ML20154H817

Insp Rept 50-312/88-25 on 880719-21.No Violations Noted. Major Areas Inspected:Exam of Emergency Facilities, Equipment & Emergency Preparedness Training

ML20154H817
Person / Time
Site:	Rancho Seco
Issue date:	09/01/1988
From:	Fish R, Prendergast K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20154H807	List: ML20154H804 ML20154H809 ML20154H817
References
50-312-88-25, NUDOCS 8809220136
Download: ML20154H817 (5)

See also: IR 05000312/1988025

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U. S. NUCLEAR REGULATORY COMMISSION

REGION V

Report No. 50-312/88-25

Licensee: Sacramento Municipal Utility District

14440 Twin Cities Road

Herald, California 9568-9799 ,

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Facility Name: Rancho Seco Nuclear Generating Station

Inspection at: Clay Station, California

Inspection Conducted: July 19-21, 1988

Inspector: [,,1 n k1,4 9/4/e p

K. N. Prenderpast 0 Dat6 S'igned ,

Emergency Preparedness Analyst j

Approved by: [ ', ( . A . b, , < - " $ 4/

(,y/ R. F. Fish, Chief Date Signed

Emergency Preparedness Section

Sumary:

Areas Inspected: Routine unannounced inspection of the licensee's emergency

preparedness program. The inspection included an examination of emergency

facilities, equipment, and emergency preparedness training. Inspection

Procedure 827^1 was covered.

Results:

One violation was identified for the failute to maintain the calibration of

dedicated emergency equipment, in addition, declining performance was

observed in the licensee's drill and exercise program and the emergency

response surveillance program. These areas are discussed ir. Sections 2 and 6

of this report.

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DETAILS  !

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1. Persons Contacted: i

• B. Croley, Assistant General Manager, Technical and Administrative  !

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i *P. Lavely, Manager, Environmental Protection

• F. Thompson, Supervisor, Emergency Preparedness Training i

D. Feighert, Supervisor, Emergency Preparedness Programs  !

i J. Price Emergency Preparedness Specialist t

B. Gwaltney, Radiation Protection Technician  !

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j * Indicates personnel attending the Exit Interview

2. Emergency Facilities. Equipment Instrumentation, and Supplies (82701)

This area was inspected to verify that key facilities and equipment were '

maintained and to determine whether changes made to facilities or

i equipment were adequate to meet the NRC requirements and that the changes

j did not adversely effect the licensee's capabilities to respond to an

j emergency.

! The inspector toured the Emergency Operations Facility (EOF 1 a.M l

• Technical Support Center (TSC), examined the Emergency Plan and  !

implementing procedures, examined records of inventories of emergency .

equipment, and examined the emergency equipment located in Warehouse A ,

and the Auxiliary Building. The following observations were noted. ,

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j A. The EOF and TSC appeared well maintained and in a state of '

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operational readiness. Communications systems and facsimile

machines were tested and found to be operational. Copies of the

Technical Specifications and plant procedures were also observed to

j be available. The TSC and EOF facility layouts appeared as  !

j described in the current version of the Emergency Plan, Revision 1.  !

, There were no changes to the facilities observed that would appear j

to decrease their effectiveness. j

l; B. The records of the quarterly Emergency Response Telephone Directory

number verifications required by EPIP 5660, were examinej and  !

considered adequate. i

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C. The records of inventories of onsite and offsite emergency equipment  !

j documented quarterly inventories had been made. However, both the i

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record review and a physical inspection identified that some i

! portable dose rate monitoring equipment were due for calibration.

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A May 1, 1988 inventor of offsite assembly kits identified two l

2 portable ion chambers Eberline R02s) that were due for calibration  !

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on February 23, 1988. A physical inventory during this inspection l

} of the energency lockers in Warehouse A an' % Auxiliary Building

i also identified two portable ion cha;nbers wat had exceeded their i

j cralibration due date. The R02 instruments, toentified as serial  !

4 numbers 1632 :nd 1410, were last calibrated on November 23, 1987 and  !

j were due for calibration on February 23, 1988. Procedure AP-311, ,

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"Portable Radiological Instrumentation," requires quarterly

calibration of dose rate instrumentation. Based upon the

calibration dates it appears that instrument nos 1410 and 1632 were .

l the same instruments identified by the licensee on May 1, 1988.  !

Corrective action to recalibrate the two instruments had not yet l'

been taken. The Manager, Environmental Protection attributed the

reason the instruments were out of calibration to a misunderstanding

between Radiation Protection and Emergency Preparedness regarding i

j who was responsible for these calibrations. In addition, numerous

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other problems were observed which included the follom ng:

a) EPIP-5660 requires records of inventories to be forwarded )

to the Manager of Emergency Preparedness. This action was

not done,

b) Some inventories were performed using an outdated  !

inventory fortn.

c) There were numerous discrepancies between the contents of +

emergency lockers / kits and the inventory fonns in EPIP i

5660.

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l The failure to ensure instruments are calibrate.d in accordance with i

plant procedures was identified as a violation and will be followed  !

as 88-25-01. .

