IR 05000206/1981038
| ML20052E667 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/19/1982 |
| From: | Book H, Cillins M, Fish R, Scown K, Wenslawski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20052E632 | List: |
| References | |
| 50-206-81-38, 50-361-81-31, 50-361-81-8, 50-362-81-08, 50-362-81-8, NUDOCS 8205110320 | |
| Download: ML20052E667 (49) | |
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U..S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION V
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Report Nos. 50-206/81-38, 50-361/81-31, 50-362/81-08 (RS)
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Docket Nos. 50-206, 50-361, 50-362 License Nos. OPR-13, CPPR-97, CPPR-98 Licensee: Southern l California Edison Company 2244 Walnut Grove Avenue Rosemead, California 91770 Facility Name: San Onofre Nuclear Generating Station Units 1, 2 and 3 Inspection at: San Onofre, California Inspection conducted: October 26 - November 6, 1981 Inspectors :
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_ 3//fh R. F. Fish, Emergency Preparedness D' ate Signed Analyst,.NRC Team Leader b:. (bn sdt}a M. Cillis, Radiation Specialist, NRC Date Signed
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K. Scown, Emergehcy Preparedness (Yate Signed Coordinator, NRC Other Team Members:
J. R. Sears, Emergency Planner, NRC E. H. Markee, Staff Meteorologist, NRC A. E. Desrosiers, Senior Research Scientist Battelle Pacific Northwest Laboratories G. J. Laughlin, Research Scientist Battelle Pacific Nort est Laborato ies l
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V Approved by:
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F. A. Wenslawski, Chief U Date Signed Reacto Radiat'on Protection Section A
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H. E. Book, Chief Date Signed t
Radiological Safety Branch
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1 Appraisal Summary-2-Inspection on October _26 - November 6, 1981 (Report Nos. 50-206/81-38, 50-361/81-31, 50-362/81-08)
Areas Inspected: Special, announced appraisal of the emergency preparedness program, including administration of emergency preparedness, emergency organization, training and retraining, facilities and equipment, emergency plan implementing procedures, coordination with offsite groups, and drills and exercises.
The' inspection involved approximately 550 inspector hours onsite by seven (7) NRC inspectors.
_Results: One significant deficiency in the area of facilities and equipment (Section 4.2.5) was identified. This item concerned the ability of the Unit 1 interim, extended range stack effluent monitor for noble gases to provide required information for emergency plan implementation. A letter confirming the licensee's proposed corrective actions for this deficiency was issued by NRC Region V on November 16, 1981.
No deficiencies were identified with respect to the other six (6) areas of the appraisa '
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TABLE OF CONTENTS Page No.
1.0 Administration of Emergency Preparedness
2.0 Emergency Organization
2.1 Onsite Emergency Organization (0E0)
4 2.2 Augmentation Organization
2.3 Conclusions: Emergency Organization
3.0 Emergency Plan Training and Retraining 3.1 Program
5 3.1.1 Site Training
3.1.2 Corporate Training
3.2 Program Implementation
3.3 Conclusions: Emergency Plan Training and Retraining
4.0 Emergency Facilities and Equipment
4.1 Emergency Facilities 4.1.1 Assessment Facilities
4.1.1.1 Control Room
11 4.1.1.2 Technical Support Center
4.1.1.3 Operations Support Center
4.1.1.4 Emergency Operations Facility
4.1.1.5 Post-Accident Coolant Sampling and Analysis
4.1.1.6 Post-Accident Containment Air Sampling and Analysis 4.1.1.7 Post-Accident Effluent Sampling and Analysis
17 4.1.1.8 Offsite Laboratory Support
4.1.2 Protective Facilities
4.1.2.1 Assembly / Reassembly Areas
4.1.2.2 Medical Treatment Facilities
4.1.2.3 Decontamination Facilities
4.1.3 Other Facilities
4.1.3.1 News Center
4.1.3.2 Expanded Support Facilities 4.1.4 Conclusions: Emergency Facilities 4.2 Emergency Equipment
4.2.1 Assessment
4.2.1.1 Emergency Kits and Emergency Survey Instrumentation
4.2.1.2 Area and Process Radiation Monitors
4.2.1.3 Non-Radiation Process Monitors 4.2.1.4 Meteorological Instrumentation 4.2.2 Protective Equipment
4.2.2.1 Respiratory Protection
4.2.2.2 Protective Clothing
4.2.3 Emergency Comunications Equipment
4.2.4 Other Equipment
4.2.4.1 Damage Control / Corrective Action and Maintenance Equipment and Supplies
4.2.4.2 Reserve Emergency Supplies and Equipment
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4.2.4.3 Transportation
4.2.5 Conclusions: Emergency Equipment
5.0 Emergency Plan Implementing Procedures
5.1 General Content and Format
5.2 EIP Review
5.3 Evacuation and Accountability
5.4 Assessment Actions
5.5 Conclusions: Emergency Plan Implementing Procedures
6.0 Coordination with Offsite Groups
6.1 Offsite Agencies
6. 2 General Public
6.3 News Media
6.4 Conclusions: Coordination with Offsite Groups
7.0 Drills and Exercises
41 7.1 Program 7.2 Walk-Through Observation
7.3 Conclusions: Drills and Exercises
8.0 Exit Interview
Appendix A - Individuals Contacted Appendix B - Emergency Plan Implementing Procedures Enclosure 1 Enclosure 2
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O DETAILS 1.0 Admini_stration of Emergency Preparedness The Vice President, Nuclear Engineering and Operations has overall responsibility for nuclear related activities at Southern California Edison Company (SCE). Within the Nuclear Engineering and Operations Department (NE0D) is the Health Physics and Emergency Planning Group (HPEPG). According to the jurisdiction statement being used, this Group has been assigned the responsibilities for (1) establishing emergency plans for San Onofre pursuant to the requirements of federal, state and industry guides and procedures, (2) coordinating emergency planning between the various sections within NE0D and state and federal agencies, (3) participating in the review and upgrading of emergency plans and (4) assisting in the planning and participating in periodic emergency drills. According to upper SCE management, the Chairman of the Board has stated that he wants emergency planning for San Onofre to be the best in the country.
The Vice President, Nuclear Engineering and Operations, said he also wanted excellent emergency planning for the San Onofre site and had made this fact known to his staff.
Both Emergency Plans (EP), one for Unit 1 and one for Units 2/3, identify the position of Emergency Planning Administrator (EPA). According to the plans, the primary duties (responsibilities) include maintenance of the EP's and the Emergency Implementing Procedures (EIP), and coordination of emergency training with offsite organizations. The EPA is also responsible for coordinating the EP with federal, state, county and local emergency plans as well as the San Onofre Nuclear Generating Station (SONGS) security and fire protection plans.
Additional EPA responsibilities include coordinating emergency planning and related exercises, coordinating the review and updating of the EP's and EIP's, ensuring that the ~EP and EIP's are consistent with one another, ensuring j
that the EIP's are coordinated and interface properly with other SCE
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procedures (including Administrative, Security, Health Physics, Training
and Emergency Operating), and assisting the Training Manager in coordinating emergency planning related specialty training.
The Supervisor of the HPEPG is also the EPA.
The incumbent has been
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responsible for emergency planning at SCE for several years. According
to upper level management, they were keenly aware of the assigned responsibilitied when this position was filled. Criteria for selecting a person to fill this position have been described in the job description and the jurisdiction (descriptive) statement for the HPEPG.
The EP (Section 8.1.4) states that the EPA will attend appropriate emergency preparedness seminars and training courses in order to remain abreast of new methods, techniques and regulatory requirements.
Upper level management confirmed this conunitment to keep the EPA current on the subject of emergency planning with the only constraint being availability of time to atten <
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-2-The appraisal disclosed that the SONGS organization includes an Emergency Planning Coordinator-(EPC) position.
The EPC position was established a few months ago and, at the time of the appraisal, the incumbent was reporting to the Station Manager. The EPC is responsible for implementing the EP at the site. This responsibility does include generating and modifying EIP's; however, the EPA has the responsibility for assuring that appropriate procedures are generated and supplying copies of all such procedures to the NRC as required by the regulations.
It should be noted that the EIP's, and changes thereto, must be approved by the Onsite Review Committee and the Station Manager.
According to SCE personnel the EPC position will be changed in the near future to a supervisory position and the individual will report to the Deputy Station Manager.
A committee of three (3) persons has been established to coordinate the emergency planning program at SCE. This committee reports to the Supervisor of the HPEPG. The three members consist of a representative of the HPEPG, the EPC and a representative of the Training organization.
The primary function of the committee is coordination.
Changes in emergency planning recommended by the site are evaluated by the committee prior to any initiating action. The committee also assures that the training in emergency preparedness is consistent with the EP and EIP's.
The EP states that there will be an independent review of the emergency preparedness program on an annual frequency. The general topics to be included in the review have been identified.
The EPA said he was aware of this requirement and he was probably the individual responsible for assuring the annual reviews are performed. To date there has been no decision regarding how the review will be routinely accomplished (e.g. outside contractor, SCE Quality Assurance organization or other SCE personnel).
The appraisal disclosed that SCE had issued a contract to Advanced Science and Technology Associates, Inc., (ASTA) for an appraisal of emergency preparedness at SONGS, including the emergency facilities and equipment at Unit 2.
ASTA used the NRC appraisal program, provided SCE by a June 16, 1981 letter from the NRC's Region V Director, as a basis for their reviews. The major portion of this review took place during the period June 17 - July 10, 1981.
The review of the Unit 2 facilities and equipment occurred during the period July 20 -
August 17, 1981.
ASTA documented the results of their reviews, including recommended corrective actions, in two reports submitteu to SCE.
SONGS established a master trackir.g system, using a computer, for the purpose of making sure that problems and deficiencies in the area of emergency preparedness would be corrected and not be overlooked.
The initial listings in this tracking system came from the ASTA reviews.
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-3-Prior to the appraisal SCE personnel had informed the NRC Team Leader that the EP needed some changes to reflect the current emergency preparedness at SCE. The EIP's, which were prepared or revised since the EP's were issued, reflected the changes to be made in the EP (see Section 5.2 of this report). Also, as noted above, an EPC position has been established; however, this position has not been described in the EP. According to the EPA a revision to the EP is presently in the review process and will be submitted in the near future. The licensee / applicant hopes to incorporate changes resulting from the NRC appraisal into the revision.
Based on the above findings, this portion of the licensee's (applicant)
program appears to be acceptable; however, the EP should be revised to reflect the current emergency preparedness program at SCE.
2.0 Emergency Organization 2.1 Onsite Emergency Organization EIP 17 states that, upon declaration of an emergency condition (Unusual Event, Alert, Site Emergency or General Emergency), the Watch Engineer shall assume the position of Emergency Coordinator (EC) and maintain that position until properly relieved or close out of the emergency condition.
For immediate response, the crew on watch comprise the emergency organization.
Table 5-2 of the EP lists emergency assignments both during normal work hours and during back shifts or weekends.
The assignments include all those listed in Table B-1 of NUREG-0654, Rev. 1.
The emergency assignments correspond to the normal duties of the workers on shift with one addition, a security person will be called to the control room by the Watch Engineer to assume the position of Communicator to offsite agencies.
EIP 17, Activation and Operation of Emergency Centers and Organizations, lists the responsibilities of the Watch Engineer. Responsibilities of the Watch Engineer that may not Le delegated include classification of the emergency event and the making of protective action recormiendations to offsite agencies.
Walk-through interviews were held with 11 of the total of 13 Watch Engineers for both Unit 1 and 2 reactors. The walk-throughs confirmed that the Watch Engineers operate in conformance with the EIP's and understand the meaning of the procedures sufficiently well to discuss them freely. The procedures and responsibilities demonstrated during the walk-throughs included emergency detection and classification using EALs (emergency action levels), initial dose assessment, notifications to offsite agencies and recommendations for protective actions. The EIP's instruct the Watch Engineers to perform these functions quickly, even before notifying upper management, and the walk-throughs confirmed that this is how the Watch Engineers would operate.
