IR 05000206/1993028
| ML13312A740 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 12/13/1993 |
| From: | Good G, Pate R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML13312A738 | List: |
| References | |
| 50-206-93-28, 50-361-93-28, 50-362-93-28, NUDOCS 9312300083 | |
| Download: ML13312A740 (4) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION V
Report No /93-28, 50-361/93-28, and 50-362/93-28 Docket No, 50-361, and 50-362 License No DPR-13, NPF-10, and NPF-15 Licensee:
Southern California Edison Company Irvine Operations Center 23 Parker Street Irvine, California 92718 Facility Name:
San Onofre Units 1, 2, and 3 Inspection at:
Walnut Creek, California Inspection Dates:
August 18 through November 22, 1993 Inspector:
\\2,,kA3 Gail M. Good, ENe:Fgency Preparedness Analyst Date Signed Approved by:
h z/3'
Robert J. Pate, chief Datd Si ned Safeguards, Emergency Preparedness, and Non-Power Reactor Branch SUMMARY:
In-Office Inspection on Auqust 18 through November 22, 1993 (Report No /93-28, 50-361/93-28, and 50-362/93-28)
Areas Inspected:
In-office inspection to review Revision 10, Temporary Change Notice (TCN) 10-1, and Revision 11 to emergency plan implementing procedure(s)
(EPIP) S01(23)-VIII-1, "Recognition and Classification of Emergencies."
Inspection procedure 82701 was use Results:
Revision 10, TCN 10-1, and Revision 11 to S01(23)-VIII-1 continued to meet the standards in 10 CFR 50.47(b) and the requirements of 10 CFR 50, Appendix E. One non-cited violation (NCV) was identified for failure to submit EPIP changes to the NRC within 30 days of the changes as required by 10 CFR 50, Appendix E, Paragraph V (see Section 2).
The violation was not cited because the licensee's efforts in identifying and correcting the violation met the criteria specified in Section VII.B of the Enforcement Polic PDR ADOCK 05000206
DETAILS 1. Persons Contacted
- C. Anderson, Supervisor, Emergency Planning
- M. Farr, Engineer, Onsite Nuclear Licensing (ONL)
R. Garcia, Engineer, Emergency Planning
- G. Lulias, Engineer, Quality Assurance
- C. Williams, Licensing Lead, ONL K. Yhip, Engineer, Corporate Health Physics and Environmental
- M. Zenker, Engineer, Emergency Planning
- Denotes participation in the November 22, 1993, telephone exit intervie. Operational Status of the Emergency Preparedness Program (Inspection Procedure 82701)
a. Background - SO1(23)-VIII-1. Revision 10 Revision 10 to SO1(23)-VIII-1, "Recognition and Classification of Emergencies," dated August 14, 1992, was submitted on September 14, 1992, in accordance with 10 CFR 50, Appendix E, Paragraph V. The licensee implemented Revision 10, without prior approval, under the provisions of 10 CFR 50.54(q).
This review was conducted.to address 10 CFR 50, Appendix E, Paragraph IV.B, which specifically requires that emergency action levels (EALs) be approved by the NR Regional emergency preparedness staff evaluated the changes to the procedure text and EALs to determine whether the changes decreased the effectiveness of the San Onofre Nuclear Generating Station (SONGS) Emergency Plan, and whether the changes continued to meet the standards in 50.47(b) and the requirements of 10 CFR 50, Appendix Evaluation - SO1(23)-VIII-1. Revision 10 Most of the changes in Revision 10 involved modifications to radiation monitor readings. Additional information to clarify/justify the changes was requested during a September 22, 1993, conference cal The licensee's response was submitted on November 5, 1993 (see Attachment 1).
