ML20211F905

Insp Rept 50-395/86-08 on 860408-10.Violation Noted: Inadequate Procedure for Notifying Offsite Authorities of Emergency

ML20211F905
Person / Time
Site:	Summer
Issue date:	06/05/1986
From:	Decker T, Kreh J, Marston R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20211F883	List: ML20211F877 ML20211F901 ML20211F905
References
50-395-86-08, 50-395-86-8, NUDOCS 8606190155
Download: ML20211F905 (11)

See also: IR 05000395/1986008

Text

- .. -_ _

'

.

.

'

. UNITED STATES

NUCLEAR REGULATORY COMMISSION

. [q'[pn atro,}'o

, REGION ll

g j ,

101 MARIETTA STREET.N.W.

• * ATLANTA, GEORGI A 30323

I'  % m.* # JUN 11 1936

' Report No.: 50-395/86-08

~ Licensee: South Carolina Electric and Gas Company

Columbia, SC 29218

Docket No.: 50-395 License No.: NPF-12

Facility Name: Virgil'C. Summer Nuclear Station

Inspection Condiicted: April 8-10, 1986

Inspector: Mil [A

J. L Kreh

/ WL d- 6-$b

Date Signed

Yf

R. R. Marston

s -r , ,

-

b ~'.5 ~ S b

Date Signed

Accompanying Personnel: G. W. Bethke, R. T. Hadley, A. K. Loposer,

J. A. MacLellan (Battelle Pacific Northwest

la rat ries)

Approved by: 6/S' 86

T. R. Decker, Chief Dhte' Signed

Emergency Preparedness Section

Division of Radiation Safety and Safeguards

SUMMARY

Scope: This routine, announced' inspection involved observation and evaluation of

a small-scale emergency preparedness exercise.

Results: One violation was identified concerning an inadequate procedure for

notifying offsite authorities of an emergency. No deviations were identified.

8606190155 860605

PDH ADOCK 0D000395

O PDR

.

REPORT DETAILS

1. Persons Contacted

.

Licensee Employees

• D. A. Nauman, Vice President, Nuclear Operations

• 0. S. Bradham, Director, Nuclear Operations

• L. A. Blue, Manager, Support Services

• K. E. Beale, Corporate Coordinator, Emergency Planning

• C. M. Counts, Station Coordinator, Emergency Planning

• D. R. Moore, Director, Quality & Procurement Services

• K. W. Woodward, Manager, Operations

• W. R. Baehr, Manager, Corporate Health Physics & Environmental Programs

• H. J. Sefick, Manager, Nuclear Security

• A. R. Koon, Jr. , Manager, Technical Support

• W. F. Bacon, Associate Manager, Chemistry

• M. N. Browne, Group Manager, Technical and Support Services

• R. M. McSwain, Coordinator, Corporate Communications

• B. C. Williams, Supervisor, Operations

• H. I. Donnelly, Senior Licensing Engineer

Other licensee employees contacted included technicians, operators, security

force members, and office personnel.

NRC Resident Inspector

R. L. Prevatte

• Attended exit interview

2. Exit Interview (30703)

The inspection scope and findings were summarized on April 10, 1986, with

l those persons indicated in Paragraph 1 above. The inspector discussed in

,

detail the violation described below in Paragraph 10 (failure to establish

! and implement an adequate procedure for notifying offsite authorities of an

emergency). Some explanatory remarks, but no dissenting comments, were

provided by the licensee. A secord potential violation (concerning

protective action recommendations) was also described but was later

determined to have been previously identified as a deficiency during a

Regional Office review of the licensee's Revision 15 to the Radiation

Emergency Plan (REP). During a telephone conversation on April 16, 1986,

the inspector informed C. M. Counts that no Notice of Violation would be

issued in connection with the latter finding. The licensee did not identify

1 as proprietary any of the materials provided to or reviewed by the

inspectors during this inspection.

3. Licensee Action on Previous Enforcement Matters (92702)

1

This subject was not addressed in the inspection.

f

..

