ML20056F408
| ML20056F408 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 08/23/1993 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20056F394 | List: |
| References | |
| 50-498-93-25, 50-499-93-25, NUDOCS 9308270148 | |
| Download: ML20056F408 (16) | |
See also: IR 05000498/1993025
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APPENDIX B
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U.S. NUCLEAR REGULATORY COMMISSION .
REGION IV i
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Inspection Report: 50-498/93-25
50-499/93-25
Operating Licenses: NPF-76 .
NPF-80 l
Licensee: Houston Lighting and Power Company f
P.O. Box 1770 ,
Houston, Texas 77251
facility Name: South Texas Project Electric Generating Station i
Inspection At: Bay City, Texas i
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Inspection Conducted: August 2-6, 1993
Inspectors: D. Blair Spitzberg, Ph.D., Lead Inspector i
J. Keeton, Resident Inspector ;
Approved: J <0 ,h6/ [d5 ' '
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B. Murray, Chief,' Facilities Inspection
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Date
Programs Section C ;
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Inspection Summary
Areas Inspected: Routine, announced inspection of the operational status of
the emergency preparedness program, including changes to the emergency plan .
and implementing procedures; emergency facilities, equipment, and supplies- t
organization and management control; training; and internal reviews and ;
audits.
Results:
. Changes to the licensee's Emergency Plan and implementing procedures had
been properly reviewed and approved (Section 2.1). >
e A noncited violation occurred as a result of the failure to submit !
certain Emergency Plan and implementing procedure changes to the NRC as ;
required (Section 2.1).
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- Nearsite emergency response facilities and emergency equipment had been ;
maintained in a state of operational readiness (Section 3.1).
- Emergency response duties and responsibilities were clearly defined, and
a good number of trained and qualified personnel stood ready to respond
to emergencies (Section 4.1). !
9308270148 930824 N
PDR ADOCK 05000498 q
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- The emergency planning staff was well qualified and experienced but had
recently lost its only staff member with significant operations
experience (Section 4.1).
- Initial emergency preparedness training had been conducted as required.
A violation was identified for failure to follow the requalification
training requirements identified in the Emergency Plan (Section 5.1.1).
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- Drills and exercises were conducted as required. The distribution of ,
drill training opportunities was not equitable, and followup on drill
findings was not well documented or tracked (Section 5.1.1).
- An Unresolved Item was identified pending a determination of whether the
licensee has corrected past weaknesses in day shift emergency
accountability (Section 5.1.1).
- Two weaknesses were identified during walkthroughs with operating crews,
one for failure to properly classify conditions corresponding to an :
Alert, and the second for failure of all crews evaluated to calculate
dose projections in an accurate and timely manner (Section 5.1.2).
- Quality assurance audits and surveillances of the emergency preparedness l
area met the requirements of 10 CFR 50.54(t) and had been conducted in i
an excellent manner (Section 6.1). ,
Summary of Inspection Findings: ,
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A noncited violation was identified (Section 2.1).
- Violation 50-498/9325-01; 50-499/9325-01 was opened (Section 5.1.1). ~!
- Unresolved Item 50-498/9325-02; 50-499/9325-02 was opened ,
(Section 5.1.1). l
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- Emergency Preparedness Weakness 50-498/9325-03; 50-499/9325-03 was ;
opened (Section 5.1.2f .
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- Emergency Preparedness Weakness 50-498/9325-04; 50-499/9325-04 was
opened (Section 5.1.2). ;
- Unresolved Item 498/9210-01; 499/9210-01 was closed (Section 7.1).
- Emergency Preparedness Weakness 498/9222-01; 499/9222-01 was closed
(Section 7.2).
Attachments:
Attachment 1 - Persons Contacted and Exit Meeting
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Attachment 2 - Operator Walkthrough Scenario Narrative Summary-
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DETAILS .
1 PLANT STATUS !
During this inspection, Unit I reached hot shutdown (Mode 4) for tests, and
Unit 2 was in cold shutdown (Mode 5). .
2 EMERGENCY PLAN AND IMPLEMENTING PROCEDURES (82701-02.01)
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The inspector reviewed changes in the licensee's emergency plan and
implementing procedures to verify that these changes had not decreased the -
effectiveness of emergency planning and that the changes had been reviewed '
properly and submitted to NRC.
