IR 05000206/1988007
| ML13316B883 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/29/1988 |
| From: | Fish R, Good G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML13316B881 | List: |
| References | |
| 50-206-88-07, 50-206-88-7, 50-361-88-07, 50-361-88-7, 50-362-88-07, 50-362-88-7, NUDOCS 8804190134 | |
| Download: ML13316B883 (11) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos. 50-206/88-07, 50-361/88-07 and 50-362/88-07 Docket Nos. 50-206, 50-361 and 50-362 License Nos. DPR-13, NPF-10 and NPF-15 Licensee: Southern California Edison Company P. 0. Box 800 2244 Walnut Grove Avenue Rosemead, California 91770 Facility Name:
San Onofre Nuclear Generating Station, Units 1, 2 and 3 Inspection at:
San Onofre Site, San Diego County, California Inspector:
I?3I G-M. Go,
'Emergency Preparedness Analyst Date Signed Approved by:
py/ff
/WY" F. Fish, Chief Date Signed Emergency Preparedness Section Summary:
Inspection on March 8-11, 1988 (Report Nos. 50-206/88-07, 50-361/88-07, and 50-362/88-07)
Area Inspected:
Unannounced, routine emergency preparedness inspection in the area of Operational Status of the Emergency Preparedness Program. Inspection procedure 82701 was utilize Results:
One violation of NRC requirements was identified for failure to conduct an independent review of the emergency preparedness program at least every 12 month PLR ADOCK 05000206 QDCD
DETAILS 1. Persons Contacted J. Barnett, Shift Superintendent, Units 2/3 0. Bennette, Supervisor, Station Emergency Planning 0. Dack, Quality Assurance Engineer P. Dooley, Supervisor, Emergency Planning E. Echevarria, Shift Superintendent, Unit 1 M. Lisitza, Shift Superintendent, Units 2/3 D. Mutzinger, Quality Engineer D. Peacor, Manager, Station Emergency Planning M. Powell, Shift Superintendent, Unit 1 R. Rosenblum, Manager, Quality Assurance S. Wylie, Administrator, Training Administrative Support Services 2. Operational Status of the Emergency Preparedness Program-(Inspection Procedure 82701)
a. Changes to the Emergency Preparedness Program To determine if any changes to the emergency preparedness program had been made which could affect the overall state of emergency preparedness, the inspector addressed the following areas:
1)
changes to the emergency response facilities (ERFs); 2) management control of the emergency preparedness program; 3) changes to the Emergency Plan Implementing Procedures (EPIPs); and, 4)
miscellaneous activities being conducted by the emergency preparedness organizations (corporate and station).
Since the last inspection of this area (January 1987), the following changes to the ERFs have been made or are scheduled to be mad Minor changes have been made to the functional layout of both Operations Support Centers (OSCs).
o Specific ingress and egress routes have been established for the OSC (See Open Item 50-206/87-15-03 in NRC Inspection Report Numbers 50-206/88-05, 50-361/88-05 and 50-362/88-05).
The two Technical Support Centers (TSCs) are being re-designed to include a central conference table to expedite the flow of information between key TSC personne The new design will require a wall to be removed in the Unit 1 TS Installation of a new computerized Interagency Telephone System (see Open Item 50-206/87-01-01 in the aforementioned NRC Inspection Report).
The above mentioned changes are considered to be improvements and should enhance the functioning of the ERF Since this area was last inspected, three notable changes have occurred which affect the management control of the emergency preparedness program. First, Station Emergency Planning (SEP) has been moved into Operation SEP personnel stated this has significantly increased the support provided to SEP. Second, Nuclear Affairs and Emergency Planning (NA&EP) (corporate emergency planning) has a new manager. The previous manager retired in July 1987. The new manager has demonstrated a firm commitment to the program and has made a concerted effort to increase the coordination between NA&EP and SEP. Third, the emergency planning groups have developed an Emergency Plan Drill Controller Program in an effort to improve the conduct and evaluation of drills and exercise Problems in this area were identified during the 1987 annual emergency exercise (see details Sections 7-9 in NRC Inspection Report Numbers 50-206/87-15, 50-361/87-14 and 50-362/87-16).
