysis prior to assessment should be dropped since it delays prompt notification to state authorities.
Verification of an alarm by instrument reading should suffice.
Initiating Condition 3 (Fuel damage). The Emergency Action Level for fuel damage does not address the rate of failure.
Initiating Condition 6 (Failure of a safety or relief valve). The position is taken that failure of the steam generator safety valve (s),
power operated relief valves, or decay heat release valve to close is not safety related unless there is significant primary to secondary leakage. However, "significant primary to secondary leakage" is not defined.
m
's Appendix C 2
Emergency Plan Deficiencies Initiating Condition 13 (Natural phenomena). The EAL for low water is not addressed.
Initiating Condition 14 (Other hazards).
The EAL for a turbine rotating component. failure causing rapid plant shutdown is not addressed.
Alert Initiating Condition 1 (Severe loss of fuel cladding). The EAL for the rate of fuel failure is not addressed.
Initiating Condition 4 (Steam line break with significant primary to secondary leakage). Using the primary to secondary leak rate prior to the steam line break as a basis for the EAL is acceptable. However, additional failures,-due to increased pressure differential in the steam generator, are possible. EALs based upon the radiation levels in the steam generator blowdown and in the condensor exhaust need to be added.
Initiating Condition 6 (High radiation levels). The requirement-for laboratory analysis to confirm the release of radioactive material should be dropped, unless it can be completed within 15 minutes of the initial alarm, in order to ensure that offsite authorities are promptly notified, as per NUREG-0654, Appendix 1.
Initiating Condition 12 (Fuel damage). The requirenent for laboratory analysis to confirm the release of fission products, before classifying the accident and making notifications, should be dropped unless it can be completed within 15 minutes of the initial alarm.
Initiating Condition 17 (Natural phenomena).
The acceleration level required to activate the earthquake alarm light on the Strong Motion Accelograph is not specified nor is the EAL for low water.
Site Emergency Initiating Condition 2 (Degraded core with possible loss of coolable geometry). An EAL for high core temperature should be added.
Initiating Condition 5 (Steam line break with significant primary to secondary leakage and indication of fuel damage). Using the primary to secondary leakage rate existing prior to the steam line break as a basis for the EAL is acceptable. However, additional failures of the steam generator tubes may occur because of increased pressure differential caused by the steam line break. EALs based upon radiation levels in the steam generator blowdown and in the condenser should be added.
Appendix C 3
Emergency Plan Deficiencies Initiating Condition 10 (Major damage to spent fuel). The requirement for analysis by health physics to confirm the release of radioactive material from the fuel before activating the plan should be dropped.
Initiating Condition 13 (Radiological effluents). The plan states the initiating condition in terms of projected doses rather than dose rates, as specified in Appendix 1, NUREG-0654.
Initiating Condition 15 (Severe natural phenomena). The earthquake EAL in the plan is unacceptable because it requires loss cf load or damage to the plant.
In addition, the EAL based on Safe Shutdown Earthquake (SSE) accelerations is not addressed.
General Emergency Initiating Condition 1 (Radiological effluents).
The Emergency Plan uses 2 Rem whole body or 12 Rem thyroid dose at the site boundary rather than the 1 Rem /hr whole body or 5 Rem /hr thyroid dose rates specified in Appendix 1, NUREG-0654.
Initiating Condition 2 (Loss of 2 out of 3 fission product barriers).
The Emergency Plan includes EALs for LOCA's but not for steam generator tube ruptures. In addition, an EAL for inadequte subcooling should be added to the LOCA EALs.
Initiating Condition 3 (Security).
A General Emergency should be established if the Control Room or any other vital area is occupied by an aggressor.
As a general comment, many of the radiation monitor readings specified in Tables 4.1, B-D of the Surry Emergency Plan are from 10 to 1000 times higher than shown for apparently similar situations in the North Anna Emergency Plan and should be checked for accuracy.
5.
(0.2) The following initiating conditions in NUREG-0654, Appendix 1, were not addressed.
Unusual Event:
7, 8, 9,11 and 17 Alert: 10 Site Emergency: 9 General Emergency: 7 6.
(G.1) The special needs of the handicapped are not addressed in the licensee's public information program.
7.
(G.3) The plan states the Lebanon Elementary School in Surry or the Power Station Training Center (adjacent to the EOF) will serve as the Public News Center. Which location will be used needs to be clarified.
e Appendix C 4
Emergency Plan Deficiencies 8.
(H.9) The plans fails to indicate if the OSC has adequate capacity to accommodate reporting personnel.
Supplies and equipment are normally kept at the Health Physics Office or warehouse and will be transferred to the OSC as needed. However, the location of the Health Physics Office and warehouse in relation to the OSC is not indicated nor is it clear that the transfer of equipment can be easily accomplished.
For example, will the movement of equipment and materials be delayed by having to enter or cross controlled access areas or avoiding exposure to radiation.
9.
(I.5) Although there are numerous sources of meteorological data, in addition to the meteorological station at the Surry Power Station, the Emergency Plan does not address where the equipment readouts are located or how this information is transmitted to the Control Room, TSC, E0F and an offsite NRC Center.
10.
(I.10) Page 6.16 of the Emergency Plan indicates only that various measured parameters will be related to dose rates for key isotopes and fails to indicate if those key isotopes are the ones listed in Table 3 of NUREG-0654.
11.
(J.1) The plan fails to indicate the time established for warning and advising onsite individuals of an emergency status.
12.
(J.10) There are no maps found in the plan showing preselected radiological sampling and monitoring points, relocation center in host areas, and shelter areas.
Also, no map was found showing the population density by evacuation areas.
13.
(N.1) The plan does not indicate that exercises and drills are conducted according to the NRC criteria.
14.
(N.2) The plan does not address the need to include the aspect of under-i standing the content of messages as part of a communications drill.
In addition, communications and record keeping are not addressed as part of Radiological ibnitoring Drills.
15.
(D.2) The plan does not address providing the types of training specified in the footnote to criterion 0.2.a, page 75 of NUREG-0654 to offsite emergency personnel.
16.
(0.3) The Emergency Plan does not address training for radiological analysis personnel and Civil Defense / Emergency Service Personnel.
17.
(P.7) Appendix 10.4, page 10.16 references Section 10.1 for a complete list of EPIPs.
Actually, the list is in section 10.3 and does not specify the sections of the plan implemented by each procedure.
18.
(P.8) The Cross Reference Index in the Surry Emergency Plan which ties the various sections of the plan to the criteria in NUREG-0654 contains numerous errors.
,._.