ML20214K188
| ML20214K188 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 11/20/1986 |
| From: | Julie Ward SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | Martin J, Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| JEW-86-728, NUDOCS 8612020211 | |
| Download: ML20214K188 (24) | |
Text
- Dcs l g" SMUD SACRAMENTO MUNICIPAL UTILITY DISTRICT C P. O. Box 15830, Sacramento CA 95852-1830,(916) 452-3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA JEW 86-728 November 20, 1986 US NUCLEAR REGULATORY COMMISSION MR. JAMES M. TAYLOR DIRECTOR OFFICE OF INSPECTION AND ENFORCEMENT 7920 NORFOLK AVE PHILLIPS BUILDING BETHESDA MD 20014 MR. JOHN B. MARTIN ADMINISTRATOR REGION V OFFICE OF INSPECTION AND ENFORCEMENT 1450 MARIA LANE SUITE 210 WALNUT CREEK CA 94596 Response to Notice of Violation and Proposed Imposition of Civil Penalty (NRC Inspection Reports Nos. 50-312/86-06, 50-312/86-07).
By letter dated October 22, 1986, the Sacramento Municipal Utility District was transmitted a Notice of Violation and Proposed Imposition of Civil Penalties concerning the December 26, 1985 overcooling transient at Rancho Seco. In accordance with 10 CFR 2.201, Attachments 1 through 5 comprise our response to the Notice of Violation and Proposed Imposition of Civil Penalty.
This letter acknowledges the violation cited and describes our intended corrective actions for each specific item listed in your Notice.
These responses and the corrective actions committed to in the Action Plan for Performance Improvement sent to you on July 3, 1986 constitute significant corrective action to prevent recurrence of the violations cited. The Plan has additional details and schedule for items to be completed prior and subsequent to plant startup.
Attached is a check in the amount of $375,000.00 for payment of the Civil Penalty.
Subscribed and sworn to
" / #
S' before me this Ja day of November, 1986.
- ,/
j y ,
/ '/ t://t -JG L k ! 1 drft.J J. E. WARD Notary Public
~ DEPUTY GENERAL MANAGER, NUCLEAR My commission expires:
g__~msum '5- _ g _ g7
$ pg OFFICIAL SEAL i Y'TjG CUSAN L FINN f i UC r:om ec - caurcem l 1 ?,(:: C,'
t?cyd.*tNTO COUNTY ,
, 'E -
8612O20211 861120 kam _r4 ern.x-..
er;nm fAAY~~D, It07 4 PDR ADOCK 05000312 i ( // ;{ f ([/
G PDR -
RANCHO SECO NUCLEAR GENERATING STATION 1 144401 win Qties Road, He rold, CA 95G38-3793, (203) 333-2935
ATTACHMENT 1 DISTRICT RESPONSE TO NRC INSPECTION 86-06 & 86-07 NOTICE OF VIOLATION NRC Violation A Technical Specification 3.1.2.4 states that the reactor coolant system cooldown rates shall be limited in accordance with Figure 3.1.2-2.
Figure 3.1.2-2 states that for reactor coolant temperatures greater than 270 degrees-F, the maximum allowable cooldown rate is 100 degrees-F per hour.
Contrary to the above, on December 26, 1985, the reactor coolant system temperature was decreased by 180 degrees-F in 26 minutes (566 degrees-F to 386 degrees-F).
District Response to Violation A
- 1) Admission or denial of the alleged violation.
The District acknowledges and admits that this item occurred as stated.
- 2) Reasons for the violation The fundamental cause of the violation was the loss of power to the Integrated Control System (ICS) and the subsequent plant response cooled the reactor coolant system at a rate greater than normal. This design feature ensured the dissipation of decay heat, however, caused the plant to exceed the assumed cooldown rate for normal cooldowns of 100 degrees-F per hour.
j A-1
1
- 3) Corrective actions which have been taken and results ,
achieved. 1 The response to Violations B, C and D provide specific actions which will minimize the likelihood of recurrence and minimize the consequences of both a loss of ICS power event and the inappropriate plant response to the loss of ICS control. These specific actions include the installation of an Emergency Feedwater Initiation and Control System (EFIC); the development of a loss of ICS power casualty procedure, and; the development of procedures for manual emergency operation of the safety-related Auxiliary Feedwater System control valve FV-20527, and similarly configured valves.
- 4) Corrective steps which will be taken to avoid further violations.