The Region V Emergency Preparedness Section performs an annual review of changes to the licensee's EPIP This review was accomplished in the office, prior to this inspection. The following procedures were reviewed:
S0123-VIII-0.301, TCN 2-5 (Temporary Change Notice), "Offsite/Onsite Communications Tests" 50123-VIII-0.302, TCN 0-6, "Surveillance of the Onsite Emergency Evacuation System" SO123-VIII-10, TCN 4-1, "Emergency Coordinator Duties" S0123-VIII-20, TCN 3-1, "Emergency Planning Coordinator Duties" 50123-VIII-30.1, TCN 5-1, "Shift Communicator Duties" S0123-VIII-80, TCN 4-1, "Emergency Group Leader Duties" Manual of Emergency Events, Revision 2.01 The questions/comments which were generated as a result of the review of these procedures were discussed with NA&EP and SEP personnel during this inspection. The inspector's questions and comments were satisfactorily addressed during these discussion The most significant issue raised by the procedure review involved procedural references to time requirements for NRC notifications (10 CFR 50.72(a) and (c)).
50.72(a) states in part that for initial notifications, "The licensee shall notify the NRC immediately after notification of the appropriate State or local agencies and not later than one hour...". The inspector found that although 50123-VIII-30.1 had been revised to include these requirements, S0123-VIII-10 still reflected previous NRC requirements which stated that the NRC should be notified within an hour of event declaratio In addition, the inspector found that a0123-VIII-lt and 50123-VIII-30.1 do not reflect the requirements of 50.72(c).
50.72(c) states in part that an immediate, followup notification is required for "any change from one Emergency Class to another".
The
licensee's EPIPs make no distinction between initial classifications and reclassification Licensee personnel acknowledged these inconsistencies and agreed to revise the applicable procedure Pending the procedure revisions and subsequent training of appropriate emergency response personnel, this matter will be tracked as open item (50-206/88-07-01)..
The inspector was informed of the following miscellaneous activities being pursued by emergency planning personnel:
o Re-assignment of source term responsibilities from Health Physics to Chemistry o
Enhanced notification agreements with the railroad and California Highway Patrol o
Presentations on earthquake awareness o
Developing methods to increase realism in drills and exercises All of the above mentioned changes are considered to be improvements to the licensee s emergency planning progra b. Training The inspector discussed changes to the EP training program, verified that training was being conducted and interviewed a small sample of selected individuals to determine whether they had been properly trained and understood their emergency responsibilitie The inspector was informed that significant changes were being made to the EP training program. The academic portion of the EP training program (computer based training) is being divided into the following three parts:
1) Emergency Response Personnel Training (given to Health Physics Engineers, Chemistry Technicians, Craft Personnel, Security Officers, etc.)
2) Nuclear Emergency Response Team Support Personnel Training (given to Shift Communicators, Emergency Services Officers, etc.)
3) Nuclear Emergency Response Team Leader Training (given to Emergency Coordinators, Emergency Planning Coordinators, Health Physics Leaders, etc.)
The above training will be conducted in a phased fashion such that members of the emergency organization falling into part 3 must master the objectives of parts 1 and 2 first, and members in part 2 must master the objectives of part 1 first. The inspector surveyed the objectives and content of each of the three parts and found no apparent problems. The inspector noted that the test questions appeared to be more difficult than in the past. Individuals taking
this training will not be allowed to challenge certain portions of the training as they have done in the past. Training personnel stated that it will take more time to complete the training and, for certain emergency positions, training can not be completed in one day, as it was in the past. In addition, a passing score of 80%
must be achieved. The inspector also concluded that the computer graphics were more educational and interesting. The new computer based training should be completed by about April 1, 198 Implementation will depend on the acquisition of more personal computers and a revision of Training Program Description ERT-By reviewing computer records, the inspector verified that training was being conducted in accordance with applicable procedures. Since about mid-1985, EP training has been conducted at the time the individual completes his/her annual Red Badge Training. This system has worked well for the licensee. Since certain emergency personnel will no longer be able to complete their EP training and Red Badge Training on the same day, the licensee will have to monitor the situation more closely to assure that personnel do not become delinquent in their EP training. Management controls are in place to monitor and alert personnel of training status; however, there are currently 1212 individuals requiring EP trainin To test the effectiveness of part of the licensee's EP training program, the inspector interviewed four Shift Superintendents (SSs)
(two from Unit 1 and two from Units 2/3).
