IR 05000445/1997004
| ML20136C008 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/05/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20136B999 | List: |
| References | |
| 50-445-97-04, 50-445-97-4, 50-446-97-04, 50-446-97-4, NUDOCS 9703110232 | |
| Download: ML20136C008 (24) | |
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1 ENCLOSURE 2 J
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U.S. NUCLEAR REGULATORY COMMISSION j
REGION IV
Docket Nos.:
50-445
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50-446
. License Nos.:
NPF-87 NPF 89 Report No.:
50-445/97-04 50-446/97-04 i
Licensee:
TU Electric Facility:
Comanche Peak Steam Electric Station, Units 1 and 2
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Location:
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Glen Rose, Texas
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Dates:
February 10-14,1997 i
Inspectors:
Gail M. Good, Senior Emergency Preparedness Analyst Thomas H. Andrews, Jr., Radiation Specialist
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Approved By:
Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety ATTACHMENTS Attachment 1:
Supplemental Information Attachment 2:
Scenario Narrative Summary 9703110232 970305 PDR ADOCK 05000445 G
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EXECUTIVE SUMMARY i
Comanche Peak Steam Electric Station, Units 1 and 2 NRC Inspection Report 50-445/97-04:50-446/97-04 This routine, announced inspection focused on the operational status of the licensee's emergency preparedness program. Emphasis was placed on changes that had occurred since the last routine emergency preparedness inspection.
Enaineerina No discrepancies were identified during a review of the Updated Final Safety
Analysis Report commitments (Section E2).
t Plant Support No emergency event had been declared at the site since the last routine emergency
preparedness inspection. Reviews of event notifications provided to the NRC operations center did not identify any events that appeared to have been misclassified (Section P1),
Essential emergency f acilities, equipment, instrumentation, and supplies were
maintained in a state of operational readiness. Additional attention to detail was i
needed related to forms control and maintaining telephone operability (Section P2).
I The program for updating the emergency plan and procedures was good.
- Emergency plan provisions for periodic reviews of offsite agreement letters were unclear and inconsistent with procedural requirements. A noncited violation was identified for failure to conduct an annual review of the emergency action levels with offsite authorities (Section P3).
Performance of the shift operating crews was less than satisfactory in several
areas. An exercise weakness was identified for f ailure of the first crew to make a timely protective action recommendation. A violation was identified for failure to correct a previously identified exercise weakness concerning protection of plant personnel. Logkeeping, teamwork, and forms completion were identified as areas for improvement. Post-walkthrough critiques were generally thorough and self critical (Section P4).
The training program was implemented in accordance with procedures; however,
the results of interviews (and the simulator walkthroughs discussed in Section P4 above) indicated that the program was not fully effective (Section PS).
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-3-Emergency planning managernent and staffing levels were sufficient to implement
the program. Significant changes to the emergency response organization were made in an orderly and controlled manner (Section P6).
The licensee's audits of the emergency preparedness program were consistent with
regulatory requirements and commitments to the NRC. An area for improvement was identified concerning emergency plan procedure review / audit responsibility independence (Section P7.1).
A recent self assessment was thorou0h and effectively identified areas in need of
corrective action (Section P7.2).
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-4-Report Details Ill. Enaineerina E2 Engineering Support of Facilities and Equipment A recent discovery of a licensee operating their facility in a manner contrary to the Updated Final Safety Analysis Report description highlighted the need for a special l
focused review that compares plant practices, procedures, and/or parameters to the
Updated Final Safety Analysis Report descriptions. While performing the inspections discussed in this report, the inspectors reviewed the applicable portions
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of the Updated Final Safety Analysis Report that related to the areas inspected. The inspectors verified that the Updated Final Safety Analysis Report wording was consistant with the observed plant practices, procedures, and/or parameters, j
IV. Plant Support P1 Conduct of Emergency Preparedness Activities i
a.
Inspection Scoce (93702)
No emergency event had been declared at the site since the last routine emergency
preparedness inspection. Reviews of event notifications provided to the NRC operations center did not identify any events that appeared to have been misclassified.
P2 Status of Emergency Preparedness Facilities, Equipment, and Resources a.
Insnection Scone (82701-02.02)
The inspectors reviewed the status of essential' emergency facilities, equipment, instrumentation, and supplies to ensure that they were maintained in a state of operational readiness.
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Observations and Findinas Control Room The inspectors observed the number and location of respirators (self-contained breathing apparatus type) stored in the control room. There were six breathing air bottles with face pieces stored in storage cabinets at various locations within the control room. This was consistent with the final safety analysis report information regarding respirator availability within the control roo.._ __ _ _ _.. _ _. _ _ _
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-The inspectors observed that these respirators were fitted with medium-sized face pieces. There were no other size face pieces in the immediate area. In response, the licensee stated that medium-sized face pieces fit a large percentage of personnel qualified to ' wear respirators and that the self-contained breathing apparatus type respirators used were positive pressure; therefore, reducing the risk if a poor seal were obtained. However, the licensee recognized that qualification for wearing a respirator was based upon a specific face-piece type and size. Once identified by the inspectors, the licensee placed small and large face pieces in the immediate area
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The inspectors questioned the source of power for the dose assessment computers.
