IR 05000312/1986032

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Insp Rept 50-312/86-32 on 861006-10.No Violations Noted. Major Areas Inspected:Emergency Preparedness Exercise & Associated Critiques,Followup on Four Open Items & Followup on LER
ML20214U035
Person / Time
Site: Rancho Seco
Issue date: 11/14/1986
From: Brown G, Fish R, Prendergast K, Temple G, Tenbrook W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20214T973 List:
References
50-312-86-32, IEIN-83-28, IEIN-85-078, IEIN-85-78, NUDOCS 8612090110
Download: ML20214U035 (11)
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U. S. NUCLEAR' REGULATORY COMMISSION

REGION V

Report No.: .50-312/86-32-Docket No.: 50-312 License No.: DPR-54 Licensee: Sacramento Municipal Utility District P.O. Box 15830 Sacramento, California 95813 Facility Name: Rancho Seco Nuclear Generating Station Inspection At: Clay Station, California Inspection Conducted: October 6-10, 1986 Inspectors: & //[/3/fjl, G. Brown, Emergency Preparedness Analyst Date Signed A

G. T c1le, Enkrgency R u Preparedness Analyst Dafe nhyIts Signed

. > Illst+/ h6 K. Prende'rgast,($mergency Preparedness Ddte ' Signed Analyst

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. W W. TenBrook, Radiation Specialist (EP)

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Team Members: G. F. Martin,7Research Scientist, Battelle-Pacific Northwest. Laboratories A. K. Loposer, Reactor Operations Engineer, Comex Corporation-Approved By: //!/YhIn R. Fish, Chief Date Signed

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Emergency Preparedness Section

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8612090110 861117 PDR ADOCK0500g2 G

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Summary:

, Inspection on October 6-10, 1986-(Report No. 50-3'12/86'-32)

Areas Inspected: Announced inspection of the emergency preparedness exercise and associated critiques, follow-up on four open' items, and follow-up of a

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licensee event repor Inspection procedures 82301, 92701, and 92703 were

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. Results:

- No violations of NRC requirements were identifie .

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1 DETAILS Persons Contacted SMUD

  • J. Ward, Deputy General Manager, Nuclear
  • Vinquist, Executive Assistant
  • A. Carver, Nuclear Licensing Supervisor
  • J. Delezenski, Site Licensing Supervisor
  • T. Shewski, Quality Engineer
  • R. Colombo, Regulatory Compliance
  • G. Coward, Deputy Restart Manager

'*J. McColligan, Assistant Manager, Nuclear Plant

  • R. Moore, Security
  • R. Jones, Security

. CONTRACTOR PERSONNEL

  • D. Poole, Nuclear Plant Manager
  • Denotes those present at exit interview on October 10, 1986 2. Followup Actions ( Open ) Open Item No. 85-26-01. Include NRC suggestions in corrective action list. A review of the licensee's corrective action list was performed during this inspection. Based upon this review it appears that the licensee is now entering NRC open items and suggestions into this list. However, the procedures to drive this system are incomplete at this time. This item will remain open until procedures are in place to ensure NRC concerns are addressed in the corrective action lis (Closed) Open Item No. IN-85-78. Event Notification Form. Licensee action related to this Information Notice has been completed. Emergency Plan Implementing Procedure AP 506, " Notification / Communication," has been revised accordingly. This item is close r

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(Closed) Open Item No. 85-?6-03. Review the responsibility for making Protective Action Recommendations (PARS) in the emergency pla AP 52E, " Protective Action Guidance" (dated 9-18-86), and Attachments and 7.2 were reviewed. Attachment 7.1 is a protective action flow chart patterned after the one contained in the NRC information notice,