Plant operating procedures, casualty procedures and emergency operating procedures which relate to plant cooldowns will be revised prior to restart to reflect the current Babcock and Wilcox (B&W) interpretation of 100 degrees-F per hour cooldown. In addition, plant operators will be trained on the revised procedures prior to restart. It should be noted that B&W is performing preliminary analysis for cooldown rates which are less restrictive than those currently in place in the Rancho Seco Technical Specifications.
This effort will require the submittal of a proposed amendment with its attendant technical justifications and significant hazards evaluations. This effort to provide a more workable definition of the cooldown i
limits is being pursued independent of the Restart Program.
A comprehensive itemization of the detailed technical specification requirements, with the procedures which implement them, will be developed prior to restart.
)
i i
A-2
- 5) Date full compliance will be achieved.
The casualty procedures for loss of ICS have been developed and implemented.
The installation of the EFIC System, the revision of the Operating, Casualty and Emergency procedures, and training of personnel which include the B&W ,
interpretation of 100 degrees-F per hour, will be completed prior to restart.
A-3
ATTACHMENT 2 DISTRICT RESPONSE TO NRC INSPECTION 86-06 & 86-07 NOTICE OF VIOLATION ,
NRC Violation B 10 CFR Part 50, Appendix B, Criterion XVI requires that in the case of significant conditions adverse to quality, measures must assure that the cause of the condition is determined and corrective action taken to prec?ude repetition.
Contrary to the above, as of December 26, 1985, a significant condition adverse to quality, specifically, the potential for a loss of DC power to the Integrated Control System transient existed, yet the cause of the condition was not determined, nor was adequate corrective action taken. The licensee failed to correct identified design deficiencies or to develop procedures which could have significantly lessened the severity of the December 26, 1985 event.
District Response to Violation B
- 1) Admission or denial of the alleged violation.
. The District acknowledges and admits that this item occurred as stated.
i l
l l
l 0
0 B-1
- 2) Reasons for the violation During the first years of Rancho Seco operation, the Integrated Control System (ICS) caused several relatively minor transients as a result of having been provided with only a single power source. A redundant power supply configuration was installed for both the ICS and Non-Nuclear Instrumentation (NNI) which resolved the concern at that time. With the ICS/NNI ,
related transients which occurred at Rancho Seco and I
similar plants during the 1978 through 1930 period, it
, was recognized that certain equipment should be j controlled by safety grade systems independent of l
ICS/NNI. The District'is approach was to combine its
) resources with other utilities facing similar requirements and to develop and install an appropriate safety grade auxiliary feedwater control system. At Rancho Seco, this system is called the Emergency Feedwater Initiation and Control (EFIC) System. A number of factors delayed the installation of EFIC which meant that the interim upgrades, to comply with post-TMI commitments, remained in service beyond their originally expected dates. A contributing factor was the failure to recognize the need for compensatory 4
event related procedures, to mitigate the consequences of a loss of ICS event prior to the availability of the yet to be installed independent controls. This directly i
led to the magnitude of the December 26, 1985 l overcooling event.
- 3) Corrective actions which have been taken and results i achieved.
In order to resolve the loss of ICS power impact on the plant, the District will install the EFIC system prior to restart.
i In addition, subsequent to the December 26 i
event, the District embarked on a comprehensive 4
program to systematically assess all aspects of facility operation. This program is descri'oed 1 in the Action Plan for Performance Improvement j already submitted to the NRC.
This new approach not only focuses on providing improved controls and improved ICS/NNI reliability, but recognizes that equipment failures can and will likely occur. Therefore, it provides procedures, training, and where appropriate, equipment to ensure the prompt mitigation of a wide range of possible transient events. This includes procedures which address recovery from transient conditions and transition to j
the normal controlling systems and equipment.
i
- B-2 t
.,.-----,.-,-.,,_n------ . . . . . - -_ - . - . - - - . - - , - . - . . - . - - . . . - , - . . _ - - - - . - ~ - = - - - -
- 4) Corrective steps which will be taken to avoid further violations.
Training is being provided to the operators on these new procedures and procedure revisions, as well as proper use of the new equipment and controls. As a final validation of these improvements, a " Loss of ICS/NNI Test" will be performed during restart to demonstrate the effectiveness of the entire plant facility, procedures, operator-training triad in mitigating such events.
- 5) Date full compliance will be achieved.