2.1 Discussion
The inspector reviewed the licensee's program for performing annual reviews of
the Emergency Plan and the process for approving changes to the plan.
Procedure OERP02-ZV-AD06 was found to properly define the 10 CFR 50.54(q)
annual review requirements and the areas to be covered by the review. Review
and approval of changes were appropriate. Since the previous inspection, the
licensee had implemented one set of Emergency Plan changes contained in 7
Revision 15, effective September 1992. !
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The licensee had implemented about 50 emergency response procedure changes
since the previous inspection. The inspector reviewed a selected number of
these procedure changes and determined that they had been properly reviewed
and approved.
An internal audit of the emergency preparedness program had identified that i
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neither Revision 15 of the Emergency Plan nor several revisions to Emergency
Response Procedures had been submitted to document control desk of NRC within
30 days of implementation as required. This problem was identified in Station i
Problem Report 932224 and had been corrected as documented in the licensees
letter to NRC dated February 2, 1993. The NRC document control desk had been
removed from distribution for the period from September 1992 to January 1993.
This violation of 10 CFR 50.54(q) and Appendix E.V is not being cited, because
the criteria in paragraph VII.B.2 of Appendix C to 10 CFR Part 2 of the NRC's
" Rules of Practice," were satisfied.
The inspector reviewed Letters of Agreement with offsite emergency support
organizations and found that they had been updated in January 1993.
2.2 Conclusions
Changes to the licensee's Emergency Plan and implementing procedures had been
properly reviewed and approved. A noncited violation occurred as a result of
the f ailure to submit certain Emergency Plan and implementing procedure
changes to the NRC as required.
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3 EMERGENCY FACILITIES, EQUIPMENT, INSTRUMENTATION, AND SUPPLIES
(82701-02.02) ,
The inspectors toured onsite emergency facilities and reviewed the licensee's
emergency equipment inventories and maintenance to determine whether i
facilities and equipment had been maintained in a state of operational ;
readiness.
3.1 Discussion
Nearsite emergency response facilities were orderly and operationally ready.
No major changes had been made to the facilities since the previous
inspection. The inspector randomly verified the presence of designated
emergency equipment and supplies as 'dentified in inventory procedures.
Sampling and radiation monitoring equipment was verified to be in calibration.
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Documentation of quarterly inventory and equipment surveillance was reviewed.
These inventories had been performed in an excellent manner. Communications
equipment in the emergency response facilities had been tested in accordance
with Procedure OPGP05-ZV-0002-03, " Communications Tests."
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3.2 Conclusions
Nearsite emergency response facilities and emergency equipment had been !
maintained in a state of operational readiness. !
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4 ORGANIZATION AND MANAGEMENT CONTROL (82701-02.03)
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The inspectors reviewed the emergency response organization staffing levels to
determine whether sufficient personnel resources were available for emergency
response. The emergency planning organization was reviewed to ensure that an i
effective programmatic management system was in place. l
4.1 Discussion e
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The inspector reviewed emergency response organization position descriptions
and assigned responsibilities. Major response duties were clearly assigned. I
It was noted that some response positions had been deleted from the
organization since the previous inspection. The inspector reviewed these l
changes and determined that the duties and responsibilities of the deleted i
positions had been transferred to other positions with no loss r,f response i
capability.
Emergency response organization staffing and duty assignments had been
established in accordance with Procedure OPGP05-ZV-0003, " Emergency Response
Organization." A quarterly duty roster had been issued identifying an on-call
duty schedule for the three response teams. The inspector reviewed recently ,
issued rosters and determined that they had been properly approved and I
distributed. The process for tracking and verifying the current training and j
qualification status of response organization assignees appeared effective. :
Selected training records of response team members assigned duty the week of 1
the inspection were reviewed and found to be accurate. With at least three
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individuals qualified for each position, sufficient depth was available to !
