ML20127K389
| ML20127K389 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/20/1993 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| NUDOCS 9301260112 | |
| Download: ML20127K389 (4) | |
See also: IR 05000445/1992046
Text
l
'
,
,
>G 8 t Cg
UNif f D STATES
4
y.
?.,
NUCLEAR REGULATORY COMMISSION
,--
) /3,
NEGION IV
,
o,
[
611 RY AN PL AZA DHIVE, SulTE 400
<,
?>
AH LING TON, T E XAS 76011 8064
'
- * " *
JAN 2 0199's
Dockets:
50-445
50-446
License:
4
Construction Permit:
CPPR-127
TV Electric
ATTN:
W. J. Cahill, Jr., Group Vice President
Nuclear Engineering and Operations
'
Skyway Tower
400 North Olive Street, L,B. 81
Dallas, Texas 75201
SUBJECT:
RESPONSE TO EXERCISE WEAKNESSES IDENTiflED IN NRC INSPECTION REPORT
50-445/92-46; 50-446/92-46
Thank you for your letter dated January 8,1993, in response to the emergency
exercise weaknesses identified in NRC Inspection Report 50-445/92-46;
50-446/92-46 dated December 7, 1992. We have examined your reply and find it
responsive to the concerns raised in our inspection report.
We will. review
the implementation of your corrective actions during a future inspection.
Should you have any questions concerning this letter, please contact
Dr. D. Blair Spitzberg of my staff at (817) 860-8191.
Sincerely,
'
(.-
L.
. Callan, Director
Div
on of Radiation Safety
and Safeguards
cc:
TV Electric
ATTN:
Roger D. Walker, Manager of
Regulatory Affairs for Nuclear
Engineering Organization
Skyway Tower
400 North Olive Street, L.B. 81
Dallas, Texas 75201
9301260112 930120
ADOCK 05000445
G
p
-
_
__
_
.
_ -
.
.
- .
--'f
TV Electric
-2-
Juanita Ellis
President - CASE
1426 South Polk Street
Dallas, Texas 75224
,
GDS Associates, Inc.
Suite 720
1850 Parkway Place
Marietta, Georgia 30067-8237
10 Electric
Bethesda Licensing
3 Metro Center, Suite 610
Bethesda, Maryland 20814
Jorden, Schulte, and Burchette
ATTN: William A. Burchette, Esq.
Counsel for Tex-La Electric
Cooperative of Texas
-1025 Thomas Jefferson St., N.W.
Washington, D.C.
20007
Newman & Holtzinger, P.C.
ATTN: Jack R. Newman, Esq.
'
1615 L. Street, N.W.
Suite 1000
Washington, D.C.
20036
Texas Department of Licensing & Regulation
ATTN:
G. R. Bynog, Program Manager /
Chief Inspector
Boiler Division
P.O. Box 12157, Capitol Station
Austin, Texas- 78711
Honorable Dalt McPherson
County Judge
P.O. Box 851
Glen Rose, Texas 76043
Texas Radiation-Control Program Director
1100 West 49th Street
<
Owen L.-Thero, President
Quality Technology Company
Lakeview Mobile Home Park, Lot 35
L
4793 E. Loop 820 South
l
Fort Worth, Texas 76119
L
L
i
!
L-
'
.
.- -
-
-
.-.
.
.
TU Electric ~
-4-
bcc to DMB (IE35)
bec w/ copy of letter dated January 8,1993:
'J. L. Milhoan
B. Murray, DRSS/FIPS
0. B. Spitzberg, FIPF
Section Chief, DR6/B
Project Engineer, DRP/B
Section Chief, DRI/TSS
Comanche Peak, R eident Inspector (2)
HIS System
DRSS/FIPS File
RIV File
Lisa Shea, RM/ALF, (MS MNBB 4503)
T. Bergman, NRR Project Manager (MS 13 H15)
B. Holian, NRR Project Manager (MS 13 H15)
C. A. Hackney, RSLO
G. F. Sanborn, EO
J. Lieberman, OE (MS 7 H5)
'
RIV:FIPS
C:FIPS
O
D:DaSn_
DBSpitzberg:(h
BMurray
pll/JCallan
,
\\gik/93
\\F1/93
/\\b93
/
~
..