The District will be in full compliance with recpect to the violation cited upon installation of EFIC, the successful performance of the " Loss of ICS/NNI Test,"
and the completion of the Action Plan items scheduled for restart.
l B-3
~
i .
ATTACHMENT 3 i DISTRICT RESPONSE TO NRC INSPECTION 86-06 & 86-07 NOTICE OF VIOIATION NRC Violation C.1 Rancho Seco Technical Specifications 6.8.1.a states that the applicable procedures recommended in Appendix A of Regulatory
- Guide 1.33 (November, 1972) shall be implemented.
- 1) Section C of Appendix A, Regulatory Guide 1.33, recommends procedures for startup, operation, and shutdown of safety-related PWR systems including j instructions for changing modes of operation.
$ Contrary to the above, no written procedures existed as
' of December 26, 1985 for securing the safety-related high pressure injection system following safety features j
- actuation or for the manual emergency operation of the safety-related auxiliary feedwater systems control valve FV-20527.
District Response to Violation C.1
! 1) Admission or denial of the alleged violation.
i i The District acknowledges and admits that this item occurred as stated.
- 2) Reasons for the violation During the District's investigation into the root causes of the December 26, 1985 event, the lack of a i
specific procedure to the return to normal configuration and lineup, following termination of SFAS, was found to be the root cause of the damage to the Makeup Pump. This was the determination of the lessons learned report. In a similar manner, the lack l of procedures and training on manual operation of the
- Auxiliary Feedwater Control Valves directly caused the
- valves to be damaged.
I l
i j C.1-1
,v , ,,.n ,,n - - ~. ~ ,-- .--m .n,- - ~ - ,,- - n . .,,--n,,-,--n ~. - - - - , - , r,-..c-- <,- . - - - , -
l l
- 3) Corrective actions which have been taken and results achieved.
Procedures specific to the reconfiguration of systems (mode changes) during or immediately following transients have been provided for the High Pressure Injection (HPI) System. Training, including simulator usage, has been provided to the operating crews.
The use of the manual positioning devices on the Auxiliary Feedwater Control Valves is addrossed in new procedures, and enhanced by improved position indicators, and operator training. The need to rely on manual operation has been significantly reduced by incorporation of these valves into EFIC, and the provision of Class 1 control air to each valve.
- 4) Corrective steps which will be taken to avoid further violations.
Revised Emergency Operating procedures, which involve the need for mode changes or recovery actions, will be in place prior to restart.
- 5) Date full compliance will be achieved.
The District is now in full compliance with the requirement cited.
, C.1-2 I
. . - ~ _ . . . _ . . _ _ _ . - - _ _ _ _ . . _ . . _ . . _ _ . - - . - - _ . _
NRC Violation C.2 a
- 2)Section I of Appendix A, Regulatory Guide 1.33, recommends procedures for maintenance that can affect the performance of safety-related equipment. It also 4 recommends preventive maintenance schedules be developed to specify lubrication schedules and 4
inspection of equipment.
i i Contrary to the above, as of December 26, 1985, no
, written procedures existed that required inspection, j maintenance, or lubrication schedules for the Auxiliary Feedwater System valve FWS-063.
4 District Response to Violation C.2 i 1) Admission or denial of the alleged violation.
The District acknowledges and admits that this item occurred as stated.
- 2) Reasons for the violation l
j During plant construction and initial operation, 3
maintenance procedures were in place, or devel.oped as the specific need was identified, to meet the
, requirements of Regulatory Guide 1.33 as committed to l in Technical Specifications. The preventive maintenance program focused on Technical Specification related commitments, active Class 1 equipment, and active balance-of-plant equipment important to
- reliability. In recent years the preventive i
maintenance (PM) requirements became better defined, the program was computerized and expanded to include i
additional equipment. Much of the maintenance effort was a balance between " corrective" and " preventive" maintenance. For example, during each refueling outage several hundred valves would be overhauled, although their selection was typically subjectively done by a maintenance engineer, rather than by a programmatic process which ensured a uniform level of attention.
The Auxiliary Feedwater System Valve FWS-063 is Class 1, with respect to its pressure boundary; however, it is a maintenance valve that ,is normally
, locked opened and is not required to function during
, design events; therefore, it was not incorporated into
- the original PM program.
I l
C.2-1
4
- 3) Corrective actions which have been taken and results achieved.
