ML20056E711

Insp Repts 50-445/93-25 & 50-446/93-25 on 930726-30.No Violations Noted.Major Areas Inspected:Licensee Performance & Capabilities During Annual Exercise of Emergency Plan & Implementing Procedures

ML20056E711
Person / Time
Site:	Comanche Peak
Issue date:	08/13/1993
From:	Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20056E708	List: ML20056E707 ML20056E711
References
50-445-93-25, 50-446-93-25, NUDOCS 9308250095
Download: ML20056E711 (11)

See also: IR 05000445/1993025

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APPENDIX

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Inspection Report:

50-445/93-25

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50-446/93-25

Operating License: NPF-87

NPF-89

Licensee:

TV Electric

Skyway Tower

400 North Olive Street, L.B. 81

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Dallas, Texas 75201

Facility Name: Comanche Peak Steam Electric Station

Inspection At: Glen Rose, Texas

Inspection Conducted: July 26-30, 1993

Inspectors:

D. Blair Spitzberg, Ph.D., Emergency Preparedness Analyst

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(Team Leader)

K. M. Kennedy, Resident Inspector, Comanche Peak

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W. Holley, C.H.P., Senior Radiation Specialist

Scott Boynton, Emergency Preparedness Analyst, Office of Ncclear

Reactor Regulation (NRR)

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Accompanying

Personnel:

E. Butcher, Deputy Director, Division of Radiation Safety and

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Safeguards, NRR

H. Astwood, Intern, Office of Nuclear Materials Safety and

Safeguards

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M. Good, Comex Corporation

Approved:

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Blaine Murray, Chief, F cilities

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Inspection Programs

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Inspection Summary

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Areas Inspected (Units 1 and 2): Routine, announced inspection of the

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licensee's performance and capabilities during an annual exercise of the

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emergency plan and implementing procedures. The team observed activities in

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the control room, Technical Support Center, Operational Support Center, and

the Emergency Operations Facility.

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Results:

The control room crew successfully detected abnormal events, analyzed

plant conditions, and aggressively pursued corrective actions and

alternate success paths (Section 2.1).

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An exercise weakness was identified for the incorrect classification of

conditions corresponding to an Alert (Section 2.1).

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The Technical Support Center was staffed and activated promptly and

response staff appeared to understand their duties and responsibilities.

Command and control were improved from the previous exercise

(Section 3.1).

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The Operational Support Center was staffed and activated promptly.

Emergency Response and Damage Control teams were well briefed and

responded promptly and properly to assigned tasks (Section 4.1).

Command and control was strong in the Emergency Operations Facility and

response personnel performed their duties well (Section 5.1).

The scenario and exercise preparation was sufficient to demonstrate the

exercise objectives (Section 6.1).

The licensee's critique process was excellent in identifying areas iii

need of corrective action (Section 7.1).

Summary of Inspection Findings:

Exercise Weakness 445/9325-01; 446/9325-01 was opened (Section 2.1).

Exercise Weakness 445/9246-01; 446/9246-01 was closed (Section 8.1).

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Exercise Weakness 445/9246-02; 446/9246-02 was closed (Section 8.2).

Exercise Weakness 445/9246-03; 446/9246-03 was closed (Section 8.3).

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DETAILS

1 PROGRAM AREAS INSPECTED (82301)

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The licensee's annual emergency preparedness exercise began at 7 a.m. on

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July 28, 1993.

The exercise was a full participation exercise and was

evaluated by the Federal Emergency Management Agency.

Initial conditions for

the exercise included Unit 1 in the process of startup at 23 percent power and

Unit 2 operating at full power.

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Major events in the scenario included a fire in a Unit 2 centrifugal charging

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pump room, followed by indications of loose parts in the Unit I reactor

coolant system.

Subsequently, a Unit I reactor coolant pump faulted and

indications came in of a reactor coolant system leak and failed fuel.

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major event was an earthquake exceeding safe shutdown limits that created a

breach in the Unit I containment structure.

This resulted in an unmonitored

radiological release. A contaminated, injured response team member was staged

to evaluate the licensee's medical emergency capabilities.

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The inspection team identified various concerns during the course of the

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exercise; however, none were of the significance of a deficiency as defined in

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10 CFR 50.54(s)(2)(ii).

Each observed concern can be characterized as an

exercise weakness or as an area recommended for improvement.

An exercise

weakness is a finding that a licensee's demonstrated level of preparedness

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could have precluded effective implementation of the emergency plan in the

event of an actual emergency.