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t-4-2.2 Augmentation of Onsite Emergency Organization EIP 18, Notification of Additional Emergency Support Personnel, and EIP 17 provide for augmentation of the onsite organization in an emergency. Tables A & B of EIP 18 list required 30 minute and 60 minute response time personnel that conform to NUREG-0654, Table B-1.
Each key individual has at least one alternate. The key individuals have a beeper, and the instructions state that if the primary person leaves the Southern California Edison area he must pass the beeper to the next alternate.
The Corporate Radiological Emergency Response Plan describes the duties and responsibilities of corporate management personnel.
The Vice President of Nuclear Engineering and Operations, or his alternates, will be dispatched to the site from SCE headquarters in Rosemead.
If weather is favorable, transportation would be via aircraft. Corporate personnel would man the Primary Emergency Operations Center (PEOC) which is located in the Administration Building on_ site. The operation of the PE0C, including being the source of information for news media, was demonstrated during the.May 1981 emergency planning exercise and was judged to be satisfactory by the NRC observers (see IE Report No. 50-206/81-19).
Dose assessment is performed 'during an emergency both in the Technical
' Support Center and the offsite Emergency Operations Facility (E0F)
in San Clemente. Technical personnel from SCE report to the E0F for liason with offsite authorities. This was also demonstrated during the May 1981 exercise.
The EP and the Safety Evaluation Report NUREG-0712, dated February, 1981, describe arrangements for medical services, including transportation
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for contaminated injured individuals. This was also demonstrated during the May 1981 exercise.
The EP states that the Camp Pendleton Marine Corps Base Fire Brigade has agreed to provide support services if requested.
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2.3 Conclusion Based on the above findings, this portion of the licensee's/ applicant's program appears to be acceptable.
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-5-3.0 Emergency Plan Training and Retraining 3.1 Program The licensee's EP training and retraining is not exactly as described in Section 8.0 of the EP.
It is essentially separated into two parts, Corporate and Site Training. The overall responsibility for the EP and training for Corporate and the Site is under the direction of the Vice President, Nuclear Engineering and Operations.
3.1.1 Site Training The licensee's site training and retraining program is outlined in EIP-74, " Emergency Plan Training" and SONGS Training Memorandum 10-81, Revision 1, dated September 22, 1981. At the time of the appraisal EIP-74 had not been formally
issued. The responsibility for the implementation of the training program is assigned to the Manager, Nuclear Training. The Training Services Administrator is responsible for scheduling and maintaining records of training conducted. The Technical Training Administrator is responsible for coordinating lesson plans and conducting the training.
The scope and content of the training and retraining appears to be consistent with planning standard
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Part II of NUREG 0654. The material included in the training is divided into twelve (12) modules. Ten (10) training groups of personnel have been identified and the training lesson plans and examinatioGs for each group have been developed and implemented. The content of the lesson plans to be given to the various groups appeared to be appropriate; however, the time allocated for the presentations (especially to essential emergency response personnel) may be insufficient.
This was reflected in the walk-throughs conducted by the various inspectors where a need for improvement in some areas (e.g.
emergency plan overview and dose assessments involving source term determination) was indicated. The lesson plan objectives appeared to be well defined. The training program does provide for hands-on training, demonstrations and practices. Additional, hands on training is provided through the scheduling of drills which exceeds the frequencies. currently specified in the EIP's.
The EPA has plans for conducting ten drills during the next few month i
-6-The Red Cross Standard First Aid Multimedia course is used to train individuals assigned to first aid teams.
Instructors are the corporate physician and two certified instructors from the Nuclear Training Group who have attended the Red Cross First Aid Multimedia.
One of these two instructors is also certified in cardiopulmonary resuscitation (CPR).
Essential emergency response personnel are trained in Red Cross First Aid Multimedia. This training also includes instructions in CPR which appears to exceed that discussed in the Red Cross First Aid Multimedia training. The CPR training provided to these individuals does not certify them or adequately train them to become competent in admin utering CPR. Personnel receiving this CPR training indicated they would not hesitate administering CPR if the occasion arose. The inspectors directed the licensee representatives' attention to the State of California Law which prohibits individuals from administering CPR unless they are certified. The CPR portion of the training in the Red Cross First Aid Multimedia course is only a few hours in length; whereas, the certified CPR course is 9 to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> in length.
The training of personnel assigned to fire brigade functions appeared quite thorough.
It provides for frequent drills and hands-on training. The appraisal disclosed that there was some misunderstanding regarding whether the General Office or SONGS personnel were responsible for providing the training to be given to the Camp Pendleton Marine Fire Brigade personnel. This same misunderstanding applied to the offsite ambulance personnel.
The licensee's criteria and standards for the selection and qualifications of instructors in the training program have been established. Current instructors average over 15 years of nuclear industry experience. This average includes the acquisition of a recent graduate with a PhD in Chemistry and an SR0 license from UC Irvine. The current training staff consists.of six instructors, not including the Technical Training Administrator who also conducts training classes. A discussion with the Technical Training Administrator revealed that an additional instructor would be added to the staff shortly.
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Consideration has been given to training members of the emergency organization in changes to procedures or equipment which could occur between the scheduled training sessions.
There are provisions for irmediate retraining if significant changes occu $
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-7-The training staff at times has been supplemented by members of the site and corporate office.
During the appraisal a member of the HPEPG provided training at the site. This training concerned a more simplified method for performing dose assessments than is currently discussed in EIP-23.
3.1.2 Corporate Training According to the training documents identified in the first paragraph of Section 3.1.1, the training of the General Office (GO)
support personnel was to be performed by persons in that office.
The supervisor, HPEPG, assumed the resoonsibility for training the G0 support personnel.
One of the engineers in the HPEPG, who had been involved in the current EP development, provided a significant-portion of this training.
Site personnel provided those portions'of the training where they had the expertise.
Satisfactory completion of the training required passing a written examination with a grade of 70 percent or higher. The licensee also considers participation in the drills and exercises _ to be a part of the training program for the GO support personnel.
The formal training program-consists of seven (7) hours of instruction and discussion plus the written examination. This training covers the following topics:
historical perspective of emergency planning; regulatory requirements and guidance; overview of the SONGS plan, procedures and facilities; offsite protective actions; emergency (GO) support plan, organization and procedures.
Two sessions of this training have been given, October 1 and 8, 1981. According to the HPEPG engineer responsible for this training program, a few of the G0 support personnel have not yet received the training and a few must still take the examination.
Completion of this training is expected in the near future. The HPEPG is maintaining the records of emergency planning training received by the GO support personnel.
3.2 Program Implementation A review of training attendance records, examinations and training schedules was conducted during the appraisal. The verification of training records at the corporate office revealed no adverse findings.
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.The verification of training records at the site was diff cult to accomplish because several different filing techniques were used for storing the same data. The technique used appeared to be dependent upon the person perfonning the filing.
It appears that a single filing system needs to be established for the maintenance of these records. The traceability of records requires a paper chase that is both tedious and very time consuming.
It was noted that there is a backlog of records of all types to be filed.
Some of the records could not readily be located as a result of the backlog and filing techniques.
As an example, there was evidence that a Wells Fargo employee had been trained;.however, his examination could not be located.
It is not known whether this examination had been misfiled or is still in the' backlog of records to be filed. The maintenance of records appeared to be in a state of disarray.
- There was evidence that the training of essential emergency response personnel had been accomplished in accordance with EIP-74..The complete training of' essential emergency response personnel appears ~to be approximately 80% complete. The
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Technical Training Administrator is maintaining the status of this training. The training provided appeared to be appropriate.
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The inspectors attended a training session for red card holders (unescorted access) to evaluate the training provided to all workers concerning plant and site evacuation.
The EPA also attended this training session.
The session consisted of a video tape presentation followed by a supplemental oral presentation by the instructor providing an EP overview and instructions for local, plant and site evacuations. At the end of the presentations an examination is administered. Handout I.
material is also provided as shown in Enclosure 2.
A video tape summary presentation is shown just prior to administering i
the exam. The presentation covers the examination almost word for word; making it difficult for a student to fail. The questions on the examination are all multiple choice questions.
Some of the' choices are' rather obvious.
The oral presentation was generally very good. The exit routes and areas to avoid in the event of a worst case Desian Basis Accident at Unit 1 were discussed.
Expected radiation levels streaming from the Unit 1 site during such an accident was also presented. The presentation for evacuating the Unit 2 site was not discussed in as much detail.
No mention was made of areas to avoid because of potentially high radiation levels during a severe accident.
Attendees were reminded that a copy of the evacuation procedure was attached to their p otected area ID badges and they should read i i
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-9-As the result of comments made by the inspectors and SCE observers of the training session, the licensee issued the Radiological Emergency Instructions shown in Enclosure 1.
These instructions were distributed to and discussed with the Wells Fargo personnel prior to the completion of the appraisal.
Each Wells Fargo employee was required to carry a copy of this document at all times.
In addition, action was taken to distribute the instructions to all personnel entering the protected area and to obtain their signatures indicating they had read and understood them. The licensee also initiated action requiring the issuance of these instructions to all site visitors. Visitors' signatures will be used to confirm that
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they had read the understood the instructions.
In connection with this change, the licensee also modified the handout material (enclosure 2) to make the two documents consistent with one another.
The licensee stated that some training of state, local, medical and news media had been conducted by the corporate office.
The inspection disclosed no evidence that offsite fire and ambulance response personnel had been provided with any training except for some Fire Chiefs from Camp Pendleton Marine Base.
A recent memo from the Supervisor, HPEPG, to the San Onofre Station Manager dated October 27, 1981 requested that the site
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training organization provide red badge training to 70 members of the Camp Pendleton US Marine Corps fire brigade.
3.3 Conclusions: Emergency Plan Trair.ing and Retraining Based on the above findings, this portion of the licensee's/
applicant's program does not appear to have, any significant deficiencies.. However, the following two (2) items are considered to be open due to the lack of information to permit an evaluation:
(a) The emergency response _ training of essential response
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personnel had not been completed. Also, a program for providing site visitors.with instructions regarding their response to an emergency signal had been initiated during
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(b) The emergency oreparedness training for contractor personnel working at Units 2/3 was being examined by the licensee /
applicant for adequacy..in -terms of responding to emergencies at Unit 1.
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-10-In. addition _to the above findings,ithe following items 'should be considered for improving the program:
.(1) Establish, document'and provide an instruction program
.for ambulance and offsite fire support personnel who might enter the site.during an emergency.
(2) Establish and implement a program for maintaining.
emergency plan training. records so that personnel who need. training and those'due for retraining can be easily identified.
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4.0 Emergency Facilities and Equipment
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Emergency Facilities
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4.1.1 -
-Assessment Facilities
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I 4.1.1.1 Control Room
There is available in the Unit 1 and Units 2/3 Control ~ Rooms (CR).an updated copy of both the EP and.EIP's.
The present
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CR method of. initial dose assessment in Unit 1 is via hand
calculations.
However,'a computerized system,--Apple II, will.be installed shortly to perform this calculation.
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With this, system, the Watch Engineer or the on-shift Health.
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Physics Foreman (or Senior Health Physics Technician) will
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type into the computer.meteorlogical and radiation information, and'the computer will then display down' wind dose projections.
A duplicate _ Apple'II computerized system for initial dose
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j assessment will also be placed;in.the Units 2/3 CR.. The i
Health Physics Computer, which will make dose projections-i without the need for manual input,.is' scheduled for operation in July 1982.- The CR was provided with adequate primary
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and backup communications capabilities for use during an r
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4.1.1.2 Technical Support Center
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The two Technical Support Centers (TSC), for Unit 1 and '
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Units 2/3, are as specified in the respective EP's.
