IR 05000498/1999009
| ML20207E215 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 05/25/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20207E198 | List: |
| References | |
| 50-498-99-09, 50-498-99-9, 50-499-99-09, 50-499-99-9, NUDOCS 9906040194 | |
| Download: ML20207E215 (13) | |
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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket Nos.:
50-498 50-499 License Nos.:
NPF-76 NPF-80 Report No.:
50-498/99-009 50-499/99-009 Licensee:
STP Nuclear Operating Company Facility:
South Texas Project Electric Generating Station, Units 1 and 2 Location:
FM 521 - 8 miles west of Wadsworth Texas Dates:
May 3 to 6,1999 Inspector (s):
S. L. McCrory, Reactor Engineer, Operations Branch P. J. Elkmann, Emergency Preparedness Analyst, Plant Support Branch Approved By:
Gail M. Good, Chief, Plart Support Branch Division of Reactor Safety Attachment:
Supplemental Information i
9906040194 990525 PDR ADOCK 05000498 e
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2-EXECUTIVE SUMMARY j
South Texas Project Electric Generating Station, Units 1 and 2 NRC Inspection Report No. 50-498/99-009; 50-499/99-009 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.
Plant Suocort The licensee has implemented a sustained highly effective emergency preparedness
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program. This was evidenced by good operational and emergency plan implementation skills, continuing emergency facility readiness, an effective training program, and sound program oversight. Close coordination with offsite officials remained an important aspect of the licensee's program (Sections P1-7).
The licensee continued to accurately assess on-site events for emergency plan
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implementation (Section P1).
The licensee maintained emergency response facilities, equipment, and systems in
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good material condition and in a high state of readiness. The licensee promptly and effectively dealt with minor discrepancies identified during the inspection (Section P2).
Minor documentation and procedure discrepancies did not detract from the licensee's
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otherwise sound procedures and complete records (Section P3).
The crews demonstrated very good operational skills in the areas of diagnostics,
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procedure use, communication, supervision, and promptly and correctly performed key emergency plan elements (classification, notification, and protective action recommendations) (Section P4).
The licensee's training program ensured that all emergency responders were highly
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qualified and current in recurring training requirements. The training staff hac pgraded the testing material used to evaluate emergency responder knowledge and at ty (Section PS).
The licensee maintained a stable emergency preparedness department that was staffed
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with experienced and knowledgeable personnel, and promptly acted to fill important positions in the emergency response organization roster. The licensee maintained up-to-date agreements with offsite agencies that were properly reflected in the emergency plan station procedures (Section P6).
Appropriately qualified licensee personnel continued to perform very good audits and
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self assessments. The licensee implemented prompt and effective corrective actions for audit and assessment findings (Section P7).
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-3-Report Details IV. Plant Support P1 Conduct of Emergency Preparedness Activities (93702)
The inspectors reviewed event notifications made to the NRC operations center by the -
licensee since September 4,1997, to determine if the events were properly classified.
The licensee had issued 33 event notifications and had made no emergency classifications during that time. The inspectors reviewed the event details of selected event notifications against the emergency action level thresholds in Procedure OERP01-ZV IN01, " Emergency Classification," Revision 4. The inspectors confirmed that none of the events had warranted an emergency declaration. The inspectors concluded that the licensee continued to accurately assess on-site events for emergency plan implementation.'
P2 Status of Emergency Preparedness Facilities, Equipment, and Resources a.
Insoection Scope (82701-02.02)
The inspectors:
Toured key emergency response facilities, including the alternate emergency
operations facility, and reviewed equipment inventories and condition to determine if they were adequately maintained.
Reviewed facilities and equipment to determine whether changes made since
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the last inspection were technically adequate, met NRC requirements and licensee commitments, and were appropriately incorporated into the emergency plan and implementing procedures.
Reviewed documents in the facilities to determine if they were the current
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revisions.
Reviewed communications equipment in the emergency response facilities to
determine if equipment was operable and if communication drills were conducted as required.
Observed the use of dose assessment and dose projection systems in the
emergency operations facility.
