ML20211G064

Responds to NRC Re Violations Noted in Insp Rept 50-312/86-14.Corrective Actions:Emergency Preparedness Dept Initiated New Tracking Sys Based on Ibm at Computer & Procedures AP.509 & AP.511 Revised

ML20211G064
Person / Time
Site:	Rancho Seco
Issue date:	02/05/1987
From:	Julie Ward SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
JEW-87-082, JEW-87-82, NUDOCS 8702250267
Download: ML20211G064 (9)

Text

• *

• .oo t

%SMU= I i'M SACRAMENTO MUNICIPAL UTILITY DISTRICT O P. O. Box 15830, Sacramento CA D5852,j 830 (916) 452-3211 AN ELECTRIC SYSTEM SERVING THB FIEhRT OF CALIFORNIA JEW 87-082 .,

February 5,1987  ;/p J. B. Martin, Regional Administrator Region V Office of Inspection and Enforcement Attn Document Control Desk U S Nuclear Regulatory Commission 1450 Maria Lane Suite 210 Walnut Creek Ca 94596 DOCKET NO. 50-312 Rancho Seco Nuclear Generating Station Unit #1 License No. OPR-54 NRC INSPECTION REPORT 86-14-01

Dear Mr. Martin:

By letter dated October 28, 1986, the Sacramento Municipal Utility District was transmitted a Notice of Violation concerning the Rancho Seco Nuclear Generating Station's Emergency Preparedness Program. In accordance with 10 CFR 2.201, the District provided a response to the Notice of Violation in a letter (JEW 86-923) dated December 1, 1986. By letter dated December 24, 1986, the District was transmitted a request for further detail on Violation Areas A and B. Attached is the District's response to the letter of request.

If there are any questions concerning this report, please contact Mr. Ron W. Colombo at the Rancho Seco Nuclear Generating Station.

Sincerely, f)

, 3Y ah E Ward Deputy General Manager Nuclear Attachment cc: I&E /

INP0 D V

rm sugie 0

f4 RANCHO SECO NUCLEAR GENERATING STATION 1444o Twin Cities Road, Herald, CA 95638-9799;(209) 333-2935

., .o/ ,.

ENCLOSURE District ResDonse to NRC Inspection Report No. (50-312/86-14)

Notice of Violation NRC Violation A: [

Rancho Seco Technical Specification 6.8.1.e requires, in part, that

written procedures covering the Emergency Plan shall be implemented.

4 Section 5.4.2 of Procedure AP.580, " Training," required training be conducted annually-and whenever necessitated by significant revisions to the Emergency Plan implementing procedures or equipment.

Contrary to the above, eight of'the control room staff, including four i shift supervisors, and twenty-four members of the licensee's emergency response organization, had not received their annual emergency preparedness retraining during the year 1985. The retraining interval for these individuals varied between 15.7 and 20 months. In addition, i personnel identified in AP.506.01 as the primary and alternate

. individuals assigned to the dose assessment responsibility had not received any training on dose assessment during 1985 even though there i were modifications to two of the dose assessment computer codes during j the year (1985).

This is a Severity Level IV Violation (Supplement VIII).

District Response to Violation A: (Dated 12/1/86)

1) Admission or denial of the alleged violation.

The District admits that the violation occurred as stated.

I 2) Reasons for violation.

! The violation was the result of an inadequate tracking system for

! Emergency Preparedness related training and retraining.

i

! 3) Corrective actions which have been taken and results achieved.

l I The Emergency Preparedness Department, in coordination with the

! Nuclear Training Departnent, has recently initiated a new tracking

system based on an IBM AT Computer. Emergency Preparedness has taken steps to increase the effectiveness of the interface with the

training department.

s

. . c- ,.

4) Corrsctiva acticns which will bs takcn.

Long term plans include Training Department retention of all training records.

5) Date when full compliance will be achieved:

The current cycle of training will be completed mid December, 1986.

Full compliance will be achieved at the completion of this cycle.

The next cycle of training is scheduled to commence in May, 1987.

-NRC Reauest for further detail:

1. The reply to Violation A states that the reason for the violation was an inadequate tracking system. The corrective action was to initiate a new tracking system. Please describe the differences between the former and new tracking systems that will assure the violation does not occur again. Since tracking systems are only as effective as their implementation, you should also describe your management actions to assure implementation of the Emergency Preparedness

, Training Program.

i District Response to NRC reauest for further detail regarding NRC Violation A i f rom NRC Inspection Report No. (50-312/86-14) .

1) Corrective steps which have been taken by the licensee and the results achieved:

The implementation and management overview of the Emergency

Preparedness (EP) Group and the Associated Emergency Plan Training

program have been a continuing source of concern to the District as

. well as to the NRC. Several actions, to remove impediments to managemenc effectiveness with regard to implementation of the Emergency Preparedness Program and Training Program have been taken to date. They are:

1) Replacement of the informal, hard copy, training tracking system with a computer based tracking system. A procedure is under development within the Emergency Preparedness Group for this tracking system.

l' This system is utilized to document and update the personnel, required training, training due dates and training accomplishment of the Emergency Response Organization (ERO). In addition the system will be utilized to " flag" overdue training to ensure that j management attention and action as described below can be l initiated.

l.

