IR 05000275/1994014
| ML16342C615 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 06/24/1994 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML16342C614 | List: |
| References | |
| 50-275-94-14, 50-323-94-14, NUDOCS 9407110110 | |
| Download: ML16342C615 (24) | |
Text
APPENDIX U.S.
NUCLEAR REGULATORY COMMISSION
REGION IV
Inspection Report:
50-275/94-14 50-323/94-14 Licenses:
DPR-80 DPR-82 Licensee:
Pacific Gas and Electric Company 77 Beale Street, Room 1451 P.O.
Box 770000 San Francisco, California Facility Name:
Diablo Canyon Nuclear Power Plant, Units 1 and
Inspection At:
Diablo Canyon Site, San Luis Obispo County, California Inspection Conducted:
June 13-17, 1994 Inspector:
A. D. Mcgueen, Emergency Preparedness Analyst Approved:
aine urray, ie eactor nspec ion rane Ins ection Summar Areas Ins ected Units 1 and
Routine, announced inspection of the emergency preparedness program; including emergency detection and classification, protective action decisionmaking, notifications and communications, and followup on open items.
Results Units 1 and
~ ~
The emergency plan and emergency plan implementing procedures included an appropriate emergency classification system and emergency action levels (Section 1.2).
The capability to properly assess and analyze emergency conditions and make recommendations to protect the public and onsite workers was maintained (Section 2.2).
Capability for notifying and communicating among licensee personnel, offsite authorities and supporting agencies, and the population within the emergency planning zone in the event of an emergency was being maintained (Section 3.2).
4I 9407110110 940630 PDR ADQCK 05000275
>"-'.
'DR
'
~
Emergency response facilities were properly maintained and were in a
state of readiness for expeditious activation (Section 4.3).
~
An appropriate training program for emergency action levels, protective action recommendations, and notifications had been implemented (Section 4.3).
~
Three unusual events had been properly classified and required notifications were made in a timely manner (Section 5.4).
~
Changes in Revision 22 to Emergency Plan Implementing Procedure EPIP EP G-I were acceptable (Section 7.2).
Summar of Ins ection Findin s:
~
Open Item 50;., 275/9320-01 was closed (Section 6. 1).
~
Open Item 50-275/9320-02 was closed (Section 6.2).
remain Attachments:
Exercise Weakness Item 50-275/9323-01 was reviewed and remains open (Section 6.3).
Emergency plan aspects of Violation 50-275/9~12-Ol were reviewed and
'
open (Section 6.4).
~
Attachment
.1 - Persons Contacted and Exit Meeting
~
Attachment 2 - Documents Reviewed
-3-DETAILS
EHERGENCY DETECTION AND CLASSIFICATION (82201)
Tne inspector reviewed the emergency plan and emergency plan implementing procedures pertaining to emergency action levels to verify that the licensee had a standard emergency classification and action level scheme; the bases of which include facility systems, effluent parameters, and projected offsite doses.
1. 1 Discussion The inspector verified that emergency plan implementing procedures contained proper emergency action levels with the exception of a minor recently made change (Section 6.4).
These were based on in-plant conditions, onsite and offsite radiological monitoring results, offsite dose projections, and other factors which could impact on safe shutdown of the plant or the public health and safety.
Emergency action levels had b en coordinated with and concurred in by, state and local agencies, and they had.been submitted to the. NRC for review and approval.
Emergency plan implementing procedures were reviewed and approved by the licensee prior to distribution and submission to the NRC.
Emergency action levels were based on example initiating conditions in Appendix 1 of NUREG-0654.
The licensee had performed a Site guality Assurance Surveillance (SgA-94-0019) to assess site preparedness for implementation of emergency action levels based on NUHARC/NESP-007, Revision 2.
The surveillance determined that Diablo Canyon Power Plant was "very well positioned for the NUHARC Upgrade";
however, no decision had been made whether to adopt the NUHARC scheme.
The inspector verified that the emergency event classifications in the emergency plan implementing procedures were consistent with those in the emergency plan, met regulatory requirements, and that the classification procedure had provisions for prompt and correct classifications.
The licensee
,
had adequate procedures to direct the user to classify emergencies.
The inspector verified that there was an individual on site at all times to function as the Site Emergency Coordinator.
This individual had the authority and responsibility to classify events and initiate emergency actions, including recommending protective measures to offsite officials.
Initially, this would be the Shift Supervisor; until they are relieved of the role of Site Emergency Coordinator by a Site Emergency Coordinator or Recovery Hanager of higher plant or corporate management.