Based upon this discussion, the inspectors learned that if the normal power supply was lost in the control room, the dose assessment computer would not operate.
The licensee stated that the computers in the technical support center were on an emergency power supply and would be used as the backup method. This meant that the shift technical advisor would have to go to the technical support center to perform dose assessment calculations.
During the facility walkthrough, the inspectors questioned the shift technical advisors regarding the ability to perform dose assessment calculations in the event of a loss of offsite power. One of the two individuals stated that the computers in i
the technical support center and emergency operations facility could be used to perform the calculations..This response was satisfactory.
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The other individual stated that the responsibility would have to be transferred to l
the technical support center or emergency operations facility. When asked what
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they would do if these facilities were not staffed, the individual began looking for a L
method to perform the dose assessment manually. A manual method did not exist.
L The inspectors concluded that the shift technical advisor was not aware that
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relocating to the technical support center to perform the calculations was an option, j
The inspectors considered this an area for improvement.
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Remote Shutdown Panej
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The inspectors toured the remote shutdown panels for both units and conducted a l
telephone test from each unit. The Unit 1 remote shutdown panel test was successful, but it was difficult to hear due to the noise in the area (running motor l
generator sets). The inspectors noted that during most conditions when the panel l
would be used, the motor generator sets would not be running, thereby,' eliminating the noise.
l The inspectors discovered that the Unit 2 remote shutdown telephone was disconnected. Tne licensee investigated the condition and determined that the i
telephone had been inoperable since August 1996 when the telephone line was
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l reassigned for outage support..The telephone was reconnected expeditiously. The
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licensee stated, that had this panel been needed in an emergency, radios could have been used to communicate to the Unit 1 panel. From there, information could have
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been relayed to the other emergency f acilities. The inspectors concluded there was
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a need to improve attention to detail.
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The inspectors also found a communications workbook in the table drawer provided i
for the Unit 1 remote shutdown panel operator. This information only document
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was dated 1990. The workbook was the predecessor for the current position assistance document. The licensee properly removed the dacument to prevent j
possible confusion in the event of an emergency.
The licensee's individual who accompanied the inspectors observed that the cage
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surrounding the remote shutdown panel for Unit 2 did not completely enclose the l
panel. There was a gap where someone might be able to squeeze between the
cage arid the panel to gain access to the panel area. This area was not a security
area, but did require authorization from operations to enter the area. This observation was provided to the shift manager in the control room for further
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j review. This resp' nse was considered appropriate.
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-Technical Succort Center The technical support center and the control room shared the same ventilation envelope. The inspectors confirmed through discussions with the licensee that the ventilation system contained means to filter the air brought into the facility and to isolate the facility. The process for shifting the ventilation from isolation mode to recirculation mode was reviewed. The process was consistent with the design presented in the final safety analysis report.
During a tour of the technical support center, the inspectors observed forms stored in a rack. These forms were placed in the rack for use by emergency response personnel. The forms rack was checked to determine if a recently revised form was included. The rack contained copies of the superseded version of the form.
The licensee discovered that the updated procedure containing the new version of the form had been placed in the procedure books but that the forms had not been updated. According to the licensee's procedure for updating forrns, the individual assigned the copy of the procedure could store forms as they determined appropriate and that they were responsible for discarding superseded forms and replacing them with the current version in this particular case, the change out of the forms was not performed on the day the new form became effective.
The inspectors reviewed the changes implemented on the form. Based upon this review, the changes would not have impacted upon the ability of the licensee to respond to an event. However, the inspectors pointed out that this may not always be; the cas a e
The licensee immediately discarded the old forms and replaced them with the current copies of the form. In addition, the licensee revised the procedure revision checklist to add a statement for the preparer to ensure that revisions of revised forms were placed in the form racks in the emergency response facilities on the effective date of the change. The licensee also indicated that they were reviewing potential alternatives to using form racks. The licensee's response was prompt and thorough.
The inspectors tested selected NRC telephone circuits in the technical support center. The protective measures counterpart link was found unplugged (inoperable).
The licensee promptly corrected this problem. The reactor safety counterpart link had a busy signal that affected the voice transmission ability of the link that was promptly reported to the NRC operations center.
Onerations Suocort Center The operations support center was being used as a work area by the PROMPT team. This team was responsible for providing expedited maintenance support for operations on an on-going basis. The licensee stated that regular drills had been conducted to ensure that the operation of this facility was not compromised by the use of this area as a work area. The area appeared to be capable of supporting its intended function.