During 1985, the District took a number of actions to upgrade the level of maintenance support of Rancho Seco which were directed at improving its reliability,
- performance, and safety. Significant among these was l the budgeting, hiring and commitment of personnel and
! resources directly into the plant PM program. These resources, for the most part, were in place prior to
- the December 26 event. Their initial efforts were to develop and implement a comprehensive PM program with j' the necessary procedures and process to ensure that plant equipment is receiving the necessary attention to ensure its safe and reliable operation. The District 2
is confident that this program would have soon provided the programmatic PM for FWS-063.
Following the December 26 event, lack of lubrication i was identified as the root cause of the inoperability of manual valva FWS-063. The other manual valves in the Auxiliary Feedwater System were determined to be functional. To determine if a lack of scheduled PM lubrication of other manual valves is a generic j problem, inspection, testing and PM have been' scheduled for those valves which could be used to isolate active i systems or components within the plant. A
! comprehensive valve preventive maintenance program is j being implemented.
1 i 4) Corrective steps which will be taken to avoid further
] violations.
l The results of valve maintenance, inspections, testing and operations will be documented to verify the i operational readiness of plant valves. The overall valve program is an integral part of the Restart
, Program and is intended to demonstrate the material condition of the plant and its readiness for power ,
i operation.
- 5) Date full compliance will be achieved.
9 I
i The District is in full compliance with the requirement cited in that a the comprehensive PM program has been implemented.
f I
t i
i C.2-2 o v-- em ,-w-m,- - ~ -.mnn,, v -m---m --,---+ma_e--- - - - - - ,~w---w,-- --~--,----~--mmm-,-rmm~n.-r r
ATTACHNENT 4 DISTRICT RESPONSE TO NRC INSPECTION 86-06 & 86-07 NOTICE OF VIOIATION NRC Violation D.1 Rancho Seco Technical Specifications 6.8.1.a states that the applicable procedures recommended in Appendix A of Regulatory Guide 1.33 (November, 1972) shall be established and implemented.
- 1) Emergency Procedure (EP) E. 0 5, " Excessive Heat Transfer", Step 3.1, which is recommended by Regulatory Guide 1.33, Appendix A, Section F, requires that Auxiliary Feedwater Pump (AFW) P-318 be stopped if Once-Through-Steam Generator (OTSG) level increases to 95 percent in the operating range. Furthermore, Rule 3 of the same procedure states "If excessive primary to secondary heat transfer exists, then stop AFW flow to the steam generator (s) being overcooled."
Contrary to the above, EP E.05 was not adequately implemented on December 26, 1985 in that AFW Pump P-318 was not stopped when the level in "A" OTSG reached 95 percent. Also, even though excessive primary to secondary heat transfer existed, AFW flow was not stopped to the steam generators being overcooled.
District Response to Violation D.1 ,
- 1) Admission or denial of the alleged violation.
The District acknowledges and admits that this item occurred as stated.
- 2) Reasons for the violation The reason for this violation is that the plant operating staff incorrectly concluded that auxiliary feedwater flow should not be interrupted since it was providing core cooling.
L I
D.1-1
+
- 3) Corrective steps that have been taken and results achieved.
As part of the licensed operator training and retraining program, specific emphasis has been placed on overcooling transients; i.e., on how to diagnose and
- mitigate them. This training is described in more
- specific detail in the Action Plan for Performance
- Improvement as Item 4B.3.2.1.d. Additional emphasis j' has been provided in Procedure E.05 " Excessive Heat Transfer" and Rule 3 of that same procedure to ensure that in any future overcooling event, the proper mitigating actions are taken without hesitation. There j have been comparatively recent inspections of the plant operating staff on this issue as well as simulator and i i some NRC examinations of the licensed operators at Rancho Seco. The results of this training are evidenced by the results of NRC Inspection number 86- .
07, dated May 14, 1986, which documented a screening of
, the operating staff on this subject. It concluded that the staff was adequately trained.
- 4) Corrective steps which will be taken to avoid further violations.
l The reactor operator and senior reactor operator i training and retraining programs have been revised to ensure that the operating staff maintains an awareness of the importance of properly diagnosing and mitigating overcooling trannients. The program is more 4
specifically described in the Action Plan for Performance Improvement as Item 4B.3.2.1.d. This 1 training / retraining includes classroom and simulator
- training on the diagnosis and mitigation of overcooling t
. transients, with specific emphasis on Rancho Seco specific design features. Training will include the ;
4 EFIC system and its effect on mitigating overcooling transients as well as manual actions which may be required should the EFIC system not be available.
i
- 5) Date when full compliance will be achieved.
l Recognizing that the plant design will be altered significantly with the installation of the EFIC system, j the District will ensure that full compliance will be achieved prior to and during restart as appropriate.
