ML20198P779
| ML20198P779 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/16/1998 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| 50-445-97-16, 50-446-97-16, NUDOCS 9801220247 | |
| Download: ML20198P779 (4) | |
See also: IR 05000445/1997016
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NUCLEAR REGULATORY COMMISSION
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AnuNotoN. tixas noit sose
January .
'98
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Mr. C. L Terry
TU Electric
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Group Vice President, Nuclear
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ATTN: Regulatory Affairs Department
P.O. Box 1002
,
Glen Rose, Texas 76043
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SUBJECT: NRC INSPECTION REPORT 50 445/07 16;50 446//97 16
Dear Mr. Terry:
Thank you for your letter of September 15,1997, in response to the exercise
weakness identified in NRC Inspection Report 50 445/9716; 50 446/9716, dated
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August 13,1997. We have reviewed your reply and find it responsive to the concerns
raised in our inspection report. We will review the implementation of your corrective
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actions during a future inspection.
Sincerely,
i
.
Blaine Murray, Chief
Plant Support Branch
Division of Reactor Safety
Docket Nos.: 50-445;50-446
License Nos.: NPF-87; NPF 89
cc:
- Mr. Roger D. Waiker
TU Electric -
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Regulatory Affairs Manager
P.O. Box 1002
Glen Rose, Texas 76043
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TU Electric
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Juanks Ellis
President CASE
1426 South Polk Street
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Dallas, Texas 75224
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TU Electric
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Bethesda Licensing -
3 Metro Center, Suite 610
Bethesda, Maryland 20814
George L. Edgar Esq.
1800 M. Street, NW
Washington, D.C. 20036
G. R. Bynog, Program Manager /
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Chief Inspector
Texas Department of Licensing & Regulation
Boiler Division
P.O. Box 12157, Capitol Station
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Honorable Dale McPherson
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County Judge
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P.O. Box 851
Glen Rose, Texas 76043
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Texas Radiation Control Program Director
1100 West 49th Street
John Howard, Director
Environmental and Natural Resources Policy
. Office of the Governor
P.O. Box 12428
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DISTRIBUTION w/ cony of hcensee's letter dated September 15.1997:
DCD (IE35)
. Regional Administrator
CP Resident inspector (2)
DRS Director
DRS Deputy Director
DRP Director
DRS-PSB
Branch Chief (DRP/A)
Project Engineer (DRP/A)
Branch Chief (DRP/TSS)
MIS System -
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DRS Action item File (98 G-0002)
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DOCUMENT NAME: . Gi\\ REPORTS \\CP716AK.GMG
Al 98-G-0002
To esceive copy of stocument,Inallcate in boa:"C" Copy without encivaures *E" a Copy with enclosures *N" = No copy
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OFFICIAL RECORD COPY--
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DISTRIBUTION w/cany of licensee's letter dated Sootember 15.1997:
000 M86) aw.x,
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Regional Administrstor -
CP Resident inspector (2)
DRS Director
DRS Deputy Director
DRP Director
DRS PSB
Branch Chief (DRP/A)
Project Engineer (DRP/A)
Branch Chief (DRP/TSS)
MIS System -
RIV File
DRS Action item File (98-G-0002)
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DOCUMENT NAME: G:\\ REPORTS \\CP716AK.GMG
Al 98-G-0002
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To receive copy of document, Indicate in boa:"C" e copy wdhout enclosures "Ea e Copy wth enclosures " Nae No copy
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OFFICIAL RECORD COPY -
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Log # TXX 97185
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File # 10130
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IR 97 16
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Ref. # 10CFR2.201
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ItIELECTRIC*
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September 15, 1997
omwe raa,we
U. S. Nuclear Regulatory Commission
Attn: Document Control Desk
Washington, DC 20555
SUBJECT: COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET N05. 50 445 AND 50 446
NRC INSPECTION REPORT NOS. 50 445/97 16 AND 50 446/97 16
RESPONSE TO EXERCISE WEAKNESS
Gentlemen:
TU Electric has reviewed the NRC's letter dated August 13, 1997,
concerning the inspection conducted by Gail Good, Thomas Andrews, Michael
Hay and Rebecca Neese during the period of July 22 25, 1997.
