IR 05000206/1986001

Emergency Preparedness Insp Repts 50-206/86-01,50-361/86-01 & 50-362/86-01 on 860106-10 & 0203-07.No Violations Noted. Major Areas Inspected:Emergency Preparedness Program Changes,Public Info & Shift Staffing

ML20141C639
Person / Time
Site:	San Onofre
Issue date:	03/21/1986
From:	Fish R, Temple G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20141C591	List: IR 05000206/1986001 ML20141C583
References
50-206-86-01, 50-206-86-1, 50-361-86-01, 50-361-86-1, 50-362-86-01, 50-362-86-1, NUDOCS 8604070282
Download: ML20141C639 (15)

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U.--S. NUCLEAR REGULATORY COMMISSION w .,

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Report No /86-01, 50- 361/86-01 and 50-362/86-01 L

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• l ~50-206,"(50-361 and 50-362

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Docket Nos.' , p . , ,n License Nos.- ,

• DPR-13, NPF-10'and.NPF-15

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Southern California Edison Company

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.P."0.~ Box 800,92244 Walnut Grove Avenue

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Rosemead, California 91770

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San Onofre Nuclear Generating Station Units 1, 2 and 3

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Facility Name:

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Inspection at: San Onofre Site, San Diego County, California l

Inspection conducted: January 6-10 and February 3-7, 1986 l Inspector: Mrd A G. M. Temple, T.mergency Preparedness Analyst b'

Date Signed

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Approved By: u / b

] R. F. Fish, Chief Date Signed i Emergency Preparedness Section i Summary:

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Inspection on January 6-10 and February 3-7, 1986 (Report Nos.'50-206/86-01 i 50-361/86-01 and 50-362/86-01)

$ Areas Inspected: Routine, unannounced cmer'gency preparedness inspection in the areas of changes to the emergency preparedness program, public information, shift staffing and augmentation, notifications and l

communications, licensee audits, emergency detection and classification, i protective action decisionmaking, knowledge and performance of duties t (training) and follow-up on four open items identified during previous j emergency preparedness inspections. Inspection procedures 82201, 82202, j 82203, 82204,'82205, 82206, 82209, 82210 and 92701 were addressed.

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4 Results: In the nine areas inspected, no significant deficiencies or i violations of NRC requirements were identified. . All four of the open items

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identified during previous inspections were closed. Three open items and one -

2 -unresolved item were identified during this inspection.

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DETAILS

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1. Persons Contacted Southern California Edison D. Barney", Shift Superintendent, Unit 1 D. Bennette, Supervisor, Station Emergency Preparedness C. Bostrom, Administrator, Health Physics / Chemistry Training G. Buzzelli, Emergency Planning Engineer R. Calsbeck, Computer Based Instruction Specialist y

A. Dack, Quality Assurance Engineer

R. Dickey, Supervisor, Operations Training-

! P. Dooley, Supervisor, Emergency Planning

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C. Elliot, Shift Superintendent, Units 2/3

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J. Firoved, Emergency Preparedness Engineer S. Jones, Foreman, Health Physics, Units 2/3 L. Kinkade, Emergency Planning Specialist J. Long, Quality Assurance Engineer G. Lulias, Quality Assurance Engineer

) Neal, Supervisor, Technical Training i Schutter, Shift Superintendent,-Unit 1 Scott, Supervisor, Health Physics, Unit 1 Vogt, Shift Superintendent, Units 2/3 i Wallace, Supervisor, Nuclear Affairs Wylie, Administrator, Training Support Services -

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Other Personnel C. Anderson, Emergency Preparedness, Engineer, (ASTA)

a S. Olofsson, Emergency Preparedness Specialist (BSG)

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R. Reed, Emergency Preparedness Specialist (BSG)

, 2. Action on Previous Inspection Findings i

! (Closed) Open Item (83-24-01): The Emergency Plan (EP) did not contain a cross reference to the criteria of.NUREG-0654/ FEMA-REP-1, Revision 1, as recommended in Section I.J. of that document. Revision 1 of-the licensee's EP, which was transmitted by letter dated December 21, 1984,

contains a cross reference to the criteria of NUREG-0654. This information has been included as Appendix F to the EP. This item is considered to be close (Closed) Open Item (85-24-01)

The licensee's evaluation of the 1985 medical emergency drill had not been completed. The-licensee's i

evaluation of the 1985 medical emergency drill had been delayed by their annual emergency exercise. In addition to the delay,' the' item was

