IR 05000275/1990004
| ML16342C243 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 02/15/1990 |
| From: | Good G, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML16341F579 | List: |
| References | |
| 50-275-90-04, 50-275-90-4, 50-323-90-04, 50-323-90-4, NUDOCS 9003070324 | |
| Download: ML16342C243 (18) | |
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos.
Docket Nos.
License Nos.
Licensee:
50-275/90-04 and 50-323/90-04 50-275 and 50-323 k
DPR-80 and DPR-82 Pacific Gas and Electric Company 77 Beale Street San Francisco, California 94106 Facility Name:
Diablo Canyon Units 1 and
Inspection at:
Diablo Canyon Site, San Luis Obispo County, California Inspection Conducted:
Januar 29 - February 2, 1990 Inspector:
oo
,
mergency repare ness na ys Approved by:
as, se Emerge y Preparedness and Radiological Protection Branch 2/(
j IQ a
e
>gne a
e sgne SUMMARY:
Ins ection on Januar 29 - Februar
1990 Re ort Nos.
50-275/90-04 and Areas Ins ected:
Unannounced, routine inspection to follow-up on two open stems s ent) ied during previous emergency preparedness inspections and to address Notifications and Communications, Public Information and the Operational Status of the Emergency Preparedness Program (audits).
Inspection procedures 92701, 82203, 82209, 82701 and 30703 were used as guidance.
Results:
No deficiencies or violations of NRC requirements were identified in
%lie areas inspected.
The two open items identified during previous emergency preparedness-..inspections were closed.
Two new open items were generated as a
~
result of this~inspection.
One of the items involved the scope, conduct and documentation~of the semi-annual Health Physics drills.
The results of the inspection indicated that the licensee has room for improvement in this area.
The other open item involved the licensee's procedures to implement Section
of its Emergency Plan.
The licensee does not have
"Emergency Plan Implementing Procedures" (EPIPs) to address its emergency preparedness training program or its drill and exercise program.
An 'administrative" procedure exists for the training program; however, because it is an administrative procedure, and not an EPIP, it has not been submitted to the NRC in accordance with Appendix E, V of 10 CFR 50.
Observations made during this inspection indicate that portions of the licensee's emergency preparedness program may require additional management attention.
~003070'24
~002l.'DR ADOCK C)5000275 A
Pn DETAILS Persons Contacted K. Dinnel, Health Physics (HP) Auditor M. Freund, Supervisor, equality Assurance (gA) Department S. Joiner, Emergency Planning (EP) Coordinator W. Keyworth, Senior Power Production Engineer, EP N.
Ransom, Control Room Assistant (CRA)
B. Thomas, News Representative E.
Waage, Senior Nuclear Generation Engineer M. White, Emergency Plan Trainer Action on Previous Ins ection Findin s (Ins ection Procedure 92701)
(Closed)
0 en Item (86-07-01):
Response to Inspection and Enforcement u
e sn o.
-
-
u ibility Problems Encountered on Evacuation of Personnel From High-Noise Areas.
A typographical error in NRC Inspection Report 50-275/86-07 referred to this open item as 86-06-01, instead of the correct number, 86-07-01.
At the time this Bulletin was issued, PG8E held a construction permit for Diablo Canyon and, therefore, did not have to respond in writing.
High noise areas requiring visual alarms were identified during startup engineering testing.
Numerous units with flashing red lights were installed during the, construction phase.
The visual alarms actuate as part of the licensee's site emergency signal.
NRC Inspection Report No. 50-275/89-04 documented NRC concerns related to the verification of the operability of the site emergency signal system (see open item 89-04-02 in Section 4).
This open item was closed in NRC Inspection Report No. 50-275/89-19 (see Section 2)
based on installation of 5 additional horns, development of surveillance test procedure(s)
(STP),
and system audibility/operability testing.
The STPs require quarterly testing of the system outside the power block and annual testing of the system inside the power block.
During this
'inspection, the inspector verified that visual alarms were installed in a number of high noise areas and verified that personnel have been trained regarding their response to activation of the visual alarms.
