ML20207M783

Responds to NRC Re Violations Noted in Insp Rept 50-312/86-14.Corrective Actions:Training Dept Will Retain All Emergency Preparedness Training Matl & Emergency Preparedness Representative Will Attend Daily Meetings

ML20207M783
Person / Time
Site:	Rancho Seco
Issue date:	12/01/1986
From:	Julie Ward SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20207M763	List: ML20207M760 ML20207M783
References
JEW-86-923, NUDOCS 8701130284
Download: ML20207M783 (17)

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'$SMUD SACRAMENTO MUNICIPAL UTILITY DISTRICT D P. O. Box 15830, Sacramento CA 95852-1830,(916) 452-3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CAUFORNIA JEW 86-923 December 1, 1986 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 provides the enclosed response to the Notice of Violation.

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J WARD DEPUTY GENERAL MANAGER NUCLEAR Attachment w

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,9 v1 8701130284 861224 PDR ADOCK 05000312 G PDR RANCHO SECO NUCLEAR GENERATING STATION E 14440 Twin Cities Road, Herald, CA 95638-9799;(209) 333-2935

-s 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, i

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 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).

i District Response to Violation A

1) Admission or denial of the alleged violation.

The District admits 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.

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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 department.

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.

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t NRC Violation B.1-Rancho Seco Technical Specification 6.;B.l.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 affluent 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 the inspection, these 1

procedures were not maintained in that:

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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.1.a i

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 s)\ were due__tulack the maintenance andofrevision continuity _irtataffresponsible_

of these_ procedures. A fog Mbuting factor was the lack of administratTve controls to assure that emergency preparedness staff were dhawareofplantcoHYigurationchanges.

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

AP-509 and AP-511 were initially revised to properly include R150044 and R150045 monitor points on August 13, l

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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

$m 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.

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.

District Response to Violation B.l.b

1) Admission or denial of the alleged violation.

The District admits that this violation occurred as stated.

2) Reasons for the violation.

i Same as violation B.1.a.

3) Corrective actions which have been taken and the results

, achieved.

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

projections.

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4) Corrective actions which will be taken.

Re' visions to AP-509, AP-511 and AP-512 will be implemented prior to restart. Dose assessment codes currently used by

[ the District will be revised, updated and reflected in AP-l 509, AP-511 and AP-512 prior to restart.

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5) Date when full compliance will be achieved.

f Prior to restart, May 1, 1987.

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

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 'RACODE'."

Contrary to the above, at the time of the inspection, the 4

procedure 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 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.

Same as violation B.1.a.

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

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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.

i 4) Corrective actions which will be taken.

! Same as violation B.l.b. In addition, user guide

information will be provided to assist those persons who perform dose assessment calculations.

5) Date when full compliance will be achieved.

Prior to restart, May 1, 1987.

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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 i

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 i 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.

l The District admits that this violation occurred as i

stated.  ;

2) Reasons for violation.

i Same as violation B.l.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 da*ed August 13, 1986, addressed t:ais 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 release points have had monitoring equipment installed.

5) Date when full compliance will be achieved:

The District considers the August 13, 1986, revision of 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 4

maintained.

Procedure AP-528, " Protective Action Guidance," required that protactive actions to be recommended to appropriate local and State 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).

District Response to Violation B.4

1) Admission or denial of alleged violation, i

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 proceduro revisions and the inadequate turnover of work in progress Z 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 l when a new staff member is assigned procedure maintenance j 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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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 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.

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 occurred as stated.

2) Reasons for the violation:

j Same as Violation B.4.

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

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

Full compliance will be achieved by issuance of revised procedures prior to restart May 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 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 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 hallway from the former location. This change was made prior to September 10, 1985.

i c) Section 7.2.2 had not been changed to show that emergency lockers, removed in July 1985, were no longer located at the i

California State Forestry Fire Fighting Academy (Ione) and the Herald Fire Department.

I j 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.

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 discrepancies 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:

Full compliance will be achieved with Management Safety Review Committee approval prior to restart, May 1, 1987.

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. s 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 50.4'7(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 bcsis.

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 achiev.'d:

The courc les 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 compliar ce will be achieved:

Full compliance will be achieved on December 1, 1986.

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. 8 NRC Violation C.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 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).

Dietrict 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 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 i

training was provided to a level equivalent to Advanced First Aid including Multi-Media. Two instructors, who are qualified to issue Red Cross Certification, have been l hired to provide Advanced First Aid training.

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4) Corrective Actions which will be taken; Section 6.2.7.d of the Emergency Plan will be revised to reflect the acceptance of both Advanced First Aid or the equivalent. Emergency Team members will be enrolled in appropriate training and retraining programs. At least one member of the Emergency Team will have Advanced First Aid Training or the equivalent. Nine Radiation Protection personnel will be trained on Standard Multimedia by December 31, 1986.

5) Date when full compliance will be achieved.

. The District considers that full compliance will be achieved with the revision of the Emergency Plan prior to restart May 1, 1987.

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