IR 05000334/1989011

Safety Insp Repts 50-334/89-11 & 50-412/89-12 on 890531- 0602.No Violations Noted.Major Areas Inspected:Emergency Preparedness Program Including Review of Previously Identified Insp Findings & Changes to Program

ML20246N242
Person / Time
Site:	Beaver Valley
Issue date:	07/12/1989
From:	Craig Gordon, Lazarus W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20246N229	List: IR 05000334/1989011 ML20246N224
References
50-334-89-11, 50-412-89-12, NUDOCS 8907190325
Download: ML20246N242 (10)

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U. S. IUCLEAR REGUIATORY COMISSION RB3 ION I Report No /89-11 & 50-412/89-12 Docket No & 50-412 License Nos. NPF-66 & NPF-73 Priority - Category C Licensoe: Duquesne Liqht Cdmpany Rx2t Office Box 4 Shippirgport, Pennsylvania 15077 Facility Name: Beaver Valley Atomic Power Station, Units 1 & 2 Inspection At: Shippirpport, Pennsylvania I*spection Conducted: May 31- June 2, 1989 NRC Team Members: A(ft . Mr ' ID Y9 rdon, Emergency Preparedness Section ine C. Z( E. F. Fox, Emergency PreImredness Section D. H. Schultz, Battelle, IUL Approved By: ,

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M4cA Aero 7 2 l i A ef, Emergency date Inspection Summary: Inspection on May 31- June 2, 1989 (Report Nos. 50-334/89-11 & 50-412/89-12) Areas Inspected: Routine, announced safety inspection of the emergency l preparedness (EP) program including review of previously identified inspwtic.at j findings, changes to the emergency prervedness program, review of organization ard management control, inspection of independent program audits, inspection of emergency response organization training, ard review of l revisions to the emergency action level I Results: No violations were identified. The Emertjency Preparedness Plan, l Emergency Plan Procedures, ard the emergency plannug program are being implemented in a maruwr to adequately protect public health and safet I

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l DETAILS 1.O Persons Contacted The followig licensee representatives were contacted during conduct of the inspection:

 * C. Bibbee, Communications Specialist A. Castelli, Radiological Controls Technician
 * J. Crockett, General Manager, Corporate lhiclear Services J. Cunning, Nuclear Shift Operations Foreman P. Eisenman, Nuclear Shift Operations Foreman
 * L. Frraland, Operations Supervisor J. Ganze, Adm2nistrative Assistant J. Hall, Radiological Controls Technician
 * C. Haney, Director, Technical Crafts ard Training F. Hummel, Nuclear Shift Supervisor I. Ianucci, Shift Technical Advisor B.~Irion, Nuclear Shift Operations Foreman D. Konopka, Nuclear Shift Supervisor
 * S. LaVie Health Physics Specialist
 *F.Lipch1ck,SeniorLicensingSupervisor
 * W. Mahan, Senior Planner
 * J. Marietta, EP Training
 * G. McKee, EP Section
 * R. Moser, EP Section
 * T. Noonan, General Manager, Nuclear Operations
 * K. Ostruski, Nuclear Shift Supervisor
 * F. Pavelchko, Director, Emergency Preparedness B. Prinkley, Administrative Assistant P. Scheboth, Radiological Controls Technician
 * K. Schuster, Operations Superintendent
 * J. Sieber, Vice President, Nuclear Group
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R. Smythe, Radiological Controls Technician J. Stauber, Nuclear Shift Operations Foreman C. Stewart, Administrative Assistant G. Storolis, Nuclear Shift Supervisor

 * H. Szklinski, EP Section J. 'Ihomas, Shift Technical Advisor J. Treese, Shift Technical Advisor B. Tuite, Nuclear Shift Supervisor B. White, Administrative Assistant
 * Denotes attendance at exit meeting CharK7es to the Emergency Preparedness Prwtam The inspectors dictmmed changes to the Duquesne Light Emgency !

