IR 05000498/1991003
| ML20217B504 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 02/06/1991 |
| From: | Murray B, Terc N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20217B481 | List: |
| References | |
| 50-498-91-03, 50-499-91-03, NUDOCS 9103120137 | |
| Download: ML20217B504 (11) | |
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p APPENDIX U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report:
50-498/91-03 Operating Licenses: NPF-76 50-499/91-03 NPF-80 Dockets:
50-498 50-499 Licensee:
Houston Lighting and Power Company (HL&P)
Facility Name:
South Texas Project (STP), Units 1 and 2 Inspection At:
STP, Matagorda County, Texas Inspection Conducted: Janua ry 7-11, 1991 Inspector:
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Nemen M. Terc, Emergency Preparedness 1 Date Specialist, Radiological Protect, ind Emergency Preparedness Section Accompanying Personnel:
F. MacManus, Comex Corporation Approved:
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////7N Bla'ine Murray, Chief, _ diological Protection Cate '
and Emergency Prepar'dness Section Inspection Summary Inspection Conducted January 7-11, 1991 (Report 50-498/91-03; 50-499/91-03)
Areas Inspected:
Routine, unannounced inspection of the operational status of the emergency preparedness program including changes to the emergency plan and implementing procedures and changes to emergency facilities, equipment, instrumentation, and supplies.
The inspection also included the review of organization and management control, audits of the emergency preparedness program, and training of emergency response personnel.
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l Results: Within the areas inspected, no violations or deviations were identified.
Various concerns were identified during walkthroughs which included:
instances of incorrect emergency classifications, absence of a method for correcting emergency classifications while a notification was taking place, dose assessment errors, and unclear shif t technical advisor duties (see h
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paragraph 6).
In general, during walkthroughs, interviewees performed well and demonstrated knowledge and proficiency in the performance of their emergency duties which are adequate to ensure an appropriate response should an emergency occur.
The licensee had promptly and correctly implemented changes to the emergency plan and implementing procedures.
Changes to the licensee's emergency planning staff were deemed as enhancements.
in addition, several contractor personnel were working on enhancements to the emergency preparedness program.
Emergency responst facilities (ERFs) were maintained in a proper state of readiness.
Audits of the emergency preparedness program were comprehensive, and audit findings were resolved in a timely manner.
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-3-DETAILS 1.
Persons Contacted G_S_V.
- A. Harrison, Manager, Nuclear Licensing
- K. Christian, Operations Manager, Unit 1
- M. Chakrovorty, Executive Director, Nuclear Safety Review Board
- V Simmons, Manager, Emergency Response
- S. Rosen, Vice President, Nuclear Engineering
- M. Wisenburg, Plant Manager
- L. Giles, Operations Manager, Unit 2
- R. Pell, General Supervisor, Health Physics
- T. Jordan, General Manager, Nuclear Assurance
- W. Randlett, Manager, Nuclear Security
- W. Kinsey, Vice President, Generation
- J. Lovell, Manager, Technical Services N_RC
- J. Tapia, Senior Resident Inspector
- Denotes those present at the exit interview, 2.
Followup on Previous Inspection Findings (92701)
(Closed) Unresolved Item (498/9005-03; 499/9005-03):
During a previous inspection, the inspectors did not find a rationale used by the licensee to establish the numbers of thermoluminiscent-dosimeters (TLDs) and self-reading pocket dosimeters at the various ERFs.
During the present inspection, the inspectors held discussions with the radiativn protection staff and found that the number of dosimeters had been augmented in the ERFs and that the staff had considered various factors in order to dedicate the proper type and number of dosimeters to the various ERFs.
In addition, the inspectors noted that operabilitj checks were now required prior to using radiation detection instrumentation stored in emergency kits.
(Closed) Unresolved Item (498/9005-04; 499/9005-04):
During a previous inspection, the inspectors noted that various changes and deletions in the emergency response organization did not appear to be justified.