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flagged as open because no supporting documentation (i.e., an itemized listing of areas where corrective actions might be warranted, status of i corrective actions and corrective actions to be implemented) could be produced for either the 1984 or 1985 medical _ emergency drills. There also appeared to be some confusion between the station and corporate l

(Nuclear Affairs and Emergency Planning (NA&EP)) emergency preparedness

, staffs regarding the overall management > responsibility associated with l

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l the evaluation / documentation of these' types of drill Since this item was identified, the licensee has compiled and placed into a binder all of the documentation to support ~their evaluation of the 1985 medical dril The inspector examined the contents of the binder and found the documentation to be well organized and. appropriate. Management responsibilities associated with all drills and exercises have been clarified and will be documented in a Memorandum of Understanding (MOU)

between the two aforementioned staffs. This MOU will replace or be

, incorporated into Emergency Plan Implementing Procedure (EPIP)

S0123-VIII-0.200 ." Emergency Plan Drills". Since the licensee has completed their evaluation of the 1985 medical drill, developed a documentation format to be used for future medical drills and clarified the management responsibilities, this item is considered to be close (Closed) Open Item (85-24-02): The coordination between the Emergency ,

Operations Facility (EOF) and Technical Support Center (TSC) staffs, with *

4 respect to the decision making process used for recommending offsite protective actions, should be reviewed. The licensee has evaluated the circumstances that led to the opening of this item (see Section 9.d of

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NRC Inspection Report Nos. 50-206/85-24, 50-361/85-25 and 50-362/85-24).

Their evaluation included discussions with affected licensee staff and offsite officials. Based on the licensee's evaluation, procedural modifications were not deemed necessary. The intent of this open item has been met through these discussions in that the licensee has become sensitive to the potential implications and interpretations related to .

this matter. This item is considered to be closed.

(Closed) Open Item (85-24-03): The reason for the number of communication flow problems during the 1985 annual emergency exercise should be examined. The NRC inspection report (Report Nos, noted in previous paragraph) for the annual exercise cited five examples of

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communication flow problems. The intent of this open item was' to get the j licensee to determine if there was a common, root cause to which these problems could be linked. The licensee has determined that training, in the area of the practical aspects of transmitting and receiving information, could be emphasized. To accomplish this, in part, the i licensee intends to start havihg communication drills in which some technical emergency response' personnel would participate. The licensee

.also stated.that a lesson plan has been changed to include the type of information that should be noted on status boards. The licer.aee has further clarified the sour'ce/ destination of information provided by l certain emergency response personnel. Since the licensee has addressed all of the communication flow' problems contained in the aforementioned inspection report-(i.e., Sections 8.a. 8.b, 8.d, 9.a and 11.h), this item i is considered closed.- 1

. Changes to the Emergency Preparedness Program j

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To determine if,any changes to the, emergency preparedness program had

. been made which:could! affect the_overall state of emergency preparedness, the inspector addressed the following areas: 1) changec to the Emergency Response Facilities (ERFs) (i.e., TSC, EOF and Operations Support Center (OSC)), 2) changes to th& emergency response organization, 3) changes to I

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the licensee's Emergency Planning Departments (station ~and corporate),.4)

changes to the EP and 5) changes to the EPIP ~

The inspector toured the EOF and TSCs (Unit 1 and Units 2/3) and determined that no significant changes had been made to these facilitie Regarding the OSCs, the Unit 1 OSC was temporarily relocated, due to construction, to the Units 2/3 OSC, beginning in the month of August 1985. An Emergency' Planning Bulletin, addressing the temporary relocation and interim activation procedures, was issued on August 16, 1985, to alert affected personnel of this change. A map showing the location of the Units 2/3 OSC was included as part of the bulletin. The Unit 1 administration building-has been expanded and a portion of this new butiding now houses the Unit l'OS The new Unit 1 OSC was completed and,_its function restored, prior to the end of this inspection. The inspector noted that all Unit,1 procedures and equipment were also temporarily relocated during this period. A subsequent bulletin was issued when the new. Unit 1 OSC was complete The new OSC would appear to be'an improvement, because it is physically larger. Around the first of April 1986, the Units 2/3 OSC will be relocated to the Unit 1.0SC so

.that the Units 2/3 OSC"can be enlarged. The licensee intends to keep both OSCs 'as similar as possible to facilitate familiarity of all emergency response personnel assigned to either OSC. One additional change, slated for the second quarter of 1986, involves the replacement

