IR 05000312/1985015

Insp Rept 50-312/85-15 on 850513-17 & 30.No Deficiencies or Violations Noted.Major Areas Inspected:Knowledge & Performance of Duties (Training),Staffing & Licensee Audit of Emergency Preparedness Program

ML20133C308
Person / Time
Site:	Rancho Seco
Issue date:	07/17/1985
From:	Fish R, Prendergast K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20133C294	List: IR 05000312/1985015 ML20133C291
References
50-312-85-15, NUDOCS 8508070009
Download: ML20133C308 (5)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION V

Report N /85-15 Docket No. 50-312 License No. DPR-54 Licensee: Sacramento Municipal Utility District P. O. Box 15830 Sacramento, California 95813 Facility Name: Rancho Seco Nuclear Generating Station Inspection at: Clay Station, California Inspection Conducted: May 13-17 and 30, and subsequent telephone conversation on June 17, 1985 Inspector: k da,, m 4 -i / n / pf Datb S'igned

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- Prendergast Q Em e y Preparedness Analyst Approved by: t/l/ 7 T S-T.lF. Fish, Chief ' Datej$igned Emergency Preparedness Section Summary:

Inspection on May 13-17, and 30, and subsequent telephone conversation on June 17, 1985 (Report No. 50-312/85-15)

Areas Inspected: An unannounced routine inspection of knowledge and performance of duties (training), staffing, and licensee audits. The inspection involved about 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> onsite by one Imc inspecto Results: No significant deficiencies or violations were observed within the scope of this inspectio A G

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DETAILS Persons Contacted

• B. Dieterich, Manager of Licensing

• R. Le Neave, Emergency Planning Specialist

• D. Finley, Emergency Planner J. Mau, Training Superintendent T. Maires (Contractor)

R. Myers, Emergency Preparedness Coordinator

• Indicates personnel present at the exit intervie . Licensee Audits The inspector examined the licensee's audit of the Emergency Preparedness Program to determine that an annual independent audit had been performed, and that it met the requirements of 50.54(t) of 10 CFR Part 50. The audit to meet the 50.54(t) requirements was performed March 4-15, 198 The audit was observed to contain an evaluation of the adequacy of the SMUD interface with state, local, and county agencies. The audit also contained an evaluation of the licensee's drills, exercises, facilities, capabilities, and training associated with the Emergency Preparedness Program. The results of the audit were transmitted to management by letter dated March 22, 1985. The audit distribution list was examined and observed to contain members of management for both plant and corporate offices. The portion of the audit that dealt with the interface between SMUD, the state, and local agencies will be made available to those agencies by a letter drafted by the Quality Assurance Department. The letter will be draf ted awaiting concurrence by the Emergency Planning Section. The concurrence from the Emergency Planning, along with the responses to the items and recommendations contained within the audit, are due June 1, 1985. The items and recommendations contained within the audit primarily referenced the need to update procedures and to provide better documentation. These same problems were also observed during this inspection and were discussed during the exit intervie During the examination of that portion of the audit that dealt with the interface between SMUD, the state and local agencies, the interface was depicted as cooperative, with the exception of one county located within the Emergency Planning Zone (EPZ). Discussions by the inspector with the Federal Emergency Management Agency (FEMA) and the State Office of Emergency Services were held and established that during the last exercise the county in question was able to perform its role in protecting the health and safety of the publi The audit was limited to the Eccrgency Plan and its implementation, and made no reference to Appendix E or 10 CFR 50.47(b), which are the regulatory requirements of the Emergency Preparedness Program. Also, from discussions with the QA Department it was learned that the licensee has no specific plan or pqycedure to provide assurance, that at some point in. time, all components of the Energency Preparedness Program have

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been evaluated. The addition of the above mentioned items would ensure that the regulatory requirements of the Emergency Preparedness Program are evaluated, should changes in the program or. Emergency Plan occu Auditor qualifications were reviewed and both members of the tece appeared well qualified. Both members of the team had degrees relating to Emergency Preparedness and had attended numerous courses in auditing along with many years of experience in Emergency Preparednes Critiques for drills and exercises were observed to be routed to management. Suggestions for improvement were noted to be contained within the critique and are tracked by the licensee's computerized tracking list. A number of resolved items from the 1984 exercise were examined end their resolution appeared appropriate. The licensee also utilizes such items in the preparation of scenarios for drills or exercises. The licensee appears to have an adequate program for tracking deficiency or improvement items identified during drills or exercise No violations of NRC requirements were identifie . Knowledge and Performance of Duties (Training)

