IR 05000445/1990016

Insp Repts 50-445/90-16 & 50-446/90-16 on 900423-27.No Violations Noted.Major Areas Inspected:Operational Status of Emergency Preparedness Program Including Implementing Procedures,Changes to Emergency Facilities & Equipment

ML20058M235
Person / Time
Site:	Comanche Peak
Issue date:	08/02/1990
From:	Powers D, Terc N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20058M231	List: IR 05000445/1990016 ML20058M227
References
50-445-90-16, 50-446-90-16, NUDOCS 9008100021
Download: ML20058M235 (12)

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a, E 'l APPENDIX

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U.S. NUCLEAR REGULATORY COMMISSION-T REGION IV j

NRC' Inspection-Repert:

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50-445/90-'16 Operating. License: NPF-87

, '50-446/90-16 Construction Permit: CPPR-127- ,

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Dockets: 50-445 50-446  ;

Licensee: Texas Utilities (TV) Electric Skyway Tower

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400 North Olive, L.B. 81

• Callas,. Texas 75201-

' Facility Name: Co'manche Peak Steam Electric Station-(CPSES)

Inspection At: Glen Rose, Texas a

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Inspection Conducted: April 23-27, 1990 l h Inspector: . M* )

Nemen % Terc, Emergency Preparednes Analys Date

, (Regional Team Leader), Security an Emergency Preparedness Section

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.l Accompanying-Personnel: D. A. Schultz,'Comex Corporation

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Approved:- [ '

Dr. Dal~e.A. PoWiersg CM ef, Security and-8-8 "/8 Date

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Emergency Preparedn%ss Section Inspection-Summary Inspection: Conducted April 23-27. 1990 (Report 50-445/90-16;~50-446/90-16) i eAreas Inspected: Routine, unannounced inspection of the operational status of i the emergency preparedness program including followup on previous inspection findings; changes to the ei..argency plan and implementing procedures; changes to emergency. facilities,-equipment, instrumentation, and supplies; organization

'and management control; knowledge and performance of duties and protective ,

actions decisionmaking; and independent audits of the emergency preparedness program, i

9008100021 900806 PDR ADOCK 05000445 Q PDC

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Results: The licensee's-emergency preparedness program was found to be

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adequate to ensure an appropriate response should an emergency occur. However, within the areas inspected, one unresolved item was identified that. requires .

further NRC refie The inspectors found that.some key emergency personnel !

made errors in o. v)Fs not proficient with their responsibilities in accident

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detection, class;,rt t ion. protective action implementation, and dose

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assessmen The inspectors found thet the licensee-had promptly -and correctly implemented changes to the emetter.cy plan and implementing procedures. The inspectors noted that change; ce the licensee's organization were deemed as enhan:ements, q

~ The inspectors found that-the licensee's emergency response facilities were

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adequately maintained. The licensee's audit program of the emergency preparedness program was found to be in compliance,with the applicable regulatory requirement >

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-3-DETAILS

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f,- Persons Contacted

• T.' Hope, Site Licensing Engineer

• R. Beleckis, Emergency Planner t

• A. Scott, Vice President, Nuclear Operations

• M.'91evins, Manager, Nuclear Operations

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• J, Salsman, Manager, Emergency Planning

• J. Beck, Nuclear Engineer -!

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• F. Miller, Principal Quality Assurance Specialist

• B.-Gill, Technical Quality Assurance Primary Support Senior Engineer -

• E. Schmitt, Manager, Radiation Protection

• J. Walker, Engineering Manager, Operations OTHERS ,

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• E.=Ottney, Onsite Project Manager, CASE I o

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• Chamberlain,' Chief, Reactor Project Section B

• J. Wiebe, Chief, Reactor Project Section D

• R. Warnick, Assistant Director- for Inspection Programs, Comanche Peak

. Project Division, Nuclear Reactor Regulation (NRR)

• Denotes those present at the exit intervie , Followup on Previous Inspection Findings (92701) ']

(Closed) Deficiency (445/8515-07; 446/8512 07_): During the November 1985 J exercise, onsite monitoring teams took air samples near building walls, i but failed to properly label and retain samples. In addition, both access

