ML20042F957

Responds to NRC Re Violations Noted in Insp Repts 50-498/90-05 & 50-499/90-05.Corrective Actions:Surveillances of Emergency Response Equipment in Technical Support Ctrs Performed to Ensure That Emergency Requirements Satisfied

ML20042F957
Person / Time
Site:	South Texas
Issue date:	05/07/1990
From:	Vaughn G HOUSTON LIGHTING & POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9005100222
Download: ML20042F957 (6)

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.The Light

compting & Powerany South Temu Project Electric Generating St P. O. Bos 289 Wadsworth, Tenu 77483

.' Houston Lig May 7, 1990 i

ST-HL-AE 3437 File No.: G02.04 10CFR2.201 x

U. S._ Nuclear Regulatory Commisston

~f Attention: Document Control Desk Washington, DC 20555 1

South Texas Project Electric Generating ' Station Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 4

Response to Notice of Violation (498/9005 01. 02: 499/9005-01. 02)

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Houston Lighting'& Power Company (HIAP) has reviewed Notices of Violation =_(498/9005-01, 02; 499/9005 01,.02.). dated-April 5, 1990, and submits the attached response pursuant to 10CFR2.201.

If you~'should have any questions on this matter,_please contact

-Mr; P /L. Walker at (512) 972-8392 or myself at (512) 972-7921.

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Vice President Nuclear Generation.

PIP /n1' Attachments:

1)~ Response to Notice of Vicistion (498/9005-01; 499/9005 01)

2) Response to Notice of Violation (498/9005-02; 499/9005-02)

.9003100222 900507 PDR ADOCK 05000498 Q

PDC A1/028'.d3 A Subsidiary of Houston Industries incorporated g

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1 ST-HL AE-3437

Hondon Lighting & Power Company File No.: CO2.04 South Texas Project Electric Generating Station Page 2 cc:

Regional Administrator, Region IV Rufus S. Scott Nuclear Regulatory Commission Associate General Counsel.

611 Ryan Plaza Drive,1 Suite 1000 Houston Lighting & Power Company

/,rlington, TX 76011 P. O. Box 61867 Houston, TX 77208 Ceorge Dick.. Project Manager U.S. Nuclear Regulatory Commission INPO

-Washington, DC 20555 Records Center 1100 Circle-75 Parkway J....Tapia Atlanta, GA-'30339-3064.

. Set.ior Resident Inspector c/c U. S. l'ucicar Regulatory Dr. Joseph M. Hendrie C(mmissic, 50 Be11 port Lane P. O. Box-910 Be11 port, NY 11713 8ay City,1DC 77414 D. K. Lacker J. R. Newman,. Esquire Bureau of Radiation Control Newman & Holtzinger, P.C.

Texas Department of Health 1615 L Street, N.W.

1100 West 49th Street Washington, DC 20036 Austin, TX 78704 i

D..E. Ward /R P. Verret

' Central Power & Light Company P. O. Box 2121

' Corpus Christi, TX. 78403 J. C..Lanier Director of Generation L

City of Austin Electric Utility 721-Barton Springs Road Austin, TX 78704 R.'J. Costello/M. T. Hardt City Public Service Board P. 0 ' Box 1771 San Antonio,' TX 78296 i

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South Texas Project Electric Cenerating Station B;

Uriits 1 and 2

-Docket Nos. STN_50-498, STN 50-499 F^>

pesponse to Notice of Violation L

'(498/9005-01: 499/9005-01) ri t

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I. - Statement of Violation M

10 (M1150.47(b)(8)istates that adequers. emergency facilities and 3

'equipmentxto-support:the emergency respanse are provided and. maintained.-

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g' Contrary _to the:above, at'the time of the inspection, the inspectors

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determined that emergency enuipment in the' Technical Support Centers ti q;

c(TSCs) to(support an emergency response _was.not,maintainedi e assure t

iT that needed-equipment would be available during av emergency.

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ll. _ Houstpp Lithtinc & Power Position E_

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1HL&P concurs lthat:the cited violation occurred.