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Observations and Findinos The licensee maintained emergency response facilities in good condition. The inspectors verified that all communications and computer equipment were functional and i
that all facilities were well equipped with numerous status boards. The licensee maintained up-to-date controlled documents in all facilities.
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f-4-During the tour of the control room, the inspectors observed the storage area for spare breathing air bottles. Documentation on the bottles indicated that the bottles were inspected on an appropriate frequency, and the pressure gauges on each bottle indicated an acceptable pressure. The inspectors determined that the spare breathing air bottles were properly stored and maintained.
The inspectors observed several control room crew members wearing glasses. When asked, the shift supervisors promptly identified additional on-shift personnel who also wore glasses. All crew members who needed eyepiece inserts in order to use respiratory protection had current lens prescriptions, and the inserts were readily available.
The inspectors verified that the emergency kits were properly maintained and stocked.
The inspectors reviewed the inventory frequency and found that inventories were performed per the licensee's procedures.
j The inspectors observed the operation of three lapel air samplers in the emergency operation facility. All of the air samplers operated at 2 liters per minute flow rate, rather than the 3 liters per minute marked on the pump flow meter and attached label. The licensee provided a copy of the calibration procedure that confirmed that the air samplers were to be set at 2 liters per minute. The inspectors reviewed calibration records for these pumps and verified that they had been calibrated according to current calibration procedures. The licensee identified additional air samplers located in the calibration facility with the same instrument marking and labeling discrepancies observed in the emergency operations facility. The licensee field calibrated the pumps in the emergency operations facility to match the pump markings and initiated Condition Report 99-7356 to resolve the calibration and pump markings at the correct value of 2 liters per minute.
The inspectors determined that the discrepancies could have led to confusion in the field
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regarding sampler operation and that non-conservative dose estimates may have been made if 3 liters per minute, rather than 2 liters per minute, was used for dose calculations. Given tha degree of redundancy for dose determination, and the fact that dose impact is more concerned with a variance over orders-of-magnitude, the inspectors concluded that the discrepancy was not significant with regard to radiation protection monitoring. The inspectors determined that the licensee's actions were timely and appropriate.
An emergency response organization dose assessor demonstrated the use of dose assessment procedures and equipment in the emergency operations facility. All facility
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I computers used to obtain plant information and perform dose assessment functioned properly. The dose assessor spoke knowledgeably about dose assessment procedures and successfully completed an assessment scenario.
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Conclusions The licensee maintained emergency response facilitics, equipment, and systems in good material condition and in a high state of readiness. The licensee promptly and effectively dealt with minor discrepancies identified during the inspection.
P3 Emergency Preparedness Procedures and Documentation a.
Inspection Scope (82701-02.01)
The inspectors reviewed:
Changes incorporated by Revision 18, Change Notices 18-1 and 18-2, to the
licensee's emergency plan to determine if the changes adversely affected the licensee's state of emergency preparedness and to determine if the changes were appropriately incorporated into emergency plan implementing procedures.
The licensee's process for documenting annual reviews of and changes to
emergency action levels by state and local agencies.
Procedures and aids to determine if appropriate off-site agency telephone
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numbers and contacts were listed.
On-shift staffing, including the staff augmentation plan, to determine the
adequacy of minimum staffing levels to perform the tasks identified in the licensee's emergency plan.
The current emergency response position roster to determine the depth of
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coverage for key positions.
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The results of augmentation drills to determine if the results were consistent with
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the licensee's plan.
The licensee's program for tracking' exercise objectives, drills, and exercises to
determine if the required elements were properly scheduled.
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Observations and Findinas While reviewing reports for selected recent drills and exercises, the inspectors determined that the format used in drill documentation made it difficult to determine if emergency plan drill requirements were met. Specific elemento of required specialty drills were not clearly described or referenced. Otherwise, the licensee conducted these activities consistent with the drill and exercise program. The licensee issued Condition Report 99-7258 to clarify the drill documentation.