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control and contamination control of personnel returning from potentially a contaminated areas to the operations support center (OSC) were inadequat Af ter the 1985 ' exercise, from April 15 to June 15, 1986, the licensee conducted radiation protection drills to ftrther develop techniques for retrieving,-labeling, and storing representative air samples. The licensee revised Procedure EPP-309, "Onsite/Inplant Radiological Surveys and Offsite Radiological Monitoring," and the procedure now refers to the y proper. health physics (HP) procedures that instruct them on how to- l

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retrieve representative samples. In addition, the licensee modified Procedure EPP-204, " Activation and Operation of the TSC," to establish contamination control' points as required at each emergency response

- facility including the OS (Closed) Improvement Item (445/8943-46; 446/8943-46)

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June 1989 appraisal, the inspectors suggested that it would be useful for '

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the licensee to prepare a matrix that would indicate what offsite agencies are to be trained, the subjects to be trained on, and the status of completion of that training. The licensee requested that the state representatives develop a matrix as outlined above. The state officials responded by letter dated February 13, 1990, that the present system meets state and Federal Emergency Management Agency (FEMA) requirements and that the matrix was not deemed necessar (Closed) Improvemens Item (445/8943-47; 446/8943-47): During the June 1989 appraisa', the inspectors suggested that the licensee review the ,

m;terials fnr emergency action level (EAL) training and revise them, as necessary, to e. ure that control room decisionmaking personnel fully undrstood the application of the " fire" EAL. During this inspection, the inspector noted that Procedure EPP+201, " Assessment o' Emergency Action Leveis, Emergency Classification, and Plan Activation," was revised to clarify the intent of the EAL decision diagram, and that training of shift supervisors and other personnel involved in using this EAL had been ,

completed (Closed) Open Item (445/8958-03; 446/8958-03): During the 1989 exercise, the inspection team observed that the licensee failed to provide specific instructions on how to update in progress notification message forms and how to issue dosimeters to emergency responders in the emergency operations facility (EOF). During this inspection, the inspectors noted that Procedure EPP-203, " Notifications," was revised to incorporate directions on how to upgrade in progress notification message forms, and that a new revision of Procedure EPP-206, " Activation and Operation of the E0F," provides instructions for issuance of personnel dosimeters to persons in the EOF in accordance with Procedure EPP-305, " Exposure Guidelines and Personnel Dosimetry During Emergency Conditions." Emergency Plan and Implementing procedures (82701-02.01) '

The inspectors noted that there has been only one revision to the emergency plan made after the last emergency preparedness appraisal performed on June 5-9, 198 The inrpectors noted that Revision 11 of the emergency plan for the CPSES was implemented on August 25, 1989, Revision 11 provided updates, corrections, additions, clarifications, and editorial changes. In addition, Revision 11 incorporated findings resulting from the appraisal, updated, and revised figures in text reflecting changes to the emergency response organization, and changed the corporate emergency management plan accordingl The inspectors noted that Administrative Procedure EPP-900,

" Administrative Control of Emergency Plan and Associated Procedures, Forms, and Workbooks," gave instructions to the staff on how to go about reviewing, approving, and distributing the emergency plan and emergency plan implementing procedures in accordance with the requirements of 10 CFR 50.54(q) and Appendix E. In the case of the plan revision, the

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-5-entire package was reviewed by the station operation review committee (SORC). Procedure EPP-900 includes a special form,

" Determination of a Decrease in the Effectiveness of the CPSES Emergency ,

Plan in Accordance with 10 CFR 50.54(q)," to determine if there has been a decrease in the licensee's response posture which is subject to SORC

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l review and approval. After the changes to the plan were approved and a determination was made that there has been no decrease in the effectiveness of the plan, control and distribution of the CPSES plan was done by TV Electric Licensing for the CPSES Final Safety Analysis Report (FSAR). l The inspectors noted that since June 1989, the licensee implemented 21 procedure revisions, and that all changes to emergency plan 1 implementing procedures were submitted to the NRC within 30 days, in ,

accordance with the requirements of 10 CFR 50 Appendix E.V. The !

inspectors also noted that revisions to procedures, unlike emergency plan changes, are not distributed by TV Electric Licensing, but by Administrative Service No violations or deviations were identified in this progrtm are . Emergency Facilities. Equipment, Instrumentation, and Supplies *