A Shift Supervisor demonstrated knowledge of the procedures and emergency action levels for classifying events and making protective action recommendations.
Event classification charts were available in the control room, the Technical Support Center, and the Emergency Operations Facilit S AJ, 0'
1.2 Conclusions The emergency plan and emergency plan implementing procedures were properly maintained.
Procedure changes were properly reviewed, coordinated, and approved prior to distribution.
PROTECTIVE ACTION DECISIONNAKING (82202)
The inspector conducted interviews and reviewed the emergency p1 an and emergency plan implementing procedures to verify that the licensee maintained a 24-hour-a-day capability to assess and analyze emergency conditions and to make recommendations to protect the public and onsite workers.
2.1 Discussion The inspector verified that the authorities and responsibilities to assess the accident and to make recommendations for protective actions were clearly reflected in the emergency plan implementing pr< cedures and were consistent with the emergency plan.
The organizational elements, responsibili~ies.
and authorities in the emergency plan implementing procedures for acc;dent assessment and protective action recommendations were compared with those in the emergency plan with particular attention given to organizational structure, reporting chains, personnel interactions, and staffing.
Requirements for the emergency organization were consistent with requirements in 10 CFR 50.47(b)(l)
and (2)
and 10 CFR Part 50, Appendix E, Section IV.A.
The criteria and methodology for making offsite protective action recommendation decisions were clearly stated in the implementing procedures.
The emergency plan implementing procedures clearly specified a methodology to make 'protective action recommendations appropriate for the particular plant conditions.
.The implementing procedures contain criteria concerning protective actions for nonessential onsite personnel, including evacuation for Site Area Emergencies and General Emergencies.
The licensee had the capability to deliver timely protective action recommendations to the appropriate offsite authorities.
Specifically,
~
.
The licensee had provisions for reaching offsite officials with the authority and responsibility for protective action decisionmaking on a
24-hour basis.
There were procedures to allow offsite protective action recommendations to be made by the licensee within"15 minutes of the determination that an emergency existed.
The licensee had predetermined criteria for making protective action recommendations on the basis of plant conditions or on projected doses.
The licensee had taken steps to understand how offsite officials use the licensee's,protective action recommendations to make protective action
0
decisions.
The licensee's emergency planning staff had met with offsite agency representatives on a regular basis to discuss emergency preparedness, notifications, protective action matters, and other topics oF interest to offsite agencies.
2.2 Conclusions The licensee maintained a 24-hour-a-day capability to assess and analyze emergency conditions and to make recommendations to protect the public and onsite workers.
3.
NOTIFICATIONS AND CONNUNICATIONS (82203)
The inspector performed interviews, inspected testing and maintenance records, inspected procedures, and inspected documents pertaining to the licensee's capability for notifying and communicating among licensee personnel, offsite authorities and supporting agencies, and the population within the emergency planning zone in the event of an emergency.
3. 1 Discussion Tne licensee's notification procedures were consistent with the emergency classification and action level scheme, and they contained provisions for message verification.
The licensee had primary and backup communications systems available to ensure continuous communication links in the event of an emergency.
The licensee emergency plan implementing procedure for notifications contained a requirement to notify county and state offices of-emergency services as soon as possible, but not later than 15 minutes after declaration of an emergency classification.
The licensee had procedures for alerting, notifying, and activating emergency response personnel.
The procedures addressed criteria for alerting and activating the appropriate personnel and organizations.
They were current, complete, and met regulatory requirements for activation of the emergency response organization.
Home and office telephone numbers of randomly selected licensee emergency response personnel, offsite authorities, and offsite support organizations were compared with the current corporate and public telephone books to verify that they were current and correct.
The content of initial and followup emergency messages to offsite authorities were adequate with regard to data and information requirements.
These initial and followup emergency messages were consistent with the guidance contained in NUREG-0654.
The prompt notification system was consistent with the description given in the emergency plan.
The primary system consisted of public alert sirens.
Testing records verified that the prompt notification system was being maintained as required.
In addition to public alert sirens, backup warning devices were maintained and tested.
These included tone alert radios and an emergency broadcast syste 'I S
,r
"V</
I
'h ( ~
Er t 4 I
'1 ~
F r
I'
v tl - '9
~
L-
~
II I
S
'
Communications equipment and procedures existed in the control room and the licensee's emergency response facilities and were consistent with the needs for communication within the licensee's organization, for offsite support, and with State and local authorities as required.
Communications links and equipment were as described by the emergency plan and implementing procedures, and they were consistent with the documented operational concepts.
The licensee had appropriate equipment and procedures for emergency response organization augmentation.