-IN-83-28. Attachment 7.2 is a protective action worksheet for use by dose assessment personnel in the TSC and E0F to work through and record the reasoning used to arrive at a protective action recommendation. This item is close (Closed) Open Item No. IN 83-2 Criteria for General Emergency PAR Licensee action related to this Information Notice has been complete Emergency Plan Implementing Procedure AP 528 has been revised accordingl This item is close . Emergency Preparedness Exercise Scenario Planning The Manager, Emergency Preparedness, has the responsibility for assuring that the annual emergency exercise is conducted. A member of the Emergency Preparedness staff was assigned to act as the Lead Controller with the responsibility of developing the scenario package and conducting the exercis The exercise objectives and scenario were developed by a committee composed of representatives from SMUD, FEMA Region IX, California State Office of Emergency Services, and local government agencies (which included the emergency planning officers from each of the three affected counties: Sacramento, San Joaquin and Amador). The exercise objectives were forwarded for review and approval to NRC Region V offices several weeks prior to the exercise. The review resulted in some changes and additions to the objectives which were discussed with and agreed upon by the licensee. In a letter to the licensee dated September 9, 1986, NRC approved the objectives as ammende The scenario development was based on considerations for providing a realistic sequence of events to meet the exercise objectives and giving a challenge to most elements of the emergency organization. The final scenario document was submitted to the NRC about one month prior to the exercis Region V acknowledged receipt of the objectives and scenario in a letter dated October 1, 1986, concluding that they were appropriat The exercise document included the objectives, instructions to the controllers, the exercise scenario, messages to be given during the course of the exercise, exercise scenario data and condition Prior to the exercise, access to the document was restricted to those persons-involved in its development and others who needed the informa-tion. A controller's briefing was held before the exercise. The exercise was intended to meet the requirements of Section IV.F.3 of Appendix E to 10 CFR Part 5 This was a full participation exercise involving both State and local agencie . Exercise Scenario l

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The exercise scenario began with an event classified as an Alert and ultimately escalated to a General Emergency classification. Milestone events were as follows:

Classification Event Alert Damage to spent fuel assembly in Spent Fuel Building results in puff release of activity which exceeds 10 times the Technical Specification limit Site Area Emergency Break of the reactor coolant pump discharge leg results in loss of reactor coolant into the containment which exceeds the makeup high pressure injection system capacit <

General Emergency The resulting pressure increase in the containment building from the discharge of-coolant posed a significant challenge to the third fission product barrier, having already lost two others (fuel cladding and primary coolant system). Federal Observers Six NRC inspectors evaluated the licensee's response. The inspectors were stationed in each of the licensee's emergency response facilitie The NRC inspector assigned to the Operational Support Center accompanied some field maintenance teams and a field monitoring team to evaluate their performances. Federal Emergency Management Agency (FEMA) observers evaluated the activities of the State and local agencies participating in this exercise. FEMA will issue a separate report that describes their finding . Control Room The Control Room crew's ability to detect and classify emergency events, analyze plant conditions and take corrective actions, decide on protective actions, and make appropriate and timely notifications were

. evaluate The NRC observations of activities in the Control Room identified several areas where licensee response was particularly effective or improve The Control Room crew quickly detected and classified the initial even Within two minutes of receiving the report of the spent fuel handling accident the Shift Supervisor properly declared the Alert and assumed the emergency responsibilities of the Emergency Coordinator. Notifications to the State and local agencies were appropriate and made in accordance with agreed upon procedure. Notifications to State and local agencies were initiated within 15 minutes as required. The Control Room Operators appeared well trained in use of the Operating and Casualty procedure Throughout the exercise they demonstrated an adeptness for applying the appropriate procedures and referencing the Piping and Instrumentation Diagrams (P& ids).

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exercise results and_ identifying areas that need improvemen a .- Dose calculations for the iodine release'made in connection with the'

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initial ~ event were extremely conservative and resulted in an unnecessary protective action recommendation to shelter within two -

miles'of the facilit The Shift Supervisor / Emergency Coordinator !