The inspector found that response to the site emergency signal, including the visual alarms, is addressed during General Employee, Training (GET).
Orange='cards covering the system and response to system activation are also att'ached to all site and protected area security badges.
This item is considered closed.
Closed 0 en Item 87-15-01:
Need to develop a policy providing a more poss ive response o
rasnsng notices by corporate personnel.
The licensee's corporate emergency response training tracking system was the original subject of this open item.
NRC Inspection Report No.
50-275/89-04 documented the development and implementation of a corporate training tracking system.
The item remained opened pending the development of a policy which provides a more positive response to training notices by corporate personnel.
[The follow-up indicated that approximately lOX of the corporate personnel were not responding to training requirements in a timely manner.]
On April 18, 1989, the
President of PG8E issued a memorandum to all Corporate Emergency Response Personnel (CERP) to address this issue.
The memorandum stated in part that "It is PG8E's policy to adhere to all procedural requirements and to maintain a high state of readiness in support of the Diablo Canyon Power Plant (DCPP).
As a member of the CERP, it is imperative that you remain cognizant of your responsibilities.... It is your responsibility to complete the necessary training and return the paperwork before the expiration date."
During this inspection, DCPP training personnel stated that there were no outstanding training deficiencies for CERP.
The inspector was informed that there were also a number of enhancements being made to the corporate emergency response training program.
These enhancements include the following:
(1) corporate trainers now report to the DCPP Training Department; (2) a job and task analysis is being performed; (3) lesson plans are being developed; and (4) training records will be transferred to the Plant Information Management System (PIMS)
data base.
Based on the actions taken by the licensee, this item is considered closed.
Notifications and Communications Ins ection Procedure 82203)
This part of the inspection was conducted to determine whether the licensee was maintaining a capability to notify and communicate with licensee personnel, offsite authorities, and the population within the emergency planning zone (EPZ) in the event of an emergency.
To accomplish this, the inspector reviewed the applicable portions of the Emergency Plan and Emergency Plan Implementing Procedures (EPIPs),
held discussions with licensee personnel, reviewed records, observed an unannounced communication/notification drill and attended a meeting with licensee and offsite authorities to discuss upgrades to the offsite early warning system.
To determine the licensee's internal notification and communication capabilities, the inspector verified that the licensee has a workable system for notifying personnel during normal work hours and off-normal work hours.
Use of the site emergency signal, public address (PA)
system, Rapid Alert Notification System (RANS), the group page system and the assembly and accountability process were specifically addressed.
The inspector also verified that communication capabilities between the licensee's Emergency Response Facilities (ERFs) were being tested on a regular. basis.
An unannounced activation of the RANS was conducted to verifyjo~erability and to evaluate the activator's familiarity with the system'~,The RANS is an automatic dialer used to notify off-duty personqe1.;
The system automatically dials members of the licensee's Emergency: Response Organization (ERO).
The system has been set-up to receive acknowledgements from those contacted and continues the process for a pre-determined number of passes or until an acknowledgement has been received from one individual in each ERO position.
In addition to the RANS, a group pager system is used to notify key personnel.
It takes approximately 20 minutes to complete the notifications via the RANS.
The RANS drill showed that the system was operable and that the activator was familiar with system operation.
Mith respect to the assembly and accountability process, EP personnel stated that they had initiated steps to have accountability readers
installed at appropriate locations (e.g.,
'and assembly areas).
The goal of the upgrade is to expedite the accountability process.
To address the licensee's ability to notify offsite authorities, the inspector reviewed and discussed EPIP G-3, "Notification of Offsite Organizations," verified that monthly communication drills were being conducted in accordance with Section 8. 1.3. 1.a of the DCPP Emergency Plan, observed an unannounced communication drill, and reviewed the records associated with emergency events declared in 1989.
The communication drill was conducted in conjunction with the aforementioned RANS drill.
No problems with communication equipment were observed during the communication drill; however, the licensee is reminded that NUREG-0654 provides for communication drills to include the aspect of understanding the content of the messages and that drills, in general, are intended to test, develop and maintain skills in a particular operation.
