IR 05000312/1990006

Insp Rept 50-312/90-06 on 900402-05.One Noncited Violation Noted.Major Areas Inspected:Followup on Three Violations Identified During Previous Emergency Preparedness Insp & Operational Status of Emergency Preparedness Program

ML20042F576
Person / Time
Site:	Rancho Seco
Issue date:	04/24/1990
From:	Good G, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20042F575	List: IR 05000312/1990006 ML20042F574
References
50-312-90-06, 50-312-90-6, NUDOCS 9005090092
Download: ML20042F576 (11)

Text

g q p y;.

.. -

.

?

d'

Q,s Oi

'

y

.

um,.

wm

.

-

e '

'

+ ' +

.r\\p

,.

,' e

y

-

-

.V.

S. NUCLEAR REGULATORY COMMISSION

.o p

'o, a

H, ;

,'

>

,

y a 1 s

.

-+^f(*"

L.

REGION V

e, l.

,

,,

,

' '

k+

u

_

-r

, -

s h ;'

- % / Report No.

50-312/90-06 E,

t t

t

,7

. g t

" Doc ke.t, No.3 50-312

,a-

' '

g

-

m.

m

',

License No. '

DPR-54

.

o

'

. 1,

<

Licensee:

Sacramento Municipal Utility District-

~

.

-

--1:,

14440 Twin Cities Road j

' Herald, California ~.95638-9799

';

Facility.Name:

Rancho Seco Nuclear' Generating Station-j Inspection at:

Clay Station, California

!

Inspection Conducted:

April PS,1990 Inspector:

k 'm bFb 3 4/R3/%

G.LM. GoodrEmbrgency Preparedness Analyst

Date= Signed-Approved by:

kk

'ilM I 93

'

.

G. - P.

hs, Chief-

< Dat,e Sicjned Emerge Preparedness and

. Radiological Protection Branch-SUMMARY:

Inspection on April 2-5, 1990 (Report No. 50-312/90-06)

Areas Inspected:' Unannounced,' routine inspection to follow-up on three violations identified during a previ_ous emergency preparedness inspection,.

.

and to address the Operational Status of the Emergercy Preparedness Program.

l i

L

. Inspection procedures 92702,;82701 and 30703 were used as guidance.

'

Results:

One non-cited violation was identified for failure to conduct an c

- annual review of the Emergency Plan Implementing Procedures as recuired by-l the Emergency Plan (see sect.'on 3. A).

The violation was not citec, because L

the criteria specified in section,V.A of the Enforcement Policy were.

satisfied.

The three violations were closed.

The results of;this inspection indicated that.the licensee was adequately maintaining 4its emergency (-

.

l preparedness 3rugram.

The findingsLin section-3.A'show that the licensee

'

<

could strengtlen its method'of ensuring that required components of the

]

emergency preparedness program are completed.

'

' >'

,

,

,

o,

-

oA

~

(

,

b'~

9003o9o0 6 900424

'

apock0500[3g2 7y

1. .

"

,,. ;

pas t

o

.

{-

Q:

w

,

f+

,:4-1;.

'

a e

(

,i)

'

fxl

'

mqQ1 3

.

,

,,

g

<

m

,

'

• - '.

. ',

.

,-

s

,

._

.

'

,[

>

.

,

,

,

'

.

• '

i

'

DETAILS

.

1.

Persons Contacted:

M. Borter, Supervising Radiological Engineering Specialist

!

=M. Bua, Manager,; Radiation Protection (RP)

'

C. Eichhorn, Jr., Technical Advisor, Emergency Preparedness (EP),-

Contractor-

'

O. Elliott, Principal Engineer R. LeNeave, EP Specialist

'

P. Noisworthy, EP Specialist J. Reese, Superintendent,. Radiological Health

.

F.' Thompson,:EP. Specialist 2.

Action on Previous Inspection Findings'(Inspection Procedure 92702)

.

-(Closed) Violation (89-14-01): ' Failure to conduct a semiannual health-

physics (HP) drill.a The licensee responded to this violation in a letter dated November 21, 1989 (D/AGM 89-080). 'The response stated that, '

i the licensee had~ conducted an HP drill on September 27 1989,:that'

entrance into the refueling mode had been suspended until af ter the successful completion'of the HP drill,z and that licensing had initiated a: Potentia 1' Deviation from Quality (PDQ) (PDQ 89-641) regarding the-failure to conduct the HP drill.