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III.. Reason for Violation' E

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The root cause of-failure to maintain emergency: equipment!to support;an:

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emergencyfresponse=was failure to secureLthe' Technical. Support Centers,

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LaBainst _ unauthorized entry.. Open access to the ~ Technical 1 Support;

'd Centers resulted_~in vulnerability to unauthorized' movement and use'of'

^ equipment

,A Plant Bulletin-had previously beers issued warning;against tunauthorized'use:of emergency' response facilities,1anduthe-entries:had

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been posted-indicating'" Authorized Personnel _Only."'

Additionaij surveillances were also being performed. However,'a physical' barrier.

d against such entr'y had not been'provided. This need to install doors' 1>

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^ had.previously. been' identified by HL&P, but inste11ation_ had 'not yet;

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been completed.

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1V' Gorrective' Actions Taken and Results Achieved 3

i Surve111ances.of-emergency response equipment in the Technical Support'

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' Centers have-been performed.to: ensure that emergency preparedness

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Corrective' Action Taken to Prevent Recurrence Each Technical Support Center has had a door installed to prevent unauthorized entry. Access through the door requires a key.

In the event of an emergency event requiring activation of a Technical Support Center, entry can be made using a key issued from the Control Room or Plant Security.

VI.

Date of Full Como11ance The South Texas Project Electric Generating Station is in full compliance at this time.

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~l Page 1 of 2 South Texas Project Electric Generating Station Units 1 and 2 j

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. Docket Nos. STN 50-496, STN 50 499 Response to Notice of V'-?stion (498/9005-02: 499/9tff,221 q

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Statement of Violation 10 CFR50.47(b)(15) states that radiological emergency response training l

shall be provided for those who may be callc4 to assist in an. emergency.

Section M of the licensee's emergency plan reqeires specialized training

'for. station emergency response personnel, and Interdepartmental Procedure 8.21Q, " Emergency Preparedness Training Program," implements specialized. training to keep personnel informed on any changes to procedures and to maintain emergency personnel proficiency at all levels.

Contrary to the above, at the time of the inspection,'the inspectors determined from interviews of key responders who might be called upon to assist in an emergency that their radiological emergency response training was ne.t always implemented to keep them informed on changes to 4

procedures and to maintain emetgency personnel proficiency.at all levels.

Some key responders did not understand basic concepts needed to compute radioactive releases and be proficient in performing basic tasks that would be raquired during an emergency. Other key responders also had not always received adequate emergency. response training on updated procedures and were not always familiar with equipment.

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Houston Lighting &_ Power Position HL&P concurs that the cited violation occurred.

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'III.

Reason for Violation The root causes of this violation are as follows:

1) Personnel were assigned to fill the role of key responders without the prerequisite training having been verified.

2)- Training in the use of STAMPEDE dose projection code did not include

'}t the different types of equipment on which the code may be expected-to be run.

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bi ST-HL-AE-3437 Page 2 of 2 IV.

Corrective Actions Tcken and Results Achieved Shift Radiation Protection Supervisors have received training in Offsite Dose Projections.

This includes training in use of STAMPEDE.. Practical exercises in use of the dose projection nomograph, the offsite dose-

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calculation program, and use of Emergency Actinn Levels has been completed.

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Corrective Action Taken to Prevent Recurrence 1

The qualifications of personnel assigned by name to emergency response duties are verified by Emergency Preparedness as part of the quarterly review of the Emergency Response Organization roster. A revision to the ERO roster procedure will be made to require that training for ERO positions filled by "onshift" or "onduty" personnel, including Health

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Physics,.is verified by the responsible manager.

The training requirements for onshift key responders will be evaluated and revised as necessary to emphasize emergency classification, protective action recommendation and dose calculation requirements.

In addition, practice' problems will lxi issued for onshift personnel.to provide them eith practice in performing offsite dose projections.

These. additional enhancements will be in place no later than September 30, 1990.

VI.

Date of Full Como11ance The South Texas Project Electric Generating Station is in full-compliance at this-time, c

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