ML13323B229
| ML13323B229 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/31/1987 |
| From: | Good G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML13323B230 | List: |
| References | |
| 50-206-87-04, 50-206-87-4, 50-361-87-05, 50-361-87-5, 50-362-87-06, 50-362-87-6, NUDOCS 8704070351 | |
| Download: ML13323B229 (9) | |
See also: IR 05000206/1987004
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos.
50-206/87-04, 50-361/87-05, and 50-362/87-06
Docket Nos.
50-206, 50-361, and 50-362
License Nos.
Licensee:
Southern California Edison Company
P. 0. Box 800
2244 Walnut Grove Avenue
Rosemead, California 91770
Facility Name:
San Onofre Nuclear Generating Station, Units 1, 2 and 3
Inspection at:
San Onofre Site, San Diego County, California
Inspector:
_
___
__
3/
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7
G. M. Good, Emergency Preparedness Analyst
Date Signed
Approved by:
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R. F. Fish, Chief
Date Signed
Emergency Preparedness Section
Summary:
Inspection on March 2-6, 1987 (Report Nos. 50-206/87-04, 50-361/87-05, and
50-362/87-06)
Areas Inspected:
Routine, unannounced emergency preparedness inspection in
the areas of emergency detection and classification, protective action
decisionmaking, shift staffing and augmentation, knowledge and performance of
duties (training) and follow-up on 4 open items identified during previous
emergency preparedness inspections.
Inspection procedures 82201, 82202,
82205, 82206, 82701 and 92701 were addressed.
Results:
No violations of NRC requirements were identified; however, there
is one unresolved item. One of the open items identified during a previous
inspection was closed.
8704070351 870401
PDR ADOCK 05000206
DETAILS
1. Persons Contacted
0. Bennette, Supervisor, Station Emergency Preparedness (SEP)
P. Dooley, Supervisor, Corporate Emergency Planning
J. Garza, Shift Superintendent, Units 2/3
P. Handley, Emergency Planning Specialist
R. Hull, Manager, Media Relations
R. Kratz, Shift Superintendent, Unit 1
M. Lisitza, Shift Superintendent, Units 2/3
R. Reed, Associate Emergency Planning Specialist
D. Richards, Shift Superintendent, Unit 1
S. Wylie, Administrator, Training Support Services
2. Action on Previous Inspection Findings
(Closed) Open Item (86-01-04):
Manual versus automatic activation of the
evacuation siren and instructions to workers should be resolved.
Procedural modifications associated with this issue were addressed in
Inspection Report Nos. 50-206/87-01, 50-361/87-01, and 50-862/87-01.
Questions regarding manual versus automatic activation of the evacuation
siren were incorporated into the Shift Superintendent (SS) interviews
described in Section 6. The results showed *that the SSs who were
interviewed were knowledgeable-about siren activation.
This item is
considered closed.
(Open) Open Item (50-206/86-32-01, 50-361/86-22-01, and 50-362/86-22-01):
Problem with detecting and classifying an emergency.
This item was
identified during the licensee's 1986 emergency exercise.
Since then,
SEP has made several procedure modifications to help prevent future
emergency misclassifications.
Specifically, notes have been added to.
event tabs Al, A2 and D1 in S01(23)-VIII-l, "Recognition and
Classificati-on of Emergencies", referring to higher level event codes for
conditions which do not have. corresponding lower level event codes.
In
addition, a procedure step (paragraph 5.1) has been added to ensure that
the highest level applicable event code is identified.
Paragraph 5.1
directs the user (Emergency Coordinators (EC)) to review higher level
event codes in all (emphasis added) cases.
Emergency Planning Bulletin
86-15 was issued on October 1, 1986, to inform affected personnel of the
changes.
The event which was misclassified during the exercise was *one
of the situations presented to each of the SSs during the interviews
discussed in Details Section 6. All of the SSs who were interviewed
correctly classified this event. This *item will remain open pending
demonstration of the licensee's ability to accomplish these actions
during the next annual exercise.
(Open) Open Item (50-206/86-32-02,' 50-361/86-22-02, and 50-362/86-22-02):
Problems with c6ordinating protective action recommendations.