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TSC has windows which provide visual observation of CR activities
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and each TSC has the same degree.of habitability as the CR. The habitability is as recommended by paragraph 2.6 i
.of NUREG-0696.
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I Both permanent TSCs, presently under construction, are expected i
to be completed by October 1982. THese TSCs, although not I
completed, are used as an interim facility and have been
manned while performing drills and exercises and during j
the response of station personnel to several actual emergency
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conditions declared at the Unit 1 site during the 3rd quarter
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i of 1981.
Each TSC appeared to function. satisfactorily during
these-occasions.
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Each TSC appears to provide ample space for personnel occupancy
and an operable communication system.
Discussion with the
staff revealed that' radio reception between the TSC/0SC and assembly areas onsite, and from these locations to offsite'
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emergency response teams was. poor to nonexistent in some cases. The availability of radio frequencies was also identified as a problem. This condition is the same for both TSCs.
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Radio communication between the Unit 2 TSC and its OSC is i
not possible; however, direct communication between the i
two facilities may be accomplished via a dedicated telephone
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extension.
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EIP-72 Emergency Equipment Inventory, provides for an inventory of the various emergency kits on a quarterly basis as well as after each use. Attachment 8 to this procedure provides a listing of the equipment in the TSC kit.
Except for the operating -and reactor safety committee (Onsite Review Committee)
records, the TSC kit inventory included those items described in Section 2.10 of NUREG-0696.
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. 4.1.1.3 Operations Support Center l
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The EP's describe the locations of the Operations Support
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Canters (0SC) for Unit 1 and Units 2/3.
For Unit 1 this facility is located in the Control and Administration Building Conference Room. 'The appraisal disclosed that the Units 2/? OSC in the Administration and Warehouse Building Lunchroom
ha_1 been changed to a new location on the 70 foot-level
=of the Units 2/3 Control Building. This new Units 2/3 OSC is still under construction. The ventilation system for the Unit 1 OSC does not provide the same habitability as the CR and TSC. According to EIP-17, Activation and Operation
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of Emergency Centers and Organizations, the Unit 1 OSC is i
to be evacuated to the Units 2/3 OSC if the primary location
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(Conference Room) is uninhabitable. The alternate OSC for
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Units 2/3 is the Unit 1 OSC.
Neither OSC is provided with
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a habitability equivalent to the CR or TSC. The EIP's do i
not provide instructions for evacuation of the OSC when i
the alternate OSC is uninhabitable.
The OSC's have been provided with a capability to communicate l
with the CR and TSC. ' Section 4.2.3 of this report discusses
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the emergency communications equipment, including problems
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l with radio contacts between the onsite emergency facilities (OSC and TSC) and the onsite or near site monitoring teams.
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.4.1.1.4 Emergency Operations Facility The interim Emergency Operations Facility (E0F).is located in-
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the San Clemente Civic Center. The EP's describe the PE0C, located
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in the SONGS Administration and Warehouse Building Conference
Room, as being a portion of-the interim E0F. During the May 1981 emergency planning exercise some observers expressed a judgement
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that the E0F at the Civic Center was too small.
The E0F has now been moved to the lower level in the same building where the available space is about 2,000 square feet. The new location provides four separate rooms for the E0F operations. The communications equipment for the liaison responsibility of the E0F includes (1)
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j an interagency telephone system with a monitor speaker, (2) a ringdown telephone from the PE0C, (3) 12 commercial phones for-
use by liaison personnel and (4) a teletype terminal. The room used for offsite dose assessment (00AC or Offsite Dose Assessment
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Center) was provided with status boards, radios for communications with offsite monitoring teams, maps and other necessary supplies, two commercial phones, an interagency phone with a monitor-speaker and a ringdown phone for the transmission of information to and from the TSC and PE0C. The E0F was also provided with radiation
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monitoring instruments (including a single channel analyzer with
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a Nal detector),' air-sampler for particulate and iodine activity, respiratory protection equipment and an ingestion pathway sampling kit. During the visit to the E0F the San Clemente Emergency Coordinator informed the appraisal-team members that he possessed two portable
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meteorological systems which could be used during an emergency.
j The appraisal disclosed'that the-up-to-date plant-records, EIP's,
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EP's and other pertinent records and materials were available at the PE0C with certain duplicates (e.g. EP's, EIP's and FSAR)
located at the E0F.
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4.1.1.5 Post Accident Coolant Sampling and Analysis The boron analyzer room is utilized for' Unit I high activity' post
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accident coolant sampling on'an interim basis.
The sample is obtained from a depressurized coolant sample line in the room.
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I Ample shielding is provided around the room, but the Chemistry i
Technician may be required to expose himself to a high radiation-
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field while obtaining the samples. A teletector survey meter is utilized'for monitoring the sampling room before entry. The
normal reactor coc s.nt sampling room, located at the access control
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point may also be used to sample the coolant during a post accident
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- .- situation provided the radiation exposure level in the boron analyzer room is less,than 1 R/hr. The sample containers are
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1000 ml-plastic florence flasks. Other equipment necessary for
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cbtaining the samplelispresent in the sampling kit located in the emergency kit lockers. Neither a shielded container nor handling tools o
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were available to reduce personnel exposures during the transporting of.the samples within the plant. A 55 gallon concrete filled drum is ~ used to store the samples for offsite transportation.
These Unit 1 samples are isotopically analyzed using a multichannel analyzer with Ge-Li detectors. The detectors are located in a room adjacent to the radiochemistry laboratory. The remainder of the analyzing equipment is located in a separate room exterior to the radiochemistry laboratory.
The path between these two rooms involves passing through the radiochemistry laboratory (including a personnel contamination check when leaving), the cold chemistry laboratory and a hallway.
With the equipment in place, both rooms (the room containing the detectors ano the room with the additional analyzing equipment) are extremely cramped and provide inadequate work space, or room for expansion. The instrumentation is incapable of handling high radiation levels, and the lack of space prevents impromptu geometry changes to aid the detectors in counting such samples. The room containing the detector support equipment is noisy enough to prevent personnel inside from hearing the plant pager or alarms.
A new post accident sampling system (PASS) designed by Bechtel with Combustion Engineering components is presently being installed in Units 1 and 2/3. The Unit 1 system, described in a report (Post-Accident Sanpling System Capabilities and Description) submitted to the NRC by letter dated July 9, 1980, will be a vast improvement over the present sampling system and should be capable of satisfying the criteria in Task II.B.3 of NUREG-0737. The PASS for Unit 1 will be installed at the next outage in early 1982, and the system for Unit 2/3 is expected to be complete by January 1,1982.
It should be noted that the Unit 2 license, issued on February 16, 1982, contained a requirement that the PASS be operational prior to going to power levels above 5 percent of full power.
4.1.1.6 Post Accident Containment Air Sampling and Analysis The Unit I radiation monitoring system has always had the capability of sampling the air from either the plant stack or the containment sphere atmosphere. The containment sphere sample lines leading to the monitors have been provided with valving that permits a sample to be collected external to this system. The valving is located on the oetside wall of the ventilation building. This external sampling capability would be used to obtain a post accident containment air sample. This area is accessible during accident conditions; however, high dose rates may be present. Nearby shielding is available to shelter personnel during the purging step and actual manipulations during the sample process are brief.
It would take about 30 minutes to obtain a representative sample.
When installed, the Unit 1 PASS will be used to sample and analyze these samples.
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e-15-The containment air samples would be analyzed using the same equipment described in the previous section for the analysis of post accident coolant samples.
During the appraisal, chemistry technicians were asked to simulate the taking of post accident samples which involves the use of EIP-46, Onsite Sampling. The technicians did not indicate a clear understanding as to which samples should be transported to the laboratory for counting and the upper limits of activity that could be measured with the Unit 1 equipment. They did indicate that samples should have contact exposure rates of less than 1 mr/hr. This_would correspond to approximately 50 uCi of activity.
The technicians stated that highly active filters could not be quantitatively analyzed, but liquid samples would be diluted to countable-levels.
Tre Unit 1 staff indicated that firm agreements for offsite analysis of highly active samples are in process, but not yet complete.
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Containment air samples from Units 2/3 will be analyzed using
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the PASS presently being installed.
PASS, which will also measure the activity in post accident coolant samples, uses intrinsic germanium detectors.
The examination of the Units 2/3 PASS disclosed that the operations panel will be accessible during severe accidents.
Also the access pathway to PASS has been shielded. The PASS operator is shielded from the sample lines by up to 4 feet of concrete, which is adequate to allow ALARA doses during operation of the PASS control panel. Area monitors are provided. The output of the multichannel analyzers (MCAs) will be directly connected to the dose assessment computer. The system is capable of performing analyses within 30 minutes if it is maintained in an operational state.
The auditors examined the Units 2/3 PASS control panel and the detector shielding arrangement, especially the provisions to control streaming where the detector butts to the concrete shield. The mimic board and the shielding appear to be functional and well arranged.
The appraisal team expects that the PASS systems will be operated or maintained frequently. The complexity of the system and the need.to cool the' intrinsic germanium detectors and calibrate the nuclear and chemical analysis systems makes it imperative that system maintenance and operator capability be assured
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4.1.1.7 Post Accident-Effluent _ Sampling and Analysis At Unit 1, liquid effluent samples are obtained from the exhaust side of the'~ recirculation pumps located in the lower level of the radwaste
"line that taps into the outlet (head)pling bottle from a short sample
' building.
The technician fills a sam side of the pumps. The pumps
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-16-are activated for a sufficient time to assure uniform mixing of the tank contents prior to taking the sample. Once the sampling line is purged, a representative sample is obtained. The same pumps are used to move the tank contents to the circulation water for disposal into the ocean.
Both the intermediate and the lower level of the building contained unshielded pipes and pumps which could produce high dose rates during an accident. However, the time required for sampling is relatively short because a few milliliters could constitute an adequate sample and because the sampling line is less than one meter in length.
The potential for high dose rates suggests that a health physics technician should accompany the chemistry technician.
At the time of the appraisal, the area monitor on the intermediate level of the radwaste building indicated a radiation level of 10 mr/hr.
At Units 2/3, liquid effluents are sampled from a sampling station
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on the lowest level of the radwaste building.
The sampling manifold is in a ventilated hood.
There are multiple access pathways to the sampling station. The lowest level of the radwaste building is heavily shielded by its structural components.
It should be accessible through the loading dock under emergency conditions.
There is an area radiation monitor at the sampling station with both a local and a control room readout. A sampling procedure similar to.that of Unit 1 ensures a representative sample. The samples are counted in the Units 2/3 radiochemistry laboratory.
At both plants, shielded containers and remote handling tools should be provided.
The present procedure 501-VIII-46 Rev. 0 only states that a shielded container will be used when available.
The two wide range gaseous effluent monitors for Unit 2, and a like number for Unit 3, include the capability to obtain a grabsample. One of the monitors samples the exhaust gas from the condenser air ejector and the other has the capability of sampling either the containment purge stack or the plant vent stack. The grab samples would be analyzed in the counting room of the radiochemistry laboratory.
The locations of the Unit 2 wide range gaseous effluent monitors were examined during the appraisal. The stack monitor is near the containment building where peak dose rates at time zero under design basis accident conditions might be in the range of 10-100 rem /hr. The condenser air ejector is in the Turbine Building where dose rates under similar conditions will be much lower.
The normal stack monitors are in the Radwaste Building where dose rates under accident conditions would probably be lower than those in the area where the wide range stack monitor is located.
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The appraisal ihcluded an examination of the partially installed analytical equipment in the Units 2/3 radiochemistry laboratory.
The Ge-Li measurement' systems are designed to operate at counting rates up to 80 MHz, which should be sufficient for high level analysis.
The Ge-Li analyzers will be connected so that outputs willego directly to the HP-1000 dose assessment computer. The laboratory has ample space for the functions assigned to it.
