IR 05000445/1997019
| ML20217H274 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/10/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20217H265 | List: |
| References | |
| 50-445-97-19, 50-446-97-19, NUDOCS 9710150108 | |
| Download: ML20217H274 (13) | |
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ENCLOSURE I
U.S. NUCLEAR REGULATORY COMMISSION i
REGION IV
l Docket Nos.:
50 445 50-446 License Nos.:
NPF 87 NPF 89 Report No.:
50 445/97 19 50 446/97 19 Licensee:
TU Electric Facility:
Comanche Peak Steam Electric Station, Units 1 and 2 Location:
FM 56 Glen Rose, Texas -
Dates:
September 22 25, 1997 Inspectors:
Gail M. Good, Senior Emergency Preparedness Analyst Edwin F. Fox Jr., Senior Emergency Preparedness Speclatist
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Office of Nuclear Reactor Regulation
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Approved By:
Blaine Murray, Chief Division of Reactor Safety ATTACHMENT:
Supplemental Information
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9710150108 971010 PDR ADOCK 05000445
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2-EXECUTIVE SUMMARY
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Comanche Peak Steant Electric Station, Units 1 and 2 NRC Inspection Report 50 445/97 19; 50 446/97 19 l
A reactive, announced inspection involving Revision 25 to the Comanche Peak Steam Electric Station Emergency Plan was conducted.
Plant Suonort Four apparent vlotations of 10 CFR 50.54(q) were identified regarding: (1) the
i f ailure to describe the emergency response organization, (2) the f ailure to describe j
the emergency response organization training program, (3) onshif t staffing and timely augmentation capabilities were reduced, and (4) the f ailure to describe offsite I
decisionmaker(s) for the ingestion pathway zone. The 10 CFR 50.54(q) review
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process was apparently ineffective, in that details were removed from the _
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emergency plan and placed in documents that did not receive a 10 CFR 50.54(q)
review. There was an apparent lack of attention to detail during the emergency plan review and revision process, Details were apparently removed from the emergency plan to avoid the need for future revisions (Section P3).
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3-lLPlanLSupanti P3 Emergency Preparedness Procedures and Documentation a,
lasocction Scone (8270102.011 The inspectors reviewed Revision 25 to Comanche Peak Steam Electric Emergency Plan. The following background intormation was relevant to this inspection:
Revision 25 to the Comanche Peak Steam Electric Station Emergency Plan
was submitted on October 29,1996. Prior approval was not requested because the licensee determined that the changes continued to meet 10 CFR Part 50.47(b) planning standards and 10 CFR Part 50, Appendix E, l
l requirements and did not decrease the effectiveness of the emergency plan.
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An open (noticed) meeting was conducted in the Region IV office, at the
licensee's request, on December 4,1996, to discuss the Revision 25
changes. Emergency response organization staffing and duties and j
responsibilities of the individual responders were addressed. A meeting summary was issued on December 11,1996.
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I On January 21,1997, the licensee was informed (letter from T. P Gwynn,
Director, Division of Reactor Safety, NRC, to C. L. Terry, Group Vice
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President, Nuclear, TU Electric) that Revision 25 to the emergency plan
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would be submitted to the Office of Nuclear Reactor Regulation (NRR) for review because some of the changes were potentially inconsistent with
10 CFR 50.54(q) or involved policy matters. The f act that the emergency
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plan was completely rewritten also had a bearing on the decision to send the change to NRR.
On January 31,1997, Task Interf act, Agreement 97TIA001 was issued to
formally request NRR evaluation of Revision 25.
In September 1997, several conference calls were held between NRR,
Region IV, and the licensee to discuss the preliminary results of NRR's I
review. On September 18,1997, a decision was made to conduct a reactive inspection on September 22 25,1997, recognizing that it would be the most efficient way to obtain the information needed to complete the review (via discussions, review of emergency plan implementing procedures, and other station procedures).
The inspectors used the preliminary results from NRR's Revision 25 review as
the foundation for discussions with the licensee. The inspectors focused on changes, which appeared questionable and/or required additional information (i.e., acceptable changes were not discussed).
