ML16341F953
| ML16341F953 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 01/28/1991 |
| From: | Good G, Reese J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML16341F954 | List: |
| References | |
| 50-275-90-32, 50-323-90-32, NUDOCS 9102130267 | |
| Download: ML16341F953 (8) | |
See also: IR 05000275/1990032
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos.
Docket Nos.
License
Nos.
Licensee:
50-275/90-32
and 50-323/90-32
50-275 and 50-323
Pacific Gas
and Electric Company
77 Beale Street
San Francisco,
94106
Facility Name:
Diablo Canyon Units 1 and 2
Inspection at:
USNRC, Region V, Malnut Creek, California
Inspection
Conducted:
December 26, 19
0 - January
10,
1991
Inspector:
oo
-
r
cy
repare
ness
na ys
a
e
)gne
i
Approved by:
SUMMARY:
a
.
e se,
e
afe uards,
Emerg ncy Preparedness
and
Non-Power Reactor
Branch
I Zs
a
e
gne
Ins ection
on December
26
1990 - Januar
10
1991
Re ort Nos.
50-275/90-32
an
Areas Ins ected:
In-office inspection of Revision ll of emergency plan
amp
emen
sng procedure
(EPIP)
number
EP G-l, "Accident Classification
and
Emergency'Plan Activation."
Inspection procedure
82701 was
used
as guidance.
Results:
No deficiencies or violations of NRC requirements
were identified in
%lie area inspected.
The results of this inspection indicated that
EP G-l, as
changed,
continued to meet the standards
and the
requirements
The review indicated
a need for the
licensee to be more meticulous in its EPIP review process
to ensure that
unintentional
changes
are not introduced
and intentional
changes
do not go
unnoticed.
During the review, the inspector identified two existing emergency
action levels
(EALs) that were not consistent with the guidance in NUREG-0654,
and the EALs were not conservative
when compared to the guidance.
The Region
has deferred its pursuit of this matter pending the final approval of the
Nuclear Management
and Resource
Council
According to the
licensee's
emergency planning staff,
PG&E has committed to adopt the
new
scheme.
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DETAILS
1.
Persons
Contacted
J. Griffin, Nuclear Regulatory Senior Engineer,
Regulatory Compliance
W. Keyworth, Senior
Power Production Engineer,
Emergency
Planning
(EP)
E. Waage,
Senior Nuclear Generation
Engineer,
2.
0 erational
Status of the
Emer enc
Pre aredness
Pro
ram
Ins ection
roce ure
i
Revision 11 of emergency plan implementing procedure
(EPIP)
EP G-l,
"Accident Classification
and Emergency
Plan Activation," dated
September
28, 1990,
was submitted
on October 23, 1990, in accordance
with 10 CFR 50, Appendix E.
Regional
emergency
preparedness
staff conducted
an
in-office evaluation of the procedure
and the emergency action levels
(EALs) contained therein.
The evaluation
was conducted to determine
whether the changes
resulted in a decrease
in the effectiveness
of the
EALs and whether the
EALs continued to meet the standards
in 50.47(b)
and
the requirements
The guidance in NUREG-0654,
Revision 1, provided the basis for evaluating the EALs.
The inspector held a January
10, 1991, conference call with licensee
personnel
to discuss
the results of the evaluation
and to discuss/obtain
additional information related to some of the issues identified.
During
the conference call, the inspector
acknowledged that most of the changes
to
EP G-1 were editorial in nature
and did not affect the intent of the
procedure.
With the exception of the editorial
comments
brought to the
licensee's
attention during the conference call, the following represents
a summary of the issues
discussed
during the conference call and the
licensee's
responses.
A.
Margin change bars were not present
where changes
in text had
occurred.
Licensee
response - The licensee stated that change
bars are only
used to ease
the plant staff's review in cases
where the intent of
the procedure
has
been
changed.
The licensee
also stated that
change
bars are
used to alert the reader to new information in the
procedure.
B.
Some of the responsibilities listed for the Long Term Organization
Site Emergency Coordinator
(SEC) (Section 4.2) also apply to the
Interim SEC (Section 4. 1), but have not been listed in both
locations.
Examples included the responsibility to (1) conduct
assembly
and accountability,
(2) evaluate the need to evacuate
nonessential
personnel,
and (3) initiate onsite monitoring.
A
caution note
has
been
used to tie the responsibilities of the two
individuals together,
but it is not located in a central location
and could be overlooked.