Unit 1 post accident gaseous effluent sampling is presently performed in the same' manner as the post accident containment air sampling (described in Section 4.1.1.6) and in the same area. A wide range effluent monitor with the capability for obtaining a grab sample will be installed for the purpose of sampling the plant stack in the near future.
Unit 1 post accident gaseous effluent samples will be analyzed using the Unit 1 instrumentation that was described in Section 4.1.1.5.
The effluent sampling locations and methods are such that the licensee will be able to provide a timely analysis of representative
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effluent samples.
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4.1.1.8 Offsite Laboratory Facilities At the present, SONGS has no official agreement with any offsite radiation laboratory facilities.
An agreement now exists with Environmental Analysis Laboratories to provide environmental analytical services. Paperwork is now being processed for an official agreement which will establish General Atomic in San Diego as an offsite radiation laboratory facility.
Arrangements concerning General Atomic as an official offsite laboratory are expected to be completed by January,1981.
4.1.2 Protective Facilities 4.1.2.1 Assembly / Reassembly Areas The actual onsite and offsite assembly areas are as shown on Enclosure 1.
Signs providing instructions and exit routes are conspicuously posted throughout the f acilities and protected areas of Units 1, 2 and 3.
The Unit 1 AWS and Unit 2/3 assembly areas appear to provide ample space for the numbers of personnel expected.
The Unit 1 assembly area used during plant evacuations is designated for SCE, visitor and contractor personnel working inside and outside the protected area. The Unit 1 assembly area does provide protection i
from adverse weather conditions.
The unit 2/3 onsite assembly area, referred to as 08-2 (Office Building-2), is only designated
.for SCE and visitor personnel working within and outside the Units 2/3 protected areas.
It too, provides protection from adverse weather conditions. Assembly areas for Units 2/3 contractors
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l will be discussed later.
Signs to conspicuously identify the Unit 1 and Units 2/3 onsite assembly areas will be installed as they are completed.
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-18-Each of the onsite assembly areas is equipped with Emergency Lockers that will contain ample emergency equipment for responding to an emergency when they are fully stocked.
SCE telephones are also available at both assembly areas.
Several hundred persons are expected to amass at each assembly area should an evacuation be necessary. Personnel on arriving at the assembly areas are instructed to report to their supervisiors.
A discussion with the EPC revealed that locater signs mounted on stanchions.were being considered to identify the supervisors in order to avoid confusion and provide some control of personnel gathering at the assembly areas.
The two offsite assembly areas, also indicated on Enclosure 1, are considered to be temporary assembly areas for SCE, visitor and contractor personnel evacuating the licensee's owner controlled and beach areas during an emergency.
Both of these areas are located on the Camp Pendleton Marine Base.
Neither area, Basilone Road Sentry Gate (4.5 miles to the north) or the Las Pulgas Sentry Gate (7 miles to the South), provides protection against adverse weather conditions. Emergency equipment is not stored at these offsite assembly areas. Telephones are provided at each of the sentry gates as a means for communicating with emergency control personnel at the site. Tests have not been made to determine whether or not comunication with the site emergency control personnel can be accomplished from the offsite assembly areas using the SCE radio comunication system.
The assembly process for contractor personnel at Units 2/3 differs from that described above.
Bechtel, the primary contractor, has prepared their own Emergency Plan for evacuations of their personnel and subcontractor personnel working for them. The Bechtel Emergency Plan is not included in the EP's at this time. Currently Bechtel requires its employees and the subcontractor employees to report to their respective " gang" boxes and then await further instructions from their immediate supervisors. Many of these
" gang" boxes are located within the Unit 2/3 facilities and Unit 2 protected area.
Negotiations are currently underway between SCE and Bechtel regarding a change in the latter's Emergency Plan
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j to provide for one central assembly point outside the Unit 2 protected
area.
The assembly area being considered is on the beach at or near the south end of Units 2/3. Upon reaching an agreement on this matter the Bechtel Emergency Plan will be included as an i
attachment to the SCE EP and affected personnel will be re-instructed.
The need to expedite these changes and instructions was emphasized to the licensee because the current Bechtel EP would not result in the evacuation of the Unit 2 facilities and protected areas as it is currently written.
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-19-The above provides a description of the onsite, offsite and contractor assembly areas as they currently exist. The above assembly areas were put into effect approximately three weeks prior to this appraisal.
The current EP's (Sections 6 and 7) do not reflect the changes in the assembly areas and the Units 2/3 EIP's also need to be made current with respect to these areas.
Personn.el who received emergency plan training prior to the relocation of the assembly areas need to be made aware of these changes.
~This is especially true at the Units 2/3 site as determined from interviews with numerous workers during the appraisal. The Unit 2 contractor personnel questioned were familiar with the current actions expected of them during an evacuation; however, approximately 90% of the SCE personnel were not aware of the latest changes even though the evacuation instructions were updated on their ID cards and signs with; instructions were recently posted within the Unit 2 facilities and protected areas.
Most of the Unit 1 SCE personnel were aware of the present assembly areas. Contractor workers at the Unit 1 site also had knowledge of the assembly area they were to report to during an evacuation.
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One problem associated with the posting of an evacuation sign was noted. The sign had been posted on the outside wall at the entrance to a wash room located near the licensee's training facility.
This posting is in an area where personnel involved in either a plant (Unit 1) or site evacuation would pass. Since, at this location, the route for a plant evacuation is opposite to that for a site evacuation, the sign as posted may confuse personnel who read it.
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4.1.2.2 Medical Treatment Facilities There is a room on the ground floor of the Administration and Warehouse Building that has been designated the "First Aid Treatment Center". This location is accessible to Unit 1 and Units 2/3.
The whole body counter is in this room. The typical first aid equipment to be stored in the First Aid Center has been described in Appendix D of the EP's.
The ambulance emergency kit which is also stored in this room, has also been described in Appendix D to the EP's.
The contents of the ambulance kit and the equipment stored in the "First Aid Treatment Center" were examined. The contents in the ambulance kit were found to be as described in Appendix D to the EP's.
The kit contained more than an adequate supply of materials to support the ambulance needs. The equipment kept at the " Center" was found to be as described in Appendix D to the EP's, however, the instrument and first aid supply cabinets were not adequately supplied with necessary items. Also the oxygen supply bottles used in connection with the resuscitators were
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low in pressure. The small first-aid kit kept in the " Center" was being used routinely, but there did not appear to be a system for assuring the kit was maintained in a ready status.
The last statement also applied to the first aid kit kept at the Unit 1 Health Physics Office located at the access control point.
Some of the first aid supplies and equipment placed at various other locations in Unit 1 were examined. This examination disclosed that these items were placed as described in the EP. However three of the Stokes baskets were deficient in that one had large holes (8-10 inches) and no safety straps, a second had rusted buckles and needed a checking of the rope and the third was leaning against the wall and not in its designated location. The licensee immediately replaced the Stokes basket containing the holes with a nondefective one when it was called to his attention.
First aid and rescue equipment and supplies have not yet been placed in the Unit 2/3 facility because of its present construction status.
The result of Unit 1 examination supports a need for a first aid maintenance system.
The appraisal disclosed that Bechtel maintains a first aid capability onsite for their personnel and those of their subcontractors.
There are two first aid facilities, one just south of Unit 3 and one just outside the Unit 1 Control and Administration Building.
There is a registered nurse at each of these locations during the normal work week hours.
EMT's are onsite during the other work hours. The EP's do not mention the Bechtel first aid capability.
SCE has not established a formal procedure or system for using the Bechtel first aid facilities; however, SONGS management said that there is a mechanism for using this Bechtel capability if necessary.
A few of the SCE personnel were aware that the Bechtel first aid facilities existed.
There is no direct communications between the control rooms (Units 1 and Units 2/3) and the first aid facilities; however, these locations all have telephones.
The future plans for first aid capability at SONGS was discussed i
with the SCE Medical Director.
He said that a medical facility was being considered in connection with the permanent EOF which is expected to be completed by the Fall of 1982. This medical facility will consist of several rooms and, during the five days normal working hours, be staffed with a doctor, registered nurse and a licensed vocational nurse.
At other times there will be EMT's onsite. The Medical Director also indicated there were plans to have EMT's onsite during the five day '.o mal working hours.
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-21-4.1.2.3 Decontamination Facilities At Unit 1, the routine decontamination facility has a single shower stall and sink in the hallway at the health physics control point.
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The Health Physics Appraisal (IE Report No. 50-206/80-17) conducted in May 1980 concluded that this facility was unsatisfactory.
At Units 2/3, the men's decontamination facility consists of a walk-in shower area, large enough to admit a stretcher and two persons simultaneously.
There is a separate area for women.
Additional decontamination facilities will be included in the EOF, which is not yet under construction. There are no decontamination facilities at the onsite assembly areas, but decontamination supplies are available. The emergency plan and procedures do not specify what decontamination facilities are available at offsite assembly areas.. Interviews with plant staff did not indicate that specific offsite decontamination facilities exist.
Instruction 6.2.3.2 of EIP-44 suggests that persons evacuated from the site may "be monitored the same as members of the general public in accordance
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with the emergency plans of the affected jurisdictions." The presumption of the team is that the decontamination facilities of the offsite government jurisdictions would also be used, if needed.
Station personnel indicated a clear knowledge of suitable methods of establishing ad hoc decontamination facilities at assembly areas using prepositioned supplies and readily available materials.
However, Procedure VII-4.4 (Personnel Decontamination), referenced in EIP-45, does not address the subject of decontamination at assembly or reassembly areas.
EIP-45, Personnel and Vehicle Monitoring, discusses decontamination by referencing Procedure VII-4.4.
The examination of EIP-45 also disclosed that the forms provided for i
recording the names of persons surveyed, extent of contamination i
found and methods and results of decontamination performed did not provide for recording the instrument used to monitor for contamination.
l 4.1.3 Other Facilities 4.1.3.1 News Center l
The licensee has arranged for the establishment of an Emergency News Center (ENC) at the South Coast Boy's and Girl's Club in
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l San Clemente which is about six (6) miles from the SONGS site.
l This facility provides adequate space for the news media as well l
as the PI0's (Public Information Officers) of the various organizations
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involved with emergency planning for the San Onofre site (see Paragraph 6.3 for activities related to news nedia operations).
I A large gymnasium will be divided into a media work area and a
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media briefing area. Separate rooms will be used by the PI0's.
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Security personnel supplied by SCE will control access to the various areas in the facility.
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Three types of communications exist at the ENC. There is a teleprocessing system consisting of a terminal (keyboard and cathode-ray-tube)
and a printer. This teleprocessing system has a capability to display bulletins stored in the SCE computer.
There is also a portable telecopier that can send and receive "hard" copies of material to the E0F, San Onofre site and the City of San Clemente.
Telephones provide the primary means for the PI0's to communicate with their respective emergency facilities and organizations.
The telephones are plugged in when aeeded.
Visual aides, radiation survey meters, dosimeters and charger and other office supplies are stored at the facility.
A small locked room is used to store the equipment and supplies.
There is only one pay telephone presently available for use by the news media personnel. At the present time there is a shortage of telephone lines into the San Clemente area which prevents the licensee from providing for additional lines to be used by the media during an emergency at the present time.
However, SCE is working with the Telephone Company to correct this situation.
There is a nearby, lighted baseball field that could be used as a helicopter landing area. There is a small, paved parking area in front of the facility.
Additional parking is available at a nearby city water treatment facility.
4.1.3.2 Expanded _ Support Facilities The licensee has designated the E0F as the location to which all corporate, contractor and non-licensee augmentation personnel will report. After tcing processed through the E0F, some personnel may report to the OSC, ESC, TSC, or PEOC. All of these locations either have or will have adequate communication equipment upon completion of the construction phases of these facilities. Most of the cormiunication equipment in the Units 1 and 2/3 TSC's and Unit 1 OSC is currently operational.