During the present inspection, the licensee's staff justified each deletion or change in their emergency response organization and showed how the duties and responsibilities of ecch position deleted would be carried out by other organizational members.
In addition, the licensee's staff explained how the transfer of some organizational members from one ERF to another would augment the ef ficiercy of the emergency response organization as a
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-4-(Closed) Exercise Weakness (498/9010-01; 499/9010-01):
During the 1990 exercise, the inspectors noted that the licensee failed to properly consider the full scope and ramifications of the simulated security threat. Af ter the exercise, on December 5,1990, a full security drill was conducted to train and test the response of emergency responders to a security threat.
The results of this drill showed that the licensee's performance was greatly enhanced.
During the drill, the full scope and ramifications of the simulated security event were adequately taken into consideration by key emergency responders.
(Closed) Exercise Weakness (498/9010-02; 499/9010-02):
During the 1990 exercise, the inspectors noted that no habitability checks were performed in the control room (CR) and that dosimetry was not issued.
The inspectors noted that on July 13 and December 5, 1990, the licensee conducted drills to test that habitability checks in the CR were properly performed and to ensure that dosimetry wc, issued.
(Closed) Exercise Weakness (498/9010-04; 499/9010-04): During the 1990 exercise, the inspectors noted that the licensee's procedures did not ccntain the conditions for classifying a general emergency (GE) involving an interfacing loss of coolant accident (LOCA) or a steam generator tube rupture accident.
Since then, the inspectors verified that a new N
emergency action level (EAL) was incorporated in Procedure OEPP01-ZA-0001,
" Emergency Classification," which directs the responders to properly classify the above conditions.
3.
Emergency Plan and Implementing Procedures (82701-02.01)
The inspectors reviewed changes to the emergency plan and implementing procedures to verify that these changes have not adversely affected the licensee's overall state of emergency preparedness.
The inspectors reviewed the licensee's emergency plan and noted that two revisions of the emergency plan, Revisions 10 and 11, dated March 27 and December 19, 1990, respectively, were implemented by the licensee. These revisions were made in acenrdance with Frocedure OEPP02-ZA-004-2, " Revision of the STPEGS Emergency Plan," to ensure that changes to the plan did not degrade the effectiveness of the plan and to ensure compliance with the requirements of 10 CFR 50.54(q).
The inspectors noted that 28 changes to procedures were made in 1990.
These changes were submitted in accordance with the requirements of 10 CFR 50, Aopendix E.
The inspectors reviewed a sample of procedures and noted that:
(1) procedure changes were checked for technical accuracy and consistency against other related procedures using Procedure OPGFG3-ZA-0004, " Plant Operations Review Committee,"
(2) proceFore changes, when finalized, were distributed to users on a timely basis using mechanisms for document control contained in Procedure IP-1.13 Q, " Document Control," and (3) selected members of the emergency response organization were notified to read changes to emergency l
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procedures by the guidelines of Procedure OEPP02-ZO-0024, " Emergency Preparedness Surveillance Schedule and Surveillance Instruction."
No violations or deviations were identified in this program area.
4.
Emergency Faci 11 ties Equipment, Instrumentation, and i
Supplies (82701-02.02)
The inspectors toured key emergency facilities to verify that equipment and supplies were available and adequately maintained.
These tours included the CRs, technical support centers (TSCs), operational support center (OSC), and emergency operations f acility (EOF).
The inspectors noted that equipment and supplies were in place as required by inventory forms in licensee's Procedure OEPP02-ZA-0002, " Emergency Equipment and Supplies Inventory."
The inspectors noted that although inventories had been conducted on a quarterly basis, the organizations in charge of performing inventories or maintenance of equipment were not ensuring that some equipment parts were functional.
The inspectors found that rubber "0" rings usea in the filter assemblies of emergency air sampling equipment had deteriorated so that they increased the probability of a degraded air sampling capability.