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of the licensee's UHF radio system with a new radio system. Based on the licensee's verbal description of the new system, it would appear that communication capabilities will be significantly improved. These changes will improve the overall state of emergency preparednes This inspection disclosed that there have been no functional changes to the emergency response organization. However, a new Station Manager and Deputy Station Manager.have been appointed during the past year. These changes do not impar * the overall state of emergency preparednes The inspector discussed with station and corporate (NA&EP) emergency -

planning personnel, any organizational or staff member changes that would have an impact on the administration of the licensee's emergency preparedness program. The only notable change occurred in the Station Emergency Preparedness staff. Three contractor individuals, who had been working in the group for some time, are going to be hired as full-time Southern California Edison (SCE) employees. This change does not impact the administration of the emergency preparedness program.

l The inspector verified that no major changes have occurred in the administrative methods used to effect changes to the EP or EPIPs. A description of these methods is contained in Section 3 of NRC Inspection Report Nos. 50-206/84-34, 50-361/84-33 and 50-362/84-34. The EP is in the process of being revised and the new revision (Revision 2) should be completed and issued in the very near futur In addition to the new location of the Unit 1 OSC, other changes beirs incorporated into the EP include the results of a more recent evacuation time study (Appendix E to the EP) and the addition of several new sirens.

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During discussions with NA&EP personnel, the inspector was informed that-the document that describes the EP training program (ERT-1) was also

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E being revised and Revision 2 would'be issued very soon. .The NRC has not

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been included on the distribution list for this document. Since the EP: .

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training. program can have a significant impact on the state of~ emergenc ~

preparedness, the inspector discussed _the need to be kept apprised of'any

- changes,being madeito the program., The inspector referenced paragraph V '

i of Appendix E to:10'CFR 50,which' addresses distribution to the NRC'of

procedures used to implement EPs.7 Since ERT-1 implements Section 8 of the licensee's EP, ERT-1 should be sent to the NRC in accordance with the

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aforementioned requirement. It should ,be noted that ERT-1 was not sent,

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in the: pasts to the NRC because it was noticonsidered to be an EPIP. The

. licensee a' greed toltransm'iti'this document ' - The inspector informed the-

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licensee that' formal transmittal'could'begin with ERT-1, Revision ; Region Vlwill. consider th'isjissue taibe'an "open" item'(86-01-01) until ,

ERT-1; Revision 2,.is sent'to the Regio ,

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The Region-V Emergency PreparednessiSection performs an annual. review of changes to the licensee's EPIPs; This review was accomplished _in the

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! office, prior to this inspection. The following procedures were  ;

4- reviewed.

i S0123-VIII-0.200, Revision 0,.TCN 0-2 (Temporary Change Notice),

, "Eu rgency Plan Drills" i i S0123-VIII-0.201, Revision 0. TCN 0-3, " Surveillance Requirements -

j Emergency Response Facilites/ Equipment" S0123-VIII-0.202.1 Revision 1, TCN 1-3, " Assignment of Emergency

. Response Personnel"

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j S0123-VIII-0.204, Revision 1. TCN 1-4, " Evacuation of Non-

- Emergency Response Personnel"

S0123-VIII-0.301, Revision 2 "Of'fsite/Onsite Communication Tests"

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S01-VIII-1, Revision 2, TCN 2-2, " Recognition and Classification j of Emergencies" l S023-VIII-1, Revision 2, TCN 2-4, " Recognition and Classification

of Emergencies"

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S0123-VIII-10,' Revision 3, " Emergency Coordinator Duties"

4 S0123-VIII-30, Revision 2. TCN 2-1~, " Operations Leader Duties"'

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Most of the changes were editorial in nature, however, some changes

- provided clarification or emphasis in particular areas;- The licensee was j contacted by telephone on December 19 and 20, 1985, for clarification of-l three procedural matters. One matter involved a' caution note on several'

of the General Emergency (GE) tabs and another matter involved monitor- )

readings associated with Emergency Action Levels (EALs). . Both of these..

matters were clarified during the telephone conversations. The third

matter, involving certain statements.made in S01-VIII-1 and S023-VIII-1

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related to event declarations when initiating conditions have been corrected prior to event classification, required further discussions..

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,, i- i Some of"these discussions involved the Chief of.the Region V Emergency -

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Preparedness.Section and NRC Headquarters Emergency Preparedness t personnel. rBasdd on these discussions, the licensee volunteered to ,

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change'the wo'rding.in the-procedures lto more clearly state their- ,

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intentions.t(The' inspector-reviewedtheproposedwordingchangesand

' discussed them with her supervisor,/ prior to_the end of this inspection.