Preparedness Plan made since the last inspection. A significant change occurred when the licensee instituted a ma]or revision to the emergency action level (FAL) and emergency classification schem 'hing the Emergency Preparedness Implementation Appraisal conducted in 1987 and just prior to Unit 2 licensing concerns were raised regarding operations staff use of FAL's arrl classification of emergency condition l l j

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In walkthrough sessions at that time with control roam staff it was found that shift crews could not readily use available procedures to perfom inw14 ate respanse duties and that classification of events varied between each operations group. In response to these cancerns, the licensee assembled a task force comprised of emergen.my preparedness, operations, health 12ysics, aM other support pennel to address the problems associated with existing EAls. In late 1988, the task force completed revision of the new EAL set and subnitted it (along with a basis document describing each change) to NRC for review. Fram early 1989 until the time of the inspection, the licenses provided training to operations personnel en changes to the EAl With the completion by the licensee of training for all shift staff and formal implementation the EAIs, this NRC inspection was conducted to focus on trainirg effectiveness frun a performance staMpoint in terms of the staff's ability to use the new EAL format. Walkthrough scenarios were prepared and presented to each shift and emergency response actions evaluated. Overall response by each shift was favorable and previously identified items in this area are closed (50-412/87-49-01 & 50-412/87-49-03).

An organizational change in reporting chain took place since the last inspection. The emergency preparedness staff now reports to the General Manager, Nuclear Operations Support Services, and is an independent group. Prior to this change the EP program was part of the training department. Dircussion with the Director EF Prwtm irxlicated that emergency response organization training 1s still provided and a good interface'with training staff has been maintaine No changes in onsite assignments of the emergency preparedness ptwtan were noted. A change in the offsite duties was made in that responsibilities for assisting county and local officials in developing hazardous material response plans to meet the EPA's Superfund requirements was adde Onsite emergency response facilities (ERF) have remained the same. 'Ihe licensee provided infomation on a significant upgrade to the Emergency News Center. A new building is currently urxler construction offsite and is expected to be completed and functional prior to the 1989 Ennual exercise. Coordination with NRC regarding design layout and space arrrwrhtions should he made prior to operation and adequacy of the new facility will be evaluated in a 9*vwment inspectio .1 Review of Beaver Valley Ibwer Station EAls

The NRC review of revised EAIs was formally transmitted to the licensee I prior to the inspection on April 24, 1989, and identified both acceptable areas and differences when campared to IURDG-0654 initiating condition A meeting was held on June 1 with task force mcmbers and upper-level staff to discuss the review. 'Ihis meeting pmvided the NRC the uppurLunity to amplify concerns and permit the licensee to respond to comments. At the conclusion of the meeting, the licensee committed to incorporate many NRC concerns into either the next EAL revision or EP Plan issue or provide sound basis for not including the camment _ _ _ - - - -

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Certain items remainu' nresolved perriing the clarification of guidance, particularly in the areas of barrier breach analysis, extent of fuel failure, arri operational node and deteminirq hw different severities of each item relates to a specific crepcf classification. % e inspectors summarized individual commitments with licensee personnel and these will be followed up during a subsequent inspectio .0 Eirewci Facilities, Equipment, Instrumentation, and Supplies

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me inspectors toured the Control Room, Eme_gency tions Facility (EOF), Technical Support Center (TSC), and Radiol cal Operations Center (ROC) with the Director, EP. 'Ihese facilit es were as described in the Emergency Preparedness Plan and are adequate to support e mIgency response activities. Each facility has been used repeatedly to support past drills and exercises. Facilities, equipment, and a lies have been maintained in a state of operational readines pment lockers, cabinets, and corsunications devices (telephones and portable radios) were inspae+ael in the EOF, TSC, and DLesel Generator building (supplies for offsite teams) and were functiona Inventories of radiation survey kits, data acquisitiorV dose assessment systems, protective clothirg, and designated emergency supplies are being maintained within each emeroency response facilit des in size and better building ventilation in the TSC arxi EOF have roved overall habitability for response p 'Ihe Director EP serves as the buildirg manager for the EOF and TSC arri ensures that regular surveillance for housekeeping and , maintenance are conducted to keep it presenta" a and operationa .0 Organization and Management Control