This reminder is offered because the only message transmitted during the drill was "This is Diablo Canyon.
We are conducting a
communication drill.
Mould you like to participate?"
The drill did not provide an opportunity for the recipients (San Luis Obispo (SLO) County Sheriff's Office and California Office of Emergency Services)
to complete a copy of the "Initial Emergency Notification Form."
In addition, the communication drill was not conducted in a manner consistent with a real emergency (i.e., the CRA who participated in the drill was not handed a
completed copy of the notification form and asked to make the drill notifications (RANS and offsite agency) in accordance with EPIPs.
The inspector reviewed records of the four Unusual Events (UEs) declared in 1989 and verified that the offsite notifications were all made in a timely manner.
The notification form from the May 23, 1989 UE stated that the event was declared at 1831 hours0.0212 days <br />0.509 hours <br />0.00303 weeks <br />6.966955e-4 months <br />; however, the Control Room (CR)
logs indicated that the fire was re orted at 1831 hours0.0212 days <br />0.509 hours <br />0.00303 weeks <br />6.966955e-4 months <br /> and the UE was declared at 1836 hours0.0213 days <br />0.51 hours <br />0.00304 weeks <br />6.98598e-4 months <br />.
EP personne s ated that the problem was proPPa y associated with individuais using their personai watches (not synchronized)
to log times, instead of the CR clock.
This matter will be included in future training interviews to ensure that there is no confusion about which time is to be used.
The licensee's capability to notify and communicate with the population within the EPZ was addressed during this inspection.
The licensee uses an early warning system (131 sirens)
and Emergency Broadcast System (EBS)
messages to accomplish this task.
This process has been a special concern~sto;the NRC because of recent problems with false siren activatioe ns..
Open item KP-06-02, in Section 2 of NRC Inspection Report No. 50-.'275/89-19, documents an example of this problem that occurred on June 2; -1989, and provides a summary of the immediate corrective actions taken by licensee and county officials.
Subsequent to that inspection, the licensee initiated a siren upgrade project.
The goal of the project was to reduce the number of false activations and to devise a method to provide feedback regarding siren status (i.e., the ability to determine whether the siren actually activated).
On January 30, 1990, PG8E held a meeting with SLO County officials to discuss the status of the siren upgrade project.
The NRC inspector attended this meeting.
During the meeting, PG8E representatives stated
that as a result of their research at other utilities, all of the siren's transistors (22 per siren) were being replaced because they were found to be the weakest link.
They also stated that lights and counters were being installed to provide positive feedback regarding siren status.
PG&E representatives'eported that 70 sirens had already been equipped with the new transistors, lights and counters.
Work on the remaining sirens was expected to be completed around the end of Harch 1990.
Additional changes were also being made at the sheriff's office to prevent inadvertent activation.
The changes involved making activation of the sirens a two-step process,.
instead of a one-step process.
County and PG&E representatives recognized that procedures would have to modified and training would have to be conducted prior to the change-over.
PG&E representatives also indicated that other siren upgrades were being considered, but that overall system reliability would not be threatened.
No deficiencies or violations of NRC requirements were identified during this part of the inspection.
Public Information (Ins ection Procedure 82209 This part of, the inspection was conducted to determine whether basic EP information was being disseminated annually to the public in the EPZ.
To address this matter, the inspector reviewed the 1989-1990 edition of the DCPP Emergency Information Booklet and discussed basic elements of the public information program with representatives from the News Department and Corporate EP.
The inspector concluded that the appropriate information was being disseminated to the permanent and transient population.
In addition to the printed material, PG&E has established a
program that provides for day-to-day communication with the community via the media and speaking engagements.
The inspector was also informed that the Energy Information Center was scheduled to be re-opened in the very near future.
The inspector reviewed the Emergency Information Booklet to determine whether any changes had been made as a result of the false siren activation mentioned in Section 3 above.
The inspector found that a new section, entitled "Accidental Siren Sounding,"
had been added.
The section has provided the public with a telephone number to call if they hear a siren without an accompanying message on any of the EBS stations.
The public,, has also been requested to not call 911.
