ML20212E704

Ack Receipt of Providing Further Detail to Util 861201 Response to 861028 Notice of Violation

ML20212E704
Person / Time
Site:	Rancho Seco
Issue date:	02/24/1987
From:	Scarano R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Julie Ward SACRAMENTO MUNICIPAL UTILITY DISTRICT
References
NUDOCS 8703040425
Download: ML20212E704 (1)

Text

JD FEB 241987 Docket No. 50-312 Rancho Seco Nuclear Generating Station 14440 Twin Cities Road Herald, California 95638-9799 Attention: Mr. John Ward Deputy General Manager, Nuclear

, Gentlemen:

Thank you for your February 5,1987 letter providing further detail to your December 1, 1986 reply to our Notice of Violation transmitted October 28, 1986. Your corrective actions will be verified during a future inspection. _

Your cooperation with us is appreciated.

Sincerely, h

Ross A. Scarano, Director Division of Radiation Safety and Safeguards cc w/cy ltrs dtd 12/1/86 & 2/5/87:

State of CA bcc w/cy ltrs dtd 12/1/86 & 2/5/87:

RSB/ Document Control Desk (RIDS)

Project Inspector Resident Inspector B. Faulkenberry J. Martin bcc w/o cy ltrs dtd 12/1/86 & 2/5/87:

J. Zollicoffer M. Smith Regionf'V

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{REQUES{ Y] _ ST COPY ] REQUEST/COPX ]

[ YES'7 NOCOPY] ] YESREQUEST

/N YE / NO ] YES / / NO / -

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KPren\ergast/ norma RFish FWenslawski 'M 5(arano 2/10 /87 2/J3/87 2pp/87 2/f//87 hA k hh

. , . , DESIGNATED ORIGINAL 4

Certified BY /dshiM/-

gSMU= SACRAMENTO MUNICIPAL UTILITY DISTRICT O P. O. Box 15830. Sacramento CA 95852-1830,(916) 452-3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA JEW 86-923 December 1, 1986 l

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J B MARTIN REGIONAL ADMINISTRATOR REGION V OFFICE OF INSPECTION AND ENFORCEMENT U S NUCLEAR REGULATORY COMMISSION 1450 MARIA LANE SUITE 210 WALNUT CREEK CA 94596 DOCKET NO. 50-312 LICENSE NO. DPR-54 NRC INSPECTION REPORT 86-14 Gentlemen:

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 puovides the enclosed response to the Notice of Violation.

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WARD DEPUTY GENERAL MANAGER NUCLEAR Attachment -

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,9 ta p)* m RANCHO SECO NUCLEAR GENERATING STATION C 14440 Twin Cities Road, Herald, CA 95638-9799;(209) 333 2935

ENCLOSURE District Response 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. 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'is 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 doce assessment responsibility had I

not received any training on dose assessment during 1985 even i

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

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This is a Severity Level r1 Violation (Supplement VIII).

District Response to Violation A

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1) Admission or denial of the alleged violation.

The District admits that the violation occurred as stated.

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2) Reasons for violation.

i The violation was the result of an inadequate tracking i system for emergency preparedness related training and r retraining.

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

The Emergency Preparedness Department, in coordination-with the Nuclear Training Department, 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 depr.rtment.

4) Corrective actions which will be taken.

Long term plans include Training Department retention of -

all training records.

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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.

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~NRC Violation B.1 Rancho Seco Technical Specification 6.8.1.e requires, in part ,

that 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.

Contrary to the above, at the time of t'he 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 affluent 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.l.a

1) Admission or denial of the alleged violation.

The District admits that this violation occurred as ,

stated.  !

2) Reasons for the violation.

l 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 i

include R150044 and R150045 monitor points on August 13, i 3

I 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 Lis now i required to attend the daily operations meetings which will assure that the EP organization is aware of plant configuration changes.

4) Corrective actions which will be taken.

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

5) Date when full compliance will be achieved.

Full compliance was achieved on September 18, 1986.

District Response to Violation B.1.b-1 j 1) Admission or denial of the alleged violation.

The District admits that this violation occurred as stated.

2) Reasons for the violation.

j Same as violation B.l.a.