The inspectors questioned the habitability of the operations support center. The licensee stated that in the event that the operations support center became uninhabitable, alternate assembly areas outside of the building could be used. If these were inaccessible, the staff could be relocated to the technical support center. The licensee's responses were acceptable.
Emeraency Ooerations Facility The inspectors confirmed through discussions with the licensee that the ventilation system contained means to filter the air brought into the facility. The inspectors observed the location of the gamma shield door at the entrance to the facility. The inspectors reviewed the process the licensee used to activate the facility, facility staffing, and accountability / access control. The stated processes were consistent with the f acility description in the emergency plan and procedures.
The locations of communication equipment, especially the location of NRC telephones, were observed. The inspectors noted that the telephones were not labelled regarding their purpose. This was also noted in the technical support center. The inspectors determined that because the individuallines were intended to have different uses, without labelling, it would be difficult for site team members to establish the communication links in a timely manner after arrival at the site.
This was discussed with the licensee, who agreed to label the telephones with the appropriate use designation.
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The inspectors observed the location and placement of licensee procedures and
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position assistance documents. Based on a selected sample of documents reviewed, the inspectors ensured that the latest revisions were in place.
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The inventory of one of three field team kits was inspected to ensure that the items I
on the inventory were present and in usable condition. The kits contained silver-i zeolite cartridges for air samplers. The cartridges were in sealed bags and did not have a shelf-life identified on the cartridge. The inspectors reviewed the licensee's process for storage and use of silver-zeolite cartridges and confirmed that it was consistent with the manufacturer's recommendations.
During the inspection of the storage of respirators at the emergency operations facility, the inspectors noted that there were only medium-sized face pieces for the self-contained breathing apparatuses (see control room section above). The licensee added small and large face pieces for the existing respirators, i
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Conclusions Essential emergency facilities, equipment, instrumentation, and supplies were j
maintained in a state of operational readiness by the licensee. Additional attention I
to detail was needed related to forms control and maintaining telephone operability.
P3 Emergency Preparedness Procedures and Documentation a.
insoection Scope (82701-02.01)
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The inspectors used Inspection Procedure 82701 to determine whether the emergency plan and implementing procedures were maintained. Specifically, the '
inspectors evaluated the following areas:
Verified that the emergency plan was reviewed annually and that changes
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were submitted in accordance with 10 CFR Part 50, Appendix E.V Verified that emergency plan implementing procedures were reviewed e
biennially and that changes were submitted in accordance with 10 CFR Part 50, Appendix E.V Reviewed the emergency plan and implementing procedures for continuity
and completeness Verified annual reconfirmation of offsite organization letters of agreement
Verified that emergency action levels were reviewed annually with state and
local authorities
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Observations and Findinos
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The inspectors reviewed records pertaining to emergency plan and implementing
procedure review and submittal. The records showed that the emergency plan and j.
procedures were reviewed at the required frequencies and that changes were submitted to NRC within regulatory time limits. In addition, the emergency planning
staff had developed additional controls to ensure consistency between the
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emergency plan procedures and position assistance documents. The inspectors
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concluded that the licensee had a good program for updating its emergency plan
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and procedures,
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l While reviewing emergency plan procedures, the inspectors noted that the terms l
emergency planning zone and emergency response zones were inconsistently used i
j in Emergency Plan Procedure 304, " Protective Action Recommendations,"
Revision 15. The inspectors concluded that the inconsisterit use of the two terms
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could cause confusion during protective action recommendation formulation, in response, the licensee initiated a change to the procedure to correct the terms.
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j Records documenting reviews of offsite letters of agreement were reviewed and i
found complete. The documents showed that the reviews had been conducted
l annually, in accordance with Emergency Plan Procedure 100, " Maintaining i
Emergency Preparedness," Revision 0; however, the inspectors noted that the
requirement to perform an annual review of the agreement letters was not clearly i
captured in the emergency plan. As a result, a reviewer could infer that the agreements were not reconfirmed periodically, in response, the licensee stated that j
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l the annual requirement would be clarified in the emergency plan.
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Prior to discussions with the licensee concerning the.10 CFR Part 50, Appendix
E.IV.B, requirements to: (1) discuss and obtain state and local agreement on
emergency action levels and (2) review the emergency action levels with state and
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local authorities on an annual basis, inspectors reviewed a self assessment that was L
conducted in January 1997 (see Section 7.2 below). The self-assessment team p
identified that the emergency acticn levels had not been reviewed with the offsite authorities in 1996 as required by Appendix E.IV.B. One Form 97-113 was issued i
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on February 3,1997, to prompt corrective actions, immediate corrective actions j
were taken to establish compliance. Additionallong-term actions were not
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complete.