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.The proposed. changes'were det' ermined to be adequate. sThe licensee was f

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informed 2of'this determination during'the inspection. Changes made to

the pr6cedures listed above con'inued t to implement the_EP, did notfreduce-the effectiveness of emergencyrpreparedness and did not result in a-failure to meet the perforic.ance standards in 10 CFR 50.47(b).

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No significant deficiencies or violations of.NRC requirements were identified during.this_part of the inspection.

' Public Information" Program

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i The inspector verified that basic emergency response information has been j disseminated to the public in the plume exposure pathway Emergency i Planning Zone (EPZ)-on an annual basis. The inspector reviewed the 2

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licensee's publications which have been developed as part of their public- l 1 information program. The licensee has developed three different _ ,

publications; one for the EPZ,'one for Camp Pendleton and one for the i

Public Education Zone. The information contained in these publications j was found to be appropriate and showed a firm commitment to the progra In addition to the 1985 EPZ publication, the inspector reviewed the draft

! text of'the 1986 EPZ publication. The 1986 publication will be reviewed ,

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! and approved by appropriate offsite officials, prior to dissemination..

j The 1986 publication will also incorporate comments made by the Federal ,

j Emergency Management Agency (FEMA). The (uspe'etor also verified that a system for providing emergency response information to the transient' ,

i population was in place. Licensee personnel stated that based on current .

census data, special provisions for non-English speaking persons ic not ,

, necessary. Special provisions have been made fer handicapped-

! individuals. Information regarding emergency response is also contained .

) in the local; telephone directory. The EPZ publication also contained the -

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address of various establishments that can provide additional information'

i if requested. Licensee personnel also produced' documentation to show

that many seminars have been presented to various organizations which j have requested additional emergency response informatio ,

No significant deficiencies or violations of NRC requirements were i identified during this part of the inspectio ;

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1 - _ Shift Staffing and Augmentation.

l The inspector verified that minimum onshift crews and augmentation  !

capabilities were consistent with the goals of Table B-1 of NUREG-0654.

j Section 5 of the licensee's EP, entitled " Organizational Control of l Emergencies", addresses the' minimum and augmented onsite' emergency  ;

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organization. Authorities and responsibilities of key individuals in the i i emergency organization have been included in Section 5. The licensee's I

) administrative method used to meet staffing goals are described in i

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S0123-VIII-0.202 " Assignment of Emergency Response Personnel". Personnel

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. 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-i as Nuclear Emergency Response Team (NERT) member Recall of ERP, which includes'NERT members, is conducted via a y

combination of telephone. calls and pager activation. During normal work hours, the site telephone operator conducts the recall. .During off normal hours, recall is initiated by the affected unit Shift Communicator, with the support of the SCE dispatcher. -The Station Emergency Recall List (SERL) is a computerized listing of qualified .

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(i.e., fully trained) ERP. The SERL.is generated from the computerized ~ .

Training Information Management System (TRIMS) records of: individuals who have completed all EP trainin It should be noted that this is a recent improvement to the SERL. The corporate or Emergency Support Organization 1 (ES0) personnel, who are contacted for emergencies, are listed in Table 2

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of the "ESO Procedures Manual". The SCE dispatcher maintains an up-to-date listing of office /home telephone and pager numbers. Calls

] trees are utilized to complete ESO notifications. Telephone numbers and

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names on the SERL and ESO roster are updated once per month or when accuracy gets below 95 percent.

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To determine whether augmentation times could be met, the inspector reviewed a summary report of the Eme'gency r Plan Backshift Drill which was conducted on August 22, 1984. Formal documentation of a later drill, conducted on December 20, 1985, had not yet been completed. The results ,

of the drill indicated that augmentation time goals could be met, j Parking problems caused delays for some station personnel and there i

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apparently was some delay in starting the ESO call. tree. On the surface, it appeared that there was some difficulty with the response of the ESO

, personnel, however, NA&EP personnel stated that the EOF was capable of '

activation within 60 minutes even though some personnel had not arrive '

It should be noted that recall included more than the minimum staff needed for activation. Emergency recall was also tested during the licensee's annual emergency exercise conducted on August 7, 1985. .One i item, related to the reliability of the pagers, has been placed on the San Onofre Commitment Register (SOCR) as a result of the exercise. The  ;

due date was noted to be January 30, 1986. In spite of the pager

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problems, augmentation times were met during the exercis No significant deficiencies or violations of NRC requirements were ,

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, identified during this part of the inspection.