, followed the applicable procedure, AP 509. iThe event was properly declared an " Alert" which meant that radioactive releases were expected'to be limited to a small fraction of the EPA-Protective-Action' Guide. levels. No protective action recommendation would have

, been expected for such a release. Part of the-problem appears to be'

' associated with considering the release to be unfiltered when,-in-

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, fact,.it went through the Auxiliary Building charcoal and HEPA filter The procedure and guidance provided to the' Control Room staff on this subject 'should be reevaluated. >

[ . _W hile the licensee's responses met the requirement, it was notEd-

! that the'NRC was not; notified until'39 minutes after completion of

' State and local agency notifications and 59, minutes after actual

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declaration of the Alert.' The. licensee should consider that the 6 3 total requirement.of 10 CFR 50.72(a)(3) includes the words, "the licensee shall notify _the NRC immediately after notification of the

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a)propriate State or' local agencies (emphasis added) and not Tater t1an one hour afteF the time the licensee declares one of the emergency classes'."

s It appears that guidance on this reporting requirement has been

~ directed to the one hour aspect rather than the entire requiremen ; This' item will be tracked as Open Item No. 86-32-0 L The. inspector concluded that, in general, this portion of the. licensee's i program is satisfactory.

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. Technical-Support Center l The Technical Support Center (TSC) staff's ability to activate in a j timely manner, assess and classify accidents, 1 cide on appropriate protective action recommendations, make proper and timely notifications, support the Control Room and maintain radiological monitoring were

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The NRC observations of activities in the TSC noted certain areas where j the licensee's response was particularly effective. The TSC staff

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t demonstrated acumen in assessing and classifying the events as well as making appropriate protective action recommendations. Within five

minutes of being notified of the loss of coolant accident the Emergency

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Coordinator properly declared a Site Area Emergency and directed L appropriate actions. It was necessary on several occasions for the

controller to curtail actions made by-the staff in order to keep the exercise running because the actions would have mitigated the event

prematurely. The TSC was prepared to perform dose assessment functions in a timely manner. Within 37 minutes of the declaration of the Alert,

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the Dose Assessment section was prepared to begin dose assessments.

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The following NRC observations should be considered when evaluating the exercise results and identifying areas that need improvement, The TSC was declared activated one hour.and 41 minutes after the Alert declaration. _The goal specified in: Supplement-1 to NUREG-0737 (Section 8.2.1.3) is one hou Additionally, when the TSC was declared activated both communicators, the Technical Report Coordinator, Maintenance Log Coordinator and Public Information Coordinator were missing. It should be.noted that AP 506.01, " Activation and Operation of the Technical Support Center", Revision 4 (8-13-86) does not specify minimum staffing requirements for the TSC. Paragraph 2.1.2 of AP 506.01 states that the Emergency Coordinator'(EC) will declare the TSC activated "when the TSC is adequately staffed". The EC should assure the presence of adequate staff and capabilities before

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declaring the TSC activate The licensee should reevaluate the process for activating emergency response facilities to assure it can be accomplished in a timely manne Open Item No. 86-32-0 The TSC's involvement in the briefing of numerous inplant field teams appears to be unnecessary and hampered the efficiency of carrying out the TSC's missio The briefings subjected the TSC to potential contamination as the teams traversed through areas of airborne contamination on their way to the TSC. Each time a team entered the TSC the habitability of the area, which is shared by the Control Room, was jeopardized. The briefings could have been carried out at the Plant Assembly Poin This item will be tracked as Open Item No. 86-32-03.

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The inspector concluded that, in general, this portion of the licensee's program was satisfactor . Plant Assembly Point (Licensee's Operational Support Center)

The inspector evaluated the Plant Assembly Point (PAP) staff's ability to activate and staff the facility with appropriate skills and craftsmen in a timely manner, and support the Control Room and TSC in their response to the event The NRC observations of activities in the PAP noted certain areas where

' the licensee's response was particularly effective. The PAP was staffed and activated within the required time. The staff appeared knowlegeable and' efficient in performing their tasks. Each seemed well trained in his duties-and began a systematic setting up of equipment upon arrival with a minimum of hesitation or indecision. Teams were assembled quickly and

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efficientl Team members reported with the proper equipment to perform their task, were issued adequate dosimetry, given a thorough briefing, logged into the records and promptly dispatche ..