While reviewing this matter, the inspectors noted that the Appendix E.lV.B requirements were not captured in the emergency plan or Emergency Plan i
Procedure 100. The licensee indicated that the long-term corrective actions
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included establishing written controls to ensure that the Appendix E requirements i.
were accomplished in the future.
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The f ailure to review the emergency action levels with the state and local authorities
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was identified as a violation of 10 CFR Part 50, Appendix E.IV.B. The violation was i
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licensee identified, nonrepetitive, corrected within a reasonable time, and nonwillful.
Accordingly, the violation is being treated as a noncited violation, consistent with
Section Vll.B.1 of the NRC Enforcement Policy (50 445/9704-01;
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i 50-446/9704-01).
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Conclusions i-l The program for updating the emergency plan and procedures was satisfactory.
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Emergency plan provisions for periodic reviews of offsite agreement letters were j
unclear and inconsistent with procedural requirements. A noncited violation was
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identified for failure to conduct an annual review of the emergency action levels j
with offsite authorities.
P4 Staff Knowledge and Performance in Emergency Preparedness i-4~
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Insoection Scoce (82701-02.01)
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The inspectors conducted walkthroughs with two operating crews using a dynamic simulation on the plant specific control room simulator. The inspectors assessed
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the ability of control room teams to classify events accurately, perform the required
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notifications in a timely manner, perform offsite dose assessments, and make i
adequate protective action recommendations. The scenario consisted of a sequence of events requiring an escalation of emergency classifications, culminating in a l
general emergency. A narrative description of the scenario is contained in Attachment 2 of this report. Each walkthrough lasted approximately 90 minutes.
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Observations and Findinas Crew 1
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With the exception of the following areas, emergency preparedness activities demonstrated by the first crew were timely and correct.
First, Crew 1 failed to make a timely offsite notification and protective action recommendation following the general emergency declaration. Step 4.1.2.1 of Emergency Plan Procedure 203, " Notifications," Revision 13, and Step 4.2.2 of Emergency Plan Procedure 304, " Protective Action Recommendations,"
Revision 15, required that notifications and protective action recommendations be communicated within 15 minutes. During the walkthrough, the shift manager / emergency coordinator declared a general emergency at 9:31 a.m. Offsite
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agency notifications, including a protective action recommendation, were initiated at 9:51 a.m. (20 minutes later).
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I The inspectors observed the following sequence after the general emergency
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declaration. The notification form was initially approved by the emergency coordinator with no protective action recommendations, Shortly thereafter, the emergency coordinator changed the form to indicate that protective action recommendations would follow. Then the emergency coordinator decided to delay i
notifications until protective action recommendations could be determined. After i
reviewing Emergency Plan Procedure 304, the emergency coordinator determined that five zones should be evacuated (2A and those in Sectors RAB). The protective action recommendations developed by the emergency coordinator were not consistent with those specified in Emergency Plan Procedure 304 for the scenario
plant conditions (more severe than the procedure).
Following the decision to evacuate the five zones, the emergency coordinator
changed the form again and gave it to the communicator to initiate the notifications to the simulatec' ofts!!e agencies. Twenty minutes had elapsed since the general J
emergency dec aration. While still online with the simulated offsite agencies (but after informing them of the need to evacuate the five zones), the emergency coordinator changed the protective action recommendations to only evacuate i
Zone 2A (consistent with the procedure) and had the communicator inform the offsite agencies of new, reduced protective action recommendations. By this time, the form was barely readable due to the number of changes. Fortunately, the emergency coordinator decided to rewrite the form prior to facsimile transmittal.
The inspectors concluded that the emergency coordinator did not demonstrate confidence or full familiarity with established processes or procedures for determining protective action recommendations to the extent that it resulted in an untimely notification and protective action recommendation. Moreover, had this been a real emergency, the licensee's credibility with the offsite agencies could have been diminished given the display of indecisiveness.
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The f ailure to make a timely notification and protective action recommendation was identified as an exercise weakness due to the potential for offsite impact (50-445/9704-02:50-446/9704-02),
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Second, logkeeping by Crew 1 was less than expected. The shift manager / emergency coordinator and several others used unofficial methods (scratch paper, hand) to capture important information. The licensee explained that
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this practice was acceptable if the information was transferred to an officiallog.
The inspectors did not see this transfer occur. The lack of officiallogs could affect event reconstruction following an actual event.
Finally, the communicator logged time, when notification messages were complete, in the space provided at bottom of the notification form. Logging the end time, rather than the start time, could be misconstrued during event reconstruction.
Since the official notification time is when the notifications are initiated, it might appear that the notifications were not made within 15 rninutes, l
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, Crew 2 With the exception of the following areas, emergency preparedness activities demonstrated by the second crew were timely and correct.
First, the shift technical advisor and unit supervisor inappropriately delayed sharing event classification status with the shift manager. Specifically, the two recognized that an alert would be required if the fire was not extinguished within 15 minutes.