(8270FD2.02)

The inspectors toured key emergency response facilities (ERFs) and equipment at CPSES to verify that they were adequately maintained, anc to determine if changes made since the last inspection were technically adequate,. met NRC requirements, met licensee commitments, were appropriately incorporated into the emergency plan anc' ii.r.c Min; procedures, and had no adverse effect on the licensee's emergency readines The' inspectors noted that ERFs were adequately maintained and that l equipment and supplies were in place and in accordance with procedural inventories. No changes to facilities, equipment, instrumentation, and supplies since the last NRC inspection adversely affected the licensee's emergency response posture. All changes reviewed were technically adequate and were appropriately incorporated into the emergency plan implementing procedure i No violations or deviations were identified in this program are . Organi7ation and Management Control (82701-02.03)

The inspectors reviewed tha administration of the licensee's emergency

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preparedness program with respect to the requirements of 10 CFR 50, Appendix E, paragraph IV.G, and the criteria contained in NUREG-0654, l Sections IIA and The inspectors reviewed responsibilities assigned for the administration of emergency planning, including the authorities given to the emergency

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-6-planning manager and the selection and qualifications of the emergency planning staff. The inspectors held discussions with members of the !

staff, and reviewed individual qualifications and their awareness and participation-in current daciopments in the emergency preparedness are .

The inspectors noted that individuals belonging to the emergency planning .

staff were the same as during the appraisal conducted in June 1989. No additions have been made to the licensee's emergency planning organizati n except for the addition of a new secretarial clerk. The inspectors also noted that the staff continued to participate in current developments in the emergency prepraedness are The inspectors also noted that the structure of the emergency response organization remained unchanged from the organization in place during the June 1989 appraisal, except that a new position (radwaste personnel) was '

adde This position is filled continuously and reports to the shift superviser at the declaration of a notification of unusual event (NOVE). .

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Although the organization essentially remained unchanged, the overall TV Electric. organization was changed such that, the emergency planning r manager reports directly to the manager of nuclear operations support who, i in turn, reports to the vice president - nuclear operations. The inspectors viewed this as a positive change because in the past the ;

emergency planning manager reported to the manager, administrative support who was two steps removed from the vice president, nuclear operation The inspectors noted that the depth of the emergency response organization was favorably augmented by the incorporation of additional personnel in some key positions. For example, previously the licensee only had two persons qualified to perform the EOF manager and the logistical support center manager positions; however, the licensee has increased coverage to four and three qualified persons, respectivel ,

The inspectors noted that the responsibilities of the shift technical advisor (STA) were modified so that he no longer performs dose assessment >

during an emergency, and his present duties are in accordance with the guidance provided in Appendix C of NUREG-073 No violations or deviations were identified in this program are . Knowledge _and performance of Duties (82206) and Protective Action Decisionmaking (82202)

The inspector reviewed the emergency preparedness training program at CPSES and interviewed emergency responders to verify that the training program was established and maintained in accordance with 10 CFR 50.47(b)(15); to determine whether the amount and type of training and retraining received by emergency responders was adequate; and to determine whether key decisionmakers were proficient in the performance of their duties and responsibilities during a simulated accident scenari In addition, the inspectors verified that changes to the program since the last inspection were incorporated into the training program and that key

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emergency responders were aware of such changes, understood them, and had been properly trained to implement the Furthermore, the inspectors verified whether authorities and responsibilities were clearly delineated ,

for assessing accident conditions and making protective action i recommendations (PARS), and determined if key decisionmakers from the control room (CR), technical support center (TSC), and EOF were capable of implementing timely onsite and offsite corrective actions. The inspectors tested the licensee's ability to understand the relationships between plant conditions (including core) and possible onsite and offsite consequences.