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The following NRC observation should be considered when evaluating the

. exercise results and identifying areas that need improvement; a.- There was-inadequate monitoring for radiological contamination, even though teams were noted to have passed through potentially airborne contaminated areas to enter other emergency facilities. This. item will be tracked as Open Item No. 86-32-0 .

In lieu-of conducting assembly and accountability of participants during the exercise, the licensee conducted a complete assembly and s accountability dril1~on September 10, 1986. This drill involved the entire plant complement and contractors' totalling approximately 900 workers. Some 80-100 others were exempted due to the nature of their

, work at the time. The normal complement of day shift workers is about 45 It required 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 12 minutes to complete the accountabilit The licensee has committed to the following corrective actions:

(1) Research computer capabilities and install 4 more' card readers in the PAP are (2) Open all doors in the Assembly Point that have card reader '

(3) Connect card readers at TSC and possibly add 1 more car'd reader

. at the TS (4) Redefine the processing of paperwork for accountability purpose NUREG-0654, Section J.5, states in part, "Each licensee shall

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provide for a capability to account for all individuals onsite at the time of the emergency and ascertain the names of missing individuals within 30 minutes of the start of an emergency..."

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The. licensee's corrective actions will be tracked as Open Item N .

The inspector concluded that, in general, this portion of the licensee's program'is satisfactory.

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. Emergency Operations Facility The-inspector evaluated the Emergency Operations Facility (EOF) staff's ability'to activate the facility in a timely manner with appropriate skills and' disciplines, provide offsite dose assessment capabilities,

' recommend protective actions, interface with offsite officials, and t

disseminate information to the medi The NRC observations of activities in the EOF noted certain areas where a the licensee's response was particularly effective or improved. The staff made good use of procedures and kept the Emergency Manager advised of required actions. The Air Resources Board representative's input to the meterological information proved to be a valuable asset. The Emergency Manager held frequent briefings with State and local officials and updated them on plant status and SMUD recommendation . _ . , _ -, . _ _ _ _ _ _ - , , _ , . . . , _ . m-_. --. m_.. , _ , , - . _ . -

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The following NRC observations should be considered when evaluating the exercise results and identifying areas that need improvemen The notification form transmitted to the EOF which is described in AP-506 (Appendix 7.1) is inadequate to record the licensee's specific protective action recommendations (PAR). The form references Procedure AP-528 but has no provisions to record the actual PAR that was mad It would be difficult to reconstruct the licensee's PARS based on information provided by this for The Dose Assessment Coordinator (DAC) was unable to produce dose projections for hypothetical radiological release situations utilizing available plant data. On several occasions the DAC received requests for hypothetical dose projections, and on each occasion was unable to provide i The dose calculation procedure (s) as well as the position capability should be reevaluated to assure such information can be generate This item will be tracked as Open Item No. 86-32-0 The inspector concluded that, in general, this portion of the licensee's program is satisfactor . Critiques Immediately following the exercise, the controllers held critiques in each of the emergency response facilities except the TSC. Discussions of oSservations were conducted between the controllers and the participant Two formal critiques were conducted the following day, one involving onsite activities and the other concerning offsite activitie The following represent the types of comments made at these meetings:

  • The number of telephones was not sufficient to support the number of people in the Control Roo The call out notification took longer than desirable, taking 45 minutes to complete. This delay was attributed, in part, to the fact that each call was sequentially made and manually dialed. An automatic dialer was suggested as a corrective actio The forms used to describe the release do not have the capability to differentiate between actual and projected release dat Operators did not have enough health physics support for the team High background noise in the TSC hampered communication Warehouse A, where the PAP was located, contained no drawings of areas outside the building The Emergency News Center would not be adequate to support its responsibilities during a real emergency.