Licensee
response - The licensee
agreed that the responsibilities
could be identified more clearly and stated that the correction
would be made in the next revision to EP G-l.
EP OR-3, "Emergency Reentry
and Recovery,"
as referenced
in Sections
'.3.ll.c and 5.4.9.c,
does not consider those
cases
where it might
be more appropriate to move directly into the recovery phase without
de-escalating
the event (e. g., Site Area Emergency
(SAE) and General
Emergency (GE)).
Licensee
response - The licensee
noted the comment
and will defer
action pending the issuance
of formal policy guidance
from the
NRC.
An "Initial Emergency
Response
Checklist"
has
been
added
as
Attachment 8.2, but a change
bar has not been
used to alert the
reader to its existence.
Licensee
response - The licensee
agreed that
a change
bar should
have been
used in this case.
The unusual
event
(UE) fire EAL is not consistent with NUREG-, 0654
and is not conservative
when compared.
According to NUREG-0654,
a
fire that lasts
more than 10 minutes warrants the declaration of a
UE.
The licensee's
EAL (Attachment 8.1) states that the
UE is
declared if the fire is not "under control within 10'inutes of
initiating fire-fighting efforts."
This could cause
a delay in the
event classification if the fire brigade's
response
was delayed.
The inspector
noted that this was
an existing
EAL (not a change)
and
that there
was another
EAL that required the declaration of a
UE if
offsite assistance
was required.
Licensee
response - The licensee
acknowledged this comment
and
stated that the need for offsite assistance
has driven the
declaration in the past.
The licensee
stated that it had committed-
to adopt the Nuclear Management
and Resource
Council
scheme.
NRC response - Interim modification of this
EAL was not considered
necessary
since the inconsistency with NUREG-0654 will be resolved
when the licensee
adopts the
NRC approved
The Alert EAL involving the loss of annunciators
is not consistent
with NUREG-0654 and is not conservative
when compared.
The
licensee's
EAL takes credit for the plant computer typewriter (i.e.,
an Alert is not declared
unless
the annunciators
and the typewriter
are lost).
NUREG-0654 does not address
the use othe plant
computer alarms.
Licensee
response - The licensee
acknowledged this comment
and
agreed that this issue will be resolved
when the
is adopted.
f>
%7
NRC response - Interim modification of this
EAL was not considered
.
necessary
since the inconsistency with NUREG-0654 will be resolved
when the licensee
adopts the
NRC approved
G.
The reason for changing the
seismic monitor reading
from'>0.6g to >0.4g was questioned.
Licensee
response - The licensee
stated that this change
was based
on a recent review of the Final Safety Analysis Report (FSAR).
NRC response - Since this is an intent change,
a change
bar should
have been
used to alert users to the change in the value.
H.
The reference in the
GE section of Attachment 8.1,XII was changed
from ¹3 to ¹5.
The change
appears
to be incorrect (i.e., ¹3 appears
to be the correct reference).
Licensee
response - The licensee
stated that this was
a
typographical error and agreed that ¹3 was the correct reference.
The licensee
stated that this would be corrected in the next
r'evision to
EP G-l.
I.
The reason for not including EP G-4, "Personnel
and Accountabi1ity,"
in Sections
2 and
3 of Attachment 8.2,
was questioned.
Licensee
response
- The licensee
agreed that
EP G-4 should
have
been
included in both sections of Attachment 8.2.
The licensee
stated
that this would be corrected in the next revision to
EP G-l.
The reference .to
EP G-3, "Notification of Offsite Agencies
and
Emergency Organization Personnel,"
in the Assembly,
Account (sic)
&
Evacuation of Non-Essential
Personnel
part of Section
3 of
Attachment 8.2, is incorrect and should probably be
EP G;5,
"Evacuation of Non-Essential
Personnel."
Licensee
response - The licensee
agreed
and stated that this would
be corrected in the next revision to
EP G-l.
3.
Exit Interview
An exit interview, via conference
call,.was
held on January
10, 1991, to
discuss the results of the in-office review of EP G-1.
The licensee
representatives
who participated in this conference call
have
been
identified in Details Section 1.
The findings described in. Details
Section
2 were discussed,
in addition to several
other editorial
comments.
The results of the NRC's review of EP G-1 indicated that the EALs, as
changed,
continued to meet the standards
and the
requirements
of 10 CFR Part 50, Appendix E.
The results indicated
a need
for the licensee to be more meticulous in its review of EPIPs to ensure
that unintentional
changes
are not introduced
and changes
involving
intent are highlighted to alert users to those
changes.
~I