IR 05000361/1998009

Insp Repts 50-361/98-09 & 50-362/98-09 on 980709-10.No Violations Noted.Major Areas Inspected:Operational Status of Emergency Preparedness Program,Using Simulator Walkthrough to Focus on Training of Assigned Key Roles for Emergencies

ML20236Y138
Person / Time
Site:	San Onofre
Issue date:	08/04/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20236Y134	List: IR 05000361/1998009 ML20236Y132
References
50-361-98-09, 50-361-98-9, 50-362-98-09, 50-362-98-9, NUDOCS 9808110199
Download: ML20236Y138 (8)

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I ENCLOSURE 1 U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket Nos.: 50-361 50-362 License Nos.: NPF-10 NPF-15 Report No.: 50-361/98-09 50-362/98-09 i

Licensee: Southern California Edison C Facility: San Onofre Nuclear Generating Station, Units 2 and 3 Location: 5000 S. Pacific Coast Hw San Clemente, California Dates: July 9-10,1998 Inspector (s): Thomas H. Andrews Jr., Emergency Preparedness Analyst Approved By: Blaine Murray, Chief, Plant Support Branch Attachment: Supplemental Information

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9908110199 990004 E PDR ADOCK 05000361 G PDR J

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2-EXECUTIVE SUMMARY

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San Onofre Nuclear Generating Station, Units 2 and 3 NRC Inspection Report 50-361/98-09; 50-362/98-09 A routine, announced inspection of the operational status of the licensee's emergency preparedness program was conducted. The inspection used simulator walkthroughs to focus upon the training of individuals assigned key roles for emergency response to determine whether they have been trained as required and understand their emergency assignments, responsibilities, authorities, and changes to the implementing procedure Plant Support

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Overall performance during simulator walkthroughs was good. Both crews properly evaluated plant conditions, identified the correct emergency action levels, and properly classified the events. Notification of state and local agencies were correct and timel Protective measures for plant personnel were prudent and timely. Notifications to the NRC were not fully demonstrated due to simulation. Offsite protective measures were consistent with the licensee's procedures, but the results were significantly different; one crew recommended evacuation of the emergency planning zone while the other crew recommended shelter (Section P4),

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-3-Reoort Details 11. Maintenance M8 Miscellaneous Maintenance issues M8.1 Environmental Qualification of Containment Hiah Ranae Radiation Monitors The licensee submitted Revision 10 of Emergency Plan Implementing Procedure SO123-Vill-1, " Recognition and Classification of Emergencies," on January 29,1998, pursuant to 10 CFR 50.54, and 10 CFR Part 50, Appendix E, Section V. One of the changes involved raising a setpoint for the containment high range radiation monitors from 10 R/hr to 100 R/hr. The reason for the change was that during loss of coolant conditions, the rapid temperature increase in containment would result in an error signal from the containment high range radiation monitor The problem was attributed to the cable from the detectors. The difference in temperature would cause two effects: (1) the increased resistance of the conductor and (2) an increased " leakage" of current across the insulatio From a review of the Final Safety Analysis Report, the inspector determined that the licensee had committed to Regulatory Guide 1.97, " Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident." Regulatory Guide 1.97 states that the containment high range radiation monitors are monitored as required for use in determining the magnitude of the release of radioactive materials and continually assessing such release. This Regulatory Guide also stated that the containment high range radiation monitor would have a range of 10' to 10 7R/hr and that detectors should respond to gamma radiation photons within any energy range from 60 kev to 3 MeV with a dose rate response accuracy within a factor of 2 over the entire range. The Final Safety Analysis Report stated that these instruments were loss-of-coolant accident qualified and that the accuracy was 20 percen Licensee Event Report 96-005 was issued in 1996, which identified the problem with the cabling. Based upon this information, the NRC issued Information Notice 97-45,

" Environmental Qualification Deficiency for Cables and Containment Penetration

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Pigtails." This information notice stated that at the time of a loss of coolant, the error signal could be very larg During the inspection, the licensee provided a copy of Action Request 970301240, initiated March 27,1997, which described problems regarding accuracy of the containment high range radiation monitors. In this action request, the licensee determined that the accuracy factor was in excess of the value specified in Regulatory Guide 1.97. Based upon information provided by the licensee, the inspector questioned whether these monitors were still considered to be qualified as described in the Final Safety Analysis Report and in compliance with the commitment to Regulatory Guide 1.97. The licensee stated that their projected completion date for this action request was December 1998. Because the licensee's corrective actions were I

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-4-incomplete, the review of the licensee's corrective actions is identified as an inspection followup item (IFl 50-361/9809-01; 50-362/9809-01).

