IR 05000498/1987024

Insp Repts 50-498/87-24 & 50-499/87-24 on 870420-24.No Violations or Deviations Noted.Major Areas Inspected: Licensee Implementation of Corrective Actions for Emergency Preparedness Appraisal Deficiencies

ML20214F883
Person / Time
Site:	South Texas
Issue date:	05/13/1987
From:	Baird J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20214F852	List: IR 05000498/1987024 ML20214F851
References
50-498-87-24, 50-499-87-24, NUDOCS 8705260329
Download: ML20214F883 (10)

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, APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

, REGION IV l

NRC Inspection Report: 50-498/87-24 Construction Permits: CPPR-128 50-499/87-24 CPPR-129 Dockets: 50-498 l

50-499 Licensee: Houston Lighting & Power Company (HL&P)

P. O. Box 1700 Houston, Texas 77001 j Facility Name: South Texas Project (STP), Units 1 and 2 Inspection At: Bay City and STP, Matagorda County, Texas

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Inspection' Conducted: April 20-24, 1987

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Inspector: [gj / 6[/3/)77 l J 8. Baird, NRC Team Leader Dat.e '

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Accompanied

By

C. Hackney, RIV, NRC L. Yandell, RIV, NRC F. Carlson, Comex Corporation-G. Bryan, Comex Corporation G. Wehmann, EG&G Services Approved:

William L. Fisher, Chief, Nuclear Materials E 3[F/

Date

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and Emergency Preparedness Branch Inspection Summary Inspection Conducted April 20-24,1987 (Report 50-498/87-24: 50-499/87-24)

Areas Inspected: Routine, announced inspection of the licensee's implementation of corrective actions for emergency preparedness appraisal deficiencie B70520 5 PDR ADOCK 05000498; G PDR . _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ - _ _ _ _ _ _ _ - _ _ - _ _ _ - - - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ .

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Results: Within the areas inspected, no violations or deviations were identified. Twenty eight deficiencies were verified as having appropriate corrective actions completed by the licensee. One unresolved item was identified (dose assessment code verification paragraph 4).

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DETAILS Persons Contacted t

Licensee

R. Craft, Radiation Protection Supervisor B. Franta, Manager, Education / Administration

• R. Frazar, Manager, Emergency Preparedness L. Giles, Shift Supervisor i

M. Hall, Security Force Coordinator A. Hill, Manager, Nuclear Security

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G. Jarvela, Health & Safety Services Manager i

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H. Johnson, Shift Supervisor W. Kinsey, Plant Manager

• J. Kubenka, Manager, Staff Training J. Lindsay, Radiological Engineer

• M. McBurnett, Principal Engineer, Site Licensing l D. McCallum, Shift Supervisor W. Parrish, Radiological Support Supervisor l S. Rosen, Chairman, Nuclear Safety Review Board L. Ryley, Manager, Physical Protection Services l J. Sims, Emergency Preparedness Coordinator

• Vaughn, Vice President, Nuclear Operations R. Waldrop, Manager, Public Affairs i * Walker, Site Public Affairs Manager N. Walker, Communications Specialist G. Williams, Staff Engineer i Others

• J. Brady, Acting HL&P Readiness Division Manager, Energy International

• D. Carpenter, Senior Resident Inspector, NRC C. Johnson, Senior Resident Inspector, NRC

• Martin, Jr., Acting HL&P Support Division Manager, Impell Corporation

• Webster, Project Director, Impell Corporation

• Denotes attendance at exit interview, i The NRC inspectors also held discussions with other station and corporate personnel in the areas of radiation protection, operations, and emergency

response organization.

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! Follow-up on previous Inspection Findings (Closed) Deficiency (498/8635-002; 499/8635-002): Method had not been

developed to notify personnel. The NRC inspector reviewed procedure OEPP02-ZA-0023, " Emergency Response Organization Roster," and l

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held discussions with selected emergency preparedness and training department personne It was noted that the licensee had provided an emergency response organization form for notifying personnel of their assignment to the emergency response organization (ER0) and provisions for monthly updates. It was further noted that the names of personnel assigned to the ERO had been transmitted to the training department and an emergency call-out roster had been develope (Closed) Deficiency (498/8635-013; 499/8635-013): Filter leak testing charcoal efficiency determination. The NRC inspector determined that the Emergency Operations Center (E0C) emergency air filter system (EFS) does not include charcoal filter It was noted that the EFS included high efficiency particulate air (HEPA) filters. The NRC inspector observed that the OPEP05-ZH-0012-1 data sheet showed a DOP penetration test had been completed on the HEPA filters on March 25, 1987. It was also noted that the system is to be retested on a 18-month cycle.