As indicated in the submittal, the changes to the radiation monitor readings were the result of:
(1) changes to calibration constants, (2) new adverse atmospheric dispersion factors, and (3) revised flows or effluent release points. The additional information, and a followup conference call on November 16, 1993, adequately explained/justified the changes to the radiation monitor reading The incremental changes between Revision 9 and 10 continued to meet the standards in 10 CFR 50.47(b) and the requirements of 10 CFR 50, Appendix Background - SO1(23)-VIII-1. Temporary Change Notice (TCN) 10-1 TCN 10-1 to S01(23)-VIII-1, dated July 2, 1993, was submitted on October 4, 1993. TCN 10-2 was issued on the same date to correct an editorial error (switched pages) in SO1-VIII-1. The licensee implemented TCN 10-1, without prior approval, under the provisions of 10 CFR 50.54(q). The regulatory basis for this review is described in Section 2.a abov d. Evaluation - SO1(23)-VIII-1. TCN 10-1 Most of the changes in TCN 10-1 were made to implement Revision 5.4 to the emergency plan (EP).
Revision 5.4 was approved by the NRC on September 21, 1993 (letter from R. Pate to H. Ray).
The following changes were approved in Revision 5.4 (EP) and implemented by TCN 10-1 (EPIP): (1) changes to Control Room (CR)
staffing/position designations resulting from Amendment 154 to the Unit 1 Technical Specifications (TSs) (approved May 27, 1993), and (2) changes resulting from the elimination of SONGS 1 accident and assessment instrumentation. TCN 10-1 also included several administrative change The changes in TCN 10-1 were consistent with those approved in Revision 5.4 to the EP. The incremental changes between Revision 10 and TCN 10-1 continued to meet the standards in 10 CFR 50.47(b) and the requirements of 10 CFR 50, Appendix e. Background -
S01(23)-VIII-1. Revision 11 Revision 11 to S01(23)-VIII-1, dated August 13, 1993, was submitted on October 4, 1993. The licensee implemented Revision 11, without prior approval, under the provisions of 10 CFR 50.54(q).
The regulatory basis for this review is described in Section 2.a abov Evaluation - SO1(23)-VIII-1. Revision 11 Most of the changes in Revision 11 were made to implement Revision 5.5 to the EP. Revision 5.5 was also approved on September 21, 1993 (see reference in 2.d above). The following change was approved in Revision 5.5 (EP) and implemented by Revision 11 (EPIP): EAL changes involving steam generator tube leakag The changes in Revision 11 were consistent with those approved in Revision 5.5 to the EP. The incremental changes between TCN 10-1 and Revision 11 continued to meet the standards in 10 CFR 50.47(b)
and the requirements of 10 CFR 50, Appendix Paragraph V of Appendix E to 10 CFR 50 states that changes to EPIPs shall be submitted to the NRC within 30 days of the changes. Contrary to that requirement, TCN 10-1 and Revision 11 to S01(23)-VIII-1 were not submitted to the NRC until October 4, 1993 -- 94 and 52 days, respectively, after the changes were made (see Sections 2.c and above).
This oversight was identified in the licensee's October 4, 1993, procedure transmittal letter which forwarded changes to 24 EPIPs. The letter stated that 20 of the 24 procedures were not submitted within 30 days, and that the oversight was due to an "administrative error." The letter further stated that processes were being revised to prevent recurrence. During a November 19, 1993, conference call, the inspector questioned the licensee about its corrective actions. The licensee stated that: (1) Emergency Planning now sends a notice (warning) to Onsite Nuclear Licensing (ONL) whenever EPIPs are submitted to Corporate Document Management (CDM); (2) the need to send this notice has been incorporated into the procedure change checklist; and (3) CDM's list of ONL personnel has been updated to reflect position titles rather than names of individuals. This violation was not cited because the licensee's efforts in identifying and correcting the violation met the criteria specified in Section VII.B of the Enforcement Policy ((NCV)
206/9328-01, 361/9328-01, and 362/9328-01).
3. Exit Interview An exit interview, via telephone, was held on November 22, 1993, to discuss the preliminary findings of the in-office inspection. Section 1 of this report identifies the licensee personnel who participated in the conference cal The licensee was informed that one NCV had been identified. The inspector summarized the findings described in Section 2 of the report.