, Notifications and Commtmications

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The inspector reviewed the licensee's EPIPs used in the notification process. This review included: 50123-VIII-10, Revision 3, TCN 3-2,

" Emergency Coordinator Duties"; SD123-VIII-30, Revision 2 TCN 2-1,

" Operations Leader Duties"; S0123-VI11-30.1, Revision 4. TCN 4-1, " Shift ( Communicator Duties"; S0123-VIII-70.1, Revision 3. TCN 3-1, " Site -

Telephone Operator Duties". From a procedural standpoint, the licensee's i notification process appears to be adequate. The procedures contained notifications based on emergency classifications and they provide a  ;

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system for alerting, notifying and activating ERP. The appropriate

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offsite agencies have been included and there is a system to assure that the information (telephone numbers) are kept current. The procedure provides for a verbal offsite agency notification within 15 minutes of event declaration and the completion'of an Event Notification Form (ENF)

(Attachment 4 to S0123-VIII-30.1), with provisions for verification, within 30 minutes of event declaration. The Emergency Coordinator (EC)

is required to approve the ENF. Attachment 5 to S0123-VIII-30.1 is a ,

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combination NRC and local offsite agency follow-up notification (NRC/ FUN)

form. Attachment 5 is to be completed, approved by the EC and the ,

information transmitted-to the NRC via the Emergency Notification System (ENS) telephone within one hour of event declaratio Inspection activities related to the licensee's communication capabilities involved a review of EPIP S0123-VIII-0.301, "Offsite/Onsite  ;

Communications Tests", verifying that communications equipment existed in the ERFs and an examination of the results of the licensee's communication tests which were conducted in December 1985. The inspector determined that the procedure was descriptive and workable, the communications equipment existed in the ERFs and that communications tests have been completed and documented in accordance with S0123-VIII-0.30 No significant deficiencies or violations of NRC requirements were identified during this part of the inspectio . Licensee Audits The inspector examined audit reports and talked to licensee personnel to determine that an independent audit / review of the emergency preparedness program had been conducted on an annual basis in accordance with 10 CFR 50.54(t) and Section 8.2 of the licensee's EP. Audit reports for 1984 (SCE Quality Assurance (QA) Audit Report SCES-015-84 dated July 2, 1984) and 1985 (QA Audit Report SCES-047-85 dated September 25, 1985)

were examined. The 1985 audit report consisted of nine (9) audit plan items. Two of them dealt with the Post-Accident Sampling System requirements and seven (7) were related to other areas of emergency preparedness. Both of the audits were conducted by the licensee's QA Departmen The inspector's examination of the 1985 audit report showed that the licensee's method for conducting this audit primarily involved observatien of the licensee's annual emergency exercise by the QA Department. Five of the seven emergency preparedness audit deems (item nos. I, 2, 3, 4 and 6)twere connected in some way to the exercise. This matter was discussed with members of.the licensee's QA department. These discussions disclosed that. consideration was being given to using this method on a regular basis' and that using the exercise observation as the basis for this audit may not have bedn specifically planned prior to the exerciae. Licensee personnel stated that since members of the QA department had participated in the August 7, 1985, exercise as controllers and/or observers, this effort could be used as part of the annual audit which'was scheduled for September 1985. The inspector expressed concern that scue program areas could possibly be missed or the depth of the audit in certain program areas could be limited in nature u_________________________________ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___ ___ _ __ _ _ _ _ _ _ _ _ _ _ - ___ _ _ _ _ _ _ o . _ . . , _ . _ _ _

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(i.e., not adequate enough'to ferret out problems / inconsistencies'in the program). Additionally, based'on a review of the procedure used to i conduct this type of audit (QA Procedure No. N18.12,~ Revision 2. "QA

} Organization Audit of the Emergency Preparedn'ess. Program"), the inspector concluded that the audit program could be improved if a matrix, listing each specific program area that needs to be audited, was developed and

incorporated into the procedure.

This was also discussed with the license ,

I No significant deficiencies or violations of'NRC requirements were identified during this part of,the inspectio . Emergen'cy Detection and Classification

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) This1 subject was' examined through;a review of applicable procedures and

! discussions with licensee personnel, including interviews with Shift Superintendents-(SSs).; The results of the SS interviews are' summarized in Section'10 of this report. The inspector reviewed EPIPs S01-VIII-1,

. S023-VIII-1,and S01237 VIII-10 and; concluded that they contained j measurable and observable EALs based-on in-plant conditions and on i onsite/offsite radiological monitoring results, criteria for recommending

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onsite/offsite protective actions, and the four levels of emergency i classifications-(i.et, Unusu_al Event (UE), Alert (A), Site Area Emergency (SAE) and General Emergency (GE)). Authority and responsibility for classifying events and recommending protective actions have been clearly

, defined. The format of the classification procedures would appear to facilitate prompt classifications. By letter dated February 13, 1985, the licensee's EALs were transmitted to State and local agencies for their review. ,Theginspector noted that each of the offsite agencies had responded with their agreemen No significant deficiencies or violations of NRC requirements were  ;

j identified during this part of the. inspection.