- e

,  :

- *

-

, ,(. ,

i i'

?' j

1

e . 2

~

4. Exercise Scenario (82301)

'

The scenario for the emergency exercise was reviewed to assure that

provisions were made to test the integrated capability and a major portion

of the basic elements ' defined in the licensee's emergency plan and

organization pursuant to~10 CFR 50.47(b)(14), Paragraph IV.F of Appendix E

.- to 10 CFR Part 50, and specific criteria defined in Section II.N of

NUREG-0654, Revisio_n 1. ,.

The scenario was reviewed:in advance of the exercise and was discussed with

licensee represe'ntatiies during a controller / evaluator meeting on April 4,

1986. While no maj6r problems with the scenario were identified, some

inconsistencies became apparent during the exercise. The inconsistencies,

however, failed to detract from the overall performance of the licensee's

emergency 6tgan12ation.

,

No violations or deviations were identified.

"

5. Fire Drill (82301)

<

The scenario for the fire drill was reviewed to assure that provisions were

. made to test specific functions in the licensee's emergency plan pursuant to

10 CFR 50.47(b)(14), Paragraph IV.F of Appendix E ' to 10 CFR Part 50, and

specific criteria ' defined in Section II.N of NUREG-0654, Revision 1.

The scenario developed for the fire drill adequately exercised the

participating licensee organization and offsite local emergency agencies.

The scenario provided sufficient informntion to local support agencies

_ consistent with 'the scope of their participation in the drill. The

[ performance of the Fire Brigade was adequate; however, an inspector observed

! that additional controllers were needed to provide information to the Fire

'

Brigade regarding extent of the (simulated) fire, direction of the wind, and

other appropriate sensory simulations. Such information should preclude the

type of observed artificiality wherein the Fire Brigade rushed into an area

engulfed in.(simulated) smoke and fire.

Inspector Follow-up Item (50-395/86-08-01): Considering additional

controllers for fire drill to improve simulation of the fire emergency.

No violations or deviations were identified.

6. Assignment of Responsibility (82301)

This area was observed to assure that primary responsibilities for emergency

t response by- the licensee were specifically established, and that adequate

staff was available to respond to an emergency pursuant to

10 CFR 50.47(b)(1), Paragraph IV.A of Appendix E to 10 CFR Part 50, and

specific criteria defined in Section II.A of NUREG-0654, Revision 1.

l

h The inspectors observed that specific assignments were made for the

'

>

e licensee's emergency response organization, and that adequate staff was

'

available to respond to the simulated emergency. Review of the licensee's

'

activation procedure and call list indicated that sufficient technical staff

-

I

4

.

.

3

was available to provide for continuous staffing of the augmented emergency

organization (although such staffing was not required by the scenario scope

and conditions).

The inspectors also observed the activation, staffing, and operation of the

emergency organization in the Technical Support Center (TSC), Emergency

Operations Facility (EOF), and Operations Support Center (OSC). At each

response center, the required staffing and assignment of responsibility

appeared to be consistent with the licensee's approved procedures, although

irregularities in TSC activation were identified (see Paragraph 13.b).

No violations or deviations were identified.

7. Onsite Emergency Organization (82301)

The licensee's onsite emergency organization was observed to assure that the

following requirements were implemented pursuant to 10 CFR 50.47(b)(2),

Paragraph IV.A of Appendix E to 10 CFR Part 50, and specific criteria

promulgated in Section II.B of NUREG-0654, Revision 1: (1) responsibilities

for emergency response were unambiguously defined; (2) adequate staffing was

provided to assure initial facility accident response in key functional

areas at all times; (3) onsite and offsite support organizational

interactions were specified.

The inspectors observed that the initial onsite emergency organization was

adequately defined and that staff was available to fill key functional

positions. The on-duty Shif t Supervisor assumed the duties of Interim

Emergency Director promptly upon initiation of the simulated emergency and

managed the response until relieved by the Director, Nuclear Operations.