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11. Followup On October 3, 1986 Temporary Loss of DHR Operation A followup inspection was performed to determine if the classification of )

a loss of the decay heat removal system during an event that occurred 1 October 3, 1986 was correct. Based upon this inspection it appears the i

licensee properly classified the event, however, it appears some changes in the classification procedure would be beneficia On October 3, 1986 (9:47 AM PDT) the licensee lost the services of the decay heat removal system for approximately 13 minutes. The plant had been in cold shutdown for approximately 281 days. Prior to the 13 minute loss of the Decay Heat Removal (DHR) System, decay heat loop B was in a standard operating configuration. Loop A was not functional due to planned maintenanc The B loop of the decay heat removal system became inoperable due to the closure of an isolation block valve on the suction side of the decay heat removal pump. The valve closure was due to a spurious signal received by the Safety Features Activation System. The licensee believes the spurious signal was generated by an electrical transient on the 120-volt vital AC bus. The licensee's corrective action to return the DHR system to operation was successful. The licensee opened the closed valve from the Control Room and reset the breakers on the DHR pump. No damage to any portions of this system that would impair the functional ability of this system was reported. The system was merely disengaged from operation (shut off) for a short amount of time with no loss of functional capabilit Based upon a review of the Emergency Plan and the classification procedure, AP 501, " Recognition and Classification of Emergencies", the licensee classified the event correctl Tab 14, " Loss of Plant Shutdown Systems", requires an Alert be declared when the DHR is not functiona Because the system did not sustain any damage to the components of the DHR system, it did not lose the ability to function. The inspector concluded that the event did not meet the definition for not being func-tional and did not meet the criteria for an Aler Attachment 7.3 of AP 501, " Action Level Criteria For Classification of Emergency Conditions", was also reviewed to determine whether the event warranted the classification of an Unusual Event. Based upon this review the event did not require any emergency classification. The October 3, 1986 operational situation did not meet the criteria for an Unusual Event. The definition of an Unusual Event requires that the safety of the plant be degraded to the point of exceeding a limiting condition for operation, as defined in the Rancho Seco Technical Specifications, and requires immediate safety concern. The October 3, 1986 event did technically exceed a limiting condition for operation, but was not of immediate safety concern, consequently the declaration of an Unusual Event was not applicable. However, this review determined that the licensee's procedures may lead to or require an incorrect classification of an emergency event. The current procedure, AP 501, does not consider the mode and status of the plant in the formulation of a classificatio According to Tab 14 of this procedure, an Alert classification is required upon the loss of any function needed for cold shut down of the

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plan Specifically referenced to meet the-Alert criteria was-the loss of the ability to sustain natural circulation,' the loss of the ability.to sustain forced circulation, and the loss of the function of the'DHR '

-system. During this inspection and during the October 3' loss of DHR, the licensee was in the process of performing numerous. maintenance activities which included maintenance on the steam generators. .The st.eam generators were-open and this activity would preclude the ability to sustain natural circulation. Consequently, because of the maintenance activities currently in progress, AP 501 would lead to an incorrect classification of an Alert.upon the. loss of forced or natural circulation capability, regardless of the operating mode:of the plant. The licensee shoul consider improvements in AP 501 to account for the. operational mode of the reacto . Exit Interview An exit interview was held on October 10,#1986 with>1icensee representatives. Licensee personnel and their contractors attending this exit interview have been identified in Paragraph 1., NRC representatives at the exit-interview included the team members, senior resident and resident inspectors. The observations'identifiedLin the above Paragraphs 6-9, as well as other observati ns 9 of lessor importance made by the inspectors were discussed. The licensee was informed that no violations of NRC requirements were. identifie .

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