This item
was identified during the licensee's 1986 'emergen *cy exercise. In an
effort to correct the problem, the licensee has decided to move the EC
responsibilities from the Technical.Support Center (TSC) to the Emergency
Operations Facility (EOF).
This means that once activated, the EOF will
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assume responsibilities for classifying events, making offsite
notifications and protective action recommendations (onsite and offsite).
These.changes will be incorporated.into the next revision of the
licensee's Emergency Plan (EP).
The target date for this revision is
April 15, 1987. The EP will refer to the lead individual in the TSC as
the Site EC and the lead individual in the EOF as the Corporate EC. The
licensee plans to practice these changes during their next site-wide
drill which is scheduled for March 17, 1987. This item remains open.
(Open) Open Item (50-206/86-32-03, 50-361/86-22-03, and 50-362/86-22-03):
EOF failure to issue timely and accurate news releases. This item was
identified during the licensee's 1986 emergency exercise. The timeliness
portion of this open item was based on the fact that the first news
release was not issued until over 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after the Alert declaration.
Investigation into this matter revealed that the delay was attributed to
a notification problem. During the exercise, media personnel were
pre-staged at a restaurant. Notification of these individuals was to be
made via a pager. Due to a malfunction of the pager, the media personnel
were delayed getting to the EOF. The first news release was issued
approximately 20 minutes after their arrival. Since the exercise,. steps
have been taken .to improve maintenance on the pagers. It should be noted
that telephone notification is the primary method used to notify
Corporate personnel.
To enhance notification of Corporate personnel,
some consideration has been given to purchasing an automatic telephone
dialer.* The other aspect of this item involved confusing news releases.
To correct this portion of the problem, media personnel have developed a
checklist which is to be used for news release preparation. Also, stock
news releases (fill-in-the-blank type) have been generated for each of
the emergency classifications. The licensee's attention to this matter
appears to be adequate, however, this item will remain open pending
demonstration of the licensee's ability to accomplish these actions
during the next annual exercise.
3. Shift Staffing and Augmentation
The inspector verified that minimum onshift crews and augmentation
capabilities were consistent with the goals.of Table 2 of Supplement 1 of
NUREG-0737. Section 5 of the licensee's EP, entitled "Organizational
Control of Emergencies.", addresses the minimum and augmented onsite
emergency organization. Authorities and responsibilities of key
individuals in the emergency organization have been included in Section
5. The licensee's administrative method used to meet staffing goals is
described in S0123-VIII-0.202, "Assignment of Emergency Response
Personnel".
Personnel designated to assist with the mitigation of
emergencies have been designated as Emergency Response Personnel (ERP).
Those individuals who are responsible for implementing sections of the EP
have been designated as Nuclear Emergency Response Team (NERT) members.
During the past year, no changes have been made to the process by which
ERP are recalled. ERP are recalled using the Station-Emergency Recall
List (SERL). The SERL is generated from the computerized Training
Information Management System (TRIMS) records of individuals who have
completed all EP training, including drill participation for NERT'
members.
Prior to issuance of the SERL (quarterly), the list is reviewed
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by members of the SEP staff who have personal knowledge of individuals in
functional areas such as operations and health physics, the SEP
Supervisor and a final review by Onsite Cognizant Functional Managers.
The inspector reviewed the latest SERL, dated February 17, 1987, and
found it to be complete and accurate.
No significant deficiencies or violations of NRC requirements were
identified during this part of the inspection.
4.
Emergency Detection and Classification
This subject was examined through a review of applicable procedures and
discussions with licensee personnel, including interviews with SSs.
The
results of the SS interviews are summarized in Section 6 of this report.
The inspector reviewed EPIPs S01-VIII-1, S023-VIII-1 and 50123-VIII-10,
"Emergency Coordinator Duties", and concluded that they contained
measurable and observable Emergency Action Levels (EALs) based on
in-plant conditions and on onsite/offsite radiological monitoring
results, criteria for recommending onsite/offsite protective actions and
the four levels of emergency classifications, i.e., Unusual Event (UE),
Alert, Site Area Emergency (SAE) and General Emergency (GE). Authority
and responsibility for classifying events and for recommending protective
actions have been clearly defined. The format of the classification
procedures would appear to facilitate prompt classifications, since event
categories (e.g., Uncontrolled Release of Radioactivity, Core Degradation
or.Overheating, etc.) have been grouped together for each of the four
emergency classifications. Nuclear Affairs and Emergency Planning
(NA&EP) personnel (Corporate Emergency Preparedness) have delayed their
EALs transmittal to the State and local agencies by about one month so
that some recent procedure changes could be completed. March 20, 1987 is
the current target date for the transmittals. NA&EP personnel
volunteered to send copies of the transmittal letters to the inspector.