To avoid further violations, the

licensee's response stated that Emergency' would be revised to identify Plan Implementing Procedure r

(EPIP) EPIP-5610 " Drills and Exercises,

'

all regulatory-required drills and their required frequencies;.and that-

-

revision of the drill schedule would require the review and si the-EP supervisor and the environmental monitoring and EP (EM&gnature of

~

P)-

manager. ' The September 1989 HPJdrill was ob erved by the NRC and

..

documented.in NRC inspection report number 50-312/89-15..im of the other corrective actions described in the licensee's"plementation l

response were verified during this inspection, The inspector concluded that adequate

,

management controls appeared to be in place to prevent, future, similar violations.

This violation is considered closed.

,'

'

q

,

.

(Closed) Violation (89-14-02)i Personnel assigned to the'; active N <,

.

,

emergency response organization (CRO)sbefore:initia1 training i*L i

requirements of EPIP-5600, "ERO Trainihg., were' met'.

The licensee's; O '*

response to this violation was included i'n the November:21; 1989, letter mentioned above.

The response. stated that!95% of the ' entire ERO was.

!'%

.

trained as'of October 11, 1989, and that STOP~ WORK ORDERS were issued to.

prevent further destaffing, and to prevent fuel movement',t' Sacramento'y-

untilia full qualified ERO was:in place.

The response also stated;tha

~

Municipal Utility District (SMUD) management had: initiated ^an f i independent investigation into the matters and that.a PDQ d89-643) sas 1 initiated.

To prevent further violations] the response stated that:" 1 the' assistant general manager (AGM) convened a special meeting of h'ist )

,

,.

l

. managers which "resulted in increased management awareness and emphasis. "N

,

L on compliance with the license and regulations"; 2) managers, including

"

,

-

,

F

.

'

,

[i.

>

c

'*

,

.

.

.

2-

..

'

-

.

e the EM&EF manager, were counseled on the importance of maintaining the ER0; 3) sufficient staff would be retained; 4) the AGM would issue a site-wide memorandum to stress the importance of documenting PDQs; 5)

the quality assurance (QA) department would increase its surveillances of the EP program; and 6) EP was developing a formal process to control theuseoftheEROtraIningandstaffingdatabases.-

During this inspection, the inspector verified implementation of the licensee's corrective action.

The inspector found that a trained ERO j

was being maintained, and that when " designees" were being placed in the Emergency-Response Telephone Directory (ERTD), ~they were properly -

identified as such, and instructions were provided regarding..their notification / participation in an emergenc The inspector reviewed the controls established by the three new EM&y.EP administrative procedures:

EDAP-501, "ERO Training Records Maintenance;" EDAP-502 " Maintenance of-Database."g;"and,EDAP-503,"MaintenanceofEPTrainIn'gRecord ERO Staffin

.

The inspector found that the procedures were being implemented, and that they appeared to offer adequate controls to prevent future deterioration of the training records and the ERO staffing, The inspector reviewed the report that was generated as a result of the l

i aforementioned investi ation.

The investigators concluded, in part thatthefailuretomantainandtraintheEROwascausedbythefallure f

of EP staff members to use the PDQ process, and the. failure of the EM&EP

manager and EP supervisor to recogni:e that violating EPIP requirements constituted a violation of Technical Specification 6.8.1.e.'

Corrective

.

actions taken as a result of the investigation included a briefing of i

EM&EP-personnelontheuseofthePDQprocets,-andallEM&EPpersonnel-

,

were required to read the Notice.of violation (NOV) and the licensee's.

el response. The inspector verified that the licensee had implemented the

-

d corrective-actions as described in its response to the NOV.';This-violation is considered closed.

,

l (Closed) Violation (89-14-03):

Failure to remove personnel from the.

active ERO wheri retraining requirements.of EPIP-5600 were not completed.

The licensee's-response to this violation, including the corrective

'

-

,

actions, was incorporated in its response to violation-89-14-02.

The inspector verified that the licensee-had-implemented the correctiv,e i

actions.

This violation is considered closed.

.