Inspection of test records and interviews verified that communications equipment in emergency facilities was tested monthly.
Communication drills were conducted as required by procedures and identified deficiencies were corrected.
Communication links onsite and with offsite officials were redundant and diverse and were equipped to continue operating in the event of power failures.
3.2 Conclusions The licensee was maintaining the capability for notifying and communicating among licensee personnel, offsite authorities and supporting agencies, and the population within the emergency planning zone in the event of an emergency.
OPERATIONAL STATUS OF THE EMERGENCY PREPAREDNESS PROGRAM (82701)
Emergency response facilities and emergency preparedness training were inspected with particular emphasis on procedures and equipment for implementing the emergency plan requirements for classifying emergency events, making protective action recommendations, and prompt notification of the public and onsite employees.
4. I Emer enc Facilities E ui ment Instrumentation and Su lies Emergency response facilities including the Control Room, Technical Support Center, and Emergency Operations Facility were inspected.
Required procedures were maintained,,in easily identifiable binders coded by titles of the cognizant emergency response positions and tabbed for quick reference.
Wall charts were available to quickly identify emergency conditions and to formulate appropriate protective action recommendations.
Appropriate and redundant communications and notification equipment was in place.
4.2
~Trainin The inspector reviewed the emergency response training program and interviewed instructors and supervisors in emergency preparedness and operations.
Individual training records were randomly selected for inspection and were found to be up-to-date and in accordance with requirements.
Initial emergency response training was provided by emergency preparedness instructors in the General Employee Training Division.
Annual refresher training for reactor operators and engineers was performed by Operations and Engineering Training instructors in conjunction with simulator training.
Annual refresher training
tI
"fi>-
C E
l ' I
< ~
I C
li e
T,
'
for the remainder of the emergency response organization was performed by General Employee Training instructors.
4.3 Conclusions Emergency response facilities were properly maintained and were in a state of readiness for expeditious activation.
Emergency preparedness training was conducted in accordance with regulatory requirements and individual training records were up-to-date.
ONSITE FOLLOWUP OF EVENTS AT OPERATING POWER REACTORS (93702)
Three licensee events were reviewed during the inspection wherein the licensee had declared unusual events.
5. 1 Event Number
On March 28, 1994, the licensee telephonically notified the NRC Headquarters Operations Officer that, an unusual event had occurred at the site at about 4:05 p.m.
(PST).
The plant had entered a Limiting Condition for Operation action statement to be in Mode 3 within six hours and Mode 5 within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> due to pressure boundary leakage The Unusual Event was terminated at ll:41 p.m.
(PST)
when the reactor reached Mode 5.
The licensee indicated state and local agencies were notified and the resident inspector would be informed
{NRC Event Number 27001).
Review of control room documentation verified that the classification was appropriate and prompt notifications, and followup notifications were made in accordance with requirements.
5.2 Event Number
On May 8, 1994, the licensee telephonically notified the NRC Headquarters Operations Officer at about 1:53 p.m.
(PDT) that an Unusual Event had been declared due to a brush fire on the owner controlled area -bout 300 yards outside the protected area.
The fire was discovered at about 1:37 p.m.
{PDT).
The licensee called the California Department of Forestry to assist the site Fire Brigade in attacking the fire.
The Unusual Event was terminated at about 3:05 p.m.
(PDT) when the fire was out and cleanup operations began.
The licensee indicated the local county sheriff and the California Department of Emergency Services had been notified, and the NRC Resident Inspector would be notified (NRC Event 27221).
Review of control room documentation verified that the event classification was appropriate and prompt notifications were made in accordance with requirements.
5.3 Event Number
On May 10, 1994, the licensee telephonically notified the NRC Headquarters Operations Officer at about 12:06 p.m.
(PDT) that an Unusual Event had been declared due to a forced shutdown of Unit 1.
The Unusual Event was declared when the licensee determined that the
"C" phase of their main transformer had to be replaced, and the time would exceed the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed by technical specifications.
The Unusual Event was terminated on May ll, 1994, at about
~ la II
~
V
'
10:45 p.m. (PDT)'pon reaching cold shutdown of the unit.
The licensee indicated that state and local authorities had been notified, as well as the NRC Resident Inspector (NRC Event 27229).
Review of control room documentation verified that the event classification was appropriate and prompt notifications were made in accordance with requirements.
5.4 Conclusions Event classifications appeared appropriate for all events.
In each case, timely notifications were made to the county, State of California, and the NRC in accordance with approved procedures.
6.