3) Corrective actions which have been taken and the results ,

achieved.

Procedures AP-509, AP-511 and AP-512 are being revised to provide appropriate means to calculate release rate / dose '

projections.

4) Corrective actions which will be taken.

!  ! Revision' alto. APa509J'lAP 5isind 'APA 512l w'ill";be implemented 7 J Eprior.toTrestartst Dose assessment codes currently used by the District will be revised, updated and reflected in AP-509, AP-511 and AP-512 prior to restart.

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5) Date when full compliance will be achieved.

Prior to restart, May 1, 1987.

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, NRC Violation B.2 Rancho Seco Technical Specification 6.8.1.<a requires, in part, that written procedures covering the emergency plan shall be maintained.

AP-Sll, " 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 'RACODE'."

Contrary to the above, at the time of the inspection, the procedure was not maintained in that the procedure provided no t- instructions for computer based dose calculations. In i

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 Security Level IV Violation (Supplement VII).

District Response to Violation B.2

, 1) Admission or denial of the alleged violation.

The District admits that the violation occurred as stated.

2) Reasons for the violation.

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Same as violation B.1.a.

j 3) Corrective actions which have been takan and results achieved.

Same as violation B.l.b. An interim procedure for .

utilizing the Apple II Code "RACODE" has been posted at '

the computer until all procedure revisions have been completed.

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4) Corrective actions which will be taken.

t same as violation B.l.b. In addition, user guide information will be provided to assist those persons who perform dose assessment calculations.

l 5) Date when full compliance will be achieved.

1 Prior to restart, May 1, 1987.

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c. 1 NRC Violation B.3 Rancho Seco Technical Specification 6.8.1.e requires, in part, that written procedures covering the emergency plan shall be maintained.

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 cf 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).

District Response to Violation B.3

1) Admission or denial of the alleged violation.

The District admits that this violation occurred as stated.

2) Reasons for violation.

Same as violation B.1.a. In addition, there was no means of identifying that Turbine Bypass Valves (TBV) or Atmospheric Dump Valves (ADV) were opened and the duration of that opening to determine a source term.

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

AP-509, Rev. 3 dated August 13,-1986, addressed this capability by requiring the assumption that all TBVs and ADVs are open unless otherwise indicated.

4) Corrective actions which will be taken:

AP-509 will be revised again when secondary re2. ease points have had monitoring equipment installed.

5) Date when full compliance will be achieved:

The District considers the August 13, 1986, revision of 1

AP-509 to be in compliance.

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NRC Violation B.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 ar 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).

District Response to Violation B.4

1) Admission or denial of alleged violation.

The District admits that this violation occurred as 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 members directly contributed to this violation.

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 adressed 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.

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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.

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'e ' -a NRC Violation B.5 Rancho Seco Technical Specification 6.8.1.e requires, in part, that written procedures covering the emergency plan shall be maintained.-

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 Herald 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 l procedures had not been made. In addition, replacement guidance regarding what equipment and supplies, formerly in these two emergency kits, required to be taken from the reactor site when the offsite assembly area (s) are activated

] had not been provided.

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

District Response to Violation B.5

1) Admission or denial of alleged violation. ~

The District admits the violation cccurred as stated.

2) Reasons for the violation:

Same as Violation B.4.

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

AP-305-9D dated September 25, 1986, has removed the l

reference to the decontamination equipment and supplies.

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4) Corrective actions which will be taken:

AP-516 and AP-552 will be revised to be consistent with AP-305-9D and the current use and location of emergency kits and decontamination equipment and supplies.

5) Date when full compliance will be achieved:

5FiallT? compliance:1 wile be" achieved ~bylissuancenof? revised 3 t:proceduresiprior tofrestartiMay 1,;[1987'.

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NRC Violation C.1

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.  ;

Section ~IV.E of Appendix E requires that the emergency facilities -

i 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:

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a) Section 7.1.5 of the emergency plan described the first

aid room as being adjacent to the Auxiliary Building and '

j 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 tha Fall of 1984, was located next to the cafeteria in the TER 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 L hallway from the former location. This change was made l

prior to September 10, 1985. L h

j c) Section 7.2.2 had not been changed to show that emergency lockers, removed in July 1985, were no longer located at the j California State Forestry Fire Fighting Academy (Ione) and the Herald Fire Department.