  'Ihe inspectors reviewed task assignments for individuals within the emergency response organization (ERO), evaluated emergency preparedness program management and administration, and held discussions with cognizant licensee personnel to determire management involvement in the stei.jmcy preparedness supcu EP p m staffirg has remained constant wer the past few years and the stirry staff level is adeguate to carry out basic pupcua responsibilities. Such responsibilities include maintenance of the Emergency Preparedness Plan, implementirq pucslures, emertJency response facilities, arx3. designated equipment, development of exercise scenarios, training of the onsite ERO ?nd State / local responders, and cooperation with offsite support groups. 'Ihe Vice President, Nuclear Group is involved in several routine program activities, participates in drills and exercises, and lends emple support to the program when necded. 'Ihe inspectors determined that program direction and personnel resources are adequat _
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2 e functions and staff of the ERO also have remained stable and no changes were noted in key response duties or assignments. An IDF liaison position has been nMM to prwide the Emergency Support Director with extra support for interfacing with State representatives in the EOF and has proved beneficial in drills. Qualified individuals in each emergency response position are maintained via camputer and the Emergency Organization call list. It was found that the licensee had sufficient personnel available to staff all ERO positions to ensure full coverage durirg a prolonged emyrn .0 Independent Reviews / Audits Audits of the EP Fwpmu are performed by a two member audit team from the licensee's quality assurance unit. Wey have been thoroughly conducted since 1982, are adequate in scope, and are con +y+M to meet the requirements of 10 CPR 50.54(t) . We auditors and central QA Department files maintain copies of audit report Criteria for the audits were developed using guidance in documents provided by American Nuclear Insurers, INIO, Edison Electric Institute, and IEC temporary instructions. A checidist of audit items was used by the QA staff to perform the audits in 1937 and 1988. Review of the checklist indicates that essential EP program functions such as implementing procedures, trainincJ, inventory maintenance, interface with State and local agencies, ard drills and exercises are covered. 'Ihe primary area not audited is the manner in which the basic framework of the program meets the plannirg standards of 10 CFR 50.47(bj. We inspectors MmiW whether the audits included all plannity stardards and other applicable IRC rules renary for program implementatio Auditors agreed to review existing fBC ruluirements and revise audit criteria accordingl 'Ihe inspectors found that no change in EPP audit team personnel has been made since 1984. 'Ihe inspectors expressed concern over usirg the same personnel each year to perform audits ard at the same time maintain independence in the review process. In order to provide a change in perspective for corduct of EPP audits, the QA Supervisor stated that a change in team members would be made for the 1990 audi We inspectors reviewed the results of audits conducted durirg 1987 ard 1988 and dimmW the firdirgs with EP and QA staffs. Results of audits identified only minor concerns with the EP program. Audit results are categorized either as deficiencies or observations and di m m W with EP staff when the audit is completed. A corrective action system is in place to rasolve findings through issuance of a QA Audit report. W e audit report is transmitted to the General Manager, Corporate Nuclear Services ard a response requested within 30 day Follwing the response by the EP program staff, auditors evaluate and confirm commitments for corrective action.