3, Operational Status of the Emergency Preparedness Program (Inspection Procedure 82701)

A.

EPIPs The Region V EP section performa an annual review of changes to the licensee's EPIPs.

This review was accomplished in the office, prior to this inspection.

The following procedures were reviewed:-

EPIP-5001, Revision 1, Temporary Change (TC) TC-3 and 4,

" Recognition and Classification of Emergencies" EPIP-5002, Revision 3, " Control Room Staff Emergency Actions"

_

-_-

_ - - -

. - - - - -

-

N=

-

n

,

j

..,

,

,

EPIP-5010, Revision 3, " Notification / Communication" EPIP-5200, Revision 3, " Activation and Operation of the Technical SupportCenter(TSC)"

EPIP-5220, Revision 2; " Security" EPIP-5300, Revision 3 " Activation and Operation of.the Operational Support Center (OSC)"

EPIP-5310, Revision 2, " Personnel Accountability"

}

EPIP-5340, Revision 1, " Personnel Accountability" EPIP-5400, Revision 3, TC-1,r" Activation'an# Ope ation of the Emergency Operatinns facilit/ (E0F)"

EPIP-5410, Revision 1, "Offsite Support and Assistance" EPIP-5420, Revision.1, " Activation and Operation of the. Unified Dose Assessment Center (UDAC)"

EPIP-5460, Revision 3, " Protective Action Guidance"

,

.

FP1P-5600, Kevision 4,."ER0 Training" EPIP-5620, Revision 2, " Procedure Preparation, Review,. Approval and Writer's Guide"

EP!P-5660, Revision 3, ' EP Surveillance Program"-

No significant issues were identified _during this review.

The-questions / comments, which were generated as a result of this s

review, were discussed with licensee's EP staff during this e

inspection.

All of the during this discussion. questions were -satisfactorily answered

-

.

'

During the procedure review described above, the. inspector. noted

,

<

that 28'of the 56 EPIPs had effective dates of. November 1987, and 7-

'

had effective dates of 1988.

A cursory review of these procedures, i

~

was conducted to determine whether any contained outdated

_information.

Onl Evacuation /-

Early Dismissal "y one procedure, EPIP-5320, " Site A

was found with outdated information.

Thin

.procedurecontalnedanincorrectreferencetoanattachmentin another procedure.

A: member of the EP staff noted this error for future correction.

.

,'

To determine whether the licensee was adequately maintaining its

,

Emergency Plan and EPIPs, the inspector selected two procedural

,

requirements, directly relaned to review of the Emergency Plan and:

n

-

the EPIPs, and-determined whether the licensee was performing the.

• required reviews.

One requbement involved an annual review of the '

.

EPIPs, and the other involved an annual review of the offsite

-

.

agreement letters.

The resuRs are described below.

.

\\.

_ _ _ _ _ _... _

_ _ _ - - _ - - - - - - - - - - - - -.

-

.

=

O

~

-

.

,

,

..,

,

m

-

,

3.,

.

Section8.4.1of'thelicensee'sEdergencyPlan(Revision 2)

requires an annual review of the EPJPs; Section 5.6.2'of EPIP-5620

= implements this portion of the plan, and requires that the annual-review be documented on a " Bien,11al Procedure Review" form..It should be noted that-Section 5.6.3.of EPIP-5520~also requires a biennial-' review of EPIPs. - This' biennial review is required bv'

giant administrative procedures, and is also1 documented on th'e.

Biennial Procedure Review" form.'

The annual reviews are conducted

' to ensure that necessary changes are made as a result of drill and exercise findings,-to. incorporate changes-or references to a

supporting procedures, to incorporate changes in staff or personnel assignments, and to incorporate results from internal and external audits. ' Review of this' area resulted in'the following-

-

. observations:

1.

Due to the absence-of the required documentation, " Biennial

~ Procedure Review" forms, it appeared that an annual review of

,

the following EPIPs had not-occurred since'May 1988:

.

l '

EPIP-5320,- EPIP-5345, "Onsite Radiological Monitoring "

EPIP-5350, Offsite RadiologicalEMonitoring;" and, EPIP-5395, i

" Core Damage Assessment."

j-c

-

2.