This determination was not shared with the shif t manager for 6 minutes. By the time the shift technical advisor discussed the potential event classification with the shift manager, the fire had not been extinguished for 14 minutes (1 minute prior to meeting the emergency action level criteria). The shift manager was preparing to declare an unusual event based on reactor coolant system leakage. The inspectors concluded that teamwork could be improved.
Second, a si'e evacuation was not ordered in a timely manner following the site ain ; umergarcy declaration. Step 4.1.1.3.1 of Emergency Plan Procedure 314,
" Evacuation and Accountability," Revision 6, required a site evacuation upon declaration of a site area or general emergency. The site area emergency was declared at 12:16 p.m.; the site evacuation process was not initiated until 12:42 p.m. (26 minutes later).
To determine timeliness, the inspectors used about 15 minutes as a reasonable timeframe, since it was consistent with the requirements for notifying offsite authorities of the need to implement public protective actions, and, therefore, could be reasonably applied to protection of plant personnel. Moreover, this timeframe was consistent with Appendix M of the licensee's emergency plan (evacuation time estimate) which specified that 16 minutes was required to notify plant personnel.
Pertinent to this matter, Step 4 of the site area emergency task list in the shift manager's position assistance document stated, " Consider, if conditions warrant, a site evacuation." This statement was repeated at the top of the site evacuation tab (referenced in the task list). However, a caution / note block followed which stated,
" Order a Site Evacuation at a Site Area or General Emergency unless this would present a greater danger to site personnel. (i.e., inclement weather, security threat, etc.)" The inspectors observed that the shift manager reviewed the site area emergency task list, turned to a tab in the binder, pulled an announcement script from the binder, and then notified plant personnel of the site area emergency declaration.
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In addition, the computer-generated notification form prepared for the site area emergency contained a preprinted message indicating that a site evacuation was being conducted, however, the shift manager deleted the comment since a site evacuation was not ordered. it is also important to note that the form stated that there was no release in progress, therefore, a radiological condition did not exist.
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During the post-walkthrough debrief, the emergency preparedness manager asked
about the circumstances surrounding the site evacuation call, such as, was the shift i
manager distracted by higher priority tasks The shift manager stated that he looked at the procedure but did not think that he had to order the site evacuation
under the existing conditions. When conditions changed, he ordered the evacuation. This explanation was consistent with the inspectors' observations.
The inspectors concluded that the site evacuation was not ordered in a timely manner because the shift manager did not follow the site evacuation procedures.
The scope of this inspection included an evaluation of corrective actions for Exercise Weakness 50-445/9521-01:50-446/952101(see Section P8.1 below).
The weakness involved failures in implementing the site evacuation process.
Specifically, one crew did not consider wind direction when making the site evacuation announcement and evacuated plant personnel through the simulated plume. Also, procedures for announcing the site evacuation were not followed.
The licensee's December 15,1995, response to the exercise weakness stated that
the errors occurred because the shift manager did not use the position assistance
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docum'ent to direct site evacuation activities and did not use self checking to ensure intended actions were correct. The shift manager and others satisfactorily demonstrated site evacuation requirements during subsequent exercises. The j
requirement to determine evacuation routes was subsequently deleted from the
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procedure.
Based on the above information, the inspectors concluded that Exercise Weakness 50-445/9521-01:50-446/9521-01 had not been corrected. The failure to correct an exercise weakness was identified as a violation of 10 CFR Part 50, Appendix E.IV.F.2.g, and states that any weaknesses or daficiencies identified during training and exercises shall be corrected 50-445/9104-03:50-446/9704-03.
The licensee disagreed with the characterization of this issue. Specifically, the licensee: (1) disagreed that the site evacuation was untimely, (2) asserted that the shift manager had followed procedures, and (3) determined that the shift manager was trying to determine whether there was release in progress prior to ordering the site evacuation.
Third, the shift manager experienced difficulty in determining affected sectors for Zone 2A. The general emergency notification and protective action recommendation were made within regulatory limits (14 minutes after the emergency declaration), the difficulty caused an unnecessary dela.
j e-14-Fourth, the general emergency notification form contained conflicting inforrnation.
One location indicated that containment was breached. Another location indicated that there was a possible containment breach. Yet another location indicated there
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was no release in progress. The inspectors concluded that the information contained on the form could have been confusing to offsite authorities and could diminish the licensee's credibility with the offsite agencies.
i Finally, the shift technical advisor and shift manager pulled the emergency action level charts from their binders and walked around the control room observing j
parameters. Additional personnel who tried to check these documents to ensure that the current classification level was consistent with the current conditions could not locate the appropriate chart. The inspectors concluded that this was not a good
practice.
The inspectors observed the emergency planning portion of the post-walkthrough critiques and concluded that they were generally thorough and self critical.
