IR 05000412/1987014

Emergency Preparedness Implementation Appraisal Insp Rept 50-412/87-14 on 870302-06.No Violations Noted.Major Areas Inspected:Emergency Preparedness Program for Facility. Program Areas Requiring Corrective Actions Included in Rept

ML20210B291
Person / Time
Site:	Beaver Valley
Issue date:	04/28/1987
From:	Fox E, Lazarus W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20210B202	List: IR 05000412/1987014 ML20210B199
References
50-412-87-14, NUDOCS 8705050279
Download: ML20210B291 (23)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /87-14 Docket N License N CPPR-105 Priority -

Category B-1 Licensee: _Duquesne Light Company Post Office Box 4 Shippingport, Pennsylvania 15077-Facility Name: Beaver Valley Power Station Inspection At: Shippingport, Pennsylvania 15077 Inspection Conducted: _Marciv)2-6,J987 Inspectors: ~

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F'. Vox,g aT(Team Leader Y[/7 /7 Date

NRC Team Members: C. Amato, EP&RPB, ORSS G. Bryan, Battelle, PNL P. Gaul, EP&RPB, DRSS G. Gordon, EP&RPB, DRSS

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W. Thomas, EP&RPB, DRSS T. Tuccinardi, EP&RPB, DRSS G monds, DEPER, IE Approved by: / ,

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. rusf L tef Emergency Date P aredne ection, EP&RPB Inspection Summary: Emergency Preparedness Implementation Appraisal conducted on March 2-6,1987 (Report No. 50-412/87-14)

Areas Inspected: Emergency Preparedness Implementation Appraisal (EPIA) to evaluate the adequacy and effectiveness of the emergency preparedness program for Beaver Valley Unit-2 including administration, organization, procedures, training, and facilities and equipmen Results: No violations were identified. Several program areas were identified

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shich are incomplete or require corrective action. These are listed as open items and will need to be addressed by the licensee and reinspected in a sub-sequent inspectio Section 4 of this report provides a summary listing of these items along wito the determination of whether the item is required to be corrected prior to issuance of the low power license or the full power licens PDR ADOCK 05000412 O PDR

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OETAILS 1.0 Persons Contacted

• T. Dodson, Records Management Administration A. Fenwick, Director Records

• P. Gangwisch, Operations and Maintenance Instructor

• D. Girdwood, Director Radiation Operations

• J. Godleski, SNR Test Engineer H. Harper, Director Security l *D. Hunkele, Director QA Operations

• J. Kosmal, Manager Radiological Controls

• Lacey, Plant Manager S. LaVie, SNR HP Specialist V. Linderbom, Director Plant Chemistry '

• A. Lambardo, Nuclear Chemical Specialist

• W. Mahan. Senior Planner

• A. Morabito,' Manager Nuclear Training

• R. Martin, Manager Regulatory Affairs

• G. McKee, Energency Planning Specialist

F. Nelson, Nuclear Shif t Supervisor (NSS)

• F. Pavlechko, Director, Emergency Preparedness Program

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C. O'Neil, Procedures Engineer J. Sasala, Director Nuclear Communication

• T. Sieber, Vice President Nuclear Operation

• R. Schuster, Nuclear Station Operations Supervisor, BV-2 T. Sloan, Computer Specialist

• G. Sovick, SNR Licensing Supervisor G. Storolis, NSS

• H. Szklinski, HP Specialist

• B. Tufte, Nuclear Shift Operations Foreman J. Vassello, NSS

• R. Vento, Director, Rad. Engineering M. Wahlen Mayer, NSS

• 0 Weitz, SNR HP Specialist

• T. Zog1mann, SNR Project Engineer

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l The inspectors also interviewed and observed the actions of other l licensee employee * Denotes those present at exit interview.

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. 3 2.0 Scope of Appraisal

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The purposes of this appraisal were to determine the emergency prepared-ness readiness of Beaver Valley Power Station Unit-2, to evaluate the overall adequacy and effectiveness of licensee onsite emergency prepared-  ;

ness, and to identify areas of weakness that need to be addressed prior to licensing. fhe principal criteria for this appraisal are contained in IE Inspection Procedure TI 2515/55, NUREG-0654, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants", 10 CFR 50.47 and 10 CFR 50, Appendix The appraisal addressed administration, emergency organization, emergency preparedness training, emergency response facilities and equipment, imple-menting procedures, and coordination with offsite group .0 Inspection Details Administration and Organization of The Emergency Plan The inspectors reviewed the Table of Organization and Section 8 of the Emergency Preparedness Plan and held discussions with licensee management and determined that the administration and organization of i

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the emergenc> plan is adequate. The licensee's emergency organiza-tion is part of the Nuclear Group and the Director of Emergency Pre-paredness reports to the Vice President, Nuclear through the Director

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of Training. Provisions are in place for centralized administration

. of the program and for upper level management control of it. The l inspectors determined through review of current job descriptions that

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emergency responsibilities were appropriately assigned and that the persons assigned these responsibilities had been given the necessary authority to carry out such responsibilit The Director, Emergency l Preparedness (EP), receives upper management support for the progra '

This was confirmed through an interview with the Vice President, Nuclear who stated he actively supports emergency preparedness activitie Public information brochures distributed by the licensee

.i also highlight upper management support. Contact and coordination is maintained between the emergency preparedness staff, site persennel,

and site organizations such as the Onsite Safety Committee (OSC) and other appropriate organizations both offsite and at the corporate

level. A high degree of coordination with various off site organiza-

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tions, local, county and state governments, local news media, and the

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general public is maintained by the emergency preparedness staff. A strong emphasis has been placed on keeping these sectors informed and

appraised of emergency preparedness at the site as evidenced by the number of information classes offered and presented by the Emergency

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Preparedness personnel and by the Vice President, Nuclea !

