IR 05000206/1989012

Insp Repts 50-206/89-12,50-361/89-12 & 50-362/89-12 on 890320-24.No Deficiencies or Violations Noted.Major Areas Inspected:Previous Insp Findings,Followup of Licensee Event & Status of Emergency Preparedness Program

ML20246C255
Person / Time
Site:	San Onofre
Issue date:	04/19/1989
From:	Fish R, Prendergast K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20246C247	List: IR 05000206/1989012 ML20246C244
References
50-206-89-12, 50-361-89-12, 50-362-89-12, NUDOCS 8905090305
Download: ML20246C255 (6)

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t U. S. NUCLEAR REGULATORY COMMISSION-

REGION V

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'l t Report Nos.,50-206/89-12, 50-361/89-12, and' 50-362/89-12

Docket Nos-50-206, 50-361, and 50-362

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' License Nos.

OPR-13. NPF-10, and NPF-15

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f e4 Licensee:

Southern California Edison Company

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P. O. Box 800 J

2244 Walnut Grove Avenuei Rosemead, California 91770

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Facillty Name: San:Onofre. Nuclear Generating' Station,. Units 1, 2, and 3

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Inspection.at: San Onofre Site, San.Diego County; California

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' Inspection Conducted: March 20-24, 1989 Inspector:

M ivi hM tl Fc/ T'I -

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M.' Prendergast Date Signed.

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, Emergency Preparedness Analyst

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Approved by:

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N /7 7-R.F. Fish", Chief Dhte' Signed.

EmergencyPrepar'ednessSeciion

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Areas Inspected:

Unannounced routine' inspection including:

actions on previous inspection; findings, follow-up of a licensee event and the status of the Emergency Preparedness Program.

Inspection procedures 82701,.92701, and 93702 were covered.

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Summary:,

No deficiencies or v.iolations of NRC requirements were identified.

Some' areas for improvement regarding Shift Superintendent training were noted

.'.and discussed in Section 4..

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DETAILS

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Persons Contacted

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• C. McCarthy, Vice President

• H. Morgan,~ Station Manager.

• K. Bellis, Manager, Nuclear Affairs and Emergency Planning (NA&EP)

• D. ' Peacor, Manager, Emergency Preparedness

• R. Plappert,' Compliance Manager

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• L. Simmons, Administrator, Units 1,2,3 Operations Training'

S. Wylie, Administrator, Support Services,

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B.-Reed,' Emergency Planning Engineer

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• J. Wallace Emergency Planning Engineer.

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l C. Anderson, Emergency Planning Specialist

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• K. de Lancey, Emergency Planning Engineer L

~*G. Buzzelli, Emergency Planning Engineer l

• Denotes those present at the exit. interview.

2.

Action Cn Previous Inspection Findings (Inspection Procedure'92701)

.;(Closed) Open Item'88-05-01, Examine conduct,' scope.and critique of future environmental monitoring drills.

A critique from a September 13,.

1989 Environmental Monitor!ng Drill.was examined and noted to contain appropriate scope and objectives for the drill.

The objectives included;-

q activation and. deployment, sample collection and identification, sample j

screening and preparation, record. keeping, and communication. The

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l objectives for the drill were compared to the requirements'.in the Emergency Plan for environmental monitoring. drills"and were considered

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-adequate.

The cr_itique document was also noted to contain areas for l

improvement whichLare to-be included in the newly established Emergency Preparedness Tracking -System or the tracking. system used by _the site.

This item is considered closed..

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(Closed) Open Item 88-07-02, Evaluate Shift Supervisor / Emergency Coordinator Emergency. Plan training to determine how toLimprove. interview results.

This area was' examined and the licensee has'made-improvements 1 to their computer based training program by' including scenario type l

questions lin the annual requalification training for the control' room staff.

In addition, classification of emergency events, protective action recommendations and notifications were also stated to have'been

added to a portion of the simulator training. ' At present', the licensee is '

l also considering performing interviews with control room personntl, similar to the interviews used by the NRC, to determine areas for improvement and to improve the control. room staffs familiarity with their Emergency Plan implementing procedures.