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ensure a full response at any time. l
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Responsibility for emergency planning and preparedness was that of the
Emergency Response Program group. The inspector reviewed the function and l
responsibilities of this group as defined in Procedure OPGP05-ZV-0005, i
" Emergency Response Program." Staffing levels remained consistent with those l
from the previous inspection period except that one planning position had
recently become vacant. Among the responsibilities of the vacated position I
were drill and exercise scenario development. The individual who had filled ,
this position had been the only emergency planning staff member with .
significant nuclear onerations background.
The inspector discussed with licensee representatives the relationships that
had been maintained with offsite response organizations and the local :
communities and reviewed relevant documentation. Training for offsite
organization response personnel had been scheduled and conducted annually as i
required. Local offsite organizations had been invited to participate in
licensee integrated drills. Licensee representatives indicated that an
excellent working relationship existed between the utility and local offsite -
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response organizations. i
4.2 Conclusions
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Emergency response duties and responsibilities were clearly defined, and a ,
good number of trained and qualified personnel stood ready to respond to !
emergencies. The emergency planning staff was well qualified and experienced ,
but had recently lost its only staff member with significant operations ;
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experience.
5 TRAINING (82701-02.04)
The inspectors reviewed the emergency response training program and l
interviewed selected individuals to determine whether emergency response '
personnel were receiving the required training to be in compliance with the l
requirements of 10 CFR 50.47(b)(15), 10 CFR 50 Appendix E.IV.F, and the
5.1 Discussion !
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5.1.1 Training Program !
Emergency preparedness training program requirements had been specified in
Interdepartmental Procedure IP-8.21Q, Revision 6, " Emergency Preparedness <
Training Program." The inspector met with training instructors ad personnel . .,
responsible for tracking and scheduling emergency preparedness training and !
reviewed related documentation. Personnel with emergency response duties had '
received initial training as required. Initial training-classes had been ;
scheduled at least quarterly. Lesson plans and course content were reviewed, 4
and they contained specific terminal objectives and success criteria for I
completion. The inspectors noted that only about five position-specific ;
lessons had been developed in the emergency preparedness area. In addition, <
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initial training classes included little practical training of individual
response duties. ;
The inspectors reviewed licensee requalification training for emergency '
response organization personnel. The Emergency Plan, Section M.2.3, requires
that annually, station personnel shall requalify for their emergency response !"
positions. The requalification may be accomplished by either classroom
instruction or through successful accomplishment of position duties through
the drill and exercise program. The inspectors verified by selective review
of training records that requalification training had been received by !
response personnel approximately once per year as required. !
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Contrary to the above requirements in the Emergency Plan, however, since '
March 19, 1992, some requalification of emergency response personnel had been i
accomplished by other means not identified in the plan. Specifically, on that- !
date, the licensee's Technical Advisory Council which oversees emergency !
response training approved a modification to the requalification requirements.
This was done without pursuing a similar change in the Emergency Plan. Such a
change to the plan would likely have reduced the effectiveness of the
emergency preparedness program and would have required prior NRC approval. .
The modified program permitted requalification to be accomplished by a trainee ;
having acted as a controller or an evaluator in an integrated exercise, or by l
having successfully passed a comprehensive written examination covering
initial emergency preparedness training objectives. The inspectors confirmed [
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through discussions that acting as an exercise controller or evaluator did not i
require the trainee to successfully demonstrate their position duties. !
Further, the written examination option amounted to achieving a 70 percent ;
score on a 20 question multiple choice examination. l
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Through a review of the training records, the inspectors determined that since i
March 19, 1992, a large fraction of the requalification training had been l
accomplished according to the modified criteria. This modified criteria did !
not meet the requirements for requalification training that were specified in ;
the Emergency Plan. This was identified as a violation of 10 CFR 50.54(q) ;
which requires, in part, that licensees follow their emergency plans !