In addition, the inspectors noted that a microphone stand of the public address system in the Unit-2 TSC was broken and that one of the clocks on the wall had stopped.
Furthermore, the cesium-137 check sources used for performing operability checks on portable radiation instruments had not been placed in the Unit-2 emergency kits (see NRC Inspection Report 498/90-30; 499/90-30).
The licensee corrected these discrepancies during the course of the inspection and plans to assign responsibilities for inspecting emergency equipment and supplies to ascertain signs of deterioration. The licensee also plans to reevaluate the number and types of emergency equipment and supplies that should be contained in emergency kits at emergency response f acilities.
No violations or deviations were identified in this program area.
5.
Organization and Management Control (82701-02.03)
The inspectors reviewed the emergency preparedness organization and/or management control systems and the emergency response organization to determine if changes have been properly incorporated into the emergency plan and icplementing procedures and have not adversely affected the licensee's emergency response readiness, i.ew manager in charge of the emergency preparedness staf f was selected on June 1, 1990. The individual selected has an advanced degree in nuclear engineering and 19 years of experience in the nuclear industry.
He presently holds a senior reactor operator (SRO) license.
During the previous 29 months, he worked as a plant operations support manager.
In addition, two new individuals were brought on-board as part of the emergency preparedness staff. One of the new staff members worked
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-6-previously as shif t supervisor (SS) in Unit-1.
The other new staff member has an advanced degree in health physics, has operated and maintained the in plant radiation monitoring system, and has provided technical support for dose assessment and field monitoring procedures.
In addition, this individual worked for 18 months as a radiation protection supervisor in Unit-1.
The inspector noted that the licensee hes five contractors working full-time in the emergency preparedness enhancement program.
No changes have been made to the licensee's emergency response orcanization since the last inspection of these program activities (January 1990).
No violations or deviations were identified in this program area.
6.
Training (a2701-02.04, 82206, 82202)
The inspectors reviewed the emergency preparedness training program and interviewed emergency responders to verify that the training program was established and maintained in accordance with 10 CFR 50.47(b)(15), to determine whether the amount and type of training and retraining received by emergency respcuders was adequate, and to determine whether key decisionmakers were proficient in the performance of their duties and responsibilities during a simulated accident scenario.
In addition, the inspectors verified that changes made to the program since January 1990 were incorporated into the training program and that key emergency responders were aware of such changes, understood them, and had been properly trained to implement them.
Furthermore, the inspectors verified that authorities and responsibilities were clearly delineated for assessing accident conditions and making protective action recommendations (PARS), and determined if key decisionmakers from the CR were capable of implementing timely on-site and off-site corrective and protective actions.
The inspectors evaluated the emergency responders ability to understand the relationships between plant conditions and possible on-site and off-site consequences.
In order to accomplish this, the inspectors interviewed instructors, other members of the emergency planning staff, and reviewed a sample of training records of the persons interviewed.
Interviews with key members of the licensee's emergency response organization were also conducted.
The inspectors determined that specialized emergency preparedness training had been conducted for emergency responders, thtt lesson plans were in place, and written examinations were given commensurate with the materials presented.
In addition, the inspectors noted that part of the training consisted of practical, hands-on applications.
The inspectors reviewed the training records and lesson plans for training provided to off-site support personnel.
The licensee's records indicated that training for firemen, 2herif f s and deputies, hospital and ambulance
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personnel, and local county officials was conducted.
The inspectors noted that the les;on plans used for this training were appropriate.
The inspectors noted that emergency response organization (ERO) training records for day workers were maintained by the EP department, whereas, records for shift ERO personnel (security, engineering, operations, health physics, chemistry, and maintenance) were main'.ained by the department to which sney are assigned. The inspectors noted that the EP department does not routinely verify the status of ERO training for shift personnel.
The inspectors discussed the advantages of having a central record file or a routine verification program that would prevent assigning an ERO position to a person whose training was not current.