Shift Superintendents were chosen because in an emergency they would be required to act as the Emergency Coordinator (EC) until relieved by the Station Manager (or his designated alternate). In addition to being asked general questions about their responsibilities as EC, each SS was asked to classify four different (unrelated) emergency events and provide protective action recommendations (PARs) for onsite personnel and the general public. The results of the interviews are as follows:
General Questions o
2 of 4 SSs elected to refer to S0123-VIII-10, "Emergency Coordinator Duties" before describing their main responsibilities (e.g., classification, notification, PARs) as E o 1 of 4 SSs thought he had 15 minutes to declare an event once the classification was determined (S01(23)-VIII-1 gives the EC 15 minutes to determine the classification after recognition of an abnormal occurrence.)
o all SSs thought they had one hour to notify the NR o all SSs thought they had one hour to notify the NRC when there is a change from one emergency class to anothe of 4 SSs were unsure of the definition of "source term".
2 of 4 SSs did not know what the term "affected sectors" mean Classifications o
2 of 4 SSs classified all four events correctl o 3 of the 16 events presented were misclassified A Site Area Emergency (SAE), Tab A-3-2 from S023-VIII-1,
"Recognition and Classification of Emergencies", was misclassified as an Unusual Event (UE) based on the "G" Tab (Miscellaneous).
(Implications: A mandatory plant/beach evacuation would be directed for the SAE, but not for the UE.)
i A UE, Tab G-1-2 from S01-VIII-1, "Recognition and Classification of Emergencies", was misclassified as an Alert based on Tab A-2-2. Tab A-2-2 was an inappropriate Tab for the situation presente (Implications:
Since the Tab used did not apply to the situation, the event would have been misrepresented to the offsite agencies, who rely on descriptions provided for each Tab event. Also, unnecessary evacuations would have been directed.)
ii An SAE, Tab A-3-2 from S01-VIII-1, was misclassified as an Alert based on Tab A-2- (Implications:
Evacuations are optional at the Alert level and mandatory at the SAE level.)
PARs o
2 of 4 SSs did not consider a beach evacuation at the Alert leve o 1 of 4 SSs did not go to the additional PARs (Attachment 3 of S0123-VIII-10) at the General Emergency classificatio The above results represent a slight decline from similar interviews conducted in 1987 (see details Section 6 in NRC Inspection Report Numbers 50-206/87-04, 50-361/87-05 and 50-362/87-06).
Based on that decline, the inspector suggested that the licensee would benefit if they were to perform an evaluation of the EP training provided to SSs/ECs and determine what could be done to improve the result This matter will be tracked as open item (50-206/88-07-02). Independent Review/Audit This portion of the inspection was conducted to determine whether the licensee had performed an independent review of its emergency preparedness program at least every twelve months as required by 10 CFR 50.54(t).
To accomplish this, the inspector held discussions with Quality Assurance (QA) personnel and reviewed QA
reports/documentation. The following documents were provided to the inspector:
i. SCE Quality Assurance Audit Report SCES-043-86, dated December 1, 1986, conducted September 3 - November 12, 1986, covering the period September 1985 - October 198 ii. A compilation of 13 Audit Plan Items (scope) to be used to generate SCE Quality Assurance Audit Report SCES-054-87, approved December 10, 1987, covering the period October 1986 November 198 iii. Audit findings for 5 of the audit plan items mentioned in (ii)
abov A review of the above documents disclosed that SCES-054-87 was 2-3 months behind schedule and that the scope of the 1987 audit was approximately one-half of what it had been for the 1986 audit, since SCES-043-86 had 22 audit plan items and SCES-054-87 had only 13. QA personnel agreed that the 1987 report was overdue and stated that the delay had occurred because personnel tasked with completing the audit had been given other assignments which took priorit Regarding the scope of the audit, the inspector was informed that the 13 audit plan items were considered to be the "minimum" audit scope and that additional audit plan items might be added before the audit was completed. Licensee QA personnel solicited from the inspector some additional audit plan items which could be used for this and future audits. In response, the inspector pointed out that all of the 13 audit plan items approved for the 1987 audit had been included in the 1986 audit and suggested that other areas addressed in the EP be audited. The inspector suggested that the development of a matrix, to be completed over a period of time, would be helpfu This was previously recommended to the licensee early in 1986 (NRC Inspection Report Numbers 50-206/86-01, 50-361/86-01 and 50-362/86-01).
