IR 05000361/1997026

Insp Repts 50-361/97-26 & 50-362/97-26 on 971208-12.No Violations Noted.Major Areas Inspected:Operationsl Status of Licensee Emergency Preparedness Program.Emphasis Was Placed on Changes Occurred Since Last Emergency Preparedness Insp

ML20198C464
Person / Time
Site:	San Onofre
Issue date:	01/05/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20198C454	List: IR 05000361/1997026 ML20198C450
References
50-361-97-26, 50-362-97-26, NUDOCS 9801070286
Download: ML20198C464 (12)

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-- ENCLOSURE' i

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U.S. NUCLEAR REGULATORY COMMISSION 1

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. + .r Docket.Nos.F 50 361;50-362: _

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l License Nos.: NPF 10; NPF 15 = , .

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Report NoF : 50-361/97-26; 50 362/97-26 l

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' Licensee: Southem Califomia Edison Col

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San Onofre Nuclear GenerMing Station, Units 2 and 3

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San Clemente,' California - ,

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ct Dates:. - December 812,1997- _

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~ Inspector: Thomas H. Andrews Jr., Emergency Preparedness Analyst -

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Approved By:: Blaine Murray, Chid. Plant Support Branch ~ 4 3 - Division of Reactor defety -  :

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EXECUTIVE SUMMARY San Onofre Nuclear Generating Station, Units 2 and 3 NRC Inspection Report 50 361/97 26; 50-362/97 26 This routine, announced inspection focused on the operational status of the licensee's emergency preparedness program. Emphasis was placed on changes that had occurred since the last routine emergency preparedness inspectio Plant Supn9d

- The operational status of the licensee's emergency preparedness program was well maintained. Facilities, emergency plan reviews, and training were properly implemente * All events reported to the NRC operations center since May 1996 were properly evaluated and classified. There were no emergency declarations between May 3,1996, and December 8,1997 (Section P1).

• Charcoal cartridges used for drills were not properly labeled. Beards worn by operations personnel could have affected the ability to don self contained breathing apparatuses in a timely manner. Some shift technical advisors were not qualified to wear respiratory protection equipment. An operability assasment was performed to determine the number of breathing air bottles needed 11 tha control room that identified the need to augment the staff early during a toxic gas emergency (Saction PE).

• A noncited violation was identified for not exercising the recovery /re-entry portions of the emergency plan every 5 years. The augmentation process for craft personnel was not well defined or understood (Section P3).

• The continuing training process was consistent with the description in the emergency plan. Position specific training for dose assessment personnel was of sufficient depth and detail (Section PS).

- Audit team members had limited emergency preparedness expertise. The assessment of the offsite interface was incomplete in that it did not include interviews of state and local iepreserdatives (Section P7).

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-3-Reno 11Patalls IV. Plant SuppoI!

P1 Conduct of Emergency Preparedness Activities (93702)

The inspector reviewed licenste event notifications made to the NRC operations center between May 3,1996, and December 8,1997, to determine if the events were properly classified. The licensee had made no emergency action level de Jarations daring that time. The inspector reviewed the event details against the emergency action levels in Procedure SO123 Vill-1, "Reco0nition and Classification of Emergericies," Revision The inspector concluded that the licensee had correctly determined that no event classifications were warrante P2 Status of Emergency Preparedness Facilities, Equipment, and Resources a. Insoection Scone (82701-02.02)

The inspector toured the emergency response facilities and reviewed equipment inventories to determine if they were adequately maintained, technically adequate, met NRC requirements, licensee commitments, and were appropriately incorporated into the emergency plan and implementing procedures. Licensee offsite communication circuits were included in this determinatio b. Observations and Findinas Emergency response facilities were maintained in a proper state of readiness. Portions of the emergency operations facility and technical support center were used as uffice spaces but did not affect operability. The licensee performed the quarterly inventories as required. Tested emergency response facility phones functioned properly. Other equipment chec'Ked by the inspector Was operable and ready for us Air sampler charcoal and silver-zeolite cartridges were stored in the emergency kits. The silverqeolite cartridges were properly stored. in some kits, the charcoal cartridges were loose and exposed to the environment. The inspector noted that the adsorption capabilities of the improperly stored charcoal cartridges could be adversely affected by fumes / aerosols. The licensee's emergency air sampling program specifies the use of silver zeolite cartridges instead of charcoal cartridges. Since charcoal cartridges were stored in the same kits as the silver-zeolite cartridges, charcoal cartridges could be used in error. According to the licensee, the charcoal cartridges were only used for "dr il'