1 9. Protective Action Decisionmaking

, Protective action decisionmaking was~ addressed through a review of

applicable procedures and discussions with licensee personnel, including interviews with SSs and Health Physics (HP) Foremen. The results of the-l SS and HP Foremen interviews are summarized in Section 10 of this repor l Procedures applicable to this subject, in addition to the procedures i noted in the previous section, are S0123-VIII-40, Revision 3, TCN 3-3,

" Health Physics Leader Duties", S01-VIII-40.100, Revision,1, TCN 1-3, and

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S023-VIII-40.100, Revision 2, TCN 2-2 " Source Term and Dose Assessment".

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Based on the review of all of these procedures, the inspector concluded <

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that the appropriate information, including authorities, responsibilities

, and protective action recommendations based on plant conditions and dose j projections, were contained in the. procedure No significant deficiencies or violations of NRC requirements were )

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1 Knowledge and Performance of Duties -

The licensee's EP training program was' examined. Training records were

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-reviewed ~to' determine.if EP training of ERP had been conducted in accordance with the licensee's procedures. Interviews with SSs and HP

Foremen.were conducted to determine their familiarity (i.e...

effectiveness'of training) with procedures they would be required to use in an emergency. . . . . - + ~-

The inspector reviewed the: TRIMS computer printout and concluded that trai,nibg of ERP;w'as'up-to-date. 'Thecaccuracy.of the information contained on the TRIMS pr'into'ut was verified by comparing training i completion dates, for certain ERP, with' attendance roster It should be noted that all EP 'traiding is now being conducted on the licensee's PLATO computer system. EP training is completed along with

the individuals' Red Badge' training. Like the Red Badge training, PLATO

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gives the user an opportunity to challenge the training material and skip i

directly to an examination. If a score of 80 percent or better is not

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achieved, the individual must start over. Repeating the process involves a full presentation of training course material and another examinatio l To test the effectiveness of the licensee's EP training program for

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operations personnel, 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

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Plant Manager. The inspector presented a total of 30 emergency situations (divided among the four SSs). For each emergency situation, the SSs were asked to classify the event and describe any other actions they would be required to take. Out of the 30 emergency situations, two were not classified in accordance with applicable procedures. In

addition, one of the SSs had a problem classifying Technical Specification related UEs. Five other situations required some prompting on the part of the inspector or additional discussions. The inspector j concluded that the SSs interviewed showed weakness in this are Additionally, three of the SSs appeared to be a little weak in the area

of protective action recommendations. Most of'the SSs were familiar with the automatic protective actions, however, there appeared to be a temptation to make a recommendation from memory, rather than check the procedure. This caused one SS to overlook the automatic beach evacuation at the SAE classification. The SS corrected his recommendation later, after he checked the procedure. During the interviews, one of the Unit 1 SSs noticed that S01-VIII-I referred to a letdown monitor. He pointed out that Unit I has no such monitor. This matter was discussed with e

Station Emergency Preparedness. The inspector verified that a mechanism exists by which individuals can report procedural glitches such as this, if they are noticed when procedures are used to accomplish trainin Based on the weaknesses described above, the inspector examined the lesson plans used for training purposes. The lesson plan material appeared to be appropriate, however, since individuals can skip this material by challenging the training and going directly to the examination, the inspector reviewed the test questions. This review showed that there were a total of 50 questions in the computer bank, from

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which about 25t.are presents.d randomly per nxamination. Out of'the. bank

, of 50~ questions Lonly four required the individual.to classify an event -

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j and'none'were relatedi to protective action' recommendations. The

inspector concluded that if'more questions related to event classification anil> protective action recommendations were added to the

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examination, the EP training program'andlits effectiveness could be improved.~ This could provide an. additional benefit, because the chances

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of identifying procedural inconsiste'ncies (like the one previously mentioned), are greater'if the procedure is being used more extensively

! to complete the examination. . All bf the SSs interviewed stated that they challenged the course material and only took the examination.' ..