IV. Plant Support P4 Staff Knowledge and Performance in Ernergency Preparedness a. Inspection Scope (82701)

The inspector conducted walkthroughs with two control room crews using a dynamic simulation on the plant-specific control room simulator. During the walkthroughs, the licensee was evaluated on the ability to:

• Evaluate plant conditions,

= identify respective emergency action levels,

• Classify the emergency using the latest procedures,

= Recommend appropriate protective actions,

• Perform and evaluate dose calculations, and

= Make timely notifications to offsite agencie The scenario consisted of a sequence of events requiring escalation of emergency classifications, culminating in a general emergency. Prior to the crew assuming the shift, both units were at full power. Crud Tank T073 was being recirculated using Crud Tank Pump P193. About an hour before the start of the scenario, a leak developed at an elbow on the outlet piping from the crud tank pump which resulted in an airborne activity level of 2000 derived air concentratio The airborne concentration was discovered by health physics technicians investigating a personnel contamination event. The high airbome concentration was reported to the control room shortly after the crew assumed the watch. The airborne concentration level required declaration of an aler A seismic event caused in a crack on control element assembly drive mechanism housing, resulting in a loss of reactor coolant. The affected control element assemblies are " ejected" from the core and became wedged in the vessel upper internals. Power in the area of the core surrounding the ejected control element assemblies exceeded

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design limits, causing core damage. The loss of coolant resulted in a declaration of a l site area emergency.

l A ground on a 480-volt conductor at a containment penetration resulted in damage to

! the penetration. This provided a release path from containment. With the loss of 2 of l 3 fission product barriers, and a potential !oss of the third, a general emergency was t

declare Each walkthrough lasted approximately 90 minutes. The walkthroughs were followed by critique _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _

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l l -5-l b. Observations and Findinas

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Both crews properly evaluated plant conditions, identified the correct emergency action levels, and properly classified the events. Notification of state and local agencies were correct and timely. Protective measures for plant personnel were made in a prudent and timely manne i l

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Supervisory oversight was very good. Briefings were held on a frequent basis and emphasized three-part communications. Three-part communications involved the first l person stating a request or observation, the second person repeating the request or ,

observation, and the first person confirming that the information received by the second  !

person was stated correctly. One noteable exception was that the first shift manager did i not specifically direct the emergency notification system communicator to inform the j NRC of event upgrade l Both crews did not fully demonstrate notification of the NRC due to simulation. One of i the operators for the first crew made the initial notification to the NRC, then simulated I making notification of upgrades. During the critique, the shift manager stated that the  ;

emergency notification system communicator position would be staffed by someone l from the other unit and that at an alert or higher, the line would be staffed continuousl During those times, the communicator would ' automatically" pass the information along ,

regarding the upgrade as a " status change." l The second crew assigned one of the operators to make the initial and upgrade notifications. This was comprised of short, cryptic information that was not realistic or meaningful for an operations officer. The operator used the emergency action level" tab  ;

numbers" to identify the reason for declaring each event rather than stating the basis of  ;

the declaration. Once these calls were made, the operator continued to act as an  !

operator monitoring plant conditions and responding to alarm Both crews used the procedure tabs to identify the basis for the event declaration /

upgrade. The communicators were informed that the procedure tab numbers are not standardized across the industry, so the NRC would not know what the basis for the event declaration was unless it was specifically stated. Other information that was confusing or incorrect that included the description that the airborne radiation was identified as radio-iodine rather than particulate and that the increase of temperature  ;

and pressure in containment as the basis for upgrading to a site area emergency instead of stating that the basis was a loss of coolani acciden The inspector noted that in a real event, the individual assigned to communicate on the

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emergency notification system would be expected to maintain ongoing communications with the NRC. The headquarters operations officer would ask probing questions to be able to properly assess the significance of the event. Later, additional NRC personnel t would be added to the call, and the need for additional information would increas Therefore, this would not permit the communicator to be effective as a board operator at the same time. Information that was cryptic or confusing would likely result in additional questions, demanding more of the communicator's time.