purposes. The licensee stated that they would followup on this issue to clarify that the charcoal cartridges were only to be used for drill The Updated Safety Analysis Report identifies that at least nine self-contained breathing apparaiuses were to be stored in the control room for use by the operating crew in case of a toxic gas emergency. The inspector found 11 self-contained breathing apparatuses in the control room.

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The shift superintendent stated that approximately 20-30 operations personnel were on l shift. When questioned, the shift superintendent identified the minimum staffing positions ]

as the individuals who would don the self contained breathing apparnkses. The j inspector determined that a sufficient number of self-contained broathing apparatuses !

were available for the minimum staffing position The inspector noted that the shift superintendent had a beard and his position was one l position considered a minimum staffing position. In case of an emergency that involved the use of self-contained breaking apparaturs, this individual would be required to shave i and then don the apparatus within 2 minutes. The licensee reviewed the facial hair -

policy and the need to don respirators in a short time. As a result, the licensee issued instructions that all personnel, who filled minimum staffing positions, to be clean shave The licensee subsequently identified that the respiratory protectiori qualifications for some shift technical advisors were not current. At the time of the exit meeting, one shift technical advisor was not qualified to wear a self contained breathing apparatus. The licensee stated that this individual would be qualified before being permitted to return to shift work as a shift technical adviso The inspector noted that no spare self contained breathing apparatus bottles were stored within the ventilation envelope. The shif; superintendent listed severallocations where they storea spare bottles outside the control room. The inspector confirmed the number and location of these spare bottle The licensee stated that they were developing a design modification to store 12 self contained breathing apparatuses in the control room, along with 24 spare bottle An additional 36 sparc bottles would be stored near the control room. The design modification would result in 72 bottles of air being stored in or near the control roo The inspector asked how many bottles of air were required in case of a toxic gas emergency. The licensee performed an assessment and determined that 49 bottles of air n ere stored in the control room or in the immediate area. Based upon a control room crew of six and assuming that the 1-hour rated bottles lasted approximately 45 minutes each, there was a sufficient supply available for a short duration emergency (approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />). For a long duration emergency (approximately 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />), bottles would need to be refilled to ensure an adequate supply of ai The licensee reviewed the staff augmentation plan for a toxic gas emergency. They developed 1 preliminary, interim plan to ensure that the proper personnel were called in to refill and transport the bottles to and from the control room. The licensee recognized that the notification of personnel had to occur very early in the event to prevent the control room from running out of air bottle The inspector noted that the control room operators were not trained on the ;.rocess to change out self contained breathing apparatus bottles. Health physics technicians were trained to do this task. The licensee designated a health physics technician to report to the control room to per'orm the bottle change out. The inspector noted that the l

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-5-licensee's assessment did not include the addition of the health physics technician as a user of a delf-contained breathing apparatus.- However, there was a sufficient margin in the licensce's assumptions to permit the addition of one health physics technician, c. ConclusiODS Emergency response facilities were properly maintained. Charcoal cartridges used for drills were not property labeled. Beards worn by operations personnel could have affected the ability to don r, elf-contained breathing apparatuses in a timely manne Some shift technical advisors were not qualified to wear respiratory protection. An operabdity assessment was performed to determine the number of breathing air bottles needed in the control room that identified the need to augment the staff early during a toxic gas emergenc P3 Emergency Preparedness Procedures and Documentation a. lDigestion Scone (82701-02.01)

The inspector reviewert:

• The licensee's process for identifying changes to the plant and to documents that require an assessment of the emergency pl.'n impac * The licensee's program for tracking exercise objectives, drills, and exercises to determine if the required elements were properly schedule * On-shift staffing to determine the adequacy of minimum staffing levels to perform the tasks identified in the licensee's emergency plan. The licensee's staff augmentation plan was reviewe The licensee's process for documenting annual reviews 2,7d changes to emergency action levels by state and local agencie b. Observations and Findinas The licensee's tracking mechanism used a frequency of 6 years for some exercise objectives. According to the emergency plan, only the after-hours exercise portion was listed as a 6-year objective. Major portions of the emergency plan that did not have a shorter frequency specified were required to be exercised every 5 years. The licensee planned to change the emergency plan to incorporate the 6-year frequency items stated in NUREG-0654/ FEMA-REP-1," Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants,"