It appeared that three EPIPs had-notlbeen reviewed lsince March 1989:'EPIP-5420;ProtectiveActionGuidance."EPIP-5430, " Control' Room Do

' :

'

and,.EPIP_-5460,'

3.

The 28 procedures mentioned above, with~ effective. dates of._

- !

1987,,wereslast' reviewed in 1989.

This-appeared;to follow the

<twoLyear cycle.- It should be noted that microfiche * records were nott checked to determine if the 28 procedures _had,been r

reviewed in 1988, because there'was enough evidence (i.e.

the H

7proceduresmentionedabove)toindicatethatannualrevIews>

l were.not consistently being conducted.'

!

Responibilitiesgo'erningthe'annualand-biennialreviewsare

j o~

..

4.

v

'

"

not clearly defined'in the ' Emergency Plan or EPIP-5620.

~

.

f.

t i

.

5.-

.No one in the current EP group was specifically assigned the i

".

tas kof conducting the annual procedure reviews..The current

!

,

'.

(as of April 2 1990) EP supervisor stated that he " assumed" that,the individual who was assigned to-work on procedures was j

'

responsible for conducting theLannualtreviews. 1That

'individualthas. only been a part of :the EP group 'for about 3

',

i 1 months, land he3 indicated that he was not aware that it was his

-;

responsibility.'

'

,

,

'

6 '.

Thedocumentcontrol'daka"tmenthasanestablishedmethodto

]

prompt.the biennial rev ews.

" Biennial Procedure Eeview" forms are automatically: distributed when the biennial reviews

,

are due. The EP group did not appear-to have similar management controls, or a " tickler" system to ensure that the j'

annual reviews were conducted.

-l

_

w-,

r:

<

,

eg'

j,,.

n

.e

-

g (

.s y

[>

>

q

-

,-

.

..

.;

.

m s.

_ '

.

The failure to conduct an annual review of EPIPs as required by step 5.6.2 of EPIP-5620 is an apparent vioiation of Technical Specification 6.8.1.e, which requires.that written procedures be

established im

,

' implementation.plemented,.andmaintainedcoveringEmergencyPlan Prior-to the end of this inspection, the licensee's EP staffEtook the following corrective actions:

1) the-a staff reviewed the 7 EPIPs that had not been reviewed in the past-

?

year, and the reviews were documented on the ap3ropriate' form;EPIP2) a:

TC was made.to EPIP-5620 to define the responsi)ility for the.

-

,

reviewf; 3) the EP supervisor made arrangements to get a monthly t

list'from document control so that the' reviews could be monitored;

"4) EP management' started to developia list of: required EP program -

components, with their associated freq~uencies, to use as a j

management to'o1 to track and document tasks; when completed, the-

'

list will be an attachment to EPIP-5660;-and, 5) major' tasks will u

be incorporated into the daily management schedule.

Based on the corrective actions taken by the licensee, the violation will'not be t

cited, because the criteria of section V.A of the Enforcement Policy were met ((NCV) 50-312/90-06-01).

Section 8.6.2.b of the licensee's Emergency Plan requires EP-supervision toLreview all existing agreements,.and to record the l

-

review and the status.

Inspectio.n into this crea disclosed that-all of the offsite agreements were current.

The inspector found-

'

that, in general, documentation was available to show that regular reviews were being conducted whenever changes to the agreements-were necessary.

The inspector identified a-weak licensee's method forsaccomplishing the reviews. point in the

'

The licensee has not developed review criteria, or a standardized method to document-the annual reviews. This was particularly evident for those-

-

agreements that spanned several-years.

This part of the licensee's program was considered.to be adequate;

.

.

however, the results indicate the need-for increased management

controls to ensure that the Emergency Plan and EPIPs are-maintained.

No deviations or cited violations were identified during this part of the inspection.

b

.J B.

Emergency Facilities, Equipment, Instrumentation and Supplies i

ThispartoftheinspectionwasconductedtodeterminewhethertIie-F licenseewasmaintainingitsemergencyresponsefacilities(ERFsF

"

.

and communication capabilities.

The inspector found that then

-)

licensee has an established, and effective, process for testing

,

communication capabilities.

Monthly communications drills 'are

'

,

conducted to test each piece of communication equipment in each:

,

<

ERF.

The inspector observed the TSC. portion of one of these

.

"

"

'

communications drills.