During the exit interview conducted on March 11, 1988, the inspector expressed her concerns regarding the timeliness and scope of the emergency preparedness audit. The hazards of having a pattern develop were also mentione On March 15, 1988, the Manager of NA&EP called the Region V Emergency Preparedness Section Chief to arrange for a conference call on March 16, 1988. The purpose of the conference call was to give the licensee's QA Manager an opportunity to present additional, pertinent information that had not been provided to the inspector during the inspection. The QA Manager stated during the conference call that the matter of the overdue audit was technically a violation. However, he indicated that credit could be given (per 10 CFR Part 2, Appendix C) because SCE had previously identified and documented the problem. The QA Manager also stated that the Institute of Nuclear Power Operations (INPO) had performed an audit of the emergency preparedness program in August 1987. The INPO report was issued in October 198 With the assistance of J. Tatum, Resident Inspector, the documentation referred to by the QA Manager was obtained and telefaxed to the Region for review. These documents included Corrective Action Request (CAR) SO-P-1077, dated November 12, 1987, and Problem Review Report (PRR) GO-081-87, dated December 30, 198 Responses for each document were also supplied. CARs are more serious findings than PRR CARs characterize problems that have already occurred, whereas PRRs characterize areas where there could be problems in the future (i.e., minor program deficiencies).
The subject of the CAR was "Delinquent Unit 1 Technical Specification Audits". The CAR identified approximately 41 Unit 1 Technical Specification (TS) provisions that had not been audited within 12 months. Block 10 of the CAR, "Actions to Resolve Problems," stated the following:
"See attached Letter of Understanding on definition of the term
"Provision".
The Manager of Nuclear Safety, the Manager of Licensing and the Manager of QA have jointly concurred that the term "Provision" means Technical Specification (T/S) Section Heading. Therefore, since all T/S headings for all three units were audited within the historical 12 month interval, no administrative noncompliance is assessed to exist. Although a more extensive audit effort was performed in the past, the audits, in some areas, were reduced to T/S minimums where little value was being gained."
Block 13 of the CAR, "Cause," stated the following:
"Previous conservative interpretation of the term "Provision" which was utilized, lead (sic) to the appearance that requirements were not being met."
Block 15 of the CAR, "Action to Prevent Recurrence," stated the following:
"None, since definition of "Provisions" is being met."
Although the subject of the CAR is somewhat similar in nature to the overdue emergency preparedness audit, the above responses do not resolve the problem, nor would they prevent recurrence. It should be noted that the emergency preparedness audit is not one of the TS audits addressed in the CA The subject of the PRR was "Master Audit Schedule implementation deficiencies". The PRR identified 6 audits that were not yet completed, and the due dates on the Master Audit Schedule (MAS) had not been met. The PRR also identified 10 audits that were completed after the MAS due date Further discussions with QA personnel on March 16, 1988 disclosed that 40 of the 94 audits listed on the MAS had been sampled during the audit that produced the PRR (Audit Report SCE-27-87). This computes to a 43% sampling of the MAS audits. Therefore, the PRR was based on 15% of the sampled audits being incomplete and overdue, and 25% of the sampled audits complete
but overdue. The emergency preparedness audit was not one of the sampled audits. However, it is listed on the MAS. After the PRR was issued, the rest of the audits were checke The following information was provided in the response to the PR "Audits not yet completed are in progress and expected to be completed by February 19t Efforts to comply with the Master Audit Schedule requirements in 1988 include:
1) reorganizing the site QA section and specifically dedicating personnel to audit )
initiated Propose Change No. 176 to Unit 1 Technical Specification, which will allow audit personnel to perform audits on a schedule and to a level of detail commensurate with past experience and consistent with the practice in other area ) The Manager of Nuclear Safety, the Manager of Licensing and the Manager of Quality Assurance have provided interpretating Technical Specification "Provision" in response to Corrective Action Request SO-P-1077. This provides new direction to Site QA T/S audit activities."
