IR 05000312/1989014

Insp Rept 50-312/89-14 on 890828-0901.Violations Noted Re Failure to Conduct Required Semiannual Health Physics Drill & Initial Training.Major Areas Inspected:Operational Status of Emergency Preparedness Program

ML20248C852
Person / Time
Site:	Rancho Seco
Issue date:	09/11/1989
From:	Fish R, Good G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20248C842	List: IR 05000312/1989014 ML20248C840
References
50-312-89-14, NUDOCS 8910040043
Download: ML20248C852 (8)

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,  : U.IS. NUCLEAR REGULATORY COMMISSION

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7 ," Report 1No.' 50-312/89-14 yppg* 4: . ,

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, Docket'N L h ,r i License'. N ,

'DPR- 54 *

. Licensee:: Sacramento Municipal Utility Distric >

.14440 Twin Cities Road

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Herald, California 95638-9799

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o Facility Name: Rancho Seco Nuclear Generating Station -

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' kJ s : Inspection at: Clay Station, California

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, Inspection Conducted: -August 28 - September 1, 1989 b o . ' Inspector:

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lG.LM. Good,-Emergency Preparedness Analyst - .Date Signed B4 , 'Npprovedby: - 1

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. R. F. Fish, Chief Date Signe a f,',1 *

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,! Emergency Preparedness Section -

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$ SUMMARY: o .e , N, s

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, / Inspection' orf August 28 - September 1,1989 (Report No. 50-312/89-14)

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L1 f ;'>' y , Arhas'Insbected: Unannounced.. routine inspection in the area of Operational

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Status:ofsthe Emergency Preparedness Program. Within this program area, 4,7 4' L '

t l emphasis was placed'on the drill and exercise program, maintenance / initial '

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g training'of>the emergency response l organization (ERO), the annual audit of the -- '

Jemergency preparedness program, ERO-retraining, and staffing of the licensee's

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p pg' ' * $ emergency, preparedness group. Inspection procedure 82701 was use ,

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L'^ (Results: . 'Three a'pparedi violations were identified during this inspection.

&xi L0ne, violation involved the f ailure to conduct a required semi-annual nealth '

l physics l drill; -The second violation involved the failure to conduct required g'. Linitia1Ltraining before assigning individuals.to the active ERO. The third

- l violation involved the failure to conduct required retraining of individuals L

assigned to the active ERO. The inspection also disclosed a potential for

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further' degradation of the maintenance of the emergency preparedness program

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- due'to projected staffing cuts-in the emergency preparedness grou . Collectively, the results oflthis inspection represent a decrease in the level

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Eof. emergency. preparedness.at Rancho seco. The findings also appear to g , represent a decrease in management's commitment to the emergency preparedness

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e j. <t n DETAILS

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c t I i c Persons Contacted ' [;

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R. Dorr, Contractor, Emergency Preparedness ,'

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W D..Finle9, Emergency Preparedness Specialist

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F. Thompson, Emergency Preparedness Specialist ,

'J. Toresdahl, Supervisor, Emergency Preparedness *

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<D. Yows, Manager,. Environmental Monitoring and Emergency Preparedness

, . 2.~ Operational Status of the Emergency Preparedness Program (Inspection ,

g? Procedure 82701)-

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.. . Drill and Exercise Program '

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i The purpose of this part of the inspection was to determine whether the licensee has- been maintaining the required drill and exercise program. To determine this, the inspector reviewed Section 8.3 of the licensee's Emergency Plan (EP); reviewed Emergency Plan Implementing Procedure (EPIP)-5610, " Drills and Exercises", Revision 1, dated March 9, 1989; reviewed the Drill and Exercise Manual referenced in EPIP-5610; reviewed the 1989 Drill Schedule, and; -

discussed the drill and exercise program with the Manager, Environmental Monitoring and Emergency Preparedness (EM&EP) and with members of the emergency preparedness staff.

l During the aforementioned discussions, the inspector was informed that a " dress rehearsal" drill, in preparation for the December annual exercise, scheduled for June 15, 1989, was cancelle The L inspector was informed that the decision to cancel the " dress f- rehearsal" was made by upper managemen The scope _of the " dress rehearsal" incorporated a health physics drill which was required.