It is a finding that needs licensee corrective

action. Other observations are documented which did not have a significant

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negative impact on overall performance during the exercise but still should be

evaluated and corrected as appropriate by the licensee.

2 CONTROL ROOM (82301-03.02.b.1)

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The inspectiori team observed and evaluated the control room staff as they

performed tasks in response to the exercise.

These tasks included detection

and classification of events, analysis of plant conditions, implementation of

corrective measures, notifications of offsite authorities, and adherence to

the emergency plan and implementing procedures.

2.1 Discussion

The control room simulator was used to initiate the exercise.

Dynamic

simulation of the exercise was accomplished throughout the exercise.

Overall, the control room staff performed well during the exercise. The crew

successfully detected abnormal events, analyzed plant conditions, and

aggressively pursued corrective actions and alternate success paths.

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The emergency action level for a fire in the Unit 2 Centrifugal Charging Pump

Room was classified by the shift supervisor in the simulator control room. At

7:30 a.m.,

the shift supervisor declared a Notification of Unusual Event after

determining that a fire existed in the Unit 2 Centrifugal Charging Pump Room

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which threatened safety equipment for a period greater than 10 minutes.

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Procedure EPP-201, " Assessment of Emergency Action Levels, Emergency

Classification and Plan Activation," Chart II, " Fire," indicated that a fire

inside the protected area lasting greater than 10 minutes for which safety

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systems were potentially affected by the fire would result in an Alert

classification.

The incorrect classification of this event was identified as

an exercise weakness (445/9325-01; 446/9325-01).

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The inspection team discussed with licensee representatives a procedural

condition which could delay prompt classification of seismic events.

Emergency Action Level Initiating Condition 12.C in the Classification

Procedure EPP-201, Chart 12, " Natural Phenomena," distinguishes the severity

of seismic events between those corresponding to an Alert from those

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corresponding to a Site Area Emergency. A decision point in the procedure

requires an analysis of the seismic data relative to a Safe Shutdown

Earthquake.

Information provided to the inspection team indicated that such

an analysis would require 2-3 hours post event as was demonstrated during this

exercise. The purpose of initiating conditions such as this is to rapidly

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enter the appropriate classification level and, hence, the required emergency

response posture before detailed or lengthy analyses can be performed. The

inspection team discussed as an improvement item the evaluation of this

classification criteria to determine whether a more prompt assessment of

post-earthquake conditions could be achieved.

2.2 Conclusion

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The control room crew successfully detected abnormal events, analyzed plant

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conditions, and aggressively pursued corrective actions and alternate success

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paths. An exercise weakness was identified for the incorrect classification

of conditions corresponding to an Alert.

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3 TECHNICAL SUPPORT CENTER (82301-03.02.b.2)

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The inspectors observed the operation of the Technical Support Center from

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activation through termination of the exercise.

The inspectors evaluated

staffing, command and control, technical assessment and support of operations,

classifications and notifications, dose assessment, formulation of protective

action recommendations, and adherence to the emergency plan and implementing

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procedures.

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3.1 Discussion

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The Technical Support Center was staffed and activated promptly, and response

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staff appeared to understand their duties and responsibilities. Command and

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control were improved from the previous exercise which had identified this

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area as an exercise weakness.

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The Site Area Emergency was properly detected and classified from the

Technical Support Center.

Notifications were prompt and accurate; however,

the inspection team noted that notification of the NRC was made by the TSC ENS

communicator without use of NRC Form 361, " Event Notification Worksheet," as

specified by Procedure EPP-203, " Notifications."

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Inspection team members approaching the primary access point noted that the

site evacuation alarm that was sounded about 9:12 a.m. was not clearly audible

or distinguishable from other station alarms from the parking area immediately

outside the primary access point.

In addition, the inspectors noted that

plant and facility announcements did not convey certain information that could

improve personnel awareness of plant and facility status.

For example, no

announcement was made in the Technical Support Center when the Operational

Support Center or the Emergency Operations Facility were activated. No plant

wide announcement was made following the earthquake for all personnel to be

alert for signs of damage and abnormalities.

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The need for protective actions recommendations was assessed properly from the

Technical Support Center; however, the inspection team noted that the

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protective action recommendation procedure is written such that unnecessary

delays could occur in issuing protective action recommendations.

Procedure EPP-304, " Protective Action Recommendations," states that if time

permits, The Texas Department of Health, Bureau of Radiation Control should be

offered the opportunity to review protective action recommendations prior to

their transmittal to offsite agencies.