No deficiencies or violations of NRC requirements were identified during this part'of the inspection.
0 erational Status of the Emer enc Pre aredness Pro ram Ins ection roce ure This part of the inspection was conducted to determine whether the licensee's emergency preparedness program was being maintained in a state of readiness.
The inspection focused on the licensee's annual audit of the emergency preparedness program, required by 10 CFR 50.54(t),
and whether the licensee had an effective corrective action system.
To accomplish this, the inspector examined gA Audit 89811T, dated August 8,
1989, interviewed two of the auditors, one of which was the lead auditor, and interviewed onsite EP personnel.
The licensee conducted its annual audit of the emergency preparedness program during the period June 19-28, 1989.
The results of this audit were documented in the above mentioned audit report.
The scope of the audit met the requirements of 10 CFR 50.54(t).
A total of 16 guality Evaluation Audit Finding Reports (gE-AFRs) and 15 Action Requests (ARs)
were issued as a result of the audit.
Only one of the gE-AFRs and 10 of the ARs were directly attributed.to the emergency preparedness program.
The remaining gE-AFRs and ARs weve attributed to EP activities that were not conducted in accordance with the gA program (e.g.,
outdated information was found in EPIPs, two EPIPs had not received concurrence from interfacing organizations, accountability packets were missing at assembly areas and the administrative training procedure did not include criteria for documenting requalifications of emergency response personnel based on participation in drills or exercises).
The gE-AFR that involved the emergency preparedness program (f0006592)
was described as follows:
"There was no objective evidence that the semi-annual health physics drill held during the first half 1987, 1988, and 1989 included all of the requirements from NUREG 0654 and Section 8 of the Emergency Plan fov on-site environmental sampling and participation by off-site environmental monitoring PG&E personnel."
Section 8. 1.3. l.e of the licensee's emergency plan requires that semi-annual HP drills be conducted which "involve response to and analysis of simulated elevated airborne and liquid samples and direct radiation measurements in the environment."
The specific audit finding was discussed with the responsible auditor and a representative from EP.
The following information was obtained during these discussions:
(1)
gA concluded that the requirement to respond and analyze direct radiation measurements in the environment had not been met because the drill did not include onsite, out-of-plant, environmental monitoring teams.
(2)'P has not interpreted the requirement to include any
.P out-of-plant environmental monitoring.
(3)~~.'To meet the offsite participation aspect of this item, as
""worded in NUREG-0654, the licensee's EP staff has been conducting a Unified Dose Assessment Center (UDAC) drill as part of the HP drill.
(4)
The EP staff has allowed air samples to be simulated during the HP drills because the personnel participating in the drills take air samples on a regular basis as part of their normal job.
To further investigate-this matter, the inspector reviewed the results of an HP drill.
The scope of the drills conducted during the first part of
the year appear to have been singled-out by gA because they are conducted independent of the annual exercise (i.e., activities involving the planning effort, the scope, the conduct and the documentation of the annual exercise are well established).
The inspector reviewed the documentation that was available for the HP drill conducted during the first part of 1989 and made the following observations:
(a)
The formal report for the April 26, 1989 HP drill was not complete.
(b)
The HP drill was conducted in conjunction with a fire drill',
however, none of the available documentation referred to the drill as an HP drill.
The drill was only referred to as a fire dri 1 l.
(c)
Objectives, anticipated responses and simulated events had only been prepared for the fire drill portion of the drill.
(Section 8. 1.3.3 of the DCPP Emergency Plan requires drill and exercise scenarios to be varied to cover all elements of the plan and their implementing procedures, and that objectives, evaluation criteria and simulated events be included for each drill or exercise.)
(d)
There was no HP data.
(e)
Comments attributed to the RP response during -the drill were not very positive.
Based on all of the above information, the inspector concluded that the licensee would have to improve this aspect of its EP program in order to assure continued compliance with Sections 8. 1.3. 1 and 8. 1.3.3 of the DCPP Emergency Plan and Appendix E, IV.F.5 of 10 CFR 50.