FOLLOWUP ON PREVIOUS INSPECTION FINDINGS (92904)
6. 1 Closed 0 en Item 50-275 9320-01:
Inconsistenc Between Licensee Emer enc Plan Im lementin Procedure EP G-3 and
CFR Part 50.72 c
.
An item in Revision 23 of licensee Emergency Plan Implementing Procedure EP G-3, "Notification of Off-Site Agencies and Emergency Organization Personnel,"
dated Nay 24, 1993, had appeared inconsistent with NRC regulatory r quirements in 10 CFR 50.72(c)(3).
The licensee stated that the inconsistency was unintentional and the procedure would be changed to reflect the requirement.
The licensee submitted the appropriate change, and this item was closed by in-office inspection on Harch 29, 1994.
6.2 Closed 0 en Item 50-275 9320-02:
Revision of Emer enc Plan and Emer enc Plan Im lementin Procedures.
The 1993 annual audit (Audit 93021I) of the emergency plan and emergency preparedness indicated that
"The EP (Emergency Plan)
and EPIPs (emergency plan implementing procedures)
meet minimum requirements for being reviewed and are able to be used."
The audit recommended the licensee "identify.
.
. all procedures that need to be revised.
Assign the procedure revisions to responsible parties, assign a completion date and meet this date."
The licensee completed the plan and procedure changes.
Based on followup submittals by the licensee, this item was closed by in-office inspection on Harch 29, 1994.
6.3 0 en Exercise Weakness Item 50-275 9323-01:
Technical Su ort Center Emer enc 0 erations Facilit En ineerin Su ort Exercise Weakness.
During the 1993 annual emergency exercise, one exercise weakness was identified by the inspector.
Based on observations by the inspector in the Technical Support Center and Emergency Operations Facility, there was a
concern that technical support provided by the engineering staff at these centers did not appear to provide emergency management with appropriate assessments regarding the areas of core damage and probable release path.
By letter (PGEE Letter No. DCL-93-285) dated December 17, 1993, the licensee stated that actions were being taken to improve performance in this functional area.
The licensee had prepared in a final draft form, two Engineers
kk M ~
'
<<
n.
~
~
4<<J
<<
'
Handbooks for reference in emergency events.
One handbook was for the Technical Support Center and one for the Emergency Operations Center.
Additionally, a
new Emergency Plan Implementing Procedure EPIP EP EN-1, titled
"Plant Accident Mitigation Diagnostic Aids and Guidelines,"
was also prepared in final draft form for the engineering staff in these two emergency response facilities.
These documents appeared comprehensive and were to be used in an emergency response drill in June 1994 for validation of the content and to upgrade the manuals as appropriate.
'After the drill and validation of the procedure, it was then intended to train six engineering teams in use of the manuals in responding to emergency events.
The inspector stated that this item will remain open pending the including of this information to lesson plans used during annual emergency response training for the engineering group and completion of briefings of engineering personnel in the Technical Support Center and Emergency Operations Facility on the changes.
6.4 0 en Violation 50-275 9412-01:
Failure to Post a Hi h Radiation Area.
NRC ! spection Report 50-2" /94-12, based on a radiation protection inspection, was -issued with a Notice of Violation indicating a failure to post a high radiation area in violation of 10 CFR 20. 1902(b).
The event had occurred on April ll, 1994.
The inspector noted that based on licensee's Bsergency Procedure EP G-l, "Accident Classification and Emergency Plan Activation," the event appeared to meet the criterion for declaration of an Alerts The licensee stated that the event was not classified as an ALERT based on information found in NUREG-0654, NUMARC/NESP-007, NRC Regulatory Guide 1. 101, and the licensee's EPIP RP G-1.
The report also stated that the rationale for reaching this decision was discussed during a conference call held by the Vice President/Plant Manager and his staff with NRC's staff on April 14, 1994.
The NRC staff determined that the licensee's rationale for not declaring an Alert was appropriate under the circumstances; however, Emergency Procedure EP G-1 needed to be clarified.
The event was also reviewed by the NRC Resident Inspector staff (NRC Inspection Report 50-275/94-11).
The resident inspector's report stated that the licensee agreed to revise the emergency response plan to more clearly and appropriately address these types of situations.
Licensee's actions in implementing the agreement among plant management and NRC concerning emergency planning aspects of this.
event were reviewed.
Revision 23 to Emergency Plan Implementing Procedure EP G-1 had been submitted for review and acceptability by NRC.
This item will remain open until the review is completed.