The licensee's Procedures OERP01-ZV-IN07,"Offsite Protective Action Recommendations," Revision 5, and OERP01-ZV-SH01, " Shift Supervisor," Revision 12,
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permitted the shift supervisor to make a discretionary protective action recommendation at a site area emergency based on indications of fuel damage. The inspectors discussed the licensee's procedure for making protective action recommendations with
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staff from the Federal Emergency Management Agency (FEMA), Region VI, on May 10, 1999. FEMA staff indicated that they were aware that the licensee could recommend
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evacuation during a site area emergency classification. FEMA staff provided background information which indicated that the licensee's procedure was based on requests from off-site agencies. Therefore, the inspectors concluded that the procedures were acceptable.
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. During the walkthrough scenarios, the inspectors observed that the first crew did not l
make a protective action recommendation at the site area emergency with indications of l
fuel damage. However, the second crew did issue a protective action recommendation to radially evacuate to a distance of 5 miles at the site area emergency classification
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based on indications of fuel damage. The inspectors challenged this inconsistent
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l response given that both crews responded to the same scenario and that inspector I
observations and licensee post scenario critiques determined that the crews were l
equally capable and competent.
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The licensee attributed the differing response to procedural discrepancies and the recall knowledge of the individual shift supervisors. Procedure OERP01-ZV-IN07 contained j
evaluation prompts regarding the need to issue protective action recommendations l
based, in part, on the immediately available dose-assessment capability. Procedure l
OERP01-ZV-SH01, which was the one that shift supervisors were expected to use, did j
not contain this information. Therefore, the first shift supervisor made the more
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appropriate determination to withhold early protective action recommendations, because
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the individual remembered the criteria in Procedure OERP01-ZV-IN07. However, the
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l second shift supervisor, using the expected procedure, OERP01-ZV-SH01, issued an early protective action recommendation consistent with the requirements of that procedure.
The licensee further stated that a revision to Procedure OERP01-ZV-SH01 that corrected this discrepancy was in the final approvat stages prior to the inspection but had not yet been issued. The inspectors reviewed the draft procedure and agreed that it
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should reduce the type of inconsistent determination observed during the walkthrough l
scenarios.
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Conclusions l
' Minor documentation and procedure discrepancies did not detract from the licensee's otherwise sound procedures and complete records.
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-7-P4 Staff Knowledge and Performance in Emergency Preparedness l'
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. Inspection Scope (82701-2.04)
The inspectors conducted walkthroughs with two operating crews using a dynamic l
scenario developed by the licensee and run on the plant-specific control room simulator.
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The scenario ran for about 90 minutes and presented the operators with conditions that warranted emergency classification ranging from alert through general emergency. The licensee conducted a critique session immediately after.each scenario. The inspectors j
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L assessed the ability of control room teams to recognize accident conditions. The '
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inspectors also observed the interactions of the crew members to verify that authorities and responsibilities were clearly defined and understood.
The scenario started with an alert due to a fire in Bus 1L, a vital area. A unit shutdown
began due to a small reactor coolant system leak that continued to increase in rate.
j Following a turbine trip, the reactor failed to automatically trip and could not be manually
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tripped from the control board (an anticipated-transient-without-a-trip condition). A site area emergency was declared based on the anticipated-transient-without-a-trip
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condition. The reactor was tripped by the removal of the reactor protection system l
fuses. The reactor coolant leak became a large break loss-of-coolant-accident and
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containment radiation monitors trended to greater than 1000 R/h. After draining the reactor water storage tank, containment sump recirculation was established. A leak occurred into the fuel building due to a leak on a low head safety injection pump, and a release occurred through the fuel building ventilation system. A general emergency was
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declared based on the loss of all three-fission product barriers based on the elevated Unit Vent release rate.
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Qbsgrvations and Findinas Both crews' demonstrated consistently good diagnostic skills, procedure use, and.
supervisory oversight. The time for operators to recognize plant conditions that warranted evaluation for emergency action level classifications ranged from less than a minute to 2-3 minutes. The longer times related to the need to obtain information from outside the control room to properly characterize overall plant conditions. Operators consistently referred to the appropriate plant abnormal and emergency operating procedures throughout the scenario. The crew supervisors established clear priorities for mitigating actions to restore system functions and recover various equipment. - In
. most instances, the operators displayed effective human performance skills with regard to communications, self-verification, and peer checking.