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l D. The Emergency Plan, Section 6, references numerous support l

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agreements with offsite individuals, groups, and agencies that would '

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provide support during an emergency. Section 8.6.2 establishes the

responsibility for an annual review by the Manager of Environmentai

Protection and to record the status of agreements or ':ontracts.

Prior to an agreements expiration date the Manager of Environmental ,

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Protection is to initiate an update and renewal of the agreement.

The licensee's files for agreements with offsite support agercies

! were examined and two contracts with the Regents of the University

of California UC Medical Center were noted to heve expired on April

15, 1988. The contracts were identified as B-16 and B-17 It

appears the licensee had perfortned the required review, homver, the

actions to renew the contracts were not timely. A siellar finding

was also identified in a March 1988 audit perfonned to satisfy the i

requirements of the 10 CFR 50.54(t). I.i this audit, two other  ;

contracts with offsite agencies were stated to have expired. The l

licensee initiated corrective action to renew the expired co.. tracts '

identified in this audit. However, their corrective action did not

preclude the expiration of the two contracts discussed above. The

licensee's actions regarding this matter will be followed as open

item 88-25-02.

Licensee performance in this program area appears to be declining

due to a lack of management involvement to insure emergency

capabilities are maintained.

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3. Changes to the Emergency Plan (82701)

Since the last inspection, Revision 1 to the Rancho Seco Emergency Plan

has been received. The revised plan was avaluated and a finding made  ;

that the revised plan continues to meet the standards contained in 10 CFR -

50.47 and Appendix E.

No changes were observed that appeared to decrease the effectiveness of

the Emergency Preparedness Program.

10 CFR 50, Appendix E contains requirements that changes to the Emergency

Plan and implementing procedures be sent to the NRC within 30 days of

such changes. During this inspection it was observed that numerous

temporary changes had been made to the licensee's classification

procedure and to the Emergency Plan. The temporary changes observed

primarily dealt with classification of emergency events. Procedural

interim change notice's (PICNs) 01, 02, 03, 04, to EPIP 5001,

"Classification of Emergency Events" were examined and appeared to be

primarily clarifications. These changes did not appear to represent a

subst'intiative change to the implementing precedures that would require a

record of the change be sent to the NRC. However, it was suggested to

the licensee that they examine their procedures to insure compliance with

I this requirement.

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No trends with regards to strengths or weaknesses were identified in the t

review of this program area. l

4. Organization and Management Control (82701)

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! There have been anc' continue to be changes in the Plant organization and  ;

} to the emergency response organization (ER0). However, these changes do  :

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not appear to impact the ERO. The responsibilities contained in the '

i Emergency Plan and implementing procedures continue to be filled with  !

qualified personnel that have received the training required by the e

! Eniergency Plan and implementing procedures.  !

No significant strengths or weaknesses were identified in this program i

area. l

C. Training (82701)

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Records of annual Emergency Plan training were examined for numerous key .

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i individuals in the ERO including: the Emergency Coordinator, the

Emergency Manager, the Emergency tews Center Manager, and selected

radiation protection positions. The training data base utilized by the

emergency preparedness group was examined to determine what training had

been received. Basea upon comparing the training requirements contained

in the Energency Plan and the implementing procedures with the records

observed, it appears required training was accomplished.

During the records review, the specific training required for the

Operations Technical Advisor (OTA), a position comparable to a Shift

Te:hnical Advisor (STA), was not observed in the ERO training

requirements. The STA typically supports the Shif t Supervisor by

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evaluating plant conditions and providing technied assistance during an

emergency, which are the same responsibilities delegated to the OTA. The

training requirements for the OTA position need to be examined and

appropriate training included in the Emergency Plan implementing

procedures.

No significant strengths or weaknesses were identified in this program

area.

6. Drills and Exercises

Records of drills and exercises required by the Emergency Plan and

implementing procedures were examined. The licensee s "Emergency

Preparedness Orill and Exercise Nnual" was also examined. The

examination showed that the licensee has established an acceptable

program for identifying areas, during drills and exercises that require

improvement in the response to an emergency. However, the timeframe for

closing items identified during drill and exercises appears unacceptably

long. A review of the open items for 1987 drills and exercises indicated

a significantly large number of open items still open from 1987 drills.

Excessive time for corrective action resulted in some items being

reidentified in the 1988 drill. At the exit interview, methods were

discussed which could improve the timeliness of corrective action, these

included:

Develop or utilize one of the existing management tracking

systems to insure management involvement is at a level to

insure priority items, dealing with errergency response or

safety, are corrected in timely manner.

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Oevelop a means to close the large number of cpen items that

require a revision to the implementing procedures or Emergency

Plan. Approximately 40 items were still open from 1987.

l.icensee perfonnance in this program area appears to be declining since

the previous evaluation.

7. Exit Interview

The scope and findings of the inspection were discussed with licensee

representatives at an exit interview conducted at the conclusion of the

inspection. 1.icensee personnel present at this meeting are denoted in

Paragraph 1 of this report. Mr. T. D' Angelo. Senior Resident Inspector

was also present as a Mpresentative of the NRC at this meeting. During

this meeting the license was informed of one apparent violation

identified in Sections 2 of this report. Other items specifically

discussed during this meeting are contained in Sections 2 through 6.

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