ML20011F443
| ML20011F443 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/24/1990 |
| From: | Powers D, Spitzberg D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20011F442 | List: |
| References | |
| 50-445-90-04, 50-445-90-4, 50-446-90-04, 50-446-90-4, NUDOCS 9003060040 | |
| Download: ML20011F443 (10) | |
See also: IR 05000445/1990004
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION IV
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-NRC Inspection Report:
50-445/90-04
Construction Permits: CPPR-126
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50-446/90-04
.CPPR-127
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Dockets:- 50-445
50-446
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-Licensee:
TU. Electric (TV)
Skyway' Tower
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400 North Olive, L.B. 81
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Dallasy Texas 75201
Facility-Name:
Comanche Peak' Steam Electric Station
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Inspection At: ' Glen-Rose, Texas
Inspection Conducted: 3 January 16-18, 1990
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-Inspector:
M
2 z3-90
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Dr. [T.EBlair Spitpeg,
ergency Dreparedness
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Analyst
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Accompanied by:
F. L. McManus, Engineer, Comex Corporation
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Approved:
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Dr. D. A. Powers, Chief, Security and
Date
Emergency Preparedness Section
-Inspection Summary
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Inspection Conducted January 16-18. 1990 (Report 50-445/90-04: 50-446/90-04)
~ Areas Inspected:
Special, announced inspection of the emergency preparedness
program to determine the status of licensee actions in response to findings ~of
the NRC's June 5-9, 1989, Emergency Preparedness Appraisal (Reference NRC
Inspection Report 50-445/89-43; 50-446/89-43).
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Results: Within the areas inspected, no violations or deviations were
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identified. - Of 21 open significant appraisal findings, 21 were closed during
,this inspection. Of 26 open improvement items from the appraisal,15 were
closed. With the closure of the significant appraisal findings, the licensee's
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emergency preparedness program has been determined to be in a state of
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operational readiness.
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DETAILS
1.
Persons Contacted
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- W. J. Cahill, Jr. , Executive Vice President -
- A. B. Scott, Vice President, Nuclear Operations
- G. Bell, Nuclear Licensing Engineer
- M. Blevins, Manager of Nuclear Operations
- J. M. Salsman, Manager, Emergency Planning
- J. R. Gallman III, Supervisor, Engineering Analysis
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- T. A. Carder, Emergency Planner
- T. A. - Hope, Site Licensing Engineer
- J. D. Rodriquez, Nuclear Licensing Engireer
- J. C. Hicks,' Manager, Licensing Compliance
- F. Dunham, Quality Assurance Engineer-
NRC
J. Wiebe, Senior Project Inspector
- R. Warnick, Assistant Director for Inspection Programs,
Comanche Peak Project Division, Nuclear Reactor Regulation (NRR)
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- D. A. Powers, Chief,' Security and Emergency Preparedness Section
The inspection team also held discussions with other statior, and corporate
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personnel in the areas- of security, health physics, operations, training,
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and emergency response.
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- Denotes those present at the exit interview.
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2.
Followup on- Previous Inspection Findings (92701)
a.
Significant Appraisal Findings Closed (NRC Inspection
' Report 50-445/89-43; 50-446/89-43)
(Closed) Significant Appraisal Finding (445/8943-01; 446/8943-01):
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Review the description of the emergency organization and revise it as
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necessary to provide a clear depiction of all emergency functions
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required during-initial, intermediate, and final phases of
augmentation and recovery; update the site and corporate EPs to
describe the updated organization; and revise and issue implementing
procedures which have been human engineered so that all emergency
response tasks can be carried out using the command and information
pathways of the organization.
The updated description of the
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emergency organization should include a sufficient level of detail to
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clearly specify the command hierarchy, its structure, and reporting
chains and interrelationships at any phase of augmentation, and
include supervisory as well as nonsupervisory elements.
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'The. inspector evaluated Revision 11 of the CPSES Emergency Plan (EP).
Organization flow diagrams have been incorporated into Section 1,
Organization, of the EP. The flow diagrams define the emergency
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organizations command hierarchy structure and reporting chains..
Interrelated diagrams detail the emergency organization structure for
each phase of emergency classifications.
Procedures and checklists
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require facility &ctivation of the Technical Support Center (TSC),
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and Emergency Operations Facility (EOF), prior to exercising command
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and control from the facility.
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(Closed) Significant Appraisal' Finding (445/8943-02; 446/8943-02):
Remove dose assessment responsibilities from shift technical
advisor (STA) in order to comply with NUREG-0737, Appendix ~C.