The drill was conducted in a thorough and

-

<

"J systematic manner.

Two members of the licensee's EP staff

_

,

w

'

-

conducted the drill, and'a telecommunications specialist was

'

a present.

The licensee's EP surveillance program-also covers the physical

'

maintenance of the ERFs, and the supplies maintained within each

..

i j

%

",

~,

n-

-

m

.

,

y

}

Y N6l

'

X

q

-

s

<

-

,

"

.%'-ofacility.. The.inspebtor veriti$d th'atlthe TSC was-being maint

[

F 3_

~

-

'

in a state of readiness.. During'the inspection, the inspector was informed thatt recent' problems had been encountered at the-EOF.

s lDuring a' drill.;that'was conducted on March 28, 1990, participants found that several telephones ind status boards had been moved, and

,J copy, machines were not readi19; usable.4 These problems were attributed to' personnel whoiwork out of the EOF on a daily basis, but-who are not involved:in' emergency response activities. -To preclude further deterioration of the EOF, the deputy AGM stated.

that he war preparing a' letter to the responsible department.

This part of theilicensee's program appeared to be effective.

No deviations or. violations'were identified.

C.

Organization and Management Control Sincethissubjectwaslast' inspected,severalsignificantchanges have been made to the management and staffing associated with tie-EP program.. The-most significantichange. involved the consolidation of EP with radiation protection ~(RP)3 to make a new RP&EP area As a result, the-positions ~of EP_ manager and-supervisor _have been eliminated, and replaced with the positions-of RP&EP manager and supervisor.

This consolidation was effective as of' April 2, 1990, and coincided with the departure of the. previous EP manager." The.

,

new RP&EP manager and supervisor-(superintendent) came from the-RPJ department, where they held equivalent level positions.

Although'

both of these individuals have-RP backgrounds and management

'

experience, neither hasehad any specialized training in the area of J

EP, other than their participation in EPcdrills;and exercises.

TheE-l two individuals stated that,;in preparation for the management turnover they had received training-from the previous EP manager.

They' indicated-thatthetrainingperiodlastedseveral: weeks,and that the training involved nearly.100% of their time.' Both.of the individuals, and licenseeananagement pers'onnel,_ expressed confidence in their ability to manage.the~EP; program.

-!

This inspection gave the: inspector.an opaortunity to observe the

-

.

!

performance of the,new EP management.

Tle inspector found that the

,t two individuals were enthusiastic about their new positions, 'and-

that they were already looking for areas;to improve.s-For example,;

the corrective actions taken as a_ result of: the-non-cited

'i violation, described in section' 3. A Labove, were thorough, cand

indicated an appropriate level of management control.. Also, the new RP&EP supervisor','who will be managing the' day-to-day-

.j

activities of the EP group,-has requested that all EP staff members

!

complete maintenance manuals, in order _to document details of

individual assignmeits and tasks.

The maintenance manuals arei intended to: function as 'a m,anagement tool, and as a trai_ning; guide I'

whenever duties are~ transferred tosdifferent individuals..The inspector determined:that bothsof these improvements would also j

'

serve as. educational tools for the.new EP management.. ~ Based on the i

' observations made:during thishinspection, the inspector concluded

.that the new RP&EP manager and supervisor appeared to be fully

'

capable-of; implementing the EP program.

'

~

.

w

,

q

,

d

.

-

....

l xp l1 7 (,,

J

.:

.'

'

y

.;

(

(w

3 x

v

,

.>

v

+

-

-

y

.

.

x nn

..

.y (

,

,

q

'

c

<

s

C The inspector also spoke wi'th.a number of$individsals from-the:RP.

'

department,to determine whether there had been any deterioration in:

,

the RP program, ias a result.of the consolidation.

None of the:five

, J < individuals who were contacted felt ~that there' had been a-

"

deterioration in the: program, due to'the" consolidation,land/or thes f, '" amount of time the individuals had been devoting to-EP.1

'

'

Bued on-i I

the reduced.RP activities at the plant, and the fact that therecare-

<

several layers of supervision already established within the:RP group,nthe inspector concluded that fit appeared that the RP&EP,

, manager and supervisor could fulfill their collateral' duties; a

Several changes have also been made at the staff level of th'e EP r

-

'

group.- The cont'ractor who previously. held'the position of.EP-

.

supervisor has been temporarily retained as a' technical advisor to J

the new EP managementi Theilicensee stated that he was being; retained, because:of his extensive EP background..and_because'he-has been involved with EP activities'at Rancho Seco for many years.