The communication equipment in these facilities has been used in recent drills and exercises
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and have proven to be satisfactory.
The communication equipment in the Unit 2/3 OSC is currently being installed and should be operational before January,1982.
l 4.1.4 Conclusions: Emergency Facilities
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Based on.the above findings, this portion of the licensee's/ applicants
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l program does not appear to have any significant deficiencies.
l However, the following four (4) items are considered to be open l
due to incompleteness of the intended actions.
(a) The Unit 2 TSC has not been completed and equipped so as to be operational.
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l (b) The area to be rised as the Unit 2 OSC has not been completed and turned over to the operating staff.
(c) The Units 2/3 Post Accident Sampling System has not been completely installed and tested.
(d) The Units 2/3 laboratory counting equipment has not been completely installed and calibrated.
In addition to the above findings, the following items should be considered for improving the program:
(1) Consideration should be given to improving the Unit 1 laboratory i
counting facilities, particularly with respect to providing a convenient access between the detector and the rest of the equipment.
(2) Since the Chemistry Technician's responsibilities have been separated from those of the Health Physics Technicians, consider the need to provide a Health Physics Technician when post accident samples (coolant and containment air) are taken.
If necessary make appropriate changes to the EIP's.
(3) Consider the need for heat tracing the Units 2/3 vent sample lines.
(4) Complete the formal arrangements with General Atomic to provide a backup laboratory analysis capability.
-(5) Consider the advisability of having Units 2/3 contractor personnel assemble at one or two locations outside the protected area rather than the " gang" boxes as presently required.
(6) Reexamine the equipment and supplies kept in the "First Aid Treatment Center" and provide additional items to assure an adequate supply of first aid materials.
m (7). Develop and institute a care and maintenance program for first' aid equipment.
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4.2 Emergency Equipment 4.2.1 Assessment 4.2.1.1 Emergency _ Kits and Emergency Survey Instrumentation
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The licensee has distributed cabinets containing emergency kits and supplies throughout the site.
The type and purpose of the kits as well as the contents are specified in procedure S01-VIII-72.
Typical contents are given in Appendix D of the Emergency Plan.
.The licensee combines prepared kits and reserved monitoring equipment in cabinets that are normally locked with breakable seals. This allows ready access by technicians.
This equipment is for use only during emerge cies.
At_ Unit 1, the kits, equipment, and supplies were located according to the procedure, except as noted. The OSC cabinet, for example, contained instruments, equipment and supplies required for in-plant, onsite and offsite monitoring teams. The inventories were correct and all equipment was operable and calibrated, except that alarming dosimeters were being calibrated. The equipment
' included TLD finger rings, 125 self-reading dosimeters, 4 friskers, 4 teletectors and 6 ion ~ chamber survey meters for measuring beta and gamma fields. The equipment in the cabinets exceeded the minimum requirements of the procedures. The equipment for air sampling consisted of AC and battery powered air samplers with a sampling head for an absorber cartridge and a particulate filter.
The kits are equipped with sjlver zeolite cartridges. The monitors are instructed to pass 10 ft of air through the sampling head and then determine the count rate on the sampling medium with a frisker. Assuming that 100 cpm is discernible above background j
and that the efficiency for measuring iodine is 1-10%, the sensitivity will be 1E-08 to 1E-09 uCi/cc.
For the particulate filter, the efficiency will be closer to 10% and the resulting lower limit
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l of detection will be approximately 1E-09 uCi/cc. The licensee has ordered portable SAM-2 sodium iodide analyzers that should
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improve the accuracy and specificity of the measurements.
The equipment cabinets in the OSC of Units 2/3 were also examined.
l The equipment is essentially identical at both plants. All equipment i
was found to be calibrated and operable. A few minor supply items had not yet been placed in the cabinets. The self alarming dosimeters were not available at either plant because "ey were in the process of being calibrated.
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waste system liquid effluent monitor and the stack gas monitor.
The former was not operatle and had not been so for a considerable period of time. As permitted by the technical specifications, periodic grab samples and analyses of the liquid being released were substituted for the liquid effluent monitor. The stack gas monitor was operable; however, the ability of the instrinent to perform its intended function was questioned during a routine health physics inspection conducted just prior to this appraisal (see IE Inspection Report No. 50-206/81-36). These area and process monitors read out in the Unit 1 CR.
The interim action for extending the range of the stack (noble)
gas monitor to satisfy Item 2.1.8 b of NUREG-0578 consisted of installing a high range (0.01-100 r/hr) Technical Associates monitor to measure the radiation from the stack sample line and implementing a procedure for in-situ radiation readings of the sample line by an individual until the high range monitor shows a reading greater than 0.01 r/hr. The appraisal included an examination of the high range monitor.
It appeared that radiation levels from nearby equipment could have a significant effect on the readings of the high range monitor.
In addition, the applicability of the EAL related to noble gas releases, as shown by the stack gas monitor and the extended range capability, was questioned. The Appraisal Team estimated that ghe nomal stack monihr with an upper capability of 10E6 (1x10 ) counts per minute would be limited to 0.3 Ci/sec (based on xenon-133) release rate out the stack. The lowest reading on the high range monitor would be equivalent to about 140 Ci/sec release rate out the stack. At the time of the appraisal EIP-22, Source Term Determination, did not include the steps for determining the noble gas (and iodine and particulate)
release rates and the information necessary to convert meter readings (including in-situ radiation readings) to release rates. According to the licensee, when the current revision (No. 1) to EIP-22 was issued, the information described in the previous sentence was left out.
The installation of the Unit 1 high range monitors (up to 10 r/hr)
and steam header monitors (up to 10 r/hr)hadnotbiengompleted.
Also the extended range noble gas stack monitor (10' -10 uCi/cc)
had not been installed. The licensee intends to install an APT post accident sampling system to aid in determining stack flow and effluent release information. These three monitors were being installed to satisfy Task Items II.F.1 (1) and (3) in NUREG-0737.
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-26-SCE's preoperational testing of the Units 2/3 area and process (including effluent) monitors had not yet been completed. The routine preoperational inspection program has been following the problems associated with the operability and primary calibration of the process monitors.
There do not appear to be any problems associated with the. area monitors. This appraisal determined that these instruments, described in Sections 11.5 and 12.3.4 of the FSAR, would provide the appropriate data for emergency actions.
These instruments read out on a panel located just outside the CR. The CR is provided with a signal (visible and audible)
that shows when an alarm setpoint has been reached by one of the area or process monitors. The area and process monitors being installed at Units 2/3 appear to meet the requirements of Task Items'II.F.1 (1), (2) and (3) of NUREG-0737.
4.2.1.3 Nonradiation Process Monitors The Unit 1 non-radiation process monitors described in the EP and EIP's that are being relied upon for emergency detection, classification and assessment were in place and operational.
Toxic gas monitors related to CR habitability do not presently exist.
The Units 2/3 non-radiation process monitors described in the EP and EIP's that are being relied upon for emergency detection, classification and assessment exist and will be operational when the facility begins operations.
4.2.1.4 Meteorological Instrumentation The bases used in reviewing the licensee's/ applicant's meteorological measurements program included Regulatory Guides 1.23 and 1.97 and the criteria set forth in NUREG-0654, NUREG-0696 and NUREG-0737.
The licensee / applicant outlined the characteristics of their meteorological measurements system in EP Section 7.3.3.
The integration of meteorological data into the licensee's/ applicant's dose projection scheme is summarized in Section 6.2.5 of the EP and is implemented using EIP S01-VIII-1.22.
The preventive maintenance program for meteorological instrumentation was also reviewed with the licensee / applicant.
The current meteorological instrumentation provides the basic parameters (i.e., wind direction and speed and an estimate of atmospheric stability) necessary to perform the dose assessment function.
Data from the meteorological measurements system were recorded on strip charts available in the control room. There were no backup sources of meteorological information in either the control room or in the emergency procedure.
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-27-The licensee / applicant has maintained a program of inspection and preventive maintenance. The instrumentation in the control room and at the meteorological tower is checked daily by SCE.
Complete inspection and servicing are done monthly by a consultant.
Quarterly calibration of electronics, wind sensor bearing tests and ice bath calibrations of the thermometers are also done by the consultant. Wind tunnel calibrations of the wind sensors are done annually.
The siting and exposure of the meteorological instrumentation on the tower at the time of the appraisal was questionable. The area around the tower is cluttered with equipment trailers, discarded material and parked vehicles which may influence the meteorological measurements at the lower (10 and 6 m) levels. The primary system vertical temperature difference is based on measurements at 10 and 40 meters whereas Regulatory Guide 1.23 recomends 10 and 60 meters.
However, the NRC has found that the measurements at 10 and 40 meters were acceptable.
At the start of the appraisal, the licensee / applicant did not have equipment or procedures to inform shif t operations personnel of severe meteorological phenomena (i.e., tornadoes, hurricanes, high wind) likely to affect the site.
However, it was stated that SCE monitors all weather conditions during normal working hours. Accordingly, should the possibility exist that severe weather condition may affect the site, the San Onofre operations personnel will be so notified.
During the second week of the appraisal, the Appraisal Team observed that a Realistic Weatherradio
Alert unit had been installed in the Unit 1 Security Secondary Alarm Station. A demonstration of its operation showed that the unit was working. The procedure governing the unit, requires security personnel to notify the Unit 1 CR if an alert signal is received on the unit.
After receiving this information the CR personnel contact Lindberg Field Airport (San Diego, California),
or an alternate location, to obtain specific weather information.
The Weatherradio Alert system will be used by the licensee / applicant to provide information on severe meteorological phenomena that may occur at or near the SONGS site.
4.2.2 Protective Equipment 4.2.2.1 Respiratory Protection An ample supply of self contained air breathing devices, primarily consisting of Bio Marine Pac's with a small supply of Surviv Air devices, are reserved for emergency use at various onsite locations inside the protected areas. The RPM stated that the Surviv Air devices are being phased out of service.
Additional reserve supplies of MSA respiratory equipment are also available at various locations for use during emergencies.
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-28-The licensee has a respiratory protection program that is consistent with ANSI E88.2 and NUREG 0041. All personnel who are blue badge and red badge trained receive training in the use of respiratory equipment available for use at the site. The training protided does not qualify an individual to use respiratory protective equipment.
MuHffy, an individual must also pass a medical physical, obtain a whole body count and be fit tested for each type of respiratory equipment he/she may be required to use. A discussion with various licensee staff members revealed that all essential staff personnel who may be required to respond to a radiological emergency are not currently respiratory qualified.
Nor have personnel trained prior to April 4, 1981 been instructed in the use of the Bio Marine Pacs. Many R.0.s, Fire Brigade Members and Chemistry Technicians at the Unit 1 site are presently not qualified in the use of the new Bio-Marine Pacs.
Currently the unit 2/3 protected areas are equipped with the Bio Marine Pacs. Most of the Surviv Air units at the Unit 1 site, with the exception of three located in the CR, have been replaced with the Bio Marine Pacs which could present problems if an accident situation were to occur before personnel are trained and qualified in the use of the Bio Marine Pacs.
A reserve supply of Bio Marine Pacs is not available for emergencies outside the licensee's protected areas.
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4.2.2.2 Protective Clothing Adequate supplies of disposable protective clothing are distributed throughout Unit 1 and its assembly area. The Units 2/3 clothing has not been fully distributed at this time.
At present the licensee is in the process of instituting a control level of stock that will ensure an adequate reserve of protective
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4.2.3 Emergency Comnunications Equipment The licensee has an elaborate communications capability that connects
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crganizations. These systems have been described in Section 7.5
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Similar communications systems, also described in
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Section 7.5 of the Units 2/3 EP, will be used at Units 2/3. The Unit 1 systems are operational and were used during the May 13, i
1981 emergency planning exercise (see IE Inspection Report No.