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. 4 Emergency Organization The inspectors reviewed the licensee's emergency response organiza-tion as identified in a draf t copy of Section 5, Rev. 8, Issue 1 of the Emergency Plan to determine that definition of authority, respon-sibility, and duties of key responders assigned to the organization are described. The insoectors also reviewed the Corporate Communi-cations' Department's " Emergency Public Information Plan, BVPS" which identifies personnel assignments for individuals involved in public information activities. (,hanges to emergency organization affecting Unit 2 were discussed with the licensee's EP staf Three basic phases of emergency organization exist based upon emer-gency classification. Initially, the on-shift organization is com-prised of an Emergency Director (Shif t Supervisor), Communications and Records Coordinator (Administrative Assistant), Technical Support Coordinator (STA), Operations Coordinator (Shif t Foreman), Radiolog- ,

ical Control Coordinator (Radcon technician), and Security Coordi-nator (Security Supervisor). Figure 5.3 of the Emergency Plan describes the organization chart for the primary emorgency (control room) organization and the exact arrangement to be used for Unit 2.

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When an Alert condition is declared, the second phase of organization takes effect. At this level, the Technical Support Center (TSC),

Operations Support Center (OSC), Radiological Operations Center (ROC), News Center, and the Environmental Assessment and Dose Pro-l jection (EA & DP) function become activated. The key functional I areas and the major tasks within each functional area are adequately described for individual response positions in Section 5.2 of the Emergency Plan. Managerial positions and the responsibilities which may be carried out are also listed and further detailed in the Emer-gency Plan Implementation Procedures (EPIP).

An Emergency Organization Call List is maintained by the EP staff which identifies individual members of the emergency organization for the Control Room, TSC, and EOF, in addition to functional areas for

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each emergency facility. Information identified on the list includes name, routine job title, work telephone number, home telephone num-ber, and emergency training completion dates. The list is updated bi-monthly and is adequate to track the status of qualified personnel within the emergency organizatio t l Basic changes in emergency staff relate to the addition of operations i (control room) personnel, radiation health technicians, and mainte-nance personnel to support the additional workload of Unit 2. One  !

minor change to the Emergency Plan was the addition of a Computer Coordinator to help with operation of the Plant Variable Computer and Safety Parameter Display System (SPDS). Operations personnel are identified on the organization call list as assigned to Unit 1 or Unit 2.

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1 ' 5 Based on the above, the Administration and Organization portion of l

the licensee's emergency preparedness program is acceptable.

l C. Training program (1) Emergency plan Training Program Establishment and Implementation

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The inspectors reviewed the training program records and lesson l plans, and interviewed Itcensee staff. It was determined that i training of on-site emergency rosponse organization personnel is the responsibility of the Nuclear Group Training Section. This l section also provides training for operations personnel and i General Employee Training. Emergency response training is man-aged by the Director for Technical and Crafts Training. Two

, qualified instructors are assigned full time to this activity.

l Twenty five courses have been developed which include classroom l instruction and required reading, table-top exercises, and stu-l dent participation in annual drills and exercise Instruction I has been developed in accordance with Institute of Nuclear Power Operations (INPO) guidelines. Unit 2 specific lesson plans are

! under development but have not been completed (50-412/87-14-01).

Emergency Directors, Senior Reactor Operator candidates, and Emergency / Recovery Managers receive an average of 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> of emergency preparedness instruction. Course content includes recognizing and classifying emergency conditions, notifications, use of communication equipment and procedures, projected dose assessment, Protective Action Recommendation (PAR) format, and recovery. It was noted that a table top exercise (Course 9251)

associated with this course is not mandatory. This issue is discussed in (2) belo Courses are given quarterly and scheduled on an individual basis. Retraining is required to maintain emergency response qualification and this training must be completed every 12 months. A review of training records indicates that with one exception, emergency positions are currently filled with quali-fied personnel. At least three personnel are qualified for each key emergency respor.c organization position. However, since 1985 there have been no qualified Shif t Technical Assistants (STA) to carry out emergency planning duties. The licensee recognized this problem and has scheduled STA training to begin March 20, 1987. This training is expected to be completed by July 1, 1987. (50-412/87-14-02)

Off-site training is the responsibility of the emergency pre-l paredness program staff. Almost 3000 offsite individuals from 250 entities have recotved such training. Included are munic-ipalities, counties, police, fire and rescue squads, public and i private schools, bus drivers, emergency broadcasters, the I American Red Cross, nursing home staffs, special care facili-ties, State personnel, and State Police.