This will permit the training of operations personnel,
- not only on overcooling transients (which has been accomplished) but will permit extensive training of
] operations personnel on the EFIC system and other j design changes which will be installed to minimize the
! p)ssibility of a recurrence of the December 26, 1985
{ overcooling event.
l j D.1-2 i'
NRC Violation D.2
- 2) Annunciator Response Alarm Procedure H2PSA-7, Revision 14, Window 12 as recommended by Regulatory Guide 1.33, Appendix A, Section F.27, requires in Step 2 that personnel be evacuated from the area being monitored for high gas activity upon receipt of a high alarm on Auxiliary Building Stack Gaseous Activity Monitor R15002B.
Contrary to the above, Procedure H2PSA-7 was not adequately implemented in that upon the receipt of an alarm from Auxiliary Building Stack High Gaseous Activity Monitor R15002B at approximately 5:05 a.m. on December 26, 1985 indicating high activity in the auxiliary building, personnel were not evacuated from the auxiliary building as required.
District Response to NRC Violation D.2
- 1) Admission or denial of the alleged violation.
The District acknowledges and admits that this item occurred as stated.
- 2) Reasons for the violation During the December 26, 1985 event, the control room operators were directing their attention to the multitude of plant operational responses needed to mitigate the overcooling event, and since local areas' Gas Radiation Monitor R15007 for the auxiliary building ventilation did not alarm and the Containment Building R15002 alarm cleared shortly after the alarm came in, no action was taken to evacuate the auxiliary building.
In addition, specific training for radiation monitor annunciator procedures had not been performed as part of the operator qualification and requalification training program.
- 3) Corrective steps that have been taken and results achieved.
The annunciator procedures for the H2PSA panel, including Window 12, have been revised to clarify the actions which need to be taken when an alarm is received.
D.2-1 i
- 4) Corrective steps which will be taken to avoid further violations.
Radiation monitor annunciator response actions will be included in the reactor operator and senior reactor operator qualification and requalification training programs. The plant operating staff at the time of restart will have received specific training on the necessary alarm responses for the radiation monitors which affect personnel and public safc.ty and which are relied upon in the mitigation of offsite releases.
- 5) Date when full compliance will be achieved.
The clarification of the H2PSA panel annunciator procedurs has already been completed. Full compliance will be achieved when the full complement of plant operators has completed radiation monitor annunciator response training. This training is considered to be a prerequisite for restart.
4 D.2-2
i NRC Violation D.3 1 Procedure AP.305-28, Revision 1, dated May 25, 1985, "MPC Determination at Site Boundary from Radioactive Releases," which is recommended by Regulatory Guide )
1.33, Appendix A, Section F.27, states in Paragraph 3.0 that a 10 CFR 50.72 evaluation is required if an unplanned, uncontrolled or accidental release of radioactive material occurs. It also states that part of the input for that report shall be derived from sampling the plant stack for noble gases, tritium, particulates and iodine.
Contrary to the above, Procedure AP.305-28 was not adequately implemented in that, with the occurrence of an unplanned, uncontrolled accidental release of radioactive material on December 26, 1985, an adequate evaluation was not performed to support 10 CFR 50.72 reporting requirements. Noble gas, tritium, particulate and iodine samples were not taken from the auxiliary building stack monitor and results that should have been derived from that sampling were not used as input for the 10 CFR 50.72 report.
District Response to the NRC Violation D.3
- 1) Admission or denial of the alleged violation.
The District acknowledges and admits that this item occurred as stated.
- 2) Reasons for the violation The individual who was performing the evaluation initially had difficulty locating the proper procedure (AP.305-28) due to the second volume of the Radiation Protection Manual not having an index. The individual had recently received training on how to perform the evaluation for 10 CFR 50.7:2 reporting and as a result, acquired an additional copy of the procedure but simply failed to thoroughly complete the procedure. This failure to complete the documentation requirements of AP.305-28 was due to a presumption by the individual involved that there was sufficient information available, without the use of the auxiliary building stack monitor samples, to determine reportability of the release in accordance with 10 CFR Part 50.72.
D.3-1
- 3) Corrective steps which have been taken and results achieved.
