IR 05000445/1989058

Insp Repts 50-445/89-58 & 50-446/89-58 on 890724-28.No Violations & Deviations Noted.Major Areas Inspected: Performance & Capabilities During Annual Exercise of Emergency Plan & Procedures

ML20246N385
Person / Time
Site:	Comanche Peak
Issue date:	08/25/1989
From:	Powers D, Terc N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20246N378	List: IR 05000445/1989058 ML20246N372
References
50-445-89-58, 50-446-89-58, NUDOCS 8909080106
Download: ML20246N385 (10)

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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

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REGION IV

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' NRC Inspection Report: 50-445/89-58 Construction. Permits: CPPR-126 50-446/89-58 CPPR-127 Dockets: 50-445!

50-446-Applicant: TU Electric (TUCO)

. Facility Name: Comanche Peak Steam Electric station Inspection At: Glen Rose Texas

. Inspection Conducted: July.24-28, 1989

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Inspector: .

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/ E-/ N i N. M.:Terc, Emergency Preparedness Analist, Date NRC Team Leader

> Accompanying. Personnel:

J. Wiebe, Senior Project Inspector, NRC, NRR R. Hogan, Emergency Preparedness Analyst, NRC, NRR R. Caldwell, Physical Security Specialist, NRC, Region IV-

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.J. Gilliland, Public Affairs Officer, NRC, Region IV M.' Good, Engineer, Comex Corporation M. Stein, Engineer, Sonolyst Corporation

' Approved: !4 W Dr. D. A. Powers, Chief, Security and Emergency E M '- U Date Preparedness Section Inspection Summary

' Inspection Conducted July 24-28, 1989 (Report 50-445/89-58: and 50-4a6/89-58)

Areas' Inspected: Routine, announced team inspection of the applicar.t's performance and capabilities during an annual exercise of the emergency plan

,. 'and~ procedures. The inspection team observed activities in the control room (CR),~ technical support center (TSC), the emergency operations facility (EOF), and.the operations support center (OSC) during the exercise.

j' Resul'ts: Within the areas inspected, no violations or deviations were j identified. Seven open items were identified by the inspection team L (paragraphs 4 through 8). Open items identified include problems with:

L coordination'and direction in~the CR and OSC, personnel accountability and o evacuation of personnel, following of procedures, and information flo Generally, the applicant's response during the course of the exercise was adequate to protect the health and safety of the publi PDR ADOCK 05000445 o PDC

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-2-DETAILS Persons Contacted TUC0

• Bell, Nuclear Licensing Engineer

• Melton, Executive Assistant to Vice President Nuclear Operations

• T. Gosdin, Manager, Administrative Support

• T. Tyler, Director of Projects

• Blevins, Manager of Nuclear Operations

'*J. Kelley, Plant Manager

• D. Moore, Manager, Work Control

• D. Stonestreet, Manager, Outage Planning

• M. Axelrad, Attorney for Texas Utilities

• B. Lancaster, Manager, Plant Support

• H. Bruner, Senior Vice President

• J. Gallman, Supervisor, Engineering Analysis

• W. Cahill, Jr., Executive Vice President

• A. Scott, Vice President, Nuclear Operations

• D. McAfee, Manager, Quality Assurance

• Riggs, Plan Evaluation Manager

• Guldemond, Manager, Site Licensing

• J. Salsman, Manager, Emergency Planning CAS *B. Garde, CASE Attorney NRC

• P. McKee,. Deputy Director, Comanche Peak Project Division, NRR

• R. Warnick, Assistant Director for Inspection Programs, Comanche Peak Project Division, NRR The inspection team also held discussions with other station and corporate personnel in the areas of security, health physics, operations, training, and emergency respons * Denotes those present at the exit intervie . Followup on Previous Inspection Findings (92701)

(Closed) Deficiency (445/8512-06; 446/8515-06): Inadequate Medical Practices During the 1985 Exercise - This item was identified during the 1985 exercise, and consisted of inadequate medical practices that could have endangered and contaminated injured personnel. The inspection team noted that the applicant demonstrated good medical practices during the 1989 exercise.

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(Closed) Deficiency (445/8512-08;~446/8515-08): Inadequate Offsite Communications During the 1985. Exercise.- This item refers to inadequate

^ portable radios used.to communicate with offsite teams during the 1985

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exercise. The inspection team noted that during the.1989 exercise .