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6.0 Knowledge and Furformance of Duties, 6.1 Establishment of Training Program me inspector reviewed the licensee's suf.cuu for emergency response training and noted that Section 8.0 of the EP Plan describes an enulycacy training program for different categories of 1mmuuml. %ese include all personnel granted unescorted access within the protected and area offsiteofsupport the site,group all licensee personnel Specific assigned ERO training to thedeterm is then ERO,ined by the training department and includes each emergency positio Discussions were held with EP training instructors who provided training and attendance lesson plans, records examination of response material, training for site examination results,ite records are personnel. Ompos maintained via computer for each individual. Tb detennine when response training for any member of the ERO was taken or when requalification is due, instructors develop an annual schedule at the beginning of each yea Review of the training records indicated that requalification of several personnel in the Emergency Response Manager and Emergency Director positions were out of date. This was due to the additional trainig on-the new EAL's given during early 1989. he instructors stated that requalification for all positions was expected to be cmpleted later in the yea Trainig provided to key response personnel by the training department - includes both classrixxn aM practical instruction in emergency classification, protective action reg -aMations, technical support, onsite/offsite surveys, chemistry, communications, and radiological a=en Trainig of offsite support groups is provided by EPP staff members to approximately 200 different groups of response personnel- within the EP S e effort provided in this area is noteworthy because it entails coordinating and administering annual training sessions to support personnel (many of whom are volunteers) after regular working hour ; EP lesson plans are detailed and focus on important response elements or implementing procedures. The lesson plan for Emergency Director training provides an outline of learnig objectives on emergency l classifications, facilities, ERO, dore a - - nt, communications and i protective action rw - ondations (PAR). A lesson plan (9283) was j developed for the new EAL revision but does not interrelate information on the ERO, dose asm-nt, or PAR's . Exam questions relate directly to lesson plan material and individuals must demonstrate proficiency in i l their reqxactive response duties as part of the annual requalificatio ' Ibrformance of response personnel has consistently been demonstrated in drills and walkthrough exercises, and no concerns were identified with response of personnel to emergencies.

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6.2 Observation of Medical Drill he inspectors observed a medical drill corducted at Salem 0:munity Ohio. We ital is identified in the Hospital EPP as one in Columbiana County,in of the centers with the EPZ ca le of treating contaminated / injured victims. The drill involved response by hospital ad amhnlance personnel and was held in light of guidance provided in FDR Guidance Mencrandum MS-1. The .nspectors observed that response of all modical perch was efficient. Durirg the post-drill critique, preliminary results provided by FDR abservers indicated no negative findirg .3 Implementation of Trainirn ProTram ard Walkthroughs In order to ascertain training of the ERO in response to severe accident conditions and rapidly escalating events, the inspectors corducted walkthroughs of four control roam crews, two crews from each unit. Each shift crew consisted of a Nuclear Shift Supervisor (NSS), Nuclear Shift Oper4tions Ebreman (NSOF), Shift Technical Advisor (STA), Radiological Controls Technician (RCT) for dose a-ent, ard Administrative Assistant (AA) . We walkthroughs focused on the duties aM responsibilities of the shift functioning as a team, to implement the new EAIs in the EP Pla Specific response areas observed were:

  - detecting emergencies ard implementing appropriate response procedures;
  - classifying emergencies;
  - making appropriate onsite ard offsite notifications;
  - performing dose projection ard a=ent activities; and
  - forn11ating onsite ard offsite protective action zw-nndation Overall performance of each shift was efficient ard dsuichated the ability to implement the EP Plan effectively. Thorough knowledge of implementing procedures, familiarity with revised EAIs, and development of conservative protective action r% +rdations were observe Details of walkthrough results were presented and dirot W with the licensee ard are summarized by functional area. The licensee committed t'. address identified concerns through additional training where rvemr Familiarity ard Knodedge of the Enernency Preparedness Plan The inspectors discussed the various IcVels of the emergency classification scheme with each shift to determine their urderstardirg of plant degradation associated with emergency classifications, and the related radiological impact to the publi I