Procedure AP'.305-28 has been completely revised and has been reissued as AP.313-3 "MPC Determination at Site Boundary from Radioactive Releases". The purpose of this revision process was to gather those radiological procedures which relate to plant events (by emergency -
sampling using the post-accident sampling system, guidelines for plant personnel for areas of unquantified radiological condition, et cetera) into one manual entitled " Radiological Event Directions Manual". This has been accomplished to facilitate radiation protection access to this information and to also facilitate departmental training on these issues.
Each radiation protection technician has received training on the revised AP.313-3, "MPC Determination at Site Boundary from Radioactive Releases".
- 4) Corrective steps which will be taken to avoid further violations.
Each radiation protection technician will receive training on AP.313-3 "MPC Determination at Site Boundary from Radioactive Releases" again prior to restart. Emphasis has been placed on the significance of completing each step of the procedure to ensure that all facets of the release are understood and well documented. Training will be provided annually to the radiation technicians at Rancho Seco.
- 5) Date when full compliance will be achieved.
The District is now in full compliance with the requirement cited.
J i
i l
D.3-2 l __ _ -
i ATTACHMENT 5 i DISTRICT RESPONSE TO NRC INSPECTION 86-06 & 86-07
{ NOTICE OF VIOIATION l
{
j NRC Violation E Item "E" of the NRC Notice of Violation and Proposed Imposition '
j of Civil Penalty deals with the District's failure to adequately implement emergency response procedures during the December 26, i 1985 event. Rancho Seco's Technical Specification 6.8.1.e requires that written procedures be implemented and maintained 4 covering Emergency Plan implementation. The specific items 1
discussed in the NRC Notice of Violation and Proposed Imposition of Civil Penalty and responses to those items follow.
l NRC Violation E.1 Procedure AP.502, Step 5.1.3, " Notification of 4
Unusual Event," requires the Emergency Coordinator to ,
direct that the emergency alarm be sounded for ten seconds and announce, or have announced, the i appropriate message described in Step 5.1.3 over the public address system whenever an Unusual Event has occurred.
i contrary to the above, on December 26, 1985, Procedure j AP.502 was not adequately implemented in that an Unusual Event occurred and the Emergency coordinator did not ensure that the emergency alarm l
sounded nor did he announce or have announced the messages described in Step 5.1.3.
- District Response to Violation E.1
- 1) Admission or denial of the alleged violation.
} The District acknowledges and admits that this item
) occurred as stated.
l 2) Reasons for the violation During the December 26, 1986 event the requirements of procedures AP.502, " Unusual Event," were not implemented due to a personnel error.
I.
l I
t E.1-1
- l l
- 3) Corrective actions which have been taken and results achieved.
Training on the requirements of procedure AP'.502 was conducted for operations personnel and Emergency Response communicators. This training was completed on september 4, 1986. It will be repeated annually within the Emergency Plan Training Program.
Command and control training for decision makers, e.g.,
the control Room staff, which gives proper focus on requirements of the Emergency Plan, was completed on March 13, 1986.
- 4) Corrective steps which will be taken to avoid further violations.
As part of the Command and Control Training, the importance of, and requirement for procedure compliance has been reemphasized. This training will be repeated annually.
A number of emergency response drills have been successfully performed during the last several months.
This effort culminated with the NRC witnessed and graded exercise of October 8, 1986.
- 5) Data full compliance will be achieved.
The District is now in full compliance with the cited requirement.
i I
l E.1-2
NRC Violation E.2 Procedure AP.506, Step 5.1.2, " Notification / Communication",
requires the Emergency Coordinator to direct the Communicator to initiate Attachment 7.2., " Emergency Notification Call-List," and to provide state and county emergency response organizations with an initial notification of the Unusual Event and certain information concerning the event as identified by Attachment 7.1, Form A.
Contrary to the above, on December 26, 1985, Procedure AP.506 was not adequately implemented in that initial notification to state and county offsite authorities of the Unusual Event did not include all the information specified on Attachment 7.1, Form A. Specifically, the following Form A information items were not provided:
(2) that the event was an actual emercency, (5) the offsite radiological release status, (6) consideration of public protective actions, (7) the status of Emergency Operations Facility activation, (8) the wind direction and speed (9) the downwind sectors affected and (10) the initiating conditions Tab Number used to classify the event.
District Response to Violation E.2
- 1) Admission or denial of the alleged violation.
The District acknowledges and admits that this item occurred as stated.