The Emergency Plan (EP) and implementing procedures were reviewed, discussions with individuals involved in training were held, and records of training were examined. Based upon the results of this inspection, the following observations were note (i) AP 580 Section 2.2 states that the Nuclear Training Superintendent is responsible for the general onsite emergency response trainin The Emergency Plan (AP 500) in Section 8.1.3(a) delegates the responsibility to assure that appropriate personnel receive appropriate training in emergency response to the Emergency Preparedness Coordinator. From discussions with these two individuals there appeared to be confusion over which position is responsible for onsite training. Both individuals indicated the other was responsible for onsite training. However, pending the completion of the licensee's reorganization, the responsibilities for emergency response training will be divided between the offsite and onsite organizations. The Training Superintendent will be responsible for the onsite organization and the Emergency Preparedness Coordinator will be responsible for the offsite organization. According to the licensee, these changes to the Emergency Plan and implementing procedures will be initiated when the position of Training Superintendent has been filled (0 pen Item 85-15-01).

(ii) Attachment 7.3 of AP 580 outlines several areas of information required for training documentation e.g., instructors name, date of training, quiz number, individuals emergency assignment and et However none of the offsite or onsite training records examined were documented correctly. Typically the information given was very minimal. Names and modules with an occasional test score were the norm for onsite records, while a name or topic was usually all that was given for offsite records. In addition records of offsite L

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..3 training were very difficult to locate. It was suggested at the exit interview that the licensee review his performance related to documentation of trainir.g record (0 pen Item 85-15-02).

(iii)The current training program now being implemented exceeds guidelines contained in the EP and implementing procedure, however because of differences in the structure of the modules this program does not follow the EP. It was recommended during the exit interview that the licensee update the EP and implementing procedures to incorporate the current trcining program and to reach clear agreement between the EP and implementing procedures (0 pen Item 85-15-03). From discussions with the Emergency Preparedness Coordinator, changes to the EP and implementing procedures have been initiated and submitted for revie (iv) Records of Shift Supervisors, Control Room Operators and Auxiliary Operators were reviewed during this inspection, and those records indicated that training was completed satisfactorily in 198 Records documented that a major portion of the required training for 1985 has also been completed and the licensee had a list of individuals who still required certain training modules prior to completion of their 1985 annual training requirement The licensee stated that training was scheduled again in July and that the July training should complete the major portion of required training for those individuals who might be in the control roo Again, records of training were noted not to have followed the format contained in Attachment 7.3 as required by AP 58 (v) The inspector reviewed the licensee's Nuclear Response Tracking List. This list was developed by the Emergency Planning Department to incorporate the individuals in the Emergency Response Organization (ERO) and to catch changes of designated positions within the ERO so that additional training may be performe A review of this document and the licensee's call out procedure (AP 506.01 and 506.02) indicated that the Nuclear Response Tracking List needs updatin It was also suggested during the exit interview that the Nuclear Response Tracking List be updated to include individuals who hold positions in the Emergency News Cente No violations of NRC requirements were identifie . Staffing During the course of this inspection Emergency Planning staffing levels were examined. The examination revealed that the licensee has had one position -in Emergency Planning vacant for approximately two years. In addition there have been two other positions vacant for approximately one year. The licensee was encouraged to expedite filling these vacancies to insure adequate staffing is available to maintain Emergency Preparednes No violations of NRC requirements were identified.

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5. Exit Interview An exit interview was held on May 17, 1985 for the purpose of discussing the preliminary findings of the inspection. Discussions were also held with the Emergency Preparedness Coordinator on May 30 for obtaining additional information concerning this inspection. Licensee personnel present at the exit interview have been previously identified in paragraph.1 above. The licensee was informed that no violations of NRC requirements were identified. However the inspection disclosed that a number of open items required their attention. The following items were specifically discusse . Low staffing levels in the Emergency Planning Department (see Section 4). Non current Emergency Plan and implementing procedures for training (see Section 3). Poor training documentation (see Section 3). , Training management responsibilities (see Section 3).