The inspector reviewed EPP-304, Revision 10, Section 4.1.1 which
removed the dose assessment responsibility from the STA and shifted
it to the on-shift radiation protection technician.
EPP-300,
Revision 3, Section 2.4.1, had also been changed to make the on-duty
radiation protection technician responsible for dose assessments
performed in the control room prior to activation of the TSC.
The
STA remains as an alternate dose assessor.
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(Llosed) Significant Appraisal Finding (445/8943-03; 446/8943-03):
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Complete training for emergency response personnel including any
training associated with the completion of emergency systems-and
related procedures.
A review of training records was conduct'ed to-determine completion of-
emergency system and procedure traiaing.
Based on this review
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sufficient personnel have completed training to-adequately staff the
emergency organization.in accordance with the utility's emergency
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plan-
Training for the emergency organization was completed in
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January 1990.
(Closed) Significant Appraisal Finding (445/8943-04; 446/8943-04):
Review and revise training requirements to include practical,
hands-on training, and drill participation.
The inspector reviewed Procedure TRA-105, Revision 8, " Emergency
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Preparedness Training," and noted in Part B a description of hands-on
training to'be completed in each training / drill offered.
Procedure EPP-902, Revision 1, was changed on October 16, 1989, with
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the addition of Section 4.2.2.8 which provides that the selection of
participants for annual field exercises will be made with the goal in
mind of having all members of the emergency organization participate
in an exercise at least every 2 years.
(Closed) Significant Appraisal Finding (445/8943-05; 446/8943-05):
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Develop specific qualification requirements for each position in the
emergency response organization.
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In the response letter dated October 2, 1989, the licensee committed
to develop qualification requirements-of each emergency response
organization position by December 31, 1990. As an interim measure,
an' agreement was= reached between the licensee and NRC Region IV to
submit for review the resumes of individuals currently assigned to
key emergency positions. The NRC received this submittal by letter
dated December 21, 1989, and found the qualifications of the
personnel to be' satisfactory.
In order to track the commitment to-
develop general qualification requirements for these positions by
December 31, 1990, _ a'new item will be opened (0 pen Item 445/9004-01;
446/9004-01).
(Closed) Significant Appraisal Finding (445/8943-06; 446/8943-06):
Complete the installation and testing of instrumentation, systems,
and controls in the CR that are required to assess plant and
environmental conditions.
Discussion with utility personnel indicated the RM-11 system is
complete. The' system is installed and functioning as designed.
Control Room HVAC-system installation is complete.
System
preoperational testing has been performed and the utility has
accepted the system.
Surveillances are being performed in accordance
with the master surveillance test list.
Some difficulty has been
noted in establishing and maintaining the required positive pressure
in the CR envelop. The excessive leakage appears to be around the
door seals.
The utility engineering department is evaluating more
effective door seals.
(Closed) Significant Appraisal Finding-(445/8943-07; 446/8943-07):
Complete the installation of TSC equipment. The inspector toured the
.TSC and found that dedicated emergency equipment assigned to the TSC
was in-place and operational.
(Closed) Significant Appraisal Finding (445/8943-09; 446/8943-09):
Install an ingestion pathway map in the EOF to assist in monitoring
the efforts of offsite authorities responsible for defining the
extent of long term, offsite radiological conditions. The inspector
toured the E0F and noted that a 50-mile radius ingestion pathway map
was available. Permanent mounting is awaiting a decision by State of-
Texas representatives as to location.
(Closed) Significant Appraisal Finding (445/8943-10; 446/8943-10):
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Complete the setup of the multichannel analyzer and
sodium-iodide (Nal) detector for counting environmental samples.
The
inspector observed the portable multichannel analyzer and NaI
detector which was set up in the chemistry hot lab of the nuclear
operations support facility (NOSF).
The instrumentation was noted to
be in calibration and operational.
(Closed) Significant Appraisal Finding (445/8943-11; 446/8943-11):
Assemble medical kits containing key medical supplies for emergency
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response personnel who would respond as part of the first-aid team.
The inspector observed the medical kit located at the RCA access
. control hallway and discussed its maintenance with a national fire
.and medical technician. The kit is checked daily against an
inventory list.
(Closed) Significant Appraisal Finding (445/8943-14; .446/8943-14):
Provide decontamination supplies in decontamination facilities. The
inspector toured-the decontamination facilities located in the NOSF
and the turbine building off of the RCA access control hallway. The
facilities were. stocked with decontamination supplies and inventory
records maintained in accordance with Procedure RPI-402-2, " Personnel
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Decontamination," were found to be in order.
(Closed) Significant- Appraisal Finding (445/8943-16; 446/8943-16):
Revise Procedure EPP-207 to provide specific instructions as to the
news media and offsite agencies to be contacted initially for the
dissemination of information to the public.