- 2) Reasons for the violation During the December 26, 1986 event the requirements of procedures AP.506, "No fication/ Communication", were not implemented due to(& personnel error.
- 3) Corrective actions which have been taken and results achieved.
Training on the requirements of procedure AP.506 was conducted for operations personnel and Emergency Response Communicators. This training was completed April 1, 1986. This training will be repeated annually within the requirements of the Emergency Plan Training Program.
E.2-1
l Command and control training for decision makers, e.g.,
the Control Room staff, which gives proper focus on requirements of the Emergency Plan, was completed on )
March 13, 1986. 1
- 4) Corrective r,teps which will be taken to avoid further violations.
As part of the Command and control Training, the importance of and requirement for procedure compliance has been reemphasized. This training will be repeated annually.
A number of emergency response drills were successfully performed during the last several months. This effort culminated with the NRC witnessed and graded exercise of October 8,1986.
- 5) Data full compliance will be achieved.
The District is now in full compliance with the cited requirement.
1 l
E.2-2
NRC Violation E.3 Procedure AP.506, Step 5.1.4, " Notification / Communication" requires the Emergency Coordinator to complete a follow-up Notification Form (Attachment 7.4) which requires that follow-up information be sent to state and county emergency response organizations at least hourly during an emergency.
Contrary to the above, on December 26, 1985, Procedure AP.506 was not adequately implemented in that the Notification Form (Attachment 7.4) was not completed.
Follow-up notifications after the declaration of an Unusual Event were not made to the appropriate offsite authorities of Amador, San Joaquin, and Sacramento counties until termination of the event.
District Response to Violation E.3
- 1) Admission or denial of the alleged violation.
4 The District acknowledges and admits that this item occurred as stated.
- 2) Reasons for the violation During the December 26, 1986 event the requirements of procedure AP.506, " Notification / Communication" for update notifications, were not implemented. This occurred due to the Control Room personnel becoming very involved with the response to the plant events and not fully implementing the requirements of procedure AP.506.
- 3) Corrective actions which have been taken and results achieved.
Training on the requirements of procedure AP.506 was conducted for operations personnel and Emergency Response Communicators. This training was completed i
April 1, 1986. This training will be repeated annually.
Command and control training for decision makers, e.g.,
the Control Room staff, which gives proper focus on requirements of the Emergency Plan, was completed on March 13, 1986.
E.3-1
- 4) Corrective steps which will be taken to avoid further '
violations. -
l As part of the command and control Training, the importance of and requirement for procedure compliance has been reemphasized.
A number of emergency response drills have been successfully performed during the last several months.
This effort culminated with the NRC witnessed and graded exercise of October 8, 1986.
- 5) Date full compliance will be achieved.
The District is now in full compliance with the requirement cited.
i l
E.3-2 i
NRC Violation E.4 Procedure AP.501, Attachment 7.2, Tab 4 " Recognition and Classification of Emergencies," Revision 4, dated August 23, 1985, lists an " Emergency Action Level"
, alarm setpoint for Auxiliary Building Stack Monitor R15002B at 20,000 counts per minute (cpm) .
Contrary to the above, as of December 26, 1985, Procedure AP'.501 was not adequately maintained in that the Auxiliary Building Stack Monitor R15002B setpoint was changed to 60,000 cpm on July 21, 1984, and the setpoint as listed in Attschment 7.2, Tab 4 still stated that the setpoint was 20,000 cpm.
. District Response to Violation E.4
- 1) Admission or denial of the alleged violation.
The District acknowledges and admits that this item occurred as stated.
- 2) Reasons for the violation The referenced value was changed on July 21, 1984, but procedure AP.501 was not updated. This procedure change
, was not made due to the lack of an adequate tracking
, system within the Emergency Planning organization to assure that procedures would be revised in a timely and t
comprehensive manner.
- 3) Corrective actions which have been taken and results achieved.
1 In order to correct this problem AP.501, Attachment 7.2, Tab 4 was updated, j 4) Corrective steps which will be taken to avoid further
- violations.
l The Emergency Planning organization has developed a i tracking system to assure that changes are incorporated l in a timely and comprehensive manner.
- 5) Data full compliance will be achieved.
This tracking system will be documented in a procedure by January 5,1987.
i l
! E.4-1 i
- __ _ . _ .. _ _. ,, _ _ _ . _ , _ _ . . _ , . _ , _ _ . _ _ . _ _ _ _ . _ , _ _ ._. _ ___ __ _ _ ,__ _ ._ -