This item is considered closed.

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3.

Onsite Follow-Up of Licensee Event

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Follow-up;on'a February 9, 1989 event involving Unit 2.'

During reactor start up on February 9, the shift crew questioned the operability of the core' protection calculators (CPCs).

Following a discussion of' thel u

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situation it was concluded that the CPCs would operate when the reactor

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went critical.

The reactor went critical at 0455 PST'and reached 10E-4

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>i percent power.

It was again noted that the CPCs were inoperable and the operators, realizing their previous assumption regarding the CPCs was

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incorrect, initiated a reactor shut down in accordance,with Technical..

j Specification (TS) 3.3.1.

As a result of their concern to shut down the l

reactor expeditiously, the operators failed to bypass the control element

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assembly calculators which provide rod position input to the core

protection calculators.

At 0510 PST, the reactor tripped due to reactor j

trip signals received from the CPCs.

All control rods fully. inserted and l

other systems functioned as required.

l The review of the documentation surrounding this event indicates that the CPCs were actually operable, but the antcunciators/ alarms'may have been inoperable.

During the Post Trip Review, the licensee concluded that they may have been in an unusual event for approximately 5 minutes,-

pursuant to the conditions listed in S023-VIII-I, Tab D.

Tab D requires an unusual event to be declared upon commencement of plant shut down pursuant to TS 3.3.1..

Technical Specification 3.3.1, Reactor Protective.

Instrumentation, requires all 4 CPCs to be operable in modes 1 and 2.

The licensee made a conservative decision and notified the Headquarters Operations Officer that they may have been in an unusual event condition from 0500 to 0505 PST.

They also notified NRC Region V and appropriate state and local agencies.

The unusual event only applied while in mode 2, from 0500 to 0505, and was terminated when.the reactor tripped and.

entered mode 3.

According to licensee personnel, the control room: staff was busy responding to the reactor trip and it wasn't until later that they determined they may have been in an unusual event condition.

The licensee's actions regarding' classification of the event and'

responding to the reactor trip appeared appropriate.

However, during the review of the classification procedures, it was noted that a declaration'

of one of the four emergency classes may'not be required by the

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procedure if the condition has been corrected prior to determining they

were in an emergency event.

The same conclusion was also observed during the interviews with the Shift Superintendents.

During the interviews,

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the operators stated, if they realized they met the criteria for; one of I

the 4 emergency classes in their classification procedures and the problem had been corrected, they,would notify plant management and plant management appeared to have the option to declare an' emergency event.

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most cases it appears the NRC would have already been apprised of'any significant event in accordance with 10 CFR 50.72.

Plant Management would also make the notification to city officials if it was required.

Because this was different than previous guidance in this area, NRC Headquarters was contacted for guidance on this type of situatior..

According to Headquarter's guidance, if a classifiable event was l

corrected prior to the declaration of an emergency event, the licensee j

should contact the Headquarters Duty Officer and declare and terminate

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the event in the same phone call.

This subject was also discussed during the exit interview and the licensee' stated, they'will examine their-procedures to determine if they require revision to be in accordance with s

the guidance from NRC Headquarters on this matter.

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4.

Operational Status of the Emergency Preparedness Program (82701)

A.

Training The inspector examined records of emergency response training, reviewed lesson plans,-and conducted interviews with 3 control room crews, to determine if the licensee has maintained an effective training program.

Records of required emergency response training for selected individuals in the control room, technical support center, operations support center, and the emergency operations facility were examined. The training records'from the licensee's computerized records system documented that required training had been conducted in accordance with training procedures.

It was also noted, that satisfactory completion of training is also required to maintain access to the protected area of the plant.

Discussions with training program management indicated that the licensee is considering adding another staff position to provide more instructor interface. Some improvements to the graphics and examination data bank were also discussed and observed.

To determine the effectiveness of part of the licensee's emergency response training program, the inspector interviewed 3 Units 2/3 control room crews, which consisted of a Shift Superintendent (SS)

and a Senior Reactor Operator or a Senior Technical Advisor.