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

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District Response to Violation C.l.a,b,c

1) Admission or denial of the alleged violation.

The District admits that this violation occurred as stated.

2) Reasons for the violation.

Same as violation B.4.

L 3) Corrective actions which have'been taken and the results achieved:

The District has initiated a review of the Emergency Plan and implementing procedures.

4) Corrective actions which will be taken.

Emergency plan revisions necessary to resolve the specific

, discrspancias noted in the violation and those identified

' during the District's review will be submitted to the plant review committee prior to March 15, 1987.

5) Date when full compliance will be achieved:

IFu11~compliande Milllbe'a' hieved c - with ' Managenent: safety w

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, C Review' Committee ~approvalL. prior- to 7 restartn May.:171:1987 3 I

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• NRC Violation C.2 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.

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.

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).

District Response to Violation C.2

1) Admission or denial of alleged violation:

The District admits that this violation occurred as stated.

2) Reasons for violation:

Minutes for the meeting with the counties and state which should have reflected this review were not retrievable because of inadequate records system. Additional contributory factors were that the District staff relied upon meeting minutes and informal agenda items to cover this commitment.

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

The counties and state were provided with an opportunity for Emergency Action Level (EAL) review by formal letter issued by Licensing, letter number NL 86-195. Discussions with the State, Amador County, and Sacramento County were held on November 5, 1986 and San Joaquin County on November 17, 1986 to further review EAL's.

4) Corrective actions which will be taken:

Annual reviews will be documented by formal correspondence.

5) Date when full compliance will be achieved:

Full compliance will be achieved on December 1, 1986.

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NRC Violation'C.3 Section IV.F of appendix E requires initial training and retraining of omergency personnel. Section 6.2.7 .of the emergency _ plan required that health physics-personnel and the-emergency team will be provided Advanced First Aid and Multi-Media every three years.

Contrary to the above,-at the time of the-inspection, retraining in the Standard Multi-Media had been discontinued -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 (Supplement VIII).

District Response to Violation C.3

1) Admission or denial of alleged violation.

The District admits that this violation occurred as stated.

2) Reasons for violation:

The violation was due to the Emergency Plan not being revised to reflect that First Aid Training for emergency i

team members could be provided at an instructional level equivalent to Advanced First Aid. An additional contributor was the utilization of emergency medical technicians as First Aid instructors who were not able to issue Red Cross Certification Cards.

3) Corrective actions taken and results achieved.

Review of 1985 and 1986 First Aid training documentation indicated that Emergency First Aid training was provided to licensed operators as a requalification training program topic. This review also indicated that the training was provided to a level equivalent to Advanced l First Aid including Multi-Media. Two instructors, who are qualified to issue Red Cross Certification, have been  !

hired to provide Advanced First Aid training.

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4) Corrective Actions which will be taken, ,' l 4.,,

Section 6.2I7[d of the Emergency, Plan will be revised to l; reflect the acceptance of both Myanced First Aid or the '

equivalent.' Emergency Team memburs will be enrolled in ~ o [' ~

appropriate training and retraining pecgrams. At least \;.

one member of the Emergency Team will have Advanced First 4 4 Aid Training or the equivalent. Nina Radiation ' T Protection personnel will be trained on Standard Multimedia by December 31, 1986.

5) , Date when full compliance will be achieved.

. ' . 'Sta i DistrihtiMNE[deEsiithaEf5il17 compliance:: will; be %

(achieved;withithelrevision of ?the; Emergency Plan prior to.

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SACRAMENTO MUNICIPAL UTIUTY DISTP.tCT O P. O. Box 15830, Sacramento CA 9'5853,j 030, (916) 452-3211 C ( AN ELECTRIC SYSTEM SERVING THh RRhBT OF CALIFORNIA JEW 87-082 ,,

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February 5,1987 ' -

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,'J. B. Martin, Regioral Administrator

.,7; egion V Office of Inspection and Enforcement it itn Document Control Desk 4 U S Nuclear Regulatory Commission 1450 Maria Lane Suite 210

'/alnut Creek Ca 94596 DOCKET NO. 50-312 Rancho Seco Nuclear Generating Station Unit #1

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License No. OPR-54 NRC INSPECTION REPORT 86-14-01 5

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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 i 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.

i Sincerely,

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l E Ward

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Deputy General Manager i Nuclear Attachment

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RANCHO SECO NUCLEAR GENERATING STATION 3 14440 Twin Cities Road, Herald, CA 95638 9799;(209) 333 2935

. . , p. . . - .