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-29-With respect to the use of the two-way radios for communications with onsite and offsite monitoring teams, there are some " dead spot" locations where these units can not be utilized for communication between the onsite emergency facilities and the monitoring teams.
The licensee became aware of the problem during the May 13, 1981 emergency planning exercise. The solution to the problem involves gaining access to a repeater station in the area. According to the licensee, arrangemets have been made to use one of the Orange County frequencies that will provide access to a repeater station. -They are also making arrangements through the FCC to use one of the frequencies assigned to SCE for the area north of Los Angeles. This SCE frequency will provide access to a repeater station. The licensee said that radios with these new frequencies have been ordered, but delivery will take a few weeks.
The licensee noted that each pole on which an Early Warning System
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siren is mounted includes a telephone connector. Therefore, they intend to include a telephone with a jack connector in the monitor's kits so that these individuals will be able to use this system as an alternate means for communicating with the SONGS site.
The radios located in the Unit 1 and Units 2/3 CRs were examined during the appraisal.
Both units were operable. At Unit I the radio was connected to an electrical circuit that was not part of the emergency electrical system. Also the radio in the Units 2/3 CR may not have been connected to a circuit that would be supplied with power during operation of the emergency electrical system.
According to the licensee, they intend to make changes so that the radios in the two control rooms will operate when either normal or emergency power is being used.
The examination of the communications capability included a check of the related EIP-16, Notification, to assure that the telephone numbers were current.
This check disclosed that the number for the NRC Region V Office was correct as listed on page 3 of Attachment 8.7 to this procedure, but incorrect on page 5 of the Attachment.
This indicates that not only is it necessary to periodically check telephone numbers to make sure they are current, but when changing telephone numbers in the EIP's a check should be made to assure all locations of the telephone number were corrected.
4.2.4 Other Equipment 4.2.4.1 Damage Control / Corrective Action and Maintenance Equipment and Supplies
SONGS Units 1 and 2/3 appear to have adequate equipment and supplies for damage control and corrective action.
The instrument machine shops, with locations convenient to the OSCs for both facilities, can provide a wide variety of tools and supplies during an emergency.
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In addition, other' equipment is located around the site which can be utilized if needed. An interview with the maintenance supervisor resulted in the suggestion that'a small tool kit consisting of hand tools (i.'e. pliers, crescents, hammers,~ etc.) be included in each emergency kit. The maintenance. supervisor indicated that they are now in the process of supplying these tool kits and that this, along with the other available equipment, would provide all the equipment necessary to handle most damage control / corrective action and maintenance in an emergency.
4.2.4.2 Reserve Emergency Supplies and Equipment The licensee has adequate supplies of radiation monitoring instruments and protective clothing reserved for emergency use during the initial stages of an incident.
At present, support can be obtained from local agencies.
The licensee is in the process of instituting a control level of stock that will ensure an adequate reserve of protective clothing.
Also, the licensee is in the process of establishing, with other west coast nuclear power plant licensees, a centrally located cache of protective clothing and necessary radiation monitoring instruments which will be delivered upon request. This will ensure long-term capabilities of supplying adequate protective gear during an emergency.
4.2.4.3 Transportation There are three vehicles assigned to the health physics group (two for Unit 1 and one for Units 2/3). These vehicles are used routinely by health physics personnel but are dedicated for emergency use by the monitoring teams.
None of the vehicles are four-wheel drive; however, the licensee has such vehicles on order. At present there is no system which makes vehicles onsite available for emergency use after hours. The licensee is. presently working on such a system.
4.2.5 Conclusions: Emergency Equipment Based on the above findings, the following deficiency must be corrected to achieve an acceptable program:
The Unit 1 interim, extended range stack effluent monitor for noble gases does not appear to be able to provide the required information for EP implementation due to problems with its sensitivity and range for the present location and shielding. Also the current EIP's do not include a capability for determining noble gas, iodine and particulate release rates using the stack effluent monitor.
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The following item is considered to be open because additional licensee / applicant action is required before the system is declared
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operational.
The process and effluent monitors for Unit 2 have not been completely installed, tested and calibrated.
In addition to the above findings, the following items should be considered for improvement of the program:
(1) Consider the possibility of adding a basic hand tool kit to the emergency kits.
(2) Determine whether the present location of the area monitor in the Unit I rad waste building could be improved.
(3) Consider removing equipment trailers, discarded material and parked cars within 150 feet of the base of the primary meteorological tower.
(4) Develop a firm schedule for respiratory qualification of emergency response personnel so that present respiratory protection equipment can be used as intended by such persons during an emergency.
(5) Evaluate the need for an additional supply of self contained respiratory protection equipment outside the protected area.
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Improve.the capability for communication between onsite and offsite monitoring teams and their bases (e.g. TSC, OSC, UDAC) so as to eliminate dead spots to the extend possible.
(7) Arrange for the base radios in the CR's to be connected to a circuit that will be supplied with emergency power.
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-32-5.0 Emergency Plan Implementing Procedures (EIP)
5.1 General Content and Format The appraisal included a review of the EIP's for both the Unit 1 and Units 2/3 EP's.
A separate set of 35 EIP's, using common numbers and titles, has been prepared for each emergency plan. A listing of these procedures is included as Appendix B to this report. The procedures use a standard format that addresses the following subjects: objective, references,~ prerequisites, precautions, the procedure and records.
Checkoff lists, when used, are included as attachments. The procedures appeared to be clearly and logically written. Also the instructions were sufficiently specific to perform the intended actions.
5.2 EIP Review The review of the EIP's disclosed that most of them were in an acceptable form. At the time of the appraisal two such procedures, EIP-73 and-74 (Emergency Plan Maintenance and Emergency Plan Training respectively),
were still being reviewed and had not been approved by the Onsite Review Comittee or the Station Manager. A copy of EIP-74 was obtained during the appraisal for use in evaluating the emergency plan training described in Section 3.0.
With respect to the EP maintenance, the EPA has that responsibility (see Section 1.0 of this report) as well as the overall responsibility for m3intaining the EIP's.
The following information pertains to those proceo'ures the Appraisal Team felt needed improvement.
(a) EIP-32, " Local Area Evacuation and Accountability," and EIP-39,
" Rescue," which provide instructions for implementing an emergency evacuation of localized radiologically affected areas were changed during the appraisal to address the concerns of IE Bulletin 79-18.
IE Bulletin 79-18 discusses audibility problems encountered on evacuation of personnel from high noise areas. The changes to EIP-33 and 39 are considered to be temporary solutions. They provide instructions to inspect pre-selected areas which have been determined to be out of reach of a paging system or within a high noise area. A permanent solution to the concerns of IE Bulletin 79-18 is still under evaluation by the licensee and is being followed by the Resident NRC inspector.
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Paragraph 6.2.3 of EIP-27, " Emergency Environmental Monitoring" requires that at least one team member be cognizant of normal environmental monitoring procedures.
Environmental monitoring is normally accomplished by Chemistry Technicians who use the procedures referenced in EIP-27.
During an emergency situation team members assigned to perform emergency environmental monitoring may consist of' personnel from the Health Physics Group who have not received training related to environmental monitoring.
During an inspection of the emergency kits used for offsite monitoring it was noted that copies of the referenced environmental monitoring procedures were not included.
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(c) Paragraph 4.1+of;EIP-36,E" Thyroid Prophylaxis" states that
! all emergency workers' should be, tested!for sensitivity to io'ine" prior to issue or.-use:
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not been= implemented yet. ;A discussion with the Hea'th Physics Manager'reve~aled,that the plant is. prepared to administer the sensitivity' tests;.however, the licensee's medical staff was still evaluating whether or not it is actually necessary.
(d) S6ction 8'.0 of the EP's states thatJthe response of station personnel'to an actual emergency condition may be allowed to satisfy a particular drill requirement, provided that a critique is performed and documented in the manner specified for a drill.
EIP-71, Emergency Drills, does not discuss the substitution of an actual emergency condition for a required drill.
(e) The post accident sampling walk-throughs at Unit 1 disclosed that EIP-46, Onsite Sampling, did not include in the equipment
list a wrench for opening and closing the shielded 55 gallon drum, a flashlight for sampling at night, a faceshield for handling a potentially pressurized glass bulb or a remote handling tool to reduce personnel exposure. The procedure does not provide clear guidance regarding when the normal sampling point should and should not be used. This guidance is important because the normal sampling point is connected to the radiochemistry laboratory by a dumbwaiter. Thus radioactive gases released into the sampling room could possibly enter the radiochemistry laboratory. Because of its importance, the precaution related to halting the procedure if the sampling area exceeds 20 r/hr should be inserted between Steps 6.2.3.15 and 16. Also, with respect to containment atmosphere sampling, there is no instruction concerning the activity limitation on samples being brought to the counting laboratory.
(f) Step 6.3.1.1.2 of EIP-24, Direction of Onsite Emergency Monitoring, states that emphasis should be on contamination monitoring of the face, hands and feet.
During an emergency, the first rapid survey of the persons congregated at the assembly point should attempt to determine the extent or potential for ingestion or inhalation. Under such conditions contamination on hands and feet is of lesser importance than ingestion or inhalation.
Blocking or chelating agents can mitigate the effects of an intake of radioactivity, but only if prompt action is undertaken. Also, monitoring hands and feet is second nature to monitoring personnel and does not deserve "particular"
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attention under the circumstances because it will be performed as a matter of course when time permits.
Steps 6.3.1.3, 6.3.2.3, 6.3.3.4 and 6.3.5.5 of this EIP contain a gross airborne radioactivity limitation of 4E-8 uCi/cc. These steps do not provide a frisker reading that is equivalent
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-34-to this airborne concentration or 1 MPC of radiciodines.
This information would be needed if the airborne samples were to be evaluated using a survey meter.
(g) Current revisions of EIP-46 were found in the OSC and the emergency kits. However, outdated versions of this procedure were found in the CR and TSC.
5.3 Evacuation and Accountability The subject'of evacuation and accountability has been addressed in several EIP's. The evacuation of personnel who are not part of the onsite emergency organization to their designated assembly locations is one of the steps in EIP's -14 and 15 (Site Emergency and General Emergency respectively).
EIP's -32, 33 and 34 cover the actions for local area, plant and site evacuation and accountability in that order.
Evacuation and accountability at SONGS have been based upon the protected area.
Thus personnel in the Administration and Warehouse Building, and other buildings located outside the Unit 1 and Units 2/3 protected areas, have not been considered in these procedures except for those SCE employees who are part of the onsite emergency organization.
According to EIP's -33 and 34, the Security Leader directs a supervising security officer at each protected area exit to determine those persons who have not yet left the protected area. There are no specific procedures or written guidance for accomplishing the accountability of onsite personnel.
Personnel not accounted for will be located in accordance with EIP-39, Rescue.
Infonnation developed by interviews disclosed that a security officer would be responsible for accountability at the assembly or reassembly areas during their activation.
Personnel outside the protected area who were not accounted for would be sought by one or more individuals making a " sweep" of the nonprotected area. SCE security guards at the entrances to the site record the names of all visitors (persons not assigned to work at the site on a regular basis) to the site after checking their identification and making sure they had been granted site access by an authorized individual. The visitors were not provided with any type of identifying badge and were allowed uncontrolled access to the nonprotected area. The site access process for visitors did not normally provide them with any form of emergency plan training; however, during this appraisal the licensee took the corrective action described in Section 3.2 of this report.
The Appraisal Team questioned whether the above described accountability process satisfied Item II.J.5 of NUREG-0654, Rev. 1.
This item states that licensees shall provide for accountability of all individuals onsite at the time of an emergency and ascertain the names of missing individuals within 30 minutes.
The licensee said that it was industry practice to interpret this requirement as being directed to the protected area. Also it was his understanding that the previous NRC Emergency
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-35-Preparedness Appraisals had applied the protected area to this requirement.
On November 10, 1981 the Appraisal Team Leader was provided additional information on the intent of this item by the Division of Emergency Preparedness during a telephone conversation.