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(Closed) Deficiency (498/8635-013; 499/8635-014): Provisions for

protective clothing, personnel dosimetry, and respiratory protection for l the EOC. The NRC inspector reviewed procedure OEPP02-ZA-0002, Emergency Equipment and Supplies Inventory," dated March 1, 1987, and verified that provisions for this equipment had been made for the E0C. The NRC inspector conducted an inventory using Form-04, " Emergency Operations l Center Inventory," and noted that the high range dosimeters were not in I place. The licensee provided documentation that the dosimeters were not

on order and committed to have them in the emergency kits prior to I licensing for fuel loa (Closed) Deficiency (498/8635-015; 499/8635-015)

No contingency plan for the TSC to perform EOC functions. The NRC inspector reviewed Section C.S.2 of the Plan and procedures OEPP01-ZA-0014, " Technical Support Center Activation, Operation, and Deactivation," and OEPP01-ZA-0018, " Emergency Operations Center Activation, Operation and Deactivation," verified that provisions had been incorporated into these procedures to have the Technical Support Center (TSC) perform E0C l

functions if the EOC is not functional in the required hour. To avoid

! ambiguity in the procedures, the licensee committed to change the word

"may" to "shall" and to specify the activation times for both the TSC and E0C.

< (Closed) Deficiency (498/8635-021; 499/8635-021): No provisions had been j made for decontamination of personnel. The NRC inspector determined that i the licensee had provided a mobile decontamination unit (MOU) that will be l available to provide for the decontamination of personnel at assembly

! areas outside of the normal radiological controlled area. All waste water I

and decontamination materials generated during operation of the MDU can be j retained until sampled and analyzed to determine appropriate processing

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and release options. Procedure OEPP01-ZA-0038, "Use of the Mobile i Decontamination Unit (MDU-6)," provides instructions for the startup, j operation, and shutdewn of the MDU.

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(Closed) Deficiency (498/8635-022; 499/8635-022): The HL&P principal spokesperson position was not included in the Plan. The NRC inspector determined that the position was not included in the Plan, and that the position of HL&P spokesperson had been included in Section C, Figure C-3, and Table C-3 of the Pla (Closed) Deficiency (498/8635-023; 499/8635-023): Job descriptions for Media Information Center (MIC) positions below the principal staff were not included in the implementing procedures. The NRC inspector noted that the assigned tasks for key MIC positions were described in procedure OEPP01-ZA-0022, "Public Information for an Alert / Site Area /

General Emergency."

(Closed) Deficiency (498/8635-026; 499/8635-026): Provisions for respiratory protection at emergency response facilities. The NRC inspector noted that procedure OEPP02-ZA-0002 specifies the quantity and type of respiratory protection provided at all onsite emergency response facilities. The NRC inspector also observed a sufficient quantity of self-contained breathing apparatus (SCBA) and respirators onsite to meet the requirements of the procedur (Closed) Deficiency (498/8635-028; 499/8635-028): Provisions were not made for respiratory protection. The NRC inspector observed that respiratory protection equipment for control room personnel and field monitoring teams, required by procedure OEPP02-ZA-0002, were onsit It also appeared that the quantity of respiratory protection devices at the Operations Support Center (OSC) was adequate for initial response to an emergenc (Closed) Deficiency (498/8635-029; 499/8635-029): Provisions for protective clothing at emergency response facilities. The NRC inspector observed that the protective clothing requirements of procedure OEPP02-ZA-0002 were in place at all onsite emergency response facilitie It appeared that the specified quantity of protective clothing would be adequate for initial response to an emergenc (Closed) Deficiency (498/8635-030; 499/8635-030): The licensee had not addressed protective clothing in the Plan. The NRC inspector noted that-Table G-1 of the Plan had been revised to include protective clothing requirements at onsite emergency response facilities. It was also noted that specific quantities of protective clothing at onsite facilities were identified in Procedure OEPP02-ZA-0002. It appeared that the quantities would be adequate for initial response to an emergenc (Closed) Deficiency (498/8635-031; 499/8635-031): Backup communication between STP and the County and State EOC's. The NRC inspector observed that the licensee had two-way radio communication between STP and the County and State E0C's. An operational test of these systems was observed by the NRC inspecto , m D.,N ,

