ML20215N210

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Notice of Violation from Insp on 860402-25.Violations Noted: Listed Procedures Re Emergency Plan Not Maintained & Current Emergency Facilities Not Described in Emergency Plan
ML20215N210
Person / Time
Site: Rancho Seco
Issue date: 10/28/1986
From: Scarano R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20215N200 List:
References
50-312-86-14, NUDOCS 8611040442
Download: ML20215N210 (4)


Text

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ENCLOSURE NOTICE OF VIOLATION l

Sacramento Municipal Utility District Docket No. 50-312 l

P. O. Box 15830 License No. DPR-54 Sacramento, California 95813 As a result of inspection conducted during the period April 2 through April 25, 1986, and in accordance with NRC Enforcement Policy, 10 CFR Part 2, Appendix C, the following violations were identified:

A.

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

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 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, 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 were modifications to two of the dose assessment computer codes during the year (1985).

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

B.

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

1.

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.

f Contrary to the above, at the time of the inspection, these procedures were not maintained in that:

a.

Procedures AP 501, 509 and 511 did not provide for using data from the expanded range effluent monitors R150044 and R150045.

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).

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2.

AP 511, " Technical Support Center Dose Calculations," described the licensee's methods for determining offsite dose assessment. AP 511 states, "These calculations may be performed using Apple II Code

'RAC0DE'."

Contrary to the above, at the time of the inspection, the procedure

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was not maintained in that the procedure provided no instructions for computer based dose calculations.

In addition, there was insufficient documentation, i.e.,

users guides on the dose assessment codes to assist those persons who perform the calculations.

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

3.

Procedure AP 509, " Control. Room Dose Calculations," described a hand calculation method for " predicting offsite dose rates and integrated doses" for releases from the Auxiliary Building vent.

In addition, the Unified Dose Assessment Center, located in the Emergency Operations Facility, used the computer code titled JADE to make the offsite dose calculations.

Contrary to the above, at the time of the inspection, Procedure AP 509 was not maintained in that a method was not'provided to calculate dose rates and integrated doses for unmonitored release paths, e.g., primary to secondary leakage (steam generator) with subsequent release to the atmosphere or leakage from the containment building. Also, at the time of the inspection, the Unified Dose Assessment Center dose calculation capability was not maintained in that the JADE code was not capable of calculating release rates and dose projections for a primary to secondary leak with subsequent release to the atmosphere. The SPECTER code, which can be used in the Technical Support Center, did provide for making this type of dose projection.

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

4.

Procedure AP 528, " Protective Action Guidance," required that protective actions to be recommended to appropriate local and State

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authorities shall be based on plant conditions or trends as well as projected doses.

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).

5.

Several procedures, i.e., AP 516, AP 552 and AP 305-9D, made reference to emergency kits, that include decontamination equipment and supplies, being located at the Harold Fire Department and the Ione Fire Academy.

Contrary to the above, at the time of the inspection, these procedures were not maintained in that the emergency kits had been removed in July 1985 and appropriate changes to the procedures had not been made.

In addition, replacement guidance regarding what equipment and supplies, formerly in these two emerger.:y kits, required to be taken from the reactor site when the offsite' assembly area (s) are activated had not been provided.

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

C.

10 CFR 50.54(q) requires a licensee to follow and maintain in effect emergency plans which meet the standards in 50.47(b) and the requirements in Appendix E of Part 50.

1.

Section IV.E of Appendix E requires that the emergency facilities and equipment be described in the emergency plan.

Contrary to the above, at the time of the inspection, the emergency.

plan did not describe the current emergency facilities in use as follows:

a.

Section 7.1.5 of the emergency plan described the first aid room as being adjacent to the Auxiliary Building and next to the Safety Office.

In addition, Figure 7.8 showed this location as being in the building housing the tool room. The first aid room, which was moved in the Fall of 1984, was located next to the cafeteria in the T&R Building.

b.

Figures 7.2 and 7.3 showed the Technical Support Center (TSC) in a room located adjacent.to the control room. The present TSC was located in a reconstructed room down the hallway from the former location. This change was made prior to September 10, 1985.

Section 7.2.2 had not been changed to show that emergency c.

lockers, removed in July 1985, were no longer located at the California State Forestry Fire Fighting Academy (Ione) and the Herald Fire Department.

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

2.

Section IV.B of Appendix E requires that emergency action levels used to classify emergency events be reviewed with the State and local governmental authorities on an annual basis.

j Contrary to the above, in 1985 the-State of California and the counties of Amador, Sacramento and San Joaquin were not provided with an opportunity to review the emergency action levels.

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

3.

Section IV.F of Appendix E requires initial training and retraining of emergency personnel. Section 6.2.7 of the emergency plan required that health physics-personnel and the emergency team will i

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be provided Advanced First Aid, Standard Multi-Media and Cardio-Pulminary Resuscitation. This section also required :

retraining in Advanced First Aid and Multi-Media every three years.

Contrary to the above,'at the time'of the inspection,' retraining in the Stdadard Multi-Media had been di'scontinued more than three years ago and retraining in Advanced First Aid was' discontinued more than five years ago.

This is a Severity Level V Violation (Supplemerit:VIII).'

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Pursuant to the provisions of 10 CFR 2.201, Sacrame'nto Municlipal, Utility District is hereby required to submit to this office within thirty days of the date of this Notice, a written statement or ' explanation including:

(1)'the corrective steps which have been taken and the results-achieved;.(2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown.

OCT 2 81986 Mw Dated oss A. Scarano, Director Division of Radiation Safety and Safeguards