l Section 8.3.5.a of the licensee's EP requires that a semi-annual L health physics drill be conducte EPIP-5610 provides the l methodology for conducting the drills and exercises identified in Section 8.3 of the EP and references a Drill and Exercise Manua Section XIII.8 of this manual describes the implementation of this semi-annually required dril Section 1.9.7 of the licensee's Technical Specifications (TS) defines semi-annual as "A time period spaced to occur at least once per six (6) months." The inspector was informed that a health physics drill had not been conducted since October 3, 198 The failure to conduct a semi-annual health physics drill required by Section 8.3.5.a of the EP represents an apparent violation of 50.54(q) of 10 CFR Part 50. Paragraph 50.54(q) requires licensee's to follow and maintain in effect emergency plans which meet the requirements in Appendix E. Appendix E.IV.F (training) requires the training of employees by periodic drill (50-312/89-14-01)

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e , Emergency Response' Organization (ERO) Maintenance / Initial Training This part of the inspection was conducted to determine whether the licensee was able to maintain its ERO given-the present fluxuations and unpredictability of the plant and corporate staffs. To

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accomplish this, the inspector reviewed the requirements for assignment to the ERO, reviewed the Emergency Response Telephone Directory (ERTD), reviewed computer records generated using the training database, and discussed the subject with.the member of the emergency preparedness staff who has the responsibility to' update the ER The licensee's total ERO, whit.h includes the licensed and non-licensed reactor operators, consists of about three hundred seventy five (375) individuals. The ERTD lists, by name and position, those individuals in the ERO who could be called upon to respond in the event of an emergency at Rancho Seco. The ERTD identifies about 60 different emergency response positions with varying numbers of individuals to fill a given position. The first-person listed is considered to be the primary responder and the others are considered to be the alternate responders. EPIP-5200,

" Activation and Operation of the Technical Support Center (TSC),"

identifies ten (10) positions in the TSC that are considered to be essential. EPIP-5300, " Activation and Operation of the Operational Support Center (OSC)," identifies two (2) positions in the OSC that are considered to be essential. EPIP-5400, " Activation and Operation of the Emergency Operations Facility (EOF)," identifies five (5) positions in the EOF that are considered to be essentia The licensee has also identified two (2) positions in the Unified Dose Assessment Center (UDAC) that are considered to be essentia !

There are a total of seventy seven (77) individuals identified in the ERTD to fill these nineteen (19) essential positions.

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Specific requirements related to the initial assignment of individuals to the ERO were found in EPIP-5600, " Training." Section 5.2.10 of EPIP-5600 requires that " personnel receive initial training before being placed in the active ERO."

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The inspector discussed the above process with the member of the

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emergency preparedness staff who is responsible for maintaining the ER0e This individual stated that, with the present situation, it is 1

.a full time job to update the ERO and to keep an up-to-date ERT I This person indicated that the ERO has to be updated on a daily

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basis due to staff reductions. This person explained that an I

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- Emergency Response Change Request Form is completed whenever changes

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, position change). . This individual further explained that when an

. ; ' individual is added to the ERO, they are considered to be a designee i

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and are categorized on the ERO as a "D." When the individual has <

, [ < completed the. required initial training for the position held, the

. . individual's category becomes a "T." In accordance with EPIP-5600, only individual's categorized as "Ts" are to be placed on the active

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In reviewing.the ERO essential ~ staffing roster, the inspector found

. .that fourteen (14) of the seventy seven (77) individuals listed in

..the ERTD under the nineteen (19) essential positions had not completed all of the required initial training prior to being i '

assigned (i.e;, listed'in'the ERTD) to the positio Specific initial.and retraining requirements for each emergency response t . position are described in Attachment;7.1 of EPIP-5600. Eleven (11)

?s .of the individuals were placed in the ERTD on April 1, 1989, and the -

Y, y three (3) remaining individuals were placed in the ERTD on July 1, ,

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? Of these fourteen (14) individuals, seven (7) are listed as primaries; +'

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Assigning personnel to the active ERO (ERTD) before the initial

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.. training, requirements in EPIP-5600 have been met is contrary to-

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.Section 5.2.10.1 of EPIP-5600 and is an apparent violation o ,

j Section 6.8.1.e of the licensee's TS. Section 6.8.1.e of the *

1icensee's TS requires that written procedures be established, '

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implemented and maintained covering EP implementatio ,

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j Annual Emergency Preparedness Audit (50.54(t)) i

