IR 05000312/1987019
| ML20236P029 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 07/17/1987 |
| From: | Fish R, Prendergast K, Solberg M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20236N971 | List: |
| References | |
| 50-312-87-19, NUDOCS 8708120193 | |
| Download: ML20236P029 (6) | |
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l U. S. NUCLEAR REGULATORY COMMISSION
REGION V
Report No.
50-312/87-19 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: June 1-5, 12, and 16, 1987 Inspectors:
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Kent M. Prendergast,LEmergency Preparedness Dath Signed Analyst YbOh b7.A$anw 7b7//7 hv Mary. E. Solberg', Emergency Preparedness Date Signed Engineer, NRC Headquarters Approved By:
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,R. Fish, Chief, Emergency Preparedness Date Signed Section Summary:
Inspection on June 1-5, 12, and 16, 1987 (Report No. 50-312/87-19)
Areas Inspected:
Unannounced inspection of the licensee's emergency preparedness program including:
knowledge and performance of duties (training), licensee audits, and follow-up inspection concerning an allegation by a former contractor employee.
Inspection procedures 82210 and 82206 were covered.
Results:
One apparent violation of 10 CFR 50.47 and Appendix E was identTfied.
The violation involved the failure to correct deficiencies identified during the 1986 Health Physics / Medical Drill.
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DETAILS 1.
Persons Contacted SMUD Personnel
- C. Andognini, Chief Executive Officer, Nuclear
- D. Ferlit, Assistant General Manager, Nuclear
- G. Coward, Plant. Manager
- B. Croley, Director of Technical Services
'*D. Martin, Manager, Environmental Protection
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S. Frey, Emergency Planner
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- R. Myers, Supervisor, Emergency Planning
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Contractor Personnel i
- C. Stephens, U.E.S.
M. Stephens, U.E.S.
- Indicates personnel attending the exit interview.
2.
Licensee Audits
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The inspector verified that an independent audit of the emergency preparedness program had been conducted on an annual basis in accordance with 10 CFR 50.54(t).and Section 8 of the licensee's Emergency Plan.
A Quality Assurance audit was performed during the week of March 30, 1987.
.This audit was performed to meet the above stated requirements and
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documented in report No.87-022.
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An' examination of the audit report showed approximately 30 open items were identified in the areas of training, procedures, administration, l
. facilities, and equipment. The 34 items were then consolidated into_four major areas and entered into the. Quality Assurance Tracking System.
The Quality Assurance Tracking System appears to be the official tracking system for the corrective action on items identified during 50.54(t)
audits.
The Emergency Preparedness organization has until June 30, 1987 to provide a response to the Quality Assurance (QA) Department on the open items.
This response will be examined during a subsequent NRC inspection to determine the effectiveness of the licensee's program for addressing the concerns identified during the annual 50.54(t) audit-(0 pen Item 87-19-01).
A review of the audit distribution list was performeo to determine that the audit was distributed to appropriate members of plant and corporate
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management and state and local agencies pursuant to 10 CFR 50.54(t).
The review indicated that the audit had been distributed to appropriate members of both plant and corporate management; however, the distribution to state and local agencies had not yet been accomplished.
According to the QA Department, state and local agencies will be sent a copy of the portion of the audit that dealt with the interface between the licensee and them in the near future.
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-No violations of NRC requirements were identified during this portion of the inspection.
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Training An examination of the licensee's training program for emergency preparedness was performed to determine the extent of the many changes to the program.
Presently, the. licensee is in the process of revising the Emergency Plan, revising the implementing procedures and rewriting the
lesson plans for emergency preparedness training.
An examination of the draft Emergency Plan showed that the rewritten Plan was nearly complete, primarily. awaiting attachments and illustrations for.
the many changes to procedures and facilities and equipment. The licensee has also made progress on the revisions to the implementing l-procedures.
According to the licensee, 32 of the 37. implementing procedures are complete and are either approved or.in the approval process.
The Emergency Plan training modules are also being' revised significantly due to the many changes in the Plan and-implementing procedures.
The licensee stated that the new lesson plans are approximately thirty pe. cent complete.
The scheduled completion'date is early in July 1987, to allow time for emergency preparedness training to be completed prior to the annual exercise scheduled in November of 1987, or plant start up whichever ocrars first.
An examination of the licensee's program for conducting drills and exercises was performed, to determine if the licensee has an effective program for correcting deficiencies identified during drills and exercises as required by 10 CFR 50.47 end 10 CFR 50-Appendix E.
Based upon this examination one apparent violation of NRC requirements was i
ider tified and is discussed below.
The "1986 Health Physics / Medical Drill" report identified deficiencies in environmental sampling relating to the adequacy of procedures, equipment and training resulting in much of the emergency environmental sampling having to be simulated during the 1986 drill.
The report further identified numerous recommendations to correct the deficiencies.,The recommendations included the following:
procedures to perform onsite environmental sampling should be written and included in the plan or a reference should be made in the procedures referring the reader to the environmental program procedures.
If the latter is done, the environmental procedures program procedures must be reviewed to ensure they address all possible samples that may be collected:
soil, vegetation, air, water.
The report further stated, "If new procedures are developed, the survey team must be trained in proper techniques and procedures for environmental sampling." An examination of the critique for the May 7, 1987 Health Physics Drill stated "...there were no
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environmental procedures or equipment." Discussions with the evaluator for the emergency environmental sampling portion of the Health Physics Drill also indicated that training in emergency environmental sampling was inadequate.