The inspectors reviewed the training records for the ERO and noted that the training of one shift radiological protection (RP) supervisor and two health physics technicians (HPTs) was not current, in addition, the training of one SS was not documeated.
in order to confirm the proficiency of key emergency r sponders, the inspectors conducted four separate 2-hour interviews w th selected members of the licensee's emergency response organization.
The inspectors interviewed four shifts.
Each shift was composed of a SS, who implements the emergency plan (EP) and becomes the emergency director (ED) in charge of coordinating emergency response activities; a unit supervisor, who directs plant vperations; one primary reactor operator (RO), a secondary R0; a third RO, who acts as a communicator; the shif t technical advisor (STA); a chemistry technician, who performs c5emical and radioisotopic analysis; a HPT, who performs dose assessment; and a head reactor plant operator / communicator.
The inspectors presented each team with an accident scenario which required operational and radiological assessments, classification, notifications, and formulation of Protective Action Recommendations (PARS)
to off-site authorities.
It was not intended to evaluate the abilities of the teams to mitigate the accident.
Prior to the interviews, the inspectors verified that the details in the scenarios were applicable, and procedures were made available to the teams. Guidelines were established at the start of each interview to ensure personnel were aware of the conditions under which the interviews and exercises were conducted. A licensee representative was present during the interviews and exercises for confirmation of observations.
Each interview lasted 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and consisted of two parts.
One part presented seven questions, and the other, a simulated accident scenario to direct the interviewees to classify, notify, perform dose assessment, and make PARS. Two interviews were conducted using one scenario and the simulator in a dynamic mode, and the other two were limited to table top walkthroughs using a different scenario.
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The inspectors noted that all teams performed well, but made the followfng observations:
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All four teams demonstrated their ability to determine PARS for each
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classification and the minimum recommendations for the general
emergency (GE) classification.
- During the tabletop walkthroughs in the EOF, the inspector observed the following:
One team overclassified 'n event based on the perception of a
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large break coolant leak into the containment when containment area radiation monitors levels increased.
The SS did not assess containment temperature, pressure, and sumps levels to confirm this conclusion.
Instead, the SS assumed a leak in the containment based on an increase of radiation levels and classified the event as a site area emergency (SAE). With no change in containment temperature, pressure, or sump level, a large break LOCA was unlikely.
The increase in containment radiation levels indicated possible fuel damage that occurred during the simulated main steam line break.
The appropriate classification would have been Alert.
The other team misclassified an event because the members did
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not research the EALs in sufficient depth to determine the appropriate classification.
In this instance, the SS classified the event of main steam line break using the EAL addressing an uncontrolled depressurization of the secondary side of the steam generator. The SS did not review the EALs to determine how they addressed an increase of 1000 times the normal radiation levels indicated by area radiation monitors.
This condition was provided in the scenario, and the event was classified as an Alert.
Both teams interviewed demonstrated the ability to use
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procedures to provide PARS to off-site agencies.
Notif*:ation forms were completed and appropriately approved prior to transmission to off-site agencies.
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During both walkthroughs, notifications were accomplished within
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15 minutes after the event was declared or changed.
NRC notification was accomplished promptly af ter state and local agencies were informed of the event.
Both SSs clearly demonstrated a command and control attitude and understood their emergency authorities and responsibilities.
STAS properly used the plant status trees to advise the ED and unit supervisor of l
critical safety functions.
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- During the dynamic simulator walkthroughs, the inspector observed the following:
Both teams demonstrated their ability to assess plant
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conditions. Notifications to state and local agencies and NRC were completed in a timely manner.
Both teams demonstrated the capability to use PAR decision trees and to provide the recommendations to state and local agencies.
In one case, the ED overclassified the (SAE) event, then after
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reevaluation of plant conditions, determined that a lower classification (Alert) was appropriate.
However, he had announced the higher classification to site personnel and decided to transmit the erroneous higher classification to state and local agencies.
The notification was accomplished, as directed, by the CR communicator.