(50-498/9325-01; 50-499/9325-01). l
Through general discussions held with licensee representatives, the inspector !
noted another emergency response training concern. For individuals assigned !
to the emergency response organization, performance of these responsibilities
is not a written part of their individual job duties nor is it a job l
perfnrmance element. Most of the emergency response training, drill i
participation, and duty coverage must be accomplished in addition to an- !
individual's normal responsibilities, and in many cases, outside of normal l
working hours. Serving in the emergency response organization can, therefore,_ i
interfere with normal job duties, but- such service may not be viewed by the i
individual as critical to successful . job performance. Because of this, l
assignment to the emergency response organization has been an unwanted burden !
to many. This has resulted in frequent requests from individual: for relief }
from their emergency response duties. In response to many of these requests, r
the licensee has often granted relief to an individual if they have served in i
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the emergency response organization for 3 years, and, only then, after they !
have played in the most recent exercise. *
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The practices described above neither encourage the pursuit of excellence in ;
emergency response training and readiness nor do they promote retention of the l
most experienced responders. l
The inspector reviewed documentation of licensee drills and exercises to
determine compliance with the requirements of the 10 CFR Part 50, j
Appendix E.IV.F, "The Emergency Plan," Section N, and !
Procedure OPGP05-ZV-0001, " Emergency Response Exercises and Drills". Licensee !
drills and exercises met the requirements for scope and frequency identified !
in the Emergency Plan, Table N-1. Drill scenarios appeared to be challenging -;
and critiques were effective in identifying areas in need of corrective j
action. The inspector noted, however, that little documentation was available i
to show the followup actions taken in response drill weaknesses. For past i
drill weaknesses, no assignment of responsibility for corrective action was !
identified, and there was no systematic tracking in effect. A similar finding !
was made in the licensee's 1993 Emergency Preparedness Audit. Licensee }
representatives stated that a tracking system was in development at the time l
of the inspection that would improve the followup documentation of drill and ;
exercise weaknesses.
The licensee's goal for drill and exercise participation is for each of three - l
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emergency response organization teams to drill at least once per year, j
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participated in, nor was scheduled for participation in a drill or exercise
from April 29, 1992 to October 7, 1993, a period of over 17 months. By !
contrast, the participation of the red team over the same period showed a :
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pattern as indicated in Table 5.1.1.
1ABLE 5.1.1 - DRILLS AND EXERCISES _ CONDUCTED FROM APRll 1992 TO AUGUST 1993 )
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Date Team Drill or Exercise
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April 29, 1992 White Graded Exercise
July 2, 1992 Red Integrated Drill ,
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Sept. 10, 1992 Blue Integrated Drill
March 24, 1993 Red Integrated Exercise
April 15, 1993 Red Integrated Exercise
May 12, 1993 Red Exercise Dress Rehearsal j
June 8, 1993 Red Annual Graded Exercise 'l
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The red team's participation in the three drills or exercises leading up to
the 1993 annual graded exercise had the appearance of preferential training in
preparation for the graded exercise. Since the remaining two teams carry 2/3
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of the emergency response duty coverage, such preferentiel training would j
provide a lesser overall level of preparedness than a mere rotational team i
training schedule. l
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In reviewing the results of drills and exercises, the inspectors note
recurring weaknesses in the licensee's capabilities to perform assembly and j
accountability during day shift drills. The guidance for accountability is l
provided in NUREG 0654, Planning Standard J.5, and the licensee's Emergency l
Plan, Section F.2. This criteria specifies that the licensee provide for a ;
capability to account for all individuals onsite at the time of an emergency
and ascertain the names of missing individuals within 30 minutes of the star +
of an emergency. The drill documentation showed accountability successes f
during off-hour drills, but during the day shift drills with a much larger i
onsite population, the recent results were unsuccessful. The last three l
accountability drills conducted during the day shift going back to July 1992 +
identified weaknesses in the accountability capability. The September 1992
drill showed over 50 onsite individuals unaccounted for after 30 minutes. The
most recent drill conducted in April 1993 found about 200 onsite individuals ;
unaccounted for after 30 minutes.
In response to the recurring weaknesses in accountability during day shift }
hours, the licensee had provided a special training lesson for the '
accountability process. 10 CFR Part 50, Appendix E.IV.F.5, requires that weak
or deficient areas identified in training shall be corrected. Following this
inspection, the NRC determined that it will evaluate the licensee's next day
shift accountability drill. This issue is considered to be an Unresolved Item :
pending a determination of whether the weaknesses identified with the {
licensees emergency accountability capability have been corrected :
(50-498/9325-02; 50-499/9325-02).