Upon review of the PRR, Region V personnel concluded that:
1) the PRR did identify a problem in completing audits and is more apropos than the CAR; 2) the late emergency preparedness audit was not an isolated case; 3) the February 19, 1988 target date was not met in the case of the emergency preparedness audit, and; 4) the corrective actions would not necessarily prevent this situation from occurring agai Additional, pertinent information surfaced during the March 16, 1988 telephone discussions with QA personne QA personnel stated that they are required to provide the QA Manager with a quarterly status (backwards glance) of audits scheduled during the quarter. QA personnel stated that as of March 16, 1988, the formal report for the last quarter of 1987 had not yet been provided to the QA Manager. The due date for the emergency preparedness audit was December 30, 1987. According to licensee personnel, the delay in completing the audits is directly attributed to diverted manpowe A Design Verification audit has been ongoing and has taken much more time than originally anticipated. The.current target date for completion of the emergency preparedness audit is April 1, 198 On March 16, 1988, the licensee issued another PRR (SO-066-88).
The subject of this PRR is "Completion of Audits by Required Due Date as Identified in the Units 1, 2 and 3 Technical Specifications (T/S)."
This PRR identifies 4 TS audits in 1987 that have not been completed and have gone beyond the required 12 month due date. The following action requested (corrective action) is provided on the PR "Provide a report or "tickler system" that would identify audits that are coming due within a 60 day time frame."
From a "management" standpoint, this would appear to be more viable than monitoring progress after the fact, when audits might already be lat Based on the Region's review of all of the above information, including that provided during the telephone discussions, the Region has determined that the requirements of 50.54(t) mentioned in the first paragraph of Details Section 2.c have not been met. Further, credit for self-identification, as provided by 10 CFR 2, Appendix C, does not appear to be appropriate in this case because adequate corrective action was not taken until after the issue was raised by the NRC. This violation will be tracked as open item (50-206/88-07-03).
3. Exit Interview An exit interview was held on March 11, 1988, to discuss the preliminary findings of the inspection. The attachment to this report identifies the licensee personnel who were present at the meeting. In addition to the inspector, Mr. J. Tatum, Resident Inspector, represented the NRC. During the exit interview, the inspector stated that it appeared there were no violations of NRC requirements identified. The inspector summarized the findings described in Section 2, except for the information obtained subsequent to the site visit. Regarding the emergency preparedness audit, during the exit interview, the Site QA Manager stated that the audit would be completed by mid-April, 1988. Subsequent to the inspection, the target date was moved up to April-1, 1988. With respect to the scope of the emergency preparedness audit, the Site QA Manager stated that the scope of the audit had been reduced, consistent with a Systematic Assessment of Licensee Performance (SALP) Category 1 ratin The Corporate QA Manager was subsequently informed by the NRC that it was inappropriate for the licensee to use the SALP rating as a means to reduce its audit load. The Corporate QA Manager agreed. The possibility of the failure to complete the QA audit of the emergency preparedness program being classified as a violation of 10 CFR 50.54(t) was discussed with the licensee's emergency planning personnel during a telephone call on March 15, 198 ATTACHMENT EXIT INTERVIEW ATTENDEES K. Bellis, Manager, Nuclear Affairs and Emergency Planning D. Bennette, Supervisor, Station Emergency Planning D. Dack, Quality Assurance Engineer K. de Lancey, Emergency Planning Engineer P. Dooley, Supervisor, Emergency Planning R. Krieger, Manager, Operations C. McCarthy, Jr., Vice President and Site Manager H. Morgan, Station Manager D. Peacor, Manager, Station Emergency Planning D. Schone, Manager, Site Quality Assurance J. Shipwash, Supervisor, Compliance M. Short, Manager, Nuclear Training G. Vaslos, Quality Assurance M. Wharton, Assistant Technical Manager S. Wylie, Administrator, Training Administrative Support Services M. Zenker, Compliance Engineer 0II 0II