IR 05000395/1990019

Insp Rept 50-395/90-19 on 900611-15.Noncited Violation Noted.Major Areas Inspected:Emergency Preparedness to Determine If Licensee Program Being Maintained in State of Operational Readiness for Responding to Emergencies

ML20055H604
Person / Time
Site:	Summer
Issue date:	07/03/1990
From:	Gooden A, Rankin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20055H603	List: IR 05000395/1990019 ML20055H602
References
50-395-90-19, IEIN-86-097, IEIN-86-97, IEIN-89-089, IEIN-89-89, IEIN-90-008, IEIN-90-034, IEIN-90-34, IEIN-90-8, NUDOCS 9007270070
Download: ML20055H604 (10)

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am#83 UNITE:) STATES .;

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n NUCLEAR RECULATCRY COMMIS$10N RE!!ON 11

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ATLANT A, GEORGI A 30323

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Report No.: 50-395/90-19

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Licensee: South Carolina Electric & Gas Company Columbia,;SC' 29218 j

, Docket No.:) 50-395 License No.: NPF-12 Facility Name: Sunner Inspection Conducted: June 11-15, 1990 Inspector: 8x M dgggX.A/

A. Gooden

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Approved by: OME%b4 W. H. Rankin, thWf ~ /

_ 7/8/R Da'teJSigned'

Emergency Preparedness Section Emergency Preparedness and Radiological

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Protection Branch Division of Radiation Safety and Safeguards

l SUMPARY J Scope

This routine, unannounced--inspection was conducted in the . area of emergency preparedness to determine if the licensee's program was being- maintained ~ 1n a- 1

. state of operational readiness for responding to- emergencies.: Programmatic areas reviewed included: training; independent audits; key program changes

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(equipment, facilities, personnel, etc.); administrative controls governing the distribution of changes to the Emergency Plan and Emergency Plan Procedures (EPPs);'andthecorrectiveactiontrackingsyste Results:~

Within the' areas examined, a non-cited violation (NCV) was identified: Failure t to conductEmonthly - testing of all NRC emergency communications equipment c .(Paragraph 3). With the exception of the aforementioned NCV,: the licensee's

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emergency: preparedness . program elements appeared to be~ adequately addressed,

, implemented,'and~ effectively managed? Noted program strengths were'as follows:'

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an effective - tracking system for ensuring followup corrective - actions on-

deficiencies;; equipment' inventories and operability checks were well documented

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, including' the ' corrective actions to resolve ' discrepancies; administrative d Jcontrols governing distribution of changes to the- Emergency Plan and EPPs; implementation _ of a training tracking system to ensure a trained and qualified

. emergency response _ organization'(ERO); and management support as evidenced by

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enhancementsLto the training program which included additional training in i

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event classification, notification, protective action recomendations- (PARS),

and various drill ,

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REPORT DETAILS

- Persons Contacted Licensee Employees D. Alt, Senior Health Physics Technician; i

• K.. Beale, Supervisor, Emergency Servi _ces 1 M. Counts, Emergency Services Coordinator

• R. Fowlkes , Associate Manaper, Shift Engineer

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• G. . Gibson, Manager, Nuclear-Protection '

• W. Higgins, Supervisor, Regulatory Compliance

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• A. Koon, Manager, Nuclear Licensing j

M. Miltner, Shift Superviso '

• D.-Moore, General-Manager, Steam Generation Project-

• J. Proper, Acting Manager, Quality Systems  :

• M. Quinton, General Manager, Engineering Services

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• A. Rice, Licensing Engineer  !

• J. Skolds, General Manager, Nuclear Plant Operations

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Other licensee employees contacted during this inspection included engineers, security force members, technicians, and' administrative personne * Attended exit intervie . EmergencyPlanandImplementingProcedures(82701)

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Pursuantto10CFR50.47(b)(16),10CFR50.54(q),andAppendixE~to10CF '

Part 50,- this area was reviewed to determine.whether changes were made' to'

the program since the last routine inspection (January- 1989), and to -l assess the impact of these changes on the overall state of emergency

. preparedness at the facility, i The inspector. reviewed the licensee's administrative program for making changes-to the Plan and EPPs. The inspector verified that changes to the  ;