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(2) Control Room Walk-Through Observation l The inspectors requested that the licensee formulate four (4)

l control room operating shifts to participate in the walk-throughs. The licensee presented crews consisting of a shift l supervisor, an administrative assistant (for notifications) and l a Rad Control Technician (for dose projections) and stated that these individuals could provide all immediate and necessary i response actions of a full on shift compliment and could be l

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evaluated as if they were full strength crews. Three generic, 3 loop Westinghouse accident scenarios were provided by the l inspectors, and presented in written form to each of the l

4 shifts interviewed. Each shift crew was given the same sco-nario to permit comparison of results. Performance was measured with respect to the Emergency Plan, Implementing Procedures, and NRC requirements or guidance. At the time of the appraisal, Unit 2 operations personnel had not been assigned to specific

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shift crews. Although one group (19 individuals) had completed NRC licensing examinations and a second group was scheduled for the exam, no personnel were licensed on Unit 2.

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l A weakness was identified during walk-throughs of the initial l response organization. Difficulty was encountered by operations l staf f using Emergency Action Levels (EAL) Tables and in clas-l sifying emergencies. Only one of the operators involved had l taken the " Table Top Discussions" and " Emergency Director l Training" courses. The inspectors reviewed this course and l

I concluded that emergency classification material should be enhanced and examination questions of a practical and applied nature be developed. This was discusseo with the licensee and the licensee agreed to consider this course be included as a required course in future training. (50-412/87-14-03)

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were: .

Emergency classification accuracy and time to evaluate Emergency Action Levels to properly classify the emergency were both severely hampered by the lack of basic human factors consideration in the procedure *

All shifts were able to classify an Anticipated Transient Without Scram (ATWS) correctly but none of the crews could locate a written definition of ATWS nor did any individual provide a satisfactory definition based upon experience or training.

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• Significant classification differences were found between shifts which used the same procedure and were provided with the same scenario situations in classifying ATWS, tube leaks with stuck open secondary code safety valves, and fires, an indication of inadequate training in these area I Shift members indicated that the EP training program for ,

Emergency Directors did not require any accident classi-  :

fication *

None of the Administrative Assistants (AA) involved in the  !

walk-throughs had completed emergency plan communicator trainin [

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Two of the four shifts failed to accomplish State and local [

l notification within 15 minutes. Time was measured from

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classification of the event to the time the shift super-I visor completed forms and presented them to the AA and did not include time required to deliver the message to offsite *

entities. One cause of the delay was the perceived need by '

the shift to make a dose assessment prior to notification.

Dose assessment walk-throughs were also conducted in con-junction with operator walk-throughs. Each of the 4 shifts

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were presented with the same dose projection proble Shift crews were free to select the method of assessment l (MIDAS or backup-hand calculation) for dose calculation '

All shifts chose the hand calculation method utilizing i the FSAR Accident Dose Projection Workshee Results from two shifts compared favorably when compared to  !

each other and to IROAM. However, portions of the results [

of the other two shifts differ significantly when compared r to other crew results and to IRDAM. The inspectors deter-mined that two of four shifts completed the problem ,

correctly while the other two shifts each failed in about  !

half of the dose assessment problem component This i appears to be a trairing deficiency and must be corrected prior to full power licensin (50-412/87-14-04)

j Fac111ttes and Equipmenj (1) Control Room j t

The inspectors toured the Unit 2 Control Room which was under t l construction. Projected completion and turn over of the Unit 2 l Control Room is scheduled for the end of April 1987. The Unit 2 Control Room is adjacent to and approximately the same size of  !

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the Unit 1 Control Room. The Unit 2 Control Room will share the l Unit 1 Control Room habitability envelope, i r

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The licensee stated that the Unit 2 Control Room would contain instrumentation to detect, measure and display radiation levels, airborne contamination, and plant process system parameter Emergency communications equipment is available for notification ,

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of offsite authorities and the NRC in the Shift Technical Supervisor's office of the Unit 1 Control Room. At the time of the inspection a wall existed between the Unit 1 and Unit 2 Shift Technical Supervisor's offices. This wall will be removed prior to operating license thereby allowing sharing of this equipn.ent for Unit 2 Control Roo Floor plan designs for the installation of communications equip-ment in the Unit 2 Control Room and the Shift Supervisor office were reviewed and once installed will be adequate. However, the dedicated line telephone system was not operable between the Unit 2 Control Room, TSC, and EOF. (50-412/87-14-05). This system is in place for Unit 1 and is powered from the uninter-rptible power supply. A base station for the DLC Industrial Radio System is also provided. This base station has its own transmitter and antenna and can communicate (via the BVPS repeater) with all DLC units. An extension to the NRC/ ENS red phone is at the TSC as well as PAX and Bell system telephone All Control Room personnel assigned are required to be respir-ator qualifie Respiratory protection equipment was not yet in place for use by control room personnel inside the control roo Protective clothing for fire brigade members was also not in place for use by assigned Control Room personnel. (50-412/

87-14-06). Further, the licensee stated that updated copies of the Emergency Plan and Implementing Procedures would be placed in the control room and added to the controlled copy listin (50-412/87-14-07)

(2) Technical Support Center (TSC)

The inspectors evaluated the licensee TSC to verify that the facility meets the requirements / guidance of NUREG-0654, NUREG-0696, NUREG-0737 Supp 1, and 10 CFR 50 Appendix E concern-ing accessibility to the control room, habitability, work space, availability of reference material, communications, data systems, and miscellaneous support equipmen The TSC and its operation are described in Section 7.1.2 and 7.1.5 of the Emer-gency Preparedness Plan and EPP/IP 1.4, " Technical Support Center Activation, Operation, and Deactivation."