It also states that for the Emergency

Operations Facility, once protective action recommendations are written on the

notification message form, a final review is offered by the Emergency

Operations Facility Communications Coordinator under the direction of the

Emergency Operations Facility Radiation Protection Coordinator to the Bureau

of Radiation Control's Chief of Field Operations.

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The inspection team discussed with the licensee the wording of this procedure,

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because obtaining Bureau of Radiation Control review of protective action

recommendations could delay the process of issuance.

Any delay in the

issuance of protective action recommendations to protect the health and safety

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of the public would be unacceptable if it occurred as a result of offering the

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review. Only if the review could be conducted with no delay in transmitting

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the protective action recommendations would it be acceptable.

The inspection team also discussed with licensee representatives potential

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improvement related to the extensive pen and ink changes noted in

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Procedure EPP-203, " Notifications," Revision 10. About 50 percent of the

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43 pages in this procedure contained pen and ink changes making it more

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difficult to read and follow.

Some of the changes were entered vertically,

which would require the procedure to be turned sideways to be read.

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3.2 Conclusion

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The Technical Support Center was staffed and activated promptly, and response

staff appeared to understand their duties and responsibilities.

Command and

control were improved from the previous exercise.

4 OPERATIONAL SUPPORT CENTER (82301-03.02.b.4)

The inspectors evaluated the performance of the Operational Support Center

staff as they performed tasks in response to the exercise to determine whether

the Operational Support Center would be effective in providing emergency

support to operations.

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4.1

Discussion

The inspectors observed the activation and operation of the Operational

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Support Center and repair teams dispatched to plant onsite locations. The

Operational Support Center was initially staffed and activated 27 minutes

after the declaration of the Alert.

Emergency Response Damage Control teams

were generally well briefed and dispatched in a timely manner. A total of

19 repair / survey teams were dispatched during the exercise.

Habitability of

the Operational Support Center was verified through periodic surveys and use

of a continuous radiation monitor located in the turbine building hallway.

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Licensee responses to a fire mini-scenario and to a contaminated, injured

person were timely and effective. The fire brigade was mobilized 8 minutes

after the alarm was received in the control room and was on the scene

19 minutes after the alarm. The fire was extinguished twenty-two minutes

after the initial alarm was received. The contaminated, injured person was

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turned over to the Hood General Hospital Emergency Medical Technicians

30 minutes after the Operational Support Center was informed of his injury.

Proper controls were taken to minimize contamination spread, and appropriate

precautions were demonstrated to the radiological aspects of the injury.

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Operational Support Center personnel were knowledgeable of their duties and

responsibilities.

Proper plant procedures were utilized by the response

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personnel.

Radios, telephones, and plant page systems were effectively used

to maintain communications with in-plant Emergency Response and Damage Control

teams. Repair team priorities were frequently requested from, and discussed

with the Technical Support Center. Support priorities were appropriately

addressed by the Operations Support Center through the timely dispatch of

Emergency Response and Damage Control teams.

Radiological control practices

were successfully demonstrated by the Emergency Response and Damage Control

teams throughout the exercise.

Logs and status boards were utilized to document activities in the Operational

Support Center; however, there were several examples noted where personnel did

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not document complete information or post information as required by the plant

emergency plan procedures. The Radiological Status Board Map was not utilized

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to post in-plant survey data or area radiation monitor data as specified in

Procedure EPP-205, Section 4.3.2.9.

The Operational Support Center Team

Assignment Board did not always provide specific status of individual

Emergency Response and Damage Control teams and their findings.

Facility logs

were generally brief and did not always provide sufficient information to

adequately reconstruct events and activities.

Several Emergency Work Permits

were not completed or logged as specified in Procedure EPP-ll6.

For example,

two separate Emergency Work Permits were labeled as EW-M3 with only one

being logged into the Emergency Work Permit Issue Log.

In addition, auxiliary

operator tracking was not logged by the Team Assignment Board Recorder in

accordance with Procedure EPP-205, section 4.3.2.11.

The Operational Support

Center Manager did not log authorization of Emergency Response and Damage

Ccntrol teams immediate entries in accordance with Section 4.2.2.1 of EPP-ll6

and the Operational Support Center Field Team Communicator did not log survey

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results in his activity log in accordance with Procedure EPP-205,

Section 4.3.2.5.

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Briefings of the Operational Support Center staff were infrequent and

generally did not provide sufficient information on the plant status or

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facility activities.