I - - - - . . , . . - - - . , . - - . _ - - - - _ - - . - - . - , , . -

.r

. .e ,

2) Elsvatien of tha Emerg:ncy Preparsdn:Iss Pr: gram to the Department level Within the Distrit.L's Nuclear Organizallon, and headed by a

~

Department Manager.

This elevation of the Emergency Preparedness Manager asd program has resulted.in an increased level of awareness at all levels of management of the importance of the program and its implementation.

To ensure continued compliance and District management attention with regard to training accomplishment, the Deputy General

. Manager, Nuclear, has issued a directive to all applicable l supervisors to include ERO training, drill exercise attendance, and performance in an individual's performance plan criteria.

l Once included in an individual's performance plan criteria, inadequate participation will result in a reduced evaluation under the District's pay for performance criteria, l In addition, failure of an individual to complete scheduled

. training will be reported to that individuals supervisor by memo from the Manager of the Emergency Preparedness Department.

Continued failures to comply with training will be reported by the manager of Emergency Preparedness to higher levels in the 1 organization until the problem is resolved. The Manager of 4

Emergency Preparedness is responsible and accountable for the Emergency Preparedness training program, additionally, each individual and supervisor within the ERO will be held accountable for their participation in the ERO through the methods described above.

i The District having just instituted the above changes, has not measured results of these actions at this time.

3) The date when full compliance will be achieved:

i

, Full compliance was achieved on January 23, 1987, the date of the Director General Manager (DGM) Directive tying ERO training, participation and performance with an individuals job performance plcn.

l l NRC Violation'8.1:

} Rancho Seco Technical Specification 6.8.1.e requires, in part, that i written procedures covering the emergency plan shall be maintained.

Procedures AP.509, 511, and 512. " Dose Calculations for the Control

Room," " Technical Support Center," and " Emergency Operations facility" respectively, provided a means for hand calculating offsite doses. In addition, Procedure AP.501, " Recognition and Classification of Emergencies," provided instruction on classifying emergencies based on

effluent monitor (R15001 and R15002) readings. Each of these procedures

relies on a knowledge and understanding of the effluent release rate.

1 I

I C:ntrary to th2 ab:va, at the time of th2 insp;ction, th2s2 pricsduras were not maintained in that:

a. Procedures SP.501, 509, and 511 did not provide for using data from the expanded range effluent monitors R15044 and R15045.

b. Procedures AP.509 and 511 did not provide a means to utilize data from the Reactor Building effluent monitor R15001 to calculate release rate / dose projection.

This is a Severity Level IV Violation (Supplement VIII).

District Response to Violation B.I.a: (Dated 12/1/86)

1) Admission or denial of the alleged violation.

The District admits that this violation occurred as stated.

2) Reasons for the violation.

The procedure inadequacies in AP.501, AP.509, and AP.511 were due to a lack of continuity in staff responsible for the maintenance and revision of these procedures. A contributing factor was the lack of administrative controls to assure that emergency preparedness staff were aware of plant configuration changes.

3) Corrective actions which have been taken and the results achieved.

AP.509 and AP.511 were initially revised to properly include R15004, R15044, and R15045 monitor points on August 13, 1986. Subsequent improvements were included in the following procedure changes, dated September 18, 1986.

AP.509, Revision 4 AP.501, Revision 6 AP.511, Revision 5 An Emergency Preparedness (EP) representative is now required to attend the daily operations meetings which will assure that the Emergency Preparedness organization is aware of plant configuration changes.

4) Corrective actions which will be taken.

Planned corrective actions have been completed as described in item 3 above.

5) Date when full compliance will be achieved.

Full compliance was achieved on September 18, 1986.

i .

. u: ,

NRC Violation 8.4 Rancho Seco Technical Specification 6.8.1.e requires, in part, that written procedures covering the Emergency Plan shall be maintained.

Procedure AP.528 " Protective Action Guidance," required that protective actions to be recommended to appropriate local and state authorities shall be based on plant conditions or trends as well as projected doses.

J Contrary to the above, at the time of the inspection, Procedure AP.528 was not maintained in that guidance for relating plant conditions and trends to the various protective action recommendations had not been provided.

This is a Severity Level IV Violation (supplement VIII).

a District Response to Violation 8.4 (Dated 12/1/86)

1) Admission or dental of alleged violation.

The District admits that this violation occurred at stated. ,

2) Reasons for violation.

The lack of continuity of staff within the emergency preparedness

organization responsible for procedure revisions and the inadequate turnover of work in progress to new emergency preparedness staff i members directly contributed to this violation.

1

3) Corrective steps which have been taken and results achieved:

AP.528, Revision 2 was implemented on September 18, 1986 to provide

! guidance for relating plant conditions and trends to protective action recommendations as addressed in IE Information Notice 83-28,

4) Corrective actions which will be taken:

A turnover briefing of work in progress will be performed when a new staff member is assigned procedure maintenance responsibilities.