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. 9 The TSC is located in the Emergency Response Facility (ERF).

This area of the ERF is sized to accommodate at least 30 persons comprised of plant technical staff and NRC personnel. There is sufficient desk space for approximately 25 people and adequate work space to accommodate full size engineering drawing Engineering drawings would be available from the ERF Records Room which currently contains all the drawings for Unit 1. The licensee stated that as-built drawings for Unit 2 will be placed in the ERF records room upon completion of construction (50-412/87-14-08).

The inspectors determined, with the assistance of Security, that the transit time from the TSC (at the ERF) to the Control Room was slightly in excess of two minutes. However, this two minute requirement was instituted to insure that information from the Control Room that wasn't available in the TSC could be quickly obtained. As the TSC has direct access to all significant parameters this is not a concer Parameter display of real-time plant status data for both Units will be through the terminals to the plant variable computer and the safety parameter display system (SPOS) computer. These systems will have video display and hardcopy printers for both units. It appears the T3C will have adequate capability for Unit 2 upon completion of installation and acceptance testing of the SPOS, projected for end of April 1987(50-412/87-14-09).

(3) Operations Support Center (OSC) and the Emergency Operations facility (MP)

The inspectors noted that the OSC and EOF are common to both l Unit I and Unit 2. These emergency facilities had previously l been found to be acceptable for carrying out emergency response activitie (4) Assembly Areas l

l The inspectors verified that the designated assembly / reassembly areas are located as described in the Emergency Plan and EPIP 3.1. The inspectors toured these areas to determine if they were marked, equipped and had adequate space. It was determined that there are three types of assembly areas: 1)

areas common to both units; 2) areas for Unit 2 within the site boundary; and 3) areas near but outside the site boundary. The

! two areas common to both units are functional (Administration Building and what will becomo the Alternate Access Facility).

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Two areas designated for Unit 2 and inside the protected area are the third floor locker room and fourth floor south of fice shop room. These two areas are partially equipped; card readers and the computer for personnel accountability are installed but the software is not yet functiona (50-412/87-14-10)

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Another area to be used for Unit 2 will be located within the l

exterior of the first floor of the Engineering Building (cur-rently the Stone & Webster engineering building). This area was not marked or equipped as an assembly area (50-412/87-14-11).

, Two remote assembly areas are Kennedy Corner and the Grange l Building in Hookstow Equipment will not be stored at these l facilities but will be brought from the site when needed.

! Initially keys for these facilities could not be found and when l found the key for Kennedy Corner was the wrong one. Access to appropriate keys to offsite assembly areas should be ensured

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(50-412/87-14-12). This facility consists of two trailers con-l nected by an enclosed are In that there are no sanitary facil-ities and minimel communication capability exists, this facility is presently not acceptable. The licensee advised the inspec-l tors that the Kennedy Corner facility would be relocated to the l Duquesne Western District Offic (50-412/87-14-13)

The facility located at Grange is adequate as a remote assembly area. Although the Grange is fenced with a locked gate there

are no key surveillance or remote assembly area security pro-l cedures. Adequacy of decontamination procedures could not be

determined since procedures and equipment were unavailable. The inspectors advised the licensee on the need to demonstrate decontamination at the Remote Assembly Areas. (50-412/87-14-14)

(5) Emergency Kits and Emergency Survey Instrumentation ,

The inspectors toured the licensee's Control Room, Technical Support Cente- (TSC), Operations Support Center (OSC), Emergency Operations Facility (EOF), and the assembly / reassembly areas in order to evaluate the adequacy of the emergency equipment stored in each facilit At certain facilities plastic seals are placed on kit lockers to provide tamper indication between inventories. The inspectors inventoried kits and storage conditions and determined that the kits at these locations contained sufficient supplies and pro-cedures for emergency teams and that storage conditions were adequat Periodic inventories required by EPP 7.1 of the Emergency Plan, were checked to verify that they had been completed as require Based on the review of randomly selected inventory records, this area was found to be acceptabl _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ____ ..

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It was determined that kits to be used for reentry contained sufficient quantities of extremity TLD's and high range direct reading dosimeters. Beta gamma and ion chamber instruments capable of measuring whole body dose rates either in plant or in a plume were also presen Instrumentation exrmined was found to be operable and in calibratio It was determined that environmental equipment and procedures which would enable the licensee to detect radioiodine and radio-active particulate materials, Cs-137 equivalent, at concentra-tions of at least E-07 pci/cc and E-09 pci/cc respectively were presen During the tour of the inplant emergency kits it was noted that two air sampler kits for Unit 2, were located on the turbine deck for Unit 1. The Unit 2 kits were locked within the Unit 1 air sampler kit storage area until the Unit 2 storage area could be built. (50-412/87-14-15)

The inspectors verified that emergency kits included an adequate quantity of respirators. Respirators examined appeared to be well maintained and ready for use. Kits also contained adequate quantities of protective clothing. Additional protective cloth-ing could be obtained from the station warehouse. Also, respi-ratory protective equipment can be obtained from a local dis-tributor and additional protective clothing could be obtained from area nuclear power station A review of the available emergency survey instrumentation revealed a list of equipment entitled " Radiological Control Department, EPP Punch List, Open Items", that is needed for the emergency preparedness program. This equipment has not yet been received. (50-412/87-14-16)