The inspector reviewed
Procedure EPP-207 to determine whether adequate instructions were
provided to ensure the newt. media and offsite agencies would be
contacted for the dissemination of information to the public. A step
has been-incorporated into EPP-207 that directs notification of news
media and offsite government information representatives when an
emergency is declared.
Phone numbers and contact name or title were
provided in the emergency facility telephone directory dated
October 6, 1989.
(Closed) Significant Appraisal Finding (445/8943-17; 446/8943-17):
Complete the news seminar providing the news media with the utility
' points of contact and locations where accident information can be
obtained. The inspector reviewed attendance rosters and determined
that on-July 13, 1989, the utility hosted a news media seminar to
provide points of contact and general facility information.
Procedure EPP-903, "Public Information Activities to Support Emergency
Preparedness," specifies annual news media briefings for
local and Dallas / Fort Worth area media.
(Closed) Significant Appraisal Finding (445/8943-18; 446/8943-18):
Complete the training of the CPSES staff on their duties in the News
Center regarding dissemination of information to the public.
A review of training attendance records was conducted by the
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inspector to determine whether CPSES staff training was completed.
Based on this review, a sufficient number of personnel received
training to support News Center staffing and disseminations of
information to the public.
(Closed) Significant Appraisal Finding (445/8943-22; 446/8943-22):
Complete the installation, testing, and turnover of the DRMS system,
and confirm that instrument maintenance and calibretion checks are
performed in accordance with applicable requirements. The inspector
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noted that the DRMS was accepted by the;1icensee for operation'on
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October 10, 1989. Discussion with personnel responsible for.the
system indicated the system functions as designed, all channels have-
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been calibrated and-the system surveillances have been performed as
required.
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(Closed) Significant Appraisal Finding (445/8943-24; 446/8943-24):
Complete the installation, testing, and turnover of nonradiation
process monitoring systems.
In!t1 ate appropriate preventive
maintenance checks on the systems and conduct appropriate training on
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operations, analysis, and distribution of. data obtained from the
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system. The inspector determined that operational testing of the
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Seismic Monitoring System has been completed. The system has been
maintained and calibrated as required by the master surveillance test
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found to be knowledgeable of the system.
System records were
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reviewed and no discrepancies were noted. Nonradiation process
monitoring system installation, testing, and turnover has been
completed.
Emergency system training was completed in January 1990.
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(Closed) Significant Appraisal Finding (445/8943-25; 446/8943-25):
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Complete the construction and installation of the primary
meteorological tower and related equipment.
Construction and
insta11ation' of-the meteorological tower and related equipment has
been completed. The utility demonstrated to the inspector the
capability-to access and display meteorological data using the
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Emergency Response ~ Facilities (ERF) computer system.
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(Closed) Significant Appraisal Finding (445/8943-28; 446/8943-28):
Complete the review and revision of the EAL/ Emergency Classification
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Procedure. The inspector noted that the licensee had completed the
review / revision of EPP-201, " Assessment of Emergency Action Levels,
Emergency Classification, and Plan Activation." 1he procedure was
-issued on July 18, 1989. Subsequent Revision 7 to EPP-201 was
. approved with an effective date of December 22, 1989.
(Closed) Significant Appraisal Finding (445/8943-29; 446/8943-29):
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Revise procedures to assign a staff member other than the STA to
perform dose assessment functions until the CR is relieved of the
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function by the TSC.
The inspector reviewed EPP-304, Revision 10,
Section 4.1.1, which removed the dose assessment responsibility from
the STA and shifted it to the on-shift radiation protection
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technician.
EPP-300, Revision 3, Section 2.4.1, had also been
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changed to make the on-duty radiation protection technician
responsible for dose ascessments performed in the control room prior
to a:tiv'ation of the TSC.
The STA remains as an alternate dose
assessor.
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(Closed) Significent Appraisal Finding (445/8943-33; 446/8943-33):
Revise Procedure EPp-304 to add guidance for developing offsite PARS
based on operational assessment of plant conditions.
Inccrporate, in
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Procedure EPP-304, a decisionmaking aid such as the " logic tree"
shown in IE Information Notice 83-28, Figure 1, " Flow Chart for
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General Emergency Off site Protective Decisions." Delete from
Procedure EPP-304 those considerations (such as weather, special
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facilities, and population distributions) that are not germane to
effectively developing and recommending-a protective action.