3 communication equipment used with emergency responders offsite was adequat M (Closed) Deficiency (445/8512-09; 446/8515-09): Inadequate Self-Critique 1 During the 1985 Exercise - This item was identified during the 1985 exercise. At.that time, the applicant was unable or reluctant to properly-identify.and characterize any open items-in the self-critique

. presented to NRC. During the 1989 exercise, the applicant demonstrated its ability to properly identify and characterize open items, (see Section 9 of this report). program Areas Inspected The inspection team observed applicant' activities in the CR,.TSC, OSC, and EOF during the exercise. 'The.. inspection team also observed emergency response, organization staffing, facility activation, detection, classification, operational assessment, notifications of applicant personnel.and offsite agencies, formulation of protective. action recommendations, offsite dose assessment, in plant corrective mea.;ures and rescue, security / accountability activities, and recovery operation Inspection findings arc documented in the following' paragraph There were no 10 CFR 50.54(s)(2)(ii) deficiencies identified during the course of the exercis No violations or deviations were identified in this program are . -Control Room (82301)(1)

'The-inspection team observed and evaluated the CR staff as they performed tasks in response to the exercise. These tasks included detection and classification of events, analysis of plant conditions and corrective actions, protective action decision making, notifications, implementation of protective actions, dose assessment, post-accident sampling and environmental monitorin The CR staff performed their duties well and were able to detect and classify emergency conditions. In addition, operators took necessary actions to ameliorate the impact of the accident by followirg emergency procedures to stabilize.the plant. They promptly made notifications to offsite agencies and to NRC, and mobilized necessary resources to coordinate and direct accident responses in a coherent manne The inspection team noted that in some instances the proficiency of the emergency responders within the CR did not result in a well coordinated and efficient response, as shown by the following:

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At about 10 a.m., the reactor operator (RO) dispatched an auxiliary i operator. (AO), to throttle a containment spray pump valve. Neither the A0 nor the R0 knew the location of this valve until the shift and unit supervisors subsequently determined where the valve wa *

At about 9:40 a.m., after the fire event in the diesel generator building, an A0 was directed to de-energize the B Diesel Generator but could not find the DC power breaker. This caused a delay until the unit supervisor identified the location of the breake During the alignment of the pumps in the B Train of the Emergency Core Cooling System (ECCS), the RO was not aware that the positive displacement charging pump could be supplied with water from the residual heat removal system, although the RO should have known of this optio *

Following the reactor trip, the back panel RO was investigating the offsite power electrical lineup instead of performing his immediate actions for the ongoing reactor trip which should have been given a higher priorit The R0s gave conflicting directions to the A0s. In one case, an R0 directed an A0 to stand by the hydrogen recombiner in preparation for securing i However, the A0 was called back by the other R0 who indicated that another A0 would be in that area and could secure the hydrogen recombine Apparently, the unit supervisor was not aware of the status of the A0 manpower until 10:49 a.m. The status was not maintained in a log and, as a consequence, one R0 had to recite from memory the tasks being performed and the names of the A0s performing each tas The fact that the emergency responders within the CR did not always react in a well coordinated and efficient manner is considered to be an open item. (445/8958-01; 446/8958-01)

No violations or deviations were identified in this program are . Technical Support Center (82301)(2)

The inspection team observed and evaluated the TSC staff as they performed tasks in response to the exercise. These tasks included activation of the TSC, accident assessment and classification, dose assessment, protective action decision making, notifications, implementation of protective actions, technical support to the CR, post-accident sampling a environmental monitorin The inspection team noted that the TSC staff performed their tasks adequately in response to the scenario. Activation of the TSC was prompt and orderly; the use of the public address system to keep personnel

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-5-informed of plant. conditions was excellent; and the use of status boards was-generally good, inlparticular, the use of the TSC. manager's tracking _

n board. Dose assessment personnel were alert to their computational results'and were able to perform manual calculations when computer result yielded ambiguous or unexpected results. TSC personnel used their procedures and system schematics effectively and were able to detect and

classify in'accordance with current emergency action levels. In addition, the TSC manager was' efficient in notifying offsite agencies, and in providing. technical support to the C :The inspection team noted that in one instance the emergency responders in the TSC.showed inadequate coordination of technical support of critical emergency repairs as follows:

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At 9:10 a.m., the'0SC manager was directed to obtain cables to restore power to Train B ECCS components. At'11:29 a.m., logistics and technical support. personnel were still attempting to obtain the cables from the warehous Inadequate coordination of technical support of critical emergency Jrepairs by emergency responders in the TSC is considered an open ite (445/8958-02; 446/8958-02)

In addition, the inspection team noted that from 8:38 a.m. to 11:30"a.m.'a second TSC manager did not form part of the emergency organization as described in the emergency plan and Procedure EEP-204, " Activation and Operation of the TSC" (see Item 445/8958-05; 446/8958-05 of this report for a similar problem in.the OSC).