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-6-The licensee a Wgnized the potential problems associated with the over-simulation of NRC notifications. They counseled the first shift manager to ensure the communicator was directed to inform the NRC of event classification upgrades. The licensee stated that they would look into reducing the simulation to ensure accurate and timely information was provided to the NRC. The inspector considered the licensee's critique and followup actions to be adequate to address the identified concern The shift managers tended to make the decision to classify an event, then began performing the required actions. Later, when they were at the point where identifying the time of the classification was needed (as in making the announcement to the crew or filling out the notification form) the current time was used. This was typically 1 to 3 minutes after the decision had been made. The inspector pointed out that this practice was not consistent with NUREG-0654/ FEMA-REP-1, " Criteria for Preparation and Evaluation of Radiological Emergency Responso Plans and Preparedness in Support of Nuclear Power Plants," Revision 1, which states:

Prompt notification of offsite authorities is intended to initiate within about 15 minutes of the unusual event class and sooner (consistent with the need for other emergency actions.5 for other classes. The time is measured from the time at which operators recognize that events have occurred which make declaration of an emergency class appropriat The inspector reviewed the amount of time required to initiate offsite notification When the time difference between the decision and declaration was added, the notifications were still considered to be timely. All communications were initiated within 15 mir utes of the decision to declare or upgrade an emergency classification. The licensee stated that this issue would be reviewed to ensure all personnel responsible for recognizing and classifying emergencies were aware of the need to properly identify the time the decision was mad The licensee's protective action recommendations apply to the entire emergency planning zone. At a general emergency, the default protective action was to recommend sheltering. It dose projections indicate that protective action guidelines were to be exceeded and the evacuation time was shorter than the expected exposure duration, then evacuation of the emergency planning zone would be recommende Procedure SO123-Vill 10.3," Protective Action Recommendations," Revision 3, contained a note stating that evacuation was not required if the release was to an unpopulated are At the time in the scenario when a general emergency was declared, dose assessment results indicated that the release exceeded protective action guidelines at the site boundary, but the wind was blowing out to the ocean. The first crew recommended evacuating the emergency planning zone due to the variability of wind direction and time of day. The second crew only recommended sheltering since the wind direction was to an unpopulated area. While both crews provided adequate justification for their decisions, the inspector pointed out that the procedure allowed two crews with the same information to make different decisions. The licensee stated that they would review this issue to determine if additional training or clarification was neede .

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-7-During the walkthroughs, the inspector observed confusion regarding the status of the emergency response facilif!ss. For example, the technical support center was assumed to have people present, but not enough to activate the facilities. At various times, the facility was characterized as " staffed,"" manned," and " activated." These terms were used synonymously._ The licensee recognized the need to ensure that a consistent

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" nomenclature" was used to ensure everyone clearly understood the status of the emergency response facilitie Conclusion Overall performance during simulator walkthroughs was good. Both crews properly evaluated plant conditions, identified the correct emergency action levels, and properly classified the events. Notification of state and local agencies were correct and timel Protective measures for plant personnel were prudent and timely. - Notifications to the NRC were not fully demonstrated due to simulation. Offsite protective measures were consistent with the licensee's procedures, but the results were significantly different; one

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crew recommended evacuation of the emergency planning zone while the other crew recommended shelter i

V. Manaaement Meetinas X1 Exit Meeting Summary l The inspector presented the inspection results to members of licensee management at the conclusion of the inspection on July 10,1998. The licensee acknowledged the findings presented. No proprietary information was identified.

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ATTACHMENT SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee D. Axline, Nur lear Regulatory Affairs W. Fargo, Er gineering K. Fowler, Ernergency Planning M. Hup. Emergency Planning Supervisor M

J. Sloan, Senior Resident inspector LIST OF ITEMS OPENED. CLOSED. AND DISCUSSED Opened 50-361/9809001; 50-362/9809001 IFl Review of corrective actions taken for containment high range radiation monitor accuracy INSPECTION PROCEDURES USED 82701 Operational Status of the Emergency Preparedness Program

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DOCUMENTS REVIEWED Procedure SO123-Vill-1," Recognition and Classification of Emergencies," Revision 10 Procedure SO123-Vill-10.3," Protective Action Recommendations," Revision 3 Action Request 970301240, Accuracy of Containment High Range Radiation Monitors

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