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Obiclyations and FindiDSS During the inspection, the inspectors identified issues in two categories: those thM appeared inconsistent with 10 CFR 50.54(q) requirements, and those that needed additional clarification, detail, or correction in the next emergency plan revision. The two categories and corresponding issues are discussed below:
Calc 201y_1 The first category consisted of the following four issues that appeared inconsistent with 10 CFR 50.54(q) requirements.10 CFR 50.54(q) requires licensees to follow and maintain in effect an emergency plan, which moots the standards in 10 CFR 50.47(b) and the requirements of Appendix E to Part 50. Licensees are permitted to make changes to the plan without Commission approval only if the changes do not decrease the effectiveness of the plan and the plan, as changed, continues to meet the 50.47(b) planning standards and tho' Appendix E requirements. As previously mentioned, the licensee did not request prior approval because it determined that the changes continued to meet 10 CFR 50.47(b)
planning standards and 10 CFR Part 50, Appendix E, requirements and did not decrease the effectiveness of the emergency plan.
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The description and responsibilities of four emergency response organization positions were deleted from Revision 25; however, the positions remained on the emergency response organization call out roster. The four deleted positions / descriptions were: (a) the emergency operations facility radiation assessment coordinator, (b) the technical support center operations coordinator, * the operations advisor, and (d) the supporting staff for the logistical support coordinator.
Related to this matter, Unresolved item 50 445;4e6/9716-01, NRC report dated August 13,1997, identified numerous other emergency response organization positions that were not described or identified in the emergency plan. For example, the emergency plan only described responsibilities for one person in the operations support center (operations support conter manager).
Figure 1.4 identified eight other positions / functions in the operations support center; however, the corresponding responsibilities of the positions were not described.
Moreover, the call out roster included an inplant team commut.icator for the operations support center, emergency planning advisors for multiple facilities, engineering team members for the technical support center, status board keepers for multiple facilities, and administrative support personnel for multiple f acilities who were not mentioned or described in the emergency plan.
The discrepancy between the call-out roster and the emergency plan was identified as an unresolved item pending NRR's review of Emergency Plan
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Revision 25. Due to he similarity / connection b9 tween the two issues, the unresolved item subject matter was subsumed into this Category 1 issue.
The inspectors determined that the f ailure of the emergency plan to include a description of the emergency response organization and responsibilities was an apparent violation of Planning Standard 10 CFR 50.47(b)(2) and 10 CFR Part 50, Appendix E.IV.A, requirements. Planning Standard 10 CFR 50.47(b)(2) requires that onshif t f acility assignments be
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I unambiguously defined, adequate staffing for initial response be maintained, I
and timely augmuntation of response capabilities be maintained. Appendix E.IV.A to Part 50 requires that emergency plans describe the organization for l
coping with radiological emergencies, including definition of authorities, l
responsibilities, and duties of Individuals assigned to the emergency l
organization. inspectors determined that the emergency response organization call out roster contained a sufficient number of personnel and positions.
Moreover, the inspectors determined that by having the description of the onsite emergency response organization and plant staff emergency assignments in locations Jther than the emergency plan, such as emergency plan procedures / call out roster, the licenseo could circumvent the 10 CFR 50.54(q) review process. That is, positions could be deleted without determining whether the deletions decreased the effectiveness of the emergency plan it is also important to note that the licensee stated that the emergency plan could not be implemented using just the individuals described in the emergency plan, in response, the licensee stated that deleting the four positions in Revision 25 was considered acceptable, since it used a philosophy that was established in previous revisions (i.e., only " key" positions needed to be described). The inspectors pointed out that reviewers would not know that the positions were maintained on the call-out roster, since the roster was not submitted to the NRC.