With the exception of the timeliness of notifications to offsite authorities

(see Paragraph 10), required interactions between the licensee's emergency

response organization and State and local support agencies were adequate and

consistent with the scope of the exercise.

No violations or deviations were identified.

8. Emergency Response Support and Resources (82301)

This area was observed to assure that arrangements for requesting and

effectively using offsite assistance resources were made pursuant to

10 CFR 50.47(b)(3), Paragraph IV.A of Appendix E to 10 CFR Part 50, and

specific criteria promulgated in Section II.D of NUREG-0654, Revision 1.

Licensee contact with offsite organizations was conducted in accordance with

approved procedures and was consistent with the scope of the exercise.

Assistance resources from State and local agencies were available to the

licensee.

No violations or deviations were identified.

-

.

.

a

,

=

_

=

4

_-

9. Emergency Classification System (82301) {

This area was observed to assure that a standard emergency classification j

-

and action level scheme was in use by the licensee pursuant to

10 CFR 50.47(b)(4), Paragraph IV.C of Appendix E to 10 CFR Part 50, and '

.

specific criteria promulgated in Section II.D of NVREG-0654, Revision 1.

An emergency action level matrix was used to classify the emergency and

escalate to more severe emergency classifications as the simulated emergency

j_1

progressed. The licensee's current classification system, known as the K

" Fission Product Barrier Approach to Emergency Event Classification," was

implemented via REP Revision 15 (dated September 1985) and was compre-

hensively reviewed during an inspection in February 1986 (see NRC Report

No. 50-395/86-05). As of the date of the exercise, a final determination

(by NRC Headquarters and the Regional Office) of the adequacy of the

licensee's classification system had not been made; such a determination was _

considered to be outside the scope of the NRC's evaluation of this exercise.

Notwithstanding the above-stated limitation, certain incidental observations

were made during the exercise. An inspector observed that the exercise

initiating event (an earthquake producins acceleration exceeding one-half of

that associated with the Safe Shutdown Earthquake [SSE], with no fission -

product barriers breached) resulted in a Notification of Unusual Event

(NOVE) classification, in accordance with EPP-001, " Activation and

Implementation of Emergency Plan." However, this classification wa; not i

consistent with the example initiating conditions (EICs) of Appendix 1 to

NUREG-0654. According to that guidance, the simulated earthquake would have

been straightforwardly classified as an Alert (EIC 17.a. " Earthquake greater

than OBE [ Operating Basis Earthquake] levels"), or, more conservatively, as .

a Site Area Emergency (EIC 15.a, " Earthquake greater than SSE levels"). The I

inspectors determined through review of the REP and implementing procedures d

that the NOUE classification of the earthquake was indicative of the A

tendency of the licensee's system to underclassify emergency conditions d

relative to the EICs of NUREG-0654. As discussed earlier, the licensee's 1

classification scheme remains under review by NRC and is being tracked as an i

unresolved item (50-395/86-05-01).

No violations or deviations were identified.

10. Notification Methods and Procedures (82301)

This area was observed to assure that procedures were established for -

]

notification of State and local response organizations and emergency

personnel by the licensee, and that the content of initial and follow-up '

messages to response organizations was established. This area was further  ;

observed to assure that means to provide early notification to the populace

within the plume exposure pathway were established pursuant to -

10 CFR 50.47(b)(5), Paragraph IV.D of Appendix E to 10 CFR Part 50, and

specific criteria defined in Section II.E of NUREG-0654, Revision 1. =

i

An inspector observed that notification methods and procedures were ,

available for use in providing information concerning the simulated -

~

emergency conditions to Federal, State, and local response organizations, -

-

-

...._ . ._ _ .. _ _ .

~

.

5

and to alert the licensee's augmented emergency response organizations.

However, notification of the State of South Carolina and local offsite

organizations was not completed in a timely manner following declaration of

each emergency classification (except General Emergency).