The SSs were chosen because in an emergency they would become the Emergency Coordinator until relieved by the Station Manager. The interviews focused on the SSs general knowledge of emergency response and included questions regarding responsibilities of the emergency coordinator, classification, protective actions, notification, and etc. The following observations were noted:

The interviews verified that the operators were familiar with their responsibilities as the Emergency Coordinator and appeared willing to carry them out.

When given operational problems similar to those used during simulator training, all 3 shift crews answered the questions expeditiously and came up with mitigating solutions.

The interviews results indicated some refresher training in the definitions of the 4 emergency classifications might be

beneficial.

2 shift crews were unable to state the definitions

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of an unusual event or alert.

Knowing these definitions may be'

helpful in the classification of some events that are not clearly described in the procedures.

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Classification and protective action recommendations (PARS)

based upon dose rates or exceeding the EPA PAGs could be

improved.

Although this area falls under health physics, it would be pruderit for the SS or shift crew to be familiar with t

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where to find this type of information in case health physics personnel are not immediately available.

The control room crews familiarity with the classification procedures could be improved. -The SSs took considerable time i

to complete some of the classifications presented in the

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scenarios.

They also acknowledged that during a real event they probably would not be able to devote as much time towards classification as they did during the interviews.

Based on the results of the interviews, the shift crews demonstrated

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Coordinator and able to carry them out.

They also demonstrated

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proficiency in responding to simulated emergency plant conditions.

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Howsver, it was noted that the timeliness of classification could be improved by increased familiarity with the classification procedure or by providing some information regarding the classification of an event in the emergency operating instructions (E0Is).

Licensee performance in the training area appears satisfactory, no trend was observed. However, additional effort to expedite the classification of emergency events is encouraged.

No violations of NRC requirements were identified in this program area.

B.

Emergency Plan Drills and Exercises Records of emergency response drills were examined and noted to have

been conducted at the frequency specified in the Emergency Plan.

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monthly communication

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drills for 1988 and 1989, the pass cask drill conducted December-

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1988, the medical drill conducted August 1988, the environmental monitoring drill conducted September 13, 1988, the health physics drill conducted October 26, 1988, and a recent Emergency Plan drill conducted March 1989. The records contained the scenario, scope, and objectives for each of the drills mentioned above.

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objectives appeared satisfactory to demonstrate the drill I

requirements.

The critiques were noted to be candid and well documented.

Items requiring improvement were noted to have been transmitted to the emergency planning group for inclusion into their newly established tracking system.

Repeat items were to be entered into the plant tracking system.

Based on the records reviewed, the emergency preparedness groups appeared to be doing a good job of making drill scenarios challenging to the participants, to obtain maximum benefit, and documenting areas for corrective action.

Licensee performance in this program area has improved.

No violations were identified.

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Changes to the Emergency Plan Implementing Procedures

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The following changes to the Emergency Plan implementing procedures were examined in connection with this inspection:

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l 50123-VIII-0.301, Revision 2 TCN 2-10, Offsite/0nsite i

Communication Tests I

$0123-VIII-10, Revision.4, TCN 4-3, Emergency Coordint. tor-

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Duties I

S0123-VIII-10.1, Revision 0, TCN 0-2, Station Emergency Director Duties l

S0123-VIII-30.1, Revision 6, TCN 6-3, Emergency Planning

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Coordinator Duties 50123-VIII-80, Revision 4, TCN 4-3, Emergency Group Leader Duties The examination shcwed'the revised procedures had been approved by appropriate members of plant management including; Quality j

Assurance, Emergency Preparedness, and Operations for all 3 units.

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The changes were considered to be improvements and were transmitted to the NRC in a timely manner.

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Licensee performance in this program area indicates a continuing

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effort to refine and improve the Emergency Plan and implementing procedures.

No violations were identified in this program area.

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' Exit Interview

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The Inspector held an exit interview with the licensee on March 24/1989 to discuss the preliminary findings of the inspection.

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personnel who attended this meeting have been identified in Section 1 of i

this report.

During the exit interview the-licensee was informed that no deficiencies or violations of NRC requirements had been identified Other items discussed during this meeting are described in Sections 2 through 5 of this report.

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