Plan and procedures were reviewed and approved by management'in accordance with procedures governing the' development, review and : approval; As evidenced by' the transmittal dates, changes were being distributed to the '

onsite and offsite copy holders in a timely manner. In addition.-a review of transmittal sheets disclosed that changes were being distributed to'the -

NRC within 30' days of the approval date. Since the last inspection .two 3 Plan revisions were submitted for NRC review and approval. Changes ,

incorporated as - Rev'sion 25 were mailed ' to NRC on May 16,.1989, and Revision 26 was mailed on March 2,.1990. A member of the licensee's staff had been contacted telephonically regarding resolution ofoitems identified by NRC during the Plan reviews.' At the time;of the inspection, a licensee contact informed the inspector that changes incorporated as Revision 27 to

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the Summer Plan would resolve issues discussed in the.NRC Plan review letter Controlled copies of the Emergency' Telephone Directory, Emergency Plan,

=and EPPs were audited in the Control Room, Technical Support Center (TSC),

and the Operational Support. Center (OSC). The selected documents were .

found to be current revision .

The licensee provided documentation (dated April 16, 1990)'to show that in accordance with~ 10 CFR 50. Appendix E,Section IV.b, ' the offsite authorities had reviewed and concurred ~ with the licensee's emergency action levels (EALs). Further letters;of agreement with offsite support'

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agencies were updated on a biennial basis as stated in Section 8.3 of the Emergency Pla No problems were note No violations or deviations were identifie . Emergency Facilities, Equipment, Instrumentation, and Supplies (82701)

Pursuant to 10 CFR 50.47(b)(8) and (9),Section IV.E of Appendix = E to-10 CFR Part 50, and Section 7.0 of the licensee's Emergency Plan,1this ,

area was inspected to determine whether the licensee's emergency response facilities and other ' essential emergency equipment, instrumentation, and supplies were maintained in a- state of operational readines ;

Discussions were held with a licensee representatives concerning modifications to-fccilities. equipment, and; instrumentation since the las ,

inspection. The inspector' toured the Control Room, TSC, and,0SC and noted that facilities were in accordance with Section 7.0 of the Emergency Pla Regarding equipment and/or facility changes,0the inspector-was informed by a member of the licensee's staff,as- follows:

Modifications had been made to the Safety Parameter Display System (SPDS). The ' system completion date for validation, verification'and turnover to operations'is estimated to be August 1990. The inspector observed an operability check and comparison between the existing hardware system and the replacement _ system. . The replacement system ,

l appeared to have definite advantages over the existing-system ( resolution, human factors, etc.).

L Communications upgrades are planned.for_ Calendar. Years 1990-91.which

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will include ?the addition ofJ a . new microwave and a new pollin j capability. for . emergency notifications to offsite agencies. = An additional ~ upgrade in communications involves' the installation ofca

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dedicated ring down1 circuit at the State and local - Emergency Operations ' Centers (E0C). This system will- be used by State and local decision-makers for. discussing various actions to protect the public.during an emergenc I

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A proposal to relocate the Emergency Operations Facility (EOF) was l submitted- to NRC for review during May 1990. If approved, the EOF i would be relocated from the Nuclear Training Center to the Palmetto i Center (11th floor of the corporate headquarters) during calendar l year 199 l In assessing the operational status of the emergency facilities, th inspector verified- that protective equipment, . and supplies were ,

operational and inventoried on a periodic basis. Emergency kits)and er cabinets .in -the Control Room . TSC, OSC and a Plant Monitoring Team Kit were inventoried. - and randomly ' selected equipment l was checked for , ;

' operability. ~ The selected equipment operated properly, displayed current calibration stickers, and successfull battery and source checks were obtaine By review of applicable procedures and check-list documentation: .