5) Date when full compliance will be achieved:

Training of operations staff on AP.528 is scheduled to be completed

, on December 15, 1986. This will achieve full compliance with this item.

i f

i f

.m .'

J NRC reauest for further detail:

2. The replies to the Violation 8 items state that lack of staff continuity was one of the reasons for the violations. Your corrective actions for these items do not appear to address this cause. Please describe what you intend to do in order to assure staff continuity between organizations and during reassignments of responsibilities within the emergency preparedness organization.

District Response to NRC reauest for further detail regarding NRC Violation B f rom NRC Inspection Report No. (50-312/86/14) .

The loss or turnover of staff members was a factor in the above violations issued by the NRC. The problem of maintaining continuity within the staff of emergency preparedness can be approached in two ways:

Approach (1) Effectively manage the Emergency Preparedness staff to assure that positions are filled by trained and qualified individuals 4

Approach (2) Ensure that the Emergency Preparedness Program is being directed, defined and proceduralized to ensure the flexibility to mitigate the impact of staff turnover.

Corrective steps which have been taken by the licensee and the results achieved.

The District has taken steps to implement both of the above approaches with methods described in sections 1) and 2) below.

1) for approach (1), transfer requests from positions within emergency preparedness to other District positions are being reviewed by management to ensure that the transfer is in the best interest of the employee, the District and the Public and in accordance with established District procedures. In addition, steps have been taken to improve relationships / communications between Emergency Preparedness management and staff to promote a positive work environment with the objective of minimizing staff turnover, i

2 e

i i

i i

Fcr appr ach (2), citigating psrsennel turn:vsr, sevsral sp:cific programs have been developed within Emergency Preparedness to ensure that commitments, implementation programs and personnel resources are being defined, tracked and managed. They are:

A) Performance plans have been written for personnel currently filling SMUD positions within Emergency Preparedness. For those positions that are currently being filled by contractor personnel, performance plans / job descriptions are currently being draf ted, and will be completed before March 1,1987.

B) A computerized management tool, titled Emergency Preparedness Implementation Code (EPIC) is being utilized. This internal commitment tracking system for Emergency Preparedness ensures that a multitude of open action items, commitments and programs are being tracked. Personnel assignments and due dates are included in EPIC. EPIC clarifies personnel priorities and responsibilities to effect a smooth transition of program duties.

C) Under development is the Project Management Program (PMP). This management tool will develop a method to ensure effective utilization of time and personnel resources to ensure completion of concurrent implementation programs. The program will be usable with a 1987 data base input by May 1, 1987.

D) In a memo to the NRC dated January 23, 1987, J Ward, Deputy General Manager, Nuclear, requested that additional visits be scheduled in the february to May time frame to review the District's actions, in response to previously identified NRC concerns, for timeliness and completeness.

Each of the above actions will assist in mitigating the effects of and lack of continuity during personnel turnover by clearly defining jobs and duties (item a), assigning commitments and work progress to specific individuals (item b), and coordinating resources and personnel (itam c).

l

__a

7 1

. y .. , ,

2) Corrective stens which will be taken:

for approach (1), effective management of Emergency Preparedness, the Emergency Preparedness Department will perform a review of current salary levels within the Emergency Preparedness staf f, and make recommendations to District Management based on a comparison of salary levels within the District and within the industry by May 1, 1987.

Future corrective action for approach (2), directing, defining and proceduralizing the Emergency Preparedness program to mitigate the impact of personnel turnover, is more programatic in nature and effects more than just personnel turnover.

NUREG 0654 in section I.J states, "all plans should contain a table of contents and an index, and the contents should be cross-referenced to the criteria contained in this document. Supporting and reference documents and tables may be incorporated by reference, and appendixes should be used whenever necessary. This is followed by "In addition to addressing the substance of all criteria, the plans must, of course, define the facility or facilities and area to which the plans apply."

The violations cited in NRC Inspection Report 86-14 have emphasized the need to apply a similar programatic cross-reference as that suggested by NUREG-0654 to each regulatory document and commitment contained in section 10 of the Emergency Plan.

A program has been initiated by the Emergency Preparedness Staff, which is intended to comprehensively list all regulatory commitments and requirements of the Emergency Preparedness Program and cross-reference each with an Emergency Preparedness procedure or Program and an Emergency Preparedness staff position responsible for compliance. When completed, it is intended to maintain this document as an up-to-date (living) management asset. When completed, the cross-reference list will be utilized to update the Emergency Preparedness Staff Performance Plans as described above. The initial cross reference list will be completed by July 1, 1987.

3) The date when full compliance will be achieved, full compliance with regard to staff continuity is difficult to gage, however, the completion of the cross reference program, outlined above,-will ensure that newly reported Emergency Preparedness personnel will have clearly defined responsibilities for the position assigned due to the clearly defined and proceduralized program as a whole.