(6) Damage Control Kits Damage control kits were checked for proper equipment and stor-age considerations. It was determined that the licensee has maintenance equipment and supplies on-site or immediately avail-able to support all except the most unusual damage control prob-lems. Unusually heavy demand for equipment, supplies, and/or personnel can be met with trained craftsmen within the corporate work forc Based on these findings, this portion of the licensee's program is acceptabl _ _ _ _ - _ _ _ _

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(7) Area and Process Radiation Monitors

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The Digital Radiation Monitoring Systems (DRMS), composed of approximately 35 area monitoring channels and 62 process moni-toring channels, is to be installed to provide specific infor-mation on radiation levels at designated locations throughout Unit 2. DRMS read-outs are located at the operators console and the programmers console in the Control Room and in the Health Physics office are The DRMS is designed to detect, measure, display, and store radiation levels in the process and ventilation pathways and to detect radiological release rates from effluent monitors. The system has been partially installed, is not yet operational, and has not been turned over to the licensee (50-412/87-14-17).

Displays associated with area and process radiation monitors and f non process monitors will provide designated monitor locations I on.each floor plan, actual radiation reading or level, trip points, level alarms for water, temperature, pressure, and flows, detector efficiency (including conversion factors), time averaged trending levels, calibration dates, background checks, purge time, status of internal check source, equipment failure alarms, and specialized activities associated with each monito Though the majority of system hardware components are in place, some components such as the containment high range monitors are not yet installed. Additionally, the portions of the system that are in place have not been calibrated at the time of this inspectio Schedule for calibration and source testing has been developed, however the procedure for calibration of instru-ments and monitors, as well as a schedule for calibration is in draft form. (50-412/87-14-18)

Some of the detectors discussed above are installed with regard to their limitation of range, operating temperature, and humid-ity. However, the certification of the operating conditions for the detectors by the manufacturer is not complete but was in l progress during this inspection (50-412/87-14-19).

Monitors for Unit 2 DRMS are easily available to Control Room and health physics personnel. Inplant monitors are not shared by Units 1 and 2, minimizing the time needed by Control Room personnel to access DRMS dat Safety-related detector channels are on vital powe These channels are fed into a pair of redundant RM-11 computers. The computers are on separate power supplie The maintenance, preliminary calibration checks, monitor repair and replacement, is on going. Training of additional station personnel for the overview inspection, and repair of DRMS was incomplete at the time of this inspection. (50-412/87-14-20)

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(8) Non-Radiation Process Monitors (NRPM)

The inspector reviewed the Emergency Preparedness Plan and implementing procedures and chose approximately 49 Non-Radiation Process Monitors (NRPM) for review. Although portions of each monitoring channel had been installed, few were operationa All monitoring channels chosen for review are planned to have readouts in the Unit 2 Control Room, but could not be inspected since the control room was still under construction. Instal-lation of NRPM readouts in the Unit 2 control room should be completed (50-412/87-14-21).

(9) Meteorological Instrumentation

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Both Unit 1 and Unit 2 will use the Meteorological Information i Dose Assessment System (MIDAS) and share the Unit 1 meteorolog-ical tower. The MIDAS system in use for Unit 1 is an adequate system that is fully operational. MIDAS terminals are located in the TSC, Alternate TSC, EOF, Radiological Operations Center and the Unit 1 Control Roo Although there will be no additional terminal for Unit 2, the Unit 1 terminal will be shared between the two Control Rooms once access is provided as described in (1) abov Based on these findings, this portion of the licensee's program is acceptabl (10) Emergency Communication Equipment The inspectors reviewed Section 6 of the Emergency Plan and determined that specified equipment is adequate for notifying and instructing the publi Section 7.6 of the Emergency Plan outlines all generic communications equipment on site and at the ERF. At the time of this inspection, IP 1.2, " Communications",

and Ref. 1.2.1 to Section 7 were not available. It was deter- i mined that alarms, which include standby and evacuation alarms, l have not been tested and are not operational at present. These systems have not been turned over to the licensee as of the date of this inspection. A projected completion date was requested from the licensee. (50-412/87-14-22)

The inspectors verified that records of communication drills were complete and that all necessary checks had been made and recorded. The inspectors also verified that there is 24-hour capability to notify the NRC, State, and local authorities from the Control Room (Unit 1), which is to be shared by Unit 2 Con-trol Roo It was determined that dedicated hotline telephones to offsite authorities are backed-up by a radio system, and that backup power supply is available.

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. 14 Although no specific communication procedure is in place for Unit 2, a generic procedure 1.2 (June 26, 1986) describes the back up system and Section 7.6 of the emergency plan outlines backup communications equipmen (11) Reserve Emergency Supplies and Equipment The inspector reviewed Section 7.1.6 of the Emergency Plan and determined that the equipment designated as emergency equipment is specified, and the storage location of supplies in kits or It was determined that DLC maintains an

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cabinets is listed.

inventory of contamination control materials at Aliquippa Hos-pital and the Medical Center of Beaver County. It was specified that emergency kits and cabinets are to be inspected and inven-toried at least quarterly and after every use, including drills and exercise Aid to affected persons is described in Section 6.8 of the Emer-gency Plan. Although physicians and nurses are not employed and stationed on or near site, at least two persons trained in Red Cross Multi-Media are on site at all times. Arrangements for medical transport and hospital treatment have been estab-lished and training provided. The inspectors examined the Aliquippa Hospital Morgue and found that it was adequately equipped for decontamination of station personne Section 7.1.6 Emergency Plan specifies that the Manager, Radio-logical Controls is responsible for ensuring that the emergency equipment and supplies are inventoried and maintained and that personnel are assigned to perform these activitie The inspectors verified by reviewing records that inventories had becn conducted quarterly and after every drill and exercise and that supplies and equipment were on hand to support emer-gency usages for approximately 10 days to 2 week Additional supplies can be requested through INP0 suppor Since the licensee uses equipment that is common throughout the industry, no additional training would be required to use the additional equipmen Based on the above review, this portion of the licensee's program is acceptabl _ _ _ . - - .