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Conclusions j
Performance of the shif t operating crews was less than satisfactory in several l
areas. An exercise weakness was identified for failure of the first crew to make a
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timely protective action recommendation. A violation was identified for failure to correct a previously identified exercise weakness concerning protection of plant
personnel. Logkeeping, teamwork, and forms completion were identified as areas for improvement. Post-walkthrough critiques were generally thorough and self-critical.
P5 Staff Training and Qualification in Emergency Preparedness a.
Insoection Scoce (82701-02.04)
Using 82701, the inspectors:
Reviewed training records for key emergency response personnel
Interviewed three emergency coordinators
Reviewed records and documents associated with emergency drills / exercises
Reviewed emergency preparedness information in unfettered access training
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Observations and Findinas The inspectors reviewed traing records to ensure that emergency response organization personnel received training required by Training Manual Procedure TRA-105," Emergency Preparedness Training," Revision 14. The records indicated that the training program was being properly implemented, however, the process to determine current training status was extremely difficult to interpret and could lead to oversights.
As indicated in Section P6 belov. the licensee had made significant changes to its emergency response organization. As a result, six new emergency coordinators were added to the roster. The inspectors interviewed three of the six new emergency coordinator qualified individuals to test the effectiveness of the emergency preparedness training program. The following results were obtained.
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Each emergency coordinator was asked seven basic emergency preparedness
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questions. Two of the three individuals demonstrated acceptable knowledge levels
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(one was very good). Less than r.pected responses in key areas were received by l
the third individual. For example, this individual thought that the time limit for
notifying offsite agencies was 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Two individuals were not aware that a
protective action recommendation was required at the general emergency classification level. The inspectors concluded that the training program was not
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fully effective.
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To validate the inspectors' assessment, the inspectors discussed the questions with tn 3 cognizant quality assurance auditor and the emergency planning manager. Both agreed that the questions involved basic information that they would expect personnel to retain from training.
The inspectors verified that the licensee was properly implementing its drill lnd exercise program. Documentation was satisfactory. The inspectors noted that the exercise matrix did not include a periodic objective to test the use (procedures, equipment, training, preparedness) of backup emergency response facilities. The emergency planning manager acknowledged this comment and stated that a recent Wf assessment had identified a similar omission. Corrective measures were planned.
The inspraors reviewed a training video that had been prepared for NRC personnel and noted that the video indicated that NRC personnel onsite should report to the logistics support center in the event of an emergency. The inspectors commented i
on the accuracy of the video since this facility was deleted in the latest revision to the site emergency plan (Revision 25, dated October 1996) Following discussions with the senior resident inspector, the licensee took appropriate action to update the training materials. The decision was made to have NRC personnel report to the staging area in the nuclear operations support facility, l
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Conclusions The training program was implemented in accordance with procedures, however, i
the results of interviews (and the simulator walkthroughs discussed in Section P4 above) indicated that the program was not fully effective.
P6 Emergency Preparedness Organization and Administration j
a.
Insoection Scone (82701-02.03)
The inspectors reviewed change; co the emergency planning organization (program management / implementation) and changes to the emergency response organization.
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b.
Observations and Findinas
Since the last routine emergency preparedness inspection, the emergency planning staff was reduced by two individuals: a supervisor and a planner. One additional reduction was planned in the near future. The remaining staff, after the planned reduction, appeared capF,ble of implementing the program. Effective measures were employed to ensure that emergency planning management and staff were aware of national program initiatives.
Significant changes to the emergency response organization had occurred since the last inspection. Specifically, on June 25,1996, the licensee " drafted" a new organization. The licensee estimated a 50 percent change in the emergency response organization, including new members, deleted members, and rotated members. Training was conducted prior to the Octobec 1,1996, implementation of the new organization. The inspectors concluded that the licensee had conducted the changes in a controlled manner.
The inspectors reviewed the controls established to implement the site emergency planning program (recurring tasks). Currently, these controls consisted of Emergency Plaa Procedure 100, " Maintaining Emergency Preparedness," Revision 0, and the master calendar. The emergency planning manager stated that each staff member had been asked to review procedures and staff guidelines to identify recurring tasks to capture on the master calendar (as a single controlling document).
Since recurring tasks were controlled via multiple documents, increasing the potential to miss a required task, the inspectors concurred with the licensee's actions to consolidate the tracking tool.
c.
Conclusions Emergency planning management and staffing levels were sufficient to implement the program. Significant changes to the emergency response organization were made in an orderly and controlled manne. _ _..
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.i P7 Quality Assurance in Emergency Preparedness Activities
P7.1 Independent and Internal Reviews and Audits (82701-02.051 j
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inspection Scope l
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The inspectors examined independent and internal review and audit reports for the l
licensee's emergency preparedness programs since the last inspection to determine compliance with NRC requirements and licensee commitments, b.