The inspectors observed the following time periods for the initial

notifications to State and country authorities of each emergency class

declaration (measured from declaration to the completion of the notification

process):

Emergency Classification Notification Time

NOUE (fire drill) 28 minutes

NOUE (exercise) 25 minutes

Alert 33 minutes

Site Area Emergency >15 minutes

General Emergency (required 15 minutes

notification of State only)

The licensee's demonstrated inability to provide timely notifications (i.e.,

"as soon as possible," according to Table 6.2 of the REP; within 15 minutes,

according to Appendix E of 10 CFR Part 50) was attributable to the fact that

five telephone calls were required (consecutive rather than concurrent, with

one to the State and one to each of the four counties in the 10-mile

emergency planning zone). Until the TSC was activated, one individual

designated as Control Room communicator was responsible for all offsite

notifications. During the exit interview, the Vice President for Nuclear

Operations acknowledged that the licensee had been aware of the notification

problem since October 1985, when a change in the State Warning Point

resulted in cessation of the previous arrangement whereby the licensee

notified only the State, which then relayed the notification to the four

counties. The licensee was considering the acquisition of a proprietary

radio system which would provide the capability of concurrent notifications

l to the appropriate offsite authorities. The licensee's inability to make

timely notifications to offsite authorities during the exercise was

determined to be symptomatic of an inadequate notification procedure.

EPP-002, " Communication and Notifications," specified that offsite

notifications merely begin within 15 minutes after an emergency declaration,

and designated only one communicator to make the five required telephone

calls. Failure to establish and implement an adequate procedure for

notifying offsite authorities of an emergency is a violation of Technical

Specification 6.8.1.e.

Violation (50-395/86-08-02): Inadequate procedure for implementing the REP

requirement for notification of offsite authorities.

l

l An inspector observed that an Alert was declared while the Control Room

! communicator was in the process of noti fying the NRC of the NOUE

,

classification. However, the communicator did not terminate the ongoing

i NOUE notification and immediately initiate the Alert notification as

i explicitly required by Section 5.2 of EPP-002. This was considered a

shortcoming correctable through appropriate training emphasis; the

.

.

6

\

licensee's performance in this area will be examined during a future

exercise.

Inspector Follow-up Item (50-395/86-08-03): Placing training emphasis on

transmission of current status information and termination of superseded

messages to NRC and offsite authorities.

The prompt notification system for alerting the public within the plume

exposure pathway was in place and was actuated following declaration of the

General Emergency. In addition, the Emergency Broadcast System was

activated to provide citizens a demonstration of the means by which they

would be informed during an actual emergency.

One violation and no deviations were identified.

11. Emergency Communications (82301)

This area was observed to assure that provisions existed for prompt

communications among principal response organizations and emergency

personnel pursuant to 10 CFR 50.47(b)(6), Paragraph IV.E of Appendix E to

10 CFR Part 50, and specific criteria promulgated in Section II.F of

NUREG-0654, Revision 1.

The inspector observed communications within and between the licensee's

emergency response fa tities, between the licensee and offsite agencies,

and between the offsite environmental monitoring teams and the EOF. The

inspector also observed information flow among various groups within the

licensee's emergency organization. Emergency communications were generally

adequate and consistent with the scope of the exercise.

A breakdown in effective communications existed briefly between the TSC and

the Control Room when the Director of Nuclear Operations assumed the

position of Emergency Director, relieving the Shift Supervisor of his duties

as Interim Emergency Director but leaving the Control Room with the

responsibility for notifications (the TSC was not yet fully staffed). This

l misunderstanding delayed transmission of the Alert notification to the State

'

and the counties.

l No violations or deviations were identified.

'

l

l 12. Public Education and Information (82301)

!

I This area was observed to assure that information concerning the simulated

emergency was made available for dissemination to the public as required by

10 CFR 50.47(b)(7), Paragraph IV.D of Appendix E to 10 CFR Part 50, and

specific criteria defined in NUREG-0654,Section II.G.

Information was provided to the media and the public in advance of the

exercise. The information included details on how the public would be

notified and what initial actions they should take in an emergency. A News

Media Area was established at the Nuclear Training Center and was well

equipped and coordinated. Two press conferences were observed and found to

be informative, accurate, and concise.