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The licensee's annual 50.54(t) audit was examined during this )

inspection. The audit was conducted by a contractor on May 11-26, -l 1989. The report was issued on June 23, 1989. The EM&EP Department j responded to the audit on August 24, 198 '

A review of the audit indicated that the scope was adequate. The audit identified two (2) Findings and twelve (12) Observation Findings are defined as deficiencies representative of a programmatic breakdown. One of the Findings (#89-A-020-01(F))  ;

involved a problem with training documentation. The auditors were j unable to verify, through documentation, that the training l qualifications identified in EPIP-5600 had been met for six (6) of j nine (9) ERO position {

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This Finding was discussed with emergency preparedness personne During those discussions, the licensee representative stated that the problem with the documentation involved the lack of training )

exemptions. Section 5.2.7 of EPIP-5600 provides for training )

exemptions based on drill / exercise participation if: (1) the  ;

performance is satisfactory; (2) the exemption is documented j including a full justification, and; (3) the individual is an active participant, controller or observer for the position he/she normally holds in the ER In response to this audit Finding, EM&EP stated that the condition  !

was the result of inadequately maintained training records for 1987 I and 1988 and that the problem was due to a lack of procedural guidance. In terms of actions to correct the problem, EM&EP ,

developed a procedure (EDAP-0501, "ERO Training Records i Maintenance") to govern training documentation. In addition, EM&EP j committed to completely retrain all ERO members by November 30, i 198 .

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For the' purpose of;this_ inspection',lif. training records, including exemption forms, could be: produced to show that an individual was actually current in their training,.the inspe';or considered the C training requirements,of EPIP-5600 to be met, even though the br individual may'have torrepeat training to meet the EM&EP commitmen .' ,

Pertinent to this issue,.the.1988 50.54(t) audit (audit number

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F 88-A-017, dated February 18, 1988) identified. problems with-H

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, emergency preparedness training. records. In addition,:the 1988.

[' audit report addresses the findings of the 1987 audit (audit number ll ,87-022, dated May 15, 1987). ' One of these findings

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R (87.-022.02/II.2),. involved emergency response' plan training'and L another (87-022/VII.2) involved retraining. Both of these findings

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were identified as being open (not completed)..

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c, .No violations of NRC requirements were identified during this l . portion-of th'e' inspection'; however, the audit reports reviewed sho T L , ta historylof problems related to the' emergency preparedness training p ,'

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rll delinquent in~their retraining'be removed from the active ERO *

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' '% ",~ ' %(ERTD). The inspector. reviewed the ERO database,.the ERO training ( dstabase and the ERO essential staffing list against the ,P retrai

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L 4 4.1'f{+^ " h 3~ requirements. identified in EPIP-5600. The. inspector found that' YY I sW + . ~- about one hundred fifty (150) of the three hundred seventy five' '

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"(375), total ERO had not.been retrained in accordance with EPIP-5600) '

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,. This9 number includes those individuals who's training had lapsed,'as

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m s 4well'as.those. individuals for'which valid training exemption forms-do not exist. It was beyond the scope of this inspection to a

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determine which of these individuals were actually listed in the

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'ERTD; however, the numbers would appear to indicate that there are , -

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many individuals listed in the ERTD in the non-essential positions '

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who were not removed from the active' list when their training '

L i r qualifications lapse "

-To narrow the scope of the extent of the retraining problem, the inspector focused on the status of retraining for the individuals listed in the ERTD in the nineteen (19) essential positions. Twent nine (29) of,the seventy seven (77) individuals listed on'the ERO essential. staffing roster are considered to be delinquent in their retraining. Two (2)' licensed operators were also found to be delinquent in retrainin The failure to remove persons from the active ERO who had not completed the retraining requirements is contrary to Section 5.2.10.2 of EPIP-5600 and is an apparent violation of Section 6.8.1.e of the licensee's TS. (50-312/89-14-03)

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y Emergency Preparedness Staffing The inspect'or reviewed and discussed the current and projected

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' staffing levels on the emergency preparedness side of EM&EP to

' determine whether any recent staff reductions or future staff ~

reductions would have an effect on the EM&EP Department's ability to maintain its emergency preparedness program. The inspector found that EM&EP had an emergency preparedness. staff of eleven (11) in

. April 1989. This included the Manager, EM&EP. As of September 1, L 1989, the number will be reduced to six (6). An additional person will be leaving the end of September 1989 and two (2) more are scheduled to leave on December 1, 198 This will bring the total staff to three_(3). Based on the projected staffing cuts, it would appear that the emergency preparedness staff's ability to maintain the required program, including conducting an annual exercise,

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conducting required drills, maintaining the ERO, maintaining emergency response facilities', conducting training and keeping up with. commitments, is in question.