Based on this additional information, " sweeping" the nonprotected areas to locate visitors who have not been specifically identified as such does not meet the intent of this requirement. The onsite visitors in the nonprotected area need a visual identification and must be recorded on a list so they can be accounted for during an emergency.
The visual identification need not be serialized so that each specific individual entering the site is traceable. The use of visual identification, recording the names of persons entering the site and provisions for " sweeping" the nonprotected areas to locate the visitors who are unaccounted for does meet the intent of Item II.J.S.
5.4 Assessment Actions The implementation of the accident assessment activities, including recommendations for offsite protective measures, is controlled by EIP-11.
The EC is responsible for the requirements contained in this procedure.
There are three EIP's involved in the process of determining the recormiendations to be made concerning offsite protective measures. EIP-22 provides for determining the source term to be used when making the dose calculations for gaseous releases. The dose calculation methodology has been recorded in EIP-23.
EIP-26 provides the guidance for the Health Physics Leader to use in making recommendations for offsite protective measures to the EC.
The three EIP's appeared to provide an adequate scheme for dose assessment and the determining of recommendations for offsite protec'tive measures.
The review of EIP-22, 23 and 26 identified the following areas where changes in these procedures could result in their improvement.
'(a) 'EIP-22
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Sect' ion 4.0'should incorporate a caution statement explaining that the use of ERMS monitors or the inside-containment monitors for estimating source terms is only possible because assumptions are made regarding the relative concentrations of noble gases and radiciodines that will be airborne in the containment atmosphere.
These assumptions are derived from source terms used for siting calculations and could be reasonably accurate or grossly inaccurate, depending upon the nature of the accident.
Section 4.0 should also indicate that the source term determination using ERMS and inside-containment monitors is intended to be most accurate during a fixed time window of time following reactor shutdown. The precaution should also explain that the source term for noble gases will
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because the photon spectrum will shift to lower energie.
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-36-Precaution 4.2 conflicts with the introductory paragraph in the Procedure, Section 6.0, because the latter requires use of all (four) methods of estimation while precaution 4.2 implies that the use of portable monitors is an alternative to the preferred use of fixed monitors.
The procedure repeatedly requires the use of the highest containment source activity estimate which is questionable because the nature of the dose rate based estimates is different than the nature of the laboratory measurement of the containment atmosphere sample.
The dose rate based ~ estimate depends on an assumed ratio of noble gases, iodines and cesiums and it will therefore be accurate only if the assumed accident occurs.
Moreover, the proportionality coefficient between detector readout and containment exposure rate is time dependent, especially for the monitors that are outside of containment.
On the other hand, the sampling may underestimate halogens and volatile solids if these species deposit on the inside surfaces of the sampling lines.
At Unit 1, this latter factor may be less important because the sampling line is of a relatively large diameter (3/4") and the line is insulated. The procedure should indicate that sampling the containment atmosphere provides a direct measurement of the radiation source quantity. After the released radioactivity becomes well mixed with the containment atmosphere and initial aerosol deposition takes place, containment atmosphere measurement may provide more realistic results than the fixed monitor. The procedure should address the advantages of each method or at least indicate periods of time or conditions when each method would be preferable.
Instruction 6.3.4 is incorrect because the highest of the instrument readings is not necessarily equivalent to the highest radioactive source estimate, since the conversion factors are approximately
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12, 17, and 474. This large difference means that the multiplication should be performed prior to determining the source quantity.
Instruction 6.5.2.3 should direct the use of the actual flow rate in the plant vent when making the source term determination.
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an alternate method.
l Instruction 6.5.1.2 should be more explicit regarding modifications to the containment leak rate.
Specifically, there should be information regarding how the containment leak rate might vary if the containment
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This is specifically recommended in NUREG-0654 Rev. 1, Appendix 1, l
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(b) EIP-23 Instruction 6.1.3 should be changed to allow the analyst to consult with the corporate meteorologist, if available, for the purpose of determining stability class in the absence of AT data. The same comment applies to the note in Instruction 6.1 The dose conversion factor for eclating the ambient ground level concentration of noble gases to a dose equivalent rate to the whole body is not appropriate. The licensee only considers the impact of Xe-133 in the gas mixture. Although Xe-133 constitutes 22% of the airborne activity, its impact on the whole body dose rate is relatively minor compared to Kr-88 and Kr-87 if releases take place within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of reactor shutdown. The EPA report EPA-520/1-75-001 recommends a dose conversion factor of 3.0 E+5 (mrem /hr)/(Ci/m3) at 4.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> after reactor shutdown. To compensate for the abundance of Xe-133 relative to other radionuclides would require a conversion factor of 1.2 E+6 rather than the 3.36 E+4 employed.
The evaluation of the dose assessment capability included observing demonstrations of dose assessment calculations by shift personnel.
The individuals performing the calculations were Health Physics Foremen or Lead Health Physics Technicians, depending upon the shift i..volved (days or nights), because these are persons the Watch Engineers said they would expect to perform this function. The Unit 1 personnel displayed a capability to perform the necessary actions and calculations to respond to the simulated conditions. The Units 2/3 personnel displayed a clear understanding of the responsibilities and authorities under the EP as well as a satisfactory knowledge about surveys using portable radiation monitoring equipment. A lack of familiarity with the locations of readouts for the plant radiological instruments and the types of measurements that are parformed by these monitors was noted. This lack of familiarity can be attributed primarily to the fact that these instruments have not yet been turned over to the Unit 2 operating staff. The limited training (about 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />) that had been received on these procedures was evident during the demonstration (e.g. transposing the sign of the exponent of the atmospheric dispersion factors which resulted in the calculated radiation doses being high by a factor of 100).
5.5 Conclusions: Emergency Plan Implementing Procedures Based on the above findings, this portion of the licensee's/ applicant's program appears to be acceptable; however, the following matters should be considered for improvement of the program:
(1) Examine Section 5.2 and make appropriate changes to the EIP's.
(2) Prepare written guidance or a procedure for use by security personnel when they account for onsite personnel during an emergency.
(3) Provide a means to identify visitors onsite but not in the protected area so that they can be directed to an assembly area during an emergency and be identified during the accounting process.
(4) Examine Section 5.4 cnd make appropriate changes to the EIP'.
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-38-6.0 Coordination With Offsite Groups 6.1 Offsite Agencies The May 1981 exercise demonstrated that satisfactory coordination existed between the licensee and offsite agencies.
As a result of that exercise, recommendations were made by FEMA (Federal Emergency Management Agency)
for upgrading the emergency response capability of offsite agencies.
The licensee has provided resources and training to accomplish this end.
The offsite agencies involved in responding to an emergency at SONGS have been provided with controlled copies of the SONGS EP's and EIP's.
It was learned during the appraisal that there is a good working relationship between the licensee and the offsite agencies which has been cultivated over the more than 10 years they have been involved in emergency planning for the SONGS site.
6.2 General Public Section 8.5 of the EP's address the subject of public information.
SCE has developed and initiated a comprehensive program for implementing this part of the Emergency Plan.
The program covers the residential sector, the business community (including hospitals and schools) and the State Parks within the Plume Exposure EPZ. The program also includes a continuing effort to inform the public.
The initial residential information effort consists of a folder distribution
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and a series of conmunity meetings. The folders contained emergency information, a map and cards that can be sent to either Orange County or the City of San Clemente informing them of special problems (e.g.
hard-of-hearing, visual impairment or need for transportation) related to the specific residence..The folder distribution, which occurred in June and August, was preceded and followed by newspaper advertisements calling attention to.the folder distribution.
Residences were also provided with business reply _ cards informing them of the folder distribution and requesting a copy of the folder be sent. Arrangements have been made for SDG&E to routinely ~ provide SCE with new residence occupation information so that a folder can be sent to the new arrival. According to the licensee, about 560 of the special problem cards have already been received by the two local governments.
About 63 community meetings will be held starting'in November, 1981. The licensee will send invitations to these meetings to all local residents-within the Plume Exposure EPZ and expects about 10 percent of the population to attend. The meetings will cover the subject matter included in the folder, a brief discussion of power plant operation, information about radiation and provide a short film titled "What If" tnat SCE has prepared. During the rirst week in November, 1981, SCE expects to mail to all residents within the Plume Exposure EPZ a copy of a newly prepared booklet titled
" Emergency Information Handbook. " This booklet discusses the subject of emergency planning associated with San Onofre and provides information about radiation and its effects.
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-29-A separate folder was prepared and sent to the business community within the Plume Exposure EPZ.
The folder included information directed to the recipient and two posters for their own use.
SCE intends to make follow-up contacts with some of the businesses (particularly schools and hospitals) in order to evaluate this part of the program.
There are four state parks and beaches within the Plume Exposure EPZ.
Posters and handout sheets prepared specifically for the beach or park have been prepared and distributed. The posters and handout sheets, i
which are color coded for a specific beach or park, provide. emergency response instructions and an evacuation map.
The handout sheets are to be handed to all those entering the park or beach. State Park and Recreation personnel reviewed and approved the content of the posters and handout sheets.
SCE has planned for a continuing effort in public information. The Orange Coast-South telephone directory,- to be distributed in May,1982, will include two pages on emergency planning related to San Onofre.
The community meetings will continue to be held on a bi-monthly or quarterly frequency primarily for the purpose of providing information to new residents There will also be an on-going program of utility bill-inserts on emergency planning.
SCE also expects to provide for periodic advertisements, possibly a card mailing, to provide additional assurance that the residents have emergency planning information.
If there are major changes in the SONGS Emergency Plan, a new mailing will be sent to all residences and businesses.
SCE is considering_
some form of sampling to provide information on the level of public information regarding emergency planning.
SCE has installed a system to alert the public of an impending notification by public authorities. This system was described in a July 24, 1981 letter to the Director of the Region V Office of the NRC. The system has been divided into five-(5) areas with a separate control center for each one. The components of the system have been tested and the sirens " growled" (actuated and innediately shut off).
Because of the proposed change in the regulations regarding the implementation date for the public warning system, SCE has delayed the final testing of the system which will include evaluating and measuring the sound level to assure satisfying the acceptance' criteria in Appendix 3 of NUREG-0654, Rev._1.
SCE still possesses the. key to actuate the five areas, SCE is consideri' g whether they should provide the appropriate n
governmental -agencies with the acttfating key prior,to the final testing.
Until such time as this system is considered-to be operational, public notification will be via police, Park Ranger and Marine use of loudspeakers in the community, at;t beaches /parksfand at~the Marine base (Camp Pendleton).
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-40-6.3 News Media
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SCE and local government, State and Federal agencies who are directly involved in the emergency planning for San Onofre have effectively coordinated their efforts with respect to the news media. This coordination is accomplished through a comittee composed of PI0's from each of the organizations. The PIO comittee is responsible for staffing and operating the ENC.
In order to accomplish their assigned responsibilities the Committee has established the positions of chairperson, ENC Media Liaison, ENC Media Briefing Coordinator and E0F/ ENC Liaison.
SCE will provide technical briefers and an Activity Recorder during emergencies to support the ENC organization.
The ENC is operated under a set of Standard Operating Procedures that have been approved by the PIO Comittee.
These procedures address the subjects of staffing, duties and responsibilities, procedures for ENC operation, facilities, equipment and administrative support. During November, 1981, these procedures will be reviewed by the Interagency Comittee that coordinates the off-site emergency planning at San Onofre.
The licensee has considered the problem of coping with rumors. Both Orange and San Diego Counties already have a telephone system for responding to rumors during various types of emergency situations. These will also be used during an emergency at the San Oncfre site.
In addition, PI0's will monitor the media presentations to identify and correct misinformation.
The PIO Comittee is presently organizing a seminar to be presented to the news media. The seminar will cover emergency planning as well as other pertinent information related to nuclear power and radiation.