-

.

.

7

No violations or deviations were identified.

13. Emergency Facilities and Equipment (82301)

This area was observed to assure that adequate emergency facilities and

equipment to support an emergency response were provided and maintained

pursuant to 10 CFR 50.47(b)(8), Paragraph IV.E of Appendix E to

10 CFR Part 50, and specific criteria defined in Section II.H of NUREG-0654,

Revision 1.

The inspectors observed the activation, staffing, and operation of the

emergency response facilities, and evaluated the equipment provided for

emergency use during the exercise. Emergency response facilities activated

during the exercise included the Control Room, TSC, OSC, and EOF.

a. Control Room - (The Simulator functioned as the Control Room for the

exercise.) The inspector observed that Control Room operations

personnel acted promptly to initiate appropriate responses to the

simulated emergency. Emergency procedures were readily available,

routinely followed, and factored into accident assessment and

mitigation exercises.

Except in the case of the misunderstanding between the Control Room and

TSC as described above in paragraph 11, the Shift Supervisor and

Control Room staff were cognizant of their duties, responsibilities,

and authorities. These personnel demonstrated an adequate

understanding of the emergency classification system and the proper

use of procedures associated therewith.

The inspector polled the players at several points during the exercise

and determined that personnel were not consistently cognizant of the

emergency classification then in effect. Examples: (1) At 9:55 a.m.

the Shift Technical Advisor thought the classification was Site Area

r Emergency when in fact it was still Alert. (2) At 12:02 p.m. several

! persons, including the Assistant Shift Supervisor, believed the

,

classification was Site Area Emergency when in fact a General Emergency

l was declared at 10:23 a.m. Regular updates for the Control Room staff

t would preclude such instances of misinformation. This matter will be

reviewed during a future exercise.

Inspector Follow-up Item (50-395/86-08-04): Keeping Control Room staff

l informed of emergency status.

l

l b. Technical Support Center (TSC) - The TSC was activated and promptly

! staffed following notifications of the simulated emergency conditions

leading to the Alert classification. The facility staff appeared to be

knowledgeable concerning their emergency duties, authorities, and

responsibilities, and the required operation appeared acceptable. The

! inspector noted that updates by the Emergency Director were too

infrequent to keep all TSC personnel well informed regarding plant

status. This facility was provided with adequate equipment for support

of the assigned staff.

f

I

~

.

8

Status boards were strategically located to facilitate viewing by the

TSC staff. Status boards were updated as required to chronicle changes

in plant status, accident assessment, and mitigation throughout the

exercise. Particularly noteworthy was the maintenance of the plant

parameter status board, which was updated at 15-minute intervals.

c. Operations Support Center (OSC) - The OSC was promptly staffed

following activation of the REP. An inspector observed that teams were

assembled and deployed in a timely manner. The OSC supervisor was

cognizant of his duties and responsibilities, and OSC operations were

well managed.

d. Emergency Operations Facility (EOF) - The EOF was located in the lower

level of the Nuclear Training Center, approximately 2 miles from the

station. The facility appeared to be adequately designed, equipped,

and staffed to support the response to the simulated emergency.

E0F security / access control was observed to be appropriately

established and maintained. Communications with other emergency

response facilities were reliable. Status boards and other graphics

were strategically located and well maintained.

No violations or deviations were identified.

14. Accident Assessment (82301)

This area was observed to assure that adequate methods, systems, and

equipment for assessing and monitoring actual or potential offsite

consequences of a radiological emergency condition were in use as required

by 10 CFR 50.47(b)(9), Paragraph IV.B of Appendix E to 10 CFR Part 50, and

specific criteria promulgated in Section II.I of NUREG-0654, Revision 1.