- covering the period of June 1989 to May 1990, the inspector determined ,

- that emergency equipment (e.g. communications equipment, warning system'

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for high noise areas, and emergency kits) was being checked in accordance' ,

with the procedures governing such tests. Records reviewed indicated-that i all discrepancies or problems identified during inventories and:

communications checks were corrected in a timely manne The inspecto did; however, identify one : inconsistency involving the periodic:

communications test CFR150 Appendix E, -Section IV.E.9.d requires monthly testing of the NRC Emergency Comunications Systems. Appendix E and Information . Notice 86-97 (Emergency- Communications Systems) requir ;

monthly testing (of the Emergency Notification System (ENS)' and the.HealthHP Physics Network a Facility (E0F). - According to test documentation,'the ENS located in the Control Room and TSC was done monthly in accordance with EPP-02 However, the ENS circuit in-the-EOF, and all HPN circuits were'done on:a

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quarterly basi The licensee, when informed 'off the' requirements in 10 CFR 50 Appendix E and the guidance,in Information Noticei(IN) 86-97 for implementing Appendix E requirements, took immediate action to revise the procedural frequency- governing such tests to require that monthly testing be initiated at all locations. The procedure was reviewed, approved, and implemented prior to the formal exit and/or inspector's site departur !

-In light of the aforementioned actions, this apparent violation fr failure to test all ENS ~ and HPN phones was discussed with Regional Management; and since all requirements as specified 'in 10 CFR Part-2

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Appendix C,Section V of the NRC' Enforcement Policy were satisfied, the licensee was informed that this finding was = considered a non-cited-violation (NCV).

NCV 50-395/90-19-01: Failure to test all ENS and HPN phones on a monthly-basi .During the Control Room tours, the inspector noted that- the . monitoring instrumentation--(e.g. main stack monitor, reactor building vent monitor, meteorological parameters, etc.) for post accident assessment and dose projection was operational.

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The licensee's management control program for the Early Warning Siren-

' System (EWSS) was reviewe Documentat' ion which sumarized the Calendar-Year 1989 testing of the EWSS disclosed the following: (1) average annual operability for 1989 was 91.1 percent;.(2)-full system activation test was performed on June 6, 1989~, during the annual exercise; and (3) action taken >

to resolve test discrepancies were well. documented. The records showed-that tests were being conducted in accordance with EPP-022 and NUREG-065 On NCV'was identifie ,.

' Organization and K :Agement Control (82601)'

Pursuant to 10 ~CFR 50.47(b)(1) and (IG). Section, IV. A of Appendix E to . >

10 CFR Part 50, and Section B of-the licensee's Emergency Plan, this area was inspected"to determine the effects of any changes in the-licensee's emergency organization and/or management control systems on the emergency >

preparedness program, and to verify that any such changes were properly factored into the Emergency Plan and EPP The inspector's discussion with a member of the licensee's staff disclose several administrative - changes involving the plant staff since the -

January 1989 inspectio For example, previously, the Mana

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Protection Services -(to whom' emergency preparedness reports)ger, reported to Nuclear the General hnager, Station -Support; and the General Manager, Station r Support reported to the General Manager, Nuclear: Plant ~ Operation Effective June 11, 1990,'the Manager,-Nuclear Protection Services reports directly to the General Manager, Nuclear Plant Operations. .Thisichange

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would appear to~ provide more -direct: attention from ~ station managemen There were other reassignments or ' promotions within , the normal organization which resulted in individuals being assigned different roles in the emergency organization. When training records were compared to position assignment, no problems were noted. Regarding the .offsite support agencies, no changes had occurred since the last inspectio Agreement letters were recently updated with the offsite support agencies-listed in the Summer Emergency Pla No violations or deviations were identifie . -Training :(82701)

L Pursuant to 10 CFR 50.47(b)(2) and (15).- Section IV.F of Appendix' E' to-10 CFR Part 50, and Section 8.0 of the Emergency Plan, this area 'was- ,

inspected to determine whether the licensee's key emergency response

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personnel-were properly trained -and understood- their emergency i responsibilitie l The inspector reviewed Section 8.0- of the Emergency Plan and ~ the

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Implementing Procedure (EPP-018) for a description of the training program ,

and training procedures. In addition, selected lesson plans and/or l instructor guides were reviewed. Since the last inspection, the licensee had implemented a manual, plant-wide tracking system for trainin .. . .