The effectiveness of the EP training provided to HP Leaders,'a position in the emergency organization, was tested by interviewing two HP Foremen L

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! (one from Unit I and one from Units 2/3). Both of the HP Foremen were~

i asked to complete a dose calculation using the manual, hand calculation method. One Foreman was asked to obtain current meteorological data and .

the other was provided with this information. Both HP Foremen were able  !

to complete the calculation and effectively discuss protective action recommendations. As a result of a' typographical error, one of the individuals suffered a delay in completing the dose' calculation. Two different acronyms were used for the same correction' factor in two sections of the data sheet. One section referred to a Noble Gas

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Correction (CNG) and another section referred to this factor as an ICF.

I The HP Foreman being interviewed did not know what ICF stood for, j however. he thought it might mean Iodine Correction Factor. This cau' sed i him confusion and delay because he was working with a noble gas figure-f and no correction is used in the procedure for iodine. This individual's-

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supervisor stated later that ICF stood for Independent Correction Facto The inspector discussed this' matter with Station Emergency Preparedness i personnel and was informed that ICF stood for Immersion Correction-Factor, but that it meant Iodine Correction Factor in the past. 'The '

j inspector examined the training lesson plan material and found that

_ training refers to this factor as a TDF or Time Decay Factor. It should l be noted that the data sheet, which contained the typographical error and

'

led to all this confusion, was copied from an uncontrolled copy of l S023-VIII-40.100, Revision 2, TCN 2-2, " Source Term and Dose Assessment".

l The fact.that uncontrolled copies of data sheets were located in the HP

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Leader's book in the OSC-was also brought to the attention of Station

Emergency Preparedness personnel. Due to the sensitive nature and time-

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limits associated with the completion of dose calculations, the correction of these matters (lesson plans and copies of uncontrolled data >

. sheets) is being classified as an "open" item so that the Region can

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track the resolution (86-01-02). '

i i No significant deficiencies or violations of NRC requirements were

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identified during this part of the inspection.- i s

1 Inspector Identified Areas of Concern

, During the course of this inspection, the inspector; learned that work to  ;

complete the installation of visual alarms in certain high noise areas in l Units 2 and 3 may have been subject to some considernble delays. en IE

Bulletin (IEB) (79-18 " Audibility Problems Encountered on Evacuation of

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Personnel from High Noise Areas") was issued on this subject on May 9, 1979. . Based on the inspector's documentation review, it appears that all work was completed for. Unit 1. No response to the>IEB was required for Units 2 or.3 because they had a construction permit, rather than an  !

operating license, at the time the IEB was issued. Based on the H inspector's review of the documentation related to this matter and  !

discussions with licensee personnel, it does not appear that these work j activities for Units 2 and 3 have been adequately tracked in the pas Interviews with Station Emergency Preparedness and QA personnel, conducted during the first half of this inspection, revealed that neither of these departments was exactly sure of.the current status of this work at Units 2 and 3. Since it appeared that the work (installation of 19 strobe lights in the containment building) had been completed for Unit 2, the inspector questioned whether workers had ever been informed of the meaning of these lights when activated and what to do in response to their activation. None of the individuals interviewed knew if th installed strobe lights were capable of activation. The inspector encouraged Emergency Preparedness personnel to issue instructions, regarding worker response to the strobes, if they were determined to be operabl t When the inspector returned to do the second half of the inspection, she was informed that Emergency Planning Bulletin No. 4-86 was issued on January 31, 1986, to inform personnel of the strobes and what to do in response to them. It should be noted that two HP personnel interviewed the second week said that they had not been aware that the strobes existed until the bulletin was issued. During a March 18, 1986, telephone conversation with the Manager of Station Emergency Preparedness, the inspector was informed that the strobes lights in the Unit 2 containment have been operational for approximately 8 or 9 month This individual also stated that there are no signs on the Unit 2 strobe lights that describe their purpose and/or worker response to their activation. He stated that the strobe lights in the Unit 1 containment building have this type of sign. With respect to Unit 3, it appears that three of the planned 19 strobes have been installed in the Unit 3 containment buildin Pending final resolution of this matter, which includes the installation of all of the strobes planned for Unit 3, this issue will be tracked by the Region as an " unresolved" item (86-01-03).

During the investigation into the matter of the visual alarms, the inspector learned that part of the Design Change Package (DCP No. 1250.0E, Revision IA), which included Proposed Facility Change (PFC)

Nos.83-904 (Unit 2) and 85-009 (Unit 3), involved a modification to the plant evacuation (Thunderbolt) sire In the past, activation of this

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siren was automatic on a Safety Injection Actuation Signal (SIAS). Since an evacuation on an SIAS may not be warranted, workers have been instructed to wait for instructions over the Public Address (PA) system before they evacuate. If 10 minutes go by without a PA announcement, workers have been instructed to evacuate anyway. The aforementioned PFCs involved cutting the circuitry so that activation of the Thunderbolt sireT becomes exclusively manual. Further investigation revealed that

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the status of this work was also in question. It appears that the work may have been completed for Units i and 3, but maybe not for Unit 1.