Revise
Procedure EPP-304 to eliminate the requirement to discuss PARS with
the State or counties until after the PARS are made to offsite
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agencies.:
'The' inspector reviewed EPP-304, Revision 10, and determined that the
above recommendations had been incorporated. Guidance for
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development of PARS based on operational assessment of plant
conditions was incorporated-in flow diagram, Attachment 3,
Core / Containment Conditions Flowchart, Attachment 1, PAR Flowchart
similar to that in IE Notice 83-28, has been incorporated into the
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procedure.
No reference to weather, special facilities, or
population distributions was referenced in Revision 10,
Provision
for discussion with the State is allowed, if time permits, prior to
notification to offsite-agencies for those situations when the
TSC/ EOF are activated.
PARS made from the control room are-
specifically exempted from any requirements for transmittal to the
State prior to their being. issued to the offsite agencies.
(Closed) Significant Appraisal Finding (445/8943-49; 446/8943-49):
Modify training materials to incorporate PARS based on core and
containment conditions and retrain'all personnel having
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responsibilities to formulate PARS. The inspector reviewed the
modified training material to ensure core / containment conditions were
incorporated as a basis for PARS.
The training materials were
adequate. A review of training records was conducted to determine
whether the required training had been conducted.
Selected personnel
trainirg records were compared to the required training matrix to
verify the required training. No discrepancies were noted.
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Improvement Items Closed
(Closed) Improvement Item (445/8943-08; 446/8943-08):
Position the
required, dedicated emergency equipment in the OSC or provide
assurance that all required equipment will be properly located in the
event of an emergency.
Activation and operation of the OSC, EPP-205, Revision 6, has been
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changed to include provisions _for obtaining and setting up the
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referenced emergency equipment (facsimile machine) during OSC
activation.
(Closed) Improvement Item (445/8943-12; 446/8943-12): Maintain
first-aid supplies in an orderly fashion. The inspector toured the
emergency first-aid supply locations and found them to be maintained
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in an orderly fashion.
(See also significant appraisal finding
closeout 445/8943-11;446/8943-11).
=(Closed) Improvement Item (445/8943-13; 446/8943-13):
Review and
revise Section 10.2 of the emergency plan to reflect the correct
location of the onsite first-aid supplies and that Hood General
Hospital Ambulance Service is the primary ambulance service, and
complete the turnover of the ambulance service from the contractor.
The inspector reviewed the Emergency Plan, Section 10.2, which lists
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a first-aid station on Elevation 810 of the turbine building.
First-aid treatment facilities and equipment are also maintained in
the NOSF. A procedure change to EPP-313, Revision 10, effective
January 19. 1990, clarified the locations of first-aid medical
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supplies as located at the first-aid and fire station and in the
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emergency medical locker opposite access control in the Elevation 810
RCA access' hallway. EPP-313, Attachment 1, page 2, " Documenting
Response to an Injured Person," lists the ambulance requested as
either Hood General Hospital, Somerville Volunteer Ambulance Service,
or others.-
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(Closed) Improvement Item (445/8943-15; 446/8943-15):
Review and
revise Section 6.9 of the EP to list the electrical and control
building as the location of tSe decontamination facility in the plant
rather:than the turbine building.
-The licensee stated in their response to-this item that Section 6.9
of the EP lists-the correct location for the decontamination
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facilities. The inspector toured the decontamination facilities in
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the turbine building and NOSF and found their location to be as
describad in the EP.
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(Closed) Improvement Item (445/8943-19; 446/8943-19):
Include the
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correct storage locations of emergency kits in procedures.
The
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inspector reviewed Revision 1 of EPP-901 effective December 15, 1989.
It was determined that the maintenance and inventory of emergency
equipment and supplies correctly reflects the location of the
emergency equipment storage lockers.
(Closed) Improvement Item (445/8943-20; 446/8943-20): Mark spare
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batteries with shelf life expiration dates to permit persons
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performing inventories to readily determine if supplies are adequate.
The' inspector reviewed a change to Procedure EPP-901, " Maintenance
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and Inventory of Emergency Equipment and Supplies," Revision 1, dated
December-15, 1989.
The procedure requires batteries to be verified
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within the shelf life of the battery as stated by the manufacturer or
a 1 year shelf life if a time has not been stated by the
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manufacturer.
(Closed) Improvement Item (445/8943-23; 446/8943-23): Assure that
proper physical units are available at local instrument channel racks
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for ARM and PRM readouts. The inspector verified that the l'icensee
has rev'ised the tags (label plates) to include the physical units on
~the control room ARM and PRM readouts.
(Closed) Improvement Item (445/8943-26; 446/8943-26):
Install
protective dust caps / thread protectors on spare SCBA bottles. The
inspector observed dust caps / thread protectors installed on spare SCBA
bottles in the emergency facilities and in the plant.