.,-
TV Eleccric
-4-
[bcc30,LDMBi(IE35)17
bec w/ copy of letter dated- January 8 1993:
J. L. Milhoan
B. Murray, DRSS/FIPS
0. B. Spitzberg, FIPS
Section Chief, DRP/B
Project Engineer, DRP/B
Section Chief, DRP/TSS
Comanche Peak, Resident Inspector (2)
MIS System
DRSS/FIPS File
RIV File
Lisa Shea, PN/ALF, (MS MNBB 4503)
T. Bergman, NRR Project Manager (MS 13 H15)
B. Holian, NRR Project Manager (MS 13 HIS)
C. A. Hackney, RSLO
G. F. Sanborn, E0
J. Lieberman, OE (MS 7 H5)
.
,
e
l
r
'
-
RIV:FIPS
-
C:FIPS
O
o:oRSet
QI
W'
DBSpitzberg:hh
BMurray
Ml/JCallan
\\ d/93
\\ M /93
\\ /\\h93
/
'
r
6
I'
250063
i
L
u
l
-.
- -
a
.
- .
,t
.
,
'.
%
1
7
h
0 I $ k-
Log
= = = = = = = =
k
l
EE
' File #
10130 (IR 92 46)
y
J
.
'
10013 clo
i
M-
g g
--- -
d
E
3
Ref.
.
.,
TUELECTRIC
- y gy
January 8, 1993
% llhm J. Cahul. Jr.
Geong L re bcentest
U. S. Nuclear Regulatory Commission
Attn:
Document Control Desk
Washington, DC 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446
RESPONSE TO NRC INSPECTION REPORT NO. 50-445/92-46
AND 50-446/92-46
Gentlemen:
TV Electric has reviewed the NRC's letter dated December 7
1992, concerning
the inspection conducted by the NRC staff during the period November 16-20,
1992.
This inspection covered activities autnorized.by NRC Facility
Operating License NPF-87 and Construction Permit CPPR-127 for CPSES Unit 1
and 2, respectively.
The inspection report identified three exercise
weaknesses in the emergency preparedness program.
The TV Electric responses to these findings are provided in the attachment
to this letter.
Sincerely,
William J Cahill, Jr,
By:
d
D. R. Woodlan
Docket Licensing Manager
i
- CLW/tg
Attachment
c
Mr. J. L. Hilhoan, Region IV
Hr.-Blaine Murrary.' Region IV
Mr. T. A. Bergman-, NRR
Mr. B,
E. Holian, NRP
Resident Inspectors. CPSES I2)
,
i
'-f #
~
~
.
400 N. Olive Street Lil 81 DaNs. Texas 7520i
!
!
.
.- - -.- .. _ .
.-
- -
-
- -
-
.
- - .
- . - -
<
.
.
y
4
Attachment to TXX 93012
Page 1 of 5
NRC Evercise Weakness 445/9246-01: 446/9246 01:
The inspectors noted unnecessary delays associated with the detection and
classification of the initiating conditions for two of the three emergency
,
classifications made during the exercise as follows:
4
o
in the control room, the Emergency Coordinator failed to implement
'
correctly Procedure EPP-201, ' Assessment of Emergency Action levels,
Emergency Classification and Plan Activation,' Chart _11, " Fire."
This
!
chart indicated that a fire inside the protected area lasting greater _
than 10 minutes for which safety systems were potentially affected by
the fire would result in an Alert classification.
The-Emergency
.
Coordinator failed to declare an Alert 10 minutes after the Diesel
l-
Generator 1-01 Day Tank Room fire alarm was received in the :ontrol
room.
instead, the declaration was made 10 minutes after the existence
of the fire was confirmed by an auxiliary operator dispatched to the
scene.