2)
The description of the fire brigade and security training programs were deleted from Revision 25. It was beyond the scope of this inspection to determine when other training program details were deleted from the emergency plan. Revision 25, Section 13, " Radiological Emergency Response Training," stated that the training program is outlined in Procedure TRA 105, " Emergency Preparedness Training," (no revision specified). Although Procedure TRA 105 was submitted to the NRC (to meet 10 CFR Part 50, Appendix E.V requirements for implementing procedures), it did not receive a 10 CFR 50.54(q) review to determine if changes decreased the effectiveness of the emergency plan. Again, the 10 CFR 50.54(q)
process could be circumvente.
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The inspectors determined that the f ailure of the emergency plan to include a description of the emergency response training program was an apparent violation of 10 CFR Part 50, Appendix E.IV.F.1, which requires that emergency plans describe the specialized training and retraining programs for certain categories of emergency response personnel, including fire brigado members and security personnel, in response, the licensco stated that it was making changes that had been accepted by NRC in other utility emergency plans. The licensee did not know l
if other utility procedures received 10 CFR 50.54(q) reviews.
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3)
Onshif t staffing and timely augmentation capabilities were reduced in Revision 25 as follows:
The tabular description of the emergency response organization no
longer included a dedicated cummunicator to perform offsite agency notifications. Revision 24 required an onshif t communicator, who could be assigned other responsibilities, to perform offsite agency notifications, and the addition of another dedicated communicator within 40 minutes. Revision 25 added a second onshift communicator
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and deleted the 40 minute responder but no longer identified a l
" dedicated" communicator. As a result, assignment conflicts could impact the capability to notify offsite agencies.
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In response, the licenseo stated that one of the individuals was actually " dedicated," but that this distinction was not accurately captured in the emergency plan. However, as written, the emergency plan change item was not acceptable, Two 40-minute responders to help the shif t technical advisor perform l
dose assessment and engineering tasks were deleted from the tabular description of the emergency response organization. As a result, the shift technical advisor would have to perform the tasks assigned to the three individuals until adoenal support arrived (70-minute responders).
One 40-minute responder to pv form offsite monitoring was deleted
from the tabular description of the emergency response organization.
As a result, offsite monitoring capabilities would be delayed until the 70 minute responders arrived, since onshif t resources were not sufficient to perform the monitoring (according to the licensee). The f ailure to perform offsite monitoring could affect the licensee's ability to recognize the need to make/ upgrade emergency classifications and assess the need to make/ upgrade protective action recommendations (i.e., unmonitored releases could not be quantified).
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I 7-Pertinent to this change, Section 7.3.2 of Revision 25 (Revision 24 included the same wording) stated ' hat the firct of fsite monitoring
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team could be dispatch 3d within 120 minutes of an emergency. Table B-1 to NUREG-0054/ FEMA REP 1, " Criteria for Preparation I
and Evaluation of Radiological Emergency Responso Plans and I
Preparedness in Support of Nuclear Power Plants," Revision 1; to l
which the licensee is committed via Regulatory Guide 1.101, l
" Emergency Planning and Preparedness for N'aclear Reactors,"
Revision 2; indicates that offsite monitoring capabilities are to be provided within 30 minutes (the exception to allow 40-minuto
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l responders, instead of 30 minute responders, was approved in Safety Evaluation Report, Supplement 3), the validity of the time was questioned by the inspectors. The licensee indicated that the 120 minutes noted in the emergency plan contributed to its decision to eliminate the 40 minute responder. However, af ter discussing the matter, the licensee stated that the reference to the 120 minutes would be deleted or corrected. The inspectors considered this response appropriate, j
i Five 40-minute responders to help perform station surveys, team
coverage, onsite surveys, access control, personnel monitoring, and dosimetry were deleted. To offset the reductions, the licensee doubled the onshift radiation protection staff (from one to two) and took credit for technology upgrades (electronic alarming dosimeters, etc.). This change meant that there were two radiation protection personnel onshif t to perform all radiation protection reis ted duties until the 70-minute respondere arrived.
The inspectors identified that the onshif t staffing and timely augmentation capibilities reductions as an apparent violation of Planning Standard 10 CFR 50.47(b)(2), which requires adequate staffing for initial response and timely augmentation of response capabilities be maintained, and constituted a decrease in the effectiveness of the emergency plan.