The accident assessment program included an engineering assessment of plant

status and an assessment of radiological hazards to onsite and offsite

personnel. During the exercise, the engineering accident assessment team

l

functioned adequately in analyzing the plant status to provide recommenda-

l tions to the Emergency Director concerning mitigating actions required to

reduce damage to plant equipment, prevent releases of radioactive materials,

and terminate the emergency condition.

l

l Radiological assessment activities involved several groups. A TSC group was

effective in estimating the radiological impact within the plant based on

f in plant monitoring and onsite measurements. Offsite radiological moni-

toring teams were dispatched to determine the level of radioactivity in

those areas within the path of the plume. Radiological effluent data was

received in the EOF. The EOF calculations were compared on a timely basis

with those from TSC and with field data from offsite monitoring teams. No

major discrepancies were observed.

No violations or deviations were identified.

.- - . . . . . . _- .- -- -- -. . -

"

.

4

!

t. 9

,15. -Protective Response (82301)

.

-

This area was. observed to assure that guidelines for protective actions,

consistent with federal guidance, were developed and in place, and protec-

tive actions for emergency workers, including evacuation of nonessential

l- personnel, were implemented promptly as required by 10 CFR 50.47(b)(10) and

! specific criteria promulgated in Section II.J of.NUREG-0654, Revision 1.

. The inspector observed.the licensee's program for personnel accountability.

The inspector noted that upon sounding of the . site evacuation - alarm,

personnel appeared to proceed promptly to designated assembly points. All

- personnel were accounted for within 30 minutes after the site evacuation

4 alarm was sounded.

l The protective ' measures decision-making process was observed by the in-

spector. Recommendations issued by the TSC and EOF were timely, adequate,

'

and consistent with the criteria cited above. Protective action recommen-

dations were provided by the licensee to the State of South Carolina and

local offsite organizations consistent with the scope of the exercise

+ scenario.

No violations or deviations were identified.

16. Radiological Exposure Control (82301)

4

This' area was observed to assure that methods for controlling radiological

l exposures in an emergency were established and implemented for emergency

1

workers, and that such methods included exposure guidelines consistent with

EPA recommendations as required by 10 CFR 50.47(b)(11) and specific criteria

defined in Section II.K of NUREG-0654, Revision 1.

,

An inspector noted that radiological exposures were controlled throughout

the exercise by issuing supplemental dosimeters to emergency workers and by

conducting periodic radiological surveys in the emergency response

facilities. Exposure guidelines were in place for various categories of

! emergency actions, and adequate protective clothing and respiratory

protection were available for use as required (although use of the latter

was simulated).

Health Physics control of radiation exposure, contamination, and radiation

>

area access appeared adequate. Dosimetry was available and was used.

High-range dosimeters were available if needed.

No. violations or deviations were identified.

.17. Exercise Critique (82301)

f The licensee's critique of the emergency exercise was observed to assure

1- that shortcomings identified as part of the exercise were brought to the

attention of management- for corrective action, as required by

,

10 CFR 50.47(b)(14), Paragraph IV.F of Appendix E to 10 CFR Part 50, and

specific criteria in Section II.N of NUREG-0654, Revision 1.

i t

,

e

4 -n , , -, ,, ., - . - . , - - - - -- , . - , , . - - - + - - - - - , , , . ,,,.-,,,,-e a _, , --------r-

. .. _

.

.

10

A formal critique was held on April 10, 1986, with exercise controllers and

evaluators, licensee management, and NRC representatives. Weaknesses

identified during the exercise and plans for corrective actions were

discussed. Licensee action on identified weaknesses will be reviewed during

a subsequent inspection. (Observation of the licensee controller / evaluator

critique, held prior to the exit interview, was included as part of the

exercise evaluation. Those NRC findings not also identified by the licensee

were summarized during the exit interview).

No violations or deviations were identified.

18. Inspector Follow-up (92701)

(Closed) Inspector Follow-up Item 50-395/85-18-02: Disparity in dose

projections between TSC and EOF. Dose assessment personnel in the EOF

communicated continuously with their counterparts in the TSC. In each of

several observations by the inspector, dose projections at the E0F and TSC

were in agreement.

s

l

l

I

!

l

l