Tnis resulted in a 5-minute delay in the Alert classification,
Through player interviews, the inspectors determined that the Emergency
,
Coordinator began the 10-minute countdown at the time when the fire was
confirmed by the auxiliary operator.
The operator confirmation took 6
minutes from the receipt of the alarm.
During this 6 minutes, the fire
potentially affected safety systems.
Under the conditions of this
>
scenario, following the operator's confirmation of the fire, the Alert
classification conditions were met 10 minutes after-the receipt of the
fire alarm.
o
in the Technical Support Center, declaration of the Site Area Emergency
following the major steam generator tube rupture and main steam line
break was not made promptly following reports of these conditions.
At
4: 28
a.m., the Technical Support Center staff became aware that the
steam generator tube rupture had significantly increased concurrent-with
reports of an unisolable steam line break outside of. containment on the-
affected steam line.
According to the licensee's classification scheme
contained in Procedure EPP-201, " Assessment of-Emergency Actions levels,
Emergency Classification and Plan. Activation," Chart 4, these conditionsL
correspond to a Site Area Emergency.
The declaration of the-Site Area
Emergency was not made by the Technical Support Center until 4:49 am, or
21 minutes following Technical Support Center staff awareness of;these
conditions.
The inspectors noted that a briefing was being~ started at-
4:30 am in the Technical Support Center as information of the main steam
line break was received.
Rather than take action on this event, the
managers took_another 5 to 10 minutes to complete the briefing.
The
-
control room finally prompted _the Technical Support Center concerning
the need to upgradento' Site Area Emergency at'about 4:47 am.
4
1
__y
__, , , , , . ,
_
_
, . . . . . ,
,_
- .
- - - - - - - - -
.- - -.-- -
. -
.
. -
~..
.
4
.
.
Attachment to TXX 93012
Page 2 of 5
10 Electric Desconse
Upon review of the actions taken by the Emergency Coordinator to classify
the Alert it was determined that the six minute delay was caused by starting
the 10-minute countdown at the confirmation of the fire rather than at the
initiating event of receiving the alarm in the Control Room.
The delay in classifying the Site Area Emergency was attributed to the three
contributing factors:
1)
Personnel in the TSC who evaluate plant conditions relative to emergency
dCtion levels were not adequately anticipating what possible events
could cause escalation of emergency classification.
Consequently, whe'
the report was received in the TSC that an unisolable steam line break
had occurred, no one in the TSC was aware that the break would cause
escalation to Site Area Emergency.
,
2)
The TSC Hanager/ Emergency Coordinator wanted to verify the report of the-
steam line break prior to taking any action with the information.
3)
The TSC Manager / Emergency Coordinator had been in the TSC for only a
short period of time and elected to continue a briefing rather than
evaluate the new information while awaiting verification of this new
information.
To address the Alert classification delay, remedial training has been given
to the individual who was acting as the Emergency Coordinator and declared
the Alert.
A random sampling of other licensed Senior Reactor Operators
verified that the training in
th'- area was adequate since they all
_
responded with correct answers
o. to what to do in this scenario.
Therefore, this classification delay was determined'to be an isolated case
and is not believed to be a generic concern.
However.:this delay will be
covered in current events during 1993 annual requalification-training for
Accident Classification.
To address the Site Area Emergency classification delay, all Emergency
4
Coordinators for the TSC and E0F shall receive training to address the
weakness identified above.
completed by May 1. 1993.
This corrective action is scheduled to be
NRC Exercise Weakness 445/9246-02: 446/9246-02:
Following the declaration of the Site Area Emergency at 4:49 am, the
notifications to offsite authorities of the classification were not.
,
completed until 25 minutes later at.5:14 am.
According to 10CFR50, Appendix
E.IV.D.3 and EPP 203. * Notifications." Section 4.1.2.2, notifications are to
be made within 15 minutes after declaring the emergency.
The licensee's
failure to make prompt offsite notifications of the Site Area Emergency was
identified as an exercise weakness.
.
.
~ . -
.
.