The seminar is expected to be presented in January, 1982. The licensee s
noted that for many years they have been working with area news media.
In the past, the licensee has arranged for media personnel to tour the San Onofre site.
6.4 Conclusions: Coordination With Offsite Groups Basedontheabovefindings,thisportionofthelicensee's/ applicant's program appears to be acceptable.
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7.0 Drills and Exercises 7.1 Program Sections 8.1.2 and 8.1.3 of the EP's specify the criteria and frequency by which all drills and exercises shall be conducted. The requirements for implementing these Sections are contained in EIP-71, Emergency Drills.
The appraisal determined that the drills and exercises specified in EIP-71 had been conducted at or more than the required frequency.
Verification of the drills and exercises was difficult because of the condition of the records.
Drill and exercise deficiencies are
being tracked by a computer system until the deficient items are corrected.
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According to the EPC ten drills are being planned for the last quarter of 1981.
Some of these drills will include testing the ability to augment the emergency organization in a timely manner as discussed in Section 13.3.2 (page 13-1) of Supplement 3 to NUREG-0712.
7.2 Walk-Through Observations The appraisal effort included evaluating the response of selected individuals to emergency situations postulated by various NRC team members. The responses were primarily evaluated by comparing them to the EPs and EPIPs applicable in plant procedures.
Control room, dose assessment, post accident sampling, offsite and in-plant monitoring and Fire Brigade personnel were included in this evaluation effort. The results of these walk-throughs have been incorporated into the previous paragraphs of this report.
7.3 Conclusions: Drills and Exercises Based on the above findings, this portion of the licensee's/ applicant's program appears to be acceptable; however the following matter should be considered for improvement of the program:
Provide an improved system for the maintenance of records associated with drills and exercises.
8.0 Exit Interview On November 6, 1981 an exit interview was held with the licensee / applicant for the purpose of discussing the preliminary findings of the appraisal.
Those licensee personnel and their contractor representatives who attended the meeting have been identified in Attachment A to this report. The following NRC and Appraisal Team members were present:
S. A. Schwartz, Deputy Director, Division of Emergency Preparedness; F. A. Wenslawski, Chief, Region V Reactor Radiation Protection Section; R. F. Fish, Region V Emergency Preparedness Analyst and Team Leader; John Sears, Emergency Planner; M. Cillis, Region V Radiation Specialist and Team Member; K. Scown, Region V Emergency Preparedness Coordinator and Team Member;
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-42-A. E. Desrosiers, Battelle Pacific Northwest Laboratories' Senior Research Scientist and Tean Member; G. J. Laughlin, Battelle Pacific Northwest Laboratories' Research Scientist and Team Member. The findings were discussed in terms of the seven (7) major areas of the appraisal.
The finding related to the possible inability of the Unit 1 interim, extended range stack monitor for noble gases to provide the required information for emergency plan implementation was identified as a significant deficiency.
In addition the finding concerning the ability to account for all individuals onsite at the time of an emergency was also discussed as a possible significant deficiency; however, following a discussion, it was decided to obtain additional NRC guidance before declaring this a significant deficiency. Section 5.3 of the report discusses the additional NRC guidance.
On November 10, 1981 the Appraisal Team Leader provided this information to Mr. W. C. Moody by telephone. Five of the findings were identified as being in an "open" status because intended actions had not been completed.
Eight items were identified as matters that should be considered for improving the program. During this meeting licensee personnel asked questions and made some statements in an effort to clarify the findings.
With respect to the Unit 1 stack monitor for noble gases, the licensee requested time for them to discuss this item and suggested they contact Region V by telephone on November 9, 1981 with proposed corrective actions.
On November 9 W. C. Moody, Manager of Nuclear Licensing, D. P. McCloskey, Supervisor of Emergency Preparedness, and J. Albers, Radiological Engineer, discussed by telephone their suggested corrective actions related to the Unit 1 stack monitor for noble gases, and the proposed implementation schedule, with F. A. Wenslawski and R. F. Fish of the NRC Region V Office.
Following this discussion the Region V Administrator sent a November 16, 1981 letter to the Southern California Edison Company acknowledging the proposed corrective actions and the expected completion times.
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LAPPENDIX A'
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Individuals ContEcted I.
Licensee Personnel
SONGS B. Katz, Station Technical Manager R. Santosuosso, Station' Maintenance Manager'
- K. Barr, Health Physics Manager
- K. Hadley, Security Supervisor S. Medling, Health Physics Supervisor, Unit 1 R. Grey, Health Physics Supervisor, Units 2/3 G. Peckham, Dosimetry Supervisor
- J. Albers, Radiological Engineer J. Barrett, Radiological Engineer S. Folsom, Radiological Engineer E. Bennet, Health Physics Foreman, Unit 1 S. Jones, Health Physics Foreman, Units 2/3 J. Scott, Health Physics Foreman, Units 2/3 K. Darcy, Senior Health Physics Technician K. Brooks, Senior Health Physics Technician G. Goff, Health Physics Technician J. Mortenson, Chemistry Foreman, Unit 1 A. Prosser, Chemistry Foreman, Units 2/3 M. Chang, Chemistry Technician, Unit 1 B. Rice, Chemistry Technician, Unit 1 S. Hock, Chemistry Technician, Unit 1
- D. McCloskey, Emergency Planning Coordinator
- C. Seward, Industrial Safety and Fire Protection Supervisor
- D. Bonnette, Emergency Planner
- G. Noel, Training Administrator C. Bostrom, Training 'nstructor R. Garcia, Training In;tructor R. Dickey, Training Instructor H. Bentz, Watch Engineer, Unit 1 J. Schramm, Watch Engineer, Unit 1 J. Kroeger, Watch Engineer, Unit 1 G. Tilton, Watch Engineer, Unit 1 T. James, Watch Engineer, Units 2/3 M. Lisitza, Watch Engineer, Units 2/3 B. Brown, Watch Engineer, Units 2/3 D. Lokker, Watch Engineer, Units 2/3 M. Trillo, Watch Engineer, Units 2/3 K. Eckman, Watch Engineer, Units 2/3 G. Bellomy, Watch Engineer, Urits 2/3 K. Meagher, Control Operator, Units 2/3 M. Jones, Control Operator, Units 2/3 J. Moore, Control Operator, Unit 1
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D. Barney, Auxiliary Control Operator, Unit 1 V. Fisher, Supervisor of Plant Coordination, Units 2/3
- R. Bonnet, Site Security Coordinator, Unit 1 J. Atwell, Security Officer B. Bunting, Security Officer General Office R. Dietch, Vice President, Nuclear Engineering and Operations J. Haynes, Manager, Nuclear Operations
- K. Baskin, Manager, Nuclear Engineering, Safety and Licensing
- W. Moody, Manager, Nuclear Licensing
- H. Ottoson, Manager, Nuclear Engineering and. Safety
- D. Pilmer, Supervisor, Health Physics and Emergency Planning E. Donovan, Supervisor, Nuclear Analysis
- G. Allen, Nuclear Engineer
- D. Evans, Nuclear Engineer
- P. Dooley, Emergency Planning Coordinator, HPEPG F. Massey, Manager, Nuclear Affairs J. Wyatt, Executive Assistant R. Hull, Supervisor, News Bureau D. Barron, Senior Corporation Connunications Representative G. Cramer, Nuclear Engineer J. Hauck DID), Medical Director
- Denotes those present at Exit Interview on November 6, 1981.
II. Other Personnel J. Prucker, Design Engineer, Bechtel III. Personnel Present at November 6, 1981 Exit Interview Only SCE_
H. Ray, Station Manager P. Croy, Manager, Configuration Control and Compliance W. Zint1, Acting Training Manager G. Mcdonald, QA/QC Supervisor, Unit 1 P. King, Supervisor, Operations QA/QC, Units 2/3 D. Duran, Radwaste Supervisor T. Garven, Lead QA Engineer, Units 2/3 S. Marsh, Meteorologist S. Garry, Radiological Engineer W. Marsh, Compliance Engineer-E. Gault, Compliance Assistant R. Sielden, Others
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K. Highfill, President,' ASTA Inc.
S. Foster, Emergency Planner, PG&E Company
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APPENDIX B Emergency Plan Implementing Procedures Procedure No.*
Title EIP-11 Recognition and Classification of Emergencies EIP-12 Unusual Event EIP-13 Alert EIP-14 Site Emergency EIP-15 General Emergency EIP-16 Notifications EIP-17 Activation and Operation of Emergency Centers and Organizations EIP-18 Notification of Additional Emergency Support Personnel EIP-22 Source Term Determination EIP-23 Dose Assessment EIP-24 Direction of Onsite Emergency Monitoring EIP-25 Direction of Offsite Emergency Monitoring EIP-26 Recommendation for Offsite Protective Measures EIP-27 Emergency Environmental Monitoring EIP-31 Emergency Exposure Control EIP-32 Local Evacuation and Accountability EIP-33 Plant Evacuation and Acc Jntability EIP-34 Site Evacuation and Accountability EIP-35 Traffic and Access Control EIP-36 Thyroid Prophylaxis EIP-37 Fire Fighting EIP-38 Contaminated Injury EIP-39 Rescue EIP-41 Onsite Monitoring EIP-42 Offsite Monitoring and Sampling EIP-43 Sample Coordination During an Emergency EIP-44 Emergency Contamination Control EIP-45 Personnel and Vehicle Monitoring EIP-46 Onsite Sampling EIP-51 Record Keeping EIP-62 Activation of the Recovery Organization EIP-71 Emergency Drills EIP-72 Emergency Kit Inventory EIP-73**
Emergency Plan Maintenance EIP-74 Emergency Plan Training (NE&ODepartgent Emergency Support Organization Procedures Procedure Manual
- Licensee procedure. designation is S01-VIII-XX for' Unit 1 EIP's and S023-VIII-XX for Units 2/3 EIP's. The Unit 1.EIP's are a-duplicate of those for Units
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2/3.
- This procedure was not reviewed because it had not yet been issued.
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GENERATING STATION RADIOLOGICAL EMERGENCY
INSTRUCTIONS CERTIFICATION OF ACKNOWI.EDGEMENT Upon hearing the Radiological Siren (
)
take the following action:
NON ESSENTIAL PERSONNEL:
1.
Listen for the P.A.
announcement of conoition of emergency 2.
In all cases immediately after the siren alarm sounds, proceed to:
UNIT 1:
Administration Warehouse Shop (AWS) Building, north end receiving entrance.
UNITS 2&3:
Edison personnel anu visitors:
Office Building - 2 (OB-2)
CONSTRUCTION PERSONNET.:
As designated ley your Tespective emergency plan.
Upon arrival at the Assembly Area report to your supervisor or company representative for accountability.
4-Remain calm, stay alert, a r.a await furtner instructions.
ESSENTIAL EMERGENCY RESPONSE PERSONNEL:
1.
Report immediately to your respective Emergency Response C ent e r (TSC, OSC).
NO*ES:
1.
This is on each yellow, Blue, and Red Bacge.
2.
Do not attempt to drive away from Site.
Go to Administration Warehouse Shop (AWS) Builaing, North End Receiving Entrance, or Office Building 2 (OB-2) depending on your location.
I have read and understand the above instructions
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PRINT NAME SSAN SIGN NAME COMPANY 1728A Enclosure 1, Page 1 of 2
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Dnergercy 2. Cont lboc Oper annconces a problem in the area Gmeral Dnertyancy Mave directly to 1. Personnel accountability Plant Ciren the evacmticri site
Ibdiological (See map attached 2. Follow Directions of the Er*3 neer or the i
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!btify the Control follow instructions of the i
Ibom (56201)
Watch DrJ neer 1.Ibport to Ibalth Ibliow !!P or First Aid Minor Injury
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if rotentially contaminated munds; contamimted follow the instructions of
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2.Ibport to First first aid personnel for Aid non-contaminated wounds.
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