5.1.2 Walkthroughs with Operating Crews
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The inspectors conducted a series of emergency response walkthroughs with !
operating crews to evaluate the adequacy and retention of skills obtained from j
the emergency response training program. A single walkthrough scenario was j
developed by the inspectors and administered to the crews to determine whether ;
control room personnel were proficient in their duties and responsibilities !
during a simulated accident scenario. Attachment 2 to this inspection report I
contains a narrative summary of the walkthrough scenario. j
The inspectors observed three crews during the walkthroughs-using the control !
room simulator in the dynamic mode. The scenario consisted of a sequence of !
events requiring an escalation of emergency classifications, culminating in a
general emergency. Each walkthrough lasted approximately 90 minutes. During )
the walkthroughs, the inspectors were able to observe the interaction of the ;
response crews to verify that duties and responsibilities were clearly defined :
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and understood. The walkthroughs also allowed the evaluation of the crews'
abilities to assess and classify accident conditions, perform dose ;
assessments, develop protective action recommendations, and make timely and ;
complete notifications to offsite authorities. l
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l During the walkthroughs, the inspectors observed a clear understanding among
crew members of their emergency duties and responsibilities. The crews
demonstrated good teamwork and communications during event mitigation. The
inspectors noted some open-ended communications, however, between the shift
supervisor / emergency director and the crew which impacted the ability to be
fully aware of all plant conditions that affected event classification and
notifications.
The inspectors observed and evaluated the ability of each crew to detect,
assess, and classify abnormal and accident conditions. Although the crews
made timely emergency classifications, one crew underclassified plant
conditions corresponding to an Alert classification. Specifically, 2 minutes
after receiving chemistry data for primary coolant indicating a dose
equivalent iodine activity level of 450 uCi/g, the shift supervisor declared
an Unusual Event based upon a potential loss of fuel clad and an attempted
unauthorized entry into the protected area. According to the Emergency Plan,
section D, Table D-1, under the classification category of loss of fission
product barrier, an Alert Emergency Action Level for any loss of fuel clad is
given as reactor coolant activity greater than or equal to 300 uCi/g dose
equivalent iodine. Failure to properly classify conditions corresponding to
an Alert was identified as a weakness (50-498/9325-03; 50-499/9325-03).
In addition to the classification weakness identified above, the inspectors
noted that for some conditions, the bases for emergency classifications were
inconsistent among the crews given the same plant conditions and indications.
One example involved an operations error observed when one crew entered into
an. incorrect emergency procedure. After this crew was unable to trip the
reactor with the manual trip switches, the next step in the reactor trip
procedure was to open the feeder breakers in the control room. This was
accomplished and caused the rods to drop, resulting in shutdown of the
reactor. Instead of remaining in Procedure E0, the Unit Supervisor entered
the functional Recovery Procedure FRS1, " Anticipated Transient Without Scram
(ATWS)." Although the eventual end point of the procedure was the same as the
reactor trip Procedure, it required more time to reach the transition, thus
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delaying event mitigation. Entry into FRS1 required declaration of a Site
Area Emergency by procedure. Accordingly, this classification was made by the
crew although plant conditions did not support classification for reasons of
l entering FRSI. This observation was considered an isolated operations error
with no generic implications in the emergency preparedness training area.
The inspectors observed and evaluated the ability of each crew to make
accurate and timely notifications to offsite authorities. The three crews
transmitted information in a timely manner. During the annual exercise
conducted in June 1993, Exercise Weakness 50-498/9317-05; 50-499/9317-05 was
identified for problems associated with the issuance of complete and accurate
notification messages. The licensee's response and corrective action had not
been implemented or reviewed prior to this inspection. The following similar
problems were noted during the walkthroughs:
. One crew failed to check Item 6.C on notification Messages 3
and 3A that were issued after protective actions were recommended
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with the Site Area Emergency. This item indicated whether the j
Texas Bureau of Radiation Control was contacted or concurred in '
the protective action recommendations. l
- One crew indicated potential failed fuel breach in the Unusual l
Event message under the event description, Item 7. Despite ;
subsequent clear indications of fuel element breach, this crew :
failed to indicate such on any subsequent notification messages.
The inspectors evaluated the ability of the crews to perform dose assessments !