. -
1
)
.
- Attachment to TXX 93012
1
-Page 3 of_5
'
TO Electric ResDonse
'
Upon review of the player logs and interviews with key players the following
is'a reconstructed time line of events:
'
0442
TSC Manager aware of release in progress.
0445
TSC Communicator updated offsite authorities verbally of release
and would provide followup information-shortly.
0450
Site Area Emergency declared.
0505
Notification Message Form #5 completed and approved.
0505
TSC Communicator commenced notifying offsite authorities verbally
of Site Area Emergency.
0515
TSC Communicator transmitted Notification Message _ Form #5 to
offsite authorities.
-
Based on this time line the completion of the Notification Hessage Form took;
up the entire 15 minutes allowed for offsite notification.
l
To address this weakness the. Notification Message Form will~be discussed-
with the State and local governments to determine.if the; form can be
simplified to reduce ~ completion time.
This corrective action is scheduled-
to be completed by June 1, 1993.
The Emergency _ Coordinators in the TSC and EOF shall _ receive instruction _ on
the importance of obtaining and providing the information needed for this
form to effect notification within the time limit.
This corrective action
is scheduled to be completed by May 1. 1993.
NoC Exercise Weakness 445/9246-03: 446/9246;03:
The inspection team made the following observations wh'ich, in the aggregate,
indicated that overall command and control during the exercise was weak:
o
The transf er of Emergency Coordinator duties f rom the control room shif t-
supervisor to the manager in-the Technical-Support: Center was
inef ficient and confusing-and appeared to leave a vacuum of command -
authority for a period of time.
The Alert was declared at 3:19'a.m.
By 3:36:a,m. -~there were=about four
people in the Technical-Support Center but_with no particular; individual
in charge.
At about 3:42, the Emergency Coordinator's. checklist logs-
indicated that the individual _who would eventually become the_ Emergency 1
Coordinator -in the Technical Support Center had Lrelieved =the. control
room shif t supervisor of the Emergency Coordinator's duties -(5diile -in-
the simulator).
By about 4 aim..-one individual in the Technical
l'
Support Center had taken charge-of1 personnel there but didLnot claim the
title of Emergency Coordinator.
The Emergency Coordinator arrived in-
the Technical Support Center f rom the simulator at about 4:28 a.m. but-
did not announce that he was the Emergency Coordinator.
Status boards:
l
in the' Technical Support Center continued ~to show that the control 1 room
had command and control.
The Technical Support Center Emergency-
Coordinator log showed.that the same individual who had assumed =
,
, . . .
. - - -
. --
- . .
, . .
. - . .
-
-.
-
.
- .--
a
i
. - -
Txx-93012
Page 4 of 5
Emergency Coordinator duties in the simulator again assumed these duties
in-the Technical-Support Center at 4:50 a.m.
Because of the distance
between the Technical Support Center _and the simulator, this exercise
included an artificially-long period of time (about 10 minutes) to
transit between the two facilities.
Even giving consideratiJn'to the
artificiality, it was unclear who was the Emergency Coordinator during
the 4:30 to 4: 50 a.m. timeframe.
o
in the Operational Support Center, the licensee failed to maintain
adequate controls over teams dispatched in response to emergency
conditions,
Between 4 and 6:07 a.m., 16 teams were dispatched from the
Operational Support Center.
No Emergency Work Permits were completed
for 10 of these teams as required by Procedure EPP 116.
- Emergency
Repair & Damage Control ano immediate Entries *, step 4.2.2.
Some of-
these teams were recorded on the Operational Support Cer.ter Team Status
board and in various logs but no consistent central record was
maintained of these teams. ' In addition, as noted in Section 4.1, early
in the exercise it appeared that no individual in the Operational
Support Center was clearly responsible for the control of assigning and
dispatching repair teams.
o
in the Emergency Operations' Facility, control of the offsite monitoring
teams and utilization of the information developed from them was
inadequate.