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(12) Emergency News Center (ENC)

The inspector toured the ENC and the portion of the EOF set aside for press releases and determined that space (room A) is available for approximately 20 news media representatives for briefings and conferences. The ENC is located in the Western division headquarters, Aliquippa, Pennsylvania. It was deter-mined that this facility provides adequate work space for the press and for Duquesne Light Corporate Communications personne It contains a briefing area which can accommodate 300 persons and has adequate parking area for cars and trailers and a hel-icopter landing pad. The ENC will serve as the focal point for all corporate communications activities for the licensee. All other media communications made by the licensee including press conferences will be coordinated through the EN The corporate communications plan is incorporated as an Emergency Plan Implementing Procedure (EPP/IP 9.1) and provides procedures for activation and operation of the ENS. It was determined that the ENS contains provisions for telephone service, electrical service for added television loads, copying and telefaxing service, public address system capability, audio / visual equipment capability, and securit It was also determined that if the Western headquarters facility becomes uninhabitable due to radiological conditions, the activities of the ENS will be transferred to the Duquesne Light Corporation Corporate Headquarters in Pittsburgh, Pennsylvania. With the addition of Unit 2, no changes in implementation of the Corporate Communication Plan or media and news center facilities are expecte Based on the above, this portion of the licensee's program appears adequat (13) In-Plant Radiological Surveys The inspectors reviewed EPP/IP 2.1, Emergency Radiological Monitoring, to determine the adequacy of the methods and equipment which are to be used to perform emergency radiological surveys. EPP/IP 2.1, dated March 18, 1987, instructs personnel that except where specifically identified, radiological surveys and laboratory analysis will be performed in accordance with existing radcon and chemistry procedures. EPP/IP 2.1 provides guidance and instructions to TSC/ EOF personnel for the direction and coordination of emergency radiological survey _ _ - _ _ _ _

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. 16 EPP/IP 2.2, Onsite Monitoring For Airborne Release, provides instructions to monitoring team personnel for performing onsite radiological monitoring in the event of an airborne release of radioactive material. This procedure instructs monitoring team personnel to obtain appropriate monitoring equipment from the monitoring team kits and to perform operability checks on the equipment before leaving the control room or the contrclled area hallway. Instrument use/ check procedures are contained in the emergency kit Procedures and instructions are written from the viewpoint of the persons responsible for performing the radiological sur-veys. Adequate means are contained in the procedure for record-ing the date, time, and location of each survey, the name of the individual performing the survey, the instrumentation type and serial number used, whether open window of closed window read-ings were performed, the duration of a reading, the air sample flow rate and the background radiation levels at the time of air sample countin The Attachments to EPP/IP 2.1 and 2.2 are inadequately labeled and no provisions are given for uniquely labeling each collected sample for later identification and possible subsequent counting for verification of counting results. Means are specified for providing collected data, including original data sheets, to the Environmental Assessment Coordinator or the Dose Projection Coordinator. However, a central collection point has not been designated for all onsite samples collected by the survey team Communications during onsite survey team activities are speci-fied in procedures. Hi-band Hand-Talkie or 60 Watt Monitoring Team Units are obtained by each onsite monitoring team for com-munications with the TSC/ EOF. Alternative communications onsite consist of the plant Gai-Tronics network and plant telephone system. Also, Radiation protection guidance is provided in onsite monitoring procedures. Self reading dosimeters and emer-gency TLDs are available for onsite monitoring team personnel in the emergency monitoring team kits. Additionally instructions for personnel protective clothing and supplies, and respiratory protective equipment needs are contained in the onsite emergency radiological monitoring procedure Areas for improvement in EPP/IP 2.1 and 2.2 were discussed with the licensee. Based on the above, this portion of the licensee's program appears adequat __

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. 17 Emergency Plan Implementing Procedures (1) General Content and Format The inspector reviewed the licensee's Emergency Plan and Imple-menting Procedures for general content and format. It was determined that the plans and procedures presented for both Unit I and Unit 2 had been combined, however, they did not have in some cases the appropriate review and in all cases the required signatures. The inspectors met with the licensee's EP staff and discussed the content, format, and changes made to Unit 2 Emergency Plan Implementation Procedures (EPP/IP's). The format of the EPP/IP's included objectives, references, respon-sibilities, action levels or precautions, actual procedure, final conditions, and attachment EPP/IP's have been revised atd separated by use of a color-code scheme into generic pro-cedures (pink), Unit I specific procedures (white), and Unit 2 specific procedures (blue).