No violations or deviations were identified in this program are . Emergency Operations Facility (82301)(3)

The inspection team observed and evaluated the EOF staff as they performed tasks in' response to the exercise. These' tasks included activation of the E0F, accident assessment and classification, offsite dose assessment, protective action decision making, notifications, implementation of protective actions, and interaction with state and local official The inspection team noted that the applicant was able to promptly activate the EOF. In addition, the inspection team deter ined that the EOF staff was efficient in classifying emergencies and mar.ing protective action recommendations-to offsite officials. Dose assessment was used effectively to determine the consequences of the postulated plume on the population, and environmental monitoring teams were well coordinated from the EOF. The inspection team noted that the interaction with other onsite emergency response facilities and offsite authorities (e.g., state representatives) was satisfactor However, the inspection team noted the Procedure EPP-203,

" Notifications," did not provide specific instructions on how to update in progress notification message forms when significant changes in plant

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status and offsite releases are occurring. :As a consequence, the applicant delayed required notification and protective: actio recommendation. updates to offsite agencies-during the general emergency conditio '

-The inspection team noted that Procedure EPP-203, " Notifications,"

did.not provide specific instructions on how to update in progress notification message forms when significant changes in plant status cand offsite releases were occurring, As a' consequence, the applicant L delayed required notification and protective action recommendation updates to offsite agencies during the general emergency condition .

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'The inspection team observed the dosimeters were not issued to

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emergency responders at the EOF (see Section 6 of this report).

The failures to provide specific instructions on how to update in progress notification message forms and to issue dosimeters to emergency responders in the EOF are considered an open item.

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(445/8958-03; 446/8958-03)

No violations or deviations were identified in this program are ' Operational' Support Center (82301)(4)

The inspection team observed and evaluated the OSC staff as they performed tasks-'in response to the exercise. The tasks included activation of the-OSC, personnel staffing, and support to the CR, TSC, and EO The inspection team noted that the activation of the OSC was prompt and that the overall performance of the OSC staff in support to'the CR and TSC staffs' was adequat The inspection team determined that the OSC staff did not maintain an accurate account of the location and status of emergency repair and damage control teams and other in plant teams. The OSC staff did not maintain sufficient information to determine when in plant teams were dispatched, who was on each team, when the teams returned, and what was accomplished by each team. The inspection team identified weaknesses in the information flow within the OSC and between the OSC and other support groups (e.g., access control point), and discrepancies between the information recorded on the emergency work permits (EWP) and that recorded on OSC status boards. Moreover, the inspection team noted that the team status board was inaccurate and incomplete, and that procedures were not always followe The inspection team observed the following instances of inaccurate tracking and display of in plant teams by the OSC staff:

At 9:15 a.m. Team F was shown on the status board to be in " standby."

At 9:55 a.m. Team F was still listed in standby, even though they entered the plant, returned from the diesel generator, and were leaving the access control point again to perform another tas _

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At 12:05 p.m. an A0 was dispatched to start the common reactor makeup water pump, but was not recorded on the status board until one hour late * At 12:13 p.m. an A0 entered the OSC and reported to the OSC manager that a security guard was found in the radiation area without proper dosimetry. The status board was not updated at that time to indicate the correct whereabouts of the A At 12:38 p.m. a radiation protection technician (RPT) returned to the access control point with Team N which had responded to the injured man in the hot machine shop. At that time, the RPT was still listed on the status board as a member of Team F in a standby mod * At 1:04 p.m. an A0 who had been dispatched to perform a valve lineup for the coolant charging pump (CCP) returned to the OSC to obtein protective clothin The status board was not updated upon his return, even though the A0 announced that he had returned to dress ou At 2 p.m. a team left the access control point to transport a blank flange needed for a critical repair operation. The team was not recorded on the status boar * At 2:35 p.m. a runner for the Post-Accident Sampling System (PASS)

team who was not listed on the status board as part of the PASS team exited the radiation controlled are Exposure data entry cards were not attached to EWP-2 for two A0s who

.were listed on the board as A0s under EWP- The inaccurate tracking and display of in plant teams by the OSC staff is considered to be an open ite (445/8959-04; 446/8958-04)

The inspection team noted the following instances where the maintenance supervisor (MS) and his staff failed to follow Procedure EPP-205,

" Activation and Operation of the Operations Support Center":

lhe MS was located in the staging area rather than in the OSC management area as shown on Attachment 1 of Procedure EPP-205.

l l The MS did not identify the repair and damage control activity to be performed (Step 1).