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In order to accomplish the above, the inspectors interviewed instructors and other members of the emergency planning staff, and reviewed a sample of training records consisting primarily of records of persons interviewed. They also conducted interviews with key members of the '

licensee's emergency response organizatio The inspectors determined that specialized emergency preparedness training had been conducted for emergency responders, and that lesson plans were in place and tests were given commensurate with the materials presented.- In addition, the inspectors noted that part of the training consisted of practical, hands-on appll'.ations. However, at the time of this '

inspection, the licenser. only had one test per lesson plan and a training data base containing , elected materials to compose other equivalent alternate tests was lacking. The licensee representatives acknowledged the need for a data base with attached weights depending on the level of difficulty of the questions in order to develop alternate tests for emergency responders. The licensee representatives elso stated that they intended to develop alternative tests and examinatior.s for each lesson plan to expand and confirm the validity and reliability of their testing '

and qualifications progra In addition to the above, in order to confirm the proficiency of key emergency responders, the inspectors conducted six separate 2-hour interviews with selected members of the licensee's emergency response organization. Those selected included four of the six CR shifts, and one team each from the TSC and the EOF. The CR shifts consisted of the shift supervisor (emergency coordinator [EC)), unit supervisor, reactor operator, STA, and a health physics technician. The TSC and EOF teams consisted of the facility manager EC, operations coordinator, engineering coordinator, and radiological assessment coordinator. The inspectors asked decisionmakers technical questions related to their specific duties, responsibilities, and functions during an emergenc The irspectors presented each team with an accident scenario, which requi"ed operational and radiological assessments, classification, notif" cations, and formulation of PARS to offsite authoritie It was not intenc'ed to test the abilities of the teams to mitigate the acciden (Prior to the interviews, the inspectors verified that the scenario details were applicable to CPSES.)

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r l In the scenario, the inspectors figuratively placed the TSC and EOF groups ,

an hour late into the scenario and requested them to validate the activities of the shift supervisor for the preceding hour, and to take .

control of emergency management for the remainder of the scenario. The '

interviews were performed on an "open book" basis, with guidelines established before the interview to clarify the materials presented to the interviewees, and their expected activities.. During each of the i interviews, at least one licensee representative from the emergency ;

planning department was presen '

The scenario presented during walkthroughs was as follows:

Initial Conditions - Unit I was at 100 percent power, and connected to the !

grid. The plant had been operating at 100 percent power for over 90 days, and the core was approaching end of life. Unit 2 was not fueled, and could not provide any electrical support for the mitigation of the even The positive displacement coolant charging pump was out of commission and undergoing repairs. It was expected that 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> would be needed to i complete those repairs. The block valve to the pressurizer power operated l relief valve (PORV) 455A was shut due to PORV leakage. The scenario took j place during the early morning at shift change. There were a large number '

of people in the 810-foot level making their way to work and watch stations at that tim Weather - Light winds were at 5 mph from 172 degrees, stability Class The forecast predicted overcast skies, no precipitation, and no significant change in weathe Event - CR personnel heard a loud explosion followed by a continuous loud roar. Numerous alarms and indications in the CR including turbine trip, reactor scram, and safety injection occurre Nuclear Indications - Although power initially trended quickly to zero, there was evidence that power returned to 10 percent about 10 seconds af ter the trip, then decayed slowly towards zero over the next 30 second The control rods bottomed following the reactor scra Primary Indications - There was a rapid decrease in primary pressure to 350 psig. The pressurizer was emptied in 7 seconds, but then there was ;

evidence of some pressurizer level restoration after about 3 minutes due ~

to nominal flow from the safety injection (SI) system. The primary temperature dropped to 435'F. Pressure and temperature were increasin ,

The SI accumulators emptied to about 50 percent. The containment isolated normall Secondary Indications - The steam generator (SG) levels rapidly went to the bottom of their indicating rang The pressures and levels in all SGs reached zero in about 35 seconds. All main steam isolation valves (MSIV)

went to midpositio The main feed isolated normally. The auxiliary t feedwater (AFW) flow was normal from two electric pumps, but the turbine driven pump provided no flo o . .