The inspectors noted that this decision was incorrect.
Correcting the classification immediately would result in proper classification of actual ongoing events. The inspectors concluded that there was a need for further training concerning how to handle rapid changes to classifications while on-site and off-site notifications are taking place.
The licensee stated that they plan to review classification procedures for fast changing events.
The radiological director (RD) for one team appeared to be weak
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in performing dose assessment.
No dose assessment was performed that provided meaningful information during this team's exercise. The RD was unable to collect the necessary information (flow rate or leak rate and activity levels) for input to the dose assessment program.
Both S$s demonstrated good command and control and understood
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their emergency authorities and responsibilities.
STAS properly used the plant status trees to advise the ED and
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unit supervisor of critical safety functions.
However, one STA became overly involved in using the RM-11 radiation monitor console, not his normal function in the CR, which may have contributed to the overclassification of an event.
It appeared that STAS need to focus on their primary duties of assisting the ED with the analysis of reactor plant parameters during emergency conditions as outlined in Step 3.5 of Procedure CPOP01ZA-0018, " Emergency Operating Procedure Users Guide."
During one walkthrough, the main steam line monitor reading
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which reads in microcuries/ cubic centimeter (uci/cc) was provided to the ED. The ED mistakenly assumed that the units of the radiation monitor were in microcuries/second (pci/sec). As a result, the event was misclassified.
The inspectors noted that the EAL was based on readings in uci/sec.
The licensee
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-10-stated that they plan to review their current EALs +o eliminate confusion that might arise between the units of pc', sec versus pei/cc.
The inspectors noted that the use of the simulator in a dynamic mode greatly enhanced the ability of the teams to demonstrate their knowledge, capabilities, and training.
Ti.ese weaknesses identified during the conduct of these shif t interviews are considered an open item (498/9103-01; 499/9103-01).
No violations or deviations were identified in this program area.
7.
Independent Audits (82701-C2.05)
The inspectors examined independent and internal audit reports for the licensee's emergency preparedness program performed since the last operational status inspection on January 22, 1990, to determine compliance with the requirements of 10 CFR 50.54(t), and to determine whether the licensee's corrective actions were implemented in a timely manner. The inspectors also examined the licensee's audit program to determine if it had a corrective action system for deficiencies and weaknesses identified during drills and exercises.
The inspectors examined the licensee's audit program to determine whether appropriate means existed to record and followup each item until corrective actions were completed.
An inJependent audit was performed during the period August 20 through September 10, 1990, by a certified lead auditor, two certified auditors, and a health physics technical specialist from another nuclear power facility.
The annual quality assurance (QA) audit included primary organization, responsibilities for emergency response, facilities, interactions with state and local governments, emergency classification and protective action level scheme, notifications process, communetions, public information, emergency facilities and equipment, medical str, ices, recovery and reentry, periodic drills, plan development, review and distribution, transfer of command and control, and prompt notification sirens and tone alert radios.
In addition, the licensee conducted six surveillances pertaining to communications testing, facilities inventories, off-site interfaces, observations of full-scope drills, and the graded exercise which identified various findings.
Audit findings that were not corrected during the course of the audit were tracked through closure in accordance with Procedure IP-4.11Q, " Quality Verification Deficiency Reporting." The audit performed for 1990 identified eight findings, four of which were ccrrected during the course of the audit.
Problem reports were generated for each finding and responsibilities for corrective actions were assigned by the QA department.
The inspectors noted that the scopt and depth of the audit appeared to meet the requirements of 10 CFR 50.54(t), and that the use of additional
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-11-expertise outside the licensee's organization enhanced the quality of the audit.
No violations or deviations were identified in this program area.
8.
Exit Interview The inspectors met with the resident inspector and licensee's representatives denoted in paragraph 1 on January 11, 1991, and summarized the scope and findings of the inspection as presented in this report.
The licensee did not identify as proprietary any of the materials provided to, or reviewed by, the inspectors during the inspection.
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