Revision 1, Supplement 1. The licensee anticipated that this change would be made by the end of the 199 The licensee identified that the recovery /re-entry portion of the emergency pinn had not been exercised since 1989 (there were no re, cords available prior to 1989). Therefore,

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-6- I the failure to exercise the recovery /re-entry portions of the emergency plan every 5 years was a violation of the emergency plan and 10 CFR 50.54(q). The licensee's corrective actions included scheduling these portions of the emergency plan as part of the drill scheduled for December 17,1997, and enhancing their tracking mechanism to show the last time the objective was demonstrated. The inspector determined that the corrective actions were adequate. The violation was licensee identified, nonrepetitive, corrected

- within a reasonable time, and nonwillful. Accordingly, the violation is being treated as a nonciteo violation consistent with Section Vll.B.1 of the NRC Enforcement Policy (50-361;-362/9726-01).

The inspector reviewed the process used to determine if changes to the plant or programs that may effect the emergency plan were reviewed in accordance with 10 CFR 50.54(q). The emergency plan contained references to other documents for detailed discussion / description of components, systems, and programs. The updated Final Safety Analysis Report was an example of one of these referenced document The inspector asked if there was a mechanism that would flag the need to perform a 50.54(q) assessment when these components, systems, and orogra 3 were change The licenseo provided several examples of methods used to identify these types of changes. However, it was determined that the process was dependent upon the knowledge and initiative of the individual performing the review to determine if +jee emergency plan was effe':tod by the change. As a result, a procedure change was initiated to add a 50.54(q) review checklist to Procedure SO123-Vill-0.100, " Maintenance and Control of Emergency Planning Documents." The inspector did not identify any changes to facilities that had not been appropriately reviewe The licensee's emergency action levels were reviewed annually with the state and local agencies. This review was documented appropriately Changes to the emergency plan and implementing procedures were transmitted to the NRC in a timely manne The inspector reviewed the radiological controls for emergency workers within emergency response facilities. Declared pregnant workers were not removed from the emergency response organization and were subject to call out to respond to an emergency. The inspector questioned if the administrative exposure limits associated with protecting the embryo / fetus were taken into account while determining protective actions and radiological controls for emergency workers. According to the licensee,if a declared pregnant worker was considered a radiation worker, the worker's administrative dose limits would be reduced to protect the embryo / fetu The inspe:. tor reviewed the emergency plan for consisteny with Section B.5 and Table B-1," Minimum Staffing Requirements for NRC Licensees for Naclear Power Plant Emergencies," found in NUREG-0654. The emergency plan listed four health physics technicians on shift. The inspector confirmed that four qualified health physics technicians were on shif However, the emergency plan did not describe positions and tasks, specific assignments made for all shifts and for plant staff members, or discuss how many people would be needed to augment the on-shift staff. The licensee provided a copy of a memorandum

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7-dated October 7,1993, regarding the review of minimum staffing requirements. This memorandum divided the specific tasks as follows:

Dose assessment Technician No.1, also is the operations support center health physics coordinator and technical support center health physics leader pending recall Onsite/offsite surveys Technician No. 2 roves the owner control area and beyond, pending recall and offsite arrivals In plant surveys Technicians No. 3 and No. 4 share in-plant surveys and radiation protection. The health physics technicians provide dosimetry for teams assigne These technicians provide job coverage and rovt as needed to verify conditions. Augmented by recall personne The licenses stated that these four positions satisfied both the onsite and 30-minute augmentation requirements. While this information was not contained in the emergency plan, personnel within the licensee's organization were knowledgeable of task assignments for emergency respons Recall personnel were expected to arrive within 60 minutes to augment the minimum staff. The inspector reviewed the staff augmentation process. The emergency plaa implementing procedure was set up for calling in additional staff after the facilities were staffed. The inspector reviewed the recalllist and determined that these people were supervisory personnel that cou!d fulfill the requirements for staff augmentation. However, it was not clear if, when, or how craft personnel were cal!cd in. The licensee stated that they plan to followun on this issu c. Conclusions The frequency used for tracking exercise objectives was inconsistent with the emergency plan; however, a change to the emergency plan was anticipated by the end of the yea A noncited violation was identified for not exercising the recovery /re-entry portions of the emergency plan every 5 years. Plant changes were reviewed for impact on the emergency plan. Emergency plan changes were properly reviewed and transmitted to the NRC in within 30 days of implementation. Reviews of the emergency plan and emergency action levels were properly performed. On-shift staffing was consistent with the emergency plan. The augmentation process for craft personnel was not well defined or understoo .-