- The crews recognized plant conditions that warranted emergency classification and used appropriate emergency action levels. In all cases, the shift supervisor performing the' emergency director's role declared an emergency classification within 5 minutes of the casualty event symptoms being available to the control room operators. The emergency responders made timely off-site notifications. The emergency responders completed appropriate dose assessments and evaluated protective action recommendations accordingly.
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8-Following each scenario, each simulator crew and the emergency preparedness department conducted an extensive critique. One of the licensee evaluators recorded the critique sessions. The participants candidly and self-critically focused on improvements for the entire team.
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Conclusions The crews demonstrated very good operational skills in the areas of diagnostics, procedure use, communication, supervision, and promptly and correctly performed key emergency plan elements (classification, notification, and protective action recommendations).
P5 Staff Training and Qualification in Emergency Preparedness a.
Inspection Scope (82701-02.04)
The inspectors reviewed the training program procedure, lesson plans, and training records for selected individuals. The inspectors focused on the status of qualifications of individuals in the emergency response organization. The inspectors also reviewed administrative requirements pertaining to emergency response organization staff and selection, lesson plan preparation and maintenance, and the systems-based approach to training, b.
Observations end Findinas Since the previous inspection, the licensee had implemented a computer-based data base to track the training and qualifications of emergency response organization staff.
Records were manually reviewed to ensure that retraining was accomplished as required. The inspectors reviewed the qualifications of selected emergency response organization personnel using the data base. Procedure OPGP03-ZT-0139, " Emergency
Preparedness Training Program," Revision 5, identified the required initial and annual training for emergency response organization personnel. The selected records reviewed by the inspectors indicated that individuals had received the proper training for their assigned positions.
The licensee discussed a system upgrade of the training data base schedulod for 1999 that should incorporate computer-based methods for reviewing retraining deadlines and ensuring the timely notification of the affected staff.
The licensee emergency preparedness trainer had discussed the subject of proper testing methodology with the licencee's licensed operator training group. Ar, a result of these discussions, the trainer had begun an overhaul of the examination question banks used in constructing initial and retraining examinations for the emergency esponse organization staf p
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Conclusions l
The licensee's training program ensured that all emergency responders were highly qualified and current in recurring training requirements. The training staff had upgraded the testing material used to evaluate emergency responder knowledge and ability.
l P6 Emergency Preparedness Organization and Administration a.
inspection Scoce (82701-02.03)
The inspectors reviewed: (1) emergency preparedness organization and changes in department staffing, (2) current emergency response' organization assignments and staffing, and (3) agreements with off-site agencies.
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Observations and Findinas The emergency preparedness department staffing had been generally stable since the previous inspection, particularly at the manager and supervisor levels. The staff had a great depth of experience in the emergency preparedness area, with personnel who were knowledgeable in operations, radiation protection, emergency planning, facility maintenance, and training.
At the time of the inspection, the licensee was reassigning emergency preparedness operational responsibilities to a new station vice-president, due to the retirement of the incumbent. The individual selected as station vice-president previously participated in the emergency response organization. The inspectors determined that the individual's experience and the stability of the emergency preparedness department supervision would result in a smooth transition that maintained an appropriate emphasis on the emergency preparedness function.
Inspectors observed that a technical support center manager position was unfilled on the emergency response orgar:ization roster. Senior station management told the inspectors that they expected to be able to announce the replacement during the week following the inspection. Staffing for all other emergency response organization positions was stable.
The licensee maintained complete, updated and easily accessible records of memoranda-of-agreement with offsite agencies. The licensee made timely revisions to station procedures and the emergency plan to reflect changes in agreements with off-site agencies.
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Conclusions The licensee maintained a stable emergency preparedness department that was staffed
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with experienced and knowledgeable personnel, and promptly acted to fill important positions in the emergency response organization roster. The licensee maintained up-
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to-date agreements with offsite agencies that were properly reflected in the emergency plan station procedures.
P7 Quality Assurance in Emergency Preparedness Activities a.
Inspection Scope (82701-02.05 and 2.06)
The inspectors reviewed:
The July 28,1998, and March 16,1999, independent and internal review and
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audit reports of the licensee's emergency preparedness program to determine compliance with NRC requirements and licensee commitments.