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Discussions with. a cognizant member of the licensee's staff regarding

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emergency preparedness training, disclosed the following-actions had been implemented since the last inspection to' ensure -all- Emergency Response Organization (ERO) personnel training was current and up-to-date: (1) the Emergency Services Staff manually tracks training by maintaining a log i book which includes an emergency response training matrix and a position {

matrix of qualified or unqualified responders;. (2)- training for response personnel is reviewed status as current.or on aand expired; monthly (3 ERO) basis for- determining personnel personnel' are notified 90,-60, and 30 days in advance of the training due dat '

.i The inspector conducted a walkthrough evaluation with a Control-Room Shift Supervisor in the areas of emergency; detection, classification, PARS, and'

notifications. The interviewee was asked to talk through his response as i the Interim Emergency Director (IED) in response to the~ simulated accident condition In response to postulated accidents, the individud was prompt and correct in the event classificatio The interviewee demonstrated excellent familiarity with the emergency classification procedures (EPP-001) and various other EPPs which implement the' Station's Emergency Pla No problems were noted in the areas of emergency action level (EAL) recognition, classification, and PAR Training records were reviewed for selected members of the emergency organization. Training records were chosen based on the. April 1990 Emergency Planning Telephone Directory. Thirty names . were randomly  ;

selected from various emergency positions on the emergency . response  !

position matri When personnel training -records were compared with position assignments, no problems-were noted.- Training was reviewed for  ;

the offsite medical and fire support. agencies. No problems were note l The inspector observed classroom training for, local law enforcement l agencies (LLEA) on June 12, 1990. The training material presented during

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the LLEA training appeared to be adequate and specific for the!LLEA role ,

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during an emergency. .The inspector reviewed drill documentation for i verification that the required drills were conducted during the Calendar  !

Year 1989 (e.g. semi-annual health physics). No problems were.noted. In addition to the required drills, the inspector was provided documentation to show that an activation drill was conducted during November 1989, and ,

included activation of' the TSC, OSC, and Backup Emergency Operations-Facility (BE0F). Regarding augmentation drills, a licensee contact i indicated that an unannounced augmentation drill requiring actual travel to the site during off-hours will be conducted during the third quarter o Calendar Year 1990. This item is being tracked by. the licensee's Regulatory Tracking System as commitment'No. LIC-DRL 90002- i No violations or deviations were identifie . Independent Review / Audits (82701)  !

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Pursuant to 10 CFR 50.47(b)(14) and 10 CFR 50.54(t), this area ' was'

inspected to determine whether the licensee had performed an independent-review or . audit of the emergency preparedness program, and whether the . '

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licensee had a corrective action system for. deficiencies and weaknesses i identified during exercises and drill !

Acco ding to documentation, an independent audit was conducted by the j Quality Assurance Program during the period January 17-26,1990.(documented i in Audit Repcii No. II-01-90-B). This audit included an evaluation of th .I '

adequacy of the- licensee's interface with State / local authorities. . No'

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problems, or findings, were noted as a result of this audit. _ The l referenced audit- satisfied the annual' frequency . requirement for such audit The licensee's program for follow-up action on audit, drill, and exercise 1 findings was reviewed. The licensee maintains a tracking system known as the Regulatory Tracking System (RTS). The inspector _-reviewed a sample of items from the Calendar Year 1989 exercise /dr111s, and noted that items '

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were assigned to a< specific organization or individual with a tentative-completion dat No violations or deviations were identified. - EmergencyPlanImplementation:(92700) {

t The inspector reviewed completed' procedure packages which resulted -from emergency declarations- that had f occurred since - January 198 Both declarations were Lat the Notification of Unusual Event-(NOVE) level. The inspector's review of documentation disclosed the-following:

On July _11, 1988, a.NOUE was declared due to a total loss of offs te powe According. to Licensee Event c Report No.89-012, a turbine / reactor trip occurred due to the- loss of . AC- power to the: !

generator stator cooling' water. The event declaration and ensuing offsite notifications were timely and in.accordance with EPP-001 and EPP-00 No problems were noted with event : declaration, notification, or-event terminatio On September 22, 1989, a NOVE was declared in response to Hurricane l Hug According to documentat'on, sustained . wind speeds were-

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recorded as - 55 mph. According to the. Emergency Director's logbook

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entries, following event declaration, offsite notifications toi

. State / local agencies were completed in eight minutes. and NRC in ,

thirty-five minute Notification times were verified by review of Emergency Notification Message forms (EPP-002 attachments). -A review of the' documentation disclosed the .following: 1) All notifications ,

were in accordance with EPP-002; and 2) actions taken by- plant

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personnel in.- response to the hurricane :were in accordance with