(Closed)' Improvement-Item (445/8942-27;446/8943-27):
Initiate.
periodic testing as appropriate for all emergency communication-
- systems, review and revise procedures to require periodic testing of
all emergency communication systems, and increase the FM radio
capability at the TSC to permit monitoring of emergency channels.
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The inspectors reviewed Procedure EPP-901, " Maintenance and Inventory-
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of Emergency Equipment and Supplies," Revision 1, to ensure the
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communications systems are scheduled for routine testing and
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verification. Section 4.3.5 requires monthly testing of all special
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telecommunications systems assigned to the emergency organization.
Procedure EPP-908, Revision 0, " Sound Powered Phones and Evacuation
Alarm System Periodic Testing," dated October 4,1989, requires
quarterly. testing (site evacuation alarm).
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The utility does not have the capability to communicate via radio to
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-the offsite monitor teams from the TSC.
However, radio
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. communications are provided to offsite teams from the OSC. The
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utility does'not plan to add an offsite monitoring team channel to.
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the TSC' radio. The NRC will review the effectiveness of this
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arrangement during the next exercise,
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(Closed)' Improvement Item (445/8943-35; 446/8943-35): Complete the-
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documentation ~of the dispersion factor (Xp/Q values)-using the dose
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assessment model and document these values into procedures.
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inspector reviewed. documentation of the emergency dose assessment
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model (EDAM), Revision 2, and found that the Xp/Q values had been
tabulated in Appendix I.
The factors had been calculated for.16
wind directions at the exclusion area boundary for each of seven
atmospheric stability classes.
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(Closed) Improvement Item (445/8943-37; 446/8943-37):
Ensure that
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units on the DRMS monitors used for dose assessment calculations are
consistent with those in the RM-11 system and the dose assessment-
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model.
The inspector operated the dose assessment program EDAM
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through several iterations under different assumptions to determine
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the' spectrum of values and units required as input. Model inputs
which can be obtained from the RM-11 system or DRMS monitors include
release rate (C1/s) 'and postaccident containment radiation monitors
(R/h).
These systems were confirmed in the control room to readout
in the units used by EDAM.
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(Closed)ImprovementItem(445/8943-39;446/8943-39):- Develop a-
procedure for the routine maintenance and operability check on the
NaI detector ' system, and describe counting-procedures for
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environmental samples and the activation of the counting laboratory.
The inspectors reviewed Procedure CLI-780, Revision 0, " Calibration
of the Spectrum 88 MCA," and CLF-781, Revision 0, " Operation of the
Spectrum 88 MCA," both effective July 24, 1989, and found them to be-
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satisfactory. Also reviewed was procedure change to EPP-206,'
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Revision 7, effective January 19,.1990, which, specifies the manning
of the NOSF counting laboratory under Section 4.3.3.
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(Closed) Improvement Item (445/8943-41; 446/8943-41):
Consider
issuing dosimetry to personnel as they enter the EOF. The inspector
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reviewed the. licensee's response to this item and determined that it
was reasonable.
The licensee stated in their response that they had
abandoned the. earlier procedure calling for issuance of dosimetry to
all personnel at the time of EOF manning in' favor of using radiation
protection coordinator's decision to issue dosimetry based on plant
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conditions and habitability status of the EOF. This course of action
is heneficial'in that it may prevent the actual issuance of dosimetry
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from. hindering the activation of the EOF. As an added precaution,
Procedure EPP-305, Revision 7, specifies that TLDs are
representatively placed in emergency response facilities to passively
monitor general area exposure conditions.
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(Closed)' Improvement Item (445/8943-44; 446/8943-44):
Review and
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revise Procedure EPP-313 to specify the use of emergency medical
. technicians (EMTs) as first-aid team members. The inspector reviewed-
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the licensee's response to this item and determined that it was
reasonable. The licensee's position is that EMTs have been-assigned
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as first-aid team members in EPP-203, " Emergency Communications," and
have been trained to respond as such. Therefore,.EPP-313 is correct
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in specifying.the EMT by their emergency organization position title.
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(Closed) Improvement' Item (445/8943-45; 446/8943-45):
Update the
Letters of Agreement with the off-site support agencies. . Letters of
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Agreement were reviewed by the utility and are in agreement with
Revision 11 of the Emergency Plan dated August 31, 1989. The
inspector reviewed Section 11 of the Emergency Plan, Letters of
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Agreement. No discrepancies were noted.
3.
Exit Interview
The inspectors met with the resident project inspector and licensee
representatives indicated in paragraph 1 on January 18, 1990, and
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summarized the scope and findings of the inspection as presented in this
report.
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