(Closed) Deficiency 498/8635-034; 499/8635-034): Emergency plan implementing procedures. The NRC inspector compared the current' listing-of emergency plan implementing procedures (EPPs) with the individual planning standards of 10 CFR 50.47(b), the requirements in paragraph IV of Appendix E to Part 50, and the Plan. It.was noted that the EPPs had been developed to address each of the key emergency preparedness element (Closed) Deficiency (498/8635-037; 499/8635-037): Procedures-for assembly were not consistent with the Plan. The'NRC inspector-reviewed Section F-of the Plan'and OEPP01-ZA-000?, " Accountability / Evacuation Procedure." l The NRC inspector determined that the assembly areas were listed as described in the Pla (Closed) Deficiency (498/8635-039: 499/8635-039): HL&P had not designated the type, number, and location of protective clothing unit The NRC inspector noted that Procedure OEPP02ZA-0002 identifies the number of-protective clothing units to be matntained in the control room, TSC, OSC, E0C, radiation van, offsite assistance kit, site access facility, offsite survey team kits, and offsite decontamination ki It appeared that'the type, number, and location of protective clothing units would be adequate for initial response to an emergenc (Closed) Deficiency (498/8635-040; 499/8635-040): No procedure had been provided to govern the required testing of the communication system. The NRC inspector noted that the licensee had implemented Procedure OPGP3-CN-0006, " Communications System Testing Program." It appears that this procedure meets the communications testing requirements of 10 CFR 50, Appendix E, and NUREG 0654,,Section I (Closed) Deficiency (498/8635-042; 499/8635-042): The emergency response roster had not been issued. The NRC inspector reviewed Procedure OEPP02-ZA-0023 effective April 3, 1987, and noted that the procedure appeared to be thorough and detailed, and that it required monthly updates and quarterly check (Closed) Deficiency (498/8635-045; 499/8635-045): Pager system. The NRC inspector reviewed OEPP01-ZA-0004, " Emergency Response Personnel Notification," dated April 7,1987, and OEPP01-ZA _0037, " Emergency Communications," dated April 7, 1987. The NRC inspector determined that an emergency personnel notification roster and pager system had been developed and implemente (Closed) Deficiency (498/8635-047; 499/8635-047): A method had not been developed to notify personnel. The NRC inspector reviewed Procedure OEPP01-ZA-0004 and the emergency response organization list. It was determined that a primary pager system and automatic dialer system ha been developed and implemente

(Closed) Deficiency (498/8635-057; 499/8635-057): Personnel' monitoring and decontamination. The NRC inspector noted that the licensee had implemented Procedure OEPP01-ZA-0035, " Monitoring and Decontamination-

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Outside Radiologically Controlled Areas," and Procedure OEPP01-ZA-003 These procedures appeared to be adequate for personnel monitoring and decontamination requirements outside the normal radiological controlled are (Closed) Deficiency (498/8635-059; 499/8635-059): Support response to a radiological emergency. The NRC inspector reviewed OSDP02-ZS-001,

" Implementing Action Review for Declared Emergencies." The Procedure did address requesting radiological support for the Central Alarm Station (CAS), Secondary Alarm Station (SAS), and guard station habitability requirement It was also noted that any procedures addressing the evacuation and reentry to the site by security will be addressed in the security contingency pla (Closed) Deficiency (498/8635-060; 499/8635-060): Concept of operations '

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for damage control / repair or corrective action. The NRC inspector noted that Procedure OEPP01-ZA-0036, " Damage Control and Emergency Repair Procedure," had been issued March 3, 1987, to provide the concept of operations for damage control / repair or corrective actio (Closed) Deficiency (498/8635-062; 499/8635-062): Individual news media to be contacted by the commercial news wire service. The NRC inspector reviewed Procedures OEPP01-ZA-0021, "Public Information for a Notificatio of Unusual Event," dated April 1,1987, OEPP01-ZA-0022, dated April 1, 1987, and OEPP01-ZA-0023, Addendum 4, "SWN Membership Reference," dated April 1, 1987, to verify that news media to be contacted by the commercial news wire service had been specifically identifie It was noted that Addendum 4 to OEPP01-ZA-0023 contains a list of news media, but does not -

include addresses and names of principal contacts. The NRC inspector

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verified that the commercial news wire service maintains this information current to ensure prompt dissemination of any press release issued by HL&P, and thus this is considered acceptabl (Closed) Deficiency (498/8635-064; 499/8635-064): Alternate principal HL&P spokesperson identified. The NRC inspector determined that an alternate principal HL&P spokesperson had been designated by title in ;