Neither the results of the 5:39 a.m.. plume traverse nor the
later measurements reported to the Emergency Operations Facility'about'6
a.m. that produced above background readings were recorded on the
offsite monitoring status board or reported to the Emergency Operations
Facility decision makers.
At the termination of the exercise, the
Radiation Protection Coordinator and the Emergency Coordinator were
unaware of the results of the monitoring team traverse of the plume 3
,
miles downwind from the plant some 25 minutes before.
For an-
undetermined period of time around 5:53'a.m., the monitoring team
communicator's station was abandoned leaving no apparent radio
communication or centralized control over_the. deployed teams during this
.
time period.
o
Staffing of the Emergency Response Facilities was at times-disorganized, -
as 'sometimes several qualified individuals' shared _ (or attempted to fill)
,
the same position.
The f acility maaagersfwere not forceful in directing
the excess staff to be released for other duties.
There appeared to be
no standard practice or procedure for staffing the initial response
organization and recording, reassigning or releasing the other personnel
who responded.
While three different qualified individuals-were signed
in for, and took part in carrying out the duties of the Emergency
Operations Facility Radiation Protection Coordinator position, the
,
Technical Support Center dose projection capability was suffering for a
lack of experienced personnel.
TU Elect ric Resoonse
The transfer of the Emergency Coordinator duties from the Control -Room to
the Technical Support Center led to an_ exercise weakness.
The Comanche Peak-
practice in this area has been for a TSC Manager to report to the Control.
Room and relieve the Shift Supervisor of. Emergency Coordinator duties so the
Shift Supervisor can concentrate on plant conditions.
Once
~
. .
_.
,_.
-_
__
.
.
.
,
,
,
. . .
.
.
, ,
. . .
.
- - - - - _ _
- _-__
_ _ _ _ _ _ - _ - _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .
_ _ _
.
.
.
I
v
1 x x 'H012
fdQe 5 oI b
the TSC is staffed, the TSC Manager / Emergency locrdinator relocates f rom the
r ntrol Rxm t o t he TSC and c ont inues Emergency Coordinator duties from the
ISC.
Thi: practice has worbed very well in the past and has proven to be
ver y effettive
In the Operations Support Center (OSC) no single individual was clearly in
inntrni nf a *,s i gni ng and di spat ching t eams .
Procedure EPP-205, 'Activat ion
and Operation of the Operations Support Center' assigns the responsibility
of dispat ching t eams to the 05C Manager, whereas procedure EPP-ll6,
' Emergency Repair and Damage Control and immediate Entries,' assigns the
retponsibility of dispatching teams to the 05C Manager, '" C Maintenance / ERDC
,
Supervisor. and OSC Radiation trotection Supervisor.
In the Emer gency Operat ions f acility, there was a lack of Control of the
offsite monitoring teams and use of the information provided by the offsite
team.
This was attributed to the inexperience of specific individuals
filling certain emergen<y 3rganization positions in the Emergency Operations
'
Facility radiological a sessment team.
The last item deals with staffing the Emergency Response facilities.
During
the enerciso it was observed that some emergency organization positions were
filimi by several individuals while other positions had a lack of personnel.
Currently, there are no written guidelines for the initial staffing of the
omargenty organ'
tion.
The following corrective actions are scheduled to be completed by
April
1.
1993,
n
The practice of the TSC Manager relieving the Shift Supervisor in the
Control Room and then moving to the T5C will be evaluated to determine
if this is still the best method of handling this transition,
o
T
address the issue of control of and dispatching teams in the 050,
procedures EPP ll6 and EPP-205 will be evaluated to determine and
provide better instructions and directions for team dispatch,
o
in the LOF, drills will be conducted to raise the experience level of
the Of f site Monitoring Team Coinmunicators and Of f site Monitoring Team
Directors.
o
Guidelines for initial staffing of the emergency facilities will be
re-emphasized to the Emergency Response Organization which outlines
management expectations.
The emergency planning training program will
be updated to provide this inf ormation in the Emergency Response
Organizotion.
_ _ _
__
_
___
_
_
_