Prior to the EPIA, the licensee submitted copies of draft proce-dures to the NRC for review. At the time of the inspection, the inspectors determined that EPP/IP's could be grouped into three (3) categories as follows: Those receiving preliminary Onsite Safety Committee approval of non-substantive revisions either minor or color-code changes or those items in procedures marked

"later" where data from startup testing was unavailabl . EPP/IP's not submitted for review since the draft version of the procedure was incomplete (IP 1.2, " Communications and Dissemination of Information" and IP 3.1, " Evacuation") Postponement of OSC review pending further procedure mod-ification (I-1, Instruction 1, " Recognition and Classifi-cation of Emergency Conditions", IP 2.6.1, " Dose Projec-tions-Backup Methods").

(2) Implementing Instructions Formal approval of all site procedures, i.e. , final review and sign-off, is required by both the Plant Manager and General Manager, Nuclear Services. Although some draft EPP/IP's have received preliminary OSC approval, official review and autho-rization by station management had not occurred. The licensee representatives stated these procedures were not expected to be changed prior to approval by station management. Assuming no further changes occur, the inspectors determined that minor modifications were made when reformatting the approved, Unit 1 EPP/IP's into the new versions. In addition to the color cod-ing, changes made to Procedures IP 1.6, " EOF Activation,

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. 18 IP 2.6.2, " Dose Projection Radose" (deleted), IP 3.2, " Account-ability" (new assembly areas added) and IP "7.3," Communication /

Verification Checks" (telephone number changes), appeared accept-able. Other procedures were not reviewed by the inspectors since both levels of review (OSC and management) were incom-plete. These will be reviewed during a followup inspection (50-412/87-14-23) and are:

• I-1, " Recognition and Classification of Emergency Conditions"

• IP 1.2, " Communications and Dissemination of Information"

• IP 2.6, " Dose Projection" IP 2.6.1, " Dose Projections-Backup Methods" IP 2.7, " Liquid Release Estimate" Comments on specific procedures are as follows: Notifications The inspectors reviewed Sections 3 and 6 of the Emergency Plan and Procedures I-1, I-2, I-3, I-4 and IP 1.1 and determined that for each emergency classification, proce-dures specified the sequence of notifications to alert, mobilize and augment the onsite emergency organization, including immediate notifications made by the Emergency Director or his designee. The Emergency Plan and Imple-menting Procedures specified that the on-shift emergency organization will be notified at the Unusual Event (UE)

classification with full activation of the emergency organization at the Alert, Site Area or General Emergency classifications. Local services support (fire and ambul-ance) notifications were not specified by action level but would be requested at the discretion of the Emergency Directo The NRC, State and county governments woula be notified by use of a call list at all emergency classiff-cations (UE or above) and when a change in emergency clas-sification occurs. The general public would be notified by the county actuated siren system following information and recommendations provided by licensee emergency staf . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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The inspectors noted that IP 1.1 and Section 3 of the Emer-gency Plan contained provisions to provide one-hour notifi-cation to the NRC Operations Center and to maintain a con-tinuous line to satisfy the requirements of 10 CFR 50.7 Beepers and answering machines with pre-recorded messages and station page announcements used for notifying station personnel were included in procedures. However, the onsite alarm systems for Unit 2 were in the testing phase and not turned over from the contractor (See Section 3.0 (10)).

Planned messages were included on initial and follow up notification forms in IP 1.1 for notification of offsite agenries. Attachment 2, IP 1.1, is the " Emergency Call List" used for making notifications and contains listings of offsite agencies, telephone numbers, personnel contacts and local support services who are notified by means of commercial telephone, b. Evacuation (EPP/IP) 3.1 describes the criteria and instructions for several types of evacuations such as local evacuation unit assembly or site evacuation. This procedure specifies the primary assembly areas for a local evacuation or unit assembly and the remote assembly areas for site evacuatio The primary assembly areas for BV-1 are specified, but the primary assembly areas for BV-2 are not identified (50-412/87-14-24).

IP 3.1 specifies the area radiation levels or projected i dose that would trigger an evacuation of the affected are In addition to other non-radiological hazards such as toxic gases or fire, instructions for specific announcements to be made over the plant page system for each type of evac-uation are also describe The procedure directs Rad Con personnel to establish mon-itoring stations and to monitor vehicles and personnel, but does not reference specific health physics procedures for radiological monitoring during evacuations (50-412/87-14-25).

EPP/IP 3.2 details the instructions for accounting for personnel and visitors onsite when an evacuation is ordere This procedure is applicable for all levels of evacuation, and addresses maintaining accountability of duty and emergency personnel not evacuate The account-ability procedures depend primarily on the Security Badge / Key Card system (which was not operational at the time of this inspection, open item 50-412/87-14-10) to clear evacuated persons from the accountability data bas l

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. 20 The Key-Card system can be interrogated at any time to determine the location of persons still within the protec-ted area. A manual personnel accountability system is available as discussed below and is in use until the card system is operational. This information is reported to the Security Coordinator who reports the results of the accountability to the Emergency Director. Search and rescue measures are initiated if necessary. The OSC Coordinator and the TSC Coordinator are responsible for maintaining continuous accountability of emergency personne If the Security Badge / Key-Card System is inoperable, accountability will be accomplished through the manual method. Evacuating personnel will exit the site via the security post through which they entered, surrendering their security badge and dosimeter. Badges are placed in the badge rack in their normal location, and a scan of the badge rack will show missing badges and personnel. Infor-mation on missing individuals will be reported to Security