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from the control room utilizing shift health physics personnel who had been
trained to perform emergency dose assessment functions. None of the 3 crews
evaluated were able to calculate dose projections in an accurate and timelv !
manner based on plant data. The following observations were made with respect i
to the crews dose assessment capabilities: '
Crew 1: j
Prior to the end of the scenario, no dose assessments were attempted during a ;
period of 20 minutes following the crew's awareness of a radiological release ;
and 26 minutes after the General Emergency classification. The health physics i
technician was observed to refer to various sections of the Dose Assessment !
, Procedure OEP,P01-ZV-TP01 but never derived a source term even though l
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sufficient plant data was given to do so. In addition, no attempt was made to
calculate computer generated dose projections based on default values. ;
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Incorrect assumptions and data were input to the computer dose assessment !
. program. Specifically, the incorrect release assumptions were selected from j
- Item 7 of Procedure OERP01-ZV-TP01, addendum 4. The release selected was for i
coolant leakage, (i.e., steam generator tube rupture) versus containment ;
leakage. This crew also entered a default windspeed of 4.5 mph instead of i
using the actual scenario meteorological conditions of 0.5 mph. i
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Crew 3:
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Errors were made in using the source term estimator in :
Procedure OERP01-ZV-TP01, Addendum 5. The containment pressure value of 0.1 j
psi was entered on the nomogram instead rf the required value for containment ;
pressure differential. In addition, the windspeed valuk was entered as the
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wind direction into the dose projection program. This resulted in the
effected sectors being incorrect in cardinal direction by 170 degrees.
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Failure of the crews to calculate dose projections in an accurate and timely i
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manner was identif.ied as a weakness (50-498/9325-04; 50-499/9325-04). l
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The inspectors noted that-none of the crews evaluated performed a site
evacuation of nonessential personnel following the Site Area Emergency as
required by Procedure OERP01-ZV-SH01, " Site Area Emergency Checklist, Step 11.
This observation was not considered a weakness only because the short period
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of time between the Site Area Emergency and the General Emergency may not have ,
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allowed reasonable time to reach the site evacuation procedural step before '
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the scenarios were terminated. The inspectors discussed as a potential area
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for improvement, a review of the timeliness of implementing a site evacuation
. during a fast breaking severe accident sequence. .
5.2 Conclusion
Initial emergency preparedness training had been conducted as required. A
4 violation was identified for failure to follow the requalification training ;
requirements identified in the Emergency Plan. Drills and exarcises were !
i conducted as required. The distribution of drill training opportunities was j
not equit able, and followup on drill findings was not well documented or ,
tracked. An Unresolved Item was identified pending a determination of whether
the licensee has corrected past weaknesses in day shift emergency
' accountability. Two weaknesses were identified during walkthroughs with ,
operating crews, one for failure to properly classify conditions corresponding
to an Alert, and the second for failure of all crews evaluated to calculate ,
dose projections in an accurate and timely manner. l
6 INDEPENDENT AND INTERNAL REVIEWS AND AUDITS (82701-02.05)
The inspectors met with quality assurance personnel and reviewed independent ;
and internal audits of the emergency preparedness program performed since the
last inspection to determine compliance with the requirements of
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6.1 Discussion
The nuclear assurance organization reported to the Group Vice President and
. was found to be independent from those responsible for managing the emergency ;
preparedness program. Documentation of the qualifications of audit personnel !
involved in the audits of emergency preparedness was reviewed. Audit team i
" leaders and team members had met the qualifications specified in l
Procedure QAP-2.1," Training, Qualification and Certification of Audit
Personnel." The audit team leader for the last annual audit of emergency
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preparedness had been qualified to the standards of ANSI /ASME N45.2.23 - 1978
The last audit of emergency preparedness conducted pursuant to 10 CFR 50.54(t) ;
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was performed during the period June 21 through July 2,1993. The audit team
consisted of four members and one technical specialist from another licensed !
facility. The inspector met with the acting audit team leader for the 1993 i
audit. The planning and preparation for the audit was thorough and was found i
to meet the guidance of Procedure QAP-2.8, " Plant and Vendor Audits." !