The licensee indicated that thissindividual would be: retained as

,

long as it was necessary.

Two'other contractors departed recently,-

'!

but two SMUD personnel have'been added to take-their places.' One

'

-

of the individuals; works-on procedures, and the other runs-the-

'

drill and exercise program.' The decision to: add these:two

.

s individuals appears to be a positive one, because both of the

individuals have previous experience inithe licensee's EP group.

'

At the time.of this inspection, the' EP staff consisted of eight-

individuals.

The inspector concluded that the licensee had ai sufficle'nt number of staff mem5ers to implement 1the EP prograis, and that the staff was well. qualified,

s y

'Several improvements were noted during this part of the inspection..

i No deviations ~or violations were: identified. '

,

D.

Training

'

This part of the inspection was conducted to determine whether the'

- licensee was implementing-its training program in accordance'with

'

,

EPIPs-5600 and 5610.

To accomplish this,:the inspector reviewed

--the training status of ERO personnel, discussed the? training

.

program with EP training personnel, verified that drills were being

.

conducted in accordance with the " Drill and Exercise Manual,'! and discussed the 'results of the integrated dr,i11 conducted on March 28,'1990.

The inspector found that training was being accomplished in accordance with-the applicable EPIPs, and that the individual..

members of the ERO were current in their. training /. The inspector

.

also verified that new ERO members, who had not comoleted required:

, f initial" training, were properly identifiedcin the Ek1D.

TheihspectorquestioneddhOEPtrainingreprisentativeabouta

'

a

'recent; change to EPIP-5600., The EPIP has been revised to eliminate annual EP Overview' training for ERO members.

Instead, this training will:onlyibe p'rovided as part of initial training.

The licenseejuspifiedthisapparentreductioninntrainingbystating

"

,

,

q l

_ nw ' ]7j) f: y

v a , ,al i c -

< f that the content of-the overview training was include'd-in the '

.' ' annual General Employee Training (GET). The inspector reviewed the

$>

content of,both of these training courses, and concluded that the annual GET training sufficiently addressed the material covered in . the EP Overview course.

The EP training representative inforned ' ~ . the 'in'spect'or that there.were two positions in the ERO -the '

DistrictHeadquartersTelephone'OperatorandtheDistrIctSystem , .

Dispatcher, where EP Overview training is-the only~EP training-

'

arovided. This concerned the inspector, because the individuals > '

, 1olding,those positions would-not receive any refresher EP training, or annual GET training.' The annual GET training would. a ' not be provided, because these individuals are normally stationed ' at SMUD Headquarters,'and do,not need access to the plant. site.. , - The EP staff member stated that " informal" training on the use;of ' the ERID has;been provided to these individuals on-an annual basis;

however,'this training hascnot been documented.

In an emergency,

these individuals would be required to notify _ headquarters personnel.

The licensee was encouraged to reconsider;the adequacy

of the training provided to these two positions, and to determine Q whether it would be advisable to document the need to conduct the ERTD training, since only two EP staff members knew that the training was being conducted.

The inspector was able to. verify that the drill and exercise: Y program was being conducted in accordance with the licensee's ' program requirements.

In additien,:the inspector discussed the { results of the March drill, and reviewed the~ drill package-(f.e., scope, scenario, and objectives).

The, semiannual-HP drill was'- j ' incorporated into the drill.

From an HP standpoint,;the ins)ector l.

concluded that theLscope of the drill was more taxing than tie

- September 1989 HP drill (see NRC inspection report number-

50-312/89-15 for details).

The-scenario for this drill includ(d a i - simulated hot particle contamination.

The results of the March drill indicated that the 1icensee-was still having problems completing the accountability process within 30 minutes, as required by EPIP-5310.

The inability to complete

, accountability within 30 minutes was' also identified during the l 1989 annual exercise (see section 8.D of NRC insaection. report ' number 50-312/89-22).

To correct the problem, t1e licensee conducted another accountability drill at 5:00 P.M. on April 4,- i 1990.