The effectiveness of the licensee's controls in identifying, resolving, and
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preventing problems by reviewing corrective action systems, root cause i
analyses, safety committees, and emergency preparedness self assessments.
Emergency preparedness condition reports generated in 1997 and 1998.
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The licensee's emergency preparedness performance indicator program.
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Observations and Findinas The licensee performed audits of the emergency preparedness program on an annual basis as required by the emergency plan. The personnel who performed the audits demonstrated familiarity with emergency preparedness program implementation, regulations, and requirements. The licensee maintained audit packages that were complete, thorough, and easy to understand. The inspectors considered the emergency preparedness program audits to be very good.
The inspectors reviewed the assessment of the off-site interfaces for the emergency preparedness program. The licensee had conducted an in-depth off-site assessment during the audit cycles reviewed by the inspectors. The assessment indicated that the licensee continued to foster a very good working relationship with off-site agencies that were maintained through frequent routine contacts with many off-site officials. The licensee appropriately documented the transmittal of the off-site interface assessment to off-site agencies.
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Conclusions:
Appropriately qualified licensee personnel continued to perform very good audits and self assessments. The licensee implemented prompt and effective corrective actions for audit and assessment findings.
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The inspectors presented the inspection results to members of licensee management at an exit meeting on May 6,1999. The licensee acknowledge the findings presented. No proprietary information was identified. The licensee confirmed that all confidential documents provided by the licensee had been returned.
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ATTACHMENT SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED l
Licensee i
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' L. Barton, Offsite Program Specialist
R. Brown, Shift Supervisor l_
J. Diehl, Health Physicist
' T. Frawley, Shift Supervisor K. Keyes, Staff Emergency Planning Specialist
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l M. Keyes, Staff Emergency Planning Specialist -
L. Meier, Staff Emergency Planning Specialist j
R. Piggott, Senior Quality Assurance Specialist
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F. Puleo, Supervisor, Emergency Response.
P. Serra, Manager, Emergency Response, Public Affairs & Communications M. Tomak, Senior Health Physics Technician V. Wagnon, Emergency Response Specialist INSPECTION PROCEDURES USED l
82701 Operability Status of the Emergency Preparedness Program 93702 Prompt Onsite Response to Events at Operating Power Reactors LIST OF ITEMS OPENED'AND CLOSED Ooened l
None
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None LIST OF DOCUMENTS REVIEWED Emeraency Plan implementina Procedures OERP01 ZV-IN07 Offsite Protective Action Recommendations Revision 5 OERP01-ZV-SH01 Shift Supervisor Revision 12 OPERP01-ZV-IN01 Emergency Classification Revision 4 OPGP03-ZT-0139 Emergency Preparedness Training Prograrn Revision 5 OPGP05-ZV-0001 Emergency Response Exercises and Drills Revision 2 OPGP05 ZV-0009 Emergency Facility Inventories and inspections Revision 5
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OPRPO4 ZR-0017
.Use of Lapel Air Samplers Revision 1 t
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O-2-Other Documents South Texas Project Emergency Plan, Revision 18, July 28,1997 Emergency Response Roster, May 2,1999, run date All 10 CFR 50.72 event reports related to South Texas Project from September 4,1997, through May 6,1999 Report for Medical Services Drill, November 13,1997 Report for Unannounced Drive in Activation Drill, February 17,1998 Combined Functional Drill Report for May 28,1998 Dress Rehersal Management Critique, July 2,1998 Report for Evaluated Exercise, August 5,1998 Report for Medical Services Drill, November 18,1998 PASS Drill Report for December 10,1998 Condition Report summary for condition reports related to Emergency Response since September 4,1997, report dated May 3,1999 Condition Report 99-7258, May 5,1999, Clarify Drill Objectives in the Drill and Exercise Reports that meet the regulatory and emergency plan requirements for STP's drill and exercise program.
Condition Report 99-7356, May 6,1999, Evaluate the off site field teams Procedure OERP01 ZV-TP02 to determine if appropriate guidance is given on flow rate values Quality Audit Report 98-06, Emergency Preparedness, July 28,1998 Quality Audit Report 99-03, Emergency Preparedness, March 16,1999 l