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. Mis 011aneous Indications - The fire protection high-temperr.ture alarm annunciators alarmed in the turbine building. Security pe'sonnel reported extremely large amounts of steam coming from all areas of the turbine building with damage to the building. Several loud, fr',ghtened reports on the Gaitronics were received. One stated, " Major steaa leak in the Unit I turbine building, some casualties, mcny people injured by steam scalding and burns." The Radiation Monitor RM-11 was alarming. The electrical penetration room containment area radiation monitors (ARMS) shnwed 35 mr/h and were increasing. All other ARMS were trending u One Hour Into Event - There was no auxiliary feedwater flow to SGs wnile personnel were performing rescue attempts for 22 survivors in the turbine building. There was degraded charging (total flow was 100 gpm), with degradcd pressurizer PORV performance; therefore, primary system pressure was at 2400 psig while floating on safeties that were opening at infrequent intervals. The pressurizer level was at 37 percent with a bubble in the reactor vessel. The water level was, however, above top-of active fue The containment pressure was 1.5 psig and its temperature was 185*F. The high-range radiation monitor read 1.0 E +4 R/h. The main steam line radiation monitors trended upwards, and read 950 pCi/c Results From Offsite Monitoring Teams - Field results from survey teams obtained in the centerline of the plume, downwind at the site boundary, were 1.0 E-4 uC1/cc gross iodine at breathing height above ground, and 60 mr/h whole bod The inspectors made the following strength and weakness observations of the licensee teams' responses to the given scenario:

Strengths J

Two of the four CR radiation protection technicians proficiently ran-dose assessment calculation :

In general, CR teams exhibited a good knowledge of recognizing i accident conditions of the baseline PARS (in the absence of dose assessment information) and in the formulation of PARS (based on dose l

assessment and plant condition information), and of issuing notification messages in a correct and timely manne ,

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• The TSC and EOF teams promptly and correctly classified accident

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conditions, prepared PARS based on baseline and dose assessment i information, and were efficient in the preparation of notification p messages. They also exhib Med a good knowledge of dose assessment L computer use, including the backfitting of field dat Weaknesses

• An EC failed to implement the EPP-109 procedure or checklist for his duties and responsibilities, even after prompting. A CR team was

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sluggish in carrying out the E0P response to red critical safety function (CSF) of loss of heat sink. Prompting was required to get ;

the team to follow the loss of secondary heat sink E0 ;

An EC made the correct emergency classification.(e.g., Alert) based l on subjective reasons, rather than on the objective evidence :

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available (i.e., right classification, but wrong reason). Two CR teams were weak on their understanding of the difference between EAls ;

and emergency classifications. One CR team erroneously considered '

EALs and emergency classifications as synonymou *

An EC provided no guidance to a dose assessment assessor concerning assumptions to be made in the difficult release path problem. On another CR team, in assisting an HP dose assessor, the STA suggested the use of an illogically high release rate for the oostulated conditions that then resulted in a significantly higher than reasonable dose assessment in the field. Another CR team dose assessor performer was not fully proficient in computer-aided dose -l assessment and did not know the magnitude of the radiological sources I or the meteorological information that was available for performing dose assessments. A CR radiation protection technician performing the dose assessment function required approximately 35 minutes to obtain dose assessment values due to lack of proficiency with the hardware and software. The TSC radiological assessment coordinator was weak in correlating the extent of radiological problems to instrumentation readings (e.g., correlation of containment high-range radiation monitor to airborne contamination levels in order to calculate unmonitored release).

When asked to list duties and responsibilities that were not .

delegatable, one CR team did not remember PAR formulatio '

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Two CR teams were unable to recall that the written procedure, as .

well as the computer software, allowed them to process gross iodine !

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field sample results into doses. A CR team mandated evacuation of the radiologically controlled areas (RCAs) and the protected area (PA). However, it would have been appropriate to evacuate areas associated with the turbine building, and order personnel assembly :

for accountability to determine missing persons in the turbine building. An EC was unsure of what protective actions should be implemented for site personnel at an Alert classification, how to perform an accountability for potentially missing personnel, and what responses would be followed by various site personnel automatically at the Alert declaration on the Gaitronics. A CR team was weak on their understanding of the differences between emergency planning zones (EPZs) and sectors (22.5 degree compass arcs).