Section C of the Plan and identified by name on the emergency response organization roste (Closed) Deficiency (498/8635-065; 499/8635-065): Procedure governing inventory. The NRC inspector noted the' revision of Procedure OEPP02-ZA-0002 included provisions for inventory, operational check, and calibration of emergency radiological instrumentatio Corrective actions if instruments fail operation checks are included in the procedur (Closed) Deficiency (498/8635-072; 499/8635-072): Public information for transients. The NRC inspector reviewed the program established for posting of information for the transient population and made spot checks of 13 postings of the information adjacent to and within the 10-mile

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emergency. planning zone (EPZ). Of the-area required to be posted, all but two that were checked were found to have the information poste (Closed) Deficiency (498/8635-073; 499/8635-073): Formal system to 1 implement and control the drills and exercise program. The NRC inspector noted that Procedure OEPP02-ZA-0003, " Conduct and Control of Emergency Exercises and Drills," initially issued September 23, 1986, had been

' revised and reissued as Revision 1,-dated April 4, 1987. The revised procedure was expanded and improved with format changes and major revision to address-this are (Closed) Deficiency (498/8635-074; 499/8635-074): Operations crew ..

walkthrough and drill-identified problems. During walkthroughs of three

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operations crews using an NRC supplied emergency scenario, the NRC inspector noted that Procedure 0EPP02-ZA-0003, " Emergency Offsite Notifications," had been modified'to require a minimum of two control room communicators and that these communicators demonstrated that they had been appropriately trained. It was also noted that required notifications were made in a timely fashion. The NRC inspector determined that the crews were familiar with the duties of the Emergency Director, which could not be delegated, and observed that the crews demonstrated the capability to use procedures to classify emergencies. Only l' error in classification was made out of a total of 53 classifications required. This was an error in failing to declare a Notice of Unusual Event (NOVE) by a' crew. It was also noted that the classification Procedure OEPP01-ZA-0001 had been revised to clarify the requirement for declaration of a NOUE in the case of a shutdown dictated by Technical Specifications. The observations by the NRC inspector in this area indicated that HL&P had satisfactorily -

addressed the operations crew and drill problems identified by this deficienc . Clear Functional Areas Inspected The following program areas were inspecte The inspection included interviews with-cognizant individuals. observaticas of activities, independent measurements, and record reviews. . The depth and scope of these activities were consistent with past findings and with the current ,

status of the facilit Except as noted, the inspection revealed no violations, deviations, deficiencies, unresolved items, or open items. Notations after a specific inspection item identify the following: I = item not inspected or only partially ~1nspected, V = violation, D = deviation, H = deficiency, V = unresolved item, and 0 = open ite '

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Inspection Procedure Functional Area and Inspection Requirements TI 2513/55 Emergency Preparedness Appraisal 1.0 Administration of Emergency-Preparedness - 1 2.0 Emergency Organization .I 3.0 Emergency Plan Training / Retraining - I 4.0 Facilities and Equipment.- I l 5.0 Procedures - I

! 6.0 Coordination With Offsite Groups - I l

7.0 Drills, Exercises and Walkthrough - 10 (see paragraph 4)

4. Dose Assessment During preparations for walkthroughs, the NRC inspector noted that the output of the STP South Texas Assessment Model Projected Emergency Dose l

Estimate (STAMPEDE) backup dose assessment code did not show good agreement for radioiodine doses with the NRC Intermediate Rapid Dose Assessment Model (IRDAM) code. STAMPEDE is one of the two backup dose projection methodologies to the primary STP method using the RM-21A Dose Assessment System. It was subsequently determined that the STAMPEDE code was in a developmental stage and the radioiodine dose projections were erroneous In addition, the NRC inspector determined that the revisions of the code were in draft form. The acceptability of the STAMPEDE code for. emergency dose assessment is considered to be unresolved pending HL&P disposition of this matter (498/8724-01; 499/8724-01).

5. Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations. An unresolved item disclosed during the inspection is discussed in paragraph . Exit Interview The NRC inspector met with the NRC senior resident inspector and licensee representatives denoted in paragraph I on-April 24, 1987, and summarized the scope and findings of the inspection as presented in this repor . - .

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