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by the same procedure used as the key-card metho F. Security During Emergencies The inspector interviewed Security Personnel and reviewed applicable EPP/IP and Security Plan Procedures regarding security during emer-gencies. It was determined that the integrated security / emergency plans and procedures for Unit I and 2 are still in draft form, have been reviewed by the Onsite Safety Committee but not approved, and had not been distributed (50-412/87-14-26). It was further deter-mined that security measures to be implemented during an emergency are specified in the Security plan and procedure. Personnel are aware of specific guard post instructions and there are specific instructions for the traffic control post. These and the other security procedures appeared to compliment the Emergency Pla G. Drills and Exercises The inspectors reviewed section 8.0 of the Emergency Plan, discussed program implementation with members of the EP staff, and reviewed the

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records of drills and exercises held since 1985. The inspectors determined that the last cycle of drills and exercises had been con-ducted within required time intervals established in the Emergency Plan and Implementing Procedure Where appropriate, they were coordinated with offsite agencies and groups and no significant deficiencies were identifie Based on the above, this portion of the licensee's emergency program is acceptabl . ,-

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. 21 4.0 Summary of Findings and Composite Listing of Open Items During the appraisal it was determined that several Emergency Preparedness Program areas were incomplete or required corrective action. These areas are listed as open items,are addressed within each section of this report and detailed below as to whether they need to be resolved prior to low power or full power license issuan Items indicated by (*) are required prior to full power license, all other items are required by low power licens *(50-412/87-14-01)

Develop and Conduct Training with Unit 2 Specific Emergency Preparedness Lesson Plan *(50-412/87-14-02)

Complete shift Technical Advisor Training / Qualificatio *(50-412/87-14-03)

Table Top Exercise as presented in Course 9251 should be given to Emergency Director, SRO Candidates and Emergency / Recovery Manager *(50-412/87-14-04)

Complete the training for shift personnel on the Emergency Plan Implementing Procedure (50-412/87-14-05)

Complete the construction of Unit 2 Control Room to include:

Install an operable dedicated line telephone system between Unit 2 Control Room, TSC and EOF, Install Connections for headset and direct phones for communications, Remove wall between shift technical supervisors' offices of Unit I and Unit 2 Control Room, and Remove wall and install separation and access doors between Unit I and Unit 2 Control Roo (50-412/87-14-06)

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Place updated and controlled copies of the EP and EPIP's in the i

Unit 2 Control Roo (50-412/87-14-07)

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Provide respiratory protection equipment and protective clothing for those persons of the Unit 2 Control Room who are members of the Fire Brigad *(50-412/87-14-08)

{ Place as-built drawings for Unit 2 in the ERF records room.

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. 22 (50-412/87-14-09)

Complete the installation and acceptability testing of the Safety Parameter Display System (SPDS).

(50-412/87-14-10)

Complete the functionality portion of the card reading / personnel accountability syste *(50-412/87-14-11)

Complete the marking and equipping of the assembly area locations within the exterior of the first floor of the engineering building (currently the S&W Engineering Building).

• (50-412/87-14-12)

Provide for access to appropriate keys to offsite assembly area *(50-412/87-14-13)

Acquire an acceptable offsite assembly area (facility) in lieu of j the Kennedy Corner facilit i

• (50-412/87-14-14)

Provide procedures and equipment for decontamination at remote assembly area *50-412/87-14-15)

Complete the construction of the Unit 2 storage are (50-412/87-14-16)

Obtain the list of equipment entitled " Radiological Control Department, EPP Punch List, Open Items" required to EP (50-412/87-14-17) {

Complete the installation, operations testing and calibration, and l turn-over of the Digital Radiation Monitoring System (DRMS). J (

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(50-412/87-14-18)

Complete the development and issuance of procedures for calibration of instruments and monitors as well as a schedule for the calibration of the DRM (50-412/87-14-19)

Complete the certification of the operating conditions for the detectors in the DRM /87-14-20 Complete the training of additional station personnel for the over view, inspection, and repair of the DRM _ _ _ _ - _ - _ _ _ _ _ _ _

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.. 23 (50-412/87-14-21)

Complete the installation of equipment in Unit 2 Control Room for required NRPM readout (50-412/87-14-22) j Complete the installation testing and turnover of standby and j evacuation alarm (

(50-412/87-14-23)

Complete and issue the Emergency Plan Implementing Procedures I-1, IP 1.2, IP 2.6, IP 2.6.1, and IP I (50-412/87-14-24)

Complete and specify the primary assembly areas for Unit ;

• (50-412-87-14-25)  !

Complete and issue procedures which reference specific health physics I procedures for radiological monitoring during evacuation *(50-412/87-14-26)

Complete and issue the integrated Security / Emergency Plan and Implementing Procedures for Unit 1 and Unit .0 Exit Interview At the conclusion of each day the inspectors reviewed the findings iden-tified in th'i report with the licensee's Emergency Preparedness staff in order to apprise the licensee of deficiencies or areas of concern as they were found. At the conclusion of the inspection on March 6, 1987 the inspectors met with the individuals identified in Section 1 and summarized each finding. At no time during this appraisal was written material pro-vided to the licensee by the inspector l I

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