The RP&EP supervisor and the inspector observed the drill.

i During this drill, the licensee utilized security personnel to- ! complete the process, rather than the old method, which required { security personnel to generate a computer list, conduct a a preliminary review, and.then transport the' list to the OSC for ! , final-reconciliation.

The licensee's decision to have security

- complete the process was based on the. fact that security has all I-the necessary information at the Security Building, and because

' . they-are used to working with the computer lists.

During the drill, security personnel were able to complete the accountability j process in eight minutes.

Based on the positive results of the' i drill, the licensee intends to revise EPIP-5310 and redefine thel ~ .,

• '

' '

responsibilitiesforcompletingtheaccountabilityprocess.

- ' , .. - a j . . , E E

4, p ,:h ,_

q s ,. , + , o , ,

w . , ,. -1

, n E V l9 ,

• ((

-. s The inspector questioned the'4"to the' Emergency Plan.

licensee.aboutEits process for; a implementing Revisions 3 and These ' revisions were approved by the NRC.on April 2, 1990. >The licensee: stated that=the revisions would be implemented on June 1, 1990.

In a the mean time, EPIPs were being revised.

Training was scheduled.to.

^ be-completed prior't'o the; implementation date.

The licensee stated.

t

that an integrated drill was scheduled for June 27, 1990, to ' Lyalidate the new' plan and procedures. :The practicality of. implementing the new plan and procedures, before testing them in'ai

drill,wasdiscussed3withthelicensee.

' " y

y . . , _u This'part'of the licensee's^ program was' considered to be , ' acceptable.x No deviationsTor< violations were identifled.

>

i E.

Audits:

,7o p , J An-audit of the EP progr' m,f.inIaccordance with 10 CFR 50.54(t), has a , not been completed sinceutheslast time this area was inspected- ' , ~huwever,.thisauditwasinprogressatthe'timeoftheinspectlon.. -c The inspector discussed thesaudit with the lead auditor and a The' audit began on March 14,1990,and reviewed the audit plan.

was scheduled to be completed by April 11, 1990. <The timing of the audit satisfied the' frequency ; requirement of 50.54(t):-(i.e., at-least every 12 months).

The target date for audit report number 90-A-000 was noted to be April 20, 1990.1 The inspector reviewed the audit plan, and concluded that it was adequate..The ins)ector-L noted that the two individuals conducting the audit did not lave B expertise in the area of EP or HP.

The inspector verified that.

l~ there was a process' by which the pertinent audit' findings;would be made available'to the offsite-agencies.

Based on the change in-EP management, and the evolution tlat will occur 'asithe plant - continues to' transition', the licensee was~ encouraged to closely; a L monitor the adequacy of the utility's interface with the:offsite

agencies.- This part of the licensee's program was considered to be adequate, r No deviations or violations were identified.

4.

Exit Interview An exit interview was held on April 5, 1990, to' discuss the preliminary findings of the inspection.

The attachment to.this report identifies the licensee personnel who'were present at the meeting.

Mr.

C.' Myers,- resident inspector, also attended the meeting.

The findings described in this report, including the non-cited violation described in section-3.A, were discussed.

At the time of the exit interview,-it, appeared- - that there was another non-cited violation' involving the review of agreement letters.

Subsequent to the inspection,-based on further review of the information, this non-cited violation was eliminated.

. e-(

r.,,... - _.

- , -~ , ,. # . ",t'. .

' . ,- .. ... .. . . , . ' '= ATTACHMENT- -

. JEXIT INTERVIEW ATTEND'EES- ~ . i

. : s g \\ <2,.- , ,; , .. ' ,[ l S. Crunk_ . . . I 0.<Gardin,eManager,1NuclearLicensing r Supervisor,lRadsaste V i 0;!Keuter, ssistant. General Manager (AGM), Nuclear -- j ^ . P.::Lavely,-l Supervisor, Licensing = ' R.!LeNeave EP Specialist + ' P.Lydon,-Manager.1NuclearPlhht , ,

• '

J.Shetier,<DeputyfAGM, Nuclear? < .' ,, u .i g ' 1.

, ( $ ' I . , ! ' ! h !

, ! ' .,., . L! ! i i t - 1 l ! , s '. i i

• Ts

' . tL - g s,, t 1 }}