The above examples of poor briefings and recording activities in the

Operational Support Center did not significantly impact the facility's ability

to perform its intended function.

These observations were discussed with

licensee representatives as potential areas for improvement.

4.2 Conclusion

The Operational Support Center was staffed and activated promptly.

Emergency

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Response and Damage Control teams were well briefed and responded promptly and

properly to assigned tasks.

Potential improvements were discussed with the

licensee in the areas of recording activities and facility briefings.

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5 EMERGENCY OPERATIONS FACILITY (82301-03.02.b.3)

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The inspectors observed and evaluated the Emergency Operations Facility staff

as they performed tasks in response to the exercise.

These tasks included

activation of the Emergency Operations Facility, accident assessment and

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classification, offsite dose assessment, notifications, protective action

decisiontaking, preparations for entering the recovery phase, and interaction

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with State, local officials, and offsite field monitoring teams.

5.1 Discussion

The Emergency Operations Facility was staffed promptly and declared activated

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79 minutes after the Alert declaration. The activation of the Emergency

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Operations Facility was delayed for exercise purposes in order to allow each

command facility to demonstrate the detection and classification objectives.

The inspection team noted that the Emergency Operations Facility staff

appeared to be trained and proficient in carrying out their response duties

and performed well during the exercise. Noise levels were controlled

effectively, and the facility was orderly throughout the exercise.

Command and control was effective from the Emergency Operations Facility.

Direction to staff was clear, and facility briefings were frequent and

concise. The briefing of the arriving NRC site team was thorough. The control

of the offsite monitoring teams and dissemination of the measurement results

were effective.

The locations and results from offsite monitoring teams were

accurately tracked and displayed on status boards.

The status boards in the Emergency Operations Facility were updated regularly.

The updating of these boards and periodic briefings by the Emergency

Coordinator and his staff enhanced the information flow in the Emergency

Operations Facility.

Some of the information written on the radiological

status board, however, was small and difficult to read.

Further, the

radiological status board did not show the times of initiation and completion

of protective action decisions.

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The General Emergency was properly classified from the Emergency Operations

Facility.

Notification messages were timely and accurate with one noteworthy

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exception. At 8:30 a.m. following a loose parts alarm and the faulting of a

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reactor coolant pump, failed fuel monitors in Unit I alarmed. The response

staff assessed the presence of a loss of the fuel cladding fission product

barrier. This was alluded to indirectly on the initial notification of the

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Site Area Emergency (Message 3) by the statement that only a single fission

product barrier (containment) was preventing a radiological release. Despite

clear indications of loss of the fuel cladding fission product barrier, the

event box " Fuel element breach" of Section 7 of the notification message form

was never checked on any of the messages transmitted. Consequently, no clear

indication of this condition was communicated to offsite authorities. The

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inspection team discussed this observation with licensee representatives as a

potential area for improvement.

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The licensee identified an exercise weakness in the Emergency Operations

facility that was not observed fully by the NRC inspection team. This

weakness occurred as a result of the misinterpretation of initial field team

survey results. The results were not well understood because of what was

deemed to be an inconsistency between open and closed window survey readings.

The reported open window readings yielded dose projections for child thyroid

that should have caused the licensee to escalate the protective action

recommendations that had been issued.

The reported closed window readings

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yielded small dose projections that would not have caused a recommendation of

additional protective actions. The licensee's failure to understand the field

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team measuremerts and to act promptly on them in issuing appropriate

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protective action recommendations was a licensee identified weakness.

5.2 Conclusion

Command and control was strong in the Emergency Operations Facility, and

response personnel performed their duties well.

The licensee identified an

exercise weakness for failure to understand and act appropriately to initial

field team survey results following the radiological release.

6 SCENARIO AND EXERCISE CONDUCT (82301)

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The inspection team made observations during the exercise to assess the

challenge and realism of the scenario and to evaluate the conduct of the

exercise.

6.1 Discussion

The inspection team determined that the scenario provided sufficient challenge

to exercise response activities in each of the exercise objectives. Realism

vas enhanced by utilizing the control room simulator in the dynamic mode to

uodel the accident sequence. The following observations related to the

scenario and to the conduct of the exercise did not significantly detract from

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the exercisa and were noted to the licensee as potential areas for

improvement:

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Plant announcements originating from the simulator could not be heard in

the plant.

In order to compensate for this, the simulator crew

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requested the actual control room crew to make plant announcements

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related to the exercise drill.