The 1993 audit identified 6 deficiencies (Station Problem Reports), 5 l
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concerns, and 14 recommendations. The inspector found the audit findings and
documentation to be excellent. The audit scope met the requirements of 10 CFR
50.54(t), and findings were properly characterized and tracked to completion l
of corrective action. Among the audit findings were the noncited violation i
referenced in Section 2.1 of this report. Another example of an excellent
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1 audit finding was the deficiency related to inadequate documentation and
followup on corrective actions to drill and exercise findings. Audit findings
requiring corrective action had typically been reviewed and signed off by the ,
lead auditor after confirming completion of the corrective action.
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The inspector reviewed copies of surveillance reports conducted in the
2 emergency preparedness area. These surveillances had been conducted according
to Procedure QAP-2.9, " Plant and vendor Surveillance." The inspector found ,
e the scope of the surveillances to be appropriate for the targeted areas of l
interest. The findings and documentation of the surveillances were I
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substantive. ,
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In addition to the routine audits of emergency preparedness, the licensee l
requested a program review by the Institute of Nuclear Power Operations.
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Quality assurance audits and surveillances of the emergency preparedness area !
met the requirements of 10 CFR 50.54(t) and had been conducted in an excellent ;
manner. i
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7 FOLLOWUP ON PREVIOUS INSPECTION FINDINGS (92702)
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. 7.1 (Closed) Unresolved Item (498/92-10-01: 499/9210-01): Lack of Sufficient !
) Information to Establish Whether the Licensee Could Meet the ERO Staff I
. Augmentation Timeliness Specified in the Emergency Plan. l
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By letter dated May 20, 1993, NRC approved a revision to the licensee's ;
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emergency plan which increased by 15 minutes the amount of time allowed for l
specified emergency response positions to report to the site to augment the ;
onshift emergency response organization. The inspector reviewed the results .
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of recent staff augmentation callout drills focussing on those conducted since 1
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the May 20, 1993 plan change. Only three actual drive-out drills had been
performed since December 1992; however, these drills were not evaluated for
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response time. Six augmentation drills had been evaluated for response
timeliness since the emergency plan change. The drills included a
, notification of the entire on-duty emergency response organization by either ;
- pager activation or manual telephone callout. Responders called in with their
estimated times to respond. In these drills, there were isolated cases where !
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designated responders would have been unable to respond within the timeliness ,
- criteria. For these individuals, however, the estimated response times would I
' have exceeded the criteria by only minutes. Except for these isolated cases, !
i the required initial staff augmentation response times were met. Based on the !
results of the drills, the inspector concluded that the licensee's initial !
staff augmentation time criteria could be met. j
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7.2 (Closed) Emergency Preparedness Weakness (498/9222-01: 499/9222-01):
This Weakness was identified During Walkthrough Evaluations with
Operating Crews and Consisted of Two Parts. The First Part Related to
Difficulties in Properly Classifyina Emergencies. The Second Part
involved Difficulties in Properly Making Notifications to NRC and Using
Communications Equipment.
During walkth-oughs conducted in this inspection, the problems associated with
i NRC notification and the use of communications equipment was demonstrated to
be corrected. A classification problem was again identified during the
walkthroughs conducted during this inspection (Section 5.1.2). The
classification part of this weakness will be tracked with the new weakness
identified.
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ATTACHMENT 1
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1 PERSONS CONTACTED !
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1.1 Licensee Personnel ;
- L. S. Barton, Supervisory Emergency Planning Specialist
- M. K. Chakravorty, Executive Director, Nuclear Safety Review Board
- K. J. Christian, Manager, Plant Operations !
- M. A. Coughlin, Senior Licensing Engineer
+M. A. Covell, Manager, Emergency Response l
T. Cloninger, Vice President, Nuclear Engineering ;
- K. Doss, Emergency Preparedness Specialist
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- W. M. Dowdy, Manager, Unit 2 Operations ,
- R. J. Graham, Supervisor, Licensed Operator Training !
- J. F. Groth, Vice President, Nuclear Generation '
- A, W. Harrison, Supervisory Licensing Engineer ;
S. Head, Deputy General Manager, Licensing :
- K. S. Kennedy, Emergency Planning Specialist !