Observations and Findinas
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t The licensee provided copies of the audits performed in early 1996 and 1997. The
inspectors noted that there did not appear to be anyone other than quality
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assurance personnel on the 1997 audit team. The inspectors interviewed the lead
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auditor to determine the individual's level of expertise. The inspectors determined that the lead auditor had sufficient background and knowledge of the emergency j
planning program to adequately assess the program.
During interviews' with the lead auditor., the inspectors learned that one of his l
responsibilities was to perform the quality assurance reviews for emergency
planning procedures. The inspectors questioned if this could represent an area of vulnerability since audit personnel were required to have no direct responsibility for
the development or implementation of the emergency preparedness program. By l
reviewing the procedures and subsequently providing comments, suggestions, or i
revisions, the lead auditor could be considered as having involvement in the
t development or implementation process. The licensee acknowledged the inspectors' assessment and indicated that the matter would be investigated to
determine a possible means to improve this situation.
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The inspectors confirmed that an audit plan and checklist were used for the audit.
l A_ copy of the audit plan was provided for the inspectors' review. The scope of the
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audit appropriately included a review of interf aces with offsite agencies as required i
by 10 CFR 50.54(t).
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Conclusion
The licensee's audits of the emergency preparedness program was consistent with regulatory requirements and commitments to the NRC. An area for improvement
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was identified concerning emergency plan procedure review / audit responsibility independence.
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P7.2 Effectiveness of Licensee Controls (82701-02.06)
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Insoection Scope
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l The inspectors reviewed a January 27-31,1997, self assessment.
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b.
Observations and Findinas i
The self assessment was conducted by a five-member team, including emergency i
preparedness representatives from three other plants (two from non-Region IV j
plants). The assessment included a review of the emergency plan and NRC
Inspection Procedure 82701 elements. The assessment team identified several I
important issues; two one forms were issued. The inspectors concluded that the i
self assessment was thorough and effectively identified areas in need of correction.
j One self-assessment conclusion mirrored the training shortcomings identified during
this inspection. Specifically, the self-assessment team noted that there were
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repeated weaknesses in critical emergency functions (classifications, notifications, l-
'and protective action recommendations) and concluded that the repetitive failures, even though the causes were different, indicated that corrective actions may not be ef fective. The inspectors concurred with this conclusion.
c.
Conclasion l
l A recent self assessment was thorough and effectively identified areas in need of
corrective action.
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j P8 Miscellaneous Emergency Preparedness issues (92904)
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P8.1 (Closed) Insoection Followuo item 50-445/9521 -01 : 50-446/9521 -01. " Exercise
Weakness - Failure to Protect Plant Personnel"
l During simulator walkthroughs conducted in September 1995, a shift t
manager / emergency coordinator did not consider wind direction when evacuating
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plant personnel. As a result, plant personnel were instructed to evacuate through-the simulated radioactive plume. In addition, the emergency coordinator did not follow the prescribed method for announcing the evacuation. All corrective actions
were completed prior to this inspection. Site evacuation was not satisfactorily t
demonstrated during this inspection. As discussed in Section P4 above, the failure to correct an exercise weakness was identified as a violation of 10 CFR Part 50, Appendix E.IV..
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-19-P8.2 Closed) Violation 50-445/9521-02:50-446/9521-02." Failure to Train Personnel on Acoropriate Responses to Visual Alarms in Hiah-Noise Areas" The reason for the violation, including the corrective actions taken and planned to
correct the violation and prevent recurrence, was adequately addressed in the original inspection report (no-response violation); therefore, no further actions / followup were necessary.
P8.3 (Closed) Insoection Followuo item 50-445 /9524-02 : 50-446/9524-02, " Exerc ise Weakness - Failure to Make a Timely Protective Action Recommendation" This exercise weakness was primarily caused by inadequate procedural guidance.
Appropriate corrective actions were implemented prior to the issuance of the originalinspection report (no-response exercise weakness). Specifically, Emergency Plan Procedure 304, " Protective Action Recommendations," was revised to require an automatic protective action recommendation at a general emergency (evacuation of Zone 2A) based on plant conditions. Although a similar failure occurred during this inspection which resulted in a new exercise weakness (see Section P4 above),
the cause was different (performance versus procedural).