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" The MS did not obtain the approval of the OSC manager to dispatch in plant teams (Step 4).

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• The MS did not notify personnel at the access control point that a I team would be entering the RCA (Step 5).

The MS did not dispatch teams (Step 8).

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The MS did not inform the OSC manager of team activities (Step 10).

The OSC staff included an executive assistant to the OSC manage This position is not included in the description of the emergency plan or Procedure EPP-20 ,

The example of the failure to follow the prescribed procedures is considered to be an open item. (445/8958-05; 446/8958-05)

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The inspection team observed the following weaknesses in. coordinating-and controlling emergency repair teams:

• When site evacuation was announced at 10:07 a.m., the OSC manager

, decided to hold all maintenance teams in the OSC until accountability was complete.

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<* CR personnel changed from residual heat removal to system recirculation while an A0 was performing a valve lineup in the CCP

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room.. This operation would have caused a large increase in radiation L, levels in the CCP room' subjecting the A0 to potentially high l radiation exposur *

Tagging procedures do not provide adequate instructions for removing red tags during emergencies. 'At 12:41 p.m., the operations coordinator verbally directed the removal of red tags, and at 12:59 p.m. he directed the restoration of power to energize the

. switch gear. The later directive was implemented without coordinating with the MS or the TSC manager. As a consequence, the power was restored without consideration for the safety of emergency workers in the switch gear are * At 12:10 p.m. Team C reported finding a security officer in the protected area without dosimetry. At 12:33 p.m. an A0 reported security guards in a 48 mr/h field without cosimetr Two personnel exiting the radiologically controlled area removed their protective clothing incorrectly. One removed his dosimetry before removing his rubber gloves. The other demonstrated an incorrect manner of removing his potentially contaminated hoo The weaknesses observed in coordinating and controlling emergency repair teams are considered to be an open item. (445/8958-06; 446/8958-06)

No violations or deviations were identified in this program are . ' Security / Accountability (82301)(8)

The inspection team observed the security staff's response to the exercise. The tasks included accounting for personnel in the protected area during site evaluation, controlling access, and evacuating

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-9-The inspection team noted that accountability of personnel in the protected area after site evacuation was not documented. In addition, the evacuation of the owner-controlled area was not demonstrated. As discussed in the applicant's letter of July 14, 1989, this aspect of the 1989 exercise will be conducted in September 198 Until accountability of personnel in the potential area and evacuation of the' owner-controlled area are demonstrated, these issues are considered to be an open ite (445/8958-07; 446/8958-07)

No violations or deviations were identified in this program are . Medical Team (82301)(10)

The inspection team observed and evaluated the applicant's medical team as it performed tasks in response to the exercise. The tasks included responding to an injured and radiologically contaminated individua The inspection team noted that in contrast to the 1985 exercise, the emergency responders provided adequate medical assistance to the victim, and exercised proper radiological control No violations or deviations were identified in this program are . Applicant Self-Critique The inspection team observed and evaluated the applicant's self-critique for the exercise and determined that the process of self-critique involved adequate staffing and resources and involved the participation of higher management. The inspection team noted that the applicant was able to properly identify and characterize a number of open items and that many coincided with findings by the inspection tea No violations or deviations were identified in this program are . Open Items An open item is a matter that requires further review and evaluation by an inspector. Open items are used to document, track, and ensure adequate followup on matters of concern to the inspector. Open items are identified in paragraphs 4, 5, 6, 7, and 8 of this repor . Exit Interview The inspection team met with the resident inspectors and applicant representatives indicated in paragraph 1 on July 27, 1989, and summarized the scope and findings of the inspection as presented in this report. The applicant acknowledged their understanding of open items and agreed to examine them to find root causes in order to take adequate corrective measures. The applicant did not identify as proprietary any of the materials provided to or reviewed by the inspection team during this inspection.

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