. However,'at one point during this inspection, Station Emergency

Preparedness personnel. stated that activation of the siren.had been made i exclusively manual. The inspector. reviewed current training material- '

l handouts and S0123-VIII-0.202 and S0123-VIII-30. This review disclosed I that all of these documents still state that the siren.can still be j activated automatically. During the SS interviews, the inspector i questioned their knowledge of this subject. Of the two Unit 1 SSs L interviewed, one thought.that activation was automatic and one thought.it l' was manual. Of'the two Units 2/3 SSs,'both thought that activation,was manual, however, one was confused because he knew that S0123-VIII-30

still referred to automatic activation on an SIAS. Pending final

! resolution of this matter, which includes a determination of current

e status, informing all affected personnel of the status and correcting all i affected procedures-and training lesson plans, this matter will be

! tracked by the Region as an "open" item (86-01-04). ,

!

i 1 Unresolved Items

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An unresolved item is a matter about which more information is required ,

e in order to ascertain whether it is an acceptable item, an open item, a V deviation, or a violation. Paragraph 11 of_this report' describes an

unresolved item concerning the use of strobe lights in high noise areas.

!

1 Exit Interview g

n The inspector held an exit interview with the licensee on' February 7,-

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! 1986, to discuss the preliminary findings of the inspection. The

} attachment to this report identifies the licensee and licensee contractor

personnel who were present at the meeting. The licensee-was informed i that no significant deficiencies or violations'of NRC requirements were  ;

f identified during the inspection. The licensee was informed that the l l four previously identified "open" items would he closed. Findings

described in Sections 3-10 were briefly summarized. The licensee was l

! specifically informed of the three suggestions for improvement described '

l in Sections 7 and 10. The four open items described in Sections 3, 10 an

] 11 were,also mentioned. The' inspector expressed c'oncern over the

apparent lack of attention to detail,which seemed to be common to most of.

J the findings, including the number,of procedural inconsistencies, that j' were. identified. s The inspector also stated that.the two "open" items described'in Section 11 appeared to be very similar in nature to a 4 situation that resulted in a Notice of Violation being issued on i January 25, 1985'(NRC Inspection. Report Nos. 50-206/84-34, 50-361/84-33 and 50-369/84-34)~. The inspector stated that the-situations were similar i 1 because Station. Emergency Preparedness was not being kept informed of i j onsite construction / work activities which have an impact on emergenc j j - preparedness, so that they can inform affected personnel through training '

and procedural modifications. The< inspector questioned the prudence of'

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continuing with the potential 10 minute delay associated with their evacuation procedure, given that-the Thunderbolt is now'(or will be)

{ exclusively manual. Some licensee personnel stated,during the meeting j

that this was, in.their opinion, a conservative' approach to cover i '

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instances involving spurious activation of the Thunderbolt siren or

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inoperability of the PA syste Due to the uncertainty of the actual status of-the visual alarms and

- - siren modifications, the licensee was requested to inform Region V of the chronological status of these items and the projected completion'dat The licensee agreed _to provide this information to the Region by March 14,.1986. Subsequent-to the inspection, the licensee _was informed that the item related to the" visual alarms was being reclassified as an

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• - ATT'ACHMENT, j

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>. , V .s ,.~ ~-EXIT * INTERVIEW ATTENDEES y , , - .-

C. A:'derson, Emergency: Pr,eparedness Engineer '(ASTA)

- D. dennette, Supervisor, Station' Emergency Preparedness

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P. Dooley,' Supervisor, Emergency Planning (NA&EP)

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J'.'Erhard,' Emergency Pr'eparedness Engineer ~

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J. Firov,ed, Emergency Preparedness, Engineer C.'Kergis, Compliance: Engineer

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H., Morgan, Station ~ Manager .,

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J. Mundis, Supervisor,: Nuclear Services

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Sj ,0lofsson', Emergency Preparedness . Specialist (BSG)

D. Peacor, Manager, Station Emergency Preparedness R. Reed, Emergency Preparedness Specialist (BSG)

D. Schone, Manager, Site QA J. Wambold, Manager, Training.

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M. Wharton, De.puty Station Manager W. Zinti, Manager,' Compliance I

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