V. Manaaement Meetinas X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on February 14,1997. The licensee acknowledged the findings presented. The licensee stated that they disagreed with the conclusion made regarding the violation. The inspcctors noted the licencee's remarks and agreed to present these remarks in the report for management's review. No proprietary information was identifie. _,
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ATTACHMENT 1 SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee
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J. Ayres, Manager, Plant Support Overview D. Barham, Emergency Planner G. Bell, Supervisor, Emergency Planning J. Ellard, Emergency Planner D. Fuller, Emergency Planner W, Guldemond, Manager, Shift Operations N. Hood, Manager, Emergency Planning T. Hope, Manager, Regulatory Compliance i
B. Lancaster, Manager, Plant Support W. Nix, Emergency Planner M. Sunseri, Manager, Nuclear Training C. Welch, Engineer, Nuclear Overview R. Walker, Regulatory Affairs C. Wilkerson, Senior Engineer, Nuclear Li ensing l
NRC V. Ordaz, Resident inspector i
LIST OF INSPECTION PROCEDURES USED 82701 Operational Status of the Emergency Preparedness Program 92904 Followup - Plant Support 93702 Prompt Onsite Response to Events at Operating Reactors LIST OF ITEMS OPENED AND CLOSED j
Ooened
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50-445;446/9704-01 NCV Failure to Review Emergency Action Levels with Offsite Authorities (Section P3)
50-445;446/9704-02 IFl Exercise Weakness-Failure to Make a Timely Protective Action Recommendation (Section P4)
50-445:446/9704-03 VIO Failure to Correct a Previously identified Exercise Weakness
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o-2-Closed 50-445:446/9704-01 NCV Failure to Review Emergency Action Levels with Offsite Authorities (Section P3)
LIST OF DOCUMENTS REVIEWED Emeroency Plan Procedures EPP-100 Maintaining Emergency Preparedness, Revision 0
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EPP-109 Duties and Responsioilities of the Emergency Coordinator / Recovery Manager, Revision 11 EPP-112 Duties of Control Room Personnel during Emergencies, Revision 8 EPP-201 Assessment of Emergency Action Levels, Emergency Classification and Plan Activation, Revision 10
EPP-203 Notifications, Revision 13 f
EPP-304 Protective Action Recommendations, Revision 15 l
Other Documents l
j Comanche Peak Steam Electric Station Emergency Plan l'
Final Safety Analysis Report Chapter 6.4 Final Safety Analysis Report Chapter 9.4 Final Safety Analysis Report Chapter 13 NOE-EVAL-96-000191," Emergency Preparedness Program," February 10,1997 NOE-EVAL-96-000002," Emergency Preparedness Program," February 5,1996 Comanche Peak Steam Electric Station Transmittal of the Offsite Portion of the Annual Emergency Preparedness independent Review, March 14,1996 Emergency Preparedness Program Self-Assessment, January 27-31,1997 TRA-105, Emergency Preparedness Training, Revision 14
Shift Manager Position Assistance Document
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4 o-3-Shift Technical Advisor Position Assistance Document
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Emergency Response Organization Roster i
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i ATTACHMENT 2 SCENARIO NARRATIVE SUMMARY
SUMMARY The crew will take the watch with Emergency Diesel Generator 1-02 tagged out for i
maintenance an operability run on Emergency Diesel Generator 1-01 in progress (the
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emergency diesel generator started okay; the auxiliary operator is taking a set of logs prior to shutdown). When the crew assumes the watch, a 10 gpm reactor coole ! system leak develops. Emergency Diesel Generator 1-01 catches fire. The fire lasts for more than 15 minutes resulting in an ALERT being declared (Chart 10). A main steam line breaks; Steam Generator 4 blows down in containment resulting in a High 3 Containment.
Spray / Phase B actuation. The reactor fails to trip both manually and automatically. The anticipated transient without trip results in a site area emergency being declared (Chart 7).
Failed fuel results form the anticipated transient without trip.
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l The Train B containment spray heat exchanger outlet valve fails to open and one of the
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Train A Containment Spray Pumps 1-01 trips followed later by the other Pump 03. This
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condition challenges containment integrity. Two Phase A valves for a penetration failed to close and a penetration in the safeguards building at el 832 foot fails. This results in a loss
of a containment barrier. The conditions have been satisfied for the general emergency
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(Chart 2).
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00:00 Emergency Diesel Generator 1-01 operations test is in progress.
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Emergency Diesel Generator 1-02 is tagged out for maintenance; estimated time to complete repair is 6-8 hours.
00:05 Emergency Diesel Generator 1-01 trips on overspeed and catches fire.
l Reactor coolant system head vent leak starts.
00:20 Reactor coolant system leak becomes stable at 10 gpm. Fire
affecting a safety system is now 15 minutes old (Chart 10; Block H, Block E: Alert).
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A main steam line break occurs inside the containment on Steam
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Generator 1-04. The reactor fails to trip on automatic and manual trip signals (Chart 7; Block D, Block E, Block F: Site Area Emergency).
Failed fuel begins and the Containment Spray Pump 1-01 trips on l
start signal.
00:55 Containment Spray Pump 1-03 trips due to runout.
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01:10 A loss of coolant accident occurs on the Steam Generator 1-04 hot leg. Containment Monitors CTE and CTW (116 and 117)
jump up over the next minutes to 17 R/hr.
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01:15 A penetration on Safeguard Building 832-el f ails (Chart 2;
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j Block A, Block B, Block C, Block D, Block E: General Emergency).
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