Based upon the findings of the 1987 Health Physics drill, it appears that deficier.cies were not corrected.
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An examination of the 1986 Medical Drill report also identified de'iciencies in the rendering of first aid.
The 1986 report stated that
"..the general handling of victims by onsite first aid personnel and t M ir knowledge of emergency equipment needs to be improved (e.g., proper
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placement of the collapsible stretcher underneath the victim, placement of oxygen mask, monitoring of vital signs, elevation of feet versus the head, etc.)."
The medical drill report further contained the following recommendations to correct the deficiencies:
" require additional first
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aid training with simulated injuries for the persons on the emergency
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team; training should interface with the ambulance personnel, and to evaluate each participant at the completion of the training program."
The examination of the 1987 Medical Drill also indicated the deficiencies were not corrected.
The documentation for the 1987 Medical Drill identified the following deficiencies; the inability to take vital signs in high noise areas (palpation), the failure to use oxygen when it would have been necessitated, inadequate patient surveys and history taking, some deficiencies in emergency first aid equipment and supplies,. lacking or nonexistent techniques for patient extrication, and the lack of communication with the Life Flight emergency medical team.
It should also be noted, that first aid training was the subject of an NRC violation issued on October 28, 1986 for not completing the first aid training required by the Emergency Plan.
The licensee's response to the violation stated "...that Emergency Team members will be enrolled in appropriate training and retraining programs and at least one member of the Emergency Team will have advanced first aid training or the equivalent."
10 CFR 50.47(b)(14) and IV.F.5 of Appendix E to 10 CFR 50 require deficiencies identified as a result of drills and exercises be corrected.
It is apparent from the documentation for the 1987 Health Physics / Medical Drills that the licensee has not been effective in correcting the above discussed items identified during drills and exercises.
This is considered a violation of NRC requirements.
The licensee's implementing procedure for drills and exercises, AP-582, requires approval of the Plant Superintendent for drills and exercises.
If Nuclear Operations is to be involved in the drill, the approval of the Plant Manager is also required.
A review of the 1987 drill packages for the Health Physics / Medical Drill and discussions with personnel conducting the drill indicated the approval of plant management was not obtained.
No documentation supporting approval by plant management for the 1987 Health Physics Drill or the 1987 Medical Drill was produced
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during this inspection.
The lack of coordination appears to have resulted in the Health Physics Drill being started in the Control Room while NRC Operator Licensing was being conducted, causing congestion in the Control Room.
The lack of coordination was also responsible for a major portion of the onsite objectives to be simulated outside of the Control Room, due to nonparticipation by the operations staff because of I
I scheduling priorities.
Because of the numerous problems encountered during the 1987 Health Physics / Medical Drills, the licensee has stated their intent to conduct another drill to satisfactorily demonstrate the major areas that were i
unsatisfactory in 1987.
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One violation.of NRC requirements was identified in this program area.
4.
Allegation RV87-A0031 a.
Characterization A former contractor employee stated that there was documentation in his/her files that indicated the Emergency Plan could not be'
implemented because the call 1.ist had not been maintained as required and that~some. personnel in the emergency response.
organization were listed and holding positions for which they had not been trained.
The employee also expressed concern'that the files might be removed or altered during the night.
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Inspection Follow-up An inspection was performed to examine the' documentation referred to in the allegation.
During the inspection, a list was compiled of all the files in that person's former work area.
The examination of the Emergency Recall List in the files did verify some members of the' emergency response organization' held positions in the organization that they had not been trained for.
However, this was not considered adversc to safety because the list was an updated recall list and'had not yet been distributed for use.
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inspection also showed that the current recall list was out of date and still contained the names of a few key officials, listed for recall during an emergency, who were no longer employed by the utility.
This problem was also brought to the licensee's attention during the exit interview and it was suggested.the licensee consider establishing a method to insure the Emergency Recall List reflects the current organization.
To insure that time would not be wasted trying to call an individual who may not be available, and that the list reflects an adequate number of trained. individuals to respond to an emergency.
On June 4, 1987 the findings of the inspection related to the allegation were discussed with the individual who maue the allegation.
The individual was informed that the referenced recall list did contain members of the emergency organization who had not i
been trained.
The inspector noted this list was in draft form and
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had not been distributed and consequently was not adverse to safety.
The list also contained the names of a few key individuals who were no longer with the util 4 g The current recall list in effect at that time also reflected those names; however, the name of another individual qualified to fill that position was correctly noted on i
the list.
The individual was also informed that a check of the i
files did not indicate uy of the files had been removed or altered.
i No violations of NRC requirements were identified during this portion of i
the inspection.
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5.
Exit Interview e
An exit interview was held by the inspector on June. 16, 1987 for the i
piirpose of ' discussing the preliminary findings of this inspection.
Licensee representatives present at'this meeting are identified in'
Paragraph 1 of thisl report.
Mr. R. Fish, Chief, Emergency Preparedness
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Section, and Mr. A. D'Angelo, Senior Resident-Inspector,.were also
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present as representatives of the NRC.
During.this. meeting the licensee was: informed of the problems identifled.in their emergency preparedness
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drill' program.and of the apparent. violation of 10 CFR 50.47 as. described in Section 3 of the. report.-~ It was also suggested the licensee' consider establishing a method to insure their Emergency Recall List is'
maintained.
Other items discussed during this meeting are described in Sections 2'through 4 of this'. report.
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