No significant deficiencies or violations of NRC requirements were
identified during this part of the inspection.
5. Protective Action Decisionmaking
Protective action decisionmaking was addressed through a review of
applicable procedures and discussions with licensee personnel, including
interviews with SSs. The results of the SS interviews are summarized in
Section 6 of this report. The inspector reviewed S0123-VIII-10 and
concluded that the procedure clearly reflects the authority and
responsibilities for recommending protective actions based on plant
conditions and dose projections.
No significant deficiencies or violations of NRC requirements were
identified during this part of the inspection.
6. Knowledge and Performance of Duties (Training)
An examination of the licensee's EP training program was conducted during
this inspection. The scope of this examination included a review of
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Training Program Description ERT-1, a review of training records and
interviews with selected ERP.
The TRIMS computer printout (training status) was reviewed to determine
whether EP training had been conducted in accordance with ERT-1.
Particular attention was given to the status of NERT member drill
participation.
Paragraph 4.1.4.2 of ERT-1 states that training of NERT
and Emergency Support Organization (ESO) (corporate support) shall
include PLATO (computer) or classroom training and drills and exercises.
The results of the TRIMS review showed that training of ERP was
up-to-date and that NERT members were participating in drills/exercises.
During the review of the TRIMS computer output, the inspector found a
problem associated with the renewal date (training due date) for a number
of ERP. The TRIMS output indicated that for some ERP, training was not
due for two years, rather than the annual requirement specified in ERT-1.
Training Division personnel were able to track down the reason for the
problem and correct the renewal dates, prior to the end of the
inspection.
To test the effectiveness of part of the licensee's EP training program,
the inspector interviewed four SSs (two from Unit 1 and two from Units
2/3).
Shift Superintendents were chosen because in an emergency they
would be required to act as the EC until relieved by the Plant Manager
(or his designated alternate). In addition to being asked specific
questions about the responsibilities of the EC and general questions
about the EP, each SS was asked to classify six different (unrelated)
emergency events and provide protective action recommendations for onsite
personnel and the general public. Out of the 24 emergency situations
which were presented, 2 were not classified in accordance with the
applicable procedures. The two were non-conservative in that they were
classified as Alerts, when they should have been classified as Site Area
Emergencies. The misclassifications were for the same postulated event
(Tab A3-3 from SO1(23)-VIII-1), one SS from each unit. In both cases,
the event was misclassified because the SS failed to look at the next
highest tab (one failed to look at the 2nd page of the next highest tab).
The two non-conservative misclassifications raise a concern because the
postulated event was essentially a verbatim representation of Tab A3-3
from the applicable classification procedures. The recent addition of
paragraph 5.1 to the classification procedures should have helped in
preventing this type of oversight (see open item 50-206/86-32-01 in
Section 2 above). Stress level is another factor which should also be
considered here. It is noted that the stress level under which the
interviews were conducted was relatively low as compared to a backshift
emergency with minimum staff levels or even the activity level of an
annual exercise.
Regarding the protective action recommendation (PAR) portion of the
interviews, all of the SSs recommended the appropriate protective actions
for onsite personnel.
All of the SSs were familiar with the automatic
PARs.
However, two of the SSs (the same two mentioned above) had trouble
with the additional PARs for GE classifications. These additional PARs
are described in Attachment 4 of S0123-VIII-10 which is entitled
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"Directions for General Emergency Offsite Protective Decisions Flow
Chart". Each of the SSs was given 2 GE classifications which required
additional PARs.
One scenario involved a loss of physical control of the
facility and the other involved imminent containment failure in
conjunction with reactor core damage. Of the 8 postulated GE events that
were presented (2 to each SS), additional PARs were not given for 3 of
them.