The attached
inspection report identified an Exercise Weakness.
TU Electric hereby responds to the Exercise Weakness in the attachment to
this letter.
Additionally, TU Electric is evaluating and will implement as applicable
corrective actions to address the improvement items discussed in the
inspection report.
Sincerely,
d. S. Q
C. L. Terry
By:
e@r A'
Rogtf D. Walker
Regulatory Affairs Manager
CLW/grp
Attachment
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E. W. Herschoff, Region IV
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J. I. Ta ia, Region IV
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T. J. Po ich, NRR
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Reside ~nt Inspectors, CPSES
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P. O. Don 10'U Olen Roe Texas 7st)
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Attachment to TXX 97185
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RESPONSE TO EXERCISE WEAKNESS
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RESTATEMENT OF THE EXERCISE WEAKNESS
(445:446/9716 02)
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Radiation protection coverage was not sufficient for those teams performing
tasks outside the power block.
Inspectors observed the following examples:
One emergency repair and damage control team was assigned immediate
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entry status to spray water on the radiological plume escaping from a
failed seal on the containment equipment hatch. This team was not
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dispatched with continuous radiation protection coverage as required
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by Section 3.3 of Procedure EPP 116. " Emergency Repair & Damage
Control and Immediate Entries." Revision 6.
The team, which included
the fire brigade and one craft person, arrived at the scene and began
to combat the emergency prior to radiation protection personnel fully
assessing the radiological conditions and determining proper
radiological controls and protection. Radiological conditions were
initially provided to the team st the scene.
Intermittent coverage
was provided later by a roving onsite radiological survey team.
Following indications of a radiological release to the environment.
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Team 97 08 was dispatched to perform work in the service watec intake
structure without assigned radiation protection personnel as required
by Section 4.2.1 of Procedure EPP 116. Inspectors also noted that the
team's emergency work permit did not specify the type of. radiation
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protection deemed necessary to protect the team from the simulated
radiological hazards. The radiation work permit included a section to
document the decision to provide continuous or intermittent radiation
protection coverage to dispatched teams, but the section was not
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completed.
The failure to provide sufficient radiation protection coverage for
emergency response ',eams could endanger personnel and degrade emergency
response efforts. Accordingly, the issue was identified as an exercise
weakness (50 445/9716 02: 50 446/9716 02).
RESPONSE TO WEAKNESS
(445:446/9716 02)
TU Electric agrees that radiation protection coverage was not sufficient
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for teams performing tasks outside the power block and therefore is an
exercise weakness. TV Electric's response and corrective actions for the
weakness are as follows:
1.
Reason for the Weakness:
orotection (P,P)
Both weakness examples occurred because the OSC Radiation
Supervisor believed that the onsite survey team could provide adequate
radiological coverage for the Emergency Res >onse Damage Control (ERDC)
teams dispatched outside the >ower block. T1e OSC RP Supervisor knew by
means of direct verbal. telepione and radio communications that these ERDC
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Page 2'of 4
teams were to be met outside at the scene by the onsite survey team and
briefed on area conditions. Although the OSC RP Supervisor was correct in
his assumption that radiation )rotection personnel assigned to the onsite
survey team would provide the ERDC teams with precautions and limitations
related to their job scope, he did not recognize that coverage as expected
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would not be provided since the onsite survey team would not specifically
stay with the teams the entire time they were in the field.
In the
weakness exam)1es noted above, TU Electric expected a RP technician to be a
part of each
ERDC team.
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Procedural Guidance:
Emergency Plan Procedure EPP 116 (Rev. 6), Section 3.3 Definition of
Immediate Entry states in part that "ERDC Teams given this priority
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(immediate entry) are initially provided continuous Radiation Protection
coverage": section 4,2.1 Prerequisites states that " initially, each ERDC
Team should be composed of at least two (2) individuals, one of which
should be a Radiation Protection Technician: section 4.4.8 Normal Entries-
states "while enroute to the work ~ area, the RP Technician, if cresent,
should enter all areas first, evaluating radiological conditions": section
4.5.1.3
Immediate Entries states "the OSC ERDC Supervisor (or the OSC
Hanager) should inform the OSC Radiation Protection Supervisor of the
situation so that they BAX brief and dispatch a Radiation Protection
Technician to accompany the ERDC Team". The instructions (Section 4) of
procedure EPP 116 provide flexibility tn allow for unplanned situations
such as current plant conditions, radiological conditions anticipated at
the local area of interest, number of RP technicians available, etc..