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No violations of NRC req.uirements were identified during this part

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.of-the inspection; however, the emergency preparedness staff's ability to maintain and implement its EP is of concern to the NR . Exit Interview

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~An exit interview was held on September 1,1989, 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. G. Yuhas, Chief, Emergency Preparedness and Radiological Protection Branch, and Mr. C. Myers, NRC Resident

"- Inspector were present. Mr. G. Kalman, Rancho Seco Project Manager, and Mr. F. Kantor, Section Chief, Emergency Preparedness Branch, represented

NRC Headquarters and participated in the exit interview via a conference cal During the exit interview, the licensee was informed that it appeared that four violations of NRC requirements had been identifie The inspector described the three apparent violations identified in'2A, B and D above. In addition, the inspector summarized and provided some perspective regarding the extent of the training problem. The inspector also discussed some of the apparent reasons for the problems identifie Closing remarks and conclusions were jointly offered by the inspector and her Branch Chie The fourth apparent violation was identified immediately preceding the exit interview. This apparent violation involved the implementation of an Administrative Procedure (RSAP-0505) governing document control. Two EPIP binders issued to the EM&EP Department were found to contain an out-dated revision of EPIP-5600. Subsequent to the exit interview it was determined that the binders in question were lower tier copies and that a current revision of EPIP-5600 was located in the binders, but the old revision had not been removed. Subsequent to the exit interview several Level 1 locations were checked and verified to have up-to-date copie Concurrently, the licensee had the old revisions removed from the binders

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mentioned aboves. . Because-the problem involved a lower level document

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• ] to remove an old revision, it was determined that the matter did not constitute a violation of NRC requirements.

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, To summarize and put the training problems'into perspective, the inspector informed the licensee that ten (10)-of the nineteen (19) ERO essential positions had no one qualified (per EPIP-5600) to perform the duties. The Emergency Manager in the EOF and the Radio. logical Assessment Coordinator in the TSC were among'those positions. The licensee was also informed that eight (8) of the ten (10) essential TSC positions, one (1)

of the two (2)' essential OSC positions, and one (1) of the five (5)

essential EOF positions had no one. qualified to perform the the emergency tresponse dutie '

l The li$ensee was informed that the results of this inspection indicated a

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. decrease in the level of emergency preparedness at Rancho Seco and that s

the NRC had' concerns about the licensee's ability.to imp 1'ement'and

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maintain'its. emergency preparedness program. The inspector also raised n 4i the issue of why hadn't the " Potential Deviation from Quality" (PDQ) , _

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of the implications of their actions. This process is intended to

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' provide a vehicis for personnel to identify issues involving potential

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4 s4 l;; 7 i , non-conforming. condition The licensee did not provide a response to the'PDQ issu ,

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. ^ The^ licensee responded to the'results of the inspection and the

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. concluding statements by committing to: (1) having at least one

,* individual trained in each of the nineteen (19). essential positions

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withinl twenty four (24) hours; (2) having the alternates trained within g

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one week; (3)iproviding the NRC, within twenty four (24) hours,.with ,

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letter committing to items (1) and (2), and; (4) providing the NPC with a ,

.' ' letter on September 8, 1989, outlining an action plan to address the broader issues of the inspection findings' and to provide the District's

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L L corrective actions to resolve the '

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ATTACHMENT EXIT INTERVIEW ATTENDEES P. Bender, Manager, Quality and Safety Q. Coleman, Supervisor, Quality Assurance i

J. Delezenski, Supervisor, Licensing 1, R. Dorr, Contractor, Emergency Preparedness T. Khan,- Manager, Design Projects and Configuration P. Lavely, Supervisor, Root Cause, Licensing R. Mannheimer, Licensing Engineer S. Redeker, Manager, Operations Department J. Shetler, Deputy Assistant General Manager, Nuclear J. Toresdahl, Supervisor, Emergency Preparedness l.

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