Coordination of plant announcements

between the simulator and the control room caused confusion and

frustration among the simulator crew and lessened the realism of the

scenario.

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Inadequate simulation of the Unit 2 control room crew resulted in poor

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simulation of the fire in the Unit 2 Train A centrifugal charging pump.

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An example of controller prompting was observed in the control room

simulator.

While control room operators were reviewing plant drawings

for alternative methods of supplying cooling water to a containment

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spray pump, prompting by a controller led operators to a procedure to

accomplish this task.

The Emergency Coordinator position in the Technical Support Center was

double staffed throughout the exercise. This staffing condition could

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be the licensee's preferred staffing during an actual emergency;

however, for the exercise it made it difficult to evaluate the

individual performance of the Emergency Coordinator in a decisionmaking

role.

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6.2 Conclusion

The scenario and exercise preparation was sufficient to demonstrate the

exercise objectives.

7 LICENSEE SELF-CRITIQUE (82301-0302.b.12)

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The inspectors observed and evaluated the licensee's tormal self-critique on

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characterize weak or deficient areas in need of corrective action.

7.1

Discussion

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The licensee described its critique process as involving all players,

evaluators, and representatives of senior management.

Licensee findings were

characterized in terms similar to NRC findings. The licensee's critique

identified the following two exercise weaknesses:

Accident classification of the Alert conditions.

Protective action recommendations delayed as a result of failing

to understand initial field team survey results.

The inspection team determined that the licensee's critique process was

excellent and had properly identified and characterized weak areas. The

licensee's critique captured the classification weakness observed by the NRC

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In addition, the licensee identified an exercise weakness that was not

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identified independently by the NRC team.

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7.2 Conclusion

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The licensee's critique process was excellent in identifying areas in need of

corrective action.

8 FOLLOWUP (92701)

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8.1

(Closed) Exercise Weakness (445/9246-01: 446/9246-01): Delays in

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detecting and classifying emergency conditions.

During the 1993 exercise, the classification delays identified during the 1992

exercise were corrected. A new exercise weakness in the area of emergency

classification was openeo (Section 2.1:

8.2 (Closed) Exercise Weakness (445/9246-02: 446/9246-02):

Licensee failure

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to make prompt offsite notifications of Site Area Emergency.

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The inspectors observed that the notifications to offsite organizations were

made in a timely manner during the 1993 exercise.

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8.3

(Closed) Exercise Weakness (445/9246-03: 446/9246-03):

Poor command and

control activities observed in the Technical Support Center, Operational

Support Center, and Emergency Operations Facility.

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During the 1993 exercise, the inspection team observed good command and

control in all emergency facilities.

The transfer of the emergency command

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from the control room to the Technical Support Center, and finally to the

Emergency Operations facility, was accomplished in accordance with procedures.

Each emergency response facility demonstrated clear chains of command in place

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for effective emergency management.

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ATTACHMENT

1 PERSONS CONTACTED

1.1 Licensee Personnel

• R. Beleckis, Senior Emergency Planner

• G. Bell, Supervisor, Emergency Planning

• M. R. Blevins, Director, Nuclear Overview

• W.

J. Cahill, Jr., Group Vice President

• N. Harris, Licensing Engineer

• N. Hood, Manager, Emergency Preparedness

• T. A. Hope, Manager, Site Licensing

• S. Johnson, Emergency Planning Supervisor

• J. J. Kelley, Jr., Vice President, Nuclear Operations

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• B. T. Lancaster, Manager, Plant Support

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D. McAfee, Manager, Quality Assurance

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• B. Nix, Senior Emergency Planner

• A. Saunders, Assessment Manager

• E. A. Sirois, Senior Engineer

• L. Terry, Vice President, Nuclear Engineering and Support

1.2 NRC Personnel

• D. N. Graves, Senior Resident Inspector

• G. Werner, Resident Inspector

1.3 Other Personnel

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G. E. Jones, Chief, Hazards Preparedness Branch, FEMA Region VI

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• R. Utter, Washington Public Power Supply System

• A. F. Klauss, Washington Public Power Supply System

• S. May, Washington State Department of Health

• Denotes those present at the exit meeting

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2 EXIT MEETING

The inspection team met with the licensee representatives indicated in

Section 1 of this attachment on July 30, 1993, and summarized the scope and

findings of the inspection as presented in this report. The licensee did not

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identify as proprietary any of the materials provided to, or reviewed by, the

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inspectors during the inspection.

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