Although not considered training weaknesses, the inspector noted the following hardware problems during the interviews. Paper was not available for the TSC dose assessment computer printer. Also, there was both a CR and an EOF computer problem in dose assessment. A steam line

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-11-break with SG tube leak required that the steam pressure input be to the nearest 100 psia. The first answers the teams obtained were wrong, and a  ;

do-loop problem aross that required rebooting of the computer and starting >

ove Summary of Interview Findings l

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10 CFh 50.47(b)(15) states that radiological emergency response training shall be provided for those who may be called to assist in an emergenc Section 13 of the licensee's emergency plan requires specialized training ,

and retraining for personnel in the station's emergency response organization as specified by Procedure TRA-105, " Emergency Preparedness Training," and to keep personnel informed of changes in the emergency plan and implementing procedures. Paragraph 6.1 of Procedure TRA-105 states  ;

that the objective of the emergency preparedness training program is to provide emergency organization personnel with the knowledge and skills ,

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The groups interviewe performed well and took necessary actions in determining emergency classifications and making prompt notifications and PARS in order to protect the health and safety of the public offsit However. there were isolated instances where interviewees' performance indicated a need for more emergency preparedness training. Specifically, some interviewees were not always able to promptly detect and classify .

emergencies, and to implement proper protective measures  :

(e.g., accountability of personnel), including performance of dose assessment calculations. These training deficiencies are considered to be an unresolved item pending further NRC review to determine what type of enforcement action, if any, is appropriat (445/9016-01; 446/9016-01)

Observation:

All CR teams were sluggish in responding to the fact that there was an AFW to hot-SG to main-steam-line break that continued to allow personnel in -

the turbine building to be injured by the stea Core cooling was available in lieu of SGs, and there was no threat to the public at the -

time of decisionmaking. The scenario compelled the shift supervisor to decide whether or not to use the administrative procedure to deviate from emergency operating procedures (EOPs) based on the uniqueness of the situati'n at hand. One CR team decided to reduce the amount of water being 4 to the SGs to a minimal amount of 100 gpm AFW flow in order to reduce mermal shock when water flow would be restored. Therefore, these teams c11 not take adequate actions to protect the health and safety of those workers. After prompting, the teams had no hesitation in using the guidance of 10 CFR 50.54(x), and licensee's operations department Procedure ODA-407, " Guideline on Use of Procedures," in order to deviate from the E0Ps and mitigate plant personnel injurie No violations or deviations were identified in this program are r I ,.

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I -12-7. Independent Audits (82701-02.05)

The inspector e::amined independent and internal audit reports for the licensee's emergency preparedness program since the last inspection to determine compliance _with the requirements of 10 CFR 50.54(t), and to determine whether the licensee's commitments and protective actions were

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implemented in a timely manner. The inspector also examined the licensee's audit program to determine if it had a corrective action system for deficiencies and weaknesses identified during drills and exercise The inspector examined the. licensee's audit program to determine whether appropriate means existed to record and follow up each item until I

corrective actions were complete The inspector reviewed the annual quality assurance audit of the emergency preparedness program to see if it met the requirements of 10 CFR 50.54(t).

The independent review was performed during the period March 19-30, 1990, by a certified lead auditor, and five certified auditors. This review included the drills and exercises that took place since the June 1989 appraisal of emergency preparedness by an NRC tea The March 1990 audit also included organization and training, emergency plan and implementing procedures, emergency communications, public education and information, state and local interfaces, emergency facilities and equipment, radiation exposure control, medical support, and exercise and drills. The auditors identified seven deficiencies requiring corrective actions and three observations, which demanded a repl In each case, responsibilities for corrective measures were identified. The inspector noted that the scope and depth of the audit appeared to meet the requirements of 10 CFR 50.54(t).

I No violations or deviations were identified in this program are . Observations Observations the inspector discussed with licensee representatives are '

discussed in paragraph 6 of this report. The observations are not '

violations, deviations, unresolved items, or open items. Observations are i identified for licensee consideration as program improvement items, but have no specific regulatory requirement.

L Exit Interview The inspectors met with licensee, CASE, and the NRC representatives, as L

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indicated in paragraph 1, on April 27, 1990, and summarized the scope and findings of the inspection as presented in this repor The licensee acknowledged their understanding of findings and agreed to examine them to find root causes in order to take adequate corrective measures. Licensee management confiriaed their commitment to develop alternate tests and examinations for each lesson plan ustd in training emergency response

, personnel. The licensee did not identify as proprietary any of the materials provided to, or reviewed by, the inspectors during this inspectio I