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8-PS Staff Training and Qualification in Emergency Preparedness a. Inspectie9 Scooe (82701-02.04)

The inspector reviewed the training program procedure, :,'aining records for selected individuals, and reco-ds and documents associated with emergency drills and exercise The inspector focused on training requirements and the status of qualifications of individuals in the emergersey response organizatio b. Observations and Findinos According to regulatory guidance provided in NUREG-0654/ FEMA-REP-1, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plana and Nuclear Power Plants," Revision 1. Section O.2:

The training program for members of the ontite emergency organization shall, besides classroom training, include practical drills in which each individual demonstr aes ability to perform his assigned emergency function . .

Appendix H of the emergency plan cross referenced NUREG-0654, Section O.2 to the training procedures. The initial training and annual retraining requirements were listed in Table 8-1 of the emergency plan. Table 81 referenced the SONGS Nuclear Training Program Description for position specific training requirements. Procedure SO123-XXI 1.11.3, " Emergency Plan Training Program Description," Revision 7, was referenced by the emergency plan as one of the emergency plan implementing procedures. The licensea's training program did not contain a requirement for participation in practical orills for each member of the onsite emergency organizatio The licensee interpreted 10 CFR Part 50, Appendix E, Section IV.F.1, to mean that they were to provide training to all c.nergency response organization members. This training consisted of classroom, computer-based training, etc. Periodic drills were conducted as an assessment of the training program. Lessons learned from the drills were used to fine tune the formal training process. Therefore, the licensee's interpretation was that participation in periodic drills or exercises by each member of the emergency response organization was not require Records provided by the licensee revealed that there were people who have not participated in drills or exercises in the past 3 years. Some of these people were assigned key positions within the emergency response organization. The inspector did not identify positions where individuals were not aware of their specific emergency response dutie Review of training records showed that position specific training was conducted annually as outlined in the training program procedure. The licensee linked the emergency pianning training with the site access training. Therefore, if an individual did not

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-9-successfully complete the training, their access to tha plant was restricted.- This was consistent with the emergency pla The inspector reviewed dose assessment training to de' ermine if the training provided was of sufficient depth and detail - Limitations of dose models/ methodologies were -

discussed cs part of the training. An interview with an individual qualified to perform dose assessment showed that they were knowledgeable regarding the process and aware of some of these limitations. The individualinterviewed provided accurate -

responses regarding the interpretation of results. The int.pector determined that the formal training provided for emergency response organization members was goo Conclusions The continuing training process was consistent with the description in the emergency plan. Training for dose assessment personnel was of sufficient depth and detai P7 Quality Assurance in Emergency Preparedness Activities Insoection Scoce (82731-02.05)

The inspector examined independent and internal reviews and audit reports for the licensee's emergency preparedness program since the lasiinspection to determine compliance with NRC requirements and licensee commitment The inspector evaluated the effectiveness of the licensee's controls in identifying, resolving, and preventing problems by reviewing corrective action systems, root cause analyses, safety committees, and self assessment in emergency preparednes .