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,' EPP-001 and' EPP-015. . Although' no problems were noted in the areas .of

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event classification, notification, and communication; the inspector noted the absence of an EAL addressing hurricane wind speeds for the NOUE categor When questioned regarding- the trigger point, the inspector was informed that this item had been identified during' a critique of' the - response. As a result, a Plan change had been

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' initiated (Revision 27) which incorporated 55 mph as the specified windspeed for'the NOVE category. During the inspection, Revision 27 ,

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was awaiting approval from Plant Managemen No-vio1Ations or deviations were identifie > NRC Information Notice (92703) l The inspector discussed with a licensee representative their_ response. to the following Information Notices (IN):-

IN - No. 89-89 " Event : Notification Work Sheets." The inspector -

reviewed documentation which disclosed the licensee had reviewed the referenced IN and determined. that the additional information in the IN would be applicable to.-their site and procedures. The current procedure (EPP-002) addressing notification and communications was revised to include the additional information contained on NRC Form ,

361 attached to the I '

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IN No. 90-08 "Kr-85 Hazards From Decayed- Fuel." According-to a licensee contact, the aforementioned Notice was assigned for review

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to determine if changes are necessary to the existing health physics

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procedures in view of the IN.

I IN No. 90-34 " Response to False Siren Activations." According to the documentation and a discussion:with a member of the licensee's staff, '

the IN was assigned for review and evaluation. .However, at the time of the inspection, the review was incomplete.

l Action on Previous Inspection Findings-(92701)

(Closed) Violation 50-395/89-02-05: Failure to provide seven members of the offsite Radiological Monitoring Team with training in accordance with

EPP-018.

E The inspector reviewed the licensee's response to the violation '(dated

April 4,1989),- and reviewed offsite monitoring team training conducted

, during February and March 1989.. The inspector noted that the licensee had ,

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provided required training to all monitoring team personnel during Calendar Year 1989, and a -random sampling of individuals currently "

assigned. disclosed that training was current.and up-to-date. Further, as corrective actions to ensure personnel assigned to the emergency organization maintained current training and certification, the following actions were taken: (1) quarterly audits are performed in specialized training areas; (2) prior to issuance, The Emergency Planning Telephoney Directory is reviewed assigned personnel areby the Emergency qualified; and (3 the) implementation Planning ' Staffof'toa ensure manual that

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-(Closed) Inspector - Follow-up Item 50-395/89-10-01:: _ Ensure required-coordination between the TSC and EOF regarding l Protective Action i Recommendations-(PARS)issuanc( of-same' to the' Stat .

t The inspector reviewed 'trainin,1 attendance" record ' documentation (File !

EPT-89-0099) dated November 2, .'989, entitled . PAR ihethodolog Primary e and' alternates for the positions Emergency Director. (TSC) and Offsite Emergency' Coordinator .(EOF) were in - attendanc i Trainingl ncluded rational for PARS; risks associated with PARS;.' PAR choices; line of-approval for PARS; and table-top. exercises which required PARS in response-to simulated accident conditions.' *

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(0 pen)ExerciseWeakness_50-395/89-10-02: Excessive delay in provision'of offsite dose assessment / projection data to the ' Offsite Emergency Coordinator following.the initial = release of radioactive materials to the environmen:.

Actions were taken procedurally in accordance NMh the licensee's response to the exercise weakness (dated August 11 ,1988). 'However, to ascertain

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the effectiveness of' the corrective action for closuret of this item, actual demonstration of assessment during a simulated accident is necessar .

1 Exit Interview The inspection scope and results were summarized ~on June 15, 1990, with-those persons indicated in Paragraph 1. The inspector described the: areas inspected and discussed -in detail the inspection' results ? listed belo The licensee did not identify ~ as proprietary any of -the information provided to the inspector during the inspection tThere were no dissenting comments from the licensee.

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Item Number Description / Reference 50-395/90-19-01 NCV Failure to test all-ENS '

and HPN phones on a monthly basis (Paragraph 3).

L Licensee management was informed that three previous open items (listed in-Paragraph 9) were reviewed and two items were considered closed, and one remains open pending exercise observation.-

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