Ho, sever, the inconsistency between the definition and 1
ructions of EPP-
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116 may have contributed to the weakness.
Snecifics for Examnles:
In the first example, the OSC RP Supervisor's belief cor.cerning
radiological coverage was not consistent with the immediate entry status
assigned to this team and the definition of "immediate entry" given in
procedure EPP 116 (Rev. 6), Section 3.3, but was consistent with
instructions for immediate entries in section 4.5.1.3.
In the second example, instructions for a normal entry were applicable as
' given in EPP 116, Section 4.4. dorsal entries are authorized by the OSC
Manager after review with the OSC RP Supervisor. Requirements for. entry
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-are documented on an Emergency Work Permit (EWP). This ERDC team was
dispatched under a normal entry with radiological coverage.to be provided
by the onsite survey team. A radiological release to the environment
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occurred after the ERDC team had been dispatched into the field. At the
time that the radiological- release was initiated, it was TU Electric's
expectation that.~a RP technician be continually assigned to this team. -The
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OSC RP Supervisor's continued reliance on coverage from the onsite survey
team was inappropriate for this situation after the release occurred.
It was also determined that the term " continuous coverage" as used on block
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Page 3'of 4
intended. This was in part caused by the general use of the term
" continuous coverage" during routine and plant outage operations. During
routine and outage operations, RP personnel are normally assigned an area
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within the plant and are expected to provide radiological coverage to all
jobs within that limited work area. It is the responsibility of the
assigned RP technician to gauge the degree of interaction required with
each working job team, and to limit the work in the area to that the RP
technician feels he can adequately cover. Therefore, a given RP technician
may provide." continuous coverage" on more than one job, if the jobs are in
the same general area.
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During the exercise, the OSC RP Supervisor and onsite survey team believed
that the onsite survey team could provide adequate * continuous coverage"
for the subject ERDC teams assigned outside the power block since they were
in the vicinity and between the point of the radiological release and the
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teams being covered. While this practice may have merit, the OSC RP
Supervisor and the onsite survey team did not demonstrate a full
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appreciation of the potential for rapidly changing radiological conditions,
i.e., as around containment during this accident scenario.
The incomplete EWP described in the second example was caused by loss than
adequate review by the OSC RP Supervisor.
During the exercise there were
16 EWPs issued: two did not fully specify the RP coverage requirements to
the ERDC teams. In both of these cases RP coverage was provided, and
coverage was consistent with that believed to be adequate by the OSC RP
Supervisor. The RP Supervisor's less-than adequate review in completing the
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EWP had no affect on the adequacy of the RP coverage provided as the
coverage was directed by the OSC RP Supervisor.
2.
Corrective actions taken:
A meeting was held with RP management to discuss the responsibilities and
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ex,7ectations on use of RP personnel during an emergency. The meeting
resulted in verbal feedback being provided to the specific OSC RP
Supervisor involved and the meeting results were documented in an Emergency
Planning Bulletin dated September 11, 1997, and sent to all OSC management
personnel. The verbal feedback and bulletin reemphasized the
responsibilities and management expectations in EPP 116 and the importance
of attention to detail during all activities at CPSES.
3.
Steps-to prevent recurrence:
A task will be added to the OSC RP Supervisor's Position Assistance
Document (PAD) delineating his responsibilities for the radiological
protection of all personnel dispatched from the OSC. This task will clearly
express management expectations on the use of OSC RP personnel during an
emergency.
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Procedure EPP 116 will be enanged to provide consistency between the
definition and instructions sections.
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- Attachment to TXX.97185
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A-tabletop sessioa will- be ' conducted with all OSC Managers and RP -
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- Supervisors to emphasize information documented in the September 11. 1997..
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bulletin and to determine what other changes need to be made to the PADS to
- further incorporate these lessons.
A discussion of these preventative measures and the above mentioned
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bulletin will be added to the Annual Requalification Workbook.
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4.
'Date when corrective actions completed:
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All corrective' actions will be completed by December 31. 1997.
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