One SS did not give the additional PARs for both GEs and one SS
gave one correct and one incorrect PAR. The discussion which was held
after the SS missed the additional PARs on the first GE, appeared to help
him for the next GE. According to the licensee's procedure (and NRC
guidance), a loss of physical control of the facility should result in a
PAR of evacuation for a 2 mile radius and 5 miles in the 3 downwind
sectors. The SS recommended sheltering these locations. It should be
noted that sheltering for a 2 mile radius and 5 miles in the 3 downwind
sectors is considered to be an automatic/minimum PAR for the GE
classification. The other GE scenario, imminent containment failure in
conjunction with core damage, should have resulted in a PAR of sheltering
for areas that cannot be evacuated before plume arrival; evacuation of
remainder of 5 mile radius and 10 miles in the 3 downwind sectors.
Both
SSs gave the automatic PAR mentioned above. It would appear that more
emphasis could be placed in this area.
During one of the interviews in which there were problems with additional
PARs, the SS and the inspector simultaneously discovered that the
procedure he was using (S0123-VIII-10, "Emergency Coordinator Duties"),
was incomplete. Page 1 of 4 of Attachment 4 was missing from the
uncontrolled (pink) copy book that was being used. The correct answer to
the question was actually located on page 3 of 4. No attempt was made to
locate a controlled copy book; however, the SS checked 3 other
uncontrolled copy books in the TSC and found that they were also missing
this page (page 22 of 26).
The SS acted as if he could not answer the
question because the page was missing.
It should be noted that each ERF contains only 1 controlled set of EPIPs.
Each ERF contains 2 complete pink copy books and several partial pink
copy books which are used by keyERP assigned to the facility. For
example, each TSC has a partial pink copy book for the EC, the Emergency
Advisor, the Technical Leader, the Health Physics Leader, etc. Many of
these partial books, even though they contain only those procedures
applicable to the positions' responsibilities, contain a copy of
S0123-VIII-10 because the position may provide direct support to the .EC.
After the interview, the inspector informed the SEP Supervisor of the
problem. SEP was contacted because the pink copy (uncontrolled) books
located in each of the ERFs are the responsibility of the SEP staff. As
it turned out,.SEP already had new (extra) copies of this EPIP for
insertion into the pink copy books, because they had noticed that one of
the pages had not copied very well.
SEP does not perform a page check
(count) on the pink procedures they receive from Corporate Document
Management (CDM).
SEP replaced the incomplete procedures within a matter
of hours.
SEP personnel estimated that about 50% of the pink copies in
the ERFs were missing the page.
6
During the remainder of the inspection, controlled copy EPIP books in the
ERFs were checked to determine whether they also contained incomplete
copies of S0123-VIII-10. On March 6, 1987, the licensee conducted a
controlled copy book check at both Control Rooms (CRs), TSCs and
Operations Support Center (OSCs). The inspector checked the EOF and the
Resident Inspectors' office. Page 1 of Attachment 4.of S0123-VIII-10 was
found to be missing from the controlled EPIP books at the following
locations:
the EOF, the Unit 1 OSC, and the NRC Resident Inspectors'
office. The controlled copies found in the CRs and TSCs were found to be
complete.
CDM personnel were contacted on March 6 and 9, 1987, in an effort to
determine what had occurred. CDM could only speculate, since
reproduction had taken place approximately one to two weeks earlier. CDM
personnel informed an NRC Resident Inspector that there are no CDM
procedures which cover reproduction. However, it was stated that page
checks are conducted when EPIPs are reproduced because they are
recognized as being more important .than .other procedures.
Problems with procedure control have been identified during previous
inspections. Section 10 of Inspection Report Nos. 50-206/86-01,
50-361/86-01, and 50-362/86-01 addressed an open item (86-01-02) related
to procedure control (uncontrolled copies).
Also, during an inspection
conducted on January 26-30, 1987 (Inspection Report Nos. 50-206/87-01,
50-361/87-01 and 50-362/87-01), the inspector found that an EPIP was
missing from the controlled copy book located in the Resident Inspectors'
office. The book contained the Temporary Change Notice (TCN) page for
EPIP S0123-VIII-40, "Health Physics Leader Duties", but the procedure was
not there. On January 28, 1987, the inspector mentioned this to the SEP
Supervisor and noted the problem on the Document Quality Audit form which
was located on the wall in the Resident Inspectors' office. The
procedure had been added to the book prior to this (March 2-6, 1987)
inspection.