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4)
The identification of the offsite protective action decisionmaker(s)
for the ingestion pathway zone was deleted from Revision 25 (existed in Revision 24). The inspectors determined that the failure to include the ingestion pathway offsite decisionmakers in Emergency Plan Revision 25 was an apparent violation of 10 CFR Part 50, Appendix E.IV.A 8.
Appendix E.IV.A.8 requires that emergency plans identify the state and/or local officials who would order protective actions.
Cateaorv 2 The second category consisted of the following issues that needed additional clarification, detail, or correction. The issues were considered more than minor
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since some initially represented potential decrease in effectiveness matters until additional clarification was provided by the licensee.,
There were numerous errors in Appendix P (cross-reference to NUREG 0654).
- There were errors in Append : K (list of emergency plan procedures).
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The description of the emergency classification responsibilities (the transfer
between the technical suppcrt center and emergency operations f acility)
were unclear.
There was e discrepency between Section 1.2.2 and Appendix H (list of
offsite agreement letters) involving the name of a local fire department.
There was no internal reference to the state agreement letters.
- Information coricerning when the Department of Health would send response
teams was inappropriately deleted.
The local emergency operations center advisor was not described in the
section that discussed the licensee's emergency respcnse organization.
The description of the post-accident sampling system and capabilities was
poorly located. The logical location for the description simply referenced the final safety analysis report; however, a description was located in another emergency plan section.
The definition of " activation" in Appendix Q, (Definitions) was incorrect. The
definition stated that " activation" meant that a f acility e.culd function in a
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" limited capacity." The licensee indicated this vas not consistent with its intentions. Activation meant that a facility could perform all required functions.
The concept of operations section lacked sufficient detail (activation / staffing
overview).
Details concerning the purpose of event classifications, including when
offsite emergency operations centers would be activated, were missing from the emergency plan.
The list of local services support was inconsistent with Appendix H (list of
offsite agreement letters).
The list of supporting emergency plans was not submitted with Emergency
Plan Revision 25 (an inadvenent omission).
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Information about the offsite decisionmaker for the plume exposure pathway
zone was unclear.
The location of the two county emergency operation:: centers was unclear.
- The reference to the Squaw Creek Park Plan (a supporting plan) was
incorrectly deleted, and provisions for notifying park officials were not described.
Section 14 of the emergency plan incorrectly stated that an independent
review of the emergency preparedness program would be conducted annually.10 CFR 50.54(t) requires an independent review "at least every 12 months."
The capabilities of the nuclear operations support f acility/ emergency
operations facility laboratory were incorrectly deleted and replaced with a reference to the final safety analysis report.
Details concerning the location of the inplant decontamination f acilities were
incorrectly deleted and replaced with a reference to the final safety analysis report.
Based on the number and types of issues listed in Category 2 above, the inspectors concluded that there was an apparent lack of attention to detail during the emergency plan review and revision process and that the net ruult was to remove detail from the emergency plan. Licensee personnel confirmed that the intent was to eliminate the need to make future emergency plan revisions, c.
Conclusions Four apparent violations of 10 CFR 50.54(q) were identified regarding: 1) f ailure to describe the emergency response organization, (2) failure to describe the emergency response organization training program, (3) reduction in onshift staffing and timely augmentation, and (4) failure to describe offsite decisionmaker(s) for the ingestion pathway zone. The 10 CFR 50.54(q) review process was ineffective, in that details were removed from the emergency plan and placed in documents that did not receive a 10 CFR 50.54(q) review. There was an apparent lack of attention to detail during the emergency plan review and revision process. Details were apparently removed from the emergency plan to avoid the need for future revisions.
P8 Miscellaneous Emergency Preparedness issues (92904)
P8.1 (Closed) Unresolved item 50-445:446/9716-01: Unresolved item involvino the descriotion of the emeroenev resoonse oraanization in the emeroency olan.
The issues identified in this unresolved item were subsumed into the apparent violation discussed in Section P3 above (Category 1, Item 1).