In particular, the inspector took exception to the scope of the licensee's HP drills, the level of simulation during the drills and the timeliness/quality of the drill documentation.
The licensee was encouraged to discuss this matter with the EP staffs from other utilities.
Region V intends to monitor the scope, conduct and documentation of future HP drills.
This matter will be tracked as open item 50-275/90-04-01.
No deficiencies or violations of NRC requirements were identified during this part', of the inspection.
The inspector's observations and the gA findinqs:'.indicate a need for the EP staff to improve its level of attention;-to detail.
The licensee's program to track corrective actions identified'during drills and exercises appeared to be adequate.
6.
Im lementin Procedures (Ins ection Procedure 82701)
During the part of this inspection that involved the licensee's training and drill/exercise programs, it became apparent that the licensee had not submitted, to the NRC, the procedures used to implement these programs.
These programs are described in general terms in Section 8 of the DCPP Emergency Plan.
Appendix E, V of 10 CFR 50 requires that changes to the detailed implementing procedures for emergency plans be submitted to the NRC within 30 days of the changes.
The inspector found that the licensee
had no "EPIPs" to implement Section 8 of its Emergency Plan.
Instead, the licensee uses an administrative procedure, AP 8-50,
"Emergency Plan Training" to implement its onsite training program.
The EP staff uses a
desk top procedure to implement its drill and exercise program; however, the inspector was informed that an administrative procedure was being developed to take the place of the desk top procedure.
There is no requirement to submit administrative procedures to the NRC.
This issue is being raised because these administrative procedures do in fact implement Section 8 of the DCPP Emergency Plan and because the NRC wishes to be kept informed about any changes made to these programs.
The licensee's response to this issue will be tracked as open item 50-275/90-04-02.
No deficiencies or violations of NRC requirements were identified during this part of the inspection.
Exit Interview (Ins ection Procedure 30703 An exit interview was held on February 2, 1990, 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.
P. Narbut, NRC Senior Resident Inspector, was present.
During the exit interview, the licensee was informed that it appeared there were no deficiencies or violations of NRC requirements identified during the inspection.
The findings described in Section 2-6 of this report were discussed.
The inspector stated that based on PG8E's reputation, some of the findings were not anticipated and that she hoped they were not precursors to more significant findings.
With respect to the uncompleted HP drill report, the inspector questioned the licensee's ability to meet the requirements of Appendix E, IV.F.5 of 10 CFR 50 if the report was not issued.
Regarding the issue of the emergency procedures, the licensee agreed that the administrative procedures do implement its Emergency Plan and that they should be sent to the NRC.
The inspector questioned the advisability of havihg two different types of procedures (administrative and EPIP)
and controlling mechanisms (e.g.,
maintenance, review, approval, etc.) governing the procedures used to implement the Emergency Plan.
The licensee stated that they did not want to make their EPIPs more cumbersome by including procedures that would not be used during an emergency.
The inspector stated that other utilities had found acceptable ways of resolving this matter.
)
Subsequent.':,to the inspection, the licensee provided the inspector with a copy ofrth'e report for the April 26, 1989, HP drill.
The report was dated February 5, 1990.
The report included objectives and stated that all of the objectives were met.
Corrective actions taken as a result of the drill will be followed as part of open item 50-275/90-04-0 '2
ATTACHMENT EXIT INTERVIEW ATTENDEES R. Bliss, Emergency Planner D. Cosgrove, Quality Control Specialist T. Grebel, Supervisor, Regulatory Compliance G. Heggli, Senior Engineer, Technical Auditing S. Joiner, EP Coordinator W. Keyworth, Senior Power Production Engineer, EP T. Martin, Manager Training T.
Owyang, Planning Analyst, EP C. Prince, EP W.
Rapp, Chairman, Onsite Safety Review Group J.
Sexton, Manaqer, QA J. Shiffer, Sensor Vice President and General Manager, Nuclear Power Generation Business Unit D. Taggart, Director, Quality Support, QA R. Todaro, Manager, Security J.
Townsend, Vice President, Diablo Canyon Operations 8 Plant Manager W. White, Emergency Plan Trainer