During the inspection, including the exit interview, the licensee
emphasized that complete, controlled copies of S0123-VIII-10 were found
in the locations where the EC would be present (i.e., the CRs and TSCs).
In this particular case, the facilities that would have needed this
procedure, had a complete controlled copy. However, this does not reduce
the significance of the problem. Missing pages from EPIPs could lead to
event misclassifications, incorrect PARs or delays in both. Also, the
OSC, and EOF, once the EC responsibilities are transferred (see Open Item
50-206/86-32-02 above), have procedures which are important to the
functioning of those facilities.
Region V received a copy of the licensee's March 30, 1987 letter to the
NRC that was intended to provide supplemental information. The letter
describes the Corporate Document Management (CDM) program and the effort
expended to assure that copies of documents, including EPIPs, being
issued are complete. The letter notes that the problem with EPIP
S0123-VIII-10 was identified late in the inspection and there was
insufficient time prior to the exit interview to address the item.
Additional evaluation of the CDM program and the information contained in
the licensee's March 30, 1987 letter is needed to ascertain whether
7
Technical Specification 6.8.1.e had been violated. Therefore, this
matter is considered an Unresolved Item (87-04-01).
7. Unresolved Item
An unresolved item is a matter about which more information is required
to ascertain whether it is an acceptable item or a violation. One such.
unresolved item was identified during this inspection. Pertinent
information on this item has been described in Paragraph 6 above.
8. Exit Interview
The inspector held an exit interview with the licensee on March 6, 1987,
to discuss the preliminary findings of the inspection. The attachment to
this report identifies the licensee personnel who were present at the
meeting. The findings described in Sections 2-6 were briefly summarized.
The licensee was informed that the existence of the incomplete procedure
in some of the ERFs appeared to be a violation of paragraph 6.8.1.e of
their Technical Specifications. The licensee took exception to the
mention of a potential Notice of Violation on the matter, stating that a
certain level of error had to be expected, given the number of procedures
handled at the San Onofre site. The licensee also stated that a quality
control system was already in place for CDM and that there was nothing
that could be done to eliminate personnel errors. They also emphasized
that the controlled copy procedures in the CRs and TSCs were found to be
complete.
The inspector discussed concerns related to the misclassifications which
occurred during the SS interviews (Section 6).
The inspector stated that
these concerns would be discussed with Regional management, because
problems with misclassifying events were identified during similar
interviews a year ago (Inspection Report Nos. 50-206/86-01, 50-361/86-01,
and 50-362/86-01) and during last year's emergency exercise (see Section
2 above). The licensee stated that it was inappropriate to expect the
SSs to be 100 percent correct since that level of accuracy is not even
required for their licensed operator training. During the exit
interview, it was acknowledged that the training lesson plan for ECs had
improved during the past year. Also, since the exercise, several
meetings have been conducted to discuss options such as increased
training or procedure modifications which could help alleviate problems
with misclassifications.
The licensee was informed that their comments would be considered during
subsequent Regional discussions of the findings. Subsequent to the
inspection, Regional management reviewed the information concerning the
misclassifications and concluded that, even though possible improvement
had been identified, the performance level was acceptable.
8
ATTACHMENT
EXIT INTERVIEW ATTENDEES
C. Anderson, Emergency Planning Specialist
0. Bennette, Supervisor, Station Emergency Preparedness
K. Delancey, Emergency Planning Specialist
P. Dooley, Supervisor, Emergency Planning (NA&EP)
J. Firoved, Emergency Planning Engineer
R. Krieger, Manager, Operations
P. Krueger, Supervisor, Corporate Document Management Operations
M. Short, Manager, Nuclear Training
K. Slagle, Manager, Materials and Administration
K. Weigand, Jr. , Operations-Quality Assurance
H. Morgan, Station Manager
0. Peacor, Manager, Station Emergency Preparedness
R. Reed, Associate Emergency Planning Specialist
J. Shields, Supervisor, Buildings and Services
W. Marsh, Plant Superintendent
M. Wharton, Deputy Station Manager
J. Winter, Engineer, San Diego Gas and Electric
S. Wylie, Administrator, Training Support Services
M. Zenker, Compliance Engineer
W. Zintl, Manager, Compliance
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