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V. Management Meetings
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The inspectors presented the inspection results to members of licensee management l
at the conclusion of the inspection on September 25,1997. The licensee acknowledged the facts presented. No proprietary information was identified,
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Regional management requested the licensee to issue a letter describing corrective
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actions to address the concerns raised in the inspection. This letter was issged on September 26,1997, as requested. The corrective actions described in the
September 26,1997, letter were considered appropriate to address the immediate
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l concerns identified during the inspection.
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l ATTACHMENT SUPPLEMENTAL INFORMATION
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PARTIAL LIST OF PERSONS CONTACTED
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Licensee
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C. Terry, Group Vice President, Nuclear i
D. Barham, Emergency Planner G. Bell, Senior Nuclear Specialist M. Blevins, Plant Manager
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D. Buschbaum, Manager, Technical Compliance
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E. Dyas, Nuclear Specialist, Nuclear Oversight Department j
J. Ellard, Emergency Planner j
- D. Fuller, Emergency Planner l
D. Goodwin, Manager, Operations Support N. Hood, Manager, Emergency Planning
'R Kidwell, Emergency Planner i
B. Lancaster, Manager, Plant Support
W. Nix, Emergency Planner i
T. Robison, Emergency Planner
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R. Walker, Manager, Regulatory Affairs l
C. Wilkerson, Senior Engineer, Regulatory Affairs
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D. Chamberlain, Deputy Director, Division of Reactor Safety H. Freeman, Acting Senior Resident inspector
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j B. Murray, Chief, Plant Support Branch
i LIST OF INSPECTION PROCEDURES USED
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Operational Status of the Emergency Preparedness Program (
IP 92904 Followup - Plant Support
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LIST OF ITEMS CLOSED Closed 50-445;446/9716-01 URI Unresolved item involving the description of the emergency response organization in the emergency plan (Section P8)
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LIST OF DOCUMENTS ilEVIEWED Emeroenev Plan Procedures EPP 100 Maintaining Emergency Preparedness, Revision 1 EPP 109 Duties and Responsibilities of the Emergency Coordinator / Recovery Manager, Revision 11 EPP 206 Activation of the Emergency Operations Facility, Revision 13
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EPP 204 Activation of Technical Support Center, Revision 12 EPP-207 Activation and Operation of the News Center, Revision 9 Other Procedures TRA-105 Emergency Preparedness Training, Revision 15 STA 116 Changes to the Comanche Peak Steam Electric Station (CPSES) Final Safety Analysis Report, Revision 2 STA 119 Changes to CPSES Licensing Basis Documents, Revision 1 STA 707 10 CFR 50.59 Review, Revision 13 Other Documents Comanche Peak Steam Electric Station Emergency Plan, Revisions 24 and 25 Final Safety Analysis Report Chapters 1 and 13 NUREG-0797 Safety Evaluation Report related to the Operation of CPSES, Units 1 and 2, Docket Nos. 50-445 and 50-446, Texas Utilities Generating Company, et al.,
Supplement 3 (March 1983), Supplement 6 (November 1984), Supplement 12 (October 1985), and Supplement 24 (April 1990)
LDCR# EP-96-004 Changes to Section 1.0 of the CPSES Emergency Plan TXX 3389 Letter, Burwell, TU Electric, to NRC, Subject: CPSES Emergency Plan Discrepancies, dated August 24,1981 TXX-89618 Letter, Cahill, Jr., TU Electric, to NRC, Subject: CPSES, Dockets Nos 50-445 and 50-446, Transmittal of CPSES Emergency Plan, Revision 11 Letter, NRC to Walker, TU Electric, Subject: Changes to Comanche Peak Emergency Plan, dated September 13,1996.
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3-Letter, NRC to Terry, TU Electric, Subject: CPSES Emergency Plan Revision 25, dated January 21,1997 Letter, NRC to Terry, TU Electric, Subject: Comanche Peak Emergency Plan Revision,
dated December 11,1996
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Letter, NRC to Cahill, Jr, TU Electric, Subject: Quality Assurance Program for CPSES, dated
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July 31,1994.
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