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2 roe of four crews were able to satisfactorily relate continued safety system function to classification. One crew however, chose to describe classificationsasafunctionofdegradingf1ssionproductbarriersand 1 was unable to rationalize how a General Emm uncy could exist with an l intact third barrier. W e inspectors noted that this crew's description ) was not consistent with the EP Pla It was also noted that the licensee does not use a fission product j barrier analysis in their classification scheme. In regard to i radiological inpact to the public for each classification, two of four ; shifts were unable to quantify dose rates or doses in comparison with ' EPA Protective Action Guidelines (PM), e.g., Alert defined as a small fraction of the PM. TAL review irdicated that this relationship is not included in the classification s &eme definition Accident Detection / Mitigation In - each shift's use of Abnormal i Operat nse to off normal Procedures with conditions, subsequent implementation of the EP Plan was 1 acceptabl Classification Classification of events using revised EAL's was demonstrated by each shift. We postulated plant coniitions presented, when considered individually, wem close to, but below EAL thresholds for the Unusual Event or Site Area Energency classificatio W e intent of the scenario was to determine the ability of the NSS to exercise discretionary authority in those marginal cases where the EAL was not explicitly exceeded. W e results were as follows: . Each shift classified the first set of conditions as an Unusual Event, notwithstanding the conditions of degraded fuel, a leaking RCS system, and unknown plant degradation due to an earthquake. Ibr simultaneous initiating corditions of failed fuel, a major lOCA, high (ard increasing) containment pmssure, less than one train of containment l sprays, ard significantly degraded DOCS systems, three shifts made a l Site Arua Emergency classification. he fourth shift classified these j corditions as a General Eugency because the crew actively pursued the l arount of increased degradation in process during the classification, I and fourd that one of the parameters previously given had degraded further, to a value in excess of a General Emergency EA Se inspectors noted that strict adherence to procedures was durskated by Nuclear Shift Supervisors. However, discretion could have been effectively instituted in those cases where degradirx3 t conditions existed ard no apparent recovery of the plant was expecte { A concern identified by the walkthroughs is that ea d NSS consider ' escalating classifications due to the combination of multiple EAL's, continued degradation of plant corditions, ard unkrxun corditions associated with massive plant damag l I

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9 Another concern was identified with Shift Te&nical Advisors not monitorirg plant Critical Safety Rinctions (CSF) until operators completed higher priority steps within the IDP's arxi then reached step 27, which acts as a reminder to initiate monitoring of critical safety function status trees. he licensee stated that monitorirg of the CSFF was not appropriate until directed by the proper step of the IDP, yet agreed that the SIA must be involved as soon as the safety level of the plant is u.ugumised. We inspectors noted, however, that monitorirg of CSFs should occur at all times by the STA in an accident transient in accordance with the guidance of IUREG-0737, Appendix Notifications m e shifts prepared the notification message forms used to notify offsite authorities and performed actual notifications to offsite authoritie %e inspectors found that each shift made at least one error in notification. Errors were noted in enterirg information on drill status, classification, message ty p and PARS. Transmission errors were identified in providing classazcation ard event times to offsite agencie Dose Projection ard Asment Each shift was requested to perform dose assessment using previously computed release rate values that had been prepared by the licensee's radiological controls staff. Wo different socnarios were prepare We first included a large fission product inventory in containment with litt4e or no radioactive release. S e second also included a large fission product inventory in containment, but the size and impact of the release cas much greate S e inspectors observed that only two of four IESs ordered the Radiological Controls Technician (the designated individual responsible for dose assessment functions) to perform dose projections based on the source term in containmort for a non-releasirg condition in accordance with EPP/I-5. Usirg the ccmputer model, one of the RCTs was unable to obtain a dose projection which was consistent with a large source term and General Emergency plant conditions. In addition, both RCTs used the default value of one hour release duration instead of the known time of 10 hours. Eis resulted in a dose projection much lower than what should have been calculated. Conversely, two RCPs who performed manual dose calculations arrived at dose projections liore than an order of magnitude in error in the conservative direction. A concern expressed by the inspectors is that RCIt be able to perform accurate dose calculations both manually and through use of the computer assisted mode I i i I ____ -

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Protective Action Recommerdati,o_ns Each NSS was requested to formulate onsite and offsite Protective Action Rm--erdations based upon the information provided in the scenari 'Ihe inspectors observed that all four NSSs properly developed and implemented a recommendation for evacuation at the General Lieuvec However, it was noted that the PAR was implemented without considering consultation with State and county officials on the Dnergency communications System -{ gold phone) to assure that understood the rm --- r3ation per EPP/IP 4.1. 'Ihe inspectors de - ied that consultation should be made to assure all factors affectire the rm- meidatim, includiry plant conditions ard expected duration of release, were available to officials considerity offsite condition .0 Dcit Meetirn

 'Ihe inspectors met with the licensee personnel denoted in Sect. ion 1 at the conclusion of the inspection to discuss the findirgs as presented in this report. 'Ibe licensee acknowledged the firdirgs and agreed to evaluate them and institute corrective actions as appropriat At no time durity the inspection did the inspector previde any written information to the license l l

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