The inspector evaluated the licensee's corrective actions for audit identified deficiencies and those identified during drills and exercise Observations and Findinos Audits of the emergency preparedness program were performed on a 12-month basis by the licensee's quality essurance organization (Nuclear Oversight Division). The inspector reviewed the results of ' e 1996 audit and attended the exit meeting for the 1997 audit. The personnel performing the audits did not have direct responsibility for implementation of the emergency prepiredness progra According to ANSl/ASME N45.2.23-1978, Section 2.2, audit teams shallinclude someone with experience or training commensurate with the scope, complexity, or-special nature of the activities audited. The inspector reviewed the qualifications and expertise of the auditors who performed the 1996 and 1997 audits. The auditors'

technical expertise was narrow in scope and potentially relevant training was age Review of resume's and training records of the auditors showed that the technical expertise was mainly that of being a member of the emergency response organizatio There were training courses provided related to emergency planning, but for the most

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-10-part, these were dated in the 1980's or early 1990's. One aspect being heavily relie i upon for technical expertise was exposure to the emergency planning program through previous audds. The inspector identified the expertise of audit team members as an area for improvemen The assessment of offsite interfaces was performed by the licensee's quality assurance organizatien. The assessment was based upon inten ilinterviews and review of correspondence / meeting minutes. One facet missing from the process was interviews of representatives from state and local agencies for their opinion on the process. According to the licensee, this had not been done recently. Members of the emergency planning staff stated that interviewing of state and local representatives was not encourage Their concern was that the state and locals would assume that the assessmerit was an audit of the offsite organizations. The inspector determined that the problems with the offsite interface could be missed, therefore was identified to the licensee as an area for improvemen Self assessments porformed by emergency preparedness provided good finding Corrective actions reviewed by the inspector were addressed appropriately and in a timely manner, c. Conclusions Personnel performing audits had limited expertise related to emergency preparednes The assessment of the offsite interface was incomplete in that it did not inc!ude interviews of state and local representative VAnaaement Meetinos X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at an exit meeting on Oe' ember 12,1997. The licensee adnowledged the findir/ss presented. No proprietary information was identified. The licensee confirmed that all confidential documents provided by the licensee had been returne _ _ .. . -.

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O ATTACHMENT 5JPPLEMENTAL INFoRMATION PARTIAL LIST OF PERSONS CONTACTFS Licemen C. A'Jerson, Manager, Site Emergency Preparedness N. Ferris, Nuclear Oversight C lvision T. Frey, Compliance P. Handley, Supervisor, Offsi:e Emergency Planning D. Richards Acting Supervisor, Emergency Planning R. Waldo, Manager, Operations NBC J. Sloan, Senior Resident inspector INSPECTION PROCEQUEES USED 82701 Onerational Status of the Emergency Preparedness Program

, 93702 Prompt Onsite Response to Events at Operating Power Reactors ITEMS OPENED AND CLOSED Qaened 50 361; 362/9726 01 NCV Failure to exercise the recovery /re-entry portions of the emergency plan every 5 years (Section P3)

Cloted 50 361; 362/9726-01 NCV Failure to exercise the recovery /re-entry portions of the emergency plan every 5 years t

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Docwnents. Reviewed  ;

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l laternal Correnoondence; j

• Review of Minimum Staffing Requirements," October 7,1993  !

• August 7,1996 Emergency Plan Drill Critique Report,' August 28,1996  :

' September 11,1996 Emergency Plan Exercise Critique Repor1," October 4,1996

" November 12,1996 Emergency Plan PASS Drill Critique Report,' November 27,1996 ,

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' March 12,1997 Emergency Plan Drill Critique Report,' April 11,1997 l I

' August 13,1997 Emergency Plan Drill Critique Report," October 22,1997 r

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t Audit Report SCES 614 96, * Emergency Preparednets/ Emergency Planning,' December 1996 ProcedurgE  !

SO123 Vill 0.100, ' Maintenance and control of Emergency Planning Documents," Revision 2-1 i SO123 Vill 0.200, " Emergency Plan Drills and Exercises," Revision 3 ,

SO123 Vill 0.201, ' Emergency Plan Equipment Surveillance Program," Revision 7 SO123 Vill 0.202, " Assignment of Emergency Response Personnel," Revision 61  :

SO123 Vill 1, * Recognition and Classification of Emergencies," Revision 9 SO123 Vill 10, " Emergency Coordinator Duties,' Revision 9 SO123 XXI 1,11.3, " Emergency Plan Training Program Description," Revislon 7 Othe * Emergency Plan for San Onofre Nuclear Generating Station Units 1,2, & 3," Revision 7

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