EMERGENCY PLAN IMPLEMENTING PROCEDURE REVIEM 7. 1 Discussion An in-office inspection was conducted to review Revision 22 to Emergency Plan Implementing Procedure EP G-l, "Accident Classification and Emergency Plan Activation."
Revision 22 to EP G-l was submitted on February 15, 1994, pursuant to
CFR Part 50, Appendix E, paragraph V.
The licensee implemented Revision 22 without prior approval in accordance with 10 CFR 50.54(q).
NRC approval of emergency action levels is required by 10 CFR Part 50, Appendix E, paragraph IV.B.
Revision 22 included changes to two emergency action levels:
Alert No. 16'nd Site Area Emergency No.
11.
Both emergency action levels
-10-were revised to limit applicability to Modes 1-4.
Since this limitation was consistent with NUMARC/NESP-007, the changes were considered acceptable.
I 7.2 Conclusion Changes in Revision 22 to Emergency Plan Implementing Procedure EP G-I were acceptabl ATTACHMENT 1 I
PERSONS CONTACTED l. I Licensee Personnel
- D. Behnke, Senior Engineer, Regulatory Compliance C. Belmont, Auditor, Site guality Assurance R. Bliss, Emergency Planner, Technical Support Center
- J. Castner, Analyst, Regulatory Compliance L. Cossette, Surveillance Group Supervisor, Surveillance Test Procedures
- J. Fields, guality Control Engineer, Site guality Control
- R. Fields, Co-op Student, Emergency Planning
- L. Hagen, Director, Safety, Health 8 Emergency Services K. Hubbard, Regulatory Compliance
- M. Hug, Supervisor, Onsite Emergency Planning D. Johnson, Offsite Support, Emergency Planning R. Magruder, Shift Supervisor D. Marsh, Health Physics Support, Emergency Planning
- D. Miklush, Manager, Operations L. Moretti, Radiation Protection Supervisor
- M. Persig, Instructor, Emergency Preparedness/General Employee Training C. Prince, Emergency Planning Coordinator
- W. Rising, 'r., Auditor, Site guality Assurance D. Rogers, Radiation Protection Foreman D. Royer, Offsite Support, Emergency Planning B. Terrell, Senior Instructor, Licensed Operator Requalification E.
Waage, Supervisor, Offsite/Corporate Emergency Planning J.
Welsch, Supervisor, Operations and Engineering Training
- W. White, Senior General Employee Training Instructor D. Vows, Emergency Planning Consultant The inspector also held discussions with and observed the actions of other members of the licensee's onsite and offsite emergency planning, administrative, operations, and technical staff during the course of the inspection.
- Denotes those present at the exit interview
EXIT MEETING An exit meeting was conducted on June 17, 1994.
During this meeting, the inspector reviewed the scope and findings of the inspection as presented in this report.
The licensee did not identify as proprietary any of the materials provided to, or reviewed by, the inspector during the inspectio '
Documents Reviewed:
ATTACHMENT 2
~
Diablo Canyon Power Plant,
"1993 Emergency Preparedness Exercise Report," dated January 6,
1994.
~
Diablo Canyon Power Plant Dress Rehearsal Drill Report for the 1993 Annual Exercise dated September 22, 1993.
~
Diablo Canyon Power Plant, Master Emergency Plan Training and Recall Roster,"
dated April 6, 1994.
~
Diablo Canyon Power Plant,
"Nuclear Emergency Response Communications Directory," Change 27, Second quarter 1994.
~
Diablo Canyon Surveillance Report SgA-94-0019, Site guality Assurance,
"Readiness for Emergency Action Level Upgrade to NUMARC/NESP-007, Revision 2," dated March 22, 1994.
~
Emergency -Plan Implementing Procedure EPIP EP G-3, "Notification of Off-Site Agencies and Emergency Response Organization Personnel,"
Revision 26, dated February 28, 1994.
Emergency Plan Implementing Procedure EPIP EP RB-10, "Protective Action Recommendations,"
Revisions 4 and 4A, dated January 1,
1994, and Nay 2, 1994, respectively.
Instructor Lesson Guide EPD-261,
"Protective Action Guidelines," dated December 21, 1993.
Instructor Lesson Guide EPD-700, "Recognition/Classification of Emergencies,"
dated November 26, 1991.
Nonconformance Report DC1-94-HP-N017,
"Unit 1 Letdown System Restoration Hot Spots,"
dated May 16, 1994.
PGKE Nuclear Power Generation Site guality Assurance Audit 93037I,
"Emergency Plan and Implementing Procedures,"
dated October 20, 1993.
Self-paced Lesson Guide EPD-450,
"Emergency Communications,"
dated March 199 '