ENCLOSURE v, ,-

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

Notice of Violation

) NRC Violation A:

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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.

, NNj/P....Contrarytotheabove,eightofthecontrolroomstaff,includingfour

%" ' $kfhthiftsupervisors,andtwenty-fourmembersofthelicensee'semergency 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 i were modifications to two of the dose assessment computer codes during the year (1985). >

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

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

1) Admission or denial of the alleged violation.

The Distrh.t Wts that the violation occurred as stated. ,

2) Reasons for violation.

, The violation was the result of an inadequate tracking system for Emergency Preparedness related training and retraining.

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

l The Emergency Preparedness Department, in coordination with the  ;

l Nuclear Training Department, 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.

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,~' 4) Corrective actions which will be taken.

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 "q.WC . .. m an inadequate tracking system. The corrective action was to initiate

• a new tracking system. Please describe the differences between the

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former and new tracking systems that will assure the violation does not occur again. Since tracking systems are only as effective as

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their implementation, you should also describe your management actions to assure implementation of the Emergency Preparedness Training Program.

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

1) Corrective stens 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 management 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.

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 management attention and action as described below can be initiated.

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2) Elevaticn of the Emergency Preparedness Program to the Department level within the' District's Nuclear Organization, and headed by a Department Manager..

This elevation of the Emergency Preparedness Manager and 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 supervisors to include ERO training, drill exercise attendance, and performance in an individual's performance plan criteria.

Once included in an individual's performance plan criteria, inadequate participation will result in a reduced evaluation

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. s under the District's pay for performance criteria.

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..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 organization until the problem is resolved. The Manager of' 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.

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:

Full compliance was achieved on January 23,19ti7, the date of the.

Director General Manager (DGM) Directive tying ERO training, participation and performance with an individuals job performance plan.

NRC Violation 8.1: .

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

Procedures AP.509, 511, and 512. " Dose Calculations for the Control Poom," " Technical Support Center," and " Emergency Operations facility" respectively, provided a means for hand calculating offsite doses. In i 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.

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• - C:ntrary to th] tb:va, at the time of the inspection, these procedures 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 Resnonse to Violation B.I.a: (Dated 12/1/86)

1) Admission or denial of the alleged violation.

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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 4

improvements were included in the following procedure changes, dated i September 18, 1986.

AP.509, Revision 4 AP.501, Revision 6 AP.511, Revision 5 i

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 correctiv4 actions have been completed as described in item 3 above.

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5) Date when full compliance will be achieved.

Full compliance was achieved on September 18, 1986.

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• ** ** ERC Violation 8.4 l

l 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 J

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 I was not maintained in that guidance for relating plant conditions and trends to the various protective action recomendations had not been provided.

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

,$DistrictResponsetoViolation8.4 (Dated 12/1/86)

1) Admission or denial 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 members directly contributed to this violation.

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.

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For approach (2), citigating personnel turnover, several specific programs have been developed within. Emergency Preparedness to ensure that commitments, implementation programs and personnel resources are being defined, tracked and managed. They are:

C-- 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 drafted, and will be completed before March 1, 1987.

8) 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

, c, , included in EPIC. EPIC clarifies personnel priorities and

,q.fy.%g.. 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.

I 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 l

progress to specific individuals (item b), and coordinating resources and personnel (item c).

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• * * ** ~ 2) Corrective steps which will be taken:-

For approach (1), effective management of Emergency Preparedness, the '

.r~ Emergency Preparedness Department will perform a review of current

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salary levels within the Emergency Preparedness staff, 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 u d, . .riCO

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' documents and tables may be inco'rporated 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 whicn 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

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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 responsibil.ities for the position

) assigned due to the clearly defined and proceduralized program as a i whole.

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