- W. H. Kinsey, Vice President, Plant Support !
- B. A. Kruse, Senior Quality Assurance Specialist ,
- M. A. Ludwig, Manager, Training
- L. E. Martin, General Manager, Nuclear Assurance ;
R. T. Mayberry, Senior Staff Consultant, Emergency Planning >
- F. J. Puleo, Emergency Planning Specialist l
- C. G. Walker, Manager, Public Information ;
- L. G. Wledon, Manager, Operations Training l
1.2 NRC Personnel
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- D. Loveless, Senior Resident Inspector !
D. Garcia, Reactor Engineer :
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- Denotes those present at the exit meeting
2 EXIT MEETING
The inspectors met with the licensee representatives indicated in Section 1 of i
this Attachment on August 6, 1993. The lead inspector summarized the scope.
and findings of the inspection as presented in this report. The licensee did :
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not identify as proprietary any of the materials provided to, or reviewed by, t
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the inspection team during the inspection.
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l ATTACHMENT 2 ,
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OPERATOR WALKTHROUGH SCENARIO SUMMARY
! Summary:
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The scenario creates a sustained and total loss of Essential Cooling Water
(ECW), which leads to equipment and reactor coolant pump (RCP) seal failures. i
The cause of the ECW loss will be sabotage by an offsite organization. Events
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will involve actual or imminent core degradation and a breach of containment '
, leading to General Emergency conditions with an unmonitored radiological f
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release. ,
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Initial Conditions:
The unit is operating at 100% power, at 6000 MWD /MTU. Fuel pin failures have
I been detected in the new fuel elements that were installed in the latest
refueling outage. Dose Equivalent 1-131 (DEI) is presently 0>5 uti/g. Gross ;
activity is 25 uCi/g (E-bar = 0.6). Chemistry is taking another sample. Its
4 a.m.
j Sequence of Events: i
Security reports that two unauthorized divers were recovered from the <
essential cooling pond near the intake structure. The divers were wearing
- rebreather gear. Security suspects that they were attempting to enter the ;
- facility. Security is investigating the possibility of declaring a Security !
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Alert. !
Chemistry reports that DEI has increased to 450 uCi/g att 200 uCi/g gross
- activity. This represents an Alert based on loss of fuel clad. ,
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Water level decreases in all three ECW bays. Discharge pressure decreases on
j all three ECW pumps. The ECW pumps lose seal cooling and either trip on
] overload or are manually tripped. This causes Component Cooling Water (CCW)
temperatures to increase and the essential chillers to trip. The Shift
Supervisor / Emergency Director may declare a Site Area Emergency based on ECW
pond level less than 25 feet since it appears that the intake bays are
blocked.
As CCW temperature increases, all of the components cooled by CCW will exhibit
problems. Centrifugal Charging Pump (CCP) 1A eventually trips on loss of .
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! cooling to the aux lo cooler. The positive displacement pump fails about 10
4 minutes later. The CCW pumps will eventually seize up if they are not
tripped.
Thermal barrier return temperatures on all four RCPs will increase due to '
elevated seal injection temperature until the thermal barrier return valves
automatically isolate. The plant computer system alarm annunciates, and
Proteus computer points will show that the RCPs should be tripped due to i
excessive bearing temperatures. At this point, the reactor should be manually :
tripped and then the RCPs tripped. However, the trip breakers fail to open, l
and the rod drive MG sets have to be secured to insert control rods. This '
- precipitates additional fuel failures and stuck rods on the trip.
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After the RCPs have been secured for about 15 minutes, the No. I seals on all I
pumps start to fail due to the absence of adequate thermal barrier cooling.
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len minutes later, the No. 2 seals start to fail, and reactor coolant escapes
into the containment (Site Area Emergency Emergency Action Level based on loss l
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of two fission product barriers).
Security reports that the north perimeter fence appears to have been breached
by unknown assailants. Several minutes later, MCB Alarm SM02-D8 annunciates,
auxiliary airlock trouble, and containment pressure is reported as decreasing i
rapidly as radioactive steam escapes from the containment through a forced ;
open auxiliary airlock. The Supervisor / Emergency Director should declare a
General Emergency based en status of fission product barriers.
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